ML20010B403

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Forwards NRC Testimony on Guard Contentions 2.A,2.B,2.C, 2.D,2.G & 2.h Re Emergency Preparedness,Aslb 810804 Emergency Plume Zone Contention & ASLB 810807 Order Modifying Issue of Earthquakes & Emergency Planning
ML20010B403
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 08/12/1981
From: Hassell D
NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To: Nauman K
Federal Emergency Management Agency
References
ISSUANCES-OL, NUDOCS 8108140444
Download: ML20010B403 (1)


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M August 12, 1901-

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.g, se Kenneth W. Hauman, Jr.

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A lj g y 3 IS 8 I h.87 Plans and Preparedness Division Federal Energency llanagement Agency N%D@

211 Hain Street

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In the liatter of SOUTHERN CAlliURNIA EDISON C0!1PANY, ET AL.

(San Onofre Nuclear Generating Station, Units 2 and 3)

, Docket Nos. 50-361 OL and 50-362 UL

Dear Mr. Haut'.an:

Enclosed is a copy of the "HRC STAFF TESTIM 0fiY ON GUARD CONTENTIONS 2.A.

2.B. 2.C. 2.D. 2.F. 2.G. AtID 2.H C0itCERNING EliERGENCY PREPAREDNESS FOR THE SAN OliOFRE NUCLEAR GENERATIf1G STATION, Ut11TS 2 AND 3"_ which was filed on August 10, 1981.

Also, I have enclosec a copy of the EPZ contention admitted by the Board on the record of August 4, 1981.

It is qy understanding that FEMA will be primarily responsible for providng testimony on this contention. On August 7,1981, the Board issued an order codifying the issue concerning earthquakes and energency planning. A copy cf this order is also enclosed.

Should you have any questions, please do not hesitate to contact me.

erely, Donald F. Hassell Counsel for NRC Staff

Enclosures:

As stated Distribution:

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N2C FORM 318 hoi 80{NRCM O240 O F@0CI AL R ECO R D CO P Y

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G August 10, 1981 UNITED STATES OF A!! ERICA NUCLEAR REGULATORY COMMISSION BEFORE THE' ATOMIC SAFETY AND LICENSING BOARD In the Hatter of SOUTHERN CALIFORNIA EDISON Docket Nos. 50-361 OL COMPANY, ET AL.

50-362 OL

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(San Onofre Nuclear Generating i

Station, Units 2and3) l NRC STAFF TESTIMONY ON GUARD CONTENTIONS 2.A.

2.B, 2.C. 2.0, 2.F. 2.G, and 2.H CONCERNING E!!ERGENCY PREPAREDNESS FOR THE SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 I

In accordance with 10 C.F.R. 9 2.743(b), the Atomic Safety and

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Licensing Board's Order on the record of July 10, 1981, and tre stipulation of the parties, the NRC Staff hereby submits its direct testimony on GUARD's emergency planning contentions numbered 2.A. 2.B.

2.C. 2.0, 2.F. 2.G., and 2.H.

Respectfully submitted,

,ff Richard K. Hoefling V

Coun al for NRC Staff O

Donald F. Hass 1 Counsel for NRC Staff Dated at Bethesda, liaryland, this 10th day of August, 1981.

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O UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION I

BEFORE THE ATOMIC __ SAFETY A_ND LICENSING BOARD In the Matter of

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SOUTHERN-CALIFORNIA EDICSON COMPANY, E S* '

Docket Nos. 50-361 OL 50-362 OL (San Onofre Nuclear Generating

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Station, Units 2 and 3)

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TESTIMONY OF JOHN R. SEARS OF THE NRC STAFF ON GUARD CONTENTIONS 2.A. 2.B. 2.C, 2.D, 2.F 2.G and 2.H RELATED TO EMERGENCY PREPAREDNESS FOR THE SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 and 3 AUCiUST 6, 1981 D !L CL-Ol($614@4GA i

I Q.1 State your name and title?

i boknR. Sears.

I am a Senior Reactor Safety Engineer in the A.

