ML20207C460
| ML20207C460 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/19/1988 |
| From: | Bores R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Eric Thomas Federal Emergency Management Agency |
| References | |
| OL-S-006, OL-S-6, NUDOCS 8808090231 | |
| Download: ML20207C460 (24) | |
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$-K s.c 'h NUCLEAR REGULATORY COMMISSION
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c 631 PARK AVENUE xiNo or Pnuss A. PENN$YLVANIA 1H06
'hNRC mn4 *88 JLL 19 PS :37 Edward A. Thomas, Chaiman Regional Assistance Comittee -
.f Federal Emergency Management Agency f0Ck. . .ib 6 ~.NEi.
susc8 John W. McCormack Post Office and Court House Boston, Massachusetts 02102
Dear Mr. Thomas:
Reference:
RAC Coments on Transient Beach Population for Seabrook Station subsequent to our April 15, 1987 meeting of the.kegional Assistance Committee on the above subject, the Atomic Safety and Licensing Board i: sued its MEMORANDUP 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 cf the one-mile plume EPZ petition. The Board deliberately left open the possibility of granting the petition if convincing infomation'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 recomrend that the O r^c aot re< reace these steeses or spec $<4c coateats ia cor preseat coasie-eration of the beach population issues.
revisee sections for the RAC report. These With that in mind, I am proposing seven through ten. proposed revisions involve pages For your convenience, a clean, rewritten copy of the RAC position paper incorporating these revisions is enclosed.
Should yow have any questions concerning the above, please contact r.e at FTS 486-1213.
response. ! woulc be very happy to treet with yot, and/or the RAC to discuss my Robert J. Bores -A Technical Assistant Division of Radiation Safety and Safeguards -
Enclosures:
As stated w' s new comW D9ctNo.i -Offigal Ein. No, b
bec W/ encl: F. tne mattu of h6 T4 I W. Russell co V IDENT!FIED V
. ut rreZ :Mt RECEIVED W. Kane b m nct F. EJECTED
. ohnston 2W T. Martin 8808090231 880519 c -
R. Bellamy PDR ADOCK 05000443 (->- : DATE h' [(1 .
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O PROTECTION OF NEW HMPSHIRE,8EACH POPULATIONS The requiresnents for emergency preparedness stem free 10 CFR; (2), which state that except as provided in 10 CFR 50.47(d) (relative licensing of a facility for operation up to 5% of rated pewtr), no license the NRC thatfor 'there a nuclear pcwerassurance is reasonable reactor that will adequate be issued protec unless a fin i
base its finding on a review of the FEMA findings an The NRC will !
whether state and local ee.ergency plans art adequate and whether th) reasonable assurance that they can be irnplerented '
The FEPA finding is prir.arily based on the review o emergency plans.
in considering implecentee. Paragraphwhether b there is reasonable assurance t of 10 CFR 50.47 requires that the onsite and offsitestandards.
planning eeergency respons(e) plans for nuclear power re O NUREG 0654/FEFA-REP-1, ' Criteria for Preparation and Evalua Erergency Response Plans and Preparedness in Support of Nuclear was issued to provide a comon reference and guidance scurce for state and ,
local goverrc.ents and licensees in the developrent of ecergency response plans and preparedness for response to a radiological ecergenj for preparedness.
and FEMA, kRC and other federal agencies for use in the rtview of th nuclear pcmer plants was taken frce NUREG 0396/ EPA Basis for the Developcent of State and local Goverreen/1-78-016, ' Planning Response Plans in Support of Light Water Nuclear t Radiolo Pcwer Plants' gical Emergen objective of the emergency 'The overall life sayings) forresponse a spectrVF plans is to provide dcse savin some cases irrediate produce offsite doses in excess of the PAGs" (NUREG 0654).of accidents that it attempted to identify the boundarthat the planning basis s and range from of potential accident consequences, y parameters based on available knowledge teristics (source ters). timing of releases, and release charac-PAGs do not equate with loss of life or even c health hazardIt sho The PAGs were between radiation risk and that of taking constraints to that action.
nce ence of a protec O
Enclosure
o 2 -
O Relative to the adequacy of erergency preparedness for the Seabrock beach population.
s i tua tion. .NUREG 0654 elecents J.9 and J.10 appear to be pertinent to the I
Elerent J.9 states, in part, that each state and local plan must establish tive action guides andforother a capability implecenting criteria. protective measures based upon protec-feplerent protective measures shall include Element J.10 states that these plans to in part: aaps showing evacuation routes and areas, relocation (reception) cen,ters and the population distribution around the nuclear facility by evacuatien areas; the means to notify all segeents of resident and transient population; the reans for pro-tect'.ag persons whose robility r.ay be impaired; the rearts of reloca*. ion reception centers / host facilities; projected. traffic capacities of svacu;ation routes under erergency conditions; control of access to evacuated areas and organizational responsibilities for control; identification of and r.eans for dealing with potential impediments to use of evacuation routes and contingenci ceasures; tire estfrates for evacuation of various sectors and distances based on a dynamic analysis; and the bases for choice of recoenended protective actions for the plure exposure pathway during erergency caditions, including consideration of local protection available and estimated evacuation times.
REYlEY OF NEY HAMPSHIRE PLAN, REYlS!0N 2, AUGUST,1986 J.9 O -- The RAC review of eierent J.9, the establishrent of capability for implereatias protective measures, for both the state aad locai ievei plans, has indicated that no apparent action was warranted by the State at this time for this element. This eierent was rated ,
' inadequate
- for thepopulation State, hcwever, (
resolved the "beach issue' because the RAC had not yet the subject of this document l New Hampshire is also currently reexam,ining 411 ecergency resource . l needs and act'a protective the resource availability and distrib. tion to support implerentation.
