ML20210E695
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1 Federal Emergency Management AgenEj Region IX Building 105 Presidio of San Francisco, California 94129 iH3 DEC 20 PH 12 b':
16 DEC ES3 UnirEd States Nuclear Regulatory Commission Region V 1450 Maria Lane, Suite 210 Walnut Creek, California 94596 Attention:
Mr. Ross A. Scarano, Director Radiological Safety and Safeguards Programs Gentle, men:
Subject:
Letter Directed to the Honorable Nunzio Palladino, Chairman of the Nuclear Regulatory Commission, from "Dr. Richard Kranzdorf, Spokesperson for Concerned Cal Poly Faculty and Staff, dated November 4, 1983.
This letter will respond to your request for assistance in formulating a response to subject letter relative to concerns about plans and preparedness of_the offsite jurisdictions around the Diablo Canyon Nuclear Generating Station. The information provided below is the result of discussions with the Office of Emergency Services, State of California, and the Office of Emergency Services County of San Luis Obispo.
1.
Evacuation Time Considerations. Evacuation Times Assessments for Diablo Canyon Nuclear Power Plant, September 1980, Alan M. Voorhees and Associates, Inc.,
based on empirical data during various weather conditions and using " standard engineering techniques" described the conclusion that a 20% additional time factor should.be applied to mormal evacuation times for heavy-rain conditions.
The study further concluded that " heavy-rain" constituted a " worst case" for emergency evacuation planning and that fog was considered to be a substantively lesser problem. Traffic studies around the Rancho Seco Nuclear Generating Station, conducted by Robert Hubenette and Associates, also confirmed a 20% additional travel time during rainy weather.
2.
Evacuation Transportation Routes. The County has addressed certain flooding problems and have budgeted funding for improvements to the impacted areas.
People can be evacuated east on Los Osos Valley Road and it is considered un-likely that both Morro Bay and Sin Luis Obispo would be evacuated concurrently.
Based on current information, thq State of California Office of Emergency Services advises that experience with the areas addressed in subject letter has reflected that these evacuation routes are.considereu to be reasonable and safe even though affected by flooding during a postulated emergency.
3.
Emergency Broadcast System. Officially designated Emergency Broadcast System stations are required to have an emergency power system. Radio station KVEC I
was operating on-the-air with emergency backup power. The two~and a half hour I
interval applies only to the amount of time it took the Pacific Gas and Electric Company to resume initial power because of a blown fuse. At this time, alter-nate radio stations are seriously considering the emergency power system in-stallation.
8603280106 860123 PDR FOIA DEVINE84-744 PDR t
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U. S. Nuclear Regulatory Commission
' o' Page Two 4.
Earthquake Considerations. Earthquake Emergency Planning at Diablo Canyon.
September 2, 1981. TERA Corporation, thoroughly addresses all aspects of
' Earthquake effects at the Diablo Canyon Nuclear Power Plant. The California Department of Transportation performed a subsequent study of projected damages identified by the TERA Corporation report and the length of time required for necessary repairs. That information was made available to the County of San Luis Obispo. puring a nuclear emergency, the County plans call for the esta-blishment of a special group to consider any earthquake problems. All these
.special efforts, as well as the planning activities resulting therefrom, have-been extensive and quite signficant.
In general, this office feels that Dr. Kranzdorf has based his comments on a " worst
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case" basis that would require one hundred percent evacuation from all local juris--
dictions within the 10-mile emergency planning zone simultaneously, without benefit of emergency public fnformation, and under extreme adverse weather conditions.
In-asmuch as there is no known' experience, planning and preparedness measures are di-rected at addressing physical probabilities, applying standards for the m6st~advan-
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-tageous use of resources available. Through a cyclic system of exercising, designed to provide continuous plan improvement, the public is afforded the optimum protection that can be developed. Recent exercises, conducted to assess the planning efforts of the offsite jurisdictions around the Diablo Canyon Nuclear Generating Station'have.
demonstrated that there is a reasonable assurance that the appropriate protective measures can and will be taken in the event of a radiological emergency.
Should you require further assistance with regard to this matter,'do not hesitate to contact Thomas F. Brinton or John P. Sucich at 415-556-9840.
Sincerely.