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Em rgency Preparedness Licensing Branch, Division of Emergency Preperedness, Office of Inspection and Enforcement, U.S. Nuclear Regulatory Commission.

Q.2 Do you have a statement of professional qualifications?

A.

Yes. A copy of my statement of profes;ional qualifications is attached to this testimony.

Q.3 What is the purpose of this testimony?

A.

The purpose of this testimony is to address Contentions 2.A, 2.B.

2.C, 2.0, 2.F, 2.G and 2.H raised by Interveners GUARD in this operating license proceeding which are related to the emergency preparedness of the San Onofre Nuclear Generating Station, Units 2 and 3 (SONG 3 2 and 3). My testimony will examine the state of the Applicants' emergency preparedness as it affects these GUARD's contentions.

Q.4 GUARD Contention 2 states in part:

Whether there is reasonable assurance that the emergency response planning and capability of implementation for SONGS 2 & 3, affecting the offsite.

transient and permanent po'ulation, will comply with 10 CfR Sections 50,47 (a)(1) and (b) or (c)(1) as regards:

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the procedures for notification by Applicants of State and

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local response organizations, 10 C.F.R. Section 50.47(b)"5),

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

Section50.47(b)(6);

B.

the means for notification and instruction to the populace

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within the plume exposure pathway Emergency Planning Zone, 10 C.F.R. Section 50.47(b)(5);

C.

the inforn:ation and the procedures for dissemination of informa-tion to the public within the plume exposure pathway Emergency Planning Zone on a periodic basis on how they will be notified and what their initial actions should be in the event of an e.nergency,10 C.F.R. Section 50.47(b)(7};

the arrangements for medical services for contaminated and injured D.

individuals,10C.F.R.Section50.47(b)(12);

the capability of each principal response organization to F.

respond and to augment this initial response on a continuous basis, 10 C.F.R. Section 50.47(b)(1);

radiological emergency response training to those who may be called G.

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on to assist in an emergency, 10 C.F.R. Section 50.47(b)(15);

the methods, staffing, systems, and equipment for assessing and H.

monitoring actual or potential offsite consequences of a radio-logical emergency condition within the plume exposure pathway EPZ for S0tlGS 2 & 3, 10 C.F.R. Section 50.47(b)(9);

With respect to Contention 2.A, have you examined the procedures for not'.:.caticn by Applicants of State and local response organizations?

A.

Yes. The applicant's procedure 1.4 entitled "flotification" provides detailed instructions for contacting offsite agencies. The procedure includes Initial flotification forms for each of the four classes of l

emergency, an emergency notification call-list, and a follow-up notification form. The procedure implenents Emergency Plan Table 5-4 Offsite Response Agency notification and conforms to the criteria of fiUREG-0654,E.

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Q.5 With respect to Contention 2.A, do the Applicants' procedures for

' notification of State and local response organizations described in your response to Question 4 above meet planning standard 10 CFR Section 50.47(b)(5)?

A.

Yes, as discussed in the pervious answer, the Applicant's procedures conform to the criteria of NUREG-0654 E which are the criteria for implementing the planning standard of 10 CFR 50.47(b)(5).

Q.6 With respect to Contention 2.A, have you examined the Applicants' procedures for notification and continued communication among emergency personnel by all involved organizations?

A.

Yes. The Applicants' procedure 1.26 entitled " Communications" describes the communications systems that are available for emergency use, their location and their functions. Th's procedure is similar to Emergency Plar, Table 7-1 and 7-2, and conforms to the criteria c' NUREG-0654,F.1. The Applicant's procedure 1.4 Noti-fication includes instructions for follow-up notification. The follow-up notification form is similar in format to the Initial Notification forms but has more extensive technical content. The Applicant's procedure', for Site and General Emergencies contain instructions for the periodic dissemination of information on the status of ansite operations and conditions to offsite authorities.

Q.7 With respect to Contention 2.A do the Applicants' procedures i

wnich you have described in your response to Question 6 above meet planning standard 10 C.F.R. Section 50.47(b)(6)?

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A.

