ML20052F596
| ML20052F596 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 04/29/1982 |
| From: | NRC |
| To: | |
| References | |
| NUDOCS 8205130225 | |
| Download: ML20052F596 (83) | |
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PRELIMINARY DISCUSSION OF EMERGENCY PREPAREDNESS REVIEW PROCESS AND DEVELOPMENT
.a OF SCHEDULE OF MAJOR EMERGENCY PREPAREDNESS REVIEW MILESTONES f
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1 UNITED STATES OF AMERICA 1
2 NUCLEAR REGULATORY COMM!SSION 3
4 PRELIMINARY DISCUSSION OF EMERGENCY 5
PREPAREDNESS REVIEW PROCESS AND DEVELOPMENT 6
3F SCHEDULE OF MAJOR EMERGENCY PREPAREDNESS 7
REVIEW MILESTONES 8
9 Room P-114 10 Phillips Building 11 Bethesda, Maryland 12 Thursday, April 29, 1982 13 The meeting convened, pursuant to notice, at O
14 10:15 a.m.
15 NRC STAFF:
16 LOUIS WHEELER 17 ION McKENNA 18 NEMEN MICHEL TERC 19 S E A BR OOK (YANKEE ATOMIC ELECTRIC COMPANY):
l 20 JOHN ROBINSON 21 ROCCO MARCELLO 22 JIM MACDONALD 23 PUBLIC SERVICE COMMISSION OF NEW HAMPSHIRE:
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24 STEPHEN DODGE 25 PETER SIRICKLAND O
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MR. WHEELER:
Let's get started.
3 3R. McKENNA:
I think the first major 4 milestone - and this is Duke's - is that we have to get 5 r n SER out and knowing, typically, in emergency 6 preparedness these SERs stay open right up to the last 7 minute.
8 We close them out sometimes just a week or two 9 before we go down to the Commission and go for a license 10 because of thinos like FEMA's findings and 11 determinations which we generally do not get until after 12 they had the exercise, etc., or possibly closing out 13 rectain issues on the appraisal may wait until the last O
14. minute - delivery of certain pieces of equipment and 15 'his sort of thing.
The ICE goes out, the region goes 16 out, we we close out the issue, we are done.
17 But the idea is to close as many issues as we l
18 can on this coming SER, try to get as much of it done as 19 possible.
20 In the case of plans, realizing that is what 21 the SER addresses, I think we ought to be able to 1
22 accomplish a lot of it.
So, the ideal is that come SER 1
l 23 time, that we get as much of this stuff done as possible.
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24 Now, it looks likt I am supposed to have a 25 draf t on Eay 31, and Duke is going to try to publish it O
l ALDERSoN REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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1 on September 7 I do not think we will be able to do 2.too much by May 31.
3 MR. 'JHEELER:
The May 31 date is the date that 4 I plan to have the draft of the SER put together.
It is 5 going to be pretty much an in-house documen t.
The date 6 that I will need your input, Tom, originally was May 7.
7 MR. McKENNA:
Right.
8 MR. WHEELER:
That is only a draft SER for the 9 purpose of highlighting open issues and it is primarily, 10 as I sa y, going to be an in-house document for our use.
11 MR. McKENNA I guess what we need to decide 12 then, Duke - they have a lot of plan revisions to make.
13 I get the feeling from discussions with them that they
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l 14 have enough information in-house to answer a lot of this 15 stuff.
16 When can you get the revision to us, the plan 17 revision?
18 MR. M ACDON P.L D:
Well, do you need answers to 19 the RAI submitted to you and the plan revision, or just i
20 answers to the RAIs?
The answers to the RAI are. sooner i
21 than the plan revision.
22 MR. McKENNA:
But ultimately we need a plan 23 revision.
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24 MR. MACDONALDs Yes.
Before you make your 25 conclusions on the SER?
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1 3R. McKENNAs Yes, I need a plan revision.
2 Now, what we have done in other cases - and I 3 do not want to do it here, to be honest with you - is, 4 we have put in SERs that sa y tha t the licensee is 5 committed to do the following things, and the only 6 deficiency remaining is tha t these be incorporated in 7 the plan.
8 But we still have that final step, I still 9 have to do the review.
I will go that route, but I 10 would just as soon not.
11 HR. ROBINSON:
How extensive are these plan 12 revisions?
13 HR. MACDONALDs They are all over the plant.
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14 3R. WHEELERS The formal Safety Evaluation 15 Report is scheduled for publication in September.
So, 16 we have from not until than to get the plan brought up l
17 to speed.
If in the interim you wish to provide us with 18 specific answers to questions and explain your 19 intentions to revise the plan, that would be helpful to 20 us in our preparing our formal Saf ety Evaluation Report.
l 21 But by the time we 70 to press with the Safety 22 Evaluation Report it must be based on the plan itself.
23 MR. BOBINSON Jim, are there any hang-ups
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24 with the changes that have to be made?
25 MB. MACDONALD:
Just the physical process, (E)
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ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W, WASHINGTON. D.C. 20024 (202) 554-2345
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1 pouring through the plan; deciding on what we are 2 coimiting to, change-wise a nd make that change with 3 UENCF and have 300 copies, or whatever.
4 MR. ROBINSON There is nothing that 5 represents c major problem.
6 MR. "ACDONALDs When we go through the RAIs 7 and we will see some major problems.
But once it is 8 decided to revise the plan that is pretty 9 straight-forward.
I do not know what the time frame for 10 cranking in UENCF, for that kind of activity, is.
But 11 it is not that bad.
12 Certainly, by the time the SER actually is i
13 officially published we will have a plan revision.
O 14 MR. McKENNAs Let me -tell you what we did with 15 Paolo Verde and see if tha t might be a course of action.
16 We generated a list of questions just like 17 this.
The licensee said, "Ok, we will come up with our 18 course of action on each one, and then let's sit down 19 and talk about it before we go through the process of 20 revising the plan.
Let's go down and say what we are 21 going to do on every single one of them.
Hopefully, 22 that will cut out a lot of trouble with the plan.
23 MR. MACDONALDs That was my intention.
There 24 are quite a few of them already.
I do not know how we l
25 can do that.
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ALDERSON REPORTING COMPANY,INC, 400 V!RGINIA AVE., S.W., WASHINGION, D.C. 20024 (202) 554 2345
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MR. McKENNA I just found cut about it.
2 MR. MACDONALD:
We are prepared verbally to 3 answer a lot of those.
4 MR. McKENNA:
Why don't we plan on doing that 5 up there, then?
That is one of the things that would be 6 on that agenda.
I think that would be very helpful to 7 me.
8 MR. ROBINSON How soon could we set this 9 meeting up?
10 MR. WHEELER 4 How does May 20 sound?
It is a 11 Thursday, the third week in May.
That is the time we 12 are looking at as a possible date for the site 13 familiarization.
14 MR. McKENNAs I think we are going to need an 15 additional day for the meeting.
16 MR. WHEELER An additional day?
17 MR. McKENNA:
I think one day for the site 18 visit.
But I think we ought to give ourselves a whole 19 day for it, just in case.
20 MR. WHEELER All right.
21 1R. McKENNA:
So, the site familiarization on 22 the 20th and the mee ting the 21st?
23 MR. WHEELER:
Thursday and Friday.
24 MR. McKENNA4 Yes.
I mean, that is up to 25 you.
What do you t hink?
It is your schedule, I am O
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2 MB. WHEELERS I am 17ailable.
From your con tacts with FEM A,[ d'o you know whether or not they 3
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5 MR. McKENNAs They said tne 20th is all right t
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6 f or there.
We are going tc, invite Jijem for' the. site 7 visit so they will : tart getting in.on the process.
8 The 21st,' the last time I heard, anything 9 after something like,the 17tli is Good for them.
I will L,
r 10 call'and confirm, and if thereis any p ro bl em ', Duke and I will have to work it'[out with you folks.
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12 MR. MACDONALD4, We are going to have:a public the em'e',egency plan exercise some time the 13 meeting on x 14 week of May 17.
15 ME. McKENNA I do not want to get into apples 18 and oranges.
17 MR. MACDONAI;Dt I nention that beause FEMA has c
18 a scheduling problem becausp of that.
19 MR. M:KENNA:
They said sny time sfter the 20 17th was good for them.
That 'was the last' thing they i
21 worr.ied about.
22 MR. MACDONALD:
Well, who goey to the Seabrook 23 meeting from a FEMA ctandpoint?
24 MR. McKENNA:
I invited Ed Thomas, and I think i
25 he was going to invite.somebody from the counsel's O
ALDERSON REPORTING COMPANY,INC.
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1 office.
All I told them was, "It is just a site 2 familiarization.
It is a good time for you to see the 3 site and start working with us.
I think we are going to
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4 have to work very closely from now on on this thing."
5 I told him that he could bring a couple of I
6 people.
He said, "Well, I want to bring so-and -so, and 7 so-and-so, and so-and-so," and I said, " Wait a minute, 8 let's keep it small."
9 So, I think that was the only restriction.
I 10 said, "Let us know and we will get a hold of the 11 licensee."
12 MR. MACDONALD:
Well, Thomas certainly will be 13 involved in the Vermont Yankee public meeting.
O 14 MR. McMENNA:
I already talked to him.
His 15 schedule said any time after the 17th he could make it.
16 I have already asked him about the 20th and he said that 17 is good for him.
I have not asked im about the 21st.
18 MR. ROBINSON:
It seems to me probably the 19 21s t would be all right.
20 MR. WHEELER:
Perhaps we can have the all-day 21 meeting on Thursday, the 20th, and site familiarization 22 Friday morning.
23 MR. McKENNA:
That sounds good.
24 MR. WHEELER:
Do we see the site 25 f amilia riza tion taking all day?
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ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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1 MR. McKENNA.
Typically, two or three hours.
2 MR. WHEELER:
All right.
Let's work towards 3 scheduling that.
Rocky, if you can see about whether or
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4 not there is a meeting place where we can all get 5 together there at the site, I would say basically all' 6 day on Thursday, May 20.
And Tom, if you can get FEMA 7 cranked into this and see whether or not they can go by 8 tha t schedule.
9 MR. McKENNA:
I would ask Nemen to check up to there and see if they have any problems.
I am sure the 11 region is going, to wan t to participate, too.
So, if you 12 could check with our boy, George or somebody, to see 13 whether they have any problems with that date.
O 14 MR. WHEELERS All right.
The regional 15 representa tion, of course, there is always a resident 18 who can sit in for them if the region themselves are not 17 readily available.
18 MR. McKENNA:
All right.
19 What I would like to do is ask Duke here - we 20 have a September 7 date - when do you need my input into 21 the final, in reality, technical input due to project 22 managers?
23 MR. WHEELERS By the schedule you have in 24 front of you it is basically a month ahead of time.
I 25 don't recall the date.
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1 MR. McKENNAs So, August 7.
I will need the 2 plan revisions two weeks in advance.
So, I will need
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3 them by 4
5 MR. McKENNA:
The third week in July.
6 N ow, realizing - I know you cannot close 7 everything out because there will be a lot of open 8 issues, the interf ace is all set officially with this 9 kind of thing, the agreemen t letters, the centers met.
to Things like that may just be hanging.
11 MR. MACDONALD4 Procedures and equipment.
12 MR. McKENNAs Procedures and equipment all is 13 just going to be open.
What would be very helpful, I 14 think, in this process, if we started in the submittal 15 somehow or other trying to keep track of what you think 16 you have closed out and what you think you have not 17 closed out.
