ML19327B699
| ML19327B699 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/27/1989 |
| From: | Fox E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | |
| Shared Package | |
| ML19327B695 | List: |
| References | |
| OL, NUDOCS 8911060354 | |
| Download: ML19327B699 (12) | |
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4 UNITED STATES OF AMERICA
.O 0:130 A9'53 NUCLEAR REGULATORY C012:!SS10t; i
BEFORE THE ATOMIC 3AFETY AND LICENSING BOARD In the Matter of Docket Nos. 50-443 OL PUBLIC SERVICE COMPANY OF
)
50-444 OL NEW HAMPSHIRE, it,41,.
Emergency Planning (Seabrook Station, Units 1 and 2)
)
AFFIDAVIT OF EDWIN F. FOX, JR.
REGARPING A00!TIONAL BASES AND CONTENTION I, Edwin F. Fox, Jr being duly sworn, state as follows:
1.
I am employed by the United States Nuclear Regulatory Comission as 6 Str.ier Er..ergency Preparedness Specialist Emergency Preparedness Section, Facilities Radiation Safety and Safeguardt Branch, Division of RadiationSafetyandSafeguards,RegionI,V.h.huclearRegulatory Commission at 475 Allendale Road, King of Prussia, Pa. A copy of my professional qualiff cations is already on recora in this proceeding following Tr. 24627. My responsibilities during the September 28, 1989 onsite exercise are set forth in my October 17, 1989 affidavit at 11 2-6.
I have read the Interver. ors' 2nd Motion and my conclusions are set forth below.
2.
It is part of the intervenors' argument for contention JI-Onsite EX-1 and their new contention, JI-Onsite EX-2, that "an onsite exercise, such as that conducted on September 27 must be broad enough in scope so that the major portions of the onsite emergency response capabilities can be evaluated." As stated in paragraphs 6 and 8 of my October 17, 1989 affidavit (" Fox Affidavit"), the scope of the Seabrook exercise conducted 9911060354 091027
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. j l' f on September 27 provided for the testing of the major portions of the onsite emergency response capabilities. The NRC Staff has provided t
guidance for detemining the adequacy ot exercise objectives and scenarios l
l and hence the scope for all exerciset in NRC Inspection Manual Inspection Procedure 82302("IP82302"). The NRC review of the objectives and scenario for the September 1989 Seabrook onsite exercise was conducted in l
i accordance with IP 82302. The review detemined that the exercise l
i objectives and scenario would provide an adequate test of the Seabrook l
t StationRadiologicalEmergencyPlan(SSREP).
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l 3.
Intervenors' state in support of contention JI-Onsite Ex-1 that l
l "the scenario failed to meet exercise objectives or regulatory require-f ments since the exercise design did not advance beyond a declaration of f
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site area emergency and, therefore, did not trigger sufficient offsite l
protective action decisionmaking." Intervenors further allege that the j
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NRC inspection report (Report No. 50-443/89-10) indicates that no protective action recommendations (PARS) based upon dose assessment or l
other factors were actually prepared or implemented. As previously stated j
in Fox Affidavit at t 8 there is no need for the exercise to progress to the general emergency classification, a classification requiring the l
1ssuance of a PpR. An SAE classification indicates in accordance with NUREG-0654, Appendix 1,page1-12,that"[a]nyreleases[arejnotexpected to exceed EPA Protective Action Guideline exposure levels except near site f
boundary." One of the purposes of the SAE classification is "to provide i
consultation with offsite authorities." NURtG-0654, Appendix 1 at 1-12.
The September 27, 1989 exercise scenario involved a loss-of-coolant acci: lent which would result in declaration of a site area emergency and f
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3-i would test the Applicants' on-site emergency response facilities including the functions of dose assessment, protective action decisionmaking, and the interface with the State of New Hampshire officials and the Offsite Response Organization (ORO) 1/ As documented in the inspection report, the NRC observed various response activities including the assessment and projection of radiological dose consideration of protective actions.
4.
Consistent with the guidance in IP 8?301, dose assessment capability was promptly established in the emergency operations facility l
(EOF), and possible protective actions were discussed with the State of New Hampshire and the ORD. 2/ The NRC staff noted that these discussions were frequent cod effective and included the detennination of potentially affected areas and consideration of specific protective actions for school I
I children.
5.
