ML19325D566
| ML19325D566 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/16/1989 |
| From: | Kantor F Office of Nuclear Reactor Regulation, NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | |
| Shared Package | |
| ML19325D564 | List: |
| References | |
| IEIN-87-054, IEIN-87-54, OL, NUDOCS 8910250049 | |
| Download: ML19325D566 (22) | |
Text
i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4
(SeabrookStation.
(Offsite Energency Planning)
Units 1 and 2) l
)
i i
AFFIDAVIT OF F ALK KANTOR, REGARDING INTERVEtiORS' MOTION TO ADMIT CONTENTIONS ON ONSITE EXERCISE 1, Falk Kantor, being duly sworn, state as f 0110ws:
I 1.
I am employed by tne United States Nuclear Regulatory Commission as Section Chiet, Energency Preparedness Branch. Office of Nuclear Reactor Regulation. A copy of my prof essional qualifications is attached.
I have reao the Intervenors' motion and my conclusions are set forth below.
2.
In their September 28, 1959 filing, the Intervenors requested that the following contention be admitted:
The September 27, 1989 Seabrook Station onsite exercise was not a full-scale onsite exercise and did not test all or even a significant number of the major observable portions of the Seabrook Station (kERP)
("onsite plan" or "SSERP"). For this reason, the September exercise i
oid not meet the regulatory requirements for the onsite exercise to take place within one year cf licensing (" pre-licensing one-year onsite exercise") as required by 10 CFR Psrt 50, Appendix E, IV.F. 11. See also CL1-89-19. As a result, the September exercise provides no basis for the required finding of reasonable assurance as set torth in 10 CFR 50.47(a ( ) ano (2), ano that exercise is not in compliance with 10 CFR 50.47 b (14). See also ALAB-900, t
8910250049 891016 PDR ADOCK 05000443 g
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i 3.
Section IV.F.1 of Appendix E to 10 CFR Part 50 provides that:
1.
A full participation exercise which tests as much of the licensee, f
State and local emergency plans as 1s reasonably achievable without mancatory public participation shall be conducted for each site at which a power reactor is located f or which the first operating license for that site is issued after July 13, 1982. This exercise shall be conoucted within two years before the issuance of the first operating license for full power (one authorizing operation above 5%
of rated power) of the first reactor and shall. incluce participation by each State and local government within the plume exposure pathway EPZ and each State within the ingestion exptsure pathway EPZ.
If the l
full participation exercise is conducted more than one year prior to issuance 01 en operating license for f ull power. an exercise
'which tests the licensee's onsite emergency plans shall be conducted within one year betore issuance of an operating license for full
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rower. This exercise need not have State or local government r
participation.
(emphasisaddeo) 4.
The first part of 61V.F.1 addresses the " full participation" exercise which must be conducted prior to the issuance of an operating license for full power. As definea in Fl4 4 to 61V.F.1, a " full participation" exercises i
includes "... testing the major observable portions of the onsite and offsite i
emergency plans and ruobilization of State, local, and licensee personnel and other resources in sutticient numbers to verify the capability to respond to the accident scenario" (emphasis acceo). On June 28 and 29,1988, the Applicants conducted a iull participhtion exercise in compliance with this requirement of the regulations.
5.
The second part of LIV.F.1 addresses the exercise of the onsite emergency plan prior to the issuance of a full power operating license if the full participation exercise is conducted more than ont year before full power licensing, in fulfillment of this requirement the Applicants conducted an exercise of the Seabrook Station Raciological Emergency Plan (SSRERP, the onsite plan) on September 27,1989.1/
1/ The exercise was considered to have been a " partial participation" exercise in that the State of New Hampshire Incident Field Of fice and the Applicants' New Hampshire Yankee Of fsite Response Organization participated on a limited basis to test the interface with the onsite emergency response organization.
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The regulatory requirenent to test the major observable portions of
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i the onsite ano ottbite plans refers to the full-participation exercise conoucteo
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within two years of f ull power licensing and not to the exercist of the onsite emergency plan within one year before issuance of a iull-power license, f
7.
As indicated in the NRC staff filing before the Commission on i
August 28, 1969, the purpose of the one year exercise requirement is to l
l assure that adequate emergency response capability exists at the time of licensing. The Seabrook Station Emergency Response Organization (ERO), which implements the 55 REP, the onsite emergency plan, was established in 1985.
In aco1 tion to extensive training ano orills, the ERO has participated in three
)
energency preparedness exercises in addition to the September 27, 1989 exercise.
