ML20030C375

Forwards Jr Sears Testimony on Guard Contentions 1,2.E,2.I, 2.J & 2.K Re Facility Emergency Preparedness

ML20030C375
Person / Time
Site:	San Onofre
Issue date:	08/21/1981
From:	Hassell D NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	Perry S Federal Emergency Management Agency
References
NUDOCS 8108260039
Download: ML20030C375 (1)

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O p' f'hfb4 August 21, 1981

' 3 nUG 25 Iggg Spence W. Perry, Esq.

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Acting Assistant General Counsel

\\e Federal Energency !!anagenent Agency

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500 C Street, S.U.

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4 Uashington, D.C.

20472 In the !btter of SOUTHERfl CALIFOR!1lA EDISOf! C0!!PANY, ET AL.

(San Cnofre fluclear Generating Station Units 2 and 3)

Decket Nos. 50-361 OL and 50-362 OL Cear Mr. Perry:

Enclosed for your information is a copy of the "!CC STAFF TESTIMGi!Y Off CUARD CONTEllTI0l;S 1, 2.E. 2.I, 2.J AND 2.K C0flCEf flIfl0 Ef ERGENCY PREPAPEDflESS FOR THE SAN Of!OFRE NUCLEAR GEfiERATING STATI0ll, UllITS 2 Af!D 3" which was filed on August 21, 1981.

Sheuld you have any questions, please do not hesitate to contact re.

Sincerely, Donald F. Hassell Counsel for ftRC Staff

Enclosure:

As stated DISTRIBUTI0ft:

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Shapar/Engelhardt Christenbury/Scinto Rutberg Chandler Vogler Hoefling Hassell

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OFFIClAL RECORD COPY usom mi-asseo NRC FORM 318 (10-80) NROM C24o

1 August 21, 1981 UNITED STATES OF AMERICA NUCLEAR REGULAT0'lY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of SOUTHERN CALIFORNIA EDISON Docket Nos. 50-361 OL COMPANY, ET &.

50-362 OL (San Onofre Nuclear Generating 5tation, Units 2 and 3)

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NRL, STAFF TESTIMONY ON GUARD CONTENTIONS 1, 2.E, 2.I, 2.J AND 2.K CONCERNING EMERGENCY PREPAREDNESS FOR THE SAN ONOFRE NUCLEAR GENEPATING STATION, UNITS 2 Af;D 3 In accordance with 10 C.F.R. 6 2.743(b), the Atomic Safety and Licensing Board's Order on the record of July 10, 1981, and the stipulation of the parties, the NRC Staff hereby submits its direct

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testimony on GUARD's emergency planning contentions 1, 2.E, 2.I, 2.J.

and 2.K.

Res ctf lly submitted e

I Richard K. Hoef ing y

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jDonald F. Hassell Counsel for NRC Staff Dated at Bethesda, Maryland, this 21st day of August,1981.

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UNITED STATES OF AMERICA NUCL, EAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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500 H RN CALIFORNIA EDIS0N COMPANY,)

Docket Nos. 50-361 OL

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50-363 OL

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

TESTIMONY OF JOHN R. SEARS OF THE NRC STAFF CN GUARD CONTENTIONS 1, 2.E, 2.1, 2.J, AND 2.K RELATED TO EMERGENCY PREPAREDNESS FOR THE SAN ON0FRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 AUGUST 20, 1981 e

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Q.1 State you, name and title?

A.

John R. Scars.

I am a Senior Reactor Safety Engineer in the Emergency Preparedness Licensing Branch, Division of Emergency Preparedecss, Office of Inspection and Enforcement, U. S. Nuclear Regulatory Commission.

Q2 Do you have a statement of professional qualifications?

A.

Yes. A copy of my statement of professional qualifications is attached to this testimony.

Q,3 What is the purpose of this testimony?

A.

The purpoe.e of this testimony is to address Contentions 1 and 2.E.

2.I, 2.J, and 2.K raised by Intervenors GUARD in this operating license proceeding each of which is related to the emergency pre-paredness of the San Onofre Nuclear Generating Station, Units 2 and 3 (SONGS 2 and 3). My testimony will examine the state of the Applicants' emergency preparedness as it affects these GUARD's i

Contentions.

Q.4 GUARD Contention 1 states:

Whether the state of emergent / preparedness for SONGS 2 and 3 pro-vides reasonable assurance that the offsite transient and permanent population within the plume exposure pathway Emergency Planning Zone, 10 C.F.R. 1 50.47(c)(2), for SONGS 2 and 3 can be evacuated or othcr-wise 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. 1 50.47(a)(1), 5 50.47(b)(10), and Part 50, Appendix E.IV.