PAR's should not be based solely on tiose assessment but should i
initially rely primarily on information concerning plant conditions. As other reliable information is obtained, the PAR's are confirmed and
- efined. Other information includes, projected or actual dose assessments, meteorological conditions (wind speed, direction, stability class), weather (rain, snow), day of the week, season of the year, time of l
day, etc. During the onsite exercise, the NRC observed the Recovery E
1/
The ORO is the New Hampshire Yankee organization responsible for
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implementing the Seabrook Plan for Massachusetts Consnunities.
l 2/
The September 21, 1989 exercise was a partial participation exercise involving the participation of representatives of the State of New L
Hampshire and the OR0. Such offsite participation is not a requirement for an exercise of toe onsite plans, however, the participation of these organizations allows for expanded " play" l.
especially in the PAR development and decisionmaking activity.
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J Manager at the EOF discussing all of these and other factors, the need for protective action recommendations and those protective actions already implemented. The factors were discussed with the Staff at the EOF, other onsite response centers (Technical Support Center, Control Room) ind the representatives of the State of New Hampshire and the ORO. This exercise 1
objective was adequately demonstrated.
6.
ihe Applicants tested their protective action decisionmaking capability through their evaluation of potential protective actions based on dose projections and plant conditions which were fully discussed with the offsite response organizations participating in the exercise. Based on the scenario and consistent with their plans and procedures at the SAE, they determined that because ro releases occurred and due to the late September weather, there was no need for a beach closing PAR or to issue protective action recommendation (FARs) for the public. Therefore, it was not necessary to issue any PARS to the public. As indicated in'the previous staff filing, onsite exercises not held in conjunction with offsite exercises (i.e., the so-called off-year exercises) are not required to proceed to a general emergency condition, the type of condi-tion associated with severe core damage and significant releases of radioactive materals.
Kantor Affidavit at 112; see NRC Information Notice No. 87-54. While no releases occurred and no PARS were actually issued in the September 27, 1989 exercise, the Applicants did engage in the decisionmaking process involved in determining the necessity for PARS.
This decisionmaking process, which included discussions with representa-tives of the offsite organizations, is an acceptable means for testing a licensee's capability to develop appropriate PARS.
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7.
Intervenors also allege "the scenario... did not involve the
-dispatch of any field monitoring teams and monitoring and assessment activities... no monitoring procedures or activities were tested even r
by mini scenario, land] only sampling procedures were demonstrated."
There is no requircrcrt ti n fie'.d i..ohitoring teams be dispatched to conduct monitoring and assessment activities during each onsite exercise.
NRC guidance IP 82302, provides that field monitoring is one of the elements of the energency plan that should be included in an exercise over a 5-year period rather than each year.
IP82302at03.01.b.2.(m)&(n).
The NRC reported that offsite radiological surveys were performed and that the field monitoring teams engdged in typical monitoring activities.
l l
Field monitoring teams were' observed in the EOF preparing their equipment and receiving briefiregs on plant conditions and expected radiological conditions prior to dispatch. The NRC Staff observed that comunications between the EOF and the field teams were excellent.
By monitoring the communications between the EOF and the field teams, the NRC staff determined that the field monitoring teams were engaged in those tasks typically assigned to such teams; i.e., taking direct measurements (plume tracking) and obtaining environmental samples in the area expected to be affected by a release from the plant. The field monitoring results were used to verify that no radiation was being released from the plant. Field monitoring teams are drilled in the performance of their assigned emergency response functions on an annual basis by the Applicants as part of their emergency plan drill program.
See ESREP at 12-1.
The conduct of these drills has been verfied by the NRC. See NRC Inipection Report No.
60-443/89-02.
Persons who become members of onsite field monitoring teams
.. p.
have a health physics background and receive training for and perform monitoring and assessment on a routine, day-to-day, basis at the
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Applicants' facility. Monitoring equipment and techniques used in the field are the same as those used day-to-day.
- 8.
Intervenors state that the exercise
" failed in that it did not include demonstrations or evaluations of primary procedures, persons, organizations, facilities, or equipment essential to implement the plan. The
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exercises did not test the adequacy of timing and content of implementing procedures and methods, did not test communi-cations networks or the public notification system, and did not ensure'that emergency organization personnel are competent or familiar with their duties."
