ML20205J820

Summary of 860908 & 09 Site Visit to Allow NRC Staff & Consultants to Visually Examine Plant Features Important to Risk Mgt & Emergency Planning Study.List of Attendees & Related Info Encl

ML20205J820
Person / Time
Site:	Seabrook
Issue date:	09/11/1986
From:	Doolittle E Office of Nuclear Reactor Regulation
To:	Office of Nuclear Reactor Regulation
Shared Package
ML20205J677	List: ML20205J673 ML20205J692 ML20205J718 ML20205J743 ML20205J760 ML20205J769 ML20205J781 ML20205J794 ML20205J820 ML20205J852 ML20205J894 ML20205K095 ML20205K127 ML20205K168 ML20205K183 ML20207A118 ML20207A145
References
FOIA-87-7 NUDOCS 8704010429
Download: ML20205J820 (55)

Text

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UNITED STATES

[ g NUCLEAR REGULATORY COMMISSION j t  ; mem=orow. o.c. nasu  ;

%,...../ I1 SEP 1986 i

Docket No.: 50-443 i

APPL.ICANT: Public Service Company of New Hampshire FACILITY: Seabrook Station Unit 1 I

SUMMARY

OF SEABROOK SITE VISIT TO EXAMINE

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YARIOUS PLANT FEATURES '

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REFERENCE:

Seabrook Station Risk Management and Emergency Planning Study  ;

and Seabrook Station Emergency Planning Sensitivity Study Submitted by letter from John DeVincentis to Vincent S. Noonan, . l dated July 21, 1986 1 A site visit was held on September 8 and 9, 1986 at the Seabrook Station in Seabrook, New Hampshire. The NRC staff was represented by members of the Division of PWR licensing-A and Brookhaven National laboratory (BNI.). The i

applicant was represented by members of Public Service Company of New Hampshirp , New Hampshire Yankee Division (PSNP) and United Engineers and Construttors (UE8C1.

A list of attendees is included as Enclosure 1.

The purpose of this visit was to allow NRC staff and its consultants to visually examine those plant features important to the Risk Management i and Emergency Planning Study (RMEPS), this work was in. support of the staff's ongoing review of the information in Reference 1.

Prior to a walkdown of containment on Monday, September 8, 1986 the applicant

~ presented slides showing construction activities for the containment and containment enclosure building.-

~ Following this presentation PSNH and UE8C represent'atives escorted NRC and BNI. staff through the Seabrook, Unit I containment and auxiliary buildings.

Areas viewed by the staff included reactor cavity configuration under the vessel, piping and electrical penetration areas, fuel transfer tube penetration area, containment to enclosure building annular space, RHR relief valve area, containment sump area, RHR pump and heat exchanger vaults and containment purge valves.

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2 On Tuesday, September 9,1986 PSNH and'UE8C representatives escorted NRC and BNL personnel through the Seabrook, Unit 2 containment building. This allowed the NRC staff to see features of containment such as the foundation configuration of the enclosure building and confiouration of structural interfaces between containment and enclosure buildings not normally visible when construction is complete. 4 The visit was concluded after exchange of some wiring and valve operator drawings.

Elizab Doolittle, Project Manager PWR Project Directorate No.5 ,

Division of PWR licensing-A d

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4 4 Mr. Wobert J. Harrison Public Service Company of New Hampshire Seabrook Nuclear Power Station l/

, I cc:

Thomas Dignan, Esq. E. Tupper Kinder. Esq.

John A. Ritscher, Esq. G. Dana Bisbee, Esc.

Ropes and Gray Assistant Attorney General 225 Franklin Street Office of Attorney General 1 Boston, Massachusetts 02110 208 State Hosue Annex '

Concord, New Hampshire 03301 l Mr. Bruce B. Beckley, Project Manager l Public Service Company of New Hampshire Resident Inspector  ;

Post Office Box 330 Seabrook Nuclear Power Station Manchester, New Hampshire 03105 c/o US Nuclear Regulatory Comission i Post Office Box 700 Dr. Mauray Tye, President Seabrook, New Hampshire 03874 Sun Valley Association -

209 Sumer Street Mr. John DeVincentis, Director ,

Haverhill, Massachusetts 01839 Engineering and Licensing Yankee Atomic Electric Company Robert A. Backus Esq. 1671 Worchester Road O'Neil Backus and Spielman Framingham, Massachusetts 01701 116 1. owe 11 Street Manchester, New Hampshire 03105 Mr. A. M. Ebner, Project Manager

' United Engineers & Constructors William S. Jordan, III 30 South 17th Street Diane Curran Post Office Box 8223 Hannon, Weiss & Jordan Philadelphia, Pennsylvania 19101

20001 S Street, NW Suite 430 Washington, D.C. 20009 Mr. Philip Ahrens, Esq.

~~

Assistant Attorney General

. State House, Station f6 Augusta, Maine 04333 Jo Ann Shotwell, Esq.

Office of the Assistant Attorney General Environmental Protection Division i

Mr. Warren Hall One Ashburton Place Public Service Company of Boston, Massachusetts 02108 New Hampshire Post Office Box 330 D. Pierre G. Cameron, Jr., Esq.

Seabrook, New Hampshire 03874 General Counsel Public Service Company of New Hampshire l Seacoast Anti-Pollution League Post Office Box 330 1

Ms. Jane Doughty Manchester, New Hampshire 03105 5 Market Street  !

Portsmouth, New Hampshire 03801 Regional Administrator, Region I U.S. Nuclear Regulatory Comission Mr. Diana P. Randall 631 Park Avenue l

. 70 Collins Street King of Prussia, Pennsylvania 19406 i d

Seabrook, New Hampshire 03874 1 Richard Hampe, Esq.

New Hampshire Civil Defense Agency 107 Pleasant Street i Concord, New Hampshire 03301  ;

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'Public Service Company of New Hampshire

'- 2'- Seabrook N1 clear Power Station cc:

Mr. Calvin A. Canney, City Manager Mr. Alfred V. Sargent.

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l City Hall . Chairman 126 Daniel Street Board of Selectmen Portsmouth, New Hampshire 03201 Town of Salisbury, MA 01950 Ms. Letty Hett Senator Gordon J. Humphrey Town of Brentwood ATTN: Tom Burack

"--W0 alton Road U.S. Senate ~

^" " '

Brentwood, New Hampshire 03833 Washington, D.C. 20510 Ms. Roberta C. Pevear Mr. Owen B. Durgin. Chairman Town of Hampton Falls, New Hampshire Durham Board of Selectmen Drinkwater Road Town of Durham

• Hampten Falls, New Hampshire 03844 Durham, New Hampshire 03824 i Ms. Sandra Gavutis Charles Cross, Esq.

