ML20039F707
| ML20039F707 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 01/06/1982 |
| From: | Sears J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20039F620 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8201130254 | |
| Download: ML20039F707 (47) | |
Text
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UNITED STATES OF AMERICA F
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of PACIFIC GAS AND ELECTRIC COMPANY Docket Nos. 50-275 OL 50-323 OL (Diablo Canyon Nuclear Power Plant, Units 1 and 2)
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i TESTIMONY OF JOHN R. SEARS OF THE NRC STAFF ON THE EMERGENCY PLANNING CONTENTION ADMITTED BY BOARD ORDER OF AUGUST 4, 1981 FOR DIABLO CANYON, UNITS 1 AND 2 i
d JANUARY 6, 1982 i
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TESTIMONY OF JOHN R. SEARS OF THE NRC STAFF ON THE 2
EMERGENCY PLANNING CONTENTION ADMITTED BY BOARD ORDER OF AUGUST 4. 1981 FOR DIABLO CANYON UNITS 1 AND 2 4
6 Q.1.
State your name and position with the NRC?
A.
John R. Sears.
I am employed by the U.S. Nucelar Regulatory 8
Commission (NRC) as a Senior Reactor Safety Engineer in the Emergency Pre-paredness Licensing Branch, Division of Emergency Preparedness, Office of 10 Inspection and Enforcement.
I l'2 Q.2.
Have you prepared a statement of professional qualifications?
A. -Yes.
A copy of my statement of professional qualifications is 14 attached to this testimony.
4 16 Q.3.
State the nature of the responsibilities that you have had with 1
respect to the Diablo Canyon Power Plant, Units 1 and 2.
18 A.
I have been responsible for reviewing and evaluating the Diablo Canyon Nuclear Power Plant, Units 1 and 2 Emergency Plan for conformance 20 with the planning standards and requirements of 10 CFR Part 50, Appendix E t
j to Part 50 and the evaluation criteria of NUREG-0654, FEMA-REP-1, " Criteria 22 for Preparation and Evaluation of Radiological Emergency Response Plans and 4
Preparedness in Support of Nuclear Power Plants" (NUREG-0654).
As part of I
l 24 my responsibilities in reviewing and evaluating the Diablo Canyon Huciear l
Power Plant, Units 1 and 2 Emergency Plan, I am also responsible for 26
-addressing the emergency planning contention concerning Pacific Gas and Electric Company's (PG&E or Applicant) Emergency Plan for Diablo Canyon, 1
4 28 Units 1 and 2 and onsite emergency planning and preparedness.
i 30 Q.4.
What is the purpose of this testimony?
A.
The purpose of this testimony is to address the admitted emergency 32 planning contention, Contention 1 (as restated by the Board), raised by Joint Intervenors which is related to Applicant's Emergency Plan and onsite emer-34 gency prepared 0ess. My testimony will address the Applicant's state of emergency preparedness as described in the Diablo Canyon Emergency Plan 36 Revision 3, August 1981 and implementing Emergency Procedures as it affects this contention for each of the planning standards of 10 CFR Section 50.47(b).
38 Q.5.
Does the Diablo Canyon, Units 1 and 2 Emergency Plan describe the 40 organization for coping with radiological emergencies, including definition of authorities, responsibilities, and duties of individuals assigned to the 42 Applicant's emergency organization? If yes, explain.
A.
Yes. Emergency Procedure G-2 describes the responsibilities and 44 the actions required by plant personnel for establishing the On-Site Emer-gency Organization and indicates the preferred candidates to fill each 46 position. The transition from a normal operating organization to an Un-Site Emergency Organization involves three basic steps:
48 a)
Filling appropriate On-Site Emergency Organization positions on an interim basis with personnel who are immediately available on I
50 site at the time of the emergency; b)
Notifying plant personnel off-site and.on-site that their 52 assistance is required; and i
c)
Filling positions in the long-term emergency organization with 1
l 54 appropriate plant personnel as they arrive at their designated emergency response facilities.
56
i
, l Q.6.
Does the Applicant's Emergency Plan identify the State, local, 58 federal and private sector organizations that are intended to be part of the overall response organization? If yes, explain.
60 A.
Yes.
Emergency Procedure G-3, Notification of Offsite Organi-zations includes Attachments 3 and 4.
These attachments contain a Required 62 Offsite Organization Call List and a Other Offsite Organization Call List which include the following:
64 San Luis Obispo County; Corporate Emergency Recovery Manager; 66 California Office of Emergency Services; U.S. Nuclear Regulatory Commission; 68 Institute of Nuclear Power Operations; Nuclear Safety Analysis Center; 70 U.S. Coast Guard; California Parks and Recreation Department; 72 Westinghouse; Southern California Edison Company; and 74 Sacramento Municipal Utility District.
The Emergency Plan includes, in Appendices, the following:
76 French Hospital Emergency Response Plan; U.S. Department of Energy Interagency Radiological 78 Assistance Plan; 80 Condor helicopters and Aviation Inc.--letter of agreement; Roger's Helicopters--letter of agreement; 82 Rotor-Aids Inc.--letter of agreement; Air Ambulance Inc.--letter of Ereement; i
, 84 San Luis Ambulance Service--letter of agreement; San Francisco Ambulance Service--letter of agreement; 86 American Red Cross--letter of agreement; California Highway Patrol--letter uf agreement; 88 California Department of Corrections--letter of agreement; California Department of Health Services--letter of agreement; 90 California Department of Fish and Game--letter of agreement; California Department of General Services--letter of agreement; 92 California Department of Hilitary--letter of agreement; California Department of Rehabilitation--letter of agreement; 94 California Department of Transportation--letter of agreement; California Department of Youth Authority--letter of agreement; and 96 California Department of Forestry--letter of agreement.
98 Q.7.
Dbc-the Applicant's Emergency Plan specifically establish the emergency responsibilities of the various onsite support organizations?
100 If yes, explain.
A.
Yes. Table 1 of Emergency Procedure G-2 specifically describes l
102 the responsibilities of the following individuals and groups in the On-Site Emergency Organization:
104 Site Emergency Coordinator, including responsibilities that may not be delegated; 106 Emergency Liaison Coordinator; 108 Liaison Assistant; Emergency Maintenance Coordinator;
i
. 110 Emergency Evaluations and Recovery Coordinator; Emergency Radiological Advisor; 112 Site Chemistry and Radiation Protection Coordinator; EARS Operator--TSC; 114 Emergency Radiological Monitoring Teams; Operational Support Center Supervisor; 116 Emergency Operations Coordinator; Emergency Operations Advisor; 118 Shift Engineer; Fire Brigades; 120 Evacuation Coordinator; First Aid and Medical; 122 Data Processing; Advisor to the County Emergency Organization; and.
124 Technical Advisor to the Public Information Recovery Manager.
126 Q.8.
Does the Applicant's Emergency Plan identify an individual by title who shall be in charge in the event of a radiological emergency at 128 Diablo Canyon, Units 1 and 2? If yes, explain.
A.
Yes.
Emergency Procedure G-2 states that the Shift Foreman 130 shall assume the position of interim Site Emergency Coordinator and shall remain in the Central Room where he is responsible for overall command and 132 control until relieved by senior members of operating management.
The line of succession for the Site Emergency Coordinator position is the Shift 134 Foreman, Plant Manager, Plant Superintendent, Power Plant Engineer, and Technical Assistant to the Plant Manager.
136
e
, Q.9.
Have you examined the Applicant's means for providing 24-hour per 138 day emergency response, including 24-hour per day manning of comunications links? If yes, explain.
140 A.
Yes. The plant is staffed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, 7 days per week, by a minimum shift operating crew of 13 individuals. The cperating crew will 142 comprise the initial On-Site Emergency Organization.
The Site Emergency Coordinator (initially the Shift Foreman) will assign a Control Technician 144 to function as Liaison Coordinator to notify the Corporate Recovery Manager, and other offsite agencies and organizations.
