ML20030D068
| ML20030D068 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 08/24/1981 |
| From: | Pigott D ORRICK, HERRINGTON & SUTCLIFFE, SAN DIEGO GAS & ELECTRIC CO., SOUTHERN CALIFORNIA EDISON CO. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8108310353 | |
| Download: ML20030D068 (68) | |
Text
I l
i e
4
\\
/
s C0)Y 1
UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4
5 6
In the Matter of
)
Docket Nos. 50-361 OL 7
)
50-362 OL SOUTHERN CALIFORNIA
)
)
)
9 fe)N 9
(San Onofre Nuclear Generating
)
g Station, Units 2 and 3).
)
'4N 10
)
p
}
hl3 2 C gggy '. ?
11 2
kD C..
of k
Cn 3
14 APPLICANTS' TRIAL MEMORANDUM -
EMERGENCY PLANNING & PREPAREDNESS 15 16 DAVID R.'PIGOTT 17 EDWARD B.
ROGIN SAMUEL B. CASEY 18 ORRICK, HERRINGTON & SUTCLIFFE A Professional Corporation 19 600 Montgomery Street San Francisco, CA 94111 20 Telephone:
(415) 392-1122 21 CHARLES R. KOCHER JAMES A.
BEOLETTO 22 SOUTHERN CALIFORNIA EDISON COMPANY P.O.
Box 800 23 2244 Walnut Grove Avenue Rosemaad, California 91770 24 Telephcne:
(213) 527-1900 25 Attorneys for Applicants, Southern California Edison Company 26 Dated:
August 24, 1981 and San Diego Gas & Electric Company p5ol 5
8108310353 810824
/
PDRADOCK05000g G
(
t TABLE OF CONTENTS Page Introduction I.
Statement of the Case 3
II.
Statement of Contentions.
12 III. Applicants' Order of Proof.
15 A. Voluntary Witnesses 16 B.
Subpoenaed Witnesses 18 C.
Summary of Witnesses Assigned to Each Contention 20 IV.
Summary of Applicants' Written Direct Direct Testimony.
21 V.
Conclusion 67 e
9
- - ~., _
y,
,+ -.
,g
, - =,
erp.
e,e-m.q
=
-e-
-7
- a--
w--
I 4
1 DAVID R. PIGOTT EDWARD B.
ROGIN 2
SAMUEL B. CASEY Of ORRICK, HERRINGTON & SUTCLIFFE 3
A Professional Corporation 600 Montgomery Street 4
San Francisco, California 94111 Telephone:
(415) 392-1122 5
CHARLES R. KOCHER 6
JAMES A. BEOLETTO SOUTHERN CALIFORNIA EDISON COMPANY 7
P.O.
Box 800 2244 Walnut Grove Avenue 8
Rosemead, California 91770 Telephone:
(213) 572-1900 9
Attorneys for Applicants 10 Southern California Edison Company and San Diego Gas & Electric Company 11 12 UNITED STATES OF AMERICA 13 NUCL' EAR REGULATORY COMMISSION 14 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 15 16 In the Mater of
)
Docket Nos. 50-361 OL
)
50-362 OL 17 SOUTHERN CALIFORNIA
)
)
APPLICANTS' TRIAL 18
)
MEMORANDUM - EMERGENCY
)
PLANNING AND PREPAREDNESS 19 (San Onofre Nuclear Generating
)
Station, Units 2 and 3).
)
20
)
21 22 INTRODUCTION 23 Applicants Southern California Edison Company 24
("SCE"), San Diego Gas & Electric Company, the City of 25 Anaheim and the City of Riverside (collectively the 26
" Applicants") hereby submit their trial memorandum to assist 2
k
r 1
the Atomic Safety and Licensing Board (the " Board") in the 2
conduct of hearings on emergency planning contentions 3
commencing August 25, 1981, in Anaheim, California.
This 4
memorandum describes the facts leading up to the commencement 5
of hearing on emergency planning contentions, sets forth the 6
contentions, outlines Applicants' order of proof, and 7
generally summarizes the content of testimony to be presented 8
by Applicants' witnesses.
9 10 I.
11 STATEMENT OF THE CASE 12 The procedural background leading up to the 13 commencement of hearings on the geology and seismology 14 contentions is set forth in Applicant's Trial Memorandum --
15
" Geology and Seismology," served herein on June 18, 1981.
16 In the interest of brevity, we will not reiterate this 17 background, but will detail the significant additional facts 18 leading up to the commencement of hearings on emergency 19 planning and preparedness contentions.
20 Effective November 1, 1980, the Federal Emergency 21 Management Agency (" FEMA") and the NRC Staff entered in a 22 Memorandum of Understanding (the "MOU") which required FEMA 23 to provide support for NRC licensing review "with regard to 24 the assessment of the adequacy of State and local response 25 plans for accidental radiological releases."
45 Fed. Reg.
26 82714 (December 16, 1980).
3 1
i n
1 Effective November 3, 1981, the NRC promulgated 2
amended emergency planning regulations which are now set 3
forth in 10 C.F.R. 5550.33(g), 50.47, 50.54(g), (r), (s),
4 (t), and (u), and Part 50, Appendix E (the "NRC 5
Regulations").
These regulations refer to published NRC 6
guidance on the establishment of emergency planning zones 7
("NUREG-0396") and criteria for the preparation and 8
evaluation of radiological emergency response plans 9
("NUREG 554").
Additional NRC guidance on the functional 10 criteria for emergency response faciliti6s ("NUREG-0696") has 11 subsequently been published.
These guidance documents are 12 not regulations, but are useful in evaluating compliance with 13 the NRC Regulations..
In the case of an application for an 14 operating license such as presented here, compliance with the 15 NRC Regulations does not have to be accomplished unti: the l
16 time of full power authorization, or such later l
17 implementation date as has been established by the NRC Staff 18 in its clarification letter ("NUREG-0737") regarding approved 19 TMI Action Plan items.
(NRC Staff Generic Letter No. 81-25).
20 In February, 1980, FEMA, Region IX and its Regional 21 Assistance Committee (the "RAC") commenced an informal review 22 of the six offsite emergency response plans for San onofre 23 Nuclear Generating Stations
(" SONGS").
These plans had been 1
24 adopted to comply with the NRC Regulations by San Diego and 25 Orange Counties (the " Counties"), the Cities of San Clemente 26 and San Juan Capistrano (the " Cities"), the U.S.
Marine 4
l l
l
1 Corps. - Camp Pendleton (the "USMC"), and the Pendleton Co.:st 2
Office of the State Department of Pa*ks and Recreation 3
(" State Parks").
At the same time, FEMA, Region IX and the 4
RAC also reviewed the Interagency Agreement and Evacuation 5
Procedure (the "IAEP"), which had also been developed by 6
these jurisdictions and incorporated by reference in each of 7
their plans.
The purpose of the review was to evaluate the 8
plans against the guidance set forth in NUREG-0654 and 9
provide suggestions for improvement.
On April 27, 1981, the 10 informal results of this plan review (the " FEMA /RAC Review 11 Comments") were published by FEMA and provided to the parties 12 herein.
13 On March 4, 1981, Brian K.
Grimes, Director, NRC 14 Staff Division of Emergency Preparedness, in a memorandum to 15 John Dickey, Director, FEMA Radiological Emergency 16 Preparedness Division, invoked Section II.4 of the MOU and 17 requested FEMA to provide NRC with findings and 18 determinations as to whether the State and local emergency 19 plans for SONGS 2 and 3 are adequate and capable of 20 implementation.
This information was requested as soon as 21 possible, but not later than June 1, 1981.
In lieu of formal 22 FEMA findings, an interim FEMA evaluation of offsite 23 preparedness was requested.
24 On April 29, 1981, a special prehearing conference 25 with respect to emergency planning issues was held in San 26 Diego, California.
As a result of that conference, the 5
1 parties were directed by the Board to work towards the 2
stipulation of final emergency planning contentions, and to 3
participate in an informal prehearing discovery session 4
including all parties and representatives from FEMA, upon the 5
publication of the FEMA evaluation of offsite preparedness.
6 on May 13, 1981, an exercise of onsite and offsite 7
emergency planning and preparedness for SONGS was conducted 8
involving the personnel and resources of Applicants, tie 9
Counties, the Cities, USMC, State Parks, the Capistrano 10 Unified School District (the " District"), the San Diego and 11 Orange County Chapters of the American Red Cross (" Red 12 Cross"), the California Department of Transportation 13
("CALTRANS"), the California Highwa.r Patrol ("CHP"), the 14 State Department of Health Servicer,, the State Office of 15 Emergency Services
(" State OES"), and various other local 16 organizations.
The exercise was observed by representatives 17 from FEMA, who subsequently provided a generally favorable 18 evcluation of the exercise and suggested areas for 19 improvement in a document entitled " Evaluation Findings, 20 SONGS Offsite Emergency Response Plans Exercise" (the " FEMA l
21 Exercise Evaluation"), which was published May 29, 1981 and 22 subsequently provided to the parties herein.
The NRC Staff 23 also observed the exercise and subsequently provided an 24 generally favorable evaluation of the Applicants' onsite j
25 performance during the exercise in an inspection report 26 (No. 50-206/81-19), which was provided to the parties by 6
i 1
counsel for the NRC Staff under cover letter dated August 4, 2
1981.
3 On May 14, 1981, representatives of FEMA, Region 4
IX, conducted a public meeting in the San Clemente City Hall 5
to informally report their evaluation of the exercise, 6
describe the plan review process, and receive public comments 7
on offsite emergency planning and preparedness.
3 Representatives from the State OES, the Counties, the Cities, 9
the District, State Parks, and the USMC attended and 10 generally described their plans and evaluation of the 11 exercise.
Representatives of the Red Cross and the j
12 California Highway Patrol also attended.
A transcript of 13 this meeting was subsequently made available to the Board and 14 the parties by counsel for the Applicants.
15 On June 3, 1981, FEMA determined that additional 16 offsite training and other short-term improvements were 17 required before it would be able to make an overall favorable 18 finding on the state of offsite emergency preparedness for 19 SONGS.
Specifically, FEMA determined that " State and local 20 government radiological emergency response plans ars i
21 minimally adequate.
However, until corrective actions have 22 been taken, the offsite capability for implementation of the 23 plans is not considered adequate."
This determination was 24 set forth in a document entitled " Interim Findings and 25 Determination Relating to the Status cf State and Local 26 Nuclear Generating Statiion (Units 2 and 3)" (the " FEMA l
7 l
l
8 f
1 Findings"), a copy of which was served on the Board and the 2
parties herein by counsel for the NRC Staff.
3 The FEMA Findings clearly anticipated remedying the 4
deficiencies noted in the FEMA Findings within the "very near 5
future," by stating (emphasis added):
6 "The conclusion reached is that there has been insufficient time, training, drill, and 7
exercise to refleft the required ability of offsite organizations to protect public 8
health and safety.
Alternatively, the efforts rendered, coupled with an aggressive 9
thorough approach to training and preparation (equipment, SOP's etc.) generated as a result 10 of these findings or related incentives, would create the necessary capability within 11 the very near future."
(FEMA Findings, Attachment, p.7.)
12 13 On June 15, 1981, the informal discovery session 14 previously ordered by the Board was conducted.
The session 15 was attended by various representatives of all the parties, 16 as well as by counsel and other representatives from FEMA, 17 Region IX.