Town of Kensington, New Hampshire Shaines, Mardrigan and RDF 1 McEaschern East'Kingston, New Hampshire 03827 25 Maplewood Avenue

/ Post Office Box 366 Portsmouth, New Hampshire 03801 Chairman, Board of Selectmen RFD 2 South Hamoton, New Hampshire 03827 Mr. Guy Chichester, Chaiman Rye Nuclear Intervention Mr. Angie Machiros, Chairman Committee Board of Selectmen c/o Rye Town Hall for the Town of Newbury 10 Central Road Newbury, Massachusetts 01950 Rye, New Hampshire 03870

- Ms. Cashman, Chairman Jane Spector Board of Selectmen Federal Energy Regulatory Town of Amesbury Connission-Town Hall 825 North Capital Street, NE Amesbury, Massachusetts 01913 Room 8105

Washington, D. C. 20426 -

Honorable Peter J. Matthews Mayor, City of Newburyport Mr. R. Sweeney Office of the Mayor New Hampshire Yankee Division City Hall Public Service of New Hampshire Newburyport, Massachusetts 01950 Company 7910 Woodmont Avenue Mr. Donald E. Chick, Town Manager Bethesda, Maryland 20814 Town of Exeter 10 Front Street Mr. William B. Derrickson I Exeter, New Hampshire 03823 Senior Vice President Public Service Company of New Hampshire '

Post Office Box 700, Route 1 Seabrook, New Hampshire 03874 i

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>l NRC/BNL SEABROOK WALKDOWN I

NAME AFFILIATION Steven long NRC Joseph Grillo NHY Operations K. M. Kalawadia UE8C Jim Moody NHY P. Bezler BNL/NRC l G. Bagchi NRC/PWR-A/EB

-Ketr Kiper NHY - ~ " " -- --- - --

David A. Maidrand Asst. Proj. Mngr. YNSD -

Bruce Miller BNL I Bob Youngblood BNL Robert White NHY - Engin'eering Richard Toland UE&C Matthew Brock Town of Hampton Kamal K. Bandyopadhyay BNL Jane Doughty SAPL George Bozoki BNL James Stacey NSD YAEC - PEM Bob' Gregory YAEC LICENSING l

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Meeting Summary Distribution ket or Central File NRC Participants NRC PDR's 1.oca-l'PDR SMeng -w ,..,

PDf5 Reading File J. Moody J. Partlow G. Bagchi V. Noonan Project Manager OGC-Bethesda E. Jordan '

B. Grimes ACRS (10)

M. Rushbrook O

cc: Licensee and Plant Service

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A' I DRAFT 3 MAJOR: MAJOR 24 9/12/86 TENTATIVE MEETING SCHEDULEABROOK STATION, YSTEMS JOINT OCCUPATIONAL MEETING OF ANDTHE ACRS ENVIRONMENTAL C.

SUBCOMMITT PROT

! ANDSEVERE(CLASS 9)ACCIDENTSH ST. NW., W ROOM 1046, 1717 26, 1986 FRIDAY, SEPTEMBER

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15 Min. -

1. Chairman's Introduction >

30 Min.

8:30 a.m.

8:45 a.m.

2. Status of Seabrook StationPercent Completion of '

ih ' US Units 1 and 2

- Schedule for Low Power .

Testing  :

- Latest SALP review results /

Remaining Significant Open Items 'N 30 Min. ,

- 3.

Current Status of Emergency Planning 9:15 a.m. -

What plans are completed What plans remain openInteraction and Status of

' Review

- Current Schedules 15 Min. l BREAK 2 hrs.

9:45 a.m. ******

4. Overview of the Seabrook Station 10:00 a.m. Probabilistic Safety Assessmentscope, description History,dology of metho Principal Recommendations, Insights & Conclusions Comparison to other PRAs (WASH 1400,etc.)

- General Discussion

• • • • • • ~

LUNCH 12:00 p.m.

S.

Seabrook Station Probabilistic Safety 1:00 p.m. Assessment Update 1-3/4 hrs.

Seabrook Station Risk Management -

A. & Emergency Planning Study

1. Introduction

2. Results and Conclusions

3. SSPSA Piant Model Update 4. Sourc -

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SEPTEMBER 25 MEETING 2

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.x Analysis

5. Site Analysis 2:45 p.m. BREAK 3:00 p.m. B. Seabrook Station Emergency Planning I hr.

Sensitivity Study

1. Introduction

. 2. Results and Conclusions

3. Overview

4. Source Terms

5. Site Analysis 4:00 p.m. 6. Proposed PRA approach to the selection of countermeasures in emergency response, Dr. F. Rowsome 1 Hour .

General Discussion & Future Actions 5:00 p.m. 7. ihQ Min.

(Note 11 hrs. currently scheduled ..

for the October full ACRS'Mtg. on blJ Friday 0ctober 10,1986) 5:30 ADJOURN . ..

Reminder: Formal Presentations should take no more than half the allotted time to allow'for questioning by the Subcommittee.

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NEWS RELEASE

,. j j FROM THE OFFICE OF GOVERNOR MICHAEL S. DUKAKIS 4

.c September 20, IME COMMONWEALTH OF MASSACHUSETT5 f XTCUTTVE DEFAILTMENT COCM:T: James Dorsey 727-2759 ATE E'5E Stephen Hosenfeld 727-2065 TON. MA 02133 Tom Subbard 727-1130 Dukakis will not asksmit_ seabrook evacuation plansi .

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amys emergency planning cavinet adequately protect puolic locause of the likelihood that an accident at the Seabrook nuclear power plar.t in usw Ragshire Md result in high dosages of radioactivity to Massachusetts ccanunities within a 10-mile radius of the plant, Gov. Michael S. Dukakis said today he cannot "in good consciones* sutnit'energency evacuation plans for the six Massachusetts ecurunities closest to the plant.

"All the evidence I have tells me that while there is roca for reamsnable disagreement on details, t.hs unshakable fundamental truth is this: if a serious accident occurs at seabrook as I as told by the Nuclear Regulatory Castission (NBC) to easme it will, the ccatination of conditions there - including principally weather, adequate abeltering and exit routes, and the altitude of the radioactive plume -

either individually or more likely in cambination, create a foresseable likelihood of high dosages of radioactive intake, against Weh emergency plav. .ing and evaeaation cannot adequately protect,' Dukakis said at a state souse announcement.

"Under mch ciromstances I do not believe I as governor can responsibly s.:tmit energency plans, since they could not constitute appropriate protective measures adequate to protect the public health and safety in the event of a radiological emergency, as fa$eral law requires. I tMrefere do not intend to do so," Dukakis a&!ed.

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~ 2- M NRC regulations state that "no operating license ... will be issued

• for a ruelear power plant unless there are reasonable assurances that adequate steps can be ,

i, taken to protect public health and safety in the event of a radiological accident, ne,

. federal goverment calls on governors to judge temther adequate mergency plans can be r

devised to cope with nuclear accidents. .

The six commmities affected by the governor's decision are saltabury, Amesbury, ~

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Newbury, He@uryport,. Hest Ne@ury, and Merrimac. -

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In making his decision Dukakis said he followed guidelines established by fa$eral agencies which require governors to judge whether an adequate plan can be devised and executed for a wide variety of accidents, including those causing a major offsite radioactive release within 30. minutes, reaching a radius of five miles within two hours.

Dukakis said that couputer models of seabrook-area evacuation times indicate that under highly favorable conditions in the middle of a dry, clear day during the winter when the area's population is at its lowest indicate it would take 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> 10 minutes to evacuate the 50,000 residents in the six comunities following a major 4 l

accident. The worst case, a perfect sumer weekend beach day hit with a sudden rain storm indicates it would take nearly 0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> to evacuate a larger number of people from the same area. The time study model used to generate these projections has been approved by the Federal Emergency Management Agency.

The governor said that although federal regulations do not specify the ,

seriousness of the radioactive release, they appear to assume a release of radioactive material equal to the April 26 accident at a nuclear power plant afchernobyl in the soviet Onion. At the governor's request, nuclear engineer and Carter Administration l

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! mc chairman-designate Albert Carnesale spent countless he'Jrs analyzing ChWenobyl and studying its applicability to Seabrook. -

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"As it turns out, there are fuariamar*al lessons to be learned from Chernobyl, i directly applicaole to my decision an seabrook,' Dukakis said, "lessona concerning the aftermath of the explosion, the ispect of the radioactive release, and the human ,

response to it. -

l "Most sur' p ristlig,' Dukakis said, "is that the ovecriding feature of the Charnabyl accident is me of good fortune. As terrible as that disaster was, it could have been far worse."