146 Q.10. Have you examined the Applicant's provisions to respond to an 148 emergency and to augment any initial response on a continuous basis?
If yes, explain.
150 A.
Yes. The Emergency Organization Call List attached to Emergency Procedure G-2 lists primary and alternate personnel for each 152 assignment in the long-term emergency organization to assure that con-tinuous 24-hour operation can be sustained.
i 154 r
Q.11.
Does the Applicant's Emergency Plan contain written agreements 156 developed between Federal, state, local, and other support organizations concerning concept of operations, information exchange and response functions?
158 If yes, explain.
A.
Yes. The response to question 6 lists the offsite organiza-160 tions for which there is a letter of agreement, or the offsite organization's plan is included as an appendix to the Applicant's Emergency Plan.
162
. Q.12.
Do the provisions of the Diablo Canyon, Units 1 and 2 Emergency 164 Plan and the Applicant's procedures which you have described in response to Questions 5, 6, 7, 8, 9, and 10 above meet the planning standard of 10 CFR 166 Section 50.47(b)(1) and the requirements of Appendix E.IV. A. of 10 CFR Part 507 168 A.
Yes, the Applicant's Pian and procedures conform to the criteria of NUREG-0654.II. A. which are the critera for implementing the 170 planning standard of 10 CFR 50.47(b)(1) and the requirements of 10 CFR 50, Appendix E.IV.A.
172 Q.13.
Does the Applicant's Emergency Plan describe plant staff emer-174 gency assignments for all shifts? If yes, explain.
A.
Yes.
As stated in response to Question 9, the plant is staffed 176 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, 7 days per week, by a minimum shift operating crew of 13 individuals who will comprise the initial On-Site Emergency Organization.
178 Figure 1 of Emergency Procedure G-2 shows On-Shift Emergency Organization i
assignments.
180 Q.14.
Describe the Applicant's Emergency Plan provisions for an emer-182 gency coordinator?
A.
The response to Question 8 lists the line of succession for the 184 Site Emergency Coordinator and states that the Shift Foreman initially assumes the position of interim Site Emergency Coordinator until properly 186 relieved.
i l
[
O 8 188 Q.15. Does the Applicant's Emergency Plan have clear definitions of on-shift personnel responsibilities for emergency response? If yes, explain.
190 A.
Yes, as stated in response to Questions 5 and 13. Emergency Procedure G-2 describes the responsibilities and the actions required by 192 plant personnel for establishing the On-Site Emergency Organization and includes the preferred candidates to fill each position, and Figure 1 of 194 Emergency Procedure G-2 shows On-Shif t Emergency Organization assignments.
l 196 Q.16. Does the Applicant have provisions for maintaining a sufficient staff to provide an initial response in key areas to an. accident at Diablo 198 Canyon, Units 1 and 2? If yes, explain.
A.
Yes, as stated in response to Question 9, the plant is staffed 200 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, 7 days per week by a minimum shift operating crew of 13 individuals who will comprise the initial On-Site Emergency Organization, 202 and Figure 1 of Emergency Procedure G-2 shows On-Shift Emergency Organiza-l tion assignments.
204 Q.17. Describe the Applicant's Emergency Plan provisions for staffing 206 the onsite emergency organization and for augmenting that staff?
A.
Figure 2 of Emergency Procedure G-2 describes the long-term 208 onsite and offsite emergency organization; and the emergency organization call-out list attached to Emergency Procedure G-2 lists primary and alter-210 nate personnel for augmenting the on-shift staff.
1
9 212 Q.18.
Do the Applicant's provisions for staffing described in response to Question 17 above satisfy the staffing requirements of 214 Table B-1 of NUREG-06547 If yes, explain.
A.
Yes. The Emergency Organization Call-Out list includes all of 216 the job functions in Table B-1 of NUREG-0654. The Call-Out list includes alternates for each position, home phone number for each individual, and 218 the pagcr call number. The applicant conducted a survey of all plant personnel on their travel time from home to work.
Due to the remote 220 location of the reactor site, the positions listed in B-1 under " Capability for Additions 30 minutes", take somewhat longer than 30 minutes to be 222 filled on other than day shift. The NRC staff judges that the Appli-cant's response satisfies the goal of the time response tables of B-1, 224 NUREG-0654.
226 Q.19. Does the Applicant's Emergency Plan describe the interfaces among various onsite response activities and offsite support and response 228 activities? If yes, explain.
A.
Yes.
Figure 5.2-2 of the Applicant's Emergency Plan delineates 230 facility designation, and lines of authority and coordination for the emer-gency organization onsite to offsite interface.
Figure 5.2-3 shows the 232 integrated emergency response organintions.
234 Q.20. Does the Applicant's Emergency Plan identify the contractor and private organizations who may be called upon for assistance for emergencies?
236 If yes, explain.
, A.
Yes, the response to Question 6 identifies contractor and 238 private organizations who may be called upon to assist in an emergency.
Section 7.3.2.5 lists the California Polytechnic Institute (Cal Poly)
'240 radiological laboratory which would be available in the event of an emergency. The applicant is also completing an agreement with Rockwell 242 of Conoga Park for radioactive sample analysis.
244 Q.21. Does the Applicant's Emergency Plan identify the services to be provided by local offsite agencies for handling emergencies?
If yes, 246 explain.
A.
Yes, the letters of agreement referenced in response to 248 Question 6 cover hospital, ambulance and fire fighting support.
Table 6.3-4 shows a company panel of physicians near the Diablo Canyon 250 power plant.
252 Q.22.
Do the provisions of the Diablo Canyon, Units 1 and 2 Emergency Plan which you have described and identified in response to Questions 14, 254 15,16,17,18,19, 20, and 21 above meet the planning standard of 10 CFR Section 50.47(b)(2) and the requirements of Appendix E.IV.A. of 10 CFR 256 Part 507 A.
Yes, the Applicant's Plan and procedures conform to the l
258 criteria of NUREG-0654 II.B. which are the critera for implementing the planning standard of 10 CFR 50.47(b)(2) and the requirements of 10 CFR 50, 260 Appendix E.IV.A.
. 262 Q.23. Has the Applicant made arrangements for requesting and using assistance resources? If yes, explain.
264 A.
Yes, the response to Question 6 lists letters of agreement with offsite organizations for assistance resources, and the response to Ques-266 tion 20 indicates that Cal Poly and Rockwell laboratories are available for sample analysis.
268 Q.24. Has the Applicant made preparations for the dispatch of a repre-270 sentative to the offsite E0C7 If yes, explain.
A.
Yes, the response to Question 7 states that Table 1 of 272 Emergency Procedure G-2 specifically describes the responsibility of an individual on the On-Site Emergency Organization to be Advisor to the 274 County Emergency Organization.
276 Q.25. Does the Applicant's Emergency Plan identify radiological laboratories that can be used to provide radiological monitoring and analyses 278 services in the event of an emergency? If yes, explain.
A.
Yes, the responses to Question 20 and Question 23 identity Cal 280 Poly and Rockwell laboratories as being available for sample analysis.
In addition, Section 7.3.2.5 of the Applicant's Emergency Plan lists the avail-282 ability of the following radiological laboratories:
PG&E's Department of Engir:eering Research (DER) Laboratory 284 PG&E's Mobile Environmental Monitoring Laboratory The capabilities, equipment and response time for the radiological laboratories 286 are listed in Table 7.3-8 of the Applicant's Emergency Plan.
. 288 Q.26. What arrangements has Applicant made to acconnodate State and local staff at the near-site EOF for Diablo Canyon, Units 1 and 27 290 A.
Figure 7.1-7 of the Applicant's Emergency Plan shows the location of the E0F-E0C of the Sheriff's Facility on Route 1 northwest of 292 the city of San Luis Obispo. The interim E0F consists of two trailers, and five offices within the Sheriff's facility.
