ML20005C051

Proposed Findings of Fact & Conclusions of Law on Emergency Planning & Preparedness Issues.Proposed Order & Proof of Svc Encl

ML20005C051
Person / Time
Site:	San Onofre
Issue date:	11/09/1981
From:	Casey S, Pigott D, Rogin E SAN DIEGO GAS & ELECTRIC CO., SOUTHERN CALIFORNIA EDISON CO.
To:
References
ISSUANCES-OL, NUDOCS 8111180328
Download: ML20005C051 (242)

Text

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3 CO?X 00LKETED c'it4RC 1 UNITED STATES OF AMERICA

'81 El13 P5:32 NUCLEAR REGULATORY COMMISSION BEFORE TI'E ATOMIC SAFETY AND LICENSING [B5dky^1h DRAtlCH

) In the Matter of ) Docket Nos. 50-361 OL

) 50-362 OL SOUTHERN CALIFORNIA )

h i - ; j ' /,-

EDISON COMPANY, ET A1. )

) /kV '

• V  %

(San Onofre Nuclear Generating ) [97/ '.h, , f '

S Station, Units 2 and 3). ) l4/ -;' 4,\ ,Rgo y 3

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APPLICANTS' PROPOSED FINDINGS OF FACT 9 AND CONCLUSIONS OF LAW ON s'f EMERGENCY PLANNING AND PREPAREDNESS ISSUES.

O DAVID R. PIGOTT EDWARD B. ROGIN SAMUEL B. CASEY S JOHN A. MENDEZ Of ORRICK, HERRINGTON & SUTCLIFE A Professional Corporation 600 Montgomery Street San Francisco, California 94111 Telephone: (415) 391-1122 CHARLES R. KOCHER JAMES A. BEOLETTO SOUTHERN CALIFORNIA EDISON COMPANY P. O. Box 800 2244 Walnut Grove Avenue O Rosemead, California 91770 Telephone: (213) 572-1900 Attorneys for Applicants Southern California Edison Company n-d San Diego Gas & Electric Company Dated: November 9, '961 3

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8111180328 811109 /j S I PDR ADOCK 050003g O

dS _- . 1

>CO?Y DAVID R. PIGOTT EDWARD B. ROGIN SAMUEL B. CASEY JOHN A. MENDEZ Of ORRICK, HERRINGTON & SUTCLIFFE A Professional Corporation

) 600 Montgomery Street San Francisco, California 94111 Telephone: (415) 392-1122 CHARLES R. KOCHER JAMES A. BEOLETTO

) SOUTHERN CALIFORNIA EDISON COMPANY P.O. Box 800 2244 Walnut Grove Avenue Rosemead, California 91770 Telephone: (213) 572-1900

) Attorneys for Applicants, Southern California Edison Company, San Diego Gas & Electric Company, City of Anaheim, California and City of Riverside, California

)

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of ) Docket Nos. 50-361 OL

) 50-362 OL SOUTHERN CALIFORNIA EDISON )

COMPAN'l , ET AL. ) APPLICANTS' PROPOSED

) FINDINGS OF FACT AND

) CONCLUSIONS OF LAW ON (San Onofre Nuclear )

Generating Station, ) EMERGENCY PLANNING AND Units 2 and 3) . ) PREPAREDNESS ISSUES.

)

)

)

SOUTHERN CALIFORNIA EDISON COMPANY , SAN DIEGO GT ,

& ELECTRIC COMPANY , CITY OF ANAHEIM , CALIFORNIA, and CITY OF RIVERSIDE, CALIFORNIA (" Applicants") hereby submit "Appli' ants'

)

Proposed Findings of Fact and Conclusions of Law on Emergency

)

D Planning and Preparedness Issues" pursuant to 10 C.F.R.

'i 2.754 and the stipulation on the record of September 30, 1981 between the parties (Tr. 11357-11359).

O DATED: November 9, 1981 Respectfully submitted, O DAVID R. PIGOTT EDWARD B. ROGIN SAMUEL B. CASEY JOHN A. MENDEZ Of ORRICK, HERRINGTON & SUTCLIFFE A Professional Corporation O

CHARLES R. KOCHER JAMES A. BEOLETTO SOUTHERN CALIFORNIA EDISON COMPANY O

By /s/ David R. Picott David R. Pigott q- By /s/ Edward B. Rocin Edward B. Rogin By /s/ Samuel B. Casey g Samuel B. Casey Attorneys for Applicants SOUTHF.RN CALIFORNIA EDISON COMPANY and SAN DIEGO GAS

& ELECTRIC COMPANY O

O

)

TABLE OF CONTENTS 3

APPLICANTS' PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW ON EMERGENCY PLANNING AND PREPAREDNESS ISSUES D PARAGRAPHS I. INTRODUCTION A. Preliminary Statement . . . . . . . . . . . 1-14 D B. Procedural Background . . . . . . . . . . . 15-41 II. PARTIES . . . . . . . . . . . . . . . . . . . . 42-43 III. EVIDENTIARY HEARING AND ISSUES 3 A. Intervenors' Contentions . . . . . . . . . 44 B. Order of Presentation . . . . . . . . . . . 45-46 C. Witnesses . . . . . . . . . . . . . . . . . 47 D D. Exhibits . . . . . . . . . . . . . . . . . 48 E. Status of Testimony . . . . . . . . . 49-51 IV. GENERAL FINDINGS OF FACT ON RADIOLOGICAL EMERGENCY PLANNING AND PREPAREDNESS . . . . . . 52-62 D

s. INDINGS OF FACT ON INTERVENORS' CONTENTIONS . . 63 A. CONTENTION 3 (Plume EPZ Determination)

1. Introduction . . . . . . . . . . . 64-69 9

2. Description of the Plume EPZ and the Extended EPZ (a) The Plume EPZ . . . . . . 69-72 B (b) The Extended EPZ . . . . . 73

3. The Rationales for The Generic lO-Mile EPZ Determination . . . . 74-78

4. The Basis and Technical Validity S of the Plume EPZ Determination . . . 79-90 s

i 9

l' 3

l l

r PARAGRAPHS L

3 5. The Procedure Followed by Local

! Officials in Adopting the Plume EPZ . . . . . . . . . . . . . . . . . 91-93

6. Rationale for Establishment of the Extended EPZ . . . . . . . . . . . 94-97

[)

7. Conclusions . . . . . . . . . . . . . 98 B. CONTENTION 2F (Emergency Response and Augmentation Capability)

D

1. Introduction . . . . . . . . . . . . .99-100 l 2. Identification of Principal and Supporting Response Organizations . . 101-108 0 3. Capability of Principal and Supporting Response Organizations to Initially Respond and to Augment their Response on a Continuous Basis . . . . . . . . . . . 109 1

l O (a) Southern California Edison Company . . . . . . . . . . . . . 110-120 l (b) Principal Offsite Respense Organizations . . . . . . . . . . 121-126 i

O (c) Supporting Offsite Emergency Response Organizations . . . . . 127-134

C. CONTENTION 2A (Emergency Response Organization Notification and Continuous Communication Capability)

O

1. Introduction . . . . . . . . . . . . . 135-139

2. Notification by Applicants of l State and Local Response Organizations . . . . . . . . . . . . 140-155 0

3. Procedures and Capability to Implement Notification of ,

Emergency Personnel . . . . . . . . . 157-169

4. Procedures and Capability to O Implement Continued Communication Among All Involved Organizations . . . 170-175 l

l

!O ii l

a

D PARAGRAPHS O 5. Program for Periodic Testing of Entire Emergency Communication System . . . . . . . . . . . . . . . . 176-178

6. Overall Conclusion . . . . . . . . . . 179 D D. CONTENTION 2E (Existence of Adequate Offsite Emergency Operation Centers, Transportation and Communications Equipment) 3 1. Introduction . . . . . . . . . . . . . 180-181

2. SCE Emergency Operations Centers . . . 182-184

3. SCE Communications and Trans-portation Equipment . . . . . . . . . 185-189 D '_

4. The Emergency Operations Centers of the Principal Offsite Emergency Response Organizations . . . 190-193

5. Availability of Necessary Trans-

,D portation and Communication Equipment to Principal Offsite Emergency Response Organizatons . . . 194-196 E. CONTENTION 2I (Interim Emergency Operations Facility)

D

1. Introduction . . . . . . . . . . . . . 197

2. Physical Design and Location of the , Interim EOF . . . . . . . . . . 198-201 D 3. The Interim EOF Communication System . . . . . . . . . . . . . . . . 202-206

4. Interim EOF Operating Procedures . . . 207-210 l F. COMTENTION 2H (Plume EPZ Radiation D Monitoring and Dose Assessment) l 1. Introduction . . . . . . . . . . . . . 211-212 l

2. SCE Rescurces and Capability . . . . . 213-234 O

l l

D iii t

O PARAGRAPHS O 3. Offsite Emergency Response Organization Rasources and Capabilities . . . . . . . . . . . . . 235-240 G. CONTENTION 2J (Ingestion EPZ g Radiation Monitoring and Dose Assessment)

1. Introduction . . . . . . . . . . . . . 241-243

2. Relationship of Organizations O Principally Involved in Protective Response Within the Ingestion EPZ . . 244-249

3. Inventory of Land Use Data Within the Ingestion Pathway EPZ . . . . . . . . . . . . . . . . . 250-254 0

4. Pro edures for Contamination Detection . . . . . . . . . . . . . . 255-257

5. Procedures for Estimating Dose Commitment Consequences O and Protecting the Public from Consequences of Ingestion EPZ Contamination . . . . . . . . . . . . 258-262

6. Time Available to Take Protective Actions Within the Ingestion O Pathway EPZ . . . . . . . . . . . . . 263-264 H. CONTENTION 2G (Radiological Emergency Response Training)

1. Introduction . . . . . . . . . . . . . 265-267 O

2. Scope and Content of Onsite Training . . . . . . . . . . . . . . . 268-276

3. Scope and Content of Offsite Training . . . . . . . . . . . . . . 277-286 O

I. CONTENTION 2D (Medical Services for Injured Contaminated Individuals)

1. Introduction . . . . . . . . . . . . . 287-290 O

O iv

)

PARAGRAPHS

2. The Number of Contaminated and Injured Individuals for Whom Medical Services Should Be Pre-arranged . . . . . . . . . . . . . 291-294

) 3. The Type and Location of Medical Services (Including Transportation) to Be Provided to Contaminated and Injured Individuals . . . . . . . . . . . . . 295-308

) 4. The Equipment and Training of Hospital, Ambulance and Medical Support Personnel . . . . . . . . . . 309-310

5. Conclusions Regarding Adequacy of Arrangements for Contaminated

) and Injured Individuals . . . . . . . 311-320 J. CCNTENTION 2C (Public Education and Information Program)

1. Introduction . . . . . . . . . . . . , 321-322

) 2. Content of Public Education and Information Program . . . . . . . . 323-325

3. Coverage of the Public Infor-mation and Education Program . . . . . 326-332

4. Applicants' Program to Update and Maintain Public Education and Information on an Annual Basis . . . . 333-338

5. Applicants' Program to Acquaint

) News Media with Emergency Plans, Information Concerning Radiation, and Points of Contact for Release of Public Information in an Emergency . . . . . . . . . . . 339-342

) 6. Conclusions Regarding Adequacy of Emergency Public Education and News Media Education and General Information Program . . . . . . . . . 343-344 K. CONTENTION 2B (Emergency Public

) Alert and Notification System)

1. Introduction . . . . . . . . . . . . . 345-347

) v

O PARAGRAPHS O 2. Administrative and Physical Means for Prompt Public Alert and Notification . . . . . . . . . . . 348-364

3. Administrative and Physical Means for Prompt Emergency O Public Instruction . . . . . . . . . . 365-38o

4. Development of Emergency Public Instructions . . . . . . . . . 381-386 L. CONTENTION 2K (General Plans for C) Reentry and Recovery)

1. Introduction . . . . . . . . . . . . . 387

2. The General Plans for Reentry and Recovery . . . . . . . . . . . . . 388-400 g

M. CONTENTION 1 (Offsite Public Protective Action Capability)

1. Introduction . . . . . . . . . . . . . 401-403 C) 2. Available Protective Actions . . . . . 404-422

3. Evacuation Planning . . . . . . . . . 423-444

4. Evacuation Time Estimates . . . . . . 445-454 O 5. Planning for Sheltering . . . . . . . 455-456

6. Planning for Thyroid Prophylaxis . . . 457-458

7. Offsite Capability to Implement Pr tective Actions . . . . . . . . . . 459 O

V. FINDINGS OF FACT ON :.NTERIM FEMA FINDINGS A. FEMA's Interim Findings . . . . . . . . . . 460-463 B. The Responses to the Interim FEMA Findings, O Including Deve'opment and Sufficiency of Corrective Actions Approved by FEMA . . . . 464-470 C. Status of Completion of Corrective Actions Approved by FEMA . . . . . . . . . 471-480 O D. Further FEMA Findings . . . . . . . . . . . 481 vi O

!O i

i i

PARAGRAPHS 10 482-483 1 VI. CONCLUSIONS OF LAW . . . . . . . . . . . . . . .

VII. PROPOSED ORDER GRANTING FULL POWER, FULL TERM OPERATING LICENSES O

O O

O O

O

..O O

O

J Q,

g DAVID R. PIGOT!

EDWARD B. ROGIN SAMUEL B. CASEY JOHN A. MENDEZ Of ORRICK, HERRINGTON & SUTCLIFFE A Professional Corporation g 600 Montgomery Street San Francisco, California 94111 Telephone: (415) 392-1122 CHARLES R. KOCHER JAMES A. BEOLETTO SOUTHERN CALIFORNIA EDISON COMPANY O P. O. Box 800 2244 Walnut Grove Avenue Rosemead, California 91770 Telephone: (213) 572-1900 Attorneys for Applicants O Southern California Edison Company and San Diego Gas & Electric Company UNITED STATES OF AMERICA O

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 9 In the Matter of ) Docket Nos. 50-361 OL

) 50-362 OL SOUTHERN CALIFORNIA )

EDISON COMPANY, ET 3 )

) .

(San Onofre Nuclear Generating )

g Station, Units 2 and 3). )

)

APPLICANTS' PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW ON EMERGENCY PLANNING AND PREPAREDNESS ISSUES.

Southern California Edison Company, San Diego Gas &

Electric Company, the City of Anaheim, California and the O

O

)

l l

City of Riverside, California hereby submit their proposed 3 findings of fact and conclusions of law on emergency planning and preparedness issues pursuant to the stipulation of the parties confirmed on the record of this proceeding by Order of the Atomic Safety and Licensing Board (" Board"). (Tr.

11357-11359.)

Applicants have previously filed their proposed 3 findings of fact and conclusions of law on the geology /

seismology issues (September 3, 1981) and the alternative motion for an operating license for fuel loading and low 3 power testing (October 12, 1981). These previously filed findings of fact and conclusions of law will not be reiterated, but are incorporated by reference to the extent J

, they may be deemed by the Board to be relevant to the l

l emergency planning and preparedness issues in this proceeding.

I.

)

l INTRODUCTION l

! A. Preliminary Statement l 1. Southern California Edison Company ("SCE"),

) San Diego Gas and Electric Company ("SDG&E"), and the Cities of Anaheim and Riverside, California (collectively

" Applicants") are co-owners of San Onofre Nuclear Generating

) Station, Units 2 and 3 (" SONGS 2 & 3"). SCE and SDG&E are also co-owners of San Onofre Nuclear Generating Station, Unit 1 (" SONGS 1"). SONGS 1, 2&3 (" SONGS") are managed and J

operated by SCE and are located on a site, adjacent to the 1

2 l

L

O i

Pacific Ocean, within the United States Marine Corps Base, O Camp Pendleton, San Diego County, Ca.1.ifornia.

2. SONGS 1 has been in operation since 1968.

Throughout the period of its operation, Applicants have O maintained and continuously upgraded an onsite radiological emergency plan in general conformance with changing NRC regulations and guidance. (Pilmer, Tr.7358-7364.) Since 0 1975, the United Statas Marine Corps-Camp Pendleton, the State of California (Office of Emergency Services), ae Pendleton Cocst Office of the State Department of Parks and O

Recreation, Orange County, San Diego County, and the City of San Clemente have also maintained offsite radiological emergency plans in general conformance with applicable NRC O

regulations and guidance. (Pilmer, Tr.7364-7366.)

3. On or about March 22, 1977, Applicants filed their. Application for Operating Licenses for SONGS 2 & 3. On

'O April 7, 1977, the notice of the filing of that application was published in the Federal Register, 42 Fed. Reg. 18460.

Pursuant to said notice, the petitions to intervene filed

'O pursuant to 10 C.F.R. 9 2.714 by Friends of the Earth et al. '

(" FOE et al.") and Grcups United Against Radiation Danger

(" GUARD") were subsequently allowed by Bcard Memorandum and

'O Order, dated October 26, 1977.

4. By Memorandum and Order of January 27, 1978, the Board admitted for discovery purposes two emergency

O planning contentions alleged by Intervenor GUARD and one 3

O

.O 5

emergency planning contention alleged by Intervenor FOE et

'O al. Following substantial discovery over the next three-year period and amendments to the Commission's emergency planning regulations, the Board approved three revised emergency

- O planning and preparedness contentions for purposes of hearing. The hearing began on August 25, 1981 and was completed on September 29, 1981. (Tr. 6823, 11130.)

iO-

5. SONGS 2 & 3 may.not be authorized to commence full power operation unless a finding is made by the Nuclear Regulatory Commission ("NRC" or " Commission") that the state

'O of onsite and offsite emergency preparedness provides reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency.

!O (10 C.F.R. S 50.47(a)(1); SECY-81-188 (March 20, 1981); NRC Staff Generic Letter No. 81-25, June 18, 1981.) The NRC is required to base its overall finding on a review of the Federal Emergency Management Agency (" FEMA") findings and determination as to whether State and local offsite emergency plans are adequate and capable of being implemented, and on

O the NRC assessment as to whether the Applicants' onsite emergency plans are adequate and capable of being implemented. In any NRC licensing proceeding, a FEMA finding

.O constitutes a rebuttable presumption on the question of 1

adequacy. 10 C.F.R. 5 50.47(a)(2).

6. The Applicants' emergency response plans for iO nuclear power plants must meet the various standards and 4

O

O other criteria set forth in 10 C.F.R. SS 50.47(b) and Part O 50, Appendix E. The offsite emergency response plans for the plume exposure pathway and the ingestion pathway emergency planning zones must meet the planning standards set forth in O 10 C.F.R. SS 50.47(b) and (c)(2).

7. Failure to meet all of the pianning standards set forth in 10 C.F.R. SS 50.47(b), (c)(2), and Part 50, O Appendix E need not necessarily result in the NRC dcclining to issue an operating license to SONGS 2 & 3. Applicants may demonstrate to the satisfaction of the Board that O

deficiencies in the plans are not significant, that adequate interim compensating actions have been or will be taken promptly, or there are other compelling reasons to permit O

plant operation. 10 C.F.R. S 50.47(c)(1). In determining the sufficiency of " adequate interim compensatory actions,"

the Board must examine State plans, local plans, and O

Applicants' plans to determine whether features of one plan can compensate for deficiences in another plan so that the level of protection for the public health and safety is O

adequate. (45 Fed. Reg. 55403 (August 19, 1980); see Section 109 of the 1980 NRC Authorization Act (Pub. L.96-295); and l Congressional Conference Report No. 96-1070, at p. 27.)

p 8. In this case, the involved local jurisdictions, rather than the State of California, have the principal offsite responsibility for planning and responding Q

l to a radiological emergency involving SONGS 2 c. 3. (Exhibit I

! 5 0

O

1. 52, Sections IV.C and V.C.; Intervenors' Exhibit #23, O

Sections III.B.2;c and IV.C.; Kearns, Tr. 10169; see Cal.

Gov. Code $ 8610.)1/ These local jurisdictions are San Diego l

and Orange Counties (" Counties"), the Cities of San Clemente O

and San Juan Capistrano (" Cities"), the State Department of Parks and Recreation - Pendleton Coast Office, (" State Parks"), and the United States Marine Corps - Camp Pendleton O

("USMC"). The State of California, through its lead emergency response agency, the State Office of Emergency Services (" State OES"), assumes a back-up or support role in O

the event these local jurisdictions, as augmented by local l mutual aid assistance, require additional manpower, equipment or technical assistance from State or federal agenciec. Each O

i of these local jurisdictions, as well as the State OES, have prepared radiological emergency plans that have been reviewed by FEMA against the Commission's emergency planning O

regulations and related guidance. (Intervenors' Exhibit #13; Staff Exhibit #11, p.1; Nauman, Tr. 10569; Kearns, Tr. 10169-10170.)

O

9. On June 3, 1981, FEMA determined that the j involved State and local radiological emergency response plans were minimally adequate, but until corrective aecions lO 1/ Applicants' Exhibit (s) will be designated as

" Exhibit (s)" throughout these proposed findings.

lO Intervenors' Exhibits and Staff Exhibit (s) will be designated, respectively, as "Intervenors' Exhibit (s)" and

" Staff Exhibit (s)".

6

,O i

t

..- . = _ . _ _ . _ . ._ .

O had been taken, the offsite capability for implementation of

' O these plans was not considered adequate. (Staff Exhibit #11, 4

p. 2.) On July 14, 1981, the corrective actions deemed sufficient to resolve FEMA's concerns were recognized by iO (Exhibits #144, #146; Pilmer, Tr. 9205; Nauman, FEMA.

I Tr. 10943.) It is FEMA's position that when these corrective actions are satisfactorily co'mpleted there will be reasonable 20 assurance that adequate protective measures can and will be taken in the event of a radiological emergency at SONGS 2 &

3. (Nauman, written testimony (September 24, 1981), p. 1;

O l_ Tr. 10372, 10942.)

10. The NRC Staff has determined that the Applicants' onsite emergency plans are adequate and capable

O of being implemented. (Staff Exhibit #12, p. 13-4; Sears, written testimony (September 18, 1981), pp. 3-4, Tr. 11340.)

i The NRC Staff has also determined that Applicants' onsite

O capability to perform offsite radiation dose assessment and monitoring is sufficient to compensate for any deficiencies the involved local jurisdictions may have in this regard, as

O reported by FEMA. (Sears, Tr. 11039.) This determination is particularly significant insofar as offsite radiation dose assessment and monitoring training is the only corrective 20 action identified by FEMA which had not been substantially i

completed prior to the close of the record in this proceeding. (Pilmer, Tr. 9206-9210; see FF. Nos. 471-480

O infra.)

7 e

O

- - - - - ~

O

11. It is also the overall conclusion of the NRC O Staff that if the corrective actions recommended by FEMA are carried out prior to full power operation at SONGS 2 & 3, the state of onsite and offsite emergency preparedness provides O reasonable assurance that adequate protective measures can and will be taken in the event of radiological emergency.

(Staff Exhibit #12, p. 13-4.) There was substantial O uncontroverted evidence presented during the hearing that most of these corrective actions had been substantially completed and all corrective actions would easily be O completed prior to full power operation of SONGS 2. (Pilmer, Tr. 9206, 11111; see FF. Nos. 471-480 infra.)

12. Intervenors' Contentions controverted certain O findings made by FEMA and the NRC Staff regarding the adequacy of onsite and offsite emergency planning.

Intervenors' also took the position that FEMA's findings of O

June 3 regarding the offsite capability for implementation of the offsite plans created a presumption that adequate protective measures cannot and will not be taken in a radiological emergency. (Statement of Counsel (Mr. McClung),

Tr. 9424.)

13. Applicants' position was that the O

preponderance of the evidence demonstrated that the capability to implement the involved onsite and offsite radiological emergency plans currently exists; that the O

deficiencies initially reported by FEMA in June either have 8

h l

O been remedied by the corrective actions recommended by FEMA, O or will be remedied prior to full power operation of SONGS 2; that other adequate interim compensating actions are available to remedy the deficiencies initially reported by O FEMA; and that the overall state of onsite an'd offsite emergency preparedness provides more than a reasonable assurance that adequate protective measures can and will be

() taken in the event of a radiological emergency involving SONGS 2 & 3. (Statement of Counsel (Mr. Pigott), Tr. 6905-6909.)

O 14. Based upon the substantial and mostly uncontroverted evidence to be discussed in detail below, the Board concludes that Applicants' position is correct. To O

fully understand this conclusion it is helpful to begin with the procedural background of this controversy. This background will then be followed by findings pertaining to O i emergency planning and preparedness generally; followed by I specific findings regarding each of the Intervenors' Contentions; and concluding with findings concerning the O

June 3 FEMA findings.

B. Procedural Background

15. At the construction permit phase of these O

proceedings, the Board determined that adequate evacuation routes were and would be available to enable development of a plan for an evacuation, if roquired as the result of a O

nuclear incident; but left it to the NRC Staff at this stage 9

O

i lO of the proceedings to determine wh' ether an adequate 0 evacuation plan had in fact been developed. (LBP-73-36, 6 AEC l 929, 950-952 (1973); affirmed ALAB-248, 8 AEC 957, 962-963 (1974).)

O 16. In June, 1979, the NRC began a formal reconsideration of the role of emergency planning in ensuring the continued protection of the public health and safety in O

areas around nuclear power facilities. The Commission began this reconsideration in reccanition of the need for more effective emergency planning and in response to the Three O

Mile Island accident. (45 Fed. Reg. 55402, August 19, 1980.)

17. On October 23, 1979, the Commission issued a policy statement expanding the areas within which

'O predetermined emergency planning for airborne radiation exposure and contaminated food and water should exist. At j that time the Commission stated that two " Emergency Planning O

Zones" ("EPZs") should be established around each nuclear power plant. The EPZ for airborne exposure (the " Plume EPZ")

l was to be a radius of about 10 miles; and the EPZ for Q

contaminated food and water (the " Ingestion EPZ") was to be a radius of about 50 miles from the site. (45 Fed. Reg. 55406 (August 19, 1980); 44 Fed. Reg. 61123 (October 23, 1979).)

3

18. On December 7, 1979, President Carter, in .;

response to the recommendation of the President's Commission on the Accident at Three Mile Island directed that FEMA take O

the lead in offsite radiological emergency planning and 10

)

e

J response to nuclear power plants. (See 45 Fed. Reg. 42341 (June 24, 1980).)

19. On December 19, 1979, the NRC published in the Federal Register its proposed amendments to its emergency planning regulations contained in 10 C.F.R., Part 50 and Appendix E. (44 Fed. Reg. 75167.)

20. On January 14, 1980, the NRC and FEMA entered

)

into a Memorandum of Understanding giving to FEMA the lead agency responsibility for developing a program for assessing State and local emergency response plans on all elements of J

offsite radiological emergency planning, and for making findings and determinations as to the adequacy and capability of implementing such State and local plans. (45 Fed. Reg.

5847.)

21. On June 24, 1980, FEMA published in the Federal Register its proposed regulations for review and O

approval of State and local radiological emergency plans.

(Proposed 44 C.F.R., Part 350; 45 Fed. Reg. 42341.) Under the proposed regulations only the Governor of a State could

~J submit State and local radiological emergency plans for FEMA review and approval. (Proposed 44 C.F.R. 5350.7; 45 Fed.

Reg. 42345.) These regulations have not been adopted, but generally are being followed as matter of policy by FEMA to the extent consistent with FEMA's obligation to support the NRC licensing review activities. (45 Fed. Reg. 42343 11

_)

l

O (June 24, 1980); Statement of Counsel'(Mr. Cosgrove), Tr.

iO~ 523-524.)

22. Effective November 1, 1980, FEMA and the NRC i Staff entered in a Memorandum of Understanding ("MOU") which

~O superseded the prior agreement betwe.an these agencies and 4

required FEMA to provide support for NRC licensing review I

"with regard to the assessment of the adequacy of State and

'O local response plans for accidental radiological releases."

i Section II. 4 of the MOU in pertinent part provides:

"Notwithstanding the p*ocedures which may be lg set forth in 44 C.F.R. 350 for requesting and 2

reaching a FEMA administrative approval of

, State and local plans, findings and determinations on the current status of 4 emergency preparedness around particular sites may be requested by the NRC through the O NRC/ FEMA Steering Committee and provided by FEMA for use as needed in the NRC licensing

process. These findings and determinations i may be based upon plans currently available to FEMA or furnished to FEFIA by the NRC."

O. (f5 Fed. Reg. 82714 (December 16, 1980).) On March 4, 1981, Mr. 3. K. Grimes, Director, NRC Staff Division of Emergency l Preparedness, in a memorandum to Mr. J. Dickey, Director, i

lO FEMA Radiological Emergency Preparedness Division, invoked

this provision of the MOU and requested FEMA to provide NRC i

with findings and determinations as to whether the State and f(3 local emergency plans for SONGS 2 and 3 are adequate and l capable of implemener; ion. This information was requested as-

}

soon as possible, but not later than June 1, 1981. In lieu

O 4

1 12 JO 1

I

O of formal FEMA findings, an interim FEMA evaluation of O offsite preparedness was requested.

23. Effective Ncvember S, 1980, the NRC -

promulgated amended emergency planning regulations which are O now set forth in 10 C.F.R. $$50.33(g), 50.47, 50.54(g), (r),

(s), (t), and (u), and Part 50, Appandix E ( 'INRC Regulations"). The NRC Regulations refer to published NRC O guidance on the establishment of the EPZs ("NUREG-0396") and criteria for the preparation and evaluation of onsite and offsite radiological emergency response plans ("NUREG-0 0654"). Additional NRC guidance on the functional criteria for emergency response facilities ("NUREG-0696") has subsequently been published. These guidance documents are O

not regulations, but are useful in evaluating compliance with the NRC Regulations.2/ In the case of an application for an operating license such as presented here, compliance with the O

NRC Regulations as regards offsite planning and preparedness does not have to be accomplished until the time of full power authorization, or such other implementation date as has been O

established by the NRC in its clarification letter 2/ Although " entitled to considerable crima facie weight",

O Vermont Yankee Nuclear Power Corp. (Vermont Yankee Nuclear Power Station), CLI-74-40, 8 AEC 809, 811 clarified as to other matters, 8 AEC 827 (1974), and compliance therewith is likely to amount to compliance with regulations, Petition for Emergency and Remedial Action, CLI-78-6, 7 NRC 400, 406-07 (1978), regulatory guides promulgated by the' Staff are not O regulations and are not entitled to be treated as such, Gulf States Utilities Co. (River Bend Station, Units 1 & 2),

ALAB-444, 6 NRC 760, 772 (1977).

13 0

O

("NUREG-0737") regarding approved TMI Action Plan items. I C) (NRC Staff Generic Letter No. 81-25, June 18, 1981.)

24. In February, 1981, FEMA, Region IX, and its Regional Assistance Committee ("RAC") commenced an informal O review of six offsite emergency response plans for San Onofre Nuclear Generating Station (" SONGS"). These plans had been adopted to comply with the NRC Regulations by the Counties, O the Cities, the USMC, and the State Parks. At the same time, FEMA. Region IX, and the RAC also reviewed the Interagency Agreement and Evacuation Procedure ("IAEP"), which had also O

been developed by these jurisdictions and incorporated by reference in each of their plans. The purpose of the review was to evaluate the plans against the guidance set forth in O

NUREG-0654 and provide suggestions for improvement. On April 27, 1981, the results of this informal plan review

(" FEMA /RAC Review Comments") were published by FEMA and

.O provided to the involved jurisdictions and the parties herein. (Intervenors' Exhibit #13.)

25. The State o'f California currently has in

O i effect a radiological emergency plan, which was adopted in 1975, revised in 1978, and concurred in at that time by the NRC. (Exhibit #52; Pilmer, Tr. 7364-7365.) In March, 1981,

.O this plan was again revised in draft form to comply with the applicable NRC Regulations and guidance. (Intervenors' Exhibit #23; Kearns, Tr. 10131.) FEMA, Region IX, and the O

l 14

!O

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

'O RAC also reviewed this draft plan during the early part of O 1981. Although the draft plan has not (Staff Exhibit #11.)

been formally adopted by the State Legislature as required by State law, this plan would now govern the State's response in O

, a radiological emergency. (Kearns, Tr. 10189; see Cal. Gov.

Code $ 8610.5.)

26. On April 6, 1981, all discovery in this O

proceeding was terminated pursuant to the stipulation of the parties approved by Board Order, dated February 9, 1981, except with respect to new information first made available O

after this date.

27. On April 29, 1981, a special prehearing conference with respect to emergency planning issues was held O

in San Diego, California. As a result of that conference, the parties were directed by the Board to work towards the stipulation of final emergency planning contentions, and to O

participate in an informal prehearing discovery session, including all parties and representatives from FEMA, upon the publication of the FEMA evaluation of offsite preparedness.

O

28. On May 13, 1981, an exercise of onsite and offsite emergency planning and preparedness for SONGS was conducted involving the personnel and resources of

'O Applicants, the Counties, the Cities, USMC, State Parks, the Capistrano Unified School District (" District"), the San Diego and Orange County Chapters of the American Red Cross O

(' Red Cross"), the California Department of Transportation 15 O

O

("CALTRANS"), the California Highway Patrol ("CHP"), the C) State Department of Health Services, the State Office of Emergency Services (" State OES"), and various other local organizations. A detailed log of the significant exercisa C) activities and responses was compiled by Applicants.

(Exhibit #110.) The exercise was observed by representatives of FEMA, who subsequently provided a generally favorable O

evaluation of the exercise and suggested areas for offsite improvement in a document entitled " Evaluation Findings, SONGS Offsite Emergency Response Plans Exercise" (" FEMA O

Exercise Evaluation"), which was published May 29, 1981 and subsequently provided to the involved jurisdictions and the parties herein. (Intervenors' Exhibit #14.) The NRC Staff O

also observed the exercise and subsequently provided a generally favorable evaluation of the Applicants' performance during the exercise in an inspection report O

. (No. 50-206/81-19), which was provided to the parties by

. counsel for tha NRC Staff under cover letter, dated August 4, 1981. (Exhibit #162; Sears, written testimony (August 20, O

1981), p. 11, written testimony-(August 6, 1981), p. 5, Tr. 10644.)

29. On May 14, 1981, representatives of FEMA, O

Region IX, conducted a public meeting in the San Clemente City Hall to informally report their evaluation of the exercise, describe the plan review process, and receive O

public comments on offsite emergency planning and 16 O

O preparedness. aepresentatives from the State OES, the C) Counties, the Cities, the District, State Parks, and the USMC attended and generally described their plans and preliminary evaluation of the exercise. Representatives of the Red Cross O and the CHP also attended. A transcript of this meeting was subsequently made available to the Board and the parties by counsel for Applicants.

O

30. On June 3, 1981, in response to the March 4 NRC Staff request for an interim FEMA evaluation of offsite preparedness, FEMA issued its " Interim Findings and O

Determination Relating to the Status of State and Local Emergency Preparedness for San Onofre Nuclear Generating Station (Units 2 and 3)" (" Interim FEMA Findings"), a copy of O

which was served on the Board and the parties herein by counsel for'the NRC Staff.3/ FEMA determined that additional offsite training and other short-term improvements were O

required before it would be able to make an overall favorable finding on the state of offsite emergency preparedness for SONGS. Specifically, FEMA determined that " State and local O

3/ It has been exclained to the Board that the word

" interim" is used a's an administrative term for findings on offsite plans which are issued by FEMA in response to a O request of the NRC Staff under the MOU prior to the time such plans have been submitted by the Governor of the State involved and reviewed by FEMA pursuant to the administrative procedures set forth in FEMA's proposed regulations, 44 C.F.R., Part 350 (proposed), 45 Fed. Reg. 42341 (June 24, 1980). The word is not to be understood as implying that O additional FEMA findings and determinations are required by FEMA or NRC for NRC licensing purposes. (Statement of Counsel (Mr. Cosgrove), Tr. 523-524.)

17 O

LO government radiological emergency response plans are O However, until corrective actions have minimally adequate.

been taken, the offsite capability for implementation of the plans is not considered adequate." (Staff Exhibit #11, p.2.)

O

31. The Interim FEMA Findings clearly anticipated remedies for the deficiencies noted within the "very near future":

O "The conclusion reached is that there has been insufficient time, training, drill, and exercise to r.eflect the required ability of offsite organizations to protect public health and safety. Alternatively, the O efforts rendered, coupled with an aggressive thorough approach to training and preparation (equipment, SOP's etc.) generated as a result of these findings or related incentives, would create the necessary capability within the very near future." (Staff Exhibit #11, O Attachment, p.7, emphasis added.)

32. On June 15, 1981, the informal discovery session previously ordered by the Board was conducted at the O

Registry Hotel in Irvine, California. The session was attended by various representatives of all the parties, as well as by counsel and other representatives from FEMA, Region IX and the Board Chairman. Counsel and other j representatives of GUARD and FOE et al. were oermitted to

informally question the representatives of FEMA on a broad O

variety of topics related to FEMA's review of SONGS offsite I

emergency planning and prepar,edness, as reflected in the l

Interim FEMA Findings, the Exercise Evaluation, and the FEMA /RAC Review Comments. At the close of the session, the i

1 18

O

O parties reported to the Board Chairman that all their

1. questions had been answered. No request for further discovery was made at that time and all discovery has been deemed closed since that time. (Tr. 646-648.)

• 33. On June 18, 1981, the final prehearing conference on emergency planning contentions, previously noticed in the Federal Register, was commenced in San Diego, California. (46 Fed. Reg. 31123, June 12, 1981.) The full range of substantive and procedural topics involved in the commencement of emergency planning hearings were argued by all parties. These topics included consolidation of the Intervenors GUARD and FOE et al., final specification of contentions, the impact of the Interim FEMA Findings, and the need to resolve outstanding legal issues regarding determination of the Plume EPZ, the impact of earthquakes on emergency planning, and the procedural efficacy of an alternative proceeding to obtain a low-power license. In view of the need to resolve these legal issues and to allow further time for the parties to discuss *.he final specification of emergency planning contentions, the Board recessed tne final prehearing conference to be reconvened, if necessary, during the seismic hearings upon the call of the Board. (Tr. 673.)

34. On or ab,ut June 22, 1981, the parties served and filed herein their views of the " Plume EPZ" and

" earthquake" issues. On June 29, 1981, Applicants served and 19 J

O filed their memorandum supporting commencement of emergency O planning hearings shortly after conclusion of the seismic hearings. At that time, in order to fully inform the parties of the steps being taken by Applicants to remedy the various O deficiencies noted in the Interim FEMA Findings, Applicants filed and served on the parties the " Declaration of Robert Dietch in Support of Commencement of Hearings on Emergency O Planning Contentions Shortly After Conclusion of Seismic Hearings," which included a list of the " Corrective Actions Required to Address FEMA Determinations of June 3, 1981" and O a schedule for implementation of these corrective actions.

On July 1, 1981, the parties agreed to submit for Board determination the various procedural and substantive legal O questions raised at the final prehearing conference, along with the final wording of the emergency planning contentions, on the basis of their written filings. (Tr. 2695-2701,2891.)

O 35. On July.lO, 1981, the final prehearing order on emergency planning c.ontentions was issued on the record.