The lassons of the Chernobyl accident indicate that:

- the flat topography of the Ukrainian plains where Chernobyl is located and

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the hot, dry climatic conditions characteristic of the area codined to keep the radioactive debris alott for long periods of time, spreading its release over a large area at great distance from the plant, rather than in concentrations close to it, and therefore reducing the threat to life,

L the nature of the explosien and the thermodynamic effects of the Chernobyl I

graphite reactor fire pushed radioactive debris to a very high altitude, about 4 4,000 feet, which contributed to dispersing the radioactive material over a wide l

area.

, - Because of the enabination of clear, constant weather and high altitude, Soviet officials were able to predict the direction of the radioactive pime and execute a well-timed, coordiosted usage of sheltering and evacuation of 125,000 people within 18 miles that would have been impossible in circumstances where -

time tes short and the path of the plume uncertain.

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- Adequate sheltering is essential to emergency planning. The 45,000 residents of Pripyat living within tw alles of the reactor received relatively low  ;

g dosages of radiation because they were inside their concrete block homes during i the hours authorities monitored the plane's path. Those living in bones not made of concrete block although farther an y from the reactor suffered far higher I dosages. ,

- "The sost bunbling lessen of Chernobyl is tt.nt the haan factor defies Icgie and computer andeling," Dukakis said. Despite the time available to nobilize for l I

evacuation and despite the totalitarian efficiency with which it tas executed in  !

same places, it took up to a teek to evacuate thousands of people within 4 l

radius equivalent to the NRC's emergency planning sones because Soviet authorities had not counted on people's unwillingness to leave their homes ard livestock and their refusal to cooperate despite the risk..

In anny ways, Dukakis said, Oernobyl tes a "bIest case acenario' for emergency planning, tven so, thousands of people within five miles of the reeceor suffered radioactive dosages at least ehrht times greater than set forth in federal guidelines for innodiste evacuation and 200 times greater than normal annual background exposu Dozens of square miles may remain uninhabitable for four years.

Dukakis noted that weather conditions at Seabrook are at the opposite end of the spectrum from mornobyl. Winds at seabrook are not constant, but concantly changing, influenced by land and sea. The climate is not dry as at chernobyl but marked by '

ente ded periods of precipitation during the year. '-

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Carnasale told Dukakis that an accident at seabrook could well result in such lower plume altitude than occuered at ChernoN1 because seabrook does not rely on a graphice reactor. A radioactive pine at a lower altitude means that the risk of

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amposure to the inanediate population foreseeably would be higher and that the plume, rather than moving aloft and out of the region quickly, foceseeably would churn in the immediate area for a substantial time.' The situation would worsen in rainy or snowy s' conditions.

• tecause the New England weather la marked by its unpredictability, it would be '

such more difficult to monitoc the plane, predict its course and execute evacuation plans ao as to travel away from the danger rather than into it," Dukakis said.

"If we wait while we determine the safest evacuation path, esposure will be l

heavy in the imediate area. Yet if w evacuate quickly to avoid the heavy exposure, we may make matters worse. When cantined, these factors suggest that the less harmful course of action mcy be to stay within the evacuation zone for several hours, placing great reliance on tesporary sheltering," Dukakis said.

"But typical New Englarzt homes around Seabrook are not made of concrete block as they are at Pripynt near Chernobyl. Many are made of wood and, at best, are far from ideal for shelter fram a radioactin plusie. During the summer, when a large i non-resident baseb population is in the energency planning zone, the absence of shelter is disastrous," he added. "

"Oltimately, the question of whether reasonable assurances can be given is 4 matter of judpent - a judgment the NRC says only I can make. Based on what I know of Seabrook and Chernobyl and on my good conscience, my best judgment is that evacuation planning will not adequately protect the lives of the people of Massachusetts living within the 10-mile evacuation 2oos,' pukakis said.

Massachusetts Attorney General Francis X. tellotti, representing the commonwealth during Dukakis's first ters, argued against licensing seabrook in 1975, pointing to the proposed plant's proximity to crowded New Rangshire and Massachusetts

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beaches. ,

Dukakis noted that to prevent huge financial resouress from beirs irretrievably ecusitted to a plant that might never be licensed, sellotti urged federal officials

' act to go forward with Seabrook.

i 'Despite the comonwealth's strenuous argument that the choice of site ws a manusental error in judgment, construction ma permitted," Dukakis said.

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LESSONS OF CHERNOBYL

• MAJOR UNCONTROLLED OFF SITE RELEASE OF RADIAT10N 35 POSSIBLE -

CHERNOBYL WAS SEVERAL M]LLION TIMES WORSE THAN THREE MILE ISLAND i HUNAX FACTOR DEFIED LOGIC AND COMPUTER MODELING --

EVIDENT IN THE ACCIDENT AND EVIDENT IN THE EVACUATION i

s PLANT SITING 15 CRITICAL -- WEATHER, GEOGRAPHY, AND POPULATION DENSITY EAVI' A DRAMATIC 1HPACT ON EXPOSURE LEVELS HEIGHT AND DISPERSION OF PLUME VARIES W3TH THE ACCIDENT SEQUENCE AND PLANT TECHNOLOGY

• GOOD SHELTER IS ESSENTIAL TO REDUCE EXPOSURE R3SK s

• LARGE AREAS NAY BE LEFT UNINHABITABLE FOR LONG PERIODS 1

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STATEMEtti 0F GOVERf!0R MICHAEL S. DURAKIS RECARDINC THE SEASROCK NUCLEAR PO%iER STATION 1

september 20, 1986 )

Under federal statutes and regulations I am called upon as covernor of Massachusetts to play a particular role in the licensing- process for the proposed seabrook Nuclear Power station. After lengthy and painstaking review of all the t

pertinent information, and careful analysis of the applicable standards, I have reached a decision, which I am announcing today.

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The Ristorical and Regulatory Context The Conunonwealth's involvement in the licensing of Seabrook actually extends back very tar. In 1975, when the construction

license for seabrook station was under consideration, Attorney General Frank Bellotti, appeating in opposition, issued warnings that have proved prophetic. F first told the federal .

regulators and then the federal courts that siting a nuclear power plant at seabrook ignored considera: tons of public safety. Pointing to the proposed plant's proximity to the crowded beaches at the New Hampshire and Massachusetts border, the Attorney General argued, as he has for nearly twelve y_ ears,

! that the lack of shelter for the beach population and the .

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inadequate highway system in the area made protection of the public in the case of a serioun accident a near impossibility.  !

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To prevent huge financial resources from being irretrie0 ably committed to a plant that might never be ILeensed, he urged the f ederal authorities not to proceed. Despite the Cor.monwealth's strenuous argument that the choice of site was a monumental I

error in judgment, construction was permitted.

At the , time, prior to the 1979 nuclear accident at Three Mile Island, the local health and safety concerns raised by the Attorney General were, at best, peripheral factors in the federal licensing equation. Three Mile Island, however, brought a long overdue, rude awakening.

It became clear that federally mandated planning for an emergency was wholly inadequate, and that health and safety were being seriously

, jeopardized. ,

i One outgrowth of the accident was reassessment of- the prospects for nuclear energy itself in light of the risk. No 1

new plant has been approved for construction since Three Mile Island. Only the few plants already in construction in 19'79, of which seabrook is one, remain to be considered for final operational licensure. It is by now beyond question -- given the escalation in cost and controversy -- that if we were to be given a second chance to avoid construction altogether, no prudent person would in hindsight choose seabrook.

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t For those plants already in operation and those approved for construction, the federal government responded to Three Mile Island by making off-site emergency planning a primary i

statutory requirement. On this issue, the importance of state and local participation was explicitly acknowledged by congress 4 with the requirement that 'there must exist a state, local or utility plan which provides reasonable assurance that public health _and safety is not endangered by the operation of the facility.'

In the words of the truclea r Regulatory Commission, 'no operating license . .