One trailer is dedicated to 294 the management, coordination and analysis of the PG&E response. The other trailer is designated as the Unified Dose Assessment Center (UDAC). The 296 offices in the Sherrif's facility are labelled licensee, state, NRC, DOE / EPA, and FEMA.
298 Q.27.
Does the Applicant's Emergency Plan identify organizations (other 300 than Federal, state and local) which can be relied upon to assist in an emer-gency? If yes, explain.
302 A.
Yes, the responses to Questions 5, 20 and 25 identify organiza-I tions which can be relied upon to assist in an emergency.
304 Q.28.
Do the arrangements the Applicant have made and the resources it l
306 has identified which you have described in response to Questions 23, 24, 25, j
26, and 27 above meet the planning standard of 10 CFR Section 50.47(b)(3) and l
308 Appendix E.IV. A. of 10 CFR Part 50?
i A.
Yes, the arrangements the Applicant has made and the resources 310 it has identified conform to the criteria of NUREG-0654, II.C. which are the criteria for implementing the planning standard of 10 CFR 50.47(b)(3) 312 and the requirements of 10 CFR 50, Appendix E.IV. A.
F
. 314 Q.29. Has the Applicant established an emergency classification and action level scheme? If yes, explain.
316 A.
Yes. Section 4 of the Applicant's Emergency Plan and Emergency ProcedureG-1,AccidentClassificationandEmergencyPlanActiv$ tion, 318 describe the methods and techniques for assessment of each of the four classes of emergency, Notification of Unusual Event, Alert, Site Emergency 320 and General Emergency.
Emergency Procedure G-1 specifies measurabie and observable indications in the plant instrumentation readings which are the 322 initiating conditions for declaring a particular emergency.
324 Q.30.
Is the Applicant's scheme that you describe in response to Questions 29 consistent with Appendix 1 of NUREG-06547 If yes, explain.
326 A.
Yes.
Emergency Procedure G-1 lists each of the conditions in NUREG-0654, Appendix 1 with the corresponding Diablo Canyon indicated condi-328 tion.
I have compared the lists and they are consistent.
In Table 2 of Emergency Procedure G-1 the applicant has listed each of the postulated 330 accidents analyzed in the FSAR and other conditions e.g. chlorine release, tsunami warning, that may result in an emergency and has assigned each of 332 these events to a specific classification.
334 Q.31. Have you examined the Applicant's procedures for establishing each emergency class? If yes, explain.
336 A.
Yes, as stated in reponse to Question 30, the procedure for classifying an event is consistent with NUREG-0654, Appendix 1.
The 338 applicant has detailed procedures for operator response to 44 specific malfunctions to the reactor plant. The procedure describes symptoms and
. 340 diagnostics, automatic actions, immediate operator actions, subsequent operator actions and an Appendix Z which gives specific instructions for 342 classifying the event.
Emergency Operating Procedure OP-1 Loss of Cociant Accident, includes 344 graphs of dose rates inside and outside containment for (1) coolant activity, (2) 100% gap release, (3) 1% fuel melt and (4) 10% fuel melt, to 346 be used by operators for a quick assessment of core conditions in an accident, and to classify the event.
348 Q.32.
Do the Applicant's scheme and procedures you have described in 350 response to Questions 29, 30 and 31 above meet the planning standard of 10 CFR i
Section 50.47(b)(4) and the requirements of Appendix E.IV.B and C of 10 CFR 352 Part 507 A.
Yes, the Applicant's emergency action level classification 354 system and procedures conform to the criteria of NUREG-0654 II.D. and Appen-dix 1, which are the criteria for implementing the planning standard of 356 10 CFR 50.47(b)(4) and tne requirements of 10 CFR 50, Appendix E.IV.B & C.
l 358 Q.33. Have you examined the procedures for notification by Applicant of State and local response organizations? If yes, explain.
l 360 A.
Yes, as stated in response to Question 31, each emergency operating procedure for coping with a plant malfunction has an Appendix Z 362 for classifying the event.
In addition, Appendix Z gives specific instructions for notifying offsite authorities.
Emergency Procedure G-3 364 Notification of Offsite Organizations describes the steps to be taken to
t 15 -
provide both the initial and follow-up notifications to Federal, State, 366' local and Company offsite emergency organizations.
4 368 Q.34. Have you examined the Applicant's procedures for notifying and mobilizing its emergency response personnel? If yes, explain.
370 A.
Yes, as stated in response to Question 9, and in accordance with Emergency Procedure G-3, the Shift Foreman acting as the interim Site 372 Emergency Coordinator appoints an interim Emergency Liaison Coordinator to perfom the initial contact of offsite personnel and organizations. The 374 Emergency Organization Call List referenced in response to Question 10 l
lists plant personnel to be notified.
376 Q.35. Do the Applicant's procedures described in. response to 378 Questions 33 and 34 above meet the planning standard of 10 CFR Section 50.47 f
(b)(5) and the requirements of Appendix E.IV.C and D of 10 CFR Part 50?
380 A.
Yes, the Applicant's procedures conform to the criteria of NUREG-0654, II.E. which are the criteria for implementing the planning standard of i-382 10 CFR 50.47(b)(G) and the requiements of 10 CFR 50, Appendix E.IV.C & D.
4 384 Q.36. Has the Applicant made provisions to work with the State and i
local offsite organizations in establishing the contents of initial messages 386 from the plant in the event of a radiological emergency at Diablo Canyon, l
I Units 1 and 2? If yes, explain.
388 A.
Yes, Attachment 1 to Emergency Procedure G-3 contains Initial Emergency Notification Messages for the four classes of emergency. The 390 messages contain information about the class of emergency, recommended
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. protective actions, and infomation on radiological release. The latter 392 has a r,eparate form, the Radiological Emergency Status Form, which includes j
the following:
i S94 time of relase; loca* ion of release; 396 duration of release; i
release monitor; 398 physical fom; iodine, particulate, noble gas quantity; 400 meteorological data; and prognosis for escalation or termination.
'402 Q.37.
Describe the Applicant's provisions for followup messages from 404 the facility to offsite authorities?
A.
Follow-up messages from the Applicant to offsite authorities 406 will include as much information on the Radiological Emergency Status Form as is available at the time of notification or update.
Emergency Proce-408 dure G-3 also requires that follow-up status reports include the information that is available on the Plant Status Emerger.cy Form and the Onsite/0ffsite 410 Radiological Field Monitoring and PIC Emergency Status Form.
Energency j
Procedure G-3 also requires status updates to be provided approximately 412 every 15 minutes to each response organization.
414 Q.38.
Have you examined Applicant's means for providing supporting information to offsite authorities for messages intended for the public?
416 If yes, explain.
. A.
Yes.
Emergency Procedure OR-2, Release of Infomation to the 418 Public, states that all infomation released must be accurate and informa-tive, and must be approved for accuracy by the PG&E Recovery llanager.
420 Federal, state and local agencies will be infomed prior to the release.
Emergency Procedure OR-2 includes General Information abodt the plant, 422 Emergency Classification definitions, news release guidelines, draft news releases and a media notification list.
424 Q.39.
Do the Applicant's provisions for initial messages, followup 426 messages and messages intended for the public which you have described in response to Questions 36, 37 and 38 above meet the planning standard of 428 10 CFR Section 50.47(b)(5) and Appendix E.IV.C of 10 CFR Part 50?
A.
Yes, the applicant's provisions for notification and instruction 430 to the emergency orgenizations and the public conform to the criteria of NURE-0654 II.E. which are the implementing criteria for the planning 432 standard of 10 CFR 50.47(b)(5) and the requirements of 10 CFR 50, Appen-dix E.IV.C.
434 Q.40. Have you examh ed the Applicant's means for notification and 436 instruction to the populace within the plume exposure pathway EPZ?
If yes, explain.
