ML20054D888
| ML20054D888 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 04/20/1982 |
| From: | Perrotti D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20054D873 | List: |
| References | |
| NUDOCS 8204230476 | |
| Download: ML20054D888 (19) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of LOUISIANA POWER AND LIGHT COMPANY
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Docket No. 50-382
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(Waterford Steam Electric Station, Unit 3)
NRC STAFF TESTIMONY OF DONALD J. PERROTTI REGARDING EMERGENCY PLANNING (CONTENTION 17/26)
Q.1.
Please state your name and occupation.
A.1.
My name is Donald J. Perrotti.
I am employed by the U.S. Nuclear Regulatory Commission as an Emergency Preparedness Analyst in the Emergency Preparedness Licensing Branch, Division of Emergency Preparedness, Office of Inspection and Enforcement.
Q 2.
Please describe the nature of the responsibilities you have had with respect to emergency planning of nuclear facility applicants and licensees.
A.2.
Since October 1980, I have had responsibility for the review and evaluation of radiological emergency plans submitted by reactor applicants and licensees to assure proposed plans meet the regula-(
tory requirements and guidance of the Commission.
I also function as a Team Leader and Team Member on Emergency Preparedness i
Appraisal Teams engaged in the onsite inspections of the l
implementation phase of licenses emergency programs.
I observe l
nuclear power plant emergency drills and exercises involving State j2042309 % :
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. l and local government response agencies and participate in interagency critiques.
i For the four year period prior to my assumption of my present responsibilities, I was the lead inspector at the NRC's Region II Office of Inspection and Enforcement in Atlanta, Georgia, where I was responsible for planning, conducting and documenting inspections of licensees' emergency plans and procedures, emergency facilities and equipment, emergency training, tests and drills, and coordination with offsite support agencies.
Q.3.
Have you prepared a statement of professional qualifications?
A.3.
Yes. A copy is attached to this testimony.
Q.4.
Please describe the nature of the responsibilities you have had with respect to the Waterford Steam Electric Station, Unit No. 3.
A.4.
I performed the NRC Staff's review of the Waterford Unit 3 Emer-gency Plan, as originally set forth in the Applicant's Final Safety Analysis Report (FSAR), Section 13.3.
Subsequent to its receipt of the Emergency Plan, the Staff submitted two rounds of questions to the Applicant; I reviewed the Applicant's responses to those questions, and prepared the Staff's evaluation of the Emergency Plan as set forth in.the " Safety Evaluation Report Related to the Operation of Waterford Steam Electric Station, Unit No. 3" (SER)
(NUREG-0787, July 1981), and in Supplement 1 to the SER, issued in October 1981.
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. On February 22, 1982, the Applicant submitted to the NRC a reformatted Emergency Plan, which was extracted from and replaced the Emergency Plan contained in the FSAR (all references to the Applicant's Emergency Plan in the balance of this testimony are.to the reformatted Emergency Plan).
The NRC Staff has completed its review of this revised document against requirements of 10 CFR Part 50 and the criteria of NUREG-0654, except in two areas; the Staff's review of these other areas is ongoing at this time.
In addition, the Staff has identified the need for further clarifica-tion of certain matters, and has obtained a commitment from the Applicant to provide further information and incorporate necessary changes to the Emergency Plan, by letter dated April 7, 1982.
Q.5.
In the Staff's view, is the reformatted Emergency Plan in compliance with applicable NRC requirements?
A.5.
Yes, except as to the matters referred to in response to Q.4 above.
Q.6.
What it the purpose of this testimony?
A.6.
The purpose of this testimony is to respond to Contentions 17/26(1) and 17/26(2) in this proceeding related to the Applicant's Emergency Plan.
Those contentions read as follows:
17/26(1)
Applicant has failed to adequately make provision, according to the Emergency Plan contained in Chapter 13.3 of the FSAR, for evacuation of individuals located within the 10-mile plume exposure pathway emergency planning zone for the Waterford 3
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site in the event of a serious reactor incident, as required by applicable NRC regulations, in that:
a.
the provisions for notifying residents of evacuation procedures are inadequate; b.
the roads and highways necessary for such evacuation are inadequate; c.
the evacuation warning system is inadequate; j
d.
there is not an adequate command decision structure, including appropriate guidance, for comencing evacuation; c
e.