The resource needs and availability NF study. acea will be reviewed by the p.AC after ccepletion of the Based on the RAC and my examination of the plans and preparedness for the beach population and those individuals in unwinterized housing, I conclude that these populations can be appropriately protected by implecenting those provisions of the current NH ecergency plans.
this area that has not been adequately addressed.There appears to b J.10.a -- The RAC review of eierent J.10.a relative to beach population l protective action implerentation, i.e., the raps of evacuation .
both the State and local plans, o reveal no (An inadewacies. ro
' inadequacy" was identified with re mental sampling locations; however, gard to the map of the environ-population protection c4asure implementation.this is unrtlated to beach i fications were _recocr. ended for bus route raaps. Several minor clari- ,
the beach population, this' eierent appears to be adequate,Hcwever, rela i i
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O J.10.b -- The PAC review of element d.10.b. maps showing population distri-bution by evacuation areas around the nuclear facility, indic' ate no iriadequacies for either the State or local plans. No actions were required of nor recorrended to the State for this element.
J.10.c -- Relative to J.10.c. the neans for notifying all segments of the population, the RAC left the evaluation of the State portion of this I element 'open* pending completion of the FFERIP-43 (now FD%. REP-10 Nov. 85) review of the alert / notification system. For the local plans this element was rated ' inadequate" because details were not provided relative to provisions for identifying siren failures and for providing backup notffication in those instances of identified siren failures. It should be noted that this inadequacy was beachgeneric population. for all town plans and was not applicable only to the The physical siren system and the administrative procedures, plans and means for alerting and notifying the public appear to be in place and adequate.
Provisions for early notification of beach populations with both siren tones and voice message capability are in place. The alert / siren system can be activated on an individual siren basis, in ,
i groups, or as the entire system to provide flesibility to the Q decision makers to acccmodate the circumstances of the event.
J.10.d -- Relative to J.IO.d. the neira for protecting persons whose mebility is impaired, the PAC identified no inadequactes at either the State or local level. Provisions were found adequata for health care facilities, Rockingham County Jail, schools, etc. Relative to
' individuals with special needs", bewever, the RAC left this item ,
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'open* pending a review at a future date by FDM of the lists of such special needs individuals. This open item is generic to the entire EPZ and is NOT unique to the beach population. i
)
The PAC also recccrended that the protection factors for special facilities be considered in any K! administration decision as they are when considering evacuation of these facilities. (The current provisions use no designated protection factors for special facil-ities when calculating projected thyroid doses for purposes of K!
administration decisions.)
j J.10.e -- Element J.10.e, provisions for use of XI, is not applicable to the beach population, at least not in any unique sense. Therefore, no evaluation is considered here. The PAC rated this element 'ade-quate".
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J.10.f -- Element J.10.f. decision making for use of K! is not directly applicable he re. to the beach population and, therefore-~Ts not conside The MC rated this element ' adequate', i 1
J.10.g -- Relative to J.10.g. the rieans of relocation, the UC found p visions to be "adequate' at both the State and local levels.
The MC did, however, have a nurber of recoesnendations in this area relat to plan and procedure inconsistencies in the bus and arbulance the nechanism for determining precisely the number o These inconsistencies, howeverpersons to be accoernodated by th were judged _not to result in a, lack of resource provisions tow l adequately accormodate those needing transportation.
J.10.h -- Relative to J.10.h. relocation centers, the MC found that pr for reception centers and host facilities wert ' adequate".
tional needs or recoceendations were identified. No addi-J.10.1 -- Relative to J 10.1, projected traffic capacities of evacuation routes, were provided. the MC indicated that the appropriate traffic capacity data O No inadequacies were identified for this element.
0.10.j -- Relative to J 10.j, control of access to evacuated areas o found no inadequacies. , the MC provisions to perfore this function.The State has responsibility and adequa workers and access logs.for this element concerned radio J.10.k -- Rela tive to J.10. t , i dentification of and means for dealing with potential irspediments to the use of evacuation routes, the MC found no inadequacies but did have one additional recocr.endation to be considered by the State for possible improvement.
Inventories of found to be ' adequate". equi;> ment, procedures and letters of ag J.10.1 -- Relative to J.10.1, evacuation tire estimates, the MC has rev the 'Seabrook Station Evacuate Time Estimate Stud 'y" (Vol. 6 of the RERP) and concluded that although the study was I essentially l adequate' in terir.s of femat, there still exist a number of technical issues that are of concern and need be addressed.
technical concerns can be grouped into several areas:The bulk of these tions" were generalltimes appear to be overly the evacuation in that th pessimistic -
data or conditions; yinconsist utilized whenever there were uncertainties in encies in data or results were not 1 0 clear; and r.aps and tables had some inconsistencies !
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1 It should be noted that the purpose of Evacuation Time Estimates '
(ETEs) is not to provide data showths that any or all areas can necessarily be evacuated prior to plume arrival, but rather to provide the decision makers with the best estimate of times needed to evacuate a given area (s) under the circumstances such that the most appropriate decision can be made relative to uttether to evacuate an area (s) and the timing of such recosmendations.
