ML20039C703
| ML20039C703 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 12/28/1981 |
| From: | Grimes B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20039C699 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8112300060 | |
| Download: ML20039C703 (9) | |
Text
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UNITED STATES OF A!1 ERICA NUCLEAR REGULATORY C0 tit 11SSION BEFORE THE AT0111C SAFETY AND LICENSING ROARD In the !!atter of
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SOUTliERN CALIFORNIA EDIS0N C0f1PANY, Docket Nos. 50-361 OL ET AL.
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50-362 OL
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(SanOnofreNuclearGeneratingStation,)
Units 2 and 3)
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AFFIDAVIT OF BRIAN K. GRIMES ity nane is Brian K. Grimes.
I am Director, Division of Energency Preparedness, Office of Inspection and Enforcenent, U.S. Nuclear Regulatory Commission, Was# ngton, D.C.
My professional qualifications have been admitted in the reco.-d of this proceeding following Tr.10,996.
This affidavit is subnitted to address the significance of the "FEf1A Region IX Update Evaluation with Respect to the Adequacy of Plans and the Implementation Capabilities of State and Local Governments Related to San Onofre Nuclear Generating Station" dated Novenber 16,1981 (the FEr1A Update Evaluation).
1.
On September 30, 1981 in this proceeding, I discussed the nature of the seven items which are listed on Enclosure 2 to Applicants' Exhibit 144 and which identify the substance of the corrective action program developed by Applicants and concurred in by the Federal Emergency i
fianagement Agency (FEt1A) to achieve a favorable FEf1A finding with respect to offsite emergency preparedness for the San Onofre Nuclear Generating Station, Units 2 and 3 (Tr. 11,159-164).
2.
I was of the view then and continue to be of the view that the seven itens identified in Enclosure 2 to Applicants' Exhibit 144 are Mk $O00 0 00 G
items whose resolution is basically straightforward. This is also the case with respect to an eighth item identified during the hearing dealing with the precise boundary of the plune exposure pathway energency planning zone (EPZ). With respect to each of these items, I would like to reiterate in this affidavit my reasons fac concluding that their resolution is straightforward and I woulu al ta like to explain why this reasoning is consistent with the information provided in the FE tA Update Evaluation.
I will discuss each of the items in series. References will be to the pertinent sections of the FE!1A Update Evaluation.
Iten 1: This iten calls for a number of standard operating procedures (S0Ps) to be developed. SOPS can be compared to the procedures.which the NRC requires to be developed and in place at a nuclear power plant prior to operation. These procedures are not reviewed by the NPC staff in the development of the staff's Safety Evaluation Report wherein the staff reaches its conclusions with respect to reasonable assurance with respect to the adequacy of the facility. That conclusion is based on information contained in the Facility Safety Analysis Report (FSAR). The more detailed procedures are examined during the inspection process carried out by the Office of Inspection and Enforcement to determine that comitments and designs provided by the licensee in the FSAR were indeed carried out.
The development of SOPS is similar to the developnent of plant procedures. Prior finalization of SOPS is not, in my judgment, needed to make a finding of reasonable assurance. Rather, this area can be left to the oversight of FEMA and the WC staff for final implementation. While
it is unfortunate that this item has not been corrected by the Applicants and the State and local jurisdictions, the deficiency is readily correctible and due diligence by the parties involved should resolve this matter.
Items 2 and 3: These itens deal essentially with procurenent of equipnent to carry out radiation monitoring and supplenental comunica-tions capability. These items require checking to see whether appropriate equipnent has been procured and installed. While some exercise of judgenent nay be necessary to determine whether adequate quantities of equipment have been procured, this exercise of judgement is straightforward and could be characterized as an inplementation iten.
The FEttA Update Evaluation indicates that nearly all of the equipment has been delivered but that there is sone uncertainty surrounding equipment lists.
I consider this to be a minor point requiring only clarification.
Substantively, I conclude from the FEttA Update Evaluation that both of these items have been essentially resolved.
Item 4: This item concerns implementing physical improvements to the interim Emergency Operations Facility (E0F). This item called for such improvements which were feasible given the limitations in physical space at the interim E0F facility. With the exception of a drill to test facility and personnel functions (IV.B.), this item has been resolved to the satisfaction of FEttA (111.0.2.) The conduct of a drill to ensure proper execution of functions is an inplementation item of a i
straightforward and confirmatory nature and can be left to the oversight of FEMA and the NRC staff.
Item 5: This item deals with the installation of sirens. The siren systen installation is complete. What is required is a test of the sirens and, as I have indicated above, in discussing Iten 4, such a test is an implementation itea and can be left to the oversight of FEMA and the NRC staff.
Iten 6: This item deals with completion of training in the use of new and existing procedures facilities and equipment. This item requires evaluation but again is analagous to the type of showing required by the NRC staff at a nuclear facility during the Office of Inspection and Enforcement inspection process rather than the showing required in t!.c FSAR to support the issuance of a safety evaluation report. Again, completion of the training program is not necessary for a finting of reasonable assurance to be made.
Rather completion of the training progran is an inplementation item of a straightforward nature and due diligence on the part of the Applicants and the State and local jurisdictions would assure its timely resolution.
Itea 7: This item deals with development of a Public Information Program.
While exercise of judgement is required in reviewing such a progran, needed improvements identified are of a nature that could be rectified during an annual update of the progran rather than an item which required rectification prior to the issuance of a license.
In any event, this h
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- ite., has been evaluated by FEMA ard found to be acceptable. (III.G.7; IV.D).
