ML19327B698
| ML19327B698 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/29/1989 |
| From: | Kantor F Office of Nuclear Reactor Regulation, NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | |
| Shared Package | |
| ML19327B695 | List: |
| References | |
| OL, NUDOCS 8911060345 | |
| Download: ML19327B698 (5) | |
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'89 OCT 30 A9:53 UNITED STATES OF AMERICA i
NUCLEAR REGULATORY COM4!SSION g,
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD N,
In the Matter of
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PUBLIC SERVICE COMPANY OF Docket Nos. 50-443 OL NEW HAMPSHIRE, et al 50-444 OL (SeabrookStation, (Offsite Emergency Planning)
Units 1 and 2)
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AFFIDAVIT UF FALK KANTUR, REGARDING INTERVENORS' SECOND MOTION TO ADMIT CONTENTIONS ON ONSITE EXERCISE I
I, talk Kantor, being duly sworn, state as tollows:
1.
I am employed by the United States Nuclear Regulatory Comission as i
l Section Chief Emergency Preparedness Branch. Office of Nuclear Reactor Regulation. A copy of my professional qualifications was attached to my previous affidavit.
I have read the Intervenors' 2nd motion and my conclusions l
are set forth below.
2.
Intervenors contend that the September 27, 1989 exercise was so abbreviated in its scope that major portions of the Seabrook Station Radiological Emergency Plan (SSREP, the onsite plan) were not demonstrated 6s l
1 required by the regulations.
The Intervenors state that the exercise did not include demonstrations or evaluations of primary procedures, persons, l
organization.c. facilities, or equipment essential to implement the plan.
Further, the exercise did not test the adequacy of timing and content of implementing procedures and methods, did not test comunications networks or l
8911060345 091027 ADOCK050g3 PDR o
s' the public notification system, and did not ensure that emergency organization i
personnel are competent or familiar with their duties.
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3.
As indicated in the previous NRC filing, the regulatory requirements l
to test the major observable portions of the emergency plans refers to the full-participation exercise conducted within two years of full power licensing and not to the exercise of the onsite emergency plan within one year before i
i issuance of a full-power license.
The regulations do not set forth specific requirements for the scope of an onsite exercise. However, the NRC staff has formulated guidance in NRC Inspection Manual, Inspection Procedure (IP) 82302, for delineating the scope of an exercise. The NRC review of the exercise objectives and scenario and the NRC evaluation of the exercise as documented in the NRC Inspection Report No. 50-443/89-10 indicates that the exercise resulted in a demonstration of the major elements of the Applicants' onsite plan. The exercise +ested the primary emergency plan implementing procedures, the activati w and response of the Seabrook emergency response organization (ERO),
the activation of the principal emergency response facilities (the technical support center, operational support center, emergency operations facility, and the media center), and the equipment essential to implement the plan.
The i
exercise tested the adequacy of the timing and content of the emergency plan implementing procedures and methods, tested the communications between the onsite emergency response facilities and with the offsite response l
l organizatfons, and provided a valuable training opportunity for the ERO.
4 Intervenors allege that the exercise failed to require or include a j
disonstration by onsite personnel of an actual shift change or a demonstration of the capa'u111'.y to provide staffing for continuous (24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) operations for a protracted period or for second shift staffing.
The Seabrook Station emergency re?ponse organization (ERO), which implements the onsite emergency plan, was l
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established in 1985. The ERO consists of over 500 members drawn from onshift personnel, other Station personnel, corporate personnel, and Yankee Nuclear f
Services Division personnel. There are a minimum of three personnel qualified and assigned to each key EMU position.
The ERO has been involved in training ano drills in an operational mode since October 1986, and the ERO has partic1-pated in three exercises of the onsite plan which were observed by the NRC in addition to the September 27, 1989 exercise. While the average emergency i
preparedness experience level of the members of the ERO is over two and I
one-half years and at least one person currently assigned to a key ERO position participated in the June 1988 tull participation exercise, one of the primary purposes in conducting the September 27, 1989 exercise was to allow for further training of the ERO staff. This was accomplished.
There is no requirement i
that a shitt change be demonstrated during each onsite exercise in order to verify the response capability of an organization. The Applicants' capability to perform a shift change under simulated emergency conditions was demonstrated in the June 1988 full-participation exercise.
See NRC Inspection Report No.
50-443/88-09.
The Seabrook ERO satisfactorily demonstrated its ability to implement the onsite emergency plan in an adequate er.anner in the September 27, 1989 exercise, as documented in the NRC inspection report. The ERO staffing of at least three qualified and trained members to each ERO position assures that the Applicants would be capable of providing staffing for continuous (24-hour) operations for an extended period of time, b.
Intervenors allege that the scope of the exercise did not include a demonstration of the capability for early notification and instruction to the l
public within the plume exposure emergency planning zone (EPZ), and did not test the public notification system.
In addition, the Intervenors state that the Applicants failed to demonstrate mobilization or deployment of their l
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vehicular alert and notification system (VANS).
The demonstration of the Applicants' capability to alert and notify the public is clearly an activity i
that requires the involvement of offsite response organizations and, hence, is i
t not appropriate for an exercise of the onsite plans. The NRC and the Federal Emergency Management Agency (FEMA) have reviewed and evaluated the Seabrook l
alert and notification system.
FEMA has reported that the Seabrook alert and f
notification design is in accordance with the guidance criteria, FEMA-REP-10,
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" Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants."
(Findings and Detenninations for the Seabrook Nuclear Power Station, FEMA, December 1988, at 16, 33.) FEMA found that the State of New Hampshire and the ORO demonstrated the ability to provide early notification, develop public instruction, deliver the public instruction to the notification system, f
l-and simulate the activation of the alert system in the June 28-29, 1988 i
exercise.1/ (Id. at 16, 33.) FEMA concluded that when the alert and notification system for the New Hampshire portion of the EPZ and the VANS for the Massachusetts portion of the EPZ are installed and operable FEMA will find the Seabrook alert and notification system adequate.
The NRC staff has also concluded that there is reasonable assurance that the VANS design satisfies the requirements of 10 CFR 50 and the guidance criteria of NUREG-0654/FLMA-REP-1.
i (Hearing May 3,1989, tt ir 344 Kantor testimony) The Licensing Board l
concluded that the VANS met the requirements of the Conuission's regulations 1/-
FEMA has indicated that its evaluation of an alert and notification system is not an exercise objective and that system adequacy is evaluated in accordance with NUREG-0654/ FEMA-REP-1 and FEMA-REP-10. This evaluation of system adequacy is based on the results of testing over a 12-month period.
Confirmation of system reliability based on records that are required to show a 90 percent performance factor, on average, over an extended period is more rigorous than dependence upon a single demonstration of siren activation during an exercise.
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and 9uidance.
(LBP-89-17 June 23, 1989) The NRC will require that the Seabrook alert and notification system be installed and operational prior to the plant receiving full power authorization.
6.
I conclude that the September 27, 1989 exercise of the Seabrook onsite plan was of sufficient scope to test the adequacy of the Applicants' emergency f
response espability and was in conformance with 10 CFR 50.47(b)(14) and 10 CFR 50, Appendix E.Section IV.F.1.
The additional information filed by the Intervenors in their second motion to admit contentions on the exercise does j
not raise a significant safety issue.
The foregoing is true and correct to the best of my knowledge and belief.
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Falk Kantor Subscribed and sworn to before me this F M'v day of October, 1989 I
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.<tthlC Notary Public My Commission expires: 7 No f
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