ML16340B672
| ML16340B672 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 03/31/1981 |
| From: | Krejsa R SAN LUIS OBISPO, CA |
| To: | |
| Shared Package | |
| ML16340B670 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8105040469 | |
| Download: ML16340B672 (26) | |
Text
h h EXHIBIT 9 f
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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PACIFIC GAS AND ELECTRIC COMPANY Docket Nos. 50-275 O.L.
) 50-323 O.L.
(Diablo Canyon Nuclear Power, Plant, Units 1 and 2)
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AFFIDAVIT OF DR. RICHARD J. KREJSA I, Richard J. Krejsa, being duly sworn, state under oath the following:
(1) I am a resident of San Luis Obispo County (" County" ),
California. I reside at 189 San Jose Court, San Luis Obispo. I currently am a professor at the California Polytechnic State University in San Luis Obispo, California.
(2) From January 1973through March'1980, I served as a member of the Board of Supervisors of San Luis Obispo County (" County" ),
Cali fornia.
(3) As Chairman of the Board of Supervisors in 1975 and subsequently as a member of the Board, I was responsible, with'other Board. members, for the overall direction of County activities relating to the safety of the citizens of the County, including their safety in the event of a radiological emergency at the Diablo Canyon Nuclear Power Plant.
(4) As a San Luis Obispo resident and former Board member, I continue to be concerned about the County's preparedness to respond effectively to a radiological emergency at Diablo Canyon. I am
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familiar with the existing County emergency plans designed to provide for offsite emergency response under County direction to a radiological emergency at Diablo Canyon. These plans were prepared when I was Vice Chairman of the Hoard.
(5) Although the County has emergency plans on paper, these plans are not current and are virtually worthless in application. The plans would not provide any protection to County residents in the event of a radiological emergency at Diablo Canyon. This is because the County simply has not budgeted sufficient funds or made sufficient preparations to implement even these meager plans and thus neither the County nor'other agencies are prepared to respond adequately to an emer-gency at Diablo Canyon. Indeed, our County plans are essentially unworkable, a view which I have held for many years. In that regard, I attach a copy of an April 13, 1979 letter from me to Senator Alan Cranston, with attachments, which documents the unworkable nature of our plans.
(6) To my knowledge, the existing County plans remain un-workable today and there are no plans for the County to implement them.
As for the current Voorhees studies, to this point, it has not got us beyond what I already knew to be inadequate in 1976.
Richard . Kre 's Subscribed and sworn to before me thss <I day o f M~M, 1981
~I otary Public i<r~~ee, + .OFFCIAL SBAL JEAN SORENSEN u
My commission expires: NOTARY PUBLIC CALIFORNIA PIIINCIPALOFFICE IN SAN LUIS OBISPO COUNTY My mission Expires Jln. 14, 1983 Attachment
l BOARD OF SUPERVIS'ORS SAM Luis ODIsPo, ChLII'oiut1A 93401 r Sp5->43.155p, Err. 321 Members oj the Board HANS HEILMANN STEVE H4C ELVAINE KURT P. KUPPER April 13, 1979 HOWARD MANKINS DR. RICHARD J. KREJSA The Honorable Alan Cranston State Senator, California 452 Senate Office Building Washington, O.C. 20510 Oear Alan:
The San Luis Obispo County Nuclear Emergency Response Plan for Canyon has a Low Population Zone (LPZ) of 6-mile radius wherein 'iablo there are located 20 residences. According to federal guidelines to this point, all planning for n'uclear emergencies is based on siting requirements for a plant and limited to the LPZ (Reactor Site Criteria 10 CFR Part 100). Yet, within a 7-mile radius of Oiablo Canyon there are 1000 people, and within a 12 mile radius more than one half of our County's 140,000 population resides!
Today I received (four months after publication and two weeks after the closure for public comments) a copy of NUREG-0396, EPA 520/1-78-016 which deals with a planning basis for radiological emergency response plans of local and state governments.
states:
On pages III-7 and III-8 it "The loss of either some or all engineered safety features are
postulated in Class 9 accidents. If the engineered safety features are lost during an accident, then the LPZ has no meanin with r egard to the size of the areas around the plant in w ic emergency response would be appropriate."
Alan, for three long years I have spoken out, written letters, testified at, hearings, etc., about the inadequacy of our County pre-paredness for a radiological emergency. While our emergency plans meet all guidelines, they are essentially unworkable. My pleas have been virtually ignored, as witness the record of correspondence, etc. that I submitted to the California Assembly Subcommittee on Energy (see enclosed).
