ML20053E705
| ML20053E705 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 06/07/1982 |
| From: | Grimes B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20053E704 | List: |
| References | |
| ISSUANCES-SP, NUDOCS 8206090179 | |
| Download: ML20053E705 (17) | |
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o UNITED STATES OF AMERICA NUCLEAR, REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of CONSOLIDATED EDISON COMPANY OF NEW Docket Nos. 50-247 SP YORK INC. (Indian Point, Unit No. 2) 50-286 SP
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POWER AUTHORITY OF THE STATE OF NEW
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YORK (Indian Point, Unit No. 3)
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r TESTIMONY BRIAN K. GRIMES, DIRECTOR DIVISION OF EMERGENCY PREPAREDNESS, U.S.N.R.C.
CONCERNING EMERGENCY PLANNING CONTENTIONS ADMITTED BY BOARD ORDER OF APRIL 23, 1982 FOR INDIAN POINT, UNIT N0. 2 AND UNIT NO. 3
. lune 7, 1982 8206090179 820607 PDR ADOCK 05000247 T
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4-4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of 2
CONSOLIDATED EDISON C0KvANY OF NEW Docket Nos. 50-247 SP YORK INC. (Indian Point, Unit No. 2) 50-286 SP
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POWER AUTHORITY OF THE STATE OF NEW
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June 7, 1982 YORK (Indian Point, Unit No. 3)
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TESTIMONY OF BRIAN K. GRIMES OF THE NRC STAFF CONCERNING EMERGENCY PLANNING CONTENTIONS ADMITTED BY BOARD ORDER OF APRIL 23, 1982 FOR INDIAN POINT, UNIT NO. 2 AND UNIT NO. 3 Q.1. State your name and position with the NRC?
A.1. Brian K. Grimes.
I am the Director, Division of Emergency in the Office of Inspection and Enforcement.
Q.2. Have you prepared a statement of professional qualifications?
A.2. Yes, it is attached to this testimony.
Q.3. What is the purpose of this testimony?
A.3. The purpose of this testimony is to address Contention 3.6, in part, and Contention 4 related to emergency preparedness for Indian
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Point Unit 2 and 3.
Q.4. Describe your role in the development of the present emergency planning regulations.
A.4. I am the Director of the Division of Emergency Preparedness in the Office of Inspection and Enforcement.
In this position I am respon-sible for NRC reviews of licensee plans for coping with emergencies and for developing the NRC emergency response capabilities.
I have been involved in some aspect of emergency preparedness since 60ut 1976 although not as my primary responsibility. My role could be best described in conjunction with a little background on the development of the emergency preparedr.ess regulations themselves.
The emergency preparedness areas was originally focused on on-site activites almost entirely and this dates from issuance of Appendix E to Part 50, about 1970, and Reg. Guide 1.101 in 1975.
In addition, the NRC developed a voluntary program for review of State plans by our Office of State Programs.
Because of discussions during the seventies with respect to class 9 accidents and particularly the WASH-1400 document, questions arose concerning the basis for off-site emergency planning and at this time I became involved.
I was then Chief of the Accident Analysis Branch.
I became co-chairman of an NRC/ EPA task force, formed in 1976 to address the issue of what accident or accidents should be considered in Emergency Planning.
In December, 1978, this task force issued its report, NUREG-0396/
EPA 520/1-78-016, " Planning Bases for the Development of State and Local Government Radiological Emergency Response Plans in
Support of the Light Water Nuclear Power Plants." The principal recommendations of this report were that a spectrum of accidents, including core relt accidents should be considered and that the task force consideration 0f this accident spectrum led it to recom-mend the establishment of Emergency Planning Zones around each nuclear power plant.
When the NRC/ FEMA task force was formed in 1976 they addressed questions from State groups as to what accidents should be used to prepare emergency plans. The conclusion of the task force was that no single accident should be singled out as the planning bases because of the wide variety of conditions and various accident possibilities.
If one picked a single accident, even two or three accidents, one could well miss relevant points of other accidents.
The concensus of the task force was as indicated above, that a planning basis would cover a spectrum of accidents, and in this were considered all of the design basis accidents that were then used in the licensing process. All of the WASH-1400 scenarios,.
including the core melt sequences, were also considered. This is discussed in an Appendix to NUREG-0396.
The task force identified the emergency planning zones, and also gave some guidance on time frames and types of radionuclides which should be considered in developing plans.
Though this report was issued prior to THI, the TMI accident was considered by the task force when they considered the connents received on NUREG-0396. The TMI accident was judged to reinforce the initial determination.,of the task force both with respect to the need for planning for a spectrum of accidents and with respect to the concept of and sizes of the emergency zones.