. will be issued unless a finding is made that there is reasonable assurance that adequate protective i

measures can and will be taken in the event of a radiological emergency.' Federal agencies look first to the state through its Governor to make this determination. I must judge whether a plan can be devised which "in the opinion of the state is 1

adequate to protect the public health and safety of its citizens living within the emergency planning zones' -- a radius typically of ten siles -- by providing ' reasonable assurance that state and local governments can and intend to effect aporopriate protective neasures of f site in the event of a radiological emergency." The standard for the Covernor, as .

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) it should be, is thus not only one of intent but of the feasibility of proposed protec. /e measures.

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, The Anolicable standards To assist in a state's approach to emergency planning, federal agencies responsible for nuclear plant licensing have i set forth comprehensive standards and guidelines.

It is those rules that I am obliged to follow in exercising my judgment as l l

Governor. To begin with, it is clear from the guidelines that j several factors which have a significant relation to health and i

safety are beyond the purview of the covernor. such on-site J

factors as design of the reactor, strength of the containment vessel, quality of management, and quality of reactor operator l j training are all important to protection of the public. l I

Nonetheless, under federal law these are questions exclusively l for the Nuclear Regulatory Commission. My judgment is not to l be influenced by the evidence on these issues. Indeed, the 1

, statistical probability of a serious nuclear accident as l

distineutshed f rom the adecuacy of the response is not e proper part_of the state's delibera*tions.

Instead, I am mandated to base my judgment regarding health and safety on several assumptions stated in the federal guidelines. As a general matter I am directed that no single  ;,

specific accident sequence should be isolated as the one for which to plan because each potential accident could have

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i different consequences. Rathe:, as the guidelines state, 'the range for planning purposes is very large, starting with a zero l

l point of requiring no planning at all . . . to planning for the l worst possible accident, regardless of its extremely low likelihood.' tiithin this mandated spectrum, federal guidelines direct Covernors to assume among other things that an accident '

could occur with offsite release within thirty minutes, reaching a radius of five miles within two hours. tfhile the seriousness of the release to he assumed is not specifically stated, the assumptions appear to include a release of

. radioactive material similar to that at chernobyl, without

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regard to the particular ca'use of the release.

In summary, the central tenet of emergency planning is that i an accident can occur. My limited role in the federal process is to attempt to devise emergency response plans to deal with such an event if it does happen.

Chernobyl This in general terms is the context for my review and for '

state planning. Last spring, with the assistance of the Attorney General, I was within a few weeks of reaching a i decision on submission of offsite emergency plans. Then, on April 26, 1986, an accident occurred de the Chernobyl Nuclear '

power i

Station in the Soviet Ukraine, which constituted the l

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world's first actual nuclear power catastrophe, with substantial loss of life, widespread exposure to radiation, and e

serious damage to the environment. We have learned that the radioactive release at chernobyl was several million times I

greater than Three Mile Island. Until chernobyl planning and i

i judgment relating to major accidents were essentially based on computer models. and mathematics. Chernobyl represents real experience, a test of the experts' predictions and an opportunity to derive potentially important lessons about planning for Seabrook.

q I asked Dr. Albert carnesale of Narvard University's Xennedy School of Government, president carter's nominee to head the Nuclear Regulatory commission, to analyse the I

chernobyl accident, and to advise me regarding the applicability of the Chernobyl experience to seabrook.

4 Dr. carnesale has devoted several months, without compensation, to this task. All citizens of Massachusetts owe him a debt of gratitude for his careful objective analysia, As it turns out, there are fundamental lessons to he learned f rom Chernobyl, directly applicable to my decision on seabrook. As Dr. Carnesale has told me, in a field as

! intensely studied as this, what learned is to be is not

entirely new, but tends to tell us more directly than computer

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i modele ever could which factors could prove pivotal in an accident and where emphasis must be placed in planning.

9 It has been debated as to whether Chernobyl offers any lessons for design of nuclear plante, in light of the fact .that ,

the chernobyl reactor reflects a design philosophy far difforent from and inferior to those used in this country. But

• under federal guidelines, _that debate is not relevant to my decision. It is the aftermath of the accident -- the impact of '

the radioactive release and the human response to it -- that we must analyse for guidance. And in this reals chernobyl has much to say. As Dr. carnesale has put it, the accident

~

confirms beyond question that adequate offsite planning is essential and must be taken very seriously. ,

The overriding characteristic of the Chernobyl accident is that, as bad as it was, it could har been f ar worse. First, the geographical and weather conditions at Chernobyl reduced .

• he threat to life by dispersing the release over a remarkably a

large area, extending in diffuse form to places remote from the plant, rather than depositing lethal concentrations in population areas close to the plant. The flatness of the Ukrainian plains where chernobyl is located, and the hot, dry .

climatic conditions prevalent in that area tended to keep the i radioactive debris aloft for relatively long periods of time.

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second, the nature of the explosion and the thermodynamic

, effects of a graphite reactor fire as occurred at chernobyt meant that the altitude reached initially and thereafter

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maintained by debris coming out of the reactor was quite great, about 4,000 feet. This contributed independently to the l aubsequent , dispersion of radioactive material over a wide area. Because graphite is absent from its design, it is expected that serious releases from a plant like seabrook will rise to and be maintained at lower altitudes and therefore be deposited.over a smaller area, even under favorable geographic l

l and weather conditions, i

Third, the combination of clear, constant weather and a '

l hig)1 altitude release permitted soviet authorities to' predict l

the direction of the radioactive plume and to execute a I well-timed, coordinated usage of sheltering and evacuation of 135,000 realdents within it' miles that would prove virtually

impossible in circumstances where time is short and the path of the plume uncertain.

l I

Fourth, Chernobyl makes absolutely plain that adequate sheltering is essential to emergency planning. The 45,000  !

• 1 residents 18' ting in the immediate vicinity -- within two miles l

-- received relatively low dosages of radiation because of the  ;

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superior protection provided by the concrete block construction of their homes, during the hours that authorities were

! monitoring the pathway of the plume and mobilizing their forces e

for efficient evacuation. Some area residents who were not so i

I fortunate to live in the concrete block con.truction of

! Pripyat, even though farther away from tha accident, suffered .

l far higher dosages, at levels considered unacceptably high for planning purposes by federal agencies. Thus, even in the event

of a catastrophic accident we learn from Chernoby1 that i

] immediate evacuation may not be a proper response, particularly I'

where the path of the plume is unpredictable, what may well be

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j needed is temporary sheltering throughout the emergency j planning zone, followed by evacuation away from the plume.

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, perhaps the most humbling lesson of Chernobyl is that the human factor defies logic and computer modeling. De spite the time available to mobilise for evacuation, and despite the totalitarian of ficiency with which the evacuation was executed i

(the town of Pripyat was evacuated in two and a half hours) it i nonetheless took up to a week to evacuate thousands of persons within a radius equivalent to the federal emergency planning l

sones, because authorities had not counted on people's

! unwillingness to leave their farms and livestock and their refusal to cooperate despite the risk.

