ML20217D557
| ML20217D557 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 09/22/1997 |
| From: | Collins S NRC (Affiliation Not Assigned) |
| To: | Borchmann P AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML20217D560 | List: |
| References | |
| 2.206, NUDOCS 9710060001 | |
| Download: ML20217D557 (14) | |
Text
pcsa g o- %.tl%z y k UNITED STATES g , f; NUCLEAR REGULATORY COMMISSION o WASNINGTON, D.C. 30486 4 001
%, . . . . . /g September 22, 1997 Ms. Patricia Borchmann 176 Walker Way Vista, CA 92083
Dear Ms. Borchmann:
This letter acknowledges receipt of your letters dated June 23. June 28. and July 11. 1997, which requested that Units 2 and 3 of the San Onofre Nuclear Generating Station (SONGS) outage be extended until all concerns discussed in your letters were resolved, and that your letters be treated as a petition in accordance ,iith 10 CFR Section 2.206. The immediate action requested in your June 23 letter and supplemented by your June 28 letter, was not to allow San Onofre Nuclear Generating Station (SONGS) Unit 3 to restart from its current refueling outage. The staff has discussed your request for imediate action verbally with you on July 8. 1997, and informed you that your concerns did not contain enough information to warrant our taking action to prevent the SONGS units from restarting. Your July 11 letter acknowledged the discussion on July 8. and stated that had you known of the shutdown of SONG', Unit 2. the Petition would have included a request to also prevent Unit 2 from restarting.
This letter documents the bases for our decision regarding your request for immediate action and provides information on how your request will be treated.
In your letters you have also alleged that the NRC has been unresaonsive and has engaged in intimidating tactics in dealing with individuals tlat have raised safety concerns. As a result. we will forward your letters to the Nuclear Regulatory Commission (NRC) Inspector General (IG).
Your letters contain a number of issues in support of your requested actions.
The staff grouped thess issues irto three broad categories for the purpose of evaluating your request for immediate action. Enclosure 1 lists the categories and the individual issues within each category. The staff's evaluation of these three categories is discussed below.
The first category contains issues that you raised that are related to concerns raised in correspondence to the NRC from another individual. You k) enclosed this correspondence with your June 23 letter. In this I acknowledgement letter, we have not addressed every issue in the e correspondence from that individual, but limited our response to those concerns that you discussed in your letter. The NRC has previously. responded [N to the issues raised in the correspondence that you enclosed and a review of Eu 288n 7J808861 0 PDR lf
, f h{[j] D
a .
Patricia Borchmann September 22, 1997 these responses confirmed that no significant safety issue exists that would warrant taking any immediate action regarding continued operation of the SONGS units. In Enclosure 1, we have provided summaries of the NRC's earlier responses to these issues.
For the reasons discussed in the NRC summary responses, the staff concludes that your request for immediate action should be denied.
In your June 28 letter, you also suggest + hat NRC responses fragment the issues and that the NRC failed to comprehensively address the issues in total.
The staff's initial review of the issues considered as a whole for signs of adverse trends or systematic problems concluded that sufficient independence existed between the individual issues. This, combined with the s. ff's find 1ngs that no significant safety concerns exist for each of the issues is the basis for our conclusion that inadequate justification exists to warrant granting your request for immediate action in this regard. The staff will provide you with its final assessment of whether the issues considered as a whole reveal trends or systemic problems associated with the safe operation of the SONGS ; nits in its final evaluation of your request.
The second category contains issues that you have identified related to the use of " manipulated data," " adjusted modeling techniques," and concerns with Southern California Edison's " placing greater emphasis on company profits than on public health ano safety." The issues are more fully described in Enclosure 1. You failed, however, to include any specific examples of these concerns or provide supporting information to substantiate their validity.
Since you have not provided any basis for these statements, the staff is unable to consider them further pursuant to 10 CFR Section 2.206, unless you provide additional information.
The third category comprises 1ssues regarding the emergency preparedness plans for the SONGS site. Enclosure 1 lists and discusses these concerns in detail.