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Rob t L. v i-La# =
Regional Director cc: ' Office of Emergency Services State of California Office of Emergency Services County of San Luis Obispo i
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i, HECEP/E0 f.T.C 9 December 1983 I?O3 DEC 15 A" D 5g i
Mr. John B. Martin AEGiCH'/ yp Regional Administrator United Stated Nuclear Regulatory Commission, Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA.94596 Daar Mr. Martin:
My thanks for your thoughtint reply of December 2 (Attachment A) to the November 4 letter of the Concerned Cal Poly Faculty and Staff addressed to NRC Chairman Palladino regarding two specific reasons for the tack of public confidence in the Emergency Response Plan for the Diablo Canyon Nuclear Power Plant. It is indeed heartening to receive such a personal and courteous letter; we are most appreciative.
In your last paragraph you kindly wrote:. Please feel free to contact us if you wish to provido further data reflecting on your concerns..." Without -
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wishing to be a burden to your office, I'd like to update one of the concerns mentioned in our November 4 letter and bring a new chapter of another, l_
older concern to your attention.
i One of our concerns in our previous letter was with an often flooded area known as the " Twin Bridges" or " Twin Trestles". Money to replace the 4
bridges was said to be unavailable for at least three years. According-to the Telegram-Tribune story of November 15 (Attachment B), County officials apparently realize a problem exists on one of only two' ways out of Los Osos/ Baywood Park (the other route is a two lane road leading into the city of San Luis Obispo which is also subject to flooding) and they intend to rehund the Bridges. Unfortunately, the article states that the effort could begin at the earliest in fiscal 1985-86, many, many l
months after full-power operations at Diablo Canyon are scheduled to be gin.
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The other concern we would itke'to bring to your attention is the continuing problem with sirens being used as the primary method of notifying the population within the Basic Emergency Planning Zone. Per the Telegram-l Tribune article of March 8 (Attachment C), power is interrupted several times each winter and when electricity is lost, the sirens which "do work off regular power lines", are lost. Whether the explanations pfferred by, i
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9 December 1983 Mr. John B. Martin Page Two by th5 PG k E spokeswoman in the article are adequate is something for the NRC, FEMA hul the California State OES to decide. We certainly do not believe there is an adequate back-up system.
We are barely into our winter season and as Attachments D, E and F make clear, power has thrice been disrupted in the area. Undoubtedly, there will be additional partial or complete losses of power in our area this winter and each time some or virtually an of the sirens will be out of commission. Such back-up systems as expecting everyone to have a battery powered radio at the ready or counting on police cars with sirens to pick up the slack are pale imitations of a fully operating siren system.
Our thanks for your attention to the matters raised. We appreciate your understanding why our group has continuing grave doubts about the Emergency Response Plan and why public confidence in this Plan is so low.
Sincerely, I,
Dr. Richard Kranzdorf, Spokesperson Concerned Ca! Poly Faculty and Staff 160 Graves Avenue San Luis Obispo, CA 93401 Enclosures cc: United States Nuclear Regulatory Commission Chairman and Commissioners Congressman Leon Panetta Congressman William Thorsas Congressman Edward Markey United States Federal Emergency Management Agency
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UNITED STATES 3
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NUCLEAR REGULATORY COMMISSION 3.
is REGION V
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1450 MARIA LANE.SUlfE 210
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j WALNUT CREEK. CALIFORNIA M506 Decenber 2,1983 ATTACHMENT A Dr. Richard Kranzdorf, Spokesperson Concerned Cal Poly Faculty and Staff 160 Graves Avenue San Luis Obispo, California 93401
Dear Dr. Kranzdorf:
This is to acknowledge receipt of your letter of Novenber 4,1983 to the Chairman of the U. S. Nuclear Regulatory Consnission and attachments thereto, expressing concerns regarding a lack of public confidence in emergency planning for the Diablo Canyon Nuclear Power Plant and inpediments to evacuation of elements'of the public in the event of a nuclear energency.
Thank you for the reasoned and documented statement regarding your concerns.
They will serve as a basis for in and resolution of these concerns.quiry, hopefully leading to a sound evaluation Please be advised that we have provided copies of your correspondence to the-U. S. Federal Emergency Management Agency (FEMA), which has a specific assignment by Executive Order of the President to take the lead in offsite radiological emergency planning and response. We will work closely with FEMA, the State of California Office of Energency Services, and cognizant local emergency services elements:in evaluating and resolving your expressed concerns.