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There are other useful dimensions of the Chernobyl experience, but these in particular help light our way. The single overriding lesson is that human catastrophe can be i

t avoided only. if circumstances permit adequate emergency planning and response, virtually every element of the offsite emergency r,esponse called for in federal regulations was utilised at Chernobyl, and most of them proved effective --

whether by luck or by good planning. Nonetheless, despite the j quality of the response, it was only because of the additional i

natural or fortuitous circumstances such as weather, geography, i and altitude of the plume, that more extensive immediate and long term injury was avoided. Chernobyl was in many ways a

'best case scenario' for emergency responsq.

l 1

Monetheless, even under these conditions, thousands of 1

residents within five miles of the plant suffered radioactive dosages at least eight times greater than the threshold set forth in federal guidelines for immediate evacuation and 200 times greater than normal annual background exposure. Also,

) the mitigating circumstances that accompanied the accident and its immediate aftermath did not spare the countryside around j Chernobyl from disktessing long-term effects. Evidence ,

j suggests that areas comprising hundreds of square miles may

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remain uninhabitable for four years. The impact of such depopulation on public health and safety, not to mention the 1

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area's economy and its basic community fabric, are bdyond calculation, j

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Turning to seabrook, the question is whether, taking into account coaditions of nature and other related conditions over which we have no control, our emergency response could, if 1

executed competently, prove adequate to avoid serious and real A

endangerment of the surrounding population. Certainty on this

) score is, of course, impossible. We must make our best judgment on the available evidence.

conditions at seabrook, viewed through the - c'sernobyl lens, compel me to conclude that, under the federally imposed assumptions, adequate plans cannot be devised. At seabrook, we  ;

need not speculate about weather conditions. They are at the other and of the spectrum from chernobyl. Winda are not constant, but rather constantly changing, influenced by land and sea. Winds are generally prone to change direction in less

, than an hour at any time. Moreover, the climate is not dry, i

but marked by extended periods of precipitation during the year. Since, as Dr. carnesale advises, we can expect a much lower plume alti ede than occurred at chernobyl, the exhaute of the imediate population foreseeably could be f ar higher, and rather than moving out quickly, the plume foreseeably could

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' churn in the immediate area for a substantial time. In ' rainy l

conditions the situation could only worsen and among other j

' thinga make evacuation itself very difficult.

l I i The changing weather takes its toll not only in immediate esposure to radioactivity but also in the difficulty of monitoring the plume, in predicting its course and in executing evacuation plans so as to move the population away from the plume rather than into it. Thus, it can be foreseen that, as we wait to determine proper evacuation pathways, exposure will

) be heavy in the immediate area. Yet if we evacuate quickly to '

i avoid that heavy exposure, we may well make matters worse.  ;

These factor: combine to suggest that staying within the

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emergency planning zone may, on balance, prove less harmful than, evacuating, at least for a period of several hours.

! Taken together, these considerations could well require us j to place great reliance on temporary sheltering in the l immediate vicinity, just as was done at Chernobyl. Yet it is

! very clear that the extent and quality of, sheltering is

{ inadequate at seabrook.

Whereas the concrete block residences in Pripyat were apparently ideal, the woodframe residences that are typical around Seabrook are far from ideal. This, in my view, presents a serious problem year rc.ad. However, sheltering is beyond question inadequate in the summer months, J

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when the extensive non-resident beech population comes within the emergency planning zone. For them the absence of shelter is disastrous, n

t All these factors make particularly important expert .

i testimony prepared by Attorney General Bellotti which shows

that i f a '-ma jor release occurred at low altitude and under weather conditions common to the seabrook site, and if i evacuation time were over five hours, many persons within two miles of the plant could auf fer exposure to life-threatening dosages of radiation as they sat in their cars, and widespread esposure to such dosages could occur in a radius extending keyor1 fout ailes.

1 i

. Under favorable conditions it is estimated that evacuation of the seabrook emergency planning tone would in fact take over '

five hours at a minimum, during whi.ch time potentially lethal .

radiation exposure would be occurring, and sheltering would he .

inadequate. If underlying conditions were ' less f avorable and evacuation faltered, the toll could only worsen. This in my view is not a hypothetical worst case, but a foreseeable

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situation under the initial set of assumptions I an kold to makes i

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l Mention must also be made of the human factor. Certainly, l l

the reluctance of many Ukrainians to he evacuated by l l

authorities after charnobyl has no immediate parallel at j

, seabrook. But in a general sense it underscores how important l

l cooperation is if we are to translate plans into actual .

operation, on this score it is relevant that the towns in Massachusetts 'within the emergency planning zone are against licensing, for reasons which even proponents of licensing must respect as honest and sincere. I have continually taken the view that these residents' views must he considered. I have also made clear that if adequate plans could be developed, I would feel myself chligated to submit them despite local opposition. However, such plans rely on previously trained ,

i local yesidents and municipal employees wcirking efficiently and l with detailed knowledge c' their assigned roles in the \

evacuation peccess. In circumstances where I am in serious doubt about whether adequate plans are possible, these doubts are only compounded by questions about whether the necessary '

singleminded execution, which is " absolutely essential for even marginal success of the best of plans, can be achieved at seabrook. The unpredictability of the human factor in this instance weighs against the ability to achieve an adequate plan. It leads se to a belief that apart from all other -

problems, efficient evacuation is not likely, j

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, conclusion -

Ultimately, the questions of whether reasonable assurances can ne given is a matter of judgment. I must make my best

, judgment based on knowledge and good conscience. In due course the Nuclear Regulatory Commission will make its judgment, and ,

, almost inevitably, whatever the commission's decision, federal judges will; b'e called upon in some manner as well. . All the evidence I possess tella me that while there is room for reasonable disagreement on details, the unshakable fundamental truth is this: if a serious accident occurs as I as told to assume it would, the combination of conditions at seabrook --

including principally weather, inadequate sheltering and exit routes, and the altitude of the radioactive plume --

either Individually or more likely in combination create a foreseeable likelihood of high dosages of radioactive intake, against which emergency planning and evacuation cannot' adequately protect.

Under auch circumstances I do not believe I as Governor can responsibly submit emergency plans, since they could not constitute appropriate protective measures adequate to protect the public health and safety in the event of a radiological energency, as f e'deral law requiree. I therefore do not intend to do so.

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ruture EnerqY Needs The decision I have made today is based, as a matter et federal law and regulation, on one factor alone --

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assessment of the adequacy of emergency plans for the I

Massachusetts portion of the seabrook emergency planning zone.

Nonetheless, having made my decision, 'I cannot ignore the concerns which the potential non-licensure of the seabrook station may pose for the future of its owners and investors, the energy picture in New England, and our region's economy.

Massachusetts stands ready to assist the owners of seabrook and the state of New Hampshire to explore fully and creatively the option of converting either of both seabrook units co a fossil fuel base.

Such conversions are now well into the -

planning stage at the Midland plant in Michigan and the Zimmer plant to Ohio. Without question, serious issues of economic feasibility and accessibility of fuel supply would face any seabrook conversion. But preliminary indications are that the engineering itself is feasible, and the potential resource of 1500-3000 megawatts is well worth the effort to fully determine its overall feasibility.

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Moreover, as chairman of the New England covernors, I have joined my colleagues in a full review and update over t.:e past nine months of energy forecasts and policies for our six-state region. It is our intention to produce, as early as our 9

meeting of this coming December, a comprehensive plan for New England's energy future. Within that approach I expect that we ,

will emphasize such power sources as the purchase of additional power from *Canadas the building of a number of smaller, gas-fired generating plantar the creation of new power through cogeneration and so-called 'small power' facilitiess conservation and land managements and the retrofitting of existing facilities currently slated for retirement.

1 s I am confident that, working .together, the economic and governmental leadership of New England will build a strong energy future that need not rely on the operation of seabrook as a nuclear generating station.

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QUESTIONS '

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t Low Power- License ,

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1. Ccn a, party file :n motion directlx with the Commission asking them to 4

I change the hearing schedule teet by a Licensing Board?- Would the motion have r to be filed in the first instance with the Appeal Board? If such a motion-i could be filed with the Commissions what kind of : showing would.the novant have to make? ..

2. If.such a motion.was filed could the Staff support it? Specificallh can j the Staff's review 2be completed in sufficient time 4to permit an earli=;r -

' hearing? If such a motion was granted how much time could bis saved in the - -

..1 issuance of a low power license? :In practical terms is auch a motion a good

}.. idea?

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• Exemution Reauest i.

How long would the Staff's' review take of an. exemption .*

request seeking to f

p restrict the EPZr to two .milds?: .

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2. When would the . Staff be sprepared 'to go to hearing on such an iexemption

' request? . .

When could a hearing reasonably start:on such an exemption request? !

