ML20196G556
| ML20196G556 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 02/22/1988 |
| From: | George Thomas PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | Meyer D NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| FRN-52FR45866, RTR-NUREG-0654 52FR45866-00004, NYN-88024, NUDOCS 8803090250 | |
| Download: ML20196G556 (7) | |
Text
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DOCKETED USNRC George S. Thomar ep RULES & PROC. E,D.URES BR v6ce Preddent Nuclear Production
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Pub 5c Service of New Hampshire'88 FEB 26 A9 :56 s
NYN-88024 N w Hampshire Yankee Division
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February 22, 1988 becer>>bev 9, MF9 United States Nuclear Regulatory Commission Washington, DC 20555 Attention:
Mr. David Meyer, Chief Rules and Procedures Branch Mail Stop 4000 MNBB
Reference:
Notice in Federal Register, Volume 52, No. 231, Page 45866, December 2, 1987
Subject:
Coments on NUREG-0654/ FEMA-REP-1, Supplement 1 Dear Mr. Meyer New Hampshire Yankee (NHY) wishes to express its appreciation for the opportunity to provide coments on the subject document. NHY represents the Joint Owners of Seabrook Station at a site which has direct and vital interest in the issue of emergency preparedness non-participation by state and local authorities.
NHY offers specific suggestions and coments that are detailed in the Enclosure to this letter.
The principal theme of the coments is to expand the subject document in certain areas to further enhance its purpose:
1.a.,
to provide review and evaluation criteria for a utility offsite radiological emergency response in a situation in which state and local authorities are or become non-participants in emergency planning.
In addition to these specific items, NHY would like to propose the concept that a federal emergency preparedness team, perhaps comprised of one FEMA representative and one USDOE representative, should be established in the region of any nuclear power plant site that faces government non-participa-tion.
This team would be on the ground floor of an emergency response for such a site and could be an early lead in the activation and response under the Federal Radiological Emergency Response Plan (FRERP).
In this way, there would be early federal involvement in the response to an actual emergency that could be used to help develop and issue protective action recomendations.
The result of this should provide better protection for the public.
8803090250 080222 PDR NUREG 0654 C PDR P.O. Box 300. Seabrook. NH 03874. Telephone (603) 474-9574 h fj,- fMEhh
United States Nuclear Regulatory Comission February 22, 1968 Attention:
Mr. David Meyer, Chief Page 2 NHY would like to state our support for the effort expended by both the NRC and FEMA in developing this document and stands ready to assist in any further development or clarification efforts that could benefit the process.
Very truly yours, Geo $
rge S. Thomas Enclosure
ENCLOSURE TO NYN-88024
' COMMENTS ON SUPPLEMENT 1 TO NUREG-0654/ FEMA-REP-1 Comment 1 Page 2 - D. Assumptions While the assumption that non-participating state and' local officials will exercise their best efforts to respond to an actual emergency is valid, further definition would be appropriate and helpful.
It is therefore suggested that assumptions 1.a and 1.b be expanded ta read as follows:
a.
Exercise their best efforts to protect the health and safety of the public, for examples o Manning of existing emergency response facilities; o Establishing communications links with the utility, the offsite response organization and other appropriate response organizations: and o Mobilizing and applying available state and local resources.
b.
Cooperate with the utility, follow the e*.ility offsite plan, and provide timely coordination of response efforts.
Comment 2 Page 2 - D. Assumptions The activation and response of the Federal Government under the terms of the FRERP, as outlined in Federal Register, Vol. 50, No. 217, pp. 46542-46579, is an additional assumption that should be included.
Indeed, a significant response capability exists from the resources available from the twelve federal member agenciss of the FRERP.
Regardless of whether the accident occurs at a nuclear power plant for which offsite authoritiee participated in emergency planning or not, the mission of the FRERP agencies is the same - accident assessment and recommendations for actic:s to protect public health. This mission would most certainly be implemented irrespective of whether the public at risk was in the vicinity of a nuclear power plant that had participating or non-participating offsite authorities.
In f act, it could easily ba argued that the need for, and mission of, the FRERP in response to a non-participating site would be even stronger than for a participating one.
NHY feels this strong and very realistic recognition needs to be made and would be additionally supportive of the realism assumption.
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Comment 3 Page 2 - D. Assumptions An additional assumption should be added. State and local authorities respond to emergencies and accidents of an incredibly wide variety, both in types and magnitude.
This is done with or without the benefit and use of emergency response plans.
Public safety is public safety and the response of state and local officials is as swift and effective as they can make it - plan or no plan.
Public officials are assumed to discharge their public trust in a manner consistent with their responsibilities.
Utility plan; should be able to assume, for example, that school authorities (superintendents, principals and teachers) would provide for the safety of their student population at the time of the emergency, or that governmental officials would direct or allow the activation of an alert and notification system.
Furthermore, there is the additional circumstance with emergency preparedness and response where appropriate key state agencies (emergency management, public health, State Police, etc.) may be full and cooperative participants in one or more nuclear power plant emergency response arrangements while, at the same time, a non-participant at another nuclear plant site.