Based on our review of these concerns, the NRC has concluded that these concerns do not warrant the granting of your request for imediate action.
Our review of your concerns regarding the evacuation time analysis will be documented in the staff's final evaluation of your request pursuant to 10 CFR 2.206.
As a result of our review, the Comission staff finds that the immediate action you have requested to prevent SONGS Units 2 and 3 from restarting is not warranted. Therefore, your request for immediate action is denied.
Your request was referred to me pursuant to 10 CFR Section 2.206 of the Commission's regulations. As provided by 10 CFR Section 2.206 action will be taken on the concerns raised in your request within a reasonable time.
-Patricia Borchmann Se.ntember 22, 1997 Enclosed for your information is a copy of the notice that is being filed with the Office of the Federal-Register for publication and a pamphlet on the 10 CFR Section 2.206 Petition' Process ~.
Sincerely.
%lt<alsigned by SemelJ.Cohg, Samuel J. Collins. Director Office of Nuclear-ljteactor Regulation
Enclosures:
- 1. Discussion of Issues
- 2. Notice
- 3. Public Petition Prccess (NUREG/BR-0200) cc w/encls: See next page m
DOCUMENT NAME-: SONG 2. PET < *For previous concurrences see attached ORC 0FC PDIV-2/PM* PDIV-2/P_M8 TECH Editor *- PDIV;2/LA PERB*
NAME MFields- Bdr$8i BCalure- EP N CMiller DATE 8/13/97 9/19/97 8/8/97 9/19 /97 8/13/97 1 0FC PDIV-2/D* OGC* DRPW:(A)D*- ADP* o-
'ih 4L NAME' WBateman JMcGurren EAdensam 'RZimmermanIs M[ns yb DATE 8/13/97 9/15/97 8/27/97 9/2/97 l
- 8 9/Z1/97 0FFICIAL RECORD COPY
- - - .. - - - - _ . _- - . - - - - - - . - _ - . - _.~ - .. - - -
l' Patricia Borchmann- September 22, 1997 cc w/encls 1 [w/o attachments) and 2:
r Mr.-R. W. Krieger. Vice President Resident inspector / San Onofre NPS
] Southern California Edison Company c/o U.S. Nuclear Regulatory Commission San Onofre Nuclear Generating Station 4
Post Office Box 4329 ,
P. 0.- Box 128 San Clemente. California 92674 San Clemente. California 92674 0128
- Mayor
, Chairman. Board of Supervisors City of San Clemente
, County of San Diego 100 Avenida Presidio i 1600 Pacific Highway. Room 335 San Clemente. California 92672 i- San Diego. California 92101 i
Mr. Dwight E. Nunn. Vice President Alan R. Watts. Esq. Southern California Edison Company Woodruff. Spradlin & Smart San Onofre Nuclear Generating Station 701 S. Parker St. No. 7000 P.O. Box 128 i Orange. California 92668-4702 San Clemente. California 92674-0128
} Mr. Sherwin Harris cc w/encls 1-[w/o attachments] and 2 i
Resource Project Manager and incoming:
Public Utilities Department Mr, Harold B. Ray City of Riverside Executive Vice President-
- 3900 Main Street Southern California Edison Company
- Riverside. California 92522 San Onofre Nuclear Generating Station P.O. Box 128
- Dr. Harvey Collins Chief San Clemente. California 92674-0128
. Division of Drinking Water and Environmental Management
, California Department of Health Services
! P. O. Box 942732 j Sacramento. California 94234-7320
- Regional Administrator. Region IV i U.S. Nuclear Regulatory Comission Har,is. Tower & Pavilion 611 Ryan Plaza Drive. Suite 400 l
- Arlington. Texas 76011-8064 i Mr. Terry Winter i Manager. Power 03erations San Diego Gas & Electric Company P.O. Box 1831 San Diego. California 92112-41F '
j' Mr. Steve Hsu Radiologic Health Branch State Department of Health Services Post Office Box 942732 '
Sacramento California 94234 s
Patricia Borchmann -5 September 22, 1997 DISTRIBUTION: (w/ enclosures 1 [w/o attachments) and 2) iDocket lile,(50 362 M incoming)a PUBLIC (w/ incoming)
PDIV 2 Reading (w/ incoming)
