ML20030C409
| ML20030C409 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 08/24/1981 |
| From: | Nauman K Federal Emergency Management Agency |
| To: | |
| Shared Package | |
| ML20030C400 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8108260078 | |
| Download: ML20030C409 (18) | |
Text
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UNITED STATES OF MfERICA NUCLE.'.R REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of
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Docket No.s 50-361 OL SOUTHERN CALIFORNIA EDISON COMPANY, )
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(San Onofre Nuclear Generating Station, Units 2 and 3)
TESTIMONY OF FEMA'S KENNETH W. NAUMAN, JR.,
l ON GUARD CONTENTIONS 1 AND 2 RELATED TO EMERGENCY PREPAREDNESS FOR THE SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 and 3 _
AUGUST 24,1981 l
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Current workload and timing constraints prohibit an NOTE:- elaborate description of details relating to some seven plans relating to San Onofre.
In light of
'the detailed citation of current findings in the informal plan review and the exercise evaluation, I find it appropriate to make reference to those documents for response to these contentions.
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Q.1 State your name and title:
Federal Kenneth W. Nauman, Jr., Emergency Management Specialist, A.
. Emergency Management Agency, Region IX.
Do you have a statement of professional qualifications?
Q.2 A copy of my statement of professional qualificationsis A.
Yes.
attached to this testimony.
What is the purpose of this testimony?
Q.3 9
The purpose of this testimony is to address Contentions 1 and 2 A.
raised by Intervenors GUARD in this operating licensing proceeding each of which' is related to the emergency preparedness of the San Onofre Nuclear Generating Station, Units 2 and 3 (SONGS 2 and 3).
i My testimony will examine the state of off-site emergency preparedness as it affects GUARD's contentions, Q.4 CUARD Contention 1 states:
i 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. & 50.47(c)(2), for SONGS 2 and 3 can be evacuated or otherwise protected in the event of a radiological emergency with offsite consequences occurring at SONGS 2 and 3, as required by 10 C.F.R.
& 50.47(a)(1), (b) (10), and Part 50, Appendix E.IV.
With respect to the portion of Contention 1 dealing with
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l' evacuation time eatterates, i.e., Part 50, Appendi:< E,IV, to
- what extent are evacuation time estintates con.sidered by you in. ;our w/aluation of of fe. ice emergency preparedaeas for SOMCS 2 2:".1_8?
The ovheustion titta estimates weec reviewed in accordance A.
with NUREG 0634/ FEMA REP-1 to thu tr.<tont that they were indicated in the emergency planning and that emergency direction and control personnel considered thent in their protective actiers recommendations, 14at criteria did you apply in your evaluation?
Q5 The eriteria applied were those reflected in UUREG 0654/
A.
FZtfA REP-1, Rev, 1, Part 3, Protective Response.
Descrs'e the results of that s'/aluation?
Q.6 o
The assessraent reflected the. jurisdictions have canaidered A.
the evacuation time owtimates developed in the SONGS study by it, Smith and Asscelates and reflected an intention to give con:1deratien of time estimates it) dealing with protective respouse in an energency situation.
In your opinion, do the evacuattoa time estimates which Q,7 you have evaluated =aet the criteria which you have 5 above?
identified in your response to questiert I
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The evacuation time estimates meet the criteria.
A.
Yes.
With respect to the portion of Contention 1 dealing with Q.8 evacuation or taking other protective measures for offsite permanent and transient population within the plume exposure pathway EPZ, have you evaluated this area for SONGS 2 and 3?
Yes, I have examined the capability of offsite organization to A.
evacuate or take other protective measures for the offsite permanent and transient population within the plume exposure Such capability is required by planning standard pathway EPZ.
10 C.F.R. & 50.47 (b)(10). In my evaluation, I applied the criteria of NUREG 0654/ FEMA REP-1, " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," II.J.
Which organizations in the vicinity of SONGS 2 and 3 have you Q.9 evaluated for conformance with the guidance of NUREG 0654?
I have evaluated the plans of the local jurisdictions within the A.
plume exposure pathwa:r Emergency Planning Zone (EPZ) and the plans of the State of California for conformance with the The local jurisdictions include Orange guidance of NUREC 0654.
County, the City of San Clemente, the City of County, San Diego San Juan Capistrano, State Parks and Recreation and Camp 3
r Pendleton.