(Tr. 3491-3515, 3562-3584.) At that time, the Board set O dates for commencement of hearings and filing of testimony, admitted final emergency planning contentions, ordered Intervenors GUARD and FOE et al. to determine among O themselves who would act as " lead counsel" for each admitted contention, and granted Intervenor FOE et al. additional time to submit an acceptable contention pertaining to the Plume O

EPZ (the " Plume EPZ Contention"). (Tr. 3491-3515.) Counsel I

( 20 0

O for Intervenor GUARD did not attend this conference, but on CJ July 11, 1981 were provided with a copy of the' transcript of the proceedings by counsel for the Applicants.

36. On July 29, 1981, the Board approved certain

() minor changes to the wording of the final emergency planning contentions previously admitted for hearing (Tr. 5543-5545);

~

and raised, on its own motion, an issue involving emergency O response in the event of an earthquake exceeding the Safe Shutdown Earthquake (the " Seismic / Emergency Planning Issue"). (Tr. 5546-5547.)

O

37. On July 30, 1981, Applicants, the NRC Staff, and GUARD, through counsel, entered into a stipulation subsequently approved by Board Order, dated August 21, 1981, O

governing the schedule for filing of testimony and the order of presentation for the hearings on the emergency planning contentions previously admitted by the Board.

O

38. On August 4, 1981, the Board admitted an amended version of the Plume EPZ Contention, and heard additional argument on the Board's proposed Seismic / Emergency O

Planning Contention. (Tr. 6802-6822.)

39. On August 7, 1981, the Board issued an Order modifying the Seismic / Emergency Planning Contention in o various minor respects. On August 17, 1981, Applicants requested the Board to certify that contention to the Commission. On September 14, 1981, the Board granted the O

Applicants' request by referring the issue to the Atomic 21 0

Licensing and Appeal Board. By order dated September 18, 1981, the Commission on its own motion directed that no further consideration of the Seismic / Emergency Planning Issue should be made by this Board or the Appeal Board until

) further order of the Commission. On October 2, 1981, the Board submitted to the Commission its rationale for proposing the issue and the criteria suggested for resolution of the

) issue.

40. On August 20, 1981, Intervenors GUARD filed a motion for a continuance of the hearings on emergency

) planning and preparedness issues. The motion was opposed by Applicants and the NRC Staff. On August 26, 1981, the motion was denied by the ~3oard fer the reasons stated in the record

) at that time. (Tr. 7402 L:06.)

41. Nineteen days of public hearings on the emergency planning and preparedness issues were held in

) Anaheim, California, with sessions commencing on August 25, 1981 and September 21, 1981. The hearings were completed on September 29, 1981. On September 30, 1981, the record was

) closed on these issues and it was stipulated by all i interested parties that Findings of Fact and Conclusions of Law be submitted on such issues. (Tr. 11357-11358.) By

) Order, dated October 6, 1981, the Board clarified that the l

record in this case was closed subject to receipt and I

! inclusion in the record of further findings and determinations from FEMA, and a response from FEMA to various l 22

)

l l

O questions previousip posed by the Board, and such responses O to this additional information as the Board may permit the parties to file. (Tr. 7703-7706.) s II.

O PARTIES

42. The Applicants, the NRC Staff, and Intervenor GUARD were represented by counsel, presented evidence, and O

cross-examined witnesses, at all hearing sessions on the emergency planning and preparedness contentions. Mr. Richard Wharton, cc.:nsal for Intervenor FOE, et al. during the

.O geology / seismology portion of the proceedings, did not participate in the hearings on emergency planning and preparedness issues. However, the interests of Intervenor O

FOE, et al. were represented by counsel for GUARD. (Tr.

6829.) Accordingly, Intervenors GUARD and FOE et al. will be collectively referred to as "Intervenors" for purposes of O

these findings of fa:t and conclusions of law.

43. FEMA was also represented by counsel.

(Tr. 6828.) Insofar as FEMA was not deemed by the Board to

'O be a party to this proceeding, the role of counsel for FEMA was limited by the Board to those instances where participation by counsel for FEMA assisted in developing a

'O sound decisional record. (Tr. 7986.)

O 23 0

i

)

i III.

2) EVIDENTIARY HEARING AND ISSUES l

A. Intervenors' Contentions j 44. Pursuant to the Final Prehearing Conference U Order of the Atomic Safety and Licensing Board, stated on the l record herein of July 10 (Tr. 3492-3493) and August 4, 1981 (Tr. 6802), and the stipulation of the parties clarifying the O wording and relettering of Contention 2, as reported by counsel for Applicants to the Board on the record of July 29, 1981 (Tr. 5543-5546), the following Intervenors' Contentions D were admitted for hearing purposes:

CONTENTION 1:

Whether the state of emergency preparedness for 3 SONGS 2 and 3 provides reasonable assurance that the offsite j transient and permanent population within the plume exposure pathway Emergency Planning Zone, 10 C.F.R. $50.47(c)(2), for SONGS 2 and 3 can be evacuated or otherwise adequately j protected in the event of a radiological emergency with offsite consequences occurring at SONGS 2 and 3, as required g by 10 C.F.R. $$ 50.47(a)(1), (b)(10), and Part 50, Appendix E.IV. .

l CONTENTION 2:

l l

Whether there is reasonable assurance that the 3 emergency response planning and capability of implementation for SONGS 2 and 3, affecting the offsite transient and permanent population, will comply with 10 C.F.R. $50.47(a)(1) and (b) or (c)(1) as regards:

l A. the procedures for notification by Applicants 9 of State and local response organizations, 10 C.F.R. $50.47(b)(5), and for notification of and continued communication among emergency i personnel by all involved organizations, 10 C.F.R. $50.47(b)(6);

-)

~

3. the means for notification and instruction to the populace within the plume exposure pathway l

l 24 D

I

I l

l l

l Emergency Planning Zone, 10 C.F.R.

550.47(b)(5);

C. the information and the procedure for dissemination of the information to the public within the plume exposure pathway Emergency Planning Zone on a periodic basis on how they will be notified and what their actions should

2) be in the event of an emergency, 10 C.F.R.

550.47(b)(7);

j D. the arrangements for medical services for contaminated and injured individuals, 10 C.F.R. 550.47(b)(12);

E. necessary transportation and communication equipment, and the operation of the emergency I

operations centers of the principal response l

organizations, 10 C.F.R. 550.47(b)(8);

h F. the capability of each principal response organization to respond and to augment this initial response on a continuous basis, 10 C.F.R. 550.47(b)(1);

G. radiological emergency response training to those who may be called on to assist in an emergency, 10 C.F.R. 550.47(b)(15);

H. the methods, staffing, system, and equipment i for assessing and monitoring actual or j potential offsite consequences of a radiological emergency condition within the l

plume exposure pathway EPZ for SONG 3 2 and 3, 10 C.F.R. 550.47(b)(9);

t l I. the physical design, communications equipment, g and operating procedures for the Interim Emergency Operations Facility, 10 C.F.R.

5550.47(b)(3) and (b)(8);

J. the methods, systems and equipment for assessing and monitoring actual or potential

) offsite consequences of a radiological emergency condition within the ingestion pathway EPZ for SONGS 2 and 3, 10 C.F.R.

550.47(b)(9);

K. general plans for reentry and recovery, 10 3 C.F.R. 550.47(b)(13).

! 25

O CONTENTION 3:

1. The emergency response plans fail to meet the requirements of 10 C.F.R. 550.47(c)(2) because local emergency planning officials have arbitrarily established the boundaries of the Plume Exposure EPZ in that they have mechanically applied a 10 mile boundary and that the Interagency Agreement (IAEP) among all lor ~ jurisdictions O defines the EPZ by drawing compass lines .. a map of the area. In determining the exact size of the EPZ, emergency planning officials have failed to consider the following local conditions:

1. topography

2. meteorology

3. evacuation routes

4. demography

5. jurisdictional boundaries

6. SAI report

7. land characteristics.

)

B. Order of Presentation

45. The order in which testimony was presented was 3 prescribed by the stipu ation of the parties, as approved by Board Order, dated August 21, 1981. (Tr. 6831.) Applicants presented their entire case first (Tr. 6893-9387), followed 7, by Intervenors (Tr. 9417-10311, 10773-10815), followed by the NRC Staff (Tr. 10317-11063), and concluding with Applicants' rebuttal (Tr. 10817-10855, 11065-11130).

7) 46. Applicants determined that in order to present their case in a manner that would allow logical progression through the three contentions, with minimal recalling of g witnesses or undue inconvenience to the subpoenaed witnesses, it was most apprcr . , > ~.o address the issues by presenting their witnessnv ' >

following order:

26

~

O t-DIRECT VOLUNTARY WITNESSES

,0 WITNESS CONTENTION (S)/ ISSUE

1. T. James DuBois 1/ Public Notification 2B/ Public Notification

!) 2. James L. Willis 2G/ Onsite Training

3. Eugene N. Cramcr 1/ -Public Notification 2B/ Public Notification to 2C/ Public Education

~

4. Kenneth P. Barr 2F/ Radiological Assessment Response and Augmentation

! 2H/ Offsite Radiological O Monitoring & Dose Assessment

5. Dr. Roger E. Linnemann 1/ Perspective on Protective Actions O

2D/ Medical Services for Contaminated and Injured Individuals l 2G/ Oncite and Offsite

() Medical Training

6. Dr. Jack E. Hauck 2D/ Medical Services for Contaminated and Injured Individuals O 7. Harold B. Ray 2A/ Onsite Notification of Offsite Agencies 2E/ Onsite Emergency Facilities O 2F/ Onsite Response and Augmentation Capability

8. Ernest L. Murri if Perspective on Evacuation and Other Protective Actions O

27 O

O DIRECT VOLUNTARY WITNESSES-(Continued)

O WITNESS CONTENTION (S)/ ISSUE 2A/ Onsite and Offsite Communication Capability 2C/ Public Education 2E/ Offsite Emergency Operation Centers 2F/ Offsite Response and g Augmentation Capability 2G/ Offsite Training 2H/ Offsite Monitoring and Dose Assessment Capability 3 2I/ Interim EOF 2K/ Onsite and Offsite Reentry & Recovery Plans

]g 3/ Plume EPZ Determination

9. Bryant T. Brothers 1/ Evacuation Planning &

Time Estimation j

3/ Plume EPZ Determination O 10. Keith Woodard SAI Study as Validating 3/

Plume EPZ Determination

11. David F. Pilmer 2A/ SCE Corporate Emergency Response Organization 2G/ Offsite Training 2H/ Offsite Dose Assessment 2If Emergency Operations Facility

()

2J/ Ingestion Pathway Plans and Procedures 2K/ Onsite Reentry & Recovery O Rationale for Plume EPZ 3/

Determination 28 O

r DIRECT SUBPOENAED WITNESSES D WITNESS GENERAL AREA OF TESTIMONY

1. Chief Ben California Highway Patrol Plume Killingsworth, EPZ evacuation traffic California Highway management.

Patrol (Border Division)

2. David H. Roper, CALTRANS EPZ evacuation California Department traffic management.

of Transportation (District 7) 3 3. Calvin Nash, Red Cross operation of American Red Cross reception and care centers for (Orange County Chapter) evacuees.

4. Jack P. Stowe, State Parks emergency planning Pendleton Coast Office, and preparedness.

3 State Dept. of Parks

& Recreation

5. Ronald J. Coleman, San Clemente emergency City of San Clemente planning and preparedness.

3 6. Cynthia S. Ferguson, San Juan Capistrano emergency City of San Juan planning and preparedness.

Capistrano

7. Donald W. Poorman, Orange County primary and Communications Division, back-up emergency

) Crenge County General communication capability.

Services Agency

8. Jill M. Swanson, Capistrano Unified School

Capistrano Unified District procedure for School District evacuation and other 3 protective measure.s.

9. Egbert S. Turner, Orange County emergency Emergency Services planning and preparedness.

Division Orange County General Services Agency

10. Barbara Fox, Orange County emergency l General Services planning and preparedness.

l Agency i

29 b

I i

'O l DIRECT SUBPOENAED WITNESSES (Continued)

O WITNESS GENERAL AREA OF TESTIMONY l

11. James Hunt, San Diego County emergency l

San Diego County planning and preparedness.

l Office of Disaster g Preparedness

, 12. Lt. Col. J. E. Wallace, U.S. Marine. Corps emergency l Marine Corps Base Camp planning and preparedness Pendleton n REBUTTAL WITNESSES CONTENTIONS / ISSUE u

, 1. Dr. Roger E. Linnemann 2D/ Medical Services for Contaminated and Injured j Individuals i

g 1/ Thyroid Prophylaxis l 2. Bryant T. Brothers 1/ Evacuation l Time Estimates j 3. David F. Filmer 2J/ Ingestion EPZ Plans and

'O Procedures i

l Status of Corrective j

Actions in Response to Interim FEMA Findings g C. Witnesses

47. The complete list of witnesses who appeared at the emergency planning and p,reparedness portion of the l

j) hearings that were held August 25, 1981 through September 29, l

1981 is as follows:

9

<O

\

30

O i

r

-- - - e.,. _ _

r j

t I

l

, (a) APPLICANTS' DIRECT (CONTENTION NO. 2B (cont.)

i AND REBUTTAL WITNESSES Subpoenaed Witnesses:

B. Killingsworth CONTENTION NO. 1 J. P. Stowe Voluntary Witnesses: R. J. Coleman R. E. Linnemann C. S. Ferguson i E. L. Murri D. W. Poorman B. T. Brothers E. B. Turner J. W. Hunt j Subpoenaed Witnesses: J. E. Wallace l

B. Killingsworth D. H. Roper C. Nash- CONTENTION NO. 2C J. P. Stowe Voluntary Witnesses:

R. J. Coleman E. N. Cramer C. S. Ferguson J. M. Swanson Subpoenaed Witnesses:

E. B. Turner J. P. Stowe B. Fox R. J. Coleman j J. W. Hunt C. S. Ferguson l J. E. Wallace J. M. Swanson E. B. Turner

! J. W. Hunt CONTENTION NO. 2A J. E. Wallace Voluntary Witnesses:

p H. B. Ray E. L. Murri CONTENTION NO. 2D D. F. Filmer Voluntary Witnesses:

l R. E. Linnemann

Subpoenaed Witnesses

J. E. Hauck B. Killingsworth j D. H. Roper l C. Nash CONTENTION NO. 2E l J. P. Stowe Voluntary Witnesses:

l R. J. Coleman H. B.-Ray C. S. Ferguson E. L. Murri J. M. Swanson D. F. Filmer 3 E. B. Turner E. N. Cramer B. Fox B. T. Brothers J. W. Hunt J. E. Wallace Sp poenaed Witnesses:

B. Killingsworth D. H. Roper l3 CONTENTION NO. 2B C. Nash Voluntarv_ Witnesses: J. P. Stowe T. J. DuBois R. J. Coleman E. N. Cramer C. S. Ferguson H. B. Ray D. W. Poorman J. M. Swanson O E. B. Turner J. W. Hunt J. E. Wallace l

l 31 a

l

O WITNESSES (cont.)

O CONTENTION NO. 2F CONTENTION NO. 2H (cont.).

Voluntary Witnesses: Subpoenaed Witnesses (cont.):

H. B. Ray E. B. Turner K. P. Barr J. W. Hunt E. L. Murri J. E. Wallace O D. F. Filmer Subpcenaed Witnesses: CONTENTION NO. 2I B. Killingsworth Voluntary Witnesses:

D. H. Roper E. L. Murri C. Nash D. F. Pilmer O J. P. Stowe R. J. Coleman Subpoenaed Witnesses:

C. S. Ferguson R. J. Coleman B. Fox J. W. Hunt J. E. Wallace CONTENTION NO. 2J O J. M. Swanson Voluntary Witnesses:

D. F. Filmer CONTENTION NO. 2G Voluntary Witnesses:

J. L. Willis CONTENTION NO. 2K O E. L. Murri Voluntary Witnesses:

R. E. Linnemann E. L. Murri D. F. Filmer D. F. Filmer Subpoenaed Witnesses: Subpoenaed Witnesses:

B. Killingsworth R. J. Coleman g C. Nash E. B. Turner J. P. Stowe J. W. Hunt R. J. Coleman J. E. Wallace C. S. Ferguson J. M. Swanson E. B. Turner CONTENTION NO. 3

'O B. Fx v luntary Witnesses:

J. W. Hunt E. L. Murri B. T. Brothers l K. Woodard CONTENTION NO. 2H D. F. Filmer Voluntary Witnesses:

K. P. Barr Subpoenaed Witnesses:

l9 E. L. Murri C. S. Ferguson i D. F. Pilmer E. B. Turner J. W. Hunt Subpoenaed Witnesses J. E. Wallace B. Killingsworth O R. J. Coleman 32

O i

i

LO i

WITNESSES (cont.)

.O (b) INTERVENORS' DIRECT WITNESSES Voluntary Witness:

S. C. Plotkin O Subpoenaed Witnesses:

I. Lyon M. Ditty J. Goodwin L. R. Ehling W. Mecham O C. Logue C. Fleming J. Kearns M. F. Reed W. R. Bloom g G. Caravalho (c) NRC STAFF'S DIRECT WITNESSES Voluntary Witnesses:

') H. Rood K. W. Nauman l J. R. S e a r !,

B. K. Grimes O APPLICANTS' RFBUTTAL WITNESSES (d)

Voluntary Witnesses:

R. E. Linnemann D. F. Filmer g B. T. Brothers i

l O

33 0

)

D. Exhibits

? 48. At the licensing hearings the following l

exhibits were identified, and where indicated, admitted into evidence:

h APPLICANTS' EXHIBITS 4/

i I

ADMITTED INTO NO. EXHIBIT IDENTIFIED , EVIDENCE

) 51 Emergency Plan for San Onofre Nuclear 6902 6903 Generating Station, Units 2 and 3, April, 1981 52 State of California, Nuclear Power 6902 6903

) Plant Emergency Response Plan, as revised August, 1978, prepared by the State Office of Emergency Ser-vices and the State Department of Health (now Department of Health Services)

) 53 Orange County Emergency Response 6902 6903

Plan, San Onofre Nuclear Generating Station, December, 1980, as adopted by the Orange County Board of Super-i visors, Resolution No. 80-2061, y December 16, 1980 54 Unified San Diego County Emergency 6902 6903 Services Organization, Nuclear P o- - Plant Emergency Response Plan, .

December, 1980, as adopted by the

) San Diego County Board of Supervisors, Resolution No. 10, December 9, 1980 55 City of San Clemente, California, 6902 6903 Radiological Emergency Response Plan Annex to the City's Emergency 4/ Applicants' Exhi, bits 1-50 were admitted during the hearings on the geology / seismology issues: Applicants' Fxhibits 160-162 were admitted during the hearings on the alternative nc' ion for an

) operating license for fuel loading and low power tescing.

34

)

9 APPLICANTS' EXHIBITS (continued)

O ADMITTED INTO NO. EXHIBIT IDENTIFIED EVIDENCE Cperations Plan, San Onofre Nuclear Generating Station, March, 1981, as O adopted by the San Clemente City Council Action No. 52, February 18, 1981 56 San Juan Capistrano Radiological Emer- 6902 6903 g, gency Response Plan, San Onofre. Nuclear Generating Station, December, 1980, as adopted by resolution of the San Juan Capistrano City Council, January 6, 1981 g, 57 Department of Parks and Recreation, 6902 6903 Pendleton Coast Area Radiological Emergency Response Plan, San Onofre Nuclear Generating Station, December, 1980 q, 58 SOP for Emergency Response, Marine 6902 6903 Corps Base, Camp Pendleton, California, 1-79, as revised by Be.se Order P3440.1 Ch. 1, January 19, 1981 59 Interagency Agreement and Evacuation 6902 6903 Procedure for the San Onofre Plume 3 Exposure Pathway Emergency Planning Zone, December, 1980 60, Siren Locations and Responsibility 6902 6913 TJD-1 Table D 61, Siren Signal Coverage Map 6902 6913 TJD-2 62, Training Memorandum 10-81 6902 6961 JLW-1 D 63, Training Memorandum 8-90 6902 6963 JLW-2 64, Training Memorandum 9-81 6902 6961 JLW-3 D

35 D

O APPLICANTS' EXHIBIT _S (continued)

1. ADMITTED INTO NO. EXHIBIT IDENTIFIED EVIDENCE 65, Training Memorandum 6-81 6902 6961 g JLW-4 66, Emergency Response Pamphlet, 10 Mile 6902 7439 ENC-1 EPZ 67, Emergency Response Information, USMC 6902 7440 g ENC-2 Camp Pendleton 68, Newspaper Advertisement on Pamphlets 6902 7439 ENC-3 Being Mailed 69, Example of Poster or Placard 6902 7439 g ENC'-4A 70, Example of Telephone Booth Decal 6902 7439 ENC-5 71, Example of Telephone Directory Insert 6902 7439 ENC-6A

()

72, Listing of PIOS With Addresses, Tele- 6902 7439 ENC-7 phone Numbers 73, Emergency Media Center Floor Plan 6902 7439 g ENC-8 (Plan I) 74, Emergency Media Center Floor Plan 6902 7439 ENC-9 (Plan II) 75, Pr -positioned Supply Boxes for Orange 6902 7439 g ENC-10 County and Radiation Apparatus 76, PIO Radiation Training Outline 6902 7439 ENC-11 (July 8, 1981) l 77, Chart of Information Flow Off-site 6902 7439

) ENC-12 During a SONGS Emergency 78, Examples of Press Releases, May 13 6902 7442 ENC-13 Exercisc 79, Map of SCE Offices and Service 6902 7441

() ENC-14 Territory 36 0

. _ . - .. .. ~= -

O i

' APPLICANTS' EXHIBITS (continued)

[) . ADMITTED ,

INTO NO. EXHIBIT IDENTIFIED EVIDENCE 80, -CRT Screen ?isplay, May 13 Exercise 6902 7442 ENC-15 81, SCE-GO Employee Bulletia, May .3 6902 7442 ENC-16 Exercise 82, Dr. Linnemann's Curriculum Vitae 6902 7715 REL-1 g

83,. List of Operators of Nuclear Generating 6902 7715 REL-2 Stations Subscribing to RMC's Medical Support Services, With Chart 84, - Qualifications and Backgrounds of-F.G. 6902 7713 O REL-3 Rocco and T.M. Linnemann 85, Chart Showing Agencies Represented at 6902 7715 REL-4 RMC Training, By Type of Agency and Number of Attendees O 86, .

Complete List of Agencies Represented 6902 7715 t REL-5 at RMC Training and Number of Person i Days For Each Agency 87, Examples of Letters of Invitation to 6902 7716 REL-6 RMC Training

)-

88, Agenda and Program, Orange County 6902 7715 REL-7 Training 69, Agenda and Program, San Diego County 6902 771i

.s

- REL-8 Training v

90, Synopsis of Lecture Topics Used in 6902 7715 REL-9 RMC Training Seminars 91, Scenarios Used in RMC Training 6902 7715 g REL-10 l 92, Lists of Handouts Provided to Attendees 6902 7715 l REL-11 of RMC Training 93, Typical EMAP Program of Instruction 6902 7715 ss v

REL-12 37 O

l L __ _._ _ _ _ _ _ _ _ _ _ _ _ _

O APPLICANTS' EXHIBITS (continued)

O ADMITTED INTO NO. EXHIBIT IDENTIFIED EVIDENCE 94, List of Required Supplies and Equip- 6902 7715 g REL-13 ment 95, South Coast Hospital Procedures for 6902 7715 REL-14 Handling Radiation Accidents 96, Tri-City Hospital Procedures for 6902 7715 g REL-15 Handling Radiation Accidents 97, San Clemente General Hospital Proce- 6902 7715 REL-16 dures for Handling Radiation Accidents 98, Umpire's Check List for RMC Drill 6902 7715 REL-17 O

99, RMC's Umpires' Report of May 13, 1981, 6902 7715 REL-18 Exercise 100, Agreement Between Radiation Management 6902 7795 O JEB-1 Corporation and Southern California Edison Company, July 1, 1981 101, Radiological Emergency Mutual Assis- 6902 7821 HBR-3 tance Agreement g 102, Initial Notification Forms 6902 7821 HBR-4 103, Manual of Emergency Events - SONGS 1 6902 7821 HER-5 g 104, Follow-up Notific.ation Form 6902 7821 HBR-f 105, Selected Instances of Large-Scale 6902 7871 ELM-1 Evacuation O 106, Manual of Protective Action Guides 6902 7871 ELM-2 and Protective Actions for Nuclear Incidents 107, Shel'.ering vs. Evacuation as a Pro- 6902 7871 ELM-3 tective Action O

38 O

9 APPLICANTS' EXHIBITS (continued)

O ADMITTED INTO NO. EXHIBIT IDENTIFIED EVIDENCE 108, Program for the Review, Revision and/or 6902 7871

, ELM-4 Development of Standard Operating Pro-cedures 109, Organizations Contacted by NUS Corpora- 6902 7871 ELM-5 tion During the Course af Emergency Plan Development 6 110, Log of Significant Events and Response 6902 7871 ELM-6 During SONGS Radiological Emergency Response Exercise, May 13, 1981 111, NUS Program for Offsite Agency Training 6902 7.871 g ELM-7 112, NUS Table Cross-Referencing NUREG-0654 6902 7871 ELM-8 Evaluation Criteria to SONGS Offsite Emergency Response Plant g 113, Response of NUS Corporation to Comments 6902 7871 ELM-9 Contained in the " FEMA, Region IX/

Regional Assistance Committee Informal Review of the San Onofre Offsite Emergency Response Plan," dated April 27, 1981 0 114, Interagency Agreement and Evacuation 6902 6903, BTB-1 Procedure for the San Onofre Plan 8027 Ev.posure Pathway Emergency Planning Zone, December, 1980 115, Organizations Contacted by Wilbur Smith 6902 8027 3 BTB-2 and Associates 116, Population Distribution By Sector 6902 8027 BTB-3 3 117, Summary of Evacuation Time Estimates 6902 8027 BTB-4 118, Comparison of Evacuation Time Estimates 6902 8027 BTB-5 3 119, Conditional Probability for Exceeding 6902 8229 KW-1 200 Rem Whole Body Dose Versus Distance 39 b

D APPLICANTS' EXHIBITS (continued)

[) ADMITTED INTO NO. EXHIBIT IDENTIFIED EVIDENCE 120, Percent of Core Melt Sequences with 6902 8229 KW-2 Doses Less than 200 Rem Versus Distance 121, Final Report, Technical Studies, Inges- 6902 7526 GR-1 tion Pathway Zone, Emergency Response Planning for Southern C:.lifornia Edison Company,. February, 1981 O 122A, Emergency Operations Facility (EOF) 9143 9143 DEP-1 123, Poster - San Onofre & Bluffs Beach 6902 7s39 ENC-17 O 124, Poster - San Onofre Surf Beach / 6902 7439 ENC-18 Trestles Beach 125, Poster - San Clemente Beach 6902 7439 ENC-19 0 126, Poster - Doheny Beach 6902 7439 ENC-20 127, Flyer - San Onofre & Bluffs Beach 6902 7439 ENC-21 0 128, Flyer - San Onofre Surf Beach / 6902 7439 ENC-22 Trestles 129, Flyer - San Clemente Beach 6902 7439 ENC-23 O 130, Flyer - Doheny Beach 6902 7439 ENC-24 131, Newspaper Advertisement re Pamphlet 7487 7488 ENC-25 (run in August, 1981)

O 132, Analysis of Time Required to Evacuate 8034 8035 BTB-6 Transient and Permanent Populations From Various Areas Within the Plume Exposure Pathway Emergency Planning l Zone, San Onofre Nuclear Generating g Station, Revision 2 l

40 b

t n

O APPLICANTS' EXHIBITS (continued)

O ADMITTED INTO NO. EXHIBIT IDENTIFIED EVIDENCE 133, List of Significant Deficiencies Iden- 8078 8083 ELM-10 tified by FEMA /RAC 134 United Orange County / Cities Emergency 8685 8687 Management Agreement Proposed for Adoption by City of San Juan Capistrano, September 1, 1981 0 135 Siren Coverage for Indoor Levels in 8735 8745 Populated Areas of San Juan Capistrano, San Clemente, and Populated Areas of Orange County g 136 Orange County Automatic Teletype System. 8767 8767 137 Orange County Maps of Mountaintop Trans- 8767 8767 mitters 138 Curriculum Vitae - Mr. Donald Poorman 8767 8767 0' 139 Capistrano Unified School District 8790 8802 Operational Letter, dated October, 1980 140 Capistrano Unified School District 8790 8802 Emergency cuide, dated August 24, O. 1981 141 Letter from Orange County (T. Egan) to 9034 9034 Anthony L. Palumbo, FEMA, Region IX, Director, responding to FEMA /RAC g Informal Comments, August 3, 1981 142, Offsite Dose Assessment Center (ODAC) 9144 9144 DEP-2 143, Emergency Response Plans for Ingestion 9144 9144 g DEP-3 Pathway 144, Applicants' letter, dated June 26, 1981,. 9146 9147 DFP-4 to Brian K. Grimes, NRC Staff, Office of -

I & E, and enclosures entitled "Correc-tive Actions Required to Address FEMA g Determinations of June 3, 1981, and Summary of Planned Action."

41 0

'O APPLICANTS' EXHIBITS (continuedl b ADMITTED INTO NO. EXHIBIT IDENTIFIED EVIDENCE

, 145 Letter from James W. Hunt to Mr. Brian 9287 9290 Grimes, dated June 26, 1981 146 Memorandum from Robert T. Jaske, FEMA, 9242_ 9243 to Mr. Brian Grimes, dated July 14, 1981 g 147 Draft SOP for Emergency Media Center 9245 9247

-148 Draft Emergency Information Handbook 9246 9247 149 Progress Reports to FEMA 10858 10860 a) Letter of July 16, 1981, K. P. Baskin to Ronald H. Sandwina O b) Letter of August 14, 1981, K. P. Baskin to Ronald H. Sandwina c) Letter of September 15, 1981, K. P. Baskin to Ronald H. Sandwina d) Letter of September 16, 1981, O Edward B. Rogin to Kenneth W. Nauman 150, Minutes of Meetings of Interagency 10859 10864 DFF-14 Jurisdictional Planning Committee (June 10, 1981-September 11, 1981) g 151 Responses to FEMA Evaluations By 10995 10995 a) City of San Juan Capistrano b) City of San Clemente (2) c) County of Orange 152, Draft Standard Operating Procedures 11102 11108 DEP-7 for Orange County, as of September 25, O

1981 153, Draft Standard Operating Procedures 11102 11108 DFP-8 for San Diego County, as of September 25, 1981 0 154, Draft Standard Operating Procedures for 11102 11108 DEP-9 City of San Clemente, as of September, 25, 1981 155, Draft Standard Operating Procedures for 11102 11108 g" DFP-10 City of San Juan Capistrano, as of September 25, 1981 42 0

O APPLICANTS' EXHIBITS (continued)

() ADMITTED INTO NO. EXHIBIT IDENTIFIED EVIDENCE 156, Draft Standard Operating Procedures for 11102 11108 DFP-11 State Department of Parks and Recrea-O tion, as of September 25, 1981 157, Lesson Plan: One Day General Radio- 11108 11111 DFP-12 logical Emergency Planning and Pre-paredness Training O 158, Lesson Plan: Three Day Offsite Radio- 11108 11111 DFP-13 logical Monitoring and Assessment ,

Training 159, Letter, dated September 9, 1981, to SCE, 11114 11120 g DFP-15 David F. Filmera from State of Califor- '

nia, Depar_tment of Health Services, Erik Vold, regarding IPZ Plan and Procedures O INTERVENORS' EXHIBITS ADMITTED INTO NO. EXHIBIT IDENTIFIED EVIDENCE o 1 Written Testimony of Sheldon C.

Plotkin 2 Chapter 7 from NUREC-0490 Final Environ- 9418 -

mental Statement Related to the Opera-tion of SONGS, April, 1981 0

3 Table 7.4.4-4, Supplement to Draft 9418 9477 5/

Environmental Statement Related to the Operation of SONGS 4 U.C.S. Finding on NUREG-0490 9418 -

O 5/ This exhibit was not admitted for the truth of the matters stated therein. The exhibit was solely admitted as evidence that the witness relied upon the numbers in this exhibit as representative of the O consequences which he believed should be considered for emergency planning purposes. (Tr. 9476.)

43 0

i D

INTERVENORS' EXHIBITS (continued)

)

ADMITTED INTO NO. EXHIBIT IDENTIFIED EVIDENCE 5 Article from " Geographical Review" on 9419 -

) evacuation from a nuclear technological l disaster 6 Study Done for the Office of Emergency 9419 -

Services by Science Applications j Incorporated. (pages C-160 - 167) 7 Assumption Lists Referred To In 9419 9483 Testimony 8 Earthquakes (human factors), 9419 9486 g/

) pages 33 and 34 l 9 Los Angeles-Federation of Scientists 9420 -

I Findings (referred to in testimony) 10 Working Study of Health Effects of 9569 -

] Radiation From a Nuclear Accident Over a 22.5 Sector 11 Cancer and Low Level Ionizing Radiation, 9570 -

Dr. Karl Z. Morgan, The Bulletin, j Sept. 1978

)' 12 Fatal Radiation Syndrome from an Acci- 9627 -

dental Nuclear Excursion i

13 Regional Assistance Committee (RAC) 10106 10441 Review of the San Onofre Offsite Emergency Response Plans, dated April 27, 1981 l 14 Evaluation Findings San Onofre Nuclear 10106 10441 Generating Station Offsite Emergency Response Plans Exercise, Dated May 13,

)

1981 l- p/ This exhibit was not admitted for truth of the matters asserted

! therein. The exhibit was solely admitted as evidence that the witness j had relied upon the exhibit in conducting his study. (Tr. 9485.)

t i

44

O INTERVENORS' EXHIBITS (continued) e ADMITTED INTO NO. EXHIBIT IDENTIFIED EVIDENCE 15 Interim Findings and Determination Re- 10106 10419 8 lating to the Status of State and Local Emergency Preparedness for the San Onofre Nuclear Generation Station (Units 2 and 3), Dated June 3, 1981 g 16, Evaluation by State OES of Orange County 10106 10211 MRF-1 Nuclear Power Plant Emergency Response Plan Using NUREG-0654 Criteria 16A Letter of June 3, 1981 from 10211 10211 I

Dr. Reed to Bert Turner, Emergency

, Services' Coordinator of Orange County Emergency Services 17, Evaluation by State OES of San Diego 10106 10211 MER-2 County Nuclear Power Plant Emergency Response Plan Using NUREG-0654 g Criteria 17A Letter of June 2, 1981, from 10211 10211 Dr. Reed to Jim Hunt, Emergency Services Coordinator, San Diego County, Office of Diaster 3 Preparedness 18, Evaluation by State OES of 10106 10211 MFR-3 San Clemente Nuclear Power Plant Emergency Response Plan Using NUREG-0654 Criteria D

18A Le'ter of June 2, 1981, from 10211 10211 D. Reed to Ron Coleman, Emergency Services Coordinator, City of San Clemente D 19, Evaluation by State OES of San Juan 10106 10211 MER-4 Capistrano Nuclear Power Plant Emergency Response Plan Using NUREG-0654 Criteria D

45 B

O INTERVENORS' EXHIBITS (continued)

O ADMITTED INTO NO. EXHIBIT IDENTIFIED EVIDENCE 19A Letter of June 1, 1981, from 10211 10211 0 Dr. Reed to Cynthia Ferguson, Office of Emergency Services, City of San Juan Capistrano 20, Evaluation by State OES of the 10106 10211 g MER-5 Interagency Agreement and Evacuation Procedures (IAEP)

Emergency Response Plan Using NUREG-0654 Criteria 21, Executive Summary for the 10106 10113 g CF1 California Disability Survey, Winter 1980 22, Memorandum Concerning Disabled 10106 10111 CF2 Individuals and Emergency Preparedness, dated January 15, 1981 4

23, State of California Nuclear Power 10106 10134 JK1 Plar ~_ Emergency Response Plan, dated July 1975 (revised March 1981) 24, Emergency Planning Zones for Serious 10106 3 JK2 Nuclear Power Plant Accidents, d at ec'.

November 1980 25, Evaluations by State OES of the 10212 10213 MER-6 State Parks and Recreation Emergency Response Plan Using 3 NUREG-0654 Criteria 25A Letter of June 3, 1981 from 10212 10213 Dr. Reed to Jack P. Stowe, Manager of Pendleton Coast Area, State of California Department of Parks 9 and Recreation D

46 D

l l NRC STAFF'S EXHIBITS 7/

T3 ,

ADMITTCD INTO NO. EXHIBIT IDENTIFIED EVIDENCE

,s 10 Irfant Mortality Data By Date Years 7708 -

J' l

(+ 2 Standard Deviations) l 11 Interim Findings and Determination 10413 10419 l Relating to the Status of State and l Local Emergency Preparedness to San on fre Nuclear Generating Station O (Units 2 and 3) Dated June 3, 1981 12 Safety Evaluation Report Related 10649 10650 to the Operation of San Onofre Nuclear Generating Station, Units 2 and 3, NUREG-0712, Supp. 3 iO E. Status of Testimony l 49. All of the Applicants' and the NRC Staff's prefiled O written testimony was admitted into evidence at the licensing hearing, except Applicants' testimony of Mr. G. Re. This testimony was voluntarily withdrawn pursuant to the stipulation of l

() the parties that the Dames & Moore Ingestion EPZ study (Exhibit

! #121), which was to have been sponsored by Mr. Re, could be l

l admitted into evidence. (Tr. 7525-7526.)

p) 50. The following portions of the testimony offered by Intervenors were not admitted into evidence:

l r

b 7/ Staff Exhibits 1-9 were admitted during the hearings on the geology / seismology issues. Staff Exhibit 13 was admitted during the hearings on the alternative motion for an operating license for fuel loading and low power testing.

')

47 Q

l l

O ITEM TESTIMONY NOT ADMITTED OR STRICKEN FROM THE

() EVIDENCE (a) Written T'estimony of Sheldon C. Plotkin -- From sentence beginning at p.2, line 26 through p. 3, line 7; from sentence O beginning at p. 4, line 9

.through p. 5, line 17; from sentence beginning at p. 5, line 20 through p. 5, line 27; from p. 6, line 1 O through p. 7 line 16; and from p. 9, line 15 through j

p. 9, line 20. (Tr.

9532-9537.)

(b) Written Testimony of

'g Irving Lyon -- Entire Written Testimony.

(Tr. 10717-10718.)

(c) Oral Testimony of Irving Lyon -- Tr. 9593:12-9595:25, 9691:1-9731:16, 9742:19, 9744:7,

'g 9749:6-9753:3, 9760:1-9824:22.

(Tr. 10715-10716.)

51. Applicants' pre-filed written testimony was O placed into the record of August 31, 1981. (Tr.'6995-7396.)

Intervenors' written testimony was placed into the record of September 24, 1981. (Tr. 10313.) The Staff's written g testimony was placed into the record of September 25 and 28, l

1981. (Tr. 10372, 10420, 10644, 10648.)8/

O I 8/ Written testimony placed in the record by the l

Intervenors and the Staff will be cited and referred to both by the page number (s) of the testimony itself and the page of the transcript (Tr.) immediately preceding the place where the written testimony has been inserted in the transcript.