438 A.
Yes. Section 7.2.2 of the Applicant's Emergency Plan describes the Early Warning System installed to provide prompt alerting of the public l
l 4a0 within the Plume Exposure Emergency Planning Zone. The system to alert the l
public to turn on their radios or television sets for further infomation l
l
442 consists primarily of a siren system. The coverage area of the Early Warning System has been extended by the applicant beyond the 10 mile radius required by NRC regulations to include the State of California Basic Emer-444 gency Planning Zone. The Early Warning System is activated from the San 446 Luis Obispo County Sheriffs Office.
Local radio and television stations are notified by county personnel to activate the Emergency Broadcast System 448 with instructions for the public.
450 Q.41.
Do the Applicant's means for notification and instruction to the populace within the plume exoosure pathway EPZ which you have described in response to Question 40 above meet the planning standard of 10 CFR 452 Section 50.47(b)(5) and the requirements of Appendix E.IV.D of 10 CFR 454 Part 50?
I conclude from my review of the siren system fcr alerting A.
No.
and of the the radio-television system for instruction that these systems 456 will conform to the criteria of NUREG-0654, II.E. and Appendix 3 which are the implementation criteria for the planning standard of 10 CFR 50.47(b)(5) 458 and the requirements of 10 CFR 50 Appendix E.IV.D.
However, 10 CFR 50, 460 Appendix E.IV.D.3 includes the following requirements:
"The licensee shall demonstrate that the State / local officials have the capability to make a public notifi-462 cation decision promptly on being informed by the licensee of an emergency condition."
464 It is not clear to me from my discussions with local county personnel and 466 from my review of the SLO County Nuclear Power Plant Emergency Response Plan (DRAFT) dated May 1981, and the DRAFT version dated October 1981, that 468 1
I have been the requirement for prompt decision making will be met.
N
. 470 informed that the Applicant, SLO County, and FEMA are working to resolve the problem in the final SLO County Plan.
472 Q.42. What provisions has the Applicant made for prompt communications i
474 with offsite response organizations?
A.
The Applicant has described in Section 7.2 and in Figures 7.2-1 476 (a thru 1) of the Emergency Plan his means of prompt communications with offsite response organizations.
478 Q.43. Has the Applicant established primary and backup means of com-480 munication for its emergency response organization? If yes, explain.
A.
Yes. The major components of the Diablo Canyon Communicati.ms 482 Systems consist of the following:
PG&E private dial systems, using 2 separate microwave 484 systems; 486 A Computerized Branch Exchange for both Internal and Access to Pacific Telephone; 488 An Internal Private Automatic Branch Exchange; 490 Dedicated Special Purpose Pacific Telephone System; 492 Dedicated Circuits for the Data Communication System; 494 Dedicated Circuits for flRC communications; 496 UHF radio system; and 498 VHF radio system.
500 i
I
. 502 Q.44. Has the Applicant made provisions for manning communication links on a 24-hour per day basis to initiate emergency response by the principal 504 offsite response organizations? If yes, explain.
A.
Yes, the Control Room, and the Technical Support Center and the e
506 Emergency Operations Facility when activated, in accordance with Emergency Procedures EF 1 and EF 2 " Actuation of the TSC and the EDF", will be manned 508 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day with personnel to man communication links.
510 Q.45. Has the Applicant made provisions for communicating between Diablo Canyon, Units 1 and 2 and the Applicant's near-site EOF, governmental 512 E0Cs, and radiological monitoring teams? If yes, explain.
A.
Yes, the systems listed in response to Question 43 will be used 514 ' for comunicating to the near-site E0F and governmental E0Cs.
Communi-cations to radiological monitoring teams will be via radio-equipped 516 vehicles and portable radio sets using the plant UHF radio system, as described in Emergency Procedure RG-8 " Emergency Offsite Radiological 518 Environmental monitoring".
520 Q.46.
What provisions has the Applicant made to ensure that a coordi-nated communication link exists for fixed and mobile medical support 522 facilities?
A.
Communications to fixed medical support facilities will be via 524 Pacific Telephone system, and to mobile medical support via radio systems.
. The French Hospital Emergency Response Plan, in Appendix H to the Applicant's 526 Emergency Plan, includes a telephone directory of hospital personnel.
Q.47. Have you examined Applicant's means for activating its emergency 528 response personnel? If yes, explain.
A.
Yes, the On-Site Emergency Organization will include a Liaison 530 Coordinator whose responsibility includes notifying plant staff personnel assigned to augment the on-shift crew. Operator alert to assemble the 532 On-Site Emergency Organization is initiated from the Central Room console by ten rapid short blasts on the code call, as described in Section 6.1.2.4 534 of the Applicant's Emergency Plan.
536 Q.48.
Has the Applicant made provisions for conducting periodic tests of its entire emergency communications system? If yes, explain.
538 A.
Yes.
Section 8.1.3.1 of the Applicant's Emergency Plan specifies the frequency of communications drills as follows:
540 Communications with County and Corporate response centers--monthly; 542 Control Room to Sheriffs Office--weekly; 544 Communications with NRC, FEMA and the State of 546 California--quarterly; and 548 Communications between plant, County E0C and field team--annually.
550 552 Q.49.
Do the Applicant's provisions for communicating with principal response organizations and emergency response personnel which you have 554 described in response to Questions 42, 43, 44, 45, 46, 47, and 48 meet the
. planning standard of 10 CFR Section 50.47(b)(6) and the requirements of 562 Appendix E.IV.C and E of 10 CFR Part 507 A.
Yes, the Applicant's provisions for communications conform to 564 the criteria of NUREG-0654, II.F. which are the implementation criteria for the planning standard of 10 CFR 50.47(b)(6) and the requirements of 10 CFR 566 50, Appendix E.IV.C and E.
568 Q.50. Have you examined Applicant's procedures for the periodic dissemi-nation of information to the public within the plume exposure pathway EPZ as 570 to how the public will be notified and what its initial actions should be in the event of a radiological emergency at Diablo Canyon, Units 1 and 2?
572 If yes, explain.
A.
Yes, Section 8.1.2.3 of the Applicant's Emergency Plan describes 574 the public education program which consists of a page of instructions in the local telephone book, a pamphlet for distribution throughout the emer-576 gency planning zone, an institutional placard for placing in motel rooms and public gathering places, and a periodic newsletter with emergency l
578 response information distributed to residents of SLO County.
I have l
[
reviewed drafts of this material.
It describes warning procedures and 580 the protective actions that may have to be taken by the public.
582 Q.51. Has the Applicant designated points of contact and physical locations for use by news media during an emergency? If yes, explain.
l 584 A.
Yes, the applicant has made arrangements for an Emergency Response Medical Center at the auditorium of Cuesta College.
l 586 l
l
Q.52.
Have you examined Applicant's procedures for coordinated dissemi-588 nation of information to the public, including news nedia? If yes, explain.
A.
Yes, Emergency Procedure OR-2, Release of Information to the 590 Public states that the first news release will be prepared by the plant staff and approved by the Public Information Recovery Manager who shall 592 notify the public information representative of the San Luis Obispo County Emergency Organization of the news release and its content, and coordinate
, 594 a joint briefing.
596 Q.53. Has the Applicant made arrangements for dealing with rumors?
If yes, explain.
598 A.
Yes, the Applicant has coordinated its plans with offsite authorities.
PG&E's plans state that the corporate Recovery Manager will 600 establish a schedule for exchanges and updates of information to designated -
spokespersons for offsite agencies so that the county will be able to 602 promulgate jointly agreed upon position statements.
Since rumor control is under the jurisdiction of the county organization, the availability 604 of centralized and authentic information will provide the county with consistent, reliable source information.
606 Q.54. Do the Applicant's procedures and arrangements for providing 608 information to the public, and the provisions for coping with news media which you have described in response to Questions 50, 51, 52, and 53 610 above meet the planning standard of 10 CFR Section 50.47(b)(7) and the requirements of Appendix E.IV.D of 10 CFR Part 50?
