Text

Forwards Jm Taylor to N Mavroules & Encl 1 Re Emergency Planning Issues
	ML20043D690
Person / Time
Site:	Seabrook
Issue date:	06/04/1990
From:	Reis E; NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:	; NRC, PUBLIC SERVICE CO. OF NEW HAMPSHIRE
References
	CON-#290-10431 OL, NUDOCS 9006110075
	Download: ML20043D690 (34)
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m:.ncn To:

Seabrook Service List Enclosed herewith is a letter, with enclosure 1, sent to Congressman Nicholas Mavroules on May 22, 1990, h,

Edwin J. Reis

'. % aL Deputy Assistant General Counsel for Reactor Licensing L

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77 900611007D 900604 gDR ADDCKOSOOg3 3so?

May 22, 1990 The Honorable Nicholas Mavroules United States House of Representatives Washington, DC 20515

Dear Congressman Mavroules:

Your letter of March 1,1990, to Chairman Kenneth M. Carr expressing your concerns regarding the evacuation of communities within the Seabrock 10-mile EPZ has been referred to me for response.

As you know, these matters are under adjudication and, hence. the Commission cannot respond to the concerns raised in your request. However, the NRC staff has set forth its position concerning these matters, based on the record of the hearings before the Atomic Safety and Licensing Board, in comprehensive briefs and pleadings filed with both the Licensing Board and the Atomic Safety and Licensing Appeal Board.

Enclosed please find a sumary of the staff's positions on the issues raised in your letter, and copies of the NRC Staff Proposed findings for both the New Hampshire portion of the Seabrook emergency plan and the Massachusetts portion of the emergency plan.

Also enclosed are copies of the relevant Board decisions in the administrative litigation and a copy of the decision of the 1st Circuit Court of Appeals decision in Massachusetts v. United States, 856 F.2d 378 (1988).

I hope these documents respond to your concerns.

Please let me know if I can be of any further assistance to you.

04inal Sh0f@ #'

I hmes 14 h8$s M. Tsylor Executive Director for Operations

Enclosures:

1.

" Summary of the NRC Staff Position Concerning Evacuation of the Massachusetts Portion of the '

Seabrook EPZ Using the Seabrook Plan for liossachusetts Communities 2.

NRC Staff Proposed Findings for New Hampshire, dated August 31, 1989 3.

NRC Staff Proposed Findings for Massachusetts dated August 24, 1989 4

Partial Initial Decision for New Hampshire Radiological Emergency Response Plan, dated December 30, 1988 5.

Partial Initial Decision for Seabrook Plan for Massachusetts Communities and 1988 FEMA Graded Exercise, dated November 9, 1989 6.

1st Circuit Court of Appeals Decision in Massachusetts v. United States, 856 F.2d. 37V (N) y 5

"NI 0

4

SUMMARY

OF THE NRC STAFF POSITION CONCERNING EVACUATION OF THE MASSACHUSETTS PORTION OF THE SEABROOK EPZ USING THE SEABROOK PLAN FOR MASSACHUSETTS COMMUNITIES In September 1986 the Comonwealth of Massachusetts decided not to participate in further emergency planning for Seabrook.

In response to that decision, Public Service Company of New Hampshire developed and submitted the Seabrook Plan for the Massachusetts Communities (SPMC) to provide needed emergency planning W tatisfy the requirements of NRC regulations.

The SPMC is designed to be implemented either in

Mode 1," which assumes The Comonwealth responds to the emergency and calls upon the utility only for resources and personnel, as needed, or in " Mode 2 " which assumes that The Commonwealth delegates full authority to the utility to respond to the emergency and carry out SPMC, or in any other mode lying within the spectrum bounded by Mode 1 and Mode 2.

The utility organization responsible for carrying out the SPMC.is the NHY Offsite ResponseOrganization(ORO),anassociationofvolunteersdrawnfrom various companies and callings.

T5e SPMC phase of the Seabrook licensing proceeding addressed issues raisedbyIntervenorsII in 84 contentions which were resolved by The active Intervenors to the SPMC phase of the proceeding)were the 1/

Attorney General of The Comonwealth of Massachusetts (MAG, The SeacoastAnti-PollutionLeague(SAPL),TheNewEnglandCoalitionon Nuclear Poil9 tion (NECNP), the Town of Amesbury, Massachusetts (TOA),

the Town of Newbury, Massachusetts (TON), the Town of West Newbury, Massachnetts (TOWN), the Town of Salisbury, Massachusetts (TOS), the City of Newburyport, Massachusetts (CON) and the Town of Hampton, New Hamphsire (TOH).

(Footnote continued on next page)

W settlement or by previous Licensing Board rulings, or litigated and resolved in the Licensing Board's November 9, 1989 Partial Initial Decision (Seabrook Plan for Massachusetts Communities and 1988 FEMA Graded Exercise),LBP-89-32,30NRC

("LBP-89-32"). This Partial Initial Decision was appealed by Intervenors including the Massachusetts Attorney-General, briefed by all parties, argued and is presently before the Atomic SafetyandLicensingAppealBoard(AppealBoardorALAB).

