ML20207C361
| ML20207C361 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/18/1988 |
| From: | Bores R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Sherwin Turk NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| References | |
| OL-S-002, OL-S-2, NUDOCS 8808090158 | |
| Download: ML20207C361 (82) | |
Text
@ to L oq% UNITED STATES
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[ h NUCLEAR REGULATORY COMMISSION
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'88 JUL 19 P5 :36 MEMORANDUM FOR: Sherwin E. Turk, Senior Supervisor) Trial #ttorney, 0GCr.,
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FROM: RobertJ. Bores,TechnicalAssistant,DRSS,RegNP!"
SUBJECT:
SEAER00X BEACli POPULATION ISSUES As you have r. sted I have prepared a summary of my involvement in the above issues and ir , articular the RAC meetings dealing with those issues. My surrary entitled "The Seabrook NH Beach Population Issues" with its attach-ments is Enclosure 1 to this memo. Mr. William Lazarus has provided his summary with respect to the RAC meetings as Enclosure 2. Mr. John Schumacher also attended those meetings and may be able to provide his recollections on them sometime later. Enclosure 3 provides some excerpts from NRC testimony for the October 6, 1986 Subcommittee on Energy Conservation and Power Hearing on Seabrook Licensing Issues (Questions 2, 14 and 15). This may also be of some use to you.
It should be noted that I have not provided you copies of my detailed comments as proviced to the RAC on the New Hampshire state and local plans. Those g comments probably constituted about 60 to 75% of the comments received from d all the RAC members and the contractor and were adopted by RAC about 90 tc 95%
of the time.
M Robert J. Bores Technical Assistant Division of Radiation Safety and Safeguards
Enclosures:
As stated ,
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- t NUCLEAR REGULATORY COMMISSION I INDEX TO EXHIBITS SEABROOK, May 2 through 6, 1988 OFFEROR'S AFFILIATION: IDENTIFIED: RECEIVED: DESCRIPTION:
Intervenor:
12 10087 Message F 13 10489 Protective Action Rec-ommendation worksheet 14 10620 10623 Shelter Survey Form 15 10621 10623 N.H. Assessor's Property Work Card 16 10624 10682 Shelter Survey Form 17 10626 10682 Calculator Cost Form 18 04 . A . G . ) 10933 10963 Testimony of Goble, Renn, Evdokimorr, Eckert 18 (Hampton) 10860 Appendix to testimony of Moughan & Lincoln 19 10933 10963 Testimony of Goble, Renn, Evdokimoff, Eckert--
Attachment 12 ;
Applicant: l 2 10023 10023 Study to identify potential !
shelters 33 10878 10878 Letter from Moughan j 1
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- O INDEX TO EXHIBITS In the Matter of:
PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE, et al (Seabrook Station, Units 1 and 2)
May 16 through 20, 1988 Offeror's Affiliation: For In Description Identification Evidence Applicant: ~-
34 11404 11444 EG&G article on structure shielding 35 11401 rej. 11402 photo of beach cottage 36 11401 rej. 11402 photo of beach cottage 37 11411 11415 Shelter survey form NRC Staff:
2 11739 11744 Memo on Seabrook Beach 2A 12034 12034 Memo on Seabrook Beach with sequential pagi-pagination 3 11746 11747 Memo on FEMA 1 RAC meetings 4 11832 11970 Memo, Oct. 15, 1987 5 11838 11841 Memo, Feb. 18, 1987 6 11894 11894 Memo, June 4, 1987 Massachusetts Atty. General 20 11549 rej. 11549 Prefiled testimony of Sholly, Beyea, &
Thompson 21 11690 11691 Videotape on sheltering 22 12118 Seabrook EPZ Coordination Committee ,
23A 12184 Minutes from 6\23 l Committee Meeting l 238 12184 Attendance List from i 6\23 Committee Meeting )
24 12190 12194 FEMA info & guidance memo l
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INDEX TO EXHIBITS In the Matter of:
PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE, et al (Seabrook Station, Units 1 and 2)
May 24 through 27, 1988 Offeror: For. In Description Identification Evidence Applicant:
38 12790 12796 Letter, Becton to Glenn Massachusetts Attorney General:
25 12235 12236 NRC Announcement 26 12367 12493 Memo, Lutz to Thomas 27 12368 12493 Letter, Bickerton to Thomas 28 12370 12493 Memo, Oleson to Thomas 29 12371 12493 Memo, Church to Thomas 30 12430 12443 Letter, Flynn to Reis 31 12470 12482 Memo, Thomas to RAC 32 12496 12496 FEMA responses to
, contentions 33 12807 12815 FEMA newsletter 34 12813 12815 Personnel chart 35 12859 12862 Letter, Thomas to Strome 36 12884 rej. 12891 Memo, Krimm to Congel 37 12906 12933 Letter, Turk to Board 38 12927 rej. 12933 FEMA's response to motion 39 13006 13021 Letter, Turk to Flynn 40 13017 13020 Letter, Flynn to Smith, et al 41 13073 13076 Letter, Flynn to Thomas 42 13079 13091 FEMA's supplemental testimony
.? . u 43 13106 13106 . Memo, Thomas ' to Krimm 44 13106 13106 Memo,. Thomas to Krimm, 45 13106 13106 Memo,. McLoughlin to Perry' 46' - 13106 13106 Memo, Watson to McLoughlin 47 13172 13210 Le tter , . S trome to Vickers 4
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'o * *'s l INDEX TO EXHIBITS In the Matter'of:
PUBLIC SERVICE COMPANY OF NEW HAMPSHIRF (Seabrook Station, Units 1 and 2)
June 14 through 16, 1988 For In Offeror: Identification: Evidence:
Description:
. Massachusetts Attorney General:
48 13378 14256 Dynamic Evacuation ,
Analysis 1 49 13437 Memo, Quinn/ Thomas 50 13544 13553 Memo, FEMA response 51 13556 13560 Memo, Flynn to Thomas 1 52 13710 13713 Memo, Vickers to McLoughlin 53 13721 13800 Memo, McLoughlin to Vickers :
54 13793 rej. 13793 Notes of Ed Thomas I 55 13842 13846 Memo, Thomas to RAC l Applicant: l 39 13858 13864 Draft Letter to Strome l
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NRC STAFF 4-============================= ------................. ,c ATOMIC SAFETY AND LICENSING BOARC) .
In the Matter of: )
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EVIDENTIARY HEARING: )
) DOCKET: 50-443-OL PUBLIC SERVICE COMPANY OF ) 50-444-OL
) 0FFSITE EMERGENCY NEW HAMPSHIRE, et al ) PLANNING
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(Seabrook Station, Units 1 and 2) )
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LOCATION: CONCORD, NEW HAMPSHIRE DATE: May 16 through 20, 1988 l
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........................................................q O HERITAGE REPORTING CORPORATION OSedalRaporters -
1224 L Street, N.W., Sidte 600 Wasadastos, D.C. 20005 (202) 628 4888
R. BORES TECH ASSISTANT DRSS, REGION I
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THE SEABROOK NH BEACH POPULATION ISSUE
- 1. The Seabrook beach population issue was raised years ago during the l construction phase of the Seabrook Station project. When the offsite plans for the site were first submitted to FEt% by New Hampshire and the Commonwealth of Massachusetts for technical review in 1982, FEMA:I and the technical reviewers (several RAC members including me and the FEMA contractor) were sensitive to beach population concerns. In revisions to I the New Hampshire state and local plans for the Seabrook site, New l Hampshire addressed each identified concern and with very few, if any '
exceptions, those concerns were resolved. l
- 2. On 12/31/85 in a memorandum to the RAC (Attachment 1), Edward Thomas of FEMA:I asked the RAC members to individually address the adequacy of the l plans to protect the transient beach population and those persons who I occupied unwinterized accommodations in the Seabrook beach areas. )
Several RAC members responded to this memo. The NRC attempted to respond ;
generically to the requirements of emergency planning and interpretations thereof in the letter of June 18, 1986 from Ed Christenbury, NRC, to Spence Perry, FEMA, confirming the NRC and FEMA positions relative to the "Dignan Nemorandum" (Attachment 2). (See also letter from Edward Thomas to Robert Boulay (Massachusetts) dated July 9, 1986 (Attachment 3) and p memo from Spence Perry to Edward Thomas dated June 25, 1986 (Attachment
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- 4) confiruing the FEMA position.)
- 3. Since the Christenbury letter was generic and did not address the specific beach issues in the Thomas memo of 12/31/85, FEMA:I felt it needed more specific information from the NRC RAC member. To satisfy this apparent need, I volunteered to address these issues. In addition I vias again assigned as the NRC RAC representative for the Seabrook site.
(See memorandum from W. Lazarus, NRC:I to Cdward Thomas, FEMA:I, dated 1/16/87, Attachment 5 and Attachment 6, RAC Membership for Region I). I generated a position paper addressing the issues raised in the 12/31/85 Thomas memo, discussing the basic requirements, the guidance, the submitted plans, RAC's ccmments on those plans, site features and general conclusions on those issues. This position paper received limited NRC:I review and underwent minor revisions as a result. FEIM:I asked for and received an opportunity to review the document before submission. Minor word changes were made in two paragraphs to acconTnodate the FEMA suggestions. The position paper was transmitted to FEMA in a letter dated 2/18/87 from me (R. Bores) to Edward Thomas (Attachment 7).
ENCLOSURE 1 O
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- 4. In a memorandum to the RAC dated March 2,1987, Mr. Thomas requested comments on my paper as well as on other submitted RAC positions on the beach issues. My respcnse (Attachment 8) and that of ANL (Attachment 9) were reviewed at the subsequent meeting on April 15, 1987.
- 5. On April 15, 1987, FEMA I convened a RAC meeting to discuss this paper and to address any questions of the RAC members, FEMA I or the FEMA centractor en this paper. The meeting was attended by me, W. Lazarus and J. Schumacher of the NRC; several FEMA staff including Mr. Thomas, J.
Lolan, L. Robertson, B. Swiren and K. Horak; R. Rospenda, ANL-contractor; P. Lutz, D0T; B. Keene, EPA:I; W. Church, FDA; D. Nevitt, USDA; H. Fish, DOE; and two representatives of NOAA.
Mr. Thomas stated that it was his understanding that the position of my paper was that the NH Radiolcgical Emergency Response Plan (NH RERP) was generally adequate, except for the beach population, but with the added features, such as the strong containn.ent, other safety systems, low probability of early radiological releases, etc., the NH RERP was also adequate for the beach population. I addressed this point by saying that Mr. Thomas's understanding was incorrect. My paper states that the NH RERP was adequate in general, including for the beach population. The specific ccr.tainment and plant features cited in my paper were ,in ac'dition to and not necessary for, the NH RERP provisions making the plan O adequate. The RAC accepted the abova position, as representing their
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views on the beach issues. Minor changes were suggested by NOAA to reflect the possibility of recirculating a portion of a radiological plume over the beach area as a result of some sea breeze situations.
They further indicated that such recirculation would result in huge dilutions of plume concentrations prior to the recirculation to the beach areas.
Because several representatives had some difficulty in understanding the intended meaning of one paragraph dealing with risk consequences, I suggested that I would revise the wording to clarify the intended i meaning. With above suggested changes and a slight modification to the ANL proposed RAC Review Spreadsheets (see memo 4/22/87, Rospenda to Ed Thomas (Attachment 10) and my letter to Ed Thomas dated 4/24/87 l (Attachment 11), the RAC unanimously (including FEMA) adopted my position l paper as their position paper relative to the beach issues. (SeeDraft i FEMA testimony dated 5/6/87, citing the RAC position paper (undated) and wording from my paper (Attachment 12).) Mr. Thomas stated that he felt ,
very comfortable in supporting this position for the hearings. !
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3 R. BORES TECH ASSISTANT !
ORSS, REGION I l
- 6. Following the 4/15/87 RAC meeting, the ASLB issued its MEMORANDUM AND l ORDER on April 22, 1987 relative to the denial of granting Public Service .
of New Hanpshire a one-mile plume EPZ for Seabrook site. In addition, l since the BNL "containment studies" were still being reviewed by the NRC, I the NRC staff recommended that I delete reference to the site specific plant and containment features in the paper which I had previously submitted to FEMA on 2/18/87. This recommendation was made because the referenced information was not the basis of the adequate finding for the beach population (See discussion on 4/15/87 RAC meeting.) and could result in unnecessary litigation on probability issues. As a result, the suggesteo revisions were made, received NRC staff concurrence, and were ;
submitted to FEMA I on June 4, 1987 (Attachment 13).
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- 7. On June 5,1987, FEMA pre-filed testimony in response to NECNP Contention RERP-8, in which, on pages 38 and 39 of that document, FEMA took the position that FEMA was unable to conclude that the NH RERP and local plans were adequate "to protect the public in the event of an accident at Seabrock Nuclear Power" and to provide "reasonable assurance that appropriate protective measures can be taken offsite in the event of a j radiolcgical emergency." (Attachment 14 is a revision of the June 5, 1987 filing with minor revisions.)
- 8. In a letter to Richard Strome (New Hampshire), Mr. Thomas discusses the FEMA filing, stating that the "Current FERA Position is largely based
('] upon the FEMA and the Regional Assistance Committee (RAC) reviews which were previously provided to you. The position of the Current FEMA Position dealing with the beach population is based on a thoroegh analysis by FEMA and the RAC. (Attachment 15)
- 9. On July 30, FEMA:I convened the RAC to discuss a number of items (7/2/87 memo from E. Thomas to RAC (Attachment 16) and agenda for 7/30/87 RAC meeting (Attachment 17)). NRC attendees were R. Bores, W. Lazarus and J. i Schumacher; FEMA attendees included E. Thomas, J. Dolan, B. Swiren; FEMA !
contractor, R. Rospenda (ANL); DOE, H. Fish; D0T, P. Lutz; EPA, 8. Keene; FDA, W. Church; and Dept. of Agriculture, D. Nevitt. Dept. of Commerce (NOAA) was not represgnted.