F gency Plan fails to provide for realistic and
..ensive evacuation drills, in t:2t the provisions for moving individuals are not actually tested; e
f.
procedures are inadequate for evacuating people who are:
i (i) without vehicles
,J (ii) school children (iii) aged or crippled iv) sick and hospitalized v) imprisoned vi) transient workers.
'17/26(2)
Applicant has failed to adequately make provision, according to i the Emergency Plan contained in Chapter 13.3 of the FSAR, for distribution and/or storage of potassium iodide in accordance with accepted public health practice in locations which are readily accessible to affected individuals as protection against thyroid irradiation.
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Q.7.
WithrespecttoContention17/26(1)(a),pleasedescribebhe Commission's requirements and guidance concerning the provisions for notifying area residents of evacuation procedures, ard compare the provisions made by the Applicant with those required by regula-tion and/or recommended in NUREG-0654.
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. A.7.
10 CFR 50, Appendix E, Paragraph IV.D.2 requires that provisions shall be described for yearly dissemination to the public within the plume exposure pathway Emergency Planning Zone (EPZ) of basic emergency planning information, such as the methods and times required for public notification and the protective actions planned if an accident occurs, general information as to the nature and effects of radiation, and a listing of local broadcast stations that will be used for dissemination of information during an emergency.
Signs or other measures shall also be used to disseminate to any transient population within the plume exposure pathway EPZ appropriate information that would be helpful if an accident occurs.
Criteria contained in NUREG-0654 stipulate that information should be provided to members of the public within the plume exposure EPZ, at least annually, on radiation, on how they will be notified in the event of an emergency, on what their actions should be, and on contact points for additional information.
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Section 6.7.2 of the Emergency Plan contains, in part, the following representations:
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The Louisiana Office of Emergency Preparedness, l
St. Charles Parish,1St. John the Baptist Parish, and l
Louisiana Power & Light Co. coordinate, develop and disseminate information annually to the public regarding how they will be notified and what their actions should be in the event of an emergency. This information includes accurate and understandable information on radiation; contacts for additional information; protective measures, e.g. -evacuation routes and relocation centers,
. sheltering, respiratory protection; and the special needs of the handicapped.
The public information program addresses the needs of both the permanent and transient population within the 10 mile EPZ potentially subject to plume exposure. The information provided to the permanent residents will include printed material suitable for retention by the residents such that it can be readily referred to during an emergency such as, information in telephone books, wall stickers, periodic information in utility service bills, and various publications designed to inform simply and quickly.
Updated information is disseminated at least annually.
Measures are taken to disseminate emergency response information to the transient population, such as posting signs, decals, or notices at public facilities.
This ensures the transient population within the plume exposure pathway are informed on how to protect themselves and, if necessary, evacuate an area.
In addition to advising immediate actions to be taken, information is provided, such as telephone numbers to call and radio and television stations to listen to which provide additional instructions and rumor control.
The Applicant has developed a draft public information brochure which contains the pertinent information as specified in its Emergency Plan; however, that broch re has not yet been finalized, nor has the Applicant finalized plans to distribute the brochure to residents in the plume exposure EPZ. Other printed matter (signs posted in motels, for example) will be placed in public facilities, although the date for such action has not been finalized.
Based on the Staff's review of the Applicant's Emergency Plan, as stated above, the Staff has concluded that the Applicant's public information program (i.e., its provisions for notifying residents l
of evacuation procedures) meets the requirements of 10 CFR 50, Appendix E, Paragraph IV.D.2 and the criteria of NUREG-0654 The
. implementation of the public information program will be reviewed and evaluated by the NRC Staff during the Emergency Preparedness Implementation Appraisal to be conducted later this year.
The Staff will ensure that the public information and education program meets the Commission's requirements prior to issuance of a full power license.
The Staff's evaluation and conclusions pertaining to the Applicants' procedures for notifying State and local officials in the event of an emergency are discussed in response to Q.10, below.
Q.8.