The NRC staff concluded, and has argued before the Atomic Safety and Licensing Board and the Atomic Safety and Licensing Appeal Board, that the record in the Seabrook licensing proceeding demonstrates that the SPMC y

satiNies the NRC requirements for emergency planning and-provides reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency. With respect to the principal issues raised in administration's litigation on the SPMC, the record shows:

+

A) FEMA has reviewed the emergency response plans for Seabrook and the 1988 full participation exercise and concluded that the emergency plans and emergency preparedness for Seabrook will be adequate to protect the health and safety of the public.

[

B) The hearing record demonstrates that the evacuation times d

estimates (ETEs) for Seabrook -- which cover a range of traffic and Eg weather conditions and range from 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months and 40 minutes to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and 10 A_

minutes -- follow NRC regulatory guidance and provide appropriate evacuation

[

(Footnote continued from previous page)

-'m JI The Town of Merrimac, Massachusetts (TOM) and the City of Haverhill, 2

Massachusetts (C0H) participated pursuant to 10 CFR ta 2.715(c), but 3

presented no evidence.

Ta 5

2

3-o time information for emergency response decisionmakers to determine what Protective Action Recommendations should be made.

C) The SPMC provides a traffic management plan to ensure adequate and efficient evacuation from the area of concern.- The SPMC traffic management plan provides traffic control posts to facilitate traffic movement and trained traffic control guides to implement traffic control.

The traffic management plan was modified to reflect concerns of local police chiefs and reflects the contribution of 5 of the 6 incumbent Massachusetts municipalities' police chiefs at the time it was developed.

D) Evacuation of the transit dependent population including school children and the special needs population was thoroughly addressed. The record demonstrates that'the SPMC would provide adequate buses and other vehicles to accommodate the transit dependent population including school children.

E) The SPMC provides adequate information, procedures and criteria to enable decisionmakers to develop appropriate protective action recommendations in the event of an emergency at Seabrook.

It adequately incorporates ETE information into the decision making process and contains information on a range of protective actions which may be suitable to the circumstances.

F) As recognized in the Commission's regulations,10 C.F.R.

I 50.47(c), in an actual emergency the Commonwealth and local officials will exercise their best efforts to protect the health and safety of the public. The Court of Appeals in Massachusetts v. United States, 856 F.2d 378, 838 (1st Cir. 1988), in upholding the reasonableness of this regulation, stated:

I

u

-. it is hardly unreasonable for the NRC to predict that state and local governments, notwithstanding their misgivings about the adequacy of a utility plan or their opposition to a.

particular plant location, would, in the event of actual emergency at a plant they were lawfully obligated to coexist with, follow the only existing emergency plan. This prediction is supported by comon sense, and also by the uncontested fact -- part of the administrative record of this rule -- that state and local governments prefer a planned emergency response to an ad hoc response. See 52 Fed. Reg. 42082(1987).

A brief summary of the evidence relating to the SPMC supporting these points is-set out below. An ample record supporting the adequacy of the emergency plan for the Seabrook station was also developed in the hearings relating to The New Hampshire portion of the EPZ. Support for the best effort presumption is continued in the cited 1st Circuit Court of Appeals decision, copy enclosed.

I.

FEMA Review of Emergency Response Plans for Seabrook and the 1988 Full Participation Exercise Pursuant to the Memorandum of Understanding between the Nuclear Regulatory Commission (NRC) and Federal Emergency Management Agency (FEMA) 2/ and also contemplated by the Commission's regulations at 10 CFR -50.47, the NRC requested and FEMA conducted a review of the offsite rdiological emergency plans for Seabrook, and the graded exercise thereof.

The review was conducted by the Federal Emergency Management Agency, Region I (FEMA I), with the assistance of the Rgional Assistance Committee (RAC). The RAC is chaired by FEMA and has the following members:

U.S.

Department of Agriculture (USDA); U.S. Department of Comerce (DOC); U.S.

DepartmentofEnergy(DOE);U.S.DepartmentofHealthandHumanServices (HHS); U.S. Department of the Interior (DOI); U.S. Department of Transportation (DOT); U.S. Environmental Protection Agency (EPA); and the U.S. Nuclear Regulatory Commission (HRC). The RAC functions in 2_/

Memorandum of Understanding, 50 Fed. Reg. 15485,15487(Apr.18, 1985) (MOV).

e

accordance with 44 C.F.R.- Part 351, " Radiological Emergency Response Planning and Response." This FEMA review and evaluation used NUREG-0654/

FEMA-1, Rev.1, Supp. 1. September 1988, as the basis (planning standards and specific criteria) for determining the adequacy of the New Hampshire Yankee Seabrook Plan for Massachusetts Communities.

FEMA Guidance Memoranda (GM) and FEMA REP-series documents were utilized to

' interpret and clarify the criteria contained in Supplement 1.

FEMA concluded that the plans, including the SPMC, were adequate. More specifically, FEMA found and concluded that, subect to the installation of a vehicular alert and notification system (VANS) for the Massachusetts portion of the EPZ, and enhancements to the alert and notification system for the New Hampshire portion of the EPZ, the plans and preparedness will be adequate to protect the health and safety of the public living in the Seabrook EPZ by providing reasonable assurance that appropriate protective measures can be taken offsite in the event of a radiological emergency and are capable of being implemented. 3/ 4/ Letter,PetersontoStello(Dec.

14, 1988), App. Ex. 43A.' See also ff. Tr. 21653 at 3; Tr. 21651. The RAC 3/

All VANS issues were subsequently decided in Applicants' favor in Public Service Co. of New Hampshire (Seabrook Station, Units 1 and 2),

~~

LBP-89-17, 29 NRC 519 (appeal dismissed (Aug. 1, 1989).

