ML19354D528
| ML19354D528 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 11/08/1989 |
| From: | NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | |
| Shared Package | |
| ML19354D527 | List: |
| References | |
| OL, NUDOCS 8911160081 | |
| Download: ML19354D528 (3) | |
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UNITED STATES OF Ar. ERICA L
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD v
i in th'e Matter of
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Docket Hos.
50-443 OL PUBLIC SERVICE COMPANY OF 50-444 01.
NEW HAMPSHIRE, et d.
Offsite Energency Pianning (Seabrook Station, Units.1 and 2)
NRC STAFF STATEMENT OF FACTS IN DISPU1E ll l
L 1~.
Intervenors' Fact 1 states the regulatory requirement for a an onsite emergency planning exercise, but fails to ste.te that Appendix E, 5 IV.F.1, distingishes between a "f ull participation" sna "onsite" exercise.
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Fox Affidavit at 5 4.
2.
Intervenors' Fact 2 is true but is not material to the profferreo i
contenticos.
3.
Intervenors' Fact 3 is true. Fox Affidavit at 1 6.
4.
Intervenors' Fact 4 is correct.
5..
Intervenors' Fact 5 is only partially true and is not material.
The scope of the Septenber 27, 1989 exercise did not require an actua' shift
- change, hawever,. the capability to oemonstrate a continuous 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> eniergency response was demonstrated.
Fox Affidavit at 1 8.
A shift change is not major part of an onsite emergency plan and staffing may be s
demonstrated separately. Lo.
6.
Intervenors' Fact 6 is correct in that the onsite exercise did not
.incluce. a demonstration of the public notification system for the Massachusetts EP2, however, this is not material since public notification
.8911160081 891108 PDR ADOCK 05000443-PDR O'
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system would require state participation for its activation.
Kantor Affid6vit at i 2.
7.
Intervenors' Fact 7 correctly states that the ensite exercise oid not include a demonstration that the aaministrative and physical means, including a siren system, have beer, established for alerting and providing pronipt ' instruction to the public within the Massachusetts EPZ
- However, this is not material since such activity is not requireo in an onsite exercise and relates to offsite planning.
Kantor Affidavit at i 3.
8.
Intervenors Fact 8 correctiy states thr.t there was no demonstration of the Applicants' VANS system for the Massachusetts EPZ, however, this is not n.aterial since it relates to off site planning and preparedness and is not required to be p!rt of an onsite exercise.
Kantor Affidavit at i 4.
9.
Irtervenors' Fact 9 is incorrect in that the VANS system was testeo curing. the 1988 exercise.
Such testing is not material since it is not required in an annual onsite exercise ano the Staff will determine that the system is installed and operational prior to full power licensing.
Kantor Affidavit at 1 5.
10.
Intervenors' Fact 10 corrr ctly states that the exercise did not progress beyono ceclaration of a Site Area Emergency (SAE) and include a siraulated release of radioactivity, however, this is not niaterial since an onsite eurcise need not progress beyond a SAE in order to test onsite eniergency response capability. Kantor Affidavit at 16.
11.
The hhc staff disputes Ir.tervenors' Fact 11.
The scope of the onsite exercise requireo and included a demonstration by Applicants' onsite emergency response personnel of their capability to actually foriaulate and communicate Protective Action Reccmmendations (FAR's) to of f site officials i.nd adjust PARS based upon changed meteorological arc plant conditions.
Such activities were observed ard evaluated by the NRC Staff.
Fox Afficavit at $5 9-11.
- 12. Intervenors' f act 12 is correct, however, it is not material since onsite exercises need not include participation by ) nedical team from~ a local support services agency as those activities involving oitsite autt.erities can be tested separately and are assessed annually, Kantor Affidavit at 5 7.
- 13. Intervenors' Fact 13 is correct, however, it is not naterial since an onsite exercise neec not include participation by an oftsite mecical
. treatment f ac111ty. M.at1/.
14.
Intervenor=' Fact 14 is not correct.
The onsite exercise did require arc incluoe demonstration of field ronitoring ano plume tracking.
Fox Affidavit at. 15 12-13.
15.
Intervenors' Fact 15 is correct that such activities were not demonstrated at the Dog Track and Warehouse, but it is not material since 1
monitoring was demenstrated a ), the EOF cnd such activities are routine.
Fox Atticavit at t.1 14-15.
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