ML20207C392
| ML20207C392 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/20/1988 |
| From: | Bores R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Sherwin Turk NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| References | |
| OL-S-002A, OL-S-2A, NUDOCS 8808090191 | |
| Download: ML20207C392 (76) | |
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'88 JUL 19 P5 36 l PEMORANDUM FOR: Shenvin E. Turk, Senior Supervisory Trial Att3r,r}ey,.0GC . ,,,,
00 caw r evws l FROM: Robert J. Bores, Technical Assistant, DRSS, Regional W "
SUBJECT:
SEASR00K BEACH POPULATION ISSUES ts you have requested I have prepared a summary of my involvement in the above issues and in particular the RAC meetings dealing with those issues. My summary entitled "The Seabrook NH Beach Population :ssues" 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 coments as proviaed to the RAC on the New Hampshire state and local plans. Those A correents probably constituted about 60 to 75% of the coments received from U all the RAC members and the contractor and were adopted by RAC about 90 to 95%
of the time.
/ 0 ASC' Robert J. Bores Technical Assistant Division of Radiation Safety and Safeguards
Enclosures:
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- l R. BORES TECH ASSISTANT
\ DRSS, REGION I i THE SEABROOK NH BEACH POPULATION ISSUE
- 1. The Seabrook beach population issue was raised years ago during the !
construction phase of the Seabrcok Station project. When the offsite l plans for the site were first submitted to FEMA 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 the New Fampshire state and local plans for the Seabr'ook site, New l Hampsh.re addressed each identified concern and with very few, if any j exceptions, those concerns were resolved.
- 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 plans to protect the transient beach population and those persons who ,
occupied unwinterized accommodations in the Seabrook beach areas. l Several RAC members responded to this memo. The NRC attempted to respond 1 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 i "Dignan Memorandum" (Attachment 2). (See also letter from Edward Thomas n to Pobert Boulay (Massachusetts) dated July 9, 1986 (Attachment 3) and l V memo from Spence Perry to Edward Thomas dated June 25, 1986 (Attachment
- 4) confirming 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 i this apparent need, I volunteered to address these issues. In addition I I was again assigned as the NRC RAC representative for the Seabrook site. I (See memorandum from W. azarus, NRC:I to Edward Thomas, FEMA:1, dated i 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 l submitted plans, RAC's ccnnents 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. FEMA:I asked for and received an opportunity to review the document before submission. Minor 4 word changes were made in two paragraphs to accommodate 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 0
- 2 R. BORES TECH ASSISTANT O DRSS, REGION I C
- 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 contractor en this paper. The meeting was attended by me, W. Lazarus and J. Schumacher of the NRC; several FEMA staff including Mr. Thomas, J.
Delan, L. Robertson, B. Swiren and X. Horak; R. Rospenda, ANL-contractor; P. Lutz, DOT; 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 Radiological Emergency Response Plan (NH RERP) was generally adequate, except for the beach population, but with the added features, such as the strong containnent, 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 containment and plant features cited in my paper were in f-d ac'dition to and not necessary for, the NH RERP provisions making the plan adequate. The RAC accepted the above position, as representing their views on the beach issues. Minor changes were suggested by NOAA to reflect the possibility of recircA ating 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 meaning. With above suggested changes and a slight nodification 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 (Attachment 11), the RAC unanimously (including FEMA) adopted my position paper as their position paper relative to the beach issues. (See Draft 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 DRSS, REul0N I O
- 6. Following the 4/15/87 RAC meeting, the ASLB issued its MEMORANDUM AND CRDER on Aprii 22, 1987 relative to the denial of granting Public Service of New Hartpshire a cne-mile plume EPZ for Seabrook site. In addition, since the BNL "centainte .t studies" were still being reviewed by the NRC, the NRC staff recomrrended that I delete reference to tne 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).
- 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 Seabrcck Nuclear Power" and to provide "reasonable assurance that appropriate protective measures can be taken offsite in the event of a radioicgical emergency." (Attachment 14 is a revision of the June 5, 1987 filing with minor revisions.)
p 8. In a letter to Richard Strome (New Hampshire), Mr. Thomas discusses the d FEMA filing, stating that the "Current FEMA Position is largely based upon the FEMA and the Regional Assistance Cemittee (RAC) reviews which were previously provided to you. The position of the Current FEMA Position dealing with the beach population is based on a thorough analysis by FEMA and the RAC. (Attachtrent 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. Colan, B. Swiren; FEMA l contractor, R. Rosgnda (ANL); DOE, H. Fish; DOT, P. Lutz; EPA, B. Keane; I FDA, W. Church; and Dept. of Agriculture, D. Nevitt. Dept. of Commarce (NOAA) was not represented.
Af ter discussing the other items on the agenda, E. Thomas apciogized for j not consulting the RAC prior to pre-filing the testimony on June 5,1987, but said there wasn't time to do so and still meet the filing deadline.
He further explained that FEMA, nut 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 r:sponse to his 12/31/85 memorandum. He said the plant specific items removed from the position paper by the HRC in its 6/4/87 revision were crucial to a FEMA l findinr; of adequacy. In the discussion that ensueo, the 00T representa-tive stated to Mr. Thcmas, "You have a problem!" Then, "We have a problem that we need to come together on." He said that whether or not (a') the paper discussed the specific plant features did not change the facts of the construction. He felt that the plans were adequate and the best he had reviewed. Similar responsas were provided by DOE, EPA and 1
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. 4 R. BORES !
TECH ASSISTANT i DRSS, REGION I Q l HHS. DOT also questioned the "high" numbers of beach goers that were l
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 hH 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 "reasonable assurance" differed from that of the NRC and from that stated in the FEMA /NRC response to the Dignan memo. l Mr. Lazarus asked Mr. Thomas to take a RAC vote on the support of RAC for the previously adopted position paper. Mr. Thomas declined to do so, tir. Lazarus then polled the RAC membership. Each of the agencies .
represented, with the exception of FEMA and their contractor, indicated l that they supported the previously adopted position as modified by my Jure 4, 1987 letter. -
l Mr. Thomas stated that the contractor (ANL) would provide some alterna-O tive wordias proposals to tne RAC membership for both the pos4 tion paper 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. i l
- 10. On August 12, 1987, at a meeting in Concord, NH, I asked the ANL I 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 8/7/87. As of this date (10/14/87) those changes have not been forwarded to the RAC.
l Robert J. Bores l
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10/13/87 i
Attachnents: As stated l
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- r FEDERAL EMERGENCY MANAGEMENT AGENCY
- John W. McCormack Post Office and Courthouse
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Boston, Massechusetts 02109 dMulp INFORMATION AND GUIDANCE MEMORANDUM DATE: December 31. 1985 NUMBER: RI-TH-85-28 HEMORANDUM FOR: Regional Assistance Comittee (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 submittal 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, were not included '1 bS the package sent to you. Therefore, some of the special, quasi-unique 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 evacuating 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 l from the RAC may be needed to assist state and local governments refine their I plans to protect this grout , it appears to us that when we discuss beach '
population, we are talking about two different groups: (a) the transient beach population, and (b) sumer residents who inhabit unwinterized accom-modations on or near the beach A. The Transir,it Beach Population i l
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-
- ditions at the plant dictated. The consulting firm of KLD Associates is in
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l 2 i 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 l 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 l 1s reasonable to assume for the present that the beach population would be i out in the open, or in vehicles close to the center of the EPZ for several l hours after the earliest indication that an accident was in progress. .
l Issue Based on the RAC's knowledge of the accepted literature in the fields of accident sequences, source 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-sient beach population would be in the open, or in a vehicle? If we have f I
advice for the state and local governments on this matter, I believe that we should make it known as soon as possible. If we need additional infor- a mation to deal with the issue, we should let them know now. ,
B. Occupants of Unwinterized Accommodations A number of people associated with the Seab ook emergency plans process Q have suggested that special attention needed to be paid to occupants of the many unwinterized cottages, motel rooms, and canp grounds in the Seabrook EPZ. These people believe that the normal assumptiov, we make about the protective effects of sheltert.19 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.
Issue 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 i any other preliminary coments on the emergency plans, we probably should make them known to the state / 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.
I HAPPY NEW YEAR!
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cc: J. Allan J. Gutierrez R. Starostecki Spence W. Perry, Acting General B. Xane Counsel r Federal Emergency Management Agency f, 0 gn Room 840 T. Martin 500 C Street, G.W.
Washington, D.C. 20472 B 6/24/86-TEM in the Matter of Public Service Company of New Hampahlre, et _a_l,.
j (Seabrook Station, Units 1 and 2)
Docket Nos. 50-443 OL and 50-444 OL l 1
Dear Mr. Perry:
i in response to a request made by Edward Thomas of FEMA Region I, we have evaluated, in conjunction with Joseph Flynn of your office , an undated memorandum prepared by Thomas Dignan of Ropes and Gray on of the applicants for the Seabrook nuclear plant ("Dignan j ehalf Our
{diemorandum", a copy of which is attached Attachment A).
evaluation is set forth in the following discussion.gs The Dignan Memorandum addresses what are described as "three misconcep-tion s" pert ajning to offsite emergency planning for the Seabrook nuclear plant , and conclude s that they are "false as matter of law" (Dignan '
j 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. l l
B. That it must be demonstrated that the plans will assure that 111 persons located in the Emergency Planning Zone or some certain portion of it can be evscuated 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.
I should be noted, however, that under the Commission's regulations, lt 10 CFR I 50.3, only written regulatory interpretations provided by the General Counsel will be recognized as binding upon the Commission.
- Epence Pehry. Esq.
O 4. Accidents involving early releases are within however, the Commission's ' emergency planning basis, the regulations do not specify a time to within which the be completed.
racommended protective actions are Sincerely ,
Edward S. Christenb[
Director and Chief Hearing Counsel Enclosure i
cc: J. Taylor E. Jordan T. Murley l l
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, . . Boston, Massschusetts 02109 July 9,1986 I ,
Mr. Robert J. Boulay
- State Energency Management Director Massachusetts Civil Defense Agency c_.
ard Office of Dr.ergency Prepare:! ness F P.O. Box 1496 5 400 Worcester Fud .
Framingham, Massachusetts 01701 c:3 w .
Dear Mr. Boulay:
1
- n Last January, you reamste$ that IT.MA conment on a memorardu:n pegared tmG Tn=.as Dignan, Counsel for the New Ha.;; shire Yankee Division of the PublTc Service Cc:pany of New Ht=pshire. A ccpy of that memorardum is enclosed.
The enclosed letter from the Nuclear Rgulatory Ccr::nission analyzing the Dignan memo was develeped in close coordination with ET.MA ard rgresents
( the combi d views of both NRC ard FEMA.
O we voics>=e cor the ae1er ta res;=retre to your teamst- eiease <=11 te you have questior.s.
Sincerel,[
4 Edsard A. Thems Chief Natural ard Tednolcgical Hazards Division D closures cc: Richard Strene ,
, Terry Harpster 1
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HEMORANDUM FOR: Edward A. Themas, Chief Natur 1 and T chnological Hazards Olvision Ku on l ,
FRCH: ,.n H. ,
Acting Gone 1 Counsel
SUBJECT:
Offsite Emergency Planning at Seabrcok Station
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InycurmeE:randumofJanuary 23, 1986 to Joseon Flynn, you ccmmunicated the request of Robert Sculay, Civil Defense Olrector for the Cer.mnwealth of ,
Massachusetts, that the Federal Emergency Management Agency (FEMA) and the Nuclear Regulatory Commission (NRC) review and comment upon a memorandum of - ,
law prepare by Thcmas Olgnan, Counsel for Public Service Company of New ,
Hamoshire. In his memorandum, Mr. Olgnan addressed what he considered to be
'g Q three miscenceptions abcut offsite emergency response planning as it relates to the Seatrcck Station.