After discussing the other items on the agenda, E. Thomas apelogized for !
not consulting the RAC prior to pre-filing the testimony on June 5,1987, i but said there wasn't time to do so and still meet the filing deadline.
He further explained that FEMA, not FEMA:I had taken the position that the NH plans were not adequate to protect the beach population because the "NRC had changed their position" in revising their response to his 12/31/85 memorandum. He said the plant specific items removed from the position paper by the NRC in its 6/4/87 revision were crucial to a FEMA !
finding of adequacy. In the discussion that ensued, the DOT representa-tive stated to Mr. Thomas, "You have a problem!" Then, "We have a problem that we need to come together on." He said that whether or not g the paper discussed the specific plant features did not change the facts v of the construction. He felt that the plans were adequate and the best he had reviewed. Similar responses were provided by DOE, EPA and w
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,' - 4 R. BORES TECH ASSISTANT ORSS, REGION I
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HHS. 00T also questioned the "high" numbers of beach goers that were supposed to use the beaches in the summer. He stated that on three separate weekends he traveled the full length of the beaches and observed only a few hundred people on the beaches on each occasion. NRC represen-tatives reiterated that the basis of the position paper rested on the features of the NH plans and not on the plant features. The NH plans were adequate to provide reasonable assurance that the beach population could be protected given a serious accident at Seabrook Station, in effect, removing any probability discussions (or assuming the probability of a serious accident was 1), the plans still met the regulations, NUREG 0654 criteria, and provided reasonable assurance. Mr. Thomas then stated that FEMA's measure of "reascnable assurance" differed from that of the NRC and from that stated in tne FEMA /NRC response to the Dignan memo.
Mr. Lazc,rus asked Mr. Thomas to take a RAC vote on the support of RAC for the previcusly adopted position paper. Mr. Thomas declined to do so.
Mr. Lazarus then polled the RAC membership. Each of the agencies represented, with the exception of FEMA and their contractor, indicated thot they supported the previously adopted position as modified by my Jur.e 4, 1987 letter.
Mr. Thomas stated that the contractor (ANL) would provide some alterna-tive wording proposals to the RAC membership for both the position paper O and the FEMA pre-filed position. He said the RAC would then have another opportunity to comment on them and reconvene for resolution of the beach issue. The meeting was then ended.
- 10. On August 12, 1987, at a meeting in Concord, NH, I asked the ANL contractor about the proposed wording changes which Mr. Thomas had directed the contractor to prepare. The contractor stated that those changes were prepared and sent to FEMA:I on 8/7/37. As of this date (10/11/87) those changes have not been forwarded to the RAC.
Robert J. Bores 10/13/87 Attachnents: As stated l
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FEDERAL EMERGENCY MANAGEMENT AGENCY 4., ,
John W. McCormack Post Office and Courthouse 7 Boston, Massechusetts 02109 cjgM64p INFORMATION AND GUIDANCE MEMORANDUM DATE: December 31. 1985 NUMBER: R1-TH-85-28 MEMORANDUM FOR: Regional Assistance Committee (RAC)
Radiological Emergency Preparedness Task Force (REP)
FROM: Edward A. Thomas, Division Chief
' Natural & Technological Hazards
SUBJECT:
Seabrook Emergency Plans -
We have all known for years that the state and local plans to protect the public in the event of an accident at the Seabrook Nuclear Power Plant must include special attention to several factors which are unique (at least in magnitude) to the Seabrook area. By now, all of you should have received the formal subnittal from the State of New Hampshire of the off-site emer-gency plans for Seabrook. As we indicated in the transmittal memo, portions of the plan have not yet been developed and, therefore, wcre not included in O . the Packe9e seat to you. Therefore. some of the sPeciai. 9uasi-uai9 ue factors which affect Seabrook, such as the impact of the road network on evacuation times, cannot be addressed by the RAC at this time. However, the state and local plans do indicate what steps the state proposes to take with respect to the vital area of sheltering and evacuatirig the beach population.
At the earliest possible time in the RAC review process, I propose that we focus in on the beach population to determine if special technical assistance from the RAC may be needed to assist state and local governner.ts refine their plans to protect this group. It appears to us that when we discuss beach population, we are talking about two dif ferent groups: (a) the transient beach population, and (b), sumer residents who inhabit unwinterized accom-modations on or near the beach A. The Transient Beach Population The transient beach population is that group who make day trips to the beaches near Seabrook by auto, bus, or other means of locomotion. This pop-ulation has no identified place of shelter other than any vehicle in which they may have arrived at the beach. The emergency plans submitted by the State of New Hampshire essentially indicate that this population will be protected in the event of an accident at Seabrook by closing the beaches at the earliest sign that a serious emergency is developing, and encouraging the transient beach population to leave the area. Those beachgoers who have nearby shelter would be encouraged to seek the shelter or evacuate as con-O ditioas at the P' eat dictated- The coasuitias tira or x'o Associates is ia l
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.h the process of developing revised evacuation time estimates for all popula-tion groups in the Seabrook EPZ. We do not now have an estimate for how long it would take to evacuate the beach population in an accident either when everyone else in the area was told to take shelter, or when the entire EPZ was ordered to evacuate, or any combination of evacuations in between these extremes. However, for the sake of discussion, we believe that it is reasonable to assume for the present that the beach population would be out in the open, or in vehicles close to the center of the EPZ for several hours after the earliest indication that an accident was in progress.
Issue Based on the RAC's knowledge of the accepted literature in the fields of accident sequences, sou ce terms, and the health effects of radiation, is the current planning acceptable or nearly acceptable? Before you can answer, do you require more precise information on the times that the tran- l sient beach population would be in the open, or in a vehicle? If we have ;
advice for the state and local governments on this matter, I believe that I we should make it known as soon as possible, if we need additional infor- i mation to deal with the issue, we should let them know now.
l B. Occupants of Unwinterized Accommodations A number of people associated with the Seabrook emergency plans process have suggested that special attention needed to be paid to occupants of the Q many unwinterized cottages, motel rooms, and camp grounds in the Seabrook
'EPZ. These people believe that the normal assumptions we make about the protective effects of sheltering are not valid for structures which are:
(a) not designed to resist air intrusion, and/or (b) which have a very small protective factor because of the slight mass of the structure.
l Issue l If the RAC believes that this is an issue which sould be covered in the emergency plans, we should raise it now to afford the state / local governments time to quantify the problem and to plan to deal with it. Finally, if we have any other preliminary comments on the emergency plans, we probably should make them known to the stat'e/ local governments as soon as possible. We would be particularly interested in passing on any indication that you have as to whether the plans are in adequate shape for a full-scale exercise at the end of February as is currently planned.
We request that you respond to this memorandum within fourteen days.
After the responses are in, we will call a meeting of the RAC to formulate a position on these matters.
HAPPY NEW YEARI O
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.o June 18,1986 En WfC7 / g cc: J. Allan J. Gutierrez l S arottecki i Spence W. Perry, Acting General Counsel S. Ebneter Federal Emergency Management Agency B. Johnston ,
Room 840 T. Martin 500 C Street, S.W.
Washington, D.C. 20472 R;Bellamy g 1.aza rus 6/24/86-TEM In the Matter of Public Service Company of New Hampshire, g a_l,. l (Seabrook Station, Units 1 and 2)
Docket Nos. 50-443 OL and 50-444 OL _
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Dear Mr. Perry:
l In response to a request made by Edward Thomas of FEMA Region I, we f have evaluated, in conjunction with Joseph Flynn of your office , an undated memorandum prepared by Thomas Dignan of Ropes and Gray on behalf of the applicants for the Seabrook nuclear plant ("Dignan a coPr of which is attached Attachment ^). our O memoren evaluationdum". is set forth in the following discussion.is The Dignan Memorandum addresses what are described as "three misconcep-tion s" pert cining to offsits emergency planning for the Seabrook nuclear j plant , and concludes that they are "false as matter of law" (Dignan i Memorandum at 1). These purported "misconceptions" are as follows:
A. That the plans must be shown to guarantee that no adverse effects on the public health and safety will occur no matter what kind of accident occurs at !
Seabrook. ,
-B . That it must be demonstrated that the plans wiD assure that aH persons located in the Emergency Planning Zone or some certain portion of it can be evacuated in some certain time.
In particular, there have been assertions that the plans must assure the sheltering or evacuation of persons from the beaches in approximately 1/2 hour.
O 1 It should be noted, however, that under the Commission's regulations, 10 CFR I 50.3, only written regulatory interpretations provided by the General Counsel will be recognized as binding upon the Commission.
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i' '.Epence Petry. Esq.
-O 4. Accidents invoMng early releases are within the Commission's ' emergency planning basis, however, the regulations do not specify a time within which the recommended protec,tive actions are to be completed.
- incerely, Edward S. Christenb[
Director and Chief Hearing Counsel Enclosure cc: J. Taylor E. Jordan T. Sturley i
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W24Y- ,s}Y Federal Emergency Management Agency l 1 g, Region I J.W. hicCormack Post Ordce and Court House l ,,, <. . Boston, hiassachusetts 02109
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July 9,1986 1 Mr. Robert J. Boulay State Energency Manajement Director Massachusetts Civil Defense Agency c ard Office of Dr.ergency Preparedness IE P.O. Box 1496 5 400 Wormster Rm.d i Framingham, Massachusetts 01701 co See .
Dear Mr. Boulay:
U Last January, you regmsted that FT.MA conment on a menorardum prepara$ teG Tn=as Dignan, Counsel for the New HE pshire Yankee Division of the Public' Service Ccepony of New Ec.pshire. A ccpy of that mercrarders is enciesed. The enclosed letter from the Nuclear Regulatory Ccr: mission analyzing the Dignan meno was developed in close coordination with FC4A ard r@ resents ( the corbined views of both NRC ard FDdA. We pologize for the driay in res;crdirg to your re:;mst. Please call if you have questiens. Sinmrel , f
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/w r Edsard A. Thomas Chief Natural ard Technolcgical Hazards Division Enclosures cc: Richard Strate '
l Terry Harpster OC 8,. y 9 Y W J c2 4 4 P A o
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.ny h 519c5 HEMORANDUM FOR: Edward A. Themas,. Chief i Natu I and T chnological Hazards Division
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FRCH: ,. . n H. . . Acting Gene I Counsel
SUBJECT:
Offsite Emergency Planning at Seabroch Station l l InyourmeErandumofJanuary 23, 1986 to Joseon Flynn ou ccmmunicated the request of Robert Boulay, Civil Defense Olrector for the Commonwealth of Massachusetts, that the federal Emergency Management Agency (FEMA) and the j
, Nuclear Regulatory Commission (NRC) review and comment upon a memorandum of
( law prepare by Themas Olgnan, Counsel for Public Service Company of New . Hampshire. In his memorandum, Mr. Olgnan addressed what he considered to be 1 3 three miscenceptions about offsite emergency response planning as it relates I m/ to the Seabrock Station. I recently received a letter frcm Edaard Christenbury. Olrector and Chief Hearing Counsel, Office of the Executive Legal 01 rector (CELD) of NRC, which respends to your request. A copy of that letter is attached. The legal discussion in that letter reflects the combined views of our respective offices. I concur in Mr. Christenbury's analysis of the Olgnan memorandum. 1 1 Attachment 1 l l
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/ : -cJs j 1 . . January le, 1997 MEMORANCUM FOR: E arc A. Thomas, Chairman, Regional Assistance Comenttee (RAC), FEMA Region I FROM: W1111am J. La:arus, Chief. Emergency Preparedness Section, NRC Region !
SUBJECT:
A55!3NMENT OF NRC RAC MEMBERS FOR SITES IN FEMA REGION I Effective istediately, the following persons are assigned NRC RAC review responsibilities for nuclear power plants located within FEMA Region !: Seabrook Mr. Robert Beres FTS 486-1213 or (215) 337-5213 All other sites Mr. John Schumacher FTS 489-1342 or (215) 337-5342 If you r. ave any questions, or are at any ttee unable to contact either Mr. Beres or Mr. Schumacher, please feel free to contact se at FTS 488-1208 or (215) 337-5208. O Will . ru Emergency Preparedness Section NRC Region I bcC: T. Martin R. Sellary R. Bores , J. Schur.acher E. Fox P. Lohaus E. Jordan S. Schwart: E, Podolak l
AtrM h . qr , Federal Emergency Management Agency
, Region I J.W. McCormack Post Omce and Court House
.O .#. Boston, Massachusetti O2109 Janua ry 27, 1987 MEMORANDUM FOR: State Emergency Management Directors Regional Assistance Comittee (RAC) '
Radiological Emergency Preparedness Task Force (REP) FROM: Edward A. Thomu l'0 7
' RAC Chairman '
SUBJECT:
Assignment of NRC C Members Attached please find an updatea Regional Assistance Comitte (RAC) listing. We have been advised by the NRC the following persons are assignea NRC RAC review responsibilities for nuclear power plants located within FEMA Region I. Seabrook Dr. Robert Bores FTS: 488-1213 O or (215) 337-s213 All Other Sites Mr. John Schumacher FTS: 408-1342 or (215) 337-5342 If you have questions, please call Betty Dionne - FTS: 223-9562 Attachment l 1 l O l
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l i Janua ry 27, 1987 l ' FEMA REGION 1 Regional Assistance Committee Members Supervisor / Director Committee Member
- Mr. Paul Lutz Rear Admiral Robert Johanson Regional Emergency Transportation Rep Commander Capt. John Foster Williams Coast Guard Bldg. 1st Coast Guard District 408 A.tlantic Ave. Capt. J.F. Williams Coast Guard Bldg.