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. 4. How long would a hearing on the exemption take?

f[., 5. Can the Comminaion decide :.the exemption question without s' hearing .

}. presuming. it is filed underi2 ?SB. ' e Can the Commission decide :the exemption : question .without a heari~ng .

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presuming it is filed underiSO.12.-

< 7. If .a hearing was . held under 2.758 crr 50/12, what would be the nature of

, the hearing?

What are the pros and cons to an; approach which combined: -(i) a request 8.

for a temporary exemption f rom the 'EP2 ' requirements; -(ii) a realism argument, that is, .if a license was granted as ;a result 'of the granting of the exemption, the: county and. . state of ficials would athen sparticipate in emergency utility plan and personnel i planning (presumably out to ten miles);t (iii) .

implement it.

l Offsite Emergency P1&nnina

1. If one state is not participating in offsite emergency planning, 'can the Governor of another state give the necessary alert notification?. (Look only : l terms of NRC and FEtiA regulations., do not consider problemsithat may exist l with other state or Federal. lawa) .

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2. Does the Governor of a state !have- to submit offsite . emergency. plans or can s

tha affected local counties submit the plans to FEMA 7

3. Can a utility submit of f site : plans directly to FEMA 'that have not been e cdopted by state.or county officials. .

4. Presuming it:in legal under state law for a county sheriff'or a majority l of the county commission to deputiae private citizens-to preform law .

cnforcement functions, could the :NRC and FEMA make a reasonable assurance '

finding as to an .of f site plan which utilized such deputized citizens as part -

of: (1),a privately sponsored emergency < plan; or :(ii) a utility sponsored .

emergency plan? '

5. Presuming it is legal :for law enforcement officials 'in one ' state to preform law enforcement functions .in another, or for law. enforcement officials-in one county to per. form ilaw enf orcement functi6ns in another, would :the NRC' 1

and FEMA's emergency planning regulations be satisfied with a plan which r

enlled for the emergency planning functions of a non-participating county or state to be performed by another. law enforcement! agency?

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F' 'he following thoughts utruck me e . I 11 stened ito ;our friends y- tr., cay. ,

. A n. m ..o c.v e.t a l prc.r. u.m i o r t M.c urqua.e<st icn which :the PRA based t

. e .e y 5 .: -tw r.c r.cn t t h .a t .t h a r.,'ir m.c.ar i n f r.,vacuation f - emerger1cy r ? wr.2 n_. .it:5 tn l i mi'. Tron;?,t . int al i t a es +wi thi n 4that . area that t: M ;* : 4 ~ C. t t.d i mr t ed thAt tf pare > we.s some ipt tenti al. f or tpr empt -

i F r tw? . ti m C n ve...... which shows that there is a. knee in the.

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c.hu t t o .TJ 1 ras + - ,th at is the potential .for prompt .

i + . e. - 8 . m .2 t i ..a tert ur.ile poi nt rb.t ply f alls sto very low. ) , ,

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k* ' b i t.s t. n r.J. arit.v., f. or Geibe c4.k f.he+ riink .of prompt f at'aliti es i e me *-

i' ' cn u t i. ..: r: i t. .o'.'.96. : t to mi l a r, then 1 mile or 2 milei L .s . . .; . . r : .m.. - N A . , . .. t . g i s. ., e - + be se.c .s . i erv'el ofrprotection againstt

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i. a r.n.i ter M Law. Ds J. th = : Comin$ ssi on :in .

..4 2 ; .1 - ) t So is. c.s is E.c 7. in i he rul e ei.7d. the pr eceding .

w c-. .;.: . i . .y ot +.tosuen t 6s) c i aar l y 2ndicate that its purpose i C.v. .

f m 1 e:.r. ' h at p r e.t e t f c. tali ties were -l imi ted as reflected tin i .t im ry.n . , .rvi- a, re s .r i e c: t.a.ari y .1:4dicni e th,it the T.en miles :Was 7 -

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t '? p'em z.-*;; br. e. a f. c.? i :3 ;. that .nni the - a no=iii w nor ner g ati ve r ,.c -r. t'<.:. es. thi n car. tic s st e.b! .t i: hod w s n.attt cr of . law Ithat.is

' r: th? f e.re cr : i s r epyrsna.tri vr obvio is fr om :tht= Com.t.i ssi on ri i .e. c ! r, . or '0761 Th i r woi.i.'. d r.ern that the intent of the i9A idor.s i s som sthir.i, ihet Licenr.rm hos tra tru te cateblish by

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whi s.h the t te:.tiinnny of the euthors wwl d t,e r. koy i ss.se --that i s .

re.:t thr pr esent. t.tgi f eesnager. crit ;-- but thre . authors of the cdport ,

uAsch included Ni~ 0 , E; A - P: d MMAI (and oth.tes, I thinu.

Ar.ulher.1r.fer enco f r om the f act .m wtmid bet what the draf ts-l P ug g e s t. . Are the drM ts avai.I sib 1 e -- Were ; they, produced iduri ng E the lir meny F ogt,vi r. i rivecti ga t ).cns *? Have they :been . produced iin l F01:4?  ! F my irtsc.o11 At-iran i s correct the to msles-was in the i i drM tr. of : 0396 Ic,ng bef oree th WAN 1400 stuff. Suggesting that<

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Goals.of Review

! To pr9 vide a technical assessment of'the adequacy,of thei Seahreck Station Emergency Planning Sensitivi ty Study .to

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.f support its conclusion that the degree of public protMction j ~

[ afforded by a 1 mile emergency' planning radius around 'the Seabrook Station,is equivalent:to therdegreesof protection.

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b that was parrceived for a 10 mile emergency planning radium at.

(. the- time thus 10 mile gener.ic planning sradius twas estab.lished i :

I in NINREG-0396. < '~

C, R. In the eventait is concluded. thati the : Study does not i.

'p adequately support its conclusion at the 1. mile radius, to i; determino ithe radius at :which the. study can support a

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':. conclusion of equivalent protection. ..

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. i f' , o T. Establish Technical.Critor.ia for Comparing the Degree of I: ~ Protection to the Public l.

• ; A. NtJREG-0396 bases ,

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.-  ; 1. DBA-k.OCA ' considerations *

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b.:early fataIntles ,

c.:early injur;tes + -

r d.: Latent. health effects -

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2. WASH-1400 considerations .

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1. wholeabodye

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, b. :early fatalities t

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d. : latent e heal.th effects

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.Ig B. NRC Safety Goal basis .,

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' II. Determine Requietory<and Policy Limitatiopsy- .; , t i' A. Source term modificas. ions

1. physical phaenomena i E. chemical phenomenai E

I B. Relationship of 10CFR100 Calci 3ations to Emergency Platoning ,,

Requirements

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C. Reittionship of PAGs to. Emergency Planning Requirements ,

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III. Revi W Plant. Mod =1 i ,

-. - A. Evtnt Trees -

g 1. review rompleteness of initiating event list ,

.- ee P. . review :completerwss of f aults :and phenomena . considered , 5 i

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in disveloping event treres - (with special attention tp g 4' containment bypass and interfacing - LOCA' sequences) (dV96+ V )

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3. tabulate signi,ficant .dtfferences between Bedbrook  ;

J model and. WASH-1400 modelt ,

i g 4. tabulate any significant deaficiencies discovered ire ,

the scope of the event troon  ;

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" 5. estimate ;the effect of :the deficiencies on the -

, probabilttieziof tho! appropriate damage. states dAoil-c.9p!d'U% N ' O@Cd3 t.uv eth #C4 .bh M.