Counsel and other representatives of GUARD 18 and FOE et al. were permitted to informally ask the 19 representatives of FEMA a number of questions on a broad 20 variety of topics related to FEMA's review of SONGS offsite 21 emergency planning and preparedness, as reflected in the FEMA 22 Findings, the Exercise Evaluation, and the FEMA /RAC Review l
23 Comments.
At the close of the session, the parties reported 24 to Chairman Kelley, who was also present, that all their 25 questions had been answered.
No request for further 26 discovery was made at that time.
8 l
t
o 1
On June 18, 1981, the final prehearing conference 2
on emergency planning contentions, previously noticed in the 3
Federal Register, was commenced in San Diego, California.
4 46 Fed. Reg. 31123 (June 12, 1981).
The full range of 5
substantive and procedural topics involved in the 6
commencement of emergency planning hearings were argued by 7
all parties, including consolidation of the Intervenors GUARD 8
and FOE et al.,
final specification of contentions, the 9
impact of the FEMA Findings, and the need to resolve 10 outstanding legal i;; sues regarding determination of the EPZ, 11 impact of earthquakes on emergency planning, and the 12 procedural efficacy of an alternative proceeding to obtain a 13 low-power licence.
In view of the need to resolve these 14 legal issues and to allow further time for the parties to 15 discuss the final specification of emergency planning 16 contentions, the Board recessed the final prehearing 17 conference to be reconvened during the seismic hearings upon 18 the call of the Board.
(TR. 673.)
19 On or about June 22, 1981, the parties served and 20 filed herein their views o1 the "EPZ" and " earthquake" 21 issues.
On June 29, 1981, Applicants served and filed their 22 memorandum supporting commencement of emergency planning 23 hearings shortly after conclusion of seismic hearings.
At 24 that time, in order to fully inform the parties of the steps 25 being taken by Applicants to remedy the various deficiencies 26 noted in the FEIIA Findings, Applicants filed and served on 9
I
- _ - ~. - -
1 the parties the " Declaration of Robert Dietch in Support of 2
Commencement cf Hearings on Emergency Planning Contentions 3
Shorty After Conclusion of Seismic Hearings," which included 4
a list of the " Corrective Actions Required to Address FEMA 5
Determinations of June 3, 1981" and a schedule for 6
implementation of these corrective actions.
Applicants, in l
7 consultation and cooperation with the involved offsite 8
response agencies are currently following this schedule and 9
reporting the achievement of various milestones on that 10 schedule to FEMA, Region IX, on a monthly basis.
11 On July 10, 1981, the final prehearing conference 12 on emergency planning contentions was reconvenin in San 13 Diego, California.
At that time, the Board set dates for 14 commencement of hearings and filing of testimony, admitted 15 final emergency planning contentions, ordered Intervenors 16 GUARD and FOE et al. to determine among themselves who would 17 act as " lead counsel" for each admitted contention, and 4
18 granted Intervenor FOE et al. additional time to submit an l
l 19 acceptable contention pertaining to.the SONGS plume exposure l
20 pathway emergency planning zone (the "EPZ Contention").
21 (TR. 3491-3515.)
Counsel for Intervenor GUARD did not attend l
l 22 this conference, but on July 11, 1981 were provided with a 23 copy of the transcript of the proceedings by counsel for the 24 Applicants.
25 On July 29, 1981, the Board recognized certain 26 minor changes to the wording of the final emergency planning 10 I
1 contentions previously admitted for hearing, heard argument 2
on the amended EPZ Contention submitted by Intervenor FOE, 3
et al.,
and raised, on its own motion, a contention involving 4
emergency response in the event of an earthquake exceeding 5
the Safe Shutdown Earthquake (the " Seismic / Emergency Planning 6
Contention").
7 On July 30, 1981, Applicants, the NRC Staff and 8
GUARD, through counsel, entered into a stipulation governing 9
the schedule for filing of testimony and the order of 10 presentation for the hearings on the emergency planning 11 contentions previously admitted by the Board.
12 On August 4, 1981, the Board admitted an amended 13 version of the EPZ Contention, and heard additional argument 14 on the Board's proposed Seismic / Emergency Planning Contention.
15 On August 7, 1981, the Board modified the 16 Seismic / Emergency Planning Contention in various minor 17 respects.
On August 17, 1981, Applicants requested the Board 18 to certify that contention to the Commission.
A schedule for 19 filing of testimony and hearing on the Seismic / Emergency 20 Plan.ung Contention has not yet been established.
21 On August 3 and 17, 1981, the Applicants served 22 their written direct testimony on all admitted emergency 23 planning contentions, except the Seismic / Emergency Flanning 24 Contention.
In addition to this direct testimony, Applicants l
25 have also subpoenaed the testimony of the twelve persons 26 representing the offsite emergency response organizations 11
i that would be principally called upon to assist and otherwise 2
protect the public health and safety in the event of a 3
radiological emergency with potential or actual offuite 4
consequences at SONGS 2 and 3.
A list of these subpoenaed 5
witnesses and a summary of their expected testimony was 6
served on the parties herein on August 17, 1981.
This list 7
and summary is restated in Part III.B. of this memorandum.
8 9
II.
10 STATEMENT OF CONTENTIONS 11 Pursuant to the Final Prehearing Conference Order 12 of the Atomic Safety and Licensing Board, stated on the 13 record herein of July 10 (TR. 3492-3493) and August 4, 1981 14 (TR. 6802), and the stipulation of the parties clarifying the 15 wording and relettering of Contention No. 2, as reported by 16 counsel for Applicants to the Board on the record of July 29 17 (TR. 5543-5546), the following emergency planning contentions 18 have been admitted for hearing commencing on August 25, 1981:
19 EMERGENCY PLANNING CONTENTION NO. 1:
20 Whether the state of emargancy preparedness for SONGS 2 and 3 provides reasonable assurance that the offsite 21 transient and permanent population within the plume exposure pathway Emergency Planning Zone, 10 C.F.R. 550.47(c)(2), for 22 SONGS 2 and 3 can be evacuated or otherwise adequately protected in the event of a radiological emergency with 23 offsite consequences occurring at SONGS 2 and 3, as required i
by 10 C.F.R.
$$50.47(a)(1), (b)(10), and Part 50, Appendix l
24 E.IV.
l 25 EMERGENCY PLANNING CONTENTION NO. 2:
26 Whether there is reasonable assurance that the 1
i 12 l
. ~ - - -
1 emergency response planning and capability of implementation for SONGS 2 and 3, affecting the offsite transient and 2
permanent population, will comply with 10 C.F.R. 550.47(a)(1) and (b) or (c)(1) as regards:
3 A.
the procedures for notification by Applicants 4
of State and local response organizations, 10 C.F.R. 650.47(b)(5), and for notification of 5
and continued communication among emergency personnel by all involved organizations, 10 6
C.F.R.
550.47(b)(6);
7 B.
the means for notification and instruction to the populace within the plume exposure pathway 8
Emergency Planning Zone, 10 C.F.R. 650.47(b)(5);
9 C.
the information and the procedure for 10 dissemination of the information to the public within the plume exposure pathway Emergency 11 Planning Zone on a periodic basis on how they will be notified and what their actions should 12 be in the event of an emergency, 10 C.F.R. 550.47(b)(7);
13 D.
the arrangements for medical services for 14 contaminated and injured individuals, 10 C.F.R.
$50.47(b) (12);
15 E.
necessary transportation and communication 16 equipment, and the operation of the emergency operations centers of the principal response 17 organizations, 10 C.F.R.
$50.47(b)(8);
18 F.
the capability of each principal response organization to respond and to augment this 19 initial response on a continuous basis, 10 C.F.R. 550.47(b)(1);
20 G.
radiological emergency response training to 21 those who may be called on to assist in an emergency, 10 C.F.R. 650.47(b)(15);
22 H.
the methods, staffing, system, and equipment 23 for assessing and monitoring actual or potential offsite consequences of a 24 radiological emergency condition within the plume exposure pathway EPZ for SONGS 2 and 3, 25 10 C.F.R. 550.47(b)(9);
26
///
13
__ _ _ __ ~
1 I.
the physical design, communications equipment, and operating procedures for the Interim 2
Emergency Operations Facility, 10 C.F.R. 5550.47(b)(3) and (b)(a);
3 J.
the methods, systems and equipment for 4
assessing and monitoring actual or potential offsite consequences of a radiological 5
emergency condition within the ingestion pathway EPZ for SONGS 2 and 3, 10 C.F.R. 6 550.47(b)(9);
7 K.
general plans for reentry and recovery, 10 C.F.R. 550.47(b)(13).
8 EMERGENCY PLANNING CONTENTION NO. 3:
9 The emergency response plans fail to meet the 10 requirements of 10 C.F.R. 550.47(c)(2) because local emergency planning officials have arbitrarily established 11 the boundaries of the Plume Exposure EPZ in that they have mechanically applied a 10 mile boundary and that the 12 Interagency Agreement (IAEP) among all local jurisdictions defines the EPZ by drawing compass lines on a map of the 13 area.
In determining the exact size of the EPZ, emergency planning officials have failed to consider the following 14 local conditions:
15 1.
topography 2.
meteorology 16 3.
evacuation routes 4.
demography 17 5.
jurisdictional boundaries 6.
SAI report 18 7.
land characteristics 19 Applicants understand that Intervenor GUARD has been 20 designated by Intervenor FOE et al. as the lead counsel for 21 each of the above-listed contentions.
As regards Emergency 22 Planning Contention Nos. 1 and 2, GUARD has entered into a 23 stipulation with Applicants and the NRC Staff, dated July 30, 24 1981, which in pertinent part provides that Applicants shall 25 serve their direct testimony with respect to contentions 2.A.,
26 2.B.,
2.C.,
2.D.,
2.F.,
2.G.,
and 2.H.,
excluding such 14
1 testimony as relates to offsite issues, on August 3, 1981.
2 Intervenor GUARD and the NRC Staff shall file their direct 3
testimony relating to such contentions on August 10, 1981.
4 Applicants shall serve their direct testimony with respect to 5
the offsite issues of those contentions set forth above and 6
for all remaining contentions on August 17, 1981.
Intervenor 7
GUARD and the NRC Staff shall timely serve their testimony 8
relating to such contentions on August 24, 1981.
Applicants 9
have complied with this stipulation.
The NRC Staff has served 10 some direct testimony on August 10, and is expected to serve 11 the balance of their direct testimony on August 24.
All of 12 Intervenor GUARD's direct testimony on Emergency Planning 13 Contention Nos. 1 and 2 is expected on August 24.
As regards 14 Emergency Planning Contention No. 3, Applicants served their 15 direct testimony on August 17, 1981.
No schedule has been set l
l 16 for filing of testimony on this contention by Intervenor GUARD 17 or the NRC Staff.
18 19 III.
20 APPLICANTS' ORDER OF PROOF 21 Applicants have determined that in order to present 22 their case in a manner that will allow logical progression 23 through the three contentior.s presented, with minimal 24 recalling of witnesses or undue inconvenience to the 25 subpoenaed witnesses, it is most appropriate to address the 26 issues in the following order, with the subpoenaed witnesses 15
I 9
l 1
being taken out of order, if necessary, for presentation l
2 during the period commencing September 14:
3 4
A. VOLUNTARY WITNESSES (Proposed Order of Presentation)
PAGE NOS. IN 5
WRITTEN DIRECT WITNESS (ORGANIZATION)
CONTENTIONiS)/ ISSUE TESTIMONY 6
1.
T.
James Dubois 1/
Public Notification 4-26 7
(SCE) 2B/
Public Notification 9-20 8
2.
