ML20033B894
| ML20033B894 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 11/20/1981 |
| From: | Mcclung C CARSTENS, A.S., GUARD |
| To: | |
| References | |
| ISSUANCES-OL, NUDOCS 8112020405 | |
| Download: ML20033B894 (70) | |
Text
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h 1
PHYLLIS M.
GALLAGHER, Esq.
00LKETED d
1695 W. Crescent Avenue, Suite 222 U%RC 2
Anaheim, CA 92801 81 NOV 27 P3i46 3
CHARLES E. McCLUNG,'JR.
FLEMING, ANDERSON, McCLUNG & FINCH M
4 24012 Calle de la Plata, Suite 330
- p g,;g7,.ny Laguna Hills, CA 92653
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0 UNITED STATES 00F AMERICA 9\\M Ms@'ou 9
NUCLEAR REGULATORY COMMISSION 10 BEFORE THE ATOMIC SAFETY AND LICENSIYGOftRg 11 12 13 In the Matter of
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Docket Nos. 50-361 OL
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50-362 OL 14 SOUTHERN CALIFORNIA EDISON
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15
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INTERVENORS' PROPOSED (San Onofre Nuclear
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FINDINGS OF FACT AND 16 Generating Station, Units 2 and 3))
CONCLUSIONS OF LAW ON
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EFERGENCY PLANNING AND 17
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PREPAREDNESS ISSUES.
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18
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19 TO THE ATOMIC SAFETY AND LICENSING POARD AND A4 '. PARTIES:
20 The -Intervenors. Guard and Carsten, et al. hereby submit to the Board pursuant to stipu!dtion contained on the record and 21 22 10 C.F.R. '2. 39 their proposed Findings of Fact, Conclusions of Law and conditions with respect to the above referenced licen' sing
- 24 proceedings.
5 Intervenors have attempted as much as possible to conform 26 in their citat.ons and abbreviations to the proposed findings and 27 conclusions cf law of the Applicant in order that they might be
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f 8112020405 Of1120 l/[
PDR ADOCK 05'100361 G
PDR II
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more easily helpful to the Board and the parties.
A 2
DATED:
Noverber 20, 1981.
3 4
Respectfully submitted, 5
6 PFVLLIS P.
GALLAGFER and CHAPLES E. McCLUNG, JR. of 7
FLEMING, ANDER.
N, cCLUNG & FISCH 8
By q
Clisrles E. McClling, Jr.
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 l
25 26 27
~
28
4 9
A 1
A.
CONTENTION No.l.
(Offsite Public Protective Action Capability).
2 "Whether the state of emergency preparedness for 3
SONGS 2 and 3 provides reasonable assurance that offsite transient and permanent population within 4
the plume exposure pathway emergency planning zone C.F.R.
S 50.47 (c) (2), for SONGS 2 and 3 can be 5
evacuated or otherwise adequately protected in the event of a radiological emergency with offsite 6
consequences occurring at SONGS 2 and 3 as required by 10 C.F.R.
S 50. 47 (a) (1), (b) (10) and Part 50, 7
Appendix E.IV.
8 9
I.
This contention while in general form is meant to test 10 the dffsite jurisdictions ability to take a range of protective 11 actions in the event of a radiological emergency.
This includes 12 the capability of choosing what action to take, a range of "trious 13 actions to take and the coordination between the various offsite 14 jurisdictions of such actions.
The underlying intent of this 15 contention asks whether or not the off aite jurisdictions can and 10 will be able to affect dose savings and limit injury to an 17 acceptable amount in the event of a radiologica' emergency with 18 offsite consequences.
This contention refers to 10 C.F.R.
S50.47 19 (b) (10) which is supplemented by Section II.J of NUREG-0654.
20 1.
Implementation of protective actions 21 Q. Implementation of protective actions is addressed in NUREG-22 0654 II J9 and II J10.
Significant deficiency in the plani exdt.
23 Discussion of a range of protective actions and the basis for' 24 choosing between the various protective actions are deficient in 25 most of the plans according to the RAC Review and OES Review.
26 (Intervenor's Exhibits #13, 16, 17, 18, 19, 20 and 25.)
27 2.
Emergency Plans for Special Groups.
28
- 3. NUREG-0654 provides for special provision for special groups I
r
i I
who may be impaired in terms of mobility (NUREG-0654, II.J10-d).
2 The RAC review and the OES Review indicated that there were no 3
demonstrated capability' to execute <. aid to the handicapped.
4 (Intervenor's Exhibits #13,16, 17, 18, 19, 20 and 25.)
5 N.
NUREG J.10.E. provides that radio protective drugs should 6
be available to those who cannot evacuate immediately.
7 5.
RAC Review and oES Review found that these were not add-8 ressed in the plan.
(Intervenor's Exhibits #13, 16, 17, 18, 19, 9
20 and 25.)
10 6.'~ Testimony of Charles Deming from the California State 11 Department of Rehabilitation indicates that fully 7% of the 12 Population of the emergency planning zone is seriously disabled 13 meaning that they would have serious _.~ u.c
-.- i.
1 sensory or 14 motor disabilities which would severly impact functioning in the 15 case of emergency or evacuation situation.
(Fleming, Tr. 10112.,
16 Logue Tr. 1074 Ditty 9841, 9836.) Mr Fleming testified that there 17 would be necessary special vehicles and preparation for this 18 population to aid them in evacuation.
There would be need for 19 special care at the relocation facilities for these people.
20 (Fleming,- Tr. 10118.)
No plans exist in either respect.
21 7.
The applicants plans and that of the local jurisdictions 22 to insure evacuation of transients, special population and school 23 children rely on Orange County Transit District bus. s upport'.
The 2<4 only witness on this subject was Jan Goodwin,. Chairman of the 25 United Transportation Union Local 19, which is the union'for the 26 bus drivers in the Orange County Transit District,(Goodwin, Tr.
27 9984)
Ms. Goodwin indicated in her testimony that the drivers 28 were completely unaware of any emergency responsibility with dL
i i
4 1
respect to a radiological emergency.
That there are no plans in 2
place at the OCTD to provide the support outlined in the various 3
other planning documents, there have been no training programs for 4
drivers for what they should do in the event of a radiological 5
emergency and that significiant problems and delays could occur 6
in the deployment of busses due to lack of prior planning and 7
deficiencies in the communication system in deployment of the bus 8
drivers.
(Goodwin, Tr. 9885-9896.)
She also testified that 9
substantial number of drivers are women of childbearing age and 10 there is no provision for noting this in the dispatchers records.
11 (Goodwin, Tr. 9908.)
Small group homes for the elderly are not easily 12 13 identified.
Such homes are proliferating due to the high cost 14 of housing.
Some are licensed and some not.
(Ditty, Tr. 9843.)
15 9
The added time factor of anxiety, disorientation and 16 other kinds of mental states not conducive to orderly evacuation 17 would be expected in many of the elderly in.the event of a 18 nuclear accident.
(Ditty, Tr. 9850.)
19
/#.
A survey conducted by Intervenor's Witness, Carolyn 20 Logue, president of the South Orange County Community Service 21 Council, surveying 12 facilities (list of facilities Tr. 10,080) 22 of special populations found 11 had not been included in any 23 emergency planning,(Logue, Tr. 10078.)
24 l/.
Of the 11 sample facilities of the survey not included 25 in the planning, one R.H.
Dana for Handicapped had 74 disabled or 26 phy~sically handicapped, of which 35 students need special help in 27 transportation, such as wheelchair or non-ambulatory students, such 28 as 6 or 7 year old children of six months capacity intellectually b-
I 10057.)
andphysically.(Logue, I
Tr.
2 12.
The loading of buses via lifts and ramps is a slow proc-ess,extendingevacuationtimes.(Logue, Tr.10057.)
3 4
16 Mobilization time is a crucial consideration in choice of 5
protective actions by decisionmakers during a nuclear power plant 6
accident. (Murri, Tr. 7926.)
7 l'/.
An increase in mobilization time greater than one hour 8
would lengthen the evacuation times.
(Brothe rs, Tr. 8114.)
9 If.
No-consideration has been given to the existence of 10
" board and care" facilities within the Plume.
Exposure Pathway EPZ 11 in arriding at mobilization times.
(Brothers, Tr.8124).
12
/G.
The Board finds that the stage of emergency preparedness 13 of the response jurisdictions and th.e applicant does not provide 14 adequate identification of the numbers and locations of elderly 15 and handicapped who may require assistance, and consequently no 16 adequate estimate of the numbers or types of transportation 17 vehicles and personnel necessary for their protection.
18 17 Wilbur Smith Associates estimates peak summer beach 19 population: 19,600 daily, State Beaches; 22,000 daily, San 20 Clemente City Beaches; figuring 40% weekday utilization, 65%
2'.
present at any given time, Wilbur Smith sets transient tourist 22 population at 23,000 (Applicants' exhibit 123, Page.26 Table 2) 23
/6 county beaches and harbor populations were not shown by
.24 Wilbur Smith in population counts nor in timings.
25 li.
A second segment of transient population noted by Wilbur 26 Smith consists of out-of-town tourists and recreation orientated 27 visitors.
Dana Point Harbor and San Juan Capistrano Mission are 28 in a listing of tourist attactions, but population counts and Y'
1 timings are not shown.
(Applicants' Exhibit 132, page 25.)
^
2 2B.
There is inadequate transportation planning for the 3
Capistrano Unified School District, private and church schools who 4
need transportation: as shown by the School District's Emergency 5
Coordinator's testimony. (Swanson, Tr. 8793-96, 8813, 8803) 6 Wilbur Smith Study estimates " Evacuation of schools (public) beyond 7
the.: Eve mile boundary would require the use of Orange County Transi 8
District buses dispatched from central or northern Orange County.
9 Mobilization and travel time into the EPZ is estimated to take from 10 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 30 minutes for the Irvine OCTD facility to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and 11 30 minutes for buses from the Garden Grove OCTD faility.
12 (Applicants Exhibit #132, page. 58) 13 Z/.
The planning for school populations is unrealistic in.
14 the base assumption that parents will evacuate, leaving their 15 children in hope that the children may be bused out three to four 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> later, when in a fast moving accident the plume could be 17 over the area before the decisionmaking and alerting had taken 18 place.
2.
Purpose of Evacuation time estimates 19 12' Purpose of evacuation planning was set forth by NRC 20 Witness, Brian Grimes as " removal of individuals from a particular 21 area with the objective of removing them prior to exposure to 11021.)
22 radiation."(Grimes, Tr.
23 13.
In requ' ing m assessment of local jurisdictions r
24 capability to respond, the board realizes that any analysis of 25 adequacy of manpower, equipment and roadways is also meaningless 26 unfess it is measured against a time critera.
Obviously the 27 available personnel and material are adequate to evacuate the 28 public of the EPZ over some extended time period; that adequacy is S.
^
1 not the issue.
The issue is whether evacuation can be 2
accomplished in such a way that the public is protected, which 3
means within some reasonable time span, in which damaging doses i.
4 of radiation can be avoided.
5 2Y.
Accurate time estimates are an essential element of an 6
acceptableplan.(NUREG-0654,J-II.0.1.10C.F.R. Part 50 7
AppendixIV.)
8 N.
The purpose of these estimates is to " identify to all 9
concerned those instances to which unusual evacuation constraints 10 exist and where sp :ial planning measures should be considered. "
11 NUREG-0654 Appenix 4-2.
12 The time required for confirmation was not included in 13 Wilbur Smith Study (Applicants' Exhibit 132) and confirmation is 14 essential component of evacuation time, to assure. reasonable 15 protection.
16 27.
Further no practical method of confEmation of 17 evacuation has been evolved, no estimates of number of manpower 18 needed is given in any plan.
19 77 Orange County plan designates "a brightly colored cloth' 20 to indicate an evacuated residence.
(Applicants' Exhibit #53 p.V3.6) 21 79.
San Clemente Plan includes instructions to residents to 22 tie a cloth to the door which is visible from the street.
"A 23 white cloth will signify resident has received notification and no 24 help is needed.
A red or orange colored cloth will signify 25 receipt of notification and need of assistance to evacuate."
26 (Applicants' Exhibit 55, p.VII26.)
27 30 No reasonable assurance can be given that residents will' 28 i:now what color cloth to use, will have that color cloth, will use h.
i l
t I
the cloth in the haste of evacuation, and that conflicts in the 2
plans could cause confusion and lengben evacuation plans.
3 3I.
It ic noteworthy that the " principle response officials 4
of San Clemente and State Parks, (San Clemente Director of 5
Emergency Services and State Parks Pendleton Coast Area Manager) 6 did not record their agreement with the estimates when questioned 7
on the record. (Stowe, Tr.8534:)..Convalho, Tr. 105791) 8 3 7-.