I The Honorable Alan Cranston State Senator, California April 13, 1979 Page Two I even shared this concern with you in July of 1976, to which you briefly
.replied on September 17, 1976 (see enclosed Exhibit "0"). Please Alan, we cannot afford a replay of Three-Mile Island in San Luis Obispo.
Please read the attached packet of information and then act in our
~behal ... now!
Thank you for listening.
Si rely yours, w(
DR. RICHARD J. KREJSA Supervisor, Fifth District.
mr Encl osure
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EI,O~RD QP SUPERVISORS Covnzliovsr li'%Ex < Si%4 LvIs OnIsro, C~I.IFoniI~ 9>108 . '".80>-)~3-3550, ExT. 321 . ~i...- = '-
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slfcmbcrs of Ihc Board HANS HEILMANN Steve Mac Elvaine KURT P. KUPPER HOWARD MANKINS DR. RICHARD J. KREJSA April ll, 1979 Honorable Mel Levine, Chairman Subcommittee on Energy Room 4167 State Capitol Sacramento, California 95814
Dear Chairman'Levine:
In resPonse to your letter of 4 April 1979, I am forwarding a letter in lieu of personal appearance and a packet of exhibits .and information regarding San Luis Obispo County s ability (or lack there-of) to respond to any emergency associated with the Diablo Canyon Nuclear Power Plan.
The exhibits detail efforts I have made in the past three years to enhance the level of preparedness in our County. I am certain there is enough information here for your committee to come to your own conclusions about the nature of the NRC Hearing procedure and the willingness of the NRC to approve each incremental stage of the licensing on the basis of promises that cannot be fulfilled.
If I can be of any further assistance to your committee, please do not hesitate to call upon me.
Sincerely yours, DR. RICHARD J. RE JSA Supervisor, Fifth District RJK:ml s Enclosures
I gt BOARD OF SUPERVISORS
( ouIITrrousE Aistx ~ Shi Lars Orrrsr'o, C~I.II:oaiu 9340S i '%'-543'1550, Exv. 321.
Afcrrr1rcrs of Ihc Board HANS HEILMANN Steve'Mac'Elvaine KURT P. KUPPER HOWARD MANKINS DR. RICHARD J. KREJSA April ll, 1979 Honorable Mel Levine, Chairman Assembly Subcommittee-on'nergy Room 4167 State Capitol Scaramento, California 9SS14
Dear Chairman Levine and Members of the Energy Subcommittee:
I am Dr. Richard J. Krejsa, Supervisor of the Fifth District, San Luis Obispo County. I was first elected in 1972 and took office in January 1973. I am currently 2nd Vice Chairman of the CSAC Energy Committee; a member of CSAC's Health and Wel-fare Committee; President of the Central Coast Regional Association of County Super-visors; Chairman of the Mid-Coast Health Systems Agency; and Professor of Biological Sciences at California Polytechnic State University, San Luis Obispo.
Please accept my apologies for not being able to attend your hearing Monday night, April 16, on such short notice. I will be in Sacramento on April 19th, and could arrange to meet with you if you wish to speak to me personally.
Given the opportunity to testify in person, I would offer the following com-ments and information to your subcommittee.
In 1966, California coastal counties competed for the "prize" of having a nuclear power plant (and potential tax benefits) within their boundaries. San Luis Obispo was the lucky "winner".
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Public hearings, such as they were, were held by the P.U.C. and the (then) A.E.C.
beginning in February, 967. Initial. permits for Diablo Canyon Unit One were granted by February, 1968. Whatever the basis for the P.U.C. and A.E.C. decisions at that time, I would call your attention to the fact that atomic energy then was considered generally to be safe, clean, inexpensive, and peaceful.
I Honorable t1el Levine 4/11/79 The initial application was never revi d '9 of either the National Environmental protectlcn Act of 1969 (NEPAL ) or of o th the California Environmental guality Act of 197O (CEqA) Maste storage was a minor r problem to be solved at some future time,.the Hosgri Fault u was un nown, and hydrogen bubbles were never even unknow imagined.
Now, 13 years lat r, the County finds itself with an courtroom facilities, nationwide atte t d t no -b dg t d s (ta doll s) a d p p that much more yet. to come t sn th f " o A t6 1978 F th d r p a j if the
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eea oc a e ss threatened NRC rrants n s an operating license to icing suc could be enormous to our County.