Yes. The implementation of the Applicant's capbility for notifica-tion and continued communication among emergency oersonnel was

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2 demonstrated during the full-scale exercise involving the applicant and offsite organizations on May 13, 1981 to the extent that the procedures and systems employed during the Unit 1 exercise were similar to those in place for Units 2 & 3.

These procedures and systems proved to workable and effective.

Q.8 With respect to Contention 2.B. have you examined the Applicants' means for notification and instruction to the populace within the plume exposure pathway EPZ?

A.

Yes, the applicant has designed a siren system in the communities

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within 10 miles of San Onofre. As of August 1,1981, 32 of the 40 sirens and the control system had been installed and the total system is scheduled to be operational by September 1,1981. The Applicant has submitted a map showing siren locanons with analytical results of the sound levels anticipated.

The purpose of the sirens is to alert the public to tune in to local radio stations for emergency instructions.

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6-Q.9 With respect to Contention 2.B do t.1e means for notification and instruction to the populace within the plume exposure pathway EPZ wh,1ch you have described in response to Question 8 above meet plan-ning standard 10 CFR Section 50.47(b)(5)?

A.

Yes the means for notification and instruction to the populace satisfy the criteria of NUREG-0654, E and Appendix 3 which are the implementation criteria for 10 CFR 50.47(b)(5).

Q.10 With respect to Contention 2.C. have you examined Applicants' pro-cedures for dis:emination of information to the public within the plume exposure pathway EPZ on a periodic basis as to how the public will be notified and what its initial actions should be in the event of an emergency?

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A.

Yes, an informational brochure hs been mailed to residents of San Clemente, San Juan Capistrano, Capistrano Beach and Dana Point. The document provides a general outline of public notification, sheltering and evacudtion procedures, and a detailed map of evacuation routes and location of reception and care facilities. The mailing was preceded by a newspaper advertisement with instructions on how to obtain a copy of the brochure for anyone who may not have received it through the mail.

New applicants for electrical service are given complete emergency planning information. A flyer has been printed with similar information for distribution to all park visitors.

Emergency response posters have been designed for notels and hotels. The next issue of the telephone directory will have a page of emergency public notification information i

s.g-a'nd protective action instructions. The total pubile education program for the p1'ume exposure pathway EPZ is scheduled for fell operation by the Fall of 1981. On an annual basis, simplified mailers and newspaper adv;er[isenents will remind residents of the emergency planning educationai t

program.

Q.11 Do the App 1tcants' procedurer for dissemination of informatior, which you have described in response to Question 10 above meet planning standard 10 CFR Section 50.47(b)(7)?

A.

Yes, the Appiicants' procedures for dissemination of information satisfy the criteria of NUREG-0654, G1 and G2, which are the implementation criteria for 10 CFR 50.47(b)(7).

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o.i2 with respect to Contention 2.0 have you examined arrangements made by Applicants for medical services for contaminated and injuredin.iidduals?

j' A.

Yes, the Applicant's emergency procedures 1.8 Emergency Exposure, 1.9 Thyroid Blocking Pills,1.11 Rescue, and 1.12 Injury described in detail such arrangements. Emergency Procedure 1.12 includes a checklist for Control Room Actions for Personr.el injury, instruction for contamination injury treatment and a directional map to egress and a layout for the South Coast Community Hospital. Arrangements have also been made with the Tri City Community Hospital to provide medical assistance for injured and contaminated patients. The Emer-gency Plan includes Letters of Agreement with local physicians for treating any individual suffering from an injury complicated by radiation contamination as a consequence of activity at San Onofre.

In addition, the Applicant has recently signed a contract for training of both onsite and offsite personnel who may be involved with a potentially contaminated and injured person.by the Radiation Management Corporation. The Applicant has written agreements with the Scudder Ambulance Company and the Superior Ambulance Company for transporting injured and contaminated personnel. The Emergency Plan at Section 6.5.2 recaires that two persons trained in first aid will be onsite at all times.