Boston, MA. 02210-2209 408 Atlantic Ave. FTS: 8-223-8451 Boston, MA 02210
=
COMM: 617/223-8431 24 HR: 617/223-8555 Coast Guard Duty Officer Mr. 8yron Keene Mr. Louis Gitto, Director U.S. Environmental Protection Agency Air Management Division 2312 JFK Federal Building U.S. Environmental Protection Agency Boston, MA 02203 (23rd Floor) 2203 JFK Federal Building FTS: 8-835-3234 Boston, MA 02203 COMM: 617/565-3234 i Mr. Warren Churen Mr. David Field Regional Radiological Healtr Represcatative Director 2 U.S. Food & Drug Administration State Program Branch j 585 C'mmercial St. 585 Correr cial St. Boston, MA 02109 Boston, MA 02109 FTS: 8-835-4718 h COMM: 617/565-4718 John Stepp Mr. Edward J. Montminy
, U.S. Dept. of Health & Human Services Regional Health Administrator Public Health Service Representative Public Health Division l 1401 JFK Federal Bldg. (14th Floor) 1401 JFK Federal Building Boston, MA 02203 Boston, MA 02203 FTS: 8-835-1,39 COMM: 617/565 1469 Jophn Schunacher Thomas Murity Nuclear Regulatory Commission , Regional Administrator ;
Region I Nuclear Regulatcay Commission l 631 Park Ave. 631 Park Ave. ' King of Prussl6, FA 194CS King of Prussia, PA 19406 FTS: 488-1342 24 HR: 215/337-5000 COMM: (215) 337-5342
*2rt 3 orts (Seabrock) Thomas Muricy t : lear Rn tory Commission Regional Administrator 3i Pe.rk w Nuclear Regulatory Commissian
' N - t PA 19406 631 Park Ave.
King of Prussia, PA 19406
.J FAX: 408-11'c (50 seconds) 488-1323 (Verification)
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(] Committee Member _(Dorothy Nevitt/ Bot Conley/Cheryl Malina/ Supervisor / Director Mr. George E. Bickerton Anna Hart) Director Office of Emergency Planning Office of Emergency Planning USDA - F3!S-PP USDA - FSIS-PP 14th & Independence Ave., S.W. 14th & Independence Avo., S.W. Room 2940 - South Bldg. Room 2940 - South Bldg. Washington, D.C. 20250 Washington, D.C. 20250 FTS: 8/475-3683 FTS: 8/447-2791 FAX: 8/447-2682 USDA Washington Contact for REP (USDA Plum Island, NY
Contact:
R.T. Tornblom, Supvr. George E. Bickerton, Supvr/Dir. Safety Specialist Office of Emergency Planning Plum Island Animal Disease Center (Pox 848) USDA - FSIS-PP Greenport, NY 11944 14th & Independence Ave., S.W. FTS: 8-649-9204 Washington, D.C. 20250 24 Hr: 8-649-9248/9253) FTS: 8-475-3683 Mr. Herbert G. Fish U.S. Department of Energy Ted Dobry Princeton Area Office Chief, Public Safety Section P.O. Box 102 U.S. Dept. of Energy p) q Princeton, NJ 08542 Office of Environment Tel: FTS 8-340-3700 (3708) Routing Symbol EV 131 (Brockhecen: 8-666-3427) Washington, DC 20545 (NY Suppurt Office 8-212-620-3608) FTS : 8-233-5434 (FAX: 3-340-2032) COMM: 301-353-5434 (PREFERRED MAILING ADDRESS: 56 Mountainview Road Millburn, NJ 07041) William P. Patterson , Bruce Blanchard U.S. Department of the Interior Director Regional Envircnmental Office Office of Environmental Project 1500 Custom House Review 165 State St< Office of the Secretary Boston, MA 02109 Department of the Interior Nashingten, 0,C. 20240 FTS: 22?-5517 or 223-5104 COMM: 202/343-3891 HOME: 617/527-4180 FTS: 343-3891 (See Other Side) e
Dept. of Commerce - NOAA/NWS Mr. Richard P. Augulis Hr. Stanley Wasserman Director Division Chief National Weather Service Os . tieterological Services Division Eastern Region Headquarters NWS Eastern Region 585 Stewart Avenue 585 Stewart Avenue Garden City, NY 11530 Garden City, N.Y. 11530 COMft: 8-516/228-5401 FTS: 8-649 5454 FTS: 8-649-5401 COMM: 8-516/228-5454 REP TASK FORCE Ken Horak - Public Relations - FEMA Don Connors - American Red Cross - FEMA Tom Baldwin - ANL Mr. Thomas E. Baldwin Argonne National Laboratory 277 Main St. 2nd Floor Port Washington, NY 11050 Comm: (516) 883-0030 0 0
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V Edward A. Thomas, Chaiman FE8 181987 #f[ i Regional Assistance Committee l Federal Emergency Management Agency ! John W. McCormack Post Office and Court House 1 Boston, Massachusetts 02102
Dear Mr omas:
Reference:
Your memo of December 31, 1985 relative to the beach populations in the Seabrook area As requested, I am responding to your memo regarding the adequacy of the New Hampshire REkP relative to the protection of the beach population. My response is based on Revision 2 of the NH RERP; the RAC/ contractor coments on it, including the Seabrook Daeuation Time Study; the analyses cf specific Seabrook ( Station features; and my professional knowledge and judgement related to emergency adequate contingent (preparedness. The bases on completion of my opinion of actions by Newthat the plans
.iampshire are or will to resolve RAC be concerns) to protect the beach population (both the beach transient group and those who inhabit unwinterized accamodatinns) arc provided in the Enclosure to l this correspondence.
Should you have any questions concerning the above, please contact me at FTS
,Q 488-1213. I would be happy to meet with you and/or the RAC to discuss my response, l i
Robert Bores, Technical Assistant Division of Radiation Safety and Safeguards Enclosure- As Stated cc w/ encl: W. Lazarus, RI i I l O
\
1 1 PROTECTION OF NEW HAMPSHIRE BEACH POPULATIONS BACXGROUND 1 1 The requirements for emergency preparedness stem from 10 CFR 50.47(a)(1) and (2), which state that except as provided in 10 CFR 50.47(d) (relative to licensing of a facility for operation up to 5% of rated p the NRC that 'there is reasonable assurance that adequate protective measures can and will te taken in the event of a radiological emergency. The NRC will base its finding on a review of the FEMA findings and determinations as to whether state and local emergency plans are adequate and whether there is reasonable assurance that they can be implemented, and on the NRC assessment of The FEHA finding is primarily based on the review of the st emergency plans. in conside.-ing whether there is reasonable assurance that the p implemented. Paragraph offsite emergency respons(b) of 10 CFR 50.47 requires that the onsite and planning standards. e plans for nuclear power reactors meet 16 specified Emergency Response Plans and Preparedness in Sup was issued to provide a comon reference and guidance source for state and O- local governments and licensees in the development of emergency response plans and preparedness for response to a radiological emergency and for preparedness. and FEMA, NRC and other federal agencies for use in the review of those plans The planning basis adopted by NRC and FEMA for emergency preparedness aroun nuclear power plants was taken from NUREG 0396/ EPA 520/1-7fi-016, "Plann Basis for the Development of State and Local Government Radiological Em Response Plans in Support of Light Water Nuclear Power Plants". objective of the emergency response plans is to provide "The doseoverall savings (and in some cases, imediate life savings) for a spectrum of accidents that could produce offsite doses in excess of the PAGs" (NUREG 0654). it attempted to identify the boundarthat the planning basis range'from triv of potential accident consequences, y parameters based on avaliable knowledge teristics (source tenn). timing of releases, and release charac-pAGs do not equate with loss of life or even a health hazard.It should b The PAGs were intendedTr use by protective action decision makers in arriving at a balance between radiation risk constraints to that action. and that of taking a protective action in the absence of 1 Enclosure l l
g " ,,y URutu 3 Asts y , ?.. NUCLEAR nEGULATOR'! COMMISslON i , ,L' '$ REGION I .s ' l S Jf PAMK AVENUE KING OF PRUS$i3, PENNSYLV ANI A 19406
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.O :<^r 8 iSS7 Mr. Edward A. Thomas, Chairman Regional Assistance Conrnittee Federal Emergency Management Agency 442 John W. McCormack Post Office and Court House Boston, Massachusetts 02109 6
Dear ' . Thomas:
Reference:
kAC Coments on Transient Beach Population for Seabrook Station I have reviewed the individual RAC comments distributed with your March 2, 1987 memorandam and provide the following general coments.
. There appear to be no issues that have not been addressed in some detail. All issues raised appear to have been adequately addressed in subsequent revisions of the New Hampshire State and local plans.
. There appear to be adequate bases and infomation now available for RAC/ FEMA to make a finding or resolve the issues kept open in this area.
The scheduled meeting should provide the forum for any additional discussions O that may be cesirable by RAC/ FEMA to resolve / address any outstanding concerns. Sincerely, e Robert . Bores i Technical Assistant ' Division of Radiation Safety and Safeguards cc: W. Lazarus, RI l l O
l l ARGONNE NATIONAL LABORATORY 9700 SOUTH CASS AVENUE, ARGONNE, ILLINOIS 60439 TELEPHONE 312/9'2-7643
/ .
April 14,1987 /)ff7 l 1 l Mr. Jack Dolan i Federal Emergency Management Agency Room 462 J.W. McCormack Post Office and Courthouse Boston, MA 02109
Dear Jack:
In response to Edward Thomas,3/2/87 memorandum, we have reviewed the RAC responses to Thomas 12/31/85 memorandum concerning the translent beach population and have the following comments:
- It appears that final resolution on t'he adequacy of planning for the beach population is dependent on the receipt and review of Information from the State of New Hampshire on the number of transionts who would need transportation during an evacuation.
- Page 3 of enclosure to R. Bores'(NRC) letter dated 2/18/87. The comment that element J.10.d has been left "open" by the RAC is not consistent with the RAC O- 1 vi 9r a a t=-
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- Page 4 of enclosure to R. Bores' letter dated 2/18/87. The comment for
.)I p element J.10.k that the RAC had "one additional recommendation" is not V4
!* consistent with the RAC review spreadsheets.
bY b Page .6 cf enclosure to R. Bores' letter dated 2/18/ri. Item #4 Indicates p #) ( that ...." resources have been provided .... for providing transportation for those without vehicles ...." However, as Indicated in comment #17 of the RAC review PA F
'r),
d of the ETE, the estimates of persons requiring transit provided in the ETE represent only estimates of permanent residents who require transit and do not p Include the transient beach population. f- If you have any questions, please.do not hesitate to contact me. W Sincerely, C $ $ h ,/r Robert E. Rospenda ! Energy and Environmental Systems Division RPRamay
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cc E. Thomas (FEMA-Region I) M. Lawless (FEM A-HQ) O\ T. Baldwin (ANL) K. Bertram (ANL) M. Singh (ANL)
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1 ARGONNE NATIONAL LABORATORY MM /8 i 9700 SOUTH CAss AVENUE, ARGoNNE, ILLINols 60439 TELEPHONE 312/972-7643 O , v . 1 i April 17,1987 Mr. Edward A. Thomas Federal Emergency Management Agency l Room 462 J.W. McCormack Post Office and Courthouse Boston, MA 02109
Dear Ed:
In accordance with your request after the RAC meeting in Boston 4-15-87, I have prepared draft revisions to the RAC review of the New Hampsh're State and local plans for Seabrook. These draft revisions are enclosed and reflect the RAC's conclusion that the plans (Rev. 2) adequately treat the beach population issue. In order to expedite final review, and to clearly show where changes are being proposed, I have purposely lef t the changes in hand-written form on marked-up copies of the origin &l pages. The proposed changes are shown on the following two enclosures: Enclosure 1. Revisions to RAC review of State plan elements J.9 and J.10.m O <sectioa i. 9 res 84. 88 ae 87)> ao ioe i sez 91 a eie eat 3 $ (sectioa ii page 17). Enclosure 2. Addition to page 8 of enclosure to R. Bores letter dated 2-18-87. (Note: Although the RAC had discussed several possible additional changes to the wording of Individual conclusions on page 10, it is my understanding that these would not be made pending additional review by R. Bores.) If yc. iave any questions, please do not hesitate to contact me. Sincerely, k Robert E. Rospetida Energy and Environmental Systems Division 4 '. (" RER:may l Enclosures (1 and 2) l l cc R. Bores (NRC) M. Lawless (FEMA-HQ) K. Bertram (ANL) T. Baldwin (ANL) l U.s. OEPARTMENT OF ENERGY THE UNIVERSITY OF CHICAGO
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.OARGONNENATIONALLABORATORY 970o SOUTH CASS AVENUE, ARGoNNE, ILLINol$
60439 1 1 April 22,1987 t Mr. Edward A. Thomas Federal Emergency Management Agency Room 462 J.W. McCormack Post Office and Courthouse Boston, MA 02109
Dear Ed:
As requested by Jack Dolan on 4/22/87, we have prepared additional draf t revisions to the RAC review of the New Hampshire State and local plans for Seabrook. These draft revisions are enclosed and reflect suggested changes by Bob Bores (NRC) to the revisions previously transmitted with our letter dated 4/17/87. These changes deal with the beach population issue. In order to clearly show where changes are being proposed, we have again purposely lef t the changes in hand-written form. The most recent changes, suggested by Bob Bores, are indicated by brackets, if you have any questions, please do not hesitate to contact me. Sincerely, k Robert E. Rospenda Energy and Environmenta! Systems Division RER:may Enclosures (1 and 2) cc R. Bores (NRC) M. Lawless (FEM A-HQ) K. Bertram (ANL) T. Baldwin (ANL) O THE UNIVER$ TTY OF CHICAGO U.S. DEPARTMENT OF ENERGY
UNITED STATES ie2880u9*.
+# ,, NUCLEAR REGULATORY COMMIS$10N est can AvtNut y,k ,<isa or raisisia. PENN YLV ANI A 19406 o- .
m e ,3,, . Edward A. Thonas, Chairran Regional Assistance Committee Federal Emergency Management Agency John W. McCormack Post Office and Court House Boston, Massachusetts 02102
Dear Mr omas:
Reference:
Your memo of December 31, 1985 relt.tive to the beach populations in the Seabrook area As requested, I am responding to your itemo regarding the adequacy of the New Hampshire RERP relative to the protection of the beach population. My response is based on Revision 2 of the NH RERp; the RAC/ contractor coments on it, including the Seabrook Evacuation Time Study; the analyses of specific Seabrook Station features; and my professional knowledge and judgement related to The bases of my opinion that the plans are or will be emergency adequate (preparedness. contingent on completion of actions by New Hampshire to reso concerns) to protect the beach population (both the beach transient group and those who inhabit unwinterized accomodations) are provided in the Enclosure to l this corresponder, e. O Shou,d you have any questions concerning the above, please contact me at rTS 488-1213. I would be happy to meet with you and/or the RAC to discuss my response.