James L. Willis-2G/
Onsite Training 3-10 9
(SCE) 10 3.
Eugerie N. Cramer 1/
Public Notification 9-20 (SCE) 11 2B/
Public Notification 4-26 12 2C/
Public Education 7-20 13 4.
Dr. Roger E. Linnemann 2D/
Medical Services for (RMC Corp.)
Contaminated and 14 Injured Individuals 15-40 15 2G/
Onsite and Offsite Medical Training 15-40 16 5.
Dr. Jack E.
Hauck 2D/
Medical Services for 17 (SCE)
Contaminated and Injured Individuals 4-7 18 6.
Harold B.
Ray 2A/
Onsite Notification of 19 (SCE)
Offsite Agencies 16-31 20 2E/
Onsite Emergency Facilities 22-24 21 2F/
Onsite Response and 22 Augmentation capability 11-14 23 7.
Kenneth P. Barr 2F/
Radiological Assessment (SCE)
Response and 24 Augmentation 14-17 25 2H/
Offsite Radiological Monitoring & Dose 26 Assessment 5-18 16 l
1
\\
1 PAGE GOS. IN WRITTEN DIRECT 2
WITNESS (ORGANIZATION)
CONTENTION (S)/ ISSUE TESTIMONY 3
8.
Ernest L. Murri 1/
Perspective on Evacuation (NUS Corp.)
and other Protective 4
Actions 26-38 5
2A/
Onsite and Offsite 49-50 Communication Capability 74-75 6
2C/
Public Education 80 7
2E/
Offsite Emergency 8
Operation Centers 71-74 9
2F/
Offsite Response and Augmentation Capability 70-71 10 2G/
Offsite Training 57-58 11 76-77 12 2H/
Offsite Monitoring and 58-63 Dose Assessment 13 Capability 77-78 14 2I/
Interim EOF 78 15 2K/
Onsite and Offsite 63-65 Reentry & Recovery Plans 78 1G 3/
EPZ Determination 81-84 17 9.
Bryant T.
Brothers 1/
Evacuation Planning 11-56 18 (Wilbur Smith & Assoc.
& Time Estimation 19
-3/
EPZ Determination 11, 17-18 20
- 10. Keith Woodard 3/
SAI Study as 7-16 (Pickard, Lowe & Garrick)
Validating EPZ 21 Determination 22
- 11. Gary Re 2J/
Ingestion Pathway 4-9 (Dames and Moore)
Inventory 23
- 12. David F.
Filmer 2A/
SCE Corporate Emergency 19-24 24 (SCE)
Response Organization 25 2H/
Offsite Dose Assessment 26-27 26 2If Emergency Operations 22-25 17
1 PAGE NOS. IN WRITTEN DIRECT 2
WITNESS (ORGANIZATION)
CONTENTION (S)/ ISSUE TESTIMONY _
3 2J/
Ingestion Pathway 26-36, Plans and Procedures 4
2K/
Onsite Reentry 36-38 5
& Recovery 6
3/
Rationale for 14-19 EPZ Determination 7
8 The testimony of each of the above-listed witnesses 9
is summarized in Part IV of this memorandum.
10 B.
SUBPOENAED WITNESSES (Preposed Order of Presentation) 11 Witness / Organization / Address General Area of Expected Testimony 12 1.
Lt. Col.
J.
E. Wallace U.S. Marine Corps emergency Marine Corps Base planning and prep.3 redness.
13 Camp Pendleton, CA 92055 14 2.
James Hunt San Diego County emergency San Diego County, planning and preparedness.
15 Office of Disaster Preparedness 16 5201 Ruffin Road San Diego, CA 17 3.
Calvin Nash Red Cross operation of 18 American Red Cross reception and care centers Orange County Chapter for evacuees.
19 601 N.
Golden Circle Dr.
P.O.
Box 11364 20 Santa Ana, CA 92711 21 4.
Chief Benj amin California Highway Patrol Killingsworth EPZ evacuation traffic 22 California Highway Patrol management.
Border Division 23 San Diego, CA 92120 24
///
25
///
26
///
18
1 5.
David H. Roper CALTRANS EPZ evacuation Deputy District Director-traffic management.
2 Operations California Department of 3
Transportation (District 7) 120 S.
Spring Street 4
Los Angeles, CA 90012 5
6.
Jack P.
Stowe State Parks emergency planning State of California, and preparedness.
6 Department of Parks and Recreation, 7
Pendleton Coast Area 3030 Avenida del Presidente 8
San Clemente, CA 92672 9
7.
Ronald J. Coleman San Clemente emergency City of San Clemente planning and preparedness.
10 100 Avenida Presidio San Clemente, CA 92672 11 8.
Cynthia Ferguson San Juan Capistrano emergency 12 City of San Juan Capistrano planning and preparedness.
32400 Paseo Adelanto 13 San Juan Capistranto, CA 92675 14 9.
Jill Swanson Capistrano Unified School Capistrano United School Dist. District procedure 15 32972 Calle Perfecto for evacuation and San Juan Capistrano, CA 92675 other protective measures.
16
- 10. Bert Turner, Manager Orange County emergency 17 Emergency Services Division planning and preparedness.
General Services Agency 18 625 N. Ross Street, Rr... B-169 Santa Ana, CA 92701 19
- 11. Don Poorman Orange County primary and 20 Communications Division back-up emergency General Services Agency communication capability.
21 County of Orange 481 l
The City Drive 22 Orange, CA 92668 23
- 12. Barbara Fox Orange County emergency General Services Agency planning and preparedness.
24 900 N. Broadway l
Santa Ana, CA 92701 25
///
26
///
l 19
1 Each of the above-listed subpoenaed witnesses has 2
been requested to bring any documents which they believe are 3
relevant to their general area of testimony listed above, 4
including existing or draft standard operating procedures; 5
personnel, equipment and resource lists, and mutual aid 6
agreements.
To the extent relevant to issues in contention 7
and their general area of testimony Applicants anticipate 8
that each of the above-listed witnesses will (1) describe the 9
participation of their respective organizations in the May 13 10 exercise; (2) respond to the FEMA RAC Comments on various 11 offsite emergency plans (April 27, 1981), the FEMA Exercise 12 Evaluation (May 29, 1981) and the FEMA Findings (June 3, 13 1981), and (3) generally describe their on-going efforts, in 14 consultation and cooperation with Applicants and other 15 involved jurisdictions and organizations, to further improve 16 their radiological emergency planning and implementation 17 capabilities.
18 19 C.
SUMMARY
OF WITNESSES ASSIGNED TO EACH CONTENTION 20 In sum, the following Applicants' witnesses are 21 expectcd to present direct testimony on the contentions 22 listed in Part II above:
23 contention No. 1 Contention No. 2A 24 T.
James DuBois Harold B.
Ray Eugene N.
Cramer Ernest L. Murri 25 Ernest L. Murri Kenneth P.
Barr Bryant T.
Brothers David F.
Filmer 26 Subpoenaed Witnesses Subpoenaed Witnesses 20
1 Contention No. 2B Contention No. 2H C
2 T.
James DuBois Kenneth P. Barr Eugene N. Cramer Ernest L. Murri 3
Subpoenaed Witnesses David F. Filmer Subpoenaed Witnesses 4
Contention No. 2C Contention No. 2I 5
Eugene N. Cramer Ernest L. Murri 6
Ernest L. Murri David F.
Pilmer Subpoenaed Witnesses 7
Contention No. 2D Contention No. 2J 8
Roger E.
Linnemann Gary Re 9
Jack E. Hauck David F. Filmer 10 Contention No. 2E Contention No. 2K 11 Harold B.
Ray Ernest L Murri Kenneth P.
Barr David F.
Filmer 12 Ernest L. Murri David F. Filmer 13 Subpoenaed Witnesses 14 Contention No. 2F Contention No. 3 15 Harold B. Ray Ernest L.
Murri Kenneth P.
Barr Bryant Brothers 16 Ernest L. Murri Keith Woodard Subpoenaed Witnesses David F.
Filmer 17 Subpoenaed Witnesses 18 Contention No. 2G 19 James L. Willis Roger E.
Linnemann 20 Ernest L. Murri Subpoenaed Witnesses 21 22 IV.
SUMMARY
OF APPLICANTS' WRITTEN 23 DIRECT TESTIMONY l
24 A.
Testimony of T. ' James DuBois l
l 25 Mr. DuBois received his Bachelor of Science Degree l
26 in Civil Engineering from the University of Connecticut and 21
~
1 is a registered professional mechanical engineer in the State 2
of California.
Currently Mr. DuBois is Supervisor of the 3
Technical Support Group of the Apparatus Engineering Svetion 4
of the Engineering and Construction Department of SCE.
As 5
Supervisor of the Technical Support Group, he is responsible 6
for the development, specification and measurement of 7
acoustic, seismic and mechanical vibration criteria for 8
apparatus and facilities.
Among his other responsiblities 9
are the analysis of noise legislation; performance of 10 environmental and occupational noise surveys; monitoring and 11 diagnostics of mechanical vibration of rotating equipment; 12 and seismic qualification analysis and testing of apparatus.
13 Mr. DuBois' testimony concerns Contentions '. and 14 2.B.
He addresses the prompt alerting system which has been 15 completely installed in the 10-mile plume exposure EPZ around 16 SONGS.
He discusses the configuration and capabilities of 17 the prompt alertino system and the reasons for its selection.
18 The pcc apt alerting system has the capability of 19 providing an audible signal throughout all populated areas of l
20 the 10-mile plume exposure EPZ which will alert the public to 21 an impending radiological emergency notification to be made 22 by public authorities over various broadcast media such as 23 the emergency broadcast system.
Mr. DuBois' testimony and 24 exhibits show where the sirens are located and how they will 25 be controlled.
26 Mr. DuBois concludes that the siren system will i
l l
22 l
1 provide the means to provide early notification to the 2
populace within the 10-mile plume exposure pathway EF2 such 3
that the requirements of Appendix 3 of NUREG-0654 and other 4
regulatory guidance dealing with prompt alerting systems are 5
satisfied.
6 B.
Testimony of Jumes L.
Willis 7
Mr. Willis is Manager of Nuclear Training for SCE 8
and i s responsible for the training provided at SONGS for 9
onsite personnel.
He has a Bachelor of Science Degree in 10 Electrical Engineering and attended the Navy's twelve month 11 Advanced Nuclear Power Training Program in 1958.
He has 12 spent over 21 years in the operation, maintenance and 13 management of nuclear power plants and the training of 14 operators for nuclear power plants.
15 Mr. Willis' testimony concerns Contention 2.G.
He 16 addresses the radiological emergency response training of 17 onsite personnel at SONGS who may be called upon to assist in 18 the event of an emergency.
19 The training to be provided to all of the various 20 categories of emergency personnel is set forth in Training 21 Memorandum 10-81, Exhibit JLW-1.
In discussing this Exhibit, 22 Mr. Willis details the initial training to be provided to the 23 various categories of personnel and the retraining which is t
24 required to be conducted annually thereafter.
25 Mr. Willis' testimony demonstrates that all onsite 26 categories of personnel who may be called upon to assist in 23
.-~
a V
1 an emergency, and particularly those categories of personnel 2
described in Evaluation Criteria 4.a.
through 4.j. of 3
Planning Standard O, NUREG-0654, are receiving the proper and 4
appropriate training and that the other Evaluation Criteria 5
of Planning Standard O which concern onsite training are 6
satisfied.