J.10.m -- Relative to J.10.m. bases for choice of protective actions for the plume exposurt pathway, the RAC left this ites 'open', citing element J.9 in its coerents. No specific actions were asked of nor recom- l rended to the State to resolve this issue. As with J.9, there appears to be no unique problem associated with the beach populations which has not Fiien adequately addressed by the NH plans.
Sumary - In reviewing the RAC coments relative to the adequacy of provisions for being able to protect the beach population, only element J.10.c was lef t "inadequate" (lack of detailed provisions in local plans concerning the identification of siren failures and backup notifica-tion capability). Element J 10.d was left "open' pending FEMA review of lists of ' individuals with special needs'. This item is not O specific to the beach population but is generic to the EPZ. Elements !
J.9 and J.10.m were lef t "open', basically awaiting RAC resolution of the ' beach population issue', but citing no specific inadequacies.
As noted above, no' additional or unique actions appear to be required to adequetely protect the beach populations. Element J.10.1, although rated ' adequate", can be conndered 'open" pending the provision of additional clarification of data / assumptions /results in the evacuation time study. Overall, there appears to be no identified technical problem which has a significant potential for precluding adequate protection of the beach populations (including those persons residing in unwinterized shelters).
ADDITIONAL PLAN DISCUSSION C454 criteria (after RAC cowents are resolved) in This the generi rieans that the plan should be adequate to provide reasonable assurance that public health and safety can be protected during a spectrum of emergency scenarios.
the offsite land uses and demography.In addition, particular attention was high by seasonal a number of organizations. populations have been studied in depth over a number Volume 6 of the KH RERP, Seabrook Station Evacuation Tire Study, incorporates many of the results of those studies, expands other areas. on other studies and provides additional data and clarifications in Q attention was focused on the beach areas, the seasonal pop of conditions in all were examined in this study). evacuation durin For surner accident
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scenarios, the evacuation tine estimates for the beach populations ranged from about 2individual evacuate hours4reas andhas10beenminutes given. to about 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and 20 minute Steilar evacuation tire estimates 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 20 minutes to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 40 minutes according Again, to th ethese vacuationstudies times.tended to raximize parameters in the direction of increasing ua tions. ) (The more likely situation would involve more rapid evac.
As noted earlier, the ETEs are required to provide the decision of the tic)es likely to be needed to evacuate a given ar circumstances at the tine of the accident. This inforvation is necessary to make the opticum recorrendations for adecision relative to the type and timing of protective action given situation.
The Statepopulations.
t.he beach and local plans include rany special considerations for protecting Some of those considerations are listed below.
1.
public access to the beach at the Alert erergency At this class classification level, no offsite action would be ordinarily warranted to protect the public, tire to clear but its or the beaches consideration here would provide additional prevent addit )
beach, just in case the situation worsens.ional public access to the O te.ersency c, ass 4rscatioa, one cuid oreinar11Note: Even at the Site Area tective actions would not be necessary to protect the public.7 excect that offsite pro 2
An alert and to provide sirennotification coverage. system has been installed with the beach areas j The strens can be activated individually, in selected groups or as the total system, can be rotated for better cover or ins fixed in any direction, and can also carry voice ressages and erargenc t ruc tions.
tow n. The system has backup activation capability locally in each 3.
Administrative provisions and wordinaticn of eeergency instructions to be broadcast have been provided to enable the decision rakers the flexil to get the of spectrum rest appropriate pssible ressage aired in a ticely ranner for the scenarios.
free that wten the ecergency organizations are fully staffed and follcwing a slowly developing situation to the unlikely case when the situation is rapidly developing, obviously severt in nature, and occurs t prior to erergency organizationt being able to fully staff or assess the situation. l 4
Procedures and resources have been provided to assist the public in evacuating the beaches, for directing and controlling traffic, for providing transportation for those without vehicles and for removing impedirents or obstructions along evacuation routes.
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- 5. Provisions have also been made to coordinate New Hampshire decisions regarding New Har6pshire beach populations with Massachusetts for consid-eration regarding the Massachusetts beach areas.
CISCUSSION The foregoing discussions have indicated that the current NH plans meet or will meet the criteria of NUREG 0654 in a generic sense. Specific and cetailed 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 popu-lations which warrant unique solution or provisions beyond those already incorporated.
Relative to the beach population, the distance to the Seabrook Station from the nearest beach area is almost two miles. This distance provides additional time to evacuate beach areas from the time of release until the frors edge of the plume arrives over the beach area (assuming the wind is blowing to the beach). This distance also can provide considerable dispersion and oilution of the plume activity in traveling from the sito to the beach. (The magnitude ,
O dut covie de severe, oreert of mesaituee-)cf sot <: ifconcentration eispersioa eaedecrease are small, then the impact (d, albeit "hot" area must Le small and the eilution is depen corresponding number of affected persons is also con;iderably smaller and presur. ably easier to protect.
It is also noted that when large, seasonal beach crowds ara likely to be present (on hot and sunny days), the typical wind pattern is from the off-shore, cooler surface to the onsbore, warmer surfaces of the land masses.
This means that any "sea breezes" would likely prevent the plume from traveling directly to the nearby beach areas when the beaches are most heavily populatec. The sea breeze would also dilute a short tern plume even if a portion of it was recirculated to beach areas.
