ML19325D568
| ML19325D568 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/11/1989 |
| From: | Dignan T PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#489-9312 OL, NUDOCS 8910250054 | |
| Download: ML19325D568 (48) | |
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October 11, 1989 !
29 CT 17 P1 :49 l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l
?n- , . !
before the WO [,Q ] % C t j ATOMIC SAFETY AND LICENSING BOARD l ) i In the Matter of ) ;
t )
PUBLIC SERVICE COMPANY ) Docket Non. 50-443-OL i OF NEW RAMPSHIRE, at al. ) 50-444-OL i
) :
t (Seabrook Station, Units 1 ) (Offsite Emergency !
and 2) ) Planning Issues) L
)
APPLICANTS' RESPONSE TO INTERVENORS' MOTION !
70 ADMIT CONTENTIONS ON THE SEPTEMBER 27, 1989 .
I EMERGENCY PLAN EXERCISE STATEMENT OF THE CASE !
i On September 27, 1989, Applicants conducted an exercise to test the Seabrook onsite emergency plans as contemplated i t
by the third and fourth sentences of 10 CPR 50, App. E !
i l $ IV.F.1. Under date of September 28, 1989, the Attorney ;
l General of The Commonwealth of Massachusetts (MAG), acting [
i for himself, Seacoast Anti-Pollution League (SAPL), and New [
i l
England Coalition on Nuclear Pollution (NECNP) filed a l l document styled "Intervenors' Motion to Admit Contentions on L the September 27, 1989 Emergency Plan Exercise" (" Motion"). -
t l
The Motion seeks to have admitted for litigation the ;
following contention: l "The September 27, 1989 Seabrook Station 8910250054 891011 .
h1 ;
u onsite exercise was not a full-scale ;
onsite exercise and did not test all or even a significant number of the major i observable portions of the Seabrook l Station RERP ('onsite plan' or 'SSRERP'). j For this reason, the September exercise did not meet the regulatory requirements :
for the onsite exercise to take place I witnin one yenr of licensing (' pre- -
licensing one-year onsite exercise') as ,
required by 10 CFR Part 50, Appendix E, ;
IV F. 11. 123 also CLI-89-19. As a i result, the September exercise provides no basis for the required finding of t reasonable assurance as set forth in 10 CFR 50.47 (a) (1) and (2), and that exercise is not in compliance with 10 CFR
- 50. 47 (b) (14 ) . Ett also ALAB-900."
The contention is accompanied by a professed statement of basis,2 a purported showing that the "five factors" test for ;
late-filed contentions is met,3 and an argument as to why the f provisions of 10 CFR $ 2.734 regarding the reopening of ,
closed evidentiary records need not be met.4 l ARGUMENT I. THE EVIDENTIARY RECORD IS CIASED' IN THIS i
PROCEEDING, AND ITS PROPONENTS HAVING FAILED l TO ADDRESS, AND DENONSTRATE COMPLIANCE WITH, THE PROVISIONS OF 10 CFR $ 2.734, THE MOT 20N !
MUST BE DENIED.
MAG takes the position that there is no need to satisfy '
the requirements for reopaning the record set out in 10 CFR f l 1 Motion, Attach. A at 1.
2 And Egg Exhs. 1-3.
Id. at 1-3. ,
1 3 Motion at 4-8. (
4 l Id. at 8-9.
l-t
E 1 c o i i 2.734 in order to have the contention at issue admitted for litigation. In so contending he (1) ince.g..'> rates by reference certain of his arguments made in prior pleadings,5 (2) references the fact that the onsite exercise is a necessary prerequisite to licensing under.10 CFR App. E !
i IV.F.1,6 and then (3) notes that in its recent decision ,
denying the Applicants' request for an exemption, the Commission "made no reference at all to any requirement to' reopen the record" and argues that, by implication, this means that compliance with 10 CFR $ 2.734'is unnecessary.7 l MAG's argument ignores the fact that, while it may be j i
that there is a right to litigate at..rvs material to ,
licensing, it is also well settled that this right is subject to " placing reasonable requirements upon the filing of late-filed contentions.nB In a case like that at bar, where the !
evidentiary record is closed, one of those reasonable i requirements is compliance with 10 CPR $ 2.734. As we understand the prior pleadings incorporated by reference by i
MAG, MAG's response to the foregoing is to say that two 1984 i decisions of the United States Court of Appeals for the i l
5 Motion at 8.
6 Id.
7 l Id. at 8-9.
t 8 public Service Comoany of New Hampshire (Seabrook Station, Units 1 and 2) , ALAB-918, 29 NRC 473, 481 at n.21 (1989).
i r
I
- l District of Columbia Circuit, UEE 9 and Mothers for Peace,10 i should be read as invalidating the 10 CFR $ 2.734 standards for reopening on a matter which is material to licensing.
MAG relies upon excerpts from these two cases for the extraordinary proponition that the court had essentially declared invalid a not-than-yet-promulgated commission rule (10 CFR $ 2.734), at least insofar as exercise contentions are concerned. However, a review of the two cases reveals that the only regulation UES discussed was 10 CFR 5 2.206, (10 CFR 5 2.734 being then nonextant), which is a rule of unfettered discretion. Mothers for Peace discussed the agency case law which set out only one of the two then-extant
" decision generated" standards for reopening, which standard was one which required the movant to show that a different result would result. of course, the 1 ster-adopted Rule of Practice, 10 CFR $ 2.734, did not adopt that draconian standard, and is, for that reason, not a rule of unfettered discretion and, thus, not within the ambit of any ruling in Mothers for Peace.11 Thus under the holding of the Appeal Board in ALAB-918 cited supra n.8, 10 CFR $ 2.734 is equally as applicable in this setting as the " late-filed" contention 9 Union of Concerned Scientists v. HEg, 735 F.2d 1437 (D.C. Cir. 1984).
10 San Luis Obispo Mothers for PeAgg v. HHg, 751 F.2d 1287 (D.C. Cir. 1984).
11 10 CFR S 2.734 (a) (3); Statement of considerations l 51 Fed. Reg. 19539 (May 30, 1986).
1 i
.e rule. MAG having made no attempt to comply with the l
provisions of 10 CFR E 2.734, the Motion must fail.
l II. .THE BAIANCING OF THE "FIVE FACTORS" DOES NOT FAVOR ADNISSION OF THE PEOPCSED CONTENTION FOR LITIGATION.
As MAG himself acknowledges, the Motion must satisfy the l l
provisions of 10 CFR i 2.714 governing late-filed contentions.12 This has not been done. Assuming that there exists good cause for the late filing on the theory that the !
l contention could not have been filed before the exercise was j i
, held, and conceding that, as is almost always the case, the less weightyl3 second (protection of the novant's interests) )
and fourth (exten.t to which that interest is represented by )
existing parties) factors favor the Movants, the fact is that analysis of the third (assistance in development of a sound record) and f2tth (delay) factors reveals a balance which tips decidedly against allowance of the motion.
Commission " case law establishes both the importance of the third factor in the evaluation of late-filed contentions and the necessity of the moving party to demonstrate that it has special exoertise on the subjects which it seeks to 12 Public Service Comoany of New Hamoshire (Seabrook '
Station, Units 1 and 2), CLI-89-19, 30 NRC ,
Slip Op. at 4 n.5 (Sept. 15, 1989).
13 CREDonwealth Edison Comoany (Braidwood Nuclear Power Station, Units 1 and 2), CLI-86-8, 23 NRC 241, 245 (1986); South Carolina Electric and Gas Company (Virgil C. Summer Nuclear Station, Unit 1),
ALAB-642, 13 NRC 881, 895 (1981).
l
D P
I raise. [ Citation omitted.) The Appeal Board has saidt l
'When a petitioner addresses this criterion it should set out !
with Ls much particularity as possible the precise issues it f plans to cover, identify its prospective witnesses, and -
summarize their proposed testimony'."14 l In a seeming effort to comply with this third factor, MAG has list 9d the names of several investigators and I paralegal assistants from his office who will testify as fact witnesses as to certain evento that they claim 15 did not occur.16 We are further advised that this testimony, in ,
conjunction with certain exhibits attached to the Motion and :
other documents, "will demonstrate that the issues raised in i the contention are genuine."17 14 Commonwpalth Edison comoany (Braidwood Nuclear Power Station, Units 1 and 2), CLI-86-8, 23 NRC 241, 246 (1986), gitina with acoroval, Mississioni Power and Licht Co. (Grand Gulf Nuclear Station, Units 1 and 2) , ALAB-704, 16 NRC 1725, 1730 (1982) i (emphasis added). Accord, Epblic Service company ef_Few Hamoshire (Seabrook Station, Units 1 and 2),
ALAB-918, 29 NRC 473, 483-84 (1989).
15 We say " claim" because, while there is no doubt that the promised testimony as to the lack of activity at the dog track and the fire station, Motion at 6, would be accurate, the fact is that offsite monitoring teams were dispatched as part of ;
the exercise, as can be seen from the Exercise Report which is attached hereto as Appendix 1.
Appendix 1, Insoection Report 50-443/89-10 at 8-9.
We are at a loss to explain how six MAG Witnesses missed this.
16 Motion at 6-7.
17 Motion at 7. <
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! i To begin with, MAG is not applying the right standard to t
his analysis of the factor. The test is not whether his j evidence will show that there are genuine issues; the test is whether he will have substantive evidence which will contribute to the resolution of the issues. This he does not l t
have. The fact witnesses he identifies will testify to [
matters that could easily be stipulated and the documents speak for themselves. What MAG should be describing, and !
does not, is expert testimony on the issue of whether the scope of this exercise was so narrow that it would fail to reveal fundamental flaws that existed in the plan. He i
identifies no witness, testinony, or other evidence of this description. In short, the showing on factor three, the most important factor, is extremely sparse, and, indeed, is ;
totally lacking as to the controlling issue. l t
As to the fifth factors there is no doubt that ;
admission of this or any other exercise contention has major potential for causing delay. Indeed, MAG is candidly on i
record in this proceeding as admittedly fomenting delay for delay's sake in order to defeat the licensing of this plant.
