ML20207C509

Intervenor Exhibit I-State-50,consisting of Response to Revised Town of Hampton Contention VII to Rev 2 of State of Nh Radiological Emergency Response Planning for Plant,Seacoast Anti-Pollution Contention 16

ML20207C509
Person / Time
Site:	Seabrook
Issue date:	06/14/1988
From:	Federal Emergency Management Agency
To:
References
OL-I-STATE-050, OL-I-STATE-50, NUDOCS 8808090253
Download: ML20207C509 (4)

Text

c: DjY vm 9 g o ,r e 2 r

^

, f*g-l}/HArrtl3lclytf-Dr S 7nPm - c e. w uf r/r z T - S Q / 6 ,, " 8 0 5 e - +- % HGr.m- h J e, s irW . , e m FEFA FESPCNSE to Revised Tcwn cf Hannton Contention VIII to Fevi rig Kiifm the Rw Fa rshire PERP for SeabrdkS SAPL Contention 16, and N Contention FIPP-8

]' These three contentions all deal with what is fundarentallbhedba.(9 P6

42 issue: protection free a radiolccical release for teach-coinc pcpulation at Seabecck stio do not have ready access to any etfective for" diNsheltorim.m This cra;p includes both "day-trinters to the teaan and those r6&nQWenlyi have access to unwinterized er other types cf constmetion which will offsr a lesser decree of protection than that of forcri bv standard residential or ccrrercial tuildircs.

Backcround - This issue has been of great concem to FFFA fro cur earliest detailed involve ent with the premration of plans and the achiew-rent of a level of emrgency creparedness which would achieve cur reculatcry standard set for that 44 CFR 350.5 of adeqmtely protecting the public health and safety by providirn reasonable assurance that apprceriate prctective ressures can he taken offsite in the ewnt of a radiolcgical emmency at the Seabrock Nuclear Pcwer Plant.

In teceter 1985 the State of New Hamshire sutnitted plans for rrotectina the public in the event cf an accident at Seabrook to FDtA for review pur-suant to 44 CFR 350. Those nlans wre for arded for review by the Reaional Assistance Ccmittee (PAC), an interaaency grcup established pursuant to 44 CFR 350.6 to both assist state ard local gowrnrent in the develcprent of radiolcgical crercency response plans and to evaluate the adecuacy of such plans. On Dece-ter 31, 1985, FEP.A, as chairman of the FAC, recuested that the mcrters of the PAC (as well as the other FEFA staff who were reviewirg the New Hamshire Plans) irrediately focus on the issue cf the protection O of teach repulation and the occurents of unwinterized acccrrodations. This

() recorandun is attached as Aprendix C to this response to interrcgatories.

It was cur intention to address and resolw this issue thrcuqh technical guidance to the State at the scenest passible tire.

Pesponses to this re"crardun were received f rcr four rcebers cf the PAC:

a. Tre Departrent of Transcortatico bv renorandun dated January 9,1986;

b. The Departrent of Acriculture by recrandun 6ted January 14, 1986;

c. The Departrent of Health ard Huran Services by rerorandum Mted January 15, 1986:

d. The Nuclear Rcqulatory Ccrrission by rercrandun dated February 18, 1987.

In addition, the representative of the Envirereental Protection Acency indicated that he was in essential acreerent with the response to this issue set forth in a remorardun &ted January 13, 1986, by FEFA reviewer, Fred B. Oleson. Follcwing the receipt cf these responses to our rerorandum frariirg the issue, FEMA trans-itted to the RAC a consolidation cf the re-sponses tecether with a letter dated June 18, 1986, frcr- the ITC to FEFA concernire alleged risconceptions atoJt crergency nlannirn at Seabrcok. The representative of the repartrent of Ccrrerce rade ccrrents concerninn the corsolidated cckaoe of responses by renorandum dated March 6,1987.

O m"M 8%

G

.e. gruap r Ls EEhb LcL henLoog ) $ t% r CoursugIw W M U D N N P g ggydt, ro pt pcq Iceu oE hLucou coursuciou AIII Cc beza;ou 3 (oE

A o

1 5

9 O

t@ 'g .