A Joint exercise of the onsite pl6n and the New Hanipshire Radiological Emergency Response Plan (hHRERP) was held in February 1986. An exercise of the onsite plan was held in December 1987.
A full-participation exercise involving the onsite plan, the hHRERP, the Seabrook Plan f or 11assachusetts Communities, onc the State of Maine Ingestion Pathway Plan was held on June 28 ano 29,1988.
Each of these exercises involveo the testing of the onsite emergency plan which was observed ano evbluoted by the NRC. These exercises included the activation of the control room, the technical support center, the operational support center, the emergency operations f acility, and the medio center. All major elements of the onsite plan were demonstrated curing these exercises.
In cocition to the exercise of record, the NRC takes into account the performance oemonstrated in previous drills and exercises as well as the adequacy of an epplicant's training, procedures, f acilities, and equipment in evaluating the adequacy of an applicant's energency response capability.
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8.
The importance of annual onsite emergency planning exercises by a licensee's operation &1 staff is recognized in the Commissiva's reguletions, L.
which now require that after a facility is licensed to operate there must be l
an annual onsite exercise (10 CFR 50, Appendix E, $1V.F.2). This annual emergency ptcparedness exercise ensures that the licensee's new personnel are acequately end promptly trainec and that ex1 sting licensee personnel raaintain their emergency response capability. The existing requirement of a pre-operational onsite exercise within one year prior to iull-power license issuance is consistent with this philoscphy. The guidance regarding the ccnduct of the er. site exercise is given in Inspection Procedure (IP) 82301 which is used by the NRC staff to evaluate the exercise. U This guidance states that licensee performance in the controi room, the technical support center, the operational support center, onc the emergency operations facility should be observed onc evaluateo, in addition, the NRC regiona'. it.spectors may adjust the Extent of observation in each area, as needed, to concentrate on areas where post 11 cense performance was consloerec marginal or in need of ubservation.
9.
Section IV.F.1 of Appendix E to 10 CFR Part 50 sets forth the pre-licensing requirements for a full-participation exercise. The Appeal Boaro in ALAB-900 concluded that this exercise must test "the major observable portiens" of the of tsite plans and mobilize sutf1cient nuFhers of personnel anc resources to verity an it.tegrated capability to respond to an accident scenario, 1
2/ The Intervenors in the Basis to their contention refer to IL Inspection Procedure 82301, dateo July 1, 1983. This procedure has been revised. The revised procedure, IP 82301, was issued on August 21, 1989.
IP 82301 was revised, in part, to reflect the flexibility in the requirements regarding the developnent of exercise scenarius.
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L An exercise of sufficient scope must test as many of the elements of the plan g
as are reasonably achievable without mandatory public participation. The l
requirements regarding the major observable portions of the plans refer to f
i the full-participation exercise (sometimes referreo to as the " initial" or "que.lifying" exercise) ano not to the exercise of the onsite plan conducted f
within one year of full power licensing. The exercise of the onsite plan within one year of licensing is considered to be akin to the annual exercise of 1
the onsite plan specified in ilV./.2 of Appendix E to 10 CFR Part 50. The i
regulations do not set forth specific requirements for the scope of an onsite exercise.
However, the staff has formulated guidance in NRC Inspection Manual, IP 62302, for celineating the scope of an exercise.
Each exercise is evaluateo in acetrdance with the guidance in IP 82301, dated August 21, 1989.
10.
10 CFR 50.47(b)(14) is the planning standard which specifies that periodic exercises are to be conducted to evaluate major portions of emergency j
response capabilities. The evaluation criteria of NUREG-0654/ FEMA-REP-1 supporting the planning standard are reflected in IPs 82301 and 82302.
- 11. The hRC staff reviewed the objectives and scenario for the 1989 onsite exercise. The staff utilized the guidance of IP 82302 in performing this evaluation, the same guidance used to evaluate other onsite emergency plan i
exercises.
IP B2302 provides the major onsite elements that should be exercised each year. The NRC review of the objectives and scenario for the 1989 Seabrook onsite exercise indicated that the exercise was in conformance with the guidence of IP 82302 ano ail of the major onsite elements would be exercised.
- 12. The Intervenors cite the fact that the September 27, 1989 onsite exercise aid not ouvance beyond a declaration of site area emergency (SAE) es ar, exercise tailure. NRC guidance to licensees and applicants on the conduct of "of f-year exercises" ci onsite emergency plans; i.e., exercises other than m
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6 the full-participation biennial exercises, specifies that the onsite exercises i
.are not required to proceed to a general emergency condition.