Furthermore, the amount of delay need not be large to be ,
unacceptable in the Seabrook setting, the public has been !
treated to "nearly eight years of this licensing ,
proceeding;"18 enough is enought obviously the admission of the contention will broaden the issues. MAG's argument that i
18 CLI-89-18, supra, at 2.
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l its admission will not increase the issues which have to be resolved is a D2d seaultur. In an operating license j proceeding no issue has to be resolved unless it is brought {
into the proceeding. Granting the Motion would expand the l
scope of this proceeding which, as of this juncture, does not j include litigation of the onsite exercise. The fifth factor weighs heavily against admission. l The two most important factors weigh againct admission.
Thus, the balance favors denial of the Motion. :
i III. THE CONTENTION FAILS FOR LACK OF BASIS.
i i
A. Introduction - The Basis Argument as .
Made.
The assertion of basis made in support of the proffered contention is not a model of clarity. Nevertheless, i
Applicants understand the theory being advanced to be as ;
follows: An NRC IE Inspection Procedure No. 82301, which is attached as Exhibit 1 to Attachment "A" to the Motion, sets forth a statement, quoted at Page 1 of Attachment "A" to the Motion, that "the entire program must be evaluated in the ;
initial exercise prior to escalation of power beyon6 5%." In ,
addition, ancther sentence from the same Exhibit 1 is quoted to the effect that the exercise scenario should be reviewed ,
"to determine that there is reasonable assurance that all i major elements of the response as specified in 10 CFR 50, .
Appendix E, Part IV F will be tested . . . .
"19 After referencing a document, which MAG says is inapplicable to the situation at hand, other than for the purpose of referencing the relevant parts of NUREG-0654 which MAG claims must be demonstrated,20 MAG next goes on to make the point that a portion of the exercise scenario from the June 1988 exercise, which he attaches as Exhibit 3 to Attachment "A," shows that more objectives were demonstrated in that exercise with '
respect to the onsite plan than were demonstrated or attempted to be demonstrated in the recent exercise. He ascribes the lack of demonstration of these objectives to four enumerated matters which he believes existed and caused a failure to demonstrate the objectives his Exhibits 1 and 3 purportedly show were required to be demonstrated.21 In short, the argument, as we understand it, is that the Staff document referenced by MAG has definitively interpreted the applicable regulations to require that all " major portions" of the onsite plan be demonstrated in the recent exercise, and this has not been done because of the supposed failure to include certain matters in the scenario. While, 19 Motion, Attach. A at 2.
l 20 MAG references IE 82302 which he attaches as Exhibit 2 to Attachment "A" to his pleading.
I Hcwever, in Footnote 1 in Attachment "A," he makes clear his view that this document is not to be deemed the controlling document. This method of "short handing" the writing process is quite legitimate, we suppose, but it surely is confusing.
21 Motion, Attach. A at 3. i 9
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as shown infra, the document that MAG relies upon has been l i
superceded in light of the 1987 rule change, and therefore, his basis is nonextant for that reason,22 immediately below I we demonstrate that even assuming the governing document was the one attached,23 its own language does not admit of the {
interpretation MAG would give it.
I B. The Language of MAG's Attached Staff Document, Even if it Were ,
Controlling, Does Not Admit of the !
Interpretation that it Governs the Exercise of Concern Here.
As notud above, the key to MAG's entire argument is the ,
language he quotes at Page 1 of his Attachment "A" taken from his attached Exhibit 1. As he correctly quotas it, it makes f
that document applicable only to "the initial exercise." .
l However, the recent exercise was not the initial exercise of i the Seabrook onsite plan. The onsite plan was exercised not i only during the June 1988 exercise, but alst' on occasions l before that. The language does not purport to say that the !
" initial exercise" has to be the "within one year" exercise r under the new regulation. As the Commission itself has I 22 ERA 5 III. C, infra. ,
23 The attached document is a staff inspection procedure. It is, of course, not a definitive interpretation of the regulations and any ,
interpretation it purports to make is subject to challenge. E.g., Vermont Yankee Nuclear Power Coro., (Vermont Yankee Nuclear Power Station),
ALAB-179, 7 AEC 159, 174 n.27 (1974); Gulf States Utilities Co. (River Bend Station, Units 1 and 2),
ALAB-444, 6 NRC 760, 772 (1977). -
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i recognized, the Seabrook "on-site plan has been previously exercised and adjudicated.n24 In short, the exerciso in !
question was not the initial exercise and therefore the key i
piece of paper relied upon by MAG, on its face, has no :
applicability.
s C. The Document Upon Which MAG Relies t was Published in Conformity With the Regulation as it Head Prior to 1987 l and Has Been Recently Superceded. ;
As noted earlier, MAG also quoted, on Page 2 of his statement of basis, language from his attached document concerning the scope of the exercise scenario. Immediately l after the sentence he quotes from Page El-1 of his attached f i
l Exhibit 1 appears the followings l l
L "In addition, it must be determined that the exercise involves the required level of State and local involvement (small or
- large scale) as prescri l Appendix E, PartIV.F."ggdin10CFR50, What becomes clear is that the document attached to MAG's t
Motion was written at the time that the full participation i
exercise was the only pre-licensing exercise for on and off- t site plans. However, since the rule change in 1987, there i
exists the possibility or an exercise of the onsite plans ;
1 exclusively after the initial full participation exercise, i l
And, indeed, the docuntent which MAG attaches to his Motion, 24 Public Service Comoany of New Hamoshire (Seabrook -
Station, Units 1 and 2), CLI-89-19, 30 NRC ,, ,
Slip Op. at 4 (Sept. 15, 1989). 4 l 25 Motion, Attach. A at El El-2.
l l )
i l-1 i
=
i which was issued on July 1, 1983, has now been superceded by j a new Inspection Procedure 82301 which was issued on !
I August 21, 1989, a copy of which is attached hereto as i
Appendix 2. I Even a cursory review of Appendix 2 will show that the l critical language upon which MAG relies has now been removed from Inspection Procedure 82301. The document attached by i MAG having been superceded, it cannot any longer supply a f basis for a contention.26 Thus, the contention fails for want of a basis.
D. There is no Regulatory Basis for the l Contention Proffered. !
Prescinding from all of the foregoing, the fact remains that there is no regulatory basis for the contention as pleaded. The thrust of the contention is that the Applicants were required to, but did not, test all of the " major observable portions" of the on-site plan. It is stated in the contention that this requirement comes from 10 CFR App. E, i IV.F.1.
The language requiring the testing of " major observable portions" of plans comes from' Footnote 4 to 10 CFR 50, App. E l 5 IV.F.1. That footnote defines the term " full ,
I 26 Public Service Comnany of New Hampshire (Seabrook
! Station, Units 1 and 2), CLI-89-3, 29 NRC 234, 241 l (1989); Vermont Yankee Nuclear Power Corooration '
(Vermont Yankee Nuclear Power Station), 30 NRC ,
Slip op, at 33 (July 26, 1989); Georcia Power Co.
(Vogtle Electric Generating Plant, Units 1 and 2), ,
ALAB-872, 26 NRC 127, 136 (1987).
i !
- i l
i participation" as used in the phrase " full participation exercise." The exercise run on September 27, 1989, however, was not, by definition, a afull participation exercise." It !
l was an exercise run pursuant to the third and fourth j sentences of 10 CFR 50, App. E $ IV.F.1 which is the exercise to be run when, as, and if there has been a full l participation exercise run within two years of licensing, but l not within one year of licensing. Thus, the regulatory language which forms the underpinning of the contention as i
pleaded simply has no applicability to the September 1989 onsite exercise. This is yet another compelling reason for finding the statement of basis deficient.
E. The Activities which MAG Claims l Should Have Been Undertaken Are Not Necessary to Reveal Whether There is a Fundamental Flaw in the Plan.
The seminal case with respect to the necessary scope of ,
i an emergency exercise is the decision of the Appeal Board in Lona Island Lichtina Co. (Shoreham Nuclear Power Station, Unit 1) , ALAB-900, 28 NRC 275 (1988). Therein the Appeal l
l Board stated the standard by which the scope of an exercise l would be judged was: "that the exercise itself must be l
comprehensive enough to permit a meaningful test and evaluation of the emergency plan to ascertain if that plan is fundamentally flawed."27 Since that time, the Appeal Board >
has also held that if the flaw revealed is one which can be 27 ALAB-900, 28 NRC at 286 (emphasis in the original).
l 1 l
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1 readily corrected or can be corrected by supplemental training of personnel, it is not a fundamental flaw.28 we are unenlightened in MAG's filing as to how the failure to j 1
engage in the four activities enumerated on Page 3 of the j Statement of Basis precluded the ascertainment of any i possible fundamental flaw in the plan. This is a pleading ;
- failure which dooms the effort.
Prescinding from the pleading failure, analysis reveals I I
that MAG could not have made such a factual allegation in any l event.29 The first shortfall alleged by MAG is that the l exercise did not: ;
"1) advance beyond a declaration of site area emergency and, therefore, did not trigger sufficient offsite protective }
action decision making.u30 If the exercise had required more protective action decision- i making, the only problem that could have resulted would be l that someone responsible therefor may have made a decision I that was erroneous in retrospect as to the action to be taken. This is a personnel training matter, i 28 public Service Comoany of New Hamoshire (Seabrook Station, Units 1 and 2) , ALAB-918, 29 NRC 473, 485- i 86 (1989). Egg glig Lona Island Lichtina Co.