.. 612' A.
Yes, the Applicant's Plan and procedures for.information to the public, and to the news media conform to the criteria of.NUREG-0654. II.G.
'.614 which are the implementation criteria for the planning standard of 10 CFR 50.47(b)(7) and the requirements of 10 CFR 50 Appendix E.IV.D.
616 c
Q.55. Have you examined the Applicant's provisions for establishing
- 618 'and activating a Technical Support Center, Onsite Operation. Support Center,
=
and a E0F to support the emergency response? If yes, explain.
620 A.
Yes, the Applicant's Emergency Procedures EF-1, 2, 3 Activation of the Technical Support Center, the Operational Support Center, and the
'622 Emergency Operations Facility describes the actions to be taken in the event it becomes necessary to activate the Centers.
624 Q.56. Has the Applicant made provisions for onsite monitoring systems 626 for use in initiating emergency measures? If yes, explain.
A.
Yes, Section 7.3.1.1 of the Applicant's Emergency Plan
.628-describes the plant seismic monitoring system of three triaxial acceler--
ometers used to identify emergency action levels, and to initiate a reactor 630 trip.
Section 7.3.13 describes the system of permanently installed radiation monitoring detectcrs for personnel radiation protection purposes.
632 Table 7.3-2 gives the location, detector type, range and a short discussion of the fixed location process stream monitor that are useful for estimating 634 consequences of emergancies. Containment and plant vent radiological monitors are examples in Table 7.3-2.
Section 7.3.14 describes two high range ' gamma Y
636 radiation monitoring instruments to monitor post accident radiation levels -
7 inside of the containment up to 10 R/hr.
638
. Q.57. Have you examined Applicant's provisions for acquiring data from 640 offsite monitoring and analysis equipment? If yes, explain.
A.
Yes. Section 7.3.21 of the Applicant's Emergency Plan lists 642 offsite geophysical monitors at University of California Berkely, Cal Poly, California Tech Pasadena, California Dept. of Water Resources Sacramento, 644 U.S. Geological Survey Menlo Park. Section 7.3.2.3 and Figures 7.3-2 and 7.3-3 describe 35 direct radiation monitoring stations which are part of 646 the environmental monitoring program.
These stations are equipped with thermoluminescent dosimeters.
Nine of the monitoring locations are equipped 648 with an air sampler for particulates and iodine.
Section 7.3.2.6 describes the Emergency Response Mobile Laboratory and Table 7.3-8 describes its equip-650 ment and capabilities for radioactive analysis.
Emergency Procedure RB-8 provides instruction for implementation of the program for emergency offsite 652 radiological environmental monitoring.
654 Q.58.
Has the Applicant made provisions for offsite radiological i
monitoring equipment in the vicinity of Diablo Canyon, Units 1 and 27 656 If yes, explain.
A.
Yes.
In addition to the TLD's and the air samplers of the 658 response to Question 57, the Applicant has installed a ring of real time l
radiation-monitors in a semi-circular pattern from Morro Bay to Arroyo 660 Grande that can provide continuous measurement and reporting of low-level gamma radiation to PG&E, local and state agencies.
l 662 Q.59. What provisions has the Applicant made for obtaining meteoro-l 664 logical information?
I
. 666 A.
Section 7.3.1.2 of the Applicant's Emergency Plan describes the primary 76 meter tower located 200 meters SSW of the _ plant, and the 668 60 meter tower located 1.2 kilometers ESE of the primary tower. The meteorological instrumentation for measurement, reduction, storage, 670 recording and transmission of data to the Control Room, Technical Support Center, the Energency Operations Facility, PGE Corporate Center, California 672 State Office of Emergency Services has been reviewed by the NRC staff and conforms to the criteria of Appendix 2 of NUREG-0654, 674 Q.60.
Has the Applicant established a central point for receiving and 676 analyzing field monitoring data? If yes, explain.
A.
Yes, initially the Applicant's field monitoring data will be 678 received and analyzed at the Technical Support Center which, as described in Section 7.1.4.1 of the Applicant's Emergency Plan, has its own radio-680 logical counting rnom for analysis of on-site samples.
Emergency Procedure RB-8, Emergency Offsite Radiological Environmental Monitoring", provides 682 that samples or fitness collected offsite will be placed in a sealed con-tainer, identified, and taken to the itEML (Mobile Environmental Monitoring 684 Laboratory).
686 Q.61.
Have you examined the Applicant's provisions for protective equip-I ment, communication's equipment, radiological monitoring equipment and ener-688 gency supplies? If yes, explain.
A.
Yes, I have examined the contents of radiological emergency 690 kits that include such equipment listed in Table 7.3-4 of the Appli-cant's Emergency Plan, and are located at the Security Building, the
27 -
692 Information Center, Morro Bay Power Plant, and the Emergency Operation Facility.
Emerge 7cy Procedure RB-8 lists the availability of hand held 694 radios at these same locations.
696 Q.62.
Have you examined the Applicant's means for maintaining those supplies and equipment?
If yes, explain.
698 A.
Yes.
Section 8.3 of the Applicant's Emergency Plan states that equipment.shich is designated for use only in an emergency such as instru-700 ments, evacuation kits and emergency kits is inspected on a quarterly basis and after each use to verify availability and functionality.
Supplementary 702 inventories of expendable supplies such as protective clothing and particu-late filters are maintained on site and replenished at a minimum level.
704 Q.63.
Do the Applicant's provisions to provide and maintain facilities 706 and equipment which you have described in response to Questions 55, 56, 57, 58, 59, 60, 61, and 62 above meet the planning standard of 10 CFR 708 Section 50.47(b)(8) and the requirements of Appendix E.IV.E and G of 10 CFR Part 50?
710 A.
Yes.
The applicant's provisions for adequate emergency facilities and equipment confonn to the criteria of NUREG-0654, II. H, 712 which are the implementation criteria of the planning standard of 10 CFR 50.47(b)(8) and the requirements of 10 CFR 50, Appendix E.IV.E and G.
714 Q.64. Have you examined the Applicant's methods for assessing and 716 monitoring actual or potential offsite consequences of a radiological emergency condition? If yes, explain.
. 718 A.
Yes, the Applicant's methods for assessing and monitoring actual or potential off-site consequences of a radiological emergency 720 condition are described in Section 7.3.1.9 of the Applicant's Emergency Plan entitled Emergency Assessment and Response System (EARS). The EARS 722 system is a computerized graphical display of dispersion of an effluent.
It accepts input data from radiological monitors and from meteorological 724 instrumentation and calculates live-time dose-rates downwind from the source. The EARS communications and display results provide color graphic 726 displays of parameters and calculated results to the following locations:
Control Room; 728 Technical Support Center; Emergency Operations Facility; 730 PGE Corporate Center; and California Office of Emergency Services.
732 Emergency Procedure EF-6 provides instructions for activation of the EARS at each of these stations. Emergency Procedure RB-11 provides instructions 734 for manual dose calculations using dispersion factor overlays, if the EARS system is inoperable. The Applicant is presently conducting a retraining 736 course in the use of manual dose calculations.
738 Q.65.
Have you examined the Applicant's plant systems for assessing and monitoring actual or potential offsite consequences of a radiological 740 emergency condition? If yes, explain.
A.
See my answer to Question 64.
742
E
. 744 Q.66. Have you examined the Applicant's provisions for equipment for assessing and monitoring actual or potential offsite consequences of a radio-746 logical emergency condition? If yes, explain.
A.
See my answer to Question 61.
748 Q.67. Do the methods, systems and equipment avellable to Applicant for 750 assessing and monitoring actual or potential offsite consequences of a rcdio-logical emergency condition described in your response to Questions 64, 65, 752 and 66 above meet the planning standard of 10 CFR Section 50.47(b)(9) and the requirements of Appendix E.IV.B and Eof 10 CFR Part 50?