A delay in decision making regarding appropriate 9
protective action can be expected where plans have not been made 10 for dealing with an accident, but must be adapted to provide a 11 protective response for an unexpected accident.
(Murri, Tr. 7908) 12 83.
Another factor leading to delay in deciding on the 13 appropriate protective actions to be taken is the difficulty of 14 tracking the plume.
The plume would be sought within a thirty 15 mile circumference-using off-road vehicles by a three teams of 16 two persons each.
Since the terrain is hilly and rugged, wind 17 directions are subject to sudden shifts and variations.
(Barr, 18 Tr.7631, 7627) 19 3y.
The Wilbur Smith and Associates Study did not do a time 20 estimate of the time it would take to evacuate the area which is 21 within the Plume Exposure Pathway EPZ off-shore.
(Brothers, Tr.
22 8193) 23 K.
Evacuation time estimates are a tool for decisionmakers 24 who will be evaluating.the choice of protective actions to be taken 25 concerning the lead time necessary to effect an evacuation prior 26 to a release.
(Brothers, Tr. 8206) 27 36 The Wilbur Smith and' Associates estimate that within 28 fifteen minutes of the notification to evacuate, 90% of the
i i
1' Population will have received notification, an assumption not a 2
conclusion based on the regulations.
(Brothers, Tr. 8109) 3 77 The Wilbur Smith and Associates estimate that 90%
4 of the people in the Plume Exposure Pathway EPZ would have 5
returned to their homes within twenty-seven minutes is based on 6
the assumption that the population which lives in the area also 7
works in the area.
(Brothers, Tr. 8110)
This assumption was not tested.(Brothers, Tr.8223.)
g 9
9f.
An. increase in mobilization time greater than onehour 10 would lengthen the evacuation times.
(Brothers, Tr. 8114) 11 74 Time estimates under normal conditions assume that no 12 roadways are physically blocked or unavilable to traffic.
13 (Brothers, Tr. 8123) 14 If there were an impediment requiring diversion of 15 traffic, the time estimate assumes that it would take a minimal 16 amount of time to implement such a diversion.
(Brothers, Tr. 8123) 17 V/.
If diversion must take place at:a traffic control
~
18 Point which is not manned by a traffic control of ficar, diversion 19 would take long.
(Brothers, Tr. 8121) 20 42.
The time for decisionmakers to decide what course of 21 action to take was lenghtened during the drill by communication 22 and coordination problems with other response agencies, including 23 line tieups by officials, the challenging of decisions, requdsts 24 for additional information, etc.
(Mechoat, Tr. 10051) 25
/5 Applicants have failed to demonstate that reasonable 26 assurance exists that the transient and permanent populations 27 within the plume exposure pathway EPZ can be evacuated or otherwise 28 ad.equately protected in the event of a radiological emergency with
(,
1 offsite consequences at SONGS 2 and 3.
2 4.
Unique Geographical Constraints.
3 44.
South Orange County is expected to double its population 4
in 10 years, impacting on adequacy of the single evacuation routes 5
(Carvadv Tr. 10,784).
San Clemente officials raised objection to 6
failure of the timing study to factor in future populations of 7
San Clemente cf four tracts which have already received preliminary 8
city approvals projecting 33,000 persons, a 120% increase over 9
city 27,325 current population.
(Carualho, Tr. 10,789, Mecham, 10 Tr.10030, 10,031.)
11 Of.
Lack of adequate evacuation routes was cited by San 12 Clemente officials, a timing consbaint and a barrier to adequate 13 evacuation planning.
Secondary evaquation routes are lacking and 14 the city's topographical unsuitability for a circulation plan in 15 the developed area, has added complications of roadway access of 16 lack of. frontage roads and traffic conjestion near the beach.
17 (Caryalho, Tr. 10,783, Bloom, Tr. 10,298, 10,301) 18 4h.
Existing County of Orange plans project no additional 19 north-south roads available for evacuation prbr to approximately 10,032)
(Mecham, 20 1995.
Tr.
21
@7.
A second evacuation route into the northerly sectors 22 (Foothill Corridor), or Easterly to inland areas through Camp 23 Pendleton (Christianitos) is needed in half that time. (Carvalho,
' 24 Tr. 10,784)
Camp Pendleton persists in prohibiting such a roadway 25 will not allow any off ramps into the backcountry.
(Bloom, Tr.
26 10255) 9'.
Freeway 5 will continue to be the primary evacuation rou s I
27 28 for the increasing population of San Clemente through approximately
1 1995.
Mecham, Tr. 10034.
2
'l f.
Additional constraint to evacuation alternatives is the 3
hilly-canyon terrain (northwesterly sectors), no frontage roads 4
along freeway, gated communities with one way ingress and egress, 5
and many narrow-not through streets, which present a maze in 6
which transient populations would have great difficulty finding 7
their way to the traffic directiond controls,at I-1 and Highway 10]
8 (Bloom, Tr. 10,285, 10,290, 10,884) 9
$ 0...
These issues are significant to the protection of the 10 public, and justify a re-assessment of evacuation timing.
11 f/.
No reasonable assurance of realization of new 12 evacuation routes can be provided within the next decade and there 13 is no reasonable assurance'that governmental constraints will 14 restrict populations from moving into the EPZ.
15 5Z.
The uniquely inadequate roadway directions and systems, 16 concentration of populations in the northwesterly EPZ, mountain 17 and ocean geographic or topographic conditions defying evacuation 18 potential and location in the fastest growing area of the United 19 states preclude a finding of reasonable assurance that the offsite 20 populations can be protected in.the event of a radiological 21 emergency.
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1 B.
CONTENTION 2F (Emergency Response and Augmentation s
Capability) 2 3
"Whether there is reasonable assurance that the emergency response planning and capability of 4
implementation for SONGS 2 and 3, affecting the off-site transient and permanent population, 5
will comply with 10 C.F.R. 550.47 (a) (1) and -(b) or (c) (1) as regards:
6 F.
the capability of each principal response 7
organization to respond and to augment this initial response on a continuous basis, 10 C.F.R. 8 S50.57 (b)_(1),,,
9 10 1.
Identi~fication of Offsite Response Organizations 53.
The planning standards contained in 10.
C.F.R. S50.47 11 12 differentiate between supporting and principal response 13 rganizations. Based on testimony and exhibits in this case, it is-14 possible to separate those response organizations which have decisionmaking aithority regarding protective measure actions and r
15 16 those organizations which support the decisionmaking organizations 17 in implementing the protective actions.
The first type of response 18 rganization is principal, and, the second type of organization is 19 supporting for purposes of meeting NRC requirements.
1.
Principal response' organizations for SONGS include:
20 21 Southern California Edison 22 The County of Orange 23 The County of San Diego -
24 The U.S. Marine Corps 25 The City of San Clemente 26 The City of San Juan _Capistrano
~
27 The State Parks 28 The School District II
I.
I
[6I.
Each of the principal response organizations identified 2
in the paragraph above, has the authority to make decisions on 3
protective actions for some segment of the populace in the event 4
of a radiological emergency.
Although each of these principal 5
response organizations has the authority to make independent 6
decisions regarding protective actions, coordination of their 7
respective decisions and implementation of the decisions in the 8
various jurisdictions, is necessary.
(Intervenor's Exhibit #13, 9
general comment 14; Intervenor's Exhibit #14 at II-6; Inte rvenor 's 10 Exhibit #15.)
11 12 2.
Capability of Principal Response Organizations to Respond and to Augment the Initial Responses 13 on a Continuous Basis 14 bl7 In reviewing the capability of principal response 15 organizations to respond initially and to augment this initial 16 response on a continous basis, FEMA used SectionsIIAand g6,of 17 NUREG-0654 to provide guidelines.
In general, the plans of the 18 counties of Orange and San Diego met the relevant guidelines, with 19 only minor exceptions noted.
(Intervenor's Exhibits #13, 16 and 11 20 17.)
b7 Both the RAC and~the State OES, however, found 21 22 deficiencies in the plans of San Juan Capistranof the State Parks.
23 Most importantly, none of these principal response organizations
.24 has the capability to respond on a 24-hour basis.
(Intervenor's 25 Exhibits #13, 19 and 25.)
26 ST.
In addition, FEMA, in its evaluation of the May 13, 27 1981 exercise, remarked on the problem of staffing for both the 28 City of San Juan Capistrano and the State Parks.
The evaluation h
I concludes that these staffing problems interfere with the response 2
organizations' capability to augment their initial responses.
3 (Intervenor's Exhibit #14.)
4 f1.
In order to address these staffing problems, FEMA 5
recommends that alternate key personnel be identified for the City 6
of San Juan Capistrano (Intervenor's Exhibit #14 at II-27.) and 7
that officials in adjacent jurisdictions consider supplementing 8
the staffing needs of the State Parks.
(Intervenor's Exhibi" #14 9
at II-33,34.)
10 f0 The " Action Plan" developed by the Applicants' to add-11 reus the concerns of FEMA (Applicants' Exhibit #144.) does not 12 address the response and augmentation limitations of the City of 13 San Juan Capistrano, the State Parks or the School District.
14 Accordingly, there is no reasonable assurance that these 15 principal response organizations have the necessary capability to 16 respond and to augment their initial response in the event of a 17 radiological emergency at SONGS.
18 19 3.
Capability of Principal Response Organizations to Coordinate Both Initial and Continuing Responses 21
&l.
The " Interim Findings and Determination ' Relating to the 22 Status of State and Local Emergency Preparerirass for the SONGS 2 23 and 3" issued by FEMA on June 3, 1981 (Intervenor's Exhibit li5.)
24 identified "significant, concern" over the need for improvements in 25 the coordination among local jurisdictions in their response to 26 radiological emergencies at SONGS.
27
(,1 FEMA's concern over the need for better coordination 28 among local jurisdictions in making decisions about protective b
i a
I actions and in implementing those decisions, was also expressed in 2
the RAC review of the local radiological emergency response plans 3
(Intervenor's Exhibit #13, General Comments on Orange County Plan -
4
- 14,20; General Comments on San Diego Plan - #13; General Comments 5
on San Clemente Plan - #11; General Comments on San Juan 6
Capistrano Plan - #12.) and in FEMA's evaluation of the May 13, 7
1981 exercise (Intervenor's Exhibit #14 at II-6, II-11, II-14, 8
II-15, II-18 and II-23.)
9 h3.
In the May 13, 1981 exercise, the lack of coordination 10 among local jurisdictions was best illustrated by the independent 11 decisions by the Cities of San Clemente and San Juan Capistrano 12 to evacuate the populara and a decision by the County of Orange to 13 sheltc; populations in adjacent unincorporated areas of the county.
14 FEMA, in its evaluation of the exercise, recommended that 15 procedures be developed for coordination.
(Intervenor's Exhibit 16
- 14.)
17 hk.
The " Action Plan" developed to address FEMA concerns 18 (Applicants' Exhibit #144) does nothing to address this concern.
19 The interagency agreement IAEP is only a draft plan written by the 20 applicants and not suitable for actual use by any agency.
(Turner, 21 Tr.8944) 22 (r i'.
Further drills are necessary to better test decision-23 making procedures of principal response organizations and their 24 ability to coordinate implementation of their decisions.
25 (Intervenor's Exhibit #14 at II-11, II-14, II-15, II-17, II-18, 26 II-23, II-31.)
FEMA also recommends that a future drill be 27 conducted to test decision-making procedures for protective acticas 28 in-both the plume and ingestion exposure EPZs (Ibid. at II-15, II-I4
1 21, II-25.)
2 bh.
The May 13, 1981 exercise failed to test procedures for 3
making decisions on appropriate protective measures and for 4
coordinating implementation of those decisions.
A new drill is 5
required to test such procedures so that the necessary evaluation 6
can be made.
Until the new exercise is conducted and evaluated, 7
there is no assurance that principal response organizations have 8
the capability to respond in the event of a radiological 9
emergency at SONGS.
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I C.
CONTENTION 2A (Fmeroency Response Organization Notification and Continuous Communication Capacity)
"Whether there is a reasonable assurance that the 3
emergency response planning and capability of implementation for SONGS 2 and 3, affecting the 4
offsite transient and permanent population, will comply with 10 C.F.R. Section 50.47 (a) (1) and 5
(b) or (c) (1) as regards:
6 A.
The procedures for notification by Applicants of State and local response organizations, 10 7
C.F.R.
Section 50.47 (b) (5), and for notification of and continued communication among emergency 8
personnel by all involved organizations, 10 C.F.R.
Section 50.47 (b) (6).
9 l.-
Notification by Applicants of State and Local 10 Response Organizations 11 h7 The ability of the Applicants to notify State and local 12 response organizations of a radioloaical emeroency has been 13 assessed in several ways, including:-the RAC review of offsite 14 emergency plans vis-a-vis NUREG-0654; the OES revi.ew of offsite 15 emergency plans-vis-a-vis NUREG-0654; FEPA's evaluation of the May 16 13, 1981 exercise; and, the June 3, 1981 Interim Findings issued 17 by FEMA.