The presence of the Diablo Canyon Nuclear Power Plant is n of previously unrecognized and unex ected functions f d al o stat spo b 1 t d o Amo h th Pl t E R o Pl . (It h dt rd to conceive of the necessity of a Solar f 1 t various off-site localities moni waste transportation routes, specialized p ze trainin raining of health and safety personnel,
, an of course, constant preparation for further demon-But all this is prologue. I wish to limit cavalier way in whi h the public safet f ty ' h b t, t, d ot o ly by th A.E.C. '
sspo oun y Board of Superv>sors. The only wer tho ghly b a wash d t b 1 t sibility and that the A.E.C./NRC wa th e source so o all w sdom and guns sc on an e , oard members have no such excuse behind which to hide.
Officially, our County has: I) a Count Emer Plant Emergency Response Plan and 3) a Nuc Emergency Evacuation Plan. On the ese 1n 1cate an increased readines s to respond by coordinat-ing the various prime agencies ws within sn thehe County. All three plans meet mandated guidelines.
But in reality, this is an illusion. The word "
to o d f 11 d Th o d "
p 1 an" imp ies a sense of secunty. It is my t th t b 1 dth f *t is fa 1 se. Mith M a few t ld to th o b 11 e d to upono respond to tl an emer enc n a d equate y. Other than mutual-aid a r od certai n fire and police agencies, Gone between. the Bit.
do not
) aes an ounty have been. entered into, as requirre d by th e County Emergency Plan..
As a matter of fact , our Board of Supervisors, on March 26, 1979 7 one day
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Honorab1e Mel Levine 4/11/79 before the Three Mile Island disaster, adopted our "revised" County Bmergency plan under grotest after I pointed out to them that while it meets State guidelines, it is umIorkable in the event of an emergency! Indeed, with unanimous approval of our Board, the Chairman wrote a letter to our Legislators, Carol Hallett and Bob Nimmo, in which, in part, says the following:
"It is our Board's belief that the County Emergency Plan, which reflects the 'recommended State guidelines is cumbersome, verbose, and unusable as a response manual." .I enclose both the Board Resolution and the Chairman's letter as my first exhibits.
(EXHIBIT "A" )
Now this recognition by our Board is most ironic in view of the following cir-cumstances, which are also documented:
On December T8, 1972, a letter was sent to P.G. 5 E. by Mr.
Russell K. Powell, a Deputy Administrator (read 3rd level heirarchy in County Administrator's Office) assuring them that the Board of Supervisors is "most receptive to the emergency needs at all times" and that "our office of .Civil Defense and Disaster" stands ready to assist your company in efforts to protect the l,ives and well-being of citizens should=.such an emergency occurrence arise at your Diablo Canyon Nuclear Plant." (EXHIBIT "B")
Honorable Chairman and members, someone directed Mr.'owell to write such a 1 etter but there i s no record of a Board Resol uti on or Board Order which says that our Board is able to meet the emergency needs of anyone! Furthermore, in 1972, there was no "Office of Civil Defense and Disaster" in the County of San Luis Obispo,.
unless Nr. Powell considered himself self-designated! Indeed, our County did not have a ~Count ~merqmenc Plan un'til one was adopted by the Board in mid-1975. In point of fact, even that single document was of such low priority with the Board
'majority that no funds were budgeted for its printing until June, 1976, at which time only 33 copies 'were printed arid distributed to less than half of the agencies which could eventually be called upon in the event of an emergency. Please recall that the plant was scheduled to open in 1976. Indeed, it is that same document slightly revised and updated to meet State guidelines that our Board unanimously found unusable just two weeks ago!.
Now, however strange you might find these circumstances, the next is even worse. That "promisor@ note" of Mr. Powell, unsupported hy Board action, forms one of the main bases on which Nuclear Regulatory Commission staff found PGS E in compliance with federal .regulation 10 CFR 50, Appendix E, Section IV D (which states that the applicant must make arrangements with local officials and agencies for any help that may be needed in an emergency.
I refer you to the letter from Mr . Lee Gossick, Executive Director for Operations, NRC, to the Honorable Robert J. Legomansino, in response to a letter from me (Exhibit C). Specifically, paragraph 4, on the first page which states:
"In the case of Diablo Canyon, the NRC's Safety 'Evaluation Report dated October 16, 1974, stated that the NRC staff
I Honorable Mel Levine 4/ll/79 reviewed the Diablo Canyon facility emergency plan and f it
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'C found that
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conforms wi th Apendix E and was acceptable."