4/

Findings and Determinations for the Seabrook Nuclear Power Station, FEMA, December 1988 (App. Ex. 43B); Review and Evaluation of the Seabrook Plan for Massachusetts Communities, FEMA, December 1988.

(App. Ex. 43C); Review and Evaluation of the State of New Hampshire Radiological Emergency Response Plan for Seabrook nation, FEMA, December 1988 (App. Ex. 43D); Status of Corrective Actiord for the 1988 FEMA Graded Exercise for Seabrook Station, FEMA.

P:cember 1988.

(App. Ex. 43E); Exercise Report, Seabrook Nuclear Pov er Station, Pre ared by FEMA, Region 1, Boston, MA September 1, '988.

(App.Ex.

43F.

was involved throughout the FEMA review and concurred in all reports filed. Tr. 19092-93.

The FEMA reasonable assurance finding is based on four " legs." These are(1)reviewoftheplanagainstNUREG-0654,Supp.1,asappropriate, (2)testoftheplaninanexercise,(3)verificationthatequipment, personnel and resources are actually there, and (4) verification that the personnel have been trained.

FEMA thoroughly reviewed all facilities and equipment to be utilized to implement the SPMC.

In addition, FEMA reviewed the results of the graded exercise of the radiological emergency response plans for Seabrook. The overall conclusion reached by FEMA in v

evaluating the June 1988 Seabrook exercise was that the exercise demonstrated that the SPMC and the emergency plans for the State of New Hampshire and the State of Maine can be implemented.

In accord with Commission regulations, these FEMA findings cobi.itute a rebuttable presumption that all aspects of the Seabrook offsite plans and emergency preparedness are adequate and capable of implementation, except as otherwise specifically noted by FEMA, 10C.F.R.I50.47(a)(2).

Tr.18498-99,18502,19108-09, App. Ex. 43F, passim Tr. 21651.

FEMA reviewed the SPMC on what is referred to as a " Mode 2 full" basis; that is to say the assumption was that the nonparticipating governments would only delegate authority, but no resources or assistance would be given to the ORO to execute the plan. Tr. 18422. The graded exercise also was conducted on the basis of Mode 2 full. Tr. 22384-85.

{

Because FEMA found SPMC to be adequate in this mode, and because it can be assumed that any response which included assistance and/or resources from The Coinmonwealth would be better than a response by the utility ORO alone, y_

. FEMA believes, has found, and the NRC Staff concurs, that the SPMC m.

operating in Mode 1 (ORO contributing resources and personnel only), or in any mode between Mode 1 and full Mode 2, would also provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency at Seabrook. Tr. 18432,18442, 18444-45,_18459-61.

In addition, the graded exercise, conducted as Mode 2 full, demonstrated the implementability of the SPMC in other modes which include varying degrees of Comonwealth participation. Tr. 22387-89.

i II. Evacuation Time Estimates (ETEs)

The Evacuation Time Estimates (App. Ex. 42) are used by decisionmakers at the time of a radiological emergency to determine what Protective Action Recommendations (PARS) should be made based on the accident scenario, meteorological conditions and other factors affecting an evacuation decision. There are no maximum times set by regulation for accomplishing an evacuation. An ETE should reflect realistic conditions, rather than a worst case scenario, so that it is of use to the decisionmakers at the time of an emergency. 5/ The ETE's include reasonable estimates of roadway capacity and represent the evacuation conditions expected under the implementation of the SPMC's traffic control plen. Ff. Tr. 26681 at 35-36. See also ff. Tr. 27150, at 3-5, 6-7.

The SPMC's ETEs provide 5/

Philadelphia Electric Co. (Limerick Generating Station, Units 1 and 2),ALAB-845,24NRC220,246(1986); Philadelphia Electric Co.,

(Limerick Generating Station, Units 1 and 2), ALAB-836, 23 NRC 479, 491(1986); Philadel)hia Electric Co. (Limerick Generating Station, Units 1 and 2), LBP-35-25, 22 NRC 101, 106 (1985).

-....-.---i..,

8-all the necessary information and parameters to allow proper selection of a representative ETE for determination of PAR's. Ff. Tr. 26681 at 48-49.

Dr. Thomas Urbanik, of the Texas Transportation Institute cf the Texas A&M University, while finding the ETE analyses to be adequate, indicated that an organized presentation of the ETEs, including assumptions and methodology, should be prepared so that the SPMC ETEs could readily be used by decision-makers at the time of an emergency.

Urbanik Dir. Ff. Tr. 27150 at 9.

With the exception of the need for an organized presentation, the existing ETEs satisfy the guidance of NUREG-0654, Appendix 4, and all applicable regulatory requirements, ld.

No additional analytical work is required and further, the preparation of this organized presentation of.ETEs is essentially an editorial or

" ministerial" task. Tr. 27179-80.

Several subsidiary issues arose as part of the ETE analysis including the number of vehicles in the Massachusetts portion of the EPZ, the effectiveness of trained civilian traffic guides as opposed to public officers at traffic and access control posts (TCPs & ACPs), the configuration of TCPs and ACPs and the impact of shadow evacuation. After careful consideration both the Intervenors' expert and the NRC Staff concluded that assuming the validity of all the expert's concerns and factoring in all the time increments, these additions would not have a significant effect on ETEs and would not affect any Protection Action Recommendations. Ff. Tr. 26482 at 20-21; Tr. 26498-502.