I do not know what you think about that, 18 there are a hundred and one issues.
I can keep track of 19 them.
20 MR. MACDONALDs Well, a simple way of doing 21 tha t is for us to provide a n answer either way on each 22 of those R AIs.
23 MR. McKENNAs With reference to the plan, that 24 would be great.
That would be great for me.
It also 25 would be helpful if it does get transferred to the
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ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGION, D.C. 20024 (202) 554 2345
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1 region, that would keep a nice paper flow for them.
2 But we in work that out.
In any case, I think 3 the important thing is, the third week in July what
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4 changes you can make.
Try to get as much as you can 5 done so we get that review.
And hopefully, at this 6 meeting up there we can identify soft spots.
7 I think we can discuss here today - I hope we 8 can discuss - scheduling issues.
In other words, the 9 centers.
I mean, there are some technical issues that 10 are going to take long-time planning and I would like to 11 be able to at least talk about that a little bit.
Maybe 12 you could run through the ones you are particularly 13 worried about, sche d uling -wise.
14 I can tell you where I think we are going and 15 what I think you need to do,and when you should have it 16 done to be able to get the process.
17 MR. WHEELER:
That is well within the scope of 18 this meeting to iden tif y those issues, that we must come 19 up with a schedule for resolving.
20 HR._ McKENNA:
Now, tha t is SER.
Realizing we l
l 21 have to close out all the open issues before the 22 licensing process is done.
Here again, emergency 23 preparedness, sometimes it goes right to the end, I oJ 24 realize that.
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25 MR. MACDONALD:
In other words, the SER may
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ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
12 1 carry a nusber of open issues.
2 MB. McKENNA:
Yes.
There will probably be
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3 several supplements on this thing and in emergency 4 preparedness these supplements may go right up to the 5 last minute.
6 Part of it is a conclusion of a typical 7 o pe ra tin g license SER, written early on in the game and 8 it identifies six items that typically are open.
That 9 will probably be open in this one.
I will give it to 10 you.
let me read them downs 11 One are the corrections of all the 12 deficiencies.
So, that is still an open issue because 13 the SER will identify anything that you have not closed 14 out.
That September SER is an open issue.
15 Submission of the state and local response 16 plans in accordance with 50.33.
17 MR. MACDONALDs Submission to NRC, or 18 submission by the states to FEMA?
19 MR. McKENNAs Submission of final plans to NRC 20 under 50.33 which says that you will submit so many 21 copies, and they have to be final.
22 So, that may be one that comes right up at the 23 last minute.
Or if they are not finals, there has to be
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24 a plan accompanied with some sort of letter agreement 25 that says, "Yes, we will implement this plan as it ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W., WASHINGTON, D.C. 20024 (202) 554-2345
13 1 stands at this point in time."
2 MR. MACDONALD:
You have the Massechusetts and
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3 New Hampshire plans right now.
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MR. McKENNAs All right.
5 All right, submission and satisfactory 6 evaluation of the emergency plan implementing procedures.
7 Now, the evaluation takes place primarily 8 during the appraisal.
But still, you have to submit the 9 procedures in accordance with the rule - I will give you 10 this, by the way - and we will have to look at it.
11 Now, the way we are going to look at it is 12 during the appraisal.
So, whatever findings come out of 13 the appraisal you will have to fix.
14 Next, there will have to be acceptable review 15 by FEMA of FEMA's findings and determinations.
So, FEMA 16 has to complete their offsite review, give us the 17 findings and determinations, and then we have to review 18 those, that all has to be cleared up.
So, anything as 19 far as offsite has to be done.
20 I think that may be - I am not sure - but that 21 may be one of our biggest scheduling constraints is 22 going to be the offsite review because FEMA is going to 23 have to complete that and the offsite plans have to be 24 done in time f or them to do tha t, for them to finish 25 their process which involves regional and headquarters O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554 2345 4
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MR. MACDONALDs right.
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3 MR. McKENNAs I do not know if you have seen 4 their rule, what is it, 44.3507 They have a lot of 5 steps.
There are a lot of steps.
There are several 6 pisces where more than one Federal agency gets involved 7 and they all have to have some comments and have to send 8 them back.
9 MR. MACDONALD:
It is a formal RAC Committee 10 review process, an exercise evaluation, public hearing, 11 what would be the finalization in the region, and then 12 submission to Washington with a recommendation.
13 MR. McKENNAs Right.
And when it comes to 14 Washington there is this Federal - whatever it is -
15 review committee that all gets a crack at it, and tha t 16 takes another month or two.
17 I au sure we can streamline that.
18 MR. MACDONALDs Let's talk about that a 19 minute.
How much of that has to be done before the NFC i
20 awards a fuel load low power physics test?
21 MR. McKENNA:
Tha t is a diff erent story.
That 22 is a different story entirely.
The policy on that - it 23 is my kowledge - the policy on that is not, I think,
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24 cast in concrete.
But my impression is, what we have 1
25 been doing, we get interim findings and determinations
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l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W, WI.SHINGTON, D.C. 20024 (202) 554-2345
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1 from FEMA and go on those.
We have those much earlier 2 in the game.
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3 The amount of planning that is required on 4 emergency preparainess planning, at least we used to 5 say, had to conform to old 101, something at that level 6 - not new 101 but old 101.
7 MR. MACDONALD:
That is the licensee plan.
I 8 am talking about offsite.
9 MR. McKENNA:
Like I said, interim findings 10 and determinations.
Oh, boy, San Onofre, I wish John i
11 had stayed, John could answer his questions.
Maybe I 12 will see if I can get him over here because he just went 13 through, exactly through that with the folks out in O
14 California.
15 MR. MACDONALD4 For San Onofre?
16 MR. McKENNA:
And basically on offsite they 17 were looking for s point of contact, somebody that you 18 would contact if som'ething did happen, and this person 19 had the authority and sponsibility to go ahead and start l
20 taking actions.
Basically, the warning system would be l
21 d oo r-to-doo r.
But somebody you could get a hold of 22 quickly who could do it, and some kind of assurance that 23 he would sta rt acting on it.
24 Now, that is my recollection.
What I would 25 like to do on that when we get a chance, let me call O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGION, D.C. 20024 (202) 554-2345
16 1 John and see if I can get him over here and he can go 2 through t h a +. for you.
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3 dR. MACDONALD:
As I understand it, there are 4 different licensing milestones associated with fuel load 5 versus a full-power operating license.
6 MR. McKENNA Right.
7 MR. MACDONALD:
I mean other regards too, but 8 certainly in this emergency plan to determine offsite 9 preparedness, conclusion by FEMA.
10 MR. McKENNAs You are right, and I have not 11 been through one.
So, everything I have is hearsay.
12 MR. MACDONALD:
As a matter of f act, it is a 13 little unclear as to whethe r an exercise is required O
14 before the fuel load license.
15 MR. McKENNA:
Exactly, I think you are right.
16 As I said, I do not think there is a piece of paper that 17 says exactly what is required.
Let me take two seconds 18 and call John to see if I can get him over here because 19 John has been through one.
I 20 MR. WHEELER:
All righ t.
You want to take 21 about three or four minutes to make a phone call?
22 MR. McKENNA Yes.
l 23 MR. WHEELER:
All right, fine.
24 (Discussion off the record.)
25 MR. WHEELER:
Back on the record.
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l ALDERSoN REPORTING COMPANY,INC.
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1 XP. McKENNA:
John said that we do not need 2 him, he can give me the story.
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3 There is not a set policy because you have to 4 apply for low power.
When you apply for a low power, 5 there has to be a hearing on that low power just 8 addressing tha t issue.
So, contentions will be raised 7 concerning the low power license.
8 So, one thing that has to be addressed are 9 those contentions.
Now, the major point of it is that 10 it is the staff's position that for a low power because 11 of the low fission product inventory in the core at that 12 time, that you have a lot of time to do things.
13 So, all those emergency preparedness things O
14 that are designed for prompt action do not necessarily 15 have to be addressed at that stage because we have 18 studies that indicate that you have 10, 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> before 17 there will be a release from the time you lost coolant, 18 a major release.
19 So, that is the way we have been looking at 20 it.
So, for California, for instance, John said that 21 the staff was not requiring sirens, they were not 22 requiring an exercise.
In one case they did not have 23 findings and determinations from FEMA but they were O
24 criticized by the Commission in that case.
25 MR. MACDONALD:
Another case you nean, not San O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W., WASHINGTON, D.C. 20024 (202) 554-2345
18 1 Onofre?
2 MB. McKENNA:
Yes, tnat was another case.
At
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3 San Onofre they did have interim requiremen ts and 4 determinations from FEMA, mainly just addressing those 5 issues that, again, do not require prompt action.
6 When you think about it, primarily governments 7 are already set up to deal with these kinds of things 8 now.
So, that is not a major issue.
However - and this 9 may be the toughest part - the staff has felt it 10 appropriate to have an appraisal, onsite appraisal, to 11 actually see what you have on site to be able to handle 12 onsite problems.
13 So, we would have an appraisal that would take O
14 you up through to look at those items that would be 15 required for a low power license.
Now, I do not know 16 how to define that for you at this poin t, but that would 17 be the process.
18 So, you apply.
There will be con ten tions.
We 19 vill have to address the contentions at the hearing.
20 So, that is one unknown.
21 MR. WHEELER:
With regard to contention s, the 22 pehearing conference on May 6 and 7 is for two 23 purposes.
Number one is determining the petitions' 24 s ta nding, and to determine what contentions will be 25 admitted into the proceedings.
O ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D C. 20024 (202) 554 2345
19 O-1 So, I expect at the end of that prehearing 2 con f e rt to have a pretty good idea of what the 3 emerger redness contentions will be; that is this 4 May 6 5
MACDONALD:
Duke, have potential l
6 interve >rs filed potential contentions?
7 MR. WHEELER:
Yes.
And emergency preparedness 8 issues do appear in several of the petitions.
9 MR. MACDONALD:
Rocky, I trust we have a copy 10 of that.
11 MR. WHEELER:
Tom, where in the sequencing of 12 things should the onsite appraisal appear, between what 13 and what?
O 14 dR. McKENNAs It sounds to me like if they 15 want a low power that the appraisal will have to take 16 place before that.
But I am looking at Nemen since the 17 appraisals are a regional responsibility.
My guess is 18 that when you start getting close --
19 MR. TERC:
What dates are we talking about?
20 MR. McKENNA:
I don't know.
21 MR. WHEELER October '83, I believe, is the 22 date scheduled for the licensing Board initial decision.
23 MR. McKENNAs Then you work back.
You don't 24 vant to have a Salem.
We had the appraisal about a week 25 or two before they wanted the license - I don 't know O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D C. 20024 (202) 554 2345
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1 what it was - and then they hired 60 guys who put up a 2 tent and started working on revising the emergency plan
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3 to correct that.
4 So, give yourself time to get things fixed..
5 MR. MACDONALDs That's right, that is what we 6 are trying to do.
7 MR. McKENNAs Right.
So, I think what it is, 8 as soon as you are ready, what you da is, you tell us 9 when you want the appraisal.
10 MR. MACDONALDs All right.
11 MR. McKENNA:
Now, realizing that you might 12 vant a low power, so you might want to do it as early as 13 you can.
But if you go too arly and find a lot of 14 stuff, you know, you are going to have to balance it.