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Again, I .remind you that however inadequate, our County did not have a ub-lished Emer enc Plan until June 1976, almost two years after P.G. 5 E. s plan a lS was approved and three and one half years after Mr. Powell assurred P.G. a E.
1J of Board readiness!
Further, you will notice in paragraph 5 of the Gossick letter to Lagamarsino, that P.G- 5 E. also has a letter in support of their application, dated January 25, 1973, from Sierra Vista Hospital which states:
"I understand. the conditions that you propose in your letter and feel that we would be able to provide the necessary faci-lity and services."
That "promisory note" was written hy Mr. Glenn Carlson, Administrator of Sierra Vista who, privately admitted to me in 1976, that the letter was not an a reement 'ospital to.provide services but only an acknowledgement of the needs of P.G. 8 E. My under-standing is substantiated by an article in the Santa Maria Times, dated November 5, 19?6, which states:
'"(Glenn Carlson, --- told the TIMES by telephone that the hospitals does not have a binding agreement, or any kind of agreement with Pacific Gas and Electric. He said there has ban contact between the two, including a letter, but "no agreement")" (EXHIBIT 0)
In my letter to Lee Gossick dated September 16, 1976, (EXHIBIT E); at the safety .
hearings conducted by the State Energy Commission in Avila Beach on November 4, 1976, EXHIBIT F; and again at the Environmental Hearings of NRC Atomic Safety Licensing Board, on December 7, 1976 (EXHIBIT G}; I testified that, the Powell letter was not
.supported by Board action and that there exists no 'arrangement for medical treatment in the event of any accident involving off-site release. That is a matter of record and it has never been refuted. .Indeed, Energy Commissioner Ron Doctor found my testimony "astounding".
I repeated these charges and others again on December 5, 1978, to the NRC Atomic Safety and Licensing Board(EXHIBIT H}. To my knowledge. at that time, there were yet no arrangements for medical care for radiation injury for other than P.G. 8 E. workers on-site.. After my testimony, the French Hospital administrator is reported to have said that they would provide assistance to others, but I am not yet aware of any public document or agreement that guarantees that care will be given at French Hospital or anywhere else to off-site victims.-
One further point. In late 1975, the State Office of Emergency Services began to push for Nuclear Power Plant Emergency Response Plans and Evacuation Plans for each County having a nuclear unit within its boundaries'. In early 1976 I tried to get our Board of Supervisors to prepare emergency plans when I discovered how ill-prepared our County was to meet any emergency (EXHIBIT I). No action was taken.
At budget, time in August 1976, our Board finally consented to fund an Emergency Response Plan and Evacuation Plan after P.G. 8 E. let it be known that such a plan
Honorable Mel Levine 4/ll/79 was necessary for them to meet NRC requirements. At that time one man, George Silva, filled the role of part-time Disaster Coordinator and p t-t A 1 ro seer ( og catcher)! The Board. allocated extra funds for a crash program to put together an Emergency Response Plan and Evacuation Plan. A hearing was scheduled for October 25, 1976. Only Orange County had a response plan available at that time so, for expedience sake, the Disaster Coordinator copied the San Onofre plan almost verbatim in order to meet the October 25 deadline, at which time the rough draft plans were presented to the Board. A hearing date was set for December 2, 1976, less than a week prior to the NRC Atomic Safety Licensing Board environ-mental hearings at Avila Beach.
On November 4, 1976, Disaster Coordinator Silva testified to the State Energy Commission that our pr~osed Nuclear Emergency Response and Evacuation Plans " -
in themselves do not re resent a com rehensive emer enc res onse s stem." Ac-cording to Silva, the "necessary implementation procedures - "to be consid si ere d he development of' comprehensive system capable of'responding effectively to a radiological hazard of an accident at a nuclear power plant." woui1d involve seven items. (see EXHIBIT J) At this point and to my knowledge,'ery little has been done on items 2, 3; and 7, nothing on items 1, 4, 5, and 6. Again, another "promisory note" by the County.
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On December 2 the draft plans were reviewed briefly by the Board, limited public testimony was received, and the Board continued the hearing until December 21 so that the matter could be "discussed in depth".
On December 21, 1976, the Board of Supervisors held a public hearing on the draft plans and, on December 22 adopted (3:2 vote) an inherently unworkable plan after allowing me to read into the record some 9 pages of detailed criticisms! (EXHIBIT K).