EDO Reading EDO 970494 J. Callan H. Thompson P. Norry J. Blaha S, Burns K. Cyr, 0GC J. Goldberg OCC E. Merschoff, Region IV J. Lieberman, OE S. Collins /F. Miraglia R. 21amerman W. Travers J. Roe E. Adensam W. Bateman M. Fields B. Westreich E. Peyton J. Kennedy OPA OCA SECY NRR Mail Room (ED0 970494 w/ incoming)
T. Harris M. Boyle (MLB4)
T. Gwynn, Region IV K. Perkins Region IV/WCF0
Enclosure 1
)
DISCUSSION OF ISSUES
- 1. Cateaory 1 - Issues raised by the Petitioner related to concernt oreviously raised by another individual u a. Issue: The pressurizer size in subsequent designs of ABB CE plants ,
following the design after the San Onofre Nuclear Generating Station '
(SONGS) was increased in order to obtain a favorable accident analysis outcome.
Response: The initial design of the SONGS pressurizer was prepared using approved standards and codes, and it was reviewed by the staff.
Before initial startup, the pressurizer is taken through a series of tests (1) to assure (a) the setpoints and seat tightness of the pressurizer safety valves are within specified tolerances: (b) the proper operation of the pressurizer pressure and level control systems is demonstrated, including auxiliary spray: and (c) the continuous spray valves are properly set, and (2) to measure the rate at which the pressurizer pressure could be reduced using normal pressurizer spray
]J --
valves. These test methods and results were reviewed and approved by the staff.
The component s)ecifications (size, operating parameters, etc.) are not
.only based on tie projected thermal output of the reactor but also on system interaction, piping size, system voiumes, temperatures, and pressures. Therefore, changes in subsequent pressurizer sizes for other facilities may have been necessary to assure acceptable accident analyses results for those facilities.
The SONGS plant safety analyses demonstrate the adequacy of pressurizer size by meeting the design basis criteria.
- b. Issue: The post loss-of-coolant accident (post-LOCA) dose calculations were 51.9% higher than reported in the final safety analysis report (FSAR).
Response: In 1994. NRC asked the licensee to investigate its post-LOCA dose calculations. The licensee began its investigation by searching its calculation index files to identify all plant dose calculations.
After further review, the licensee developed a list of all post-LOCA offsite dose calculations. This list included calculations identified as being related to input parameters employed in the offsite dose analysis. The licensee then reviewed each calculation to determine whether it was currently valid or whether the calculation should be superseded or identified as obsolete. Next, the licensee reviewed the remaining calculations, along with Section 5.16 of the FSAR. to establish which calculations constituted the current post-LOCA offsite
]
2 dose analysis of record to establish historical records of changes to each calculation, assess the validity of calculation input data, and examine the assumptions and modeling for consistency between calculatMns.
The licensee's review disclosed that --
(1) Many calculetions identified as " active" were superseded, outdated (inconsistent with the current as built plant), or otherwise not part of the cur,ent post-LOCA offsite dose analysis of record.
This situation mae identification and conn of the analysis difficult.
(2) Several types of inconsistencies were noted between various calculations that were part of the post-LOCA offsite dose analysis of record. These inconsistencies included modeling of the containment spray system as it affects the low population zone (LPZ) hydrogen purge thyroid dose: dose conversion factors:
breathing rates: and typographical errors, inconsistent numerical roundoff values. and consideration of noncontributing isotopes in source terms. These inconsistencies were formally documented in Nonconformance Report 94120025.