What were your findings with respect to each of the juris-Q.10 dictions which you have identified in response to Question 9 d
.above with regard to each of the guidance elements containe in NURw 0654, II.J7 With respect to each of the jurisdictions related to SONGS 2 A.
and 3, the findings are reflected in the plan review and exer-cise evaluation findings produced by FEMA Region IX (Informal Plan Review letter to Alex Cunningham, State of California 27, 1981; and, Office of Emergency Services, dated April Evaluation Findings, San Onofre NGS, Offsite Emergency 13, 1981). They identified Response Plans Exercise, May additional work was needed to meet all of the NUREG 0654 criteria.
- cize the status of offsite jurisdictions' conformance Q.ll S
d to the guidance contained in NUREG 0654, II.J and provi e us with your judgement as to whether or not the offsite jurisdic-
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tien mcct planning standard 10 C.F.R. & S0.47(b)(10.
The status of offsite jurisdiction planning as it relates to A.
conformance to NUREG 0654 is reflected in the plan review Generally, the addressed in the answer to Question 10 above.
jurisdictions demonstrate an ability to respond to general h disaster conditions, but need additional training in the
It is my opinion that the radiological response areas.
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tandard 10 C.F.R.,
. jurisdictions have met the p ann ng s
" ara. 50.47(b)(10) except to the extent that further develop-ment of protective action procedures for ingestion pathway EPZ has to be completed.
GUARD Contention 2 states:
t, the emergency Whether there is reasonable assurance that response planning and capability of implementation for SONGS 2 and 3, effecting the offsite transient and per-manent population, will comply with 10 C.F.R., Section 50.47(a)(1) and (b) or (c)(1) as regards:
the procedures for notification by Applicants of State and local response organizations, 10 C.F.R.
A.
Section 50.47(b)(5), and for notification of and continued communication among emergency personnel by all involved organizations, 10 C.F.R. Section 50.47 (b) (6) ;
the means for notification and instruction to the populace within the plume exposure. pathway Emergency B.
Planning Zone,10 C.F.R. Section 50.47(h)(5);
the information and the procedures for dissemina-tion of information to the public within the plume C.
exposure pathway Emergency Planning Zone on a periodic basis on how they will be notified and what their initial action should be in the event of an emergency,10 C.F.R. Section 50.47 (b)(7);
i the arrangements for medical services for contaminated and injured individuals,10 C.F.R. Section 50.47(b)
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(12);
necessary transportation and communication equipment, and the operation of the emergency operations centers E.
of t'te principal response organizations, 10 C.F.R.
Section 50.47(b)(8);
the capability of each principal response organization to respond and to augment this initial response on a F.
continuous basis,10 C.F.R. Section 30.47(b)(1);
C.
radiological cr:crgency response training to those who u.sy be called on to assist in an coergency, 10 C.F.R. Section 50.47(b)(15);
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the cctheds, staffing, systems, and equipment for B.
assessing and monitoring actual or potential off-site consequences of a radiological energency condition within the plume exposure pathway EPZ for Soe4GS 2 and 3,10 C.F.R. Section 50.47(b)(9);
the physical design, cors!sunications equipment, and I.
oporating procedures for the interia Faergency Operations Facility,10 C.F.R. Section 50.47(b)(3) and (b)(8);
the saethods, systems, and equipment for assessing J.
and mnitoring actual or potential offsite conse-quences 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 reentry and recovery plans and K.
procedures,10 C.F.R. Section 50.47(b)(13).
To the extent that the standards of NUREG 0654/ FEMA REP-1, Rev.1, A.
have been applied to the review of emergency response planning and capability of implementation regarding SONGS 2 and 3, and assuming the contention asks if there is a reasonable assurance that the items A-K (less J) will be o have been addrep ed in p1Anning, the ansvar is in the affimative.
(This assumes reentry and recovery planning vill ba accomplished.)
2nd Part of With respect to Contention 2. A. have you a==ined the procedures Q.12 of offsite response organizations for notification of and Y
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coatinued couranication among emergency personac1 by all involved response organizations?
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2nd Parc of Yes, the procedures of of fsite response organizatiops for A.12 notification and courunication regarding emergency personnel 1
were exaatned in accordance with NUREG 0654/FDfA REP-1, Rev.
standards II.E and II.F.