That plan was further updated with SOP's for various County departments and the California Highway Patrol on June 20, 1977. Otherwise, the plan remains full of unanswered questions rendering it barely implementable, if at all.
At this point I would call your attention to the fact that the 6-mile radius Low Population Zone (LPZ), set by the applicant with NRC approval, includes only 20 residences. Yet, within a 7-mile radius there are 1000 people and, within a 12-mile radius, more than half the population of our County resides! (EXHIBIT L)
I would ask your committee to fully re-evaluate the unworkable concept of the LPZ and in its place suggest a workable strategy that would reasonably protect the population from unexpected releases of radioactivity from a functioning or ma1-functioning nuclear power plant.
Mr. Chairman and members of the committee, I submit to you that not withstand-ing the existence of three "approved" plans, had we experienced an emergency such as that recently at Three-Mile Island, or, heaven forbid, one worse than that, our County would be ill-prepared to respond in a manner which would guarantee the safety
Honorable hei Levine 4/ll/7B of even a few of our citizens! I respectfully request that you read my documenta tion and then ask yourselves, in all honesty, if you had a nuclear plant in your backyard, whether you would trust the guidelines and procedures thus far established by the NRC or State O.E.S. to protect you and your families from the ultimate acc-ident!
Thank you for your patience in receiving my testimony.
tfully submitted, OR. RICHARD J. REJSA Supervisor, Fifth District RJK:ml s Enclosures
I BOARD OF SUPERVISORS CovBTHpvsB Q~NBx ~ S~N Lvis OBISPO, ChLIFOR'cIA 93001. e j 80j-j-.3ml joa Exx. 32) hfnfibtrS Of !he BOard HANS HElLMANN STEVE MC ELVAINE KURT P. KUPPER March 26, 1979 HOWARD MANKlNS DR. RICHARD J. KREJSA Assembly~oman Carol Hallett State Capitol,, Room 3126 Sacramento, California 95814
Dear Assemblywoman Hallett:
At the March 26. 1979, meeting of our County Board of Supervisors, this Board considered and approved the; revised "San Luis Obispo County Emergency. Plan" (enclosed). During discussion on the. matter, our Board strongly noted that the State emergency'plan guidelines contained use-less information which did not meet'ocal needs.'urther, the. guidelines failed to outline model response procedures for use during an emergency.
Our approval. of 'the revised plan was strictly a matter of meeting the State's final deadline for'submittal of the plan.=
It is our Board's belief that the County Emergency Plan, which reflects the recommended State guidelines, is cumbersome, verbose, and unusable as a response manual.i It is unfortunate that the State Office
~o Giergency Seruices considers their guidelines a "model" examp1e of an emergency response plan.. It is obvious that this is not the case.
Me request that you review and determine the usefulness of our emergency plan. Further, we strongly request that you'take steps which would mandate the State Office of Emergency Services to publish step by step guidelines'which'could be ised to develop'a simplified and useful emergency response'plan.
Respectfully submit'ted, HAiRS HEILMANN Chairman Board of Supervisors HH/JP: jr Encl osure
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.December -18, 1972 Hr- Raymond-H- Nhite, Manager Claims and Safety Department Pacific Gas and Electric Company 245 Harket Street San Franci sco,'al i fornia 94106
" Attention: Hr - Hugh M. Reynolds
Dear Hr. Reynolds:
.. Thank. you for your letter of December 8, 1972-
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As you know, th Board of Supervisors is charged with the. respons ibi i ty of caring for the ci t izens of 1
the County, and readily accepts th!s premise insofar as the statutory and moral scope oF the ir respons i-.
bilities are concerned ~
Our Qff ice oF Civil Defense and Disaster stands ready to assist your company in efforts to protect the lives and v;all being of citizens should such an.
eme rgency occur rence a r i se a t your 0 i ab o Canyo'n 1 Nuclear P 1 ant-You are aware, < am sure, that t: he Board of Supervisors would need to oFF icial ly order this oFfice to put into effect t:.he general rescue, transportation, enForcement and personal care facil ities and planning based on the ne d of each individual - You wi 1 1 f ind them ost receptive to the emergency needs at al times- 1 lf we can help you further in this matter, please
.do not, hes i tate to cal 1-RUSSE LL ..K- PO"lELL
, Beputy Admi n is t ra tor Special 'Ass ignments ch
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