ML20128C533

Requests Further Assistance in Evaluating Transition of Emergency Responsibilities for Ma Portion of Plant Plume Exposure Pathway Emergency Planning Zone from Licensee to Commonwealth of Ma

ML20128C533
Person / Time
Site:	Seabrook
Issue date:	11/25/1992
From:	Congel F Office of Nuclear Reactor Regulation
To:	Kwiatowski D Federal Emergency Management Agency
References
NUDOCS 9212040462
Download: ML20128C533 (3)

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'e UNIT [D STATES NUCLEAR REGULATORY COMMISSION S

f wAsemoTou, o. c. rom 9.,,,,* November 25, 1992 Dennis H. Kwiatkowski Assistant Associate Director Office of Technological Hazards federal Emergency Management Agency 500 C Street, S.W.

Washington, D.C. 20472

SUBJECT:

RE0 VEST FOR ASSISTANCE REGARDING THE TRANSITION IN EMERGENCY PLANNING RESPONSIBILITY AT SEABROOK lhe purpose of this letter is to request further assistance from the federal Emergency Management Agency (FEMA) in evaluating the transition of emergency planning responsibilities for the Massachusetts. portion of the Seabrook plume exposure pathway Emergency riinning Zone (EPZ) from the Seabrook licensee to the Commonwealth of Massachusetts. The North Atlantic Energy Service Corporation (NAESCO, the licensee) currently maintains an Offsite Response Organization and the utility-developed Seabrook Plan for Massachusetts Communities (SPMC), the currently approved plan for the Massachusetts portion of the Seabrook EPZ.

Transition efforts hr.ve been underway for some time including the development of a siren transition plan for the conversion of the licensee's Vehicular Alert and Notification System (VANS) to a fixed pole siren system. FEMA provided technical assistance to the licensee to support this effort and reported the results of its initial analysis to the Nuclear Regulatory Commission (NRC) in October 1991.

NAESCO has informed the NRC that they and the Massachusetts Emergency Manage-ment Agency (MEMA) have agreed on January 1,1993, as the target date for the completion of the transition from the SPMC to the Massachusetts Radiological Emergency Response Plan (MARERP). The MARERP was initially sut"nitted to FEMA for review ;n September 1991 and several revisions were later submitted to FEMA and reviewed. The implementation of the MARERP was demonstrated as part of the full participation exercise conducted at Seabrook in June 1992. We are aware that a considerable effort is currently underway involving MEMA, NAESCO, and FEMA to resolve the remaining open issues identified in the review of the MARERP and supporting preparedness activities.

Based on information presenteu at a transition planning meeting attended by MEMA, NAESCO, FEMA, and the NRC on November 13, 1992, we understand that a revision to the MARERP addressing FEMA technical assistance comments and items identified from the June 1992 exercise was to be submitted to FEMA for review on November 20, 1992. Another meeting is scheduled for November 30, 1992, to confirm the status of the required items for the turnover of offsite emergency 9212040462 921125 PDR ORO EUSF Y'

Dennis H. Kwiatkowski November 25, 1992 preparedness responsibilitles from NAESCO to the Commonwealth of Massachusetts, lhe NRC rules applicable to changes in approved emergency plans for operating nuclear power reactors such as Seabrook are found in 10 CFR Part 50.54(q) whi<.h states:

A licensee authorized to possess and operate a nuclear power reactor shall follow and maintain in effect emergency plans which meet the standards in 50.47(b) and the requirements in Appendix E of this part...The nuclear power reactor licensee may make changes to these plans without Commission approval only if the changes do not decrease the effectiveness of the plans and the plans, as changed, continue to meet the standards of 50.47(b) and the requirements of Appendix E to this part... Proposed changes that decrease the effectiveness of the approved emergency plans may not be implemented without application to and approval by the Commission. .

We believe the transition in emergency planning responsibilities from a licensee organization to State and local gove.nmental organizations constitutes an action that should enhance the effectiveness of the plans.

lherefore, we would expect the licensee to submit the changes to its plans, in this case the replacement of the SPMC by the MARERP, under 50.54(q) as an action that dees not decrease the effectiveness of the plans.

As the rule indicates, the licensee does not require Commission approval to make changes in its plans if the changes do not decrease the effectiveness of the plans and the plans continue to meet the emergency planning standards and requirements. The licensee, however, would be in violation of the Comission's rules if f he NRC, upon review, found that the changes did decrease the effectiveness of the plans. Althe>gh not required, the licensee may elect to await Commission review before implementing the changes in the plans due to the nature, .; cope, and complexity of the changes.

We believe the best way that the licensee can demonstrate that the changes do not decrease the effectiveness of its currently approved plans is to provide a copy of the FEMA report to the Commonwealth of Massachusetts on the results of FEMA's review of the MARERP and assessment of the exercise. We intend to rely on the FEMA a:sessment of the adequacy of the MARERP in making our determination whether the emergency plan changes submitted by the licensee under 50.54(q) do or do not decrease the effectiveness of the currently existing and approved plans. Therefore, the NRC, under the provisions of the April 1985 FEMA-NRC Memorandum of Understanding, requests that FEMA provide its determination of the adequacy of the MAP.ERP and assessment of the June 199c exercise of the MARERP to the NRC upon the completion of its review efforts. At that time, the NRC will make its determination regarding the effect of the changes to the emergency plans under 10 CFR 50.54(q).

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I Dennis H. Kwiatkowski November 25, 1992 If you have any questions or require further information, please contact me or Robert A. Erickson, Chief. Emergency Prepandness Branch, at (301) 504-3924.

Sincerely, (Original Signed By)

Frank J. Congel Director Division of Radiation Safety '

and Safeguards Office of Nuclear Reactor Regulation cc: Ted C. feigenbaum Senior Vice President and Chief Nuclear Officer North Atlantic Energy Service Corporation.

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