** i
\
Robert Bores, Technical Assistant Division of Radiation Safety , and Safeguards l Encl o' 'J re : As Stated ,
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cc w/ encl: W. Lazarus, RI O
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. U% Tao STATES -
, i[ p*'L*8eg\, NUCLEAR REGULATORY COM41s310N
- .,,,.".',n',.. ENd6SME 2 ' '
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Edward A. Thocas. Chairran ! Regional Assistance Cemittee Federal Emergency Management Agency John W. McCcreack Post Office and Court House Boston, Massachusetts 02102 Cear Me omas:
Reference:
Your remo of December 31,1985 relative to the beach populatiers , in the Seabrook area I l l As requested, I am responding to your ramo regarding the adequacy of the New ;
)
barpshire RERP relative to the protection of the beach population. My response is based on Revision 2 of the NH RERP; the RAC/ contractor corrents on it, including the Seabrook Evacuation Time Study; the analyses of ,;acific Seabrook Station features; and my professional knowledge and judgemern ajated to emergency preparedness. The bases of ry opinion that the plans are or will be adequate (ccntingent on completion of actions by New Hampshire to resolve RAC 1 O ca c r">> ta arat ci '8 6 ><a rer i t'a" (6ath t8 6 ch tr ">' * 'rava "' those who inhabit unwinterized accorrodations) are provided in the Enclosure to l this correspondence. Should you have any questicns concerning the above, please contact me at FTS 488-1213. I would be happy to r4et with you and/or the RAC to discuss ry ; response. I l
& ^
l Rcbert Beres, Technical Assistant I 01 vision of Radiation Safety : and Safeguards
Enclosure:
As Stated ! cc w/ enc 1: W. Lazarus, RI l l O
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It is also noted that when largE seasonal beach crowds are likely to be present (on hot and sunny days), the typical wind pattem is from the offshore. l cooler surface to the onshore, wareer surfaces of the land rasses. Tits eeans j u"i that any "sea breezes' would likely prevent the plume free traveling')to nearby beach areas when the beaches are rost heavily populated. G D15CUS$10N a/rtel l The foregoing discussions have indicated that th'e current NH plans rett or will reet the criteria of NUREG C654 in a generic sense. Specific and detailed procedures have been provided to assure early notification and evacuation of the beach population can be effected should the plant status appear to be threatening. The review of these plans and procedures do not indicate the presence of concerns or situations involving the beach populations which warrant unique solution or provisions beyond those already incorporated. The beaches themselves are nearly two kiles from the station at their ciosest approach. This distance provides for dispersion and dilution of the plume as well as additional plure travel tire for a plure to reach the beach area from the site. Additionally, because of the sea breeze situations nonna11y associated with sea coast areas, the wind direction will be normally on shore, O i.e.,towardtheplant,ratherthanoffshorefromtheplanttotheshort) during hot, sunny days when the beaches are Itkely to be ecst populated. The analyred severe accident scenarios (core melt with early containment failure) indicate that the rajor portion of the dose to the affected population from such an event is due to exposure to deposited radioactive raterials on the ground surfaces rather than from the passing plume. The risk / consequence codes generally used (CRAC models or MACCS) all assure th6t the population is exposed , to this ground deposition for 24 hours af ter the arrival of the first portion ; of the plure and to any additional plumes over that area. In other words, the codes assume that no protective actions are implemented for 24.h0urs af ter the l release reaches thTheach (or other areas of interest). In view of the NH plans for beach closure and access control as early as the Alert classification; the cited "negligible probability of proept contaircent failure" at Seabrook 'and low consequence / low probability of serious containment bypass sequences; the plume travel tire to the beach areas and the relatively short (2 to 4 hours) time esticated to clear the beaches, it appears that risks I to the beach population are a small fraction of the cited risks in NUREG 0396 for this distance. Thus, even if there were a proept, severe, contaminating release and a portion of the beach population were caught in or under the plume for two hours during the evacuation process, their exposure to deposited radioactivity would only be approximately 2/24 or less than one tenth of the code assumed dose. In aedition, they would be avoiding any additional exposure to the plure(s) af ter leaving this area. l o l 1
I 4,p* * % t0 f,k ' UNITED STATES ' 8 o NUCLEAR REGULATORY COMMISSION - 1
*, d l REGION I 631 PARK AVENUE y
n 4, ,o KING OF PRUS$1A, PENNSYLVANIA 19406 y *s.
- i l
APR 24 19g7 Mr. Edward A. Thomas, Chairman hhc W /I J Regional Assistance Connittee i Federal Emergency Management Agency ' 442 John W. McCormack Post Office & Court House Boston, Massachusetts 02109
Dear Thomas:
Reference:
Coments Related to RAC Meeting on Beach Issues On April 22 and 23, 1987, I had telephone discussions with Jack Dolan of your staff regarding some clarifications. Bob Rospenda of ANL is providing sorte changes as discussed on April 22, 1987. Below is a suggested addition as discussed with Jack Dolan on April 23, 1987, which may help in understanding i the terminology related to risks. The following sentence should be inserted on p. 7 of the enclosure to ray February 18, 1987 rremo on this subject, at the end of the second paragraph, folicwing "Using the RSS assumptions, the New Hampshire Yankee and 8NL studies ! indicated that a severe accident at Seabrook Station posed a public health O risk at about two miles from the station that was essentially the same 1 V magnitude as considered in NUREG 0396 at 10 miles from a nuclear plant." Add: l "That is, since public health risk is inversely related to public safety, the level of safety for a person living two miles from Seabrook Station is essentially the same as the level of safety considered in NUREG 0396 for a l person living 10 miles from a nuclear plant." Should you have any questions, please contact me at FTS 488-1213. , 1 F : Robert . Bores Technical Assistant Division of Radiation Safety and Safeguards cc: W. Lazarus, RI R. Rospenda, ANL l s
7 m Y-07 '87 14:38 ID:MGCHE mTL LRB TEL :312-972-7819 N17? P01
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-O ENERGY AND' ENVIRONMENTAL SYSTEMS DIVISION TELECOMMUNICATION MESSAGE
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l t%Y-07 '87 14:38 !D W4ttE MTL LAB TEL to:312 cR2-7819 #1 n P02
]
Draf t 3/6/87 gl
. 1 1
O - REv=D ex or HAveroN CONTENTION VIII TO REVISION 8 PEMA Respons_e PEMA has addressed the Town of Hampton Revised Contention VIII and its basis of Inadequate protective actions for the beach population by applying Plann!ng 8tandard J (Evaluation Criteria J.9, J 10.a, J.10.g and J 10.m) in PEMA-REP-1. The December 15, 1986 RAC review of the state and munlolpal plans, the amended portions of the RAC review dated , and the RAC pos!tlon paper on I the beach population issue transmitted to the 8 tate of New Hampsh!re dated reflect FEMA's views on this issue. Speettically, FEMA's review comments on the New Hampshire State plan on this tasue are provided on pages 84,74, 4 l 80,87,88, and 91 of Section I. FEMA's revlew comments on the municipal plans on th!s O issue are preided on pa,e 12 or Soma u. rEMAs raiew -mments on ine Evouauon Time Estimate (ETE) on this !ssue are provided on page 4 of Section VI.
.. ~ = .=; .: , .w - -- a n :z FEMA,- relled upon
- the following m .n ,: : ,,
documents. In f.orming
.--,s its co,nclusions a- on this -.
; s. ;;-;- ;;.
Issue Rev!alen 2 to the Hampton plan Rev:slon 2 to the New Hampshire State plan; and the Applicant's Motion for Summary Disposition of the Town of Hampton Revised Cor.tention Vill dated March 15,1987. As Indicated in the December 15, 1986 RAC rerlew (page 64, Scotlon I), determination of the adequacy of protective responses for the beach population remained open pending final review by the RAC of planned protective measures, and pending receipt of informatten from the state on the number of translents who would need transportation during an evacuation. The RAC has recently concluded (see RAC posit!on I paper dated ) that the besch population can be appropelately protected by implementing provisions of the current (Rev. 2) New Hampshire emergency plans and O that there appears to be no unique problem relative to the beach population that has not been adequately addressed. m - - _ __ J
1 I r%Y-07 ' 87 14:39 IDifRGCNE MTL LAB C:312-9??-7819 0177 P03
,. . (Hampton Vill) Draft 5/6/87 ;
7"' " " ' "* ' '" ' " ^ o ""' " ' " " '"' 6* ' " P 9 "2'" " t" ' * *' ' d 'd '"
.O i the position paper transmitted from PEMA to the State of New Hampehlte on May _,
1987. Work on th!s position paper was inttlated by a 12-31-s5 memorandum from the RAC Chairman to the RAC members requesting tholt review and comments on the adequacy of plans for protecting the beach population (14., the transient beach population, and summer residents who lhthabit unw!nterfred secommodations on or near the beach), and the possible need for special protective actions to protect the beach population. Written comments in response to the memorandum were received by the RAC Chairman during 1988 and 1987. A special meeting of the RAC wu convened in April 1987 to review all comments and, if possible, to arrive at a un!ffed positio,n on whether the plans were adequate or inadequate to protect the beach population. On the basis of this review. the RAC resolvec tnat, contingent vu the uvmyl.tlan of action by tne btate to resolve the utlier RAC concerns with tho Mow Hampshire and lheAl DIANA. O ..
..,.. .. . . i iii ii i !
--!J . . :.-_J L.tinuaissa Inst tha.h000h IM llDIlillitllifd f r i I . Julitlisa tilli ha nlatnated IMeillit fllfilf J1]OM Wlll jHggjgy mget.the., .. .. .
. .u..i.. ..e nunca oct t and os intant nf thakh rainilatinnsin thh area, y Tne rouowing cousiuvreuvu. m. m...--- -, . - .... -.II. I il vouubtvu ..tAtiva ta the bouuh vvplation?
.... II I .1 ll Il! Elli UllIIII 0lll 0Dllll}l generleally l
- Special provisions for beach populatlons In plaue
- No identifled problems requiring unique or unaddremed solutions
- Provisions for early warning of beach populations
- Adequate transportation resources available for those needing public trantit
--r , - - - - - ,,w,--- - , - - - ,,-, e,- ---w- - -. - - - - - , , , - - - , , , - - , - - - - - - , - , , - - , - - , -
MAY-07 'B7 14:40 IDIARCbt MTL LAB TEL NO:312-972-7919' gg77 pg4
. QIampton Vill) Draf t 5/8/87 ,J.
- Beaches are nearly two miles from station affording delay in plume l arrival and dilution and dispersion of plume
- Sea breezes would tend to keep plume from traveling directly toward beach when beaches are most populated
~
o ZTEs for beaches are relatively small 7 Containment at Seabrook is very strong; probabDity of prompt I contalnmer.t failure is negilglble l 1 e Containment bypass is unlikely to caitse severe offsite problems
- Site speelfic studies for Seabrook Indicate risks at two miles are
,_ comparable to NUREG 0396 analyzed risks at 10 miles i * "Reasonable assurance" does not equate with "absolute safety,"1.e.,
guarantee of no exposures or exposures above the PAQs. l The ateve are described In further detallin the RAC position paper transmitted l to the State of New Hampehlte on May a 1987. Although the RAC has.renobed p-conclusion.or! the beach.populatfortisspe e tthe_t. e :-- R AC still awalts recelpt of Information from ine State of New Hamp6htte on the number of transients who would need transportation during an evacuation. The State Plan (ETFo Volume 8 Table 11-8) presently provides estimates of permanent res! dents who would require transportation, but does not ine'ude estimates for translents requiring transportation (RAC review, Section VI, comment 17, page 4). Although the number of transients without transportation is expected to be small and well within the available transportation resources (RAC review, Seetton I, page 74) Identified in the plan, this information has not yet been provided to FEMA. Because of the potentially 1sige seasonal beach population, speelal precautionary protective actions for the beach population have been established by the State of New O mmpehire <xew a.mpshire rian, uncoi rroaedures, Appendix r), inetudin, eariy precautlonary evacuation. The use of public buildings for sheltering of translents without
MA -07 '87 14:4A IDifRGCreE MTL LAB ~EL tC:312-972-7819 0177 P05
.. . (Hampton VI!!) Draft 8/6/87 -
0 l . . , \ transportation may be implemented on an "ad hoc" buls (RAC review, Section I, page 64). As indicated in the RAC position paper on the beach pcpulation Issue, provistons have been made In the plans to conalder closing the beaenes or restricting public access ;
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to the beach at the Alert emergency classification. At this classification level, no offsite action would be ordinarily warranted to3rotect the public, but its consideration l Ocsoik
- r_ymed o//**w n/ prJffs. west N_Q bere womo provide additional time to clear thefbeach, just In case the situation Xl 1
worsens. Even at the S!te Area Emergency classification, ons would ordinarily erpact that offsite protective actions would no_t be necessary to protect the public. As noted in i i the State plan (page 2.1-13) precautionary protective actions for the beach population ! will be considered during the period of heaviest beach use, from May 15 through September 15. Detalls on the early precautionary protect!w actions for the beach l 1 population, including precautionary evacuation, are provided in the State plan procedures O (NNeo^ rrocedures 499end!= r>. . . The use of -early. precautionary protective notions such as. beach . closing.and.= - evacuation are not the sole means for protection of the beach population. The beach . d ~) population ts, in effect, also protected by the unusually strong containment system at the l Seabrook Station. As Indicated in the RAC position paper on the beach population iss'n; l l I Brookhaven National Laboratory (BNL) reviewed analyses pedormed by the Appilcant and performed additional analyses of the systems and features of Seabrook Station. BNL eencluded that (t)here is neg!!glble probability of prompt containment failure (at k Seabrook). Fallure during the first few hours after core malt is also unlikely and the I timing of overpressure failure (of contalnment)is very long compared to the RB8. Most i eore melt accidents would be effectively mit! gated by containment spray operation. ) BNL revlews of containment bypus accident scenarios also Indicated that s!gnificant releasas from such accidents were also not ilkely In the first hours after a severo O accident. f
=
th -07 ' 87 14: 41 ID:fAGCNE tMTL LM TEL NJ: 312-972-7019 88177 P06 (Hampt:n V111) Draft 5/8/87 .