15 MR. TERC4 In the next meeting, whenever we go 16 with this issue, if you will like to hear some hint as 17 to how to go about doing it right from the beginning, if 18 you have not done it maybe we can talk about it.
19 MR. WHEELER All right.
20 MR. TERCs Where the emphasis should be.
21 MR. McKENNAs You mean on preparing for the 22 appraisal?
23 MR. TERCa On preparing for the appraisal.
O 24 MR. McKENNA:
Right.
l 25 MR. WHEELER:
I will make a note of that as
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ALDERSON REPORTING COMPANY,INC.
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1 one item to be covered at a future meeting.
2 MR. TERCs That's right.
(}
3 MR. MACDONALD:
Why is that?
That is not 4 allowed here?
5 MR. WHEELER:
We don't want to get into the 6 details of the onsite appraisal, what it is going to 7 involve, what is required, and this sort of thing.
8 Right now, for this discussion, I would just like to get 9 into determining when, at least a time frame for having 10 the onsite appraisal.
11 If there are some things that you want to 12 discuss regarding the onsite appraisal, at least tell us 13 now what those things are and we will make sure they get 14 put into the agenda for the next meeting.
15 MR. MACDONALD:
Well, tne only item we had in 16 regard to NRC appraisals was what the plan was for 17 conducting an appraisal at Seabrook.
Was there indeed 18 going to be an appraisal before either a full power 19 ope ra tin g license or a low power testing license.
i 20 MR. McKENNA:
I would say the answer is yes to 21 both - although, talking to John you probably, if you go 22 for a low power, you probably will end up getting two 23 appraisals.
You will probably get the original 24 appraisal for the low power and then it sounds like 25 maybe later on we will come back and fill in the gaps O
1 ALDERSON REPORTING COMPANY,INC.
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1 that were left on that appraisal.
You migh t get two.
2 I am just guessing, I do not know.
[]}
3 MR. ROBINSON:
This would mea n, then, we have 4 this low power appraisal prior to October '83?
5 MR. WHEELER:
Yes.
6 MR. McKENNA:
My quess is, just t hin: ting about 7 it, the region always goes back to check deficiencies.
8 MR. TERT:
I don't see why they need two 9 appraisals.
10 MR. McKENNA:
You get one appraisal, and then 11 in another visit to check the things for close-out.
12 MR. TERC:
The_ follow-up, yes.
13 MR. McKENNA:
And the question that will be 14 raised by the first appraisal is, are the deficiencies 15 identified sufficient enough to prevent a low power 16 license.
If the answer is yes, then it will prevent a 17 low power license.
If it is not, then those can be 1
l 18 fixed when the region goes back to check.
That is l
19 probably the way.
20 MR. WHEELER 4 Tom, would two months before the 21 Licensing Board initial decision, would that give us 22 adequate time for the onsite appraisal?
l l
23 MR. TERC:
In order for them to get the report 24 and to work on the items, I don 't know how much time 1
25 they want to cive it.
But you should think of times of
()
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1 at last six weeks, four to six weeks, from the time we 2 have an appraisal onsite and we issue the report.
3 MR. MACDONALDs That sounds rather optimistic.
{}
4 MR. TENC:
That 's correct.
5 MR. WHEELER:
Then I would say, to allow for 6 scheduling uncertainties, he says four to six weeks.
7 Let's tentatively schedule eight weeks, let's say about 8 two months prior to the Licensing Board initial decision.
9 MR. TERCs That would be best, yes.
10 MR. MACDONALDs That is just to get the report 11 to us.
12 MR. McKENNA:
Then you have to fix the stuff.
13 MR. TERCs They have to work on it.
(
14 MR. MACDONALD:
And reply to you.
15 MR. TERC:
The findings on the appraisal would 16 depend on the amount of work, of course, that you do 17 before the appraisal.
That is what we want to talk l
18 about in another meeting in order for you to go in the
(
19 right direction.
I am sure that is what you want, the 20 minimum number of findings.
21 MR. MACDONALD:
Right.
22 MR. WHEELER:
When does the region recommend 23 that we actually conduct the onsite appraisal?
}
24 MR. TERCs I cannot answer for the region 1
25 because I don 't know.
The appraisals that I have been
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2 84 O
1 involved with have not been in the process of licensing.
2 MR. McKENNAa If it helps you at all - and 3 this is totally off the cuff - this is what Region 3 4 did.
Zimmer tried to get an early appraisal, they 5 wanted to get started.
It was almost as if they wanted 6 us to do an audit on them so they knew what they did to 7 do.
They did not want to do too much.
8 The region said, "No, we are going to come out 9 there about a month before you think you are ready for a 10 day and just look around.
But if we don't think you are 11 ready we are not coming.
We are not going to waste our 12 time."
13 So, I suspect that I would not be surprised if 14 Region 1 might want to do the same thing.
15 MR. TERCs Yes.
16 MR. McKENNAs They are not going to want to 17 come out there and waste their time with all that 18 manpower and effort until they think you are fairly 19 ready.
l 20 MR. MACDONALDs I can appreciate that.
I 21 wonder how they are coing to get the feeling on whether 22 we are ready or not.
l 23 MR. TERCs You tell us when you are ready.
O 24 MR. MACDONALD They have a resident.
25 MR. ROBINSON:
It looks like we are talking, O
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1 probably, f our months prior to the initial decision to 2 make sure we have time to correct any deficiencies.
(}
3 MR. WHEELEBs All righ t, f our months before 4 the initial decision would be June of
'83.
Perhaps we 5 could schedule the 1st of June for a preliminary visit 6 to determine the ntatus of preparations.
I 7
3R. McKENNA:
I don't think we want to talk 8 for the region.
9 MR. WHEELER:
No, I am just proposing.
10 MR. TERC:
I would say sometime in July, but 11 it would be subject to scheduling from the people who do 12 the scheduling.
13 ER. WHEELERa OK, we are here to identify the 14 best times.
15 MR. TERC:
Yes, July would be a good time.
16 MR. WHEELER:
Subject to approval by the 17 region for their involvement.
18 MR. TERC Yes, right.
19 MR. McKENN A:
It would be good if we could get 20 this, get it out to everybody and have everybody look at 21 it.
22 MR. WHEELER:
All right, we will just say 23 mid-June for a preliminary visit, mid-July for the 24 full-blown apprsisal.
25 MR. McKENNA:
Are you getting all this?
O ALDERSON REPORTING COMPANY,INC, 400 VIRGLNIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554 2345
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MR. TERC:
What is a preliminary visit, what 2 does it consist of?
I have no idea.
()
3 MR. McKENNA:
I guess what Namen is saying, I 4 don't think the region thinks they need that.
They will 5 just check with the resident and if they think they need 6 to go out and look, they will go out and look.
7 MR. WHEELER:
After we publish this schedule 8 they can give us their feedback.
9 MR. McKENNA:
I would just say July for the 10 first, that is good enough.
11 MR. DODGE:
How far in advance are the 12 procedures needed, prior to the appraisal?
13 MR. TERC:
Prior to the appraisal?
I would 14 say you should have your procedures in our office within 15 three weeks befora.
16 MR. D0DGE:
Three weeks?
17 MR. WHEELER:
Call that the last week in June.
18 MR. TERC:
The last week of June?
19 MR. WHEELER:
Yes, we are talking about 1983.
20 MR. EcKENNAa Realizing, too, tha t things like 21 training will have to be completed also, for the 22 sppraiss1.
23 MR. MACDONALD:
Training would have to be 24 completed st the time of the appraisal, is that what you 25 just said?
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27 O.
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1 MR. McKENNA4 Yes, because we walk through 2 people.
At least some of it will have to be completed, 3 correct.
4 MR. TERC:
Well, the appraisal includes 5 valk-throughs, provision of training records, as you l
6 know.
You have an instruction for that.
t i
7 MR. WHEELER:
Does the governing regulation 8 rule on this appraisal, specify what must be done in the 9 way of training prior to the appraisal?
10 MR. TERC:
I believe that if you look at the 11 technical Instruction 25.1555 - I think it is - that 12 outlines all the different' areas that you should have, 13 the questions that will be asked.
14 MR. MACDONALD Well, this is a dif ferent 15 animal, an appraisal of a new operating plant with a new 16 set of procedures and a new training program, etc.
I am 17 just wondering what kind of guidance exists within the 18 NRC for conducting the appraisal f or an animal like that.
19 MR. TERC:
You are right, that is a different 20 animal.
I cannot talk in terms of operating plants.
21 MR. MACDONALD:
An appraisal plan would be 22 provided on it.
We know what the appraisal consists of 23 there.
24 MR. McKENNA:
I know on other sites we have 25 been using essentially the same document, there has not O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINTA AVE, S.W., WASHINGION, D.C. 20024 (202) 554-2345
20 1 been any change there.
But I think the question that 2 might be raised here is because with a plant that is
()
3 going to be coming up you are coing to be doing training 4 right up to the last minute.
5 How are those types of things going to be 6 accomodated by the appraisal team?
That sounds like an 7 issue for, maybe, the next meeting because Nemen can cet 8 back to his management and find out.
That is a good 9 question.
10 That is right, you will be doing stuff right 11 up to the la st minute.
j 12 MB. TERCs What did you sa y, you would need 13 July, August, September to do the training?
)
14 MR. McKENNAs Well, see, they will be-training 15 right up to the inst minute, hopefully, so that at the 16 point they start operation evarything will be complete 17 and they will be ready to go.
18 I think the issue'is, it is not very 19 appropriate to have them have all their training 20 completed four months in advance, five months in advance.
21 MR. MACDONALD:
Really, the training is 22 dictated by the timing required for an exercise to be 1
I i
23 conducted.
l 1
24 ER. McKENNA:
That will be another issue, 25 right.
l C:)
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1 MR. MACDONALDs So, if indeed we are required 2 to have an exercise prior to fuel load, then the
(}
3 training program is going to be scheduled to support 4 that.
5 MR. TERC:
Yes.
6 MR. MACDONALD:
We will be holding off an an 7 exercise to the time frame between fuel load and full 8 power operating license which might be what, six months?
9 MR. McKENNA:
John told me - Sears - that they to did not require an exercise at the California plant 11 before low power.
So, right.
12 But still, there will be a certain amount of 13 training we will have to check.
There is no question 14 about that.
15 MR. ROBINSON:
Maybes a subject for this next 16 discussion is identification of the issues that the area 17 region will be looking at for this low power license.
18 It might ba that the training of the HP Department and 19 the operators might not include all the offsite dose 20 assessment and the rest of it.
We can identify the 21 specific issues.
22 MR. TERC:
How long will you have that lov 23 power license?
Do they go into a high power license 24 afterwards in a few months?
25 MR. WHEELER:
Yes.
Now, a low power license ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
30 1 is just based on the Licensing Board's initial 2 decision.
The ful power license requires, of course,
{}
3 Commission approval.
Our record to date with low power 4 licenses has been that it says generally some small 5 number of months between the two.
It will be driven in 6 large part by the applicant's schedule.
7 The issueance of licenses will be timed, among 8 other things, to ensure tha t there is no dealy in 9 loading the fuel and ul tima tely going commercial which, 10 I think, is now scheduled for February
'84.
11 MR. R3BINSONa It is my understanding that the 12 low power is going to be tied to five percent, exceeding 13 five percent power?