The analyzed sevtre accident scenarios (core melt with early containment !
failure) indicate that the major portion of the dose to the affected popula-tion from such an event is due to exposure to deposited radioactive materials on the ground surfaces rather than from the passing plume. The l l
risk / consequence codes generally used (CRAC models or MACCS) all assume that the population is exposed to this ground deposition for 24-hours after the -
arrival of the first portion of the plume and to any additional plumes over that area. In other words, the codes assume that no protective actions are implemented for 24-hours after the release reachesThe beach (or other areas of interest). In view of the NH plans for beach closure and access control as l O
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eerly as the Alert classification, the plume travel tirne to the beach areas and the r'elatively short (2 to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />) time estimated to clear the beaches, there is reasonable assurance that the beach population would be adequately protected in the event of an accident at Seabrook Station. Thus, even if there were a prompt, severe, contaminating release and a portion of the beach population were cau evacuation process,ght theirinexposure or under to thedeposited plume forradioactivity two hours during wouldtheonly be approxinately 2/24 or less than one-tenth of the code assumed dose. In addition, they would be avoiding any additional exposure to the plume (s) af ter leaving this area.
The
" overall objective of emergency response plans', as cited in NUREG 0654, is
...to provide dose savings (and in some cases, imediate life savings) for a spectrum of accidents that could produce offsite doses in excess of the PAGs.
It has never been the intent of emergency preparedness / emergency plans to guarantee that no one would ever be exposed to radiation, or exposed in excess of the epa PAGs as a result of any accident or postulated accident. Rather, the purpose is to minimize the risks (produce dose savings) to the extent possible under the circumstances of the given accident. In this context, it is clear that it would be inappropriate to judge the adequacy of emergency planning on the basis of whether or not the plans and preparedness can guarantee that no one would be exposed in excess of the PAGs as a result of p any accident scenario. As stated earlier, the PAGs are guidance tools for use by decision makers and are not levels of acceptable or unacceptable risks.
The adequacy of emergency plans must be based on a finding that "there is reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency." Edward Christenbury of the NRC cefined the hRC position relative tc "reasonable assurance" in his letter to Spence Ferry of FEMA, dated June 18,1986, (copy attached). This position appears to be applicable to the protection of the Seabrook area beach popu-lations.
A similar analysis for persons inhabiting non-winterized facilities wculd parallei the above.
Further, this subset of the beach population would opear to be less at risk than the beach population with no ,helter; would be a smaller number than the beach population; and would generally be treated as part of the local population group. (Those persons in properties on the beach front would be considered part of the beach population during daytime beach season.)
Since precautionary evacuation for nearby areas appears to be the accepted -
federal and state protective action strategy if the EPA FAGS are projected to be exceeded, the sheltering potential of buildings, other than identified special facilities, is generally not considered for populations within about a 2 mile radius. Fersons inhabiting unwinterized buildings in this area would be treated in the same manner as other (year round) residents, i.e.,
evacuated. Persons outside this area may be considered separately on an ad n hoc basis by the decision makers. Finally, it is noted that habitation of V unwinterized buildings is generic to all sites with nearby beach or resort areas and that this situation is not unique to Seabrook. The New Hampshire provisions for these individuals near the Seabrook site appear to be well advanced in comparison with those at other applicable sites.
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O CONCLUSIONS Following ar'e some of the areas considered above which were utilized in arriving at a conclusion relative to the beach populations.
NM state and local plans essentially meet NUREG 0654 criteria generically Special provisions for beach populations in place No identified problems requiring unique or unaddressed solutions Provisions for early warning of beach populations Adequate transportation resources available for those needing public transit Beaches are nearly two miles from station affording delay in plume 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 "keasonable assurance" coes not equate with "absolute safety", i.e.,
guarantee of no exposures or exposures above the PAGs Esased on the above, it appears that contingent on the completion of action by the State to resolve the other RAC concerns with the New Hampshire and local plans, those plans appropriately provide for dose savings for the spectrum of possible accidents and are adequate to provide reasonable assura.1ce that the teach and unwinterized housing popu'lations will be protected and that these plans will essentially meet the criteria of NUREG 0654 anc the intent of the hRC regulations in this area.
Attachment:
Letter from Christenbury to Perry dated June 18, 1986 l
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' UNITto s7Atts Nt)CLCAR REGULATORY COMMISSION
' . O {s f MA MM ton. o. c. Mos
% ,,,,, June 18,1986
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cc: J. Allan J. Gutierrez Spence W. Perry, Acting General R. Starostecki Counsel -
- 8. Kane gFederal
,ou g4gEmergency Management Agency S. Ebneter 500 C Street S.W. B. Johnston Washington, D.C. T. M n 20471 R. Bellamy B. Lazarus 6/24/86-TEM In the Matter of Public Service Company of New Hampshire, et al.
(Seabrook Station, Units 1 and 2) ~~
Docket Noe. 50-443 OL and 50-444 OL
Dear Mr. Perry:
In nsponse han e valuat to ed,a request made by Edward Thomas of FEMA Region I, we in conjunction with Joseph Flynn of your office, an tur:w; Md memorandum of the applicants prepared by Thomas Dignan of Ropes and Gray on for the O m =or aeum". - coar at ~hich 5-Seabrook st ca a nuclear plant Att ch= at ^)-
("Dignan evaluation is set forth in the following discussion.t ot.
.e Thes"Dignan tion pertainingMemorandum to offsite addresses what are described as "three mismnc emergency planning for the Seabrook nuclear plant , and concludes Memorandum at 1). that they are "fals e as matter of law" (Dignan These purported "misconceptions" an as follows:
A.
That the plan s must be shown to guarantee that no adverse effects on the public health and sa.fety will occur Seabrook.no matter what kind of accident occurs at D.