754 A.
Yes, the methods, systems and equipraent available to the Appli-cant for assessing and monitoring actual or potential offsite consequences of 756 a radiological emergency condition conform to the criteria of NUREG-0654, II.I which are the implementation criteria for planning standard of 10 CFR 758 50.47(b)(9) and the requirements of 10 CFR 50 Appendix E.IV.B and E.
760 Q.68.
Why are time estimates for evacuation and for taking other pro-tective action required to be submitted by the Applicant pursuant to 10 CFR 762 Part 50, Appendix E.IV?
A.
Time estimates for evacuation and for taking other protection 764 actions are used for two principal purposes:
1) to identify those transportation routes, areas or facilities in 766 the vicinity of a site for which special traffic controls during an emergency or other special plans would be desirable; 768 2) to provide to decisionmakers during an emergency knowledge of the length of time required to effect evacuation under various
4
. 770 conditions. This knowledge allows an informed choice of protective actions (e.g. between in-place sheltering and 772 evacuation) during any actual accident situation.
774 Q.69.
For the time estimates which are required to be submitted by the Applicant pursuant to Appendix E.IV of 10 CFR Fart 50, what criteria must 776 those time estimates meet?
A.
The time estimates for evacuation and for taking other 7/8 protective actions are considered acceptable if the criteria of NUREG-0654 II.J. and Appendix 4 are met.
780 Q.70. Has the Applicant submitted the time estimates for Diablo Canyon, 782 Units 1 and 27 If yes, describe the document.
A.
Yes, the Applicants submitted an analysis of time estimates for 784 evacuation of the plume exposure pathway zone in Evacuation Time Assessment for the Diablo Canyon Nuclear Power Plant, September 1980, PRC-Voorhees Inc.
786 The other protective action that may be taken is shelter, and the time neces-sary to take shelter is principally a function of the time for notification.
788 The Applicants have installed a siren systera for early alerting of the public and have an ongoing public educational program that instructs the public that 790 the activation of the sirens is not a signal to. evacuate, but is a signal to seek shelter and to listen to local radio and television stations for further 792 instructions on protective actions.
794 Q.71. Have these time estimates been examined for conformance with the criteria you have identified in your response to Question 70 above?
796 A.
Yes.
. 798 Q.72. Who performed that examination and how was it conducted?
A.
The examination was performed by a contractor, the Texas 800 Transportation Institute of the Texas A&M University System. The evaluation technique is described in NUREG/CR-1856, An Analysis of Evacuation Tiga 802 Estimates Around 52 Nuclear Pcwer Plants, and NUREG/CR-1745, Analysis of Techniques for Estimating Evacuation Times for Emergency Planning Zones.
804 The evaluation used a subjective scale requiring professional engineering judgment in determining ratings. The process then indicates areas which 806 the reviewer considers the plan to be strong or weak.
808 Q.73.
Describe the results of that evaluation?
A.
The contractor's evaluation stated that the Applicant's report 810 was excellent with respect to maps, assumptions and methodology and its overall rating was adequate, and contained no reference to review by State 812 and local officials.
814 Q.74. Have you reviewed the Applicant's time estimates which you identi-fied in response to Question 717 816 A.
Yes.
i 818 Q.75.
In ycur opinion, do the Applicant's time estimates meet the criteria you identified in your response to Question 707 If yes, explain.
820 A.
Yes. Appendix 4 of NUREG-0654 includes a description of the material to be covered in an evacuation times assessment study. The NRC 822 contractor's evaluation described in answer to Question 73 covers all of the elements in Appendix 4.
I have reviewed the Applicant's study and the I
i 4
O 824 NRC contractor's evaluation and I have verified that the Applicant's study satisfactorily covers all the elements in Appendix 4.
The Applicant's 826 contractor, PRC-Voorhess, who made the Applicant's study, is also a contractor for emergency planning to San Luis Obispo County, and the 828 Applicant's study has been mc.de available to County officials.
830 Q.76. Have you examined the Applicant's means for advising persons onsite or persons in areas controlled by Applicant in the event of an emer-832 gency? If yes, explain.
A.
Yes, the plant Emergency Signal is described in Sections 6.1.21 834 and 7.2.1.12 of the Applicant's Emergency Plan and in Emergency Procedure G-4.
The emergency signal is a very loud sound produced by electronic 836 warblers placed at numerous locations throughout the plant.
It has a characteristic sound; a rapid rise in pitch followed by a slower drop.
838 Flashing beacon lights are proviced in containment and other areas of high background noise. The system is tested weekly. Upon receipt of the 840 signal, onsite personnel are instructed to report to a predesignated assembly area.
842 Q.77. Has the Applicant made provisions for evacuating and transporting 844 onsite individuals in the event of a radiological emergency? If yes, explain.
A.
Yes. Section 6.3.13 of the Applicant's Plan and Emergency 846 Procedure G-5 describes the procedure for evacuation of onsite non-essential personnel. The decision is the responsibility of the Site Emergency 848 Coordinator.
. 850 Q.78.
Have you examined the Applicant's provisions for radiological monitoring and contamination surveys of people evacuated from the site?
852 If yes, explain.
A.
Yes. Section 6.3.13 of the Applicant's Plan states that a 854 Radiological Monitor.will leave with each group of evacuees, so as to monitor doses as the evacuation proceeds. At the offsite assembly area the 856 Radiological Monitor is responsible for Evacuee Dosimeter and Contamination Control. Equipment and supplies to perform these functions are contained 858 in the evacuation kits which will be at the re-assemply area with the evacuees.
860 Q.79. Have you examined the capability of the Applicant to account for 862 individuals onsite at the time of an emergency? If yes, explain.
A.
Yes, Emergency Procedure G-4 states that each site employee, 864 security officer, PG&E general construction employee, and contractor is assigned a predesignated assembly area.
A supervisor is assigned to each 866 area. The " badge out" process will be used for accountability. A search will be made for personnel not accounted for.
868 Q.80.
Have you examined Applicant's provisions for protective measures 870 for those individuals remaining or arriving onsite during an emergency?
If yes, explain.
872 A.
Yes.
Section 6.3.2 of the Applicant's Emergency Plan describes the use of onsite protective equipment and supplies for individuals remain-874 ing onsite during an emergency. This equipment includes respirators, protective clothing, emergency dosimetry, and a stockpile of approximately
O O 876 7000 thyroid blocking pills.
Emergency Procedure RB-4 provides criteria for expanding the boundaries of an onsite Controlled Area or establishing a 878 new Controlled Area if the need arises under emergency conditions, and establishes administrative controls for radiation protection purposes.
880 Q.81.
Have you examined the capability of Applicant to recommend evacu-882 ation or other protective actions to the offsite authorities? If yes, explain.
A.
Yes.
Emergency Procedure RB-10, Protective Action Guidelines, 884 describes the mechanism for recommending protective actions to offsite authorities. The procedure includes the bases for the choice of 886 recommended protective actions for the plume exposure and the ingestion exposure pathways.
888 Q.82.
Do the Applicant's provisions for protective response of onsite 890 individuals and its capability to recommend protective actions to offsite authorities for persons within the plume exposure EPZ meet the planning 892 standard of 10 CFR Section 50.47(b)(10) and the requirements of Appendix E.IV.
D and E of 10 CFR Part 50?
894 A.
Yes, the Applicant's provisions for protective response and for recommending protective actions confom to the criteria of NUREG-0654, 896 II.J. which are the implementation criteria of the planning standard of 10 CFR 50.47(b)(10) and the requirements of 10 CFR 50, Appendix E, IV.D and E.
898 Q.83.
Have you examined the means established by Applicant for con-900 trolling radiological exposures to its emergency workers in the event of a radiological emergency at Diablo Canyon, Units 1 and 27 If yes, explain.
J 35 -
902' A.
Yes.