With respect to Contention 1, why are time estimates for evacuation and for taking other protective actions required to be submitted by the Applicants pursuant to Part 50, Appendix E.IV?

A.

Time estimates for evacuation and for taking other protective actions are used by the NRC staff for two principal purposes:

(1) 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; (2) to provide to decisionmakers during an emergency, knowledge of the length of time required to effect evacuation under various conditions. This knowledge allows an informal choice of protective actions (e.g., between in-place sheltering and evacuation) during any actual accident si' ation.

Q.5 With respect to the time estimates which are required to be submitted by the Applicants pursuant to Part 50, Appendix E.IV, what criteria must those time estimates meet?

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A-The time estimates for evacuation and for taking other protective actions are considered acceptable if the criteria of NUREG-0654, FEMA REP-i, Kev.1, " Criteria for Preparation and' Evaluation of Radiological

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Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," specifically II.J and Appendix 4 of NUREG-0654, are met.

Q.6 Have the Applicants in this proceeding submitted time estimates for SONGS 2 and 3 facility?

A, Yes, the Applicants submitted an analysis of time estimates for evacuation of the 10 mile plume exposure Emergency Planning Zone and beyond to include the communities of San Juan Capistrano, Dana Point and Ortega. This analysis is contained in Appendix E to the Applicants' Emergency Plan. The other protective action that may be taken is shelter and the time necessary to take shelter is p.-incipally a function of the time for notification. The Applicants are installing a siren system for early alerting of the public and have ongoing public educational program both of which have been de-i an scribed in my testimony dated August 6, 1981 responding to GUARD Contentions 2.B and 2.C.

Q.7 Hr.e these time estimates been examined for conformance with the criteria you have identified in your response to Question 5 above?

A.

Yes.

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Q.8 Who performed that examination and how was it conducted?

A.

The examination was performed by a contractor, the Texas Transpor-tation Institute of the Texas A & M University System. The evaluation technique is described in NUREG/CR-1856, An Analysis of Evacuation Time Estimates Around 52 Nuclear Power Plants and NUREG/CR-1745, Analysis of Techniques for Estimating Evacuation Times for Emergency Planning Zones. The evaluation used a subjective scale requiring professional engineering judgment in determining ratings. The process then indicates areas which the reviewer considers the plan to be strong or weak. The results of the review are then presented in a table (See Table Below).

Table 1:

Evacuation Criteria Item Excel.

Adeg.

Poor None

Background

A.

Area Map B.

Assumptions C.

Methodology Demand Estimation A.

Permanent Population B.

Transient Population C.

Special Population D.

Time of Day / Week Traffic Routing A.

Map of Network B.

Capacity by Segment Analysis A.

Components Considered B.

Adverse Condition Considered Overall g,

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6-s Q.9 Ocscribe the results of that evaluati0n?

A.

The contractor's evaluation stated that.the Applicants' report (Appendix E to the Applicants' Emergency Plan) is excellent with one exception in that inadequate consideration was given to ad-verse >!eather conditions and its effect on highway capacity. The Applicants' estimates had resulted in very little difference in time between fair weather conditions and adverse weather condi-tions. The NRC contractor's concept of adverse weather envisions a more severe environment than I conclude is necessary to fulfill the criteria of NUREG-0654.

Q.10 In your opinion, do the Applicants' time estimates meet the criteria which you have identified in your response to Question 5 above?

A.

Yes, Appendix 4 of NUREG-0654 includes a complete outline of the material to be covered in the evacuation times assessment study.

The NRC contractor's ev?luation described in answer to question 8 covers all of the elements in Appendix 4.

I have reviewed the Applicants' study and the NRC contractor's evaluation and I have verified that the Applicants' study satisfactorily covers all the elements in Appendix 4.

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With respect to Contention 1, have you evaluated the capability l

Q.11 to initiate evacuation or other protective measures for offsite l

permanent and tratisient population within the plume exposure j

pathway EPZ?

Yes, I have examined the capability of the Applicants to evaluate A.

the need for and to make recommendations to offsite response agencies with respect to evacuation or other protective measures.

Such capability is required by planning standard 10 C.F.R.

The. criteria of NUREG-0654, specifically II.J.,

5 50.47(b)(10).

provide guidance in this area.

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l Q.12 Have the Applicants' emergency plans been examined for conformance with the guidance of NUREG-0654 II.J7 A.

Yes, I have examined the Applicants' emergency plans with respect to this guidance and I will now summarize my findings.