"1IIbd-Il i

' 9-The ETEs, as updated, and subject to tneir being published in an organized presentation, are adequate for PAR decision making for the following reasons:

1.

The ETEs were calculated using a state of the art methodology and are as accurate as reasonabD t;hievable.

2.

-The ETEs provided to the PAR decisionmakers are for an adequate number of scenarios which account-for the most predominant conditions and variables norra11y experienced in the Seabrook EPZ.

3.

The ETE scenarios in the SPMC are the same ones used in the NHRERP, which were found adequate after hearing all the evidence on PAR decisionmaking.

4.

The ETEs prove to be relatively insensitive to roadway impediments and expected variations in beach area population.

5.

PAR decisionmakers are alerted to consider emergency-specific conditions which may direct additional logistical considerations for added flexibility.

6.

Under most conditions evacuation would be the preferred PAR for the Seabrook EPZ.

Ff. Tr. 26681 at 52; see also ff. Tr. 27150 at 7-9.

The hearing record contained no evidence to support the argument that further refinement of the ETEs would make a further contribution to public protection.

The ETE's for special facility ETEs are comparable to those for the general population, thus obviating the need to-consider separate PARS for special facility populations.

Ff. Tr. 26681 at 63, 64-67, see also Tr.

21231-33, Tr. 22596-97. Recommending PARS on a group-by-group or facility-by-facility basis is not likely to provide any additional dose savings for special populations. However, given that the special facilities and special populations PARS are comparable to those of the general public, the SPMC will provide for special consideration of these groups. The SPMC will be revised to incorporate a priority list for allocating evacuation vehicles to all special populations. This list will indicate which population cat? gory should receive resources first and the sequence in which facilities within each category will be serviced.

Specifically, schools and day care facilities would be assigned vehicles first, followed by the transit dependent general population routes, curbsidepickup(homebound) routes,specialfacilitiesandthenhospitals.

When there are multiple facilities within a category, the facilities which are closest to Seabrook would be serviced first followed by those that are further away. This assignment priority ensures the most efficient use of transportation resources. Thus, the SPliC takes all appropriate steps for maximizing dose reduction for EPZ special populations.

Ff. Tr. 26681 at 63-64.

For fast-breaking scenarios (such as are considered in the ETE), the Applicants will use an expedited bus mobilization procedure.

Ff. Tr.

26681 at 65-66; Tr. 27099. The f act is -that for Seabrook, because PARS will be generated largely based on plant conditions, and because of the uncertainties associated with predicting accident sequences and events, a PAR other than evacuation is unlikely except in a very small number of scenarios. Tr. 27072-74; Tr. 27126-27. And, indeed, it is doubtful that even a difference of as much as one and one-half hours in an ETE could affect any PAR choice at Seabrook. Tr. 26933-34.

. Dr. Urbanik testified that~ the Applicants' ETEs account for the

- specific circumstances, difficulties and delays which might exist in conducting an evacuation in the Massachusetts portion of the Seabrook EPZ.

Ff. Tr. 27150 at 3.

Further, Dr. Urbanik stated that the ETEs are realistic, and that no significant errors exist in the ETEs' assumptions as to the number of vehicles that will be using roadways, intersections and ramps in Massachusetts or as to the number of vehicles that may be expected to evacuate from and through Massachusetts. M.at4-6.

Based on his review of the SPMC ETEs, and his extensive knowledge of the Seabrook EPZ and of Seabrook ETE modeling efforts which have been made over$hepastyears,seee.g.,ff.Tr.26337at2-3,thisexpert concluded that no further ETEs are necessary. Ff. Tr. 27150 at 2.3, 9; Tr.

27167, 27170, and 27180.

Indeed, he stated that "the sensitivity of the Seabrook EPZ [is known] in a way that's unseen any place else in the world." Tr. 27170.

III. Traffic Management Plan While the development of a traffic management plan is not a regulatory requirement, applicants are permitted to develop special trafficmanagementplanstoeffectivelyutilizeavailablecapacity.

See NUREG-0654, Appendix 4, at 4-5.

In addition, applicants are instructed to provide " specific recommendations for actions that could be taken to significantly improve evacuation times." H at 4.

The purpose of traffic management planning in conjunction with radiological emergency planning and preparehess is (1) to provide a means to identify and plan for those actions which could be taken to significantly reduce evacuation times in 0

' th'e event of a radiological emergency, thereby providing the lowest reasonably feasible evacuation times, and (2) to make the most effective use of available traffic management resources.

Ff. Tr. 2633 at 4; see also Tr. 26456. Such a traffic management plan was developed here.

The primary objective of traffic management is to support emergency evacuation operations to ensure an adequate and efficient evacuation from the area of concern. To support this objective it is necessary to recomend evacuation routes and implementable traffic control strategies to utilize efficiently the available roadway network capacity.

In some instances, control strategies which enhance existing roadway capacity can significantly expedite evacuation traffic movements.

Since such treatments are frequently resource-intensive, they should be limited to those locations which offer the greatest potential benefits. Thus, a well-designed traffic management plan identifies the most effective control strategies, quantifies the resulting benefits, and balances these benefits with the available resources to define the most effective and implementable plan responsive to the stated objective.

