ML20140B589

Forwards Matls Re Recently Filed Testimony of Nauman

ML20140B589
Person / Time
Site:	San Onofre
Issue date:	09/09/1981
From:	Hoefling R NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	Perry S Federal Emergency Management Agency
References
ISSUANCES-OL, NUDOCS 8109140256
Download: ML20140B589 (13)

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t Septeober 9, 1981 A B

E i Spence W. Perry, Esq.

l l Acting Assistant General Counsel

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N Washington, D.C. 20472 p[.

In the l'atter oi SOUTHERil CALIF 0RiilA EDIS0ft COIPAliY, ET AL.

. (San Gnofre Nuclear Generating Station, Units 2 and 3)

Docket tos. 50-361 OL and 5J-362 OL

Dear fir. Perry:

Enclosed are sone materials relative to the recently filed testirony of I;r. Nauman for your use.

Thank you for your assistance at the recent hearing session in Annthein, Calif)rnia. The hearing will reconvene in Annaheim on Septenber 21, 1981.

i Sincerely, Richard V. Poefling Counsel for luiC Staff

Enclosure:

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8/24/81 MARSHALL: Suggest you attach the documents identified in the response to question 10 as exhibits A and B to this response. I have so noted this in the response to question 10.

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evacuation time estimates, i.e., Part 50, Appendix E.IV, to what extent are evacuation time estimates considered by you in your evaluation of offsite emergency preparedness for SONGS 2 and 3?

A. The evacuation time estimates were reviewed in accordance with NUREG 0634/ FEMA REP-1 to the extent that they were indicated in the emergency planning and that emergency direction and control personnel considered them in their protective action recommendations.

Q.5 Wha,t criteria did you apply in your e. valuation?

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A. The criteria app?.ied were tho*~ reflected in NUREG 0654/

FEMA REP-1, Rev. 1, Part J, Protective Response.

Q.6 Describe the results of that evaluation?

A. The assessment reflected the jurisdictions have considered the e~acuation time estimates developed in the SONGS study by W. Smith and Associates and reflected an intention to give consideration of time estimates in decling with protective response in an emergency situation.

.7 In your opinion, do the evacuation time estimates which you have evaluated meet the criteria which you have identified in your responsa to Question 5 above?

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8/24/81 G. radiological emergency response training to those who may be called on to assist in an emergency, 10 C.F.R. Section 50.47(b)(15);

H. the methods, staffing, systems, and equipment for assessing and monitoring actual or potential off-site consequences of a radiological emergency condition within the plume exposure pathway EPZ for SONGS 2 and 3,10 C.F.R. Section 50.47(b)(9);

I. the physical design, communications equipment, and operating procedures for the interim Emergency

. Operations Facility,10 C.F.R. Section 50.47(b)(3) and Co)(8);

J. the methods, systems, and equipment for assessing and monitoring actual or potential offsite conse-quences of a radiological emergency condition within the inge.ation pathway EPZ for SONGS 2 and 3, 10 C.F.R.

Section 50.47(b)(9); and K. general plans for reentry and recovery plans and procedures,10 C.F.R. Section 50.47(b)(13).

A. To the extent that the standards of NUREG 0654/ FEMA REP-1, Rev. 1, have been applied to the review of emergency response planning and capability of impicmentation regarding SONGS 2 and 3, and assuming the contention asks if there is a reasonabic assurance that the items A-K (less J) will be or have been adeiressed in planning, the answer is in the affirmative. (This assumes reentry and recovery planning will be accomplished.')

2nd Part of Q.12 With respect to Contention 2.A, have you examined the procedures of offsite response organizations for notification of and o pn-,

LfBAWLB continued communication among emergency personnel by all inv'olved response organizations?

2nd Part of A.12 Yes, the procedures of offsite response organizations for notification and communication regarding emergency personnel were examined in accordance with NUREG 0654/ FEMA REP-1, Rev. 1, standards II.E and II.F.

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Q.13 With recpect to Contention 2.A, do the procedures for notifica-tio,n of and continued communication among emergency personnel

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which you have described in response to Question 12 above meet planning st andard 10 C.F.R. Section 50.47(b)(6)?