I recently received a letter frcm Ed.ard Christer. bury. Director of and Chief NRC, which l Hearing Counsel, Office of the Executive Legal Directer (CELO) The legal respcnds to your request. A copy of that letter is attached.
l discussion in that letter reflects the combined views of our respective
, offices. I concur in Mr. Christenbury's analysis of the Olgnan memorandum. :
Attachment I
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O January le, 1997 ME"0RANCUM FOR: E: ars A. Thomas, Chateman, Reg.onal Assistance Committee (RAC), FEMA Region !
FRCM William J. La:arus, Cstef. Emergency Preparedness Section, NRC Regton I
SUBJECT:
A5313NMENT OF NRC RAC MEMBERS FOR SITES IN FEMA REGION !
Effective namediately, the following persons are assigned NRC RAC review responsibilttles for nuclear power plants located within FEMA Region 1:
Mr. Robert Bores FTS 488-1213 Seatrook or (215) 337-5213 Mr. John Schumacher FTS 408-1342 All other sites or (215) 337-5342 If you have any questions, or are at any time unable to contact488-1208 either Mr.
or Bores or Mr. Schusacher, please fcel free to contact as at FTS (215) 337-5208.
Q W . ' ' ru Ceergency Preparedness Section NRC Region 1 occ:
T . 'ta r;1n ,
R. Bellary l R. Bores l J. Schumacher
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- E. Jordan f l
S. Schwart:
E. Podolak i O
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Federal Emergency Management Agency 5 Region I J.W. McCormack Post Omce and Coun House n . . Boston, Massachusetti O2109 U .
l Janua ry 27, 1987 1 l
l MEMORANDUM FOR: State Emergency Management Directors l Regional Assistance Comittee (RAC) l Radiological Emergency Preparedness Task Force (REP)
FROM:
9 'O f #
[' Edward A. Thomas RAC Chairman
SUBJECT:
Assignment of NRC C Members Attached please find an apdated Regional Assistance Comitte (RAC) listing. We have been advised by the NRC the following persons are assigned NRC RAC review responsibilities for nuclear power plants j l
located within FEMA Region I.
Seabrook Dr. Robert 3 ores FTS: 488-1213 Q or (215) 337-5213 All Other Sites Mr. John Schumacher FTS: 488-1342 or (215) 337-5342 If you have questions, please call Betty Dionne - FTS: 223-9562 )
Attachm:!nt O
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Janua ry 27, 1987 FEMA REGION 1 Regional Assistance Committee Members Committee Member - Supervisor / Director Mr. Paul Lutz Rear Admiral Robert Joharison Regional Emergency Transportation Ref Commander Capt. John Foster Williams Coast Guard Bldg. 1st Coast Guard District 408 Atlantic Ave. Capt. J.F. Williams Coast Guard Bldg.
Boston, MA. 02210-2209 408 Atlantic Ave.
FTS: 8-223-8451 Boston, MA 02210 COMM: 617/223-8451 24 HR: 617/223-8555 Coast Guard Duty Officer Mr. Byron 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 Mr. Warren Churen Mr. David Field Regional Radiological Health Representative Director U.S. Food & Drug Administration State Programs Branch 585 Commercial St. 585 Commercial St.,
Boston, MA 02109 Boston, MA 02109 FTS: 8-835-4718 O COMM: 617/565-4718 John Stepp Mr. Edward J. Montminy U.S. Dept. of Health & duman Services Regional Health Administrator Public Health Service Representative Public Health Division 1401 JFK Federal Bldg. (14th Floor) 1401 JFK Federal Building Boston, MA 02203 Boston, MA 02203 FTS: 8-835-1469 COMH: 617/565-1469 Jophn Schumacher Thomas Murley Nuclear Regulatory Commission Regional Administrator Region 1 Nuclear Regulatory Comission 631 Park Ave. 631 Park Ave.
King of Prussia, PA 19406 King of Prussia, PA 19406 FTS: 488-1342 24 HR: 215/337-5000 COMM: (215) 337-5342 Robert Bores (Seabrook) Thomas Murley Nuclear Regulatory Comission Regional Administrator 631 Park Ave. Nuclear Regulatory Comission King of' Prussia, PA 19406 631 Park Ave.
FTS: 8-488-1213 FAX: 488-1135 (50 seconds) King of Prussia, PA 19406 488-1323 (Verification) q FTS: 8/488-1000 Q COMM: 215/337-5213
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Committee Member, Supervisor / Director (Dorothy Nevitt/ Bob Conley/Cheryl Malina/ Mr. George E. Bickerton Anna Hart) Director Office of Emergency Planning Office of Emergency Planning USDA - FSIS-PP USDA - FSIS-PP 14th & Independence Ave., S.W. 14th & Independence Ave., 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 Animil Disease Center (Box 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 e Princeton Area Office Chief, Public Safety Section b P.O. Box 102 U.S. Dept. of Energy Princeton, NJ 08542 Office of Environment Tel: FTS 8-340-3700 (3708) Routing Symbol EV 131 (Brookhaven: 8-666-3427) Washington, DC 20545 (NY Support Office 8-212-620-3608) FTS : 8-233-5434 (FAX: 8-340-2032) ,
COMM: 301-353-5434 (PREFERRED Malt. LNG ADDRESS:
56 Mountainview Road
. Millburn, NJ 07041)
Willian P. Patterson Bruce Blanchard U.S. Department of the Interior Director Regional Environmental Office Office of Environmental Project 1500 Custom House Review 165 State St. Office of the Secretary Boston, MA 02109 Department of the Interior Washington, D.C. 20240 FTS: 223-5517 or 223-5104 COMM: 202/343-3891 HOME: 617/527-4180 FTS: 343-3891 (See Other Side)
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3-Dept. of Commerce - NOAA/NWS Mr. Richard P. Augulis Mr. Stanley Wasserman Director
(]) Olvision Chief .
National Weather Service tieterological Services Division Eastern Region Headquarters NWS Eastern Region 585 Stewart Avenue 585 Stewart Avenue Garden City, NY 11530 Garden City, N.Y. 11530 COMti: 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 O
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Edward A. Thomas, Chainnan Regional Assistance Committee Federal Emergency Management Agency l John W. McConnack Post Office and Court House !
Boston, Massachusetts 02102
Dear Mr omas:
Reference:
Your memo of December 31, 1985 relative to the beach populations in the Seabrook area !
I l
As requested, I am responding to your memo 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 connents on it, 3 including the Seabrook Evacuation Time Study; the analyses of specific Seabrook Station features; and my professional knowledge and judgement related to !
emergency preparedness. The bases of rny opinion that the plans are or will be i adequate (contingent on completion of actions by New Hampshire to resolve RAC !
concerns) to protect the becch population (both the beach transient group and '
those who inhabit unwinterized accomodations) are provided in the Enclosure to this correspondence. l O bhould you have any questions concerning the above, please contact me at FTS 488-1213. I would be happy to meet with you and/or the RAC to discuss my response. l Robert Bores, Technical Assistant Division of Radiation Safety and Safeguards
Enclosure:
As Stated cc w/ enc 1:
W. Lazarus, RI O
n
\
1 1
. l O PROTECTION OF NEW HAMPSHIRE BEACH POPULATIONS 4
.BACXGROUND l
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 power), no operating license for a nuclear power reactor will be issued unless a finding is made by l the NRC that 'there is reasonable assurance that adequate protective measures can and will be 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 adequacy and implementability of the licensee',s onsite emergency plans.
The FEMAplans.
emergency finding is primarily based on the review of the state and local in considering whether there is reasonable assurance that the plaj implemented. Paragrcph b of 10 CFR 50.47 requires that the onsite and ;
offsite emergency respons(e) plans for nuclear power reactors planning standards.
NUREG 0654/ FEMA-REP-1, "Criteria for Preparation and Evaluation of RadiologicI Emergency Response Plans and Preparedness in Support of Nuclear Power Plan was issued to provide a comon reference and guidance source for state and local governments and licensees in the development of emergency O response plans and preparedness for response to a radiolo ,
for FEMA, and NRC preparedness. and other federal agencies for use in the review of those plans j
The planning basis adopted by NRC and FEMA for emergency preparedness around nuclear power plants was taken from NUREG 0396/ EPA 520/1-78-016, "Planning Response Plans in Support of Light Water Nuclear "The overall Power Pla objective of the emergency response plans is to provide dose savings (and in l some cases, imediate life savings) for a _ spectrum of accidents that could l produce offsite doses in excess of the pAGs" (NUREG 0654). i it attempted to identify the boundarthat the planning basis range from triv ,
of potential accident consequences, y parameters based on available knowledge timing of releases, and release charac-teristics (source term).
PAGs do not equate with loss of life or even a health hazard.It should be The PAGs were intendedTr use by protective action decision makers in arriving at a balance l between constraints radiation risk and that of taking a protective action in the absence of to that action. l
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E 7 NUCLEAR REGULATORY COMMisslON )
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[ necios i 5 g $31 FAKK AVENUE Os KIN 3 OF P2US$l A, FENNSYLV ANI A 19104
% ...., p. 7 A :/A?.18 1987 y
Mr. Edward A. Thomas, Chairmar.
Regional Assistance Convaittee Federal Emergency Management Agency 442 John W. McCormack Post Office and Court Ht_se Boston, Massachusetts 02109 6
Dear ' . Thomas:
Reference:
RAC Coments on Transient Beach Population for Seabrook Station I have reviewed the individual RAC coments distributed with your Hard 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 s':bsequent revisions of the New Hampshire State and local plans.
. There appear to be adequate bases and infonnation 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 teet may be oes4 able by a^Certs^ to resolve /ederess any outsteadias coacerns.
Sincerely, Robert . Bores Technical Assistant Division of Radiation Safety anc Safeguards i
cc: l W. Lazarus, R1 i l
1 R' l l
ARGONNE NATIONAL LABORATORY 9700 s0UTH CASS AVENUE, ARGONNE, ILLIN015 60439 TELEPHONE 312/972-7643
, f April 14,1987 /} ff 7 Mr. Jack Dolan 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 i responses to Thomas 12/31/85 memorandum concerning the transient beach population '
and have the following comments:
It appears that final resolution on the adequacy of planning for the beach population is dependent on the receipt and review of Information from the State 1 of New Hampshire on the number of translents who would need transportation during an evacuation.
Page 3 of enclosure to R. Bores'(NRC) letter dated 2/18/87. The comment that O, element J.10.d has been left "open" by the RAC is not consistent with the RAC review spreadsheets.
Page 4 of enclosure to R. Bores' letter dated 2/18/87. The comment for P[$p element J.10.k that the RAC had "one additional reccmmendation" is not consistent with the RAC review spreadsheets.
