ML19354D530
| ML19354D530 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 11/07/1989 |
| From: | Kantor F Office of Nuclear Reactor Regulation, NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | |
| Shared Package | |
| ML19354D527 | List: |
| References | |
| OL, NUDOCS 8911160089 | |
| Download: ML19354D530 (6) | |
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OhllED STATES OF AMERICA I;UCLEAR REGULATORY C0FNISS10N BEFORE THE AT0hlC SAFETY AND LICENSING BOARD 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, (Offsito Emergency Planning)
Units 1 and 2)
AFFIDAVIT OF FALK KANTOR REGARDING INTERVENORS' MOTION FOR SUMNARY DISPOSITION 1, Falk Kantor, being duly sworn, state as f ollows:
1.
I am employed by the United States huclear Regulatory Commission as a Section Chief in the Emergency Prepareoness Branch, Office of Nuclear Reactor Regulation. A copy of my professional quali11 cations was attached to my affidavit fileo on October 16, 1989.
I have read the Intervenors' Motion for Summary Disposition and statement of material facts appended thereto end my conclusions concerning particular facts (which are indicated in parenthesis) are set forth below.
- 2. - (Fact 6) It is true that the scope of the September 27, 1989 onsite exercise did not include a demonstration of the public notification systen for the Massachusetts EPZ, however, such a demonstration is not required or appropriote 1or an onsite exercise. The public alert and notification system for the Messachusetts portion of the plume exposure EPZ is part of the Seabrook Plan f or Massachusetts Lopu.unications (SPMC) and would not be expected to be tested in an exercise of the ensite plan.
In accordance with the FEMA /NRC 8911160089 9933cg
{DR ADOCK 05000443 PDR
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1 Memorandum of bnderstanding (50 FR 154C5), FEMA evaluates the "offsite" portion of exercises while the NRC evaluates the "onsite" portion of exercices. The public notification system 1s part of the offsite emergency plan and is thus observed by FEMA during full participation exercises.1 The public notification system for the Massac M etts EPZ is part of the SPMC and was testeo curing the Seabrook 1988 full participation exercise. FEMA fnund that the New Hampshire Yankee Offsite Response Organization (NHY ORO), the organization responsible for implen,enting the SPMC, demonstrated the ability to develop public instruction, deliver the public instruction to the notificetion system, and simulate the activation of the alert system in the exercise.
(Finoings and Determinations for the Seabrook Nuclear Power Station FEMA, Decenber 19P8, at 34.) The public notification system was not tested during the 1969 onsite exercise since it is not part of the onsite plan. The Staff has observed ano evaluated a number of onsite exercises and activation of the 1
1 The demonstration of the public notification system ourir:g full participation exercises does not necessarily include the ectual sounding l
of the sirens. Demonstration of the ability to alert and notify the public within the 10-mile EPZ within 15 minutes of a decision by I
appropriate offs 1te officials is accomplished in accordance with the l
guidance of FEMA Guidence Memorandum (GM) AN-1, dateo April 21}1987,and FEMA-REP-10, dated November 1985.
GM AN-1 states (on page 1-2 that "the l
'15-minute capability' is confirmed through the obscrvation of actual demonstrations or simulations of this capability (during offsiteemphasisadded) GM i
radiological emergency ireparedness exercise."
further states on page 1.5 that "[i]t is acceptable to simulate the activation of alert and no ification systems during exercises. However, I
even though the system activaten is being simulated, the 15-minute capability can still be confirmed."
It adds that "the observer shculd see the preparation of the instructional message, coordination with partici-pating jurisdictions, communication with the broadcast station and l
completion of the authentication process." FEMA-REP-10, on page N-2, Acceptance Criteria, states that "a satisfactory exercise of an alert i
decision implementing chain can occur up to the point of actually activation of the aler t and notification system (altnough activation shuulo be simulatec as realistically as possible)." FEMA's evaluation of the reliability.of public notification systems is based on the results i
01 testing over a 12-month period rather than upon a single demonstration l
of siren activation during cn exercise.
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4 public alert ano notification system was, in general, not performed du*ing the conduct cf those exercises. The public notification system, an integral part of the offsite plan, is activated at the direction of offsite officials.
Therefore, public alert and notification testing may be properly excluded f rom an onsite exercise since i IV.F.1 specifically provides that onsite exercises "need not have State or local government participation."
3.
(Fact 7) Intervenors are correct that the scope of the September 27, 1989 onsite exercise did not include a demonstration that the administrative and pnysical means, including the siren system, have been established for alerting and providing prompt instruction to the public within the Massachucetts EPZ, however, such a cemonstration is not material to onsite exercises. The public notification system is part of offsite planning and preparedness and, as indicated in 2 above, its cemonstration is not required for an exercise of the onsite plan. While the siren system component of the public notification system for the Massachaetts EPZ is under the control of the Applicants, its activation in an emergency requires authorization from the Commonwealth of Massachusetts. The statt has observed and evaluated numerous onsite exercises and demonstration of the public notification system including activation of the sirens is usually not incluceo in these exercises because the public notification system is part of the offsite plen.
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(Fact 8) It is true that the scope of the September 27, 1989 onsite exercise aid not include a demonstration of the Applicants' vehituiar alert and noti 11 cation system (VANS) for the Massachusetts EPZ, however, this is not material to an onsite exercise. The VANS system is part of offsite planning and preparedness and as indicated in paragraph 2 above, its demonstration is not required for an exercise of the onsite plan. The NRC and FEMA have reviewed eno evaluated the VANS system.