O 48 O

O IV.

fO GENERAL FINDINGS OF FACT ON RADIOLOGICAL EMERGENCY PLANNING AND PREPAREDNESS

52. Prior to setting forth specific findings on each of the Intervenors' Contentions, it is helpful to set

,:O forth our general findings on the magnitude of the emergency we are required to consider under the NRC Regulations, the nature of the public health hazard involved in such

-Q, emergencies, and the type of preplanning required by NRC Regulations to mitigate these hazards.

g 53. Radiation injuries may result either from direct exposure to radiation or f_am prolonged contamination by radioactive materials. In the case of radiation exposure, the radiation passes through the body as it does in medical O

x-rays. While the patient suffers injury as a result of the energy deposited in the cells during the period of radiation O **P """*' th* P****"* i* " * "*di ""*i"* ""# P"***"t* "

hazard to emergency response personnel or others.

Contamination results from loose radioactive particles g adhering to the body. By definition, these particles emit radiation, but no exposure hazards remain for the contaminated person or emergency response personnel once these particles are removed. Radioactive contamination is

)

easy to detect and decontamination is easily accomplished through removal of clothes and bathing the affected areas.

(Linnemann, Tr. 7082-7084, 10817-10822.)

)

49 0

N

O l

54. Radiation exposure injuries are seldom O life-threatening and do not generally require immediate emergency treatment. Once a person has been 1; radiated, a predictable clinical course ensues which is directly 7'"

correlated with exposure dose and dose rate. This clinical course cannot be interrupted and will evolve over a period of days and weeks. (Linnemann, Tr. 7083-7084, 10819.)

O

55. A " rem" is the unit used to describe the biological effect of ionizing radiation. To measure smaller doses, dose equivalents are often expressed in " millirems".

O' One rem equals 1,000 millirems. Another important element is the time over which exposure continues and this is expressed in terms of the " dose rate," that is, the number of millirems O per hour. For example, being exposed to a constant level of 30 millirems per hour would result in a total dose of 30 millirems after an hour's time. The time of exposure is O important because a dose of radiation received over a short time results in more injury than an equivalent dose received l over a longer period of time. (Linnemann, Tr. 7085, O

10818-10819.)

l

56. The average dose from natural background

! radiation to the United States population is about 100 O

millirems per year. The average annual dose to the United States population from medical diagnostic activities is also l

l about 100 millirems per year. A single chest x-ray exposes O

the patient to a dose of about 10 millirems.

The table below '

t 50 b

O shows the acute dose-effect relationship for total body O ,

exposure from penetrating radiation delivered over a period of a.few hours:

75 rem i T,000 millirem) - symptom threshold

O 150 rem (.? ,000 millirem) - hospitalization 600 rem ( 6f 000 millirem) -

fatality without treatment.

'O (Linnemann, Tr. 7085 J86.)

57. Protective Action Guides (" PAG's") are the l projected radiological doses to individuals in the general

O public which warrant protective action following a significant release of radiation. The PAG's established by the State of California for whole body and child thyroid

O exposure for the general public are 500 millirem and 25,000 millirem respectively. These PAG's are extremely conservative and are set far belok those levels which would

!O produce detectable short-term biological effects and at levels which would minimize the risk of long-term biological effects. The whole body IAG established by the State of

O California exceeds the Environmental Protection Agency's

(" EPA") PAG for whole body dose by a significant factor. 'The EPA's PAG for whole body exposure is 1,000-5,000 millirem.

O (Exhibits #51, Section 6.4.2., #106; Murri, Tr. 7210-7211, 8010-8011.)

58. It is highly unlikely that an accident at SONGS would produce significant doses of radiation offsite.

, 51 1.0

• ty -- y iq u a y_.p...+ -

,.-..--_.y . . , _ m - , - c - ,- , ,---y w

f O

The characteristics of a release of radiation from an O

accident mitigate against-the possibility that anyone offsite would receive anywhere near a dose of radiation resulting in symptoms of radiation sickness, much less a dose requiring O

hospitalization. The exposure from a passing plume is limited to the time the plume is over a specific location; the dispersion of the radioactive atoms, reducing the O

intensity as the plume moves away from its source; the height of the plume and the distance over which a ray must travel from its source in the nucleus of an atom to the ground; and O

the protection afforded by available shelter. (Murri, Tr. 8011-8012; Linnemann, Tr. 7086-7087.)

59. Although it is highly unlikely that an-O accident at SONGS would require implementing protective actions, detailed emergency plans and procedures are required and have been developed by the Applicants and the local O

jurisdictions surrounding SONGS. (Exhibits #51-59, #95-97,

1. 122A, #134, #139, #140, #142-144, #147, #152-156.) This emergency planning is designed to encompass the entire O

spectrum of possible accidents, ranging from minor onsite occurrences up to and including accidents of much greater severity. (Murri, Tr. 7198, 7199.)

O

60. If a release were to occur offsite, exposure could occur either from direct radiation from a passing plume or from inhalation of radioactive material within the plume

O or both. (Exhibit #51, Section 4.0.) Also possible, but of 52 0

t i

D lesser concern from an immediate emergency response 3 viewpoint, is that the radioactive material could deposit on food or water supplies and present'the potential for i

i radiation exposure through the ingestion pathway. (Exhibit

)

! #51, Section 6.0; Nauman, Tr. 10940.)

61. The two basic protective actions for the offsite population are evacuation and shelter. Evacuation is

) quite straightforward and has been successfully accomplished at Three Mile Island and in many other instances for a wide variety of emergency conditions, even without the benefit of O

_ preexisting evacuation plans. (Exhibit #107; Murri, Tr.

l 7205-7206.) A recommendation, or directive, to evacuate means simply to leave the affected area in an orderly

) fashion. A recommendation, or directive, to take shelter i

requires the population to go or stay indoors, close all windows and doors, turn off air conditioning and await 3 further instructions. (Murri, Tr. 7924-7934.)

! 62. As discussed in more detail below at l .

! Paragraphs 404 through 422, the bases for recommending D specific protective actions are highly dependent on i

prevailing conditions at the time of the accident. However, l- detailed information gathering procedures are in place, both

)

for SONGS and the jurisdictions, to assist the decision-makers in d.etermining the appropriate actions.

l (Exhibits #51, Section 6.C, 2152-156.) Factors that the D

decisien-makers must consider in recommending evacuation, i

! 53 i

S sheltering or providing other instructions include: the magnitude and composition of the radioactive material release; and probability and/or expected duration of the release; meteorological conditions, such as wind speed, wind 9

direction, temperature gradient and precipitation; the estimated time required to evacuate the involved area (which includes demography, evacuation route road capacity, time of S

day, seasonable transient population, ter:ain topography and mass transportation requirements); and any other existing constraints such as temporary road conditions, fogging or any S

variety of known unusual conditions. (Exhibit #106, Section 1.3.)

v.

O FINDINGS OF FACT ON INTERVENORS' CONTENTIONS

63. An appropriate exposition of findings on the Intervenors' Contentions is best accomplished by considering S

the various issues raised by these contentions in the general order that the particular planning element er response capability involved in a contention generally becomes a S

concern in the planning process or a developing radiological emergency. Acccrdingly, the Intervenors' Contentions are considered in the reverse order of their numbering and the S

various sucparts of Contention 2 are considered in a rearranged order.

l 8

54 9

O A. CONTENTION 3 (Plume EPZ Determination).

O "The emergency response plans fail to meet the requirements of 10 C.F.R.

$50.47(c)(2) because local emergency planning officials have arbitrarily established the boundaries of the Plume Exposure EPZ in that g they have mechanically applied a 10 mile boundary and that the Interagency Agreement (IAEP) among all local jurisdictions defines the EPZ by drawing compass lines on a map of

& the area. In determining the exact size of the EPZ, emergency planning officials have

.O failed to consider the following local conditions:

1. topography

2. meteorology

3. evacuation routes O 4. demography

5. jurisdictional boundaries

6. SAI report

7. land characteristics."

1. Introduction

'O

64. Messrs. D. F. Filmer and B. T. Brothers were the primary witnesses for the Applicants; and Mr. J. Kearns was the primary witness for Intervenors, regarding the O

geographic description of the Plume EPZ and the Extended EPZ. The Staff did not present any witnesses directly on this subject. (Pilmer, Tr. 7368-7372; Brothers, O

Tr. 'T'G-7277; Kearns, Tr. 10147-10150.)

65. Mr. 3. K. Grimeo was the prAmary witness for the Staff regarding the planning rationale for the

O development of a generic Plume EPZ of about ten miles.

Applicants and the Intervenors did not present any witnesses directly on this subject. (Grimes, Tr. 10997-11002.)

O 55 O

D

66. Messrs. D. F. Pilmer, E. L. Murri, K. Woodard, D

E. S. Turner, J. W. Hunt, Col. J. E. Wallace, and Ms. C. S.

Ferguson were the primary witnesses for the Applicants; and Mr. J. Kearns was the primary witness for Intervenors, D

regarding procedures followed by local officials in adopting the Plume EPZ. The Staff did not present any witneses directly on this subject. (Pilmer, Tr. 7371; Murri, S

Tr. 7260-7261; Woodard, Tr. 7336; Turner, Tr. 8910-8911; Ferguson, Tr. 8725; Hunt, Tr. 9263-9264; Wallace, Tr. 3322; Kearns, Tr. 10152, 10163.)

D

67. Messrs. D. F. Filmer and K. Woodard were the primary witnesses for the Applicants; and Messrs. K. W.

Nauman and J. R. Sears were the primary witnesses for the B

Staff regarding the technical validity of the Plume EPZ boundaries for SONGS. Intervenors did not present any witnesses directly on this subject. (Filmer, Tr. 7368-7370; D

Woodard Tr. 7332-7338; Nauman, written testimony

( Septenter 16, 1981), p. 1, Tr. 10420; Sears, written testimony (August 4, 1981), pp. 1-4, Tr. 10648.)

B

68. Messrs. D. F. Filmer, B. T. Brothers, and E. N. Cramer were the primary witnesses for the Applicants; and Mr. J. Kearns .as the primary witness for the D

Intervenors, regarding planning for the Extended EPZ. The Staff did nct present any witnesses directly on this subject. (Brothers, Tr. 7276-7277; Pilmer, Tr. 7371-7372:

D Cramer, Tr. 7040-7041; Kearns, Tr. 10163-10167.)

56 D

O

2. Description of the Plume EPZ and the Extended EPZ.

.-)

(a) The Plume EPZ ,

/

69. The boundaries of the Plume EPZ is a radius of O approximately 10 miles (16km) around SONGS. The boundary was established by the involved local planning officials with the assistance of Applicants after consideration of NRC O

Regulations and related guidelines and the characteristics of i

the SONGS environs. (Pilmer, Tr. 7368- 7371.)

70. The boundary in the northern sector of the O

Plume EPZ was established along the San Juan Creek, from its termination at the beach to the inland point where it passes beneath the Ortega Highway. This portion cf the San Juan O

Creek generally lies at a radius of about 10 miles from SONGS. (Exhibit #59, Attachment 2; Pilmer, Tr. 7370.)

71. In all other directions, with one minor O

exception, the Plume EPZ radius is defined as being 10 miles from SONGS without any reference to geographical features or jurisdictional boundaries. The exception is a very small O

portion of Riverside County, less than one-half square mile, whi:h was excluded from the Plume EPZ, even though it is included within the 10-mile radius, due to the rugged terrain 0

and totally unpopulated nature of this isolated area.

(Exhibit #59, Attachment 2; Pilmer, Tr. 7370, 9224;. Brothers, Tr. 7277.)

O 57 O

1 O

'i

72. As so defined, the Plume EPZ encompasses the O entire City of San Clemente; the unincorporated community of  ;

Capistrano Beach; the northern section of the U.S. . Marine Corps Base, Camp Pendleton, including lands leased by the O California Department of Parks and Recreation; and the portion of the City of San Juan Capistrano south of the San

[

Juan Creek. The unincorporated community of Dana Point and O

the portion of the City of San Juan Capistrano north of the San Juan Creek are outside of the Plume EPZ. (Exhibit #59, Attachment 2; Pilmer, Tr. 7370-7371.) ,

O (b) The Extended EPZ

73. The Extended EPZ is defined as an area within about a 12-mile radius of SONGS north of the site. In 0 addition to the area included in the Plume EPZ, the Extended EPZ includes the community of Dana Point and all portions of the City of San Juan Capistrano not included in the Plume O

EPZ. (Exhibit #132, Figures 2a, 2b; Pilmer, Tr. 7372, 9186-9187; Brothers, Tr. 7276-7277, 8029.)

3. The Rationales for the Generic 10-mile O EPZ Determination.

74. The NRC regulation on the establishment of the Plume EPZ is provided in 10 C.F.R. 650.47(c)(2):

O " Generally, the plume exposure pathway EPZ for nuclear power plants shall consist of an area about 10 miles (lokm) in radius . . . .

The exact size and configuration of the EPZs surrounding a particular nuclear power reactor shall be determined in relation to O the local emergency response needs and capabilities as they are affected by such 58 O

l

i D

conditions as demography, topography, land characteristics, access routes, and O jurisdictional boundaries . . . ."

75. This regulation was based upon the findings of the NRC/ EPA Task Force on Emergency Planning (the " Task O

Force"). (45 Fed. Reg. 55406, August 19, 1980.) The Task Force determinations, which were initially published in NUREG-03S6, recommended a generic Plume EPZ around nuclear O

power plants of about ten miles, with the exact dimensions of the zone to be adjusted in or out by local planning officials depending upon the characteristi:s of a particular site. The O

Task Force recommendation was adopted as a planning. criterion in NUREG-0654 and the Commission formally adopted the Task Force recommendation as a regulation in 10 C.F.R.

O 550.47(c)(2), effective November 3, 1980. (Grimes, Tr.

! 10998-11002; 10 C.F.R. 550.47(c)(2); NUREG-0396, pp. 15-17; NUREG-0654, pp. 10-13; see 45 Fed. Reg. 55406, August 19, O

l 1981.)

76. The Task Force reasoned that detailed emergency planning within a 10-mile radius would provide a O

substantial base for ad hoc expansion of response efforts

! outside this radius in the unlikely event it should ever be i

needed. With the substantial preplanning and organizational O

capability available within the 10-mile radius, expansion

into areas outside of the 10-mile radius could be accomplished in a fairly efficient manner even though there O

l l 59

'O L

)

was no specific preplanning for these areas. (Grimes, Tr.

) 11001; NUREG-0396, pp. 15-16.)

77. The Task Force made its recommendation after considering the full spectrum of accidents, including the

) most serious loss of coolant / breach of containment type accidents, and the corresponding consequences of these accidents tempered by probability considerations. Its

) conclusion was that a generic 10-mile Plume EPZ provided reasonable assurance that even for most core melt accidents, using EPA Protective Action Guidel:.tes, no protective actions

) -

would be necessary beyond a distance of about 10 miles.

(Grimes, Tr. 11000; NUREG-0396, pp. 15-17 and Appendix 1.)

78. Although the rationale for the generic 10-mile Plume EPZ implies a circular area, the actual shape depends upon the characteristics of a particular site. In determining the actual Plume EPZ, consideration should be given to the local emergency response needs and capabilities as they are affected by such characteristics as demography, topography, land characteristics, access routes, and jurisdictional boundaries. Judgments in this regard are to be left to the discretion of local emergency planning i

l officials. (10 C.F.R. 550.47(c)(2); NUREG-0654, p. 11;

) 45 Fed. Reg. 55406, August 19, 1980.)

)

60

)

)

4. The Basis and Technical Validity of the Plume EPZ Determination

79. In establishing the Plume EPZ for SONGS, the Applicants considered the technical basis for the NRC Regulations which require the establishment of a Plume EPZ.

3 In particular, the results of the Task Force set forth in NUREG-0396 were studied. (Pilmer, T r. . 7368.)

80. SCE also contracted with consultants NUS 3

Corporation ("NUS"), and Pickard, Lowe and Garrick ("PL&G")

to assist in determining and verifying appropriate Plume EPZ 3) boundaries. (Pilmer, Tr. 7367-7372; Murri, Tr. 7259-7261; Woodard, Tr. 7335-7338.)

81. The Applicants compared the site-specific

3) factors for SONGS with the same factors considered generically by the NRC in arriving at the conclusion that the Plume EPZ should be "about 10 miles (16 km) in radius".

3 (10 C.F.R. $$ 50.33(g), 50.47(c)(2)). The most important factors which went into this comparison were:

a. The probabilities and consequences cf the 3 accident sequences given in the Reactor Safety Study ("RSS"), upon which NUREG-0396 relied;

b. Atmospheric dispersion characteristics, 3 including terrain effects and local meteorological conditions; and

c. Local demography. (Pilmer, Tr. 7368-7369.)

3 l

i i

61 D

,0

82. Consideration of the first factor listed above I) resulted in a judgment that most accident sequences e insidered in the RSS have lower probabilities of occurrence at SONGS than assumed by the NRC in establishing the generic r)

Plume EPZ. (Pilmer, Tr. 7369; Woodard, Tr. 7332-7336.)

83.

The second factor was also judged to be more favorable for SONGS than t' hat considered in the RSS and

'O NUREG-0396 because of the larger dispersion factors associated with the rougher terrain at SONGS; the tendency for greater frequency of unstable atmospheric conditions; and i

'O the generally better dispersion conditions characteristic of coastal sites. (Pilmer, Tr. 7369.)

84. The population density near the site is O

similar to the population density used in the RSS, so the third factor was about the same as that used by the NRC in NUREG-0396. (Filmer, Tr. 7369.)

'd 85. The effect of the first two factors is to reduce the expected risk for similar accident conditions considered by the NRC in establishing the Plume EPZ dimension

'O of "about 10 miles (16 km) in radius." From this analysis, it was generally concluded that the Plume EPZ need not be larger than 10 miles. (Pilmer, Tr. 7369.)

O

86. The Applicants then considered the configuration of jurisdictional boundaries, topography, con figuration of evacuation roadways, and distinct land O

characteristics. In the populated areas around Dana Point 62 0

O-and San Juan Capistrano, it was noted that the San Juan Creek I) is a highly distinctive land characteristic which creates a natural open space between residential communities. This open space is generally arouna 1/4 mile or greater in width O and is not subject to future encroachment. For this reason, the San Juan Creek was chosen as a desirable Plume EPZ boundary from*its termination at the beach, to the inland

'O point where it passes beneath the Ortega Highway. (Murri, Tr. 7260-7261; Pilner, Tr. 7370.)

87. In all other directions, there was found to be no populated areas generally between a 9 and 12 mile radius from SONGS. Therefore, the Plume EPZ was simply defined as i

being 10 miles in radius without any reference to

'O geographical features or jurisdictional boundaries, with the one minor exception concerning Riverside County discussed in Paragraph 71 above. (Pilmer, Tr. 7370.)

>O-

88. Science Applications, Inc. performed a study (the "SAI Report") for the State of California analyzing the consequences of nuclear power plant accidents using

O site-specific data from SONGS and a methodology similar to that used in the RSS. At Applicants' request, PL&G analyzed the SAI Report to determine whether the data in that report i

O supported the Plume EPZ established for SONGS. Mr. K.

Woodard cf FL&G testified concerning the results of that analysis. Mr. Woodard concluded that the results of the SAI Report show that the NRC planning rationale is conservative t

63

.O

O for SONGS. This is because the probability of exceeding O whole-body doses given a core melt accident at any given distance is significantly lower for SONGS than for the sites used by the NRC in establishing its generic Plume EPZ.

O Moreover, based on the data in the SAI Report, the probability of core melt accidents for SONGS is found to be the same in NUREG-0396 as the probability of core melt O' accidents used as the basis for establishing the NRC Regulations. Thus, M*. Woodard concluded that the SAI Report supports the conser,atism of the NRC Regulations as applied

')

to the Plume EPZ. (Exhibits #119, #120; Woodard, Tr. 7332-7336.) ,

89. Mr. Woodard further explained that the CRAC O

computer program, as used in the SAI Report, takes meteorological, demographic, and topographic conditions in the SONGS vicinity into account in a conservative manner; and O

that if actual meteorological data, terrain conditions, and population distribution information had been more vigorously accounted for in the SAI Report, the Plume EPZ for SONGS O

would be seen to be even more conservative. (Woodard, Tr. 7337-7338.)

90. The results of the PL&G analysis were reported a

to the Counties by PL&G and SCE. (Woodard, Tr. 7336-7337.)

lC 64

O l

t

O

5. The Procedure Followed by Local Officials in Adopting the Plume EPZ.

O-

91. 'The Applicants analyzed the consultants' recommendations, along with their own analyses, and recommended to the emergency planning officials of Orange County and the City of San Juan Capistrano, the Plume EPZ as it is defined above. (Pilmer, Tr. 7371, 9183; Murri, Tr.

7261; Turner, Tr. 8910-8911; Ferguson, Tr. 8725.)

O

92. Orange County and San Juan Capistrano planning officials found the Applicants' recommended Plume EPZ .

g acceptable and adopted it for their emergency planning.

(Exhibits #53, p. I-3, Fig. 1-1, Exhibit #55, p. I-6, Fig. 1; Pilmer, Tr. 7371, 9183-9184; Turner, Tr. 8910-8911; Ferguson, O Tr. 8725.)

93. The Applicants also presented their Plume EPZ recommendation to emergency planning officials of San Diego County and the USMC. The Applicants' recommendation was O

found acceptable by planning officials and adopted for their emergency planning. (Exhibits #54, p. I-2, #58, g p. K-3-D-(3)-3; Pilmer, Tr. 9183-9184; Hunt, Tr. 9263, 9292; Wallace, Tr. 9322.)

6. Rationale for Establishment of the Extended EPZ.

i

~O

94. In the process of working with local j jurisdictions in developing the Plume EPZ boundaries, the Applicants identified certain desirable planning elements

!O that both the Applicants and local jurisdictions considered i

e t

65 iO

r i

O to be above and beyond those required by the NRC O Regulations. Particularly, ther.e was a desire to have l omergency planning for evacuation purposes encompass the en; ire city of San Juan Capistrano and the unincorporated O community of Dana Point. (Pilmer, Tr. 9186-9187; Turner, l

Tr. 8910; Ferguson, Tr. 8725-8728.)

l

95. Thus, detailed traffic studies, evacuation

) time estimates, and evacuation plans have been done throughout San Juan Capistrano and Dana Point. (Exhibit

1. 132, p. 2-3, #53, #56; Brothers, Tr. 7276-7277.)

C 96. Public education materials have also been distributed throughout San Juan Capistrano and Dana Point sad public education seminars will also be held in these areas.

D (Cramer, Tr. 7040-7041.)

97. Sirens have not been placed in the Extended EPZ, but sirens located in the Plume EPZ will be audible in D the Extended EPZ, although the sound levels will be less than the Federal standard for areas within the Plume EPZ. This fact is not critical because helicopters and emergency 3 vehicles equipped with loudspeakers are available to alert and notify the public within the Extended EPZ within about the 45 minute period suggested for the area beyond a 5-mile 3 radius of SONGS in NUREG-0654, Appendix 3, p. 3-3. (Exhibit

1. 53,Section V.S.2.a.(1); Turner, Tr. 8916; Coleman, Tr.

, 8597-8598; Killingsworth, Tr. 8271-8281; Nauman, Tr. 10509; 3

l Pilmer, Tr. 7372; Dubois, Tr. 6931.)

, 66 l

)

O

' 7. Conclusions O 98. Local planning officials did not arbitrarily establish the boundaries of the Plume EPZ or the Extended EPZ. The Plume EPZ recommended by the Applicants and adopted O by the local jurisdictions appropriate.ly takes into account local topography, meteorology, evacuation routes, demography, jurisdictional boundaries, land characteristics and the SAI O Report. The Plume EPZ is adequate to protect the public health and safety. The Extended EPZ provides additional protection for the public health and safety.

O B. Contention 2F (Emergency Response and Augmentation Capability).

"Whether there is reasonable assurance that the emcrgency response planning and capability of implementation for SONGS 2 and b) 3, affecting the offsite transient and permanent population, will comply with 10 C.F.R. S 50.47(a)(1) and (b) or (c)(1) as follows:

C) F. the capability of each principal I response organization to respond and to i augment this initial response on a continuous basis, 10 C.F.R.

S 50.57(b)(1); . . . .

[) 1. Introduction

99. Mr. E. L. Murri, Mrs. J.-M. Swanson and Ms.

l C. S. Ferguson were the primary witnesses for the Applicants;

)' Mr. J. Kearns was the primary witness for Intervenors; and Mr. K. W. Nauman was the primary witness for the Staff regarding the identification of principal and supporting O offsite response organizations. (Murri, Tr. 7247: Swanson, 67

(

D t

, e~ - - - , - . o -w-,

O Tr. 8792-8793; Ferguson, Tr. 8684-E;85; Kearns, Tr.

O 10169-10170, 10176-10177; Nauman, Tr. 10546.)

100. Messrs. H. B. Ray, D. F. Filmer, E. L. Murri, J. L. Willis, B. Killingsworth, D. E. Roper, C. Nash, J. P. i O Stowe, R. J. Coleman, J. W. Hunt, Col. J. E. Wallace, Ms.

C. S. Ferguson, and Mrs. J. M. Swanson were the primary witnesses for Applicants; and Mr. J. R. Sears and Mr. K. W.

O Nauman were the primary witnesses for the Staff as regards ,

the capability of principal and supporting response organizations tt initially respond to a radiological O

emergency at SONGS 2 and 3 and to augment this initial response on a continuous basis. Intervenors did not present any witnesses directly on this subject. (Ray, Tr. 7130-7140; O

Pilmer, Tr. 7375-7377; Murri, Tr. 7247-7248; Willis, Tr. 7025-7032; Killingsworth, Tr. 8272; Roper, Tr. 8336; Nash, Tr. 8430; Stowe, Tr. 8501-8503; Coleman, Tr. 8588;

O Ferguson, Tr. 8698; Swanson, Tr. 8808; Hunt, Tr. 9267; Wallace, Tr. 9332; Sears, written testimony.(August 6, 1981),

p. 9, Tr. 10644; Nauman, written testimony (August 24, 1981)

O

p. 10, Tr. 10372.)

2. Identification of Principal and Supporting Response Organizations.

O 101. Numerous public and private organizations are potentially involved in responding to a radiological emergency involving SONGS 2 & 3, depending on the severity oi

~O 68 O

O the emergency involved. -(Exhibit #51, Section 5; Ray, Tr.

O 7129-7156; Murri, Tr. 7246-7249.)

102. At the federal level, the NRC and FEMA have the primary roles in planning and coordinating the Federal O response to a commercial nuclear power plant accident. The Department of Energy has a major technical support function in the area of offsite radiological monitoring and dose O assessment. Other federal agencies with a potential role to play include the Departments of Agriculture, Commerce, Defense, Health and Human Services, and Transportation, the O Environmental Protection Agency, and the National Communict.tions Systen. (See National Radiological Emergency Precaredness/Resoonse Plan for Commercial Nuclear Power Plant O Accidents (Master Plan), 45 Fed. Reg. 84910 et seq.,

December 23, 1980.)

103. At the State level, the State OES har the O primary role of coordinating the State of California response to a cc.nmercial nuclear power plant accident. In this regard, the State OES has assigned the " lead role" for

!O planning and responding in the event of a radiological emergency to the involved local jurisdictions. (Exhibit #52, Sections IV.C, V.C, Intervenors' Exhibit #23, Sections III.A O

and B., IV.C, V.; Kearns, Tr. 10169-10170, 10176.)

104. State OES has assigned the various support resperisibilities to the appropriate State agencies, and will

!O take the lead in requesting Federal assistance in the event 69

,0

O the emergency exceeds the capabilities of local and State

• government. Major technical support in the area of offsite radiological monitoring and dose assessment for both the Plume and the Ingestion EPZ, has been assigned to the State S

Department of Health Services (" State DHS"). (Exhibit #52, Sections V.B.2.b., VI.C.2. and D.; Intervenors' Exhibit #23, Sections IV.B.2.b., V.C.2. and D.; Kearns, Tr. 10177.)

6 105. At the local level, numerous Federal, State and municipal agencies have plans and procedures to respond to an emergency condition at SONGS. These agencies include D

the United States Marine Corp - Camp Pendleton ("USMC"), the U.S. Coast Guard (San Diego), the State Department of Transportation, District 7 ("CALTRANS"), the California 9

Highway Patrol, Border Division (the "CHP"), the Pendleton Coast Office of the State Department of Parks and Recreation

(" State Parks"), San Diego and Orange Counties (the D

" Counties"), the Cities of San Juan Capistrano and San Clemente (the " Cities"), and the Capistrano Unified School District (the " District"). (Exhibits #53-58, #139, #140);

9 Turner, Tr. 8901-8902; Hunt, Tr. 9261; Coleman, Tr. 8573; Ferguson Tr. 8692-8693; Stowe, Tr. 8489; Wallace, Tr 9321; Swanson, Tr. 8799-8802; Roper, Tr. 8332-8333; Killingsworth, D

Tr. 8267-8268.)

106. In addition, a number of private organizations have plans, procedures, or other arrangements to respond to 9

an energency condition at SONGS. In particular, SCE has a l

70 9

i D

well-developed onsite 'and offsite response organization D capable of providing extensive onsite and offsite emergency response activities. Other private response organizations with procedures and other arrangements to assist SCE or other 3 offsite response organizations in emergency activities are the Red Cross (Orange County Chapter); Tri-City, South Coast and San Clemente General hospitals; Scudder and Superior 3 Ambulance Services; Pacific Gas & Electric Company, Sacramento Municipal Utility District, Environmental Analysis Laboratories, General Atomics Corporation, Bechtel Power 3 Corporation, Combustion Engineering, and the Institute for Nuclear Power Operations. (Exhibits #51, Appendix A, #95,

1. 96, #97, #101; Nash, Tr. 8422-8423; Ray, Tr. 7136-7138, D 7837-7840; Linneman, Tr. 7108.)

107. Not all of the foregoing organizations having potential involvement in emergency activities. involving SONGS 2 & 3 should be considered " principal response organizations" as that phrase is used in 10 C.F.R. 5 50.47(b)(1). Based on the testimony and the exhibits in this case, the " principal

response organizations" involved in emergency planning and l preparedness for SONGS 2 & 3 are o SCE; o The Orange County General Services Agency, l

Emergency Services Division; o USMC; 9 o The City of San Clemente; 1

I f 71

?

t

i f

!O l

l o The Unified San Diego County, Office of Disaster Preparedness; and o State Parks.

l All of the other potentially involved organizations are deemed for purposes of these findings to be supporting Q,

emergency response organizations. (Murri, Tr. 7247; Nauman, l

Tr. 10546.)

g 108. The District and the City of San Juan Capistrano are not principal response organizations. The

! District principally relies on the emergency resources of l

g Orange County and the City of San Clemente. The City of San  ;

Juan Capistrano principally relies on the emergency resources i l

r of Orange County. (Murri, Tr. 7247; Swanson, Tr. 8792-8793; i

'g Ferguson, Tr. 8684-8685; Nauman, Tr. 10546.)

3. Capability of Principal and Supporting Emergency Response Organizations to Initially Respond and to Augment their Response on a Continuous Basis.

l D 109. A considerable amount of evidence was admitted I

pertaining to the capability of principal and supporting .

l emergency response organizations tc initially respond and to r

O augment this response on continuous basis.

l

! (a) Southern California Edison Company.

l l 110. The Station Manager of SONGS 2 & 3, as the O onsite Emergency Coordinator, is directly in charge of and i responsible for the organization and direction of emergency response personnel at SONGS 2 & 3. The current Station O

1 72

) ,

r

T l

b l

l Manager is Mr. H. B. Ray who testified at the hearing. (Ray, D Tr. 7129) 111. The control of emergencies from an organizational perspective is fully described in the SONGS 2 D and 3 Emergency Plan (Exhibit #51). SONGS personnel have been organized to cover the essential functions and responsiblities which are critical in responding to any D foreseeable emergency at SONGS 2 & 3. (Exhibit #51, Section 5; Ray, Tr. 7130; Sears, written testimony (August 6, 1981),

p. 8, Tr. 10644.)

D 112. The level of emergency responso staffing onsite at SONGS 2 & 3 prior to July 1, 1982 will be in accordance with NRC Generic letter 81-10, dated February 18,

) 1981. The level of emergency response staffing onsite at SONGS 2 & 3 by July 1, 1982 will be in accordance with Table B-1 of NUREG-0654. (Staff Exhibit #12, p. 13-1; Ray, Tr.

)

7131; Sears, written testimony (August 6, 1981), pp. 8-9, Tr.

10644.)

113. Additional SONGS personnel can be called in

) from offsite on a 24-hour per day basis. In addition to those already onsite, qualified personnel can be present within 30 minutes to perform the accident assessment

)

i functions listed in Table 3-1 of NUREG-0654. The additional recuired personnel can be present within 60 minutes. (Staff Exhibit 412, p. 13-1; Ray, Tr. 7131, 7845-7847; Sears,

)

! written testimony ( August 6, 1981), p. 9, Tr. 10644.)

l 73 l

t

)

114. Additional executive, administrative, D communications and engineering support is available from the SCE Corporate Radiological Emergency Support Organization

("ESO"). The ESO consists of the SCE Vice President D responsible for Nuclear Engineering and Operations Services, senior managers and technical specialists from the Nuclear Engineering and Operations Department and various other SCE departments. This support group provides services in an emergency to the SCE onsite emergency organization, as well s as to various offsite emergency response organizations. ESO S

emergency logistical support will include providing for the necessary transportation, communications, temporary quarters, food and water, sanitary facilities, and procurement of O'

special supplies and equipment. The ESO is also responsible for carrying out the duties and responsibilities assigned to a licensee in the operation of the offsite Emergency 9

Operations Facility (" EOF"). (Exhibit #51, Section 5.3; Ray, Tr. 7134; Pilmer, Tr. 7375-7377; see NUREG-0654, II.B.2, NUREG-0696.)

S 115. SCE has identified the offsite services to be provided by participating governmental agencies, ambulance companies, doctors and hospitals. SCE has executed written 9

agreements with CALTRANS, the USMC, three local hospitals, two ambulance ccmpanies, three doctors, an environmental analysis laboratory, and a firm specializing in the treatment 9

of radiation injuries. The various offsite emergency 74 9

D response plans adepted by the State of California, the O Counties, the Cities and State Parks constitute written agreements of emergency cooperation and assistance under California law. (Exhibit #51, Appendix A, #100; Ray, Tr.

U 7140; see 'al. Govs Code 55 8615-8617.)

lit in addi' tion to the technical support available from off-duty SONGS personnel and the ESO, technical support O can also be obtained by SCE from Bechtel Power Corporation's on-call emergency support team, Combustion Engineering's emergency response group, and the Radiological Protection and O

Emergency Preparedness Division (the "RP&EP") of the Institute for Nuclear Power Operations. The RP&EP has established an Emergency Response Center, with a 24-hour per 9

day response capability, to support utilities in the event of a radiological emergency. SCE, Pacific Gas & Electric Company, and the Sacramento Municipal Utility District (the O

" Companies") have also executed a mutual aid agreement to provide emergency assistance in the form of equipment and personnel, to assist in radiological monitoring, laboratory 9

analysis, decontamination efforts, and 2ecovery operations.

(Exhibit #101; Ray, Tr. 7136-7138.)

117. SCE has sufficient trained personnel to e

sustain onsite emergency operation for a protracted period.

p (Exhi'it #51, Section 5.2.5; Ray, Tr. 7138-7139.)

118. On May 13, 1981, an exercise of the ESO and O

SCE's onsite emergency response organization was conducted 75 9

l i

_ _ _ _ _ _ _ _ . _ ]

D and evaluated by an NRC Staff inspection team. No items of 3 noncompliance with NRC requirements were identified within the scope of this inspection. (Exhibit #162, p.1.)

119. SCE has established a program for maintaining its capability to respond to a radiological emergency and to augment this capability on a continuous basis. This program includes on-going training, periodic drills and annual

~

exercises, routine maintenance and inventory of emergency equipment and supplies, and an annual plan review.

(Exhibit #51, Section 8; Willis, Tr. 7025-7032; Linneman, -

D Tr. 7104.)

120. Based on the substantial uncontroverted -

evidence in the record, there is reasonable assurance that at

) the time of initial fuel loading for SONGS 2, SCE will have l

l the capability to respond to emergencies at SONGS 2 & 3 and to augment this initial response on a continuous basis.

D (Staff Exhibit 41, p. 13-3; Staff Exhibit #12, p. 13-1; Ray, l

Tr 7140-7141; Pilmer, written testimony (September 21, 1981)

p. 1, Tr. 11243; Sears, written testimony (August 6, 1981),

D p. 9, Tr. 10644-10645.)

I l (b) Principal Offsite Response Organizations.

j 121. Each of the principal offsite response

)

l organizations (which are identified in Paragraph 107 above) l has adopted a radiological emergency, plan that describes the l capability of each principal response organi=ation to

)

l initially respond and to augment this initial response on a

! continuous basis, as recommended in NUREG-0654, II.A.4.

76

)

t i

O (Exhibit #112 (local plan cross-reference table) 9/; Murri, d) Tr. 7248.) This planning has been generally-approved by FEMA. (Nauman, written testimony ( August 24, 1981), p. 10, Tr. 10372.)

O 122. Each of these principal offsite organizations functions on a 24-hour per day basis and responds to i emergency conditions on a regular basis enough to assure an lO 1 ongoing general emergency preparedness capability. (Murri, Tr. 7202, 7248, 7907-7911; Hunt, Tr. 9259, 9266; Turner, Tr.

4 8913; Stowe, Tr. 8490-8491; Wallace, Tr. 9318, 9332; Coleman,

O Tr. 8584; Nauman, written testimony (August 24, 1981) p. 10, Tr. 10372.)

123. Each of these principal organizations has iO

sufficient equipment and personnel, as well as access to additional equipment and personnel from the larger Federal, State and local jurisdictions of which they are part or with which they have mutual aid agreements. For example, the Counties can call on the substantial resources of CHP, CALTRANS, the National Guard, and State DHS. Private

'O organications such as the Red Cross can also be called upon for assistance. (Exhibits #53,Section IV, #54,Section IV; Murri, Tr. 7248-7249; Hunt, Tr. 9267; Turner, Tr. 8923-8924; O

9/ To expedite citation and reference to the various provisions in the local radiological emergency plans applicable to a particular finding, Applicants will refer

'O herein to Exhibit #112, which is a table cross-referencing NUREG-0654 Evaluation Criteria to the SONGS Offsite Emergency Response Plans reviewed by FEMA.

77 O

i l

l Stowe, Tr. 8501-8503; Wallace, Tr. 9332; Coleman, Tr. 8588; Nauman, Tr. 10928-10929.)

124. Each of these State agencies and local jurisdictions have a legal obligation under State law, as

) well as a demonstrated professional commitment, to protect the public health and safety of persons within their

jurisdiction, regardless of the nature of the public hazard,

)

t as well as to render mutual aid in support of the other l

l principal response organizations. (Murri, Tr. 7249; see Cal.

l Gov. Code $$ 8596, 8616.)

D 125. Each of the principal organization's has j

demonstrated the capability to respond, coordinate and l augment this response during the May 13 exercise. (Exhibits-

) #110, #141, #145, #151; Intervenors' Exhibit #14,Section II; i Murri, Tr. 7261-7263; Hunt, Tr. 9287; Fox, Tr. 9034-9035; Coleman, Tr. 8619-8621.)