Fgh V
- Page .6 of enclosure to R. Bores' letter dated 2/18/87. Item #4 Indicates p 68 p) (
that ...." resources have been provided .... for providing transportation for those without vehicles ...." However, as indicated in comment #17 of the RAC review i
I P d of the ETE, the estimates of persons requirir.g transit provided in the ETE l
'/ represent only estimates of permanent residents who require transit and do not g, p include the translent beach population.
f If you have any questions, please.do not hesitate to contact me.
b J Sincerely, C& ,/r Robert E. Rospenda Energy and Environmental Systems Division RER:may E. Thomas (FEMA-Reglon I)
O' cc M. Lawless (FEMA-HQ)
T. Baluw!n (ANL)
K. Bertram ( ANI.)
M. Gingh (ANL)
l ARGONNE NATIONAL LABORATORY TELEPHONE 312/972-7643 I
- 970o south CASS AVEM)E, ARGCmE, ILLINols 6o439 l
April 17,1987 1
l l
Mr. Edward A. Thomas Federal Emergency Management Agency Room 462 J.W. McCormack Post Office and Courthouse Boston, MA 02109
Dear Ed:
In accordance with your request af ter the RAC meeting in Boston 4-15-87, I have I prepared draft revisions tc the RAC review of the New Hampshire State and local plans for Seabrook. These draft revisions are enclosed and reflect the RAC's conclusion that/j the plans (Rev. 2) adequately treat the beach population issue. l In order to expedite final review, and to clearly show where changes are being I proposed, I have purposely lef t the changes in hand-written form on marked-up copies of the original pages. The proposed changes are shown on the following two enclosuret Enclosure 1. Revisions to RAC review of State plan elements J.9 and J.10.m I] (Section I, pages 64, 86 and 87); and local EPZ plan element J.9 (Section !!
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 you have any questions, please do not hesitate to contact me.
Sincerely, M k Robert E. Rospenda
,'e Energy and Environmental Systems Division
/c RER:mav Enclosures (1 and 2) cc: R. Bores (NRC)
M. Lawless (FEMA-HQ)
K. Bertram (ANL)
O T 8 iewia c^nt)
U.S. DEPARTMENT oF ENERGY THE UNIVER$iTY of CHICAGO
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. SECTION E .
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! Radiological Emergency Respomoe Pleas for Seabrook .
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TELEPHONE 312/972-7643 DNNE NATIONAL LABORATORY 60439
$0UTH CAS$ AVENUE, ARCC'4NE, ILLINOl$
April 22,1987 Mr. Edward A. Thomas Federsl 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 additiona f Seabrook. revisions to the RAC review of the New Hampshire State and local plans or These draft revisions are enclosed and reflect suggested deal changes by Bo the revisions previously transmitted with our letter dated 4/17/87. These change 7tth the beach population issue. (G In order to clearly show where changes are being proposed, d by we have ag purposely lef t the changes in hand-written form. The most recent change - Bob Bores, are indicated by brackets. If you have any questions, please do not hesitate to contact me. Sincerely, f Robert E. Rospenda , Energy and Environmental Systems Division i RER:may Enclosures (1 and 2) cc R. Bores (NRC) M. Lawless (FEM A-HQ) K. Bertram (ANL) T. Baldwin (ANL) O 303 THE UNivERstTY oF CHICAGO U.S. DEPARTMENT or ENCRGy
UNITED ST ATES
.p* U809 NUCLEAR REGULA1)RY COMMis$lON l
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~ en pacx AvcNUE 80NC OF PRUSSI A, PENN5%V ANI A 19404 'g 0"*g .
u.s 1 8 ser Edward A. Thomas, Chairman Regional Assistance Committee rederal Emergency Management Agency John W. McCortnack Post Office and Court House Boston, Massachusetts 02102
Dear Mr omas:
Reference:
Your nemo of December 31, 1985 relative to the beach populations in the Seabrook area As requestod, I am responoing to your memo regarding the adequacy of the New My response Hampshire RERP relative to the protection of the beach population. is based on Revision 2 of the NH RERP; the RAC/ contract Station features; and my professional knowledge and judgement relate adequate contingent emergency on completion of actions by New Hampshire to resolve RAC (preparedness. Concerns) to protect the beach population (both the beach transient group and those who inhabit unwinterized accomodations) are provided in the Enclosure to thi. ;correspondence. OShou,d you have any questions concerning tne above, ,, ease contact me at r15 488-1213. I would be happy to meet with you and/or the RAC to discuss my I response.
, y I
Robert Bores, Technical Assistant Division of Radiation Safety and Safejuards
Enclosure:
As Stated cc w/ enc 1: W. Lazarus, RI O 3)
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! Radiologleel Emergency Response Plan for Seabrook 4
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- /. . ~.s .A, WCMAR RsGULATORY COMMissl0N
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u .; i s e r - Ecmard A. Thomas, Chairman Regional Assistance Coevnittee Federal Emergency Management Agency John W. McCormack Post Office and Court House Boston, Massachusetts 02102
Dear Mr omas:
Reference:
Your merno of December 31,1985 relative to the bead populations in the Seabrook area As requested. I am responding to your memo 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 corrents on it, including the Seabrook Evacuation Time Study; the analyses of specific Seabrook Station features; and my professional knowledge and judgement related to ee.ergency The bases of my opinion th.t the plans are or will be adequate (preparedness. contingent on completion of actions by New Hairpshire to resolve O concerns)toprotectthebeachpopulation(boththebeachtransientgroupand those who inhabit unwinterized accomodations) are provided in the Enclosure to this correspondence. Should you have any questions concerning the above, please contact me at FTS 488 1213. I would be happy to reet with you and/or the RAC to discuss ry response.
, .. j , ,
Robert Bo es, Technical Assistant Division of Radiation Safety and Safeguards
Enclosure:
As Stated cc w/ enc 1: W. Lazarvs. RI l I l
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.. 8 7/pg. Sey h ggye sen// WJe M V/t o NHY Nw p/pa,e gyg,j f nf ri 6*>dNd 0 b& M* l Q peks*0 It is also noted that when large, seasonal beach crowds are likely to be l
i present(onhotandsunnydays),thetypicalwindpatternisfromtheoffshore. l cooler surface to the crishore, wariner surfaces of the land Nsses. This seans j u"i l that any ' sea breezes
- would likely prevent the plume from traveling"to the j 1 'l nearby beach areas when the beaches are most heavily populated. f l DISCUS $10N a/ Add l The foregoing discussions have indicated that th'e current NH plans meet or will meet the criteria of NUREG 0654 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 j warrant unique solution or provisions beyond those already incorporated. l The beaches themselves are nearly two hiles from the station at their closest l approach. This distance provides for dispersion and dilution of the plume as i well as additional plume travel time for a plume to reach the beach area from p the site. Additionally, because of the sea breeze situations normally Q associated with sea coast areas, the wind direction will be normally on shore, i.e.. toward the plant, rather than off shore from the plant to the shore) during hot, sunny days when the beaches are likely to be most populated.
1 The analyzed severe recident scenarios (core melt with early containment i failure) indicate that the m jor portion of the dose to the affected population ' frcm such an event is due to exposure to deposited radioactive n terials on the ground surf aces rather than from the passing plume. The risk / consequence codes generally used (CRAC models or MACCS) all assuet that the population is exposed l to this ground deposition for 24. hours af ter the arrival of the first portion of the pluee and to any additional plumes over that area. In other words, the codes assume that no protective actions are implerented for 24. hours after the release reaches thTbeach (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 containment failure' at Seabrook and low conse;wnct/ low probability of serious containment bypass sequences; the plume travel time to the beach areas and the relatively short (2 to 4 hours) tire esticated to clear the beaches, it appears that risks 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 here caught in or under the plume for two hours during the evacuation process, their exposure to deposited radioactivity would only te approximately 2/24 or less than one. tenth of the code assured dose. In addition, they would be avoiding any additional exposure to the plume (s) af ter leaving this area. O 49
pM%q gi jo,, UNITED STATES
;; - g NUCLEAR REGULATORY COMMISSION -
* , REGION I
. t 831 PARK AVENut
%, . . . . . ,o'f K!NG OF PRUS$1A, PENNSYLVANI A 16406 APR 24 ggg, Mr. Edward A. Thomas, Chairman hitt M /I Regional Assistance Connittee Federal Emergency Management Agene.y j 442 John W. McCormack Post Office & Court House ;
Boston, Massachusetts 02109 ;
Dear Thomas:
Reference:
Connents 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 some 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 the terminology related to risks. The following sentence should be inserted on p. 7 of the enclosure to ray February 18, 1987 memo on this subject, at the end of the second paragraph, following "Using the RSS assumptions, the New Hampshire Yankee and BNL studies indicated that a severe accident at Seabrook Station posed a public health p V risk at about two miles from the station that was essentially the same magnitude as considered in NUREG 0396 at 10 miles from a nuclear plant." Add:
"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 486-1213. i
,u
., t :. : ,
Robert . Boros Technical Assistant Division of Radiation Safety and Safeguards CC: i W. Lazarus, RI R. Rospenda, ANL o :
r, MY-Er? ' B7 14: 38 !Dt FO+E mTL LAB TEL NO:312-97F 7919 ggy gg
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MY-07 '87 14 38 !D CRGCNE MTL LAB TELN:'312-972-7819 C177 PS2 Draf t 3/6/87 REVISED '!OWN OF HAMPTON O - CONTENTION Yul TO REVISION 1 , I l RMA Response FEMA has addressed the Town of Hampton Revised Contention VIII and its basis of inadequate protective actions for the beach populatlan by applying Plsnning Standard J (Evaluation Criterls J.9, J.10.a J.10.g and J,10.m)la FEMA-REP 1. The December 15, 1986 RAC review of the State and munfolpal plans, the amended portions of the RAC review dated , and the RAC position paper on the beach population lasue transmitted to the State of New Hampshire dated reflect FEMA's views on this lasue. Specifically, FEMA's review l comments on the New Hampshire State plan on this tasus are provided on pages $4,74, 38,87,88, and 91 of Section I. FEMA's revlow comments on the munlo! pal plans on th!s Q lasue are provided on page 17 of Section 11. FEMA's review comments on the Evacuation Time Estimate (ETE) on this issue are provided on pass 4 of Secrtion VI.
' - . =w :s -
*- .1.: Y m' FEMA relled upon the following documents,in formtag its conclusions on this m.- ; n n; n g .4 -r ;- . - - . ~ ~ a- ;'j;- ;;; -
tasue Revision 2 to the Hampton plans Revision 2 to the New Hampshire State plans and the App!! cant's Motion for Summary Disposition of the Town of Hampton Revised l Contention VIII dated March 15,1987. I As Indloated in the Dacember 15, 1986 RAC revlaw (page 44, Section I), l determination of the adequacy of protective reponses for the beach populatlon .emained I open pending final revlew by the RAC of planned protective measures, and pending receipt of information from the state on the number of transients who would need transportation during an evacu* tion. '!he RAC has recently concluded (see RAC poeltlon paper dated ) that the beach population can be appropriately protected by implementing provisions of the current (Rev. 2) New Hampshire emergency plans and i that there appears to be no unique problem relative to the beach popult.tlon that has twt i been adequately addressed.
r%Y-07 '87 14:39 !DIMtCO+E IMTL LAB TEL to 312-9??-7819 #177 P03
.. Ofampt:s VIII) Draft 8/6/87
'ar th =^c aaae2a'iaa aa th heaen 9 9=t tioa t ue ar eravia o ia O rn 6 the position paper transmitted from FEMA to the State of New Hampehlte on May ,,,,
1987. Work on thls poeltlon paper was initiated by a 12-31-85 memorandum from the RAC Chairman to the RAC members requesting their review and comments on the adequacy of plans for protecting the beach population (14., the transient beach population, and summer residents who Inhabit unwinterised seeommodations on or near the beach), and the possible need for specla! protective sottons to protect the beach population. Written comments in response to the memorandam were received by the RAC Chaltman during 1988 and 1987. A specla! meeting of the RAC was convened in P April 1987 to review all comments and, if possible, to arrive at a un! fled positle,n on whether the plans were adequate or inadequate to protect the beach popu!= tion. On the bests of this review. the RAC resolveo snat, contingent vu L1= vvmy!,tlea of setlen by sne state to resolve tite vtl a RAC 4*ncerns with the Now Hampehfre entt IneAl plana.