Ts . Probabi11tyiEstimates t

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1..reviewsprobabilkties.-of faults andtphenomena e 2.. tabulate signkficantidifferences between Seabrook mode-1 and WASH-1400 modol. ,

3. audit procedure.used,in study (to estimate probabkitties,for> items that are significantly different from WASH-1400 4.. tabu.Intetany disputed probabi2ity estimates 5.. estimate the effect of-the disputed probabilities of-the appropr.iate idamagei statesi

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r r TV. Review Containment Model ,

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A. Evaluate CohtainmentiBehavior ,

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1. : review ! containment, structur a1 < analyses .containedt in h- , the study .,

!' ' E. condact site tour to tassess:containmentfeatures with ,

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. 4 respect to various. phenomena (eg, direct heating t phenomena)

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3. develop a model and use BNL *NFAP Jcode to evaluate continment per.formance -

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? QF a. . evaluate . largo deformation and post' cracking i r ' behavior. -

b. evaluate overall: pressure.capact.ty.of containment; #

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4. evaluate behavior of criti; cal containment penetrations 3 e

e a. minimum, failure pressure t

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, b. maximum.faiture pressure t i

c. effects of penetration failure on furtheri.

pressurizationiof the: containment '

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B. Event Trees ,

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1 review damage state siist for . adequacy of representation >

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/. rev' teu complertoness sof faul ts and phenomena consider' ott i.

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in developing e, vent strees, zwi th special attention.to f phenomena that can produce gross contatinment failures

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[ 3. tabulate significant' dif forfences betweentSeabs ook .

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> model and WASH-1400.model Y.

4.< tabulate *any deficiencias discovered in the scope ofr the event treesc(ie, significant safety functions or t response iphenomens neglected ) -

5.'estimateithe effect ofsthe deficiencies on the ,

prcebabil1. ties < of theiappropriate release catagr.rie=s i P(c. av (odCuofwAul C c4ht W i A-* cy-t : . .. .e ., m e : p

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2 1- C. Prribability Estimatesi

i. review probabilitles of* faults and phenomena:-

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2. tabulate significant differnnees between Seatrook

[- modelland 14ASHt1400 model , 4 '

1-T' 3. audit' procedure eased in-the EPZ studyrto erst'imate probabilities for itemsithat.are signifi'cantly J- ~

different ifrom WASH-1600 1 j . . 4. tabulate any disputed probability estimates -

I 5. estimate the effect of thm disputed probabilitins-of p

the appropriate releassicatagories h V. Review the' consequenses ModeI'

[* A. Review the Bource Terms t

1. tabul. ate any differences from the WASH--1400 source s

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• - tnrm wethodologyt

R 2. review the grouping of event sequences into releasei y

catagor.ies i I':

R. Review the Noteorological Database fo'r' appropriateness to .

the model' -

f' . Review the Demographic Dat' abase for proper repr.osentation ,

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of seasonal population r j,,

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[ D. Produrn benchmark runs for comparisoncof Brookhaven twork ^ g

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with Seabrook study:.

VI.-Review Conclusionsiof EPZ' Study .

'A. Produce thyroid dose versus distance curves for theirelease i catagories, modified astnecessary to. account-for findings  !  ;

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in :the review of .the plant and containment models B. Produce.whole body dose > versus e distance : curves pfor any-modifiied release e catagorles as needed , to accoimt for resul.tu of the! plant endo 1. and containment *model reviews

' C. Develop risk versus distance curves as appropriate for comparison with criter'ia developed under task I D, Estimate radius at.which comparability criteria are, t4atisfled( .- -

I' VII. noeument Results ofiReviow A. Repor.t on icontractuali tasks at BNI. '

- B. Safety Evaluat[on Report covering entire review

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k QUESTION 2. The Subcomittee staff has reviewed the undated niemorandum of Thomas Dignan of Ropes and Gray on behalf of the Seabrook appli-cants relating to the so-called " misconceptions" about emergency planning. The memorandum was reviewed in a June 18, 1986 memo-randum by Edward S. Christenbury, Director and Chief Hearing Counsel of the NRC. The review was requested by Edward Thomas of FEMA Region I.

a. Does the NRC routinely review legal m'emoranda prepared by license applicants which are not submitted as part of any formal proceeding?

ANSWER. .

No.

b. Does the Comission have any procedures with respect to

. . such reviews?

ANSWER.

No.

c. -Please exp. lain, to the best of your knowledge, what prompted the writing of the Dignan memorandum, and its review.

ANSWER.

It is our understanding, based upon statements made to NRC Staff members by officials of the Federal Emergency Management Agency (FEMA), that the Applicants  :

had submitted their legal memorandum to the Commonwealth of Massachusetts as

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guidance concerning certain aspects of offsite emergency planning and prepared-ness criteria. We are infonned that in January 1986, the Massachusetts director

. of civil defense asked representatives of FEMA Region I whether FEMA was in agreement with the views expressed in the Applicants' legal memorandum. FEMA Region I expressed an interest in providing an authoritative response to the Comonwealth, and stated that it was also interested in receiving guidance as to the issues raised in the Applicants' memorandum. FEMA Region I requested that a draft response be prepared by FEMA's Office of General Counsel, and that the NRC Staff provide its views with respect to the draft response to the Applicants' legal memorandum. The response was then to be forwarded to the I Comonwealth of Massachusetts.

Pursuant to the request of FEMA Region I, members of FEMA's Office of General Counsel prepared a draft response to the Applicants' legal memorandum, and for-warded the draft response to the NRC Staff for its review and coment. This draft response was reviewed by officials in the Office of Inspection and Enforce-ment. Emergency Preparedness Branch, who are also members of the NRC/ FEMA Steering Comittee, and by the NRC Staff's legal counsel in the Office of the Executive Legal Director. The NRC Staff made certain modifications to the Markey/0GC

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draf t response and the draft response, as modified by the Staff,'. is essentially set forth in Mr. Christenbury's memorandum of June 18, 1986.

The NRC Staff's review was undertaken in the interest of furthering the cooper-ative relationship which exists between FEMA and the NRC, and to ensure that integrated, coordinated guidance be provided to the Commonwealth of Massachusetts as to the correctness of the views expressed in the Applicants' memorandum, upon which the Commonwealth might rely in formulating its emergency plans related to the operation of the Seabrook nuclear power plant.

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The Subcomittee has received a copy of an attendance list at a QUESTION 9.

meeting on March 27, 1986 to discuss emergency planning at Sea-brook. According to FEMA, the meeting attendees discussed "the complete FEMA plan and exercise review and the NRC hearing process, and how this would affect an integrated schedule for projected Seabrook planning, exercise, and Atomic Safety and Licensing Board (ASLB) events. (Same schedule was sent to :he State the following day.)" The attendees were Ed Jordan and Ed Cf.ristenbury of NRC, 10 FEMA officials, Edward Brown of New Hm.s hire Yankee, Bruce McCarthy of BME Strategies, and Thomas gn.1 of Ropes and Gray, t

a. Please provide all notes or transcripts of this meeting.

> ANSWER.

NRC staff has been unable to locate any notes of that meeting. ,

- b. No record of this meeting appears in the " Chronology of ,

- - Meetings and Discussions with Utility and Other Groups .

Seabrook," which the NRC provided for the Subcomittee on September 10, 1986. Please explain this omission.

ANSWER.

That chronology refeTred to discussions of a possible exemption to decrease the size of the Seabrook EPZ. The Staff does not recall any discussion regarding changing the size of the EPZ at the meeting with FEMA on March 27, 1986.

c. Has the NRC participated in other such meetings, of which it has not' informed the Subcomittee? If so, pleasa provide all documents related to those meetings, including but not

- limited to internal memoranda, notes and transcripts.- ,

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ANSWER.

NRC staff cannot recall any meetings concerning the changing of the size of the <

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• EPZ which were not included in the chronology previou;.ly provided, however, a telephone conversation was held on August 6,1986 between Governor Sununu, and Mssrs. Stello, Cunningham and Christenbury which briefly discussed this matter and was not the major issue discussed. Another meeting was held with FEMA shortly after the March 27, 1986 meeting, to discuss its review schedule.

d. Were other parties to the Seabrook licensing proceedings i

including States, localities, and intervenors notified of this meeting? ,

ANSWER.