There are some additional things that come out of the TMI incident and I would like to go through a brief list of those starting from the plant outward.
These are all things that relate to the emer-gency preparedness improvements that have been required by the NRC since that time.
First, is the need for better assurance that instrumentation is available to follow a full spectrum of accidents and is that information made readily available to and understandable by the plant operator.
Second, is the need for provisions for a higher degree of technical understanding and technical resources on shift at all times.
Third, the development of recommendations for off-site protective actions based on plant praremeters rather than waiting for off-site consequences to occur. As a course of events is identified by Control Room instrumentation to have serious potential for resulting in off-site release, protective action should be recommended even l
before sending out monitoring teams, in order to allow for maximum lead time to take actions on behalf of the public.
In fact, some situations-(core melt) warrant taking protective actions even though a release has not yet taken place.
The fourth was the standardization of nomenclature regarding the seriousness of emergencies.
Previous to Three Mile Island there was not standard classification system and this resulted in con-fusion when emergencies were reported.
The fifth item was the principle of notification of off-site authorities, for even minor events, to try to establish the credibility of the notification process, and to assure that offsite organizations were given maximum lead times. We feel that we get better assurance that notification will be made if we can see that the notifications go forward, even for minor events, thereby better assuring that those same notifications would proceed for more severe events.
For events requiring urgent actions, the offsite officials who make protective action decisions must be notified by the nuclear plant operator within 15 minutes of detection of such conditions.
The sixth item is the capability to notify the public in a timely manner of a serious emergency. Once a decision is made to take protective actions, there must be both the adminitrative and physi-cal means to alert and promptly provide information to the public.
in the plurne exposure EPZ. This replaced the old door to door approach. Usually the initial instructicres would not be to evacuate, but more likely to shelter or to stand by for further information and prepare to,, evacuate if necessary.
The seventh was the establishnent of centers for technical personnel and managers to receive and analyze data and to manage accident miti-gation.
Item eight is the establishment of public information programs on the nature of the hazard and the appropriate actions to take during emergencies. The plume EPZ population must know to turn on the radio when they hear a signal and to obey civil authorities and whatever recommendations they might make.
Ninth is improvement in decisionmaking capability on the part of offsite organizations and provision of resources required to carry out those decisions.
It must be demonstrated that State and local officials have the capability to make protective actions promptly on being informed by the licensee. The Federal Emergency Manage-ment Agency has been given the respersibility by the President's Statement of December 7,1979 to review offsite emergency prepared-ness and we rely on them for judgments on the adequacy of the offsite capabilities, although it is our final responsibility to make the licensing decisions.
The tenth and last item I wanted to mention are periodic exercises of all plans. The exercises are held jointly with the offsite authorities because we regard emergency preparedness as an ongoing business, and to some extent an iterative process in defining in current performance and providing an opportunity for correction on a periodic basis.
After President Carter, on December 7,1979, gave FEMA the lead role in the development of the offsite plans, I was appointed by the NRC as co-chairman of the FEMA /NRC Steering Committee which overviews the day-to-day problems that may arise in coordinating the two agency's efforts in emergency preparedness.
I worked with FEMA to assure consistency in the development of our regulations with the FEMA effort.
During this time I also supervised an NRC effort to visit each of the more than 50 operating or near-operating sites in the United States. The sites were all visited by review teams who evaluated the existing plans and pointed out improvements that needed to be made to bring the preparedness up to the standards and criteria of NUREG-0654. These visits were accomplished between October 1979 and May of 1980. At each site, the NRC held meetings with the licensee and in some cases State and local representatives, open for public observation, and a separate meeting, usually in the evening, was held at which pubic comments were solicited.
I chaired a number of these public meetings.
During 1980 I participated in a number of Commission meetings and public workshops on the development of the final Emergency Prepared-ness rule which was published in August of 1980; and tnen after a final workshop, sponsored, by FEMA, with representatives of all States impacted by nuclear plant planning requirements we revised and ar.d published the Revision 1 to NUREG-0654. NUREG-0654. Revi-sion 1, is the basic criteria document used to evaluate onsite and offsite emergency preparedness.
4 During the sume of 1980 I participated in the development of NUREG-0696 entitled " Functional Criteria for Emergency Response Facilities." After issuance of a draft of this document for interim use and comment, a final version of the report was issued in February of 1981 after Commission approval of the report as evaluation criteria.
In late March 1981, the staff began an extensive onsite appraisal program designed to evaluate the upgrading of emergency prepared-ness tnat was initiated after TMI.
By late March 1982, a total of 54 appraisals had been completed. All operating reactor facility appraisals were conducted between April 1,1981 and April 1,1982.