(SeeNRC Information Notice No. 87-54, attached.) As noted in the guidance, the P
flex 1bility within the requirenents contained in the emergency plar.ning rules 6110ws for tne development of realistic scenario > which can improve emergency response capability.
i 13.
Intervenors also raise objections that the exercise did not involve a meatcal team from local support services, did not involve the dispatch of any field monitoring teams, and did not involve any monitoring and decontamina-tion centers for onsite personnel. Field monitoring teams were in f act a part of the exercise scenario.
(See inspection Report No. 50-440/89-10.) The exercise of medical support teams and the monitoring 6nd decontamination of onsite personnel are elements of the plan thet need not be performed in conjunc-tion with each onsite exercise. Medical support services have been satisfactorily demonstrated in previous exercises and drills.
(SeefindingsandDeterminations for the Seabrook Nuclear Power Station, FEMA, dated December 1988, at 39.)
honitoring and decontamination of onsite personnel are activities which are routinely perf or6Ted as part of plant operation activities. The demonstration of this activity as part of 6n exercise is an element which can be tested over a 5-year period.
14.
I conclude that tne September 27, 1989 exercise of the Seabrook onsite plan was of suf ficient scopn to test the adequacy of the Applicants' emergency l
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response capability and was in conf ormance with 10 CFR 50.47 (b)(14) and 10 CFR 50 Appendix E, Section IV.F.1.
Thus, the informatiori brought forwara by Intervenors i
does not raise a significant safety 1swe.
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Folk Kantor f
subscribed and sworn to before this 16th day of Octoter,1969 t
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FALK KANTOR EMERGENCY PREPAREDhESS BRANCH DIVISION OF RADIATION PROTECTION AND EMERGENCY PREPARECNESS OFFICE OF NUCLEAR REACTOR REGULATION PROFESSIONAL QUALIFICATIONS I am employed as a Section Chief in the Imergency Prepareoness Branch, Division of Radiation Protection and Emergency Preparedness, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Connission.
I have responsibility for supervising the review ano evaluation of radiological emergency plans submitted by reactor applicants ano licensees to ensure proposed plans meet the regulatory requirements and guidance of the Commission.
I also function as a team member on emergency preparedness inspection teams engaged in the observat1on and evaluation of nuclear power plant emergency drills and exercises.
I have been involvec in the assessment of emergency planning and preporeaness for nuclear power plants since March 1981.
I have been a member of the NRC (AEC) Staff since January 1973.
From that time until June 1960 I helo the position of Site Aralyst in the Accident Analysis Branch. My cuties included the review and evaluation of the radiological consequences of postulated design basis accidents, the ef fectiveness of pro-posed engineered safety features, the population density and growth character-istics in the site environs, and the possible aoverse effects on plant safety of eiearby industriai, transportation and military facilities.
F rom September 1980 until March 1981 i was a member of the NRC's ensite technical support section at the Three Milt. Island f acility.
I have participated in the detaileo review of over thirty r.uclear power plant sites with the primary objective being to ensure public heaith 6nd safety through the application of Commission regulatory requirements and guidance on reactor siting.
I have presenteo testimony on siting ano emergency preparedness issues at public hearings on the licensing of nuclear tacilities, including Shoreham and Seabrook, and I have j
appeared before the Advisory Committee on Reactor Saf eguards.
I entereo graduate school in 1967 at the University of Pittsburgh on a U.S. Public Health Service Fellowship and receiveo a MS degree in 1968 in Radiation Health (Health Physics).
Following graduation I was employed by the h0S Corporation in Rockville, Marylano, and engineering and environnental consulting organization. At NUS I was involved in the environmental aspects of siting both nuclear and fossil power plants, in 1963, I began employment with the Westinghouse Electric Corporation at the Bettis Atomic Power Loboratory in Pittsburgh, Pennsylvania. My duties incluced the design of raciation shielding for nuclear power reactors for both landbased and shipboard applicants.
1 participated in field tests at Feoeral reactor facilities to evaluate the etiectiveness of shielo design f eatures on operating reactors.
I receiveo a BS degree in Industrial Engineering in 1958 from the Pennsylvania 1
State University, Upon gracuation 1 entered the U.S. Air Force where I attenced the Basic Meteorology Program at St. Louis University in St. Louis, Missouri.
Following the completion of this program in 1959, I served as a weather officer in the U.S. Air Force.
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In addition to my formal education, I have attended training courses sponsored by the NRC on reactor systems and operation ano emergency preparedness.