(Snoreham Nuclear Power Station, Unit 1), ALAB-903, 28 NRC 499, 506 (1988).
l 29 This is not surprising. The onsite plan has been l exercised several times previously. Presumably any ;
l " fundamental flaw" would long since have come to light. -
l l
30 Motion, Attach. A at 3.
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l The second shortfall alleged is that the exercise did i
not ;
il "2) involve a medical team from a~1occi f support services agency (the Seabrook i Fire Department pursuant to the Seabrook (
RERP) or an offsite medical treatment facility (Ex theSSRERP)"ggerHospitalaccordingto ,
Assuming this had been done, all that could have been i revealed would have been personnel weaknesses in performing their duties; again a matter of training. ,
r The third shortfall alleged is that the exercise did not: t i
"3) involve the dispatch of any field monitoring teams and monitoring and assessment activities;"32 ,
t In fact, this was done, AAn n. 15, gupra. But again, assuming it had not been done all that could have been ,
revealed would be personnel errors in carrying out monitoring activities, a matter overcome by training and, thus, not a fundamental flaw. l The final shortfall, according to MAG, was that the exercise did not: ,
"4) involve any onsite personnel monitoring and decontamination at the offsite locations planned for that purpose (the ;
Seabrook Dog Track and the ' Warehouse' on Route 107)."33 ,
31 yg, ;
32 Id.
33 Id. i
<>. l l
'Again, all that could have been revealed would be personnel I errors in carrying out the monitoring and decontamination j activities, a matter overcome by training and, thus, not a (
fundamental flaw. ;
IV. THE NOTION FAILS TO COMPLY WITH 10 C.F.R. 5 2.714(b)(2) AS AMENDED. l The Motion fails to address the requirements recently !
4 added to 10 C.F.R. I 2,714(b) fort ;
"(i) A brief explanation of the bases of the contention. l (ii) A concise statement of the alleged facts or expert opinion which support the contention and on which the petitioner intends to rely in proving the contention at -
the hearing, together with references to those specific '
sources and documents of which the petitioner is aware and on which'the petitioner intends to rely to establish those facts or expert opinion. i (iii) sufficient information (which may include information pursuant to paragraphs (b) (2) (1) and (ii) of :
this section) to show that a genuine dispute exists with i the applicant on a material issue of law or fact. This showing nuat include references to the specific portions !
of the application (including applicant's environmental report and safety report) that the petitioner disputes and the supporting reasons for nash dispute, or, if the ;
petitioner believes that the application fails to contain information on a relevant matter as required by ,
law, the identification of each failure add the l l supporting reasons for the petitioner's belief."34 -
r MAG undoubtedly would attempt to justify his failure to comply with 10 C.F.R. I 2.714(b) on the basis of the >
statement in the Statement of Basis which accompanied the 1
promulgation of the amendments to the Rules of Practice to the effect ther. the rules concerning contentions would not 34 54 Fed. Reg. 33180 (August 11, 1989) (emphasis added).
u
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( I apply to contentions filed in proceedings commenced prior to the effective date of the amendments.35 Prescinding from the [
l thorny issue of whether a regulation can be made effective {
but denied general applicability by a statement in the f Statement of Basis as opposed to language in an actual !
t regulation, MAG cannot take advantage of this statement. Ho l i
is estopped from doing so because of his assertion to the i I
commission just a few weeks earlier, in arguing that possible ;
litigative delay did not warrant exempting Applicants from being required to hold this Exercise, that the new requirements of 10 C.F.R. I 2.714(b) would apply to any j contentions filed concerning the Exercise.36 Having argued f to his advantage to the commission that these "recent rule :
I changes restricting the admissibility of contentions," id., :
do apply to contentions concerning this Exercise, MAG is estopped from now arguing to this Board that the rules do not apply.37 And, having admitted that the requirements apply, i
f 35 54 Fed. Reg. at 33179.
36 Resoonse of Mass. AG to Aeolicants' ADolication for AD_Exemotion from the Regulrement of 10 C.F.R. Part !
- 19. Anoendix E.Section IV.F.1 at 18 (August 21, 1989).
37 Illinois ex rel. Gordon v. Camobell, 329 U.S. 362, 369 (1946); Wilcox Dev. Co. v. First Interstate Bank of Orecon, 590 F.Supp. 445, 452-53 (D. Or. ,
1984), rev'd on other arounds, 815 F.2d 522 (1987);
but ang Note, The Doctrine of Preclusion Acainst Inconsistent Positions in Judicial Proceedings, 59 HARV. L. REV. 1132, 1136 (1946).
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MAG's failure even to address them is grounds for the denial
{
I of his motion out of hand.38 t
CONCIESION f The motion should be denied and the proffered contention l i
excluded.
Respectfully submitted, i i
,,sts, r f _"- ' m-Thomi~s'G . D5ifnan , J r.
~
George H. Lewald !
Jeffrey P. Trout ,
Jay Bradford Smith (
Geoffrey C. Cook William L. Parker Ropes & Gray One International Place -
Boston, MA 02110-2624 :
(617) 951-7000 counsel for Applicants ;
i b
t 38 Egg Memorandum and Order (Rulina on Massachusetts Attorney General's Exercise Contentions 8.C.1.
8.C.3. 18. and 21.C) at 12-13 (January 13, 1989),
and cases cited therein; gat also Georcia Power Company (Vogtle Electric Generating Flant, Units 1 and 2), LBP-86-41, 24 NRC 901, 927-28 (1986), 1 modified, ALAB-859, 25 NRC 23, aff'd, ALAB-872, 26 l NRC 127 (1987). ,
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Docket No. 50 443 <
l Public Service Company of New Hampshire !
ATTN: Mr. Edward A. Brown !
President and Chief Executive Officer )
P.O. Box 300 j Seabrook, New Hampshire 03874 i y
Gentlemen: I l
Subject:
Inspection Report No. 50 443/89 30 ;
A routinebysafety'E.
conducted Mr. Fox. Jr., of this office anc ether members of an NRC teami!
i on September 26 28, 1989, at your Seabrook Nuclear Power Station. Seabrook, New Hampshire. Discussions of our findings were hele by Mr. Fox with you and i other members of your staff at the conclusion of the inspection. ,
f i
Areas examined durinji the inspection are described in the NRC Region I -
Inspection Report wh'ch is enclosed. Within these areas, the inspection '
consisted of selective examination of procedures and representative records, !
interviews with personnel and observation of the emergency exercise by team .
members. 2 j
Within the scope of this inspection, no violations, deviations, or unresolved i
items were observed. Public Service Company's perforstnce during the exercisa demonstrated the ability to implement the Emergency Plan and the Emergency g i 1
Plan laplesenting Procedures in a panner that would provide adequate l protective measures for the health and safety of .tae public. ,
No reply to this letter is required. Your cooperation with us in this matter ,
is appreciated. l, sincerely, kkf s -
(
Ronald R. Bellamy, Chief ,
Facilities Radio 10lical Safety and :
Safeguards trancs :
Division of Radiation Safety and Safeguards l
Enclosure:
Region ! Inspection Report No. 50 443/89 10 4
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. . v voo6 y
-. . .. . - _ _ . - . . . _ . ~ . -.
OCT-86-1999 15877 FR31 NH Y4KEE E-N.44 TO Rc3 P.C3 1
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I OCT e 3 tggg Public Service Company ef 2 New Hampshire j cc w/encli l J. C. Duffett, President and Chief Executive officer, PSMH T. C. Feigenbaum, Chief Operating Officer and $r Vice President J. M. Peschelm, Regulatory Services Manager, NNY ;
Station Manager, NHY i D.
P. W.I. Moody, Agnes, Jr., Assistant $ecretary of Public Safety, Comonwealth of I Mass 6chusetts l POR)
Public Local Public Document Document Room (Room (LPOR) j Nuclear Safety Information Center (NSIC) 4 State of New Hampshire :
Connonwealth of Massachusetts i Seabrook Hearing Service List FEMA Region 1 :
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- OCT 86 *89 14812 NRC RI DRSS . PO4 i
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U. $. NUCLEAR REGULATORY COMMI$510N REGION 1 Report No. $0 441/a3 10 .
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Docket No. 19 .1 0
. License No. GP1.LH - Priority .. Category C Licensee: Public Service Co. of New Hamethire ,
P.O. Rom 130 ;
Manchester. New Hafnesh<re 01101 i
Facility Name: 1embrosk $tgig i i
inspection At: 1eabrook. New Wagghig;g j Inspection Conducted: Imptember 28 28, 1989 !
inspectors: bb v4 te[t [ f T f E. F. Fox, Jr., Fr. Emergency Preparedness Idete !
Specialist. EPS, FRS&SB, DRSS ;
C. Amato EPS, FR$&$8, DRSS i A. Cerne, $R1, Seabrook Nuclear Power Station !
R. Serbu, PEP 5, NRR ,,
W. L at us. Chief. EPS, FR$&SB, DR$$ ;
Approved by: "+r #P '
w.L. Aalg34, Chief. Emergency Preparechtss date SectTon, rRs&SB, DR55 ,
I i l Inanection Summarvt :.nnnection on tentgr 26-18. lete i l LRenert ho. 10 443/89 101 (
l Areas Insnected! Routine, announced emergency preparedness inspection and observation of the licensee's. partial. participation annual emergency i preparedness exercise conducted on September 27, 1969. The inspection was performed by a, team of five NRC Region ! and headquarters persont.e1.
l Resultat No violations, deviations or unresolved items were identified. Yhe c licensee's response actions for this exercise demonstrated the stility to
! implement the emergency plan in a manner whien would provide adequate i protective measures for the hetith and safety of the public.
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DLIAILS 1.0 Penent contmeted The following itcensee represer.tatives attended the exit meeting held on ,
September 28, 1989. l S. Suchwald, Quality Assuranct; Supervisor R. toyd, Jr., Performanet Services Manager i E. Brown, President '
A. Callendrello, Manager, Emergency Planning Licensing :
P. Casey, Senior Emergenty Planner E. Desmarais, Independent Review Team Manager i B. Drawbridge, Executive Director Nuclear Production ;
J. Ellis, Manager, Response and Implementation '
T. Feigenbaum, Chief Operating Officer and Sr Vice President T. Grew, Manager, Spec 141ty Training J. Grillo, Operations Manager T. Harpster, Director, Licensing Services J. MacDonald, Radiological Technical Specialist !