Ff. Tr.17353 at 1.

The SPMC traffic management plan was the result of an extensive recursive and iterative process which the Applicants' witnesses summarized succinctly for the record.

Ff. Tr. 17333 at 2-5.

Fine-tuning of the traffic control plan continued until no material improvement in ETEs was obtained. M.at4-5.

The Traffic Control Posts (TCPs) in the SPMC are designed to perform a number of functions:

(1)facilitateevacuatingtrafficmovementswhich serve to expedite travel out of the EPZ along the planned evacuation

.- routes; (2) discourage traffic movements which permit evacuating vehicles to travel in a direction which takes them significantly closer to the powerstation;and(3)resolvepotentialconflictsbetweentrafficstreams at intersections by assigning right-of-way so as to promote safe operations and to keep traffic moving.

Ff. Tr. 17333 at 6.

The number of Traffic Guides assigned to each TCP and access control post (ACP) was determined based upon the complexity of the point's traffic strategy, the location's general configuration, and the type of equipment assigned for use.

Police Chiefs in the Massachusetts EPZ communities were requested to provide input on the traffic routing, TCP and ACP strategies, and how many personnel and what equipment would be required to implement the desired strategies. Detailed inputs to the design of the traffic controlplanwerereceivedfromfiveofthePoliceChiefs(allexceptthat of the Town of Amesbury) during interviews and through subsequent correspondence.

Ff. Tr.17333 at 6-7.

See also App. Ex 50; Tr. 17451, 17464-66. The number of Traffic Guides at each TCP was minimized to the number required to implement its control strategy in an efficient manner, in order to avoid confusion and conflict between guides. Tr.17443; see also Tr. 17153-54. The SPMC provides an adequate number of traffic control personnel.

Ff. Tr. 26337 at 9; Tr. 26449-50; Tr. 26456. Nor is the SPMC traffic management plan constrained by any lack of necessary resources. Tr. 26381-82, Tr. 26456.

For example, the original control policy developed for the intersection of Routes 1,1A, and 110 in the Town of Salisbury was to facilitate both the westbound travel along Route 110 toward I-95 and 1-495, and the southbound travel along Route 1.

Ff. Tr.17333 at 7.

The police chiefs in TON and CON, however, objected because they believed that I

Route 1 would be congested with evacuating traffic from Salisbury Beach to the extent that evacuees from these communities would be unduly delayed as a result. id, at 7-8; see also Tr. 16968-69. To respond to these concerns, the traffic control policy at Salisbury Center was revised and took its present form, whereby all traffic is routed over two lanes along westbound Route 110 to I-95 and -495. This revised policy was reviewed with the then Town of Salisbury Police Chief (Chief Olivera), who approved it and stated that the town police could implement it. Ff. Tr.17333 at 8.

See also ff. Tr. 27150 at 7.

Personnel at thirty-seven (37) TCPs and at any supplemental ACPs provide a readily available source of feedback information regarding impediments to evacuation traffic along prescribed evacuation routes I

. within the Massachusetts portion of the plume EP2. These personnel will be-in place during the evacuation regardless of weather conditions and time of day. Aerial surveillance of road network impediments is available by heicopters during acceptable flight conditions. App. Ex. 42, IP 1.3, ; Plan, Appendix C, 1.0A for use of helicopters. Traffic impediment, road construction, and flood information will also be available form local police and road departments via the local Emergency OperationCenters(EOCs). App.-Ex. 42 IP 1.8.

The SPMC contains adequate and elaborate traffic impediment response procedures provide for the identification, analysis and removal or avoidance of traffic impediments during on evacuation.

Ff. Tr. 17333 at 49-52, 57.

FEMA concludes that the SPMC is adequate with respect to providing the necessary procedures and equipment to clear impediments blocking evecuation routes. App. Ex. 432 at 67-68.

In sum, the SPMC traffic management plan is one of the most extensive in the United States and probably only one or two others are even comparable to it. Tr. 26389. The hearing record demonstrated that the plan takes advantage of available opportunities to reduce evacuation times to as great an extent as is reasonably feasible.

Ff. Tr. 26337 at 18.

Further, the SPMC traffic management plan utilizes appropriate and sufficient capacity enhancing measures and other traffic control strategies; and the SPMC has identified those actions that could significantly improve evacuation times.

Id.

IV. Evacuation of Transit Dependent Persons FEMA reviewed and found the procedures for the evacuation of the transit dependent to be adequate. The record before the Licensing Board l

s

contains testimony elaborating on the development and criteria for the

. evacuation bus routes, how the bus transfer points will operate, how the estimates of transit dependent persons were made, how the number of runs to be made was determined, the duties of Route Guides and how the Route Guides will interface with bus drivers.

Ff Tr.17333 at 59-60, 63-67 and Attachs. ! & J.

Evacuation bus routes were initially developed for the six Massachusetts communities by emergency planners under the direction of Massachusetts Civil Defense Agency (MCDA) with input from EPZ planning contacts _(e.g., local civil defense directors, selectmen) in each of the six Massachusetts communities. The routes were designed to start at the Local Staging Area (i.e., Transfer Point) and extend through the town to form a closed path while generally following the guidelines stated below:

a.