)

l 126. Based on the substantial evidence in the i

i record, there is reasonable assurance that the principal

! offsite emergency response organizations have the capability to respond to emergencies at SONGS 2 & 3 and to augment this 1

initial response on a continuous basis.

(c) Supporting Offsite Emergency Response Organi=ations.

127. The CHP has substantial resources and existing procedures to initially respond to an cmergency at SONGS 2 &

)

78

)

O 3 and to augment this initial response on a continuous C) basis. (Killingsworth, Tr. 8272.)

128. CALTRANS has substantial resources and-existing procedures to initially respond to an emergency at O SONGS 2 & 3 and to augment this response on a continuous basis. (Roper, Tr. 8336.)

129. Red Cross has substantial resources and O

existing procedures to initially respond to an emergency.at SONGS 2 & 3 and to augment this response on a continuous basis. (Ncsh, Tr. 8430.)

0 130. The State of California has substantial resources and existing procedures to initially respond to an emergency at SONGS 2 & 3 and to augment this respond on a O

continuous basis. (Kearns, Tr. 10170, 10177) 131. The CHP, CALTRANS, the Red Cross and the State of California (and particularly State OES) function on a 24 O

hour per. day basis and respond to emergency conditions on a regular basis which assures an ongoing preparedness capability and effort. (Killingsworth, Tr. 8270-8271; Roper, O

Tr. 8360-8362; Nash, Tr. 8425, 6436; Reed, Tr. 10258.)

132. The City of San Juan Capistrano, while principally relying on the emergency response resources of-O Orange County, has sufficient plans ;nd has, or has access to, sufficient equipment and personnel to adequately perform its limited initial and on-going emergency response O -

functions. (Exhibits #56, 155; Ferguson, Tr. 8698.)

79 O

~

l l

l 133. The Capistrano Unified School District, while 3 principally relying on the emergency resources of Orange i

County and the City of San Clemente, has sufficient plans and I implementing procedures and has, or has access to, sufficient  !

) equipment and personnel to adequately perform its limited initial and on-going emergency response functions. (Exhibits

1. 139, 140; Swanson, Tr. 8808.)

D 134. There is reasonable assurance that the supporting organizations have the necessary capability to fulfill their functions in emergencies at , SONGS 2 & 3 and to D assist the principal response organizations in responding to emergencies at SONGS 2 & 3. The existence of this substantial back-up emergency response capability within D

various supporting emergency response organizations at the Federal, State and local level, available through mutual assistance agreements, private arrangements, or general State D law, provides additional support for che finding that there is reasonable assurance that the principal emergency response organizations have the capability to initially respond to a

) radiological emergency at SONGS 2 & 3 and augment this response on a continuous basis.

C. CONTENTION 2A (Emergency Response

]) Organization Notification and Continuous Communication Cacacity).

"Whether there is a reasonable assurance that the emergency response planning and capability of implementation for SONGS 2 and Y

l 80

)

O 4

3, affecting the offsite~ transient and permanent population, will comply with 10

O C.F.R. 6 50.47(a)(1) and (b) or (c)(1) as regards:

i A. The. procedures for notification by

.g Applicants of State and local response organizations, 10 C.F.R. 5 50.47 (b)(5),

and for notification of and continued communication among emergency oersonnel by all involved organizations, 10 C.F.R.

$ 50.47(b)(6); . . . ."

1. Introduction j 135. Messrs. H. B. Ray, E. L. Murri, and D. F. Filmer were the primary witnesses for the Applicants;

! and Mr. J. R. Sears was the primary witness for the Staff regarding SCE's procedures and capability to' implement notification of State and local response organizations.

!O

Intervenors did not present any witnesses directly on this subject. (Ray, Tr. 7141-7151; Murri, Tr. 7227-7228

Pilmer, i

Tr. 7372-7375; Sears, written testimony (August 6, 1981),

10 .

i pp. 3-5, Tr. 10644.)

I 136. In addition, representatives of the various 4nvolved Federal, State and local jurisdictions and agencies O

described their systems and procedures for receiving such i

notification. (Killingsworth, Tr. 8269-8270; Roper, Tr. 8334; Nach, Tr. 8425; Stowe, Tr. 8490-8491; Coleman, ,

!O Tr. 8584; Ferguson, Tr. 8698; Swanson, Tr. 8797-8799; Turner, i Tr. 8913-8914; Fox, Tr. 9040; Poorman, Tr. 8760.; Hunt, I

Tr. 9266; Wallace, Tr. 9332.)

!O l

81 lO i

IO 137. Messrs. H. B. Ray, B. Killingsworth, 4

3) D. H. Roper, C. Nash, J. P. Stowe, R .' J. Coleman, E. S. Turner, D. W. Poorman, J. W. Hunt, Col. J. E. Wallace, Ms. C. S. Ferguson, Ms. B. Fox and Mrs. J. M. Swanson were-

"3 the primary witnesses for the Applicants; Ms. J. Goodwin and Dr. M. F. Reed were the primary witnesses for the Intervenors; and Messrs. J. R. Sears and K. W. Nauman were

'O the primary witnesses for the Staff, regarding procedures and capability to implement notification of emergency personnel by each involved organization. (Ray, Tr. 7130-7131;

. n" Killingsworth, Tr. 8268; Roper, Tr. 8332-8335; Nash, Tr. 8424-8427; Stowe, Tr. 8492; Coleman, Tr. 8584-8585; Ferguson, Tr. 8690; Swanson, Tr. 8797-8799; Turner, Tr. 8913;

n' Poorman, Tr. 8756-8757; Fox, Tr. 9041-9042; Hunt, Tr. 9266; Wallace, Tr. 9332-9333; Goodwin, Tr. 9885-9886

Reed, Tr. 10258; Sears, written testimony (August 6, 1981) pp. 3-5,

!O Tr. 10644; Nauman, written testimony, pp. 6-7 (August 24, 1981) Tr. 10372.)

138. Messrs. H. B. Ray, E. L. Murri, D. F. Filmer, O

B. Killingsworth, D. H. Roper, C. Nash, J. P. Stowe, R. J. Coleman, E. S. Turner, D. W. Poorman, J. W. Hunt, Col. J. E. Wallace, Ms. C. Ferguson and Mrs. J. M. Swanson

'O were the primary witnesses for Applicants; Ms. J. Goodwin was the primary witness for the Inte. - iors; and Messrs. J. R.

Sears and K. W. Nauman were the pr. mary witnesses for the

O Staff regarding the procedures and capability co implement i

I 82 10

G continued communication among all involved organizations.

8 (Ray Tr. 7152-7155; Murri, Tr. 7227-7228; Pilmer, Tr. 7373.;

Killingsworth, Tr. 8268; Roper, Tr. 8331-8332; Nash, Tr.

8424-8425; Stowe, Tr. 8491-8492; Coleman, Tr. 8584; Ferguson, O

Tr. 8698; Swanson, Tr. 8793; Turner, Tr. 8916; Poorman, Tr. 8760; Hunt, Tr. 9266-9267; Wallace, Tr. 9329-9332; Sears, written 'estimony (August 6, 1981), p. 4, Tr. 10644; Nauman, O

written testimony (August 24, 1981), pp. 6-7, Tr. 10372; Goodwin, Tr. 9909.)

139. Messrs. B. Killingsworth, D. H. Roper, D J. P. Stowe, R. J. Coleman and D. W. Poorman were the primary witnesses for Applicants, regarding periodic testing of the entire emergency response cctmunication system. Intervenors D

and Staff did not present any witnesses directly on this subject. (Killingsworth, Tr. 8270; Roper, Tr. 8331-8332; Stowe, Tr. 8491-8492; Coleman, Tr. 8586; Poorman, 7

~

Tr. 8779-8781.)

2. Notification by Applicants.of State and Local Resoonse Organizations 3 140. Notification by SCE of State and local response organizations is required by the SchGS 2 & 3 Emergency Plan for any emergency event at SONGS 2 & 3.

) (Exhibit #51, Section 4.0; Ray, Tr. 7141-7146.)

141. As required by the NRC Regulations and related guidance (NUREG-0654, II.D.1), SCE, %he principal offsite 3 emergency response organizations, as well as State OES, CHP, 83

)

O the City of San Juan Capistrano, and the Capistrano Unified  ;

O School District have adopted a standard emergency classification and action level scheme. (Exhibits #51, #103,

1. 112, #139, #140, Intervenors' Exhibits #23, III.B.1; Ray, O Tr. 7141, 7151; Murri, Tr. 7227-7228; Killingsworth, Tr.

8269; 5 ears, written testimony (August 20, 1981), p. 7, Tr. 1 10644; Nauman, Tr. 10467-10468.)

0 142. Under this s7 heme, emergency events are classified into four distinct categories: in order of increasing severity, Unusual Event, Alert, Site Emergency and lO General Emergency. Notification to the offsite organizations of an " Unusual Event" need not be made immediately, but must be made on a timely basis. All reasonable efforts must be O-made to classify, and declare an " Alert", " Site Emergency",

or " General Emergency" within 15 minutes of the initial indication of the event with notification to offsite O

emergency response organizations to commence immediately upon declaration of the condition. (Exhibit #51, Section 4; Ray, Tr. 7141-7151; see 10 C.F.R., Part 50, Appendix E.IV.D.3.)

O 143. The onsite Emergency Coordinator _s responsible for classifying and declaring the emergency, notifying and activating the onsite emergeacy response O

organization, and notifying the offsite emergency personnel and organizations. There will be a trained Emergency Coordinator on-duty in the SONGS 2 & 3 Control Room at all O

times. (Exhibit #51, Section 5.2; Ray, T. 7132-7133.)

84 0

'O 144. With the agreement of the agencies to be O notified, Applicants have implemented a procedure for notifying the State OES, the Counties, the Cities, State Parks, USMC and the NRC on a 24-hour per day, 7-day per week O basis in the event of_an emergency. Each of these agencies have the capability of receiving this notification on a 24-hour per day, 7-day per week basis. (Exhibit #51, Section O 6; Exhibits #53, IV.A.5, #54, IV.A.6, #55, VI.B., #57, VIII.A; Intervenors' Exhibit #23,Section V.B; Ray, Tr.

7141-7143, 7149; Pilmer, Tr. 7374-7375; Reed, Tr. 10258; O Poorman, Tr. 8760; Hunt, Tr. 9266; Coleman, Tr. 8584; Ferguson, Tr. 8697: Stowe, Tr. 8490-8491; Wallace, Tr. 9332.)

145. An Interagency Telephone System ("ITS") has O

been specifically engineered and installed for the purpose of notifying and maintaining continuous communications with offsite organizations. The ITS is a dedicated, private, O

dial-up party line telephone network connecting the Counties, the Cities, State Parks, USMC and the CHP with SONGS and the interim Emergency Operations Facility (" Interim EOF"). The O

ITS is not affected if regular telephone lines are overloaded. At SONGS 2 & 3, the ITS is installed in the Technical Support Center, the Watch Engineer's Office (next to the Control Room) and the Emergency Support Center. Each instrument on the ITS is equipped with a push-to-talk handset, LED lamp to indicate the circuit is being used and a

!O monitor speaker to provide for group listening. Each i

85

,0

LO location on the system may be contacte'd by using either an

'O "all-call mode" or a selective station call mode. If the circuit is_being used, it is possible to interrupt so that the ITS may be used to transmit information requiring O immediate distribution. (Pilmer, Tr. 7372-7374; Poorman, Tr.

8771-8772.) >

146. In the event of an emergency event, the NRC, O Region V will be immediately notified using a dedicated telephone installed in the SONGS 2 & 3 Control Room.

(Exhibit #51, pp. 3-6, Table 7-1; Ray, Tr. 7143.)

0 147. An alternative method for notification of and communications with the offsite emergency response organizations,'in addition to the ITS, is through the SCE n'

Energy Control Center ("ECC"). Under this system, the Emergency Coordinator at SONGS notifies the ECC on a microware telephone system which, in turn, notifies and activates the State Warning Center in Sacramento, California. The State Warning Center has 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day notification and communication capability with the Counties.

O i In the event of failure of the ITS or because of other circumstances, the ECC, upon notification from SONGS, would implement its back-up procedure for notifying principal and lO supporting Federal, State and local emergency response organizations. The ECC is continuously staffed and has l reliable primary and back-up communications with SONGS, other

!O utilities and the potentially involved Federal, State and l

l 86 10

I~

l local organizations. (Exhibit #51, Section 7.5; Pilmer, Tr.

D 7374-7375, 9192-9194; Poorman, Tr. 8783-8784; Reed, Tr. 10258.)

148. In addition to the ITS and the microwave D

telephone system to the ECC, SONGS has other communications I

capabilities for notification of offsite agencies, consisting

! of-a regular public telephone system, a VHF radio system to D

i USMC, a UHF radio system to State Parks, additional dedicated telephone circuits to the Interim EOF and a "hard copy" teletype system to the Interim EOF and the Emergency Media D

l Center. In addition, an Orange County Automatic Teletype System terminal is being installed at SONGS to provide hard-copy communications with the County EOCs, the Interim EOF and D-Orange County's Control One Communications Center discussed below. (Exhibit #51, Table 7-1; Ray, Tr. 7147-7148, Cramer, Tr. 7068-7069; Poorman, Tr. 8764.)

' 149. The various SONGS communications systems that l

could be used to notify and c.ommunicate with Federal, Sta_t,e and local emergency response organizations are manned on a 24-hour per day basis. (Ray, Tr. 7149, 7841-7842.)

150. The initial contact with an offsite emergency l response organization is generally made to a communications D

operator or other similarly qualified individual, so the initial notification must be brief, factual and uncomplicated. To facilitate this process, SCE and the involved offsite emergency response organizations have 87 l

t

r I

lO I

adopted standardized Initial and Follow-up Notification

'O forms. (Exhibits #51, Sections 6.1.5 and 6.1.6, #102, #104; Ray, Tr. 7149.)

151. The Initial Notification forms prepared by SCE O have pre-worded information and blank spaces for event-specific information. The Initial Notification forms contain spaces to include specific information such as

'O identification of the event, whether or not a release of radioactive material has taken place, potentially affected areas, and recommended protective actions, as applicable.

g There is a separate, color-coded Initial Notification form for each of the emergency classifications: Unusual Event, Alert, Site Emergency and General Emergency. Copies of these i

forms are in place at SONGS and at the contact point of each of the offsite emergency response organizations. The back of

each Initial Notification form contains a listine, by title

'O and number, of each emergency event postulated to fall within L. ..

. . - . . - .the classification for which the form applies.. . . - - .(Exhibits . - - - - - - - -

1. 51, Section 6.1.5, #102; Ray, Tr. 7150; Murri, Tr. 7228.)

D 152. SCE has had prepared a Manual of Emergency Events (" Manual") for SONGS 1 which is presently in use. The l numbers ond titles of the events on the back of the Initial 3

Notification forms coincide with the numbers and titles in the Manual wherein each emergency event is described in

non-technical layman terms. Each of the offsite emergency resconse agencies has copies of the Manual. Use of the

?

I l

88

'3 t

)

Manual in conjunction with the initial notification of an O emergency, as well as for the continuing communications during an emergency, helps to alleviate communication difficulties that might otherwise arise due to the fact that O the plant systems are complex and the terminology commonly used by plant personnel may not be readily understood by the offsite agency personnel. A revision to the Manual is now in O progress, and will include and describe the postulated emergency events for SONGS 2 & 3. The new SONGS 1, 2&3 Manual of Emergency Events will be distributed to the offsite 3

agencies and will replace the SONGS 1 Manual prior to the initial fuel load for SONGS 2. (Exhibit # 102; Murri, Tr.

7227-7228; Ray, Tr. 7151.)

m 153. A follow-up notification message form has also been developed by SCE and supplied to the offsite agencies.

The Follow-up Notification form serves two purposes: the 7

first is to provide technical information about the emergency directly to those individuals qualified to utilize that type of data; the second is to provide additional details rl concerning onsite conditions and recommended protective actions. Similar in format to the Initial Notification forms, the Follow-Up Notification form contains a standard

'3 format and specific blank spaces for providing event-specific essential information. (Exhibit #51, Section 6.1.6, #104; Ray, Tr. 7153-7154; Murri, Tr. 7228.)

3 89 3

O 154. Applicants' capability to implement SONGS

'O procedures for notification of state and local response organizations was demonstrated during the full scale exercise involving the Applicants and offsite organizations on May 13, 1981. This capability has also been demonstrated in recent communication drills and actual notifications involving l unusual events at SONGS 1. (Exhibit #110,; Murri, Tr. 7231-

!O l 7233; Sears, written testimony (August 6, 1981), p. 5, Tr.

l 10644; Pilmer, Tr. 7391-7392; Stowe, Tr. 8551-8552.)

l 155. The NRC Staff has evaluated SCE's systems and O

procedures for notifying offsite emergeny response organizations and concluded they are " workable and effective." (Sears, written testimony (August 6, 1981), pp.

'O 3-5, Tr. 10644.)

156. Based on the substantial and uncontroverted evidence in the record, there is reasonable assurance that O

Applicants' are capable of notifying involved State and local emergency response organizations in a prompt and understandable fashion.

b 3. Procedures and Capability to implement Notification of Emergency Personnel.

157. SCE has procedures and the capability for 9 notifying and mobilizing onsite and offsite personnel, as well as other private response agencies, on a 24-hour per day basis. (Exhibit #51, Section 6 and Appendix A, #101; Ray, O

90 0

O Tr. 7130-7131, 7151-7153, 7842-7843; Barr, Tr. 7174-7175, C) 9066-9072.)

158. Orange County has procedures and the capability for notifying and alerting key County agencies and "O

=

decisionmakers, the Orange County Transit District, the City of San. Juan Capistrano, the Capistrano Unified School District, the Red Cross, all County and local law enforcement n

l" agencies in the County the CHP, CALTRANS, as well as fixed and mobile medical support facilities on a 24-hour per day basis. (Exhibit #53, Sections V.A. and B., #152(c); Turner,

'O Tr. 8913, 9003-9004; Poorman, Tr. 8757-8758, 8765-8766;. Fox, Tr. 9041-9042.)

159. San Diego County has the procedures and the

O capability for notifying and alerting key County agencies and decisionmakers, Santa Fe Railroad, the U.S. Coast Guard, the U.S. Border Patrol (San Onofre Station), the CHP (who 50 notifies CALTRANS), the Cities of Carlsbad, Encinitas, Vista, San Marcos, Fallbrook and Oceanside, as well as fixed and mobile medical support facilities on a 24-hour per day iO basis. (Exhibit #54, Appendix V-I.D, and Section VIII.B.,

1. 153(c); Hunt, Tr. 9266.)

! 160. The Capistrano Unified School District has the iO

procedures and capabilities for notifying and alerting the various schools, District decisionmakers, and bus 1

transportation dispatchers involved when school is in

O session. (Exhibits #139, #140; Swanson, Tr. 8797-8799.)

91 10

O 161. CALTRANS has the procedures and capabilities D"

for notifying and alerting its personnel on a 24-hour per day basis. (Roper, Tr. 8332, 8334-8335, 8360-8362.)

162. CHP has the procedures and capabilities to O

notify and alert its personnel on a 24-hour per day basis.

(Killingsworth, Tr. 8270, 8285-8286.)

163. The USMC has the procedures and capabilities O

to notify and alert emergency response personnel on a 24-hour per day basis. (Exhibit #58, K-A; Wallace, Tr. 9332.)

164. The City of San Clemente has the procedures O

and capabilities to notify key City agencies and decisionmakers on a 24-hour per day basis; and the Capistrano Unified School District when schools are in session or IO administrators are present. (Exhibits #55, Sections IV, V, VI; #154(c); Coleman, Tr. 8638, 8642-8646.)

165. The City of San Juan Capistrano, with the O

support of Crange County, has the procedures and capabilities to notify key City agencies and decisionmakers on a 24-hour per day basis. ~(Exhibit #56, Section I.C., #155(c);

O Ferguson, Tr. 8697-8698, 8719-8720.)

166. State Parks has the procedures and capabilities to notify their emergency response personnel on O

a 24-hour per day basis. (Exhibit #57,Section VIII.A.,

1. 156(c); Stowe, Tr. 8515-8518.)

167. State OES has the procedures and capabilities O

to notify involved Federal, State and local emergency 92 0

f

)

l l

l

( agencies on a 24-hour per day basis. (Intervenors' Exhibit O #23,Section V.B; Reed, Tr. 10258.)

168. The capability of SCE and the involved offsite i emergency response organizations to notify and alert their

) emergency response personnel has been demonstrated by the existing plans and procedures, the day-to-day operation of these organizations, previous exercise.s and drills, and by 3 the previous emergency experience of these organizations.

(Exhibit #110, #141, #145, #151, Intervenors' Exhibit #14; Ray, Tr. 7130-7132; Murri, Tr. 7253; Turner, Tr. 8913; Fox, D Tr. 9034-9035; Ferguson, Tr. 8697, 8719-8721; Swanson, Tr.

8799; Coleman, Tr. 8585-8586; Stowe, Tr. 8491-8492; Wallace, Tr. 9329-9332; Hunt, Tr. 9266-9267; Sears, written testimony D (August 6, 1981), pp. 3-5, Tr. 10644; Nauman, Tr. 10509-10511.)

l 169. Based on the substantial uncontroverted

)

evidence in the record, there is reasonable assurance that SCE and the involved offsite emergency response organizations are capable of notifying and alerting the various agencies

) and personnel involved in responding to a radiological j emergency at SONGS 2 & 3.

i l 4. Procedures and Capability to Implement Continued Communication Among All Involved Organizations.

j 170. Systems and procedures for continuous communication exist between the onsite Technical Support and Emergency Support Centers and the offsite interim Emergency

! 93 i

C)

Operations Facility (" Interim EOF"), where a representative C) of each involved offsite emergency response organization is stationed, utilizing the ITS and other back-up means of communication. (Exhibit #51, Section 6.1; Ray, Tr. 7152-O 7154; Pilmer Tr. 7373, 9193-9194.)

171. Systems and procedures also exist for continous communication on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day basis between O SONGS, the Interim EOF and the Emergency Operations Centers

("EOCs") operated by the Counties, the Cities, State Parks, the USMC, CALTRANS, the Emergency Media Center, utilizing the D ITS and other dedicated means of communication. (Exhibit

1. 51, Section 6.1; Ray, Tr. 7153-7155; P11mer, Tr. 7373; Poorman, Tr. 8760.)

O 172. Systems and procedures for radio communication l

between SONGS, the Offsite Dose Assessment Center, and the various.SCE and other radiation monitoring teams in the field O

also exist . (Exhibit #51, Table 7-1, #152(f), #153(f),

l 4154(f); Barr, Tr. 7171; Pilmer, Tr. 7379-7380, 7394-7396; f

l Poorman, Tr. 8760.)

D 173. Continuous hard-copy communication will also be available between the Interim EOF, the Counties' EOCs, and r

[ SONGS utilizing the Orange County Interagency Teletype

) System. (Exhibit #136, Poorman, Tr. 8764, 8788.)

174. The capability to implement this continous communication is demonstrated by the existing procedures, the D

l day-to-day operation of this system, and the results of the

. 94

)

g 3 l

\

j drills and exercises of this system that have ueen

) .successfully conducted. (Exhibit #110; Murri, Tr. 7227-7228, l 7253; Ray, Tr. 7152-7155; Pilmer, Tr. 7373; Killingsworth, Tr. 8268; Roper, Tr. 8331-8332; Nash, Tr. 8424-8425; Stowe, O Tr. 8491-8492; Coleman, Tr. 8584; Ferguson, Tr. 8698; Swanson, Tr. 8793; Hunt, Tr. 9266-9267; Wallace, Tr.

9329-9332; Poorman, Tr. 8779-8781; Turner, Tr. 8916; Nauman, O written testimony (August 24, 1981), p. 6-7, Tr. 10372; Sears, written testimony (August 6, 1981), p. 4, Tr. 10644.)

175. Based on the substantial and uncontroverted D evidence in the record, there is a reasonable assurance that SCE and the involved offsite emergency organizations are capable of implementing continued communication among all D

involved organizations.

5. Program for Periodic Testing of Entire Emergency Communication System.

) 176. Much of the communications system involved in offsite emergency notifications and communications is used and tested regularly, often on a daily basis. (Exhibit #51, J section 8.4; Poorman, Tr. 8779-8781; Killingsworth, Tr. 8270; Roper, Tr. 8331-8332; Stowe, Tr. 8491-8492; Coleman, Tr. 8586.)

) 177. Applicants and the involved offsite emergency response organizations have a program to inspect, inventory and operationally check communications equipment on a

) quarterly basis. (Exhibit #51, Section 8; Poorman, Tr. 8781.)

1 1

95

O 178. Applicants and the involved offsite emergency

) response organizations also have a program for monthly communications drills between SONGS and the principle emergency response organizations, as well as annual O communications drills between SONGS and the various offsite emergency response facilities, as recommended in NUREG-0654, II.N.2.a. (Exhibits #51, Section 8.4, #112.)

O

6. Overall Conclusion.

179. Based on the substantial uncontroverted evidence in the record, there is reasonable asaurance that O the onsite and offsite energency response organization notification and communication systems are adequate and capable of being ir..plemented so that State and local response O

organizations can be notified and so that emergency personnel of all involved organizations can be notified and communicated with on a continuing basis.

D D. CONTENTION 2E (Existence of Adequate Offsite Emergency Operation Centers, Transportation and Communication Equiement).

"Whether there is reasonable assurance'that

] the emergency response planning and capability of implementation.for SONGS 2 and 3, affecting the offsite transient and permanent population, will comply with 10 C.F.R. 5 50.47(a)(1) and (b) or (c)(1) as follows:

D . . .

E. necessary transportation and communication equipment, and the operation of the emergency operations centers of the principal response O organizations, 10 C.E.R.

I $ 50.47(b)(8); . . . .

96

)

\

t

C)

1. Introduction C) 180. Messrs. H. B. Ray, E. N. Cramer and ,

D. F. Filmer were the primary witnesses for Applicants; and Mr. J. R. Sears was the primary witness for the Staff, regarding the operation of SCE's emergency. operations centers and the transportation and communication equipment available to support tP SCF emergency response organization. The Intervenors did not present.any witnesses directly on this subject. (Ray, Tr. 7138-7139, 7147-7148; Cramer, Tr. 7054-7058, 7068-7069; Pilmer, Tr. 7372-7380; Sears, O written testimony ('sugus*. 20, 1981), pp. 9-11, Tr. 10644.)

181. Messrs. E. L. Murri, B. T. Brothers, B. Killingsworth, D. H. Roper, C. Nash, J. P. Stowe, O R. J. Coleman, D. W. Poorman, E. S. Turner, J. W. Hunt, Col. J. E. Wallace, Ms. C. S. Ferguson and Mrs. J. M. Swanson were the primary witnesses for the Applicants; G. Caravalho O was the primary witness for the Intervenors; and Mr. K. W. Nauman was the primary witness for the Staff, regarding the operation of the emergency operations centers O of the offsite emergency response organizations and the transportation and communication equipment available to l support these organizations. (Murri, Tr. 7250-7251; O

l Brothers, Tr. 8295-8296; Killingsworth, Tr. 8270; Roper, Tr. 8332; Stowe, Tr. 8491-8492, 8500-8501: Coleman, Tr. 8588-8592; Ferguson, Tr. 8698, 8721-8722; Poorman, O

Tr. 8754-8765; Swanson, Tr. 8803-8807; Turner, Tr. 8911-8924; 97 p

i

O Hunt, Tr. 8268-8272; Wallace, Tr. 9329-9330; Caravalho, O Tr. 10796; Nauman, written testimony (August 24, 1981), pp.

9-10, Tr. 10372.)

2. SCE Emergency Operations Centers O 182. SCE has plans and procedures to activate, staff and operate three interrelated onsite emergency operation centers in support of the SONGS 2 & 3 Control O Room. These centers are the Technical Support Canter-("TSC")

located adjacent to the Control Room, the Operaticns Support Center ("OSC") located in the SONGS Administration Building, O'

and the Emergency Support Center (" ESC") also located in the SONGS Administration Building. Basically, the TSC coordinates the technical response to the emergency O

condition, the OSC provides logistical and other support to the TSC, and the ESC, staffed by offsite SCE management and emergency support personnel, coordinates the SCE onsite O

emergency response with the offsite activities of the other involved emergency response organizations. (Exhibit #51, Section 7; Ray, Tr. 7138-7139; Pilmer, Tr. 7375-7377; Sears, O

written testimony ( August 20, 1981), p. 10, Tr. 10644.)

183. SCE also has plans and procedures for the activation, staffing and opt._. ion of two offsite emergency O

operations centers: the interim Emergency Operations Facility (" Interim EOF") located in the San Clemente City Hall and the Emergency Media Center ("EMC") located in the O

S at. Clemente Boys & Girls Club, approximately one-half mile

'T 98

.O

D from the Interim EOF. Basically, the purpose of the Interim

) EOF is to provide a point of interface where all involved i i

! emergency response organizations can assess conditions and l

l coordinate emergency response activities. The purpose of the EMC is to expedite and coordinate the dissemination of public information through the media. (Exhibits #122A, #147;

(

Pilmer, Tr. 7377-7380; Cramer, Tr. 7054-7058, 7533.)

O 184. SCE's capability to activate, staff, and operate its onsite and offsite emergency operations centers was successfully demonstrated at the May 13 exercise.

O (Exhibit #110; Murri. Tr. 7252; Cramer, Tr. 7054; Sears, written testimony (August 20, 1981), p. 11, Tr. 10644.)

3. SCE Communications and Transportation O Equiement.

185. SCE has plans and procedures describing in detail the location and function of the various types of D communication equipment that are available for emergency use. The SONGS 2 & 3 communication equipment provides multiple systems and redundancies which ensure the D performance of vital functions in maintaining contact with onsite and offsite SCE emergency response personnel and transmitting and receiving information between SONGS and D involved Federal, State and local response organizations throughout the course of an emergency. These systems include an onsite intercom and public address system, a UHF radio to O SCE personnel, a regular public telephone system, a dedicated 99 O

O telephone system (the "ITS"), two additional dedicated CY ring-down circuits to the Interim EOF, a dedicated telephone to the NRC, Region V, a VHF radio system to the USMC, a UHF radio system to State Parks, and a dedicated microwave O multiplex system to the SCE Emergency Control Center and the SDG&E Energy Control Center. These systems can be energized with back-up power sources to minimize the risk of O communication loss from localized events. In addition to these systems, the SCE Customer Information System has been installed in the ESC, EOF and EMC to provide, via teletype, O "hard copy" communications capability between.these facilities. This "hard copy" communication capability will be further supplemented by installation of the Orange County O Automatic Teletype System between SONGS, the Counties' EOCs, and the EOF. (Exhibits #51, Section 7.5, #136; Ray, Tr.

7147-7148; Pilmer, Tr. 7372-7374, 9193-9194; Cramer, Tr.

O 7CG8-7069; Poorman, Tr. 8764.)-

136. In the event that normal access to SONGS should become restricted, SCE has plans and procedures to O transport emergency personnel and equipment to SONGS via helicopter. SCE maintains a fleet of aircraft which includes five helicopters and one twin-engine fixed wing aircraft.

O capable of carrying six passengers. The fleet is based at Chino Airport. Provisions have been made for the dedicated use of two helicopters and all aircraft could be dedicated to O

100 0

i 3

SONGS, if necessary. (Exhibit #51, Section 6.0; Sears, D written testimony ( August 20, 1981), pp. 9-10, Tr. 10644.)

187. SCE also owns and operates an extensive fleet of ground transportation vehicles consisting of heavy-duty D trucks, equipment and four-wheel drive vehicles which would be available to SONGS, as needed. (Exhibit #51, Section 6.0; Sears, written testimony (August 20, 1981), pp. 9-10, D

Tr. 10644.)

188. Additional helicopter and ground transportation assistance is available to SCE from the USMC, should'the D

circumstances necessitate such assistance. (Wallace, Tr. 9342.)

189. The capability to utilize the SCE D

communications system, as well as the availability of necessary transportation equipment in support of the SCE emergency response organization, was demonstrated to be D

" workable and effective" during the May 13 exercise. (Sears, written testimony (August 20, 1981), p. 11, Tr. 10644.)

4. The Emergency Operations Centers of the 3 Principal Offsite Emergency Response Organizations 190. Each of the principal offsite emergency response organizations operates an EOC. In addition, the

)

l City of San Juan Capistrano, the District, the State OES, the l CHP, and CALTRANS operate EOCs. The purpose of an EOC is to l

i provide a single location where a jurisdiction or agency may efficiently manage and deploy its emergency response l

l l

l 101 D

O equipment and personnel; request, receive, coordinate and D

dispatch all information, equipment and personnel from all other responding jurisdictions and agencies; control rumors; and communicate necessary public information. (Murri, O

Tr. 7249-7250; Turner, Tr. 8911; Hunt, Tr. 9271-9272; Coleman, Tr. 8592; Ferguson, Tr. 8721-8722; Wallace, Tr. 9329; Stowe, Tr. 8501; Killingsworth, Tr. 8270, 8281; O

Roper, Tr. 8332; Swanson, Tr. 8807.)

191. The Counties' EOCs meet or exceed the minimum Federal criteria for sufficient space and communications, and O

are self-sufficient in supplies and accomodations. The location of the Counties' EOCs are:

o Orange County Offices of Emergency Services, O

625 N. Ross Street, Santa Ana, California; o San Diego County Operations Center, Overland Avenue, San Diego, California.

O The Cities also have EOCs, which are located in their respective City Halls. The USMC has its EOC at its Base Headquarters. The State Parks has its EOC at its Pendleton O

Coast Office. The CHP has an EOZ in its Border Division Headquarters, San Diego, California. CALTRANS has an EOC at its District 7 Headquarters, in Los Angeles, California. The O

District has an EOC located at the District Educational Center in San Juan Capistrano. The State of California EOC is located at the State OES headquarters in Sacramento, California. The ECCs of the Cities, the USMC, the State 1

102 0

O Parks, the District and the State OES are manned by trained O staffs with reliable communications systems. (Murri, Tr. 7230-7251; Turner, Tr. 8911; Hunt, Tr. 9271; Coleman, Tr. 8592; Ferguson, Tr. 8721-8722; Wallace, Tr. 9329; Stowe, O Tr. 8501; Killingsworth, Tr. 8270, 8281; Roper, Tr. 8332; Swanson, Tr. 8807; Reed, Tr. 10258.)

192. The capability to operate these EOCs is O assured by the existing plans and procedures for their operation, the program for periodic drills and exercises involving activation of these EOCs, and the periodic O

activation of these EOCs for actual emergencies not involving SONGS. (Murri, Tr. 7252; Turner, Tr. 8911; Hunt, Tr. 9271-9272; Coleman, Tr. 8593-8594; Ferguson, Tr. 8691; Wallace, O

Tr. 9329; Stowe, Tr. 8500-8501; Killingsworth, Tr. 8270, 8281; Roper, Tr. 8332; Swanson, Tr. 8807; Nauman, Tr. 10928.)

193. The operation of each of the principle offsite O

emergency organization EOCs was successfully demonstrated during the May 13 exercise. (Exhibits #110, 141, Intervenors' Exhibit #14; Murri, Tr. 7252; Hunt, Tr. 9272; O

Coleman, Tr. 8593; Wallace, Tr. 9329; Killingsworth, Tr.

8316; Swanson, Tr. 8807.)

5. Availibility of Necessary Transportation and O communication Equipment to Principal offsite Emergency Resconse Organizations 194. The EOC for each of the principal offsite emergency response organizations is equipped with a reliable O-system for communicating with their own organization, as well 103 O

I l}

as the EOCs of the Counties, Cities, State Parks, the USMC, O State OES, CHP, CALTRANS and SCE. The EOC of each principal offsite emergency response organization is connected to and is part of the ITS. Each of these EOCs also is connected to h) and a part of the State of California radio net. Each has regular telephone communication. The EOCs for the Counties l

are also terminals for the Orange' County Automatic Teletype 7"

System. Detailed back-up provisions exist to re-establish radio communicavions between SONGS and the principal emergency response organization EOCs in the event such O'

communications are disrupted by technical failures or network catastrophes. (Exhibits #137, #138; Murri, Tr. 7252; Poorman, Tr. 8754-8762, 8764-8765, 8771-8779, 8783-8785, C) 8788; Stowe, Tr. 8491-8492; Killingsworth, Tr. 8267-8269; Roper, Tr. 8333, 8371-8372; Hunt, Tr. 8268-8270; Wallace, Tr.

8329-8330; Ferguson, Tr. 8698; Coleman, Tr. 8589-8592; Reed, O Tr. 10258.)

195. Each of the principal offsite emergency response organizations have or have access to the O transportation equipment necessary to respond to a radiological emergency at SONGS 2 & 3. (Murri, Tr. 7252; Brothers, Tr. 8295-8296; Turner, Tr. 8924; Hunt, Tr. 8268; O Coleman, Tr.8588-8589; Ferguson, Tr. 8691; Wallace, Tr. 9342; Stowe, Tr. 8501-8502: Killingsworth, Tr. 8272, 8283-8285; Roper, Tr. 8335-8340; Swanson, Tr. 8803-8806; Nauman, Tr.

O 10928.)

104 O-

)

196. Based on the substantial uncontroverted

) evidence in the record, there is reasonable assurance that each of the principal response organizations has an emergency operations center and the communications and transportation

) equipment necessary to support its functions during an emergency at SONGS 2 & 3 affecting the offsite transient and permanent populations.

3 E. CONTENTION 2I (Interim Emergency Operations Facilityj.

"Whether there is reasonable assurance that the emergency response planning and J capability of implementation for SONGS 2 and 3, affecting the offsite transient and permanent population, will comply with 10 C.F.R. S 50.47(a)(1) and (b) or (c)(1) as regards:

) . . .

I. the physical design, communications equipment, and operating procedures for the Interim Emergency Operations Facility, 10 C.F.R. SS 50.47(b)(3) and 3 (b)(8); . . . ."

1. Introduction 197. Messrs. D. F. Filmer, E. L. Murri, E. N.

3 Cramer, D. W. Poorman, and R. J. Coleman were the primary witnesses for the Applicants; Messrs. W. Mecham, G. Caravalho and Dr. M. F. Reed were the primary witnesses for the

) Intervenors; and Messrs. J. R. Sears and K. W. Nauman were the primary witnesses for the Staff regarding the physical design, communication system and equipment, and operating 3 procedures for the Interim EOF. (Pilmer, Tr. 7376-7379, 105 J

D 7392-7395, 9194; Murri, Tr. 7254-7255; Cramer, Tr. 7065-7066; h Coleman, Tr. 8596-8597; Poorman, Tr. 8757; Sears, written testimony (August 20, 1981), pp. 11-12, Tr. 10644; Nauman, written testimony (August 24, 1981), pp. 12-13, Tr. 10372; Mecham, Tr. 10051-10052; Reed, Tr. 10220; Caravalho, Tr.

10796-10798.)

2. Physical Design and Location of the g Interim EOF.

198. SCE is responsible for establishing an Emergency Operations Facility (" EOF") from which evaluation g and coordination of all SCE activities related to an emergency is to be carried out and from which SCE is to provide information t.o Federal, State and local authorities e responding to radiological emergencies involving SONGS.