O 14 SR. WHEELER:
The low power licenses to date 15 have limited operations, core power, to less than five 16 ercent.
The purpose of the low power license is to at 17 least allow the loading of the fuel and some testing 18 that can be done at less than five percent power.
19 This involves a fair amount of time, we 20 recognize that.
It allows this to take place while we 21 are in the process of closing out those final issues 22 tha t need to be closed out prior to the full power 23 license.
24 HR. McKENNA:
And from an emergency planning 25 standpoint, I guess the most important thing to realize
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1 is, Nemen, that we looked a t it and it takes about 15 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> at those power levels.
It takes about 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> 3 before you get into a core-melt type situation and you
{}
4 lose your systems.
So, there is a big difference 5 between that ind 1 fully operating plant.
6 So, whatever has to be done real quickly might 7 not have to be looked at.
8 MR. TERC:
I do not know how willing the NRC 9 is to go back.within six months and do another a ppraisal to of the same plant.
We will have to compromise somewhere.
11 MR. McKENNA:
Let's take a look.
I will bring 12 it up with my guys and you can bring it up with your 13 guys and then they can get on the phone.
That sounds O
14 great.
I think we are making some progress.
15 Where am I?
OK, I am going to continue 16 through my little list here.
17 Acceptable findings of an onsite appraisal to 18 astablish that the applicant plant is capable of being 19 implemented.
20 MR. WHEELER:
We set July to actually conduct i
l 21 the onsite appraisal.
I 22 MR. McKENNA:
Tentatively.
23 MR. WHEELER:
Of course.
(
l 24 MR. McKENNA:
Right.
l 25 1R. WHEELERS Let's say, August to September O
l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGION, D.C. 20024 (202) 554 2345
32 O-1 for findings.
Did you not say it would take about four 2 to six weeks to produce the documents?
()
3 Publication of findings, September
'83.
4 MR. McKENNA:
And that would have to be filed 5 by the region to ensure that the fixes have been made.
6 I do not know typically when you do that either.
7 MR. TERCs I'm sorry.
8 MR. McKENNA:
That the findings to the 9 licensee will be followed by a visit by you folks to 10 ensure that it has been fixed.
I do not know when that 11 is done.
12 MR. TERC:
Well, the f ollow-ups a re based on 13 the 120 days.
14 MR. McKENNAs In this case that does not apply.
15 MR. MACDONALDs This is different.
16 MR. McKENNA:
This will have to be fixed 17 before.
18 MR. TERCs So, what I am saying is, that is 19 usually the case in an operating plant.
However, when 20 the plant is in the process of refueling or maybe in 21 your case of fueling, it will be before or prior to which is another way of meeting the 22 sta rt-up 23 requirements before you start up.
O 24 MR. MACDONALD:
Well, time-f rame wise we are 25 potentially talking about the document we need for O
l ALDERSoN REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
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1 permission to load fuel coming out of the NRC in October 2 of
'83.
3 MR. McKENNAs When you are talking October '83 4 you are not talking full power license?
5 MR. MACDONALDs Loading fuel.
6 MR. McKENNAs Loading fuel.
So, when do you 7 expect to go to the Commission for full power?
8 MR. WHEELER:
We tentatively have scheduled a 9 Commission decision in November of
'83.
10 MR. McKENNA:
That may not be full power.
11 MR. MACDONALDs Well, is someone here familiar 12 with what we are applying for right now?
We have filed 13 the FSAR as an application for a full power operating O
14 license.
15 MR. WHEELER:
Right.
You have ultimately 16 applied for a full power license.
In our licensing 17 review we will make a determination on the full power 18 license.
The matter of a low power license is just an 1
{
19 intrim step.
It is an option which we have found to l
1 20 make much more efficient use of our time and to 21 substantially reduce delays at the end of the licensing 22 process, delays attributable to regulatory j
23 considerations.
24 After the Licensing Board issues their initial 25 decision we do go ahead before the Commission gives a l
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1 decision.
We do go ahead and give at least a low power 2 license.
It allows you to take the fuel off the
{)
3 railroad car snd put it into the vessel.
4 MR. MACDONALD Yes, but you do not award that 5 automatically.
6 MR. WHEELER:
No.
7 MR. MACDONALDs Are you sa ying we have to 8 apply for that?
9 MR. WHEELER No.
You come in and ask for a 10 low power license -- correction, you come in and ask for 11 a f ull power license.
12 MR. MACDONALDs Which we have done.
13 MR. WHEELER:
Which you have done.
14 MR. HACDONALD:
And your licensing review is 15 proceeding on that basis.
16 MR. WHEELER:
Is proceeding on that basis.
If i
17 it appears that you will get a full power license based 18 on the Licensing Board's initial decision, then at the 19 time of tha initiil dsecision we issue a low power 20 license to allow you to proceed with loading the fuel 21 and doing some ini ti al testing until such time as we l
22 complete the final hearing processes and the Commission i
23 authorizes a full power license.
24 MR. ROBINSON:
You know, it almost looks like 25 we should be looking at the October date as the full O
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1 power license for the purpose of gettinc our end of t r.e 2 e me rgency planning out of the.way.
3 MR. TERCs Yes.
~
4 MR. ROBI!ISON:
I ha(e to see us reach October s
m 5 and find out we'have a fg11, power. license and then ha'e 6 to hold'back because we have.not completed the emergency s-7 plan.
p t
8 MR. WH E E LF.R i-WE1Y,'I ce'Etuinly don't,.
9 anticipate a full power license in October.
'Our' i
w 10 Commission decision'is not s'cnedulsd until November.
11 That Cogmitision decision is req'uired for'sthe full power s
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k 12 license.
. ~
13 M9.
aaAs 71.e re migli ts, bet tissues that m Hht u
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y 14 be hanging and you might ge t siOl-k.
15
'M R. W' HEELERS' All tight, go f r Nov, ember' ar
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16,the full power license'uate/;% fin s '.'
17 MR. McKENNA:. 50, these> dates that are goo:1, "i.
I N
18 try to,, d o ss much as yod,caA.
MR.MACDONALD$\\
Oh, yes.
19 20 MR. McKENNAs' Idsuess th ro ugh o ut the low power 21 discussion, that is jpst confusing.
s s
'22 1
MR. MACDONM.Dt,That confused us, yes.
That
'.l 23 means exercise scheduling.
and plans, and FEMA review, O
24 and findings, etc., should be geared to a Novembre '83
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25 full power operpting license.
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1 MR. WHEELER:
Yes.
That would be the 2 conservative approach.
(}
3 MR. TERC:
In practice, also I have found that 4 it is harder to fix emergency plans and procedures that 5 started in the wrong direction, than to get them right 8' f rom the beginning.
So, I think you should aim because 7 it is really a hassle to try to fix emergency procedures 8 because they are all interacting with each other, after 9 you have done thes the first time.
10 So, it is better to shoot for a good set of 11 procedures, plans and equipment and so forth.
12 MR. MACDONALD:
Do it right the first time.
13 MB. TERCs Yes, do it right the first time.
14 MR. McKENNA I think maybe we can work out 15 some kind of way we can get a dialog going between them 18 and the region, on-going, on this thing because you are 17 sort of pushing two things.
You are pushing the plan 18 which is sort of us, right now; and then you are pushing 19 the appraisal which is the region.
So, I think you 20 should keep both of us informed of what is going on.
'21 I do not know quite how to do that because it l
22 has not been done in the past.
But mainly, we have not 23 been in this kind of situation bef ore in the past, I
l 24 either.
l 25 3R. WHEELERS I see no reason why they cannot
(
l l
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGT.ON, D.C. 20024 (202) 554-2345
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1 prepare correspondence to the region administrator with 2 myself as copy addressee; or for that matter, why you 3 can't have two principal addressees, address it to the
( )
4 region and address it to ayself.
5 MR. McKENNAs I think in this case that is 6 appropriate - on everything, plans, anything.
I think 7 both people should get it because what the roles of 8 people are is not clear.
9 MR. WH EELE R:
All right, let's do that, then.
10 Any of your correspondence that comes to the NRC, 11 related to emergency preparedness, address it both to 12 the headquarters here and to the regional adminitrator.
13 MR. McKENNA:
I am just tryino to think.
All O
14 richt, then the last step is going to be the exercise 15 and in fixing any deficiencies identified.
16 Now, a long time ago I sat down and thought 17 about exercises, and FEHA's findings and input, and all l
18 that sort of thing, and came up with a little bit of a 19 schedule.
20 I hate to speak for FEMA at this meeting.
I l
21 was hoping somebody from FEMA might be here but they did 22 not show.
But as a working, talking document, let's 23 draw up soie dates, let's put them down and send them l
l 24 off to FEMA as part of this whole package and hopefully 25 we can get FEMA, maybe, to discuss it at that meeting up CE) l l
ALDERSON REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W., WASHINGION. D.C. 20024 (202) 554-2345
38
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I there.
We will try to aske them a participsnt in that 2 meeting.
{}
3 MR. WHEELERS On this you are talking about 4 the evacuation drill?
5 MR. McKENNAs Yes, the exercise - say 6 " exercise."
7 MR. WHEELERS Yes, I understand.
8 MR. McKENNAs Please.
9 (Laughter.)
10 MR. McKENN'As Please, say " exercise."
11 All right, let me throw out some dates that 12 Jeal with offsite planning.
These, I have to stress, 13.tre my dates, they are not FEM A 's dates; they are not 14 anybody else's dates.
They are in there just for 15 discussion purposes and we should transmit them to FEMA, 16 probably, as a point for starting discussions, something 17 lik e that.
18 It looks to me like the exercise has to happen 19 in August of
'83.
The reason being, it will give them 20 one month to get their findings to us.
So, that gets 21 them to us by September.
That gives us a couple of 22 months before we go down to the Commission.
23 So, I would say, FEMA's findings to us by 24 9-83; exercise complete by 8-83.
Backing off from that 25 with the hearing scheduled for March I am sure that O
l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
39
()
1 formal testimony will have to be filed, probably, in 2 February.
With formal testimony filed in February, FEMA
()
3 will need - depending on what contentions are admitted 4 they are going to need a certain amount of draft plans 5 so that they can address thoca contentions.
6 So, my guess is, somewhere around September, 7 the fall of this year, they are going to start needing 8 certain planning documents from state and local 9 governments.
10 Now, I do not want to say that they are going 11 to need a complete set of plans, but depending
- on what 12 the contentions are, some time this fall they are going 13 to have to start getting stuff to be able to start O
14 preparing because it is going to take them a while to 15 review it.
16 That is just the big picture the way I look at 17 it right now.
Now, it is my understanding that in 18 discussions with FEMA -- maybe it was with iou, Jim -
19 that maybe local plans are supposed to be done about 20 this fall.
21 MR. MACDONALD:
That is true.
22 MR. McKENNA:
All richt, so, quick picture.
23 I also understand that we are not too Oure 24 what is going on with state planning ani I am going to 25 pursue that.
I think that would be a good topic for O
ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345 1
40
(
1 discussion up there at the meating.
We will invite FEMA 2 and see if we can discuss scheduling of the state and
(}
3 local planning efforts, and these milestones I just 4 discussed.
5 I think what we should probably do is write so 6 that FEM A is not caugh t unaware, that we write them a 7 little meno explaining what we would like at that 8 meeting and see if they are willing to participate.
I 9 am sure they are willing but will they be ready to 10 discuss that.