- .- . . u . . . : .c., . . . . . . I lll ll l
. e - :nJl_ litussaae Itat the hntah Ind ling l Dig [lliN) ,-.
I I . . Julillini alli te nintnoted Indethet.thrijf OldM 1ll gll{Q]lgy ayet -the.. .. . . . 1
. .ti..t.. ..P I!UnDQ 00C L and the intant nf thekh regulallnntin this Arts, y Tne touoWing constuwrs6avim ww. u 4. . ., . . . .ll. I il vuuch-twu ..tative ts 4ks beuvli yvyulation?
'I l .I ll Ill Elli Utl0lf 0lll Giltil}l generleally
- Speelal provisions for beach populations in place
- No identlfled problems r qu! ring un!que or unaddremed solutions
- Provlsions for early warning of beach populations 1
- Adequate transportation resources available for those needing l O , io transit
< 45
my-cr/ 's? 14:4a lo: ARooteE *TL LAB TEL tc 312-972-7ets- ci n pee
. . Ota pton VIII) Draft 5/8/07 O - 8. en r a rir t"a =ii tra= t tioa 'rareias a 2 7 ia aium-arrival and dilution and dispersion of plume
- Sea breezes would tend to keep plume from traveling directly toward beach when beaches are most populated
- ETEs for beaches are relatively small 7 Cor.tainment at Seabrook !s very strong probabDity of prompt containment failure is negligible e Containment bypass is unlikely to cause severe offslie problems
. Site specific studies for Beabrook Indicate risks at two miles are
, comparable to NUREG 0396 analyzed risks at 10 miles-
* "Reasonable assurance" does not equate with "absolute safety,"i.e.,
guarantee of no exposures or exposures above the FAQs. The above are described in further detallin the RAC position paper transmitted to the State of New Hampshire on May s 1947. Although the RAC has.renobed p-oonclusion, ort the baseh population.lssue e tthe.t. c' : RAC still awalts rece!pt of Information from the State of New Hampshire on the numbee of translents who would need transportation during an evacuation. The State Plan (ETFn Volume 8 Table 11-6) presently provides estimates of permanent residents who would require transportation, but does not include estimates for transients requMng transportation (RAC review, Section VI, comment 17, page 4). Although the number of transients without trr.nsportation is expected to be small and well within the available transportatten resources (RAC review, Bection I, page 74) Idientitled in the plan, this I infemation has not yet been provided to FEMA. Because of the potentially large seasonal beach population, speela! precautionary l 1 protective sottons for the beach population have been established by the State of New O Hampshire (New Hampshire Plan, NHCDA Proceduras, Appendix F), including early ) precautionary evacuation. The use of public buildings for sheltering of translents without
! 4b i
N Y-07 '87 14:41 IDifftGONE NATL LAB TEL pct 312-972-7819 3177 P05
. (Haupton V11I) Draft 8/6/07 I . -
transportation may be implemented on an 'ad hoca basis (RAC review, teotion I, Q page 84). As indleated in the RAC poeltlon paper on the beach pgulation issue, provisions have been made in the plans to consider closing the beaches or restricting pubile access to the beach at the Alert emergency classifloation. At this classification level, no offette setton would be ordinarily warranted tomrotaet the public, but its considera'lon C Jees Va.e or p m ee+ oN &wal odb nuestle_ M nere wou2a provice additional time to clear thefbeach, just In case the situatlot. k-worsens. Even at the Site Area Emergency chavf:eation, one would ordinarily erpect that offsite protective actions would not be nimv.ry to proteet the public. As noted in the 8 tate plan (page 2.1-13) precautionary protective aettons for the beach population will be conaldered during the period of heavlest beach use, from May 18 through September 15. Details on the early precautionary protective aettons im the beach population, including precautionary evacuation, are provided in the State plan procedures O (NHCDA Proceduras, Appendix 7). . .. The use of .early-precautionary protective notions such as. beach .olosing.and.== avacuation are not the sole means for: protection of the beach population.1'he'betek . d population is, in effect, also protected by the unusually strong containment system at the Seabrock Station. As Indleated in the RAC poaltion paper on the beach population issue, 4 Brookhaven National Laboratory (ENL, reviewed analyses performed by the Appiloant ) and performed additional analyses of the systems and features of Seabrook Station. BNL eoncluded that (t)here is negliglble prcbability of prompt eentainment failure (at k
- 8eabrock). Fa!!ure during the first few hours estter core mslt is also unlikely and the 1
timing of overpressure failure (of containment) is very long compared to the 188. Most l eore melt aceldents would be effectively mitigated by containment spray operation. 1
- ANL reviews of containment bypass aceldent scenarios also Indleated that signifleant g
- O -ie-a from -h auieents w-e al- -t liweiF in the fwi h- after a -v- !
j accident. p A i - h
M2i-@7-WTdiM m:W<GONf E tMYL LAB TEL tC 312-972-7619 n177 P06 (Hampten Vill) Draft 5/4/87 , The RAC pcattlon paper further indicates that, in view of the New Hampshire
, plans for beach closure and access control as early as the Alert classification, the cited "negligible probability of prompt containment failure" at Beabrook and low consequence / low probability of serious containment bypass sequences, the plume travel time to the tseach areas and the relatively short (2 to 4 hours) time estimated to clear the besches, it appears that risks to the beach population are a small fraction of the
~
alted alshs la Wilflir A108 fas thin dIntanon Thun nunn if thnso Enna a nnnmnt tairena l 11111Illllillj 1111111 III I pilllII II ill IIllI Illidillli 11151 llll0Il II AlllRdll lllt plums fos tiso houno dusing the ovaoustion pnnness, thals arpnsure in risonelted radioactivity would only be e7prvalmately 2/24 or less than one-tenth of the code assumec cose. In aQQ1119ni inty woulo M BY91ging gny pgostionna exposure to ine plume (s) af ter leaving this area. j FEMA Response (Further Basts) O FEMA has addressed the Town of Hampton Revised Contention V111 and its further basis of inadehuatie protectfife -ntions~for resident'sPof-th'eV8ea~ coast 11eW1th # - Center by appIying'Plannhig Standards'H'and I~(Eviluation Criteria H4,'H.11, 7.10.d,^ " J.10,g, J.10.m) in FEMA-REP-1. The December 16, 1988 RAC review of the State and municipal plans reflects FEMA's views on this issue. Speelfically, FEMA's revlew comments on the New Hampshlte State plan on this issue are provided on pages $7,74, and 88 of 5ection 1. FEMA's revlew comments on the munle! pal plans on thi~ Issue are provided on page 19 of section U. FEMA's review comments on the State Compensatory Plan on this lasue are provided on pages 8 and 8 of Section IV (Compensatory Plan subsection). FEMA relled on the following documents in formlag its conclusions on this issue Revision 2 to the Hampton plant Revision 2 to the New Hs:apshire State plant and O she i,piicants motion for Summary Di.p iiion of the Town of nampion novls.o Contention VIII dated useoh 25,1987. \ 48
ID:rRGCNE MTL LAB TEL FC: 312-9'G-7819 n177 P07 MY-07 '87 14:42 Draft 5/6/8'T ! Diampton VIU) On the basis of the RAC review of Revision 2 of the Date and municipal plans, ! FEMA has not yet received sufficient Information to have assurance that the residents of 1 i the Seacoast Health Centet 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 ind!cated that it will not participate in the planning and response to an accident at the Seabrook Station, it is necessary to determine the State's abutty to . implement compensatory measures for the Town of Hamptoe and to, therefore, provide I for evacuation for the residents of the Seacoast Health Center. The Hampton plan (page 11-30) Indicates that in the event of the evacuation of special facilities (such as the Seacoast Health Center), the Hampton Pub!!c Works Director 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 provision of transportation resources for the evacuation of the residents of the Seacosst Health Center. '!he concept of operations for the State's compensatory measures.ls, provided in. Appendix O_ of the State Plan .As_ ..,,_, .__
-:,5. .
indicated in this appendix and in the NMCDA Procedures (Vohsneti .of State Plan),.if 4 municipality is unable to respond to the emergency, an IFO Local Liaison will be assigned to coordinate the provision of transportation resources fo* evacuation. Although the RAC had no comments on the adequacy of this plan concept per se, 'the RAC has questioned the adequacy of the numbers of Local Llaison persons to be assigned and the adequacy of available communications resources availabls to implement this aspect of the compensatory plan. These items (NURE0' elements H.4 and H.11, pages 6 and 8 of Section IV RAC comments on Compensatory Plan) were left open by the RAC pending provlslon of additional supporting information by the State. 'nds Information has not yet been provided to FEMA. Relative to the special facilities plans themselves (i.e., those included as Appendix F of the munletpal plans),b.:2lFl FEMA sonoludes that the health y Y -
MAY-07 '87 14:43 ID: AR3CNE NATL LAB TEL NJ:312-972-7819 #177 P00
.- . - (Hampton VIII) Draft 5/4/87 O o r facility speciai riaas, inciudine that for tae So coast wealth Center, have heen adequately revised and now contain adequately detailed procedures for evacuation and relocation of patients (RAC review, Section I, page 67). Although there are still numerous inconsistencies in the plan in bus needs eettmates, all estimates Indicate that overall the number of buses provided for in the letters of agnement are adequate and that additional transportation resources available from othat organizations provide a large redundancy of resources (RAC review, Section I, page 74).
The bus boarding time of 10 minutes for residents of special facilltles la provided in the State Plan Evacuation Time Estimate study, page 11-21. The RAC had no comment on this revised estimated bus boarding time. In regard to sheltering residents of the SeacotAt Health Center, the State indicates that sheltering is the preferred protective action. FEMA concludes that tha plans have been adequsstely revised to take into account the sheltering protection factors for speelal facilltles, including the Seacoast Health Center. A special tabulation of
~
speelfic protection factoh foVeacli of the 'faellities,'Includng the Beacoast"Healthm - Center, is present'in Table'2.6-3 of the State plan (RAC review; Bectiod I, page 67). The"' RAC review (Section I, page 88) Indicates that the flow diagram in the State plan (Fig. 2.6 'l) now properly reflects the deelslon-making process for the election between sheltering and evacuation, and that the treatment of institutionc.11:ed persons is now adequately detalled. O 50
l f%Y-07 ' 87 14 : 44 ID: ARCOeE MTL LAB 'TEL to:312-972-7 egg m177 peg i
. .. becM y+t?
l O . s^rt+cowr=wTrow to FEMA Response PEMA has addressed SAPL Contention 16 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, 1986 RAC revlaw of the State and local plans, the amended portions of the RAC review dated . and the RAC position paper on the beach p
, opulation lasue transmitted to the State of New Hampehire dated refleet PEMA's views on thle !ssue. Speelfically, FEMA's review comments on the New Hampshire State plan on this issue are provided on pages 64, 47, 87, 88; 89 and 81 of Section I. PEMA's review comments on the municipal plans on this !ssue are provided on page 17 of Section u.
