ML20087G486

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Motion to File Supplemental Contention on State of Nh & Local Emergency Response Plans.Contention Based on Applicant Recent Probabilistic Safety Assessment Rept.Certificate of Svc Encl
ML20087G486
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 01/01/1900
From: Curran D, Jordan W
HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION
To:
Atomic Safety and Licensing Board Panel
References
NUDOCS 8403200036
Download: ML20087G486 (8)
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Text

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DOCKETED if3ff6h 15, 1984

'84 11Ag 39 ,yg 40 UNITED STATES OF AMERICp_EE n5 0? SECRGm D ,';c. r NUCLEARREGULATORYCOMMISsI'UN$

BEFORE'THE ATOMIC' SAFETY AND LICENSING BOARD 4

)

Public Service Company of New )

Hampshire, et al. ) Docket Nos.

) 50-443, -444 (Seabrook Station, Units 1 and 2) )

)

NECNP MOTION TO FILE SUPPLEMENTAL CONTENTION ON NEW HAMPSHIRE STATE AND LOCAL EMERGENCY RESPONSE PLANS Introduction NENCP moves that the Board admit this supplemental emergency planning contention, which is based on Applicants' recently available Probablistic Safety Assessment.- The conten't ion meets the NRC's standards for late-filed contentions, as discussed below.

Contention The New Hampshire state and local emergency response plans do not comply with the requirements of 10 C.F.R. S 50.47(b)(5),

Section IV. D.3 of Appendix E to 10 C.F.R. Part 50, or NUREG-0654 S II.E.6, in that the audible alert systems on which they rely cannot be depended upon to provide prompt notification to the public.in an emergency.  !

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8403200036 840315 PDR ADOCK 05000443 9 ," ._ PDR, ..q j

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6 Basis:

Under NRC regulations, operating license applicants must demonstrate the existence of "means to provide early notification" of an emergency to the public within the plume exposure pathway Emergency Planning Zone. 10 C.F.R. 3 50.47(b)(5). The notification system must be designed "to have the capability to essentially complete the initial notification of the public within the plume exposure pathway EPZ within about 15 minutes." Appendix E, 5 IV.D.3. The notification system must assure direct coverage of essentially 100% of the public within 5 miles of the plant in 15 minutes, and provide special arrangements to notify 100% of the population in the a entire EPZ within 45 minutes. NUREG-0654, Appendix 3, implementing S II.E.G.

The radiological emergency response plan for the state of New Ilampshire relies on sirens and NOAA tone alert weather radios for initial alerting in the EPZ. RERP at 2.1-7. Local plans rely on sirens, tone-activated radios, and mobile public-address units for initial public notification. See local plans, S II.A. These audible alert systems have not~been designed yet.

To the extent that any.of.these systems depen..i upon offsite power sources to operate, they cannot be relied upon to function during an accident at Seabrook. .The Seabrook Station l Probabilistic Safety Assessment ("PSA") prepared for Applicants l

l by Pickard, Lowe and Garrick, Inc. in December of 1983, demonstrates-that over half of the accidents at Seabrook

v leading to a significant radioactive release (and thus requiring an emergency response) would involve a loss of offsite power.* Therefore the sirens and any other notification devices dependent upon offsite power are likely to be disabled and rendered useless in an emergency at Seabrook.

In order to provide the necessary reasonable assurance that the populace in the EPZ can be notified promptly of an emerger.cy, Applicants should provide for some alternative, independently powered audible alert system to coapensate for failure of the sirens or other offsite power-dependent notification systems.

  • NECNP used statistics provided in Applicants' PSA to calculate that 55% of core melt accidents leading to a significant radioactive release would involve loss of of fsite i power. Of the six release categories defined in the PSA, NECUP considered those categories that wculd involve containment breach and lead to a major radioactive release, thus triggering {

l an offsite emegency response. These release categories j consisted of the following:

RELEASE CATEGORY DESCRIPTION F REQUENCY S6V -- large containment bypass 2.4 x 10-6 1:417,000 S2V -- small containment bypass 1.8 x 10-5 1: 56,000 S3V -- late overpressure failure 8.0 x 10-5 1: 12,500 with vaporization release S3 -- late overpressure with no 5.8 x 10-5 1: 17,200

, vaporization release l

The overall core melt frequency from these category releases is 1.6 x 10-4 or about 1:6,250.

