ML20057F718

Comment Supporting Proposed Rule 10CFR50 Re Emergency Planning & Preparedness Exercise Requirements

ML20057F718
Person / Time
Site:	Seabrook
Issue date:	09/13/1993
From:	Feigenbaum T NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO)
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-58FR34539, RULE-PR-50 58FR34539-00012, 58FR34539-12, NYN-93124, NUDOCS 9310190020
Download: ML20057F718 (5)

Text

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3 P.O. Box 300 j

Seabrook, NH 03874 f

Telephone (603)474-9521

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Facsimile (603)474-2987 Energy Service Corporation

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Ted C. Feigenbaum

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Senior Vice President and Chief Nuclear Officer 1

NYN. 93124 g

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September 13,1993 8

Secretary of the Commission

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United States Nuclear Regulatory Commission f

C Washington, D.C. 20555 22 L

Attention:

Docketing and Service Branch g

Reference:

Facility Operating License No. NPF-86, Docket No. 50-443

Subject:

Proposed Rule: Emergency Planning and Preparedness Exercise Requirements (FR34539)

Gentlemen:

North Atlantic Energy Service Corporation (North Atlantic), as managing agent for Seabrook Station, is pleased to offer comments on the subject proposed rule.

North Atlantic supports the proposed rule. The change in the requirement for exercising the ingestion exposure pathway emergency plan from once in five to once in six years (Appendix E. Section l

IV.F Training; 2.d) makes NRC guidance in this regard consistent with that of FEMA. The six-year interval can tiso more easily be aligned with the biennial interval. This significantly simplifies scheduling for plants such as Seabrook Station which must coordinate with three states.

North Atlantic also agrees with the deletion of the regulation that requires all states within the plume exposure pathway emergency planning nne (EPZ) for a given site to fully participate in an offsite exercise for that site at least every seven years. The biennial exercise requirement ensures state participation since EPZ community participation and exercise demonstration relies on state direction.

Deletion of this rule will allow states with multiple sites more flexibility in scheduling their level of participation for a given site.

Since one of the purposes of the proposed rule is to remove inconsistencies and clear ambiguities, Nonh Atlantic recommends consideration of the additional changes indicated on the enclosure to this letter.

If you have any questions on this matter, please do not hesitate to call Mr. Donald R. Tailleart.

Emergency Preparedness Manager at (603) 474-9521, extension 3482.

Very truly yours.

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Ted C. Feigenbayfn TCF:)BlFact

, (j Enclosure a member of the Northeast Utilities system 9310190020 930913 PDR PR 50 5BFR34539 PR

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i United States Nuclear Regulatory Commission September 13,1993

.l Attention:

Docketing and Service Branch Page two i

cc:

Mr. Thomas T. Martin Regional Administrator U.S. Nuclear Regulatory Commission

'j Region I 475 Allendale Road -

r King of Prussia. PA 19406 i

Mr. Albert W. De Agazio, Sr. Project Manager l

Project Directorate 1-4 j

Division of Reactor Projects i

U.S. Nuclear Regulatory Commission

'l Washington, DC 20555 Mr. Noel Dudley

-l NRC Senior Resident Inspector P.O. Box 1149 l

Seabrook, NH 03874 l

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Recommended Revisions to 10 CFR 50, Appendix E i

Proposed or Recommended Chance:

Correct the inconsistencies between Appendix E.IV.F.1 and NUREG-0654. FEMA-REP-1,.

Revision I, Section 0.4.

Comment:

Numerous differences exist between NUREG-0654 training categories and Appendix E.IV.F.1

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training categories.

The following inconsistencies should be reviewed and corrected in the l

upcoming revision:

(a)

NUREG-0654, Section 0.4 identifies ten specific training categories (paragraphs a through j), whereas Appendix E.IV.F.1 ' identifies only nine categories-l (paragraphs a through i). NUREG-0654 identifies the tenth category (paragraph j) as: " Personnel responsible for transmission of emergency information and instructions." This category is redundant as it is incorporated in the other training categories recognized by Appendix E.IV.F.1.

Appendix E should note this inconsistency.

l (b)

The third training category (paragraph c) listed in Section 0.4 of NUREG-0654 lists a training commitment involving " radiological analysis personnel" in addition to the " radiological monitoring teams" referenced by the third training category (paragraph c) of Appendix E.IV.F.1.

We recommend adoption of the NUREG-0654, Section O.4 wording.

(c)

" Fire control teams (fire brigades)" are specifically recognized by paragraph (d) of Appendix E.IV.F.1 whereas NUREG-0654, Section 0.4, paragraph (d) recognizes " Police, Security and Fire fighting Personnel". The definition of a fire brigade differs at each site. Since each site provides for " fire brigade" training in conjunction with 10 CFR 50, Appendix R requirements, Appendix E should delete this reference. If the fire brigade reference remains in Appendix E.IV.F.1, we recommend that a note is added referencing each site's technical specification definition of" fire brigade" Proposed or Recommended Chance:

t The proposed Appendix E.IV.F.2 states "The plan shall describe provisions for the conduct of emergency preparedness exercises as follows: Exercises shall... test the public notification system.. "

Comment:

i The words " test the public notification system" should be deleted. The proposed Appendix E.IV.F.2 describes the general elements to be included in both onsite and full participation exercises. Since the activation of the public notification system is a component of the offsite plans only, testing the system should only be a part of the full participation exercise. Deleting the words would eliminate confusion as to whether testing the public notification system is required as part of the onsite exercise.

Recommended Revisions to 10 CFR 50, Appendix E Pror>osed or Recommended Chance:

Proposed Appendix E.IV.F.2 (e) states " Licensees shall enable any State or local government located in the plume exposure pathway EPZ to panicipate in annual exercises when requested by.

such State or local government".

Comment:

The wording of the above requirement is inconsistent with the requirement for full panicipation exercises to be conducted every two (2) years. If biennial exercises are the rule, then that should be the standard. As stated, a licensee must " enable" State / local participation annually if they decide that it is warranted. To most State and local organizations, the word " enable" means that the licensee is required to provide financial reimbursement for State / local participation where this has been common practice. In addition, many local participants will not panicipate unless the event is scheduled off-hours. Both conditions mentioned present the licensee with a considerable budgetary commitment. It is also not clear what benefits would be gained by State and local organizations by participating in an exercise that, by design, focuses on licensee response organization performance and may have little, if any, off-site consequences.

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