Please feel free to contact us if you wish to provide further data reflecting on your concerns or if we may answer any questions regarding our handling of the evaluation of your concerns.
Sincerely,
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piu John rtin Regional Administrator sh i
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ATTACHMENT. B Joint effort seen to repair Twit;Br*
s wl.a with the county to rebuud the Twta es thatlead 1As Ones.
The es are within the city knits of Morro Bay but y
Soo4 blocking one of two ways lato IAs Ooos.
The Morro Bay City Conner en Monday directed its staff to formal-he a agreemaet with San Imis Cesaty to share costs la the bridges en South Bay i
1bs joint effort, which could begin is escalyear 100HO, win cost about
$1 milBen. Morre Bay and the caus-
. ty wS1 each pay N percent, about
$100,000, and Caltrans will pay about te percent, er about $800,000, meet of that federal funds, said City Admial* ster Paul Baxter.
The county has been aattfled that Caltrans doesn't espect to have money avaGable for the repairs for atleast three i
South Bay is occasico-I eDy flooded at the bridges when
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Chorro Creek is backed up by high thies and winter rains.
l The connen also a 800,-
000 payment from the Com-mission that will be put into the etty's general fund. The harbor fund had unansicipated revenues and lower 4hasespected expenditures this year of about $100,000. The Herber Fund still owes the city aboutIMO,000.
A of the surplus will be used by Harbor 4t--t 's par-chase two portable radios for $5,000.
The remaining surplus will be put in a special account for maintenance andimprovement projects.
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l sass lies rimmen fmissty sCALIF.) TELEGRA48-11HgUNE, TUE304Y, llAACH 8.1933 A3 No Diablo sirens if power outl i N an emergency at the Diable because, theagh anergency breed-M speteam erected to worn of -
Ceesty Emergency deerdinator Canyon nuclear power plant were east station KVEC has an emergen-
-; % at Diable Canyon de IJada West agreed that, "In any
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- d by a power failure, ty wer nepply, plug.in radies work off power lines, PG&E kind of esmergency, people should!
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meet of San Luis Obispo County's
't work, Kranadorf said, representa Susanne G. Brown have battery operated redles. It-H warning stress wouldn't work, a conceded.
comid be teaDy unrelatd to DiaWel o
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oup of a lear Cal Poly facal led by the klad of fierce storms the
$be sold only these in remote C**F***
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'g,=,: c,iadar,,,, opwe(- een y sufwed a ww,. xveC areas.ec6 as See ca.y. h. e nore s. -y mat o,e ee.,4y l ayen i
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eeuld be knocked off the air, and andar d.as seier power systems.
een either provide these (radies) er
- j b8 * 'I*'"y"yI wind and fleed damage could block Brown said, however, that people require that people have them, but
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dont need h b sinns for 1. der. t M snakes good commen smee."
- po bi t would have been a h
unwgemey, M as a Asked about sternwsesed travel
- major disaster with considerable "VirteaWy every read===tia ad pninged probleens, West said that M evacue
- less of hfe," Richard Kranadorf, a as a snajor artery (in the county's member of the Concerned Cal Poly emergency plan) has been ciegged "In an emergency siteetion, pee. tien routes were h=p===ble er K-2 Faculty and Staff, said during a er blocked er out of comenission at pie tend to be pretty level headed," there was tee little time to evacu-;
news conference st Mission Plaza.
least once this winter," Kranadorf
'she said. " People went to know, ate, coenty emergency officials, I
It could prove fruitless to turn en said.
M N they want to know badly eenid ask people le remain indeers.
radios for emergency information. l Mest strees in the Pacine Gas and /ensegh, they'E find a way."
Latead of evacuating.
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ATTACHMENT D Damp hojiday weather;
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Alaskan sioim on tap r
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i 19e blastery Alaskaa storm that seeni to 3.34 laches. The mermat treaght chilly rains and 8 to 1 Heat shfaB for tida thne of year is 1.84 surf le me Cameral coast tus week. hess, he mid. The total last year and wm leave clear skies behind at tus tism was 3.37 leches.
today, het residents should brace There sure some inesaveniences Ier a repeat performance for the arean thestorm.