Emergency Procedure RB-2, Emergency Exposure Guides.
addresses required authorization; guidance, and maximum exposure criteria 904 where it may be necessary for established limits to be exceeded.
906 Q.84. Do the Applicants means for controlling such radiological exposures include exposure guidelines which'are consistent with EPA Emer-908 gency Worker and Lifesaving Activity Protective Action Guides?
If yes, explain.
910 A.
Yes.
Table 1 of Emergency Procedure RB-2 lists emergency' I
exposure guides for whole body, thyroid and extremeties for sampling under 912 accident condition, for corrective or protective actions and for life saving actions. The emergency exposure guides for corrective or protective 914 actions and for lifesaving actions are based on the " Manual of Protective Action Guides and Protective Actions for Nuclear Incidents", USEPA, 916 September 1975, revised June 1980, and the National Comittee on Radiation f
i Protection (NCRP), Report 39, 1971.-
918 Q.85. Has the Applicant made provision for an onsite radiation pro-920 tection program to be implemented during emergencies, which includes a 24-hour-per-day capability to determine. doses received by emergency personnel?
922-If yes, explain.
A.
Yes.
Emergency Procedures RB-2 Emergency Exposure Guides and 924 Emergency Procedure RB-4 Access to and Establishment of Controlled Areas Under Emergency Conditions establish ground rules for radiation protection 926 during an emergency. These rules provide, among other things, that individ-uals shall not enter any area where dose rates are unknown or beyond the 4
P 1
m....,
..-r
. __ --~. _, - -.. _ _, -... - _ _
~r
, -.... ~,,.,
--.m,
. 928 range of instruments used.
Personnel dosimetry shall include two direct reading pencil dosimeters and a permanent record dosimeter.
During emergency, 930 individuals who routinely operate TLD readers will be made available to ensure ccntinuous capability to determine doses.
932
-Q.86.
Do the means provided by Applicant for controlling radiological 934 exposures to emergency personnel during an emergency which you described in response to Questions 83, 84, 85, and 86 meet the planning standard of 10 CFR 936 Section 50.47(b)(11) and the requirements of Appendix E.IV.E of 10 CFR Part 507 938 A.
Yes, the means provided for controlling expousres conform to the criteria of NUREG-0654II.K which are the implementation criteria of 940 planning standard of 10 CFR 50.47(b)(11) and the requirements of 10 CFR 50 Appendix E.IV.E.
942 Q.87. Have you examined Applicant's arrangements for medical services 944 for contaminated injured individuals? If yes, explain.
A.
Yes.
Emergency Procedure R-1 Personnel Injury-Radiological 946 Related describes the action to be taken in the event of injury to personnel where the victim is radiologically contaminated.
The immediate action is 948 first to render first aid and to remove the patient to the first aid room providing that this can be done without aggravating the injury. The 950 procedure covers both minor, and major (i.e. the patient must be taken to a hospital) injuries where contamination is present.
For the serious injury, 952 the procedure points out that the need for treatment of the injury will usually take precedence over the need for decontamination.
954 i
. Q.88.
Has the Applicant made provisions for an onsite first aid 956 capability? If yes, explain.
A.
Yes.
Section 7.5.2.2 of the Applicant's Emergency Plan 958 describes the first aid room in the access control area.
It is equipped with standard first aid supplies, decontamination equipment, blankets, 960 sheet plastic, hot and cold running water, sink and phone.
962 Q.89. Have you examined Applicant's arrangements for transporting contaminated injured individuals to medical support facilities?
964 If yec, explain.
A.
Yes. Appendix E to the Applicant's Emergency Plan includes 966 letters of agreement for transportation of contaminated injured individuals from two ambulance services, and an air ambulance service.
There is also a 968 letter of agreement wherein French Hospital agrees to accept for treatment injured PG&E employees who may be contaminated with radioactive material.
970 Appendix H to the Applicant's Emergency Plan describes the Procedures For Admission and Management of Radioactively Contaminated Patients at French 972 Hospital.
I have visited French Hospital and found that it has adequate facilities and equipment to treat contaminated injured persons.
974 Q.90. Do Applicant's arrangements for medical services for contami-976 nated injured individuals which you have described in response to Questions 87, 88 and 89 meet the planning standard of 10 CFR Section 50.47(b)(12) and the 978 requirements of Appendix E.IV.E of 10 CFR Part 50?
A.
Yes, the arrangements for medical services for contaminated 980 injured individuals confonn to the criteria of NUREG-0654II.L which are the
O implementation criteria of planning standard 10 CFR 50.47(b)(12) and the 982 requirements of 10 CFR 50 Appendix E.IV.E.
984 Q.91.
Have you examined the general plans developed by Applicant for recovery and reentry? If yes, explain.
986 A.
Yes.
PG&E has documented general recovery plans in Section 9 of the Emergency Plan and in Section 10 of the Corporate Emergency Response 988 Plan. All recovery operations rccessary to restore the plant to an operational condition will be conducted within the framework of the 990 Corporate Emergency Response Organization.
From the Emergency Operations.
Facility, the Recovery Manager and the Emergency Operation Facility 992 Organization will direct all offsite recovery operations as well as work closely with the plant operations staff in making any repairs and 994 modifications to the plant.
Section 9 of the PGE Emergency Plan lists plant status conditions to serve as guidelines for decision by the Recovery 996 Manager on termination of the emergency and initiation of post-emergency recovery efforts.
j 998-Q.92.
Do the Applicant's plans for recovery and reentry which you have l
1000 described in response to Question 91 above meet the planning standard of 10 CFR Section 50.47(b)(13) and the requirements of Appendix E.IV.H of 10 CFR 1002 Part 50?
A.
Yes, the Applicant's Plans for recovery and reentry conform to 1004 the criteria of NUREG-0654II.M which are the implementation criteria of 10 CFR 50.47(b)(13) and the requirements of Appendix E.IV.H of 10 CFR 50.
1006 1
. Q.93. What was your role in the August 19, 1981 emergency response 1008 exercise for Diablo Canyon, Units 1 and 2?
A.
I was the NRC observer in the control room and I participated 1010 in the post exercise NRC critique with the Applicant's personnel.
i
'1012 Q.94.
Briefly summarize the onsite scenario for the exercise conducted on August 19, 1981.
1014 A.
The scenario provided for a sequence of simulated events which required the ' mobilization of the_ Applicant's emergency orgainzation 1016 beginning with an Unusual Event and progressing thru sequentially escalating classes to a General Emergency.
The scenario included a switch 1018 gear fire, a rod ejection accident, a contaminated injured person transported to a hospital and a traffic accident to the ambulance, a loss
.1020 of all offsite power, fuel damage and containment hydrogen explosion.
1022 Q.95.
What functional areas of the Applicant's emergency response organization were tested by the exercise?-
1024 A.
The exercise tested emergency organization and control, accident classification, dose assessment, notification of offsite 1026
' authorities, augmentation of onsite organization, first aid, transportation of contaminated injured individual, on and off site monitoring, fire 1028 brigade response, on site evacuation, reactor plant control.
.1030 Q.96.
From the standpoint of onsite emergency response and Applicant's emergency preparedness, what were the results of the exercise?
. -1032 A.
The exercise demonstrated the Applicant's overall capability to respond to an emergency.
1034 Q.97. Explain the process whereby Applicant's deficiencies noted during 1036 exercises or drills will be corrected.
A.
Within PG&E, responsible individuals have been identified and 1038 assigned responsibility for assuring that deficiencies have been corrected.
1040 Q.98. How will the Office of Inspection and Enforcement assure that 1042 problem areas identified during the exercise are corrected by Applicant?
A.
The Office of Inspection and Enforcement assures that problem 1044 areas identified during tne exercise are corrected through its on-site inspection process.
1046 Q.99. Has the Applicant established provisions for implementing the 1048-corrective actions? If yes, explain.
A.