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I Q.13 With respect to Contention 2.D do Applicants' arrangements for 5ebicalservicesforcontaminatedandinjuredindividuals

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described in your respon.se to Questien 12 above, meet planning standard 10 C.F.R. Section 50.47(b)(12)?

A.

Yes, the Applicant's arrangements for medical services satisfy the criteria of NUREG-0654, L 1, 2 and 4 which are the implementa-tion criteria for 10 C.F.R. 50.47(b)(12).

Q.14 With respect to Contention 2.F have you examined the Applicants' provisions to respond to an emergency and to augment any initial response on a continuous basis?

A.

Yes, Section 5 of the Emergency Plan describes in detail the onsite g

emergency organization and its augmentation and extension offsite.

The Watch Engineer is initially designated as the Site Emergency Coordinator. When an abnormal situation arises, it is his responsi-bility to determine the classification of the situation and to implement the Emergency Plan. There is continuous 24-hour communication capability between San Onofre and Federal, State and local response organizations to ensure rapid transmittal cf accurate notification information and emergency assessment data.

The Site Emergency Coordinator has the authority to declare the emergency and to make the necessary notifications and recommendations to offsite authorities. Station staff emergency assignments have been made.

Call-out for augmentation of on-shift. capabilities would t

be made,immediately upon declaration of the emergency. The Applicant

-g-1 states that all required personnel would be present within 60, minutes, and qualified personnel necessary to perform the functions listed in NUREG-0654, Table B-1, under capability for 30 minutes, would be present within 30 minutes.

Q.15 With respect to Contention 2,F, does the Applicants' capability to respond to an emergency and to augment this initial response on a continuous basis described in your response to Question 14 above meet planning standard 10 C.F.R. Section 50.47(b)(1)?

A.

Yes, the Applicant's capability to respond to an emergency and to augment his staff satisfies the criteria of NUREG-0654, A & B, which are the implementation criteria to meet the planning standard 10 CFR 50.47(b)(1)?

Q 16 With respect to Contention 2.G have you examined the Applicants' radiological emergency response training provided to those who may be called on to assist in an emergency?

A.

Yes, the Applicant's Emergency Plan in Table 8-1 lists the personnel involved and the requirements for both initial and periodic re-training on the scope, responsibilities and functioning of the Emergency Plan and Emergency Implementing Procedures with specific instruction on those aspects applicable to the particular person's responsibility. These areas include emergency response coordina-tion and direction, accident assessment, radiological monitoring, repair and damage control, rescue and first' aid.

I have been I

informed by the Applicant that the initial training on the Emergency Plan is in' progress and will be completed prior to fuel loading. In

I addition, the Applicant has described to me the training provided

.through the Applicant's support by the Radiation Management Corporation for over 300 personnel from offsite organizations, i

including physicians and hospital emergency room personnel, ambulance personnel, police and firemen.

Q.17 With respect to Contention 2.G, does the radiological emergency response training provided by the Applicants which you have de-cribed in response to Question 16 above meet planning standard 10 C.F.R. Section 50.47(b)(15)?

A.

Yes, the radiological emergency response training provided by the Applicants satisfies the criteria of NUREG-0654, O which are the implement-tation criteria to meet the planning standard of 10 CFR 50.47(b)(15).

Q.18 With respect to Contention 2.H, have you examined the methods, staffing, systems and equipment available to Applicants for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition within the plume exposure pathway EPZ for SONGS 2 and 37 A.

Yes, radiological monitoring systems to monitor radioactivity levels in all of tha important process and effluents points are described

'in Section 11.5 of the PSAR. Additional listings of equipment available at the station for both' initial and continuing assessment of emergency situations are in Tabics 7-3 through 7-7 and Appendix D l

of the Emergency Plan.

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The Applicant is training the Health Physics Shift Foreman to perform dose assessments. There are at least 2 Senior Health Physics technical 2

personnel, qualified to perform dose assessments, whose driving time from..

honie to San Onofre is less than 30 minutes.

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The Applicant's Emergency Implementation Procedure 1.22, Emergency Dose Projections - Airborne Release, for Unit 1 is-presently under study and revision to apply to Unit 2 and 3.