A. Yes. Additionally, siren systems are being installed at this time and are forecast to be in place before licensing. Plans and procedures currently exist for notification and communication.

Q.14 With respect to Contention 2.B, have you examined the means established by offsite response organizations for notification and instruction to the populace within the plume exposure pathway EPZ?

, A. Yes, the standards of NUREG 0654/ FEMA REP-1, Rev. 1, Part II.E, were applied. These means include, establish govermental telecommunications systems, gc a rnment vehicles, media, sirens, and Emergency Broadcast Systet equipment.

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8/24/81 Q.15 With respect to Contention 2.B, do the means which you have described in response to Question 14 .above for notification and instruction to the populace within the plume exposure pathway EPZ meet planning standard 10 C.F.R. Section 50.47(b)(5)?

I A. Yes, to the extent that they have been addressed in planning and were critiqued by the informal plan review document referred to in the answer to Question 10. When sirens are installed and tested and plans and SOP's finalized / updated, they should meet the standard. Future evuluation of the demonstrated imple-mobtation will vali. ate the capability to meet the stan'dard from an implementation standpoint.

Q.16 With respect to Contention 2.C, have you examined procedures established by offsite response organizations for dissemination of information to the public within the plume exposure pathway EPZ on a periodic basis as to how the public will be notified and what its initial action should be in the event of an emergency?

A. Yes. NUREG 0654/FEJM REP-1, Rev. 1, planning standard II.E was applied to the plans. Procedures are identified that the utility will provide informational disseminations through mailings on a

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periodic basis. Additional coverage through motels, recreation areas, and other transient locations is planned.

Q.17 With respect to Contention 2.C, do the procedures which you have described in response to Question 16 above, meet planning standard 10 C.F.R. Section 50.47(b)(7)?

8/24/81 A. Yes. Jurisdictions have included procedures to the extent identified in the informal plan review cited in Question 10.

Q.18 With respect to Contention 2.D, have you examined the arrange-ments made by offsite response organizations for medical services for contaminated and injured individuals?

A. Yes. NUREG 0654/ FEMA REP-1, Rev. 1, Standard L, was applied to the plans. Some local hospitals have been identified and have recieved some training for handling patients subject to radiation contamination.,

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Q.19 Do the arrangements for medical services made by offsite response organizations for contaminated and injured individuals described in response to Question 18 above meet planning standard 10 C.F.R.

Section 50.47(b)(12) .

A. To a limited extent, yes. Some specific actions were cited as not observed in the informal plan review. Reference the citation of informal plan review in the response to Question 10.

Q.20 With respect to Contention 2.E, have you examined provisions of the principal offsite response organizations to provide trans-portation and communications equipment during an emergency and to establish emergency operations centers.

o A. Yes. Provisions of NUREG 0654/ FEMA REP-1, Rev. 1, Standards II.C, E, F, H, J, and L were applied to the plans reviewed. Emergency Operating Centers and the transportation and communications assets of the two co.nties and two cities, the U.S. Marine Corps, and the State and Federal organizations are available to support an emergency.

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Q.21. Do the emergency operation centers established by the principal offs'ite response organizations and their commitment of transporta-tion or communications equipment described in your response to Question 20 above meet planning standard 10 C.F.R. Section 50.47(b)(8)?

A. Yes. Orange and San Diego Counties have established operational EOC's with required emergency response plans and equipment to respond to transportation and communications requirements most likely to occur.

Q.22 With respect to Contention 2.F, have you examined the capability of the principal offsite response organizations to respond to an emer-gency and to augment any initial response on a continuous basis?

A. Yes. Provisions of NUREG 0654/ FEMA REP-1, Rev., 1, standards A and C were applied to the plans reviewed. The capability to respond was demonstrated through past demonstrated disaster response and through planning oriented to principles of mutual aid and redundant staffing.

Q.23 Does the capability of each principal offsite response organization i

i to respond to en emergency and to augment this initial response i

on a continuous basis described in your response to Question 22 above meet planning standard 10 C.F.R. , Section 50.47(b)(1)?