The PSA demonstrates that loss of offsite power-events contribute to about 38% of the total frequency of core melts leading to significant releases, or 6.0 x-10-3 See PSA-Table 2.3-3, attached. Scismic events, which cause a loss of offsite power by failing insulators on the distribution lines, contribute to about 17% of'the total core melt frequency leading to a significant release, or 2.7 x 10-5. Id. Thus, loss of offsite power is involved in at leact'55% of all core melt accidents which lead to atmosphe'ric containment failure.

A____--. .___.----A-_.-.-.-----.-_

- .u_. --_ . .- - _ - -- _ . - - . . ~_ --_-

F M

Justification for Late Filing of Contention This contention meets the requirements of 10 C.F.R. 33 2.714(a)(1) and (b) for admission of late-filed contentions.

1. NECNP has good cause to file the contention at this time. The contention relies principally on the Probabilistic Safety Assessment prepared by Pickard, Love, and Garrick for Applicants in December of 1983. That PSA did not reach the l NRC's Public Document Room until January 30, 1984. As soon as NECNP learned that the study was in the PDR we immediately obtained expert assistance in interpreting the PSA, which consists largely of statistical tables and computer printouts.

This contention is filed promptly.

2. NECNP knows of no other means by which our interest in this issue can be protected, since the Atomic Safety and Licensing Board is the only tribunal which can consider it.
3. NECNP's participation in litigating this issue can be reasonably expected to contribute substantially to the record of the hearing. We have already obtained expert assistance in interpreting the PSA data, and expect to continue to contribute that expertise to the hearing record.
4. NECNP knows of no other party that has raised this particular issue before the Licensing Board.
5. Litigation of this contention will not broaden or delay the proceeding beyond the scope and-timing already expected.

The Board can reasonably expect that.once the design of the

s audible alert system is submitted, parties will file contentionn on the adequacy of the design. In fact, admission of this contention now may expedite the hearings by notifying other parties of NECNP's concerns regarding the design of the l audible alert system before the design is completed.

We consider that the plans' stated intention to rely in part on sirens, coupled with the information revealed in the PSA, is sufficient basis for admission of a contention at this point. The issues will be clarified, however, when the design of the audible alert systen, showing the extent to which the system relies on sirens and other offsite power-dependent avstems, is submitted. Thus admission of this contention now will permit more orderly and expeditious litigation of the 4

adequacy of the audible alert system once the design become available.

Respectfully submitted, Diane Curran k

William S. Jo an, IIIr HARMON, WEISS JORDAN 1725 I Street, N.W.

Suite 506 -

Washington, D.C. 20006 (202) 833-9070 Dated: March 15, 1984

TABLE 2.3-3. CONTRIBUTIONS OF SEQUENCES GROUPED BY INITIATING EVENT TO FREQUENCY OF RISK SIGNIFICANT RELEASE CATEGORIES AhD CORE MELT Release Category Frequency Contributions fevents per reactor year) Core Melt Initiating , g,g, Frequency Event Initiating Event Large Small ate Contributions Group Containment Containment Basemat Overpressure D erpressure - Containment Intact (ewnts m Cypass with No Vaporization nactor year)

By Lass Mrit,34V-Through tio 55 av T,2V Vaporiza,gy,n g,j,,,, Release 53 Loss of Large LOCA * * * *

  • 1.1-6 1.4-6 Coolant Small LOCA * * *
  • 2.5-6 1.7-5 2.0-5 Inventory Interfacing Systems LOCA 1.8-6 0 0 0 0 0 1.8-6 Steam Generator Tube Rupture *
  • 1.0-7 8.2-7
  • 6.3-6 6.2-6 1,3-5
  • * * *

Loss of Main Feeduater * * '

  • 1.0-6 8.3-6
  • 1.1-5
  • *
  • 5.0-6 2.6-6 7.8-6

.Y-Partial Feedwater loss *

  • 8.9-! 1.1-6
  • * * *
  • 4.9-6 5.0-6 MSiv Closure Loss of Primary Flod * * .
  • 1.2-6 1.1-6 2.4-6 Steam Line dreak * * * *
  • 6.9-6 7.3-6
  • * *
  • 5.0-7 1.4-7 7.8-7 Main Steam Relief Opens Coween Cause Loss of Offsite Power *
  • 6.8-6 5.5-5 4.9-6 1.5-6 6.9-5 initfating Loss of One DC Dur * * * *
  • 1.7-6 2.3-6 Events- Loss of Serv!ce Water * * *
  • 2.5-6 0 2.5-6

- Support Loss of Compr,ent Cooling * * *

  • 1.4-6 0 1.4-6 System  ;

Faults

- External Seismic Events (total) 5.8-7 1.7-5 5.3-7 4.0-6 2.9-6 2.8-6 2.8-5 Evee.ts Fires (total) *