The meeting was arranged by FEMA; the NRC does not know who FEMA notified of the meeting. The NRC did not notify any party of the meeting.

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The Chronology of Meetings provided to th2 Subcommitt'ee by the 00ESTION 10. Comission indicates a significant level of correspondence and meetings between the NRC staff and representatives for PSNN.

a. Is it customary for NRC to participate in such meetings?

ANSWER.

It is not uncommon for NRC Staff representatives to meet with representatives Such of a license applicant to discuss various aspects of the license application. '

meetings are specifically sanctioned by NRC regulations (10 CFR 52.102(a)). ,

b. What is the function of the NRC representatives at these .

meeting?

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ANSWER. .

The function of NRC representatives at such meetings depends upon the I nature of the meeting. At some meetings, the Staff's function might be to receive inforination as in a briefing; in other meetings,- the Staff's function may be to direct specific questions to the applicant so as to acquire additional information pertinent to the Staff review of the application; in still other meetings, the Staff might participate in an interchange of ideasFrequently, or providethe technical suggestions and information to a license applicant.

Staff will fill more than one of these roles in a meeting.

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d. Have the other parties to the Seabrook licensing proceed-ings including States, localities, and intervenors been ~

' notifir.d of each of these meetings? Have they been invifed

• to participate? If not, why not?

ANSWER.

As per the Policy Statement mentioned in 10(c), other p from the Staff's review of the Seabrook license application.

' to attend such meetings as observers, but as a general rule they are not allowed to actively participate. The purpose of such meetings is to facilitate the flow of technical information between a license applicant and the Staff, not to re solve the concerns of other parties. The Policy Statement further provides the meeting without furthering its purpose.

that applicant; may attend as observers only at meetings between the Staff and other parties to a proceeding. Although not required under the terms of the Policy Statement, observers are frequently asked for their coments at meetings between applicants and the NRC Staff.

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QUESTION 3.

Please provide all documents the Comission has recef'ved related to the difficulties Soviet officials faced in evacuating the population around the Chernobyl nuclear power plant, and all other aspects of their radiological emergency response activities subsequent to the accident (both on- and offsite). These should include but not be limited to all internal staff memoranda, analyses and reports concerning the response by Soviet officials to the emergency at Chernobyl.

1 ANSWER.

The only information the staff has received related to radiological response activities at Chernobyl is the Soviet report to the ;AEA and the draft INSAG

- Comittee report. A copy of these reports are enclosed. Prior to the August.

IAEA meeting in Vienna, the U.S. was preparing a factual report on Chernobyl,

~ based on the information that was available at that time. Chapter 8 of that report dealt with emergency preparedness response and a draft was prepared by the Federal Emergency Management Agency (FEMA). For completeness we are including a copy of this draft. However, since the Soviets have given us an extensive a:: counting of the accident, this draft chapter is no longer relevant, and a revised factual report is being prepared.

A copy of a preliminary internal NRC memo requesting initial contributions to the Chernobyl implications assessment is also enclosed.

Enclosures:

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1. Soviet report to IAEA

- 2. INSAG Comittee Report

3. FEMA Draft Chapter 8 4 Memo on Implications Assessment

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j OUESTION 4 Based on the Chernobyl related information the NRC.has received, i

what has it learned about the need for carefully coordinated l l

offsite planning and preparedness activities at nuclear power plants in advance of an emergency? What does the Chernobyl experience reveal about the human factors involved in effec.

tively implementing a radiological emergency response plan?

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i ANSWER.

As the Subcommittee was told in testimony given prior to the August IAEA meeting, the NRC planned, subsequent to receipt of the Soviet report on Che~rnobyl. to - -

complete both a factual report on Chernobyl as well as an implications assess-

, ment report.

At this time, we are actively studying the large amounts of information provided to us by the Soviets, and have identified a preliminary list of candidate issues to examine for generic applicability to commercial U.S. nuclear power plants.

This list is included for your information and includes a topic on emergency planning.

We plan to complete our implications report by early December and at that time any further actions to be taken, including in the area of emergency planning, will be identified. However, at this time it is premature to speculate on the lessons to be learned from Chernobyl in the area of emergency response planning.

Enclosure:

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Chernobyl Accident Candidate Issues 1

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QUESTION 8. According to documents provided to the Subcommittee, the Commission is spending a considerable amount of money and staff time to review a safety analysis performed for PSNH for the purpose of deciding whether the EPZ for Seabrook can be reduced.

a) In light of the fact that PSNH has made no

- petition to reduce the EPZ, why is this study being conducted?

ANSWER.

In view of questions which have been raised by member: of the public concerning' ~

- possible unique emergency planning problems at Seabrook, the staff considered.

it appropriate to review the Seabrook submittal to obtain a better overall per-spective of risk at Seabrook. For this reason, the staff agreed to review the SeabrookProba~bilisticSafetyAssessment(PSA)updatesinceitprovided additional plant specific information regarding containment design and accident sequences which have the potential for bypassing containment.

PSNH submitted the report to obtain staff comments on the risk perspectives suggested by the PSA update ard the sensitivity study on emergency planning zone size. For several years the staff has had a policy of reviewing Probabilistic Risk Assessments for the purpose of identifying any potentially significant safety issues. Additionally, the PSA update identifies design features and accident recovery measures which have' the potential for significantly reducing the radio-logical consequences resulting from intersystem loss of coolant accidents.

In discussions with the staff, PSNH management has stated that along with othir

, emergency planning measures being pursued, and depending on the NRC's staff tech-nical evaluation of the emergency planning zone sensitivity study, the study could be a factor in decisions regarding emergency planning for Seabrook.

Markey/NRR 9/24/86

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b) How has the Commission permitted, or encouraged, public par-QUESTION 8.

• ticipation in the review of this issue?

ANSWER.

Docketed PSNH documents are available to the public from the Public-Document Rooms (Washington, D.C. and Exeter, N.H.). Notices of scheduled meetings with the utilities were made publically available. Scheduled meetings with the utility on these issues were publicly announced. As discussed in response to Question 10, the public may attend such meetings as observers.

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c) Has the Commi:sfon also been reviewing studie,s, such as those QUESTION 8.

accompanying the Chernobyl accident, to determine whether the EPZ for reactors should be increased?

ANSWER.

The NRC has indicated that it intends to begin a reassessment of emergency planning, in light of any new insights arising from our extensive research on severe accident releases or " source terms." We consider it appropriate tha't any such reassess-ment should also include pertinent information from Chernobyl, taking into account the significant differences between the Chernobyl design and that of U.S. reactors, as they affect accident risks. At the present time, the NRC staff review has not progressed far enough in order to develop a position regarding whether the size of the plume exposure EPZ should be changed.

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t QUESTION 8.

d) 'Has the Commission staff ever advised PSNH concerning the studies it would deem appropriate for justifying a reduction of the EPZ? If so, please provide all details of such dfs-cussions.

ANSWER.

In the recent past there have been some discussions of risk and emergency prepared-ness between management of PSNH and Robert Bernero, Director of BWR Licensing at NRC. Prior to taking his present position in November 1985, Mr. Bernero was in NRC's Office of Research and at NRR in positions involved in risk analysis, source term research, and regulatory utilization of such information. In those positions Mr. Bernero gave many public statements about the regulatory process including the reassessment of emergency preparedness requirements. Mr. Bernero did discuss such issues with Mr. William Derrickson and others of PSNH on two occasions. These were informal meetings which took place in Mr. Bernero's office. One took place -

on July 30, 1985, and Mr. Bernero recalls the other one as being a few months -

later.

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Parkey/NRR 9/24/86

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