7 Mr. Willis concludes that adequate radiological 8
emergency response training is being provided to the onsite 9
personnel at SONGS who may be called upon to assist in an 10 emergency.
11 C.
Testimony of Eugene N.
Cramer 12 Mr. Cramer is the Engineer for Advanced Energy 13 Systems in the Nuclear Engineering and Operations Department 14 of SCE.
He is a registered professional nuclear engineer in 15 the State of California.
He has Bachelor of Science Degrees 16 in Physics and Mathematics and a Masters Degree in 17 Management.
He has completed the post-graduate course at the 18 Oak Ridge National Laboratory ("ONL") School of Reactor 19 Technology, and has also taught at that School.
He has also 20 completed a Program in Nuclear Por r Reactor Safety at 21 Massachusetts Institute of Technology.
Mr. Cramer has helped 22 design, construct and operate a nuclear power reactor; 23 monitored advanced-reactor design and tests; and was a 24 Development Engineer at ONL with a wide variety of 25 assignments in both reactor operations and reactor safety 26 research.
It has been Mr. Cramer's responsibility at SCE to 24
I assist SCE's Corporate Communications Department in ef; orts 2
to explain the benefits and costs of nuclear energy to the 3
public.
Mr. Cramer is a member of the SONGS Emergency 4
Support Organization.
5 Mr. Cramer's testimony is concerned with 6
Contentions 1, 2.B.,
and 2.C.
He primarily addresses 7
Contention 2.C regarding the information being disseminated 8
to the public within the plume exposure EPZ on how they will 9
be notified and what their actions should be in the event of 10 an emergency.
Mr. Cramer's testimony also addresses 11 Contentica 1, the evacuation contention, and Contention 2.B.
12 to the ex ent these contentions involve instructions to be 13 provided to the populace within the plume exposure pathway 14 FPZ.
Mr. Cramer has been actively involved in the pl.nning 15 and the review of the information for public education and 16 has, at times, supervised the entire effort.
17 Mr. Cramer's testimony describes the program 18 Sssigned by the Applicants to disseminate educational 19 information to residents and transients within the plume 20 exposure EPZ.
The program commenced in June 1981 with the 21 mailing to all residents within the plume exposure EPZ of an 22 emergency pamphlet, Exhibit ENC-1, which provides the proper 23 actions to take in the event of an emergency.
This mailing 24 also informed the public how to obtain additional information 25 and assistance, if necessary.
Mr. Cramer also describec how 26 the Emergency Broadcasting System, ("EBS") will provide 25
1 information to the public in the event of an emergency.
2 Following the initial educational efforts, neriodic 3
information campaigns will be undertaken to make certain that 4
the public is generally kept informed about the information 5
they will need and the actions to take in the event of an 6
emergency.
The information programs will be designed for 7
both residents and transients.
Exhibits submitted by Mr.
8 Cramer demonstrate the type of information which will be 9
available for both permanent residents and transients in 10 public places, businesses and telephone directories.
11 The information provided to the public will include 12 general background information on such items as who decides 13 when to take action in the event of an emergency, action 14 levels of local government agencies, radioactivity releases 15 and radiation effects, effective public p-otective actions, 16 and reception and care centers.
17 Mr. Cramer also describes how the release of 18 information to the public would be coordinated in the event 19 of an emergency at SONGS through the public information 20 officers (" PIOS") of the local response agencies and the 21 operation of the Emergency Media Center ("EMC") in San 22 Clemente.
Mr. Cramer describes how information flows to and 23 from the EMC from SONGS, the various offsite Emergency 24 Operatior.s Centers and the nearby Emergency Operations 25 Facility.
Mr. Cramer also describes how the EMC would assist 26 in the coordination of decisions and instructions to the 26
1 public and in rumor control in the event of an emergency.
2 Mr. Cramer's testimony also addresses the actions 3
taken in response to recommendations from FEMA for better B
l 4
coordination of the activities of the 4MC.
These include the 5
development of a management structure to control the 6
operations and the appointment of a subcommittee to draft 7
Standard Operating Procedufes for the EMC.
He also describes 8
educational programs to be provided by the Applicants for the 9
PIOS and the media on radiation and radiation effects.
10 Mr. Cramer concitJes that there is reasonable i
11 a r,surance that information will be n;ade available to the 12 public on a periodic basis as to how they will be notified 13 and what their actions should be in the event of an 14 emergency; that principle points of contact with the news 15 media for dissemination of information during an emergency 16 are established; and that procedures for coordinated I
17 dissemination of information to the public are being 18 developed so that the applicable regulatory requirements have 19 been met.
20 D.
Testimony of Roger E.
Linnemann, M.D.
21 Dr. Linnemann is President of Radiation Management 22 Corporation ("RMC"), Clinical Associate Professor of 23 Radiology at the University of Pennsylvania School of 24 Medicine, visiting Associate Professor of Clinical Radiology 25 at Northwestern University School of Medicine and is 26 licensed to practice medicine and surgery in the states of 27 1
1 Pennsylvania, Minnesota and Illinois.
He is certified by the 2
Am1rican Board of Radiology and the American Board of Nuclear 3
Medicine.
4 Dr. Linnemann has an extensive background in the 5
areas of radiology, nuclear medicine and in the preparation 6
for and the handling of radiation accidents.
His experience 7
includes being head of the Nuclear Medical Research 8
Detachment, Europe, (1965-1968) where he was the radiological 9
health consultant to the United States Army Europe, 10 responsible for plans, procedures and training necessary for 11 military hospitals' medical personnel in the evaluation of 12 radiation casualties.
Since 1971, Dr. Linnemann has 13 represented the State of Pennsylvania in the Medical Liaison 14 Officer's Network, a national organization of physicians 15 established by the Environmental Protection Agency and the 16 Department of Energy to consult on radiation problems 17 associated with federal installations.
Dr. Linnemann has 18 appeared as an expert witness in the fields of radiation 19 medicine, nuclear medicine, and radiation effects in numerous 20 hearings.
21 Dr. Linnemann's testimony pr'ovides a general 22 perspective concerning the nature of radiation injuries, the 23 offsite medical requirements to handle such injuries as they 24 occur onsite, and the medical and public health consequences 20 of an offsite releare of radiation.
His testimony addresses 26 Contention 2.D.,
concerning arrangements for medical services 28
e I
for contaminated and injured individuals, and contention 2
2.G.,
concerning radiological emergency response training of 3
first aid and medical support personnel.
4 Dr. Linnemann exylains the difference between 5
radiation exposure and contamination and the importance of 6
distinguishing between them in terms of developing 7
appropriate procedures for response to radiation accidents.
8 In the case of radiation exposure, radiation passes through 9
the body as it does in medica. x-rays; the patient is not 10 radioactive and presents no hazard to response personnel.
11 Contan:ination results from loose radioactive particles 12 adhering to the body.
Since these particle emit radiation, 13 they must be removed to prevent further hazards to the 14 patient and to response personnel.
Dr. Linnemann describes 15 how contamination may be detected and how decontamination can 16 be accomplished through the removal of clothing and the 17 bathing of effected areas.
Dr. Linnemann also describes why 18 the treatment of traumatic injury always takes precedence 19 over the treatment of a radiation injury since radiatio,n 20 injuries are seldom if ever immediately life threatening.
21 Dr. Linnemann explains why there is not a need for 22 a large number of hospital beds in the event of a release of 23 radiation caused by an accident at SONGS.
The 24 characteristics of a release of radiation and of radiation 25 itself mitigates against the possibility than anyone offsite 26 would receive a dose of radiation resulting in symptons of 29
I radiation sickness or requiring hospitalization.
To the 2
extent monitoring of individuals for c'ntamination is o
3 desirable, it does not need to be and should not be done at 4
hospitals.
As set forth in the emergency plans, it can be 5
done at the predetermined reception and care centers operated 6
by the Red Cross.
7 Dr. Linnemann discusses thyroid protective drugs 8
such as potassium iodide ("KI") and how such drugs act to 9
protect the thyroid gland.
KI should be considered for 10 emergency workers, but would rarely be considered for the 11 population as a whole.
12 Dr. Linnemann next describes the training provided 13 by RMC Corporation for representatives of offsite response 14 Agencies in Orange and San Diego Codnties which may be called 15 upon to assist in the event of an emergency at SONGS.
The 16 attendees included physicians and hospital emergency room 17 personnel; city, county and state emergency response 18 peraonnel; emergency medical technicians and others 19 responsible for first line rescue of radiation accident 20 victims; and sheriffs, police, firemen, Red Cross and others 21 who are responsible for attending to the needs of the general 22 populace in the event of offsite release of radiation.
This 23 training introduced those in attendance to an understanding 24 of ionizing radiation, including the biological effects and j
25 medical significance of radiation exposure; provided each 26 attendee with the medical basis for decision making in the 30
1 event of offsite release of radiation; defined basic 2
protective actions which can be taken to reduce exposure 3
levels in the event of an accident; provided specific 4
training concerning notification, response requirements and 5
specific responsibilities and/or procedures for each group's 6
area of concern; and initiated situational exercises for 7
reinforcement of each participant's understanding of the 8
coordination required for response to various types of 9
accidents which might occur at a nuclear facility 10 As described in the testimony of Dr. Jack E. Hauck, 11 SCE has contracted with RMC to obtain its Emergency Medical 12 Assistance Program ("EMAP").
As part of EMAP, RMC has 13 already assisted the hospitals with which SCE has contracted 14 for medical support to prepare emergency procedures for 15 handling radiation accidents.
RMC has also provided specific 16 training to the staffs of these hospitals in the handling and 17 treatment of radioactively contaminated and injured patients 18 with individualized training for various disciplines of the 19 hospitals staffs.
Such training will continue in the future 20 as a part of EMAP.
21 Through EMAP, RMC will insure that SONGS' first 22 aid, ambulance transportation, and support hospitals' 23 emergency care capability are adequate through semi-annual 24 audits and annual training and drills.
In addition, 25 emergency medical equipment and instruments onsite and 26 offsite will be inventoried and tested.
31 1
L
1 Dr. Linnemann's testimony demonstrates that the 2
medical support facilities for SONGS can handle multiple 3
contaminated and injured patients and that the personnel 4
providing such services are properly trained.
Dr. Linnemann 5
concludes that the Applicants do have s.n adequate program to 6
handle radiation injuries including contaminated and injured 7
personnel, that the first aid capability provided onsite at 5
SONGS is adequate, that the arrangements made by SCE for the 9
transportation of victims of radiological accidents to 10 medical support facilities are adequate, that loc %: and 11 backup hospital services for which the Applicants have 12 arranged are capable of evaluating raddation exposure and 13 uptake with the assurance that the persons providing such 14 services are adequately prepared to handle contaminated 15 individuals and that all of these capabilities will be 16 maintained.
17 E.
Testimony of Jack E.
- Hauck, M.D.
l 18 Dr. Hauck is the Corporate Medical Director for SCE 19 and is in charge of all the medical treatment provided under 20 SCE's Employee's Medical Benefit Package.
Among his 21 responsibilities is the supervision of the medical treatment 22 provided at SONGS and insuring that adequate support is 23 provided for such medical services.
24 Dr. Hauck is a medical doctor licensed to practice 25 in the states of California, Arizona, Nevada and New Mexico.
26 Before joining SCE he practiced general medicine in l
l 32 l
l
1 Huntington Beach, California for ten years.
He has taken 2
courses through the Department of Energy Training Center at 3
Oak Ridge, Tennessee and the Radiation Emergency Assistance 4
Center and has participated in training sessions with 5
Radiation Management Corporation.