If not, we might have to schedule a 11 separate maeting.
That is another topic, is this 12 schedule I just propoed.
13 That's it.
I do not know what else to say.
O 14 MR. WHEELER:
To review the last point, then, 15 ve are saying fall, and I just arbitrarily wrote down 16 October.
Ihe two local plans completed and submitted to 17 NBC - or we will say local plans completed and made 18 available to FEMA.
19 MR. MACDONALD:
Yes.
I 20 MR. McKENNAs Made svailable to FEMA.
l 21 MR. MACDONALD FEMA needs then.
22 MR. McKENNA:
They need them, not NBC.
l l
23 MR. MACDONALD:
Not NPC at that point.
I 24 MR. WHEELER:
All right, available to FEMA.
25 MR. McKENNAs We ultimately need them on the O
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1 docket, but that can be well down the road.
What has to 2 happen at the hasring stage is that there is suf ficient 3 information available for them to address the 4 con ten tion s.
It is going to be one of these things 5 where on one issua all we need is s drsft of a plan, and 6 the next issue we might need a draf t of specific 7 procedure.
There are going to be all sorts of this kind 8 of thing going on.
9 But there has to be enough.so the testimony 10 can be placed in the record that clearly shows that 11 while the issue may not be resolved, it is resolvable 12 and a course of action has been identified that will fix 13 it in time for the licensing.
Those are typically the
()
14 steps involved.
15 So, it is going to be tough.
As soon as we 16 get the contentions we will probably be able to do a 17 better job of deciding what needs to be done offsite; 18 after that, formalizing.
19 But I would like to start talking about that 20 with FEMA, that would be a good topic, I think.
21 MR. WHEELER:
Does anybody else have any 22 particular issues they want raised here with regard to 23 working them into the schedule?
If not, what I propose 24 we do is take about a tan-minute break.
I am going to 25 review my notes and come out with the schedule that I C) t l
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I think we worked on here.
I will write it on the 2 blackboard here and we can all look at it and see 3 whether or not it is what we think we have said.
We may
(])
4 vant to make some adjustments.
5 And then also come up with the list of those 6 things that I heard we want to discuss at a future meeting at the site.
8 MR. McKENNA4 Before we do that, if you want 9 to make a list I think all we have had is a few of 10 them.
I think we want to talk about centers in additon.
11 MR. WHEELERS Sure.
All I am saying, let's 12 take about ten minutes and get my thoughts up on the 13 board, and then go from there.
O 14 (Whereupon, at 11:15 a.m.
a short recess was 15 taken.)
16 NB. WHEELER:
All right, I will read what is 17 on the board.
It represents the schedule that we have 18 developed here.
19 First of all, for the remainder of 1982, May 6~
20 and 7, prehearing conference, which will be up at 21 Portsmouth.
The Licensing Board there will determine 22 the emergency preparedness contentions.
23 The third week in July we get answers from the 24 utility on all open issues and answers in the form of 25 plan revisions.
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1 In September I will publish the Safety 2 Evaluation Report.
3 October of 1982, the local and state plans are
()
4 complete and made available to FEMA.
5 In 1983, the fourth week of January, FEMA and 6 the NRC file formal testimony in preparation for hearing.
7 In March, the hearings will begin.
By the 8 fourth week in June we will need the emergency 9 preparedness procedures submitted to the NBC.
10 In July will be the formal onsite appraisal.
11 August will be the exercise.
In September the exercise 12 results sent from FEMA to the NBC.
And the first week 13 in October we resolve all of the open items that are O
14 still with us, relating to the plan t, the a ppraisal, and 15 the exercise.
And October is the licensing Board 16 initial decision.
17 MR. McKENNAs I see one thing we lost.
18 3R. WHEELER:
All right, we will bring it up 19 in just a.tinute.
20 Over there on the right side of the board are 21 just a few extracts of my notes on things that I thought 22 ought to be discussed at a future meeting at the site.
23 Number one is onsite appraisal, both the plans 24 and the requirements.
We did talk about the needs to 25 delve into tha t further.
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1 A review of the exercise dates, and scheduling 2 of the state and local planning efforts.
(}
3 Now, taking a look at this is a rought draft 4 of what we are trying to produce here, what adjustments 5 are appropriate.
6 MR. ROBINSONs We lef t out the NRC appraisal 7 report.
That would be some time in September, would 8 it?
9 MR. McKENNAs I think that was that other, to that one, that I had you erase.
11 MR. TERC:
Also, we left out the NRC exercise 12 results and the reports, the FEMA snd NRC, two different 13 reports.
O 14 MR. McKENNA Why don't we just nahe it "and?"
15 MR. TERC:
Yes.
16 MR. McKENNA:
That was easy.
17 MR. WHEELERS Say again the right words that 18 belong in he re.
19 MR. McKENNA Appraisal, issue appraisal 20 report.
21 MR. WHEELERS All right, in September of
'83, 22 issue the appraisal report.
23 MR. MACDONALD:
And then you have to resolve
)
l 24 the apptsissl report findings in the first week of 25 October?
I think we have to back up from that one.
We i
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1 need more room between the issuance of the appraisal 2 report and the resolution of leficiencies.
3 MR. WHEELER:
Good point.
4 MR. ROBINSON:
If we could back up a month.
5 MB. WHEELER:
Tom, if we specified here the 6 first week of September, that would give us essentially 7 a month from the first week of September until the first 8 week of October.
Will that work, taking a look at it?
9 MR. TERC I don ' t know, it depends on the 10 number of findings that we htve.
11 MR. McKENNA:
They may need a lot of time.
12 Especially, you see what happens is - let.me tell you 13 what happens.
We will find a procedural problem or we O
14 will find an equipment problem.
That will require a 15 procedureal change which will require new trainine.
16 Tha t takes a long time, every shift has to be trained.
17 MR. TERCs Everything is intertwined.
18 MR. McKENNA:
It takes months, sometimes.
It l
19 will be chaos.
20 MR. MACDONALDs Wen you talk about the 21 original time you have to talk about, you know, we have i
l 22 to resolve just what we are expected to do, licensing 23 vise, with this appraisal.
()
24 MR. McKFNNA:
We expect those items to be 25 corrected, now.
The Salem experience was that they did O
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1 correct them in a very short period of time because they 2 had that appraisal just before they were tring to come 3 up.
However, it was a big effort on their part and I do 4 not think you wsnt to go through tha t.
5 MR. TERC Are we shooting for the final, for 6 one appraisal for power, and tha t is it?
7 MB. McKENNA:
Right.
8 MR. MACDONALDs Yes.
9 MR. McKENNA:
In July.
10 MR. MACDONALDs Right.
11 MR. TERC Then I think we should go back 12 maybe a month on the appraisal, then.
If you go back a 13 month on the appraisal that would give them two months.
O 14 MR. ROBINSON:
That means we get the 15 procedures in in May?
16 MR. TERC:
The first part of June, and then we 17 issue the report in August.
And the emergency l
18 procedures should be submitted to us about three weeks i
19 before the appraisal.
So, that would be in May.
Does 20 everyone sgree with that?
21 MR. SIRICKLAND:
You want to move it up to May?
22 MR. WHEELERS We will change that.
23 MR. TERCs Yes, the procedures submittal
(
24 should be in May.
That looks good.
l l
25 MR. MACDONALDs No less than 180 days prior to O
l l
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1 scheduled issuance of operating license.
So, that may 2 be the beginning of May for procedures.
Can we consider 3 the ASLB as the operating license?
4 MR. WHEELER:
I will have to get a reading on 5 it since we are now dealing with two different levels of 6 licenses.
Tom might be able to have an answer based on 7 recent experience.
We will wait until he gets off the 8 phone.
9 (Discussion off the record.)
10 MR. WHEELERa We are back on the record now.
11 Tom, would you review the regulation there as 12 it specifies 180 lays?
Can you tell us whether that 13 would apply to the low power or full power license?
14 MR. McKENNAs Well, since we are treating them 15 both the same, it is a full power license.
So, we need 16 that 180 days, yes.
17 MR. WHEELER:
Not less than 180 days.
18 MR. TERC Not less.
We have more.
19 MR. McKENNAs Prior to 180 days.
20 MR. WHEELER All ric h t, presuming a November 21 of December full power license, we meet that requirement 22 coming in in May.
23 MR. MACDONALD:
That is still May.
)
24 MR. WHEELERa Just leave it the way it is.
25 3R. McKENNA:
We have even been accepting O
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1 draft procedures to meet that.
2 I just not some information on low power 3 licensing, if you are interested.
Do you want to 4 digress for a second, or do you want to do it later?
5 On December 15, 1981 - ard I did not even know 6 this - in 46 FR 511.33, a proposed regulation went out 7 on low power license and its relationship to emergency 8 preparedness.
I do not now if you have seen that.
I 9 will get it.
10 MR. MACDONALDs Yes, that was the Federal 11 Register Notice about exercise.
12 MR. McKENNA:
Exactly.
You have to prove 13 onsite capability.
O 14 MR. MACDONALD:
That's it.
15 NR. McKENNA:
All richt, you know that.
16 NR. MACDONALDs It has not been acted on, has 17 it?
18 MR. McKENNAs Well, I have just heard that it 19 is down at the Commission and they think it is going to 20 be acted on favorably shortly.
So, like John said, what 21 it amounts to is that you do not have to have findings 22 on offsite at all to get a low power; no findings on 23 offsite.
24 However, onsite does have to be demonstra ted 25 and certain interface points offsite have to be i
C)
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1 demonstrated - notification, communications, police, 2 fire, and probably some point of contact with protective 3 action procedure, something lik e that.
Basically in
[
4 line with what we discussed.
Very good.
5 MR. WHEELERS What additional adjustments are 6 appropriate to the schedule here?
Is anybody cognizant 7 of any other issues that we are going to want to discuss 8 a t a f uture meeting up ther at the site?
9 We were talking earlier about taking all day 10 for such a meeting.
11 MR. ROBINSON:
Are we going to talk about 12 facility scheduling?
13 MR. WHEELER:
At the site?
O 14 MR. ROBINSON:
I mean in conjunction with this 15 overall schedule.
16 MR. WHEELER:
We can discuss facility 17 scheduling.
18 MR. ROBINSON:
As far as when the public 19 notification system will have to be in place and 20 testing.
Would that come within the schedule?
21 NR. McKENNAs Normally, that is done as part 22 of the exercise.
23 MR. WHEELER:
That is within the realm of this 24 meeting, yes.
25 MR. McFENNA:
Normally, that is exercise.
O i
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1 Realizing, under this change to the rule on the warning 2 system, you are supposed to conduct a test and give us 3 some test results that show your design standards.
We
(}
4 are not saying it meets FEMA's or ours or anybody 5 else's, but you go ahead and start, test it some ways 6 describe what you did, send us the results.
That is one 7 thing you do.
8 But the warning system test traditionally is 9 done at the time of the exercise.
Now, that is an issue 10 that I think should be discussed at this other meeting, 11 too because that is really a FEMA issue.
When is FEMA 12 going to do that.
13 MR. ROBINSON:
They are still working on a
[
14 test proced u re.
l l
15 MR. McKENNAs I understand it is about ready l
l 16 to finally pop out.
I just heard that.
17 Duke, I think one of the issues up here on the l
18 aeeting is FEM A's intention on the warning system test
{
i 19 because right now it is up -- I think for this case they 20 are going to have to resolve it.
