ML20006F636

Forwards Comments on Seabrook Emergency Plan,Per 890817 Meeting.Organization for Emergency Response Planning Appears to Be More Elaborate than Provided for Many Other Nuclear Power Sites

ML20006F636
Person / Time
Site:	Seabrook, 05004430
Issue date:	08/22/1989
From:	Bender M QUERYTECH ASSOCIATES
To:	Igne E Advisory Committee on Reactor Safeguards
References
ACRS-CT-1950, NUDOCS 9002280250
Download: ML20006F636 (4)

Text

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QUERYTECH ASSOCIATES, INC. f D b d # !'I # ]

9040 EXECUTIVE PARK DRNE, SUITE 217 KNOXVILLE, TN 37923 ',

Phone (615) 690 2728 August 22,1989~ Y'2 '

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U. S. Nuclear Regulatory Commission

' Advisory Committee on Reactor Safeguards 1

. Mailstop P-315-

Washington, D. C. 20555 Attention: Mr. E. P. Igne,

Dear Al,

I (Enclosed is a copy of my comments on the Seabrook meeting of' August '

17,1989. .lf there is a need for any.further assistance, please call me.

Sincerely, ,

M. Bender Copy to Professor Wm. Kerr ,

' DESIGNATED ORIGINAL  !

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. COMMENTARY ON SEABROOK EMERGENCY PLAN u

PREPARED BY M. BENDER, QUERYTECH ASSOCIATES, INC.

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-m August 22,1989 -

GENERAL OBSERVATIONS The Seabrook emergency plan.seems to be fully responsive to the NRC regulations. The Ucensee has evidently bent every effort to be sure that _

the local authorities in.both Massachusetts and Now Hampshire are l- conscious of their- obligations in an emergency and will respond  ;

J appropnately if the need arises. .

l . l Organization; for' emergency response planning appears to be more elaborate than provided for many other nuclear power sites. Local concern of the citizenry for nuclear accidents probably warrants the level of effort expended but in.the longer term it might be more realistic to - )

reduce the size of the response organization and rely on a smaller group to provide key actions if a real emergency arises, q

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EMERGENCY EVACUATION  !

Emergencies requiring site evacuation are'very low probability events. The licensee's conservative estimate is that at a time of peak occupancy the L

entire area within the emergency planning zone could be evacuated in less than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The transient visitors to the beaches represent the  !

principal -load on the emergency routes and under non-emergency  ;

j conditions, observed subsequent to rainstorm warnings, only about two hours have been needed to clear the beaches.

l The licensee's emergency actions are predicated on evacuation at an i early stage of an accident. Since the PWR system installed at Seabrook has ample heat capacity and a strong reinforced concrete containment l 1

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. SEABROOK EMERGENCY PLAN

' BENDER COMMENTS, 8 2' 2-89 l I structure, there is every reason to believe that even the lowest probability.

L events would not result in potential for significant radionuclide release from ,

the reactor system and its containment before complete evacuation could ,

be implemented.

a l EMERGENCY RESOURCES The resources available to the Licensee in the event of a serious accident ,

- are not very clearly defined. Presumably, the operating staff understands j

' .the basics of dealing with bulk radionuclide releases if they occur. The documentation describing the training for such circumstances is not readily available but the Seabrook SER (NUREG 0896, Supplement 8), indicates ,

that the regulatory staff has reviewed the Seabrook capabilities and found ,

them adequate.

Obviously, there are uncertainties associated with any accident that might j not be anticipated by the training program. Backup capabilities to provide advice in such circumstances ought to be identified.

1 EMERGENCY RESPONSE TESTING j Most of the emergency response tests performed, thus far, seem to involve actions related to a site emergency conditions defined by the 20 l critical safety functions outlined in NUREG 0654. The accident scenarios I for testing response are developed by the Seabrook emergency planning .I staff and used to challenge the response of the operating staff and the H external emergency response organization. This seems to be an effective y approach to rnaking 'sure that the organization remains "on its toes".

J lt would be useful to compare the test scenarios being used to real  !

emergency circumstances that, in the past, raised questions about emergency response capabilities at nuclear power plant sites (e.g. TMI-1, 2

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SEABROOK EMERGENCY PLAN BENDER COMV:NTS,8-22-89 ,

. the Browns Ferry Fire, the Fermi simulator-error initiated operating mistake, q

the Davis-Besse feedwater malfunction, loss-of-power at Millstone) to see- a how they would be addressed in current emergency response planning.

b Such a review should show that all of the previous deficiencies. in emergency response capability have been addressed.

TOWN OF ESSEX SAFEW ISSUES L The classical issues raised in the July 31,1989 letter from'the Town of -

L Essex should be recognized in Seabrook emergency plans. Effectiveness of the containment in limiting the dispersal of radionuclides in the event '

p of an accident, even if leakage occurs, should be established. The experience at TMI-1 shows that even with substantial core melting, only the ,

noble gases are likely to escape and these will be quickly dispercod in a manner that results in negligible health threat to the public.

The NRC staff should be able to provide documentation to support such a position in order to display appropriate interest in questions of this sort when raised by public intervenors.

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