~
J PEMA rolled on The followlng ' documents 'in forming"Its c'oi.elusio~ns el tSe Issue: Revision 9 fo the New Hampehire State and local plans; ed the Applicant's Motl56'7J for Summary Disposition of SAPL Contention 18 dated March 25,1987. PEMA does not yet have all information to be provided by the state. As ! Ind!cated in the December 15, 1988 RAC review (page 64, Section D, determination of i l the. adequacy of protective responses for the beach population rema!ned open pending i final review 'by the RAC of planned protective measures, and pending receipt of information from the state on the number of translents who would need transportation during an evacuation. The RAC has recently concluded kee RAC position paper dated _ J that the beach populat'on can be appropelately protected by implementing provlslons of the current (Rev. 2) New Hampshire emergesey plans and that there O a,,ea,, to be ,o onigoe ,,obiem ,eiauve to the 3each ,o,e1.uon ami ha, not seen adequately addressed. '!he % for the RAC's conclusion on the beach population lasue ,k n
l f%Y-07 '87 14:44 ID:f:RGONE NATL LAB TEL to:312-SrT2-7919 n17? P10 l
$4Pt.~ 16f btbha TM7 are providad in the position paper transmitted from PEMA to the State of New l Hampshire on May ,1987. Details on how this position paper was developed, and a j discussion on the key considerations used by the RAC in arriving at its conclusion are provided in the FEMA respofnse to Revised Town of Hamfpton Contention Y111. 4 Although the RAC has reached a conclusion on the beach population lasue, the RAC still awatts receipt of Information from the State of New Hampshire on the nuniber of translants who would need transportation during an evacuation. Although the number of translents without transportation is expected to be small, this Information has not yet been provided to FEMA. This also appl!as to NUREG element J.10.m as indicated by the RAC review comments on page 87 of RAC review Section I.
State Plan Section 2.6.5 Indicates that New Hampshire rolles on two protective actions for limiting the direct exposure of the general public within the Plume Exposure EPZ. These to protective actions are sheltering and evacuation (State plan, page 2.6-4). The decision whether to shelter or evacuate is based on several variables, including dose reduction factors due to shelterng'(State Planfpage 2.8-81).' Sheltering een apply- - to the permanent resident populition,'ltatitutiohiilltsd persons,' add'trans!ents;"" '*C"W* State Plan Section 2.6.5 (page 2.6-6) Ind! cates that New Hampshire employs the "Shelter-in-Place" concept if sheltering Is the chosen protective sotton. The plan indicates that "those at home are to shelter at home; those at work or school are to be sheltered in the workplace or schoul building" (State Plan page 2.6-4). As Indicated in the RAC review comments (Section I, page 64) on the State plan, the use of publio l l abelters !s not proposed during & Seabrook Station emergency, 'Its only ezooption la the possible use cf public buildings for shelters for translents without transportation. Transtents with transportation and "wlthout access to an Indoor location," including those at beaches and at campgrounds, will be advised to evacuate la their own vehicles. The use of pubtle buildings for sheltering of transients without transportation is acceptable Q since the translents without transportation are expected to be a very small number. The b l 2 _ _ _ _ _ _ _ _ _ . _ . . _ _ . _ _ _
InR-&f-T1 M:4@ !@iM@lD06 Mn. LAB TE' to:312-972-7819 #177 P11 ($8N*N) bipH Nk7 plan (p. 2.6-6) states that 'Public buildings may be set g and opened as shelters for O translents, on an ad boo basts". Because of the potentially large seasonal beach population, specla! precautionary protective actions for the beach population have been establistied by the State of New Hampshire (New Hampshire Plan, NHCDA Procedures, Appedix F), including early 1 precautionary evacuation. The use of public buildings for sheltering of transients w!thout transportation may be implemented on an "ad hoc" basis (RAC review, Section I, page 84). As noted above, the use of public shelters is not proposed during a Seabrook f Station emergency. As noted in the State plan (/ age 2.1-13), precautionary protective y b action such as early closing and evacuation of the beaches will be considered during the period of hem lest beach use, from May 15 through September 15. The use Of precaut!onary protective actions are not the sole means for protection of traralents such b as visitors to beaches and campgrounds. They are, In effect, also protected by the unusually strong containment system at the Seabrook Station. This is described 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 contenuon vm. mesuueu a . unuu lun v1 m, un!!allel= vavl=Lilll i J v. = vl containment fallute at Weobsook. l In unans.1 in ehnitnsina sesfrientt nf snanfal fenillt!st steh of hnfinitAh !)11mlDr L. w, ...J J.11,, (l Ot t. l..JI. t.., thu aktleaplag is 4ks penf assed poeteettnn natinn i w m . ,. , y.e . .. w ,,. . um o ...... - ~ . J L. L . ,. L, 1 .,.L .I., . . . L ..I t . take into account tne sneltering protection factors for spedal favilities (RAC review, 5.v1!vn I, v.a. 49). A .v.vt.1 t&Wlatl6n af spaalfla pratantim fastses top scoh of the awam = y.. .. m . . .. ... . .. , . .. . . .., . ..,,.., .... ., ,, . ,,. O - 1 i '.- iii i ii i ii i ii a =. i ii rii i ritii (Fig. 3.6-7) now properly reflects the decision-making process for the election beWeen b
my-0 ' 14:26 ID:FRGCHE MTL LA9 TEL N3: 312-972-7819 up"? Pg g . sheltering and evacuation, and that the treatment of instituticaalized is now adequately O detailed. The State Indicates that the tabulation of specifle abanering protection factors referenced above (Table 2.6-3 of State Plan) is only for special facilltles such as health care facilltles and Jalls for which independent determinations of appropriate p$otective actions are made during an emergency (see Sta,te response on page 91 of RAC revlew Section I). The State ind!' cates that "other types of special factitles such as schools and day care centers will follow the protective action recommendations prescribed for the general population." The State continues that the "proteettre setton recommendation process uttilzes conservative sheltering protection factors for general population deelston-making." Sectlen 2.6.5 of the State Plan now includes a generic external sheltering futors table which shows the levels of protection that can be expected from varlous building types in the EPZ (Table 2.5-4, page 2.6-10 of the State Plan). O T.-2 eer::in r:i'se Ti * 'p' h ; rf , ,- - j ,ygf g ji:g ;,g 3 7g ; e 4 O n N'
._ y - _ __ _ _ _ -
- . , m, e v, w.w m.mmtre umw.-- a at.wnrress .2- /es m braf/ 3-4 97 AMENDED NECNP CONTENTION RERP-8 FEMA Response FEMA has addressed NECNP Contention RERP-8, and its basis that there is no l
. reasonable assurance that sheltering is an adequete protective measure for all members j of the public who may need it, by applying Planning Standard J (Evaluation Celterla 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 l l the RAC revlow det d , and the RAC position paper en the beach popu'ation l Issue transmitted to the State of New Hampshire with FEMA letter dated re-Syg TinMAV .t.... . O.12 tsaut. Oy a siftsally, TTH ele seerlene es,e sm anta inn thn Unta i 1 if I* Ill lI Illi II till 111111 Ill 11111llll II IIIllfl ll (( II II Il R[ld l} [lf Section I. O <=ma reiieo on sne roiiowins occu ni >n i rno< ,- - ...- ,#- Issuer Revision 2 to the New Hampshire,. State plant .and.ibe. Applicant's Motion;for. ,_ lhim a ssil tilsalsillan.af Nf('MHfontflntinn.fIflat litistl girnh41.1H7 , ,g. ,.; g _ uma uu.. aus yn :-v. .u uuvi u..uvi . v. v.v.lJ.J I,, ,l. .LL L .,111 im noted later In this resonnne, thin mining Information consists of the number of transients who would nood tsantportettnn diming an svenustion State Plan seetton 2.6.5 Indleates that New Hantpshire telles on two proteettve actions for limiting the direct exposure of the general public within the Plume Exposure EPZ. These two protective actions are sheltering and eveeustion (8 tate Plan, page 2.6-4). The deelslon whether to shelter or evacuate is based on several variables, including dose reduction factors due to sheltering (State Plan, page 2..-19). Sheltering enn apply to the permanent resident population, Institutionalized persons, and translents. O sute ran .e ta.n i... c,ase s... nndicates that x.w Hampshire empare the Shelter-in-Place" concept if sheltering is the chosen eroteettve action. The plan 65
/ .
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r$v-07 '87 14:47' 10:MGONtE NATL LAB ~TEi ~ N0: 317-DT@l9 77 4
, Q gCAIP-458P 9 Ptc 97 indicates that "those at home are to shelter at homes those at work or school are to be O aheltered in the workplace or school building" (State Plan page it.6-8). As indicated in the RAC review comments (Section I, page 64) on the State plan, the use of public shelters is not proposed during a Seabrook Station emergency. The only exception is the possible use of public buildings for ahelters for transients without transportat!on.
Transients with transportation and "without access to an Indoor location" will be advised to evacuate in thelt own vehicles. The use of public buildings for sheltering of transients vithout transportation is acceptable since the translents without transportation are expected to be a very small 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 of planned protective measures, and pending O receipt of inf-mation f- the state on the number of traesients who wooid need transportation during an evacuation. The RAC has recently. concluded that the beach - . population can be appropriately protected by implementing provisions.cf .the current. m :- (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 addressed. The bases for the RAC's conclusion on the beach population issue are providad in the position paper transmitted from FEMA to the 8 tate of New Hampshire on May .1987. Details on how this pos! tion paper wu developed, and a discussion on the key consideratlons used by the RAC in arriving at its conclusion are provided in the FEMA response to Revised Town I of Hampton Contention Vll!. Although the RAC has reached a conclusion on the beach populationlasuh D b[e RAC still awalta recelpt of Information from the State of New Hampshire on the number of translents who would need transportation during an evacuation. Although the number of translents without transportatlon is expected to be small, this information
- 2. , 1
uvimmvinsve m. miweF#ren=rs - ggW ,.,,.: , [ p(c.M$ M t/. )ny-moaleje . rs gg., '97 f has not yet been provided to FEMA. T.'.is also applies to NUREG element J.10.m as Indicated by the RAC review comments on page 87 of RAC revlew Bection I. Because of the potentially large seasonal beach populatten, special procautionary protective sections for the beach populat!cn have been established by the State of New 1 Hampshire (New Hampshire plan, NHCDA Procedures, Appendix F), including early precautionary evacuation. The use of public buildings for sheltering of translents without transportation may be implemented on an "ad hoc" basle (RAC review, Section I, page 1 64). As noted above, the use of public shelters is not proposed during a Seabrook Station emergency. As noted in the State plan (page 2.1-13), precautionary protective actions such as early closing and evacuation of the beaches willbe considered 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 visitors to beaches and campgrounds. They are, in effect. also protected by the unusually strong containment system at the Seabrook Station. 'Dt!s is described in detall in the RAC position paper on the beach population lasue transtnitted to the State on l May .1987, and is also summarlzed in the FEMA response to Revised Town of Hampton Contention Vll!. Included !s a discussion of the negligible probability of prompt containment failure at Seabrook. In regard to sheltering residents of spec!al facilities, the State lodicates that sheltering is the preferred protective action (State Plan page 3.6-7). FEMA concludes that the plans have been adequately revised to take lato account the sheltering peotection factors for special facilities (RAC review, Section I, page 87). A spoolal tabulation of specific protection factors for each of the faolllties la present in Table 2.6-3 of the State plan (RAC review, Section I, page 67). The RAC review (Section I, page 88) Indicates that the flow d!agram in the State plan (Fig. 2.8-7) now Q properly reflects the doulutun-meklug yeuuvus for 11w wievtloa tmtween sheltering and b 3 . _ _ _ _ _ . - - _ _ . - -
- W 1 (NBCMP- And}P
- 3. .