With respect to Contention 17/26(1)(b), please describe the Commission's requirements and guidance concerning roads and high-ways necessary for evacuation, and describe the Staff's analysis of the evacuation routes in light of Commission requirements and/or the recommendations contained in NUREG-0654 A.8.
10 CFR 50.47(b)(10) specifies that the onsite and offsite emergency response plans must include a range of protective actions (e.g.,
evacuation and sheltering) that meet the specific criteria in NUREG-0654.
These criteria specify that the Applicant's plan shall contain time estimates for evacuation within the plume exposure EPZ, in accordance with Appendix 4 NUREG.0654 also specifies i
other criteria that must be included in the plans to implement l
l protective measures for the plume exposure EPZ.
Neither the Commission's regulations nor NUREG-0654 require that any particular
. 7 evacuation route capacity exist as part of an Applicant's emergency
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preparedness capability.
An updated evacuation time estimate study, dated February 1982, has been submitted by the Applicant to FEMA and the NRC Staff.
This revised evacuation time estimate study has been incorporated into the Emergency Plan as Appendix 8.
The NRC Staff has retained the
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services of Thomas Urbanik II as its consultant concerning the adequacy of the Applicant's evacuation time estimate study.
Mr. Urbanik has conducted a review of that study on behalf of the Staff and has informed the Staff that the Applicant's study conforms with the criteria set forth in NUREG-0654 and that the methodology utilized provides reasonable estimates of evacuation times upon-which a State decision-maker may base its decision as to whether to evacuate the area or take other protective measures. Mr. Urbanik's testimony is being submitted simultaneously herewith.
Q.9.
With respect to Contention 17/26(1)(c), please describe the Commission's requirements and guidance concerning the evacuation warning system, and analyze the Applicant's evacuation warning system in light of those requirements and/or the recommendations l
contained in NUREG-0654.
A.9.
Requirements as to the alert and notification system are set forth in 10 CFR 50, Appendix E, Paragraph IV.D.3.
That provision requires, in part, the following:
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responsible State and local governmental agencies within 15 minutes after declaring an emergency.
The licensee shall demonstrate that the State / local officials have the capability to make a public notification decision promptly on being informed by the licensee of an emergency condition....
Each nucicar power reactor licensee shall demonstrate that administrative and physical means have been established for alerting and providing prompt instructions to the public within the plume exposure pathway EPZ....
The design objective of the prompt public notification system shall be to have the capability to essentially complete the initial notification of the public within the plume exposure pathway EPZ within about 15 minutes.
The use of this notification capability will range from immediate notification of the public (within 15 minutes of the time that State and local officials are notified that a situation exists requiring urgent action) to the more likely events where there is substantial time available for the State and local governmental officials to make a judgment whether or not to activate the public notification system....The responsibility for activating such a public notification system shall remain with the appropriate governmental authorities.
10 CFR 50.47(b)(10) requires that onsite and offsite plans must include a range of protective actions for the plume EPZ, that guidelines for t:1e choice of protective actions be consistent with Federal guidance, and that protective actions for the ingestion EPZ appropriate to the locale have been developed.
Guidance contained in NUREG-0654 addressing protective actions covers not only evacuation, but sheltering and ad hoc respiratory protection, as well. Appendix E to 10 C.F.R. 50, IV.D.3, provides that the responsibility for activating the alert and notification system is properly the responsibility of State and local governments; the responsibility for demonstrating that such a system is in place rests with the Applicant.
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. Section 6.7.1 of the Emergency Plan specifies that once local and State authorities have been notified, several methods to warn the population-at-risk can be utilized.
The method used and the time required will depend on the severity of the situation.
The methods available are the Emergency Broadcast System (EBS); siren system; central dispatching; the St. Charles Parish Emergency Preparedness / Industrial Hot Line System; emergency vehicles equipped with loudspeakers; house-to-house notification; amateur radio; and citizens band radio.
Further details with respect to these methods are set forth in Section 6.7.1 of the Applicant's Emergency Plan.
The Applicant submitted to the NRC, on August 10, 1981, its i
conceptual design of the alert and notification system for the plume exposure pathway EPZ.