(NUREG-0654, II.H.2).

199. Applicants are not required to have an EOF e which meets the functional criteria set forth in NUREG-0696 at this time. (Staff Exhibit #12, p. 13-2.) In order to meets these criteria, SCE is currently designing a permanent e EOF which is scheduled for construction and operation by about October, 1982. (Pilmer, Tr. 7376.)

200. While SCE is constructing its permanent EOF, e SCE is meeting its responsibility in this regard by establishing an Interim EOF with aix physically separate, but interrelated, components. Theae components are: the D Emergency Support Center (" ESC"), located onsite in the SONGS 106

.O Administration Building; the EOF Directors' Office ("DEOF")

O located on the first floor of the San Clemente City Hall; the Offsite Dose Assessment Center ("ODAC"), located on the first floor of the San Clemente City Hall; the EOF Coordination and Administration Center ("EOFCAC"), located on the first floor of the San Clemente City Hall; the Sample Collection and Analysis Center ("SCAC"), located in the garage of tne San

,0 Clemente Fire Station; and the Emergency Media Center

("EMC"), located in the San Clemente Boys and Girls Club.

The components of the Interim EOF located in the San Clemente O

City Hall and the Fire Station comprise approximately 2000 square feet of working space. The location of these components in four separate, but adjacent, rooms provides O

noise control and physical separation of functions, while assuring adequate coordination capability. (Exhibit #122A,

p. 1; Pilmer, Tr. 7376-7378.)

O 201. The function of the ESC, which is manned by ESO personnel, is to manage the overall SCE emergency response. Coordination of radiological and environmental O

assessment occurs in the ODAC upon receipt of information from either the SCAC or the ESC. Public protective actions are recommended by the ODAC and determined in the DEOF. The O

EOFCAC is the location where Federal, State and local emergency response activities are reported and transmitted.

The function of the EMC is to disseminate emergency O

information to the public via the news media by designated

$107 O

D spokespersons. (Exhibit #122A; Pilmer, Tr. 7377; Cramer, 7-Tr. 7052.)

3. The Interim EOF Conmunication System.

202. SCE has provided an extensive communication O system which connects the various components of the Interim EOF together and permits the Interim EOF to communicate between SONGS and the various offsite EOCs. (See FF. Nos.

O" 185-189.)

203. SCE management located in the ESC can communicate with the Emergency Coordinator in the onsite Technical Support Center ("TSC") using the SCE private telephone system, the ITS, and other back-up systems. The ESC can also communicate with onsite and offsite SCE O

emergency response personnel using the SCE private telephone system, the SONGS Public Address System, the regular public telphone system, SONGS UHF Radio, or the SONGS Intercom

'O System. (Exhibit #51, Table 7-1; Pilmer, Tr. 7377.)

204. Communications equ'ipment available in the ODAC

~

to coordinate radiological monitoring includes the ITS, a o dedicated telephone to the TSC, commercial telephones, FM communications radio to the SCAC and field radiation monitoring teams, and the Orange County Automatic Teletype O

System to SONGS, and the Counties' EOCs. (Exhibit #142,

p. 5; Filmer, Tr. 9194; Poorman, Tr 8760, 8764.)

205. Communication equipment available in the O

EOFCAC to coordinate response activities and disseminate 108 O ,

f b

information and recommended protective actions to the SCE and

)

l responsible governmental agencies includes the ITS to the TSC l

and the EOCs, a dedicated telephone to the TSC, commercial telephones, FM communications radio, and the Orange County

) Aut/xatic Teletype System. (Exhibit #122A, p. 3; Pilmer, Tr.

l 9193-9194; Poorman, Tr. 8764.)

206. Public information and recommended public

) protective actions can be communicated from the EOFCAC via dedicated telephone to the EMC or via the Emergency Broadcast System accessible through either the-San Clemente EOC or the Orange County Communication Center using the ITS or other backup system. Sudi information can be ccmmunicated to the public from the EMC either through news conferences, press b' releases, the SCE Customer Information System, or the SDG&E l

l Customer Information System. (Exhibit #77; Cramer, Tr.

7065-7066; Poorman, Tr. 8757; Coleman, Tr. 8596-8597; See D

FF.375-377 infra)

4. Interim EOF Operating Procedures.

207. Applicants and the involved local jurisdictions D have developed standard operating procedures for the Interim EOF. These operating procedures describe the procedures for activation and staffing, communications, record-keeping, D establishing maps and other displays of information; and set forth the functions of the various representatives of SCE and the responding Federal, State and local jurisdictions and

) agencies. (Exhibits #122A, #152(b), #153(b), #154(b),

1. 155(b), #156(b); Pilmer, Tr. 7378-7379, 9139, 11103-11105.)

109 D

O 208. Applicants are currently offering training on O these procedures to the involved Federal, State and local representatives. It is expected that these representatives will complete this training prior to full power operation of O

SONGS 2. (Exhibits #111, #157; Murri, Tr. 7254-7255; Pilmer, Tr. 7395, 9209, 11108-11111.)

209. The capability of SCE to operate the Interim O

EOF was demonstrated in the May 13 exercise. (Intervenors' Exhibit #14, pp. II-36--II-38.) Since that time a number of improvements in the physical design and communications

!O equipment for the Interim EOF have been implemented. A l

t full-scale exercise of the Interim EOF is required on an a

I annual basis to assure an adequate implementation capability

O is maintained. (Exhibit #51, Section 8.1.3, Pilmer, Tr.

l 7392-7395; Nauman, Tr. 10936.)

210. Based on the substantial evidence in the

O record, there is reasonable assurance that SCE's emergency response planning and implementation capability as regards the physical design, communications equipment and operating O

procedures for the Interim EOF are adequate to protect the public health and safety.

F. CONTENTION 2H (Plume EPZ Radiation Monitoring O and Dose Assessment).

"Whether there is reasonable assurance that the emergency response planning and capability of implementation for SONGS 2 and 3 affecting the offsite transient and O permanent population, will corply with 10 C.F.R. 550.47(a)(1) and (b) or (c)(1) as follows:

110 0

e O

F. the methods, staffing, system, and l equipment for assessing and monitoring actual l or potential offsite consequences of a l radiological emergency condition within the i plume expoure pathway EPZ for SONGS 2 and 3, g 10 C.F.R. 550.47(b)(9) . . . ."

1. Introduction.

211. Mr. K. P. Barr was the primary witness for g Applicants; and Mr. J. R. Sears was the primary witness for the Staff regarding SCE's onsite capability and resources to assess the radiological significance of any e.ccidental e offsite release of radioactivity, conduct offsite radiation monitoring with the Plume EPZ, and formulate recommended protective actions for the affected offsite transient and O permanent populations. Intervenors did not present any witnesse' directly on this subject. (Barr, Tr. 7164-7177; Sears, written testimony (August 6, 1981), pp. 10-12, Tr.

O  :.0644.)

212. Messrs. E. L. Murri, D. F. Filmer, R. J.

Coleman, E. S. Turner, J. W. Hunt, and Col. J. E. Wallace

) were the primary witnesses for Applicant; Dr. R. L. Ehling, and Mr. J. Kearns were the primary witneses for the Intervenors; and Mr. K. W. Nauman was the primary witness for

[) the Staff regarding the resources and capability of offsite emergency response organizations to assess the at- or potential magnitude and location of a radiological hasard.

() (Murri, Tr. 7238-7240; Pilmer, Tr. 7379-7380; Coleman, Tr.

111 f0

G 8607-8608; Turner, Tr. 8919-8921; Hunt, Tr. 9276; Wallace,

1. Tr. 9335-9338; ELling, Tr. 9938-9947; Kearns, Tr.

10177-10180; Nauman, written testimony (August 24, 1981) p.12, Tr. 10644.)

• 2. SCE Resources and Capability.

213. Applicants have considerable onsite resources and capability to aseess and monitor actual or potential 8 offsite consequences of a radiological emergency condition within the Plume EPZ. In order to perform such functions, it is the normal practice to obtain in~ plant radiation levels, S radiation release rates, and certain meteorological data for the vicinity of the plant. Field monitoring confirms the accuracy of offsite dose projections made on the basis of 6

this ensite data. Appropriately conservative offsite protective action recommendations can be made even in circumstances where some or all of these parameters cannot be O accurately determined. (Exhibit #51, Section 6.2.5; Ray, Tr.

7847-7848; Barr, Tr. 7154, 7367-7170, 9070.)

~

214. A meteorological tower is located onsite O immediately north of SONCS 1. The tower has instrumentation which records and displays temperature, lapse rate, wind speed and wind directional variability. This information is O

recorded and displayed in the Control Room and the Technical Support Center ("TSC"). A backup tower which can duplicate the functions of the primary tower is .=cheduled to be O

installed onsite by July, 1982. Back-up or supplementary 112 O

3 meteorological data is currently available from Lindberg

[] Field, San Diego; Palomar Airport, Carlsbad; Oceanside f Airport; El Toro Marine Corps Air Station; Orange County l

l Airport; and Camp Pendleton Headquarters Landing Field.

I D (Exhibit #51, Table 7-3; Barr, Tr. 7165.)

215. The SONGS 2 & 3 Area Radiation Monitoring System (" ARMS") provides initial and continuing assessment of 3 in-plant radiation levels. ARMS includes wide-rrnge containment radiation monitors which are placed at strategic onsite locations. Wide-range effluent monitors, capable of

) indicating high ranges of radioactivity, are installed on the stack and condensor air ejector of each unit. Area radiation monitors are also directed at the main steam line of each C) unit. These monitors provide data to indicate a source term which may then be used to determine potential offsite dose in the Plume EPZ. (Exhibit #51, Table 7-5; Barr, Tr. 7165-7166.)

1. 216. The SONGS 2 & 3 Post-Accident Sampling System

(" PASS") provides the capability to analy=e the radioactivity level of the reactor coolant and the containment atmosphere.

O PASS utilizes a multi-channel gamr.a-ray spectrometer to identify and quantify radioactive materials. PASS can be operated remotely from the Control Building. (Exhibit #51,

1. Table 7-5; Barr, Tr. 7166.)

217. The primary methods of calculating potential or actual offsite consequences of relerses of radioactivity

1. to the atmosphere are analytical projections based on 113 9

e readouts from installed monitoring devices. Some of these 8 monitoring devices are also used to establish the initial magnitude of off-normal conditions for the purpose of identifying the appropriate emergency action levels. These 8 devices are intended to be used for this function and have sufficient sensitivity and range to remain functional during emergency conditions. Installed monitoring devices are O available for each type of postulated accident and release pathway, such as liquid discharge line, plant vent stacks and containment radiation. The indications from these devices O are converted to a source term of radioactive material available for release from the containment or other locations based on predetermined ccasirnts. (Barr, Tr. 7167-7168.)

'O 218. If plant radiation instruments should go off-scale or become inoperable, health physics personnel can be dispatched to perform measurements of radiation levels at O predetermined locations around the plant using portable instrumentation. The results of these measurements would be communicated to the TSC via portable radio. These results D would then be used to estimate release rates and offsite dose projections in the same manner as results taken from installed monitoring devices. (Barr, Tr. 7166 7167.)

219. Once the source term has been established using installed monitoring devices, back-up portable monitoring devices, or back-up portable instrumentation and b sampling techniques, the effect of this source term is 114 D

y predicted by applying atmospheric dispersion coeffic'ients O based on available meteorological data-and established dose I conversion factors, which relate airborne radioactivity concentration to direct dose rate, thyroid dose rate, and D lifetime integrated doses. The dose conversion factors are contained in the Offsite Dose Calculation Manual ("ODCM").

The ODCM provides a methodology for the consideration of 9

multiple pathways of radioactive materials propagated within the Plume EPZ. Upon determination of the projected offsite dose rates, they are provided to the onsite Emergency O Coordinator in the Technical Support Center ("TSC") and to the Offsite Dose Assessment Center ("ODAC"). ', Exhibit #51, Section 6.2.5; Barr, Tr. 7168-7169.)

0 220. A health physics foreman trained to perform offsite dose calculations will be onsite at all times.

l During the initial phase of an accident, the on-shift health physics foreman has responsibility for and can provide the capability for immediate assessment of liquid and airborne hazards. He has onsite radiological monitoring teans at his

) disposal for immediate assessment of liquid and airborne hazards. All required equipment, including monitoring l

l instruments, vehicles and portable radios, are onsite for D

this use. All personnel onsite trained in radiological l monitoring may be assigned to radiological monitoring teams, at the health physics foreman's discretion. This responsibility for immediate assessment and personnel

! 115 P

t

O direction will be augmented and reassigned to designated C) emergency response personnel in accordance with implementing procedures, as required. (Barr, Tr. 7169.)

221. In order to confirm'and verify offsite dose O projections based upon in-plant conditions, offsite monitoring teams will be dispatched from SONGS. Offsite monitoring team personnel, equipped with respiratory O protection equipment, if appropriate, will take direct radiation readings with appropriate survey instruments and collect samples for analysis of airborne radioactivity. Air I sample media will.be field-checked and significant results reported immediately to the TSC using portable radio j equipment. Radiciodine concentration levels as low as 10E-7

O uci/cc can be detected under these field conditions, ,

i j including the effects of noble gas concentrations and background radiation. The results of all radiation

!O l monitoring activities will be recorded on data sheets by the  !

i monitoring teams and are reported to the TSC. At the TSC, f

o the data will be recorded on data sheets for data reduction I

and evaluation. All sample media are returned to SONGS or to lO f other designated locations for laboratory analysis, i - -

l Monitoring data is compared to the results of dose lO l projections, and the results of these comparisons will be

~ used to upgrade preliminary assessments and to formulate or revise protective action recommendations. (Barr, Tr.

!O i 7170-7171.)

1 i 116 lO s

O 222. Each monitoring team will have a motor vehicle 8 and equipment to monitor low levels and high levels of beta-gamma surface contamination levels and alpha contamination levels. Each team will have a portable air

1. sampler which will be used to collect air samples to check for iodine and particulate radicactivity. Appropriate quantities of support material will be provided, such as 8 sample bags, water sample containers, air sample filter media, emergency implementing procedures, maps and data recording material. Each team will be provided with

• appropriate respiratory protection equipment, as required.

(Barr, Tr. 7171-7172.)

223. Each monitoring team will consist of a highly D trained health physics technician and one other person assigned from the SONGS maintenance department. The health physics technician will perform all of the required D monitoring duties and communication with the TSC. The maintenance worker will be under the direction of the health

~ physics technician and will assist in transporting equipment, D driving the survey vehicle, recording data, and providing any other assistance required by the health physics technician.

(Barr, Tr. 7173-7174.)

D 224. The Plume EPZ has been separated into 16 22-1/2 degree pie shaped sectors with SONGS at the focus l

point of the sectors. Offsite monitoring teams would be O dispatched to the downwind sector based on the known wind 117 O

direction at the time of the release. Other teams would bt J dispatched to each of the sectors adjacent to the downwind sector. As a result, there will be team coverage of a 67-1/2 degree sector. Teams will perform radiation air sample measurements as they move through the sectors and at specific locations selected by the Manager. Health Physics. In order to determine the exact location where any particular reading or sample would be taken offsite, aerial maps of the Plume EPZ are being made and will include a radial-circular gridwork of linec to specify exact lection of measurements a

and samples. Radial grid lines will be labeled with numeric characters. The grid coordinates will also be used to deploy offsite survey teams to specific locations. (Barr, Tr.

7172-7173.)

225. The Manager, Health Physics, for SONGS testified that he is capable of initially deploying within

~

about 30 minutes at least two offsite monitoring teams and three teams once SONGS 2 & 3 are both operational to each of the three sectors described above. These teams could be

^

augmented with two additional teams within about sixty minutes, if necessary. These teams provide an adequate level of offsite monitoring. Additional teams would be dispatched as additional manpower becomes available. (Barr, Tr. 7173, 9070-9071.)

226. A radiological emergency mutual assistance

)

agreement exists between SCE, Pacific Gas & Electric Company 118 3

O (operator of Diablo Canyon) and Sacramento Municipal O Utilities District (operator of Rancho Seco). Pursuant to this agreement additional trained personnel and equipment from the participating parties can be used for offsite radiation monitoring and dose assessment. (Exhibit #101; Barr, Tr. 7174.)

227. An agreement also exists between SCE and O

Environmental Analysis Laboratories ("EAL"). EAL provides radiological analytical services in support of routine and emergency operations. EAL support for environmental sample O

analysis is also available. (Exhibit #51, Appendix E; Barr, Tr. 7174-7175.)

228. An agreement also exists between SCE and O

General Atomic ("GA") for analysis of emergency samples at the GA offices in San Diego, California. (Barr, Tr. 7175.)

229. There is substantial uncontroverted evidence O

in the record that SCE itself has a sufficient staff of trained dose assessment and radiation monitoring personnel at SONGS 2 & 3 to adequately accomplish all necessary offsite O

radiological dose assessment and protective action recommendation functions within the Plume EPZ. This capability is only enhanced by the resources available from O

Pacific Gas and Electric Company, the Sacramento Municipal Utilities District, EAL and GA. SCE's capabilities satisfy the standards for offsite dose assessment and radiation O

monitoring capability without consideration of the offsite 119 O

D radiation monitoring and dose assessment capability of

) Federal, State and local agencies. (Barr, Tr. 7175-7176; Pilmer, Tr. 7379; Sears, Tr. 11039; see NUREG-0654, II.I.8.)

230. To further enhance its capabilities for

) radiological dose assessment and protective action recommendations, SCE is currently developing a more advanced method at SONGS 2 & 3 te perform offsite dose calculations.

D SCE has purchased a Health Physics Computer System ("HP Computer") to be implemented within the next year as an aid in performing offsite dose calculations in accordance with J NRC requirements. This system will have the capability to assess the consequences of a potential or actual radiological emergency condition within the Plume EPZ by providing

)

continuous online monitoring of possible release paths for radioactive materials to the environment, the current meteorological conditions, and the ca_culations of offsite

) dose projections. (Barr, Tr 7176.)

231. SCE has established the Offsite Dose Assessment Center ("ODAC"). The ODAC is located in the

) Interim EOF to direct offsite emergency response organization dose assessment and monitoring activities and to coordinate these activities with SCE's activities in this regard.

) (Exhibit #142; Filmer, Tr. 7379.)

232. The ODAC will be set up following the declaration of a " Site Emergency" or " General Emergency".

J The ODAC functions as the technical offsite center for the 120

)

O coordination of radiological and environmental assessments.

J The coordinator for ODAC is a health physicist from the Orange County Department of Health Services. It is also staffed with health physicists from SCE, an SCE 9

meteorologist, and other staff required for communications, analytical analyses and maintenance of status board displays. The State Department of Health Services may also provide health physicists or other staff in support of ODAC functions, as demmed necessary. (Exhibit #142, Interveners' Exhibit #23, III.B.2.c.(2); Pilmer, Tr. 7379.)

)

233. The ODAC receives technical data from both onsite and offsite sources via designated communications systems. Technical data from both onsite calculations and

~

offsite measurements are transcribed to hard copy, interpreted, displayed, summarized and disseminated to offsite agencies by the ODAC technical staff. The ODAC D

management utilizes the summarized technical data in deploying field survey teams and in making recommendations of

~

protective actions to the EOFCAC and the EOC's. The ODAC is responsible for providing all involved offsite agencies with current status reports. Each EOC will use the reports in the self-determination of the protective actions to be taken q

within its jurisdiction. The CDAC will also function in an advisory capacity in providing technical interpretations and support of the offsite agencies. (Filmer, Tr. 7379-7380.)

121 y

G 234. SCE has developed standard operating O procedures for the ODAC, and supplied the communications, radiation monitoring and other equipment necessary for the proper operation of the ODAC. (Exhibiu '142; Pilmer, Tr.

W 7380, 9207; see FF. 200 and 204 supra.)

l

3. Offsite Emergency Response Organization Resources and Capabilities.

235. In the event of an emergency, the SCE 3

emergency response organization at SONGS would be primarily relied upon for offsite dose assessment and radiation monitoring. However, these activities will be augmented by 3 ~

the significant resources and capabilities of the Counties, the USMC, the City of San Clemente and the CHP in this 3 regard. Each has equipment for performing radiation monitoring and dose assessments and personnel trained in such monitoring and assessment operations. (Murri, Tr. 7238-7239; Turner, Tr. 8919-8921; Coleman, Tr. 8607-8608; Hunt, Tr.

}

9276; Wallace, Tr. 9335-9338; Killingsworth, Tr. 8294-8296.)

236. In addition, local response agencies all have 3 the capability of obtaining additional dose assessment and radiation monitoring assistance from the State Department of Health Services and the United States Department of Energy.

3 (Intervenors' Exhibit #23,Section V.A.3 and V.C.2; Murri, Tr. 7239; see 45 Fed. Reg. 84911 et seq., December 23, 1980.)

)

122 D

r i

l 3

i l

l l 237. The May 13 exercise demonstrated that the capabilities for dose assessment shown by the State and local l officials operating in the ODAC were adequate to protect the l public health and safety. (Exhibit #141, Intervenors'

) Exhibit #14, p. II-36; Murri, Tr. 7240.)

238. SCE end the involved offaite emergency response organizations are currently implementing a training

)

I program to further improve offsite dose assessment and monitoring capabilities. (Exhibits #111, #157, #158; Murri, Tr. 7240; Pilmer, Tr. 7393, 9209, 11108-11111.)

D 239. SCE has provided the various involved offsite emergency response agencies with the additional communications and radiation monitoring equipment required by

)

l these agencies to properly assist in offsite radiation l

l monitoring activities. (Exhibit #149(d); Pilmer, Tr. 9207.)

l 240. The substantial capabilities of the State of

) California, the Counties, the City of San Clemente, the CHP, and the USMC to assist in radiation monitoring and dose l assessment and the coordination of their efforts and those of

)

SCE through the ODAC provides additional assurance that there

is an adequate capability for assessing and monitoring actual l

l or potential offsite consequences of a radiological condition b

l in the Plume EPZ. The on-going training and the required periodic drills and exercises of the SCE and offsite agency capability to conduct offsite dose assessment and radiation

)

provides additional support for this assurance.

123

)

G. CONTENTION 2J (Ingestion EPZ Radiation Monitoring and Dose Assessment).

)

"Whether there is reasonable assurance that the emergency response planning and capability of implementation for SONGS 2 and 3, affecting the offsite transient and permanent population, will comply with 10

) C.F.R. 950.47(a)(1) and (c)(1) as regards:

J. the methods, systems and equipment for

) assessing and monitoring actual or potential offsite consequences of a radiological emergency condition within the ingestion pathway EPZ for SONGS 2 and 3, 10 C.F.R. 550.47(b)(9); . . . ."

j 1. Introduction 241. Mr. D. F. Filmer was the primary witness for the Applicants regarding the relationship of the

] organizations principally involved in protective response within the ingestion-pathway emergency planning zone

(" Ingestion EPZ"). Neither the-Staff nor the Intervenors 3 provided any witnesses directly on this subject. (Pilmer, Tr. 7381-7384.)

242. Mr. D. F. Filmer was the primary witness for 3 the Applicants regarding inventory of land use data within the Ingestion EPZ. Neither the Staff nor the Intervenors provided any witnesses directly on this subject. (Filmer,

) Tr. 7832.)

243. Mr. D. F. Filmer was the primary witness for the Applicants; Mr. J. Kearns was the primary witness for the

) Intervenors; and Mr. K. W. Nauman was the primary _ witness for 124

)-

)

L p

the Staff regarding procedures for estimating dose commitment-

) consequences and for protecting the public from consequences of Ingestion EPZ contamination. (Pilmer, Tr. 7834; Kearns, Tr. 10187; Nauman, written testimony (August 24, 1981),

) p. 14, Tr. 10372.)

2. Relationship of Organizations Principally Involved in Protective Response Within the Ingestion EPZ.

) 244. Numerous Federal, State and local emergency response arganizations may be involve;l in assessing and monitoring within the Ingestion EPZ. (Pilmer, Tr. 7381-7383.)

) 245. The applicable NUREG-0654 evaluation criteria indicate that the primary responsibility for implementing offsite emergency response actions with respect to the

) Ingestion EPZ rests at the State level, and that the Applicants and the local government agencies have the responsibility of supporting the State, or providing

) emergency response plans in the avent the State has not completed its efforts. (Filmer, Tr. 7381; see NUREG-0654, II.J.11.)

) 246. The Radiological Health Section of the State Department of Health Services ("DHS") is the lead State agency responsible for the preparation of planning for the

)

Ingestion EPZ for SONGS 2 & 3. DHS has developed an Ingestion EPZ plan and procedures, which were to be finalized in early October. (Exhibit #159; Intervenors' Exhibit 23,

) pp. 27, 31; Pilmer, Tr. 9198; Kearns, Tr. 10187.)

125

)

l 247. DHS works with the counties located in'the Ingestion EPZ's 50-mile radius in. developing procedures in order to complete the total ingestion pathway planning process. The entire or a small portion of the following

) counties are located within the Ingestion EPZ:

o Orange County; o San Diego County; o Riverside County; o San Bernardino County; and o Los Angeles County.

(Exhibits #142, #152(g), #153(g); Pilmer, Tr. 9197-9198; Kearns, Tr. 10187.)

l 248. The State and local agencies responsible for

) implementating ingestion pathway emergency response plans can rely on: SCE for overall support; the U.S. Department of .

1 Energy to coordinate and perform the required monitoring

) (short term); the U.S. Environmental Protection Agency for providing guidance on response levels, hazard assessment, and

! intermediate and long-term monitoring; and the U.S.

)' Department of Agriculture for guidance in assessing and implementing the appropriate protective measures. (Pilmer, Tr. 7381; see 45 Fed. Reg. 84910, December 23, 1980.)

) 249. Ingestion EPZ monitoring and dose assessment will be coordinated by the Offsite Dose Assessment . Center

("ODAC"). A representative from DHS will be at the ODAC,

? participating in dose assessment and developing 126

)

h recommendations to the local jurisdictions. (Pilmer, Tr.

h) 11123.)

3. Inventory of Land Use Data Within the Ingestion Pathway EPZ.

j 250. The Applicants engaged the consulting earth l sciences firm of Dames & Moore to perform a baseline study

(" Ingestion EPZ Study") of the Ingestion EPZ surrounding (Exhibit #121.) Based on the information provided in SONGS.

]

the Ingestion EPZ Study, a general plan and implementing procedures have been substantially completed in conformance 3 with requirements for Ingestion EPZ planning. (Exhibits

1. 121, #152(g), #153(g), #159; Pilmer, Tr. 7388.)

251. The Ingestion EPZ Study provides quantitative

) information in the following areas:

a) Identification of primary food pathways around SONGS;

) b) Farm commodity components; c) Agricultural land use acreages; d) Agriculture production by county;

} e) Cattle feed - estimated sources and consumption patterns; f) Major open water reservoirs; and

} g) Seafood production near SONGS. (Exhibit

1. 121; see NUREG-0654, II.J.11.)

252. The Ingestion EPZ Study presents a map out to

) 50 miles from the SONGS which displays the land use patterns 127

)

O and indicates the location of the following land use 8 categories:

a) Rangeland; b) Cropland and pasture; O

c) Orchards, groves, and vineyards (including nurseries and ornamental crops);

d) Confined feeding operations; and O

e) Reservoirs and lakes. (Exhibit #121; Fig. 1.1; see NUREG-0654, II.J.11.)

253. The Ingestion EPZ Study identifies and 9

quantifies the radionuclide ingestion pathways present within the Ingestion EPZ, the likely access points to these pathways for radionuclides, the types of radionuclides likely to be D released during different types of accidents, and the potential doses or dose equivalents to humans as a result of the projected contamination of food supplies. (Exhibit #121; see NUREG-0654, II.J.11.)

254. The Ingestion EPZ Study has been submitted for review by DHS and has~ generally been found to be acceptable D and consistent with DHS plans and procedures for the Ingestion EPZ. (Exhibit #159; Pilmer Tr. 11114-11115.)

4. Procedures For Contamination Detection.

D 255. Upon r, quest by the ODAC, SCE and designate';

EOC's will deploy ingestion pathway sampling teams. These teams will collect food samples and perform a preliminary O

analysis of the samples to determine whether the samples are 128 D

O contaminated. Samples will be labeled and brought to the O ODAC for further analysis. (Exhibit #142, p. 25.)

256. At the ODAC, the samples will be reavalyzed by SCE Health Physicists. Both GM detector and Na.T analyses O will be performed, which will provide results of radioactivity concentrations on the samples for the most significant radionuclides. (Exhibit #142, p. 25.)

0 257. After samples are analyzed at the ODAC, they will be sent to radiation laboratories where they will undergo specific radionuclide analyses. The laboratory O analysis results will be reported to the ODAC. (Exhibit

1. 142, p. 26.)

5. Procedure for Estimating Dose Commitment Consequences And Protecting the Public

~O From Concequences c; Ingestion EPZ Contamination.

258. The projected dose commitments for the Ingesti n EPZ will be calculated at the ODAC by SCE Health O

Physicists. (Exhibit #142, p. 27.)

259. Projected dose commitments will be compared to g the protective action guidelines. The ODAC coordinator will formulate a recommendatior, for control measures and/or protective actions necessary to protect the public and

.g provide this recommendation to the DEOF, which will forward this information to the EOCs. (Exhibit #142, p. 20.)

260. Protective actions available to implement the g CDAC coordinator's recommendation include, 129 O

O o Place dairy cattle on stored feed; O o Impoundment; o Decontamination; o Processing; O o Product diversion; o Preservation; and o Crop condemnation.

O (E'xhibit #142, pp. 21, 24-30; #143; Pilmer, Tr. 7385-7387.)

261. Based on the ODAC coordinator's recommendation, the responsible official in each jurisdiction O will make protective action decisions which will be released to the general public via the EMC and the Emergency Broadcast j Network. (Exhibit #142, p. 29.)

'O j 262. State and county health and agriculture I officials will also contact processors and_ distributors in i

j the contaminated area te interdict, as appropriate, the

'O i distribution and consumption of water and food stuffs

identified in the area. (Pilmer, Tr. 7387; Ehling, I

l Tr. 9976-9977.)

O

6. Time Available to Take Protective

{ Actions Within the Ingestion Pathway EPZ.

I 263. Extensive preplanning for Ingestion EPZ dose g assessmer.t and radiation monitoring is not necessary because of the time available to take protective actions. There is sufficient time between an actual accident and the deposition

() of radioactive materials in the Ingestion EPZ to do sample 130 0

O 2

monitoring, identify contaminated areas, and notify

)

1 appropriate processors and distributors. (Pilmer, Tr.

7387-7389 11123; Ehling, Tr. 9976-9977; Nauman, Tr.

10939-10941.)

I) 264. Based on the substantial and uncontroverted evidence in the record, there is reasonable assurance that the methods, systems, and equipment for assessing and

!O j monitoring actual or potential offsite consequences of a

radiological emergency condition within the Ingestion EPZ are adequate and capable of being implemented.

O H. CONTENTION 2G (Radiological Emergency Response Training).

"Whether.there is reasonable assurance that the emergency response planning and

O capability of implementation for SONGS 2 and 3, affecting the offsite transient and permanent population, will comply with 10 C.F.R. S 50.47 (a)(1) and (b) or (c)(1) as regards:

l

D

G. radiological emergency response training to those who may be called on to assist in an emergency, 10 C.F.R. S 50.47 (b)(15); . . . .

1. Introduction O

265. Mr. J. L. Willis was the primary witness for the Applicants; and Mr. J. R. Sears was the primary witness for the Staff regarding the scope and content of onsite

O training. Intervenors did not present any witnesses on this subject. (Willis, Tr. 7025-7032; Sears, written testimony (August 6, 1981), pp. 9-10, Tr. 10644.)

'O

266. Dr. R. E. Linnemann was the primary witness for the Applicants, and Mr. J. R. Sears was the primary 131 O

9 witness for the Staff regarding the training provided to O

those who may be called upon to provide first aid or medical services onsite or offsite in the event of an emergency.

Intervenors did not present any witnesses with respect to O

training for first aid or medical services. (Linnemann, Tr. 7102-7116; Sears, written testimony (August 6, 1981) pp. 7, 8 and 10, Tr. 10644.)

267. Messrs. E. L. Murri, D. F. Filmer, B. Killingsworth, C. Nash, J. P. Stowe, R. J. Coleman, E. S. Turner, J. W. Hunt, Ms. C. S. Ferguson, Ms. B. Fox and Mrs. J. M. Swansen, were the primary witnesses for the Applicants; Ms. J. Goodwin, Dr. R. L. Ehling and Dr. M. F.

Reed were the primary witnesses for the Intervenors; and Mr.

D K. W. Nauman was the primary witness for the Staff regarding the on-going general radiological emergency training program for offsite emergency response organizations. (Murri, Tr.

J 7254-7255; Pilmer, Tr. 11110-11111, 11121; Killingsworth, Tr.

8294-8295; Nash, Tr. 8427; Stowe, Tr. 8549-8550; Coleman, Tr.

8605-8606: Ferguson, Tr. 8692; Swnnson, Tr. 8807-8808; J

Turner, Tr. 8923-8924; Fox, Tr. 9028; Hunt, Tr. 9275-9276; Goodwin, Tr. 9902-9903; Ehling, Tr. 9931-9935; Reed, Tr.

10215-10217; Nauman, written testimony (August 24, 1981), p.

s 11, Tr. 10372.)

2. Scoce and Content of Onsite Training 268. Mr. J. L. Willis, Manager, Nuclear Training, J

for SCE testified concerning the onsite radiological 132

O emergency response training for those who may be called on to O assist in an emergency. Those responsible for the direction and coordination of emergency response actions all have had extensive nuclear power plant experience and training as a C) part of their job qualifications. These personnel receive additional specific training on the organization, structure and duties set forth in the Emergency Plan for SONGS 2 and 3, O April, 1981, (" Emergency Plan"), as well as the implementing procedures to be followed in the event of an emergency.

Personnel directly involved in assessment of possible O accidents have also had extensive nuclear power plant experience and training. In addition to specific instruction in the Emergency Plan, these personnel receive training on O

specific procedures detailing actions to be taken to support plan implementation. (Exhibit #51, Section 5; Willis,

Tr. 7025-7206.)

O 269. SCE's Training Memorandum 10-81 (" Training l

Memorandum") describes the training provided to onsite personnel. This Memorandum identifies specific training for O

i the following categories of emergency personnel:

i

a. Directors and/or coordinators of the response i

organizations;

.O.

b. Personnel responsible for accident assessment; t

c. Radiological monitoring te.ams and radiological analysis personnel;

'O

d. Police, security, and fire-fighting personnel; 133

O

)

e. Repair and damage control / correctional action

) teams (onsite);

f. First aid and rescue personnel;

g. Local support services personnel including

) Civil Defense / Emergency Service personnel;

h. Medical support personnel;

i. Licensee's headquarters support personnel; and

) j. Personnel responsible for transmission of emergency information and instructions. (Exhibit #62; Willis, Tr. 7028-7029.)

) 270. Each category of emergency personnel is instructed on the specific portions of the Emergency Plan and implementing procedures related to their duties during

) emergencies. Enclosure (1) of the Training Memorandum identifies the specific training requirements for each personnel category. Although they are grouped differently, the personnel categories identified in Enclosure (1) include all of the categories set forth in NUREG-0654, II.O.4.

Enclosure (1) also identifies the initial training, annual J retraining and annual retraining on changes only for each category of personnel. Enclosure (2) of the Training Memorandum and Exhibits #63, #64 and #65 contain the

) curricula outlines for the training subjects set forth in Enclosure (1). (Exhibits #62-65; Willis, Tr. 7025-7029; Sears, written testimony (August 6, 1981) p. 9, Tr. 10644.)

) .

134 D

D 271. The training program set forth in the Training 3 Memorandum is currently being conducted in accordance with the curricula outlines. Initial training in support of the SONGS 2 & 3 Emergency Plan is in progress and will be D completed prior to fuel load for Unit 2. At that time, tho first designated teams which will staff Unit 2 will have received all of the initial training identified in D Enclosure 1 of the Training Memorandum in accordance with the curricula outlines. Additional teams will receive *his initial training on an on-going basis to assure the D availability of sufficient trained personnel at all times.

(Exhibit #62; Willis, Tr. 6984-6985, 7030.)

272. The training includes classroom lectures and D drills in which each individual must demonstrates ability to perform his or her assigned emergency function. During the practical drills, on-the-spot correction of erroneous C performance is made and proper performance is demonstrated by the instructor. (Willis, Tr. 7030-7031.)

273. Two first aid courses are provided as part of D the onsite training, basic first aid and advanced first aid.

The latter is desianed to be and is equivalent to the Red l

( Cross multi-media first aid training. In addition, the D Applicants have contracted with RMC to obcain its Emergency j

i I

Medical Assistance Program ("EMAP"). Part of EMAP includes additional training and drills for onsite first aid and O

rescue personnel. This additional training inrures that the I 135 3

l

\

O onsite first aid training and capability is adequate.

O (Exhibit #100; Willis, Tr. 7031-7032; Linnemann, Tr. 7104.)

274. Although personnel turnover exists within the SCE emergency response organization, as it does within any O

organization, this turnover does not affect the training since there are always sufficient trained personnel to carry out the emergency functions. (Willis, Tr. 6980-6981, O 6984-6985; see Statement of Counsel (Mr. Pigott), Tr. 11359-11360.)

275. Mr. H. B. Ray, Station Manager of SONGS, O

explained that no specific training on site access procedures is required for local services' support organizations who may enter the site. Onsite personnel, primarily security O

personnel, are instructed to meet such support organization personnel at the entrance to the site and escort them to the areas where they are required. Specific procedures also O

exist to admit support organization personnel during emergencies. (Ray, Tr. 7866-7868.)

276. Based on the substantial and uncontroverted O

evidence in the record, the radiological emergency response training being provided to onsite personnel at SONGS who may be called upon to assist in an emergency is adequate.

.O (Willis, Tr. 7032; Sears, written testimony (August 6, 1981),

p. 10, Tr. 10644.)

3. Scone and Content of Offsite Training O

277. SCE has developed an on-going program, in cooperation with the involved offsite emergency response 136 O

O organizations, to provide radiological emergency response e

training to those within these organizations who may be called on to assist in an emergency. (Exhibits #111, #157,

1. 158; Pilmer, Tr. 7395; Linnemann, Tr. 7102; Murri, O

Tr. 7254-7255; Turner, Tr. 8924; Fox, Tr. 9028; Hunt, Tr.

9275; Coleman, Tr. 8605.)

278. The Counties, the Cities, the Red Cross, State O

Parks, and the Capistrano Unified School District maintain general radiological emergency response training programs for their personnel, and are participating in the radiological D

emergency response training program being offered by SCE.

The USMC also maintains a radiological emergency training program for its personnel. (Turner, Tr. 8923-8924; Hunt, D

Tr. 9275-9276; Wallace, Tr. 9318; Nash, Tr. 8427; Stowe, Tr. 8549-8550; Swanson, Tr. 8807-8808; Ferguson, Tr. 8692; Coleman, Tr. 8605-8606.)