J. kartin, Manager, Community Relations D. McLain, Production Services Manager >
D. Moody, Station Manager l P. Richardson, Manager, Training N. Pillsbury, Director, Quality Programs P. Stroup, Director, Emergency Implementation and Response l W. Sturgeon, Nuclear Services Manager R. Sweeny, Bethesda licensing Office Manager D. Tailleart Emergency Preparedness Manager J. Tefft, Lead Engineer R. Winn, Director Corporate Comunications During the conduct of the inspectien, other lictiste emergency response personnel were interviewed and observed. ,
2.0 Emeroency Exercise The Seabrook Station partial participation exercise of the licersee's on site Esergency Plan was conducted on September 27, 1999, from 8:0D a.m. until 3:30 p.m. FEMA did not observe. There was limited off site participation of State of New Hampshire Incident Fleid Office (IFO) and the licensee's Off site l Response Organization (ORO) to test the interface with the licensee's on site emergency response personnel.
2.1 Pre-emercise Activities ,
The exercise objectives submitted to the NRC Regior I on June 30, 1989 were i reviewed and determined to adequately test the licensee's Emergency Plan. On July 27, 1989, the licensee submitted the complete scenario package for NRC review and evaluation. Region ! representatives had telephone conversations with the licensee's emergency preparedness staff to discuss the scope and content of the scenario. As a result, minor revisions were made to the .
scenario and suppcrting data provided by the licensee. As this was a partial-participa n exercise, it was not necessary to demonstrate off site
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f prottetive actions. It was determined that the setnario would suptort an adeo64te partial participation exercise of the licensee's Emergency Plan and -
jmplementing Procedures, The scenario involved a less of coolant accident which would result in declaration of a site Area Emergency and would test the :
licensee's on site emergency response facilities including the functions of '
dose assessment, protective action decision making, and tae interface with the 5 tate of New Hampshire officials and the ORO, which compensates for the lack
- of participation by the Comorwealth of Nassachusetts. Although a majer ,
release of radioactivity was ret included in the scenario, the existence of !
the potential for such a release would force the demonstration of the major areas of the licensee's emergency response orgar.itation. NRC otiservers attended a licensee briefing cr. September 27, 1989 and participated in the discussion of escrpency resporse actions expected during the scenario. It was agreed that contro lors would intercede in exercise activities to prevent I scenario deviations or disruption of ncrsal plar.t operations.
The exercise scenario included the following events:
f I -- Loss of both emettency diesel generators requiring declaration of an UNV5UAL EVENT;
- A leak in the reacter coolant system of greater than 53 gallons
( per minute from the Resistance Temperature Detector (RTO) manifold return line isolation valve requiring declaration of 43 ALERT; A swall break loss of coolant accident (LOCA) from the RTD ,
manifold requiring declaration of a $1TE AREA ENERGENCf. :
The above events caused the activation of the licensee's on site ew rgency ,
response facilities and demonstration of the interface with the ORD and the State of New Hampshire.
2.2 .ietivitten Obaarvg During the conduct of the licensee's exercise, NRC team members made detailed observations of the activation and augmentation of the emergency response organization, activation of energency response facilities, and actions of emergency restense personnel during the operation of the emergency response facilities. The following activities were observed: '
- 1. Detection, classification, and assessment of scenario events '
- 2. Direction and coordination of the emergency response I 3. Notification of licensee personnel and off site agencies; '
l 4. Comm'unications/information flow, and record keepingi l 5. Assessment and projection of radiological dose and consideration i
of protective actions; l 6. Provisions for in-plant radiation protection:
- 7. Performance of off site and in-plant radiological surveys;
- 8. Maintenance of site security and access controli
- 9. Performance of technical support, repair and corrective actions;
- 10. Assembly and accountability of personnel and
- 11. Provisions for comunicating information to the public. '
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3.0 clannification of Exertif e Findinas Emergency PrepareCness exercise findings are classified as follows:
traccise Strenoths ;
Exercise strengths are areas of the licensee's response that provide i strong positive indication of the ability to cope with abnomal plant l conditions and implement the emergency plan and procedures. ;
tvereite Weaknottet l (xercise weaknesses are areas of the licensee's response in which the performance was such that it could have precluded effective !
implementation of the emergency plan in the event of an actual emergency ,
in the area being observed. Existence of an exercise weakness does not .
of itself indicate that the overall response was inadequate to protect the health and safety of the public. ,
Areas for lanrovemarit An area for improvement is an area which did mot have a significant negative impact on the ability to implement tne emergency Olan and response was adequate; however it should be evaluated by tae licensee to ,
detemine if corrective action could improve performance.
4.0 trereine ehervat9tD1 The inspectors observed licensee response actions in the emergency .
response facilities as follows:
Control Itoca iThe licensee'simu143er was used) I Several exercise strengths were identified. ;
- 1. The shift crew demonstrated alertness and fast response to alares and indications. For example, the increased leakage from the reactor coolant system was ouickly identified and quantified based on et<reasiry pressuriger level before any alems were received wAch would aave brought it to the operators' attention.
- 2. The Shift Supervisor (55) completed correct preliminary classification of the UNUSUAL EVENT in 2 minutes and announced it as scon as the lost, of the second diesel generator was confirmed by tre auxiliary operate:' (total elapsed time of 4 minutes).
- 3. Notifications of the UNUSUAL EVENT were made to the states within '
3 minutes and the NR0 within 9 n.inutes of the classification of the event. Since the exercise involved the use of the simulator control roon rather than the actual control room, these times are gesed on when the operators simulated the use of the ' orange'
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i 5 j phone (used for notification of New Hampshire and Massachusetts) and the NRC tmergency Nottf tcation lystta phone in tre simulator ,
control room. These emergency phones are not capable of being used from the simulator. In an actual event, the calls are made
" 1 from ohones which are operable in the plant control room. l
- 4. The Shift Superviscr/ Shift Techneial Advisor ($$/$TA) conducted j frequent, irdependent critical safety function checks of the 1 plant. J
, 5. There was excellent comunication ameng the shift personnel. .
- 6. Correct recc.gnition of and adherence to Technical Specification Action Statteents wert demonstrated.
- 7. Routine operations and emergency procedure compliance were professional and precise.
- 8. Good communication was maintained with emerpency response i personnel outside the centrol room. An add tional licensed operator reported to the control roon after the declaration of the ALEP.T to set up and maintain dire:t on 1tne comunications with the lechnical Support Center (TSC) and Operations Support Center l
(0$C). This aided in establishing priorities for direction of y
repair and troubleshooting activities outside the control room.
! 1 One area fcr improvement was brought to the licen6ee's attontion:
The transfer of authority from the $hort Tem Emergency Director (STED) (Shift Supervisor in the Control Roos) to the Site ;
Emergency Director ($t0) in the Technical Support Center was not announced on the plant paging system. Although the $T00 and SCD i were both clearly aware that the transfer had occurred, announcement of that fact may be beneficial to other emergency response personnel.
Technical sunnert tantar several exercise strengths were identified.
- 1. Appropriate enginearing solutions were pursued to ccrrect or i mitigate casualties to equipment, including Use of both a fire truck and compressed gas cylinders on.
site to recharge the emergency diesel generatcr air bank; Use of the site specific Probabilistic Risk Assessment to identify probable locations of the teactor coolant system leakage and the subsequent small break LOCA.
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!. Additional support was sought from and use was made of Yankee Atenic Service Department to identify the location of the reactor .
coolant system leakage.
- 3. Comunications were effective and continuogs, t
4 Effective use was made of status bosrds which were updated every l fifteen minutes. Data relating to Regulatory Guide 1.57 accident -
variables were trended, including estrapolation of Refueling Water Storage Tank level and interpretation of the trend. Plots were !
cross correlated. i
- 5. Discussions were held regarding the potential need for protective l actions and at what point they woulf becomt necessary if ;
. conditions worsened.
Two areas for improvement were brought to the licensee's attention:
Within the Technical Support Center, two instances of telephone line noise occurred, causing some miner communications problems j during the exercise; loron concentratien curves should be reviewed to verify that they cover all reasonably expected conditiens.
Doeratient tunbort Centte 1
l Several exercise strengths were identified.
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! 1. Excellent consnand and control was demenstrated.
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- 2. Dispatch of repair teams was timely and proper. Approximately nine (g) teams were used in attordance with repair efforts determined by the TSC.
- 3. Information from the repair teams, including results of both containment air and reactor coolant samples obtained from the post Accident Sampling System (PAS $) were rapidly provided to decision makers,at the TSC and the Emergency Operations facility.
- 4. Excellent in plant radiation protecticn precautions were f instituted and maintained throughout the exercise.
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Emerenney 0cerations Facility (EOF)
Several exercise strengths were identified.
- 1. The EOF wat activated promptly and was operated effectively.
Actions by response personnel were timely and in accordance with procedures.
- 2. Coordination and comunication with other emergency response facilities including the TSC, ORD, and the New Hampshire IFO were frequent an:. Effective as were consnunications between the various .
divisions of the EOF emergency response staff.
- 3. Technical assessment was clearly in evidence throughout the j exercise. Any suspected inconsistencies between varicus pieces of 1 information were questioned and resolved.
4.. Emergney comunications (news releases) were effect.vely proptred, reviewed and approved.
- 5. Radiation Monitoring Teams were effectively staged, dispatched and
, directed.
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- 6. Dose assessment capability was promptly established using the backup Hewlett.Packard HP41 CV calculator after the scenario indicated failure of the METPAC systen primary, backup, and Yankee Atomic computer systems to force use of the HP41-CV system.
Several proposals were made which would have quickly restored the METPAC computers tc operation, however in order
- t. to test the backup, they were' prevented from being implemented by the exercise controllers. l h
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Several 'what if' projections were made for potential eyeits j l- with radioactive material teleases including steam generator l tube rupture, containment ventir.g, and containment failure. ;
Field samples were received and promptly counted in accordance with procedures.
Meteorology was kept current and forecast conditions !
' carefully evaluated. ' The effect of any potential wind shift on protective action considerations ,was considered. ,
- 7. Effective security wac maintained at the EOF. Persont.e1 accountability results were provided to both the EOF and TSC Managers in a timely manner.
l 8. Possible protective actions were discussed with the ORD and New I Hampshire IFO. These discussions were frequent and effective and I; included the determination of potentially affected areas and consideration of whether school children should be dismissed at
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the normal end of the school day or helc at school where they ,
y' could be more easily evacuated if conditions worsenee. Conditions considered included plant evolutions such as the switchover from the injection to the recirculation mode and the stability of j proje:ted weather conditions. ;
Field Monitorir.c Teams
- Several exercise strengths were identified. .