The methodology and techniques for assessment of each of the <nur classes of emergency, Notification of Unusual Event, Alert, Site Area Emergency and General Emergency are described in Section 6 of the Applicants' Emergency Plan. The Applicants' Emergency Implementing Procedure 1.1, Recognition and Classification of Emergencies, snecifies measurable and observable indications in the plant instrumentation readings, which are the initiating condi-tions for declaring a particular emergency. The procedure instructs the Emergency Coordinator, who initially is the plant Watch Engineer, to make notification to offsite authorities in conformance with Emergency Implementation Procedure 1.4, Notification. The Notification procedure states that notification shall be made to all offsite authorities by the on duty shift personnel immediately following the declaration of the emergency. The Notification procedure includes message forms, with the recommended protective action, for each type of emergency. Emergency Implementation Procedure 1.24, Recommendations for Offsite Protective Measures, j

provides specific guidance to the Emergency Coordinator for the recommending of offsite protective actions to local emergency response authorities. This procedure states that the applicant is N

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required to make recommendations for protective actions as part of the initial notification process if the nature and magnitude of the actual or potential radioactivity release warrants pro-tective actions for the general public.

State whether the Applicants' procedures conform to the gu' ance Q.13 contained in NUREG-0654 II.J and provide us with your judgment as to whether or not the Applicants meet planning standard 10 C.F.R. 150.47(b)(10).

A.

The Applicants' Emergency Implementation Procedures demonstrate his capability to evaluate the need for and make recommendations to offsite response agencies with respect to evacuation or other protective measures. The procedures satisfy the criteria of NUREG-0654, II.J which are the implementation criteria for 10 C.F.R. 50.47(b)(10).

Q.14 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 5

population, will comply with 10 C.F.R. Sections 50.47(a)(1) and (b) or (c)(1) as regards:

E.

necessary transportation and communication equipment, and the operation of the emergency operations centers of the principal response organizations, 10 C.F.R. Sections 50.47(b)(8);

n t.1e physical design, communications equipment, and I.

operating procedures for the interim Emergency)Oper-and ations Facility, 10 C.F.R. Sections SU.47(b)(3 (b)(8);

the methods, systems, and equipment for assessing J.

and monitoring actual or potential offsite con-sequences of a radiological emergency condition within the ingestion pathway EPZ for SONGS 2 and 3, 10 C.F.R. Section 50.47(b)(9); and general plans for recovery and reentry, 10 C.F.R.

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t 50.47(b)(13).

With respect to Contention 2.E, have you examined the Applicants' Q.14 provisions to provide transportation and communications equipment during an emergency and to establish emergency operations centers?

Yes, the Applicants' procedure 1.26 entitled " Communications" describes A.

the communications systems that are available for emergency use, their location and their functions. Section G of the Applicants' Emergency Plan states that,in the event that normal access to SONGS should he-restricted, emergency personnel and equipment can be transported come to the Station via helicopter. The Applicants maintain a fleet of aircraft which includes five helicoptors, one twin engine, fixed The fleet is wing aircraft capable of carrying six passengers.

based at the Chino Airport. Provisions have been made for the dedicated use of two helicopters for the transport of emergency personnel and equipment to SONGS; however, the Applicants state that all of the aircraft could be dedicated to SONGS if necessary.

In additi'on, the Applicants own and operate an extensive fleet of

ground transportation vehicles consisting of heavy-duty trucks, equipment and four-wheel drive vehicles which would be available to SONGS as needed.

Section 7 of the Applicants' Emergency Plan describes the Applicants' emergency facilities, the Station Control Room, the Technical Support C mter, and the Operations Support Center. Section 7 also describes the interim arrangements for the Emergency Operations Facility, which will include an onsite Emergency Support Center staffed by Corporate Emergency Support personnel, and a Priraary Emergency Operations Center (PE0C). The PE0C is located in the City of San Clemente City Hall and is for the use af Southern California Edison (SCE), Federal, State and

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local authorities. The Applicants' Emergency Implementation Procedure 1.3 entitled " Activation and Operation of SCE Emergency Centers and Organiza-tions" provides instructions for the activation, operation and organiza-tion of the Operatioas Support Center, Technical Support Center and the Emergency Support Center. The Emergency Operations Centers of local offsite authorities are described in their individual Emergency Response Plans which the Applicants have submitted to the NRC Staff.

Q.15 Do the Applicants' provisions for Emergency Operation Centers and their commitment to transportation and communications equipment described in your response to Question 14 above, meet planning standard 10 C.F.R. ! 50.47(b)(8)?