' land calculations are employed in this procedure. The Applicant is installing a Health 1

Physics computer system which will process meteorological data and data from radiation monitors to calculate dose at various distance's from the plant. This automated system is scheduled to be fully operational by July 1982 and will be available for connection to offsite I

authorities.

Q.19 Do the methods, staffing, systems and equipment, available to Applicants for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition described in your response to Question 18 above meet planning standard 10 C.F.R.

Section 50.47(b)(9)?

A.

Yes, the methods, staffing, systems and equipment for monitoring releases and assessing consequences satisfy the criteria of NUREG-0654, I which are the implementation criteria to meet the planning standard of 10 C.F.R. 50.47(b)(9).

Q.20 What is your assessment of the Applicant's capability to implement-the procedures and activities which you have described in this i

testimony?

l' A.

I'have reviewed the implementing procedures and, in my judgment,

,they provide adequate and clear direction to the person called

- upjntoimplementthem. The Applicant has an ongoing training prbgram which I have examined and found acceptable. This training program provides assurance that the procedures will be followed.

Additional confirmation of the Applicant's ability to implement tha emergency preparedness program is provided through the Offic'd-of Inspection and Enforcement's Emergency Preparedness Appraisal Program (EPAP) which is an onsite inspection and verification process, and the conduct, by the Applicant of an onsite exercise, both of which are scheduled far before the time expected for issuance of the operating license for San Onofre 2 & 3.

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JOHN R. SEARS RESUME' L

Prior to 1952, I w.s employed in field jobs in various aspects of mechanical engineering. In1952.IjoinedBrookhavenNationalLaboratoryasaReactorShift Supervisor on the Brookhaven Graphite Reactor. While at Brookhaven, I completed a series of courses given by the Nuclear Engineering Department in nuclear engineering.

These courses were patterned on the ORSORT programs.

In 1956. I was appointed Project Engineer on the Brookhaven Medical Research Reactor.

I was a member of the design group, participated in critical design experiments, wrote specifications, coauthored the hazards report, was responsible for field ipspection and contractor liaison, trained operators and loaded and started up the reactor. About three months after start-up, in 1959, following the successful completion of proof tests f

and demonstration of the reactor in its design operating mode for boron capture therapy of brain cancer, I accepted a position as reactor inspector with the Division of Inspection, U. S. Atomic Energy Commission.

In 1960 I transferred, as a reactor inpsector, to the newly-formed Division of Compliance.

I was responsible for the inspection, for safety and compliance with license requirements, of tha licensed reactors and the fuel faDrication and fuel processing plants. which use mora than critical amounts of special nuclear material, in the Eastern United States.

In September 1968, I transferred to the Operational Safety Branch, Directorate of

' icensing. My responsibility included development of appropriate guides for evaluation of operational aspect of license applications and staff ussistance in review of power reactor applicants submittals in the areas. of Organization and Management.

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Personnel Qualifications, Training Programs, Procedures and Administrative Control, Review and Audit, Start-up Testing Programs Industrial Security and Emergency Planning.

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u The Branch was reorganized as the Industrial Security and Emergency Planning Branch in April 1974 to place increased empnasis and attention upon areas of physical security and emernency planning.

In 1976 I transferred to the Divison of Operating Reactors as the sole reviewer responsible for review of emergency planning for all the operating reactors in the United States.

New York City College,1950 - Mechanical Engineering Argonne International School of Reactor Technology,1961 - Reactor Control Course GE BWR System Design Course,1972 Popo-U.S. Army,1974 - Course in Industrial Defense and Disaster Planning Instructor at DCPA, 1976, 1977 - Course in Emergency Planning Director,1962 - Reactor Program, Atoms for Peace Exhibit, Bangkok, Thailand

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Director,1966 - Atoms for Peace Exhibit, Utrecht, Holland

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I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSItG BOARD In the Matter of SOUTHERN CALIFORNIA EDISON COMPANY,

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Docket Nos. 50-351 OL ET AL.