- 1. Field monitcring team members arrived at the EOF promptly and effectively prepared for dispatch.
The teams performed thorough menitoring kit inventory, instrument checks including source checks Jortable air sampler checks. radio checks, and vehicle esecks in accordance with their procedures.
Personnel were very knowledgentile of the procedures and demonstrated proficiency and a good understanding of their ,
respor,sibilities. ,
1 Good radiological practices were followed in the set up of !"
the vehicle bay used for the dispatch of the teams and receipt of samples. _
l Teams were thoroughly briefed on plant conditions and L expected radiological conditions prior to dispatch.'
H Team members received appropriate dosimetry prior to dispatch. .
- 2. The teams were dispatched promptly (within 50 minutes of arrival
- at the EOF).
- 3. Communications between the EOF and the field teams was excellent.
- 4. Sample coun1.ing equipment was set up promptly.
$. Sample control and analysis including surveys and the use of anti-cont'antpation clothing were effectively demonstrated.
- 6. A personnel monitoring and decontamination station was established in the vehicle bay using effective procedures for control of access and egress, installation of ficor coverings, use of survey equipment, and manning the control point.
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g Media Center /Jeint Telephone Information Centtr Several exercise strengths were identified.
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- 1. Activation, staffing, and command an$ control were effectively and efficiently accomplished. J
- 2. Inforestion was obtained through authorized officials, and .
t appropriately coordinated and reviewed prior to release to the '
public. '
- 3. Information provided to the public was clear, concise and >
accurate.
l l 4. Rumor control was effective. Media Center rumor control personnel L promptly sought verificaticn of rumors and provided the correct information in all cases.
- 5. Responses to questions posed by exerct5e controllers simulating press personnel tc media briefers were detailed and understandable.
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i overall Conclusions 1
L The NRC' team noted that the licensee's activation and augmentation of the -
L emergency organization, activation of the emergency response facilities, and use of the facilities were consistent with their emergency response plan and
- implementing procedures. No exercise weaknesses were identified.
The licensee denonstrated the ability to implement the emergency plan in a manner which would have provided adequate protection for the henith and safety of the public. i 5.0 Licensee Critinue and Exit Interview ,
l The licensee conducted an adequate self critique of the exercise. There were L no exercise weaknesses identified. Following the licensee's self critique, P the NRC team met with the licensee representatives listed in Section 1 of this l+ report to present exercise observations as detailed in this report.
At no time during this inspection did the inspectors provide any written information to the licensee.
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l' '.. NUCLEAR REGULATORY COMMISSION l s wAsnacros, o. c. nones l
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NRC INSPECTION MANUAL PRPR INSPECTION PROCEDURE C2301 '
EVALUATION OF EXERCISES FOR POWER REACTORS R PROGRAM APPLICABILITY: 2515 and 2525 82301-01 INSPECTION OBJECTIVES 01.01 To assess the adequacy of the licensee's emergency respense program.
the implementation of the emergency plan, the emergency implementing procedures, and the training program.
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, 82301-02 INSPECTION REQUIREMENTS 02.01' Evaluate the performance of the licensee's amergency response during !
an exercise. .
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- a. Verify that the emergency preparedness exercise meets the licensee's .
commitments and regulatory requirements,
- b. Observe the licensee during the exercise for the followir.g functiotial !
l areas and related activities: :
- 1. Control Room Assess the performance of the staff as it conducts the tasks listed below:
facility management and control analysis cf plant conditions and corrective actions detection and classification of emergency events protective action decisionmaking e notifications and communications implementation of protective actions dose assessment evaluation of post-accident sampling results
- 1) dispatch and coordination of monitoring teams
- 2. Technical Support Center (TSC) l Assess the performance of the staff as it conducts the tasks 1
listed below a) staffing and activation of the TSC b) facility management and control c accident assessment and classification "
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d)'doseassessment i
'F e) protective action decisionmaking l
L notifications and connunications 1 implementation of protective actions I assistance and support to control room t
evaluation of post accident sampling results l dispatch and ccordination of monitoring teams ,
- 3. I'nercency Operations Facility (EOF)
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Assess the perfomance of the staff as it conducts the tasks 1 listed belows.
(a) staffing and activation of the EOF '
I,b) facility management and control '
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, accident assessment and classification .
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, offsite dose assessment- ,
I protective action decisionmaking -
(I,f notifications and connunicatiens g implementation of protective actions (h interaction with offsite officials, NRC, and other e
organizations l *
- 4. Operational Support Center (OSC) ;
Assess t le performance of the staff as it conducts the tasks listed below:
- a) staffing and activation of the OSC b) facility management and control c) performance of support functions 5._ Cot. orate Connand Center (CCC)
Asssss the performance of the staff as _ it conducts the tasks i listed below:
(a) staffing and activation of the CCC (b) performance of support functions
- 6. Of_ftite Monitorino Assess tne perfomance of the staff as it conducts the tasks s listed below:
(a) activation and depicyment of the monitorin1 teams (b) surveys, satt.pling and analysis
- 7. Corrective Action / Rescue Teams Assess the perfomance of the staff as it con:!ucts the tasks L listed below:
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i a in plant repair acticns b rescue
- 8. Security / Accountability Assess tne perfomance of the staff as it conducts the tasks listed below:
(a) security (b) accountability O - ,
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i 9. Emergency News Center (Joint Information Center) !
g,- Assess the performance of the ~ staff as it conducts the tasks listed below: 1 v
(a) staffing, activation, and facility control '
L (b) processing and dissemination of information to the media -
- 10. Emeroency Medical Services Assess the performance of~the medical response team.
i -11. Post-Accident Samplino Team (PASS)
Assass the performance of the FA55 sample team. :
- 12. Critique '
Assess the licensee's critique. ,
82301-03 INSPECTION GUIDANCE 0*J 01 General Guidance. The general pr6ctices for a team inspection should be utilized in the planning and conduct of this inspection and the
.properation of the inspection report.
During the exercise. licensee performance in the control room, the TSC. OSC and the EOF should be observed and evaluated. However, consistent with Paragraph C. of Appendix 1 to inspection Manual Chapter 2500, the regions may adjust the extent of.
observation in each area as needed. .to concentrate on areas where past 4
licensee performance was , considered marginal or in need of observation.
The exercise is a training tool to prepare for an emergency. It is important to remember that there are three aspects to.a successful exercise. The first is the development of a technically acet/ rate and challenging scenario to test i the plans, procedures, equipment, and implementation of the exercise. The second part is the implementation of the plans, procedures, and equipment, The last aspect of the exercise is the critique following the exercise in
.which the licensee the scenario; makes e candid self evaluation of the exercise in terms of the ade cedurest the players' quacy of theand responsest emergency the effective equipment, use of the facilities, evaluations and pro-and the controllers.
The observers or the NRC evaluators should not interfere with the players or the controllers. The controllers also should not prompt, coach, or otherwise interfere with the performance of the players. NRC evaluators may query or seek clarifications or infomation from the controllers regarding the exer-cise and/or the scenario.
In assessing the licensve's performance, scehario-related problems should be noted in the inspection report and discussed in the a: tit meeting.
03.02 Specific Guidan_ce
- a. Inspyction Requirement 02.01a. requirument The for Emergency Treparedness exercises may bTe found under 10 CPR Part 50. Appendix E.
Part IV.F.I and 10 CFR $0.47(14).
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- b. Inspection' Reouirement 02.01b
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- 3. Control Room (a) Control room operators should be able to correctly interpret control room instrument displays. From these and other sources of available information, they should be able to e recognize that events are progressing abnormally, detemine plant status and develop. appropriate strategies to bring the plant to a ,
safe shutdown condition if necessary. !
Control room operators should be able to classify the emergency on the basis of plant conditions and confim, where possible, t the emer calculations or monitoring, gency classification by dose ,
(b) After recognizing and classifying the emergency, control f room operators should correctly implement the imediate actions of the emergency plan implementing procedures
.(EPIPs). The shift supervisor should coordinate and oversee the control room response, redirecting the response as necessary. Actions should be perfomed in acccrdance with ,
the applicable procedures and instructions. '
(c) Control room operators should be able to classify the '
L emergency using emergency action levels (EALs) and detemine protective actions for onsite and offsite personnel without
- waiting for e dose assessment. They should recomend I
protective actions on site and off site, on a timely bcsis, that are . consistent with those in the approved onsite :
emergency plan and the Ep!Ps. Guidance on protective '
L actier.s is provided in NWREG-0654.
(d) The licensee should consider, to the extent time Demits, the following items in promptly deciding uoan appropriate i offsite protective actions:
i (1) current plant status
- 2) current dose assessment and dose projection !
expected duration of re10ase i evacuation time estimates local sheltering efficiencies ,
' current meteorological parameters (wind speed, wind directions, and stability class) and projected weather ,
conditions (7) local geography ;
[.
(8) time of day l: !
H (e) For a Site Arca Emergency or a General Emergency, nonessen-L tial personnel should be evacuated from the site to the L
offsite locations (s) specified in the rmergency plan and i
I appropriate protective measures should be initiated for those personnel remaining on site (e.g., accountability, protective clothing, KI).
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(f) Onsite personnel .should be promptly following: int'ermed of the / -!
W
. i1) emergency conditions
- 2) emergency classifications d i
(({3) activation of protective the emergency organization and facilities actions
(( radioactivity release status
( any changes in these conditions t (g) Offsite officials, including NRC, c
should be promptly informed of the fo110 win 0: .
- 0) emergency conditions L2) emergency classifications ;
3)
L(4) activation of release radioactivity the emergency status organization and facility
- 5) potentially affected population .
- 6) projected population doses t
- 7) recomended protective actions
- 8) any changes'in these conditions A communications link should be caintained between the control room, the TSC, the OSC, and the NRC, if requested.