On February 24, 1982, the Applicant submitted a further report entitled " Verification of the Siren Alert System for Waterford 3 Nuclear Power Station" (February 1982), prepared by Acoustic Technology, Inc. (ATI) under contract with the Applicant, which includes siren location changes as requested by St. Charles and St. John the Baptist Parishes.
Since the alert and notification system proposed by the Applicant has not been completely installed and tested, no determination as to adequacy can be made at this time.
The NRC Staff will require that'the Applicant demonstrate that the system meets the require-l I
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a ments of 10 CFR 50, Appendix'E, Paragraph IV.D.3 prior to issuance of a full power license.
To the extent that the contention employs the phrase " evacuation warning system" to mean methods of notifying individuals of an emergency situation other than by the " alert and notification system", please refer to my responses to Q.7 and Q.10.
Q.10. With respect to Contention 17/26(1)(d), please describe the Commission's requirements and guidance concerning command decision
-structures, and analyze the Applicant's command decision structure in light of those requirements and/or the recommendations set forth in flVREG-0654.
A.10.10 CFR 50, Appendix E, Paragraph IV. A sets forth particular requirements as to the identification in the Emergency Plan of onsite and offsite authorities (including State and local officials) who will be responsible for taking necessary actions in the event of an emergency.
These include an identification of (a) onsite individual (s) who will take charge during an emergency, and who will be in charge of the exchange of information with i
offsite authorities responsible for coordinating and implementing offsite emergency measures, as well as (b) the State and/or local officials responsible for planning for, ordering, and controlling appropriate protective actions, including evacuations when necessary, i
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. Section 5.1 of the Emergency Plan describes the Applicant's emergency organization, which consists of the Emergency Onsite Organization and the Emergency Offsite Support Organization.
The Nuclear Operations Supervisor-Shift Supervisor (NOS-SS), who directs the on-site shift organization will implement the Emergency Plan as required and has the responsibility and authority for declaring emergencies until relieved by the Emergency Coordinator.
The line of succession for the position of Emergency Coordinator is specified in the Emergency Plan. Among the responsibilities of the Emergency Coordinator which cannot be delegated is the decision to notify and recommend protective actions (including evacuation of people in the EPZ) to offsite authorities.
Section 6.2.1 of the Emergency Plan commits to prompt notification (within 15 minutes) of offsite agencies by the Emergency Coordinator.
Section 6.5.1.2 of the Emergency Plan provides guidance to the Emergency Coordinator as to the choice of protective action recommendation based on the type of emergency.
The Applicant's choices of recommended protective actions are consistent with those estab-lished in the EPA manual of Protective Guides and Protective Actions for Nuclear Incidents, EPA-520/1-75-001.
Emergency Plan Implementing Procedures (EPIP) provide detailed instructions to the Emergency Coordinator as to the notification of and recommended protective actions to offsite authorities.
The Staff's review of the Applicant's Emergency Action Level scheme against the criteria of NUREG-0654 is ongoing at this time.
. The Applicant's Emergency Offsite Support Organization is responsible for offsite emergency management activities and will provide assistance to or obtain assistance for the Emergency Onsite Organization as required. A description of the offsite organization, its duties, and the time at which those duties are activated, are set forth in Section 5.1.4 and Table 5.1 of the Applicant's Emergency Plan. After the Emergency Offsite Organi-zation has been activated, the duties of coordinating with State and local officials is assumed by the Emergency Operations Facility Director.
In the event of an emergency at Waterford Unit 3 which dictates notification of State and local agencies, an operational hotline located in the control room will be used to make the initial notifications.
This system provides dedicated telephone links with St. Charles Parish, St. John the Baptist Parish, the Louisiana Office of Emergency Preparedness, and the Louisiana Nuclear Energy.
Division.
Section 7.5.2 of the Emergency Plan describes various other emergency communication systems that are available to the Applicant for notifying offsite authorities.
The Staff has determined that clarification is needed with regard to distinguishing between the primary and backup means of emergency communication.
By letter dated April 7, 1982, the Applicant has committed to provide additional information to clarify this aspect i
of the Emergency Plan.