After initial evaluation of these inconsistencies the licensee concluded that, when corrected, the calculated offsite dose for the analyses of record would increase by no more than 15 percent (worst case); and some of-the calculated total doses would decrease. In all cases, the calculated doses would remain significantly lower than the values in 10 CFR Section 100,11 of 300-rem thyroid, 25-rem beta skin, and 25 rem whole body (at both the exclusion area boundary (EAB) and the LPZ).
The licensee committed to correct all identified dose calculation deficiencies by September 1,1995, and to complete a FSAR update, as necessary to address these matters, by December 1, 1995. Subsequently, in consultation with the NRC staff, the licensee revised its commitment
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and corrected all identified dose calculation deficiencies by October 1, 1995.
During correction of the dose calculation deficiencies, the licensee
. identified that a correction based upon resolution of the issue pertaining to the efficiency of post-LOCA hydrogen purge charcoal filter 1odine removal subsequent to its investigation resulted in a calculated post-LOCA LPZ thyroid inhalation dose that was 51.9 percent higher than that reported in the FSAR. The newly calculated LPZ thyroid inhalation
- oose of 79.6 rem was still significantly below the 10 CFR Section 100.11 limit of 300 rem, however. All other adjustments to the calculated EAB and LPZ doses were well within the predicted worst case of +15 percent.
All offsite dose analyses of record resulted in calculated doses remaining significantly below the limits of 10 CFR Section 100.11.
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i After all dose calculation deficiencies were corrected, the NRC staff reviewed both NRC and licensee records. This review determined that the licensee performed a comprehensive review of calculation records to correct problems pertaining to the dispositioning of superseded or i obsolete calculations and obviated the need _for further NRC expenditure of resources to independently calculate associated EAf; and LPZ doses.
. This initial phase of the licensee's effort culminated-in the definitive identification of the offsite dose analysis of record. In the second F
phase of the effort, the licensee performed detail 6j reviews of all calculations in the analyses of record to identify any " technical" problems involving inconsistencies in input data, assumptions, or i modeling. The types and numbers of inconsistencies identified and 1
. corrected by the licensee indicate that these detailed reviews of l individual calculations were similarly comprehensive and thorough. j
- c. Issue: The condition of the membrane on the Unit 1 spent fuel pool l (SFP) is not known and previous repairs to the membrane would fail during a seismic event.
Response: Since this is an issue concerning Unit 1 only (Units 2 and 3 do not have such a membrane), it is not relevant to your request for immediate action concerning Units 2 and 3. However, for your information the Unit 1 analysis report (FSAR),specified plant design, as function that the stated inofthe final as acting safety a
barrier to flow from the SFP to the beach was accomplished by a stainless steel liner backed by a channel-type leak-collection system.
The FSAR states that the purpose of the nembrane is to prevent-groundwater from coming in contact with the concrete. Because the membrane was placed around the entire undseground portion of the spent fuel pit, it follows that it could act as a barrier to leakage out of the pool given that there was any leakage through the liner and that the channel-ty)e leakage collection system failed to perform its function.
However, tie NRC did not credit the membrane as a barrier to prevent SFP leakage to the environs. Accordingly, the current condition of the membrane, and the effects of a seismic event on repairs to the membrane, do not impact the ability of the-stainless steel liner and leak collection system to perform their design function. To date, there is no evidence that the stainless steel liner and channel-type leakage collection system have not performed their design function. The NRC will verify with the licensee that there are no other uses intended for the membrane that are not stated in the FSAR but may be part of_the licensing basis,
- d. Issue: The use of high-density-fuel racks and the amount of fuel stored on site in the SFP would increase the probability of degradation and accidental criticality during a seismic event.
Response: The NRC staff found the seismic adequacy of the SFP racks acceptable when it approved the licensee's request to increase the capacity of the SONGS Units 2 and 3 SFPs by Amendment No. 87 to the Facility Operating License No. NPF-15, dated May 1, 1990. Moreover, the
Boraflex panels in-the SFP fuel racks are tightly enclosed between steel
- plates that are an integral part of the fuel racks, and the entire assembly is fabricated to withstand the design-basis earthquake. An additional margin of safety is supplied by the presence of dissolved boron in the SFP water.