That it must be demonstreted that the plans wiD assure that all persons located in the Emergency Planedng Zone or some certain portion of it can be evacuated in some certain tima. .
In' particular, plans must there have been assertions that the persons from assure the sheltering or evacuation of hour.' the beaches in approximately 1/2 O 1 It should be noted, however, that under the Commission's regulations.
10 CFR l 50.3. only written regu1& tory interpretations provided by the General Counsel will be recognl ed as binding upon the Commission.
ATTACHMIMT
- spence Perry Esq. . O C.
That the able, to coplans must be designed, and shown to be particular, peonewith a particular type of accident -- in involving an early radioactivity oft-site. release of For the reasone set forth below, it is ou'r opinion tnat fleation (B) above; Mr. however Dirnan's conclusions are essentially withcorrect minor clari- as to item and which requires corre,ction.his discussion of item (C) appears to contain an error DISCUSSION ,
A.
_ Absolute Assurance of Perfect Safety.
As set forth above, item (A) concerns the question of whether emergency an response effects plant.
wiu occur, plan must regardlessbe shown of what to guarantee that no adverse y health Atocic In our opinion, Mr. Dignan correctly concludes that "[n]eithe)d Energy Act nor any regulation of NRC, whether rdealing the with emergency (Dignan Memorandum, at 1-2). planning or not, requires absolute assurance aeyof perfect s O lations require a finding "thatAs you know, priorse.toNRC issuance regu- of a fu protective measures can and wiu bethere is reasonable assurance that adequate emergency."
NRC will base in C.F.R. 5 $0.47(a)(1).taken in the event of a radiological its finding on a With respect to offsite matters, the review of the FEMA findings and determinations "as to whether State end local emergency ns are can adequate pla and whether Id.,
f 50.47(e)(2). there is reasonable These regulations assurance that they p emented."
be im l Eimonstration of "absolute plainly do not require aesurance" that the any will be totally the Commission's emergency planningRather, reprotected the intentinofthe even into consideration piant conditions,an through protective accident actions andthatachieve take "dos evacuation times, other conditions that may edat at the time of the accidentshelter factors, an FEMA-REP-1, Rev.1 states as follows (at 6): .
N UREG-0654 /
The overall objective of emergency response plans is to provide dose savinga (and in some cases ic2 mediate life
' saving) for a spectrum of accidents that could produce offsite (PAGs). doces in excess of Protective Action Guides The Appeal planning is . . Board has simDarly stated. "[t he basicemergency goal of emergency." . the achievement of maximum] dose savings in a radio Cincinnati Gas & Electric Co. (Wm. H.
Station. Unit No.1) ALAS-iti.17 NRCTO, 770 (1983)7.immer Nuclear Power i
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Spence Perry. Esq. -
O in Southern California Edison Co. ,
Units 2 and 3). CLI-83-10, 77 (San NRC Or.ofre 528 533 Nuclear Centrating Station.
summarized- its rationale for selecting an (1983), the Commission follows: emergency planning basis as The underlying assumption of the planning regulations in 10 CFR I 50.47 is thatNRC's emergency i application clear accidentof stringent may occur. safety measures, a ser,ious nu-despite ,
This presumes that offsite !
Individuals may become contaminated with radioactive !
materic]
atton or or may beboth.
perhaps exposed to dangerous levels of radi- j Planning for emergencies is individuals. required Since a as a prudent risk reduction measure for those ,
1 dJffering offsite consequencesrange of accidents with widely can be postulated, the )
regulation does not depend on the assumption that a particular type of accident may or wiu occu.r. In fact no specific accident sequences should be s;+:ified be-both in nature and degree.cause each accident could have differe Although the emergency planning basis is independent of specific accident oe- l quences, a number of accident descriptions were con-O including the core meltsidered in development of the Commission' accident !
the Reactor Safety Study (WASH-1400). release categories of i These statements demonstrate that the reduce the impact and achieve dose savings for a spectrum to of acciden
, and that emergency potential for adverse plann.ing m a ," satisfy NRC regulations even thou elininated. heajth effects in an emergency has not been totally Notwithstanding our opinion that conclusion as to item (A), Mr. Dignan is essentiaDy correct in his memorandum requirr clarification, two statements first , contained in this portion of his "st he goes too far in asserting that has been recognized from the outset accident with offs .
. . that if one assumes a major peunition, occur" ite releases.
(Dignan Memorandum at 2some adverse effect on the public _ win, by emphasis added).
leases wiu not necessarily lead to adverse health y offsite re- effects Rather in some circumstances, adverse health effects.amergency Further, planning may serve to avert the occ !
and as the thety extent of any such effects, wiD depend upon a,such host of factorI
, conditions,peexposure and quantity of relesse, the plume direction , meteorological i durations and the appropriate p ective response. , timely implementation of an Se .N. n'dly , his memorandum states that Q Limit any adverse health effecta to as lowemergency planning is intended to "given the facilities at h an d a level as reasonably possible.
(&) . possibly implying that additional l
.cpence Perry. Esq. . O facilities w1D never be required to be built or installed to satisfy HRC emergency planning regulations.
cites the San Onofre decision, supra.In support of this statement. Mr. Dignan limited suppori for this conclusion. There, However, that decision provides only the Commission addressed only the issue of whether additional hospital construction should be undertaken, and concluded that such extraordinary meas'ures are not requ!Md.