evacuation, and that the treatment of institutional! zed pomons !s now adequately The State Indicates that the tabulation of specific shshering protection factore referenced above (Table 2.6-3 of State Plan) Is only for specla) facilities such as health care facilities and Jalls for whleh Independent determinations of appropriate protective actions are made during an emergency (see ' State response on page 91 of RAC review Section I). The State Indicates that "other typer of special fact 11tles such as schools and day care centers will follow the protective action recomtuendations prescribed for the general population." The State continues that the "protective action recommendation process utilizes conservative sheltering protection factore for general population decision-making." Section 2.6.5 of the State Plan now includes a generic external sheltering factors table wh!ch shows the levels of protection that can be expected from various building types In the EPZ (Table 3.6-4, page 2.6-10 of the State Plan). l 1 l O 52 4 -- ~- _ _ - -_ - _= = = = . _
l ]
/,pa nney[o, -
UNITED STATES y p "va ( ,g,s' NUCLEAR REGULATORY COMMISSION b # REGION I
- t,
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,,*,..e 631 PARK AVENUE KING OF PRUSSIA, PENNSvLVANIA 1H06 A4 N l (V~h JUN 04 gggy l Edward A. Thomas, Chairtnan Regioral Assistance Comittee i Federal Emergency Management Agency 1 John W. McConnack Post Office and Court House j Boston, Massachusetts 02102 '
1
Dear Mr. Thomas:
1
Reference:
RAC Coments on Transient Beach population for Seabrook Station 1 Subsequent to our April 15, 1987 meeting of the Regional Assistance Comittee i en 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 document, the Board concluded that the current studies provided by the { applicant did not provide a prima facie showing to warrant the granting of the 1 one-mile plume EPZ petition. The Board deliberately left open the possibility ' of granting the petition if convincing inforr.ation~ 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 recomend that the RAC not reference these studies or specific contents in our present consid-O eration of the beach population issues. With that in mind, I am proposing reviseo sections for the RAC report. These proposed revisions involve pages seven through ten. For your convenience, a clean, rewritter, copy of the RAC position paper incorporating these revisions is enclosed. Should you have any questions concerning the above, please contact ce at FTS 485-1213. I would be very happy to meet with yot, and/or the RAC to discuss my response. M l Robert J. Bores A Technical Assistant Division of Radiation Safety and Safeguards
Enclosures:
As stated bec w/ encl: W. Russell J. Allan J. Gutierrez O" W. Kane W. Johnston T. Martin R. Bel, lamy R. Bores Q'
1
]
O l rRotEction or NEw snessiRE 8EACs eorutations l BACXGROUND The requirtsnents for emergency preparedness stem free 10 CFR 50.47(a)( (2), which state that except as provided in 10 CFR 50.47(d) licensing of a facility for operation up to 51 of rated power (relative to
), no operating the NRC that 'there is reasonable assurance that ade can and will be taken in the event of a radiological ecergency.
whether state and local emergency plans are adequat the adequacy and implementability of the licensee's on The FEFAplans. emergency finding is prirarily based on the review of the state and local . in considering implecantec. whether there is reasonable assurance that t Paragraph b of 10 CFR 50.47 requires that the onsite and offsin standards. planning ecergency respons(e) plans for nuclear pcwer reacto HUREG 0654/TEFA-REP-1, ' Criteria for Preparation and Evaluation of Ra Erergency Response Plans and Preparedr.ess in Support of Nuclear Powe O 'oca1 issued was to provide a cocinon reference and guidance source for state and 9overaceats aad 2 $ cease > ia the deve1oReaat or eoerseacy 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 pli The planning basis adopted by NRC and FEMA for erergency preparedness ar nuclear pcver plants was taken from NUREG 0395/ EPA 520/178-016, ' P Basis for the Development of State and 1.ocal Governcent Radiologica Response Plens in Suppcrt of Light Water Nuclear Power Plants".
'The overall objective of the emergency response plans is to provide dose savings (and i some cases. icrediate life savings) for a spectrw of accidents that could produce offsite doses in excess of the PAGs" (NUREG 0654).
it attempted to identify the boundarthat the olanning basis range from t of potential accident consequences, y parameters based on avaiiable knowledge teristics (source ters). timing of releases, and release charac-PAGs do not equate withItloss should of lifebe or noted even a that healthdoses in excess of the EPA hazard. The PAGs were intended T r use by protective action decision rakers in arriving at a balan between radiation constraints to that action. risk and that of taking a protective action in the absence J' O W) W a i
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- Enclosure g
gLLJ d 4 l UNITED STATES CF AMERICA i NUCLEAR RECUR.A'ICRf COMMISSICH l
. l BEFORE 'IHE A'IOMIC SAFETY AND LICENSING BOARD
)
In the Matter of )
)
l Public Service Co. of New Hanpshire, ) Ibcket No. 50-443-OL i et al. ) 50-444-OL I
) Offsite Emergency I (Seabrcok Station, Units 1 & 2) ) Planning Issues l
) 1 l
l l FDiA PRE-FILED TESTIKNY O The Federal Emergency Management Agency (FEMA) hereby serves on the l parties to this proceeding its prefiled testinony on contentions on the New Hanpshire Radiological Emergency Response Plan. FEMA notes, for the record, that its review of issues addressed therein is ongoing. s mi A ;
<0 /L.1 . ., % Q* K ,
H. Joseph Plynn l Assistant' General Counsel Federal Emergency Management Agency l Washington, D.C. Septenber 11, 1987 l O fr
e e 1
. i UNITED STATES CF AMERICA NUCLEAR REGULATORY COMMISSICN BEFORE 'IHE ATOMIC SAFETI AND LICD4 SING BOARD l /
l l
) l
~
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
)
DIRECT TESTIMJNY CF EDARD A. 'IHOMAS, EURRD A. TANZMAN, AND BRUCE J. SWIREN CN 'IHE NEN HAMPSHIRE RADIOI4GICAL EMERGDiCY RESPONSE PUN PRESENTED CN BEHAIE CF 'IHE FEDERAL D4E%iENCY MANAGEMENT AGDCI j l The witnesses whcm the Federal Emergency Management Agency (FEMA) is l sponsoring on the admitted contentions having to do with the New Ha@ shire n
\ /
Radiolcgical Emergency Response Plan (NHRERP) in the Event of an Accident. at Seabrook Station are: Edward A. Thcmas, Chief Natural and 'Ibchnological Hazards Division Federal Emergency Management Agency Region I Boston, Massachusetts i Edward A. Tanzman Energy and Environmental Programs Attorney Energy and Environmental Systems Division l Argonne National Laboratory ' Atyonne, Illinois and Bruce J. Swiren Emergency Management Specialist Natural and Technological Hazards Division Federal Emergency Management Agency Regicn I Boston, Massachusetts O 6a
Our Statements of Professional Qualifications are attached to this Direct I Testimony and are incorporated herein by reference.
In general, the putpse of our testirony is to address the admitted contentions and supporting bases. As explained below, our testimny is limited to certain contentions and bases. As noted in'the Statement of position, the Nuclear Regulatory Ccmnission (NRC) is sponsoring the testinony of Dr. Thcrr,as Urbanik on certain contentions havire to do with the validity of Evacuation Time Estimates, and so FD% is not sponsoring testi:reny on those contentions, namely
- Revised Ha@ ton Contention III to Revision 2 Revised Hampton Contention VI to Revision 2, Basis A (Rev.1) SAPL Contention 18 SAPL Pevised Contention 31 SAPL Contention 34 SAPL Cor.tention 37 . FD'A considers its statement about the transient beach population largely to involve matters of policy. Edward A. Thcxras is the FD% official in Begion I who is responsible for explainirs, applying, and carrying out FD%'s policies as they apply to the Radiological Emergency Preparedness Program. For this reason, Mr. Thmas is the single witness as to those contentions having to do with tha lack of shelter for the transient teach pcpulation, namely: Revised Harpton Contention VIII to Revision 2 SAPL Contention 16 NECNP Contention REBP-8 Durirg the period of time when Bruce Swiren was employed by HMM Associates, he worked on obtaining revised or renewed I4tters of Agreement O
)
(o3
----a
_ .q.
c (3 L/ frm hospitals, ambulance orpanies, towing ccmpanies, and bus empanies. In order to avoid even the possibility of the appearance of a conflicc of interests, Mr. Swiren has removed himself as a witness on contentions and bases having to do with these letters of agreement and the determination of the number of Teamsters to be made available by their employers in the event of an energency. For this reason, Edward A. Thcmas and Edward A. Tanzman will testify on those contentions and bases, namely: Revised Hanpton Contention IV South Hampton Contention 3; Bases 1, A, B, C, E, ard Further Bases A.l. , A.2. , and B Town of Kensirgton Contention 6 NECG Contention NHLP-2, Basis D NEXNP Contention NHLP-6, Bases d and e and HP-1-e SAPL Contention 15 SAPL Contention 25 All three of us will address the remaining admitted contentions and bases. The attached document entitled "Current FEMA Position on Admitted Con-tentions on New Hanpshire Plans for Seabrook" (hereinafter referred to as the "Statement of Position"), dated June 4,1987, has previously been made a part of the record of this case. That Statement of Position was attached as Apperdix A to the Response of the Federal Emergency Management Agency to Massachusetts Attomey General James M. Shannon's Off-Site Emergency Preparedness Interrogatories and Request for Production of Documents to FEMA (Set No. 2) and is herein identified as Exhibit A. The language of the contentions and their bases is set forth in that Statement of Position and so is not repeated herein. Exhibit B to this testinony, entitled "Current FEMA Position on South Hanpton Contention 8 and NECG Contention NHLP-4", t nd dated June 26, 1987, is a supplement to FEMA's Statement of Position and is also a part of the record of this case. b
-4 *} I I
d Exhibit C is a ccpy of a letter dated August 7,1987 frcm H. Joseph Flynn to Thmas G. Dignan, Jr. It reflects FEMA's positicn on the issues discussed
/
therein. We individually incorporate by reference those portions of Exhibit A, B, and C which are pertinent to our respective testinony. We positions which FDR has taken on the NHRERP, the exercise of the NHRERP, and the contentions which this Atcmic Safety and Licensing Board l l l has admitted were arrived at through a collegial process of review by FEMA's Regional Office in Boston, consultation with FD%'s Regional Assistance V Ccmmittee (RAC) and Argonne National Laboratory, and review by FEMA's _-State and L: cal Programs and Support Directorate in Washington, D.C. l Re RAC is an interagency ccmittee constituted in each of the 10 standard l Federal regions pursuant to 44 C.F.R. @351. The ecmittee is ccmposed of representatives of FEMA, the NRC, the Envitonmental Protection Agency, the Derartment of Energy, the Depart: rent of Health and " unan Services, i the Depart: rent of Transportation, the Department of Agriculture, the Department of Ccmerce and the Department of Interior. FDR and the RAC have prcvided ceriments on New Ha:rphire draf t planning for Seabrock dating back to surmissions in 1982. Hcwever, the current plan, which is under litigation, dates back to 1985. In December, 1985, the State of New Hanpshire submitted the NHRERP (Revision 0) to FD%. New Hanpshire submitted extensive changes to the NHRERP (Revision 0, Supplement 1) in February,1986, which included:
- 1. Volume 5 NHRERP, "Letters of Agreement in Support of the NHRERP";
- 2. Volume 7 NHRERP, "Seabrook Station Alert and Notific1 tion System Design Report";
- 3. Evacuation Time Estimate (ETE) Study naterials (Prcgress Reports Nos.1-6) frczn KLD Associates; I
~ - -- - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
. 9 0 1 e
( l
- 4. Revised procedures for the New Hanpshire Department of Pesources' and Econanic Development; ;
- 5. Caq:ensatory Plan cutlining the means used by the State to l protect citizens in towns within the Seabrook EPZ when municipal govenments cannot or will not carry out tasks assigned by the local plan, and; l
- 6. Draft public information material.