In May of 1979 I attended the course titled " Planning for Nuclear Emergencies" at harvard University and in September 1980 1 participated in the Radiological Emergency Response Operations Training course at the Nevada Test Site.
1 am a men.ber of the Health Physics Society.
I was a member for 25 years of the hational Guard and currently am a member of the U. 5. Coast Guard Auxiliary.
I have contributeo to the 10110 wing NRC documents:
" Emergency Planning loput f or Shoreham huclear Power Station " NUREG-0420, Supplement flo.10, May 1989.
"Dir6ctor's Finoings on Shoreham Emergency Planning Contentions,"
April 7, 1969.
" final Director's Decision Under 10 CFR 2.206," Pilgrim Nuclear Power Station December 29, 1966.
"15suance of Extension to the Exemption to CFR Part 50, Appendix E,Section IV.F.3 for the Pilgrim Suclear Power Station," May 11, 1988.
" Issuance of Exemption to 10 CFR Part 50, Appendix E, Section IV.F.3 for the Pilgrim huclear Power Station," December 9, 1987.
" Director's Decision Pursuant to 10 CFR 2.206 for the Perry Nuclear Power Plant," coteo Septenber 14, 1987.
" Issuance of Exemption to 10 CFR Part 50, Appendix E, Section IV.F.2 for the t; orth Anna Power Stetion," March 28, 1988. Exemption to conduct an exercise in 1987 granted baseo on licensee's response to SGTR event on July 15, 1987.
" Emergency Planr.ing Input for the hun.boldt Boy Power Plant, Unit I;o. 3 Decomis>1cning Saf ety Evaluation Report," letter to J.D. Shif fer, VP huclear Power Geteration, PGE, April 29, 1967.
" Director's Decision Under 10 CFR 2.E06 for San Onofre fiuclear Generatin9 Station (Expansion et EPZ)," January 29, 1987.
" Emergency Planning input for Grand Gulf Safety Evaluation Report,"
December 12, 1966.
" Issuance of Exemption to 10 CRF Part 50, Appendix E,Section IV.F.2, Wolf Creet Generating Station," November 14, 1986.
" Issuance of Exemption to 10 CFR 50, Appendix E, Section IV.F.1 for the Perry huclear Power Plant," dated October 31, 1986.
"Emerger.cy Plan Input for the Nine Mile Point Nuclear Station, Unit No. 2, Safety Evaluation Report," NUREG-1047, coted February 1985. Supplement f;c. 3 dated July 1980.
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$ SINS No.:
6835 IN 87-54 UNITED STATES NUCLEAR RErdlLATORY C0pplS$10N OFFICE OF WUCLEAR REACTOR REGl'LATION WASHINGTON, D.C.
20555 October 23, 1987 NRC-INFORMATION NOTICE N0. 87-54:
EMEp4ENCY RESPONSE EXERCISES AMressees:
All holders of operating licenses or construction pemits for nuclear power reactors.
Puroose:
l This infomation notice is being provided to remind addressees of flexibility l
that exists in certain reouirements contained in emergency planning rules.
It l
1s expected that meipients will review the infomation for applicability to i
their program. However, suggestions contained in this infomation notice do l
i l
not constitute NRC requirements; therefore, no specific action or written response is required.
(
Description of Circumstances:
I To satisfy the current requirements of 10 CFR 50.47 and 10 CFR Part 50, Appen-dix E, each licensee must annually exercise its emirgency plan.
In addition, each licensee is required to exercise with offsite authorities such that the State and local government emergency plans are exercised biennially. Currently there are no specific mquirements which address whether each exercise scenario must lead to the declaration, of a General Emergency. However, perhaps as a i
carryover from the previous requirements for annual State and local exercises.
almost all exercise scenarios are planned to progress to a General Emergency
}
condition.
Discussion:
While it may be appropriate for biennial offsite exercises to proceed to a General Emergency declaration, exercises other than biennial offsite exercises I
foff-year exercises) are not required to proceed to severe core damaoe. Such exercises can provide an opportunity for som realistic emergency response l
l training and evaluation of licensee staff. For example, before severt core
~
s damage would be expected to occur, the operating staff may be given the oppor-tunity to diagnose and attempt to correct the probles through an interactive scenario.
In addition, some exercise scenarios may be designed with initiating events at the Alert or Site Area Emergency classification.
Since actual events may go directly ta these higher level classifications without sequencing
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IN 87-54 1
October 23, 1987 i
t Page 2 of 2 i
through each emergency class, advance coportunity to activate response facili-ties may not occur. The flexibility within the requirements allows for the i
development of other realistic scenarios which, in turn, can improve emergency response capability.