B. Evacuation Within A Specific Time Period.
The second item addressed by Mr. Dignan is whether the Applicante must demonstrato that an or pArt of the plume. exposure pathway EPZ can be evacuated in some s; ecified time; in particular, this item addresses the question of whether the beaches in the Seabrook vicinity must be evacuated within approximately one-half (1/2) hour. It is FAr. Dignan's conclusion that imC regulations do not particular time (Dignan Memorandum require that an evacuation be assured within any at 2). We concur with Mr. Dignan's conclusion as to this item.
Ju support of his conclusion on this matter Mr. Dignan cites twc decisions:
Cincinnati Gas n Electric Co. (Wm. H. Zimmer Nuclear Power Station. Unit E 1). AL A 6-7 27, 17 NRC 760, 770 (1983), and Dettelt Edison Co. (Enrico O Fermi Atomic Power Plant . Unit 2). ALAB-730, 17 NRC 1057, 1069 n.13 (1983). In Zimmer, the Appeal Board stated as follows:
The applicants are . . . correct in their insistence that the Commission's emergmey planning requirements do not prescribe specific time limits governing the evaeus-tion of plume EPZs.
The matter of the time in which evacuation can be accomplished is left to be determined o') a case-by-case basis upon consideration of all rele-t ant cor.dtions prevailing in the specific locality. But it does net follo , as the applicants would have it, that a particular evacuation plan need not be concerned with the efficiency with which evacution might be accom-plished given the conditions under which it must take place [n . 16 ) . Indeed, the Commission guidelines sug-gest the contrary. . . . If the responsible govern-mental officials are to make an in formed decision respecting what is appropriate protective action in a given radiological emergenc' / . they must have available to them time estimates which are rerJistic appraisals of the minimum period in which, in lir< t of existing local conditione r evacuation could reascrably be accom-plished. And, the nearer to the plant the area that
> might have to be Svacuated, the greater the importance
.- of acsurate time estimates.
- n. 16/ Those conditions include, for example, the size
'aW nature of the population , the available
-__._ _ _ _ _ _. _ _ .__. _ _ . _ - _ _ _ _ ~ ,
, Epence Perry, Esq. .
O transportation facilities, the existing road topographical features und political boundaries. network, . . .
-Zimmer, supra,17 NRC at 770-71.
peal IIoar_d stated: '
Similarly, in the Fermi decision the Ap-
. . . [T]he tions do not Commission's emergency planning regula-EPZ gency. must be evacuated in the event of a nuclear emer-s only that10 C.F.K. Part 50 Appendix E, I IV, requires required to evacuate provide "an analysis of the time applicants and for taking other protective actions plume exposure for various sectors and distances within the nent populations."pathway EPZ for transient and perma-Fermi, su ra,17 NRC at 1069 n.13.
evacuat on e accocap!!shed within 30 minutes.Thus, there is no requirement that a must be capable of being accomplished White see other functions within that time frame, those ft.nctions generally officials ar.d notifleation of the public. invo've the notification of appropriate governmental I IV.D. See 10 C.F.R. Part 50, Appendix E.
~
O C.
Planning for A Particular Type of Accident.
The must plans third issue addressed by Mr. Dignan is whether s' facility's emerg be designed to cope with a particular type of accident and, in particular, an accident involving an "early release of radioactivity off-site."
Two conclusions tha t while emergency appear plans to must be reached by Mr. Dignan in this regard: (1) acciden ts , they need not be designed be designed to cope with a spectrum of
- any worst to cope with a specific accident or l emergency pleas caseare accident" not (Dignan Memorandum at 4), and (2) that reicase of radioactivity (Id., at 9-3). required to be designed to cope with an early conclusions, the second~3nclusion is While we agree with the first of these incorrect and require & clarification. ,
signed any partfeular toaccident cope with sequence or a a crectrun of accidents, but are n !
Commission has decided , on a gene ric basta, "worst casa accident . " The l emergency planning regulations that compliance with ita ;
oy 10 C.F.R.
I 50.47(a): accordingly, provides the reasonab)e assurance required reaufred to address particular accident sequences. offsite emergency plans are act In the Statement of planning regulations, the Commission stated as follows: Cons i Q The Commisslor. recognizes that no single accident...
scenario should form the basis for choice of notification capability requirements for offsite authorities and for G
, .___..___.,,____-__,-,,,,,_.__y-_,r,-.m_n.-_.__-_.,,.,_.c_.-_,_.,,,,,,,- .- - , . . , , , . _.
Spence Perry, Esq. .
the public. Emergency plans must be developed that will have the flexibiEty to ensure response to a wide spectrum of accidents. This wide spectrum of potential accidents also reflects on the appropriate use of the :
offsite notif! cation capability. . . .. l Any accident involving severe fuel degradation or core melt that results in significant inventories of f!ssion i products in the containtrent would warrant immediate !
public notification and consideration, based on the particular circumst snees, of appropriate protective action because of the ootential for leakage of the con-tainment building. In addition, the warning time avail- !
able for the public to take action may be substantially less than the total time between the original initiating event and leases takethe time. at place . . which
. significant radioactive re- -
times from the The reduction of noti 6 cation several hours required for street-by-street notif! cation to clinutes will algnificantly increase the options available as protective actions un-der severe accident conditions. These actions could O include staying indoors in the case of a release that has already occurred or a precautionar case of a potential release thought'ytoevacuation in the away. Accidents that do not result inbe a few hours core melt may also actions, at cause relatively quick releases for which protective vicinity, are desirable. least for the public in the immediate plant 45 Fed. Reg. 55402 (1980).
provides as follows (at 6-7): Similarly, NUREG-0654/ FEMA Rep.1, Rev. 1, No single speelfte accident sequence should be isoleted as ths one for which to plan because each accident could degree.have different consequences, both in nature and Further, the range of possible selection for a i planning basis is very large, starting with a zero point of requiring no planning at all because significant off-site radiological scrident consequences are unlikely to occur, to planning for the worst possible accident, re-gardless of its extreciely Icw likelihood. The NRC/ EPA .