No house would be more than approximately one-half mile from a bus route; b.-

Buses would not back-track on the same route where possible; and c..

Buses, in general, would follow the directions provided at the Traffic Control Points.

In developing the SPMC bus plan, NHY relied on.the bus routes developed by MCDA, Once the routes were designed, a field verification was done to ensure the roadways were correctly shown on the map.

Due to changes in thelocationsofthetransferpoints(i.e.,localstagingareas),the evacuation bus routes were slightly modified.

Ff. Tr. 17333 at 58-59.

'A comprehensive field study was conducted of the evacuation bus routes for all six SPMC communities between November 7 and 15, 1988.

Standard full-size school buses were used for field verification of the

38 -

evacuation bus routes. The buses were 9'6" wide with both mirrors extended and 7'6" wide with mirrors retracted. Thus, at least 17 feet of road wicth (pavement plus shoulders) was needed for two buses to pass each other. The weight of the bus was 26,600 pounds when empty. A field study 1

was made consisting of three separate runs.

First, specific roadways where potential problems had been identified through drill coments, exercise comments, and contention bases were driven with a bus to assess the existence or severity of the stated problems.

Road measurements, where appropriate, were taken at the observed narrowest point on roadways to determine if the road was wide enough to accommodate an evacuation bus-and opposing traffic. Second, all routes were driven with automobiles'to verify the information on the bus route maps regarding the existence of l-street signs, landmarks, roadway configuration and correct labeling of streets. A set of criteria was developed and given to the personnel to L

direct them in the method which should be followed when driving the l

routes. Third, all bus routes were driven with buses to verify that a bus could perform all turn movements and to record route distances. As a result of this field survey, 4 out of the 26 evacuation bus routes were revised and then rerun to record route distances. An analysis was then performed to determine new bus route transit times, total trip completion times and the number of buses to be allocated to each route.

Ff. Tr.

17333 at 60 and Attach. K.

Bus Route maps were changed and clarified in light of these field surveys.

Ff. Tr. 1733 at 60-63.

Evacuation buses are not expected to encounter undue delays when crossing heavily congested evacuation routes. The evacuating vehicles will permit the bus to get through. The amount of time spent by evacuees

' waiting in personal vehicles for the bus to cross the evacuation route will be minimal. The backed-up traffic will quickly rejoin the original lit.e of evacuating traffic due to the fact that minimal forward progress would have occurred in the time span it took for the bus to cross the evacuation route. Ff. Tr.17333 at 68.

To evaluate and provide for the potential for area-wide flooding, flood plain maps were obtained from the Flood Map Distribution Center in Baltimore, Maryland, for TON, CON, TOS, AND TOWN. Flood plains are classified into 1-year,10-year, 50-year, 70-year,100-year and 500-year -

intervals based on the expected occurrence of a major flood incident in the respective time period. The roadways identified in the Intervenors' contention bases as problematic all fall into either the 100-year or 500-year flood plain intervals. This translates into the probability of 0.01 or 0.002 that major flooding will occur on these roadways in any year. Therefore, it is highly unlikely that these roadways will be

-rendered impassable by flooding concurrently with an emergency at Seabrook.

Ff. Tr. 17333 at 69.

In certain weather conditions evacuation buses might encounter sections of road covered by water. An evacuation bus would generally be able to traverse roads and pick-up transit-dependent evacuees, depending on the level of flooding. Buses used in picking up transit dependent residents have a clearance of approximately 15 to 20 inches from the road surface to the tailpipe. This distance is the limiting factor for buses i

traversing flooded routes.

If a segment of roadway which appears to be impassable due to local flooding or some other obstacle is encountered, the Route Guide is to contact the Transfer Point Dispatcher and, using the

l

- e'

.}

z detailed route map (Ff. Tr.17333, Attach L), determine alternate roadways available to rejoin the assigned route. The Route Guides are to

" report any obstacles, stalled cars, or other impediments to traffic flow.... to the Transfer Point Dispatcher... " App. Ex. 42. IP 2.10, at 26.

SPMC procedures call for the evaluation of constraints such as " road conditions, current weather conditions, and special evacuation problems." If a significant rerouting is necessary, Traffic Guides will be reassigned as necessary.

(App.Ex.42,IP2.11at5, step 5.1.7).

Ff.

Tr. 17333 at 69-70, s.. The evacuation of a. school or special facility is accomplished by dispatching all necessary buses with one Route Guide to the facility.

It is far more efficient to move buses through an intersection in a convoy as envisioned in the SPMC than it is to move single buses. The competing traffic flow is interrupted only once by a convoy instead of multiple times for individual buses. Ff. Tr. 17333 at 70-71.

The bus routes in the SPMC, with the commitments which the Applicants have made to improve them as reflected in the record of this proceeding, are adequate and can be implemented.

(

V..

Personnel and Training FEMA concluded that the Offsite Response Organization (ORO) in the l

SPMC is adequately staffed. App. Ex. 43C at 13; see also Tr. 18836..

Personnel for a second shift would be requested and supplied through Yankee Atomic Electric Company by means of the Yankee Atomic Mutual Assistance Plan. Second-shift staff will be briefed by the personnel they replace to the extent necessary and are capable of performing the required l

f.

. functions. App. Ex. 42 at 2.1-1, IP 2.11, IP 2.17 IP 3.2, IP 3.5, IP 2.9; App.-J..