In order for the Applicants to meet the objectives approved by the NRC and the elements for yearly exercises'in IP 82302, Applicants should:
(1) activate their facilities in accordance with their plan and proco-dures; (2) staff these facilitie,. with individuals who have been previouslyfoundtobequalifiedandcompeten$duringNRCinspections using NRC Inspection Manual, Inspection Procedure 82/01 ("IP 82701);
(3) use equipment determined to be adequate in previous inspections such as an Emergency Preparedness Implementation Appraisal or an inpection(s) using 10 SE701; and (4) use their plan and procedures to carry out functions prescribed for the facility or position in mitigating the consequences of the hypothetical accident. The plan and its implementing procedures have been reviewed and found adequate by the NRC Staff.
Revisions are reviewed to assure that these revisions have not degraded the effectiveness of the plan and procedures.
9.
During the inspection of the September 27, 1989 Seabrook exercise, NRC inspectors at various emergency response facilities observed and evaluated exercise activities with knowledge and understanding of
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7-these and other factors as the accident scenario progressed.
Staff Report at 1-9.
A part of the inspection involved thn observation and evaluation of notification and cosununication networks with not only the offsite organizations, but in and among all emergency reponse facilities. Also, as stated above, these items were reviewed as part of the core inspection program in accordance with IP 82701. The NRC Staff also observed and evaluated these onsite networks during the September 27, 1989 exercise and documented its findings in the Staff Report. During the completion of the
- IP 82701 inspection, the NRC inspection of training included a review of
' training records and effectiveness by performing walk-through examinations to verify that the requisite training for positions in the emergency response organization had been cortpleted on an annual basis.
Information regarding the pcsition, training and competence are then correlated with the names of the personnel designated to fill"these positions.
l 10.
Intervenors also state that "[t]he scope... failed to include a demonstration of onsite personnel of an actual shift change or a l
demonstration of the c6p6bility to provide staffing for continuous (24 -
l hour) operations for a protracted period or for second shift staffing."
o 1'
j As indicated in paragraph 9, above, the Applicants' capability for 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> staffing is evaluated when conducting the routine core inspection program at Seabrook Station using IP 82701. Consequently, there is no need to demonstrate this during each annual exercise.
The important aspect is l-24-hour coverage, not the ability of one person to brief his or her relief l
on status prior to turning over the activity.
Therefore, this capability need not be demonstrated during an exercise but rather can be separately 1'
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evaluated when conducting the routine' ccre inspection program when reviewing changes to the emergency respcnse organization.
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11.
Intervenors also state that "the scope... failed to require or include a demonstration of the capability for early notification and clear instruction to the populace within the plume exposure EPZ." As stated in NUREG-0654, Appendix 3 (at 3-1), "Means for Providing Prompt Alerting Notification of Response Organization and The Population "
"NRC and FEMA recognize.that the responsibility for activating the prompt notification system called for in this section is l
properly the responsibility of state and local government.
NRC l
and FEMA also recognize that the responsibility for demon-strating that such a system is in place rests with the facility licensee."
(Emphasis added.)
Since activating the Seabrook alert ano notification system is the responsibility of the state and local governments and the September 1989 Seabrook exercise was not a " full participation" exercise, this aspect did not have to be tested. Also, other testing is perfonned throughout the year, such as a silent test (every two weeks), a growl or equipment test (quarterly or when preventive maintenance is performed) and a complete cycle test (at least annually and as required for fonnal evaluation).
.12.
The information relied on by Intervenors does not show a g
deticiency in scope of the onsite exercise and thus does not raise a significant safety issue.
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i the foregoing is true and co rect to the best of N,' knowledge and belief.
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subscribee and sworn to before -
me tfiis E th~ day of October 1989 t
- Notary Pub 11c.
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UNITED STATES OF AMERICA L
NUCLEAR REGULATORY COMMISSION
'89 DCT 30 A9:53 BEFORE THE ATOMIC SAFELY AND LICENSING BOARD in the Matter of
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Docket Nos. 50-443 OLML" PUBLIC SERVICE COMPANY OF
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50-444 OL NEW HAMPSHIRE. g M.
Offsite Emergency Planning (Seabrook Station, Units 1 and 2)
CERTIFICATE OF SERVICE 1
I hereby certify that copies of "NRC STAFF RESPONSE TO INTEEVENORS' SECOND MOTION TO ADMIT CONTENTIONS ON THE SEPTEMBER 27, 1989 EMERGENCY PLAN h
EXERCISE" in' the above captioned proceeding have been served on the following by deposit in the United Ststes mail, first class or, as indicated by an asterisk, by deposit in the Nuclear Regulatory Connission's internal mail system, as-indicated by double asterisks, by Express Mail, this 27th day of October 1989:
L Ivan W. Smith, Chairman (2)*
Philip Ahrens, Esq.