FEMA has reported that the Seabrook alert and
4 notificction system design, incluoing the VANS, meets the design requirements l
of FEMA-REP-10, " Guide for the Evaluation of Alert and hotification Systems for Nuclear Power Plants", November 1985.
(Findings and Determinations for the Seabrook Nuclear Power Station, FEMA, December 1988, at 33.) FEMA found that the NHY ORD oemonstrated the ability to develop public instruction, deliver the public instruction to the not1fication system, and simulate the activation of the alert sy> tem in the June 1988 full participation exercise.
(Id. at 34.)
FEMA stated that when the VANS for the Massachusetts portion of the EPZ is instelled and operable, FEMA will find the alert and notification system adequate.
(1d.at34.) The NRC staff has alsc concluded that there is reasor.able assurance that the VANS design satisfies the requirements of 10 CFR 50 and the guidance criteria of NUREG-0654/ FEMA-REP-1.
(Testimony of Falk Kantor Regarding Basis A.5 of Masschusetts Attorney General's Amended Alert hotification System Contention, if Tr 344) Further, the Staff found that i
the Applicants h6ve demonstrated that the aoministrative and physical means have been establishec for alerting and providing prompt instructions to the l.
public within the Massachusetts portion of the EPZ.
(1d.at10) The t.icensing l
Boarc concluded that the VANS met the requirements of the Commission's regula-l tions and guidance.
(LBP-89-17, June 23, 1989 at 31) The NRC will require verfication that the Seabrook public alert and notification system including 1
the VAh5 is installed and opert.tional prior to full power issuance.
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(Fact 9) It is not true that the Applicants' VANS system has never been field tested in on exercise.
In any event, as indicated in paragraph 2 I-above, such testing is not material to or required for an onsite exercise. A u
demonstration of the VANS concept that involveo a limited number of vehicles did occur as part of the June 1988 iull participation exercise.
(SeeSeabrook Exercise Report, FEMA, September 1, 1988, at 201.) As noted in paragraph 4, 1
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5 FEMA found that the NHY ORO demonstrated the ability to develop public instruction, deliver the public instruction to the notification system, and j
sinulate the activation of the alert system in the June 1988 exercitie. The NRC q
will require verification that the Seabrook alert and notification system is i
installed and operational prior to full power issuance.
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(Fact 10) It is true that the exercise aid not include a simuleted major release of radinactivity end that it did not advance beyond a declaration of Site Area Emergency. However, as indicated in previous Staff filings, an onsite exercise need not incluce a major release nor advance beyono a Site Area Emergency to 6 neral Emergency.
IIRC Infort. ion Notice No. 87-54 dated October 23, 1987, which is accressed to all holders of operating licenses or construction permits, states thet:
"While it may be appropriate f or biennial offsite exercises to proceed to a General Emergency oeclaration, exercises other than biennial offsite exercises (of f-year exercises) are not required to proceed to severe core damage.
Such exercises can provide an opportunity for more realistic emergency response training and evaluation of licensee staff.
For example, betore severe core damage would be expected to occur, the operating staff may be given the opportunity to diagnose and attempt to cctrect the problem through an interactive scenario.
In addition, some I
exercise scenarios may be designed with initiating events at the Alert or l
Site Art.a Emergency classification.
Since actual events may go directly l
to these higher level classifications without sequencing through each l
emergency class, advance oppor tunity to activate response f acilities may l
not occur. The flexibility within the requirements allows for the development of other realistic scenarios which, in turn, can improve emergency response capability."
l Thus, onsite exercises need not pre:eed to a ik.neral Emergency nor have l '
simulated severe core damage with the attendant major release of radioactivity.
The NRC staff has observed several onsite emergency plan exercises which have only rea.hed the Site Area Emer gency level. These exercises have been acceptable for meeting onsite emergency preparedness cbjectives.
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(Facts 12 and 13) It is true that the September 27, 1989 exercise cio not include participation by a medical team from a local support services agency nor participation by an offsite medical treatment facility. The guidance in NUREG-0654/ FEMA-REP-1, Rev.1 (H.2.C., p. 72) states that a medical emergency drill must be conducted annually and that offsite portions of the medical drill iyr be performed as part of the required annual exercise (emphasis acdeo). Thus, inclusion of the medical drill in an exercise is optional, in part, because the medical crill can be ettectively conducteo separate from an exercise. The medical drills may be observed by the NRC if done in support of the onsite plan or by FEMA if done in support of the offsite plan or ouring the biennial exercise. When a medical drill is conducted in conjunction with an exercise the medical orill is of ten performed as part of a " mini-scenario" and is not directly related to the principal sequence of events invcived in the primary exercise scenario. Applicants have performea three annual mecical l
orilis involving a team from the local apport services agency and an of fsite I
meoical treatment f acility.
(Ca11endre11oAfficavitat115) Another meoical drill is scheduled for hoveniber 1989.
The foregoing is true and correct to the best of my knowledge and belief.
d)
A Falk Kantor j
Subscribeo ano sworn to before me l
this % day of November,1989 1
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Rotary Public Hy connission expires: 7/, /90 t (
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