Since 1980 he has been a 6
guest lecturer and on the teaching facility of the University 7
of California, Irvine teaching a course on a the handling of 8
radiation accidents.
l 9
Dr. Hauck's testimony addresses Contention 2.D.
10 and the medical services for contaminated and injured 11 individuals.
Dr. Hauck describes the first aid and medical j
4 12 care which will be available at SONGS and identifies the 13 arrangements which SCE has made for local and backup 14 hospitals, medical services and for the transportation of 15 victims of radiological accidents to the medical support i
16 facilities.
Exhibit JEH-1 to Dr. Hauck's testimeny is SCE's 17 agreement with Radiation Management Corporation for its j
18 Emergency Medical Assistance Program.
This program is 19 described in the testimony of Dr. Roger E. Linnemann.
l 20 F.
Testimony of Harold B.
Ray l
21 Mr. Ray is employed by SCE as Station Manager of 22 SONGS.
He has a Bachelor of F isnce in Engineering, and a 23 Master of Science in Nuclear Engineering.
He has also 24 completed a post g.aduate course specializing in the design i
r 25 and analysis of pressurized water reactors.
Mr. Ray is a 26 registered professional engineer in both mechanical l
i I
33 I
1 engineering and nuclear engineering the State of California.
2 Mr. Ray has previously served as a reactor systems 3
engineer and has been employed by SCE since 1970 in various 4
engineering and technical management positions relating to 5
nuclear power generation.
Prior to becoming Station Manager 6
at SONGS, he was Manager, Quality Assurance (1975 to 1979) 7 with the primary responsibility for inspection and audit 8
procedures to assure safe design, construction and operation 9
of all units at SONGS.
He was also Project Manager for Units 10 2 and 3 (1979 - August, 1981) with overall responsibility for 11 design, construction and start up testing of these units.
12 Mr. Ray's testimony addresses Contention 2.F.,
13 concerning the capability of the onsite response 14 organization; Contention 2.A.,
concerning procedures for 15 notification of state and local response organizations and 16 continued communication among emergency personnel; and 17 Contention 2.B.,
concerning the menns for notification and 18 instruction to the populac'e within the plume exposure EPZ.
19 Mr. Ray is directly in charge of and responsfole 20 for the organization and direction of station personr.el at 21 SONGS 2 and 3 assigned to respond in the event of an 22 emergency.
Mr. Ray identifies and describes the Emergency 23 Plan for SONGS 2 and 3, April 1981 (the " SONGS 2 and 3 24 Plan"), Exhibit HBR-1.
Together with the offsite emergency 25 response plans, Exhibit HBR-2, these plans are maintained up 26 to date in the Control Room and Technical Support Center 34
1
2 Mr. Ray generally describes the organizational 3
control of emergencies and the designated staffing to respond 4
to an emergency and to augment the response on a continuous 5
basis.
The overall response organization consists of an 6
Emergency Coordinator who is in overall charge of emergency 7
activities at SONGS 2 and 3 and has the sole responsibilty 8
and clear authority to act in all matters relating to the 9
conduct of operation in response to an emergency condition.
10 The Watch Engineer becomes the Emergency Coordinator until 11 -
relieved by the Station Manager, Mr. Ray.
The Emergency 12 Coordinator is supported by leaders of several functional 13 groups covering the essential areas of operations --
14 radiation protection, security, engineering and 15 administration.
The SONGS Emergency Response Organization 16 is capable of continuous emergency operations for a 17 protracted period if necessary.
18 The onsite technical support staff can be augmented 19 by obtaining support from companies such as Bechtel Po'wer 20 Corporation, Combustion Engineering, Institute for Nuclear 21 Power Operations, the Pacific Gas & Electric Company, and the 22 Sacramento Municipal Utilities District.
23 Mr Ray describes the interface between the SONGS 2 24 and 3 Plan and offsite emergency response plans and 25 evacuation procedures.
He explains the means of the 26 coordination between the onsite Emergency Response 35
1 Organization, the SCE Corporate Radiological Emergency 2
Support Organization ("ESO") and state and local response 3
organizations.
Written agreen.ents for offsite services to be 4
provided by participating governmental and private agencies 5
for handling emergencies, as set forth in t,a SONGS 2 and 3 6
Plan, ere also described.
7 Mr. Ray concludes, with respect to Contention 2.F.,
8 that there is reasonable assurance that at the time of 9
initial fuel loading for SONGS 2, the SCE Emergency Response 10 Organization, assisted by the technical support described by 11 him, will have the capability to respond to emergencies at 12 SONGS 2 and 3 and to augment this initial response on a 13 continuous basis as required by the NRC Regulations.
14 In addressing Contention 2.A., Mr. Ray describes 15 the procedures which have been established for notifying 16 Federal, State and local response organizations of an 17 emergency at SONGS 2 and 3 and describes the four level j
18 scheme of classification which has been uniformally adopted 19 by all onsite and offsite emergency response organizations.
20 The cicasifications levels are designated " Unusual Event,"
21
" Alert," " Site Emergency," and " General Emergency."
22 The Emergency Coordinator is responsible for 23 initiating the alerting and activation of both onsite and 24 offsite emergency personnel organizations.
The procedures 25 for offsite notification are set forth in the SONGS 2 and 3 26 Plan.
Mr. Rey describes the state and local response 36 l
l
I 1
organizations which will be notified in the event of 2
particular emergency conditions.
The SONGS 2 and 3 3
communications system includes multiple systems and 4
redundancies to er..sure the performance of vi'tal functions and 5
transmitting and receiving information between SONGS involved 6
Federal, State and local response organizations.
These 7
systems range from public and dedicated phone systems to VHF 8
radio, UHF radio and microwave multiplex systems.
Message 9
forms keyed to the emergency classification system, an 10 Emergency Events Manual, and other procedures have been 11 developed to ensure that emergency messages are received and 12 understood.
Communication between and among onsite personnel
^
13 is achieved through the SONGS telephone and intercom rystems, 14 UHF radio and a public address system.
Communications are 15-also established with the SCE administrative personnel who 16 are detailed to report to the ESO or the EOF.
Communication 17 with these individuals is maintained on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, 7 day week 18 basis.
19 Mr. Ray concludes that the SONGS 2 and 3 20 communications system and the initial and follow-up 21 j
communications procedures for notification of Federal, State 22 and local emergency response organizations provide rearonable 23 assurance that Applicants can initially notify and then 24 maintain necessary communications with Federal, State and 25 local response organizations during the course of an 26 emergency at SONGS 2 and 3, as required by the NRC 37
~
I regulations.
He also concludes that the SONGS 2 and 3 2
communic tion system and the procedure for notification and 3
continued communication between the key personnel in the 4
SONGS 2 and 3 onsite and corporate emergency response 5
organizations provide reasonable assurance that Applicants 6
can initially notify and then maintain necessary 7
communication among SCE emergency response personnel.
8 With respect to Contention 2.B. Mr. Ray explains 9
the r.eans to provide emergency notification and protective 10 action and instruction to persons who may be in the SONGS' 11 Beach Area in the event an emergency requiring such 12 notification.
He describes the Beach Area Public Address 13 System which includes speakers mounted on the SONGS perimeter 14 fence capable of transmitting a clearly audible message 15 throughout the near-site beach area within about a half mile 16 of the SONGS perimeter.
In addition, a siren system, 17 described in more detail in the testimony of Mr.
T.
James 18 DuBois, includes five sirens located within the land area 19 subject to the jurisdiction of the State Department of Parks 20 and Recreation (" State Parks").
These sirens can be 21 activated from the control room at SONGS 1 until such time as 22 control of these sirens can be assumed by State Parks.
Upon 23 the activation of the public siren warning system, local l
24 organizations will authorize transmission of emergency taped l
l 25 messages over the emergency broadenst system as described in 26 the testimony of Eugene N. Cramer.
l l
38 l
r 1
G.
Testimony of Kenneth P.
Barr 2
Mr. Barr is employed by SCE as Health Physics 3
Manager at SONGS.
He has a Bachelor of Science Degree in 4
Mathematics and has completed post-graduate courses covering 5
many facets of reactor operation, including reactor health 6
physics and environmental radiological monitoring.
His 7
experience includes various management responsibilities in 8
the area of health physics and radiological emergency 9
response activities.
10 Mr. Barr's testimony addresses Contention 2.H.
and 11 describes the substantial onsite capability to assess the 12 radiological significance of any accidental offsite release 13 of radioactivity at SONGS 2 and 3 and to formulate 14 recommended protective actions for the affected offsite 15 transient and perminant populations.
16 As Manager cf Health Physics for SONGS, Mr. Barr is 17 responsible for the entire health physics program including 18 staffing and equipment.
During emergency operations, he is 19 responsible for appointing and directing SCE's onsite and 20 offsite radiological monitoring activities; performing dose i
21 projections for onsite and offsite areas; providing health l
22 physics support for onsite emergency activities; providing 23 technical advice to the Emergency Coordin cor on radiological 24 aspects of both onsite and offsite activities; coordinating l
25 offsite monitoring activities with State and local agencies; 26 ensuring issuance and proper use of radiological protective
I equipment; and assigning an SCE Health Physics Engineer to 2
the Emergency Operations Facility (" EOF") to provide 3
technical assistance to the offsite emergency response 4
organizations in matters pertaining to offsite dose 5
calculation, radiation monitoring, and protective action 6
formulation.
7 Mr. Barr describes how the SONGS 2 and 3 Area 8
Radiation Monitoring System (" ARMS") provides initial and 9
continuing assessment of in-plant radiation levels.
In 10 addition the Post-Accident Sampling System (" PASS") provides 11 the capability to analyze the radioactivity levels of the 12 reactor coolant and the containment atmosphere.
These 13 systems can be operated remotely from the Control Room to 14 avoid personnel radiation exposure.
In the event plant 15 radiation instruments are inoperable, the capability exists 16 for Health Physics personnel, appropriately protected, to be 17 dispatched to perform measurements of radiation levels using 18 portable instrumentation.
19 Mr. Barr then describes the method for calculation 20 of potential or actual offsite consequences of releases of I
21 radioactivity to the atmosphere through the use of analytical l
22 methods based on readouts from installed monitoring devices, 23 as well as other parameters.
The data provided by monitoring 24 instruments are converted to a source term of radioactive 25 material available for release.
By applying atmospheric 26 dispersion co-efficients based on meterological data 40
1 (available from onsite sources as well as offsite backup 2
sources) and dose conversion factors, which relate airborne 3
radioactivity concentration to direct dose rate, thyroid dose 4
rate and life time integrated doses are converted to 5
projected offsite dose rates.
These are provided to the 6
onsite Technical Support Center and Offsite Dose Assessment
'7 Center ("ODAC") located in the EOF.
Through ODAC, SCE can 8
coordinate with other involved Federal, State and local 9
agencies in the area of offsite radiation monitoring and dose 10 assessment.
By comparing these projected dose rates to the 11 established Protective Action Guides ("PAGs"),
12 recommendations for protective actions are then made to the 13 onsite Emergency Coordinator, who may convey these 14 recommendations to emergency response officials at the EOF.
15 An individual trained to perform offsite dose 16 calculations will be onsite at all times and provisions exist 17 to augment this capability.
In the event projections 18 indicate that the potential for release of radioactive 19 materials to offsite areas may result in doses approaching 20 the threshhold of the range of PAGs offsite radiation 21 monitoring teams are dispersed from SONGS.