With respect to Contention 2. A, do the procedures for notifica-Q.13 tion of and continued cotscunication among emergency personnel which you have described in response to Question 12 above meet planning standard 10 C.F.R. Section 50.47(b)(6)?
Additionally, siren systems are being installed at this A.
Yes.
Plans time and are forecast to be in place before licensing.
i and procedures currently exist for notification and comunicat on.
With respect to Contention 2.B, have you emained the means Q.14 established by offs...te response organizations for notification and instruction to the populace within the plume exposure pathway EPZ?
Tes, the standards of NUREG 0654/ FEMA REP-1, Rev. 1, Part II.E.
L These means include, establish govermentr?
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elecommunications systems, government vehicles, media, sirens, 7
and Emergency Broadcast System equipme't.
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_g-Q.15 With respect to Contention 2.B do the r. cans which you have described in response to question 14 above for notifiention and instruction to the populace within the p1tene exposure
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' pathway EPZ met pLinning standard 10 C.P.R. Shetion 50.47(b)(5)?
A.
Yes, to tbn ovant that they have been addressed in planning and were critiqued by the infonaal plan review docunent referred to in the answer to Question 10.
When sirens are installed and tested and plans and SOP's finalized / updated, they should meet the standard.
Future evaluation of the demonstrated imple-mentation will validate the capability to meet the standard from an implemntation standpoint.
Q.16 With renpact to Contention 2.C have you examined procedures established by offsite response organir.ations for disstuninrtion of infomtion 10 the public within the plume exposure pathway En ou a periodic basic as to how the public will be notified and what its initial action should be in the event of an emergency?
A.
Yeq.
wupy: Of 34/FIwa. PIP-1, Rev.1, planning standard II.E was applied to the plaus. Procedures are identified that the utility will provide luformational disseminaticas through mailings on a periodic basis. Additional coverage through matels, recreation areas, and other transient locations is planned.
Q.17
'yith respect to contention 2.c. do the procedures which you have edescribed in response to Question 16 above, meet planning standard 10 C.F.R. Section 50.47(b)(7)?
N A.
Yes. Jurindictions b va included proceduros to the extent idaatified in the infomal plan revic> cited in Question 10.
Q.18 With respect to Conteation 2.D, have you examined the arrange--
e$t's made by offsite response orgarizations for medical servicas for contaninated and injured individualst Yes. NUREG-0654/ FEMA REP-1, Rev.1. Standard L was applied to the A.
Some local hospitah have been identified and have received plans.
for he.ndling patients cubject to radiation contamination.
some training Q.19 Do the arrangements for pedical services made by offsite response organizations for contaminated and injured. individuals described in response to Question 18 above meet planning standard 10 C.F.R.
Section 50.47(b)(11).
A.
To a limited extent, yes. Some specific actions were cited as not observed in the informal plan review. Reference the citation of informal plan review in the response to Question 10.
Q.20 With respect to Contention 2.E, have you examined provisions of the principal offsite response organir.ations to provide trans-portation and cozuunications equipment during an emergency and to establish emargency operations centers.
A.
Yes. Provisions of NUREG 0654/ FEMA REP-1, Rev.1, Standards II.C, E, F. B, J, and L were applied to the plans reviewed. Emergency Operating Centers and the transportation and cor=ranications assets of the two counties and two cities, the U.S. Marine Corps, and the Stat and Federal organizations are available to support an energency.
. Tio the weargeacy operation centera established by the prtucipal Q.tl.
of fstte responsa oigsntestions cod t. heir comitmant of t'r6nsporta-tion c r'corcunicot Lons equipmenF_ described in your response to Question 20 obove avet plannLng stcadard 10 C.F.It. Section 50.47(b)(S)?
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Yes, Orange and San Diego. counties have established and operational E0C's A.
with required emergency response plan and equipment to respond to transpo and communications most likely to occur.
ifith recpect to Contention 2.P, have you examLued the capahtitty of Q.21 the principal ot telee ver.ponee organtsstions. to re.spond to an eser-guncy cnd to Augment cny initL2.1 retponsa on a continuous b8818?
Provisions of (fuREG 0654/FDS REP 4, llev.,1, etendards A cod A.
Yes.
C vare appliel to the pisne reviewed. The capability to respond was demonecrated through past demonstrcted. disaster response and through picnning ortsnted t o principles of nutual aid and redundant staf fins.