(Intervenors Exhibits 13, 14, 15, 16, 17, 18, 19, 20 and 18 25.)
19
[,,$.
In reviewing the adequacy of the offsite radiological 20 emergency plans, both the RAC and the OES found that the City of 21 San Juan Capistrano and the State parks had no provision or back-22 up for being notified on a 24-hour basis.
This lack of capability 23 for 24-hour notification was also observed in FEMA's evaluati3n Intemc4 24 of the May 13, 1981 exercise.
(g Exhibits 13, 14 at II-27, 20 and 25 25).
26
(/j.
In its general comments on the emergency plan of Orange 27 County the RAC noticed that there was some confusion in commu6i-28 cations between the Emergency Operations Center (EOC) of the IG
1 County of Orange and the onsite Technical Support Center (TSC),
2 and between the County EOC and the Emergency Operations Facility 3
(EOF).
To remedy this situation FEMA recommended that the direct 4
line from the onsite TSC to the Orange County EOC he devoted to 5
initial alerting purposes only and that communications with the I,st ewca's 6
EOF be conducted through alternative means.
(
Exhibit 13, 7
General Comment #5 on the Orange County Plan.)
8 70.
In reviewing the radiological emergency response plans 9
of the principal offsite organizations, the RAC and the OES also 10 reviewed compliance with the NRC guidance for periodic testing of 11 emergency communications.
Both the RAC and the OES found that 12-plans by the Counties of Orange and San Diego provided for such 13 periodic teating, but that plans by the cities of San Clemente 14 and San Juan Capistrano and by the State parks did not.
The 15 School District has no appart it provision kwvceov's 16 for periodic testing.
(g Exhibits 13, 16, 17, 18, 19, 25.)
17 7/.
There is no reasonable assurance that SCE is capable 18 of notifying and alerting the City of San Juan Capistrano and 19 the State parks on a 24-hour basis.
20 2.
Notification and Continuous Communication Among Emeroency Personnel by All Involved Organizations
~
21 22 NRC guidance for meeting NRC regulations which require 23 provisions for prompt and continuous communications among eme'r-24 gency personnel of all. principal response organizations set forth 25 criteria'for: altering emergency personnel; identifying those 26 individuals with specific responsibilities who should be contacted; 27 continuous communication between the principal response organiza-28 tions and state and other local governments; and communication
~
U
I i
1 I with federal agencies, the utility and field monitorin,g teams.
2 (NUREG-0654 E, F.)
3 73.
Both the RAC and the OES reviewed the radiological i
4 emergency response plans of the principal offsite organizations I.d <vvu o A 5
for compliance with the criteria above.
(p Exhibits 13, 16, 17, 6
18, 19, 20 and 25.)
7 7Y.
The RAC and the OES found that the plans of the 8
Counties, the Cities and the State Parks provide for alerting of 9
their respective emergency personnel but that all of these plans 10 lack specified procedures for doing so.
Testing of the capability 11 of these organizations to alert their respective emergency per-12 connel was not demonstrated on the May 13, 1981 exercise for the 13 City of San Juan Capistrano.
In its-evaluation of the exercise, 14 FEMA concluded that the City of San Juan Capistrano had failed in 15 alerting and notifying its EOC staff.
FEMA also found that back-16 up notification procedures for such notification by the County of 17 Orange and the City of San Clemente had failed.
In conclusion, 18 FEMA recommended that alerting procedures be developed for the 19 City of San Juan Capistrano and that these procedures be tested 20 before their adequacy is judged.
(Intenenors Exhibits 13, 16,.17, 21 18, 19, 25; Intervenors Exhibit 14.at II-26.)
22 7f.
Furthermore, after observing the testing of: provisions 23 for continuous communication withithe state government and among 24 local governments, FEMA recommended that there should be at least 25 two additional "hoti lines" established between the -EOF and the 26 EOC's of the principal response organizations.
These additional 27 lines will help facilitate continuous communication among contigous 28 local governments within the plume exposure EPZ.
FEMA reiterated M
I its recommendation for instali.ation of these two yellov phones in 2
the Iterim Findings issued June 3, 1981.
Lack of such additional htervoswh 3
phone was identified an a " serious" concern.
(g Exhibit 14 at 4
II-36; f Exhibit 15, pgs. 4 and 5.)
70 5
. FEMA made a general comment that there was a lack of 6
discipline within all principal offsite response organizations 7
with regard to the use of the telephone and communication systems.
8 FEMA observed that the phones designated for use in transmitting 9
information on radiation and for coordination amono various organi-10 zations were used for other purposes.
To remedy this situation, 11 FEMA recommended several corrective actions:
12
"(1)
That all jurisdictions review their plans and procedures to develop more disciplined handling 13 of internal and interjurisdictional communica-tiens.
14 (2)
That the presently used hot line (yellow phone) 15 be identified as to the specific nature of communications that are to be carried out.
16 (3)
That additional phone lines similar to the hot 17 line be considered for specific pre-identified use as follows:
18 (a)
ODAC coordination of information.
19 (b)
Interjurisdictional coordination and decision-20 making by decision makers.
21 (4)
That EOC communications equipment be staffed by communicators'and services by runners to handle 22 dissemination of messages to EOC personnel.
23 (5)
That communications equipment areas be isolate'd from decision-makino areas so as to not interfere 24 with each other.
Areas should be developed with acoustical materials to reduce sound interferences 25 with other operations.
26 (6)
That interjurisdictional (including utility) hard copy communications be improved to provide more 27 timely distribution of information to all partici-pants.
28 (7)
That Standard Operation Procedures (SOPS) be writ-ten to identify communications operations."
1 77 FEMA's evaluation of the May 13, 1981 highlighted one 2
particular hinderance in the capability of the State parks to 3
continue communications with other local organizations and with 4
the state government.
Specifically, FEMA observed that the EOC 5
for the State Parks is in San Clemente and that as a.rresult of 6
being so close to the plant might require early relocation.
Such 7
relocation would interrupt communications between the State Parks 8
and others.
To remedy this situation, FEMA recommended that a 9
" yellow phone" be installed at the Doheny State Beach Park so that 10 continuous communication with the State Parks might be allowed in 11 the early stages of a radiological emergency at SONGS 2 and 3 2n+ en eaur's 12 with offsite consequences.
(p Exhibit 14 at II-32.)
13 77 In its Interim Findings issued on June 3, 1981, FEMA 14 noted " major" concern over the ability of the principal offsite 15 response organizations to communicate with the OES.
These find-16 ings recommend that these communications with the state be im-17 proved to increase in clarity and timeliness.
The " Action Plan",
18 submitted into the record as an outline for actions planned to 19 address the June 3, 1981 FEMA concerns, does not address this
%strvew h 20 major concern.
( 4 xhibit 15 at 4 and 5; Applicants' Exhibit 144.)
E 21 In their review of the plans of offsite principal re-22 sponse organizations, both the RAC and the OES found that the 23 Counties of Orange and San Diego provided for communication with 24 federal agencies, but that this communication is accomplished only 25 through land lines with no back-up provisions.
The RAC and the 26 OES found that the Cities of an Clemente and San Juan Capistrano, 27 and the State Parks failed to make any provisions for communications 28 with federal agencies in their respective radiological emergency
l i
ykyytw S 1
response plans.
(
Exhibits 13, 16, 17, 18, 19 and 25; NUREG-0654 2
11, p,1,c,)
3 d.
There was general agreement in nearly all of the 4
review documents that existing communications between offsite 5
principal response organizations and field teams is poor.
The 6
oES found that the various emergency response plans, if they 7
addressed this criterion at all, were weak in providing for com-8 munications with field teams.
Such communications were addressed 9
in the plans for the Counties of Orange and San Diego, but not 10 in the plans for the Cities of San Clemente and San Juan Capis-11 trano or in the State Parks.
FEMA, in this same evaluation, said 12 that specific procedures should be developed for communicat. ions 13 with field teams and, then, should be tested.
Later in the 14 evaluation, FEMA notes that communications with, field monitoring 15 teams should be accomplished through radios and not telephones.
iatervwoc'S 16
(
Exhibits 16, 17, 18, 19, 25; Exhibit 14 at II-16 and II-19.)
17
. g./.
The evidence in the record shows that while there is 18 some planning and capability for notification and continuous 19 communication among emergency personnel by all involved offsite 20 organizations, there are important exceptions.
The plans of the 21 Cities of San Clemente and San Juan Capistrano and the State Parks 22 fail to even address provisions for continuous communications 23 with the state and with contiguous local governments within the 24 plume exposure EPZ, communications with federal agencies, and 25 communications with field teams.
The Counties of Orange and San 26 Diego do address communications with several of the above groups 27 in their respective plans, but there are specific problems.
For 28 instance, the plan for County of Orange fails to address continuous 17-
t l
i 1
+
communication with state government and with' continguous local 2
governments within the plume exposure EPZ.
The County of San 3
Diego fails to address continuous communications with the state.
4 The lack of effective communication between local offsite re-5 sponse organizations and the state was labelled a " major" concern 6
by FEMA in its June 3, 1981.
This concern was not addressed in 7
the " Action Plan", therefore thera is r.c assurance that the O
capability for communications between principal response organizavi 9 lj tions and the state of California exists.
Overall, the ability 10 of local response organizations to communicate with federal 11 agencies, other local governments, and field teams is also very 12 wae.k, and there is no reasonable assurance that such communica-13 tions can be accomplished ~in the evett of a radiol 6gical emergency I4 at SONGS 2 and 3 with-offsite consequences.
15
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23
1 D.
CONTENTION 2B (Emergency Public Alert and Notification System).
"Whether there is reasonable assurance that the 3
emergency response planning and capability of implementation for SONGS 2 and 3, affecting the 4
offsite transient and permanent population, will comply with 10 C.F.R. S50. 47 (a) (1) and (b) 5 or (c) (1) as regards:
6 B.
the means for notification and instruction to the populace within the plume exposure 7
pathway Emergency Planning Zcne, 10 C.F.R.
S50.47 (b) (5) ;
8 9
hbt The Applicants have chosen a two-step notification 10 process for their public alert system.
Sirens go off, and the 11 public turns on their radios and listen for instructions on the 12 emergency broadcast system.
This method of alert requires public 13 knowledge of the program and good coordination of an emergency 14 broadcast message system. (EBS).
15 if3 It is clear from the evidence in this case that sirens 16 do not adequately cover nor were they intended to cover the 17 populated areas outside the ten mile concentric circle EPZ in the 18 area of Dana Point and San Juan Capistrano.
(Applicants' Exhibit 19
- 139.
Intervenor's Exhibit #13 Orange County General Comments.)
20 The Board finds that the sirens must extend to that area and there-21 has been no showing of any reasonable reason for not complying with 22 the requirement in this case.
23 d(I.
The Board takes judicial notice of the fact that the 24 applicants have indicated in their brief in support of their 25 findings'of fact at page 30 they may delay the testing of their 26 implementation of their siren system until 1982 because of recent 27 NRC proposed extension of the public notification of the 28 requirement contained in Federal Register 46587 (September 21, 3 81).
1 This Board feels that it is imperative that the public notification 2
and alert system be in place prior to full operation of the plant.
3 The Board is also concerned that there is inadequate notification 4
of boaters.
The State Parks and NRC officials suggest that boats 5
can be' brought from the EPZ to San Diego.
This method of 6
notification is clearly insufficient to meet the 15 minutes 7
requirement found in 10 C.F.R.
S50.47, Appendix IV.D.
(Stowe, Tr.
8 8533; Sears 10678.)
9 f6.
San Clemen'te Emergency Planning Officials and the FEMA 10 representatives suggested that a better notification system for 11 offshore and possibly onshore would be the NOAA radb system.
12 (Intervenor's Exhibit #13, General Comment No. 26 re NOAA.)
13 k.
This type of device could be installed aboard ships in 14 the area as well as homes to provide immediate notification and 15 live or prerecorded messages directly into the houses or boats.
16 (Mechem, Tr. 10045-48).
Extensive work needs to be done on the 17 coordination of the Emergency Broadcast System for radiological 18 emergency purposes.
(Intervenor's Exhibit #14, page 2-1, 2) 19
- i:
e' _ r..... -
w 20 d.
The interim findings indicated dated June 3, 1981 21 (Intervenor's Exhioit 15) iridicated the emergency broadcasting 22 network needed further testing and drill to insure operational 23 capability.
h.
Until the siren and emergency broadcasting system is 24 25 coordinated and tested it cannot be said that there is reasonable 26 assurance that the populace within the plume exposure pathway can 27 be notified as provided 'in the regulations.