. Yes, the -Applicants' provisions for emergency operation ccnters A.

and their commitecnt of transportation and communications equip-ment satisfy the criteria of tiUREG-0654, II.F and H which are the implementation criteria for 10 C.F.R. I 50.47(b)(8).

The implementation of the capability for necessary transportation and communications equipment and the operation of the Applicants' emergency operations centers was demonstrated during the full scale exercise involving the Applicants and offsite organizations on to the extent the procedures and systems employed May 13, 1981, during the Unit 1 exercise were similar to those in pisce for These procedures and systems proved to oe workable Units 2 and 3.

and effective.

With respect to Contention 2.I, have you examined the physical design, Q.16 communications equipment and operating procedures for the interim Emergency Operations Facility (E0F)?

Yes, I was the t!RC observer at the Applicants' onsite Emergency A.

Support Center during the May 13, 1981 exercise and at that time I also visited the Primary Emergency Operations Center at San Clemente.

Do the physical design, comunications equipment and operating pro-Q.17 cedures f.or the interim E0F described in your response to Question 16 above meet planning standards 10 C.F.R. 5 50.47(b)(3) and (b)(8)?

2

. A.

The criteria for the interim E0F are contained in NRC letters to all Applicants dated September 27, 1979 and November 9, 1979.

(These letters are attached to the Applicants' Emergency Plan).

The Applicants' provisions for the interim E0F satisfy these criteria and meet the planning standards of 10 C.F.R. 1 50.47(b)(3) and (b)(8).

The criteria for the permanent E0F are contained in NUREG-0654,II.H, with specific guidance for implementation in NUREG-0696, Functional Criteria for Emergency Response Facilities. The Applicants have submitted detailed descriptions of their permanent Emergency Opera-The tions Facility in the July 1, 1981 letter to the NRC Staff.

permanent Emergencv noerations Facility will be located at Japanese Mesa across Highway I-5 ano approximately 1 kilometer from the plant.

It will conform to the guidance in NUREG-0696 and will be operational by October 1, 1982.

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

l Yes, in addition to the provisions that I have described in my A.

testimony dated August 6, 1981 responding to GUARD Contention 2.H.

the Applicants' Emergency Implementation Procedures 1.34, Emergency l

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Environmental Monitoring, provides instructions for the collection of environmental samples in the event of a release of radioactive material to the environment during an emergency. The instructions include the kinds of samples, the need for clear identification of The the samples, and an admonition against cross-contamination.

Technical Support Center has been designated by the Applicants as Federal the place for receipt and analysis of field monitoring data.

Agencies will coordinate their Emergency Radiological Monitoring and Assessment activities through the Federal Radiological Monitoring Assessment Plan (FRMAP). The Applicants will have space available in the Emergency Operations Facility for a liaison from FRMAP.

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. 1 50.47(b)(9)?

i Yes, the provisions for assessing and monitoring for the ingestion i

A.

pathway EPZ satisfy the criteria of NUREG-0654, II.H and I which are the implementation criteria for 10 C.F.R. 5 50.47(b)(9).

l With respect to Contention 2.K, have you examined the general plans Q.20 developed by the Applicants for recovery and reentry?

Yes, Section 9 of the Applicants' Emergency Plan describes general A.

plans for recovery and reentry. Criteria have been established

for declaring that the emergency is under control and in the recovery phase. The Energency Coordinator is responsible for notification to all offsite authorities that the emergency has shifted to a recovery phase. Planned radiation exposure limits for urgcnt re-entry shall be in accordance with National Council on Radiation Protection (NCRP) criteria and, in any lesser situa-tion, the criteria of 10 C.F.R. Part 20 apply. Analyses will be performed to estimate population exposure from all applicable t

exposure pathways. The general structure of a long-term recovery organization is described in the Emergency Plan.

Q.21 Do the plans for recovery and re-entry described in your re:ponse to Question 20 above meet planning standard 10 C.F.R. Section 50.47(b)(13)?

Yes, the Applicants' plans for recovery and re-entry satisfy the A.

criteria of NUREG-0654, II.M which are the implementation criteria l

for 10 C.F.R. I 50.47(b)(13).

i What is your assessment of the Applicants' capability to implement Q.22 the procedures and activities which you have described in this i

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I testimony?

i I have reviewed the implementing procedures and, in my judgment, they i-A.

provide adequate and clear direction to the person called upon to l

, implement them. The Applicants have an ongoing training program which I have examined and found acceptable. This training program prcvidc :::ur:nce thct the procedures will be followed. Additional confirmation of tile Applicants' ability to implement the emergency preparedness program is provided through the Office of Inspection and Enforcement's Emergency Preparedness Appraisal Program (EPAP) l which is an onsite inspection and verification process, and the l

conduct by the Applicants of an onsite exercise, both of which are scheduled far before the time expected for issuance of the operating license for San Onofre 2 and 3.