10 CFR Part 50, Appendix E, Section !Y.F.3.f. states that "Itcensees shall enable any State or local government. located within the plume exposure pathway EPZ to participate in annual exercises when requested by such State or local government." To satisfy this requirement, it may be necessary for licensees to develop an exercise scenario which provides opportunities to test the appropri-ate aspects of the offsite response plan. Such participation may need to be j
negotiated between the licensee and the offsite authorities.
Licensees that have conducted realistic and interactive exercises have id'nti-e fied and corrected weaknesses in their ability to respond to such simulated.
onsite events as fire, loss of electrical power, and equipment failure. The response of personnel and availability and utilizatinn of alternate equipment.
to mitigate simulated severt off-normal plant conditions have been challenging I
and have led some. licensees to conduct further training and provide added i
procedures and support equipment.
In addition, interactive exercises can provide a. training opportunity for personnel that would be called upon to make i
strategic decisions in areas that are not addressed by existing procedures.
i Licensees and applicants may wish to ennsider incorporating.these concepts in -
)
planning and conducting off-year emergency response exercises.
~'
The revision. to the exercise frequency requirements of 10 CFR Part 50..
Appendix E has been previously discussed.in.!E Information Notice 85-55.-
" Revised Emergency Exercise Frequency. Rule."
No specific action or written response is. required by this.information notice.
If you have any questions about this matter, please contact :the technical contact listed below or the Regional Administrator of the appropriate regional office.
harles E..Rossi. % rector z
Di Division of Operational Events Assessmer;t
' Office of Nuclear Reactor Regulation theb492-90041 A.'Sakenas. AE0D "
Technical
Contact:
(30 r
Attachment:
List of Recently issued NRC Information Notices 6
i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i
In the Matter of Docket Nos. 50-443 OL PUBLIC SERVICE COMPANY OF 50-444 OL NEW HAMPSHIRE, ej al.
Emergency Planning (SeabrookStation, Units,1and2)
)
i AFFIDAVIT OF EDWIN F. FOX. JR. REGARDING ONSITE EXERCISE i
I, Edwin F. Fox, Jr, being duly sworn, state as follows:
1.
I am employed by the United States Nuclear Regulatory Comission as a Senior Emergency Preparedness Specialist, Emergency Preparedness Sectior, Facilities Radiation Safety and Safeguards Branch, Division of Radiation Safety l
and Safeguards, Region I, US Nuclear Regulatory Comission at 475 Allendale i
Road, King of Prussia, Pa. A copy of nty professional qualifications is already on record in this proceeding following Tr. 24627.
2.
I was the Team Leader of the NRC Inspection Team during the observation and evaluation of the September 28, 1989, partial participation exercise at the Seabrook Nuclear Power Station.
The conclusions and findings of that inspection are documented in NRC Region I
Inspection Report 50-443/89-10.
3.
During the conduct of this inspection, the team had available for its i
use the evaluation criteria in NRC Inspection Manual Procedure 82301 ("IP 82301") dated July 1,1983 and the final version of that procedure dated August 21, 1989.
As Team Leader, I followed the guidance provided in the August 21, 1989 version of 82301 for the ~1989 Seabrook Exercise.
This procedure states
2 that the licensee's performance in the Control Room, the Technical Support Center, the Operations Support Center, and the Emergency Operations Facility should be observed and evaluated.
It further states, that NRC regional inspectors may adjust the extent of observation in each area, as needed, to concentrate on areas where past licensee performance was considered marginal or in need of observation.
4 Team member assignments were as shown on the Team Memorandum,' dated August 31, 1989.
I served as the leader of the NRC inspection team, responsible for observing and evaluating the adequacy of onsite activities of
+
the Seabrook exercise.
In this regard, I was responsible for the overall inspection effort, which included planning and operation, chairing entrance and exit interviews, consolidating the findings of individual inspection team i
1 members, preparing the inspection report and reporting the results of the i
exercise inspection to NRC Region I management.
Individual team members were assigned to be present at the major emergency response facilities, and were to I
observe the licensee's emergency response and preparedness activities in accordance with the guidance of IP 82301. These locations included the Control
- Room, the Technical Support Center (TSC),
and the Newington Emergency j
Operations Facility (EOF).