A qualified staff member. should be available to notify the licensee and Federal. State, and local authorities of the" !
emergency and to maintain communications 15 minutes after the emergency is declared, r
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. (h)' The control room should initiate onsite protective actions until the TSC.or the LOF is activated. For a General Emer-
, gency with imminent major releases projected, evacuation should be directed without monitoring or decontamination of the ensite nonessential staff. For. General Emergencies in which major releases are not imminent, evacuation should be
" initiated following monitoring and decontamination. The licensee should' be able to accomplish the initial account-r ability within 30 minutes of the order for the assembly of '
L all nonessential personnel and should be able to account for l
all remaining personnel continuously thereafter. Habit-ability of the control room and assembly areas should be '
assessed periodically, c
(1) Personnel should use approved procedures for dose assessment and should know how to use them. If a release is antici-
- pated or in progress, control room personnel should be able to correctly and rapidi) assess and integrate information from the reactor system's statut. and trends, source-term i
!e_. " assumptions, post-accident sampling system (PASS) samples, and meteorological information to define the magnitude and location of the onsite and offsite impact. These assess-o ments need not be as sophisticated or as accurate as dose J projections made by the TSC or the EOF but should be suffi.
ciently accurate for adequate onsite protective actions and offsite protective recommendations as necessary. If a release is under way, personnel should promptly initiate 1
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. stp ' u ' *E9 13:29 ECCHTEL GAITHERSEURG. 11D t P.7 onsite samplin and monitoring to confirm the composition of i'
' the releases i.e., iodine fraction) and to better oefine the scurce term and confirm projected doses. Dese assess-i ment should be performed in the TSC or the EOF once these facilities are activated.
(j) If appropriate, the control room may request th6t a prst- [
l accident containment air or primary water sample be obtained to confim the composition of any release (i.e., iodine 3 fraction). The results of the samples would be used to redefine or confirm the condition of the reactor, the >
emergency classification, the source term, and projected '
doses. Post accident sampling may be directed from the TSC after this facility has been activated. l r
(k) If a release is anticipated or in progress, the Etergency '
Director tray deploy teams to perform environmental sampling at appropriate locations to characterize the size, location, and intensity of the plume. The teams could be asked to take measurements of radiation levels, radiciodine or gross beta levels in the air, or to' collect samples of water, i vegetation and milk to determine the radioactivity concen -
trations in these samples. Onsite and offsite monitoring i may be directed from the TSC or the EOF after these '
facilities have been activated. .
(a) For Alerts, site Area Emergencies and General Emergencies, the TSC should be activ
! lowing functions within,ated andI hour about prepared after to theperform emergency the foi- is
- l. <leclared:
(1) Manage site activities.
(2) Provide technical support to reactor operations, t'
(3) Manage corporate emergency resources. (Monitoringand dose gencyprojections operationsare nomally) facility (EOFtransferred afteritisactivated.) to the emer-(4) Manage radiological effluent and environs monitoring and dose projections. (These functions are nomally e
transferred to the EOF after it is activated.)
(5) Provide fo11nw-up notification of the emergency to Federal, State, and local emergency response organiza-tions and make recommendations for public prctective actions.' (This function is normally transferred to r the EOF after it is activated.)
(6) Establish and maintain a primary communications link with the control room.
b
_h_ - - - -. - - - - - - - - - -
j
- - i SEP 14 'E9.13:40 BECHTEL GAITHER5 BURG. f1D
.. P.B-7.-
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(suidance of Supplernent on the staffing of the T5C can be found in Table 2
, I to NUREG-0737.
the TSC procedures. can be found in site entargency plans or implem /
i i
1 (b) Accident Assessment / Classification. Personnel utivating thET5C the following: should be able'to adequately and accurately perforri b (1) . Use EAlf, as appropriate, to classify the emergency.
(2)
Initially assess and continuously reassess reactor conditions, i w
(3)
Confirm the emergency. emergency classification or reclassify the (4) Using technical staff and infomation available from '
them er from other sources, maintain an overview of the reactor and plant conditions.
(5) l
' Use the results of post accident sampling er monitor-ing, as appropriate, to redefine reactor conditions and the emergency classification.
(6) Provide this infomation to proper room. EOF, NRC, offsite authorities, personnel (control corporate manage-ment,etc.).
L (c) Dose Assessment. If a should promptT/ initia, release is in~ progress, TSC personnel te onsite and offsite samplin ano monitoring to confim the composition of the release i.e.,
iodine fraction) and to define the source tem and projected doses.
If a release is anticipated or in progress, TSC personnel should correctly assess and integrate infomation from the reactor system's status end trends, radiological monitoring, source-term essumptions, and meteorological l infomation onsite and to define offsite the magnitude and location of the impact.
L TSC personnel should use the results of post > accident sampling and radiological L monitoring to redefine projected doses, as appropriate. ,
Approved procedures should be used for dose assessment and ;
personnel should know how to use them.
L (d) protective Action Decisionmakine. As appropriate. TSC personnel should use plant conditions to decide on protec-tive actions for onsite and offsite personnel without waiting for a dose assessment. TSC personnel should promptly recommend protective actions ensite and offsite consistent gency plan. with the criteria in the approved onsite emer-General Emergency Within 15 minutes of the classification of room personnel conditions. TSC personnel (or control if the TSC is not staffed and functional) should recommend appropriate protective actions to offsite officials. Guidance is provided in NUREG-0654 t
- v. f
~
[. SEP 14 #69 13141' BCCHTCL GAITHERSBURG,'HD p,9 ,
{
7.
The licensee should use the following parameters. to the exteht time permits, in deciding upon appropriate prctective j actions:
(
- 1) current plant status l
- 2) current dose assessment and dose projection
- expected duration of release i evacuation time estimates local sheltering efficiencies
- 6) curr6nt meteorological conditions (wind speed, wind i direction, and stability classification) and projected weather conditions (7) local geography (6) time of day (e) Notification. The licensee should promptly notify onsite personnel of the following i emergency conditions emergency classification activation of the emergency organization and facility ;
protective actiers :
radioactivity release status :
(6) any changes in these conditions ;
(f) implementation of Protective Actions. The licensee should" perform the following tasks (1) Confirm that the onsite prctective actions above have [
been implemented.
(2) Direct that all onsite personnel are accounted for.
(3) Confirm that all persennel are accounted for and, if .
l not accounted for, begin setrch and rescue fur missing +
personnel (initial accountability should be completed o
' within about 30 minutes of the declaration of the emergency). The licensee should also be able to account for cnsite personnel continuously thereafter.
l (4) Confirm and periodically assess the habitability of the L TSC. the 05C and assembly areas. Functions of the TSC should be transferred to habitable areas if necessary.
(5) Confinn that offsite authorities are aware of the licensee's recommendations for protective actions.
(6) Determine from the offsite authorities what, if any, protective actions are being taken.
(7) Inform management and NRC of these actions.
(g) The TSC cocrdinator (the person in charge) should oversee the analysis and corrective action response. Actions should be perfomed in accordance with approved procedures.
Perfonnence of other functions should not interfere with +
direction or determination of corrective action. Corrective .
actions should be implemented in an effective and timely manner. Potential offsite consequences of corrective ;
L -
actions should be considered and discussed with offsite l officials. The resources necessary to perform the required analyses should be available. Those performing the analyses l fasueDaterb/21/89 n an am a
a c.1
, y .U 3CP y 11 'C9 131 E BCCHTCL GAITHEREEURG, MD P.s0 and making decisions should be aware of important trends or changes of status. Job aids such as status boards should be used effectively and should not interfere with the perfer. h mance of corrective actions. Those in charge of ophrstions, maintenance, and radiation protection shculd consult fre. i quently and as necessary with each other and with offsite i members of licensee emergency response support organizations (e.g., censultants. corporate persennel, ana contractor i personnel) about corrective actions. j (h) If appropriate, the licensee should request that post-accident containment air or primary water samples be ;
obtained to confim the composition of any release (i.e., ;
iodine fraction) and use the results of the post accident sampling to redefine or confim the condition of the t reactor, the emergency classification, the source term, and projected doses, as appropriate. ,
(1) If a' release is anticipated or is in progress, the licensee should deploy an initial environmental sampling team (s) tn appropriate locations to intercept the team (s) regarding geographical movementthe e.g., p(lume, remain direct at ;
predesignated locations, go to the approximate center, a begin a traverse from location to locat. ion), direct the ,
teams regarding measurements or samples to be taken (e.g 5 ;
gross beta (B), air, water, vegetation, milk, TLDs), and use
' , results of monitoring to redefine the source tem and projected doses, as appropriate, r
(j) Approved plant procequres should be. curront, readily avail- >
able and used. TSC personnel should comunicate frecuently with each other and with other centers, especially with the centrol room. Congestion and noise levels should be kept to ,
a minimum. All communications systems should be functioning ,
properly. The EOF should be kept infomed of the status of '
the emergency and proper functions should be transferred to the EOF when that facility becomes operational; all concerned partie :uld be notified of .such a transfer.
Bound or other ', ent-type logs should be kept and all important data, caicuestions, notifications, and decisions should be recorded as they occur. Relief personnel should be properly end adequately briefed. Job aids such as status boards, should be accurate and should be kept up to date.
o
- 3. Emergency Operations Facility (EOF)
(a) For Site Area Emergencies and General Emergencies, the EOF should be activated and prepared to perfom the following ;
functions within about I hour after the emergency is 1 declared:
l (1) Manage emergency resources (before activation of the l EOF, this function may have been initiated at the TSC). l (2) Manage overall radiological effluent and environs l nonitoring and dose projections. (Before activation j of the EOF, this function may have been per'omed at l the TSC.)
O
_ s. -
SEP 14-889 13:43 BCCHTCL cAITHEREBURG.11D
> , P.11
-(3) Notify Federal. State ano local emergency response and make recommendations r
organizatinns for public prntective of action the emergency (before activation of t EOF, this function may have been initiated at the TSC.)
(4) Establish ano maintain a primary communications link
( -
I with the TSC. l J
(5) Comunicate with hRC Site Team. !