FEMA verified that the Applicants demonstrated shift change capability at both reception centers during the emergency planning exercise, including shift change capability for evacuation monitoring positions. Tr. 18685, 19163.

See also App. Ex. #3F at 240. The replacement shift was well-trained and fully knowledgeable of their responsibilities. App. Ex. 43F at 239. FEMA observed from the exercise that the Yankee Atomic Staff designated as the second shift for monitoring positions are as adequately trained as first-shift personnel. Tr. 18686, 18691, 19160. Personnel provided through the Yankee Mutual Aid Program would be drawn from e group of people who already have pre-identified skills and know: ledge of radiation monitoring equipment and other knowledge necessary to be able to perform designated tasks. Tr. 18688, 19126.

Testimony on personnel recruitment and screening indicated prerequisites included experience and training in. emergency response.

Ff Tr. 27388 at.

1-2.

FEMA observed that the 2cond shift was able to step in, receive a turnover shift briefing and use the instruments and demonstrate its proficiency just as the first shift did. Supervisors for the second shift have been pre-identified and trained. Tr.18687.

VI. Protective Action Recommendation (PAR) Generation

. FEMA concluded that the SPMC is adequate in establishing a capability for implementing protective measures based upon Protective Action Guides (PAGs)andothercriteria, App.Ex.43 Cat 53-58,thattheSPMCadequately describes the basis of choice of recommended PARS during emergency conditions, App. Ex. 43C at 69-70, and that the SPMC adequately describes

- - - - - - - - - - - - those functions which require state and local authorization before implementation.

App. Ex. 43C at 9-12. FEMA has found that ORO has executed the necessary agreements with respect to all support organiza-tions including the State of New Hampshire, that the agreement for coordination between those two entities is adequate App. Ex. 43C at 12-13, and that Applicants' population distribution information for the permanent population and methodology for estimating the transient-population is adequate.

Although there is no regulatory requirement that a shelter survey be included in a radiological emergency response plan (RERP), Tr.18576, the decision criteria of the SPMC contains a full range of protective actions including a shelter option for the permanent population. Tr. 18572-18573.

While many structures in the EPZ may provide greater protection, FEMA established that the selection in the SPMC of the 0.9 dose reduction factor (drf) is the most prudent and conservative approach to take. Tr.

18578; 18587-88, 18590.

EPA draft guidance suggests that shelter is a protective action that is viable for only a limited time equal to less y

than six hours. Tr. 18593. The fact that an area may have long evacua-u.

tion time estimates does not mean that there is any greater need to explore sheltering alternatives. Tr.18590-92.

During the emergency planning exercise, FEMA verified the reasonable-ness of Applicants' dose projections using its own (FEMA's) dose code.

Tr. 18324-28; App. Ex. 43F at 220-221. At the plan review stage, FEMA had checked the dose projection assumptions and during the exercise the reasonableness of the results were checked. Tr. 18328-29.

No evidence l

l

~- - -

. g,,

was adduced to contravene the adequacy of the SPMC with respect to the generation of protective recommendations.

I The "HETPAC" computer model which was used to create protective l.

action recommendations (PARS) was particularly subject to test in the Seabrook hearings.

The evidence showed that the PARS generated by the onsite organization to the State of New Hampshire and the NHY ORO were L

L timely and appropriate and that the PAR generating procedures were 1

L correctly followed during the exercise.

Ff. Tr. 24627 at 8,14-15; ff.

l Tr. 25614 at 91-92, 192-93.

In_ summary, the SPMC sets forth adequate procedures and criteria for

't'he generation of PARS, adequately incorporates ETE information into the PAR.decisionmaking process, and contains a range of possible protective actions which are suitable to the circumstances of the Seabrook site. NRC Staff P.F. 6.3.1-6.3.4 at 102.

Further, the SPMC contains adequate population distribution informa-tion and contains adequate procedures to provide for the notification of PARS to State and local officials'and the general public, and for'coordi-l' nation of PARS with the State of New Hampshire, NRC Staff P.F. 6.3.5-6.3.6 at 103, and PAR generation and execution during the graded exercise revealed no fundamenta*. flaws in the emergency plans exercised.

NRC Staff P.F. 6.3.7 at 103.

VII. Communications'/ Notification FEMA concluded that the Applicants have adequately described the ORO organization and the areas where it needs legal authorization and that adequate and necessary Letters of Agreement (LOAs) have been ext:cuted.

App. Ex. 43C at 10-12.

FEMA further concludes that the provisions in SPMC

., forcommunicationswithinORD,withotherorganizations(includingstates andlocalgovernments),withfederalagencies,withtheplant,for activating response personnel, and for communicating with medical support facilities are adequate. App. Ex. 430 at 29-34.

There are three methods for notifying schools of the emergency:

telephone, the sirens, and tone alert radios which will be supplied..Tr.

19015.

Initial notification of offsite authorities of an emergency at Seabrook does not rely on the commercial telephone network.- Such notification, including that of Massachusetts governmental entities, is madebySeabrookStationControlRoomviatheNuclearAlertSystem(NAS).

The NAS is comprised of various microwave-and leased telephone links and does.not rely on commercial telephone line availability. App. Ex. 42, Section 4.1.

The public notification system in Massachusetts does not rely on the availability of commercial telephone lines for primary communications.