~
28
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15
i
.l 4
1 E.
CONTENTION 2C (Public Education and Information Program) 2
' Whether there is reasonable assurance that the 3
emergency response planning and capability of implementation for SONGS 2 and 3, affecting the 4
offsite transient and permanent population, will comply with 10 C.F.R. Section 50.47 (a) (1) and 5
(b) or (c) (1) as regards:
6 C.
the information and the procedure for dissemina-tion of the information to the public within the 7
plume exposure pathway EPZ on a periodic basis on how they will be notified and what their actions 8
should be in the event of an emergency, 10 C.F.R.
Section 50.47 (b) (7) ;.
9 10 1.
The initial Public Education and Information Program.'
11 h.
NRC Regulations and guidance for dissemination of in-12 formation to the public within the plume exposure EPZ on how they 13 will be notified and what their actions should be in the event of 14 a radiological emergency at SONGS 2 and 3 is a crucial link in the 15 development of effective emergency preparedness.
Mr. Brothers 16 testified in this proceeding that the time estimates developed by 17 Wilbur Smith & Associates for evacuation of the populace within 18 the plume EPZ assumed that the public knew what to do when alerted 19 of the accident.
(NUREG-0654 Section II. G.; Brothers, TW.'g lO$dy )
20 21 llO.
Much evidence has been presented on what SCE has or 22 plans to do in its initial programs for public education.
SCEh 23 plans include a mailing of a phamplet and handbook to the:hom'e' of 24 every resident in the plume EPZ.
The first provides information o[whattodoandwheretogointheeventofaradiological 25 26 emergency at SONGS; the second provides basic background informa-27 tion on the effects of radiation.
(Applicants' Exhibit 148; 28 Cramer, Tr. 7047-7048).
Y
I hl SCE has promised to send posters similar in, format and content to the Pamphlet to busines'ses within the plume EPZ for 3
these establishments to display at all times.
Similarly, posters 4
and flyers will be used at the State parks Ond beaches to provide 5
emergency information to the users of these facilities.
There 6
was evidence presented that the posters currently displayed at the 7
State parks do not explain that if there were an emergency
- 6. hat 0
there may be releases of radiation offsite.
Instead, these posters 9
instruct beachgoers to wait on the beach when they hear the sirens 10 until they receive instruction from a park official.
The current 11 posters explain that the sirens could mean that there is a fire 12 or chemical spill on the bluffs or highway.
This information is 13 misleading and needs to be changed. ' Posters displayed at both 14 State parks and at local businesses must contain information on 15 the unique hazards of an accident at SONGS with offsite radiologi-16 cal emergencies.
These same posters, if they are indeed like the 17 pamphlets or handbooks, must describe protective measures for IO radiation to be idtT(W n response to a radiological emergency.
10 (Applicants ' Exhibits 69, 123-130; Cramer, Tr. 7049-7050; Stowe, 0
Tr. 8493-8497).
21 7,.
The initial mailing of the pamphlet and handbook to all 22 residents and the signs and posters were not prepared in Spanish 23 for residents who speak only Spanish.
As much as 8.4% of the population in the plume exposure EPZ may speak Spanish and not 25 O^6 Engligh.
SCE should prepare the two mailings in Spanish and at-g 26 te!..pt to reach this sizeable minority population.
(Mecham, Tr.
27 10,043).
G. provides that offsite re-27
l i
l I
sponse organizations: p ovide for periodic coordinated public 2
information; public education for permanent and transient popula-3 tions; and coordinated education of the news media.
In general
(
4 the plans of the counties of Orange,and San Diego and the State 5
Parks provide for each of the above but their individual efforts 6
are not coordinated in any way with other adjacent jurisdictions.
7 In general neither the plan of the City of San Clemente nor the 8
plan of the City of San Juan Capistrano addressed in adequate 9
detail any of these guidance criteria for public information.
Initvvwv 4 10
(
Exhibits 13, 16, 17, 18, 19, 2 5,).
11 h.
There is evidence that SCE has yet taken steps to 12 educate renters with mailings of the pamphlet and handbook,-unless 13 their name appears on the utility service account.
SCE plans to 14 send individual copies of the pamphlet to new residents within'the 15 so-called " extended EPZ" when they apply for electricity hookups 16 or to have electricity turned on.
The Board finds that it would 17 be helpful to also distribute the handbook to these new residents' 18 in the " extended EPZ".
There should also be some provision for 19 disseminating both items to renters who do not need to call to 20 establish new electric service.
(Cramer, Tr.'7041, 7045.)
21 In its Interim Findings issued June 3, 1981, FEMA 22 noted a " Major" cacern that advance public information dissemina-23 tion be monitored to assure credibility of releases and standardi-
- 24 zation of terminology.
FEMA believes that the "public must be 25 intimately familiar with protective action procedures."
FEMA 20 recommends follow-up surveys with those who live and work within 27 the plume EPZ to see if the mess. age is getting through.
Subse-28 quent programs should be altered according to what the surveys 2f
4 I
reveal.
Among the questions asked, SCE or its representative m
2 should inquire into the most effective communication medium. -
3 There is no evidence in the record that SCE did any preliminary 4
research to determine how it might best reach the populace within 5
the plume EPZ.
The board takes judicial notice that numerous 6
studies in similar matters traditionally reveal that the tele-7 vision advertisements are mest effective and that bill inserts 8
are the least.
Yet, SCE's public education programs fail to use 9
the first and'uses the last.
(Intervenors' Exhibit 15 at 5; 10 Nauman, Tr. 10,541.)
11 2
Dissemination of'Information on a Per' iodic Basis.
12 if,.
Evidence presented in the case on periodic communica-13 tions with the public in an effort to continue awareness of what 14 to do in the event of an accident at SONGS was basically promisory.
15 SCE plans to do a public information update at least annually.
16 If there are changes in the content of information which should be 17 made known to the public, revisions would be provided in the 18 annual general program update or earlier,'if required.
(Cramer, 19 Tr. 7051-70,2.)
20 41 Ia order to insure that the public is well-informed 21 on what to do inithe event of an emergency, the Boasd finds that 22 SCE or, preferably, local response organizations will need to repeat the direct mailing of the painphlet and handbook or so[n'e 23 24 equivalent on at least an annual basis.
With this condition, 25 there is some assurance that the public will receive information 26 on what to do in the event of an emergency on a periodic basis.
27 k.
With the conditions noted herein, including revised 28 posters for businesses and the State parks, Spanish pamphlets and 21
I handbooks, and follow-up surveys on the effectiveness of initial mailings, together with annnal updates, there is some degree.of j
3 assurance that SCE will provide information to the public on what t
4 to do in the event of a radiological emergency at SONGS.
5 ll l 6
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30
k 1
F.
CONTENTION 2I (Interim Emergency Operations Facility).
"Whether there is reasonable assurance that the 3
emergency response planning and capability response planning and capability of implementation for SONGS 4
2 and 3, affecting the offsite. transient and I
permanent population, will comply with 10 C.F.R. 5 S50. 4 7 (a) (1) and (b) or (c) (1) as regards:
6 I,
the physical design, communications equipment and operating procedures for the Interim 7
Emergency Operations Facility, 10 C.F.R. S50.47 (b) (3) and (b) (8) ;...."
9 90 The operation and the failure of the operation of the 10 Interim Emergency Operations Facility in the May 13 exercise was 11 one of the most serious concerns contained in the FEMA findings.
12 (Intevenor's Exhibit #15.)
13 (60 The Interim EOF is set up in six distinct components.
14 The Board finds that this crucial facility should.not be fragmented 15 in this way for an extended period of time because of the potential 16 communications and logistic problems which may take place.
17 (Pilmer prepared testimony; Intervenor's Exhibit #15.)
18 (0/.
The applicants scheduled for completing by October 1982 19 and in that light the Board does not feel that this is a significant 20 impediment to the emergency response capability for SONGS.
21
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23
/II 24
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25
/((
26
((I' 21 Ill 28 ll I -
2T I
1 G.
CONTENTION 2D (Medical Services for Injured Contaminated Individuals.)
"Whether there is reasonable assurance that-3 the emergency response planning and capability of implementation for SONGS 2 and 3, affecting 4
the offsite transient and permanent population will comply with 10'C.F.R. S50. 47 (a) (1) and 5
(b) or (c) (1) as regards:
6 D.
The arrangements for medical services for contaminated and injured individuals, 10 C.F.R. 7 S50. 47 (b) (12) ;
8 The guidelines for the offsite jurisdiction and the 9
applicants 1 reparation for offsite medical care are found in NUREG-0654 SL.1. and L.4.
While the guidelines are not completely clear as to what precautions the offsite jurisdications must take as regards arrangements for medical services, it is clear there should 13 be some arrangement at local jurisdictions hopsitals.
(Nauman, 14 Tr. 10544.)
15 (03 Orange County, San Clemente, San Juan C.apistrano do not have arrangements in their plans for transferring victims of a radiological emergency.
(Intervenor's Exhibits #13, 16, 18, 19 and 25.)
There is also very limited planning for the capability of evaluating exposure and updating in the local hospitals (iEbichD.,,
f0V.
The effectiveness of potassium iodide as a blocking agent is directly related to the time at which it is administered.
After the exposure has occurred, the earlier it is administere.d, the more effective it will be.
If it is administered prior to exposure, it can be completely effective in preventing uptake of radioactive iodine.
(Linnemann, Tr. 7080) 26 Id.
The risk from small doses of potassium iodide for 27 emergency uses is slight.
(Linnemann's testimony.)
31
l 1
(Oh.
To deal with the medical problems of exposure to 2
radiation at high levels, history and physical, complete blood 3
counts, thyrcid uptake studies, chromosome analysis of the 4
circulating lymphocyres, whole body counts and bioassay should be 5
considered.
(Linnemann's testimony).
Specially equipped medical 6
centers are needed to provide such care.
(Linnemann's, Tr. 7106) 7 (07.
No special arrangements for the use of radio protective 8
drugs has been made for the general public, even for children, who 9
are particularly vulnerable to radiation injury via thyroid uptake.
10 No special arrangements have been made for medical services for the 11 general public in the event of a sericus nuclear power plant 12 accident.
13
[06 The Board finds that in order to adequately address 14 needs for serious medical care in the event of a radiological 15 emergency at SONGS there must be provided planning basis through 16 arrangements between local response organizations and the 17 hospitals in the area for the treatment, care and monitoring of 18 exposed contaminated or injured people.
19 ltl 20
- 1 21 fff 22
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23
/If 24 til 25 Ill 26 II { -
27 Ilf 28 II)-
33
I 1
H. CONTENTION 2G (Radiologic'al Emergency Response Training)
"Whether there is reasonable assurance that 3
the emergency response planning and capability of implementation for SONGS 2 4
and 3, affecting the offsite transient and permanent population, will comply with 5
10 C.F.R. 550.47(a) (1) and (b) or (c) (1) as regards:
7 G.
radiological emergency response training 8
to those who may be called on to assist in an emergency, 10 C.F.R.
S50. 4 7 (b) (15);
9 10 1.
Offsite personnel requiring training.
11 (O
NRC Regulations and guidance require that radiological 12 emergency response training be provided to those who may be called 13 on to assist in an emergency.
NRC guidance calls for training of 14 appropriate individuals, appropriate offsite organizations 15 (including mutual aid personnel), and specific individuals who 16 implement the emergency response plans. (NUREG-0654 SII. 0) 17 II0.
The RAC and the OES reviewed the emergency response 18 plans of local jurisdictions within the plume exposure EPZ for 19 adequacy vis-a-vis NUREG-0654.
In general, the RAC and OES found 20 that the plans the Counties of Orange and San Diego contained 21 some sort of provision for training of emergency personnel.
22 However, neither of these plans were at all specific about whom 23 should receive this training.
The plans of the Cities of San" 24 Clemente and San Juan Capistrano and the State Parks failed to 25 address this NUREG-0654 criteria at all.
(Intervenors Exhibits 26
- 13, 16, 17, 18, 19, 25, NUREG-0654 II.
0.1.,
II 0.1.b.,
II.0.
4.
27 a-j.,
II.0.5.)
28 34
1
{Il.
HUREG-0654 Section ' '. 0. 4. (a)- (j ) requires training 2
for individuals who fall into the following categories; Directors 3
or coordinators of the response organizations; personnel 4
responsible for accident assessment; radiological monitoring teams 5,
and radiological analysis personnel; police, security and fire 6
fighting personnel; repair and damage control / correctional action 7
teams (onsite); first aid and rescue personnel; local support 8
services personnel including Civil Defense / Emergency Service 9
personnel; medical support personnel; licensee's headquarters 10 support personnel; and personnel responsible for transmission of 11 emergency information and instructions.