\ a A. Yes. The basic planning of the jurisdictions, coupled with the State and local mutual ai,d agreements, and Federal support through the FEMA' Organization provide the necessary response capability. l 4

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.. 8/24/81 Q.24 With respect to Contention 2.G, have you examined radiological emergency response training that has been provided to offsite response personnel who may be called on to assist in an emergency?

A. Yes. Training has been reviewed under NUREG 0654/ FEMA REP-1, Rev. 1, standard 0 and.said standard applied to response plans.

e Training provided to response personnel has been limited. Addi-tional training has been identified as being needed. Local juris-

- dictipns have teams identified who have had training given by the State such as the RDO, RDIW, and RM courses and associated courses, provided by county offices. Medical radiological courses were presented by the utility. Additional training is felt necessary.

to improve proficiency and expand on the specific techniques of power plant field monitoring and ingestion pathway sampling, as well as the provision of basic radiation concepts training to all parti-cipants. Training plans and procedures are being developed at this time as a result of the exercise evaluation findings.

Q.25 Does the radiological emergency response training of offsite personnel which you have described in your response to Question 24 above meet planning standard 10 C.F.R., Section 50.47(b)(15)?

A. To some degree. Reference informal plan review and exercise evaluation findings documcuts cited in Question 10 above. Addi-

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. 8/24/81 12-Q.26 With respect to Contention 2.H, have you examined the methods, staffing, systems and equipment available to the offsite response organizations for assessing and monitoring actual or potential offsite consequences of a rad'iological emergency condition within the plume exposure pathway EPZ for SONGS 1 and 2?

A. Yes. NUREG 0654/ FEMA REP-1, Rev. 1, standard I was applied to plans reviewed. System and equipment exists in limited quantities, while/ staffing has been designed to meet plan requirements.

Methods for assessment and monitoring are being expanded through SOP's.

Q. 27 Do the methods, staffing, systems and equipment available to the offsite response organizations for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition, described in your response to Question 26 above, meet planning standard 10 C.F.R. , Section 50.47(b)(9)?

A. Generally speaking, yes. Some equipment is presently not on hanu

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which would enhance the response capability of the local jurisdic-tions. SOP's cre being developed to address procedures for response. Staffing from local, State and Federal organizations is being refined and training is being developed to improve the response capability. Reference informal plan review and exercise

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Q.28 With respect to Contention 2.I, have youcxamined the physical design, communications equipment and operating procedure for interim Emergency Operations Facility (EOF)?

A. The facilities of the interim EOF were examined relative to NUREG 0654/ FEMA REP-1, Rev. 1. The permanent offsite EOF has not been established at this time. An interim facility at the San C1cmente City EOF is currently being used for the EOF. The design, equipment and procedures are being reviewed and updated as a rekult of an exercise; as of May 13. They reflected a shortfall

, from perceived requirements.

Q.29 Do the physical design, communications equipment and operating procedures for the interim EOF described in your response to Question 28 above meet planning standards 10 C.F.R. Sections 50.47 (b)(3) and (b)(8)?

A. The design, communications equipment, and operating procedures i

for the interim EOF were reviewed in the exercise on May 13, 1981.

The findings resulting from that exercise evaluation identify the current state of operations and suggested corrective actions.

Reference the exercise evaluation findings cited in Question 10 above. At this time, there is additional work being accomplished regarding facilities, equipment and procedures. Upon completion of these actions, a demonstration should be conducted to allow for verification of facilities and capabilities.

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Q.30 With respect to Contention 2.J, have you examined the methods, staffing, systems and equipment available to offsite response organizations for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition within the ingestion pathway EPZ for SONGS 2 and 3?

A. Yes, to the extent that they are covered by NUREG 0654/ FEMA REP-1, Rev.1 standards II.C.3, 4 a,nd J-11. There has been no ingestion -

pathwa'y response capability demonstrated.

Q.31 Do the methods, staffing, systems and equipment available to offsite response organizations for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition described in your response to Question 30 above meet planning standard 10 C.F.R. Section 50.47(b)(9)?

A. As yet the methods, staffing and systems and equipment relating to ingestion pathway response have not been clearly identified or demonstrated. The State of California has a draft proposal for ingestion pathway response and has indicated n draft plan will be submitted in the next two to three months.

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