Does the capabi)ity ot cach princLpal otf aite response organicatLon Q.21 to respond tu on emergency sud t.o augment this initLal response on a continuous bastu described in your response t.o QuestLon 22 above invet pisnning secadard 1,0 c.r.n., Section f.0.47(b)(1)?
A.
Yes. 'the baste plannin,q of the jurisdictions, coupled with the State nad locci nutual aLd ugeeements, and Federal eupport through the PZltA iOrganization provide the necessery r acponse capabil-Ity.
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Witis respect to Contention 2.0, have you saamined radiological Q.24 emergency response training that has baun provided to offsite response personnet who may be called on to assist in an emergency?
Training ha. been reviewed under NUREG-o654/ FEMA Rep-1, Rev.1 Yes.
Training A.
standard 0 and said standard applies to response plans.
Addf-provided to response personnel has t een limited.
Local.juria-tional trairing has been identified av being needed'.
dictions have teams identified who have had traiulug given by the State auch as the RDO, RDIM, and PM Courses and associated Medical radiological courses courses, provided by county of fices.
Addicional training is felt necessary were presented by the uti.licy, to iciprove profic.tency and expand on the specific techniqueu of power plant f teld monitorin2, and ingestion pathway sampling, as well vistua of basic 14dlistlon cun.teptu training to all parti-as the Training plans and nrocedures are being developed at this cipants.
ticle se a result of the exerciae v!aluation flud.ings, Doea the radioingimil emergency response training of of f aite Q.25 peraunnel whf ch you have deuccibed in y;ur response to Qucstion 24 Aove r.; eat plar,ning standard 10 C.F.R., Section 50.47(b')(13)7 Reference informal plan review and exercise A.
To sote cegree.
Addi-euskuution findtugs documents cited in Question 10 stove.
tiot 1 training is recocenended.
l With respect to Contention 2.K, Itave you examined the methods, Q.26 staffing, systeus and equipment availabio to the offatte reponau for.ma<<ing and rnonitoring actual or potential o rge.n.t s.= t i nn <
of fsite conaequences of a radiological emergency condition withirt the pl.ne exposure pathway UPZ for SONGS 1 and 27 NUREG 0654/FElfA B2P-1, Rev,1, standard I was applied to A,
- Yea, plana reviewed.
Syatem and equipment exists in limited quantitles, while staffing haa been designed to meet plan requirements, Muthcds for assesntent and rionitoring arc being expanded through S07's.
Do the methods, stofflug, systems and equipment available to the Q 27 offsite response organhacions for assessing and monitortug actual or pctential offaite consequences of a radiological emeegency condition, described in your response to questica 26 above, meet plannius standard 10 C.F.R., Section 50,4T(b)(9)?
A, Generally speak. tug, yes. Some equipment is prencatly not on hand which unuld enhance the response capability of the local jurisdic-Sot"s sie being developed to address procedtrees.for tions.
Staffing from local, State and Federal organizations
- reaponse, is being refined and training la being developed to improve the Reference intnrmal plan review and e:<ercise resp,ense capability.
evahuation cited in question 10 above.
Q.23 141,th respect to Contention 2.I, have youexamined the physical stestEn, coumunteations equipment and operating procedure for interiti Secrgency Operations Pac 111ty (E07)?
The facilities of the interim E07,Were e;<amined relative to A.
N0aEC 0634/FDfA REP-l., Rev, 1.
The pertuanent of faite 80F has not been established at this time. An inter.im facility at the The San Clemente City EOF is currently being used for the EOF.
design, equipment and procedures are belug reviewed and updated as result of an exercise; sa of Huy 13. They reflected a shortfall a
from parceived requitecents.
Q.29 Do the physical design, commen'. cations equipment and operating peacedures for the interim EOF described.in your responde to Question 28 above meet planning standards 10 C.F.R. Sections 50.47 (b)(3) and (b)('d)?
The design, cormunications equipment, and operating procedures A.
for the interim EOF i4*re reviewed in the exercise on Nby 13, 1981.
The findings resulting from that e.<ercise evaluation identify the curreut state of operationa and suggested corrective actions, Reference the exercise evaluation findings cited in Question 10 At this time, there is addiclunal work being accomplished above.
Upon completion of regdvding facilities, equipment and proceducee.
thee'e actions, a demonstration should be conducted to allow for verification of facilities and capabilities.