Inspection team members were assigned to make detailed observations at their respective locations regarding the licensee's ability to perform various emergency response functions in such areas as:
Recognition and Classification of Emergencies; Notification to Offsite 5
Authorities; Activation of Facilities; Accident Assessment; Dose Assessment and projection; Protective Action Recommendations; and Overall Connand and Control.
By analyzing the licensees' performance in these functional areas, the inspection team was able to determine that each of the exercise objectives was met.
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5.
Following the exercise, the NRC inspection team met in a debriefing session, which I chaired as team leader.
The team members briefed me on their observations. As team leader, I then summarized the team members' observations and as::ertained that the individual team members were in agreement with the inspection sununary that would be presented to the licensee at the exit interview and incorporated into the inspection report.
t 6.
In preparing for the inspection, I reviewed the objectives and l
scenario for the September 1989 exercise utilizing the guidance of NRC l
l Inspection Procedure 82302, dated January 1,1989.
This procedure specifies the major onsite elements that should be exercised each year and other elements l
that should be exercised over a five-year period.
The review I conducted of the objectives and scenario for the 1989 Seabrook onsite exercise indicated that the exercise would support an adequate demonstration of the major portions of the Seabrook response capability.
7.
It is part of the intervenors' contention that: "This failure was due to the exercise design that did not:
1) advance beyond a declaration of site area emergency and, therefore, did not trigger sufficient offsite protective action decision-making." NRC Information Notice No. 87-54 states that:
While it may be appropriate for biennial offsite exercises to proceed to a General Emergency declaration, exercises other than biennial offsite exercises (off-year exercises) are not required to proceed to severe core damage.
Such exercises provide an opportunity for more realistic emergency response training and evaluation of licensee staff.
For example, before severe core damage would be expected to occur, the operating staff may be given the opportunity to diagnose and attempt to correct the Droblem through an interactive scenario.
In addition, some exercise scenarios may be designed with initiating events at the Alert or Site Area Emergency classification.
Since actual events i
may go directly to these higher level classifications without sequencing through each emergency class, advance opportunity to activate response facilities may not occur.
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1 Licensees that have conducted realistic and interactive exercises have identified and corrected weaknesses in their ability to respond to such simulated onsite events as fire, loss of electrical power and equipment failure. The response of personnel and availability and utilization of alternate equipment to mitigate simulated severe off-normal plant conditions have been challenging and have led some licensees to conduct further training and provide added procedures and support equipment.
In addition, interactive exercises can provide a training opportunity for personnel that would be called upon to ma ke strategic decisions in areas that are not addressed by existing procedures.
8.
It is not necessary for a scenario to reach the General Emergency classification as long as the major portions of the response plan can be tested.
These major portions are specified in NRC Inspection Manual, Inspection ("IP 82302") Procedure 82302 as Accident Detection and Assessment; Emergency Classi?1 cation; Notification of Onsite and Offsite Emergency Responders; Communications; Radiological Exposure Control; Protective Action Recommendations; Staff Augmentation; and Shift Staffing.
These items are evaluated during each annual exercise.
The other portions of the plan are considered to be of lesser significance and are observed and evaluated over a five-year period.
Attached is the correlation of the major elements of an onsite plan with the objectives for the 1989 Seabrook exercise (Attachment A).
In Region I Inspection Report No. 50-443/89-10 (at 6), it is noted with I
respect to the TSC that " Discussions were held regarding the potential need for protective actions and at what point they would become necessary if conditions worsened."
I also observed the Recovery Manager discuss with the designated representatives of the State of New Hampshire and the New Hampshire Emergency Response Organization (State of Massachusetts) on several occasions the need for protective actions. These discussions included those that had already been taken or recomended by the States and those that the utility would be I
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recomunending if conditions degraded at the plant.
The scenario events were sufficient to trigger meaningful offsite protective action decision making.
9.
The intervenors' contention states that, "the exercise design...did i
not..
- 2) involve a medical team from a local support services agency (the l
Seabrook Fire Department pursuant to the Seabrook RERP) or an offsite medical treatment facility (Exeter Hospital according to the SSRERP)."
The Medical i
services / support aspect of a plan is not required to be performed in each onsite exercise.
This aspect of the plan is performed by a licensee each year during drills that are periodically evaluated by NRC and FEMA observers or during biennial exercises.
Conducting them coincident with an annual exercise is of little additional value.
Further, the Applicants have demonstrated the effectiveness of the medical services aspect of the plan by utilizing it for actual emergercies that have occurred over past years.
10.
The intervenors' contention asserts that "the exercise design...did not..
- 3) involve the dispatch of any field monitoring teams and assessment activities."