Initial activation of the VANS operators at the VANS Staging Areas will be made by the Emergency Operation Center (EOC) Contact PointviatheVehicularAlertandCommunicationsSystem(VACS)which transmits a radio signal that activates an alarm system. Subsequent voice communicatfe s between t h Offsite Response EOC and the VANS Operator is via'the ORO Emergency Radio Network (ERN). App. Ex. 42, Section 4.5.

The graded exercise tested and verified the mechanics for notifying the appropriate parties to activate the siren alerting system. Tr.18312.

At the time of an emergency, Massachusetts State and local authori-ties will continue to provide the standard functions associated with a

police, fire and other public safety activities. The NHY ORO maintains the capability to communicate with State and local governments via the

l MAGI (MassachusettsGovernmentalInterface)radionetwork. The MAGI network operates on existing radio frequencies which are routinely utilized by Hastachusetts State and local response organizations.

Ff.

Tr. 27223 at 13.

During 1985 and 1986, NHY designed or redesigned, provided and installed many.of the primary communication systems now in use by many of the Massachusetts Public Safety entities that would be involved with a response to an emergency at Seabrook. The ORO MAGI system was designed to provide a communications link to these and other public safety entities.

The hardware components of MAGI were chosen and configured to allow compatibility and integration with these public safety communications systems. Accordingly, MAGI can be thought of as a " Gateway" mechanism allowing the MAGI radio operators at the EOC the ability to monitor the public safety activities taking place in Massachusetts, in the event it becomes necessary, due to the failure of primary communications paths between the ORO and Massachusetts Public Safety entities, MAGI will also allow a voice communications link to the various Massachusetts state and -

local public safety agencies.

Ff. Tr. 27223 at 13-14.

In summary, by following the SPMC procedures, the ORO satisfactorily communicated with all appropriate locations, organizations and field personnel during the-1988 FEMA graded exercise for Seabrook. NRC Staff P.F. 7.1.52 at 115.

The SPMC prvoides methods for the development, dissemination and coordination of emergency information.

Facilities and equipment for the media have been provided at the Media Center. With respect to accommodating the media, it is important to provide them accurate and

[

e 1 timely information, as well as reasonable access to authoritative sources of information. The Media Center functions and processes provide this type of information and access to official utility and governmental information without interference with response activities. Widespread dissemination (bothlocalandnational)ofnewsisassuredbecauseSPMC procedures require news releases to be provided to AP and UPI wire

[

serviccs.

SPMC at 5.6.7, 5.7.2.

Therefore, local and national broadcast media stations will have access to all news releases in a timely manner V

since virtually all TV and radio stations receive either or both wire services.

Ff. Tr. 27843 at 43.

In an actual emergency, PARS will depend on the risk to the affected I

public.

Recommendations to evacuate a specific population, for example, will depend on the existing and projected risk of exposure. That risk is location and time specific depending on meteorological conditions, distance from the release, and other factors concerning the status of response functions. These factors pertaining to risk were built into the 1988 exercise scenario. Thus, communities in New Hampshire might be evacuated sooner than communities in Tne Commonwealth depending on meteorological and distance factors. The 1988 Exercise scenario required

]

communities in New Hampshire to take protective actions sooner than communities in The Commonwealth based on the plume trajectory.

Conse-quently, EBS messages reflecting the PARS were issued sooner in New Hampshire than in The Commonwealth. This result was consistent with the exercise scenario and found to be adequate by FEMA. Ff. Tr. 27843 at 54.

EBS messages for Massachusetts are developed by the Public Informa-tion Staff in the EOC and are coordinated with the New Hampshire officials

. prior to final approval by the NHY Offsite Response Director. Overall coordination of EBS messages is further ensured by the fact that the Media Center provides a mechanism and a facility for representatives of the principal State, Federal ud utility response organizations to coordinate and interact on public information matters.

In addition, representatives oftheORD,theonsiteEmergencyResponseOrganization(ERO)andtheState of New Hampshire review all news releases and EBS messages at the Joint TelephoneInformationCenter(JTIC)priortodistributingthemtotheir staff. This provides another process for the review, coordination and correction, if necessary, of EBS messages and news releases. Ff. Tr.

27843 at 55 56.

Protective Actions for Particular Populations L

FEMA concludes that the SPMC provisions with respect to protective l

actions for schools, hospitals, and special needs populations are l

adequate. App. Ex. 43C at 38-39, 57, 60-6%, 64-65. Emergency planning for special facilities was hampered by the fact that a number of public and private institutions, schools, resource groups, hospitals and other l

institutions refused to participate in planning out of deference to the stand of the Governor of The Comonwealth against Seabrook. M. Tr.

18842-43, 18970, 18974, 19011. Where a nursing home or other facility would not cooperate, the planning basis for special needs vehicles was based upon estimates with the actual transportation requirements to be verified at the time of an actual emergency. Tr. 21369.

A listing in the SPMC of all presently known schools, special facili-ties and special populations in the six EPZ communities is reviewed and updated at least annually.

Ff. Tr. 21049 at 3.

Applicants have committed 1

l

o 28 -

to include the intervenor identified special facilities in the SPMC's listing and to update the data on day care centers quarterly due to apparent volatility of this segment of the special facilities universe.

Ff. Tr. 21049 at 3-8; Tr. 21637-43.

ML20043D690

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ML20043D690

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