. Gith reapect to Contention 2.;f, htne you exatained the methods, q.30 staf fing, systens and equipment available to offaite response o.ou iup, and monitoring actual or potentisi orgattiaatiotis fot offsite consequences of a redfological emergency condition within the ingestion pathway EPZ for SONGS 2 and 3?
Yes, to the extent that they are covered by NOREG 0654/ FEMA RIT-1, A,
"fhere has been no tugestion Rev.1 stunderds II.C.3, 4 and J-11.
pathway response capability de:scostrated.
Do the metheds, staf.fing, eyotees and equipment available to 0.31 offuite response organisstions for assessing arid monitoring actual ot potential of fsite consequences of a radiological ettergency condition described in your response to Question 30 above meet 4
planniud standard 10 C.F.R. Section 50.47(b)(9)7 As yet tho aaethods, acaf finy, and systems er.:1 equipment relating A.
to intestion pathway responsa have not been ciently identified or Thu St.ite of California haa e draf t proposal for decenct:2ted.
ingestion pathway response and haa indluated a draft plan will be submitted in the nest two to three months.
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FEDERAL EMERGENCY MANAGEMENT AGENCY Region IX 211 Main Street, Room 220 San Francisco, CA 94105 PROFESSIONAL QUALIFICATIONS KCNNETH W. NAUMAN, JR.
Emergency Management Specialist Plans and Preparedness Division Federal Emergency Management Agency Region IX, San Francisco, California i am an Emergency Management Specialist in the Plans and Preparedness Division of the Federal Emergency Management Agency, Region IX, San Francisco, California, and a Radiological Emergency Preparedness Site Project Of ficer for the San Onof re Nuciear Generating Station (SONGS),
i was also the principal coordinator of findings of the SONGS Exercise Findings and Plan Review document: developed in 1981.
I participated in the NRC/ FEMA Radiological Emergency Response Planning (RERP) Course, Radiological Emergency Preparedness Planners, and the DOE Emergency Response Course at the Nevada Test Side in 1979 and 1980.
IreceivedaBachelorofIrtsDegreeinPoliticalSciencefromthe University of Oregon in 1965.
I attended the McGeorge College of Law, University of the Pacific, Sacramento, for li years prior to a call to military service.
I served in the United States Air Force as a pilot, operations of ficer, plans of ficer, and Disaster Preparedness Of ficer during a tour of active duty from 1967 to 1973 From 1973 to date, I have served with the United States Air Force Reserve, serving in the above duties, and as a Base Disaster Preperedness Augmentation Officer, McClellan AFB, California.
I attended the USAF Disaster Preparedness Course, Lowry AFB; Senior Of ficer's Disaster Preparedness Course, Disaster Preparedness Refresher l
Course, and numerous seminars, training meetings, and conferences dealing with radiciogical and emergency planning.
During Air Force duty, I served l
as Evaluation Team Chief, team member and instructor of emergency response l
l programs, as.-< ell as participating in two actual disaster / accident response events.
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Prior to employment with the Federal Emergenty Management Agency, t
served as an Emergency Mcbilization Plans Officer (Civilian) with the Duties included planning, management, and U.S. Army for 2 years.
execution of functions related to emergency movement and control (handling) of up' to 15,000 personnel in various types of situations.
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Professional Quali fications Kenneth V. Nauman, Jr.
1 Service with the Federal Emergency Management Agency included planning, development, policy implementation, and liaison work with local, State, Areas of and Federal goverr.mer.ts as wall as private enterprise.
included program management and deuelopment relating to involvement Further work Crisis Relocation Planning and general emergencf planning.
included course development, management, and instruction of radiological I have defense training, and development of radiological defense plans.
(RDO-1, attended, directed, and instructed in radiological defense courses Radiological Monitoring, and Radiological Instructor Training) developed I have written numerous plans by the Defense Civil Preparedness Agency.
regarding general and specific disaster response, both in the Air Force Further, I have completed the FEMA Career Development and in DCPA/ FEMA.
Phase Courses Il and li t, and the Air Force Command and Staff College Course.
is to the Radiological Emergency Preparedness Most recent assignment Program as project officer for offsite planning for SONGS and evaluation Additional duty involvement Team Chief for exercises within Region IX.
with the program began in 1980 with primary duty beginning in February 1981.
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