These teams take i
12 direct radiation readings with appropriate survey instruments 23 and air samples for analysis of airborne radioactivity.
The 24 results are recorded on data sheets and reported to the TCS.
25 Mr. Barr also describes a health physics computer 26 system which is to be implemented within the next year as an 41
7 1
aid in performing offsite dose calculations in accordance 2
with NRC requirements, and providing additional offsite 3
radiation monitoring capability.
4 In order to augment the onsite SONGS emergency 5
response capability, Mr. Barr explains how help could be 6
sought from the other utilities pursuant to the Radiological 7
Mutual Assistance Agreement described in the testimony of 8
Herold B. Ray, and other companies with which SCE has 9
contracted.
10 Mr. Barr concludes that the offsite radiation dose 11 assessment and monitoring capability to be provided by 12 SONGS personnel provides reaebrable assurance that offsite 13 transient'and permanent populations within the plume exposure 14 EPZ can be protected in the event of an emergency with 15 potential or actual offsite consequences at SONGS 2 and 3 16 even without the support of Federal, State and local 17 resources which are.available to augment to SCE's capability.
18 H. Testimony of Ernest L. Murri 19 Mr. Murri is Supervisor of Health Physics 20 Applications for NUS Corporation.
He has Bachelor of Science 21 and Masters degrees in Physics and has been involved in 22 emergency planning since 1961.
He has prepared onsite and 23 offsite emergency plans for nuclear generating stations and 24 conducted emergency response training for onsite and support 25 personnel.
He has testified in ASLB hearings on the issues 26 of health physics and emergency planning.
At the request of 42
1 the Applicants, NUS has developed or revised onsite and 2
offsite emergency plans to comply with the NRC Regulations.
3 Mr. Murri has been directly responsible for all work of NUS 4
related to the development and revision of the SONGS offsite 5
and onsite emergency plans.
6 Mr. Murri's testimony generally describes emergency 7
planning terms and methodology, describes some of the 8
significant details of the emergency planning work that he or 9
people under his direct supervision have done relative to 10 SONGS including the on-going effort to further improve 11 offsite emergency planning and preparedness in response to 12 some helpful suggestions made by the Federal Emergency 13 Management Agency.
14 The central purpose of his testimony is to provide 15 the necessary perspective from which one can reasonably 16 assess:
the current adequacy of offsite emergency planning 17 and preparedness; the significance of the concerns and 18 suggestions that have been expressed by FEMA; and the 19 sufficiency of the on-going efforts to maintain and improve 20 offsite emergency planning and preparedness to a level that 21 provides reasonable assurance that the public health and 22 safety can and is being protected.
23 Mr. Murri's testimony is supported by nine 24 exhibits, identified as Exhibits ELM-1 through ELM-9.
An 25 explanation of these exhibits provides a useful summary of 26 Mr. Murri's testimony and the purposes for which it is 43
~ - - - - - - - - - -..
._ ~
z.
1 offered.
2 Exhibit ELM-1 consists of a summary of instances 3
wherein large-scale evacuations of people have been conducted 4
and documented.
This exhibit demonstrates that large numbers 5
of people have been..d can be evacuated in a safe, orderly 6
and timely manner if and when the need for such evacuation 7
arises, even in the absence of the detailed evacuation 8
planning that has already been accomplished in area around 9
10 Exhibit ELM-2 is the Environmental Protection 11 Agency " Manual of Protective Action Guides for Protective 12 Actions for Nuclear Incidents".
This manual, identified as 13 EPA-520/1-75-001 and dated September, 1975, provides the 14 guidelines and rationale for implementing protective actions 15 such as evacuation or sheltering as measures to minimize or 16 reduce the radiation doses to members of the public in the 17 event of a serious nuclear incident.
These guidelines were 18 used extensively in the development of the SONGS and offsite 19 agency emergency response plans and procedures and are 20 extremely instructive in the considerations involved in 21 formulating protective action decisions.
22 Exhibit ELM-3 is a summary of factors and 23 considerations to be taken into account if the need should 24 arise to recommend either sheltering or evacuation or a 25 combination thereof as protective measures to minimize or 26 reduce the radiation doses to members of the public in the 44
'\\
I event of an emergency at SONGS.
These factors, including 2
type and magnitude of radioactive ma*orial release, 3
anticipated duration of release, time estimated to effect an 4
evacuation and existing meteorological conditions, must all 5
be considered by the decision makers at the time the 6
emergency occurs.
7 Exhibit ELM-4 describes the program which is now in 8
prcgress for the review, revision and development of the 9
Standard Operating Procedures (" SOPS") necessary to implement 10 the emergency plans of each of the offsite agencies.
Most of 11 the concerns previously expressed by FEMA, as discussed in 12 detail in my exhibit ELM-9, will be resolved by the 13 development of formal-SOPS that describe the emergency 14 response functions of the offsite organizations in greater 15 depth than is contained in the basic emergency plans that 16 were reviewed and evaluated by FEMA.
The training program 17 described in exhibit ELM-7 is, of course, an integral part of 18 the SOP development effort.
19 Exhibit ELM-5 identifies the organizations and the 20 key individuals within each organization that were contacted 21 by Mr. Murri or NUS personnel under his direct supervision 22 during the course of assisting Applicants and the offsite 23 agencies in the development of their emergency plans.
24 Exhibit ELM-6 summarizes and presents in a 25 chronological order many of the significant events that 26 occurred during the full-scale exercise conducted at SONGS on 45
s 1
May 13, 1981.
This log of events, which is presented in a 2
matrix format, illustrates not only the overall excellent 3
coordination among the various Applicants and offsite 4
emergency response centers, but also points out areas where 5
improvements needed to be made in the collective and 6
individual agency emergency planning effort.
The latter 7
aspect was a major objective in conducting the exercise -- to 8
identify and correct deficiencies.
Steps have been taken or 9
are underway for completion prior to February 1, 1982 to 10 remedy each significant deficiency noted by FEMA or other 11 participating organizations as a result of the exercise.
12 Exhibit ELM-7, as previously m'entioned, describes 13 the program which was established and is now in progress to 14 provide training for offsite agency personnel on the newly 15 developed and/or revised SOPS.
This training includes dri..ls 16 and exercises that allow the participants to demonstrate the 17 capability to perform the new or revised functions and ensure 18 the proficiency to carry out those functions in an emergency.
19 Exhibit ELM-8 is a cross reference which identifies 20 the location within each of the six offsite agency emergency
(
21 plans where applicable evaluation criteria of NUREG-0654 are 22 addressed.
It should be recognized that, due to varied and 23 sometimes limited involvement of some gf the agencies, not l
24 all of the NUREG-0654 and evaluation criteria are applicable 25 to each of the agencies.
Furthermore, many of the evaluation 26 criteria are, or will be, more fully satisfied by material i
46 I
l
I contained in the agency SOPS.
2 Exhibit ELM-9 is Mr. Murri's finding-by-finding 3
response to the comments contained in the FEMA /RAC Review 4
Comments.
This informal review contained a large number of 5
FEMA comments.
However, many of the comments were 6
repetitious among the various jurisdiction plans.
Thus, the 7
actual number of FEMA concerz was significantly less than 8
the cumulative number of comments listed in the informal 9
review.
Many of the FEMA questions would have been answered 10 and the corresponding comments unnecessary if the SOPS in 11 existence at that time had been included in the review.
Most 12 of the other comments, not resolved by previously existing 13 SOPS, can be readily resolved by the development of some 14 additional SOPS and conducting training on those documents as 15 described in exhibits ELM-4 and ELM-7, respectively.
The l
16 level of effort to complete the development of all the 17 necessary SOPS is about 20 to 30 man-days per jurisdiction, 18 depending on the scope of the specific jurisdiction's 19 involvement.
This SOP development work is now in progress 20 and will be completed by about November 15, 1981.
The 21 corresponding training program, including demonstration of 22 proficiency, for the offsite agency personnel has begun and 23 will be completed by February 1, 1982.
24 Mr. Murri states that despite the FEMA findings, 25 the individuals with whom he and other NUS representatives 26 have dealt have demonstrated the utmost competence and i
47 i
1 sincerity in achieving appropriate and workable emergency 2
planning relative to SONGS.
The FEMA Findings, together with 3
the May 13 exercise, identified some areas where improvements 4
should be made, primarily through additional SOPS and 5
training thereon.
Applicants, with the assistance of NUS and 6
cooperation by the offsite agencies, are taking the necessary 7
actions to ensure that the offsite emergency response plans 8
and implementation capabilities are adequate in every aspect.
9 Mr. Murri concludes that there is reasonable 10 assurance that the state of offsite planning and 11 implementation capability is adequate to protect the public 12 health and safety in the event of a radiological emergency 13 requiring evacuation or other offsite protective action at 14 SONGS 2 and 3.
15 I.
Direct Testimony of Bryant T.
Brothers 16 Mr. Brothers is the Associate-In-Charge and Manager 17 of the Los Angeles office of Wilbur Smith & Associates 18
("WSA").
He is a registered professional civil engineer in l
19 the States of California and North Carolina.
Mr. Brothers 20 has a Bachelor of Science ir ivil Engineering and a Master 21 of Science in Transportation Engineering.
His previous 22 studies have encompassed traffic estimation, highway capacity 23 analysis, traffic flow theory, computer modeling of traffic 24 flow with capacity restraints, traffic operations and control 25 and traffic planning.
For the last twelve years he has been 26 a consultant concerned with transportation engineering l
48
{
l 1
problems and has conducted numerous transportation 2
engineering studies.
3 WSA is a multi-discipline consulting engineering 4
and planning firm specializing in all aspects of 5
transportation planning, research engineering and design.
6 WSA was engaged in 1973 by the Applicants to conduct a 7
feasibility study for the development of an evacuation plan 8
for the area surrounding SONGS.
This study became the basis 9
for WSA testimony in the construction permit phase of this 10 proceeding.
Since 1979, WSA has been retained by the 11 Applicants to expand the then existing evacuation plans and 12 evacuation time estimates to comply with current regulatory 13 requirements.
Mr. Brothers has been responsible for the 14 overall management and supervision of all WSA work related tc 15 the development, revision and review of evacuation plans and 16 evacuation time estimates for the resident and transient 17 populations within the SONGS vicinity.
18 Mr. Brothers' testimony addresses Contention 1, 19 the evacuation contention, and Contention 3, which concerns 20 the size of the plume exposure emergency planning zone.
21 Mr. Brothers testimony describes the evacuation time estimate 22 studies performed by WSA for Applicants and the evacuation 23 planning performed based on these studies.
24 With respect to Content'on 1, Mr. Brothers' 25 testimony describes the process undertaken by WSA in 26 developing the evacuation plans and time estimates.
This 49
I work included meetings and coordination with the Counties, 2
the Cities, CALTRANS, the California Highway Patrol, the 3
District, State Parks, the USMC, Red Cross and other 4
organizations and agencies which would be involved in any 5
evacuation of the area around SONGS.
Preparation of the 6
evacuation plans involved assignment of evacuation routes for j
7 the population within each area; consideration of traffic 8
control and diversion measures; identification of the numbers 9
and distribution of the population around SONGS; 10 identification of those institutions and population elements 11 which require transportation assistance and the resources 12 available for this purpose; identification of reception and 13 care centers outside the EPZ and the assignment of EPZ 14 populations to the centers; and the identification of 15 potential locations at which disruption of the primary 16 evacuation routes could possibly occur and the effects of 17 these upon the evacuation.