. In addition, the Staff has determined that additional information l
is required as to the "offsite emergency notification system", the description of which is omitted from the Applicants' Emergency Plan (p. 7-38); as to a diagram of the interfaces between onsite, corporate headquarters, local se, vices support, and state and local governmental response organizations; as to the training to be provided for Corporate Emergency Center (CEC) personnel; as to the duties of the Emergency Planning Coordinator; and as to the i
training to be provided to individuals responsible for the planning effort. The Applicant has committed to providing additional information to clarify these aspects of its Emergency Plan, by letter dated April 7,1982. Subject to satisfactory resolution of these items, the Staff has concluded that the Applicant's organization and provisions for command decision, including guidance for commencing evacuation, meet the requirements of 10 CFR Part 50, Appendix E, Paragraph IV.A, and the criteria set forth in NUREG-0654.
Q.11. With respect to Contention 17/26(1)(e), please describe the i
j Commission's requirements and guidance concerning evacuation i
drills, and analyze the proposed evacuation drills for Waterford Unit 3 in light of those requirements and/or the recommendations set forth in NUREG-0654.
A.11.10 CFR 50, Appendix E, Paragraph IV.F. requires, in part, that each licensee shall exercise at least annually the emergency plan for each site at which it has one or more power reactors licensed for
. operation, which shall include participation by appropriate State and local government agencies.
That provision further specifies that "a full-scale exercise which tests as much of the licensee, State, and local emergency plans as is reasonably achievable without mandatory public participation shall be conducted" (emphasis added).
10 CFR 50.47(b)(14) specifies that periodic exercises will be conducted to evaluate major portions of emergency response capabilities, periodic drills will be conducted to develop and maintain key skills, and deficiencies identified as a result of exercises or drills will be corrected; there is no requirement that evacuation of individuals, whether mandatory or voluntary, be conducted as part of the required drills.
Section 8.1.2 of the Emergency Plan describes the Applicant's drill and exercise program.
Section 8.1.2.4 specifies that a major annual exercise simulating a Site or General Emergency shall be held, which is to include evacuation of non-essential onsite personnel.
The NRC Staff will require that evacuation of non-essential onsite personnel be demonstrated during the emergency exercise held prior to licensing.
Based on the Staff's review of the Applicant's Emergency Plan, the Staff has concluded that the Applicant's program for drills and exercises meets the requirements of 10 CFR 50, Appendix E, Paragraph IV.F and the criteria of -
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. Q.12. With respect to Contention 17/26(1)(f), please describe the Commission's requirements and guidance, if any, concerning the evacuation of offsite individuals in the event of an emergency.
A.12. 10 CFR 50.47(b)(10) specifies that the onsite and offsite emergency plans must demonstrate that:
A range of protective actions have been developed for the plume exposure pathway EPZ for emergency workers and the public.
Guidelines for the choice of protective actions during an emergency, consistent with Federal guidance, are developed and in place, and protective actions for the ingestion exposure pathway EPZ appro-priate to the locale have been developed.
Criteria in NUREG-0654 address the Applicant's role in the evacuation of ron-essential onsite personnel, and the state and local governments' roles in the evacuation of offsite personnel.
The adequacy of State and local response plans with respect to e.scuating offsite individuals, such as those who are without vehicles, aged, crippled, sick, hospitalized, imprisoned, or transients, has been reviewed and evaluated by FEMA.
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Q.13. With respect to Contention 17/26(2), please describe the Commission's requirements and guidance concerning the distribution and/or storage of potassium iodide to affected individuals, and analyze the proposed plan for such measures in the event of an emergency at the Waterford Unit 3 site in light of those require-ments and/or the recommendations set forth in NUREG-0654.
A.13. 10 CFR 50.47(b)(11) requires that the Applicant establish the means for controlling radiological exposures in an emergency. NUREG-0654
. specifies that the Applicant shall make provisions for use of radioprotective drugs (e.g., individual thyroid protection) for individuals remaining or arriving onsite during the emergency.
The Applicant's Emergency Plan provides for the storage onsite and distribution of potassium iodide (KI) to Waterford Unit 3 emergency workers, and to offsite emergency support personnel such as fire fighters, for thyroid blocking to minimize I-131 uptake.