JOHN R. SEARS _

RESUME'_

Prior to 1952 I was employed in field jobs in various aspects of mechanical In 1952. I joined Brookhaven National Laboratory as a Reactor Shift engineering.

While at Brookhaven, I completed Supervisor on '.he Brookhaven Graphite Reactor.

a series of cot.rses given by the Nuclear Engineering Departmer.t in nuclear engineering.

In 1956. I was 6p,nointed These courses were patterned on the ORSORT programs.

I was a member of Project Engineer on the Brookhaven Medical Research Reactor.

the design group, participated in critical design experiments, wrote specifications, coauthored the hazards report, was re,sponsible for field inspection and contractor About three liaison, trained operators and loaded and started up the reactor.

month's after start-up, in 1959, following the successful completion of proof tests 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 In 1960. I transferred, Division of Inspection, U. S. Atomic Energy Commission.

I was responsible as a reactor inpsector, to the newly-formed Division of Compliance.

for the inspection, for safety and' compliance with license requirements, of the licensed reactors and the fuel fabrication and fuel processing plants. which i

use more than critical amounts of special nuclear material, in the Eastern United States.

In September 1968, I transferred to the Operational Safety Branch, Directorate of My responsibility included development of appropriate guides for evaluation Licensing.

of operational aspect of license applications and staff assistance in review of power reactor applicants submittals in the areas of Organization and Management.

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

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The Branch was reorganized as the Industrial Security and Emergency Planning Branch in April 1974 to place increased emphasis 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,0CPA,1976,1977 - Course in Emergency Planning Director,1962 - Reactor Program, Atoms for Peace Exhibit Bangkok, Thailand Dir~ector,1966 - Atoms for Pcace Exhibit, Utrecht, Holland G

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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SOUTHERN CALIFORNIA EDISON COMPANY,

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Docket Nos. 50-351 OL

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50-362 OL ET AL.

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(San Onofre Nuclear Generating Station, )

Units 2 and 3)

)

CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF TESTIMONY ON GUARD CONTENTIONS 1, 2.E 2.I. 2.J ANO 2.K CONCERNING EMERGENCY PREPAREDNESS FOR THE SAN O NUCLEAR GENERATING STATION, UNITS 2 AND 3" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class or as indicated by an asterisk, by deposit in the Nuclear Regulatory Commission internal nail systen, this 21st day of August,1981:

• 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.

Of Orrick, Herrington & Sutcliffe Washington, D.C.

20535 A Professional Corporation

)

Dr. Cadet H. Hand, Jr.,

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

Daniel K. Spradlin P. O. Box 247 Bodega Bay, California 94923 Rourke & Woodruff 10555 North Main Street Suite 1020 Mrs. Elizabeth B. Johnson, Santa Ana, California 92701 Administrative Judge Oak Ridge National Laboratory Richard J. Wharton, Esq.

P. O. Box X, Building 3500 University of San Diego School Oak Ridge, Tennessee 37830 of Law Alcala Park San Diego, California 92110 Janice E. Kerr, Esq.

J. Calvin Simpson, Esq.

Lawrence Q. Garcia, Esq.

Mrs. Lyn Harris Hicks California Public Utilities Commission GUARD l

3908 Calle Ariana 5066 State Building San Clemente, California 92672 San Francisco, California 94102

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. A. S. Carstens Charles R. Kocher, Esq.

2071 Caminito Circulo Norte James A. Reoletto, Esq.

Mt. La Jolla, California 92037 Southern California Edison Company 2244 Walnut Grove Avenue

• Atomic Safety and Licensing Board Rosemead California 91770 Panel U.S. Nuclear Regulatory Commission David W. Gilman Washington, D.C.

20555 Robert G. Lacy San Diego Gas & Electric Company

• Atomic Safety and Licensing Appeal P. O. Box 1831 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 Ana'.af m, California 92701 U.S. Nuclear Regulatory Commission ATTN: Chief, Docketing & Service Charles E. McClung, Jr., Esq.

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

20555 23521 Paseo De Valencia Suite 308A Laguna Hills, California 92653 7i

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190 L/74L )7 Donald F. Hassell Counsel for NRC Staff l

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