Provision for training 12 individuals working in these categories is made in the Orange 13 County, San Diego, and State Parks p,lans, but there is no 14 training schedule provided.
Such training is not addressed in the 15 plans by either San Clemente or San Juan Capistrano.
(Intervenor5 16 Exhibit #13, 16, 17, 18, 19, 25.)
17 2.
Programs for Radiological Emergency Training 18
((1/.
Evidence has been presented which shows that SCE began 19 an offsite radiological emergency training program in March 1981.
20 At SCE's request, the Radiation Management Corporation (RMC) 21 provided radiological emergency training to personnel of private 22 and public agencies within Orange and San Diego Counties who 23 might be called on to assist in an emergency response to an a'dcident 24 at SONGS.
The Orange County training took place March 23 through 25 March 26, 1981.
The San Diego County training took place April 20 26 through April 24, 1981.
In Orange County, training was presented 27 to 127 people who represented 29 offsite organizations.
In San
~
28 Di. ego, training was presented to 259 people representing 76 35i
1 offsite response agencies.
RMC has been requested to provide 2
additional training in the future.
,(Applicants' Exhibits #85, 86; 3
Linnemann, Tr. 7091, 7092.)
ll%.
Notwithstanding the existence of the classes by RMC in 4
5 March and Apri_1 of 1981, FEMA in its review of an exercise held on 6
May 13, 1981 found several major problems with the level of 7
training by all personnel.
In its evaluation of the May 13, 1981 8
exercise, FEMA made a general comment that "The specific areas g
dealing with radiological issues,... reflected areas of concern 10 and the n'e'ed for further training and drills to improve i
11 proficiency and to assure an ongoing capability to respon'd to the 12 needs ci an offsite nuclear emergency.
There is a need for 13 milestone depiction indicating proposed meetings, training, drills, 14 and exercises both within the next year and over a five-year 15 period."
(Intervenor's Exhibit #14, at II-1.)
lk.
FEMA, in this evaluation of the May 13, 1981 exercise, 16 17 concluded that an understanding of basic Radiological Defense 18 principles is not sufficient training for radiation monitoring.
19 FEMA observed that only the San Clemente's field monitoring team 20 was qualified for radiation monitoring.
To remedy the deficiency 21 in training, FEMA. recommended, that SCE conduct training for 22 monitoring teams, dose assessment, personnel, decisionmakers, 23 Public Information Officers, the news media and communication ~s-24 personnel.
(Intervenor's Exhibit #14 at II-5. )
In addit. ion, FEMA singled out the problem of t9aining 25lth e Marine Corps field monitoring teams.
Through observations on 26 27 May 13, 1981, FEMA found that the Marine monitoring teams were 28 untrained and unfamiliar with the procedures that they were N
l I
supposed to use.
FEMA concluded that basic Marine training 2
programs are inadequate in terms of training for radiological 3
emergencies and reccmmended that SCE provide training to the Marinet.
4 (Intervenor's Exhibit #14 at II.30.)
5 (d._
The written testimony of Mr. Kenneth Nauman in this 6
proceeding concluded that the training provided to emergency 7
response personnel in the past has been limited and that 8
additional training is necessary.
Mr. Nauman's testimony said that 9
he felt that the planning standard in NRC Regulations relating to 10 radiation emergency response training was met only to "some 11 degree".
( Nauma,1 pg(Ared +c4b C*1f @ fgd' OIE(l k U IITI) s 12 ll7 At SCE's request, the NUS Corporation has developed a 13 Program of initial training and peripdic retraining for offsite 14 emergency response personnel.
Outlines for these upcoming courses 15 were submitted on the very last day of hearing.
Mr. Kenne
.t Nauman 16 testified that he is skeptical about this training program and 17 expressed an interest in reviewing the outlines and attending a 18 class before he made a judgment on the adequacy of this training 19 program.
(Nauman Y-lD N DN t/k df}
f 20
{d.
The Board finds that radiological emergency training 21 programs are essential and that until a major portion of those 22 individuals, especially decisionmakers, who may be called on to 23 assist in an emergency, have been successfully through the
' 24 training, there is no reasonable assurance that there is an 25 acceptable number of emergency personnel who are qualified to carry 26 outi offsite emergency plans. ( NOAtMn, TV (0404 Ed'(eq.)
27
(@.
In addition, it is important the assurance of trained 28 individuals to implement emergency response plans continues through 37
I time.
SCE has presented some evidence that the training programs 2
of the NUS Corporation will continue in time.
The Board finds 3
that a promise of continued training is essential to providing 4
reasonable assurance.
At the same time, it is important that SCE 5
and the offsite jurisdictions monitor not only the names of the 6
individuals who take the training, but also a current list of 7
employees with responsbilities in the event of a radiological 8
emergency.
If SCE discovers that job turnover in one particular 9
rganization or in classification of emergency worker is high, the
- 10 frequency ~of training opportunities will need to be increased.
11 12 1
CONTENTION 2H (Plume EPZ Radiation Monitoring and Dose Assessment) 13 "Whether there is reasonable assurance that 14 the emergency response planning and capability of implementation for SONGS 2 and 3 affecting 15 the offsite transient and parmanent population, will comply with 10 C.F.R. 550.47 (a) (1) and 16 (b) or (c) (1) as regards:
17 F.
the methods, staffing, systems, and equipment for assessing and monitoring actual 18 or potential offsite consequences of a radiological emergency condition within the 19 plume exposure pathway EPZ for SONGS 2 and 3, 10 C.F.R.
S50.47 (b) (9 )..."
1.
SCE Resources and Capability.
21 (10 Applicants have onsite resources and capability 22 available te help assess and monitor actual cr potential offsite 23 consequences of a radiological emergency condition within the Plume exposure EPZ.
In its efforts to help this assessment and monitoring, SCE has procedures established to obtain in-plant radiation levels, radiation release rates and certain meteorological data for the vicinity of the plant.
Field W
h
I monitoring can confirm the accuracy of offsite dose projections 2
made on the basis of this onsite data.
(Applicant's Exhibit #51, 3
Section 6.2.5; Ray, Tr. 7847) 4 (Il.
A Meteorological tower is located onsite immediately 5
north of SONGS 1.
The tower has instrumentation which records'and 6
displays temperature, lapse rate, wind speed and wind directional 7
variability.
This information is recorded and displayed in the 8
Control Room and the Technical Support Center (TSC).
A backup 9
tower which can duplicate the functions of the primary tower is 10 scheduled to be installed onsite by July 1982.
(Applicant's 11 Exhibit #51, Table.7-3; Barr, Tr. 7165.)
12
($D.
If plant radiation instruments go off-scale or become 13 inoperable, health physics personnel,can be dispatched to perform 14 measurements of radiation levels at predetermined locations around 15 the plant using portable instrumentation.
SCE has said that the 16 results of these measurements would be communicated to the TSC via i
i 17 portable radio.
These results would then be used to estimate 18 release rates and offsite dose projections in the same manner as 19 results taken from installed monitoring devices.
(Barr, Tr. 7166-20 7167.)
21 IL3.
In making the calculations, SCE applies atmospheric j
22 dispersion coefficients based on available meteorological data and 23 established dose conversion factors, which relate airborne 24 radioactivity concentration to direct dose rate, thyroid dose rate, 25 and lifetime integrated doses.
The dose conversion factors are 26 containe'd in the Offsite Dose Caledation Manual which provides a 27 methodology for the consideration of multiple pathways of 28 radioactive materials propagated within the Plume EPZ.
Upon l
l l
31
l j
e I
determination of the projected'offsite dose rates, they kre
~
2 provided to the onsite Emergency Coordinator in the TSC an5 to the 3
Offsite Dose Assessment Center (ODAC).
(Applicant's Exhibit #51, 4
Section 6.2.5; Barr, Tr. 7168-7169) 5 l'ld.
SCE is currently developing a more advanc6d yethod at 6
SONGS 2 and 3 to perform the offsite dose calculations.
SCE has 7
purchased a Health Physics Computer System to -be implemented 8
withinthenextyearasanaidinperformingoffsitedose]
9 calculations..
(Barr, Tr. 7176.)
10 N.
Each monitoring team will consist of a trained' health P ysics technician and one other person assigned from the SONGS h
11 12 maintenance department.
The health physics technician will 13 perforn all of the required monitoring duties and communications 14 with the TSC.
The maintenance worker will be under the direction 15 of the health physics technician and will assist in transporting 16 equipment, driving the survey vehicle, recording data,.and 17 providing any other assistance required by the health physics 18 technician.
(Barr, Tr. 7173-7174) 19 Ih.
The Manager, Health Physics, for SONGS testified that 20 he is capable of initially deploying within about 30 minutes at 21 least two offsite monitoring teams and three teams once SONGS 2 and 22 3 are both operational to three of 16 22-1/2 degree pie shaped 23 sectors of the plume exposure pathway which uses SONGS as a focal 24 point.
These three teams could be augmented with two additional 25 teams within about. sixty minutes, if necessary.
Additional teams 26 would be dispatched as additional manpower becomes available.
27 (Barr, Tr. 7173.)
28 lN.
SCE has agreements with a variety of outside 40
1 organizations which might be called in to help in radiation o
monitoring.
In general, however, there organizations are located 3
'tn areas outside the plume exposure EPZ and personnel from these 4
' organizations could take unreasonably long time's in getting to the 5
plume exposure EPZ.
(Applicant's Exhibit #101, Barr, Tr. 7174; 6
Exhibit #51, Appendiz E; Barr, Tr. 7174-7175.)
7 lM.
Due to the importance of prompt radiation monitoring 8
and dose assessment in deciding appropriate protective actions to 9
overall personnel limitations of SCE in conducting all monitoring 10 activities, and to the importance of letting offsite response 11 organizations have credible and reliable data on which to make 12 decisions on protective measures, offsite response organizations
~
13 have the responsibility for conducting their own radiation m'onitoring programs.
The applicant's capability puts too strong 14 E' 15 a reliance on the guesswork of do.58 projections and extrapolations T' ) rather than actual field sampling.
SCE has established the Offsite Dose Assessment Center.
/
18 (ODAC).
The ODAC is located in the Interim EOF to direct offsite 19 [, emergehcy response organization dose assessment and monitoring 20 activities and to coordinate these activities with SCE's monitoring 21 activities and dose assessment.
(Intervenor's Exhibit #142; 22
/Pilmer, Tr. 7 '; 7 9 '. )
23 B0 Assuming that SCE finishes construction of the bac$-up 24 tower for measuring meteorological parameter onsite and installs 25 the Health Physics Couputer, there is some assurance that SCE has 26 the capability and resources to perform initial radiation
'27 j monitoring and to calculate an offsite dose projection.
It is
'r 28 i.ncumbent upon the offsite response organizations, however,'to
l l
1 verify and validate the initial assessment provided by SCE.
2 3
2.
The Resources and Capabilities of Offsite
~
Emergency Response Organizations, 4
5 lb.
NRC. Regulations and guidance require offsite emergency 6
response organizations to have the capability and resources for 7
plume monitoring, to have specifled procedures for field team 8
monitoring, and to have methods oy which these organizations can 9
convert measured parameters into dose rates.
(NUREG-0654 SII.I.
10 7-10.)
11 N '.
The RAC and the OE3 have reviewed the radiological 12 emergency response plans of the principal response organizations 13 for SONGS vis-a-vis the criteria set,forth in NUREG-0654.
In this 14 review, these groups assessed the descriptions in each of the plans 15 of the capability and resources for plume monitoring within the 16 plume exposure EPZ.
The RAC and the OES found that the Orange 17 County plan addressed its capability and resources for such 18 monitoring, but failed to provide specifics on either.
The San 19 Diego County plan says that the state and the utility have primary 20 responsbility for such monitoring and, therefore, the County's P an fails to meet this criterion.
The plans ci-San Clemente, San l
21 22 Juan Capistrano and the State Parks fail to address this cirterion 23 directly.
(NUREG-06 54 II. I. 7; Intervenor5 Exhibits #13, 16,'17, 24 18, 19, 25.)
25 (33.
In assessing whether the respective plans adequately 26 described specific provisions for field team monitoring methods, 27 activation, transportation, etc., the RAC found that the plans of 28 Orange County, San Diego and the City of San Clemente failed to
1i provide methods, equipment and expertise to make rapid 2
assessments or hazards through liquid or gaseous pathways.
The 3
City of San Juan Capistrano and the State Parks did not even 4
attempt to address this criterion from NUREG-0654.
(NUREG-0654 II.
5 I,
8; Intervenor's Exhibits #13, 16, 17, 18, 19, and 25.)
6 le3f{.
The RAC and the OES also reviewed the plans of 7
principal local response organizations to assess whether they 8
addressed three criteria which NUREG-0654 calls a state WFM 9
responsbility, but in the State of California, is, in fact, asid6-4 10 responsibility: provisions for detection and measurement of iodiae 11 in the plume; conversion of measured parameters to dose rates; and 12 plume tracking.