'"*"^ .O "'""'""*'"'""'""'""'"'""'**'"
plans for beach closure and access control u early as the Alert clusification, the cited
~~7 "neg!!glble probab!!!ty of prompt containment failure" at Beabrook and low I
,.. (
consequence / low probability of serious contalnment bypass segaences, the plume travel time to the beach areas and the relatively short (2 to 4 hours) time estimated to clear
. the beaches, it appears that risks to the beach population are a small fraction of the alted alshs la Hill 1TP A108 fna thin dintnnan Thlin nirnn if thnen unM a nmmnt sairane i11lll11I51111)1111111 III I filllII il lli Illii 91811111111 Idall lill0II II AlImdll thi plume fos tteo houac dua!ng tho otmountion omness, thats arposura in dannelteri radioactivity would only be apprvalmMelf 2/24 or less than one-tenth of the code manumaa cose. In 400111on Inty woulo pt nV91Qtog ply pgoitiona> exposure to tne plume (s) af ter leav!ng this area.
FEMA Response (Further Basts) O FEMA has addressed the Town of Hampton Revised Contention Vill and its further basis of inadequat'e protective mettons fo'r residenta of-thei8ea' coast Be'alth ' 1 Center by appIyt'ng PlannTrig 8tandards' H snd J (Evsluation Cetteita H.4', H.11,'J.10.d,-' " ' J.10,g, J.10.m) In FEMA-REP-1. The December 15,1988 RAC review of the State and mur.lcipal ple.ns reflects FEMA's views on this luue. Speelfically, FEMA's review comments on the New Hampsh!re State plan on this issue are provided on pages 67,74, and 88 of Beotion 1. FEMA's review comments on the munic!ps! plans on this lasue are provided on page 19 of l Beotion D. FEMA's review comments on the State Compensatory Pim on this lasue are l prov!ded on pages 8 and 8 of Section IV (Compensatory Plan subsection). FEMA relled on the following documents in forming its conclusions on this l 1ssue Revision 1 to the Hampton plans Revision i to the New Hampshire State plant and i O the Appilcant's Motion for Summary Disposition of the Town of Hampton Revise <! Contention Vill dated March 25,1987.
r%Y-07 '87 14:42 ID ARG0tfE FATL LAB TEL FC:312-W2-7919 N177 P07
, , Giampton Vill) Draft 5/6/87 1 O oa the e=i or th are revie or aevi ioa = or ide set. =ad muaieies! elen ,
FEMA hu not yet rece!ved sufficient Information to have assurance that the residents of I the Seacoast Health Center will be properly evacuated in a timely manner in the event of a radiological emergency if Hampton does not implement the emergency response plan.
~
Since Hampton has Indicated that it will not participate in the planning and response to l an accident at the Seabrook Station, it la necessary to deteredne the State's ability to . implement compensatory measures for the Town of Hampton and to, therefore, provide for evacuation for the residents cf the Beacoast Health Center. The Harnptor. plan (page 11-30) Ir.dicates that in the event of the evacuation of rpecial facilities (such as the Beacoast Health Center), the Hampton Public Works Directer will coordinate transportation services. However,if the Town of Hampton does not participate In the implementation of its response plan, the State will assume responsibility for coordinating the provlston of transportation resources for the O evacuation of the residents of the Beacoast Health Center. 'he concept of operations for the State's compensatory measures.ls provided in. Append!x 0 of the State Plan. As;_.. ..... -- .. Indicated in this appendix and in the NHCDA Procedures (Vohrne 6,0f State Plan),.lf a 9 . . -i municipality is unable to respond to the en.ergency, an IFO I.ocal Llatoon will be us!gned to coordinate the provision of transportation resourcee for evacuation. Although the RAC had no comments on ,the adequacy of this plan concept per ##, 'the RAC has questioned the adequacy of the numbers of Local Llatson params to be assigned and the adequacy of available communications resources available to implement this aspect of the compensatory plan. Nese items (NUREG' elements H.4 and E.11, pages 6 and 8 of Section IV RAC comments on Compensatory Plan) were left open by the RAC pending provision of additional supporting information by the State. 'nds information has not yet been provided to FEMA. Q Relative to the speelal facilities plans themselves (i.e., those included as Appendix F of the municipal plans),Cm. n!dp FEMA eonoludes that the health x l
- n. ~1~,.n..,.-_.~.__n,,--- .- - . - , - - . - _ - - -
MAY-07 '87 14:43 ID CRGCNE FATL LAB TEL N3:312-972-7819 #177 P08
- (Hampton VIII) Draft 5/8/87 O are facility special plans, including that for the Seacoast Health Center, have been adequately revised and now contain adequately dstalled procedures for evacuation and relocation of patients (RAC review, Section 1, page 67). Although there are still numerous inconsistencies In the plan in bus needs estimates, all estimates Indicate that overall the number cf buses provided for in the letters of agreement are adequate and that additional transportation resources available from other organlaattons provide a large redundancy of resources (RAC revlew, Section 1, page 74).
The bus boarding time of 10 minutes for residents of special faellities la provided in the State Plan Evaountion Time Estimate study, page 11-11. The RAC had no comment on this revised estimated bus boarding time. In regard to sheltering residents of the Seacoast Health Center, the State indleates that shelter!ng is the preferred protective action. FEMA concludes that the plans have been adequately revised to take into account the sheltering protection factors O for speelal facilltles, including the Seacoast Health Center. A special tabulation of
~
speelfle protection factors foVeach of the fadlities, Inclueng the Beacoast"Health " '- t Cer.ter, is present in Table 't.6-3 of the State plan (RAC review; Bectiod I, page 67). The"" t " RAC review (Section I, page 88) Indicates that the flow dlagram in the State plan (fig. 2.6-7) now properly reflects the decision-mak!ng process for the election between sheltering and evacuation, and that the treatment of institullonallred persons !s now adequately detalled. O
~
MY-07 ' 87 14 : 44 ID: ARGCt4E t4TL LAB TEL to:312-972-7819 0177 P09
- brof/ 5447 O .
.1,o CourExtion 1.
FEMA Response 1 PEMA has addressed SAPL Contention 18 and its basis that plans do not make
~ '
adequate provisions for the sheltering of various segments of the populace in the EPZ by
~
applying Planning Standard J (Evaluation Criterla J.9, J.10.a. J.10.d, J.10.m) In PEMA- . REP-1. The December 15, 1988 RAC review of the State and local pisns, the amended portions of the RAC review dated . and the RAC position paper on the beach
,p opulation issue transmitted to the State of New :tarapshire dated reflect PEMA's I
vlaws on th!s !ssue. Spac!fically, FEMA's revlew comments on the New Hampshire State plan on this issue are prov!ded on pages 64, 67, 87, 88, 89 and 91 of Section I. FEMA's , review comments on the municipal plans on th!s issue are provided on page 17 of Section II. : PEMA relled on 5he 'eJowing documents in forrning' lts concluslins os tSe
~
Issue Revision 2 fo the New Hampshire Blate and local plans; and the~ Applicant's Motl66T for Summary Disposition of SAPL Contention 18 dated March 25,1987. l PEMA does not yet have all Information to be provided by the state. As indicated in the December 15,1988 RAC review (page 64, Seetton 0, determinatlon of the adequacy of protective responses for the beach population rema!ned open pending final review 'by the RAC of planned protective 'c.euures, and pend!n;; recelpt of information from the state op the number of transients who would need transportation I during an evacuation. The RAC has recently concluded tsee RAC position paper dated -) that the beach population can be appropelately irotected by implementing provlstons of the current (Rev. 2) New Hampshire emergesey plans and that there O anan to de no imieue erobiem rotative to th desex Popaiation that has not been adequately addressed. The % for the RAC's conclusion on the beach population tasue Je
my-07 'e7 14:44 10:catmE MTL LAB TEL to 312-W2-7819 n1W P10 l ' b e fr" F W 7 I
, ($dP4 /6f l l
are provided in the position paper trhns:nitted from PEMA to the State of New Hampshire on May ,1987. Detalls on how this posltlon paper was developed, and a j discussion on the key constderations used by the RAC in arriving at its conchtston are provided in the FEMA respofnse to Revised Town of Hamfpton Contention VUI.4
~
Although the RAC has reached a conclusion on the beach population lesue, the RAC still awatts rece!pt of information from the State of New Hamtshire on the nurnber of transients who would need transportation during an evacuation. Although the number of I l tn.nstants without transportation is expected to be small, this information has not yet l 1 been provided to FEMA. This also appl!as to NUREO element J.10.m as Indicated by the RAC review comments on page 87 of RAC revlew Section 1. State Plan Section 2.6.5 Indicates that New Hampshire relles on two protective actions for limit!ng the direct exposure of the general public within the Plume Exposure EPZ. These two protective actions are sheltering and evacuation (8 tate plan, page 2.6-O 4). The deetsien wn ther to sheiter or evaeuate is based on a.veral variables, faciudine I dose reduction factors due to shelterTng'(State Plani page 2.6-49).' Sheltering een apply- - to the permanent resident population,~lnatitutioniilized personinridtr'anslan'tr."* '"* '" %* State Plan Section 2.6.5 (page 2.6-6)lndicates that New Hampshire employs tho "Shelter-in-Place" concept lf sheltering la the chosen proteettve aetton. The plan . 1 Indicates that "those at home are to shelter at home; those at work or school are to be ! sheltered in the workplace or school building"(State Plan page 2.6-4). As Indicated in the RAC review comments (Section 1, page 64) on the State plan, the use of public shelters is not proposed during a Seabrook Station emergency. ne only exception is the possible use of public buildings for shelters for translents without transportation. Transients t11th transportation and "wlthout access to an Indoor location "includlng thoSe at beaches and at campgrounds, will be advised to evacuate la tholt own vehicles. The use of pubtle buildings for sheltering of translents without transportation is acceptable O since the translents without transportation are expected to be a very small number. The 2.
. - . _ . ._ . .- - _- -_- = = = -.
q t%Y-07 ' 87 14 : 43 IDI ARGCetE tMTL LAB TEL NJ:312-772-7819 ' 88177 P11 ($dPL*N) btrN J W 7
.Q plan (p. 2.8 6) states that 'Public buildtrgs may be set up and opened as shelters for translents, oc an ad foo bests'.
Because of the potentially large seasonal beach population, special precautionary protective actions for the beach population have been estabildied by the State of N3w l Hampehire (New Hampshire Plan, NHCDA Procedures, Append!x F), including early I precautionary evacuation. The use of public buildings for sheltering of translents without transportation may be implemented on an "ad hoc" basis (RAC review, Section I, page 84). As noted above, the use of public shelters !s not prgosed during a Seabrook f Station emergency. As noted in the State plan (/ age 2.1-13), precautionary protective g A action such as early closing and evacuation of the beaches will be considered during the period of heavlest beach use, from May 15 through September 15. The use of precautionary protective actions are not the sole means for protection of transtents such as visitors to beaches and campgrounds. They are, in effect, also protected by the unusually strong containment system at the Seabrook Station. This is descr! bed in detall in the RAC position paper on the beach population issue transmitted to the State on May .1987, and is also summarlzed in the FEMA response to Rey! sed Town of nampton contention vtu. anciuueu = = uneuu lva vi us, wallsil,1. y.ht,Illt, .7 v.... l conta!nment failure at Beobrook. In ensnid in r.hnitnsina nastrient nf snantal fenillilas Erh of hmnitah nlnint I,. w, ...J Joll.,, ll., Ot t. l..JI..t.. that skalasslag la the peef ssoed yesteettun nattan l l m m . n . ., y . ..w ,,, . o ...... - - . J., ,L L . ,, L... .L, L1, . . . L ..! L l take into account ina sneltering protection factors for spegla! revititt (RAC review, l 5.ullun I, p uv 87). A .y.vt.1 sc..Ittl6n af spalfle patsstlast fastsps f0F SQOh Of th0
. u i u a. v. . .. . . a. ..v.. ... . v. w a, - - .. . - . . .. ... .., ...... ., . . . . .
Q .. 1 1 1. . ,, Ill 1 Il I il i 11 8 31 I 11 nl l Tills (Yig. 3.6-7) now properly reflects the deelslon-making process for the election between ~ ' * ' - --
., N Y-0 '
14:46 ID:@3CNE MTL LAF TEL to: '3 2 91 7819 n,tgPg4 c l
- aheltering and evacuat!on, and that the treatment of Institutloaallzed is now adequately l
-O detailed.
i l The State Indicates that the tabulation of speelfle sheltering peotection factore referenced above (Table 2.6-3 of State Plan) is only for specla! faellltles such as health ! l
. care facilltles and Jalls for wh!ch independent determinations of appropriate protective ;
actions are made during an emergency (see State response on page $1 of RAC review Sect!on I). The State Indicates that "other types of special factitles sveh as schools and day care centers will follow the protective act!on recommendatlons prescribed for the general population." The State continues that the "protective action recommendation process uttlltes conservative sheltering protection factors for general population dec! sten-making." Section 2.6.5 of the State Pian now Includes a generic external sheltering factors table which shows the levels of protectlen that can be expected from var!ous building types in the EPZ (Table 2.6-4, page 2.610 of the State Plan). O - [ n g a e O l l k.
tm -m 6. uias in:,#a m e t u 6 . nashi;5-1 Mis alifia bre/Y S4 F? ]
. AMENDED NECNP CONTENTION RERP4 FEMA Response FEMA has addressed NECNP Cor.tention RERP-8, and its basis that there is no
. reasonable assurance that sheltering is an adequate protective inessure for all members of the public who may need it, by applying Planning Standard J (Evaluation Celteria J.9, J.10.a. J.10.d, J.10.m) in FEMA-REP-1.