As a part of the appraisal program 53 joint exercises were evaluated to verify adequate implementation of the upgraded emergency plans.
These exercises were designed to test the capabilities of the licensees as well as the local and State governmental emergency response organi-zations.
In summary, I have been involved in aspects of the NRC and FEMA efforts to upgrade the state of emergency preparedness around nuclear power plant sites.
Q.5. Describe the means employed by the NRC to assure corrective actions are taken by licensees to remedy significant deficiencies in emer-gency planning standards.
A.S. The NRC staff would identify any significant deficiencies in emergency planning standards after reviewing the onsite emer-gency response plans and evaluating the licensees' capabilities during onsite appraisals and exercises. Similarly, FEMA vould identify any significant deficiencies concerning the emergency planning standards after reviewing the offsite emergency response plans. Although FEMA does not have a separately defined inspection process as compared to their plan review process, FEMA does go into detail in many areas to verify that means are available to carry out the provisions of the offsite plans.
In addition, the joint exercise referred to in the answer to Question 4, above, tests the capability of offsite emergency preparedness plans of organizations, and FEMA provides a finding on the exercise to the NRC.
If the NRC determines that significant deficiencies exist, the provisions of 10 C.F.R. Part 50.54(s)(2) allow the licensee up to 120 days from the date of such a determination to take cor-rective action.
If the deficiencies are not corrected, the NRC
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will determine whether the reactor shall be shut down until such deficiencies are corrected or whether other enforcement action is approprfate. The NRC will base its determinations upon its own review of the licensees' onsite plan and on a review of FEMA's findings on the adequacy of State and local offsite planning.
Contention 3.6 - The emergency plans and proposed protective actions do not adequately take into account the full range of accident scenarios and meterolc&ical conditions for Indian Point, Units 2 and 3.
1 Q.6. Describe the extent to which emergency preparedness for Indian Point Units 2 and 3 accounts for a range of accident scenarios and meterological cord >tions.
A.6. The NRC staff position is that the emergency plans and proposed potential actions for Indian Point take into account both' fair and adverse weather conditions, and a range of accident conditions that include Class 9 accidents. The planning basis elements needed to scope the planning effort are (1) the distance to which planning for the initiation of predetermined protective actions is warranted; (2) the time dependent characteristics of potential releases and exposures and (3) the kinds of radioactive materials that can potentially be released to the environment. The techni-cal basis for each specific planning element is descrioed in NUREG-0396, Planning Basis for the Development of State and local governments, Radiological Emergency Response Plans in support of Light Water Nuclear Power Plants, December 1978.
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Contention 4.1 - The plume exposure pathway EPZ should be expanded from its present 10-mile radius in crder to meet local emergency response needs and capabilities.
Q.7. Describe the basis for NRC's use of a plume exposure pathway EPZ of about 10 miles for emergency planning around nuclear power plant sites.
A.7. The basis for the establishment by NRC of a plume exposure pathway EPZ of about 10 miles is described in NUREG-0396; EPA 520/1-78-016
" Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in Support of Light Water Power Pl' ants," December 1978 and summarized in NUREG-0654, Revision 1.
The size (about 10-mile radius) of the plume exposure EPZ was based on the following considerations:
a.
projected doses from the traditional design basis accidents would not exceed Protective Action Guide levels outside the zone; b.
projected doses from most core melt sequences would not exceed Protective Action Guide levels outside the zone; c.
for the worst core melt sequences, immediate life threatening doses would generally not occur outside the zone;
d.
detailed planning within 10 miles would provide a sub-stantial base for expansion of response efforts in the event that this proved necessary.
The NUREG-0396 report also illustrates the relative effectiveness of shelter versus evacuation at various distances, and indicates that shelter with subsequent relocation after cloud passage may be as effective as evacuation even in severe accident sequences at dis-stances greater than about 10 miles.
e Q.8. In your opinion do you believe the present plume exposure pathway EPZ of about 10 miles is appropriate for emergency planning in the vicinity of the site for Indian Point Units 2 and 3.
A.8. Yes. The selection of a radius of about 10 miles for the plume 1
exposure pathway EPZ was made in the Commission's final emergency preparedness regulations published August 19, 1980, which l
reference NUREG-0396.
I conclude that the rationale for selec-tion of the plume exposure pathway EPZ described above holds for the Indian Point site.
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M BRIAN K. GRIMES PROFESSIONAL QUALIFICATIONS OFFICE OF INSPECTION AND ENFORCEMENT
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I am employed as Director, Divisibh'of" Emergency Preparedness, Office of I
Inspection _and Enforcement, U. S. Nuclear Regulatory Commission Washington, D. C.