The reviewing organizations found that none of 13 the principal response organization plans addressed any of these 14 requirements.
(NUREG-0654 II.I. 9,10 and 11; Intervenor's 15 Exhibits #13, 16, 17, 18, 19, and 25.)
16 Mf; The general lack of spccified provisions for radiation 17 monitoring in the plume expsoure EPZ by local response 18 organizations was re-emphasized by the RAC in its general comments 19 on the various plans.
In its general comment #13 on the Orange 20 County plan, the RAC noted that "the ability to prevent 21 unacceptable exposure and provide effective, proper actions will be 22 dependent on the ability to obtain valid radiological measurements.
23 Yet is this plan, one of the most, if not the most import. ant 24 activities--radiological monitoring--seems to have the least degree 25 of address."
In this general comment, the RAC goes on to l
26 recommend that health physicists provide input to revidon of the 27 plan.
(Intervenor's Exhibit #13.)
28 I%.
In general comments #15 and #25 on the Orange County
I plan and in general comments on each of the other plans reviewed, 2
the RAC calls attention to another major deficiency in the 3
capability and resources of local response organizations to 4
perform radiation uonitoring in the plume exposure EPZ, as 5
described in the plans.
These general comments point to an "almost 6
comphte lack of meteorological understanding in the plans which 7
raises grave concern since evacuation hinges on it."
The general
,8 comments ask what nearby weather observations are available since 9
the data that the local response organizations intend to rely 10 on is not generally local.
Meteorological data is currently _.
11 available from Lindberg Field, San Diego; Palomar Airport, Carlsbad; 12 Oceanside Airport; El Toro Marine Corps Air Station; Orange County; 13 and Camp Pendleton Headquarters Landing Field.
There are no sourcer 14 for meteorological data, for instance from the City of San Clemente 15 or San Juan Capistrano.
(Intervenor's Exhibit #13--General 16 Comments #15 and 25 on Orange County Plan; #38 on San Diego Plan; 17
- 16 on the San Clemente Plan; in the San Juan Capistrano plan 18 critique; and #21 on the State Parks plan. )
19 ff7 In addition, the RAC in its general comments observed 20 that the plans of the local response organizations were deficient 21 in not providing for greater interjurisdictional communication on 22 joint analysis of dose accumulations, dose essessment information 23 releases and other activities.
(Intervenor's Exhibit #13, Gen'eral 24 Comment #7 on Orange County Plan.)
25 Nh.
In several instances, FEMA was abl.e to observe the 26 capability of implementation of plan provisions, where they 27 existed, during the May 13, 1981 exercise.
~
28 f6i.
In its general findings contained in its evaluatbn of
i I
the May 13, 1981 exercise, FEMA observed that the meteorological 2
data available from the National Weather Service was not used well 3
in most instances.
" Weather status boards were not maintained, 4
where established in EOCs, and weather information was not 5
considered regarding all actions."
From this observation, FEMA 6
recommended that: "(1) all jurisdictions review plans and
-7 procedures to factor in weather information to all phases of 8
planning; and, (2) the utility and jurisdictions establish a 9
line of communication with the National Weather Service by formal 10 agreement to assure adequate coverage and response to offsite 11 emergencies."
(Intervenor's Exhibit #14 at II-3.)
12 (40 In its general findings on the May 13, 1981 exercise, 13 FEMA also observed that there was no demonstration of a flexible 14 monitoring response capability to plume tracking through the use 15 of sector or zone designators in accordance with Table J-l in 16 NUREG-0654.
FEMA went on to recommend that the zone designation 17 system be applied to all field monitoring and sampling techniques 18 used by principal response organizations.
The zone designation 19 system would require extensive drilling once it wrs established in 20 order to insure that field teams were familiar with it.~
(Inter-21 venor's Exhibit #14 II-6.)
Use of such a zone designation system i
22 would help to coordinate inter-jurisdictional monitoring team 23 response capability. (Ibid.)
24 Nfl.
FEMA's findings on the May 13, 1981 exercise detailed
~
25 a variety of additional problems relating to radiation monitoring 26 efforts by local response organizations, the most important of 27 which are exhibited below opposite FEMA's recommendation for 28 remedies to these identified issues:
W
1 Problems Recommendations 2
- 1. All field teams require 1.
Only the San Clemente i
field monitoring ~ team additional training,' written 3
showed capability for operation procedure and proper radiation monitoring.
direction from a coordinated 4
health physics center.
5 2.
None of th'e jurisdictions
- 2. Aerial monitoring should be had capability to conduct factored into exercises and 6
radiciodine air sampling.
drills.
(Equipment needs already discussed in findings 7
of fact above.)
8 3.
No monitoring of doses
- 3. Monitoring of field doses received by field teams he conducted.
9 was observed.
10 4.
There was a lack of
- 4. Utility and local jurisdict-coordination among ions should develop a unified 11 principal response radiological response team organizations for which is directed by the ODAC 12 radiation monitoring.
And, procedures should be formalized for various types 13 of monitoring, including:
plume; deposition; egress to 14 prevent cont. amination of personnel and equipment; air-15 borne material; sampling of soil, vegetation, water and 16 pipes.
17 5.
Sampling-collecting
- 5. Further drills should be capability of Orange conducted.
Air Sampling 18 County was not equipment should be obtained.
demonstrated.
19 6.
Sampling techniques used There.should be air sampling.
20 by San Clemente should be There is no water or improved.
vegetation sampling ability.
21 Cross-contamination of samples is possible under 22 current procedure, field monitoring teams need more 23 information on the statu's of the emergency.
24 (Intervenor's Exhibit #14, 25 II-4, 5, II-13, II-22.)
26
[T' In addition, FEMA recommended that the Marine Corps 27 bring in a health physicist to make educated decisions on 28 pr.otective actions and field monitoring in the event of an kh
I emerg)ncy.
FEMA also suggested that the Mayine Corps standardize 2
its radiation monitoring procedures so that other off-site 3
response organizations might share in the information collected.
4 (ISfervenor'sExhibit #14Sh'II-30,f31.)
f 5
bi).
FEMA found that the Marine Corps shouB consider 6
adopting provisions under which it can calculate a dose 7
assessment on its own, in light of the fact that there are base g
populations very near to the plant and that the Marines may not 9
want to wait to hear from the ODAC.
(Ibid.)
lYi.
The general dissatisfaction in the state of current 10 11 Procedures of off-site local emergency response organizations for 12 radiation monitoring and dose assessment expressed in FEMA's 13 evaluation of the May 13, 1981 exercise was reiterated, to a large 14 degree, in the Interim Findings which FEMA issued on June 3, 1981.
15 In the June 3 Interim Findings, FEMA noted " Major" concern over:
16 the lack of coordinated planning and a consolidated cooperative 17 approach to radiation monitoring especially consider the fact that 18 some jurisdictions, like San Juan Capistrano, lack response 19 personnel to really do radiation monitoring; the conflicts in P an responsibilities; and th'e lack of clarity in the monitoring l
20 21 and assessment duties for both plume and ingestion pathway EPZs "as 22 they pertain to the state OES, State Radiological Health, and local 23 jurisdictions."
The " Action Plan" submitted into evidence bi'the 24 Applicants says that SCE will develop Standard Operating Procedures 25 (SOPS) for local jurisdictions and the Off-site Dose Assessment 26 Ce'nter '(ODAC) by August'1981, and that SOPS to coordinate the 27 activities of state and local governments in ingestion pathway 28 monitoring will be developed.
Until these actions and other N
I
t I
actions identified in the three paragraphs below are t.aken, there 2
~
is no reasonable assurance that off-site response organizations 3
will be able to provide for field monitoring or dose assessment in 4
the event of a-radiological emergency with off-site consequences.
5 (In'tervenor's' Exhibit #15, pg. 3; Applicants' Exhibit #144.)
6 (f(
In the June 3, 1981 Interim Findings, FEMA also 7
identified " Major" concern over: the lack of clarity in operation 8
of the ODAC since dose assessment responsibilities are split bet -
9 ween the TSC and the EOF which impedes joint-decisionmaking: and, 10 the fragmented nature of coordination of field monitoring teams 11 whic'h limits overall assessment.
In response to these concerns, 12 the " Action Plan" lists SCE's intent to develop SOPS for ODAC by.
13 August 1981 and its intent to develop an " integrated radiological 14 response team to be directed by the ODAC to conduct field monitor-15 ing."
The " Action Plan" is less than clear whether this 16 integrated radiological response team will conduct field 17 monitoring in both the plume and ingestion exposure pathway EI-Zs.
18 The " Action Plan" implies that the integrated response team will j
19 be used for ingestion pathway monitoring only.
The Board finds 20 that such.an integrated monitoring team should be used for both 21 plume and ingestion pathways, and until the integrated teca is 22 developed, there is no reasonable assurance that local response 23 organizations have the capability or resources to conduct rad tion 24 monitoring.
(Intervenor's Exhibit #15, pg. 4; Applicants' 25 Exhibit #144.)
[4(,.
The Board also notes that two of the concerns expressed 26 l
27 in the paragraph above are not a'ddressed in the " Action Plan".
28 Specifically, there is no address made of the identified need to N
I i
I revise local plans to change procedures for field monitoring 2
teams, and more importantl.v, there is no mention of the division 3
in responsibility between the TSC and the O2AC for dose assessment.
4 Until, such a division is made there is no reasonable assurance 5
that local jurisdictions working, though the ODAC can verify dose 6
projections provided by SCE personnel.
Lack of this ability 7
would interfere with the responsbilities of the local jurisdictions 8
to assess the mergency and recommend specific protective actions 9
to the public.
(Intervenor's Exhibit #15, pg.4; Applicants '
10 Exhibit #144.)
11 (L{7.
In addition local jurisdictions should work to 12 incorporate provisions to meet applicable NUREG-0654 criteria, and 13 to make necessary changes in procedures to remedy problems 14 identified in preceding paragraphs.
Until corrective measures ~ based 15 on the RAC and FEMA are adopted and incorporated by local 16 jurisdictions, there is no assurance that there are resources and 17 capabilities of off-site response organizations to conduct 18 radiation monitoring in the plume exposure pathway EPZ.
19 t/ /
20 til 21
///
22
///
s 23
///
24 Ill 25
(//
26
/ //.'
27 fil 28
///
QT
I J, CONTENTION 2K (General Plan
- for Reentry and Recovery.)
2 "Whether there is reasonable assurance that the emergency response planning and capability of I
3 i.;
implementation fpr SONGS 2 and 3, affecting the
[
offsite transient and permanent population, will 0
i 4
comply with 10 CFR Section 50.47 (a) (1) and (b) or
_ (c) (1) as regards:
K.
General Plans for Reentry and Recovery, 10 C.F.R. 6 Section 50.47 (b) (13) ;
7 8
lY(. A guideline for the requirements contained in 50.47 (b) (13) 9 can be found in NUREG-0654 II,M at page 70.
The planning criteria 10 indicates that each organization should develop general plans and 11 procedures for reentry and recovery and provide the means by which 12 decisions to allow protective measures and allow reentry into 13 evactuated area.
This process should consider both existing and 14 potential conditions.
A review of local jurisdiction plans of 15 orange County, San Diego County, San Clemente, San Juan Capistrano 16 and the State parks indicates that none of these plans contain 17 sufficient material to meet this planning standard.
(Intervenor's 18 Exhibit #13, San Clemente (an informal review at page 5) ;
i 19 Intervenor's Exhibitp#16, 17, 18, 19 and 20.)
20 l %.The applicants have offered no evidence that such plans exist 21 Its position that ad hoc planning is all that it required. (Pilmer 22 7390.)
Tr.
x 23
// /
l 24
///
I 25
///
26 t//
27
///
28
///-
N l
I I
K.
CONTENTION 3 (Plume EPZ Determination.)
2 "The emergency response plans failed to meet the
. requirements of 10 C.F.R. 50.47 (c) (2) because 3
the local emergency planning officials have 4
arbitracily established the boundaries of plume ex'posure EPZ in that they have mechanically applied 5
a ten mile boundary and that the Interagency Agree-ment (IAEP) among all local jurisdictions defines 6
the EPZ by drawing comp &ss lines on a map of the area.
In determining the exact size of the EPZ 7
emergency planning officials have failed to consider the following local conditions:
8 1.
topography 2.
meterology 9
3.
evacuation routes 4-dem 9 rap y h
10 5.
jurisdictional boundaries 6.
SAI report 77 7.
land characteristics.'..I 12 1.
The Boundary of the Plume Exposure Pathway EPZ.