Therefore, the staff has determined that no basis has been provided with respect to the fuel racks that would warrant taking any immediate action regarding safe continued operation of the SONGS units.
- e. Issue: The NRC failed to reprimand the licensee for its failure to adequately monitor the SFP for leakage from 1981 to 1986.
Response: In January 1986, the licensee identified a leak in the Unit 1 l SFi In a September 1986 status report, the licensee noted that there were no procedural requirements for monitoring SFP leakage.
Notwithstanding the lack of specific requirements, also in September 1986, the licensee initiated a routine check of the leak-detection system and logging of the results. An NRC review confirmed that the FSAR in effect at the time did not contain a detailed description of the leak-detection system and did not contain requirements for monitoring the SFP. Further, the staff found no other requirements for the licensee to monitor the Unit 1 SFP for leakage during the period in question. As a result of its review. NRC concluded that no enforcement was appropriate in this matter. In May 1988, the FSAR was revised and a more detailed description of the SFP leak-detection system and monitoring provisions was included. In addition, the licensee recently upgraded the SFP leak- detection capabilities by installing a new system, which provides continuous indication of SFP monitoring well levels in the control room and includes an automatic pumpdown system.
Similar control room monitoring systems and pumpdown systems are in place for the Unit 2 and 3 SFPs.
- ' f. Issue: The SFPs were not designed for permanent storage of fuel: the pools and fuel assemblies were only intended for temporary storage: and the fuel assemblies were intended to be shipped off site before they began to degrade.
Response: In 1984. the NRC issued its Waste Confidence Decision (WCD).
(Requirements of Licensee Action Regarding the Disposition of Spent Fuel Upon Expiration of Reactor Operating Licenses. Federal Reoistgt, 49 Fed.
Reg. 94688. August 31, 1984) in which it reviewed dry cask storage and other spent fuel options. In 1989, the Comission performed a review of its 1984 findings (see 55 Fed. Reg. 38474. September 18. 1990). In this review, the Commission found there was reasonable assurance that at least one mined geologic repository will be available within the first quarter-of the twenty-first century, and sufficient repository capacity will be available within the next 30 years beyond the life for operation (which may include the term of a revised or renewed license) of any reactor to dispose of commercial high level waste and spent fuel originating in such reactor and generated up to that time. Also, the
5-Commission found reasonable assurance that, if necessary, spent fuel generated in any reactor can be stored safely and without significant environmental impacts -for at least 30 years beyond the life for operation (which may include the term of a revised or renewed license) of that reactor at its spent fuel storage basin, or at either onsite or offsite. independent spent fuel storage installation (ISFSIs).
j
- g. Issue: Recent earthquakes in the Landers and Northridge areas produced g loadings-and horizontal offsets far greater than expected, indicating that plants were not designed to withstand the actual seismic activity.
Further, seismic design assumptions and criteria are flawed.
Response: This issue is the subject of a 10 CFR Section 2.206 petition filed by Mr. S. Dwyer. Our acknowledgment letter dated November 22, 1996, presented the basis Dr concluding that no immediate action was warranted. Attached to th;s enclosure is a co)y of the subject letter.
A copy of the Director's Decision addressing t11s concern will be provided to you in the near future as soon as it is issued,
- h. Issue: The licensee's increased liability insurance indicates that -
problems exist.
Resoonse: The structure of the nuclear liaDility insurance is est'a blished by the Price Anderson Act, Section 17.0 of the Atomic Energy Act of 1954, as amended. The key features are the approximately $8.8 billion limitation of liability and the sharing of responsibility by the nuclear power and insurance industries for the public's protection. The primary layer of coverage required for each nuclear power plant with an operating license is $200 million. In tt.e event that claims exceed this insurance amount, additional protection is provided by the secondary retrospective insurance system. Under this system, each licensee is required to pay up to $75.5 million per operating nuclear power plant per incident, plus an additional 5->ercent surcharge if it is needed to cover such claims. Therefore, on tie basis of the current number of licensed operating nuclear power plants (109), the secondary insurance system could fund approximately $8.6 billion in additional protection.