50-362 OL (San Onofre Nuclear Generating Station, )

Units 2 and 3)

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CERTIFICATE OF SERVICE I hereby certify that copies of "flRC STAFF TESTIM 0!!Y ON GUARD CONTENTI0fis 2.A, 2.B 2.C. 2.D, 2.F 2.G, AflD 2.H C0flCERflING EfiERGENCY PREPARED'lESS FOR THE SAN ON0FRE NUCLEAR GEtlERATING ST.aTION, UNITS 2 AtlD 3" in the above-captioned proceeding have been served on the following by depoeit in the United States mail, first class or as indicated by a double asterisk by express delivery service or as indicated by an asterisk by deposit in the Nuclear Regulatory Commission internal mail system, this 10th day of August,1981:

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  • James L. Kelley, Esq., Chairman
    • David R. Pigott, Esq.

Administrative Judge Samuel B. Casey, Esq.

Atomic Safety and Licensing Board John A. Mendez, Esq.

U.S. Nuclear Regulatory Commission Edward B. Rogin, Esq.

Washington, D.C.

20555 Of Orrick, Herrington & Sutcliffe A Professional Corporation Dr. Cadet H. Hand, Jr.,

600 Montgomery Street Administrative Judge San Francisco, California 94111 c/o Bodega Marine Laboratory University of California Alan P.. Watts, Esq.

P. O. Box 247 Daniel K. Spradlin Bodega Bay, California 94923 Rourke & Woodruff 10555 North Main Street Mrs. Elizabeth B. Johnsen, Suite 1020 Administrative Judge Santa Ana, California 92701 Oak Ridge National Labcrrfory P. O. Box X, Building 350J

    • Richard J. Wharton, Esq.

Oak Ridge, Tennessee 37830 University of San Diego School of Law Alcala Park Janice E. Kerr, Esq.

San Diego, California 92110 J. Calvin Simpson, Esq.

Lawrence Q. Garcia, Esq.

Mrs. Lyn Harris Hicks California PuLlic Utilities Commission GUARD 5066 State Building 3908 Calle Ariana San Francisco, California 94102 San Clemente, California 92672 N

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    • Charles R'. Kocher, Esq.

A. S. Carstens

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James A. Beoletto, Esq.

2071 Caminito Circulo Norte Southern California Edison Company Mt. La Jolla, California 92037 2244 Walnut Grove Avenue Rosemead, California 91770

  • Atomic Safety and Licensing Board Panel David W. Gilman U.S. Nuclear Regulatory Commission Robert G. Lacy Washington, D.C.

20555 San Diego Gas & Electric Company P. O. Box 1831

  • Atomic Safety and Licensing Appeal San Diego, California 92112 Board Panel U.S. Nuclear Regulatory Commission
    • Phyllis M. Gallagher, Esq.

Washington, D.C.

20555 1695 West Crescent Avenue Suite 222

  • Secretary U.S. Nuclear Regulatory Commission Anaheim, California 92701 ATTN: Chief, Docketing & Service
    • Charles E. McClung, Jr., Esq.

Branch Fleming, Anderson, McClung & Finch Washington, D.C.

20555 23521 Paseo De Valencia Suite 30BA

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' Laguna Hills, California 92653 Donald F. Hassell Counsel for NRC Staff l

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I EPZ CONTENTION ADt11TTED BY ASLB ORDER ON THE RECORD OF AUGUST 4, 1981 (TR. 6803)

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 they have mechanicilly 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 tha area.

In determining the exact size of the EPZ, emergency pianning officials have failed to consider.the following local conditions:

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topography 2.

meteorology 3.

evacuation routes 4.

demography 5.

jurisdictional boundaries 6.