1 Guidance for staffing uf the EOF is specified in Table 2 of l Supplement 1 to NUREG-0737 and the licensee's staffing is listed in the site emergency plans or implementing prn-cedures. Persnnnel should not be prepositioned before 1 commencement of the exercise. The personnel performing key functions should be knowledgeable in their duties and respcosibilities. I L
(b) Offsite Dose Assessment. If a release is anticipated or is l
in progrrss, the licensee should correctly assess and -
integrate information from the reactor system's status and :
i.
trends, radiological monitoring, source-term assumptions, l and meteorological information to define the magnitude and
' location of the offsite impact. If a release is anticipated-or in progress, the licensee should depicy an initial environmental to intercept ~the sampling team (s) to appropriate locations plume, direct the team (s) regarding geographical movement (e.g., remain at a predesignated loca tion, go to the approximate center, begin a traverse from location to location), and direct the team s regarding i measurements or samples to be taken (e.g., g(ro)ss b, air, water, vegetation, milk, TCDs). The results of monitoring should be used to redefine the source term and projected
< loses appropriate. 1 The licensee should be able to promptly i L
and correctly project the direction.and maximum dose within L the plume EPZ and the distance to which the EPA's pAGs are ,
projected to be exceeded. Licenses staff responsible for !
protective action recommendations should also communicate !
i with the reactor systems' status personnel to comprehend plant status and trends and anticipate radiological con-sequences of the progression of events. The licensee should i obtain the necessary current and forecasted meteorological ;
information from onsita systems and appropriate offsite i sources Service).(e.g., supplomantal systems, the National Weather The licensee should assure that assessments are updated as tangible changes in plant status, release, or meteorological conditions become evident, are forecasted, or are refined from confirmatory -
measurements. ' Current t approved procedures should be used for dose assessment and personne1' should know how to use thw.. A backup dose assessment system should be available if the primary system fails. The staff should be trained in using the alternate system. .
(c) Protective Action Decisionmakino. As appropriate, the licensee should assess the status nf the reactor core, systems and containment to recomend offsite prctactive actions without waiting for a dose assessment. (Before activation of the E0F, this function may have been initiated
(@ '
~
';. SCP 14 '8913:43 BECHTCL GAITHEREBURG, MD P.12 at the TSC.) The licensee should promptly recomend nf' site prctective actions that are consistent with these in the approved onsite emergency plan, Guidance on protective nwasures can be found in Appendix ! of NUREG. 0654.
1 The licensee should consider, to the extent time pemits, ther following items in deciding upon appropriate protective \ -
actions:
l (1) current reactor and plant status -l (2 prognosis of accident i 3 expected duration of release 4 evacuation time estimates ,
- 0) local sheltering efficiencies
- 6) current and projected weather conditinns '
- 7) local geography
- 8) time of day (d) Netificati6n. The licensee should set up and maintain a '
comunications channel to' offsite authorities, including the NRC, and (if not already accomplished by TSC or control room personnel), promptly inform offsite officials, includ-ing NRC, of: 4 L, 1) emergency conditions
- 2) emergency classification radioactivity release status potentially affected population '
projected population doses l- 6) recorrr. ended protective actions
- 7) any enanges in these conditions (e) implementetion of Protective Actions. The . licensee should I confirm and periocically assess the habitability of the: EOF. <
If the EOF has to be evacuated, its functions should be '
transferred to alternate facilities without disruption of l l- offsite interaction, command and control, dose projections, '
or protective action decisionmaking. The licensee should L
confim that offsite authorities are aware of the licensee's I recommendations for protective actions. The licensee should determine from the offsite authorities what, if any, protec-tive actions are being takea and should inform management ,
and NRC of these actions. The licensee should always be aware or informed of the rtatus of offsite protective actions.
(f) Interaction with Offsite Officials. The offsite representa-tives at the EOF and the site should be briefed upon arrival and kept infomed of changing conditions without interfering with the onsite response. Offsite monitoring and sampling results should be coordinated with offsite officials.
(g) The plant procedures used should be current, readily available and approved. EOF personnel should connunicate frequently with each other and with other centers (especially with corporate headquarters and with offsite 0 m - _
i h ' lSEP iM 'E9 13844'BECHTEL'GAITHERSBURG, r1D' p,13 i
3-authorities). Congestion and noise levels should be kept tu a minimum. All Weary communicatict.5 systems should func.-
tion properly and if they do not, backup systems should be
'available. Proper functions should be transferred to the
~ E0F tier,clin.
. aAll timely manner when that facility becomes opern-concerned parties should be notified of such a transfer. Bound or other permanent type logs should be kept ano all important data, calculations, notifications, and-decisions should be recorded chronologically. Relief personnel should be properly and adequately briefed. The EOF should be properly equipped to perform its functions.
Job aids such as status boards, should be ' accurate and ;
should be kept up to date. At the request of personnel in the TSC, the control room, or elsewhere, outside resources t should be obtained in a timely manner,
- 4. Operational Surcort Center (OSC)
(a) The OSC should be quickly staffed, activated, and fully '
L factional. Operations at the OSC should be supervised by licensee officials predesignated in the emergency plan and ;
procedures. The licensee's personnel assigned to the OSC i should be identified in the Emergency Plan and/or the I
implementino. procedures. The manager-in-charge should be knowledgeable of his or her duties and responsibilities.
Reliable voice communication should be established with the "
control room, the-TSC, and the EOF. Habitability of the OSC t
should be confirmed and periodically assessed and, if need be, its functions should be transferred to a habitable area.
For conditions reouiring iodine protection, personnel should promptly implement apprbpriate iodine-protective ineasures (use appropriate respiratory protection or take K1h :
Guidance on staffing is presented in Table 2 of Supplement I to NUREG-0737. .
1 (b) Congestion and noise levels should be kept to a minimum.
All primary communications systems to the TSC, the EOF and i y the repair teams should function properl not, backup systems should be available. yRelief and personnel if they do should be properly and adequately briefed. Periodically, the OSC staff should be briefed on plant and radiological conditions. The OSC should be properly equipped to perform its functions. Teams dispatched from the OSC should be briefed, tracked, and debriefed upon return to the OSC.
! Communication with the teams should be maintained.
l Personnel who wt11 perform specific tasks as requested by management, the TSC, or the control room should be assigned i in a timely manner and should be given clear instructions. '
A pre-impleneentation planning meeting involving operations, maintenance. . and health physics should be held to reduce exposure by means of appropriate tool selections, routes of travel., development of temporary procedures, etc. (These actions it;ay be parformed in the TSC or the control room.)
Exposure and exposure limits of personnel should be considered in planning actions. (These actions may be performen in the TSC or the control room.)
, .p-OevN vytw y s _ -
Q p y ,e9 tir4"> sccHTEL GAITHERSEJRG, fD o[y ..
P.14 4*c,
- 6. CorporateCommandCenter(CCC]
(a) If- called for in the emergency plan or procedures, the Corporate Command Center should be activated and prepared to purform its functions in a timely manner. Reliable voice connunications should be established with the site (pri- h marily the EOF). Licensee officials should be predengnated 1
in the . emergency plan c r. related procedures to manage !
M operatichs.' The senior manager should be knowledgeable of i l' his ur her duties and responsibilities and able to perform his or her functions.
J (b) When calleo upon for assistance, the CCC should provide timely support in such areas as liaison, logistics, and- finance. Congestion andGovernment noise levels should be kept to a minimum. The CCC should be prnperly equipped to '
perform its functions.
- 6. Offsite Monitoring L
(a) Licensee staff capable of performing offsite surveys should be prepared to implement their functions in a timely manner.
Monitoring teams should be dispatched in a timely manner.
Personnel should not be prepositioned before commencernent of the exercise.
(b) Team members should be able to demonstrate proficient use of protective measurcs equipment such as respiratory protection. Teams should be able to quickly locate sampling and monitoring locations (for example, predetermined sample '
sites). Team members should exhibit in collecting, bagging,' and marking samples, proficiency and tr eading monitoring results in accordance with procedures (e.g., open i and closed G.M. window readings). Team members should keep
. track of their individual exposures. Teams should be adequately briefed on radiation conditiens, their mission, and plant conditions before they are dispatched and should be kept informed of changing conditions in the field.
Vehicles should be available and readily accessible to transport the teams and should be capable of functioning under adverse weather conditions. Calibrated instru-mentation and equipment should be available for monitoring and for taking samples. Instrumentation to detect radio-indine at levels as low as 10-7 mci /cc under field conditions should be available. Teams should be equipped with an adequate communications system (e.g., a radio that permits unimpeded transmission and reception of data and instructions over the entire plume emergency planning zone
( 8,p2 )) . Monitoring results should be promptly and correctly reported to the TSC and/or the EOF.
- 7. Corrective Action or Rescue Teams. Team actions should be initiated and performed promptly following the decision to conduct the operation. Betore entry, the team should consult and coordinate with the control rocm, and should be briefed on potential hazards. The team thould be provided with adequate protective equipment such as self-contained breathing apparatus 82301 O Issue Date: 08/21/89 .
, .. _ -. . . - - _. .~ . - . _ . .. _
EEP 14 'ES 13:46 BECHTEL GAITHERSBURG.'MD P.15'
- 3 .
j (SCRA) with sufficient stay times, ano monituring equipment with
' ' sufficient range (e.g., up to 1000 R/ hour). Team exposure, moni- <
~ tored constantly should not exceed guidelines or preestablished '
values. Connunication with the team should be maintained by the t I control room, the TSC, or the OSC. The team personnel should be qualified by training or experience to perform the specified job
, in a: high radiation environment, and they should be trained in
' the use of the appropriate protective equipment. Team personnel !
should be able to demonstrate proficiency in the use of pro-tective equipment, i
P. . Security and Accountability (a) Access control should be maintained at the site and should not interfere with the response to en emergency (e.g response of offsite assistance should not be hindered 5.,
Security practices or procedures should not irnpede move-ment and access of site operating and response personnel to plant areas during an emergency situation (e.g., computer-controlled doors to vital areas fail in the open position upon loss of electrical power, essential personnel have keys to locked doors or can easily obtain keys, anti-passback-features do not hinder reentry 1. Any practice or procedure i to allow easy access during emergencies must be compatible L
with the licensee's Physical Security and Contingency Pla~ns
! developed in accordance with 10 CFR Part 73 and 1C CFR 73..