The December 15,1986 RAC review of the State plan, the amended portions of the RAC review d.ted , and the RAC position paper en the beach population issue transmitted to the State of New Hampshire with FEMA letter dated _ ,re-Ovyl UW A'-
- I-". - U.!J !saut. Og s siftsally, PWife saillem sarnninnta on thn Unin n I- ni li 11: is nli lislii sii niinlied si simia li li li 11 Il onli11 af Section 1.
O ros reiieo on ine rouowiag oocum.ni. m m,mm, m. ..me....... . m. Issuer Revision 2 to the New Hampshire. State plani .and.ibe Appl! cant's Motion; for.,,_ , him assil niissillisa af MrblUfoninntinn f f fist tiltid Wir!1117,11187... . .._.j . a .a . .-
, c.m4 uu.. uv 6 y 6 n.v. .u uu vi m uvii w v. r v.lJ.d I,, .l .L.L., L .tli 1,.
noted later in this resonnu, th!A mining Intnrmatinn cons!sts of the number of tranaltnts ! who would nood tuntportetInn during en avenustion State Plan section 2.6.5 Indicates that New Hampshire relles on two protective actions for limiting the direct exposure of the general public within the Plume Exposure EPZ. These two protective actions are sheltering and evacuation (8 tate Plan, page 2.5-4). The deelston whether to shelter or evacuate la based on several varlables, including dose reduction factors due to sheltering (State Plan, page 2.6-29). Sheltering enn apply to the permanent res! dent population, institutionallred persons, and translents. O stat. et a etion i.e s (>=re 2 i s) taote t that s. n==9.nir. m9iori in. Shelter-in-Place" concept if sheltering le the chosen protective action. The plan b _ _. .
MY-07 ' 87 14: 47 ID:(6 TONE teTL LAB TEL to:312-972-7819 4 l N*g77 *
.i
~
,. , (N6CN!-858 P't
( Indicates that "those at home are to shelter at homer those at work or school are to be sheltered in the workplace or school building" (State Plan page 2.6 8). As Indicated in the RAC review comments (Section I, page 64) on the State plan, the use of public shelters !s not proposed during a Beabrook Station emergency. The only exception la the
- poss!ble use of public butidings for shelters for translents without transportation.
Translents with transportation and "without access to an Indoor location" will be advised to evacuate in their own vehicles. The use of public buildings for sheltering of transients i l without transportation is acceptable since the transients without transportation are j expected to be a very staall number. The plan (p. 2.6-6) states that "Public buildings may be set up and opened as shelters for translents, on an ad hoc basts". As Indicated in the December 15, 1986 RAC review (page 64, Section I), ; determination of the adequacy of protective responses for the beach population remained open pending final review by the RAC cf planned protective measures, and pending O receipt or iatormation from the state on the number of tra sieats ho wouid aeed transportation during an evacuation. The RAC has recently concluded that the beach - - - population can be appropriately protected by implementing provis!ona.of the current.
., a - ,
(Rev. 2) New Hampshire emergency plans and that there appears to be no unique problem relative to the beach population that has not been adequately addre: sed. The bases for the RAC4 conclusion on the beach population tasue are provided in the peltlor. peper I transmitted from FEMA to the State of New Hampshire on May _,1987. Deta!!s on how this poeltlon paper wu developed, and a dlscussion on the key consideratlons used by ths RAC in arriv!ng at its conclusion are provided in the FEMA response to Revised Town ) of Hampton Contention V111. Although the RAC has reached a conclus!on on the beach population tasuh Q b[e RAC still awalta recelpt ofinformatlon from the State of New Itampehlte on the number of translants who would need transportation during an evacuation. Although O the number of translents without transportatlon is expected to be small, this Information
- 2. s
my-07 ' e7 14 : 4e ID: argot E mTL LAB TEL to: 312-972-7853 177 1 ,.,,- , [pf Mt/* G) ,
!* M7 O has net yet been provided to FEMA. This also applies to NtmEG element J.10.m as indicated by the RAC revlaw comments on page 87 of RAC rev!ew Sect!on !.
Because of the potentially large settsonal beach population, special precautionary protective sections for the beach populst!cn have been established by the State of New Hampshire (New Hampshire Plan, NHCDA Procedures, Appendin F), including early precautionary evacuation. The use of public buildings for sheltering of trar.31ents without transportation may be implemented on an "ad hoc" basle (RAC review, Section I, page 64). As noted above, the use of public shelters is not proposed dur!ng a Beabrook Station emergency. As noted in the State plan (page 2.1-13), precautionary protective actions such as estly closing and evacuation of the beaches willbe cons!dered during the period of heavlest beach use, from May 16 through September 15. The use of precautionary protective actions are not the sole means for protection of transients such as vishots to beaches and campgrounds. They are, in effect, also protected by the ' unusually strong containment system at the Seabrook Station. 'Ihls is described in detall in the RAC poaltion paper on the beach population lasue transmitted to the State on May ,1987, and is also summarized in the FEMA response to Revised Town of Hampton Contention Ylli. Included is a disassion of the negilglble probability of prompt containment fa!!ure at Seabrook. In regard to sheltering residents of special facilities, the State Indloates that sheltering ts the preferred protective action (8 tate Plan page 3.6 7). FEMA concludes that the plans have been adequately revised to take into account the sheltering protection factors for special facilitles (RAC review, Section I, page 87). A spoola] tabulation of speelfic protection factoes for each of the facilities is pruent in Table 2.6-3 of the State plan (RAC review, Beetton I, page 67). The RAC review (section I, page 98) Indicates that the flow dlagram la the State plan (Fig. 2.6-7) now properly reflects tw doulelun maktug process fur t1= w!evtloa tatween 6heltering and 3 _ . - _ - -
- NW EW7
[ f tC M P - A B A Pet) evacuation, and that the treatment of Institutionallzed pemons !s now adequately
-O detaned. .
The State indleates that the tabulation of specifle shettering protection factors referenced above (Table 2.6-3 of State Plan) is only for special fac!!!tles such as health care faellities and Jalls for whleh Independent determinations of appropelate protective actions are made during an emergency (see State response en page 91 of RAC review Section D. The State Indicates that "other types of speelal facDities such as schools and day care centers will follow the protective action recommendations preser! bed for the general population." The State continurs that the "protective action recommendation process utilizes conservative sheltering protection factore for general population deelslon-making." Section 2.6.5 of the State Plan now Includes a generle external sheltering factors table whleh shows the levels of protection that can be expected from various building types In the EPZ (Table 2.6-4, page 2.6-10 of the State Plan). 1 l O
/ dg,o *
- 8 ',
c g'*, - UNITED STATES 4 [ v. g NUCLEAR REGULATORY COMMISSION S
*~ l AEGION I 631 PARK AvtNut
%, e . . . . ,o*e KING of PRusstA, PENNSYLVANIA tuos ((d4 <t/Akp O
~0 .
JUN04 ggy Edward A. Thomas, Chairman Regional Assistance Comittee . Federal Emergency Managecent Agency John W. McComack Post Office and Court House Boston, Massachusetts 02102
Dear Mr. Thomas:
Reference:
RAC Cornents on Transient Beach population for Seabrook Station Subsequent to our April 15, 1987 reeting of the Regional Assistance Committee on the above subject, the Atomic Safety and Licensing Board issued its MEMORANDUM AND ORDER on April 22, 1987 relative to the Public Service Company of New Hampshire petition for a one-mile plume emergency planning zone. In that docutent, the Board concluded that the current studies provided by the applicant did not provide a prima facie showing to warrant the granting of the cne-mile plure Ep2 petition. The Board deliberately left open the possibility of granting the petition if convincing information'is subsequently provided. Even though the beach population issues differ substantially from the above litigation, because of it and because the NRC staff has not yet completed its review of all issues in the Seabrook and "BNL' studies, I recorrend that the RAC not reference these studies or specific contents in our present consid-q eratien of the beach population issues. With that in mind I am proposing v reviste sections for the RAC report. These proposed revisions involve pages seven through ten. For your convenience, a clean, rewritten copy of the RAC position paper incorporating these revisions is enclosed. Should you have any questions concerning the above, please contact re at FTS 485-1213. response, ! would be very happy to reet with you and/or the RAC to discuss my i Robert J. Bores A Technical Assistant Civision of Radiation Safety I and Safeguards
Enclosures:
As stated bec w/ enc 1: W. Russell J. Allan J. Gutierrez W. Kane pd W. Johnston I T. Martin R. Bel, lamy R. Bores ) I
1 ! l 4
-O PRotECrion or NEl< anPswiaE EACs PoPutetrons SACXGROUND The requirtrents for emergency preparedness stem free 10 CFR 50.47(a (2), which state that escept as provided in 10 CFR 50.47(d) (rtlative to 3 licensing of a facility for operation up to 55 of rated pcwer), no oper!!
license for a nuclear power reactor will be issued unless a finding the NRC that 'thert is reasonable assurance that adequate protec base its finding on a review of the FEM The findings NRC will and di i whether state and local emergency plans are adequate and whether there is reasonable assurance that they can be implerented, and on the NRC asses the adequacy and implecentability of the Itcensee's onsitt ecergency plans The FEMplans. etergency finding is prirarily based on the review of the state and local . in considering implacented. Paragraphwhether b there is reasonable assurance that of 10 CFR 50.47 requires that the onsite and offsitestandards. planning erergency respons(e) plans for nuclear pcver react Erergency Response Plans and Prep & redness in was issued to provide a cornon reference and guidance source for state and local goverreents and licensees in the developrent of erergency response plans and preparedness for response to a radiological ecergency for preparedness. and FEMA, NRC and other federal agencies for use in the review of thos nuclear pcmer plants was taken from NUREG 039 Basis for the Developeent of State and Local Geverncent Radiolog Response Plans in Support of Light Water Nuclear Pcwer Plants'. objective of the eeergency response plans is to provide 'The overall desc savings (an scoe cases, irrediate life savings) for a spectrw of accidents that could produce offsite doses in eness of the PAGs" (huREG 0654). NUREG 0396 intended it attempted to identify the boundarthat the planning basis range frce t i of potential accident consequences, y parareters based on available knowledge teristics (source tenn). ti:ning of releases, and release charac-PAGs do not equate with loss of itfe or even a health hazard.It shou The PAGs were intended ~fiir use by protective action decision rakers in arriving at a b between radiation constraints to that action. risk and that of taking a protective action in the abse de
% d */ kW r adu O t 4 , u / 2 " 7,.? gg Eaciosure
l
.o .
LNITED STATES CF AMERICA NUCLEAR REGULA'IORt COMMISSICH BEFORE 'n!E A'ICMIC SAFETI AND LICDISDIG BOARD
)
In the Matter of )
)
Public Service Co. of New Ha.pshire,
) Docket No. 50-443-OL et al. ) 50-444-OL
) Offsite Emergency (Seabrook Station, Units 1 & 2) ) Planning Issues
)
FD% PRE-FILED TESTIM 2TI
'Ihe Federal Emergency Management Agency (FEMA) hereby serves on the parties to this proceeding its prefiled testinony on contentions oa the New Ha pshire Radiological Emerger.:y Response Plan. FEMA notes, for the ;
record, that its review of issues addressed therein is ongoing.
'A l q.*
1- l1. a .e t4 Q'd.. - H. Joseph f'lynn Assistant' General Counsel
, Federal Emergency Mrtnagenent Agency Washington, D.C.
Septerter 11, 1987 1
- l i
O 1 1
- . . . j
Ut1ITED STATES T AMERICA NUCLEAR REGULATORt COMMISSICN BEOPE WE ATOMIC SAFETt AND LICD1 SING BOARD
)
In the Matter of ) .
)
Public Service Co. of New Ha- pshire, ) Docket No. 50-443-OL et al. ) 50-444-OL
) Offsite Dnergency (Seabtcok Station, Units 1 t, 2) ) Planning Issues
)
DIRECT TESTIMJttl T EIkARD A. THOMAS, EDWARD A. TN12 PAN, AND BPUCE J. SWIRD4 01 THE NEW HAMP91 IRE RADIOt4GICAL EMEPGDiCY RESPONSE PIAN PRESDiTED 01 BDiAIF T THE FEDERAL DEPGDJCY MANAGDtDir AGDCl The witnesses whczn the Federal Emergency Management Agency (FEMA) is sponsor'.ng on the a&nitted contentir ] having to do with the New Ha.pshirt Radiolcgical Emergency Response Plan (NHRERP) in the Event of an Accident. O at Seaeroox Station are E&ard A. Thcst u, Chief Natural and 74culogical Hazards Division Federal Emergency Manage.ent ~ Agency Region I Boston, Massachusetts Edward A. Tanznan Energy ard Enviturental Pttgrams Attorney Enetr and Environmental Syste:rs Division Argonne National Laboratory Argonne, Illinois and Bruce J. Swittn Dnergency Management Specialist Natural and Technological llazards Division Federal Emergency Management Agency Region I Boston, Massachusetts O .
,-. , - - - . - - - --, ,, - ,,--w wrr g 4
--. - w -r.
_2- 7
-I Our Statements of Professional Qualifications are attached to this Direct A Testigony and are incetTorated herein by reference.