SAI report 7.

land characteristics f

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NUCLEAR REGUIA10RY 00'4:4ISSION 3

A'IOl4IC SAFETY MD LICENSINGyp BE50AE AIX4INIS'IRATIVE JUDGES James L. i.elle,-. Chairman r) H M v

Elizrbeth B. Joh'6's'on

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  • Cadet H.. Hand
  • U3!J.C.-0 ELD

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In the Matter of

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Docket Nos. 50-361-OL

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50-362-OL S'XTrdERN CALIEORNIA EDISCN 02MPANY,

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er (San Onofre Nuclear Generating

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Station, Units 2 and 3)

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August 7, 1981

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ORDER

(!tdifying an Issue Concerning Earthquakes and Emergency Planning)

At the time of our filing of July 29, 1981, the Board had in hand menoraMum to'it from Darrell G. Eisenhut of the NRC the June 11, 1981 13, 1981 letter That memorandum transmitted to us a copy of the May Staff.

from Ecbert L. Tedesco of the NRC Staff t2s Mr. Robert,Dietch aM Mr. D. W.

Gilman (Vice-Presidents of Southern California Edison Conpany and San Diego Gas and Electrlc Conpany, respectively). 'Ihat letter set forth in detail the Staff's view of the natters to be considered by the Applicants

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concerning the evaluation of the effect of earthquakes on their emergency Specifically, the Board noted that the Applicants were told, For plans.

purposes of this evaluation, as a planning " basis you may assume that the plant experiences earthquake effects no nore severe than the Safe Shutdow I

Earthquake." Tne Board Order of July 29, 1981 stated our reasons for postulating an earthquake in excess of the SSE and we a-e rot, swayed from that position.

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,y We have listened to oral arguments, concerning our Order and have Our concerns still focus upon received written me.roranda from the' parties.

the questions we raised in the Order, namely, "What steps could be taken the Applicants ard responding jurisdictions to carry out evacuation in a timely manner and/oc protect those in the EPZ pending evacuation" follow a damaging earthquake.

29,1981 may It now appears, however, that th'e Board order of July have posed such severe consequences resulting frczn the hypothesized earthquake that evacuation and/or ' protection of t%se in the EPZ would be virtually inpossible. W at was not our intention. We Board's intent was, a site specific inquiry to examine the inpact of a najor earthquake,.

he Board, acconpanied by a radioactive release, qpon the _emergeng plans.

does rot know what magnitude earthquake would be required to cause a

" breach of containment" ard " collapse of bridges and overpasses 'and surfa We therefore breaks rendering the highways tenporarily inpassable."

present the following revised issue.:

his assuned Assume a major earthquake in the MS area.

earthquake causes extensive structural damage to s

accompanied by radiological releases requiring evacuation in theI plume exposbre pathway of the EPZ.

could be taken by the applicants and responding jurisdictions to carry out evacuation in a tinely manner and/or protect thos i

EPZ pending evacuation? resources, could be brought in to assist in would federal assistance be acconplished?

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h t the physical In p> sing the' foregoing the Board wishes to learn w a l

increasing seperity beyond the consequences of earthquakes, in a scale of l te to comunications and i

SSE, would be upon the cmtrgency plans as they re a ticn would become,a evacuations up to some presumed point where evacua A point of beginning physical ingossibility in any reasonable time frame.f an SSE should relate to the presumed consequences o icarions and highways.

upon evacuation and the meessary related c:>nmun l

Ing for such an Pursuant to the Staff's earlier instructions, p ann Sequentially, in progress.

earthquake presumably either is conplete or d conseEpences from that level of planning, we wish to eramine the presume s they relate to the k

of a series of increasingly nore severe earthqua es a y of Our giyestions are designed only to. test the adequa emergency plans.

cance is reasonable assu h

the emergency plans and td determine whether t ereill be tak that adequate protective measures can cui w diological releas,es severe event of a najor earthquake accoapanied by ra l

enough to initiate the e:rergency evacuation p an.

FOR TdE A'IOMIC SAFEIY AND LICENSIN3 BOARD 3M'-

J4 meg L. Kelley, Chairman AIX4INISTRATIVE JUDGE Dated at bethesda, Maryland this 7th day of August 1981.

Chairman Palladiro cc:

Cbmaissioner Gilinsky (bmissioner Bradford Comissioner Ahearne Iconard Bickwit, Jr., GC

' **mme. = m e e

em,

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