Section 4.0 of Inspection Report No. 50-443/89-10 reports that t
i field monitoring teams arrived at the EOF and were promptly and effectively prepared for dispatch; were promptly dispatched (within 50 minutes of arrival l
l at the EOF); communications between the EOF and the field teams were excellent; sample counting equipment was set-up promptly; and sample control and analysis including surveys and the use of anti-contamination clothing were effectively demonstrated.
Also, this is a plan aspect that need only be demonstrated over a five-year period.
(See 19 above).
Field monitoring assessment was 1:
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l
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I demonstrated in accordnace with Objectives Nos. 15 and 16 in the 1988 Seabrook Exercise.
11.
The last part of the intervenors' contention states that "the exercise design... did not..
- 4) involve any onsite personnel monitoring and f
decontamination at the offsite locations planned for that purpose (the Seabrook Dog Track and the " Warehouse" on route 107)."
As noted in paragraph 8 above, this is not a major portion of the Seabrook onsite plan.
Monitoring and decontamination of personnel is a routine activity and portions or all of it is done daily at a nuclear power plant.
Personnel leaving the plant are monitored for contamination automatically as they pass through portal monitors.
The use of the Seabrook Dog Track wotild only be used under the situation in which a radioactive plume was blowing toward the security exit where the portal monitors are located, nullifying their effectiveness.
The scenario did not provide for such a release so normal monitoring was in effect.
12.
The intervenor's basis for the contention is the section from NRC's inspection and Enforcement Manual ("lE Inspection Procedure 82301") with its attachment, NRC's Exercise Evaluation Criteria for onsite exercises, dated July 1,1983, which states:
" Sections 1, 2, and 3 [of the Evaluation Criteria]
(control room, technicai support center, and emergency operating facility) must be evaluated annually g the entire program must be evaluated in the initial exercise prior g escalation of power beyond 5%."
(Emphasis added).
The July 1, 1983 version of IP 82301 was superceded by the August 21, 1989 version utilized as guidance for the September 1989 Seabrook Exercise.
The section quoted above is not in the current version of IP 82301.
1 13.
The NRC evaluated the September 1989 Seabrook Exercise and published a sumary of its exercise team findings concerning the adequacy of on-site emergency planning and preparedness in Inspection Report No. 50-443/89-10.
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That report concludes, "No violations, deviations or unresolved items were identified.
The licensee's response actions for this exercise demonstrated the ability to implement the emergency plan in a manner which would provide adequate protective measures for the health and safety of the public."
The l
scope of the September 1989 exercise was sufficient to test the major elements I
of the Seabrook onsite emergency response plan.
The information relied on by the intervenors does not show a deficiency in the scope of the onsite exercise i
and, thus does not raise a significant safety issue.
The foregoing is true and correct to the best of my knowledge and belief, Edwin F. Fox Subscribed and sworn to before this day of October, 1989 Notary Public My Comission expires:
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$Ifi Attachirni:
A CORRELATION OF 1989 SEABROOK i
PARTIAL PARTICIPATION EXERCISE OBJECTIVES AND NRC INSPECTION PROCEDURr 823Q2 i
ANNt'AL REQUIREMENT 9/27/89 Exercise Objective Nos.
A.
Accident Assessment 3, 10, 14, 21 B.
Emergency Classification 2
C.
Notification of onsite end offsite 5(onsite);
Emergency Responders 6a - c. , 9, 24 (offsite)
D.
Comrani:ations 19, 25, 25
'i.
E.
Rt.diolcgical Exposure Control 12, 13 l
F.
Piv6ective Action Recomendations 10, 11, 27 G.
Staff Augmentation 5., 6, 22 H.
Shift Staffing 1, 4, 5, 8, 15, 20, 22 l
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w, W UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 89 BCi 17 P1 :45 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Docket No,S$( 6.. ' ?, d 9
in the Matter of
- s. 50-443'0L PUBLIC SERVICE COMPANY OF 50-444 OL j
NEW HAMPSHIRE, g aj.
Off-site Emergency Planning (Seabrook Station, Units 1 and 2) s CERTIFICATE OF SERVICE I hercby certify that copies of "NRC RESPONSE TO INTERVEN0RS' MOTION TO ADMIT CONTENTIONS ON SEPTEMBER 27, 1989 EXERCISE, and AFFIDAVIT OF FALK KANTOR h
REGARDING INTERVENORS' MOTION TO ADMIT CONTENTIONS ON ONSITE EXERCISE and AFFIDAVIT OF EDWIN F.