Thanksgiving weeksad.
\\ Susanne G. Brown of Pacific Gas i
National Weather Service special-and Electric Co. said Templetes let Mike Campbell in Santa Maria and merth Atasendere last electrici-predicted mostly fair skies today ty edt and a for sa beer from 1:30 and with alghtthne tem >
p.m. Saturday. It affected 4,000 paratures to tae upper sis customers.
I a miHRs.
wEl be aarthwest A tres e a power lies knocked Breen le to 3 aph today.
aut power for las Cambria custaak Temaeratures dipped to as de.
era sa Pine Emells frun 13:3B to grees [a afaaeadare this morning 3:15 p.m. Sunday.
Brown aald there were abort seat.
and Bin Santa Margerna.
"It leeks its the aest storm wm tered peuer failures elsewhere la he h.eet just la tkne for inanksgiv-the ennty due to blown fases.
g. Camphil mid.
On the ocean today, winds will be The weekend storm dumped.41 northwest 18 to 5 knots, with seas 3
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inebes of rain, bringing the seasonal to feet and N M 4 to It Wister storm watches were la affect thrseghout the West today as mow esatinued to fall in Nevada, Utah, Artsons and Colorade.
l Cae to 3 feet of snow fell la the Sierra Nevada and around Lake Tahoe, the National Weather Serv-
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.w Big storm blusters.-
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L across SLO. county
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e sy rea r.ts ts.
Raf Wrmer W/g Cesaty sheriff's deputy Wilber MEs said his department reedved Eigh winds and besvy rains a few tel bene calls Thursday ATTACHMINT E seweed la Alaska reced late the might, about burglar alarms Central Coast a Dursday, es hat weet accidentally.
power Asilares la soms areas At Morre Bay'Harker,4. to.Most j
ansvy surf shes the coast..
swells hampered tients from getting Mg surf is blamed for the sinking te #Noot astramee his ef a mRhost sif the Big Sur coast-
,the Coast Genni reported.
j Ilme Tharsday afterseos. Its two The waves were rusning close passengers are sem missing. (See together and.at least one. fishing separate story e A4.)
best had to wait more than two While Thursda s dewspear hours outside the entrance before it abeeld dissipate this evening, eenid enter safely, accoreng to the asether storm is espected to siam CeestGuard.
late the aren by early Saturday, Renovation work sa the city's according to Jeff andth of the Na aorth breekwater was halted again tional Wester Service la Santa becsese of the high waves and peer Maria.
seether===Ma==
s stormis the tar and of The Atascaderei Police Depart.
that originated la usat's 'eemm=alemma center had
- PactSe Japan and moved elf to resort to emergency for te Paedile Northwest,Snik said, about as hour during the after The storm desaped its inches of PG&E tems serving R went sein m San Luis A power pele caught fire east of he city's season to Paso Rebles at about 8 p.m. Durs-0.83 inches, ahnest double for the day as electrical equipment shorted rest of the county, aeterding to the est. California Department of For-Wether service.
entry arenghiers gnickly had tim Santa Margarita causeted 1.74 are under esotrol and then stood by i
hebes af rain, while Arrere Grande usa after midnight as PG&E crews seterdad.3L, Morre Bay.44 and repaired damage.
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Jhs Bower of Pactfle Telephone g Co. said his company received l
skies wie decreasing "about deoble" the normal amount wth Mghs in the ses and 'st service cans with scattered fau-vartaWe at 5 mph, Smith ares throngbeat the consty, but l
. sect.d abo.n.. electric Mackouts
'm"*" 'Ert 88 88ti888 reports of l
M mones and b.si.
sesses in the North County and ziecirie C repress ific Gas and T-T delayed Cambria, said Pac ve :--e e5lll'rE" $ da'oh["N' a mrie 10 85 as toda, forcing French fault. A ute electrical asif Sea Luis General hosph fausre in sen Luis Ob.
his to hoek up emergency se this moralag delayed L*'se eraa s-
'E""'fno.,esgan at abo.t
- P.'h -a-t 2.o'rm INSIDi TODAY.
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."er was re "g,,",", arms by 8 am My, mW AGRICULTURE................A.8 CLASSIFIED.................B.7
' "In Cambria, there were seat.
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COMICS...............