18 Mr. Brothers describes how the various evacuation 19 plans are coordinated by the affected county and local 20 emergency response agencies in the form of the Interagency 21 Agreement and Evacuation Procedure for the San Onofre Plume 22 Exposure Pathway Emergency Planning Zone, December 1980 (tue 23 "IAEP"), Exhibit BTB-1.
24 Mr. Brothers' testimony identifies the primary and 25 secondary evacuation routes and the manner in which those 26 persons whose mobility may be impaired may be protected and 50
_ ~
O I
the manner in which transients will be evacuated and informed 2
of evacuation plans.
The Orange County Transit District and 3
the Capistrano Unified School District have 400 and 55 buses, 4
respectively, which could to be used to aid in evacuation.
5 In addition, there are 11 licensed ambulance agencies with 6
approximately 62 ambulances available to aid in the event of 7
an evacuation.
8 Mr. Brothers explains that abnormal roadway 9
conditions caused by adverse weather, natural disasters, or 10 major traffic accidents have been considered in the 11 evacuation plans and identifies the available emergency 12 public assistance which could be called upon following an 13 evacuation notification in the form of medical assistance, 14 fire protection, transportation assistance, and law 15 enforcement.
16 Mr. Brothers presents the results of the evacuation 17 time estimate studies and describes the use that would made 18 of the evacuation time estimates by the decision makers in 19 deciding whether to shelter or evacuate the population.
If 20 the nature of a release indicated higher radiation levels
~
21 than safe for sheltering, evacuation would be ordered if 22 there were sufficient time to evacuate the population.
The 23 evacuation time estimate study divides the plume EPZ into 24 sectors so that decision makers can determine how long it 25 would take to evacuate various segments of the population 26 within the EPZ.
51
1 The methodology used in the evacuation time 2
estimate study meets the requirements of Appendix 4 of 3
Mr. Brothers describes how the approach used 4
more accurately reflects actual time estimates than other 5
available approaches.
The approach used considers various 6
components, such as receipt of notification, return home, 7
departure from home, and evacuation travel time, in 8
determining the total time required for evacuation.
The 9
evacuation time estimates do include response and 10 mobilization time for those who do not have access to private 11 automobile transportation and include separate estimates for 12 adverse weather conditions.
13 Mr. Brothers' testimony describes a number of 14 changes in evacuation routes made by the local agencies 15 following the completion of the evacuation time estimates and 16 notes that these changes do net have any appreciable impact 17 on the evacuation tima estimates.
Mr. Brothers does t
18 conclude, however, that if ce tain populations now assigned 19 by local evacuation plans to the Pacific Coast Highway were 20 shifted to Interstate 5, as has been recommended by WSA, the 21 current evacuation time estimate of 6.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> for the l
22 Extended EPZ would be reduced to 3.75 hours8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br />.
Mr. Brothers i
23 also describes a number of conservative assumptions upon 24 which the evacuation time estimate study is based.
These 25 include the fact that the time estimates represent the peak 26 population conditions which could be expected under each 52 i
l
1 evacuation scenario; that the population assumptions reflect 2
no prior, spontaneous evacuation of residents or transients 3
prior to the public notification to evacuate; that no 4
assumption is made concerning preparation for evacuation; 5
that it is assumed that all populations would evacuate beyond 6
the extend EPZ; and all evacuation routes are operated in the 7
normal direction without any use of one-way operation or 8
roadway shoulder areas.
9 Mr. Brothers concludes that the evacuation time l
10 estimates study and the currently existing evacuation 11 planning for the extended EPZ complies with the applicable 12 NRC regulations and NUREG-0654.
13 With respect to the Contention 3, involving the 14 determination of the size of the EPZ, Mr. Brothers explains 15 that the applicable NRC Regulations require evacuation 16 planning and time estimates for full or partial evacuation of 17 the plume exposure pathway emergency planning zone which 18 includes an area within an approximate lO-mile radius of 19 SONGS taking into consideration local emergency response 20 needs and capabilities as they are effected by such 21 conditions as demography, topography, land characteristics, 22 access routes, and jurisdictional boundaries.
A simple 23 10-mile radius around SONGS encompasses all or a portion of 24 the Cities of San Clemente and San Juan Capistrano, the 25 unincorporated area of orange County knowr. as Capistrano 26 Beach and Dana Point, as well as the northern section of the 53
1 United States Marine Corps Base, Camp Pendleton, including 2
lands leased by the State Parks.
Although the lo-mile radius 3
actually bisects San Juan Capistrano and Dana Point, the 4
entire area and popu'.ations of these communities were 5
included within the EPZ in considering evacuation planning 6
and evacuation time estimation.
This expanded planning area 7
is referred to in Mr. Brothers' testimony as the " Extended 8
EPZ".
9 J.
Testimony of Keith Wociard 10 Mr. doodard is a senior consultant for Pickard, 11 Lowe & Garrick.
He has a Bachelor of Arts Degree in Physics, 12 and a Master of Science Degree in Nuclear Eng'neering.
He 13 has completed post-graduate courses in nuclear reactor theory 14 and reactor design and safety analysis.
He previously was 15 employed.by the United States Atomic Energy Commission as a 16
" project leader" in the Division of Reactor Licensing 17 responsible for safety analysis and evaluation of nuclear 18 power and research reactors.
He has been involved in the 19 development of computer models for establishing environmental 20 monitoring programs and for performing site evaluations and 21 has been directly responsible for supervision of atmospheric 22 dispersion analyses in support of over 40 applications for 23 approval of power plant sites, weather towers, major 24 atmospheric dispersion field experiments, and other field 25 measurement programs.
He has been qualified to submit expert 26 testimony on reactor siting, safety, and accident analysis in 54
I three proceedings related to nuclear power plants during the 2
last five years.
3 Mr. Woodard's testimony addresses Contention 3, 4
which deals with the determination of the size of the plume 5
exposure EPZ, with particular attention to the results of a 6
study performed by Science Applications, Inc. (the "SAI 7
Report").
8 Mr. Woodard generally explains that a probabilistic 9
rink assessment, such as the SAI Report, deals with (1) plant 10 analysis to determine the frequency of core melts in areas 11 leading to plant damage categories; (2) containment analycia 12 to determine the conditional frequency of each release 13 category given that plant damage of a particuler type 14 occurred; and (3) consequence analysis to determine the 15 conditional frequency of doses, health effects, and other 16 damages, given that a particular release category has 17 occurred.
He also explains the use of the CRAC computer code 18 as a basic tool for assessing such consequences.
19 Mr. Woodard explains the basic planning rationale 20 of the NRC in establishing the generic plume exposure EPZ at 21 ten miles.
By examining conditional probability vs. distance 22 considerations, the NRC determined the distance from the l
23 reactor within which emergency planning would have a 24 reasonable probability of reducing significant injuries.
An 25 analysis which appears in NUREG-0396 indicates that little 26 benefit is gained in terms of injury reduction if immediate 55
1 emergency reactions are taken beyond about ten miles.
2 Moreover, if the planning zone is as large as about ten 3
miles, sufficient resources would already be available to 4
support an emergency response'beyond ten miles if necessary 5
given the actual conditions of a particular accident 6
situation.
7 Mr. Woodard explains that the SAI Report actually 8
shows that the SONGS Plume Exposure EPZ is actually larger 9
than required by planning ationale set forth in NUREG-0396.
10 This is because the probability of exceeding whole-body doses 11 given a core melt accident at any given distance is 12 significantly lower for SONGS than for the sites used by the 13 NRC in making its generic study.
Thus, the results of the 14 SAI Report show that the NRC planning rationale is 15 conservative for SONGS.
Moreover, based on the data in the 16 SAI Report, the probability of core melt accidents for SONGS 17 is found to be the same as the probability of core melt 18 accidents used as the basis for establishing the NRC 19 regulations.
Thus, Mr. Woodard concludes that the SAI Report 20 supports the conservatism of the NRC regulations as applied 21 to the SONGS plume exposure EPZ.
22 Mr. Woodard explains that commencing in August, 23 1980 his opinion verifying the conservatism of the NRC 24 Regulations, as applied to SONGS, has been made known to the l
25 emergency planning officials in Orange and San Diego Counties 26 by himself and those who have assisted him in his analysis,o r 1
56 l
1 the SAI Report.
His opinion has also been submitted by 2
Applicants to the State OES with copies provided to the 3
Chairmen of the Board of Supervisors for both San Diego and 4
Orange Counties.
5 Finally, Mr. Woodard states that the application of 6
the CRAC computer program used by SAI uses the particular 7
meteorological, demographic, and topographic conditions in 8
the SONGS vicinity in a conservative manner, and that if 9
actual meteorological data, terrain conditions, and 10 population distribution information had been more vigorously 11 accounted for in the SAI Report, lower doses and fewer 12 consequences would be expected.
13 Mr. Woodard concludes that the local conditions of 14 topegraphy, meteorology, demography, land characterisics, and 15 the SAI report have been conservatively considered in the 1G establishment of the SONGS plume exposure EPZ.
17 K.
Testimony of Gary Re 18 Gary Re is employed as a Health Physicist by Dames 19
& Moore and is the principle author of the baseline 20 environmental study prepared by Dames & Moore for the 21 Applicants entitled " Final Report, Technical Studies, 22 Ingestion Pathway Zone Emergency Response Planning," Exhibit l
23 GR-1.
i l
24 Mr. Re has a Bachelor of Science Degree in Nuclear 25 Engineering and a Masters of Science Degree in Envircnmental 26 Health (Radiological Health) Sciences.
He has been engaged 57
1 in radiation related work for Dames & Moore during the past 2
four years.
3 Mr. Re's testimony addresses Contention 2.J. with 4
respect to the methods, systems and equipment for assessing 5
and monitoring actual or potential offsite consequences of a 6
radiological emergency condition within the ingestion pathway 7
The primary purpose for Mr. Re's testimony is 8
to authenticate the Dames & Moore study, Exhibit Gr-1, which 9
provides quanitative inf.srmation in the following areas:
10 Identification of primary food pathways around SONGS; farm 11 commodity components; agricultural land use acreages; 12 agriculture production by county; cattle feed -- estimated 13 sources and consumption patterns; major open water 14 reservoirs; and sea food production near SONGS.
A map, at 15 page 7 of Exhibit GR-1, shows land use patterns including 16 rangeland; cropland and pasture; orchards, groves and 17 vineyards; confined feeding operations and reservoirs and 18 lakes 19 The technical basis for the formulation of counter 20 measures to prevent the uncontrolled ingestion of potentially 21 contaminated water and food supplies is also contained in 22 Exhibit GR-1.
The data included in Exhibit GR-1 provide SCE 23 with a methodology for defining the extent to which potential 24 radiological contamination could occur in the event of an 25 accident and the technical basis for the development of 26 procedures for assessing, monitoring and recommending 58
1 counter-measures to offsite assistant agencies in order to 2
prevent or mitigate adverse health effects to the population.
3 L.
Direct Testimony of David F.
Filmer 4
Mr. Pilmer is Supervisor of the Health Physics and 5
Emergency Planning Group of the Nuclear Engineering and 6
Safety Section of SCE.
He received a Bachelor of Science 7
Degree in Chemical Engineering in 1961 from Stanford 8
University, completed the nuclear power training program in 9
the Navy and received a Masters of Science Degree in Nuclear 10 Engineering from the California Institute of Technology in 11 1969.
He is a registered professional engincer in the State 12 of California.
13 Mr. Filmer has been employed by SCE since 1969 in 14 its Nuclear Engineering Department and has worked on the 15 project to construct and operate SONGS 2 and 3 since that 16 time.