Item 8: This iten deals with the precise boundaries associated with the plume exposure pathway EPZ. At the hearing, Applicants proposed an plume exposure pathway EPZ which extended to San Juan Creek to the north. This boundary bisected San Juan Capistrano and did not include Dana Point. Emergency planning in the northern portion of San Juan Capistrano and Dana Point is complete with respect to the regairenents imposed upon the plume exposure pathway EPZ, with the exception of the requirement for pronpt notification. FE!1A recommends that the plume exposure pathway EPZ include the entire jurisdiction of San Juan Capistrano and also Dana Point and consequently some form of prompt alerting in these areas is recommended.
(III.C;IV.C)
The NRC staff has no objection to the FEMA recommendation. With respect to the requirement for prompt notification, NUREG-06541/
(p. 3-3, Appendix 3) sets out criteria with respect to the means for providing prompt alerting and notification to the population. While the criteria do call for the capability of providing an alert signal throughout the plume exposure pathway EPZ within 15 minutes, it is 1/
" Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants",
NUREG-0654, FEMA-REP-1, Revision 1, November 1980.
sufficient that there be direct coverage of essentially 100% of the population within 5 miles and special arrangements made to assure 100%
coverage within 45 minutes of the population who nay not have receives initial notification within the entire plume exposure pathway EPZ. There was evidence in this proceeding that helicopters and energency vehicles equipped with loud speakers would be available to alert and notify the public within the expanded plume exposure pathway EPZ.
( Appl icants '
Exhibit 53 Section V.B.2.a(1); Turner, Tr. 8917; Colenan, Tr. 8597-8598; Killingsworth, Tr. 8271-8281).
Additional sirens are also a feasible option.
Consequently, the resolution of this iten can be readily achieved once agreenent is reached anong local jurisdictions with respect to the precise boundary of the plune exposure pathway EPZ. The areas which will require supplemental notification are well defined, and the capabilities that are available to assist in that notification are also well defined.
The staff has no objection to implenentation of the FEMA reconnendation but considers this to be a straightforward item which can be left for resolution prior to full power operation by the NRC staff in conjunction with FEMA.
In sunnary, I continue to be of the opinion that the remaining outstanding deficiencies do not prevent the Board from making its required reasonable assurance finding on the issues in controversy. To 4
the extent final implementation is not yet complete or has not been confirmed, these matters can be left to the oversight of the NRC Staff in conjunction with FEf1A.
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I declare under perjury of penalty that the aforegoing is true and Correct.
ExecutedonDecemberM,1981
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%,J5 Brian K., Grimes Subscribed and sworn to bafore me, in my presence, this 28th day of December 1981.
My Commission Expires July 1, 1982
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,0.c i... : k u I.,J..... '
Notary Public
e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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SOUTHERN CALIFORNIA EDISON COMPANY,
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50-362 OL
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(San Onofre Nuclear Generating Station, )
Units 2 and 3)
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CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF RESPONSE TO CONSOLIDATED INTERVENORS' MOTION TO RE0 PEN THE RECORD" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or as indicated by an asterisk through deposit in the Nuclear Regulatory Commission's internal mail system, this 28th day of December, 1981:
- James L. Kelley, Esq., Chairman David R. Pigott, Esq.
Administrative Judge Samuel B. Casey, Esq.
Atomic Safety and Licensing Board John A. Mendez, Esq.
U.S. Nuclear Regulatory Commission Edward B. Regin, Esq.
Washington, D.C.
20555 Of Orrick, Herrington & Sutcliffe A Professional Corporation Dr. Cadet H. Hand, Jr.,
600 Montgomery Street Administrative Judge San Francisco, California 94111 i
c/o Bodega Marine Laboratory University of California Alan R. Watts, Esn.
P. O. Box 247 Daniel K. Sprsdlin Bodega Bay, California 94923 Rourke & Woodruff 10555 North Main Street Mrs. Elizabeth B. Johnson, Suite 1020 Administrative Judge Santa Ana, California 92701 Oak Ridge National Laboratory P. O. Box X, Building 3500 Richard J. Wharton, Esq.
Oak Ridge, Tennessee 37830 University of San Diego School of Law Alcala Park Janice E. Kerr, Esq.
San Diego, California 92110 J. Calvin Simpson, Esq.
Lawrence Q. Garcia, Esq.
Mrs. Lyn Harris Hicks California Public Utilities Commission GUARD 5066 State Building 3908 Calle Ariana San Francisco, California 94102 San Clemente, California 92672
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. Charles R. Kocher, Esq.
A. S. Carstens Jaces A. Beoletto, Esq.
2071 Caminito Circulo Norte Southern California Edison Company Mt. La Jolla, California 92037 2244 Walnut Grove Avenue Rosemead, California 91770
- Atomic Safety and Licensing Board Panel David W. Gilman U.S. Nuclear Regulatory Commission Robert G. Lacy Washington, D.C.
20555 San Diego Gas & Electric Cocpany P. O. Box 1831
- Atomic Safety and Licensing Appeal San Diego, California 92112 Board Panel U.S. Nuclear Regulatory Commission Phyllis M. Gallagher, Esq.
Washington, D.C.
20555 1695 West Cre: cent Avenue Suite 222
- Secretary Anaheim, California 92701 U.S. Nuclear Regulatory Commission ATTN: Chief, Docketing & Service Charles E. McClung, Jr., Esq.
Branch Flering, Anderson, McClung & Finch Washington, D.C.
20555 24012 Calle de la Plata Suite 330 Laguna Hills, CA 92653 Lawrence J. Chandler Deputy Assistant Chief Hearing Counsel