........ 8 5 tered but pretty thorough estages,"
she said.
COMMUNITY................A.6 la Cambria 'and Atasendero CROSSWORD................ 512 hiackouts securred when trees and.
EDITORIAL.....................A.10 tranches feu sa power lines, Brown ENTERTAIN MENT.............B.6 mid.
081TU ARIES.....................A.9
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down, said Brown, add ng Paso WEATHE"R.....".."..".,"............. A.4
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Robles radio station KPRL was knocked off the air for several
ATTACliMENT F StorrQ4r.ings. rain,
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- e tree ad
- 1. st.rt h e m..I m w e. _ ped t e kn0 CTS Out'p0Wer taMeshit,,
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h.t. e,e.,s,s.mte had
[ A weekend storm that struck The storm slee forced Grover ty's Dean hee High Scheel.
setsmite and mesy d hem shamir Northers CaMismia with hurricane Oty, Merre Bay and Pass Behies to Morre Bay Herber Pattelmes 'sease hacir aereas he herber. M force wisde brought only scattered postpone.their Christusas paredse Larry L8ader and casseursts to the Central Coset.
and San Luis OMape to delay its reported ferryhg, Dick Rodgere quickly wanmed the rest with dresh of the SI she-elas showder and het c i
dets and two teachere back aereas made everearesemperse."hocolate lie serises damage was reported Ortelsensla the Plesa.
la San Imie g Commty as a The Pase Bohlen and Geover City
.the herber to near their Merre Bay
- The esamty's heaviest rainfat was reamit of Satenley a storm, though paredes were regebeduled at Sat.
State Part empettein the evening.
la Santa Marmarita, where 1.33 me winde wa, biassed ser ehetrical arday - to Pass Behies parade at "At least two of he kMe west se i
Lblackoute p5ecting.aheel seemens. 11 a.ne. and the Groser Oly parade eeld they eenido't held este any, inches fee and San Luis Chhpe, which reeerded f.33laches.
i Ig ceWresidente. ~
Quietuses in the Plass wel alas at te a.as.
gand had tremble stameng,"
Is Northern Siderala, he storm amid. Mene of the studente omrtermed welleles and plaam, m stens stranded WMgh scheel
.e=d==*a from Sentern Caufende take mest weekend, said See eired heepital treatmest, het shut does read and go, led en te Merre Bay Mare I*
special Evente Geord, comp 8res.,,mede a heaths to their trees, 'mak homes sure Bay Herber Patretmas to asterJean Peasa.
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and est to as estimated g,g,,g,g.,,g,gy "Everytidag's gehg to be The stademie were stranded a to 7L people.
[ Most of the power faRures ee. Se asm (as pimed)," she syk after a day W elmGg$g and The siens was blamedleratIsant cured Satuder asereing, as wtads "the entertainment and every-tidspeel Efe.
Breedeaths, Olre, a SS-yearold b-
- true Make late Maes IMRS "
8tpe a sur heet's austeerd la Sea Les and sossetisses shookWwires No indenmeem was avaBeMe his starte broke who a poepared to semen ein by the winds hee '-
themselves se hard that ther maing en pim der ruehedutig hanged
, said Susasse d.
the Merre Bay parade.
Brous of Gas and Eiseerte Osamty Engineer Geerse C. Prete-Co.
pages said puty whMe se Solarder She asid a alagle blackest in
-See5TORM,Page A4 i
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!merthern Aimaradere and seethwa i
. Tempa.a== alfacted 3, Gee e 4sammes I
. for 1% hears whus 3,588 homes and husimenese in Arveye M and a steel asnee and kEnd. IIsar W5 In the the aterra Nevada, the i
Ocease were withest power for leem, a mother and see were hEnd siens elseed leierstate 80, the male i
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aheet as hourSaturder morning.
when theh* cm Mt a Seeded seede kanssesastate Greeway, with bus-
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A sortes of faamres hit San Luis and res late aseter ear.
sard snous and stranded many ane-Olmpe's Festhis Beelemd area, The W e e m' W W tarise.
les 1,90s casteners witheet whid up to 88 mph a See Natlesal Weather Service fore.-
48 h, and 183 for as F
Bay, eteeMag peak gude caster BE Goshe Mamed the assiy er usare. Amster y.113 were of et asph en See BruneIdeastain a senditions en s treet "sechered to j
affected by====.am,y estages' Gew anSu ssut dies Framhee.
an h,lemas sudoes low to liertera Br w m said.