D 279. SCE's offsite radiological emergency training program commenced in March, 1981. At SCE's request, the Radiation Management Corporation ("RMC") provided radiological emergency training to personnel of private and public agencies within Orange and San Diego Counties who l

\

might be called on to assist in an emergency response to an accident at SONGS. The Orange County training took place March 23 through March 26, 1981. The San Diego County training took place April 20 tnrough April 24, 1981.. In J

Orange County, training was presented to 127 people who 137

)

~

4

O represented 29 offsite organizations. In San Diego, training O was presented to 259 people representing 76 offsite response agencies. RMC has been requested to provide additional training in the future. (Exhibits #85, #86; Linnemann, g*

Tr. 7091-7092.)

280. The RMC training introduced those in attendance to an understanding of ionizing radiation, O

including the biological effects and medical significance of radiation exposure; provided each attendee with the medical basis for decision-making in the event of an offsite release

O of radiation; explained the basic protective actions which can be taken to reduce exposure levels in the event of an accident; provided specific training concerning notification

O and response requirements; reviewed the various responsibilities of physicians and hospital personnel, emergency response managers, and general emergency response

.O personnel; and provided situational exerciser for reinforcement of each participant's understanding of the coordination required for response to various. types of O

nuclear power plant emergencies. (Exhibits #88 - 92; Linnemann, Tr. 7093-7098.) t 281. At SCE's request, RMC is also conducting an ,

O on-going radiological emergency training program for hospital, medical and ambulance staffs at the Tri-City, South Coast and San Clemente General hospitals and other ambulance O

personnel with whom SCE has agreements for support, as part 138 O

O

-of EMAP. This training is designed to maintain a state of 43 preparedness for onsite and offrite medical personnel to effectively respond to a radiological emergency involving radiation induced or complicated injuries. (Exhibits #88 -

O 92: Linnemann, Tr. 7099-7102; Hauck, Tr. 7122.)

282. At SCE's request, 'che NUS Corporation has also developed a program of initial training and periodic O retraining for offsite emergency response personnel involving the proper procedures for direct and control, notification and basic radiation protection, as related to their specific

(

roles as emergency response directors or coordinators, accident assessment personnel, radiation monitoring personnel, police, security and fire fighting personnel, first aid and rescue personnel, support services personnel, or communications personnel. The NUS training program is designed to fan:lliarize offsite emergency response personnel

.-O with both the plans and standard operating procedures

(" SOPS") to be followed in the event of a radiological emergency at SONGS 2 & 3. Techniques to be used in the NUS

'O training program include lesson plans and written course material, classrocm instruction, table-top exercises and hands-on operation of equipment, as applicable. (Exhibit O-

1. 111, #157, #158; Murri, Tr. 7254-7255; Pilmer, Tr.

11110-11111, 11121.)

283. The NUS training program is being offered in I') -

two phases. The first phase of the NUS training program is divided into two distinct lesson plans. The first involves a 139 10

~

O one-day general radiological emergency planning and n" preparedness program. This program is designed to ensure interjurisdictional coordination during emergencies and to increase cc.nfidence in the radiological emergency planning.

O The program involves familiarization with SOPS and training in the functional areas of Direction and Control, Notification, Alert / Warning, Emergency Communications, O

Radiological Monitoring and Assessment, EOF Liaison, Ingestion Pathway Protection, Recovery, and Public Information. The second lesson plan in the first phase O

involves an intensive three-day course in radiological monitoring and dose assessment for both the Plume and Ingestion EPZs. (Exhibits #111, #157, #158; Murri, Tr. 7254; O

Pilmer, Tr. 11108-11110.)

284. The second phase of the NUS training program involves familiarization with SOPS and training in the

'O functional areas of EOC Operation, Law Enforcement / Security, Traffic Control, Fire, Medical / Rescue, Evacuation / Sheltering, Reception Centers and Mass Care, Transportation, O

Decontamination, Potassium Iodide Use, Training Exercises / Drills, and Logistical Support. (Exhibits #111; Pilmer, Tr. 9209; Murri, Tr. 7254.)

0 285. The NUS training program is currently underway and initial training of the personnel within the involved offsite emergency response organizations is expected to be O

completed prior to full power operation of SONGS 2.

140 0

O Thereafter, the NUS training program will be continued.in

'f3 order to maintain the necessary state of offsite preparedness. (Pilmer Tr. 9209, 11110-11111, 11121; Murri, Tr. 7254.)

'O' 286. Based upon the uncontroverted evidence in the record there is reasonable assurance that appropriate radiological emergency response training has heen and will

..O continue to be provided to onsite and offsite emergency response personnel who may be called on to assist in an emergency.

I. CONTENTION 2D (Medical Services for Injured Conta;minated Individuals).

"Whether there is reasonable assurance that the emergency response planning and O capability of implementation for SONGS 2 and 3, affecting the offsite transient and permanent population, will comply with 10 C.F.R. 550.47(a)(1) and (b) or (c)(1) as follows:

jO - - -

D. the arrangements for medical services for contaminated and injured individuals, 10 C.F.R. 550.47(b)(12);

'O

1. Introduction 287. Dr. R. E. Linnemann was the primary witness for the Applicants: Dr. I. Lyon (a biochemist) was the

!O primary witness for the Intervenors; and Messrs. H. Rood and E. K. Grimes were the primary vitnesses for the Staff regarding the number of contaminated and injured individuals

O for which medical services should be pre-arranged.

141

'O

!O Dr. Lyon's testimony in this regard was stricken from the O

record. (Linnemann, Tr. 7085-7087, 7108-7109, 10822-10826; Lyon, Tr. 10715-10718; Rood, Tr. 10322-10341; Grimes, Tr. 11007-11008.)

'O 288. Drs. R. E. Linnemann and J. E. Hauck were the primary witnesses for the Applicants regarding the type of medical services to be provided to contaminated and injured

.O individuals. The testimony of Dr. I. Lyon concerning the type of medical services to be provided to contaminated and injured indivicuals offered by Intervenors was struck by the

.O Board, and the Staff did not present any witnesses on this subject. (Linnemann, Tr. 7102-7108; Hauck, Tr. 7120-7121.)

289. Dr. J. E. Hauck was the primary witness for the Applicants: Dr. R. L. Ehling was the primary witness for

the Intervenors; and Mr. J. R. Sears was the primary witness for the Staff regarding the arrangements for medical services 10 to be provided to contaminated and injured individuals and the arrangements for transporting victims of radiological accidents to medical support facilities. (Hauck, Tr. 7122-7124; Ehling, Tr. 9982-9988; Sears, written testimony (August 6, 1981), p. 7, Tr. 10644.)

290. Dr. R. E. Linnemann was the primary witness O

for the Applicants and Mr. J. R. Sears was the primary witness for the Staff regarding the equipment for and training of hospital, ambulance and medical support O

personnel. Intervenors presented no witnesses on this 142 O

O subject. (Linnemann, Tr. 7091-7108; Sears, written testimony O (August 6, 1981), p. 7, Tr. 10644.)

2. The Number of Contaminated and Injured Individuals for Whom Medical Services Should Be Pre-Arranged O 291. Some pre-arrangement of medical facilities and services for onsite personnel and offsite emergency workers is necessary and required. (NUREG-0396, 44 Fed. Reg. 61123 O

(October 23, 1979), 45 Fed. Reg. 55402 et. seg. (August 17, 1980), and NUREG-0654, II.L.) However, no specific pre-arrangment of medical facilities and services for mass 0-care is required for the general public either within or beyond the EPZ. Mr. B. K. Grimes, the NRC's Director of Emergency Planning and Preparedness, Co-Chairman of the O

FEMArNRC Steering Committee which issued NUREG-0654 and Co-Chairman of the Task Force which issued NUREG-0396, testified that such arrangements were not contemplated or O

required by NUREG-0654. (Grimes, Tr. 11007-11008, 11059-11060; see NUREG-0396, p. 15.)

292. The NRC pol' icy and Mr. Grimes position are O

supported by the testimony of Dr. R. E. Linnemann. The characteristics of a release of radiation from an accident at a nuclear power plant and the characteristics of radiation O

itself mitigate against the possibility that a member of the general public offsite would receive a sufficient dose of radiation resulting in symptoms of radiation sickness, much O

less a hospitalization dose. (Linnemann, Tr. 7086.) To the j

1 extent monitoring of individuals for contamination is 143 0

O desirable, it does not need to be and should not be done at

() hospitals. If decontamination is required, it is a simple process not requiring hospitalization unless accompanied by traumatic injury. (Linnemann, Tr. 7085-7087, 10822.)

() 293. While no specific pre-arrangement for medical facilities is required for the general public within or beyond the EPZ, the pre-arrangments which do exist for onsite

O personnel and offsite emergency workers provide a basis for the treatment of the general public in the unlikely event the need should arise. Due to the nature of radiation injuries,

'O time is not a critical factor. Thus, arrangements for the treatment of the general public could be made on an ad hoc basis using the basic structure and training in place for the iO treatment of onsite personnel and emergency workers.

(Linnemann, Tr. 7102-7103, 7108-7109, 7746-7748, 10824-10826, 10830-10831, 10843-10846; Grimes, Tr. 11007, 11059-11060;

O Sears, Tr. 10711.)

294. While the likelihood for the need for medical services for the general public within or beyond the EPZ for

O contaminated and injured individuals is very remote, hospital facilities do exist within and beyond the EPZ to handle as many as 2,000 persons if the need should arise and even a O

l number as large as 31,000 could be handled on an area-wide (i.e. Southern California) basis. (Ehling, Tr. 9992-9993.)

l l

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[ >

9

3. The Type and Location of Medical Services (Including Transportation) to O Be Provided to Contaminated and Injured Individuals.

295. In the event of an accident at SONGS which

, results in injury and contamination, there are three levels of medical care which may be required:

o SONGS - Initial first aid, and possible g decontamination and evacuation of injured and contaminated patient (s);

o Support hospitals (local) - Emergency g treatment and decontamination of injured and contaminated patient (s); and o Radiation Medicine Centers - Exposure g evaluation and definitive care of radiation and accident victims. (Hauck, Tr. 7120-7121; Linnemann, Tr. 7102-7108.)

296. Applicants have provided that initial first g aid services will be available at SONGS. There will also be medical facilities at SCNGS capable of treating patients for injuries and diseases as well as for initial decontamination

7) depending on the type of injury. There will be one doctor and two registered nurses on duty at SONGS during the period 8 A.M. to 5 P.M. and at least two other persons qualified in g first aid methods onsite at all times. Training arranged for by the Applicants and provided by Applicants and RMC Corporation will ensure that the first aid and onsite medical

]) facilities are properly maintained and that proper equipment l

l i

l 145 9

O and supplies are available. (Exhibit #51, Section 6.5; O Hauck, Tr. 7121-7122; Willis, Tr. 7031-7032; Linnemann, Tr. 7104.)

297. Applicants have arranged with Scudder O Ambulance Company, Laguna Hills, California and Superior Ambulance Company, Oceanside, California for the transportation of patients from SONGS to local treatment O'

facilities. (Exhibit #51, Appendix A; Hauck, Tr. 7123.)

, 298. Additional, ambulance and transporation services may be called upon from Orange County or requested O'

from the USMC, if necessary. (Ehling, Tr. 9987-9988; Wallace, Tr. 9342, 9379-9382.)

299. Applicants have also contracted with three O'

support hospitals in the area to provide medical treatment facilities for patients suffering from injuries, injuries complicated by radiation contamination or excessive radiation O

as a consequence of activity at SONGS. The agreements are with South Coast Medical Center (previously known as South Coast Community Hospital), South Laguna, California, Tri-City O

Hospital, Oceanside, California; and San Clemente General Hospital, San Clemente, California. (Exhibit #51, Appendix A; Hauck, Tr. 7123-7124.)

g

300. Treatment of a traumatic injury or an injury complicated by contamination may take place at the three

( support hospitals with whom Applicants have contracted, after

!O 146 O

k

l O

initial treatment at SONGS if necessary. (Exhibit #51, O Appendix A; Hauck, Tr. 7123-7124.)

301. In the event of a traumatic injury complicated by contamination, evaluation of radiation exposure and uptake O does not need to be completed immediately. Treatment of the traumatic injury always takes precedence. When the traumatic injury has been stabilized, evaluation of radiation exposure O and uptake may be completed at the support hospitals or at a radiation medicine center. (Linnemann, Tr. 7084; Hauck, T r'. 7798.)

C 302. The Applicants have contracted directly with three medical doctors (Drs. Bernard L. Bundy and John P.

Chard, San Clemente, California and Dr. Joseph F. Ross, Los D-Angeles, California) to provide general medical treatment for any individuals suffering from injuries or injuries complicated by radioactive contamination as a consequence of O activity at SONGS.

In addition, SCE's Medical Director, Dr.

J. E. Hauck who testified at the hearing and whose office is at Rosemead, California, is available to provide consultat' ion O as well as general medical treatment for such individuals.

(Exhibit #51, Appendix A; Hauck, Tr. 7118-7119, 7124.)

303. As noted earlier, decontamination of persons O not otherwise injured may be required, but does not need to take place at hospitals or special facilities. Persons at SONGS who may be contaminated can be decontaminated at the Q'

decontamination facilities at SONGS. Persons not at SONGS 147 O

O who may be contaminated may be decontaminated at home or at O any facilities where showers are available. (Hauck, Tr. 7121-7122; Linnemann, Tr. 7087, 10822; Ehling, Tr. 9982.)

304. If a significant over-exposure were to occur, 9 there is a clinical course which will be followed and cannot be inte$upted. It evolves over the course of days and weeks. During the first few days, the patient's exposure can be evaluated at the support nospital, with assistance from RMC's consultants and laboratories. (Linnemann, Tr. 7102-7103, 10843-10844.)

O 305. As noted above, Applicants have contracted with RMC to obtain its Emergency Medical Assistance Program

("EMAP"). This program is designed to provide continuing O training, inspection of equipment and supplies, and drills for the medical support provided at SONGS and at the support i hospitals and ambulance companies with which Applicants have D contracted. EMAP is designed to develop and maintain l necessary medical services for contaminated and injured individuals. (Exhibit #100; Hauck, Tr. 7122-7123; Linnemann, O

Tr. 7102-7104.)

l 306. Through EMAP, Applicants also have available the services of Dr. R. E. Linnemann and other experts D

l employed by RMC on a 24-hour basis to provide consultation for the treatment of injuries complicated by contamination or j for patients who have received excessive radiation exposure D

as a consequence of activities at SONGS. Such assistance may l 148 D

l

O often be achieved by telephone and, if required, RMC may O dispatch a Radiation Emergency Medical (" REM") Team, consisting as a minimum of a radiation medicine physician, a certified health physicist and technicians with portable O instrumentation. (Linnemann, Tr. 7104.)

307. Although the REM Team might not arrive for some hourc following an injury or overexposure to radiation, O

such delay is not critical. Upon arrival the REM Team would assist the hospital in cleanup of contaminated areas and assist over the next days in the evaluction of the patients

)

exposure, dispatching bioassay samples to RMC's Chicago or Philadephia laboratories if necessary. These laboratories, which are part of RMC's backup support, are periodically O

reviewed for their capability to perform all types of i necessary analyses. Other RMC back-up support includes consultants in radiation medicine, radiochemistry and health O

physics, including expertise in dosimetry. (Linnemann, Tr. 7104-7105.)

308. If it is determined that a patient requires tO long term definitive care, the patient can be transferred to a medical center in California equipped to do the clinical treatment of radiation injuries or to one of RMC's definitive O

care centers, Northwestern Memorial Hospital in Chicago or the Hospital of the University of Pennsylvania in Philadelphia. If a center in California is chosen, it will O

have available RMC's radiation medicine expertise, exposure 149 0

O evaluation expertise, and bioassay laboratory capability.

O (Linnemann, Tr. 7106.)

4. The Equipment and Training of Hospital, Ambulance and Medical Support Personnel.

g 309. Under its EMAP program, RMC will ensur'e that local plant first aid, ambulance transporation, and support hospital emergency care capability are adequate thrcugh C semi-annual audits, and annual training and drills. The audits will consist of performing inventory of emergency medical equipment and supplies for handling injured and

() contaminated patients. All supplies will be checked for presence, location and expiration dates. Instruments will be checked and calibrated and p'ersonnel at each level of care g will be retrained annually in their respective responsibilities and procedures for the first aid and A

emergency care of radiation injuries. (Exhibits #93, #94; j() Linnemann, Tr. 7104.)

i 310. The EMAP program has been initiated at SONGS where emergency medical plans and training has been

!O evaluated. In addition, the plans, procedures, f acili ties, i

equipment and supplies at the ambulance companics providing i

transportation services and at the support hospitals have 4

'O been reviewed. Facilities at the support hospitals for handling contaminated patients have been reviewed and redesigned and equipment acquisition and placement has been

,o accomplished.

i 150 0

D 4

(Exhibit #94; Linnemann, Tr. 7107-7108.) RMC has also D reviewed and rewritten the support hospital's procedures for the handling of radiation accidents. These procedures have been reviewed by the support hospitals and presently are in D final form. Training in accordance with these procedures has also been accomplished as described above and will be repeated annually. (Exhibits #95-#97; Linnemann, 3

Tr. 7107-7108.)

5. Conclusions Regarding Adequacy of Arrangements for Contaminated and Injured Individuals.

D 311. The facilities, equipment and personnel at SONGS, and the ambulance companies and the three support hospitals can adequately' handle injured and contaminated D

patients from SONGS. (Linnemann, Tr. 7109-7111.)

312. The medical personnel with whom the Applicants have contracted and those who have attended RMC's programs D

under EMAP have been provided with instructions and procedures to handle multiple contaminated and injured

-patients. (Linnemann, Tr. 7108-7109.)

313. The support hospitals already have procedures to handle mass casualty situations which can be easily

! applied to handling multiple injured and contaminated b

patients, if necessary. Such patients would be triaged on the basis of their traumatic injury, not their contamination or radiation exposure status. Because time is on the side of l the doctor in an exposure or contamination case, such cases 151

)

i

/

)

involving multiple patients are much easier to handle than

) multiple patient disasters of other kinds. (Exhibits #95-97; Linnemann, Tr. 7108-7109, 10844-10845.)

314. The training already provided and the training

) to be provided by the Applicants and through the EMAP program in the future will ensure that local medical care at all levels (plant, ambulance and hospital) will be adequate for

) handling potentially injured and contaminated patients from SONGS. (Linnemann, Tr. 7109.)

315. The additional training seminars provided to

) representatives of local agencies within Orange and San Diego Counties strengthen the ability of the medical care in the area, increases the general ability of the medical services

) to treat injured and contaminated patients from SONGS and provides a basic structure to treat others if the need should arise. (Linnemann, Tr. 10830-10833.)

) 316. The State of California has not yet developed a list indicating the location of public, private and military hospitals and other emergency facilities within

) California and neighboring states which are considered capable of providing medical support for contaminated and injured individuals. However, the lack of such a list does

)' not present any problems in providing the necessary medical services for contaminated and injured individuals.

(Linnemann, Tr. 7110.)

)

152

)

0--

317. Applicants first aid training and capabilities O- at SONGS is adequate. (Willis, Tr. 7031; Linnemann, Tr. 7111.)

318. The training provided and the arrangements O made for transporting victims of radiological accidents to medical support facilities are1 adequate. (Linnemann, Tr. 7111.)

O 319. Applicants do have an adequate program to handle radiation injuries including contaminated and injured personnel. Local and backup hospital services for which the O

Applicants have arranged are capable of evaluat'ing exposure and uptake with the assurance that the persons providing such services are adequately prepared to handle contaminated individuals. (Linnemann, Tr. 7110-7111.)

320. In conclusion, based on the substantial and uncontroverted evidence in the record there are sufficient O

facilities and trained personnel at SONGS and in local support organizations to provide medical services for contaminated and injured individuals.

O J. CONTENTION 2C (Public Education and Information Program).

"Whether there is reasonable assurance that the emergency response planning and O capability of implementation for SONGS 2 and 3, affecting the offsite transient and permanent population, will comply with 10 C.F.R. $ 50.47(a)(1) and (b) or (c)(1) as follows:

O - - -

153 0

3-C. the information and the procedure for dissemination of the information to the

) public within the plume exposure pathway Emergency Planning Zone on a periodic basis on how they will be notified and what their actions should be in the event of an emergency, 10 C.F.R. 3 5 50.47(b)(7); . . . ."

1. Introduction 321. Mr. E. N. Cramer was the primary witness for the Applicants; Ms. C. Logue was the primary witness for 3

Intervenors; and Messrs. J. R. Sears and K. N. Nauman were the primary witnesses for the Staff regarding the content of 3 the public education and information program, the initial means of disseminating public education and information, the coverage of the public education and information program, the

] program to update and maintain a public education and information program on an annual basis and the program to acquaint news media with emergency plans, information

) concerning radiation and points of contact for-release of public information in an emergency. (Cramer, Tr. 7038-7052, 7074-7075; Logue, Tr. 10071; Sears, written testimony 3 ( August 6, 1981), p. 6, Tr. 10644; Nauman, written testimony

( August 24, 1981), pp. 8-9, Tr. 10372.)

322. Witnesses from local jurisdictions dnscribed 3 the public education and information programs al:eady l underway or to be developed by them in the future. (Coleman, l

Tr. 8577-8580; Stowe, Tr. 8493-8497; Ferguson, Tr. 8693-8694;

) Swanson, Tr. 8824-8825; Turner, Tr. 8908-8909; Hunt, l Tr. 9265; Wallace, Tr. 9328-9329.)

l 154 b

O

2. Content of Public Education and Information Program.

g 323. The principal means for providing specific information on responses to an emergency will be an Emergency g Response Pamphlet (" Pamphlet") prepared by Applicants in conjunction with local planning officials and based on the local emergency plans. The Pamphlet addresses the following O subjects relative to proper actions to be taken during an emergency:

o Public notification of an emergency; o Protective actions to take (including shelteting,

()

evacuation and reception and care facilities);

o School children; 9 o Preparing for an emergency; o obtaining special assistance for handicapped; o Dos and Do nots in an evacuation; and 9 o Maps containing area designations, public transportation assembly points and evacuation routes and reception centers.

() (Exhibit #66; Cramer, Tr. 7042-7043.)

324. Applicants have also prepared an Emergency i

Information Handbook (" Handbook") which, among other topics,

() covers general information about radiation, including radioactivity releases and radiation effects. The cbjective of the Handbook is to provide individuals with a basic 9 understanding of how and why emergency responses were l

l l

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155 3

i

P developed and will be applied and how and why various

() protective actions will be effective. The Handbook will be mailed to all mailing addresses within the Plume EPZ and Extended EPZ. It will also be made available through local

'O' governments and community groups for distribution within the community. (Exhibit #148; Cramer, Tr. 7047-7048, 7454-7455, 7506-7507.)

O 325. The Handbook and Pamphlet each provide contacts for additional information both prior to an emergency and during an emergency. In addition, Applicants

'O have taken other steps to provide contacts for information prior to an emergency and during an emergency. Such measures include identifying radio stations which will broadcast

O emergency information, newspaper advertisements, telephone book inserts, posters and placards, utility bill inserts, and community meetings, as well as special cards to be returned

'O by those persons wishing additional information or special assistance. (Exhibits #66, #68-71, #123-130, #348; Cramer, l Tr. 7044-7048; Sears, Tr. 10687-10690; Stowe, Tr. 8493-8497;

'O Coleman, Tr. 8577-8580; Ferguson, Tr. 8693-8694, 8717-8718; Turner, Tr. 8908-8909; Hunt, Tr. 9265; Wallace, l

Tr. 9328-9329; Nauman, Tr. 10540-10542, 10926; Sears, written IO l

testimony (August 6, 1981), p. 6, Tr. 10644.)

l

3. Coverage of the Public Information and Education Program.

O 326. The initial mailing of the Pamphlet was made 156 LD l

l

\

I O

on June 12, 1981 to certain residences within the portion of n

the Extended EPZ served by San Diego Gas & Electric Company.

Although initially there appeared to be some confusion concerning the area covered by this mailing, all residences O within the Extended EPZ other than those within Camp Pendleton (who have been given similar inforr.ation through their Base Housing Office) have been mailed copies of the O Pamphlet. News' paper advertisements and special mailed reminders as well as information released to the media refer to the availability of the Pamphlet and notifies residents that they should have received it. Such newspaper advertisements, publicity releases and special mailed reminders provide means to obtain copies of the Pamphlet if G

none were received or to'obtain additional copies of the Pamphlet. (Exhibits #66-77, #123-131; Cramer, Tr. 7044-7045, 7567-7569; Statement of Counsel (Mr. Pigott), Tr. 8728.)

O 327. Individial copies of the Pamphlet will be mailed to new residents within the Extended EPZ when they apply for electricity hookups or to have electricity turned O

on. (Cramer, Tr. 7041, 7045.)

328. Businesses will receive posters similar in format and content to the Pamphlet to be displayed in their n

establishments. Similarly, posters and flyers will be used at the State parks and beaches to provide emergency information to the users of these facilities. (Exhibits #69, O

157 O

O

1. 123-130; Cramer, Tr. 7049-7050; Stowe, Tr. 8493-8497.)

'O 329. Residents and transients will also be provided emergency information by means of telephone directory inserts, telephone booth _ecals and information placed in O hotels and rooming establishments. (Exhibits #69-71; Cramer, Tr. 7049.) l 330. Persons beyond the Extended EPZ who may hear O the warning sirens, will be mailed information similar to that contained in the Pamphlet and Handbook but which will not include specific information relating to evacuation and O

other items'which relate directly to those within the Plume and E:ttended EPZs. (Cramer, Tr. 7039.)

331. Others outside the Extended EPZ but within the O

Ingestion EPZ will also be mailed information relevant to their concerns in the event of an emergency. (Cramer, Tr. 7039.) .

O 332. Following the initial distribution of the Pamphlet and Handbook, Applicants plan to conduct, in

~

conjunction with local jurisdictions, community meetings to provide further information on radiation, to explain the available protective measures, to discuss the special needs of the handicapped and other special populations, and to O

answer any questions which may arise. (Cramer, Tr.-7455-7456,-7469, 7520-7522; Coleman, Tr. 8579; Ferguson, Tr. 8717-8718; Turner, Tr. 8909; Swanson, Tr. 8824-8825; O

158 O '

.O Mecham, Tr. 10065; Sears, written testimony (August 6, 1981),

O p. 6, Tr. 10644; Nauman, Tr. 10541.)

4. Applicants' Program to Update and Maintain Public Education and Information on an Annual Basis.

O 333. Applicants will ensure that all persons within the Extended EPZ have been provided the' basic public education and information through newspaper advertisements, O

utility bill inserts, community meetings and other means.

(Cramer, Tr. 7041.)

334. Those persons needing special assistance or O .

additional information may use the special response cards provided with the Pamphlet or may obtain the information or assistance they require by contacting those companies or

.O organizations who are identified in the utility bill inserts, advertisements and at community meetings. (Exhibits #68,

1. 131; Cramer, Tr. 7462-7463.)

O 335. Local jurisdictions plan to work closely with Applicants to insure that complete and proper information is provided to their residents. (Coleman, Tr. 8576-8577; lO Ferguson, Tr. 8694; Turner, Tr. 8909; Caravalho, Tr. 10809; Mecham, Tr. 10065.)

l 336. At least annually there will be a public

O information update including efforts to make certain that all -

persons are aware of the emergency information. If there are l

changes in the content of information which should be made lC i

l known to the public, revisions would be provided in the 159

'O i

1 O

annual general program update or earlier, if required.

O (Cramer, Tr. 7051-7o52.)

337. During the annual update the following information needs would be reviewed and revised as required:

D' o Placards and posters would be checked and resupplied; o Businesses would be checked and resupplied with O

posters and pamphlets; o Radio, TV and community organizations will be checked for presentations; and O

o Publicity releases would be circulated and newspaper advertisements used.

(Cramer, Tr. 7051-7052.)

'O 338. In addition, periedic utility bill inserts and other means will be used to make certain that all residents within the Plume and Extended EPZs know of and have copies of O

the Pamphlet and Handbook and that transients have access to such information. (Cramer, Tr. 7051.)

5. Applicants' Program to Acquaint News O Media with Emergency Plans, Information Concerning Radiation, and Points of Contact for Release of Public Information in an Emergencv.

339. The information available to residents and O

transients within the Plume and Extended EPZs directs them to information available to them in the event of an emergency such as that contained in the Handbook, the Pamphlet, O

telephone directories, and posters and placards. This information is also available to the media. (Exnibits 160 0

O

1. 69-71, #123-130; Cramer, Tr. 7049-7050.)

E) 340. An initial special orientation for the news media was to be held to acquaint news media with emergerey plans, information concerning radiation and points of contact O for release of public information and emergency. (Cramer, Tr. 7074.)

341. In order to facilitate information being O supplied to the media, training has been provided for the public information officers of the local jurisdictions and agencies. (Exhibit-#76; Cramer, Tr. 7063-7064.)

O 342. An annual program is planned which will include briefings of news media with emergency plans, information concerning radiation, and points of contact for O release of public information in an emergency. (Cramer, Tr. 7074.)

6. Conclusions Regarding Adequacy of g Emergency Public Education and News Media Education and General Information Program.

343. The public education and information program o developed by Applicants, in conjunction with the local jurisdictions, provides adequate public information and education to the resident and transient populations within O the Plume and Extended EPZs and to those outside the E?Z who may require information on how they will be notified and what their actions should be in the event of an emergency.

O (Cramer, Tr. 7075; Sears, written testimony (August 20, 161 0

O 1981), pp. 6-6A, Tr. 10644.)

8 344. The training and information provided to the media and public information officers of the local jurisdictions provides adequate information to acquaint news O media with the emergency plans, information concerning radiation, and points of contact for release of public information in an emergency. (Cramer, Tr. 7075.)

O K. CONTENTION 2B (Emergency Public Alert and Notification System).

"Whether there is reasonable assurance that the emergency response planning and capability of

, implementation for SONGS 2 & 3, affecting the offsite transient and permanent population, will comply witt 10 C.F.R. S 50.47(a)(1) and (b) or (c)(1) as regards:

3 B. the means for notification and instruction to the populace within the plume exposure pathway Emergency Planning Zone, 10 C.F.R. 5 50.47(b)(5); . . ."

1. Introduction D 345. Messrs. T. J. DuBois, H. B. Ray, and E. N. Cramer were the primary witnesses for the Applicants; and Messrs. J. R. Sears and K. W. Nauman were the primary D witnesses for the Staff regarding the administrative and physical means for prompt public alert and notification.

Intervenors did not present any witnesses directly on this D subject. (DuBois, Tr. 6997-7021; Ray, Tr. 7156-7157; Cramer, Tr. 7043; Sears, written testimony (August 6, 1981), pp. 5-6, Tr. 10644; Nauman, written testimony (August 24, 1981),

pp. 7-8, Tr. 10372.)

162 D

)

346. Representatives of each of the local

) jurisdictions and agencies involved described their participation in the prompt public alert and notification system and described how it will operate within their D jurisdictions. (Stowe, Tr. 8497; Coleman, Tr. 8584, 8599-8600; Ferguson. Tr. 8711-8712; Poorman, Tr. 8760-8763; Turner, Tr. 8914-8916; Hunt, Tr. 9273; Wallace, D

Tr. 9332-9333.)

347. Messrs. E. N. Cramer, D. W. Poorman, H. B. Ray, J. P. Stowe, R. J. Coleman, E. S. Turner,

) J. W. Hunt, B. Killingsworth and Col. J. E. Wallace were the primary witnesses for the Applicants; and Mr. K. W. Nauman were the primary witness for the Staff regarding the

) administrative and physical means for prompt emergency public instruction during an emergency. Intervenors did not present any witnesses directly on this subject. (Cramer,

)

Tr. 7043-7073; Poorman, Tr. 8757; Ray, Tr. 7156; Stowe, l Tr. 8493-8498; Coleman, Tr. 8596-8598; Turner, Tr. 8916;

. Hunt, Tr. 9259, 9272-7274; Wallace, Tr. 9372-9373; b

Killingsworth, Tr. 8271-8272; Nauman, written testimony (August 24, 1981), pp. 7-8, Tr. 10372.)

2. Administrative and Physical Means for

[) Prompt Public Alert and Notification.

348. Mr. T. J. DuBois described the prompt alerting j siren system now installed in the Plume EPZ and the 1

[) development of the system. Applicants commissioned two 163

)

L _ _ _ _ _ _ _ _ _ _ _

O independent acoustic consulting organizations, Wilbur Smith &

O Associates and Wyle Laboratories, to prepare studies concerning a prompt alerting system. These studies considered the topographical and existing ambient background O noise characteristics of the Plume EPZ and provided outline plans showing the number of sirens, the sound rating (i.e.,

the intensity-at a 100-foot radius) of commercially available O sirens, and potential locations within the Plums EPZ which would cover the populated area with an alerting signal.

(DuBois, Tr. 7004.)

O 349. The prompt alerting system was designed to provide an alerting signal within the Plume EPZ throughout all populated areas of San Clemente, San Juan Capistrano, the O

industrial areas of Orange County and, within San Diego County, at residential and administrative areas of Camp Pendleton and at Doheny, San Clemente and San Onofre State O

Beaches. (DuBois, Tr. 6998-6999.)

350. In considering the prompt alerting system, Applicants considered and followed the requirements and O

guidance set forth in Appendix 3 of NUREG-0654 (" Appendix 3")

and documents cited therein, including the FEMA publication,

" Outdoor Warning Systems Guide," CPG-1-17. (DuBois, O

Tr. 7002.)

351. The siren system which was selected to provide the tonal source is a well-proven, reliable, available and O

efficient system for alerting the public which meets the 164 O

l 3

specifications set forth in Appendix 3. (DuBois, Tr. 7000.)

O 352. Appendix 3, specifies that the sirens should produce a sound 10dB above average daytime ambient background. The value sought to be achieved by the sirens O was a sound level that would exceed in at least 98% of the time 10dB above the daytimo ambient noise levels as identified in the studies commissioned by Applicants. This

() required a level of 60dB(C) in residential areas removed from the San Diego Freeway, 63dB(C) or 65 dB(C) in beach recreational areas and 70dB(C) in areas close to the freeway O or major shopping centers. (DuBois, Tr. 7006-7007.)

353. In order to ensure tnat no person would be exposed to siren signals at levels which might harm them, a O

criterion for a maximum level of 123 dB(C) was incorporated in ..sNGS system by virtue of selection of minimum

, mounting heights for the various sirens. On this basis, no t

person will be. exposed to a level above 123 dB(C) no matter how close they approach the base of a siren mcunting pole.

I The net result is that the SONGS siren system provides more O protection, as far as the maximum level of sound exposure is concerned, than is called for by FEMA's design guidelines.

(DuBois, Tr. 7005-7006.)

'g l 354. Installation of the sirens within the Plume EPZ has been completed. Although not tested at the time of the hearing, their design basis is such that all persons out

!n~

of doors (other than those with s,erious hearing impairments) i j 165

)

will hear the sirens when activated, including those persons

) who may be in the surf off of the beaches within the Plume EPZ. If acoustic tests reveal areas where the coverage is not as expected, recommendations would be made for additional

) sirens. (DuBois, Tr. 6926, 6940, 8735, 8738.)

355. Studies done for the Applicants have established that during nighttime hours (i.e., 10:00 p.m. to

) 7:00 a.m.), when interior ambient noice levels are lower than they are during the day, the sirens installed in the SC"GS

. Plume EPZ will provide 100% coverage for those inside

) buildings. Exhibit #335 depicts the areas where there is also 100% coverage '.ndoors during daytime hours. This includes the areas covered by State Parks sirens SP 1-5, Camp

) Fendleton sirens CP 1-10, and Orange County sirens OC 4-8.

In the areas covere.i by San Juan Capistrano sirens SJ 1-3, Orange County sirens 00~ -3 and San Clemente sirens SC 1-14

) there is 100% coverage eutdoor both day and night and 100%

coverage indoors at night. During daytime hours coverage of these areas indoors would be approximately 85% at a minimum.

) However, even where the ambient noise level indoors is such that 90% of the tute the sirens would not be heard, during 10% of the time the sirens would be heard in such structures. For example, even where interior noise levels are at a high level due to music being played, the noise level drops d2e to quieter portions of the music or between

) selections. Thus, the coverage of the sirens should reach 166

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nearly all persons indoors at some time during the three to I) 'five minute period when the sirens are activated. (Exhibit

1. 135; DuBois, Tr. 8733-8738.)

356. The actual locations of the sirens are as follows:

o Ten sirens are located within Camp Pendleton; o Five sirens are located along San Onofre State O

Beach; o Fourteen sirens are located within the City of San Clemente; o Three sirens are located within the City of San Juan Capistrano; and o Eight sirens are located within unincorporated O

areas of Orange County. (Exhibit #60; DuBois, l Tr. 7012-7015.)

357. The actual location and coverage of these O

sirens is shown in Exhibits #61, #135. (Exhibits #61, #135; DuBois, Tr. 7001, 8734.)

! 358. With the exception of the sirens for use at

!O State Parks and Beaches, the sirens will be controlled by the jurisdictions in which they are located. The State Parks l sirens will be activated at the control room at Soh*GS.

O l Special arrangements exist to prevent accidental operation of i

l the sirens. (DuBois, Tr. 7016-7017; Ray, Tr. 7157; Coleman, Tr. 8652-8653; Ferguson, Tr. 8711; Turner, Tr. 8914; Wallace, lg i

Tr. 9333; Stowe, Tr. 8497.)

167

[O

l 0

l 35'9. With the exception of the City of San Juan O Capistrano, the locations where the sirens are to be activated are manned on a 24-hour per day basis. In the event the sirens require activation at a time when no one is present at City of San Juan Capistrano, their sirens may be activated by the City of San Clemente through the special arrangements which have been made. (Ray, Tr. 7157; Poorman,

.O Tr. 8760; Stowe, Tr. 8497; Ferguson, Tr. 8712; Coleman, l

Tr. 8584; Turner, Tr. 8914; Wallace, Tr. 9332-9333.)

j 360. When activated each siren will generate a

,0 three to five minute steady signal. The educational information provided to persons within the Plume and Extended EPZs, as well as other information to be made available on a

O -

nation-wide basis, informs people that such a signal means to i

" Turn on radio or TV, listen for essential emergency I

information." The Emergency Pamphlet and other parts of the

O i Public Information Program inform people which radio stations l

l will carry emergency information in their area. (Exhibits i

, #66, #67, #69-71, #123-130, #148; DuBois, Tr. 7000; Cramer, LO l Tr. 7043.)

l

! 361. In addition to the siren system, othe.r means i

also exist to provide prompt public alert and notification.

i O

l There is a public address system installed at the fence at the perimeter of SONGS which can be used to alert onsite personnel as well as those within the vicinity of SONGS. The i

r 168 lO l--

)

CHP, County Sheriffs Department and State Parks vehicles and

) helicopters are equipped with loud speakers which can be used to alert the public as well as to provide information.