*V '
/ In general, the putrose of our testinony is to address the admitted contentions and supporting bases. t.s explained belcw, our testinony is limited to certain contentions and bases. As noted in'the Statement. of
~
rosition, the Nuclear Regulatory Ccmission (NRC) is s@nsoring the testinony of Dr. Theras Urbanik on certain contentions having to do with the validity of Ew cuation Tine Estinates, and so FD% is not sponsoring testinony on those contentions, namely: Revised Hanpton Contention III to Revision 2 Revised Hanpton Contention VI to Revision 2, Basis A (Rev.1) SAPL Contention 18 SAPL Revised Contention 31 SAPL Contention 34 SAPL Contention 37 . FD% considers its statenent about the transient beach population latsely to involve nutters of policy. Edward A. Thcras is the FD% official in Region I who is responsible for explaining, applyirg, and carrying out FD%'s policies as they apply to the Radiological Energency Preparedness Program. For this reason, Mr. Thcras is the single witness as to those contentions having to do with the lack of shelter for the transient teach pcpulation, na.ely:- , Revised Ha.~pton Contentien VIII to Revision 2 SAPL Contention 16 NECG Contention RFRP-8 Durirg the pericd of tine when Bruce Swiren was crployed by HMM Associates, he worked on obtaining revised or ttnewed Letters of Agreement O
@ e ma. .
l L I .' ! [ fra hospitals, ambulance corrpanies, towing cmpanies, and bus ccmpanies. In f e i order to avoid even the possibility of the appearance of a mnflict of interests, ; Mr. Swiren has ra mved himself as a witness on m ntentions and bases having to do with these letters of agreement and the determination of the nunber of ; . r j Teamsters to be made available by their employers in the event of an , j ! j energency. For this reason, Edward A. Scmas and Edward A. Tanzman will . l testify on those contentions and bases, namely ( 1 i
- Revised Hanpton Contention IV J South Hangton Contantion 3; Bases 1, A, B, C, E, and 1 Further rases A.1. , A.2. , and B ,
! Town of Kensington Contention 6 ;
] NECNP Contention NHLP-2, Basis D ,
1 NUMP Contention NHLP-6, Bases d and e and HP-1-e '
- SAPL Contention 15 j SAPL Contention 25 I
, All three of us will address the remaining admitted contentions and l
l Q bases. j ? ne attached document entitled "Current FDR Position on Admitted Con- .
- tentions on New Hanpshire Plans for Seabrook" (herwinafter referred to 1
as the "Statement of Pesition"), dated June 4,1987, has previously r i been made a part of the record of this case. Wat Statement of Position ] was attached as Appendix A to the Response of the Federal Emergency Management Agency to Massachusetts Attomey General James M. Shannon's off-Site Dnergency Preparedness Intertogatories and Request for Prcduction i of Docunents to FD% (Set No. 2) and is bettin identified as Exhibit A. I j 2 e larguage of the contentions and their bases is set forth in that ' j Statement of Positi m and so is not typeated herein. j Exhibit 8 to this testimony, entitled "Currtnt FDR Position on South l Hanpton Contention 8 and NIENP Contention NHLP-4", and dated June 26, 1987, O . is a sur,1emeat to rDR's State-ent of nosition and is aise a ears of I the record of this case.
---,%+--+- .,,,qm-- --e,- . , - - - - . - . ,
,,__.,,_,-m..em _, ,..g4g,-. -,--,,,m .p,,m.,,,,., ,.9-7,ww e&gm91--g gg 9 *e-p-wgym,e-,,,m.iiw9--
-4 l
!Ol l
'd Exhibit C is a.ccpy of a letter dated August 7,1987 frca H. Joseph Flynn r to Thcras G. Dignan, Jr. It reflects FDA's position on the issues discussed
/ )
therein. We individually incorporate by reference those portions of Exhibit A, I
\.
B, aM C which are pettinent to our respective testinony. We positions which FDiA has taken on the IMFIRP, the exercise of the imRERP, and the contentions which this Atcmic Safety and Licensing Board has a nitted were arrived at thro.lgh a collegial process of review by FWA's Regional Office in Bcoton, consultation with FWA's Regional Assistance
. V Ccrmittee RAC) and Aztjonne National Laboratory, aM review by FWA's
_. State and Iccal Prcgrams and Support Directorate in Washington, D.C. We RAC is an interagency ecnmittee constituted in each of the 10 stardard Federal regions pursuant to 44 C.F.R. @351. W e ccnnittee is ccuposed of representatives of FWA, the NBC, the Envitonmental Protection Agency, v the Departrent of Energy, the Departrent of Health and Hunan Services, the Departrent of Transportation, the Departrent of Agriculture, the Departrent of Cccrerce and the Departrent of Interior. FWA and the RAC have prcvided ccments on New Harpshire draf t planning , 1 for Seabruck dating back to sutnissions in 1982. However, the cutrent plan, which is under litigation, dates back to 1985. In December,1985, the State of New Ha.pshire sutnitted the !MRIRP (Revision 0) to FD4A. New Ha.pshire sutnitted extensive charges to the NHPIRP (Revision 0, Supple.-ent 1) in February,1996, , which included:
- 1. Volume 5 tmRERP, "Letters of Agrement in Support of the IMRERP";
- 2. Volune 7 iMRERP, "Seabrook Station Alert and Notification System Design Report"t
- 3. Evacuation Tine Estimate (ETE) Study nuterials (Pttgress
('") Reports Nos.1-6) frun KLD Associates;
4 I j
. i , 1
- 4. Revised procedures for the New Ha@ shire Departrent of 1 Resources' and Econmic Developcent;
- 5. Ccqpensatory Plan cutlining the treans used by the State to protect citizens in towns within the Seabrook EP2 when nunicipal govenments cannot or will not carry out tasks assigned by the local plan, ard;
~
- 6. Draf t public inforTration traterial.
The February,1986, revisions were served on the parties m March 11, 1986. Iho State of New Hamshire filed additional plan changes in April,1986, (Pevision 0, Supplement 2 cf t% NHRERP) consisting of the followirg:
- 1. KLD Prcgress Report u ~;
s
- 2. A revision to the Department of Public Health ard Safety (DRIS)
Procedures, includirs replacement and new appendices to the DRIS Procedures;
- 3. Rockingham County Cmplex procedures, includ! o one for the Rockingham County Nursirg Home, Pockingham CoM e ' all Facility ard Rockirgham Ccunty Dispatch Center; ard
- 4. Procedures for the decontamination of personnel at the Manchester Decontamination Center, along with Apperdix F to those procedures.
A full-scale exercise of the IMRERP was conducted on February 26, 1986. Durirg the first several tronths of 1986, FWA aid the PAC were involved in extensive reviews of the Decerber IMRERP (Revision 0), the February revisions (Supplements 1 ard 2 to Revision 0), an$ the February exercise. In April, 1986, FWA sent the rolicving doc.:ments to the State of New Hamshitt:
- 1. FWA's tiport of the deficiencies observed during the Febru-aty 26,1986, exercise of the state ard local plans to protect the public in the event of a radiolcgical emergency at Seabrook;
- 2. Final Draf t Report of the Exercise of the emergency plans for Seabrook held February 26, 1986;
- 3. Final review by the PAC of the state ard local plans subnitted by New Ha pshire in Decerrber,1985; ard
- 4. Draf t FAC Review of the state ard local plans subnitted by New Ha@ shire in February,1986.
'Ihese docunents have been served on the parties to this proceedirg.
w -
%eues==. .me--me,=== o-..=e=e-+ -o -. .= *.+ -
.p l .- O Oa June 2,1986, the Seete etted enother revieion of the NHRERe (Re-vision 1) responding to the canments of the PAC conceming the plan and the exercise of the plan. The ETE Study prepared by KLD Associates, which hsd recently been released in a final draft, was incorporated into the NHRERP at that time.
On June 23 and 24,1986, the RAC met with representatives of the State of New Ha@ shire and the Applicant and explained in further detail the concerns identified in the documents described above. On September 8,1986, the State of New Ha@ shire sutmitted another revision of the NHRERP (Revision 2, dated Aucust,1986) addressing the concerns identified by the RAC. FD% submitted the FEMA /RAC Review of Revision 2 of the state and local plans to the State of New Ha@ shire on December 12, 1986. 'Ihis document is the basis for trost of the positions taken by FDR in this licensing proceeding and has also been served on all the parties. On April 15 and July 2,1987, the NHC filed FDR's positions on the parties' various Motions for Sunmary Disposition of Contentions. On June 4,1987, FDR filed its Statement of Position as part of a response to Interrogatories frcm the parties. 'Ihis reflects FD%'s current position, even though the State of New Hampshire submitted a Sunmary of Personnel Resource Assessment for the New Ha@ shire Radiological Emergency Response Plan in late August,1987, ard additional information in early September.
'Ihe review period for material which a state submits to FDR as part of a radiological emergency response plan is normally at least 60 days.
Rese materials are not reflected in this testimony principally because they were not received early enough to have been reviewed by FDR and f-s the RAC and because the State of New Ha@ shire has advised FD% that the U material submitted in Septenter is not part of the NHRERP. l l
, 38 (
NECNP CONTENTION RERP-8 n
.U The New Hampshire RERP does not provide a "reasonable assurance that adequate protective measures can and will be taken in the event of a 50.47(a)(1), in that radiological emergency." as required by 10 C.F.R.
the plan does not provide reasonable assurance that sheltering is an
. "adequate protective measure" for Seabrook. Nor does the plan provide adequate criteria for the choice between protective measures as required
- j. by i 50.47(b)(10) and NUREG-0654. I II.J.10.m.
b 8
" FEMA PESECNSE to Revised Tcwn of Harpton Contention VIII to Revision 2 (of E the New Hamcshire RERP for Seabrook) , SAPL Contention 16, and NECNP Contention
- r. FIRP-8 ,
p. f e . These three contentions all deal with what is fundamentally the same
- issue: protection frcra a radiolcgical release for beachyoing population at Seabrook who do not have ready access to any effective form of sheltering.
Bis group includes both "day-trippers to the beach and those persons who only have access to unwinterized or other types of construction which will offer a lesser degree of protection than that offered by standard residential or ccriraercial buildings. Backaround - This issue has been of great concern to FEMA frcm our D. earliest detailed involvement with the preparation of plans and the achieve-b ment of a level of emergency preparedness which would achieve our regulatory standard set for that 44 CFR 350.5 of adequately protectirg the public health and safety by providing reasonable assurance that appropriate protective measures can be taken offsite in the event of a radiological emergency at the Seabrcok Nuclear Power Plant. - In December 1985 the State of thw Hampshire sutnitted plans for protecting the public in the event of an accident at Seabrook to FDiA for review pur-suant to 44 CFR 350. Rose plans were forwarded for review by the Regional Assistance Ccmittee (RAC), an interagency group established pursuant to 44 CFR 350 to both assist state and local government in the develognent of radiological emergency response plans and to evaluate the adequacy of such plans. On December 31, 1985, FEMA, as chair of the RAC, requested that the members of the RAC (as well as the other FEMA staff who were reviewing the New Hampshire Plans) immediately focus on the issue of the protecticn of beach population and the occupants of unwinterized acecrudations. Ris mecerandum is attached as Appendix C to this response to interregatories. Em A Position - Sinco the time of our Decader 31, 1985, memorandum on the subject of the protection of the public on and near the beaches around Seabrcok, the State of tbw Hampshire has refined and improved its ernergency plans and submitted a detailed Evacuation Time Estimate which sheds a considerable amount of light or, this issue. n e facts relevant to understanding this issue are thatt pJ l l
. . ,.} W wV
- .' y 5Y p 3 9. '
, ,~ MECIP CCtTMPICU .' ERD-8 (Cont.), ,
y .s__ { r \ v"- t (1) he primary guidance document used by FEMA and the PAC in reviewi'ng
^
2
%) off-s ite emergency plans is NUREG-0654, FEMA REP-1, Fev.1, a doctnent. jointly developed by FEMA and the NRC. W at guidance
, y,
, /[. - document indicates on p.13 that "(t)he range of times between F ,' 2 '. g
(?, r j i'j gl
/ f the onset of accident conditions and the start of a major release j ,g 3.' ., is of the order of one-half hour to several hours". nis_statementf r'. j 4 is further clarified on p.17, Table 2 to indicate that (a) the "
'(/ "
3' major portion of a release may occur in a time period ranging - r#; ,' y' dp/ ., 4 from as little as one-half hour to one day after the release begins and (b) that the travel time of the release to exposure :W A A , c' point can range frcm one-half hour to two hours at five miles, g;; p i[g.YF , h. a and one hour to four hours at ten miles. , , ,
- C, /_ 5 N,.,-t p..- Am C r o M
- / '(2) Cn peak strmer days there are thousands of beachgoers in the f_b, g]l~
j
- j. Seabrook EPZ in areas beginning approximately 1.7 miles frca
'j]g[.r ' q')
-. ,y r). F , the plant. me current New Hampshire plans contemplate evacuating l l
2
# ,j C#, P f,. thQman 4.housands of beachgoers who have access to no adequate shelter as a protective action in the event of an accident at Seabrook.
? #g '/ We understand that the plans contain no consideration of sheltering
M /' ~
the "dayoftrippers" number because these people, it is on notsunmer possibledays to find when there are a largeW/P, ,0' reasonably accessible shelter for them. Were are an additional number of persons who would be in or have access only to shelter in unwinter-ized cottages and notel rocms. We protection afforded by 1 sheltering in these structures will definitely be less than that #7 afforded by a normal weed . frame house. .- Q (3) The Evacuation Time Estimate for the Seabrook EPZ subnitted by the State of New Hampshire indicates at pp.10-1 et. set. that in good ,g,,A p weather when the beaches are at 60 to 100 percent of capacity it will take three and one-half hours to clear the beaches, and a MM sp ' , k total of frcm four hours and fif ty minutes five hours and ' fifty minutes to evacuate all the population on the beaches from the EP2. In scme situations such as sudden d weather follcuing a peak stamer day, the total evacuation time or portions of the EP2 range up to seven hours and fifty minutes. terefore, using the standard guidance for the initiation and dbration 1 ' of radiological releases, a6d the catfreI5t New Hampshire RERP including ETE, N it appears that thousands of people could be unable to leave during an # accident at Seabrook involving a major release of radioactivity without adequate shelter for as much as the entire duration of that release. ' nerefore, until these issues are resolved even if all the other inadequacies and deficiencies cited in the RAC Peviews of the New Hampshire Plans, and the Review of the Exercise of these plans were to be corrected, FEMA would not be able to conclude that the New Hampshire State and local plans to I l protect the public in the event of en accident at the Seabrook Nuclear I R:wer Plant are adequate to meet our regulatory standard that such plans i "adequately protect the public health and safety by providing reasonable assurance that appropriate protective measures can be taken offsite in the { event of a radiological emergency." (See, 44 CFR 350.5(b)). ! O l 1 l Ib .INbNbS.b I .