I Task Force did not attempt to define a single accident sequence or even a limited number of sequences. Rath-er, it ider)tified the bounds of the paremeters for which ;
planning is recomc> ended, based upon knowledge of the
- potential consequences, timing, cnd releante characteris- ;
O .
tics of a spectruca of accidents. Although the selected planning bar.is is independent of tpecifle accident se-quences, a number of accident descriptions were con-sidered in the developmcnt of the goldance, including !
1, e
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l
. Spence Perry, Esq. . O ,
the core melt accident release categories of the Reactor Safety Study (WASH-1400).
Accord, San Onofre, s upra , 17 NRC at 533. In ten
. ~[Shoreham Nuclear Power Station). LBP-85-12, 21 tiRC 4 r03, Island Lighting Co.
888 (1985) (cited in Dignan !Jemorandum at 4), the Lic+nsing Board dismissed a contention as-serting that the emergency plans must be capable of coping with any worst case accident (there involving the possible loss of offsite power); the Board stated, "NUREC-0654 possible accident' at does not require an adequate response for the ' worst Shoreham. "
pronouncemen ts In sum, these regulatory for a nuc! car plant and decisions is not require clearly < demonstrate to that emergency planning particular accident sequence or a "worst case accident.'be, designed In this respect,towe cope with a concur with Mr. Dignan's memorandum.
l The Dignanplans emergoney Memorandum are not is incorrect, however, in its conclusion that the re. lease of radioactivity (Dignan Memorandum at 2-3), required to be design have involvingresulted an early byrelease.
confusing the "worst possible accident
- for any accidantThis an early release of radioactivity, While the ' worst possible accident' could involve other less severe acciQnts might also result in early releases and were included within the parameters which established the Commission's emergency planning basis.
Q Consideration. quoted above, clearly recognizes that 'early releases" me The Statement of occur; it is for this reason, in part, that the licensee is required to notin'
- offsite authorities within 15 minutes after the licensee has declare emergency, and that responsible offsite authorities have a capability to i
l the licensee of an emergency condition.netify the pub!!c within 15 min The following guidance is provided in NUREG-0654/ FEMA Rep.1. Rev.1 (at 13-14):
The range of times between the onset of accident condi-tions and the start of a ma}or release is of the order of one-half hour to several hours.
The subsequent time period over which radioactive material may be expected to be released is of the order of one-half hour (short-term release) to a few days (continuous release). ...
(G]uidance on the time of release . .. . has been used in developing the criteria for notification capabilities . .
(Other reasons for requiring prompt notiScation capabilities include faster moderate releases for which protective, actions are desirable and the need for sub-stantial lead times to carry out certain protective mea-sures. such as evacuation,
,. plant conditions.) when this is indicated by Q It should be noted that the responsible offsite authorities are not necessar required, in all cases, to notify the public within 15 minutes after they have
.,,-..--..-----,,,-,,,,_.e--y--.-.-.-,,.-,.,.e_.......,,..-,-,v---.-,,,..y,,,...,-_-,.,,,.-,-ry-. - .
Spence Perry Esq. -
I received notification by the licensee.
is notided. will range from immediate noti $ cation (within' 15 minute i state and urgent action) local to officials are notifled that a situation exists which requires the more likely events where there is substantial time availtble public for them to notiScation system.make a judgment as to whether or not to activate the s Also, it should be noted that the 15 minute i criterion refers only to the time in which the public is to receive !
notification, be completed.and does not refer to the time in which protective actions are to I
i In sum, responsible offsite authorities must have received notiacation of the -
1 emergency situation within 15 minutes after the licensee has declared an euergency, and the offaite authorities must have the capability to notify the public within 15 minutes after they have received notification from the licensee.
required Emergency planning for accidents involving 'early releases" is be fore , -- although the protective action recommendations may be issued There isduring or after the occurrence of an offaite release of radioactivity.
no requirement that protective actions be completed within 30 minutes after the licensee has declared an emergency.
_ CONCLUSION i
For the reasons set forth above, the following conclusions are offered as to the matters referred to in the Dignan Memorandum:
1.
reduce The basic goal of emergency planning is to spectrumthe of impact of and achieve dose savings for a accidents ; however, there is no requirement that absolute assurance be provided that adverse radiological effects will not occur.
l 2.
tions do not The Commission's energency planning regula-require that the evacuation of all or pa.rt )
of a plume exposure pathway EPZ be completed within any particular time. I l
- 3. The emergency plans must comply with the Commission's emergency planning regulations and there-by should be capable of responding to a wide spectrum of accidents; however, the plans are not required to be designed for any specific accident sequence or a "worst case accident."
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O
! pence Perr.". Esq. -
- 4. Accidents involving early releases are within the Commission's emergency planning basis, however.
the regulations do not specify a time within which the recommended protec,tive ections are to be completed.
Sincerely, p -
Edward S. Christenb[
Director and. Chief Hearing Counse!