In his present capacity, he supervises the activities 17 of three engineers in the preparation of emergency plans and 18 procedures for SONGS 2 and 3 and related activities.
19 Mr. Filmer's testimony provides a general history 20 of onsite and offsite emergency planning for SONGS and 21 specifically addresses Contentions 1, 2.A.,
2.H.,
2.I.,
2.J.,
22 2.K.,
and 3.
He also describes the steps taken or planned by 23 Applicants in response to the FEMA Findings and the FEMA 24 Exercise Evaluation.
25 Emergency planning at SONGS commenced in 1963 in 26 connection with SONGS 1.
This planning effort has continued s
59
1 as regulatory requirements evolved and as the planning for 2
SONGS 2 and 3 progressed.
The present SONGS onsite emergency 3
plans were written to comply with the NRC Regulations.
4 Offsite emergency planning commenced in 1965 with 5
the adoption of an emergency plan for Camp Pendleton.
In 6
1975 radiological emergency response plans were developed by 7
the State of California, the Counties, State Parks and the 8
City of San Clemente.
These plans have been revised and 9
further developed to meet the NRC Regulations and the 10 criteria recommended in the NUREG-0654.
With the exception 11 of the draft State of California plan, the revised versions 12 of the other emergency plans have been adopted and 13 implemented by the appropriate governing bodies and found to 14 be minimally acceptable by FEMA.
SCE has assisted the 15 jurisdictions in developing, revising and coordinating their 16 emergency plans.
SCE has also provided assistance in the 17 form of its own employees and consultants and has provided 18 direct funding, labor and materials where required.
l 19 With respect to Contention 3, Mr. Filmer's 20 testimony traces the development of the plume exposure EPZ.
21 SCE established a boundary for the EPZ based on appropriate 22 regulatory guidance.
The most important factors considered 23 in making the recommendations were the probabilities and 24 consequences of the accident sequences studied by the NRC; 25 atomspheric dispersion characteristics, including terrain 26 effects and locel meteorological statistics; and local 60 l
1 demography.
Because the first two factors were considered 2
more favorable than those considered by the NRC in 3
NUREG-0396, and the third was similar to population density 4
used in NUREG-0396, it was concluded that the plume exposure 5
pathway EPZ need not be larger than ten miles.
Using th'at 6
guidance it was noted that north of SONGS, San Juan Creek 7
provided a highly distinctive boundary between residential 8
communities and was just about ten miles from SONGS from 9
where it passes the beneath Ortega Highway until it 10 terminates in the ocean.
In all other directions, since no 11 other other populated areas were about ten miles from SONGS, 12 the boundary of the EPZ was determined in all other arcas to 13 be simply a ten-mile radius.
Only an area of less th.an half 14 square mile which is the only portion of Riverside Co.tntf 15 within the ten mile boundary was excluded from the EPZ 16 because of the remoteness and the jurisdictional boundary of 17 Riverside County.
With the boundary drawn in the manner 18 described, Dana Point is entirely outside the EPZ and the 19 Capistrano Beach area is entirely inside the EPZ.
The City 20 of San Juan Capistrano is divided by San Juan Creek into 21 areas both within and outside the EPZ.
22 SCE's definition as described above was discussed 23 with and approved by the local planning officials for Orange 24 County and San Juan Capistrano.
Other jurisdictions around 25 SONGS were not in anyway affected by the boundary chosen for 26 the EPZ.
Moreover, evacuation time estimates and evacuation 61
1 planning has included all of the City of San Juan Capistrano 2
and Dana Point and the sirens being installed as part of the 3
Prompt Alerting System will be audible in these communities 4
although at levels less than the federal standard for areas 5
in the EPZ.
Thus, with the exception of the siren sound 6
level, the emergency planning does cover all populated areas 7
within about twelve mile radius of SONGS.
8 With respect to Contention 2.A.,
Mr. Filmer 9
describes the installation of a dedicated telephone system 10 known as the Interagency Telephone System ("ITS").
This 11 system, which is operable at all times, provides primary 12 communications between SONGS, the Counties, the Cities, USMC, 13 State Parks, and the California Highway Patrol.
The ITS may 14 be used to contact specific jurisdictions or all 15 jurisdictions simultaneously.
16 In the event of an emergency at SONGS, the 17 Emergency Coordinator contacts SCE's Energy Control Center 18
("ECC") which is responsible for notifying SCE's Corporate 19 Radiological Emergency Support Organization ("ESO") and the 20 State Warning Center-in Sacrament If the ITS is 21 unoperable, the ECC is staffed -t all times and has available 22 primary and backup communications systems for the 4
23 notification of all involved offaite emergency response 24 organizations.
25 With respect to Contention 2.I.,
Mr. Filmer's 26 testimony describes SCE's Corporate Radiological Emergency i
62
t I
1 Response Procedure and the operation of the interim Emergency 2
Operations Facility (" EOF").
The ESO augments the activities
]
3 of SONGS onsite management and personnel for emergencies 4
(except those classified as an " Unusual Event").
This j
5 includes senior management and technicci specialists which 6
can provide emergency services to the onsite emergency 7
organization and offsite local government organizations.
The 8
ESO is responsible for the operation of the offsite Emergency 9
Operations Facility (" EOF").
While a permanent EOF is being 10 designed, emergency facilities have been established to 11 fulfill the functional equivalent of a permanent EOF using 12 existing onsite and offsite facilities.
These include the i
13 Emergency Support Center (" ESC") at SONGS; the interim EOF at 14 the San Clemente City Hall, the Emergency Media Center i
15
("EMC") in San Clemente, and the SCE General Office in 16 Rosemead, California.
Using these facilities, all onsite and 17 offsite emergency response activities are monitored and 18 action initiated as required.
19 The EMC provides contact with the news media and 20 the personnel at SCE's General Office and they coordinate 21 additional support activities within SCE and throughout the i
22 utility industry.
23 The EOF is' operational following declaration of a 24
" Site Emergency" or " General Emergency."
The EOF functions 25 as the center of information for decision making and 26 coordination of decisions requiring of an offsite response to 63
1 an emergency period.
2 With respect to Contention 2.H., Mr. Filmer's 3
testimony describes the operation of the Offsite Dose 4
Assessment Center ("ODAC") which is set up at the EOF 5
following declaration of a " Site Emergency" or " General 6
Emergency."
The ODAC functions as the technical offsite 7
crater for coordination of radiological and environmental 8
assessments and is staffed with representatives of SLZ as 9
well as other response agencies.
The ODAC interprets, 10 displays, summarizes and disseminates to offsite agencies 11 data received from both onsite and offsite sources.
It is 12 responsible for providing all offsite agencies with current 13 status reports.
14 In discussing Contention 2.J.,
Mr. Filmer's 15 testimony addresses the efforts underway for assessing and 16 monitoring actual or potential offsite consequences of a 17 radiological emergency with respect to the ingestion pathway 18 emergency planning zone.
While the State of California is 19 primarily responsible in this area, it may rely on SCE and 20 various federal agencies for support.
Accordingly, SCE has 21 had a baseline study of the ingestion pathway zone prepared 22 nnd has developed a draft emergency response plan and 23 implementing procedures for the 50-mile ingestion pathway 24 around SONGS.
The baseline study, which is Exhibit GR-1, 25 provides descriptions of all the basic food stuffs grown 26 within the ingestion pathway EPZ and provides the technical 64
-~.
I bases for the ingestion pathway emergency response plan and 2
related implementing procedures.
3 The baseline report and the plan and procedures 4
being developed will met the applicable regulatory 5
requirements with respect to the ingestion pathway, although 6
individual farms, diaries, processing plants, water supply 7
intakes and treatment plants out to fifty miles and food 8
processing plants beyond fifty miles that process food 9
originating within the ingestion pathway have not been 10 specifically identified.
By conservatively estimating the 11 potentially effected area and notifying responsible State and 12 county health and agricultural officials, the distribution 13 and consumption the water and food stuffs originating in the 14 area so identified may be halted until sampling teams and 15 related laboratory analysis have determined that 16 interdiction, product diversion, or decontamination processes 17 for such wrter or food stuffs is unnecessary.
18 The State of California has prepared a draft plan 19 for the ingestion pathway which is generally consistent 20 ingestion pathway plan being developed by SCE.
SCE is 21 working with the State and the involved counties in l
22 developing the ingestion pathway pl4n to insure consistency.
23 The work necessary to complate ingestion pathway implementing i
24 procedures should be completed by October 1, 1981.
i a
25 With respect to Contention 2.K. which involves 26 Leentry and recovery, Mr. Filmer's testimony explains that an 65
~
u
1 onsite recovery organization will be formed with resources 2
provided depending on the nature of the recovery operations.
3 These resources may be augmented by resources from throughout 4
the industry, consultants, and engineering firms.
The 5
offsite recovery organization will be formed by SCE anc 6
local, state and federal agencies and will operate out of the 7
EOF.
The first function is to determine what land areas are 8
contaminated and which are not contaminated and maybe 9
rehabitated.
Areas where contamination does exist will then 10 be decontaminated.
11 Finally, Mr. Filmer's testimony addresses 12 recommendations made by FEMA with respect to offsite 13 emergency plans and the general state of preparedness to 14 implement such plans.
The May 13, 1981 exercise served as a 15 useful training function and served to reveal areas that 16 could be improved.
Areas noted for improvement include 17 improved EOF operations, improvement of ODAC capabilities, 18 improvement of interjurisdictional communications, t
19 improvement of coordination and function of freeway closures, 20 and improvement in accuracy of communicating and depicting 21 meteorological conditions.
Efforts to improve the areas 22 noted are already underway and include the formation of an l
23 Interjurisdictional Planning Committee ("IPC") to coordinate 24 and expedite emergency planning activities.
The IPC has met 25 on several occasions and has determined to develop standard 26 operating procedures to govern response activities in a 66
e
~
1 number of important functional areas including operation of 2
ODAC, radiation surveys by field monitoring teams, emergency 3
communications, use of the siren alert and public 4
notification system, coordination relating to protective 5
actions, agquisition, display and use of meteorological data, 6
operation of the EOF, and ingestion pathway monitoring.
The 7
IPC will also develop training to improve proficiency in 8
these areas.
9 10 V.
11 CONCLUSION 12 Applicants submit that the foregoing testimony and 13 related exhibits, taken together with the testimony and 14 exhibits to be provided by Applicant's subpoenaed witness, 15 provide substantial, if not overwhelming, evidence that there 16 now exists a state of onsite and offsite emergency 17 preparedness that provides reasonable assurance that adequate 18 protective measures can and will be taken on behalf of the 19 expected transient and permanent populations in the event of 20
///
21
///
22
///
23
///
24
///
25
///
26
///
67
r 1
a radiological emergency at SONGS 2 and 3, as required by 2
applicable NRC Regulations.
3 4
Dated:
August 24, 1981 5
Respectfully submitted 6
DAVID R. PIGOTT EDWARD B.
ROGIN 7
SAMUEL B. CASEY JOHN A. MENDEZ 8
Of ORRICK, HERRINGTON & SUTCLIFFE A Professional Corporation 9
10 CHARLES R.
KOCHER JAMES A.
BEOLETTO 11 SOUTHERN CALIFORNIA EDISON COMPANY 12 13 By
/s/ DAVID R.
PIGOTT David R.
Pigott 14 One of Counsel for Applicants 15 16 17 18 19 20 21 22 23 24 25 26 68
=.
-