The Golden Gate Bridge was CeWornia."
l She seM that m,ase d PG&E's 3 eteesd beeanes of the high winds-The Weather Servies smM aesther
.=m-c=da===u in Nereers and and aR sMpping h to Gelden Gate storm may treates rain en es 1 utral Calitsenia autIwed peer cheesel west of the bridge was, Central Cemet by Tesedey whee a C
lanees during the storm and 8,880 -
hated for~a time beesese d mous ' third stans la espected in ChMermis asently en the San Frames,c, Penis-toisem soons.
hetere to week.md.
' sala - were sea without power this
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UNITED STATES Of AMERICA 00pf,EJ,E:
NUCLEAR REGULATOR? COMMISSION Before Administrative Judges:
John F. Wolf, Chairman Glenn 0.
Dr. Jerry $right GFFE CF SELRt s--
Kline GCCKLiftgER V,'CE In the Matter of:
SERVEp SEP 11SM
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PACIFIC GAS AND ELECTRIC COMPANY
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Docket Nos. 50-275 OL (Diablo Canyon Nuclear Power Plant,)
50-323 OL Units 1 and 2)
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August 31, 1982
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INITIAL DECISION Appearances For the Applicant:
Bruce Norton, Esquire Norton, Burke, Berry, & French, P.C.
,5 For the State:
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Lawrence Coe Lanpher, Esquire Herbert H. Brown Esquire Kirkpatrick, Lockhart, Hill, Christopner, & Phillips t
For the Intervenors:
Joel R. Reynolds. Esquire David S. Fleischaker, Esquire for San Luis Obispo Mothers for Peace For the Nuclear Regulatory Comission Staff:
William J. Olmstead, Esquire \\
Donald F. Hassell Esquire George E.. Johnson,, Esquire
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3 Planning Standard b(10): Protective Actions 245. Planning Standard b(10) states: A range of crotective actions have been developed for the plume exposure pa;hway EPZ for emergency workers and the public. Guidelines for the choice of protective actions during an emergency, consistent with Federal Guidance, are developed and in place and protective acti'ons for the ingestion exposure pathway EPZ appropriate to the locale have been developed.
246.
Procedures for the activation and functioning of the onsite emergency organization, including use of an em rgency warning signal system, are in place.
The warning system is to De used to alert onsite personnel that an emergency condition exists.
The actions to be taken upon activation of distinctively different signals are to be communicated to onsite visitors and construction workers as well as to all onsite plant personnel. Offsite comunication systems,, including telephones and radio broadcasts, are also in place and available to warn the public (Applicant Emergency Plan, Ex. 73, 6, 7; Sears Testimony ff. Tr.
12638, p. 32) 247.
Methods exist to account for plant staff personnel, visitors and any construction workers who may be on site. (Sears Testimony (f.
Tr.12638, p. 33; Applicant Ex. 73, 6.3.1.2.)
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hacuation of onsite non-essential personnel is planned as a re action.
(Applicant Ex. 73, 6.3.1.3; Applicant Ex. 75, p.
i 249.
Sheltering is used as a protective action for non-essential personnel on site when the dose expected during
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evacuation is higher than that which would be received in shielded I
(Applicant Panel No. 6 Testimony t'f. Tr.12134, p.
areas.
6-2) 250.
The Applicant can evacuate onsite non-essential personnel even during heavy rains on more than one road.
It can also provide evacuation by helicopters or boats.
(Sears, Tr. 12649, 12667-69, 12791-792; Shiffer, Tr. 12773-776) l 251.; Persons remaining or arriving on site during the emergency t]ill receive protection by using respiratory egafpment as required using protective clothing, by taking thyroid blocking pills when it is determined that their use is appropriate and by using dosimetry and contamination control.
(Applicant Emergency Plan, 6.3.2 and 6.3.3; Applicant Panel No. 6 Testimony, p. 6-2) 252.
The evacuation time estimate ma6e by Applicant conforms with the requirements of Appendix 4 of NUREG-O654 and is therefore accepted for the purposes of this case.