For examnle, the Commonwealth of Massachusetts and all of its key agencies are full participants in RERP arrangements for three nuclear plants whose EPZ's fall within the Commonwealth, while a non-participant for Seabrook Station.
The response capabilities of Massachusetts officials which is j
maintained and repeatedly demonstrated before both FEMA and the NRC at three plants would certainly be brought to bear at an emergency associated with anotber location.
The assumption that state and local authorities will appropriately use i
their existing emergency preparedness and response capabilities, particularly RERP knowledge, should be explicitly noted in Section I.D.
Propossd language is as follows:
d.
Avail themselves, to the fullest extent possible under the circumstances, of existing capabilities, emergency preparedness l
procedures, training and resources.
Comment 4 Page 2 - E. Scope The statement that starts on line 11 ("The utility offsite plans and preparedness...') is in need of clarification.
If this statement is meant to say that any predefined or existing state or local capabilities, such as communications systems or emergency response facilities, may be ralled upon in a utility offsite plan, then that should be so stated. A utility plan should be expected to account for varying degrees of participation in response to an actual radiological emergency, it should not be required to account for arbitrarily varying degrees of participation during the l
j planning process, as the cited sentence presently could be read to l
require.
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Comment 5 Page 3 - G. Summary of Changes Item 2.c The phrase, ' emergency operations facilities' should be changed to 'Nmerdancy response facilities' to be consistent with other federal publicatlionsi )
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3 Comment 6
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Page 5 - Evaluation Criteria A.1.c
(\\ v This criterion appears to be inconsistent with element A.1.b.
Should ai -
utility offsite plan be developed to reflect the various modes of operation discussed in A.1.b, it would be rather difficult to display a definition of the "roles for the offsite response organization and non-participating state and local governments' on a single block diagram.
Since these ' roles' are defined within the various modes, this requirement should be deleted.
Comment 7 Pages 5, 6 and 19 - Evaluation Criteria A.2.a and J.10.k Certain functions listed in the first paragraph of criteria A.2.a and considered in J.10.k fall within the day-to-day responsibilities of state and local governments independent of radiological emergency response plans.
Functions such as fire and rescue, law enforcement, public health and sanitation, snow removal and emergency medical services are independent of radiological emergency response needs and should not carry oven es t
requirements of utility sponsored offsite plans. See e.g., Long Island Lighting Company (Shoreham Nuclear Power Station, Unit 1), LBPk '5-12 Vol. 21 NRC 644, 815 (1985).
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Comment 8
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Page 5 and 6 - Evaluation Criteria A.2.a
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.r The listing of functions included in criterion A.2.a for which it is necessary to obtain offsite authority authorization before implementation should be clarified. The criterion calls for authorization from both state at.0 local officials for functions that actually are under the statutory purview of one or the other, not both. Rather than call for ' state and local authorization,'
line 5 of page 6 should be changed to ' state or local authorization."
Comment 9 Page 5 and 6 - Evaluation Criteria A.2.a l
A number of functions listed as requiring state or local authorization may not l
be required in an offsite plan, or may not require state or local authorization.
For example, item lii. (posting traffic signs) and item it.
(dispensing fuel to automobiles along roadsides) are not required to be t
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k
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' included'in offsite plans. See e.g Long Island Lighting Company (Shoreham s
Nuclear Power Station, Unit 1), LBP-85-12. Vol. 21 NRC 644, 816 (1985).
Additionally, statebrud local authorization for access control at utility controlled facilities'is not required as may be interpreted in item x.
Therefore, it is suggested that this listing be refined to reflect only those functions that require state or loca1' authorization prior te implementation.
Furthermore, item v. should be, revised to read, "Activating the alert and notification system and directingiche broadcast of protective actio'.
Criterion E.5 does not require 'EBS' nessages and other organizations are not precluded from issuing informational press releases.
. Comment 10 Page 15 - Evaluation Criteria G.5 Evaluation Criterion G.5 should be expanded to allow credit for news media orientation programs conducted for a nuclear power plant site by other organizations eig., the licensee or a participating state for a portion of T
i the EPZ.
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Comment 11 i
Page 22 - L. Medical and Public Health Support,
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Thes'e evaluation criteria should reflect the use of FEMA Guidance Memorandum H3-1,Hedical Services.'
,y Comment 12 Page 24 - Evaluation Criteria N.1.b The second sentence of criterion N.1.b appears to be internally inconsistent.
It considers a demonstration during an exercise of ' capabilities to interface with non-participating state and local government.' yet excludes the use of governmental staniins to support this demonstration. We believe that the use of standins would be a beneficial way to demonstrate, and therefore evaluate, the effectiveness of an offsite rer.ponse organization to coordinate with non-participating governments during an exercise.
In the absence of standins, whether physically present, remotely located, or a combination of both, a
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further definition of how this function will be demonstrated during an
's exercise is needed.
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