13 Ifd.
With this contention Intervenors challenge the manner 14 in which the exact boundary of the plume exposure pathway EPZ was 15 drawn by the local emargency planning officials whose task is to 10 draw that boundary.
Also this contention asks the Board to review 17 the emergency planning zones as set forth in the various plans to 18 ascertain whether they are in fact consistent with one another and 19 to determine whether or not there is agreement on the extent and 20 nature of the emergency plume exposure emergency planning zone.
IEl.
A review of the various plans themselves of the local 22 jurisdictions indicates that there is not agreement in those plans as to what the plume exposure emergency planning zone is. For 24 instance, San Clemente plan indicates that it is simply a compass 25 drawn circle at ten miles (Applican ts ' Exhibit 55, Figure 1).'
26 The plan for San Juan Capistrano also indicates that the EPZ is 27 drawn at ten miles notwithstanding the fact this bisects the city 28 (Applicants' Exhibit 56, page 5, Figure 1).
The emergency plan for b
1 San Diego County also draws the EPZ line at a ten mile concentric circle.
(Applicants' Exhibit 53).
3 (6L.
On the other hand, the SOP for the Marine Corps does 4
not contain any reference to an EPZ because the plan was written 5
and adopted before the EPZ concept came into effect.
(Applicants '
6 Exhibit 58).
7 N.
Orange County plan indicates that the City of San Juan 0
Capistrano and the incorporated community of Dana Point are in-9 cluded #ithin'the emergency planning zone even though they are 10 outside e concentric ten mile circle in the northern sector.
II Orange County draws the line around these two population centers 12 rather than bisect the various communities.
13 f(C The emergency,; plan of the State of California also I4 draws its line to include San Juan Capistrano and. Dana Point in-15 creasing the boundary to the northern section to approximately 16 12 miles.
The State of California plan also includes all of 17 Camp Pendleton, the southern aspect of the EPZ going out to ap-18 proximately 15 miles.
(Intervenors Exhibit 23 at page 7.)
The record reflects a set of emergency planning zones 20 ranging from the state's emergency planning zone which. includes 21 Camp Pendleton to the south and San Juan Capistrano and Dana 22 Point to the north to the ten mile radius plans found in San 23 The lines of the various. plans Clemente and San Juan Capistrnao.
should be standardized and should have the came emergency planning 25 zone for the plume exposure passway specified in each of the 26 principal response organizations' plans.
The exact extent of the
~
zone will be set out below.
~
1.
The existence of the potential conflict and discrepan-
1 cies between the various emergency planning zones which in the 2
"'O local response organizations plans A confirmed by Mr. Grimes 3
of the NRC. (Grimes,Tr. 11,164.)
4 2.
How the Line was Drawn.
5 I67 It is apparent from a review of the record that the 6
Applicant defined the extent and boundary of the zone.
The local 7
planning officials acceded to the superior knowledge of the Appli-O cants' consultants with respect to the NRC regulations and guide-9 lines.
It is clear from a review of the testimony of these con-10 sultants, Mr. Woodard and Mr. Murri, that the Applicants' recommen-11 dations to the various local agencies contained very conclusive 12 weight.
(Turner, Tr. 8938; Hunt, Tr. 9253.)
13 ifh.
The Applicants' experts testimony indicates that the 14 consulting firm of Pickard, Lowe and Garrick (PL&G) made a review 15 of the characteristics of the site compared with reactor safety 16 study th'at was used in the formulation of the ten mile generic 17 boundary in NUREG-0396, The consultants argued that because 18 certain site specific characteristics at San Onofre made either 19 the risk and the consequences different than the factors considered 20 in the reactor saf[ty study in NUREG-0396 that less than a ten mile 21 EZ was necessary for SONGS.
.The Board finds that this is not the 22 type of analysis which is contemplated by the regulations asking 23 the local planning officials to consider the local demography I
topography and other site specific characteristics.
In fact this l
25 expert testimony is an attempt to challenge the regulation and is 26 therefore inpermissible.
The Applicants' use of dispersion analy-27 sis and comparative dispersion analysis to justify a ten mile EPZ l
28 or a less than ten mile EPZ to the local planning officials usurped 53
1
_the local planning officials independent. judgment as to the use 2
in the drawing of these boundary lines to take into consideration 3
the pragmstic characteristics of the local plant and populations.
4 It is no biore permissible to use a dispersion analysis to justify 5
lowering the boundary of the EPZ than it is to use such analysis 6
to extend the EPZ beyond the generic ten mile l'imit.
The latter 7
was ruled out in the case of the EAI report which the Intervenors 8
attempted to argue justified increasing the size of the EPZ.
9 (Woodard Direct Testimony.)
10
-[y@,The Applicants' definition of the EPZ in fact uses site 11 specific characteristics only to decrease the size of the EPZ.
12 This is done in two places.
The first along San Juan Creek to the 13 north, the San Juan Creek bed is followed instead of the ten mile 14' concentric circle which dips under the ten. miles and bisects San 15 Juan Capistrano and Dana Point.
Also the App'licants'did not 16 include an area in Riverside County which is contained within the 17 if drawn at a ten mile zone based on their analysis that there EPZ 18 was insufficient population to warrant planning.
19
$D.
The Applicants' attempt to get around obvious arbitrary 20 character of their determination of the emergency planning zone 21 by creating a novel zone, th'e " extended zone".
This zone does not 22 appear anywhere in the regulations.
The Applicants' attempt to 23 create an emergency planning' zone for some purposes and other' 24 emergency planning zones for other purposes.
(Tr. 8725).
There is 25 no authority and they have provided no such authority for these
~
26 l
various planning zones.
They argue that the "e'xtended NPZ" is 27 an emergency planning zone for informational and evacuation pur-O poses but that it does not need to have adequate sirens.
The Ff 9
1 Board finds that the emergency planning zone must be an emergency 2
planning zone for all purposes and that to create additional zones which are not found in the regulations might lead to confusion.
3 (Pilmer, written testimony;. )
4
'(bl.
The record reflects that confusion took place in this 5
case as the public information packages were not sent to the 6
extended EPZ as defined by the Applicant.
(Ferguson, Tr. 8718.)
' fh 7'.
In fact the use of this term created confusion in the 7
local emergency planning official as to what the emergency planning 8
zone is.
Mr. Turner, a representative from Orange County Emergency 9
Planning Agency, indicated that the City of San Juan Capistrano 10 was contained within the emergency planning zone while the witness 11 from San Juan Capistrano indicated that it was not.
(Ferguson, 12 Tr. 8725; Turner, Tr. 8738.)
13 l$h.
It is clear from the records that not all local juris-14 dictions were even made privy to the emergency planning zone
~
15 decision.
Mr. Stowe, the representative from the State Parks and 16 Beaches,'was not consulted with respect to the size of the emergency 17 zone even though his beaches extend beyond the concentric circle 18 to the south.
(Stowe, Tr. 8556).
Firechief Coleman, the emergency 19 planning coordinator for the City of San Clemente, war not con-l 20 sulted with respect to the formation of the eme gency planning 21 zone.
(Coleman, Tr. 8630.)
22 jgp While the City of San Juan Capistrano was consulted their s.
23 recommendation was ignored.
They wanted their entire city to be 24 contained within the emergency planning zone b.ut the Applicants' 24 declined to accede to their request.
(Ferguson, Tr. 8725.)
26 Mr'.nMechdM7indicatpf'that'the City Council of San Clemente was not 27 considered in the drawing of the emergency planning zone boundaries.
28 (Mechum, Tr. 10,054.)
$5
([.
Mr. Hunt, representative from the energency planning 1
2 organizations.in San Diego County, indicated that he was consulted i
3 by the Applic' ants' consultants and he was convinced to draw the boundary linelas a concentric circle.
He pointed out that most 4
5 of the EPZ south of the plant is contained in part of the Camp
~
6 Pendleton Marine Base and only small portions north of_the Marine 7
Base near Riverside County are contained within San Diego County.
8 (Hunt, Tr. 9253.)
9
-(%.
There is no indication that anyone fron the City of 10 Riverside was ever consulted with respect to drawing the emergency 11 planning zone to exclude Riverside County for the Applicants' There is also no evidence presented in the, record by 12 purposes.
13 any party which would show that the Marine Corps was consulted 14 in drawing the EPZ boundary as a concentric circle to bisect the 15 Marine Reserve.
16 f(r7.
It is interesting to point out that the emergency 17 planning official for orange County, Mr. Turner, indicates that 18 there is no such thing as an " extended planning zone" as referred 19 to by the Applicants.
In fact that term is being confused with a 20 term known as the " extended planning zone" as provided by the State 21 of California.
(Turner, Tr. 8938.)
22
[b6.
The records indicate that the State of California has developed an additional emergency planning to supplement the' 2
24 NRC ten mile EPZ guidelines.
The State of California has an 2~R emergency planning' zone called the bayic planning zone which is 26 equivalent to the NRC plume exposure pathway EPZ.
(Intervenors Exhibit 23, page 10.)
It encompasses San Juan Capistrano and 27 28 Dana Point on the north edge of the sector and it encompasses the
I entire Camp Pendleton Marine Base on the south.
2 l69.
In addition to this planning zone the State of California 3
has developed what it calls an " extended planning zone" which 4
extends approximately ten miles from the basic planning zone.
5 The extended planning zone was created by the State of California 6
because it feels that planning greater than ad hoc measures 7
should be in place beyond the basic evacuation zone which is the 8
plume exposure passway EPZ.
This extended planning zone is not a 9
concern of this hearing except as it might impact upon the emer-10 gency response required by the NRC regulations.
(Kearnf, Tr. 10,15C) 11 (10 The Board finds that there is potential confusion in 12 terminology between what the Applicants have labeled extended 13 planning zone for siren purposes and the extended planning' zone 14 used by the State of California.
There should be only one emer-15 gency planning zone under the NRC regulations and that should be 16 the plume exposure pathway EPZ for all purposes.
If the Applicants 17 propose to now comply with certain regulations for parts of that 18 emergency planning zone, i. e.
for the sirenc, they should meet 19 that regulation directly and propose their reasons why compliance 20 is not necessary rather than by redefining the zone to produce -
21 compliance.
22 3.
The Proper EPZ Determination.
f7[.
The Board would note its concern that the Applicant did 24 not discuss with Riverside County the possibility of having an 25 emergency response plan based on their inclusion in the ten mile 26 emergency planning zone.
In that regard the Board points out 27 that San Diego County has only a similar amount of territory in 28 similar location within the plume exposure pathway concentric 97
I circle EPZ.
(Hunt, Tr. 9279.)
The rationale for the plume 2
exposure pathway EPZ is that a jurisdiction ~will plan for the EPZ 3
and therefore have plans in place so that they may react and have 4
a basis for their:ad hoc reaction for emergencies which might 5
extend beyond ten miles.
The Board finds that just as it is 6
appropriate to have San Diego to develop emergency response plan 7
because of their proximity to the nuclear power plant, it is also 8
prudent to include Riverside County in the emergency planning dis-9 cussions and therefore the Board determines that the emergency 10 planning EPA should include that portion of Riverside County 11 which would be contained in the concentric circle at the tem mile 12 zone.
13
[71' The Board is also concerned that there is no evidence 14 in the record that the Marine Corps was ever consulted in the draw-15 ing of this boundary line.
The Marine Corps' SOP was developed 16 prior to the adoption of NUREG-0396, 06.54 and the various planning 17 sta.sdards relating to emergency planning zones.
It is unclear, 18 in fact, whether the emergency planning zone is anywhere indicated 19 in the Camp Pendleton plan.
The only evidence in the record with 20 respect to considering the Camp Pendleton Marine Corps Base is 2I that"provided by Mr. Kearns from the State Office of Emergency 22 Services who indicated (Tr. 10,152) that the State of California 23 believes that the NRC regulatio.. would be property complied with 24 by including the entire Marine Corps Base which only extends to 25 approximately 15 miles from the plant within the plume exposure 26 pathway EPZ.
One obvious reason for this is that the Marine Corps 27 plan calls for them to march into the~ back. country of Camp Pendleton 28 which is a mountainous area with few roadways and, if any accidents
i 1
in the area escalated to the point where additional territory 2
needed to be evacuated and measures needed to be taken, the Marine 3
Corps would be totally unplaAned for and any of their attempts to 4
evacuate using the Highway 5 towards San Diego would be very 5
difficult without going back into the emergency planning zone and 6
risking exposure.
Indeed the emergency plan for the Marine Corps 7
indicates that they intend to be able to redeploy to the emergency 8
planning zone within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
(Applicants' Exhibit 58).
The 9
Board finds therefore that the entire Camp Pendleton Marine Corps 10 Base should be included withinithe plume sxposure pathway EPZ for 11 emergency planning purposes.