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Administrative Judge Assistant Attorney General i
Atorpic Safety and Licensing Board Office of the Attorney General j
U.S." Nuclear Regulatory Commission State. House Station Washington, DC 20555 Augusta. ME 04333 i
Richard F. Cole
- John Iraficente, Esq.**
Administrative Judge Assistant Attornit:y Otrmi Atomic Safety and Licensing Board Office of the Attorney General U.S. Nuclear Regulatory Connission One Ashburton Place,19th Floor Washington, DC 20555 Boston, MA 02108 Kenneth A. McCollom**
Geoffrey Huntington, Esq.**
Administrative Judge Assistant Attorney General 1107 West Knapp Street Office of the Attorriey General Stillwater, OK 74705 25 Capitol Street Concord, NH 03301 Thomas G. Dignan, Jr., Esq.**
Robert K. Gad, III, Esq.
Diane Curran, Esq.**
Ropes & Gray Hannon, Curran & Tousley One International Place 2001 S Street, NW Boston, MA 02110-2624 Suite 430 Washington, DC 20009
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- (1 H.: J. Flynn, Esq.
Judith H. Mizner, Esq.
Assistant General Counsel 79 State Street
. Federal Emergercy Management Agency Newburyport, MA 01950 500 C Street, S.W.
Washir.gton, DC.20472 Robert Carrigg, Chaiman Board of Selectmen Paul McLachern. Esq'**
Town Office
$haines & McEachern Atlantic Avenue A
25 Maplewood Avenue North Hampton, NH 03862 P.O. Box 360 Portsmouth, NH 03801 William S. Lord.
Board of Selectmen Sandra Gavutis, Chairman Town Hall - Friend Street l Board of Selectmen Amesbury, MA 01913 RFD-#1, Box 1154 Kensington, NH 03827 Mrs. Anne E. Goodean, Chairn.nn j
Board of Selectmen Calvin A. Canney 13-15 Newmarket Road City Hall Durham,.NH 03824 126 Daniel Street b
Portsmouth, NH 03801 Hon. Gordon J. Humphrey United States Senate i
R. Scott Hill-Whilton, Esq.
531 Hart Senate Office Building L
Washington, DC 20b10 Lagoulis, Clark, Hill-Whilton l
& McGuire-l' 79 State Street Richard R. Donovan l
Newburyport, MA 01950 Federal. Emergency Management 1
Agency i
Allen Lampert Federal Regional Center
' Civil Defense Director 130 228th Street, S.W.
Town of Brentwood Pothell, Washington 98021-9796 20 Franklin Exeter, NH 03833 Peter J. Matthews, Mayor City Hall William Armstrong Newburyport, MA 01950 Civil Defense Director Town of Exeter Michael Santosuosso, Chairman 10 Front Street Board of Selectmen Exeter, NH 03833 South Hampton, NH 03827 Gary W. Holmes, Esq.
Ashod N. Amirian, Esq.
Holmes & Ellis Town Counsel for Merrimac 47 Winnacunnet Road 145 South Main Street Hampton, NH 03842 P.O. Box 38 Bradford, MA 01835 Barbara J. Saint Andre. Esq.
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Kopelman and Paige, P.C.
Robert A. Backus, Esq.**
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. 77 Franklin Street Backus, Meyer & Solomon Boston, MA 02110 116 Lowell Street Manchester, NH 03106
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Ms. Suzanne Breiseth J. P. Nadeau Board of Selectmen Board of Selectmen Town of Hampton Falls 10 Central Street Drinkwater Road Rye, NH 03870 Hampton Falls, NH 03844 Atomic Safety and Licensing Robert R. Pierce, Esq.*
Board Panel (1)*
Atomic Safety and Licensing U.S. Nuclear Regulatory Commission
' Board Panel-Washington, DC 20555 U.S. Nuclear Regulatory Comission Washington, DC 20555 Office of the Secretary (2)*
U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, DC 20555 Appeal Panel (6)*
Attn:
Docketing and Service Section U.S. Nuclear Regulatory Commission Washington, DC 20555
=_"
Elaine I. Chan Counsel for NRC Staff
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