~~
-I
1 .. . 7,g e r ency management Agencyf (' ,# Regbn 1 J.W. McCormack Post Omu snd Coun House Boston, Manachutetts 02109 J 4 d'g'
/
O wr. Richard N. strom Director, New Hampshire Civil Defense Agency - Aw ) > State office Park South , concord, New Hampshiro 03301 h# g ,,
. Dear Mr. Strome h
/4 ) i This is written as a follow-up to our conversation on June 5, 1981, concerning the document "CORRENT TEMA POSITION ON ADMITTED CONTENTIONS ON NEW HAMPSHIRE PLANS FOR SEABRo0K." (Hereinafter called Current FEMA Position.) This document was developod as a part of FEMA's responses to interrogatories in the Seabrook Atomic safety and Licensing Board (ASLB) proceedings, our discussion primarily related to that portion of the Current FEMA position dealing with the beach population which is found at pp. 36-39 and enclosed with this letter.
Before further discussing that particular section, it mi worthwhile to quickly review the history of this filing.ghtThe be Current FEMA Position was developed as the result of several actions including the decision of the Atomic Safety and Licensing Appeal Board (ASLB) made May 1, 1987, and the subsequent Memorandum and Order issued by the ASLB on May 4,1987. These i O actions included a specific request that FEMA develop and file a position on the contentions admitted for litigation in the seabrook proceedings by June 5, 1987. is, therefore, The Current FEMA position Commission Memorandum of Understanding cited in 44 CFR 350 Section 350.3 (e) . However, the Current FEMA position should not be viewed as a formal "finding" by FEMA under 44 CFR 350. The current PEMA Position is largely based upon the FEMA and Regional Assistance Committee (RAC) reviews which were previously provided to you. with and thetheRAC.beach population is based on a thorough analysis by The issue of protecting the beach population has been an item of discussion between Fr.MA, the State of New Hampshire, and the applicant for several years. Our position is based to the on the guidance seabrook site. provided by NUREG-0654, FEMA = REP-1 applied We believe that our eencern about the protection of the beach population may revolves be unique around some rather unusual circumstances which to Seabrook. of the day. peak summer population in the area travel to the beach eachD Unlike other sites we have reviewed, these daily visitors are not identified with a temporary residence or public facility. l O l
r.
'a P.03 2- '
d
- In addition, many of the summer resid
.Q. unwinterized accident thanand thattherefore circumstances dramatically i found in afford insulated lessbuildienc sh l e ter ngs.in the event of an These specifically, the information evacuation and shelter. provided More otprimar evacuation from the beaches would requireo FEMA indicates t Evacuation standard. tin!e estimates are not requi red approximately 3.5 hours.,
~
fast-breaking scenarios is consider e dThe to meet some availability apecific of s some hard time objective for evacuation to mitigate the need foron in the mor the sheltering optien is also cloud e d. However for what is even in the more by favorable the absen,ea of shelteringin effective shelter for many othersseveral estimates amountsthousand appsrently to ind individuals that might beunded involvedon one evacuation another ir. a and mann but for a number of lesserI might add that these scenariosnumbers worst-case accident, appar may alter the case as weover discussions on the subject, e understand the past years which itA numbe a wide varietyInciaddition sources to our own have of the plant, and sheltering is an alternative alternative evacuationproposed ering, seasonal operation routes. Althcugh O public or private facilities,would ceptable. be acwe doubt if the use of e to the complexity of the issueThe a vari solution to the probl in the paragraphs numbered 1-3 ofHowever, ety of alterna tives due position will be subject pageto 39 of theandposition review current TEMAif are the fas FEMA will, therefore, be willing t re modified, then our modifications to the New Hampshire modification eme as necessary. which might impact evacuation tire o arrange for the review of any estiplans for Seabrook the beach population. rgency assumptions made about Anyaccident modifications rel of the standardmates or the she probability, as well,as the impact due t schedule for the plant come under o any altered the pur iease times, dur operational hearing for seabrook. FEMAswill soon v ew ofbe thedeveloping NRC. its te ti Given the expected sequence of evmony for the S evaluation of the New Hampshire the first licensingplanis ents, it this hea related all parties to our to the seabrook filing testimonyt (a) proceeding It would be very if y useful to i set forth in the current FEMAif the facts we have discussed a dou could Position asteps n ! t state these of New facts and (c Hampshire is considering re incorrect; (b) c if the whi h i i to exercise, options)that would if you are chan aware of intentions ofmight change ge the facts. anyone else O l
o- 74 ,,n *gg g e s so v s.o r, m r * == = - = \ W ld, of course, be happy to meet with you as New Hampshire
'O =e wou
=ntinu *a x9 =r. it eation - 2 none that 22 or == can 2
continue work togdther to resolve this issue and achieve our mutual commitment to public safety. sincerely,
' i. W Edward A. Thomas Chief Natural and Technological Nazards Division O
J l I O . l s 4 e- ., .
^
06/19/87 301 492 7285 1 06:41 l PC-EAST 4 JEST-W1 NO.002 004 - pg ~ "' 4 that adequate protectivThe New Hampshire RERP does not provi radiological the plan does emergency.e measures
" as required not provide by le Ccan and wiL1 he taken in the event of "adequate protective measure *r,asonable 40.4f f 4)(1), la that assura.F.R.
for Seabrook. nce that sheltering is na Nor dosa the plan provide by 5 $0.47(b)(14) and NUREG-0884.
, .. es, as required I !!.J.10 aadeq FD Wa
~
the%N4W RESPCNSt Henshire RCR) to Revised
~
for SaabreckJilAPLTcwn of CNanpton Con ontention 16. and NECNp Contention
~
issue s These three contentions all deal with what is f at Seabrook who do not have readyngaccess populatien to any effpro 21s group includes both ' day trippera to the ective fonn bea h ahave lesseraccess degree oftoprounwinterized or other ctypes of c of sheltering. onstruction which will offerand thos ccmsercial buildings. tection than that offered by standard reside sackertund = ; ear test estalTed involvement with the preparationWis issue has rorn our standard set for health and safety by providing reasonable that 44 CFR u 350.5 achieve our regulatory assura of adequately ecting the public protective measures can be taken offsite in the ence that appropriate - apergency at the Seabrook Ric1sar Power vent ofPlant. a radiological i the public in the event of aneaccident ouant to 44 CTR 350. at sin tecerter 1985 submitted plans for prot nose eabrook to FDM for reviw purecting I Assistance CFR radiolo 350 to both assist Cemnittee state and local (RAC), gwo plans we're forwaid g onal I I rment in the develogrent of plane. the morsera gical Ch Deosmber ersorgency of the 9AC31,1985, FDM resperwe plana such and to evaluatej ; the 19ew Haryshire Plans)(asas chair wellofas,the the RAC, requested other FD%that staff who were { (mediately , of beach poplation and the occujants of unwinte focus on the issue of threviewing e protecti 3 ' sonorarAss :.s attached as Agend;x C to this re i r zed Thacc.. 4ations. ion FEMA Pesition - spones to interrogatories,is ! onw the subject ogh pcutection of the public , marande on andSince the t ' around Seabrock, the State of near Miw Han; shire has refim . the beachea D ed Evacuation Time tatined and impmod its standing this inaue are thatconsiderable ancunt of light on this is mate which De facts relevant ,
# I V
.= __ _ - - - -
i JUN 19 '87 08:49 P01 -
,j., g g m e r w t.se FEL CTR 4 " ar.
l .... e cenen mi (cont.) li (1) The primary guidance doewant used by FD% and the MC in reviewing
.h off-site energency plans is NU10F0654, FD% REP-1, Rev.1, a l document jointly developed by FD% and the NRC, Bat guidance doctrent indicates on p.13 that *(t)he range of times between the onset of accident conditions and the start of a ma}oe relaaes is of the order of one-half hour to several hours". Rio statement l is f arther clarified on p.11, Table 3 to indicate that (a) the '
- major portion of a release may occur in a tisus period rarging frtrn as little as oneulf hour to one day after the release begins and (b) that the travel time of the release to entpecure point can range frei one*alf hout to two hours at five miles, and ene hour to four hours at ten miles.
(2) 01 peak sawner days there ars thmsards of beachgoers in the Seabrook EP2 in areas beginning approximately 17 miles from the plant, The current New Hagehare plans conter@ late evacuating the many thmsands of beachocers who have soooos to no adequate WM 2# shelter as a protective action in the event of an accident at saabrook. W/f Qthe "day trippers" because on sumer days when theraWe arv a largeurderstand that gg4 number of these people, it is not possible to find reasonably ME accessible shelter for them. %ere are an additional f%tnDer of persons who would be in or have access only to shelter in uratinter-ined cottages and notel roons. Se protection afforded by shelterirg in these structures will definitely be less than that . afforded by a notwil wood frame house. O . i kT (3) The D/acuation Time Estimate for the Seabrook EF2 sultnitted by the State of New Bripehire irdicates at pp.10-1 et.noa. th4t in good v weather when the beaches are at 60 to 100 will taAs three and ana.hau w* u -S percent as w of haa. capacity and a it M m J- ?I) total of fran four hours and fif ty minutes to five hours and ^
~~
fif ty minutes to evacuate all the population on the beaches frera the EPI. In see tithations such as sudden bed weather following a peak strener day, the total evacuation tians for portions of the EF1 range up to seven hours and fifty minutas.
%erefore, using the standard outdance for the initiation and duration of radiological releases, and the current New Hagshire RB2p including ETE, it a; pears that thmsands of people could be unable to hwe Amire an ~
I cecident at seabrtx* involving a major rolsace of radioactivity wig adequate sheltar for as much as the entire duratiers of that ru
- )
m ease. J 5 ETHtore unta these issues are resolved even if all the other i@ies and deficiencies cited in the MC Inviews of the New Hangshin Flans, and the Deview of the tuercios of these plans were to be cocrocted, FDE would - not be able to conclude that the New Har@ahlre State and local plans to protect the public in the event of an accident at the Esabrook Maar , Power Plant art adegaata to poet our regulatory standard that sudi plans
adequately protect the public health and safety by providing reasonable surance that appropriate protective measures can be taken o(isite in the ,
nt of a radiological energency.' (jge,44CFR350.5(b)). g s 4 , I :
. - _ . __ _ . - _ , _ . . _ , , ____ _,____ , _ . _______m___ _ . , _ , . . _ _ . . . _ _ , _ _ _ _ _ , . . . _ _ . _ _ , _ _ _ _ _ , . . _ _ _ . . , _ _ _
t Federal Emergency Management Agency Re$i on I J.W. McCormack Post Omce and Court House O. no. ion, wa-.cau.etu 02109 f !d July 2,1987 MP OoR OJM PJR: Pegional Assistance Co,-Jttee (PAC) Padiolcgical E, ergency Preparedness Task Force FROM: O
' PAC Chairman Edward A. Thomas 9[ [V SUIDECT: RAC Review of F Se f-Initiated Review of Pilgrim NPS DZ Please review the attached FDiA self-initiated review and submit your coments no later than July 10, 1987.
There are four docu ents attached:
- a. Merro to Dave McLoughlin, FDiA Headquarters
- b. FDiA's Draf t Interim Finding on DTer@ncy Preparedness in the Pilgrim NPS D2 C-)
d.
' " ' ' ' ' ' ^""*** " ' " ' " " ' " ' ' ' ' " " ' ' " " * ' ' ' ' "
FD!A's Draf t Ccmments on the Report to the Governor Please plan on atterding a RAC reeting here at 10:00 A.M. on July 30,1987, to discuss the following:
- a. Massachusetts Prcposal to Expard the Pilgrim NPS DZ
- b. A Revised RAC Position on the Seabrook Beach Menorandum As a Result of the Change in NRC's Position
- c. The Final Version of FDIA's Self-Initiated Review of the Pilgrim NPS DZ.
Your cooperation is very much appreciated. Please call Jaci. Dylan at FT5 223-9562 if yce reef any assist.ance. O
( .. .' I t AGENDA b& ll ' For
- o RAC MEETING JULY 30, 1987 - 10:00 A.M.
ITEMS FOR DISCUSSION: .
--vl . Status Reports
- M
- 1. Up-date t h. M RAC on status of "350" process for Vermont, New Hampshire and Maine.
h Gflp?R-l
- 2. Status of "Annual letters of Certification" from all New England States. A G,Qp. Afen .
, 3. Review of Maine "4 Ingestion Pathway Plan for Seabrook Station ')
m c4s _q a. Argonne Comments y,y l 4. Up-date on Pilgrim Nuclear Power Station. - NM $ EC M h #!#
'911. Coming Workload g pif- )
5. q-- --. w p s< g , g Seabrook Station Hearings Dates (see attached schedule). , .vy '"p
- 6. Possibility of necessity for RAC support during Seabrook Hearings.
- 7. If New Hampshire submits or up-dates their plans it will require RAC assistance.
- 8. If Utility submits Massachusetts plans for Seabrook Station it will require RAC assistance. ( LeRO g,.QM )
- 9. Possibility of revised Massachusetts Plans for Pilgrim, Vermont Yankee and Rowe. ,
~~
p al m,.'l/ '
- 10. Possibility of RAC Review of Utility submission for Pilgrim.
f 10a. gw 2, ge h
- b;, . < , ,.
U i 4III. Issues for Meetings f, l
~
- 11. Pilgrim EPZ Expansion. ,,/p f >' d {
- 12. Maine Yankee EPZ Expansion. y y .
Q.J-N
~
(13. Maine - M Ingestion P1an_Re_.y_lew $b gf '
- 14. Seabrook Beach Population. / Cdb +
f, llf f L
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