Yes, operator training-and retraining was accomplished, and 1050 the initial manning of the Emergency Operation's Facility was restructured with senior plant personnel whose response time is consistent with the l
1052 guidance in NUREG-0696, " Functional Criteria for Emergency Response Facili-ties", February 1981.
1054 Q.100. Have you examined Applicant's provisions for conducting drills 1056 in the functional areas of emergency response identified in NUREG-0654, II.N.27 If yes, explain.
. 1058 A.
Yes.
Section 8.1.3.1 of the. Applicant's Emergency Plan describes the communications, fire, medical emergency, radiological 1060 monitoring and health physics drills to be conducted.
1062 Q.101.
Have you examined Applicant's provisions for when exercises and drills are to be conducted? If yes, explain.
1064 A.
Yes.
Section 8.1.3.1 of the Applicant's Fmergency Plan specifies the frequency with which each of the drills described in response 1066 to Question 100 shall be conducted. Section 8.1.3.2 states that an annual exercise will be conducted which will include mobilization of County 1068 personnel and resources adequate to verify the capability to respond to an accident scenario.
1070 Q.102. What can you conclude about the Applicant's emergency prepared-1072 ness program from the August 19, 1981 exercise?
A.
The exercise demonstrated the Applicant's overall capability 1074 to implement the Emergency Plan and procedures and that appropriate measures can be taken to protect the public health and safety in the event 1076 of a radiological accident at Diable Canyon. The Applicant was informed through the NRC critique and the subsequent written report where there are 1078 areas for improvement, and the Applicant has taken action to implement the recommendations.
1080 Q.103.
Do the Applicant's provisions for taking corrective action, its 1082 performance during the August 19, 1981 exercise and its provisions for con-ducting exercises and drills which you have described in response to
.~
. 1084 Questions 94, 95, 96, 97, 98, 99, 100, 101, 102, and 103 above meet the planning standard of 10 CFR Section 50.47(b)(14) and the requirements of 1086 Appendix E.IV.F of 10 CFR Part 50?
A.
Yes, the Applicant's provisions for conducting drills and 1088 exercises and for taking corrective actions conform to the criteria of NUREG-0654II.N. which are the implementation criteria for planning standard 1090 for 10 CFR 50.47(b)(14) and the requirements of 10 CFR 50 Appendix E.IV.F.
1092 Q.104.
Have you examined the Applicant's radiological emergency response training provided to those who may be called on to assist in an 1094 emergency? If yes, explain.
A.
Yes, since early 1981 the Applicant has conducted training 1096 sessions for on-site personnel, for corporate headquarters personnel, and for local and state officials.
A series of training documents including 1098 plans, procedures, lecture notes and visual aids formed the bases for this training.
1100 Q.105. Have you examined those provisions of the Applicant's training 1102 program for the specialized training and periodic retraining in the cate-gories identified in NUREG-0654, II.0.47 If yes, explain.
1104 A.
Yes, the specialized training in the categories of NUREG-0654II.0.4 was verified during an NRC onsite Emergency Preparedness 1106 Appraisal team visit to Diablo Canyon and Corporate Headquarters conducted during December 1981.
I was a member of that Appraisal team which visited 1108 the site.
e
.... 1110 Q.106. Does the radiological emergency response training provided by Applicant which you have described in response to Questions 104 and 105 above 1112 meet the planning standard of 10 CFR Section 50.47(b)(15) and the require-ments of Appendix E.IV.F of 10 CFR Part 507 1114 A.
Yes, the training conforms to the criteria of NUREG-0654II0 which are the implementation criteria for the planning standard for 10 CFR 1116 50.47(b)(15) and the requirements of 10 CFR 50 Appendix EIVF.
1118 Q.107.
Has the Applicant established responsibilities for emergency plan development? If yes, explain.
1120 A.
Yes, Section 8.1 of the Applicant's Emergency Plan states that the Vice President, Nuclear Power Generation, is the individual charged with 1122 overall authority and responsiblity for emergency preparedness and training. The Technical Assistant to the Plant Manager is responsible for 1124 management of on-site planning and training and for coordination with local officials for offsite training. The Supervising Engineer, Personnel and 1126 Environmental Safety Section is responsible for the Corporate Emergency Response Plan.
1128 Q.108.
Has the Applicant established responsibilities for review and 1130 distribution of emergency plans? If yes, explain.
A.
Yes, Section 8.2.1 of the Applicant's Emergency Plan states 1132 that the Diablo Canyon Emergency Response Plan will be reviewed and updated annually, and that on a quarterly basis, telephone numbers and responsible 1134 individuals on contact and notification lists will be verified.
Distribution of the Plan and revision will be controlled in accordance with I
..., 1136. plant document control procedures. Revisions require review by the Plant Staff Review Committee and approval by the Plant Manager.
1138 Q.109. Have you reviewed Applicant's provisions for training the emer-1140 gency response planners? If yes, explain.
A.
Yes, emergency response planners for on site, offsite and
- 1142 corporate plans are included in the training plans described in Section 8.1.1 and 8.1.2 of the Applicant's Emergency Plan.
1144 Q.110. Have you reviewed Applicant's arrangements for having indepen-1146 dent reviews conducted periodically of its emergency preparedness program?
If yes, explain.
1148 A.
Yes.
Section 8.2.1 of the Applicant's Emergency Plan states that an independent audit of the emergency plan, implementing procedures, 1150 training, readiness testing, equipment and interfaces with state and local organizations will be conducted annually and will be documented in 1152 accordance with the Applicant's Quality Assurance Program requirements.
1154 Q.111. Does Applicant's Emergency Plan provide for (1) a listing of supporting plans and their sources, (2) an appendix listing procedures 1156 required to implement the plan, and (3) a specific table of contents?
If yes, explain.
1158 A.
Yes, the Applicant's Emergency Plan includes the following appendices to its Table of Contents:
l 1160 A.
PG&E Corporate Emergency Response Plan i
1162 B.
San Luis Obispo County Nuclear Power Plant Emergency Response Plan 1164 C.
State of California Nuclear Power Plant Emergency Response Plan
..... 1166 D.
Westir.ghouse Electric Company Emergency Response Plan 1168 F.
Diablo Canyon Emergency Response Plan Implementary Procedures 1170 G.
Cross Index to NUREG-0654 1172 H.
French Hospital Emergency Response Plan 1174 I.
U.S. Department of Energey Interagency Radiological Assistance Plan 1176 1178 Q.112. Do Applicant's development, periodic review and distribution of emergency plans which you have described in response to Questions 107, 1180 108,109,110,111, and 112 meet the planning standard of 10 CFR Section 50.47(b)(16) and the requirements of Appendix E.IV.F of 10 CFR Part 50?
1182 A.
Yes, the Applicant's provisions for development, review and distribution conform to the criteria of NUREG-065411.P. which are the 1184 implementation criteria for planning standards for 10 CFR 50.47(b)(16) and the requirements of 10 CFR 50 Appendix E.IV.F.
1186 Q.113. Has the Applicant submitted (or provided the appropriate 1188 reference to) radiological emergency response plans of the State and local governmental entities that are wholly or partially within the plume exposure 1190 pathway EPZ as required by 10 CFR Section 50.33(g)?
If yes, explain.
A.
Yes, as stated in response to Question 111, the Applicant's 4
1192 Emergency Plan includes the following in appendices:
San Luis Obispo County Nuclear Power Plant Emergency Response Plan 1194-State of California Nuclear Power Plar.t Emergency Response Plan.
.... 1196 Q.114.
Has the Applicant submitted (or provided the appropriate reference to) radiological emergency response plans of State governments 1198 wholly or partly within the ingestion pathway EPZ as required by 10 CFR Section50.33(g)? If yes, explain.
1200 A.
Yes, the Applicant has submitted the State of California
' Nuclear Power Plant Emergency Response Plan.
No other state is within the 1202 ingestion pathway EPZ.
s