Through an extensive and sophisticated communication cystem,

) Orange County Communications Control One, which has direct communications with SONGS, can immediately alert each of the 2,000 emergency vehicles in Orange County of an emergency and

) these vehicles may then be used to alert and inform the public. Similar communications exist with the CHE which can then alert their vehicles on patrol to alert and provide

) information for the public. These systems are available on a 24-hour per day basis and are used regularly. Thus they do not require specific testing for this purpose. (Exhibit #53,

)Section V.B.2.a.(1); Ray, Tr. 7156; Poorman, Tr. 8763, 8779-8700; Killingsworth, Tr. 8271-8272; Turner, Tr. 8916; Hunt, Tr. 9273.)

) 362. Local government agencies and others controlling the use of the sirens do have procedures for the use of such sirens. Through existing procedures, as well as

)

procedures curre'ntly being revised as part of tSe Interjurisdictional Planning Committee, coordinated use of the sirens is not only feasible but agreed upon. Through

) joint operating procedures, each jurisdiction has agreed to make every effort to coordinate activation of the sirens and not to activate the sirens without first notifying the other

)

169 .

)

)

jurisdictione even under emergency conditions. (Exhibits

) #152(d) #153(d) #154(d) #155(d) Pilmer, Tr. 11103; Wallace, Tr. 9333; Turner, Tr. 8914-8915; Coleman, Tr. 8599-8600; hauman, Tr. 10539.)

) 363. Although the siren system will be turned over to the local jurisdictions upon the completion of testing, maintenance of the system will be the responsibility of the D

Applicants who have agreed to assume this responsibility.

Continuing tests of various types were described by Mr. DuBois to insure that the systen remains operational.

) (DuBois, Tr. 7017-7020; Pilmer, Tr. 9208-9209.)

364. The public alert system consisting of the sirens as well as other means of public alert and

) notification, is adequate to promptly alert the public in the event of an emergency at SONGS.

3. Administrative and Physical Means for

) Prompt Emergency Public Instruction.

2ES. A number of means are available for promptly providing emergency instruction to the public. The primary

) means would be through the Emergency Broadcast System

("EBS"). Arrangements now exist within Orange County and San Diego County to utilize the EBS and arrangements are

) currently being completed for a better coverage of EBS within Orange County. EBS permits emergency notifications and instrpctions be broadcast over designated radio and

) television stations to insure accurate and prompt communication with the public.

170

)

O (Cramer, Tr. 7043-7044; Peorman, Tr. 8757; Hunt,

$) Tr. 9272-9273; Turner, Tr. 8915-8916.)

366. In addition to the EBS, San Clemente has  !

special arrangements with a radio station within the Plume O EPZ to broadcast emergency information to the public.

(Coleman, Tr. 8596-8597.)

l l 367. Other means also exist to provide emergency C

l public instruction. These include the United States Marine Corps communications system, the SONGS public address system, l loudspeaker-equipped emergency vehicles (including P helicopters) and Coast Guard communication systems.

t . .

(Wallace, Tr. 9372-9373; Pilmer, Tr. 9211-9212; Ray, Tr. 7156; Killingsworth, Tr. 8271-8272; Coleman, D-Tr. 8597-8598; Hunt, Tr. 9259, 9273; Turner, Tr. 8916; Nauman, Tr. 10509.)

368. In order to facilitate the providing of D

information to the public, each jurisdiction and agency has identified a public information officer ("PIO") to coordinate the flow of information to the media and to be a contact for D

the media. (Exhibit #72; Cramer, Tr. 7052.)

369. The Pios will initially be located'in their local jurisdictions. A designated PIO from each jurisdiction

)

will move to the Emergency Media Center ("EMC") when it is established. Another PIO will remain in the local jurisdiction. (Cramer, Tr. 7054, 7063, 7065.)

D 370. The EMC is located in the Boys and Girls Club 171 3-

.= -_ , -=

in San Clemente, approximately one half mile from the Interim O EOF. The physical layout and design were described by Mr. E. N. Cramer. (Exhibits #73, #74; Cramer, Tr. 7054.)

371. The activation of the EMC would commence O within 15 minutes of the notification of an Alert or more serious emergency declaration or when there was an indication of a build up of interest in the news media. The EMC is O capable of being set up within 15 minutes after personnel i

1 arrive. (Cramer, Tr. 7062-7063.)

372. Based on a review of the information available O'

to the PIOS at the EMC, they would aid in the coordination of the dissemination of information throughout the emergency or until an evacuation ' order was issued which included the area P

in which the EMC is situated. As each response agency takes an action or recommends a protection action, communications l with the public would include disseminating the information O

l originating from the ESC to those at the EMC for their I coordination and release purposes. (Cramer, Tr. 7052-7053.)

l 373. The Emergency Media Center will have 3

l communications established with SONGS, the corporate l

l headquarters of SCE, the EOCs of Orange and San Diego l

Counties, the Cities of San Clemente and San Juan Capistrano, the Unitec States Marine Corps Base, and the California Department of Parks and Recreation. Thus, the EMC has access to all necessary information and can aid in the exchange of O

information between agencies as well as between PIOS and l 172 D

- . -.... __ ~-

O media representatives. (Exhibit #77; Cramer, Tr. 7065-7066.)

O 374. An important element of public instruction is rumor control. The EMC plays an important role by providing access _for the PICS to deal directly with the media in a

() coordinated fashion. Since the Emergency Media Center is in communication with the EOF, information required to deal with rumors can be provided to the media. (Cramer, Tr. 7066-7067.)

O 375. Information to respond to and deal with rumors can be coordinated through the use of the Interagency Telephone System ("ITS") and the SCE and SDG&E Customer O

Information Systems. These systems enable decision-makers in various agencies and jurisdictions to become aware of the most recent information promptly and to coordinate release of O

information to the public in order to prevent rumors from starting or to respond to existing rumors. Such systems can also be used to inform decision-makers of the existence of O

rumors so that information can be released dealing with the subject matter of the rumors. (Cramer, Tr. 7067-7074.)

376. Both SCE and SDG&E have Customer Information O

Systems which are coordinated and can be used to provide information to the public as well as to their employees.

Both systems provide "hard copy" data transmission. The SCE O

Customer Information System has been installed at the EOF as well as at the EMC so the networks can be used as part of the

• umor control system. Persons who call any of SCE's offices

!O can thus be provided with up-to-date and accurate information.

173

)

L

)

In addition, arrangements have also been made to provide

) accurate information to those persons at SCE who may receive calls from the public, i.e., the SCE Speakers Bureau and the Edison Newspaper. (Exhibit #80; Cramer, Tr. 7068-7070.)

) 377. SDG&E has a similar external rumor control system. A terminal of SCE's Customer Information System is located at the SDG&E headquarters in order to supply

) information to SDG&E and to coordinate the release of information. Further information may be disseminated by telephones at the SDG&E Business Office in San Clemente.

) (Cramer, Tr. 7071-7172.)

378. Both SCE and SDG&E also have internal rumor control capabilities to inform their employees of the status

) during an emergency and what such employees should do, if anything, in connection with the emergency. Such c'jstemu include telephone communications via an employee HOTLINE,

) building public address systems and employee bulletin beards. In addition, the information made available to the public is also available to company employees. (Cramer, '

)

Tr. 7070-7073.)

379. Orange County has an established rumor control system at its EOC. This system includes nine telephone lines

)

with the capability to increase that number, if necessary.

County employees.are designated to report to and operate this rumor control system. (Turner, Tr. 8918.)

)

380. San Diego County also has an established 174

)

O method for controlling rumors. This method involves a bank i

O of telephones manned by operators from the Office of Disaster Preparedness and the Registrar of Voters, who are instructed to respond directly to calls from the public in order to

O quelch rumors. (Hunt, Tr. 9273-9274.)

i i

4. Development of Emergency Public Instructions 1

381. Each of the local jurisdictions and the lO.

Applicants have prewritten instructions for the public in their emergency plans and procedures, as recommended in f

• NUREG-0654, II.E.6. (Exhibit #112; Turner, Tr. 9005;

!O Coleman, Tr. 8599-8600.)

382. Through the Interjurisdictional Planning Committee, representatives of all local jurisdictions, as

'O

well as the Applicants, are working to achieve consistency of the prewritten public instructions concerning emergency

] classification and protective action recommendation. Such O

i

structions will be completed before fuel load. (Exhibits

1. 152(d), #154(d); Coleman, Tr. 8599-8600; Pilmer, Tr. 11113.~ )

383. The prewritten instructions, which are to be O

used based on the decisions of those responsible for emergency actions, contain standard language dealing with sheltering, evacuation procedures, and other protective iO measures. The appropriate instructions would be given l depending on the nature of the emergency and the decisions of

, those responsible for selecting appropriate emergency iO _

responses. (Exhibits #53, Appendix 6, #55, Appendix 2, 454, i

175

!O

-- . , ,- r., ,_ .yc,._.r._ , . -. _ ,_,.,_._.,_y _

i

O Attachment C, #152(d), #154(d).)

0 384. By use of the extensive communications systems which are available, Applicants have established a procedure to provide supporting information and recommendations to O

local public officials for emergency public instruction as required. (Exhibit #51, p. 6-30; Ray, Tr. 7154.)

385. In the State of California, the State fills a O

supporting role in the public alerting, education and information systems. The State OES has been working with the local jurisdictions and the Applicants to insure proper and O

adequate procedures. State OES has had representatives at the meetings of the Interjurisdictional Planning Committee in order to keep informed as to the progress made by that O

committee. (Reed, Tr. 10266; Pilmer, Tr. 11113.)

386. The emergency public notification system and the procedures adopted by the Applicants and local jurisdictions are adequate to provide reasonable assurance that the public will receive prompt and accurate information and instructions on what to do in the event of a radiological O

emergency with actual or potential offsite consequences at SONGS 2 & 3.

l L. CONTENTION 2K (General Plans for Reentry and h) Recoverv).

"Whether there is reasonable assurance that the emergency response planning and capability of implementation for SONGS 2 and 3, affecting the offsite transient and permanent population, C) will comply with 10 C.F.R. 550.47(a)(1) and (b) or (c)(1) as regards:

l l

l l

176 0

l l

)

l i

K. general plans for reentry and recovery 3 10 C.F.R. $50.47(b)(13)."

l 1. Introduction.

i 387. Messrs. D. F. Filmer, E. L. Murri, R. J.

[) Coleman, E. S. Turner, J. W. Hunt, and Col. J. E. Wa'llace l were the primary witnesses for Applicants; Mr. J. Kearns was the primary witness for Intervenors; and Messrs. J. R. Sears O and K. W. Nauman were the primary witnesses for the Staff, I

regarding general plans for reentry and recovery. (Pilmer, Tr. 7390-7391; Murri, Tr. 7242-7243; Coleman, Tr. 8608-8609;

[) Turner, Tr. 8922; Hunt, Tr. 9276; Wallace, Tr. 9339-9340;

(. Kearns, Tr. 10188; Sears, written testimony (August 20, i

l 1981), pp. 13-14; Nauman, Tr. 10375.)

[] 2. The Plans for Reentry and Recovery.

l l 388. After an accident has been fully controlled,

( the emergency response organizations will proceed into a

[)- recovery and reentry emergency response phase. The recovery l organization is divided into onsite and offsite segments.

(Pilmer, Tr. 7390.)

[) 389. The important aspects for recovery are a pre-established recovery organization and arrangements for l

! augmenting existing resources. (Murri, Tr. 7242.)

h) 390. Applicants' planning for reentry and recovery after an accident is set forth in Section 9 of the SONGS 2

, and 3 Emergency Plan. (Exhibit #51, Section 9; Pilmer, l

[) Tr. 7390; Sears, written testimony (August 20, 1981),

pp. 14-15, Tr. 10644.)

177

O 391. The object ci the onsite recovery effort is to O make repairs, to take positive steps to prevent recurrence of the same or related accidents, and to return the facility to a safe condition for renewed operations. (Exhibit #51, O Section 9; Pilmer, Tr. 7390) 392. An onsite recovery organization will be formed by Applicants with resources provided as best fits the nature O

of the recovery operation required. (P11mer, Tr. 7390.)

393. Applicants resources for staffing the recovery organization will be augmented, as necessary, by resources O from throughout the industry, such as other utilities, suppliers, consultants, and engineering firms. (Exhibit #51, Sections 5.3.2 and 9; Pilmer, Tr. 7390.)

O 394. The recovery operation is based on the organizational structure recommended by the Atomic Industrial Forum. (Murri, Tr. 7242; Se_e NUREG-0654, II.M.2.)

O 395. Principal offsite emergency response agencies' planning for reentry and recovery after an accident are set forth in each agency's emergency response plan, as recommended in NUREG-0654, II.M.1. (Exhibits #52,Section VI.I., #112; Coleman, Tr. 8608-8609; Hunt, Tr. 9276; Wallace, i

l Tr. 9339-9340; Turner, Tr. 8922; Kearns, Tr. 10188; Nauman, O '

l Tr. 10940.)

l l

i 178

[)

i

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

O 396. An offsite recovery organization will be O

formed by SCE, local, state and federt.1 agencies. (Pilmer, Tr. 7390.)

397. The recovery operation will operate out of the O

EOF which serves as the central location for coordination and function. (Pilmer, Tr. 7390.)

398. The first function of the recovery e

organization is to determine which land areas are contaminated and which areas are not contaminated. Those areas where contamination does not exist will be allowed to e

be rehabilitated. Those areas where contacination does exist will then be decontaminated. (Pilmer, Tr. 7390-7391.)

399. Reentry and recovery are properly addressed in C

the offsite agency plans for their potential level of involvement. There would never be a critical time element for emergency reentry by an offsite agency. The recovery O

organization for each agency is the same as its emergency organization, which is essentially the same as its day-to-day operating organization. (Murri, Tr. 7243; Turner, O

Tr. 8921-8922; Hunt, Tr. 9276.)

400. Based on the substantial and uncontroverted evidence in the record, the existing general onsite and offsite plans for reentry and recovery following a radiological emergency at SONGS 2&3 are adequate to protect the public health and safety.

179

O i M. CONTENTION 1 (Offsite Public Protective O Action Caoability).

"Whether the state of emergency preparedness for SONGS 2 and 3 provides reasonable assurance that the offsite transient and permanent population within the plume

-() exposure pathway Emergency Planning Zone, 10 C.F.R. 6 50.47(c)(2), for SONGS 2 and 3 can be evacuated or otherwise adequately protected in the event of a radiological emergency with offsite consequences occurring at SONGS 2 and 3, as required by 10 C.F.R.

(3 $$ 50.47(a)(1), (b)(10), and Part 50, Appendix E.IV."

1. Introduction 401. Mr. E. L. Murri and Dr. R. E. Linnemann were iO the primary witnesses for the Applicants; Dr. L. R. Ehling j

was the primary witness for the Intervenors; and Mr. B. K.

Grimes was the primary witness for the Staff regarding the range of available protective measures, the type of protection afforded by such measures, and the various constraints on the decision to implement one or more of these

O measures. Intervenors did not present any witnesses directly

,' on this subject. (Murri, Tr. 7204-7210; Linnemann, Tr. 7080-7082, 7089-7091; Ehling, Tr. 9936-9938; Grimes, lO

Tr. 11004-11005.)

402. Messrs. E. '. Murri and B. T. Brothers were the primary witnesses for the Applicants; Mr. S. C. Plotkin

,O was the primary witness for the Intervenors; and Messrs. J.

R. Sears, K. W. Nauman, and B. K. Grimes were the primary witnesses for the Staff, regarding evacuation planning, O

including estimation of the time required to evacuate the 180

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

D l

Plume and Extended EPZs. _(Brothers, Tr. 7276-7316, 11068-11089; Sears, written testimony (August 20, 1981),

I l pp. 3-6, Tr. 10644; Nauman, written testimony (August 24, i 1981), pp. 2-4, Tr. 10372; Grimes, Tr. 11003-11007 Plotkin,

) written testimony (August 25, 1981), pp. 7-9, Tr. 10313.)

j 403. Messrs. E. L. Murri, B. T. Brothers, B.

Killingsworth, D. H. Roper, C. Nash, J. P. Stowe, R. J.

Coleman, J. W. Hunt, Col. J. E. Wallace, Mrs. C. S.

l .

I Ferguson,'and Ms. B. Fox, were the primary witnesses for the Applicants; Messrs. S. C. Plotkin, M. Ditty, J. Goodwin, R.

)

l Ehling, W. Mechem, C. Logue, M. F. Reed, C. Fleming, W. R.

i l Bloom and G. Caravalho were the primary witnesses for the l

l Intervenors; and Messrs. J. R. Sears and K. W. Nauman were

) the primary witnesses for the Staff, regarding the capability l to evacuate or otherwise protect the transient and permanent l population within the Plume and Extended EPZs. (Murri, Tr. 7208-7210; Brothers, Tr. 7277-7321; Killingsworth, Tr. 8267-8268; Roper, Tr. 8332-8340; Nash, Tr. 8425-8430; Stowe, Tr. 8488-8503; Coleman, Tr. 8568-8599, 8609; Ferguson, Tr. 8692-8698; Fox, Tr. 9031-9035; Hunt, Tr. 9256-9286; Wallace, Tr. 9321-9322, 9341; Sears, written testimony l

(August 20, 1981), pp. 6A-8, Tr. 10644; Nauman, written testimony (August 24, 1980), pp. 3-5, Tr. 10372; Plotkin, Tr. 9451-9567; Ditty; Tr. 9848; Goodwin, Tr. 9885; Ehling, Tr. 9987; Mecham, Tr. 10022; Logue, Tr. 10093; Reed, 1 Tr. 10232-10236; Fleming, Tr. 10118-10119; Bloom, Tr. 10290:

181

)

f L

i

!O-l l

l l

l Caravalho, Tr. 10791-10792.)

i

5) 2. Available Protective Actions. ,

404. The protective actions that are available to prevent.or mitigate the public health consequences of an offsite release of radioactive material'from SONGS 2 & 3 l

l within the Plume and Extended EPZs are evacuation, sheltering, thyroid prophylaxis, and individual protective

'O actions such as respiratory equipment and use of protective clothing. (Exhibits #106, p. 1.23, #51, Section 6.4; Murri, Tr. 7207-7208; Grimes, Tr. 11004-11005.)

O 405. The ideal goal of protective action in an

! emergency would be complete protection of the endangered L population. However, various constraints may prevent

'O l attaining this goal, so a more realistic goal is minimization I

l of harmful effects. (Exhibit #106, p. 1.24; Murri, Tr. 7208; l

l Grimes, Tr. 11004, 11021-11022.)

{} .

l l

406. The constraints which operate to prevent l attaining the ideal goal include environmental, demographic l and temporal factors, resource availability, type of

O radioactivity release and exposure duration. (Exhibit #106,

p. 1.26; Murri, Tr. 7208.)

l l 407. Environmental constraints will include lQ meteorologic and geographic considerations. Protective action options may be restricted by severe weather conditions. Options are also restricted by numbers, types O

and directions of roadways and the rate of egress available 182 3

+gr =

w-+r-.y " - --

ww-rwr 4 w -

v ge------ -

M- -*v --N" " ' " - -

O given geographic and roadway constraints. (Exhibit #106, p.

(} 1.26; Murri, Tr. 7208.)

408. Protective action options are further constrained by the density and distribution of the O population, the total size of the population involved, the age and health status of segments of the population, and other demographic considerations. (Exhibit #106, p. 1.26; O

Murri, Tr. 7208.)

409. Temporal constraints will be present during all phases of protective action. Time available for action O

may be a real constraint for evacuation of close-in populations, particularly in the case of short-term (' puff) releases. Eved after a decision for action has been made, O

the time to notify the population and implement protective action may not be sufficient to prevent some exposure.

(Exhibit #106, p. 1.26; Murri, Tr. 7208; Grimes, Tr.

O 11021-11022.)

410. Resources availability is also a constraint on viable options for protective action. The local planner must

'O evaluate these conctraints in any emergency situation.

Ideally, it should be possible to balance these constraints in some analytical fashion which would place each constraint O

in its proper perspective on a common scale. Since many of the constraints cannot be quantified, local planners must use rational, subjective judgment in evaluating them. (Exhibit O

1. 106, p. 1.28; Murri, Tr. 7208.)

183 O

)

411. Evacuation is the removal of the population at

) risk with the object.'.ve of removing them prior to exposure to radiation. While evacuation may seem to be the protective action of choice following a nuclear incident at a nuclear

) power plant, constraints associated with a specifie. emergency could render the evacuation ineffective or undesirable. The effectiveness of evacuation in limiting radiation dose is a function of the time required to evacuate. If a radioactive plume is present, the dose will increase with the time of exposure. Anything that delays an evacuation until after

) plume arrival is a constraint. An evacuation may not be desirable where the radiation dose to be saved is vanishingly small, and the economic and social cost of the evacuation is relatively large. (Exhibit #106, pp. 1.28-1.38; Murri, Tr.

7208-7209; Grimes, Tr. 11021-11022.)

412. For evacuations caused by storms or floods,

) the hazard to life and limb is obvious. However, in the event of a nuclear incident there may be a strong inclination to evacuate even though the radiation dose to be saved is

) exceedingly small. Spontaneous evacuation is likely to occur when people perceive themselves as threatened and leave the area before they are required and directed to do so. If

)

spontaneous evacuation does occur, it generally improves the success of a subsequently directed evacuation, insofar as the spontaneous evacuation will have lowered the population at

)

risk so that there will be less traffic and congestion during 184

)

i D

i the subsequent directed evacuation. (Exhibit #106, pp.

O 1.37-1.08; Murri, Tr. 7204-7205.)

413. If evacuation is determined to be the appropriate protective action, there is extensive evidence D that evacuations can be and have been smoothly accomplished.

When the need arises, people are generally very alert, cautious, calm and committed to accomplishing a smooth O evacuation. Of the numerous evacuations that have been successfully accomplished, very few have had the benefit of such extensive preplanning as now exists for the area around D SONGS. (Exhibit #105; Murri, Tr. 7206-7207.)

414. Where local constraints on evacuation such as the time to take the action, the cost of taking the action, 3 '

the dose savings afforded by the action, and other societal considerations weigh against evacuation, the protective action of sheltering should be considered. (Exhibit #106, D

pp. 1.31, 1.38; Murri, Tr. 7207-7209; Grimes, Tr. 11022.)

415. Sheltering is an appropriate protective action l for severe events in which evacuation cannot be implemented

)

l becauce of inadequate lead time due to the rapid passage of l

l the plume. Sheltering will be recommended when local l constraints such as inclement weather, traffic conditions, or

)

evacuation route disruption or disablement dictate that sheltering is a more feasible and effective protective measure than evacuation. In such circumstances, shelter D

185 D-l l

O followed by relocation of the population to another area 8 after the passage of the plume might be warranted to minimize the population exposure to the radiation deposited on ground. (Murri, Tr. 7208; Grimes, Tr. 11021.)

• 416. Sheltering is also indicated where projected doses are smaller than the range of Protective Action Guides prescribed for evacuation counter-measures. Sheltering in 9 this case is a feasible means of reducing radiation exposure and increasing the margin of public safety. (Murri, Tr.

7208-7209; See FF.57 supra.)

O 417. Considerable protection is afforded by sheltering. Even a normal wood structure provides some protection for an indefinite period from direct exposure to D gamma rays and substantial protection from beta radiation emitted from the plumc or radioactive material deposited on the ground. Such a structure with windows and doors closed D and ventilation turned off can significantly reduce the inhalation dose for a limited period if the sheltering action is taken prior to the arrival of the plume. The problem in D

totally preventing an inhalation dose for an indefinite period is the fact that there is a continual air change within a structure. The rate of air change depends on the D " air tightness" of the structure. Even so, there is a considerable reduction in the concentration of radiciodine and particulate radioactivity due to plate out and filtration r3 as the airborne material from the plume seeps thrcugh small 186

O openings into the sheltering structure. The inhalation O exposure can also be reduced if sheltering is required for extended periods of time by breathing through a towel or taking other respiratory protective action to further filter O out the radiciodine and particulate radioactive material.

(Exhibits #106, pp. 1.38-1.41, #107, pp. 1-4; Murri, Tr.

7209, 7933; Sears, Tr. 10759; Grimes, Tr. 11004-11005.)

O 418. The uptake of inhaled or ingested iodine by the thyroid gland may be reduced by the ingestion of stable iodine, most often potassium iodide ("KI"). The oral O administration of about 130 milligrams of KI will introduce sufficient accumulation of stable iodine in the thyroid to prevent significant thyroid uptake of radiciodine which is O then eliminated in the urine. In other words, when the thyroid is saturated in the stable iodine, the uptake of radiciodine is " blocked" and will be excreted in the urine, O resulting in significant thyroid dose saving. The principal constraints in the use of KI are the logistics of properly administering the drug within the time it will be most O affective. (Linnemann, Tr. 7089.)

419. The effectiveness of KI as a blocking agent is directly related to the time at which it is administered. If O

KI is administered prior to exposure, it can be 100%

effective. After exeosure has occurred, the earlier it is administered the more effective it will be in preventing the O

uptake and reducing the radiation exposure. For example, if l 187 P

t

r l

lO a 130 mg. tablet of KI is given within the first two hours E

after exposure, it will block 90% of the uptake of radioactive iodine. If it is administered 4 to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after exposure, it will block the uptake by 40% to 50%. If

'O administered later than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after exposure, KI will have I little effect. (Linnemann, Tr. 7080, 7782.)

420. A legal constraint to the use of KI is the

'O fact that it is a prescription drug in California and must be.

distributed in accordance with state health laws, even though the risk from a small dose for an emergency condition is very

,O small. Accordingly, distribution of KI during an emergency l

must be conducted upon order of the State or County Health Officer in such a manner that the potential for allergic

O l reaction to this drug can be properly supervised. (Exhibit

1. 106, pp. 1.41-1.42, Exhibit #52,Section IV.A.2.a.(1),

Exhibit #53,Section III.C.4; Reed, Tr. 10231; Murri, Tr.

lO

! 7209-7210; Linneman. Tr. 7089-7090; Ehling, Tr. 9938.)

421. The use of stable iodine as a protective action for emergency workers is generally recommended, but

O l

only in accordance with State health laws and under the direction of medical officers as indicated above. However, KI or other thyroid blocking agents are not generally O

recommended as a protective action for members of the general i population. (See NUREG-0654, II.J.10.e.) The reason is that the dynamics of a plume release in which the radioactive.

O l 188 lQ

O material is moving and diluting suggest it would be extremely O unlikely to'obtain a high enough concentration of radiciodine to deliver a critical dose to the thyroid gland of a member of the general population prior to evacuation or sheltering. -

O Moreover, use of KI or other blocking agents are not really useful on a mass basis in an emergency, because of the logistics of distribution and administration in a timely O manner. On the other hand, administration of KI should be considered for emergency workers, who may be working in the exposure area for extended periods, or who may be working in O

a closed area where the concentration of radiciodine could deliver a significant thyroid dose. As a general rule, KI should be administered if the expected or likely dose is 10 O

rem or greater to the thyroid gland, especially where other means of respiratory protection are not available or are not practicable. (Exhibit #106, p. 1.42; Linnemann, Tr.

O 7090-7091; Murri, Tr. 7210; Ehling, Tr. 9936-9938.)

422. With these general parameters regarding the l

l available protective actions in mind, we may next examine

O whether the existing planning for implementation of these protective actions properly takes these various parameters L

l into account.

y "

3. Evacuation Planning 423. Evacuation planning principally involves consideration of the following factors:

,0 l

189 IQ

O i

l -

o Determination of the number of people who may

) have to be evacuated; 1

o Identification of the modes and quantity of transportation available; O o Identification of special facilities such as hospitals, nursing homes and schools; o Identification of usable roads and potential O impediments to their use; i

l o Identification of reception and care facilities in host areas for use by evacuees, if h) necessary; l

o Identification of medical resources inside and outside the Plume and Extended EPZs;

g o Dissemination of prompt public notification and information; l

o Provision of security for the evacuated area; O and

, o Determination of the time involved for the conduct of an evacuation given various circumstances.

(Murri, Tr. 7203-7204; see NUREG-0654, II.J.10.)

424. SCE and the principal offsite emergency response organizations have adopted and implemented O evacuation plans and time estimates, which properly consider the above factors, for the approximate 12-mile area around-SONGS previously n ' erred to in these findings as the Plume and Extended EPZs. bits #51-55, #57, #58; Brothers, 190 r)

i O

Tr. 7276-7277; Stowe, Tr. 8489-8490; Coleman, Tr. 8573-8574; 13 Turner, Tr. 8902; Hunt, Tr. 9262-9263; Wallace, Tr. 9321.)

425. The offsite supporting emergency response organizations have also developed evacuation, plans and O procedures which are consistent with the evacuation plans and

! procedures adopted by SCE and the principal offsite emergency response organizations. (Exhibits #56, #139, #140; Killingsworth, Tr. 8267-8268; Roper, Tr. 9332-9333; Nash, Tr. 8422-8423; Ferguson, Tr. 8692-8693; Swanson, Tr. 8799-8802.)

426. The various evacuation plans and procedures i

! adopted and implemented by SCE, the principal and supporting offsite emergency response organizations were initially

'O coordinated using an overall evacuation routing and j management plan for the Extended EPZ developed by Wilbur Smith & Associates ("WSA"). This plan was subsequently

!O segmented and the applicable portions incorporated in each offsite emergency response plan. Throughout the planning l

process and preparation of the various evacuation plans,

' O Applicants made special efforts to assure that the evacuation l components of each jurisdiction's emergency response plan remained both compatible and coordinated with the plans for

'O i the other jurisdictions. This coordination effort also i

included providing to each involved jurisdiction a special

. binder that contains the evacuation plans for all the other

O jurisdictions; and developing the " Interagency Agreement and 191

,o

f

'O 1

Evacuation Procedure for the San onofre Plume Exposure iO Pathway Emergency Planning Zone" ("IAEP") to aerve as a joint standard operating procedure for each involved offsite

, emergency response organization. The IAEP, which is

3) incorporated by reference in each of the principal offsite emergency response organization plans, ensures the necessary consistency of public information announcements, evacuation O routes, use of reception and care centers, establishment of traffic control points to limit access to and to direct traffic out of the evacuation area, possible medical aid

'O assistance, and general information. (Exhibit #59; Murri, Tr. 7221; Brothers, Tr. 7278-7280.)

427. To assure on-going coordination in the offsite O

plan review and implementation process, including evacuation planning, an Interjurisdictional Planning Committee ("IPC")

has been formed. The IPC is comprised of representatives from the SCE, USMC, the Cities, the Counties, and State Parks. The IPC'is currently revising the IAEP to reflect changes and improvements as suggested by the FEMA /RAC O

comments and the experience gained in the May 13 exercise.

(Exhibit #150; Pilmer, Tr. 7394; Coleman, Tr. 8600-8601; Ferguson, Tr. 8689-8690; Hunt, Tr. 9304-9305; Wallace, Tr. 9334; Fox, Tr. 9030.)

428. To assist in the development of the offsite evacuation plans, WSA held numerous discussions with local O .

192 O

officials to identify resources and review existing plans to-ensure that the evacuation plans would conform to the individual jurisdiction's normal approach and procedures for handling emergency situations. Principal elements that were "i discussed, considered and incorporated into the evacuation plans were:

(a) Responsibility and general location for

)

~'

diversion of non-local traffic around the Extended EPZ, and the establishment of measures to control entry into the Extended ErZ;

~'

(b) Identification of the numbers and distribution of resident and transient population which may be within the Extended EPZ at the time of initial O

notification of an incident at SONGS; (c) Assignment of an evacuation route for the population within each area; O

(d) Identification of the locations at which traffic control measures are desirable in order to facilitate evacuation traffic flow; O

(e) Identification of those inctitutions and population elements which may require transportation assistance, and the resources available for this purpose; O

(f) Identification of reception and care centers outside the Extended EPZ, and the assignment of Extended EPZ populations to each; and O

(g) Identification of potential locations at 193 e

l r

i l

uhich disruption of the primary evacuation routes could h possibly occur, and determination of the effects of i

i these upon an evacuation. (Exhibit #115, Brothers, i

Tr. 7292-7283.)

) 429. WSA met with representatives of local law enforcement agencies, the California Highway Patrol ("CHP")

cnd the California Department of Transportation ("CALTRANS")

) to obtain recommendations and concurrence on responsibilities for emergency traffic diversion and EPZ perimeter security.

It was agreed that the CHP is responsible for the initial

) diversion of traffic at the selected locations on Interstate 5 ("I-5"), the principal highway through the EPZ.

l CALTRANS will mobilize crews with traffic control equipment

) to replace the initial manual CHP diversion efforts.

l (Exhibit #59,Section IV.D; Brothers, Tr. 7284-7285;

,_ Killingsworth, Tr. 8267-8269; Roper, Tr. 8330-8331, 8334-8335.) .

430. The Orange County Sheriff Department is i responsible for initial diversion of traffic on Pacific Coast

) Highway ("PCH") north of the EPZ and would assist CHP with l

l traffic diversion in the EPZ within Orange County. The San l

l Diego County Sheriff Department and the City of Oceanside

)-

Police will provide immediate response in assisting the diversion of traffic on northbound I-5 south of the EPZ. The t

! Orange County and San Diego County Sheriff Departrents will

) provide security at the perimeter of the area to be evacuated l

I 194

}

)

and will obtain the assistance of the National Guard if

) necessary. (Exhibit #59,Section IV.B.2; Brothers, Tr. 7285; Turner, Tr. 8959; Hunt, Tr. 9300-9301.)

431. In order to expedite selective or incremental

) evacuation of portions of the Extended EPZ, if conditions should so warrant, the Extended EPZ has been divided into evacuation planning subsectors. Subsector boundaries were

) delineated using readily identifiable boundaries to facilitate the communication of evacuation or other protective action instructions to the public prior to and

) during an emergency. Specific evacuation routes and reception and care centers procedures were designated for the transient, residential and institutional populations within

) each evacuation planning subsector. The evacuation routings for each individual subsector include: the recommended primary evacuation route out of the area; the most efficient routing on surface streets to each the primary evacuation route; and directions to predesignated reception and care centers located outside the EPZ. (Exhibit #132; Brothers, Tr. 7279-7280, 7290.)

432. At the Applicants' request, WSA has identified or conservatively estimated the numbers and distribution of the permanent and transient population which may be within the Extended EPZ at the time of initial notification of an j incident at SONGS. (See NUREG-0654, II.J.10.b.) Demographic data for the Extended EPZ was derived from U.S. Census Bureau l

j data, and confirmed by Orange County Environmental Management l

195

'O Agency and Administration Office Forecasting and Analysis O information, as well as by population figures obtained from local planning agencies in the Cities. Demographic data for the following special populations within the Extended EPZ O were quantified through interviews with the following agencies:

o Camp Pendleton populations - USMC, Camp -

O Pendleton; o Beach visitation - State Department of Parks and Recreation; San Clemente Marine Safety O Division; o School enrollment - Capistrano Unified School District; Individual private schools; and 9' . o Transient Workers and Tourists - State Employment Development Department; San Clemente Planning Department; San Clemente

}

Fire Department; San Juan Capistrano Planning Department; and Local Chamber of Commerce Office.

O A table and a map showing population distribution in a l

sector-by-sector format has been devised based on this data and made available to the involved State and local O jurisdictions (Exhibit #132, p. 4, Appendix A; Brothers, Tr.7285-7286.)

433. The Plume and Extended EPZs have two major transportation facilities, Interstate 5 anc the Pacific Coast l

} 196 o

i L -

O Highway, which are identified as the primary evacuation 3 routes. Basilone Road, although not considered to be a high capacity facility, is designated along with Interstate 5 as the evacuation routes for Camp Pendleton. There are also 7

several secondary routes which parallel or provide alternatives to the primary routes, and which could be used by evacuation traffic in the event of partial impairment or complete blockage of one or more of the primary evacuation routes. These secondary routes include, but are not limited to, Ortega Highway, Camino Capistrano, Rancho Viejo Road, O Margarita Parkway, Old Highway Route 101, and Crown V&lley Farkway. (Exhibit #132, p. 3-5; Brothers, Tr. 7288-7289.)

434. In order to provide for a more orderly 3 evacuation, preselected -traffic control locations have been identified. The traffic control locations were identified and prioritized based on recommendations by representatives of the San Clemente Police Department, Oceanside Police Department, County Sheriff Departments, CHP, and CALTRANS.

J The high priority traffic control locations are those g

identified by the local officials and in the WSA studies as having the highest potential for constraining evacuation traffic flow. (Exhibit #59,Section VI.C; Brothers, O

Tr. 7290-7292.)

435. The private automobile would be the principal means of evacuation. About 93 percent of the population O

within the Extended EPZ are people who live in households 197

O that have access to one or more automobiles. Nevertheless, O the evacuation plans identify and take into consideration the several elements of the permanent and transient population which will require transportation assistance. (Exhibit #132, O p. 22; Brothers, Tr. 7292.)

436. Through Applicants' public information program discussed above, persons without transportation will have

'O' information regarding telephone numbers to call for transportation. In order to minimize the need for telephone use during the emargency for the purpose of requesting O

transportation assistance, two steps have been taken. First, about thirty transportation assembly points have been established throughout the Plume and Extended EPZs for O

persons to walk to and obtain transportation. Information regarding the location of these points has been and will continue to be made available to the t,ransient and permanent O

population within the Plume and Extended EPZs through Applicants' Public Education and Information Program.

Second, Applicants, in cooperation with the Cities and Orange O

County have provided a post card to the residents of the Plume and Extended EPZs which may be returned in advance of an emergency notifying the responsible official of the O

person's need for transportation assistance. Respot.sible officials in the San Clemente and Orange County are currently in the process of collecting this information and attempting O

to make certain that those needing such assistance have been identified.

198 O

)

Various representatives of organizations involved with caring

) for the elderly and the handicapped are also~becoming involved in this effort. (Exhibit #66; Brothers, Tr.

7292-7293; Cramer, Tr. 7042-7043, 7049, 7462-7463; Turner, b Tr. 8908-8909, Ferguson, 8695, Coleman, Tr. 8578; Ditty,'Tr.

9862, Logue, Tr. 10093.)

437. In Orange County, arrangements have been made

) through the Orange County Transit District ("OCTD") and the Capistrano Unified School District (" District") to provide bus transportation for people without automobiles including

) those in special institutions such as schools, hospitals, nursing / retirement-homes, and those with restricted mobility due to age or a disability. A sufficient number of buses and

) ambulances are available and committed to the evacuation, based upon the most conservative estimates of persons who might require such transportation assistance. In San Diego County, whatever minimal requirement, if any, for transportation assistance would be provided through the San Diego Office of Disaster Preparedness, while the USMC will provide for its transportation needs, as well as assist i

others, if necessary. (Exhibits #53,Section V.C.2.b.(6),

1. 54,Section XIII.B.6, #59,Section VIII; Brothers, Tr. 7295; Swanson, Tr. 8803-8804; Turner, Tr. 8907; Wallace, Tr. 9326.)

l 438. The majority of transients are expected to i

j have personal transportation. Information regarding the securing of-public transportation for those transients who do 199

)-

l

O -

not have access to an automobile will be provided by (3 Applicants at all appropriate locations throughout the EPZ.

(Exhibit #132, pp. 25-26; Brothers, Tr. 7293; Cramer, Tr.

7049-7050.)

O 439. Public transportation assembly points have been established throughout the Plume and Extended EPZs.