- l. , Appendix.C. Access control should be maintained at the control' rocm, the OSC, the TSC, and the EOF, Security l personnel. exposure should be monitored and appropriate protective actions'shopid.be taken. ,
1 L (b) All onsite personnel should be accounted for and the names
' of missing individuals should be achieved within about 30 minutes of the declaration of a Site Area Emergency or a General Emergency. A search-and-rescue operation should be initiated promptly for missing people. All onsite personnel >
should be continuously accounted for during the emergency y response.
l
- 9. Emergency News Center (Joint Information Center)
(a) Information should be disseminated to the media / press in an accurate and timely manner. News releases should be properly coordinated with the NRC and other offsite officials. Media personrel should be prohibited from interfering with the emergency response. Corrected or supplemental information should be promptly released in the event of error o'r misin-formation in news stories (e.g., rumor control), Informa- >
tion given to the public should be prepared to the technical e '
level that the public can understand. News should be updated periodically whether or not the status has changed.
(b) Adecuate numbers of telephones should be available for nrass i
use. Personnel giving the briefings should be technically qualified and able tc answer media questions accurately and quickly, p
l
. . . 9 .... .
n...._ aasv saa -
S L *' ., -
( 10. {prcency Medical Services l g
r i j (a) Preparation. and Implemeentation of First Aid, Mecical Trans-
' portation, and Hospital Assistance. For a life threatening p i injury, first aid should be given and victims transported i
l before decontamination. Generally, the victim shnuld be l, decontaninated before first aid and hospital care are given.
Personnel, vehicles, ano equipment postibly contaminated l
should be controlito. Hospital personnel should be briefed P_
and trained ir radiation protection and contamination s
control.
m (b) Communications should be maintained between the emergency '
O vehicle and the hospital. All transmissions to the hospital from the emergency vehicle should be preceded by an an-nouncement such as "This is a drill."- A qualified radio-inpical control technician should accompany the injured person to the hospital. Hospital personnel should be adequately briefed by the radiological control technician on the extent of the injury and on contamination levels.
- 11. Post-Accident Samolino Team,. When the licensee conducts post-accident analysis of the primary coolant and containment atmosphere, appropriate exposure limits for the in-plant team -
operations should be maintained. The team should be qualified !
, and capable to take and analyze coolant and
- containingnt !
atmosphere samples under emergency cenditions. The team shculd l
be able to proficiently implement the post-accident sampling 4 procedure, wear, or simulate the wearing of. the appropriate pro-
' tactive' equipment (e.g., SCBA), and follow the appropriate l
radiation protection procedures. Appropriate tools should be used, and samples should be properly transported. Samples should L be -
analyzed using the appropriate precautions to prevent personnel exposure and gentamination of the lab. Samples should be analyzed for the following: noble gases, iodine, cesium, i
nonvolatile isotopes hydrogen, chlorides, and bor9n. The results from these ana, lyses should be available in the TSC within i I
about 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> of taking the samples. i
- 12. Crit mi u . At the end of the exercise each facility should hold i a crit 1gue with the contrellers and pl,ayers while the details are !
fresh. This' preliminary critique should be followed by a formal i
' critique that evaluates the overall performance of the exercise i and the interaction of faci 31ty representatives and players with one another. During the critique, the evaluators should provide an unbiased and candid evaluation of the exercise, identifying the areas of steength as well as weakness and areas needing improvement.
Corrective actions should be defined and scheduled.
Q _ - - - - -
- ,cpj4'99'1348 BcCHTEL GAITHERSBURG, MD P.17 .
- i
. , 82301-04. RESOURCES
- 1
he estimated
-pelow: .
direct onsite time to complete this inspection is previded Inspection Tyoe Staff Hours Per Site ;
Regional Team leader 28 Resident Inspector 1' .
Headquarters Observer
- 14 '
Thus for planning purposes, the total estimated direct onsite inspection time s .to complete this inspection is 54 hours6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br />.
t cThe inspection effert expended by headquarters observers is separate from
' regional budget allocations. Because they are available to observe only one-half of the exercises conducted, an overall average of their time was '
estimated..
L l l , 82301-05 -REFERENCES
, ANSI /ANS 3.1-1981 " Selection. Qualification, and Training cf Persnnnel fcr L Huclear Power Plants" (supersedes ANSI N18.1-1977-77).
L EPA-520/175-001. " Manual of Protective Action Guides and Protective Actions .,
for Nuclear. Incidents," Revision 1 June 1980.
n0 REG-0396, " Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in '
Support-of Light-Water Nuclear Power Plants." December 1978.
L NUREG-0654, " Criteria for Preparation erd Evaluation of Radiolocical Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," Revision 1. November 1980. !
I i
NUREG-0696, " Functional Criteria for Emergency Response Facilities," February l 1901. l h0 REG-0731, " Guidelines for Utility Management Structure and Technical Resources," September 1980.
NUREG-0737, " Clarification of TMI Ac'sion Plan Requirements " Nove ser 1980; !
Supplement 1- (Generic Letter 82-33). December 17, 1982.
' l Regulatory Guide 1.97, "Instrumenta' tion for Light-Water. Cooled Nuclear Power ;
' Plants To ' Assess Plant and Environs Conditions During and Following an l
' Accident," Revision 3, November 1980.
Regulatory Guide 1.101, Revision ?, " Emergency Planning and Preparedness for Nuclear Power Reacters." October 1981. .
END O
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UWr C 19 DCT 17 P1 :49 CERTIFICATE OF SERVICE p ,
j I, Thomas G. Dignan,oneoftheattorneysforINNAplic'a$ds p
herein, hereby certify that on October 11, 1989, I made service !
of the within document by depositing copies thereof with Federal l Express, prepaid, for delivery to (or,.where indicated, by I' depositing in the United States mail, first class postage paid, addressed to):
Administrative Judge Ivan W. Smith Adjudicatory File Chairman, Atomic Safety and Atomic Safety and Licensing Licensing Board Board Panel Docket (2 copies) ;
U.S. Nuclear Regulatory U.S. Nuclear Regulatory !
Commission- Commission 'l East West Towers Building East West Towers Building l 4350 East West Highway 4350 East West Highway ,
Bethesda, MD 20814 Bethesda, MD 20814 Administrative Judge Richard F. Cole Robert R. Pierce, Esquire I Atomic Safety and Licensing Board Atomic Safety and Licensing }
U.S. Nuclear Regulatory Commission Board East West Towers Building U.S. Nuclear Regulatory-'
4350 East West Highway Commission ;
Bethesda, MD 20814 East West Towers Building 4350 East West Highway I
Bethesda, MD 20814 Administrative-Judge Kenneth A. Mitzi A. Young, Esquire i McCollom Edwin J. Reis, Esquire- '!
1107 West Knapp Street Office of the General Counsel Stillwater, OK 74075 U.S. Nuclear Regulatory ;
Commission One White Flint North, 15th F1. ,
11555 Rockville Pike !
Rockville, MD 20852 ,
John P. Arnold, Esquire Diane Curran, Esquire l' Attorney General Andrea C. Ferster, Esquire George Dana Bisbee, Esquire Harmon, Curran & Tousley i Assistant Attorney General Suite 430 Office.of the Attorney General 2001 S Street, N.W.
25 Capitol Street Washington, DC 20009 Concord, NH 03301-6397
- Atomic Safety and Licensing Robert A. Backus, Esquire Appeal Board 116 Lowell Street U.S. Nuclear Regulatory P. O. Box 516 Commission Manchester, NH 03105 j Washington, DC 20555
D
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Philip Ahrens, Esquire Mr. J. .P. Nadeau Assistant Attorney General Selectmen's Office Department of the Attorney 10 Central Road General Rye, NH 03870 L
Augusta,.ME 04333.
Paul McEachern, Esquire John Traficonte, Esquire ]
Shaines & McEachern Assistant Attorney General i 25 Maplewood Avenue Department of the Attorney P.O. Box 360 General Portsmouth, NH 03801 One Ashburton Place, 19th Fl.
Boston, MA 02108 Chairman Mr. Calvin A. Canney Board of Selectmen City Manager 95 Amesbury Road City Hall Kensington, NH 03833 126 Daniel Street Portsmouth, NH 03801
- Senator.Gordon J. Humphrey R. Scott Hill-Whilton, Esquire U.S. Senate Lagoulis, Hill-Whilton &
Washington, DC 20510 Rotondi (Attn: Tom Burack) 79 State Street Newburyport, MA 01950 !
- Senator Gordon J. Humphrey Barbara J. Saint Andre, Esquire i One Eagle Square, Suite 507 Kopelman and Paige, P.C. !
Concord, NH 03301 77 Franklin Street (Attn: Herb Boynton) Boston, MA 02110 Mr. Thomas F. Powers, III Mr. William S. Lord Town Manager Board of Selectmen i Town of Exeter Town Hall - Friend Street I 10 Front Street Amesbury, MA 01913 ,
Exeter, NH 03833 l H. Joseph Flynn, Esquire Judith H. Mizner, Esquire Office of General Counsel 79 State Street, 2nd Floor Federal Emergency Management Newburyport, MA 01950 Agency ,
500 C Street, S.W. <
Washington, DC 20472 i Gary W. Holmes, Esquire Richard A. Hampe, Esquire Holmes & Ells Hampe and McNicholas 47 Winnacunnet Road 35 Pleasant Street Hampton, NH 03842 Concord, NH 03301 t
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r Mr. Richard R. Do'novan
Federal Regione.1 Center [
4 130 228th Street, S.W. t
'Bothell, Washington 98021-9796
. l Ashod N. Amirlan, Esquire :
145 South Main Street i P.O. Box 38- <
. Bradford, MA 01835
-[
Thomfs 6. 'DpyfrtfT1, r Jr.
(*= Ordinary U.S. First Class Mail) ,
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