  • 6.6-7 5.3-6 2.0-5
  • 2.5-5 Flood (total) *
  • 2.3-7 1.9-6 1.8-6
  • 3.9-6
  • 1.8-7 1.4-6 1.4-7
  • 1.8-6 Truck Crash Total 2.4-6 1.8-5 1.0-5 8.0-5 5.8-5 6.0-5 2.3-4

~

  • Less than 11 contributton to release category frequency. >

NOTE: Exponenttal notation is Indicated in abbreviated form; 1.e. 1.1-6 = 1.1 x 10-6, e

CERTIFICATE OF SERVICE I certify that on March 15,1984, copies of flECNP MOTION TO FILE SUPPLE!! ENTAL CONTENTION Oli NEW IIAMPS!! IRE STATE A!1D LOCAL EMERGE! ICY RESPOtiSE PLAtlS were served on the following by first-claus mail or as otherwise indicated:

  • Ilelen Hoyt, Esq., Chairperson Rep. Roberta C. Pevear Atomic Saftey and Licer. sing Board Drinkwater Road Panel Hampton Falls, Nil 03844 U.S. tiuclear Regulatory Commission Washington, DC 20555
  • Dr. Emmeth A. Luebke Phillip Ah rens, Esq.

Administrative Judge Assistant Attorney General Atomic Saftey and Licensing Board S tate llouse, Station # 6 U.S. tiuclear Regulatory Commissior. Augusta, ME 04333-Washington, DC 20555

  • Dr. Jerry !! arbour Robert A. Backus, Esq.

Administrative Judge 111 Lowell Street Atomic Saftey and Licensing Board Manchester, N!! 03105 U.S. 11uclear Regulatory Commission Washington, DC 20555 Atomic Safety and Licensing Board *

  • Thomas G . Dignan, Esq.

Panel R. K. Gad, III, Esq. .

II.S. Nuclear Regulatdry Commission Ropes and Gray Washington, DC 20555 225 Franklin Street Boston, MA 02110 Atomic Safety and Licensing Appeal Dr. Mauray Tye, President Board Panel Sun Valley Asociation U.S. Nuclear Regulatory Commission 209 Summer Street Washington, DC 20555 Haverhill, MA 01830 Docketing and Service

  • Robert G. Perlis, Esq.

U.S. Nuclear Regulatory Commission William F. Patterson, Esq.

Washington, DC 20555 Office of the Executive

  • Legal Director Town Manager's Office U.S. Nuclear Regulatory Town Hall - Friend St. Commission -

Amesbury, MA 01913 Washington, DC 20555 Mr. Angie Machiros Anne Vorge, Chair Chairman Board of Selectman Board of Selectmen Town Hall

!!ewbury, MA 09150 ' South Hampton,-NH 03842

e Jo Ann Shotwell, Esq. George Dana Bisbee, Esq.

Assistant Attorney General Edward L. Cross, Jr., Esq.

Department of the Attorney Asst. Atty. Generals General State flouse Annex 1 Ashburton Place, 19th Floor Concord, N!! 03301 Boston, MA 02108 John B. Tanzer Letty !!ett, Selectmaa Town of Hampton Town of Brentwood 5 Morningside Drive RFD Dalton Road Ilampton, N!! 03842 3rentwood, N!! 03833 Edward F. Meany Sandra Gavutis Town of Rye Town of Kensington 155 Washington Road RFD 1 Rye, NH 03870 East Kensington, NH 03827 Diana P. Sidebotham Diana P. Randall R.F.D.2 70 Collins Street Putney, VT 05346 -

Seabrook, NII 03874 Richard E. Sullivan, Mayor Donald E. Chick City Hall Town Manager Newburyport, MA 01950 10 Front Street Exeter, NH. 03833 Alfred V. Sargent, Chairman Brian P. Cassidy, Esq.

Board of Selectmen FEMA Region I Town of Salisbury, MA. 01950 J.W. McCormack Post Of fice and Courthouse Boston, MA. 02109 i

Sanator Gordon J. Humphrey Senator Gordon J. !!umphrey U.S. Senate 1 Pillsbury Street Washington, D.C. 20510 Concord, NH 03301 (Attn:- Tom Burack) (Attn: Herb Boynton)

Selectmen of Northampton Calvin A. Canney Town of Northampton City Manager New Hampshire 03862 City Hall 126 Daniel Street Portsmouth, NH 03801 -

  • By Hand
    • By Express Mail ,

Diane Curran l

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