The Price-Anderson Act also specifies that Congress shall review the consequences of accidents that exceed these levels of protection to determine if additional payments are needed. The levels of liability
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protection described above are available for all operating nuclear )ower plants, regardless of location or poaulation density. Therefore, t1e liability levels required for the 504GS units need no adjustment on the basis of changes in the local population density. However, there have
-been general. increases in the level of secondary retrospective protection by Congress to provide additional coverage, and by the NRC to reflect inflation. For example, in 1988, the secondary assessment was increased by Congress from $10 to $63 million per operating nuclear power plant per accident, and in 1993, it was further increased by the NRC to the current level of $75.5 million to account for inflation.
- - - ~ - . - . - - - - - - - - - . - - - . - . - - .
Therefore, the increases-in liability insurance are not an indication that problems exist at the SONGS site.
II, Cateaorv 2: Issues not succorted by available information which do not meet the threshho' d for inclusion into the 2 206 netition and which will 1
not be addressed further.
!. a. Issue: You state that Southern California Edison Company (SCE) cares more about its profit margin than about the risks to the public caused
.by ti,e SONGS units.
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Response: In that you have provided no specific information supporting your assertion, we have no basis to take the immediate action you requested. Furthermore NRC resident inspectors, Region IV based inspectors, and periodically. Headquarters based inspectors, perform ongoing inspection activities at the facility. Regional and Headquarters managers are involved in ongoing comun1 cation and assessment of the inspectors' findings. NRC conducts these inspections
' and reviews to ensure that the applicable nuclear safety requirements are met regardless of the SCE profit margin.
i b. Issue: You asserted that SCE has used manipulated data and adjusted modeling techniques that should be rejected by the NRC.
- Response Ycu have not supplied any specific information regarding data 1
or mode' 'echniques to support your concern. Further, the NRC is not aware c: -a ich manipulation of data or modeling techniques. As a result, we nave no basis that would justify the immediate action you
- have requested.
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- c. Issue: You state that the NRC has established a philosophy of " defense
-in depth" as nothing more than " rhetoric."
Response: The NRC has adopted a philosophy of " defense in depth" to ensure-that the failure of individual systems will not affect the
- ability of the plant to safely shut down. The NRC has established its i inspection program to ensure that required systems are available and ready to perform their safety function. You have not included any
- specific information to support your assertion.
! III. Cateacry 3- Issues concernina emeraency creoaredness olans
- a. Issue: You state that the evacuation and traffic capacity analysis-
+
performed for SONGS underestimates the actual number of vehicles projected to be used during an emergency event. Further,you state that the evacuation plan does not assume lane closures of major roads during the evacuation which has been observed during natural events in the past.
i i
__e-- - a _-
Response: The offsite emergency plans for SONGS have been developed by public officials of the local counties within the plume exposure pathway emergency planning zone (EPZ) with the assistance of the State of California. The offsite plans have been reviewed and approved by the Federal Emergency Management Agency (FEMA), the Federal agency that has 4
the lead res>onsibility for offsite emergency planning at nuclear power plants, and lave been demonstrated in numerous exercises, most recently in October 1995. Following the drill. FEMA reported to the NRC that the State and local radiological emergency plans and preparedness for SONGS can be implemented and are adequate to provide reasonable assurance that appropriate measures can be taken off site to protect the health and safety of the public in the event of a radiological emergency at the site.
The NRC requires nuclear power plant licensees to study the population distribution relative to the transportation network in the vicinity of a nuclear power )lant and to develop evacuation time estimates (ETEs) on the basis of tie results of the study. However. NRC regulatior.s do not specify any preset minimum evacuation time that must be met in order for
, a site to be acceptable or for emergency plans to be approved. In the event of 6 serious accident requiring offsite arotective measures, plant conditions are the primdry means used by the NRC to determire protective
'- actions rather than offsite dose calculations and estimates of evacuation times. ETEs are used primarily during the planning process to identify potential traffic bottlenecks so that effective traffic control measures can be developed.