The February,1986, revisions were served on the parties on March 11, 1986. The State of New Hampshire filed additional plan changes in April,1986, f (Pavision 0, Supplement 2 of the NHFERP) consisting of the following:
- 1. KLD Progress Report No. 7;
- 2. A revision to the Department of Public Health and Safety (DPHS) l Procedures, including replacement and new appendices to the DPHS Procedures;
- 3. Rockingham County Canplex procedures, including those for the Rockingham Ccunty Nursing Hcme, Rockingham County Jail Facility I and Rockingham Ccunty Dispatch Center; and O 4. Procedures for the decontamination of personnel at the Manchester Decontamination Center, along with Appendix F to those precedures.
A full-scale exercise of the NRRERP was conducted on February 26, 1986. I During the first several months of 1986, FDM and the RAC were involved in extensive reviews of the December NHRERP (Revision 0), the February revisions (Supplements 1 and 2 to Revision 0), and the February exercise. In April, 1986, FDR sent the following documents to the State of New Hampshire:
- 1. FPR's report of the deficiencies observed during the Febru-ary 26, 1986, exercise of the state and local plans to protect the public in the event of a radiological emergency at Seabrook;
- 2. Final Draft Report of the Exercise of the energency plans for Seabrook held February 26, 1986;
- 3. Final review by the RAC of the state and local plans sutmitted by New Hanpshire in Decerter,1985; and
- 4. Draft RAC Review of the state and local plans submitted by New u av= hire ia rehtuary, 1985-O These documents have been served on the parties to this proceeding.
O M
l 1
)
On June 3,1986, the State filed another revision of the NHRERP (Re-vision 1) responding to the ecmtents of the RAC concerning the plan and the exercise of the plan. The ETE Study prepared by KLD Associates, which had recently been released in a final draft, was incorporated into the NHRERP at that time. On June 23 an3 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 docunents described above. On September 8,1986, the State l of New Hanpshire submitted another revision of th' NHRERP (Revision 2, dated August, 1986) addressing the concerns identified by the RAC. FDA subnitted the FDM/RAC Review of Revision 2 of the state and local plans to the State of l New Hampshire on December 12, 1986. This document is the basis for most of the l positions taken by FDn in this licensing proceeding and has also been served Q on all the parties. On April 15 and July 2,1987, the NRC filed FEFA's positions on the parties' various Motions for Sunmary Disposition of Contentions. On June 4,1987, FDA filed its Statement of Position as part of a response to Interrogatories frta the parties. Eis reflects FD%'s current position, even though the State of New Hampshire subnitted a Sunmary of Personnel Pascurce Assessnent for the New Hangshire Radiological Diersency Response Plan in late August,1987, ard additional information in early September. The review pericd for material which a state subnits to FD% as part of a radiological emergency response plan is normally at least 60 days. nese materials are not reflected in this testinony principally because they were not received early enough to have been reviewed by FEMA and the RAC and because the State of New Hanpshire has advised FEA that the material subnitted in September is not part of the lERERP.
38. 4
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NECNP CONTENTION RERP-8 The New Hampshire RERP does not provide a "reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency." as required by 10 C.F.R. 50.47(a)(1). N that the plan does not provide reasonable assurance Nor that the does sheltering plan is an provide "adequate protective measure" for Seabrook. adequate criteria for the choice between protective measures, as required by 9 50.47(b)(10) and NUREG-0654. I II.J.10.m. FEMA PISEONSE to Revised Tcwn of Hancton Contention VIII to Revision 2 (of the New Hamosnire RERP for Seabrook) , SAPL Contention 16, and NTNP Contention RERP-8 These three contentions all deal with what is fundamentally the same issue: protection frcm a radiological release for beach-going population at Seabrook who do not have ready access to any effective form of sheltering. mis 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 ccumercial buildings. Backarcund - This issue has been of great concecn to FEMA frcn our (,) earliest detailed involvement with the preparation of plans and the achieve-ment of a level of emergency preparedness which would achieve our regulatory standard set for that 44 CFR 350.5 of adequately protecting 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 tecember 1985 the State of New Hampshire submitted plans for protecting i the public in the event of an accident at Seabrook to EmA for review pur- l suant to 44 CFR 350. n ose plans were forwarded for review by the Regional ' l Assistance Ccmittee (RAC), an interagency group established pursuant to 44 CFR 350 to both assist state and local government in the development of radiological emergency resgense plans and to evaluate the adequacy of such plans. On Cecember 31, 1985, FmA, as chair of the RAC, requested that the members of the RAC (as well as the other FEA staff who were reviewing the New Hampshire Plans) innediately focus on the issue of the protection of beach pcpulation and the occupants of unwinterized achucdations. His memorandum is attached as Appendix C to this response to interrogatories. Em A Position - Since the time of our Deceber 31, 1985, mmorandum on the subject of the protection of the public on and near the beaches around Seabrcok, the State of thw Hampshire has refined and improved its mergency plans and sutmitted a detailed Evacuation Time Estimate which sheds a considerable amount of light on this issue. We facts relevant to understanding this issue are that: 60
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'f f> 39 s MIX CCerfarICU RC20-8 (Cont.), h m i , 7,.__ _ ,
(1) .n e primary guidance document used by FEMA and the RAC in reviewing
,'g,'d
, /-
off-s ite emergency plans is NUREG-0654, FEMA REP-1, Rev.1, a docunent . jointly developed by FEMA and the NRC. W at guidance a'y g y ' ,'/ document indicates on p.13 that "(t)he range of times between b ' ' ). ,,pg
, ;' f the onset of accident conditions and the start of a major release ,;
., t~
3 J
$ , , '/, is of the order of one-half hour to several hours".-n'~i,s is further clarified on p.17, Table 2 to indicate that (a) the major portion of a release may occur in a time period rangirg
" 2 frcm as little as one-half hour to one day af ter the release tM "
d*5; begins.and (b) that the travel time of the release to exposure 6, G A
.a point can range fran one-half hour to two hours at five miles, g; y hg'N, $ and one hour to four hours at ten miles. g
/ ?/,. % M.3 9.?hm t p a W . $, _
c (2) On peak suTmer days there are thousands of beachgoers in the ~ v ' j (' Seabrook EP2 in areas beginning approximately 1.7 miles frcm f, g 7 3 (F.,the
. plant. He current New Hampshire plans contemplate evacuating thOnan4.housands of beachgoers who have access to no adequate l
I 1
',>j ' (/c' , b
#"2 shelter as a protective action in the event of an accident at Seabrook.
, 0 h ,/ We understand that the plans contain no consideration of sheltering '
'M /' the "day trippers" because on sunmer days when there are a large nunter of these people, it is not possible to find reasonably e #/f'3 '
accessible sholter for them. Were are an additional ntsnber of persons who would be in or have access only to shelter in unwinter-ized cottages and motel rocms. We protection afforded by sheltering in these structures will definitely be less than thatjg'C, afforded by a normal wced. frame house. .- p O (3) ne Evacuation State rime Estimate of New Hampshire for the indicates at Seaeroox pp.10-1 et.EP2 seq.suemieted e that in goedby the a- 4 4 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 k total of frcm four hours and fifty minutes five hours and fifty minutes to evacuate all the population on the beaches from s*% the EP2. In scme situations such as sudden weather following a peak sumner day, the total evacuation time or portions of the EPZ range up to seven hours and fif ty minutes. Herefore, using the standard guidance for the initiation and ddration 1 of radiological releases, aM thrcofrent New Hampshire RERP including ETE, I, C
#g it appears that thousarxis 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. tereforo, until these issues are resolved even if all the other inadequacies and deficiencies cited in the RAC Beviews of the New Hanpshire Plans, and the Review of the Exercise of these plans were to be corrected, ELMA would not be able to conclude that the New Hangshire State and local plans to ! protect the public in the event of an accident at the Seabrook Nuclear R:wer Plant are adequate to meet our regulatory standard that such plans "adequately protect the public health and safety by providing reasonable assurance that appropriate protective measures can be taken offsite in the event of a radiolcgical emergency." (See, 44 CER 350.5(b)). W e 4
_ _ _ -- --._ _ - -- - - mm r em p ,aa l- r
' TaTerdT WtrWrgency wianagement Agency
( Region 1 J.W. McCormack Poet Ofra sad Court House Boston, Manachuutts 02109 8g Mr. Richard H. Strom ) Director, New Hampshire civil Defense Agency - [ I 8 tate office Park south , ;- concord, New Hampshire 03301 h 44g g ,, T4
. Dear Mr. Strom s m}
'/
This is written as a follow-up to our conversation on June 5,1987, concerning the document "CURRENT FEMA POSITION ON ADMITTED CONTENT 10N8 ON NEW HAMPSHIRE PLAN 5 FOR SEABRC0K.' (Hereinafter called Current FEMA Focition.) This document was developed as a part of FEMA's responses to interrogstories in the Seabrook Atomic Safety and Licensing Scard (ASL8) proceedings. Our discussion primarily related to that portien of the Current TEMA Position dealing with the beach population which it found at pp. 38-39 and enclosed with this letter. Before further discussing that particular section, it might be worthwhile to quickly review the history of this filing. The Current FEMA Position was developed as the result of several actionsBoard Appeal including (AsLB) the decision of the Atomic 5 4 sty and Licensing made May 1, 1987, and the subsequent Memorandum and Order issued by the ASLB on May 4,1987. These O actione ine2u4e4 a>ecific re==*at thatfor rEMA 4 veicP and file a position on the contentions admitted litigation in the seabrook proceedings by June 5, 1997. The current FEMA position is, therefore, provided pursuant to the FEMA / Nuclear Regulatory Commission Memorandum of Understanding cited in 44 CFR 350, Section 350.3(e). However, the Current FEMA Position should not r- be viewed as a formal "finding" by FEMA under 44 CPR 350. the Current Regional FEMA Fosition Assistance Ccmmitteeis largely_haasd)upon the FENh_An!(
-proVfd'er to you. The portto C1 review Ns6h were previously with tha hanch population is as the Curient FEMA lasition dealin i C eWThe issue of pro octingtr theN beach Tugantlyt h by EZ population has @g l
[ @ Hampshire, and the applicant Our been an item of discussion between FEMA, the State of New forposition several is yea I based on the guidance provided by NUREG-0654, FF,MA-REP-1 applied to the Besbrook site. We believe that our concern about the protection of the beach population revolves around some rather unusual circumstances which may be unique to seabrook. Demographically, a substantial portion of the peak summer population in the area travel to the beach each day. Unlike other sites we have reviewed, these daily visitors are not identified with a temporary residence or public facility. O
- =. ..