I am also the NRC Cochairman on the joint NRC/ Federal Emergency Management Agency (FEMA) Steering Committee for Emergency Preparedness.
Responsibilities-under my current assignments include directing the activitier of; personnel in the review of emergency plans for operating power reactors, operating licenses and construction permits and coordinating NRC and FEMA efforts in the review of emergen:y preparedness at and around nuclear power plant sites; assuring-that the NRC's Operations Center is staffed, trained, and ready to respond promptly and effectively to actual or simulated emergencies, o i directing the NRC's inspection program to ensure NRC licensees are maintaininc is effect emergency plans that there is no degradation in their ability to respond to emergpncies.
I~ attended the University of Washington, Seattle, Washington, and received a BS degree in Chemical Engineering in 1962 and a MS degree in Nuclear Engineering I
cin 1964. While completing my graduate work, I was employed as a research assistant at the University of Washington Engineering Experiment Station; -
my duties involved performing analytical and experimental work on the University of Wasnington research reactor.
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In 1963, I. accepted ekploynent with the Division of Reactor Licensing, USAEC. -
M/ first ~ assignment involved attendance at the International Institute for na E
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h Nuclear Science and Engineering at Argonne National Laboratory for four months.
Upon completion of this course, I was assigned as a Nuclear Engineer in the Division of Reactor Licensing. My initial duties included primary responsibility for the continuing review of the nuclear safety aspects of various research I subsequently particip'ated"in the safety evaluation of a number reactors.
of construction permit; applications for both pressurized and boiling water power reactors.
Later, as a Reactor Project Engineer in the Division of Reactor Licensing, I had primary responsibility for the safety review of the construction permit application for the Comonwealth Edison Company's Quad-Cities Units 1 and 2, for the Duke Power Company's Oconee Nuclear Station Units 1, 2 and 3, for 'the Metropolitan Edison Company's Three Mile Island Nuclear Station Unit 1, and
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for the Indiana & Michigan Electric Company's Donald C. Cook Nuclear Plant Units-1 and 2.
I was assigned to the position of Technical Coordinator for Reactor Projects in October, 1968.
Prior to March,1970, I served as Technical Coordinator for both pressurized and boiling water reactors. After March, 1970, as Technical Coordinator for Boiling Water Reactors, my responsibilities included coordinating the technical aspects of all safety reviews in the Boiling Water Reactor group, providing liaison with the pressurized water reactor group and serving as administrative assistant to the Assistant Director for Boiling Water Reactors.
I was assigned to the position of Chief of the Radiological Safety Branch,.
Division of Reactor Licensing in July,1971, in which position I was responsible for the review of systems necessary for the control and treatment of radioactivity O
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e under nonnal and accident conditions.
In January, 1972, the functions of this branch were diyided and I was appointed Chief of the Accident Analysis Branch. My responsibilities as Chief of the Accident Analysis Branch included reviewing calculational models', p'r'jed,ures and methods developed by members j
l-of the Branch for both conservative assessment and a realistic assessment of the onsequences,of a 3pectrum of accidents for all nuclear power plants and reviewing analyses of all nuclear power reactor sites performed by members of the Branch with regard to site related hazards and compliance with the guidelines of 10 CFR Part 100.
In January,1976, I was assigned to the position of Chief of the Environmental Evaluation Branch in the newly formed Division of Operating Reactors.
In this position my responsibilities included supervising the review of radiological and non-radiological impacts of operating
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nuclear power plants from both a safety and environmental standpoint.
Branch l
review areas included accident analyses, site-related hazards, effluent treatment systems, off-site radiological effects, and thennal and chemical effluents.
On April 1,1978,I was appointed Assistant Director for Engineering and Projects' in the Division of Operating Reactors.
In this position my responsibilities included managing the activities of the Engineering Branch, the Environmental Evaluation Branch, Operating Reactors Project Branch No. 3, Operating Reactors Project Branch No. 4 and the Standard Technical Specification Group.
On June 25, 1979, I was assigned Acting Assistant Director for Systems Engineering in th'e Division of Operating Reactors, and managed the Plant Systems Branch and the Reactor Safety Branch.
On October 25, 1979, I was designated Director l
of the Emergency Preparedness Task Group reporting to the Director of the, i
-y a.
d Office of Nuclear Reactor Regulation.
In November,1980, all reactor emergency -
preparedness review, activities were combined with NRC response activities in the new Division of Emergency Preparedness in the Office of Inspection and EnforcementandIwasappointehDik,ctprofthatDivision.
In this position, e
..,n t-I supervise the Emergency Preparedness Licensing Branch., Emergency Preparedness d..,.
Development., Branch and the Incident Response Branch.
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