I don't think we are 21 going to let them slide.
22 MR. ROBINSON:
I think they will have their 23 test procedure in place prior to tha t time.
24 HR. McKENNA:
All right, good.
i 25 On the other centers' appraisal.
Now, I do O
i l
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1 not know if you know what our intention is on the 2 emergency centers.
3 MR. MACDONALD:
I think you mentioned it.
4 MR. McKENNA:
Right.
We had planned'to have 5 another appraisal for centers for the operating plans.
8 But in this case I suspect it is all the same 7 appraisal.
I cannot imagine coming out with two 8 appraisals, do one for centers.
So, the center should 9 be up and running, come appraisal time.
10 MR. MACDONALD:
Powever, as it stands right 11 now you have no idea what you would appraise them.
12 MR. McKENNA:
Exactly.
And our review 13 criteria sn appraisal criteris, center review criterion, O
14 which is a planning.
So, it is more than just the 15 appraisal.
16 MR. WHEELER:
Criteria sppraisal and 17 scheduling, when are you going to have things built.
18 MR. McKENNA:
Yes, when are you going to have 19 them built.
When do we need pieces of paper to review 20 what is our intention.
I do not know the answer to any 21 of those questions, as you know.
22 MR. ROBINSON:
That may be decided sometime 23 the next month or so?
(
24 MR. McKENNAs What does that say?
25 MR. WHEELER:
Tha t says construction schedule.
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1 MR. McKENNA4 Yes.
Other issues - I am 2 looking at your thing.
You have " evacuation analysis" 3 down here.
That is ours.
I can give you the status on
)
4 that.
5 As they know, we were doing an independent 6 evacuation analysis.
Schedule wise I do not know when 7 it is due out, but I know that the computer runs are 8 being done right now.
That is all I can tell you.
They 9 are physically running the codes the isst few days.
to MR. MACDONALD:
What is going to happen on 11 that, the contractor is runnlag their code wi th the 12 input of vehicles, or whatever.
They are coming out 13 with the results and does the NRC publish.the report?
O 14 HR. dcKENNA:
There will be a report 15 published, that I all I can tell you; there will be a 16 report published.
The data used was primarily data 17 independent.
18 HR. WHEELER:
If it is all right, we will just 19 put this down as something to be discussed, perhaps, at 20 th e next meeting, the independent evacuation analysis 21 that the NRC is performing right now.
22 MR. McKENNA:
The next one, that says our 23 request for information, categorization, clarification.
(
24 Ca tegoriza tion, I think, we can discuss here.
25 Clarificaton, I think, we need to discuss up there.
O v
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1 Right?
2 MR.
ACDONALDs Even if it involves an RAI 3 tha+ strictly deals with the station procedures, 4 equipment, personnel, organization, etc.?
There are a 5 number of those we would like clarification on that do 8 not involve any offsite agency or authority.
7 MR. WHEELER 4 Frankly speaking, it is beyond 8 the scope of this meeting.
Now, categorization within 9 what, for instance?
Give us an example.
10 MR. MACDONALDs Categorization of R AIs that we 11 have information now sufficient to answer.
12 Categorization of RAIs that have to await offsite 13 emergency plan agency development.
O 14 Another category that involves procedures and 15 equipment development for in-plant activities.
18 A few that are answered already in the 17 emergency plan as submitted.
18 MR. WHEELER:
OK, a ca tegory that a particular 19 RAI would drive when you would be giving us your 20 response?
21 MR. MACDONALDs That's right.
22 MR. WHEELER:
We can discuss it, as long as we 23 stay away from the actual content of the response 24 itself.
You can identify the kind of information, but 25 let 's not ;et into any grest discussion of whether or O
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1 not the information is acceptable to us.
2 MR. MACDONALDs All right.
3 MR. WHEELER:
Do you need this information now?
()
4 MR. MACDONALDs Yes.
There are a number of 5 R AIs I would like clarifica tion on to find out what is 6 meant by the question, so that we know we are answerino 7 the question asked.
Can we do that?
8 MR. WHEELERS Yes, you can ask clarification 9 questions.
10 MR. MACDONALDs Well, then I get into my long 11 list.
12 MR. DODGE:
One of the things on the schedule, 13 you are still planning to have a 20-21 meeting up at O
14 Seabrook; is that right?
15 MR. McKENNA:
Yes.
Hopefully the agenda is 16 the thing on the right.
You know what I would like to 17 do also, let's try to tentatively get up a list of 18 attendees while we are here to see if anybody can think 19 of anybody else who we might invite.
I am going to need 20 our cen ter guys, we are going to neet FEMA, we,are going 21 to need the lawyers.
22 HR. WHEELER:
Fin e.
Write it all down and 23 give it to me and when I generate the meeting notice and 24 the acenda, I will get input from you.
25 MR. McKENNAs Great, that sounds good.
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1 MR. UACDONALD:
Would you need licensee legal, j
2 3r is that up to us?
3 3R. McKENNAs I would.
[}
4 MR. M ACDON A',D a You would recommend it.
5 Now we are at the point of RAls.
It is ten 6 minutes to twelve, do you want to break for lunch now?
7 MR. McKENNA:
How lon do you think you are 8 going to take?
9 MR. WHEELER:
Yes, I was going to say, keeping to in mind that all you are going to be doing is asking for 11 clarification of what we meant when we said what we 12 said, and looking at those that you want to cover, how 13 long is this going to take?
O 14 MR. MACDONALDs I cut it down considerably.
15 We micht as well push on and find out how long it takes 16 af ter we are all done.
17 MR. McKENNAs I think that is what he wants, 18 he wants to work through.
We understand.
19 MR. MACDONALDs Do you have a copy of the RAIs 20 in front of you?
i 21 Well, I guess under the revised procedures 22 here for this meeting I go to RAI 10.4 first.
23 MR. McKENNAs What is it?
(
24 MR. MACDONALD:
The question about the plume 25 EPZ boundary.
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1 MR. McKENNA:
All right, I have it.
I 2 renumbered 1 to 101, if tha t will help.
{}
3 MR. MACDONALD:
I have those renumberings on 4 the margin, tha t is what I am going by.
f MR. McKENNA:
All right, good.
6 MR. MACDONALDs Was this a question that came 7 from a review of our table listing of pounts in the EPZ 8 or the figure?
9 MR. McKENNAs I think it came from the to figure.
I think you just used the circle, or did you?
11 I can 't remember.
12 MR. D0DGE:
Yes, we did.
13 MR. McKENNAs You did use a circle.
O 14 MR. D0DGE Ten-mile radius.
15 MR. McKENNA:
I get conf used sometimes.
All 16 right, the idea is, the plume EPZ boundary is supposed 17 to be -- the demarka tion of the plume EPZ boundary is 18 supposed to be by features that csn be recognized by the 19 local population so that they know whether they are or 20 are not in the zone, for one thing.
21 So, when you submit you have to show us that 22 and discuss how demography, topography, land 23 characteristics, and that sort of thing, were taken into O)
\\~
24 consideration.
25 That can probably be done.
If the map is O
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1 fairly clear that may answer itself.
In other words, if 2 you use access roads and jurisdictional boundaries that 3 will be clear.
If you are doing it a==ording to 4 topography or land characateristics, or demography, it 5 may require a little bit of an explanation because 6 sometimes those things are not clear.
Like if you have 7 a ravine and you are going to use a ravine, that might 8 now show up.
9 MR. STRICKLAND:
Local roads.
10 MR. McKENNA:
The kind of stuff that shows up.
11 MR. STRICKLAND:
Municipal boundaries?
l 12 MR. McKENNA:
Yes.
l 13 MR. MACDONALD4 In this case they are
)
14 jurisdictional governmental boundaries.
That will be 15 even easier.
16 MR. McKENNA:
That is easy.
17 MR. MACDONALDs And the determination has to 18 be with the state.
I i
19 MR. McKENNAs Exactly.
l l
20 MR. McKENNA:
On A 10.5, we do not understand 1
21 why we are being asked for letters of agreements with 22 any Federal agency.
l l
23 MR. McKENNA That is a general statement if
(
24 you are relying on any support from a Federal agency, 25 like Coast Guard.
Pilgrim uses the Coast Guard for
()
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1 offsite monitering support.
2 MR. MACDONALDs If we are not using anyone, we 3 do not need a letter agreement.
And that is the case 4 for a local agency as well, right?
5 MR. McKENNAs We are talking about local here, 6 typically that is fire depa rtments.
7 MR. IERC:
Hospitals.
8 MR. McKENNA:
Hospitals.
9 MR. TERC:
A m bulan ces.
10 MR. MACDONALDs Certainly we are relying on 11 them for support, but there are no local town agencies 12 just because they are set up emergency plan wise.
13 ER. McKENNAs Exactly.
I just want to make O
14 sure I take notes of what I am saying here -- oh, I 15 don't need to do it.
I 16 MR. MACDONALDs The next one, what kind of i
17 information are you looking for, what kind of detailed 18 information are you looking for from us in connection l
19 with 810.11?
20 ER. McKENNAs Is that specified response times?
21 MR. MACDONALDs Yes, Table B-1.
l 22 MR. McKENNAs I think, one, we want to know l
23 who is on shift, period.
Secondly, that is the on-shift 24 and you will have to meet the minimum on-shift manning.
25 Secondly, for offsite augmentation, what we
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1 have been looking f or are -- let 's put it this way, 2 there are probsbly a lot of different approaches on how 3 to demonstrate cospliance with that table.
4 One approach being used is to tell us where 5 people live by emergency function and travel time and 6 discuss notification times, so that we have some idea of 7 their response times - supported by some sort of 8 information on how long it does actually take to notify 9 these people based on some sort of evac real test.
10 I would suggest that you look at the 11 correspondence to operating plants such as Vermont.
12 MR. MACDONALDs.
Of course, s back-shift 13 exercise of this nature will not be conducted for quite O
14 some time.
15 MR. McKENNAs Well, you provide us that 16 information and then a commitment to conduct this and 17 just figures accordingly.
18 MR. MACDONALD:
On 810.50, what phase are we 19 talking about there, emergency planning or an actual 20 emergency response?
21 MR. McKENNA:
That is 157 l
22 MR. MACDONALD:
Right.
23 MR. McKENNAs Let me read the question.
()
24 Specify who will provide corporate level interf ace with 25 govermental authorities?
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1 MR. MACDONALD:
Right.
2 MR. McKENNA:
What we are lookino for here is 3 if somebody over at the eme rgency response center, i.e.,
4 one of the Commissioners, wants to talk to somebody at 5 the highest level of corporate authority during an 6 accident at Seabrook, who does he call.
That is exactly 7 who we are talking about.
8 So,.if Palladino wants to pick up the phone, 9 who does he call?
10 MR. MACDONALD:
So, it is in connection with 11 an actual emergency.
12 MR. McKENNA:
Who could be considered the 13 corporate level representative.
It may not be the O
14 normal guy.
15 MR. MACDONALD:
Is by governmental authorities 16 only meant the NBC7 17 MR. McKENNA:
No, I would not say thst.
I 18 quess I could see cases where you might be talking with depending on how big it got you might be talking with 19 20 other people.
You might be talking to DOE nationally, 21 clearly.
You could be talking to people like the Coast 22 Guard.
23 But since things will be coordina ted through 24 the NRC and through FEMA, those are probably the two 25 primary agencies we are talking about.