While the NRC's emergency planning regulations require that a range of pro-tective actions be developed for the public in the plume exposure EPZ (10 CFR 50.47(b)(10)), they do not specifically require that protective actions for the general public include the use of radioprotective drugs. Guidance in NUREG-0654 indicates that planning for protective actions should include provisions for the use of radioprotective drugs, particularly for emergency workers and institutionalized persons within the plume exposure EPZ, and that State and local plans should include the method by which the State Health Department may decide whether to administer radio-protective drugs to the public during an emergency.
Based on the Staff's review of the Applicants' Emergency Plan as stated above, the Staff has concluded that the Applicant's provision for use of radioprotective drugs meets the requirements of 10 CFR 50.47(b)(11) and the criteria of NUREG-0654.
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DONALD J. PERROTTI 0FFICE OF INSPECTION AND ENFORCEMENT STATEMENT OF PROFESSIONAL QUALIFICATIONS I am employed as an Emergency Preparedness Analyst in the Emergency Preparedness Licensing Branch, Division of Emergency Preparedness, Office of Inspection and Enforcement, U.S. Nuclear Regulatory Commission.
I have responsibility for the review and evaluation of radiological emer-gency plans submitted by reactor applicants and licensees to assure that proposed plans meet the regulatory requirements and guidance of the Commission.
I also function as a Team Leader and Team Member on Emer-gency Preparedness Appraisal Teams engaged in the onsite inspection of the implementation phase of licensee emergency programs.
I observe nuclear power plant emergency drills and exercises involving State and local government response agencies and participate in interagency critiques.
From December 1976 to October 1980 I was employed at the NRC's Region II Office of Inspection and Enforcement in Atlanta, Georgia.
I was the lead inspector for Region II emergency planning inspections at nuclear power reactors and fuel facilities. My responsibilities included planning, conducting and documenting inspections of licensees' emergency plans and procedures, emergency facilities and equipment, emergency train-ing, tests and drills, and coordination with offsite support agencies.
From April 1977 to August 1978, I assisted my immediate supervisor who served as Chairman of the Federal Regional Advisory Coninittee (RAC) in the review of State Radiological Emergency Plans.
During October 1978 I assisted in the review and approval of emergency plans for two nuclear fuel facilities. During the period of March - August,1979, I partici-pated in the Commission's coverage of environmental monitoring programs at Three Mile Island, where I served as Emergency Monitoring Team Leader; in that capacity, I was responsible for coordination with State and Federal agencies engaged in measurement and evaluation of environmental radioactivity levels in the vicinity of the TMI nuclear plant.
From 1973, to [1976], I was employed at Florida Power and Light Company's Turkey Point Nuclear Power Plant, as Health Physics instructor.
My duties included radiation safety training of plant personnel (general employees and technicians), special project reports such as providing background material for management comment on proposed changes to the Code of Federal Regulations, and maintaining radiation exposure records for plant personnel.
From 1953 to 1973, I served in the United States Army. As a member of the U.S. Army Engineer Reactors Group during the period 1961-1973, I performed a variety of jobs with varying degrees of responsibility as rank and experience were gained. Among my more responsible jobs were shift health physics technician at the PM-3A Naval nuclear power plant in McMurdo, Antarctia (1965-1966), Senior Health Physics / Process Chemistry instructor at Ft. Belvoir, Virginia (1966-1972), and Project Officer for SM-1 Army nuclear power plant (1972-1973).
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. I received an Associate of Arts Degree in Health Physics from the New York State Regents, Albany, NY, in 1973.
In addition, I attended Army service schools including Special Nuclear Weapons Disposal and the 52-week Nuclear Power Plant Operators course.
I have completed the following U.S. Public Health Service courses:
Basic Radiological Health Radionuclide Analysis by Gamma Spectroscopy Environmental Radiation Surveillance Analysis of Radionuclides in Water Occupational Radiation Protection Chemical Analysis for Water Quality Statistical Methods - Quality Control in the Laboratory Operational Aspects of Radiation Surveillance Reactor Hazards Evaluation I attended the " Radiological Emergency Response Operations" course at the Nevada Test Site and the " Planning for Nuclear Emergencies" course at Harvard University.
I am and have been a member of the Health Physics Society since 1974.
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