- However. the NRC does expect the ETEs in an emergency plan to be i accurate so that they provide reliable information for use in the a
ennergency ]lanning process. We have recently received a revised Emergency )lan for SONGS. dated July 25, 1997, which re evacuation time study currently in the emergency plan. The places NRC withthe 4
the assistance of: FEMA. will take your concerns into consideration during a review of the recently submitted updated analysis for SONGS.
For your information, we have included a copy of the submittal as an attachment to this letter. For the reasons stated above, your concerns regarding the adequacy of the ETEs for SONGS do not-warrant the g ininediate actions you have requested. -
- b. Issue: You questioned the adequacy of the 10-mile " emergency zone" on the basis of the results of the accidents at Three Mile Island (TMI) and Chernobyl plants. -
Response: The size of the EPZs for nuclear power plants is established by the NRC regulations. The size of the EPZs (generally about 10 miles in radius for the plume exposure pathway and about 50 miles in radius for the ingestion pathway) is determined in relation to local emergency response needs and capabilities as they are affected by such conditions as demography, topography, land characteristics, access routes, and jurisdictional boundaries. In a particular emergency, protective actions might well be restricted to a small part of the planning zones.
)
8 On the other hand, the response measures established for the 10 mile and 50-mile EPZs can be expanded if the conditions of a carticular accident warrant it. Regarding the Chernobyl accident, the NRC has concluded that no changes are needed in the NRC's emergency planning regulations as a result of the Chernobyl accident because the design, operational controls, and regulatory requirements for U.S. reactors protect them from a combination of problems such as those experienced at Chernobyl (see NUREG-1251). In particular, the NRC found that the size of the 10-mile plume exposure EPZ continues to be adequate,
- c. Issue: You expressed a concern that the local population will not respond to an emergency at SONGS because of the effect of Camp Pendleton >
training activities or because of lack of attention resulting from listening to tapes or compact discs.
Response: The NRC relies upon the established alert and notification system, which includes sirens throughout the EPZ and prescripted messages to be broadcast repeatedly over local radio and TV stations to inform the populace of an emergency. We do not expect that training activities at Camp Pendleton or temporary delays in receiving emergency broadcasts by certain individuals in the EPZ will significantly l interfere with the public's response to an emergency at SONGS.
I
- d. Issue: You questioned whether licensee personnel would remain on duty in an emergency or just run away.
[
Response: The combination of a highly trained emergency response staff.
frequent drills, and selection of personnel that are very cognizant of their duties and the risks and hazards associated with responding to a
, radiological emergency provides assurance inat licensee personnel will respond in an actual emergency. In addition, the requirements to )lan for continuous 24-hour response capability requires redundancy in cey positions. Licensees have also responded to real events at their sites, and the NRC staff is not aware of any cases in which licensee employees left assigned positions during emergency conditions other than for good cause. During the 1979 accident at THI Unit 2. some non-licensee emergency workers at the local hospital did leave to evacuate their families but later returned to their onsite duty stations. There is no record of licensee personnel leaving their onsite duty stations during this event. The emergency action taken in response to this accident is discussed in more detail in NUREG/CR-1215. "The Social and Economic j Effects of the Accident at Three Mile Island. Findings to Date " dated January 1980. Further, the historical record shows that in actual emergencies. State, local, and Federal officials have invariably done their utmost to protect the citizenry. In thousands of natural and technological disasters throughout history, paid and volunteer emergency workers have conclusively demonstrated that they will perform their
9 duties even in the face of situations involving the potential for personal harm. As a result of these factors, the NRC concludes that it would be unlikely that the SONGS emergency response personnel would abandon their positions in the event of an accident.
Attachments: As stated J
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