The highest O
l l
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1 levels of the N9C and FEMA, they want to talk wi th 2 equivalent people at your site.
Who is that?
3 MR. MACDONALD Tom, I am a little puzzled by 4 810.18, since our understanding is that the Federal 5 response plan is initiated by the NRC, not us.
6 MR. McKENNA:
Scratch 18, that has been 7 resolved.
Wait u minute, let me see.
8 OK, scratch the section that says, "To request 9 assistance directly through the Federal Badiological 10 Monitoring and A ssistance plan."
However, let me look.
11 Before I say anything, let me see what the criteria says 12 before I am letting you off on tha t.
13 We sti31 vant in your plan, though, a listing O
14 of what would be available, and by general category how 15 long you expect
.t to be there since you know what kind 16 of support you can expect and how fast it would be there.
17 Also, something in the plan that would 18 indicate to the Feds if they were going to respond what 19 is available to tnem to be used in their response, i.e.,
20 is ther an Air Force base nearby; is there that kind of 21 assistance.
22 MR. FACDONALD:
See, I an having a problem 23 here.
I am getting into potentially answering these
(
24 RAIs in addition to clarifying them.
I guess I have to 25 hold this of f until May.
O l
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1 MR. M:KENNAs OK, I can explain the 2 requirement.
The requirement basically is, we want you 3 to know - you being a little special case because you
{}
4 clearly know but not all licensees clearly know, and we 5 apply the requirements to everybody equally - we want 6 you to know what Federal support is available.
- Like, 7 you know, you can have the airplane out of Brookhaven, 8 it takes the airplane a couple of hours to get there.
9 So, it is nice to know those kinds of general 10 things.
You can have air-borne monitoring.
You 11 probably have a mobile lab, these kinds of things, it 12 takes them so long to get here, in general.
That is a 13 simple listing.
()
14 Secondly, if the Feds had to go to that site, 15 what is available locally that they could use so that'if 16 that support had to be sent we would have some idea of 17 where to go look for places to set up - nearby airports, 18 nearby military installations, that kind of thing.
l 19
'Je are not looking for letters of agreement or l
20 anything like that with those f acilities, just a listing 21 of what is available.
That is sort of a resource for 22 us.
Now, if you want to talk about more?
23 MR. MACDONALD:
I certainly would.
DOE does 24 not look at our plan at all for what is in the area.
25 That is already well known, where we are going to go in O
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1 case of an accident in any of the facilities of the 2 country.
s 3
ER. hcKENNAs That was not my undgrstan41ng.
4 I will take myelf a no te on i e45 t."
It is more than DOE, 5 by the way, it is us too.
So, what is available?
You 6 know, it'is not just DOE.
7 MR. MACDONALD:
Radiological Monitoring is.
8 MR. McKENNA Yes, Radiological Monitoring is, 9 all these other helpful things we wt11 do for yoc.
10 NR. MACDONALDs On, rs 10.19, can you clarify 11 what you mean by " principal offsite governmental EOC7" i
12 Are you talking just the Massachusetts and New Hampshire s
13 State EOCs?
14 MR. McKE!!N A:
Yes.
If that is the way they 15 operate, I don't know.
We will start off with the site 16 and then, within a few hours we are going to move to 17 some regional EOC.
You'know, there vill be a transfer.
18 If they are going to do something like that, if that is 19 what is going to happen, then the, principal -- whCever 20 the principal is.
r 21 NE. MACDONALD:
On.610.22, what do you mean by 22 the ters'" job aids?"
23
.3R. McKENNA:
Wait a minute, classic problem, p
s 24 it seem; to be getting a little better.
But typically 25 the procedures developed for implementation of the EALs, O
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1+s list of EALs which tracks pretty close to what is in 2 0654 When it comes time for the operators to use them
(}
3 they start readins, they go to the first page and start 4 reading; then they go to the second page and say, "Oh, 5 yes, I think that one."
And then they will go, "Oh, 6 this one too," and then it goes on, and on, and on.
7 One, it is too slow.
Two, it is very 8 confusing.
Three, it just does not work.
So, take a 9 hard look at it and come up with something that works.
10 I think the key here is, go try it out because 11 we certainly will when we show up at the site.
So, 12 whatever works.
In some ways this finding comes 13 directly out of the appraisals.
14 MR. TERC Whatever you do, make it short.
15 MR. McKENNAs Whatever you do, make it short.
16 And a point, a real important point - and this 17 is something everybody is doing wrong, although I get 18 the feeling if I remember correctly, you folks have 19 figured this one out.
20 The AELs in the procedures do not have to 21 address every single one of those initiating conditions 22 specifically.
In other words, you can have a set of 23 EALs for general emergency and what they are, are EALs 24 that will get you to declare a general emergency for all 25 the ini tia ting conditions.
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1 But if you are going to have the same set of 2 EALs for ten different initiating conditions, you do not 3 have to repeat them.
Just one see of EALs so the 4 ' operator does not have to go through and read all 5 initiating, two or three fission product areas -- if it 6 is the same set of EALs, get rid of all the redundancy 7 and try to collapse it down.
8 For instance, a lot of people felt that they 9 had to repeat them, for instance.
That is not 10 necessary.
The thing is, you have a seat of measurable, 11 observable things the control room operators can use 12 quickly with the sinimum probability of making mistakes.,
13 And the key, we find this every place we go, O
14 nobody has checked them with the operators.
"Has anyone 15 ever come down to talk to you?"
"No."
I don't know if 16 corporate did this.
That kind of stuff.
17 We will do that at the appraisal, we will do 18 it several times during the appraisal.
That man will 19 probably check every shift.
l 20 You have had lots of experience.
l 21 MR. MACDONALDs On 810.28, Tom, are you 1
l 22 referring to the emergency public information brochure 23 tha t is distributed before an accident?
()
24 MR. McKENNAs No.
25 MR. MACDONALDs Or messages during an accident?
()
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1 MR. McKENNA:
Public messages during an 2 accident.
Now, that can be done throuch reference to 3 the state plan if we have that.
Let me say a few words 4 about that.
5 We want some kind of reference.
In addition -
6 I know it is tough because it is an offiste planning 7 area, but the massages have to address protective 8 action, they just can't be the thing we see so often 9 which is " stand by for more information."
to MR. MACDONALDs That is not our jurisdiction.
11 MR. McKENNAs I know.
I am warning you that 12 this is a problem.
OK, the next issue.
13 MR. MACDONALDs By 810.35, what do you mean by O
14 " posting information for transient population?"
15 MR. McKENNAs just that there will have to be l
l 16 some kinds of provisions to make available information 17 for posting.
What I am saying 18 MR. TERC Public beaches.
l 19 MR. McKENNAs Public beaches, for instance.
20 MR. MACDONALD:
Posting what on public beaches?
21 MR. TERCs A sign saying, in case of a nuclear 22 accident do this or that, or, call here.
23 Transient population would not receive a 24 brochure, for example.
Your to'trist population. for l
25 example, that would be at beaches and other places.
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I would have to have devised means to provide the people 2 with some kind of information because they will be 3 completely ignorant, I guess because they do not live
)
4 there.
5 MR. M:KENNAs Now, the way we look at it, 6 private establishments you cannot go in and twist their 7 arms and make them nail it up.
You can make it 8 available to them.
9 MR. MACDONALDs A motel or a hotel, or 10 something like that?
11 MR. McKENNA:
Right.
But public places - and 12 this is a FEMA review item, so we are really getting out 13 of scope.
We look at that a little differently.
But I O
14 would just as soon not go beyond the scope of the 15 meeting.
16 MR. TERC4 Yes.
17 MR. MACDONALD:
On 810-38, what do you mean 18 by, "and their relation with possible plant conditions 19 during the media programs?"
20 MR. McKENNA:
Wha t we are trying to do here 21 is, we are trying to say that the public information 22 with the media, you should make available some sort of 23 discussion basically of the methodology you are going to 24 use to recommend protective actions, i.e.,
if you get a 25 core melt, we are going to recommend you are going to ALDERSoN REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 504-2345
68 1 start moving people.
If there is some kind of slow kind 2 of release going on it will not be.
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3 The idea is theoretically - and I say 4 theoretically - the idea is that it will help their 5 understanding of why certain protective actions would be 6 recommended and why it is important that those 7 protective actions be followed and not others.
8 MR. MACDONALDs Now, on 810.40, of course, we 9 have the great uncer tainty about the applicability of 10 NUREG-0696.
11 MR. McKENNA4 Exactly.
I will check with Ed 12 Williams and have Ed Williams at that meeting.
13 I think, to be honest with you, 41 falls under O
14 exactly that same blanket.
15 MR. MACDONALD:
My question on that one was 16 where you got it.
17 MR. McKENNA:
It came out of 696.
18 MR. MACDONALD:
Out of 696.
I 19 MR. McKENNA:
Yes, the same blanket.
20 MR. MACDONALD:
On 810.46 I an a little 21 confused about the request for " habitability 22 demonstration of the OSC."
We are unaware of a 23 habitability requirement.
24 MR. McKENNA:
It is not a requirement.
I 25 think that the plan should indica te -- the idea is, you O
1 l
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1 should know whethar it would or would not.
2 MR. TERC:
Can I add something?
3 MR. McKENNA:
Yes.
4 MR. TERC4 You are right, there is no 5 requirement for habitability of the OSC.
However, the 6 only thing yru should look forward to is to be able to 7 nove those people to another location where they would 8 be accessible so they can also remain.
Have some kind 9 of a scheme in the event that the OSC or the selected 10 location for the OSC is uninhabitable.
Then they should 11 be able to move to another location because you may need 12 the people to take corrective action, this kind of 13 thing.
That is all you need.
O 14 MR. McKENNA:
It is not a habitability 15 requirement, we are just trying to say that you should 16 take a look at some of the accidents that might happen 17 and what that would probably do to your OSC.
18 MR. ROBINSON 4 I think that is reasonable.
19 MR. MACDONALDs Well, are you looking at an 20 accident analysis of the OSC for habitability?
21 MR. McKENNA:
A formal accident analysis, no.
22 You know, you take a look around, you have no pumps that 23 are going to be shining; there is no direct shine from
()
24 the containment; you do not have a charging pump sitting 25 richt down in the corner.
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1 MR. MACDONALD:
Review.
2 MR. McKENNA4 Yes.
We looked around and we 3 thint this is OK.
We looked around and it looks like we 4 esn get people in and out, realizing at the time of an 5 accident everybody is going to be running around -
6 hopefully the survey meters and the area radiation 7 moaltors will support that.
8 But you don't want to stick it some place like 9 you forgot there is a charging pump over there and that 10 is going to blow you out of there right away.
Give it a 11 little thought.
12 MR. MACDONALD:
Well, did you review the plan 13 to see where it is?
14 MR. McKENNA:
Where is it?
15 MB. PACDONALD4 The administration building.
16 MR. McKENNA I will look at the plan, and 17 this may require no further information.
18 MR. TERCs What you are saying is that a 19 loca tion is already selected?
20 MR. MACDONALDs There is not any charging pump.
21 MR. McKENNA4 You do not have one.
22 MR. MACDONALD:
It is difficult to resist the 23 temptation to answer some of these.
24 MR. McKENNA:
We just have to do it.
25 MR. TERO:
There is a possibility that the O
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1 plume ma y go in that direction.
2 3R. MACDONALD:
There is a possibility of what?