(Sears Testimony ff. Tr.12638, p. 34;
" Evacuation Times Assessment Study for the Diablo Canyon Nuclear Plant,"
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f (Applicant Ex. 75A)) A second estimate of evacuation time, which was done independently by the TERA Corporation, leads to similar estimates as the above report.
( Applicant Ex. 84) 253. The plan includes a procedure that provides criteria for expanding the boundaries of onsite controlled areas or the setting up of new controlled areas;if the need arises during an emergency to establish administrative control for radiation protection purposes.
(Sears Testimony ff. Tr. 12638, p.
34; Applicant Ex. 74A) 254. The plan sets out the mechanism for recornnending protective action to the appropriate State and County authorities after the occurrence of a radiological event. (Applicant's Ex. 7'5A, Number E.P-RB-10.)
255. FEMA's evaluation of offsite preparedness found no corrective actions needed to meet this planning standard.
(Applicant Panel No. 1 Testimony ff. Tr. 11782, Attach. 2; Eldridge Testimony ff.
Tr.12688,p.5-6) 256.
Ingestion pathway protective actions have been developed by the Applicant, the State and th,e :ounty. Actions would be taken by the State and County to prevent or reduce the concentration of radioactivity in human food and animal feed.
(Applicant Ex. 73, App. C, pp. 12, 13, 35; Applicant Ex. 80, 11.10)
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The County plan has provisions for notifying all segments of sient and resident population for protecting persons whose lity is impaired due to institutional or other confinment; for use radioprotective drugs for emergency workers and institutionalized persons; the means of relocation, including buses needed for non-car t
owners and school populations; and' precautionary measures such as limiting hospital admissions, closing schools, Darks, and beaches.
(Applicant Ex. 80, II.5, II.7, II.8; Applicant Ex. 81, III.01, III.02, III.05, III.08).
258. Joint Intervenors' witnesses challenged the evacuation time estimates for several reasons: (1) Traffic wi11 not flow at maximum capacity; (2) Police would not control traffic and traffic would stagnate; (3) evacuatior. times do not account for bus or antulanc e
{
trips; (4) the number of private vehicles is undercounted; and (5) shadow evacuation from outlying areas will cause traffic backup in the EPI.
(Plotkin/Pulido Testimony ff. Tr.12580, p. 3-10; Tr.12617-621)
The witnesses consistently urged the most conservative assumptions, i
however, which the Board concludes are not credible.
(Plotkin, i
Tr. 12599-600, 12604) 259. The purposes for evacuation time estimates are to identify transportation routes for which traffic control planning is needed and to provide time estimates which enable decision makers to choose between sheltering and evacuation s protective actions.
(Sears
/
- 174 -
Testimony ff. Tr. 12638, p. 29-30)
Extremely conservative assumptions do not serve these purposes.
(Urb anik, Tr. 12389-400)
The time estimates by T. R. C.
Voorhees were realistically made over a range of normal and adverse conditions.
These provide a range of estimates of evacuation times to decision makers.(Winslow, Tr. 12193-207; Urb ani k,
- Tr. 12380) Applicant's and Staff's witnesses both conclude that p li o ce can control traffic.
(Winslow, Tr.12222; Urbanik, Tr.12394)
Accidents are considered in traffic flow estimates and th ey do not affect overall time _ estimates significantly.(Urbanik, Tr. 12381) The number of ambulance and bus trips required would be too sma?1 t o impact overall evacuation times.
(Urbanik, Tr. 12391-392)
The number of vehicles involved in an evacuation is not undercounted e
estimate of 1.3 vehicles per household is consistent with recent studies.
(Urbanik, Tr.12383)
Voluntary evacuation from outside the BEPZ will not cause traffic backups within the EPZ (Winslow. Tr.
12779-80) 260.
The Board has considered Joint Intervenors' asser public and emergency worker behavior in its analysis of Planni n
Standard b(1), b(2) and b(7) where we conclude that their r.g proposed actions are not warranted.
We conclud,e that time estimates for emergency evacuation of the public wit,hin the plume exposure EPZ a y
valid and in conformance with Appendix 4 of NUREG-0654 re The Applicant has conformed to the onsite criteria of NUREG-0654 for protective actions.
The Board therefore finds that adequate protective actions can be taken both on site and off site in the event of an emergen and
m r.- ~..,.,.
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