l l-
. d
- In addition, many of the summer residences in th e area are
.([) unwinterized accident than that circumstances dramatically i and found therefore in insulated afford buildings less e eventshelte of an These
! primary protective measures,mpact the acceptability of the two specifically, the information evacuation providedandto shelter. FEMAMore indi evacuation.tido from the beaches would require cates that Evacuatior sD ndAr estimates are not required to meapproximat y 3.5 hours., l The-availability of shelter as aTroptton'ir! aspecift eet some
~
'Yastabgeaking scena,rios is considered e to mitigat the pore some hard tire 3htac.tive-for-e.vanetion.rM6ileve in this case for what is even in the more favorable estientee e ering effective shelter for many othersseveral s amounts thousand to indivi y
on evacuation and sheltering compo. Thus, the information provided individuals that might be involved.unded one another in a mannet of I might add that these but for a number of l'sser scenarios. numbers accident,appa may alter the case as we understand discussions on the subject, . e pastitA yearsnumber which o proposed alternatives which a wide include variety of sources haveIn addition sheltering of the plant, and alternative evacuatien routes, naasonal operatio sheltering is an alternative, we doubt . Although () public or private facilities would be acceptableif the use of existi . 1 to the complexity of the issue.The solution to the proble of alternatives due in the paragrapha numbered 1-3 of page 39However, if the facts s position are shown to be incorrect or are modifiedof the curre position will be subject to review and modificati , then our rEMA will, therefore, be willing to arrange modifications to the New Hampshire emergencyew on asfor the revi necessary. plaof any which the beach might impact evacuation time estimates population. ns foroSeabrook ! assumptions made about accident release timesAny modifica probability, as well as the impact due to duration any, altand schedule for the plant come under the purview . of the NR ered operational C. hearing for reabrook. FEMA will soon be developing its testim is this hearing board that will make tGiven the expected sequence , it of ev evaluation of the' Hew Hampshire plan. he first licensing related allour to parties to the seabrook filing testimony: (a) proceeding if you uscould prior tellIt w State of New Hampshire is considering these facts and (c c c ; (b) if thesteps might change to exercise, options)that would change the factif you are O s.
'2 l
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fMfio ur aDr o n .~ h , 1
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Qwewould,ofcourse,behappytomeetwithyouasNewHampshire continues to explore its options. I hope that all of us can l' continue work togither to resolve this issue and achieve our autual commitment to public safety. ; sincerely, l l
' i.MA Edward A. Thomas Chief Natural and Technological Nazards i Division 1
l l l O O
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l 301 492 7285 Og1987 08:41
,. PC-EASTAEST-W1 tO.002 C04 ~ pg NTION RERPat that adequate protectivThe New Hampshire RERP does not provide 4 the plan does" not as required by le C provide reasonable 40.47f a)(1),ensurs.F.R.
in that ra
*adeguate proteetive measurt" for Seabrook. ace that sheltering la na adeguate criteria fbe the choice between Nor does the by s St.47(b)(15) and NUMEQ-0684. I !!.p?oteetJve measures. plan provide as required I J.10. m.
FtNAnew Ehe Ba>-s RESKNstwepentre to Revised prRP rorTown n seaoreekrJsAPL ef Mamten Conte ti contenttos16o \
, and Nti5!p conten g \
issues These three contentions all deal with Wt is f
'!his have access to unwinterised or other types of group includea both ' ve day-trippers fann population of sheltering.
to thI a lesser doorn of pro condtraction Wich will offervid thcee casseretal O buildings. tection than that offered by standard residen1 , Ba&cetund - j earliest detalTod involvement with the preparation A frtre our ofThis tas meat of a level of emergency preparedness which would plans and th < h standard health andset safety for by that 44 CTRreasonable providing 350.5 of adequately assur prot achieve ou ecting the public protective apergency at the Seabrook helear Power Plant measures can be taken offaite in the eve tance that approp .
. n of a radiological the public in the event of an accident mant to 44 CFR 350. nose submitted plans atforsprot bin tecenter 19 .
em reck to Fr"? fw review purecting I Assistance CFR radiolo 350 to both assist Comittee state and(RAC), local gwerplans wereonal forwarded I rmant in the 6evelopment of plane. the seenborsgical On Decerter amargency responu of the MC31,1385, FD% plans and to evaluate t ; as chair of the MAC, requested that -, the forw Harpshirsimediately Plans)(as well focus on the as,the i other FDR eviewing staff who were r of beiech population and the occupants of unwinterisedssue of' the sencrandura na attached as Appendnx% e to 4atione. this respo Bi ftMA Position - nse to interrcoatories, s an the subject of De $1nce protection the time of of theour public Decenber on , 31,1985 men oratskan ircund seabrook, the state of hw Man;shiro has refiatd neiar the beaches t i plane and sutaitted a detailed Evacuation ned and hge w ed its o understarding thismaount considerable w of light on this issue. time ratimate which are that: The facts relevant I g g, i _ _ _ _ _ _ _ __ _ __ _ _ __..__ _ _ _ _~ _ .__ _ ._ _ ___
JUN 19 '87 08:49 P01 -
;; . , a 3 m09 ro% e FEL GR 4 " n,
. , c ' Mr::P ccNutrict! Ut9-3 (Cont.)
(1) O 22 primarf guidarwe doement used by PtNA and the RAC in reviewing off11te emergency plans is NURZCr0454, rtMA REP-1, Asv.1, a doctrent jointly developed by FEMA and the NRC. Wat guidance deement indicates on p.13 that *(t)he range of times between i the onset of accident conditions and the start of a major relaaes is of the order of one+all hour to several houre'. 21s statment is further clarified on p.17, hble 2 to indicate that (a) the major portion of a release may coeur in a tias period ranging frcn as little as one-half hour to one day after the release ; begins and (b) that the travel time of the rulease to eitposure l point can range fran one+alf hour to two hours at five mi24a, and one hour to four hours at ten miles. (2) Cn peak suurer days there are thousands of be 4 rs in the 1 Seebrnk EP2 in areas beginning approximately 17 miles frse i the plant. De curtwnt New Hagshhre plans conterglate evacuating Yp the many thcusands of beachgoers who have soones to no Wequate
~/ shelter as a protective action in the event od an accident at Seabreck. I M Q ths "F.ayWe urderstand that the plans contain no consideration of sheltering trippers" because co atmner days when there are a large l g c,4 ntet:er of these people, it is not possible to find reasonably l W W- accessible shelter for them. Were are an additional n6anber of l persons who would be in or have access only to shelter in umrinter- !
ised cottages and notel recms. Se protection afforded by O sheltering in these structures vill definitely be loca than that . afforded by a nomal wood free house. . 4T i (U me tvacuation Time Eatinate for the sesbrock EF2 eMtted by the State of How Hm$4 hire indicates at pp.101 et.aeo that in good 1 l weather when the beaches an at 60 to 100 #' vill tAke three__ and an -hau ** * +-* percent of espe, city it the w hea. and a total of frun four hours and fif ty minutes to fies hours and fitty minutes to evacuate all the pop;1ation on the beades from the EF3. In acme sitbations such as sudden had weather following a peak stamer day, the total evacuation time for portions of the EF2 range up to seven hours and fif ty minutes. 1terefore, uniro the standard guidance foc__ths initiation and duration of radiological releases, and the current New Hangehire RR3P including E3, it a;paars that thousands of people c - accident at seabrook involving a majo_cy,1d r release of beradioactivity unadie ta imava wff durW an ; adequata shelter fce sa noch as the entire duration of that rteese%d, J . i mentore, uhta these issues are resolved even if all the other inedegaecies and deficiencies cited in the RAC ** views of the New Haugehire Flane, and the Review of the thercise of these plans were to be correctode FSE would - not be able to conclude that the New Mar @ehire State and local plans to protect the public in the event of an accident at the Seabrook thclear , fewer Plant are adequata to poet our tugulatocy standard that such plars tely protect the public health and safety by pcwiding ressenable surance that appwpriate protective asacures can be taken offaite in the , event of a radiological emetgency.' (jge,, 44 CFR 350.5(b)). g I
\
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I
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.,._3 Federal Emergency Management Agency l O mesio.1 3.w. ucco,-aci e orr- a o coun nouse Boston, Massachusetts 02109 l
// /d July 2,1987 l l
l VIMDDR E POR: Pegional Assistance Ccrr.ittee (PAC) l R!diolcgical E,7rgency Preparedness Task Force: 1 I FROM: Thaard A. Thonus / Il '
' PAC Chairman g]f [j
?
SUMECT: h PAC Review of F Se f-Initiated Reviea' of Pilgrim NPS DZ Please review the attached FD% self-initiated review and sutnit your ccrxtents no later than July 10, 1987. Bere are four documents attached: l
- a. Meno to Dave Mct.cughlin, FDa Beadquarters i
- b. FENA's Draf t Interim Findirg on DTergency Preparedness in the Pilgrim O c.
sPs =z F&.A's Draf t Analysis on the July 15, 1986, Pilgrim Petition l
- d. FEMA's Draf t Ccmments on the ReInrt to the Governor l
Please plan on atterding a RAC neetirg here at 10:00 A.M. on July 30,1987, to discuss the following:
- a. Massachusetts Prcposal to Expand the Pilgrim NPS DZ
- b. A Revised FAC Pcsition on the Seabrock Beach Menorandum As a Result of the Change in NRC's Position
- c. We Final Version of FDm's Self-Initiated Review of the Pilgrim NPS DZ.
Your cooperation is very much appreciated. Pleas + call Jac:. D:lan at FT5 223-95f 2 if yx n+ef an assistance. O
- v o' AGENDA O '"
c RAC MEETING JULY 30, 1987 - 10:00 A.M. ITEMS FOR DISCUSSION: . , ti. Status Reports
,1 W4
- t
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/ T C N
- 1. Up-date t on status of "350" process for ermont, Nev: Hampshire and Maine.
G/lp $ fR-l 2. Status of "Annual Letters of Certification" from all New England States. ALC,Q/s- 1%.
. 3. Review of Maine " C Ingestion Pathway Plan for Seabrook Station et
[ a. Argonne Coments y,y J 4. Up-date on Pilgrim Nuclear Power Station. - N W ~ .. ----- 411. Ccming Workload {l . p y) v
' 4j' .-
kJ 5. Seabrook Station Hearings Dates (see attached schedule). , y2"
- 6. Possibility of necessity for RAC support durisig Seabrook Hearings.
- 7. If New Hampshire submits or up-dates their plans it will require 9AC assistance.
- 8. If Utility submits Massachusetts plans for Seabrook Station it will require RAC assistance. ( LeRO ;MM)
- 9. -
Possibility and Rowe. of revised Massachusetts Plans for Ptigrim,ft,w " Vermont m,.' ' /' Yankee)
- 10. Possibility of RAC Review of Utility submission for Pilgrim.
lua. fw 2, Bm $1&st &w %,.m V 5 111. Issues for Meetings (/
- 11. Pilgrim EPZ Expansion. ' H
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4, p r / d J- p
- 12. Maine Yankee EPZ Expansion. /hy 1 J.4
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h3. Maine @ Ingestion Plan _ Review M bb g,J h+ 1
- 14. Seabrook Beach Population. +
]% 'k N"" '
.el/>/.Cffr &W j'f\ Fj & ,.sin ' qS t e A J
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