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1 PROPOSED LICENSE CONDITIONS 2
Because of the seriousness of the emergency planning preparedness issue after three Mile Island it is 3
necessary to restore the public confidence and faith in the nuclear power industry in general, the Board 4
feels it appropriate to outline certain conditions to the applicants' license to operate the plant in 5
the emergency planning area:
6 1.
The secondary meterological tower must be installed 7
and in operation by July 1982 as set forth in the Applicants' 8
testimony and exhibits.
9 2.
The Health Physics Computer System must be installed 10 and operational by December 31, 1982.
11 3.
The utilities and local jurisdictions must establish 12 a communication link with the National Weather Service by formal 13 agreement to access meterological information in the event of an 14 emergency before full power operation of the plan, 15 4.
A dose designation system for the sectors of evacuation 16 coordinated among the various emergency response organizations 17 should be set up to monitor offsite radiation releases before 18 full power operation of the plant.
19 5.
Public information posters sh81 be prominently displayed 20 in representative local businesses in the-community within the 21 emergency planning zone as well as signing at public beaches and 22 other areas where transient might congregate before the full 23 power operation of the plan.
24 6.
That applicants'shall provide public information 25 materials in Spanish and posters in public places should be 26 bilingual before full power operation of the plan.
27 7.
A follow-up survey should be done within the plume 28 exposure pathway EPZ to indicate whether or not the populace has CO
1 received and understands the emergency preparedness information on 2
or before December 31, 1982.
3 8.
The applicants in conjunction with local response 4
organizations should mail the emergency response pamphlet and 5
handbook to the residents in the plume exposure pathway EPZ at 6
least once a year during their annual public information program.
7 9.
An integrated and operating procedure for coordination g
of protective action decisions should be in place before full 9
p wer operation of the plant.
10
- 10. Coordinated drill of radiological response monitoring 11 assessment together with protective action decision making should 12 be done and reviewed before full power operation of the plant.
13
- 11. The installation of an additional dedicated telephone 14 line for use by decision makers coordinating protective action.
15 decisions and them alone should be implemented prior to December 16 31, 1982.
17
- 12. A SOP for discrimination between the use of various 18 redundant communsations systems between various local response 19 organizations should be drafted and in place prior to full power 20 operation of the SONGS.
21
- 13. Energency plan for the county of Riverside should be 22 drafted to cover the part of that county included in the plume 23 exposure emergency planning zone prior to December 31, 1982.
24
- 14. The SOP for the Marine Corps Emergency Plan should be 25 revised in accordance with including the entire camp within the 26 plume exposure emergency planning zone.
27
- 15. Applicants' and the local jurisdictions must demonstrate 28 that there are emergency plans in place to provide protective Qf
1 response action for special population groups such as the elderly, 2
physically handicapped and children before full power operation
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of the plant.
4
- 16. There must be an independent review of the Wilbur Smith 5
study and the computor program which underlies it before December 6
31, 1982.
7
- 17. Further update of the applicants' time estimate study 8
should be made with a detailed description of proposed population 9
increases and demonstration of use of alternative routes and future.
10 18'.' A completed emergency operations facility offsite 11 meeting the updated requirements of NUREG-0696 shl1 be completed before December 31, 1982.
12 13
- 19. A completed siren system tested and operational into 14 all areas of the EPZ including all of Dana Point and San Juan 15 capistrano to be in effect prior to full power operation of the 16 plant.
17
- 20. The permanent emergency operations facility shall be 18 in place by December 31, 1982.
19 20 21 i
22 23 24 l
l 25 26 27 28 l
I-1 2
CONCLUSIONS OF LAW U on consideration of the record of the proceeding and P
3 4
in light of the foregoing findings and discussion, the Board 5
concludes that, with respect to the requirements of the Atomic-6 Energy Act of 1954, as amended, and the rules and regulations of 7
the commission relating onsite and offsite planning and emergency 8
Preparedness:
9 (1) The Plume and Extended EPZs' established for 10 SONGS do not meet the requirements of 10 C.F.R. 11 S50. 47 (c) (2).
12 (2) The principal offsite emergency response 13 organizations do not have the capability to 14 respond to emergencies at SONGS 2 and 3 and to 15 augment this initial response on a continuous 16 basis as required by 10 C.F.R. S50.47 (b) (1).
17 (3) Applicants' capability to notify involved 18 most State and local emergency response 19 organizations meets the requirements of 10 20 C.F.R. S'50. 4 7 (b) (5) and Part 50,-Appendix E.IV, 21 except for San Juan Capistrano and the State 22 Parks and beaches.
23 (4) The capability of Applicants and the 24 involved offsite emergency response organizations l
25 to. notify and alert the various agencies and 26 Personnel involved in responding to a 27 radiological emergency at-SONGS 2 and 3 does not 28 meet the requirement of 10 C.F.R S50.47 (b) (6)
I and Part 50, Appendix E.IV.
2 (5) The capability of Applicants and the involved offsite 3
emergency response organizations to implement continued 4
communication among all involved organizations does not 5
meet the requirements of 10 C.F.R. S 50.47 (b) (6) and 6
Part 50, Appendix E.IV.
7 (6) The various onsite and offsite emergency response 8
organization notification and communication systems are 9
not adequate and capable of being implemented in 10 compliance with 10 C.F.R. 550. 4 7 (b) (5) and (6) and Part 11 50, Appendix E.IV.
12 (7) Each of the principal response organizations has 13 an emergency operations center but does not have the 14 communications and transportation equipment necessary 15 to support its role during an emergency at SONGS 2 and 16 3 affecting the offsite transient and permanent 17 population in compliance with 10 C.F.R. S50.47 (b) (8).
18 (8) Applicants' emergency response planning and 19 implementation capability as regards the physical.
20 design, communications equipment, and operating 21 procedures for the Interim EOF does not meet the 22 requirements of 10 C.F.R. S50. 47 (b) (3) and (b) (8) 23 and Part 50, Appendix E.IV.
.24
,(9) The Applicants' capabilities to accomplish all 25 necessary offsite radiological dose assessment and 26 protective action recommendation functions do not 27 satisfy the standards for offsite dose assessment 28 and radiation monitoring capability set forth in
1 10 C.F.R. S50. 4 7 (b) (9) without the need to consider 2
the additional offsite radiation monitoring and 3
dose assessment capabilities of Federal, State and 4
local agencies.
5 (10) The plans, procedures and capabilities of the 6
involved offsite jurisdictions and supporting 7
Federal, State and local agencies to perform radiation 8
monitoring and dose assessment, as coordinated in the 9
Offsite Dose Assessment Center, do not satisfy the 10 standards for offsite dose assessment and radiation 11 monitoring capability required by 10 C.F.R.
S50.47 12 (b) (9).
13 (11) The plans, procedures and capabilities of the 14 State and local jurisdictions and SCE to assess and 15 monitor actual or potential offsite consequences of 16 a radiological emergency condition within the
~
17 Ingestion EPZ are not adequate and do not satisfy 18 the requirements of 10 C.F.R.
S50.47 (b) (9).
19 (12) The radiological emergency response training 20 being provided to onsite personnel at SONGS-who may 21 be called upon to assist in an emergency is not 22 adequate and does not satisfy the requirements of 23 10 C.F.R.
S 50. 47 (b) (15).
24 (13) Insufficient. radiological emergency response 25 training has been provided to onsite and offsite 26 emergency response personnel who may be called on 27 to assist in an emergency ~and such training 28 satisfies the requirements of 10 C.F.R.
S5 0. 4 7 (b) (15 )'.
O 1
(14) Adequate arrangements for medical services for 2
contaminated and injured individuals have not been 3
made in compliance with 10 C.F.R. S50.47 (b) (12).
4 (15)The information and procedure for dissemination 5
of such information to the public within the 6
Plume and Extended EPZs on a periodic basis is not 7
adequate to inform the public on how they will be 8
notified and what their actions should be in the event 9
of an emergency in compliance with 10 C.F.R.
S50. 4 7 (b) 10 (7) and Part 50, appendix E.IV.
11 (16) The physical and administrative means for 12 Prompt emergency notification to the populace within 13 the Extended and Plume EPZs is not adequate and does 14 not meet the requirements of 10 C.F.R. 550.47 (b) (5) 15 and Part 50, Appendix E.IV.
16 (17)The means to provide instruction to the 17 Populace within the Extended and Plume EPZs is not 18 adequate and does not meet the requirements of 19 10 C.F.R.
S50. 47 (b) (5).
20 (18) The general plans of SCE and the local response 21 agencies for recovery and reentry following a 22 radiological emergency at SONGS 2 and 3 are not
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23 adequate and do not satisfy the requirements of 24 10 C.F.R.
S 50.45 (b) (13) and Part 50, Appendix E.IV.
25 (19) There is not reasonable assurance that the 26 offsite transient and permanent population within 27 the Extended and' Plume EPZs for SONGS 2 and 3 can 28 be evacuated or otherwise adequately protected in G2 5'
I the event of a radiological emergency with offsite 2
consequences, as required by 10 C.F.R.
S50. 4 7 (a) 3 (1), (b) (10) and Part 50, Appendix E.IV.
4 (20) The onsite and offsite radiological emergency 5
response plans are not adequate, and the capability 6
to implement these plans currently does not exist.
7 (21) The overall state of onsite and offsite 8
emergency planning and preparedness does not provide 9
reasonable assurance that adequate protective measures 10 can and will be taken in the event of a radiological 11 emergency involving SONGS 2 and 3, as required by 12 10 C.F.R. 550. 47 (a) (1) 13 14 15 16 17 18 19 20 21 22
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23 24 25 26 27 28 (2(h
n u.trEn wc 1
'81 NOV 27 P3:46 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION k
1. EEC?Ei/3Y BEFORE THE ATOMIC SAFETY AND LICENSING.-
9VICE I
In the Matter of
)
)
Docket Nos. 50-361 OL SOUTHERN CALIFORNIA EDISON COMPANY,
)
)
)
(San Onofre Nuclear Generating Station,)
Units 2 and 3)
)
CERTIFICATE OF SERVICE I hereby certify that copies of Intervenors Proposed Findings of Fact and Conclusions of Law on Emergency Planning and Preparedness Issues dated November 20, 1981 in the above captioned proceedings was served on the following parties by deposit in the United States mail -or if indicated by an. asterisk by expedited overnight service on November 24, 1981 i
44 James L.
Kelley, Esq., Chairman 3% David R.
Pigott, Esq.
Administrative Judge Samuel B.
Casey, Esq.
Atomic Safety and Licensing Board John A. Mendez, Esq.
U.S.
Nuclear Regulatory Commission Edward B.
Rogin, Esq.
Wa shing ton, D.C.
20555 of Orrick, Herrington & Sutclifft A Professional Corporation qq Dr. Cadet H.
- Hand, Jr.,
600 Montgomery Street Administrative Judge San Francisco, California 94111 c/o Bodega Marine Laboratory University of California Alan R.
Watts, Esq.
P.O.
Box 247 Daniel K.
Spradlin Bodega Bay, California 94923 Rourke & Woodruff 1055 North Main Street, #1020 Santa Ana, California 92701 l
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KMrs. Elizabeth B. Johnson, Richard J. Wharton, Esq.
Administrative Judge
' University of San Diego Oak Ridge National Laboratory School of Law Alcala Park P. 'O. Box X, Building 3500' San Diego, California 92110 Oak, Ridge, Tennessee 37830 Mrs.' Lyn Harris Hicks Janice E. Kerr, Esg/
GUARD J. Calvin Simpson, Esq.
3908 Calle Ariana Lcwrence O. Garcia, ESg.
San Clemente, California 92672 California Utilities Commission 5066 State Building A.
S. Carstens San Francisco, California 94102 2071 Caminito Circulo Norte Mt. La Jolla, California 92037 Charles R. Kocher, Esq.
James A. Beoletto, Esq.
g Richard K. Hoefling, Esq.
Southern California Edison Company Lawrence J. Chandler, Esq.
4244 Walnut Grove Avenue Donald Hassel, Esq.
Rosemead, California 91770 U. S. Nuclear Regulatory Commission David W. Gilman Office of the Executive Robert G. Lacy Legal Director San Diego Gas & Electric Company Washington, D. C. 20555 P. O.
Box 1831 San Diego, California 92112 Atomic Safety and Licensing Appeal Board Panel Phyllis M.
Gallagher, Esq.
U. S. Nuclear Regulatory 1695 West Crescent Avenue Conunission Suite 222 Washington D. C.
20555 Anaheim, California 92701 Secretary Robert Dietch, Vice Presiden't U. S. Nuclear Regulatory Comm.
Southern Edison California Company Attn:
Chief, Docketing &
P.
O.
Box 800 Service Branch 2244 Walnut Grove Avenue Washington, D. C.
20555 Rosemead, California 91770 1
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l Charles E. McClung, Jr.
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