Most of these assembly points are located in the

.O heavily-populated sections of Orange County. OCTD, the primary agency providing transportation assistance, has developed specific procedures for coordinating the assignment O of OCTD resources to these points in an event of an emergency. Reassignment or further instruction to OCTD busec is possible using the mobile communication system between the O OCTD dispatcher and the OCTD buses. (Exhibit #53, Attachment 2; Brothers, Tr. "296; Goodwin, Tr. 9914.)

440. The District has prepared emergency evacuation "O procedures which specify deployment of District and-OCTD transportation resources for this purpose, as well as making

~

District transportation resources available during non-school

'O hours. (Exhibits #139, #140.; Brothers, Tr. 7296; Swanson; Tr. 8799-8801.)

441. The deployment of ambulance resources is the n

responsibility of the Emergency Medical Services Division of the Orange County Human Services Agency. In the event of a declared emergency, the Orange County Office of Emergency Services has the authority to take control of private 200 O

C ambulance resources and utilize them as needed. In San Diego

/'

' County, the coordination of ambulance resources is through the Emergency Medical Services, San Diego County Department of Health Services. (Exhibits #53,Section V.C.2.b, #54, C Section V.F; Brothers, Tr. 7296-7297; Ehling, Tr. 9987.)

442. Reception and care centers have been identified for evacuees who may not have made prior arrangements to stay with friends or relatives. Six primary reception and care centers have been selected in Orange County and three in San Diego County. Several backup

~q facilities have been designated'for each primary reception and care center. The American Red Cross will activate the centers in the event of an evacuation. (Exhibits X "

1. 53,V.C.2.b, #54, XVIII.C; Brothers, Tr. 7297; Nash, Tr.

8423.)

443. CALTRANS has procedures in place whereby O response teams would be dispatched to assess the nature and extent of any actual or suspected damage or other traffic impairments along I-5. The CALTRANS survey teams would develop appropriate traffic diversion recommendations, relay the recommendations to the appropriate agencies, and initiate mitigative actions to clear the roadway of the impediment O

i and/or repair damage to roadway structures. (Exhibits #51, Section 6.2.7 and Appendix A (Letter from CALTRANS), #132, pp. 68-71; Brothers, Tr. 7298-7299; Roper, Tr. 8332-8335.)

p 444. The various kinds of emergency public l

i l

I l- 201 D

)

assistance that could be needed to protect the public health

) and safety following an evacuation notification have been provided for in the evacuation planning. Medical assistance shall be coordinated by the Emergency Medical Services

) Division of Orange County and by San Diego County. Fire protection shall be provided for by San Clemente and San Juan Capistrano Fire Departments and the San Diego County

) Volunteer Fire Fighters. Transportation assistance during an evacuation shall be coordinated by the Orange County General Service Agency Transportation Division and the San Diego

) County Office of Disaster Preparedness. Law enforcement shall be provided by Orange County and San Diego County Sheriff's Department in conjunction with local police departments, CHP and the National Guard, if requested.

(Exhibits #53,Section IV.A, #54,Section IV.A, #59,Section IV.B; Brothers, Tr. 7299-7300; Hunt, Tr. 9300-9301; Turner,

) Tr. 8959; Killingsworth, Tr. 8312.)

4. Evacuation Time Estimates 445. Time estimates for evacuation are required by the NRC Staff for two principal reasons: First, to identify those transportation routes, areas or facilities in the vicinity of a site for which special traffic controls during

) an emergency or other special plans would be desirable; and, second, to provide to decisionmakers during an emergency, knowledge of the length of time required to effect an

) evacuation under various conditions. (Staff Exhibit #12, 202

)

O

p. 13-3; Brothers, Tr. 7303-7304: Sears, written testimony

n (August 20,, 1981), p. 3, Tr. 10644; Grimes, Tr. 11003-11004.)

446. In the case of SONGS, evacuation time estimates have been provided for " Summer-Weekend", " Summer O Weekday", " Nighttime", " Adverse Weather" and various roadway disablement conditions showing the lead time necessary to evacuate the 0-2 mile sector, the 0-5 mile sectors simultaneously, the 0-10 mile sectors simultaneously, and the entire Extended EPZ simultaneously. Generally speaking these estimates indicate that the Extended EPZ can be evacuated, assuming optimum conditions, in about 2-1/2 hours; with peak permanent and transient population conditions in about 6-1/4 hours; and with adverse weather conditions in about 7-1/4

,o hours. These evacuation time estimate (s) will be used if evacuation of part or all of the North or South sectors appears to be the desired protective action. The time

-O estimated to evacuate the desired area would be compared to predicted time and nature of the release, and the expected meteorological conditions at the time of release; to indicate g

the ability to effect an evacuation prior to plume arrival in 1

the area. The comparison would then be used in'an evaluation l of potential exposure risks of sheltering versus evacuation

O to arrive at the recommendation of protective action (s).

(Exhibit #132, Chapter 8; Brothers, Tr. 7303-7304; Sears, Tr. 10644; Grimes, Tr. 11004.)

'O 447. The NRC has not established an upper limit for 203

'O

O the time within which the Plume EPZ must be evacuated. The O rationale for not establishing an upper limit is that the NRC's siting criteria require sufficiently low population densities around a site that evacuation would always be e generally feasible and no severe problems in this regard are to be anticipated. Accordingly, there is no particular need for evacuation time estimates other than as a decision tool.

O In this regard, the " Guidance on Initiation and Direction of Release," contained as Table 2 to NUREG-0654 is not to be used in making judgments as to the adequacy of time for D evacuation. Such judgments cannot be made in advance but must be based on the particular conditions of the plant at the actual time of the emergency. (Grimes, Tr. 11006-11007, O

~

11022-11023; see NUREG-0654, p. 17.)

448. The evacuation time estimates were calculated for various evacuation conditions using a computer-based D

evacuation time assessment program previously developed by WSA for FEMA's use in assessing evacuation time estimates for nine other nuclear plants. The evacuation time estimate D

computer program is not a new program, but is a refinement of a basic program that has been used for many years by WSA and other firms. 'The program and input data has been adjusted to D

reflect site-specific conditions in the Plume and Extended EPZs. The program, as utilized for SONGS, has been reviewed and approved by the Texas Transportation Institute. The D

methodology used in the program ic in conformance with the 204 D

O criteria in NUREG-0654, Appendix 4. (Exhibit #132, C) Chapter 2: Brothers, Tr. 7305-7306, 11068; Sears, written testimony (August 20, 1981), p. 5, Tr. 10644.)

449. Substantial evidence was received on the C) methodology used to arrive at the evacuation time estimates for areas within the Plume and Extended EPZs under various conditions. Basically, the time required to evacuate is O' comprised of several individual time components which correspond to a sequence of public response actions during an evacuation. These time components are the receipt of O notification, return home, departure from home, enroute evacuation travel, and delay time. Because each individual would react differently in terms of speed, each of the public O

response time components (notification, return home, and departure) is considered as distribution of response times rather than a single, fixed time increment. Public response n'

times were determined for the general automobile using resident and transient population for daytime and nighttime conditions. Separate consideration was given to the time it n

takes to mobilize public transportation and ambulance services for the maximum number of persons estimated to need such services. (Exhibit #132, pp. 36-37 and Tables 5 and 6; O

Brothers, Tr. 7306-7309.)

450. The computer simulation model was used to evaluste each fifteen minute increment of the evacuation

~

period. The computer model continues to measure evacuation 205 0

O time and related parameters from initial notification of the 8 public until the emergency planning sector (s) is evacuated.

The computer analyses considers the capacity constraints present in both the primary and secondary evacuation routes O

relative to the rate at which traffic accesses and traverses these. roadways. Both travel times and delay times are estimated, and included with the response time, to provide a O

total time of evacuation. (Exhibit #132, Appendix B; Brothers, Tr. 7305-7307.)

451. The evacuation time estimates take into O

consideration the potential effects on traffic caused by adverse weather, or roadway disablements at the most critical junctures in the roadway system. (Exhibit #132, pp. 56-57 and Chapter 9; Brothers, Tr. 7309-7311, Sears, written testimony (August 20, 1981), p. 6, Tr. 10644.)

452. The evacuation time estimates are based on a O

number of conservative assumptions, including:

o The evacuation time estimates represent the peak transient and permanent population condition which O

could be expected under each evacuation scenario; o The population assumptions reflect no prior, voluntary evacuation of residents or transients prior to O

the public notification to evacuate; o Similarly, the public response / mobilization time distribution used in the evacuation time estimates O

assume that the population is going about normal daily 206 O

r

)

routines at the time of public notification to evacuate,

) and that no efforts have been taken to assemble and prepare the household unit for evacuation; o The time estimates assume that all households and transients within the evacuation area would evacuate beyond the Extended EPZ. This is a conservative assumption insofar as there are many cases where some 3 people refuse to evacuate when presented with a grave threat; and o Evacuation routes are assumed in general to be 3 operated in their normal direction without any use of one-way operation on roadway shoulder areas and parking strips on arterial streets, or the use of freeway

) shoulder areas to reduce delay times at traffic

" bottlenecks."

(Exhibit #132, Chapter 3; Brothers, Tr. 7315-7316, D

11069-11070.)

453. The Intervenors questioned the validity of the WSA time estimation study on a number of grounds including

) their lack of understanding as to the computer model used, the use of overly optimistic evacuation conditions, the underestimation of transient populations within the Plume EPZ, the overestimation of highway capacity factors, the underestimation of the length of time that Interstate 5 would be fully-loaded, the underestimation of public transportation

)

mobilization time, the underestimation of road blockage due l

l l

207

)

O to traffic accidents, the underestimation of nighttime

'" evacuation times, the failure to consider the impact of spontaneous evacuation of populations located beyond the

~ Plume and Extended EPZs, and the failure to consider travel O time involved in on-ramp queuing and use of poor secondary roads. (Plotkin, written testimony (August 25, 1981), pp.

3-4, 7-8, Tr. 10313, 9451-9567; Goodwin, Tr. 9885; Mecham, O

Tr. 10022; Bloom, Tr. 10290; Caravalho, Tr. 10791-10792.)

454. The Board has reviewed each of the Intervenor's concerns and concludes that the Intervenors

O criticisms of the WSA time estimate study are not valid for the reasons stated in-the study and Mr. Brothers' testimony.

Specifically, the methodology used in the computer program is

'O explained in sufficient detail in the study. WSA has evaluated a full range evacuation conditions using conservative and generally accepted vehicle demand and

O highway capacity figures. WSA has considered the likely

numbers and effects of traffic accidents on evacuation traffic flow and time estimates, as well as the impact of O

spontaneous evacuation of areas beyond the Plume and Extended EPZs. The mobilization times used in the study are based on empirical data obtained from appropriate sources, no evidence O

was submitted to controvert this data which appears l

reasonable to the Board. The time estimate does consider delays at on-ramps and travel time on circuitous local

{O l streets. Neither of these factors is of sufficient 208 O -

4 0

significance to affect the overall sector evacuation time.

O The study has been reviewed and the evacuation time estimates therein have been found reasonable by the persons responsible for its use in an emergency, including representatives of n

local-jurisdictions, CHP and CALTRANS. In sum, the substantial weight of the evidence and expert opinion supports the validity of conclusions reached in the WSA time O

estimate study. (Exhibit #132; _ Brothers, Tr. 7318-7320, 11068-11100; Sears, written testimony (August 20, 1981),

p. 6, Tr. 10644; Nauman, written testimony (August 24, 1981),

O

p. 3, Tr. 10420; Killingsworth, Tr. 8276; Roper, Tr. 8398; Coleman, Tr. 8581-8582; Ferguson, Tr. 8696; Wallace, Tr.

9326-9327; Turner, Tr. 8906; Swanson, Tr. 8831.)

O

5. Planning for Sheltering 455. The emergency plans of each of the principal emergency response organizations provides for sheltering in O

the appropriate circumstances. (Exhibits #53,Section V . C .1. a , #54,Section XII, #55,Section III.E.1; Brothers, Tr. 7300-7302.)

O 456. If sheltering is the recommended protective action, in preference to evacuation, people can obtain shelter in their homes or other places of lodging, their places of employment or designated public shelter locations.

A series of public shelter locations are being identified i

throughout the Plume and Extended EPZs. (Brothers, Tr.

lO l

7300-7302; Murri, Tr. 7208-7209.)

l 209

g k - -

)

6. Planning for Thyroid Prophylaxis.

) 457. The plans of the Counties provide for thyroid prophylaxis for emergency workers and institutionalized persons, under appropriate circumstances, as suggested by

) NUREG-0654, II.J.10.e. (Exhibit #112; Murri, Tr. 7210; Ehling, Tr. 9936-9937.)

458. A sufficient amount of potassium iodide has

) been stockpiled by SCE and Orange County for this purpose.

(Exhibit #51, Section 6.4; Ehling, Tr. 9936.)

7. Offsite Capability to Implement Protective

) Actions.

459. Substantial uncontroverted evidence was presented in support of the capability of the Counties, the

) Cities, USMC, State Parks, the District, CALTRANS and the CHP to implement the full range of protective actions. This evidence included the plans and procedures of these agencies,

) the resources available to these agencies, the mutual aid relationships between these agencies, the previous evacuation i and other emergency experience of these agencies, the b

day-to-day experience of these agencies, the overall response of these agencies during the May 13 exercise, and the commitment of each of these agencies to maintain and improve upon this capability through an on-going program of plan l< coordination, periodic training, drills and exercises.

(Exhibits #53-59, #122A, #134, #139-143, #145, #147,

) #151-156; Murri, Tr. 7240-7241; Brothers, Tr. 7321; i

I 210

)

J Killingsworth, Tr.8267-8268, 8271-8272, 8277-8279; Roper,

) Tr.8332, 8335-8337, 8339-8340, 8398-8399; Swanson, Tr.8793-8796, 8799-8806; Nash, Tr.8425-8426, 8428-8430; Stowe, Tr.8488-8490, 8501-8503, 8549-8550; Coleman, Tr. 8568-8574, 8588-8589, 8605-8606, 8609; Ferguson, Tr. 8698, 8692-8693; Turner, Tr. 8903-8904, 8923-8925; Fox, Tr. 9028, 9031-9035; Hunt, Tr. 9256-9257, 9259-9263, D 9268-9269, 9275-9276, 9285-9286; Wallace, Tr.9321-93?2, 9341; Nauman, written testimony (August 24, 1981), pp. 4-5, Tr. 10644, 10917.)

D VI.

FINDINGS OF FACT 3 ON INTERIM FEMA FINDINGS.

A. FEMA's Interim Findings 460. On June 3, 1981, National Headquarters of FEMA D (" FEMA National") issued its " Interim Findings and Determination Relating to the Status of State and Local Emergency Preparedness for the San Onofre Nuclear Generation D Station (Units 2 and 3)" (the " Interim FEMA Findings"), in response to the request for such an evaluation from the NRC Staff, contained in the memorandum from Mr. B. K. Grimes of D the NRC Staff to the Mr. Dickey of FEMA National, dated March 4 and 10, 1981. (Staff Exhibit #11, p. 1) l l

l 211 b

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O 461. The Interim FEMA Findings were based upon an 9

assessment period concluding as of May 22, 2981. (Staff Exhibit #11, Attachment, p. 1) 462. The Interim FEMA Findings concluded that O

" State and local government response plans are minimally adequate. However, until corrective actions have been taken, the cffsite capability for implementation of the plans is not O

considered adequate." (Staff Exhibit #11, p. 2) 463. The Interim FEMA Findings are based upon the results of a review of the radiological emergency response O

plans adopted by the Ccanties, the Cities, State Parks and the USMC, which was conducted by the FEMA, Region IX, Regional Assistance Committee ("RAC") and published by FEMA, O

Region IX on April 27, 1981 (the " FEMA /RAC Comments";

Intervenors' Exhibit #13); the evaluation of the May 13 exercise which was published by FEMA, Region IX, on May 29, D

1981 (the " FEMA Exercise Evaluation"; Intervenors' Exhibit

1. 14); and the officially transcribed comments received by FEMA, Region IX, at a public meeting held on May 18, 1981 in D

San Clemente, California (Staff Exhibit #11).10/

D 10/ The transcript of this public meeting was made available to the parties and the Board by the Applicants. However, the D transcript was not offered or admitted into the evidence of this proceeding by any party.

212 D

)

B. The Responses to the Interim FEMA Findings, Including

, Development and Sufficiency of Corrective Actions Approved by FEMA.

464. Applicants and the local supporting agencies disagree with many specific findings made by FEMA and the

) determination that "the offsite capability for implementation of the (offsite] plans is not considered adequate." Evidence presented on behalf of Applicants and the local supporting

) agencies challenged the validity of many of the specific findings made by FEMA and questioned the significance of other deficiencies reported in the FEMA /RAC Conments and the

) FEMA Exercise Evaluation. (Exhibits #113, 9.41, #145, #151; Murri, Tr. 7246, 7261-7264; Killingsworth, Tr. 8316; Roper, Tr. 8399; Coleman, Tr. 8603-8604, 8610-8613, 8617-8620; Turner, Tr. 8924, 8961; Fox, Tr. 9032-9036; Hunt, Tr.

9285-9288; Wallace, Tr. 9344, 9348-9349.)

465. Applicants and the local supporting agencies

) also noted that the FEMA /RAC comments and FEMA Exercise Evaluation did not purport to present a current review, but were as of April 27, 1981 and May 13, 1981 respectively.

) Substantial evidence was presented concerning corrective actions already taken by the local supporting agencies to remedy many of the deficiencies noted in the FEMA /RAC

) Comments and the FEMA Exercise Evaluation and other corrective actions to be taken prior to fuel lead at SONGS

2. (Murri, Tr. 7236; Linnemann, Tr. 7114-7115; DuBois, Tr. 6926; Cramer, Tr. 7039-7052; Filmer, Tr. 7376-7389, 7395, J

213

)

9206-9210, 11102-11105; Fox, Tr. 9028; Killingsw' orth,

) Tr. 8268; Stowe, Tr. 8493-8497, 8595, 8605-8607; Ferguson, Tr. 8690, 8692-8693; Coleman, Tr. 8577-8579, 8595, 8605-8607; Wallace, Tr. 9327-9328, 9333; Hunt, Tr. 9265, 9275-9276.)

) 466. As noted at the outset of these findings, the Interim FEMA Findings anticipated that adequate offsite implementation capability could be demonstrated "within the

) very near future" provided certain corrective actions suggested in the Interim FEMA Findings were taken. (Staff Exhibit #11, Attachment, p. 7)

) 467. Even prior to publication of the Interim FEMA Findings, steps were underway to improve offsite response capability. At a critique meeting held on May 14, 1981 at

) SONGS between SCE and the State and local agencies which participated in the May 13 exercise, the following topics were identified along with the corresponding suggested action:

) l l

Topic For Improvement: Suggested Action:

} 1. Improve EOF operations 1. Develop procedures gov-to make more manageable. erning EOF activities and make physical improvements to the facility.

) 2. Improve ODAC capability. 2. Develop procedures, make facility improvements, and obtain additional equipment and staffing to expand ODAC

] capability.

214

)

O Topic For-Impr vement: Suggested' Action:

O.

3. Improve interjurisdic- 3. Develop procedures tional communications. governing emergency communications.

Develop a teletype o message system between SONGS and EOC for rapid / accurate dissemination of initial and backup notification O information. Provide speaker-monitors for the Interagency Telephone System at every EOC.

o 4. Improve coordination in 4. Expand Interagency 4

the function of freeway Telephone system to closure. include CHP stations and identify standard emergency conditions for Interstate-5 O closure.

5. Improve accuracy in 5. Develop improved maps communicating and depicting and communications meteorological conditions. procedures which provide clear, O unambigious t.erminology.

(Pilmer, Tr. 7392-7393.)

468. In response to the Interim FEMA Findings, the O following additional corrective actions were immediately undertaken to complement those actions already underway:

1. A formal Interjurisdictional Planning Commitee O (the "IPC") was formed to coordinate and expedite emergency planning activities. Each of the primary response jurisdictions,

() including SCE, has a representative on this 215 O

e committee. Several meetings of this committee 9

have occurred to date.

2. It was decided by the IPC to develop standard procedures which would govern emergency O

response activities in several important functional areas:

a. Operation of the Offsite Dose Assessment O

Center (ODAC);

b. Radiation surveys by field monitoring teams; O

c. Emergency communications;

d. Use of the siren alerting and public notification system; O

e. Coordination relating to protective actions;

f. Acquisition, display and use of O

meteorological data;

g. Operation of the EOF; and

~

h. Ingestion pathway monitoring.

O

3. It was decided by the IPC to put together a program of training primarily directed towards achieving proficiency in the areas covered by O

the procedural topics listed above.

(Exhibit #150; Pilmer, Tr. 7394-7395.)

0 -

216 C

N 469. By letter, dated June 26, 1981, from

) Applicants to Mr. B. K. Grimes of the NRC Staff (Exhibit l

1. 144), Applicants specified the foregoing and other corrective actions that were being taken to remedy the

) deficiencies noted in the Interim FEMA Findings and the schedule for implementation of these corrective actions. By Memorandum, dated July 14, 1981, from Robert T. Jaske of FEMA

) National to Mr. B. K. Grimes (Exhibit #146), FEMA National concurred that these corrective actions would be sufficient to remedy the deficiencies noted in the Interim FEMA D Findings. These corrective actions and the schedule for their completion will be referred to below by " Corrective Action No." and may be summarized, as follows:

) Corrective Scheduled Action Completion No. Action Item Date

1. Develop Standard Operating Procedures covering the following topics:

3

a. Operation of the Offsite Dose Assessment Center (ODAC) 10/1/81

b. Radiation surveys by field

[) monitoring teams 10/1/81

c. Emergency Communications 10/1/81

d. Use of the siren alerting system and public notification 10/1/81 D e. Coordination relating to pro-tective actions 10/1/81

f. Acquisition, display and use of meteorological dar- 10/1/81

)

i 217 L

1 l

1

)  !

l Corrective Scheduled Action Completion

) No. Action Item Date

g. Operation of the EOF 10/1/81

h. Ingestion pathway monitoring 10/1/81

1. Existing SOP's covering other plan elements 12/1/81

2. Obtain equipment required to carry out radiation monitoring functions:

r) a. survey types and quantities of equipment actually in place 7/15/81

b. Initiate procurement of equipment shortages 8/1/81

) 3. Develop additional communications capability:

a. Expand interagency phone network to include CHP 7/15/81

) b. Provide speaker monitors at EOC's 7/15/81

c. Provide teletype message system network between all

) principal centers 10/15/81

d. Provide additional com-munication circuits 10/15/81

4. Make physical improvements to the EOF

a. Identify possible improvements 9/1/81

b. Obtain agreements to make improvements 9/1/81

c. Construct improvements 10/15'81 f

5. Install Sirens 10/15/81

6. Accomplish training in use of new and existing procedures, facilities, and equipment.

)

218

)

O

a. Develop training program (long and short term) 7/15/81

b. Develop training material (short term program) 9/1/81

c. Conduct training and drills 0

(short term program) 9/1/81-10/15/81

d. Implement long term training program 11/1/81-2/1/82 e 7. Implement Public Information Program (Exhibits 4144, #146.)

g 470. It is the view of FEMA National that if the foregoing corrective actions are completed there is reasonable assurance adequate protective measures can and 3 will be taken in the event of a radiological emergency at SCNGS 2 & 3. (Nauman, written testimony (September 24, 1991), p. 1; Ir. 10420; Grimes, Tr. 11012-11013.)

C. Status of Completion of Corrective Actions 3 Approved by FEMA.

471. There is substantial evidence in the record that the corrective actions recommended by FEMA are either complete or will be complete prior to the scheduled full power operation of SONGS 2.

472. The Public Information Program (Corrective D

Action No. 7) has been implemented. (Exhibits =66-71,

1. 123-131, #148; Cramer, Tr. 7039-7052, 7448-7568; Stowe, Tr. 8493-8494; Coleman, Tr. 8577-8579; Fe r gu s on , Tr. E693; D

Swanson, Tr. 8797: Turner, Tr. 8907-8909; Hunt, Tr. 9265; 219

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D Wallace, Tr. 9327-9328; Mecham, Tr. 10065; Caravalho, f

I) Tr. 10792, 10809; Nauman, Tr. 10540-10542, 10926, 10956-10957; Sears, written testimony ( August 6), p. 6, Tr.

10644.)

O 473. The sirens (Corrective Action Item No. 5) have been installed and standard operating procedures for use of the siren system and public notification have been developed.

9 (Exhibits #60, #61, #135, #152(d), #153(d), #154(d), #155(d) and #156(d); DuBois, Tr. 6926; Pilmer, Ir. 9208-9209, 11102-11105; Stowe, Tr. 8497; Coleman, Tr. 8599; Ferguson, O

Tr. 8590; Turner, Tr. 8913-8914; Wallace, Tr. 9333; Sears, written testimony (August 6, 1981), p. 5, Tr. 10644, Nauman, written testimony ( August 24, 1981), p. 7, Tr. 10372, 10535, O

10921-10922.)

474. Physical improvements and standard operating procedures for the Interim EOF (Corrective Action Nos. 1(e) 4 and 4) hase been substantially completed. (Exhibits #122A,

1. 152(b), #153(b), #154(b), #155(b) and #156(b); Pilmer, Tr.

7376-7378, 9208, 11102-11105; Coleman, Tr. 8595; Reed, Tr.

9 10268; Nauman, Tr. 10550-10551, 10937; Sears, written testimony ( August 20, 1981), p. 12, Tr. 10644.)

475. Enhancement of offsite communications G

capability (Corrective Action No. 3) has been substantially completed by adding the CHP to the Interagency Telephone System; providing speaker phones to the various terminals of 9

the Interagency Telephone System located in the Interim EOF 220 9 l l

h i

l l

l l

and the various emergency operations centers; providing terminals for the Orange County Automatic Teletype System at SONGS, the Interim EOF, and the Counties' ECCs; and by i

installing additional communications circuits. (Exhibits

1. 136, #149(c); Killingsworth, Tr. 8268, Poorman, Tr. 8764, 8771; Pilmer, Tr. 9207-9208.)

476. Applicants have provided or have on order the a

additional equipment required by offsite emergency response organication to carry out radiation monitoring functions.

(Exhibit #149, Coleman, Tr. 8607; Turner, Tr. 8924, 8960; q

rilmer, Tr. 9207.)

477. Plans and procedures for monitoring and dose assessment within the Ingestion EPZ have been developed

_)

~

(Corrective Action No. 1.h). (Exhibits #53,Section IV.A.2, 254,Section XIX; Exhibits #152(g), #153(g); Pilmer, Tr.

7384-7389, 9140, 9144, 9197-9199; Turner, Tr. 8923, 3

8982-8983; Ehling, Tr. 9976-9977; Kearns, Tr. 10187.)

478 Standard operating procedures for the Offsite Dose Assessment Center, including acquisition, display and J

use of meteorological data and radiation surveys by field

=cnitoring teams, have been developed (Corrective Action Item No. 1(a), (b), and (f)). (Exhibits #142, #149(c), #152(f),

uv 4153(f), #154(f); Pilmer, Tr. 7279-7380, 9140, 9207, 11103.)

479. Standard operating procedures governing offsite emergency communications and coordination relating to O

protective actions (Corrective Action Nos. 1(c) and (e)) have 221 A

- ___m_,_ - . _ _

n) '

t been developed. (Exhibits #152(a) nd (e), #153(a) and (e),

D #154(a) and (e), 4155(a) and (e), #156(a) and (e); P2. lme r ,

Tr. 9207, 11102-11105.)

480. An on-going offsite program of general O radiological emergency response training and radioloc. '. cal monitoring and assessment training has been developed and is being made available on an on-going basis to the offsite emergency response personnel, in addition to other training programs on these topics (Corrective Action No. 6).

(Exhibits w85-92, #111, #150 (IPC Meeting Minutes O

(September 11,1981), p.3), 4157, #158; Linnemann, Tr.

7081-7101, 10831-10833; Murri, Tr. 7236: Pilmer, Tr. 7395, 9209, 11102-11105; Killingsworth, Tr. 9294-8295; Stowe, Tr.

O 8503, 8549; Coleman, Tr. 8605-8606: Ferguson, Tr. 8692; Swanson, Tr. 8807; Turner, 8923-8924; Fox, Tr. 9028; Hunt, Tr. 9275-9276, Nauman, written testimony (August 24, 1981),

O

p. 11, Tr. 10372, 10929-10932; Sears, written testimony (August 6, 1981), pp. 9-10, Tr. 10644, 10723.)

O D. Further FEMA Findincs 481. FEMA has indicated to the Board that it will review the corrective actions outlined above to determine if, O

as implemented, they are sufficient to remedy the deficiencies noted in the Interim FEMA Findings. FEMA will report the results of its review to the Board. Under these O

circumstances, the Board finds it unnecessary at this time to 222 O l

)

resolve the app. rent conflicts becween the Interim FEMA

) Findings and th" evidence offered by Applicants and the local emergency response organizations.

O VII.

CONCLUSIONS OF LAW D 482. The conclusions of law which follow are in addition to those conclusions of law reached by this Board with respect to the geology / seismology and low power D

contentions considered in this proceeding. Any finding of fact which is more properly a conclusion of law is hereby incorporated in these conclusions of law.

D 483. Upon consideration of the record of the proceeding and in light of the foregoing findings and discussion, the Board concludes that, with respect to the D

requirements of the Atomic Energy Act of 1954, as amended, and the rules and regulations of the Commission relating to onsite and offsite planning and emergency preparedness:

D (1) The Plume and Extended EPZs established for SONGS meets the requirements of 10 C.F.R. S 50.47(c)(2)

(2) At the time of initia' fuel loading for SONGS D

2, Applicants will have the capability to respond to emergencies at SONGS 2 & 3 and to augment this initial response on a continuous ba_,s as required by 10 C.F.R.

D

$ 50.47(b)(1) and Part 50, Appendix E. IV.

223 D

J

l (3) The principal'offsite emergency response 3 organizations have the capability to respond to emergencies at SONGS 2 & 3 and to augment this initial response on a continuous basis as required by 10 C.F.R. S 50.47(b)(1).

h (4) Applicants' capability to notify involved State and local emergency response organizations meets the requirements of 10 C.F.R. S 50.47(b)(5) and Part 50, Appendix D E.IV.

1 5) The capability of Applicants and the involved offsite emergency response organizations to notify and alert 4

the various agencies and persoanel involved in responding to a radiological emergency at SONGS 2 & 3 meets the requirements of 10 C.F.R. S 50.47(b)(6) and Part 50, Appendix 0

E.IV.

(6) The capability of Applicants and the involved offsite emergency response organizations to implement O

continued communication among all involved organizations meets the requirements of 10 C.F.R. ! 50.47(b)(6) and Part 50, Appendix E.IV.

9 (7) The various onsite and offsite emergency response organization notificatien and communication systems are adequate and capable of being implemented in compliance O

with 10 C.F.R. SS 50.47(b)(5) and (6) and Part 50, Appendix E.IV.

S 224 0

O (8) Each of the principal response organizations O has an emergency operations center and the communications and transportation equipment necessary to support its role during an emergency at SONGS 2 & 3 affecting the offsite transient O and permanent population in compliance with 10 C.F.R.

S 50.47(b)(8).

(9) Applicants' emergency response planning and O implementation capability as regards the physical design, communications equipment, and operating procedures for the Interim EOF meets the requirements of 10 C.F.R.

O $$ 50.47(b)(3) and (b)(8) and Part 50, Appendix E.IV.

(10) The Applicants' capabilities to accomplish all necessary offsite radiological dose assessment and protective O action recommendation functions satisfy the standards for offsite dose assessment and radiation monitoring capability set forth in 10 C.F.R. S 50.47(b)(9) without the need to O consider the additional offsite radiation monitoring and dose ,

assessment capabilities of Federal, State and local agencies. .

(11) The plans, procedures and capabilities of the O involved offsite jurisdictions and supporting Federal, State and local agencies to parform radiation monitoring and dose assesement, as coordinated in the Offsite Lsse Assessment O Center, satisfies the standards for offsite dose assessment and radiation monitoring capability required by 10 C.F.R.

S 50.47(b)(9).

O 225 0

_ _ _ _ _ _ _ _ . _ _ _ _ _ _ - - _ _ - . -)

O (12) The plans, procedures and capabilities of the G State and local jurisdictions and SCE to assess and monitor actual or potential offsite consequences of a radiological emergency condition within the Ingestion EPZ are adequate and O satisfy the requirements of 10 C.F.R. 5 50.47(b)(9).

(13) The radiological emergency response training being provided to onsite personncl at SONGS who may be called O upon to assist in an emergency is adequate and satifies the requirements of 10 C.F.R. $ 50.47(b)(15).

(14) Appropriate radiological emergency response e training has been and will continue to be provided to onsite and offsite emergency response personnel who may be called on to assist in an emergency and such training satisfies the G requirements of 10 C.F.R. 5 50.47(b)(15)

(15) Adequate arrangements for medical services for contaminated and injured individuals have been made in

] compliance cith 10 C.F.R. S 50.47(b)(12).

(16) The information and procedure for dissemination of such information to the public within the D Plume and Extended EPZs on a periodic basis is adequate to inform the public on how they will be notified and what their acuions should be in the event of an emergency in compliance D with 10 C.F.R. S 50.47(b)(7) and Part 50, Appendix E.IV.

(17) The physical and administrative means for prompt emergency notification to the populace within the Extended and Plume EPZs is adequate and meets the 226 D

)

requirements of 10 C.F.R. 5 50.47(b)(5) and Part 50, Appendix E.IV.

(18) The means to provide instruction to the populace within the Extended and Plume EPZs is adequate and

) meets the requirements of 10 C.F.R. 5 50.47(b)(5). '

(39) The general plans of SCE and the local response agencies for recovery and reentry following a D

radiological emergency at SONcS L & 3 are adequate and satisfy the requirements of Ic C.F.R. 5 50.47(b)(13) and Part 50, Appendix E.IV.

S (20) There is reasonable assurance that the offsite transient and permanent poculation within the Extended and Plume EPZs for SONGS 2 & 3 can be evacuated or otherwise 3

adequately protected in the event of a radiological emergency with offsite consequences, as required by 10 C.F.R. 5 57.47(a)(1), (b)(10) and Part 50, Appendix E.IV.

9 (21) The onsite and offsite radiological emergency response plans are adequate, and the capability to implement these plans currently exists.

9 (22) The overall state of onsite and offsite emergency planning and preparedness provides reasonable assurance that adequate protective measures can and will be B

taken in the event of a radiological emergency involving SONGS 2 & 3, as required by 10 C.F.R. 5 50.47(a)(1).

D 227 D

)

UNITED STATES OF AMERICA

) NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

D Docket Nos. 50-361 OL

)

SOUTHERN CALIFORNIA EDISON ) 50-362 OL COMPANY, ET AL )

)

(San Onofre Nuclear ) ORDER GRANTING FULL

) Generating Station, Units 2 and 3

)

)

POWER, FULL TERM OPERATING LICENSES

)

IT IS HERE3Y ORDERED, pursuant to the Atcmic Energy D Act of 1954, as amended, and the U.S. Nuclear Regulatory Commission regulations and based upon the findings of fact and conclusions of law set forth herein and in the Partial

) Initial Decision with respect to seismology / geology and low power issues, that the Director of Nuclear Reactor Regulations is authoriced pursuant to 10 C.F.R. 5 2.764(b),

D upon making the findings on all other matters specified in 10 C.F.R.  ! 50.57(a), to issue to Appilcants Southern California Edison Ocmpany, San Diego Gas & Electric Company, City of B

Anaheim, Califernia and City of Riverside, California, license to authorice full power operation for Units 2 and 3 of San Onofre Nuclear Generating Station, for a term of not D

r. ore than forty (40) years, at power levels not exceeding 1161 MWe net of electrical power per Unit.

IT IS FURTHER ORDERED, in accordance with 10 C.F.R.

D Sections 2.762, 2.764(a), 2.795 and 2.786, and Part 2,

,,a uuv

O Appendix B of the Commission's Rules of Practice, that the O effectiveness of this Initial Decision shall be stcyed pending review of this Decision by the Nuclear Regulatory Commission, or further order of the Commission.

O Atomic Safety and Licensing Board O James L. Kelley, Esq., Chairraan Dr. Cadet Hand, Jr.

O Ms. Elizabeth B. Johnson O Dated at this day of _ , 1981 i

i

'O O

O O

229 O

l

(?C)J3)(

O O PRCJF OF SERVICE BY MAIL I declare that:

I am amp 1 yed in the City and County of San O

Francisco, California.

I am over the age of eighteen years and not a party to the within entitled action; my business address O

is 600 Montgomery Street, 10th Floor,- San Francisco, California 94111.

g On November 9, 1981, I served the attached APPLICANTS' PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW ON EMERGENCY PLANNING AND PREPAREDNESS ISSUES in said o cause, by placing a true copy thereof enclosed in the United States mail at San Francisco, California, addressed as follows: (except where indicated by *)

O James L. Kelley, Chairman Administrative Judge Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C. 20555 O Dr. Cadet H. Hand, Jr.

Administrative Judge c/o Bodega Marine Laboratory University of California P. O. Box 247 Bodega Bay, California 94923 Mrs Elizabeth B. Johnson i

Administrative Judge l

Oak Ridge National Laboratory 1 P. O. Box X, Building 3500 Oak Ridge, Tennessee 37830 i

g 230

)

t

) David W. Gilman Robert G. Lacy San Diego Gas & Electric Company P.O. Box 1831 San Diego, California 92112

) Robert Dietch, Vice President Southern California Edison Company P.O. Box 800 2244 Walnut Grove Averue Rosemead, California 91770 ,

Alan R. Watts, Esq.

Rourke & Woodruff California First Bank Building 10555 North Main Street Santa Ana, California 92701 b

• Lawrence J. Chandler, Esq.

Richard K. Hoefling, Esq.

Donald F. Hassell, Esq.

Nuclear Regulatory Commission Office of the Executive Legal Director Washington, D.C. 20555

) (3 copies)

Janice E. Kerr, Esq.

J. Calvin Simpson, Esq.

Lawrence Q. Garcia, Esq.

) California Public Utilities Commission 5066 State Building San Francisco, California 94102 Mr. Lloyd von Haden

) 2089 Foothill Drive Vista, California 92083 Mrs. Lyn Harris Hicks GUARD 3908 Calle Ariana 92801

) San Clemente, California James F. Davis State Geologist Division of Mines and Geology 1416 Ninth Street, Rocm 1341

) Sacramento, California 95814

) 231

)

i l

• Richard J. Wharton, Esq.

[) Universit.y of San Diego School sf Law Alcala Park l

San Diego, California 92110 l

[)

• Phyllis M. Gallagher, Esq. ,

1695 W. Crescent Avenue, Suite 222 Anaheim, California 92801 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 -

3 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 J

• Spence Perry, Esq.

Federal Emergency Management Agency Of fice of General Counsel Room 840 500 C Street, S.W.

) Washington, D.C. 20472

• Charles E. McClung. Jr., Esq.

24012 Calle Dela Plata, Suite 330 Laguna Hills, California 92653 3 -

) /s/ Samuel B. Casey SAMTEL B. CASEY One of Counsel for Applicants SOUTHERN CALIFORNIA EDISON COMPANY and SAN DIEGO GAS &

) ELECTRIC CO.

)

• Served by Network Courier

) 232

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