3 MR. TERC Of the plume going in that 4 direction and affecting the area of the OSC.
So, you 5 want to move them to another location anyway just 6 because of the plume itself, not because of direct 7 radiation levels.
8 MR. MACDONALDs We will look at it.
9 MR. TERC Yes, that is just a scheme.
10 HR. M:KENNA:
All right.
11 MR. MACDONALD On 810.59, 60 and 61 I guess 12 the question is just, what are you looking for here.
13 MR. McKENNA On the first one, traditionally
)
14 the sites that had assembly areas on site or right 15 outside the gate or something a t which - they conduc.t 16 monitoring and make a decision on what they are going to 17 do from there.
i I
18 We are saying tha t you should have provisions 19 if you get into a condition, for instance, a core melt 20 condition where you think you are going to have a big 21 release or something, that you could send people farther 22 away from the plant than that and have them assemble l
23 there for monitoring.
24 Now, thst does not have to be much more than 25 just that, an area they will go to aad wait, and then ALDERSON REPORTING COMPANY,INC.
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1 you could grab the kits or something and go out there.
2 It could be where the state people are going to set up 3 the monitoring location.
Just some place they can go to
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4 directly without waiting for monitoring and that sort of 5 stuff.
6 MR. MACDONALDs Well, is this evacuees, 7 nonessential evacuees?
8 MR. McKENNAs Yes.
You can go by your scheme 9 you have now, where you do it outside the gate or 10 something.
I do not know what you have now.
But under 11 very special circunstances you should have identified 12 the place so that the emergency planning coordinator -
13 whoever is in charge - does not think he wants them 14 sitting out there, then tell them all to get out.
15 They should somehow or other be able to be 16 told how to do that.
One way is, people have a bunch of 17 pamphlets and have them stuck away.
But if you ever 18 have to, you just hand them to them and tell them to go 19 there and wait.
And, you know, don't mingle with the 20 people until a team gets there, or something.
21 It is a place away f rom the plant you can go 22 to if things get really bad.
That is what that is.
23 MR. STRICK LA ND :
Is there any dista nce 24 cri te ria ?
25 MR. McKENNA:
Just not real closa.
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1 five miles, is wha t I said.
The area that you might 2 raquire, immediate evacuation of offsite population, 3 that is about two to five miles.
4 MR. TERC4 The question is, why not send them 5 home?
If that is the case they can go home.
6 MR. McKENNAs The question I asked is, what 7 about monitoring.
8 MR. STRICKLAND:
You are assuming that we do 9 not have the time to monitor.
10 MR. McKENNAs No, you would not want to hold 11 them up for monitoring, just tell them to get out -
12 monitorig, tagging, decon and all that kind of stuff can 13 take a long time.
O 14 MR. STRICKLAND:
These evacune manitoring 15 points in question 61, I take it tha t is the same place 16 we are sending these people to, or is that monitoring 17 points in this station?
18 MR. McKENNA:
Tha t is the station monitoring 19 points.
20 MR. STRICKLAND:
So, tha t has nothing to do 21 with it.
22 MR. McKENNA:
No, just station.
This other 23 thing is really a special case.
(
24 MR. STRICKLANDa Because 810-60 says, "Specify 25 the criteria used to determine when plant evacuee O
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1 monitoring is required and the criteria for allowing 2 lamediate evaeustin and further monitorin7 and 3 decontamination offsite.
Provide for monitoring at the
)
4 offsite assembly areas if onsite monitoring is not f possible."
6 Do we have to provide a decontamination 7 capability based upon this question, at this of fsite 8 assembly area, or just a way of controlling the people 9 until we can get them back in to decontamination, is to what I am ssking.
11 MR. McKENNAs I think that provisions to 12 control decontamination later are OK.
I think, however, 13 some sort of provisions should be made so that you can O
la get some kind of monitoring out ther, at least to spot 17 check to see if that would be required or not.
16 MR. STRICKLANDs I understand that.
17 MR. McKENNA:
Ihat's it.
I do not expect you 18 to have a shower some place out th ere.
19 Ihis is a very special case.
20 MR. MACDONALDs All right, the next one is 21 810.67.
The implication given here is that it would 22 have different emergency exposure guidelines for 23 different groups.
24 MR. McKENNAs Pardon me, where?
25 MR. MACDONALD:
In 810.67.
That is not your O
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1 intent, is it?
2 MR. M:KENNAs No.
I think, to be honest with 3 you, I think this is primarily a paper problem.
You
.)
4 just have to clastly indica te -- the criteria has that 5 list of activities.
I think you just have to basically 6 show how these categories f all within the guidelines you 7 already established.
8 MR. TERC Which one was that?
9 MR. MACDONALD:
In 67.
10 MR. McKENNA:
K-1.
11 MR. TERCs I think there is a typo here, is 12 there not?
If you look at 810.56, there is no ten to 13 the minus.
CE) 14 MR. MACDONALD What number are you on, Nemen?
15 MR. TERCs At 910.56, we have ten to the minus 16 seven there.
17 MR. MACDONALD:
Are you ready for the next?
18 MR. McKENNAs Yes.
19 MR. STRICKLAND:
Could I hear the response 20 again?
21 MR. MACDONALD:
On 67?
22 MR. McKENNA:
If you want you can either 23 establish separate ones or you can tell me how those fit
()
24 into the established criteria, the emergency exposure 25 guidelines that are already established.
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1 MR. MACDONALD:
The next one is 58.
Wh a t are 2 you looKing for there, are you looking f or a procedure
(
3 to handle that?
Recognizing that the state, of course, 4 has a big role in this kind of area.
But are you only 5 talking about --
6 MR. McKENNA:
Just onsite, just onsite.
It is 7 probably a sub-part of another procedure.
In the 8 planning all you really do have to say is that, you 9 know, this will be contained in the procedure, addressed 10 by procedures.
11 HR. DDDOE:
For clarification, do you mean 12 " contamination" control measures or " decontamination" 13 control measures?
O 14 MR. McKZNNA:
Contamination control measures.
15 MR. TERC.
Contamination control, that is 16 something in 10 CFR 20.
17 MR. STRICK1ANDa-Radiation protection, what 18 controls that even in an emergency.
19 MR. TERC:
Yes.
20 MR. McKENNAs That is an interesting point.
21 You might as well bring it up now.
We say procedures in 22 by May.
We need all the procedurus that might be used 23 in an emergency.
So, if you have other supporting i
24 procedures that would be crucisl that we look at to be 25 able to understand how you respond - like post accident ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGT.ON. D.C. 20024 (202) 554 2345
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1 sam plin g procedures or if you are going to rely on your 2 normal decon procedure, we need those too.
We need the 3 package.
4 MR. MACDONALD:
Oh, on 810.84 5
MR. McKENNA:
Right, "The annual exercise 6 should simulate."
7 MR. MACDONALD4 While you recognize tha t the a annual exercises are a big-ticket item with a lot of 9 organiza tions involved, the licensee cannot commit for 10 other agencies.
11 So, we have a little bit of difficulty saying 12 we are going to do all that without agreement by other 13 Federal, state and local agencies.
O 14 MR. TERC:
Yes, but you can still make a 15 statement saying that you have provisions as long as the 16 others agree.
17 MR. MACDONALD:
We will make the commitment 18 subject to agreement.
19 MR. TERC4 Right, contingent on agreement.
20 NR. MACDONALD:
That is not much of a 21 commitment.
22 MR. TERC But you will be prepared.
23 MR. MACDONALD:
Yes.
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24 MR. TERC:
That is the only thing you can do.
25 MR. MACDONALD:
My last question of this ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGT.ON, D.C. 20024 (202) 554 2345
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1 nature here for this meeting is 99.
2 MR. M:KENNA:
Oh, I love it.
3 3R. HACDONALD:
Is a cross-reference still
{)
4 required?
You have already reviewed the plan.
5 MR. McKENNA:
Let me tell you this, we will 6 not delay fuel loading for a cross-reference, I 7 quarantee it.
It certainly would be helpful to me to 8 have that.
9 MR. TERCs It will be useful to you in order 10 to review the emergency plan f arther on.
11 MR. McKENNA:
Let me say this, too, if you do 12 not want to put it in the plan so it will have to be 13 updated and all that sort of stuff. it certainly will be O
14 helpful if you could just provide it at some point.
15 MR. MACDONALDs Well, by 654 it is only to be 16 provided on the initial submittal.
We have already made 17 that.
18 MR. TERC:
Right.
19 MR. McKENNA:
I vondered why that dropped 20 out.
I still look at it, though.
l 21 MR. D3DGE:
One more question, a generic 22 question regarding responses.
Some responses are going i
23 to be informational and are not going to yield a direct 24 change or modification to the plans others may yield a 25 statement that says the plan will be amended as follows.
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1 It is OK to use both?
2 MR. McKENNAs We will take a look at each one, 3 yes.
You-know, some of the stuff we might want in the 4 plan.
Some of these things you think are just 5 informational but we want them in the plan because the 6 plan is that tie between the regulation and what you do 1
7 in the field.
So, some of this stuff we do want in the 8 plan no matter what.
9 But yes, try to explain it the best you can 10 and then we will work it out.
11 MR. DODGE:
All right.
12 MR. TERC:
The procedures implement the plan, 13 so you have to have all the elements in the plan in O
14 order to implement it.
15 HR. FHEELER:
If that wraps up your request 16 for clarifications, then let's review what we have a 17 accomplished here.
18 We have developed a schedule, and it is a 19 tentative proposed schedule, for the emergency 20 preparedness review from now until the completion of 21 that review.
22 I understand that you came to this meeting 23 desiring to discuss a few other issues outside of the
()
24 scheduling considerations.
We are going to set those 25 issues aside, they have been identified.
They will be O
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1 discussed at a meeting in the future that will be held 2 up in the vicinity of the site.
(}
3 We have gotten some clarification of our 4 request for information which was sent to you at an 5 earlier date.
6 Now, with rega rd to those three things, does 7 anybody else have anything here that they wish to add to 8 those?
9 All right, what is going to happen then is, I 10 am going to generate a summary of this meeting and part 11 of that will be the schedule that we developed.
12 I an also going to start working on an agenda 13 for the next meeting that will be held up a t the site O
14 sometime around the third week of May.
If you have 15 anything that you want included into that agenda, let me 16 know, I would say, within the next several working days.
17 Now, of course those things that we identified 18 to be discussed, the independent evacuation plan and so I
19 forth, will all be put in there.
20 If you have anything else when you get back to 21 your of fices and discuss this with your people that you 22 vant us to work into this agenda for the third week in 23 May, let me know, as I said, within the next couple of (q/
24 workin7 days.
25 Does anybody else have anything?
All right,
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81 i
1 the meeting is closed.
j t
2 (Whereupon, at 12 :30 p.m.
the meeting in.the 3 above-entitled matter was closed.)
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MUCLEAR REGULATORY Cn!d'iISSION p) m This is to certify that the attached proceedir.gs before the OG in the matter of:
Preliminary Discussion of Emergency Preparedness Review Process and Development of Schedule of Major Emergency Preparedness Date of Proceeding:
April 29, 1982 Review Milestones Docket llumb e r :
? lace of Proceeding:
Bethesda, Maryland were held as herein appeers, and that this is the original transcript thereof for the file of the Commissicr..
M.
E.
Hansen 3
Official Reporter (Typec) r~
Official Reporter (Signature) n v
n v
w-.-..-