Encloture y
cc: J. Taylor E. Jordan T. Mu:-ley O '
4 4
4 e
O
O
.y.EMORANDUM This.memerandum addresses thre. misconceptions whach have arisen as to the standards to,which state and munacipal emergency plans will be held in an NRC licensing proceeding These misconceptions are:
A. That the plans must be shown to guarantee that no adverse effects on the public health and safety will occur no matter what kind of accident occurs at Seabrook.
B. That it must be demonstrated that the plans vill assure that all persons located in the Emergency Planning Zonu or some certain portion of it can be evacuated in some certain time.
In part;:ular, there have been assertiens that i the plans must assure the shelcering or evacuat:en of persons f rom the beaches in approximately 1/2 hcur.
C. That ,
the plans must be designed, and shown to be able. . . . . .
to cope with a particular type of accident --
I in particular. one . . _ _ _ .
, involving an early release cf radioactivity off-site.
Each of these prepcsttions is false as a matter of law.
First, the issue of absolute safety:
Neither the Atomic Energy Act ner any regu;atien of NRC.
O) q.
whether deal r.g with eme rgency pla..ning er net, requires absolute assurance of
perie : safet:. Indeed, it has been recognized from the i outset of the formulation of the current emergency planning regulattons that if one assumes a major accident with effsite releases, def nition, some adverse eff,ect on the public will by
__ cecur. ,
The purpose of emergency planning is to ,
have in place means and methods of coping with in order to keep those effects such an event reasonabl- to as low a level as
/ pessible given the facilities at hand California Edison Co.
Southern
_ (San Onofre Nuclear Generating Station, _second, as Daits 2 and 3), CLI-83-10, 17 NRC 528, S33 (1983).
to the proposition that the plans must be demonstrated to be capable of assuring evacuation of certain areas within a certain time: This simply is not
() the law.
The Appeal Scards of the Commission haveeso h ld
- flatly and without e:uivocation. C;ncinnati
( W.- H. :
Cas & Electric Comeane
.- er Nuclear Power Sta len, Unit No. 1, ALAB-727, 17 NRC 760, 770 (1983): The Detroit Edison Co. ( Enrico Fe rT.:
Atomic Power ?lant, Unit 2), ALA3-730, 17 NRC 1057, 1065 n.13 ( 19 83 ) . - Indeed, the only activity which the regulat::ns specifically require to be capable of accomplishment in one-half hour is public notification. And it is in that context the 1/2 hour rule is discussed in NUREC-0654, the NRC emergency planning guidance document Third .
the propositten that
- adequacy aga:nst the plans will be judged as a
certa:.. type of accident and in particular ene involv:ng a re.' ease as socn as '/2 hour:
c
O ha prepositzen is not only bad law.
It as directly contrary to the theory of the NRC emergency planning criter:a. The theory upon which the regulations were based was that the planners should consider a spectrum of accidents. The key is that the plan be shown to be flexible and capable cf reducing the adverse effects to theeatest gr extent reasonably possible.
stated: The Commission itself has differing offsite consequences can be"Since a r postulated, the regulation does not depend e'en the assumption that a particular occur. In type fact, of accident may or will sequences no speci:ic accident should be specified because each accident could have different consequences both in nature and degree.
O Although independentthe emergency plar.ning basis is of specific accident sequences, a number of accident descriptions were considered in development of the Commissien's regulations, accident :ncluding the core melt release categories of the Reactor Safety Study (WASH-1400).
"It was never the intent of the regulatien indirectly that to require directly or state and local governments adopt extraordinary measures, such as construct:on of additional hospitals or recruitment cf substantial additional medical personnel, plant accidents.just to deal with nuclear The emphasis i prudent risk reduction measures.s on regulation does not require dedication The of resources to handle every possible accident that can be imagined."
CLI-83-10, 17 NRC at 533.
O 3-
) Furthermore. there is no requirement that it be -
demonstrated that a plan vill cope with any worst case accident. NURIC-0654 simply does not require an adequate response for the worst possible accident. k Long faland Lighting Co_.
(Shoreham Nuclear Power Station), LBP-85-12, 21 NRC 603, 888 (1985).
In short. the standard by which any emergency plan is to be judged is whether or not it represents the best efforts of knowledgeable people through the use of reasonably available fae:1 ties to reduce to the maximum extent reasonably possible the adverse effects on the public health and safety which vill result from off-site releases resulting from a spectrum of accident scenarios. The
() guiding pr:nciples, as recently stated by an NRC Licensing *d Scard are:
"The purpcse cf emergency planning :s to ach eve dose savings to the general pub 1:e in the event that radioact ve mater:al is accidentally released off site.
There is.no minimum standard cf pub' e radiation dcte which must be met in emergency planning.
"Absciute protection of the public agal..st all radiation doses cannot be guaranteed and is not required for all possible accident scenarios.
"The emergency response plan should not be developed for any specific prectnce.:ved ace: dent sequence. It should instead be framed to cope with a spe=trum of accident possibilities
,. ine'uding
. the worst ace: dents.
O
e
) e.
"There is no standard time required to
( be met for evacuation in a radiological emergency. Estimates are necessary to determine accurately the actual time required for evacuation. These estimates are needed to aid in protective action decisionmaking.
"No massive investment of resources (stockpiling ci supplies or construction of hospitals) are required for emergency planning. We wf.11 apply a practical standard of efficience of utili.=ation of existing resources (such as roadways and manpower) in evaluati'ng the acceptability of the evacuation plan."
LBF-85-12 at 782.
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