FOX REGARDING ONSITE EXERCISE" in the above caotioned R
- proceeding have been served on the following by deposit in the United States I
mail, first class or, as indicated by an asterisk, by deposit in the Nuclear j
Regulatory Comission's internal mail system, as indicated by double asterisks, by Express Mail, this 16th day of October 1989:
Ivan W. Smith, Chaiman (2)*
Philip Ahrens, Esq.
Administrative Judge Assistant Attorney General
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Atomic Safety and Licensing Board Office of the Attorney General L
U.S. Nuclear Regulatory Commission State House Station Washington, DC 20555 Augusta, ME 04333 Richard F. Cole
- John Traficonte Esq.**
Administrative Judge Assistant Attorney General Atomic Safety and Licensing Board Office of the Attorney General i
U.S. Nuclear Regulatory Comission One Ashburton Place, 19th Floor i
Washington, DC 20555 Boston, MA 02108 i
Kenneth A. McCollom Geoffrey Huntington, Es Administrative Judge Assistant Attorney Gene al 1107 West Knapp Street Office of the Attorney General Stillwater, OK 74705 25 Capitol Street-i Concord, NH 03301 Thomas G. Dignan, Jr., Esq.**
l Robert K. Gad, III, Esq.
Diane Curran, Esq.**
Ropes & Gray Harmon, Curran & Touslay One International Place 2001 S Street, NW Boston, MA 02110-2624 Suite 430 Washington, DC 20009
r
)
O o
i H.' J. Flynn, Esq.
Judith H. Mizner, Esq.
j Assistant General Counsel 79 State Street Federal Emergency Management Agency Newburyport, MA 01950 500 C Street, S.W.
Washington, DC 20472 Robert Carrigg, Chairman Board of Selectmen Paul McEachern, Esq.
Town Office 1
Shsines & McEachern Atlantic Avenue 25 Maplewood Avenue North Hampton, NH 03862 P.D. Box 360-Portsmouth, NH 03801 William S. Lord Board of Selectmen Sandra Gavutis, Chairman Town Hall - Friend Street Board of Selectmen Amesbury, MA 01913 RF0 #1,. Box 1154 kensington, NH 03827 Mrs. Anne E. Goodman, Chairman l
Board of Selectmen i
Calvin A. Canney 13-15 Newmarket Road i
C1ty Hall Durham, NH 03824 l'
126 Daniel Street 1
Portsmouth, NH 03801 Hon. Gordon J. Humphrey l
United States Senate R. Scott Hill-Whilton, Esq.
531 Hart Senate Office Building Lagoulis, Clark, Hill-Whilton Washington,_DC 20510
& McGuire l
79 State Street Richard R. Donovan Newburyport, MA 01950 Federal Emergency Management Agency Allen Lampert Federal Regional Center Civil Defense Director 130 228th Street, S.W.
Town of Brentwood Bothell, Washington 98021-9796 20 Franklin Exeter, NH 03833 Peter J. Matthews, Mayor City Hall William Armstrong Newburyport, MA 01950 Civil Defense Director Town of Exeter Michael Santosuosso, Chairman i
10 Front Street Board of Selectmen Exeter, NH 03833 South Hampton, NH 03827 Gary W. Holmes, Esq.
Ashod N. Amirian, Esq.
Holmes & Ellis Town Counsel for Merrimac 47 Winnacunnet Road 145 South Main Street Hamnton, NH 03842 P.O. Box 38 Robert A. Backus, Esq.**
1 Bradford, MA 01835 Backus, Meyer & Solomon i
116 Lowell Street Barbara J. Saint Andre, Esq.
Manchester, NH 03106 Kopelman and Paige, P.C.
77 Franklin Street Boston, MA 02110 l
P,
% Ms. Suzanne Breiseth J. P. Nadeau Board of Selectmer.
Board of Selectmen Town of Hampton Falls 10 Central Street I
Drinkwater Road Rye, NH 03870 Hampton Falls, NH 03844 Atomic Safety and Licensing Robert R. Pierce. Esq.*
Board Panel (1)*
Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board Panel Washington, DC 20555 U.S. Nuclear Regulatory Counission Washington, DC 20555 Office of the Secretary (3)*
U.S. Nuclear Regulatory Commission j
Atomic Safety and Licensing Washington, DC 20555 Appeal Panel (6)*
Attn: Docketing and Service Section i
U.S. Nuclear Regulatory Commission
{
Washington, DC 20555 i
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tt4 ny Mitzi 5. Ydung
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Counserfor NRC Staff
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