\ h0

\\'

%p .1 o

}

? l-%

o -

G' g - &

t I. I .

n a5a 'm .

s=n d,<\ .

ISd a

T i

i

-w\

3 j Q'

- i si '

.Y

.s Q (Q i m

O

• 4 -e m

---vr--m--e p-- y 9 - c w- y- w e---r9msr- --gNw _N&NN--ewm w-N e-ew w--v---mv-'

d

! i A cray of the February 18, 1987 rercrandun f rom the NRC is attached as Appendix D to this suMission since it has already teen released to one of the parties to this proceedira. FEMA will not release the other resccrses to its re:e-ter 31,19F5 rercrandum cut of concern that the release of these documents ray interfere with the deliberative and collegial PAC prcuss.

O'

" If necessary, FD% will seek to rrotect the cther PAC restonses by assertina Executive Privilece.

On Acril 15, 1987, the PAC ret to fCCJlate a positiCD on this issue s0 as to a) close out the unresolvM PAC concerns about the protection of the beach population set forth in the PAC ccrrents en Revicion 2 of the New Harpshire Plars; and b) provide advice to FR% about the owrall adecuacy of the New Ha-oshire Plans concernirq this natter. TheFDG RAC was able to ard its contrac-reach a basic corsersus on the ratter at the reeting.

tors were tasked with develcpirq the exact larcuage to be used in the ~

revised PAC review which was to haw teen acccmpanied by a detailed paper settirr; forth the reasonira for the anended RAC review.

In early Fay, while the FAC final ocsition was still being written, FEMA was contacted by the h7C reoresentative to the PAC who informed us that we cculd no lonoer rely uron the February 18, 1987, nemrandu- NRC had provided ccccernim this ratter. He indicated that the entire ratter was beiro Since the NRC input was critical to the reviewed at STC Headauarters.

formulation of the PAC cosition, EUA determined that the fornulation On of June 2, the PAC pcsition rust te deferred until NPC clarificd its cdvice.

1987, a reetirq was held at FDG Heacuarters at which representatives of the NRC indicated that the February 18, 1987, nererandum frce the NRC would to redified to delete all reference to the site specific protective features of the Seabrook Plant, the probability of an early release, as q well as all reference to the site specific analyses done concerniro the b risk of an accident at Seabrook. bhen the revised MPC resronse to our Eecenter 31, 1985, recorardu- is received, FUm will distribute it to the PAC and reconvene a reetirq cf that ccmittee to finalize those tortions of the PK Peview of Pev-2 of the New Hampsbire Plars for Seabrock Wich i were lef t ocen pendira resolution cf these issues. l l

FDV. Position - Since the tire of our D3cemher 31, 1985, remrardum on the suc]ect of the protection of the public on ard near the teaches araJnd Seabrock, the State of New Harpshire has refined ard impreved its erermncy plars and submitted a detailed Evacuation Tire Estinate which i sheds a considerable anount cf licht on this issue. The facts relevant '

to understanding this isste are that:

(1) The primary guidance document used by FEF% ard the PAC in reviewirq of f-site ereroency plars is NUPEG-0654, FD% RFP-1, Rev.1, a docunent jointly developed by FC% and the NRC. That cruidance docunent indicates on o.13 that "(t)he rance of tires between the onset of accident corditiers and the start of a naior release is of the orckr of one-half hour to sewral hours" (erphasis added). This statcrent is turther clarified on p.17, Table 2 to indicate that (a) tre rajer portion cf a release ray occur in a tire pericd ramiro f rcr as little as one-balf hour to one day af ter the release tegins and (b) that the travel tire of the release tc.

exresure point can rame frcr one-half bour to two hours at five riles, and one hour to fcur hcurs at ten riles.

o U

l

Y,

,y m

Cn reak surrer days there are thousands of beachocers in the b) (2)

Seebrook EP2 in areas beginniro approxirately 1.7 riles frcm the plant. R e current New Harpshire plans cont & plate evacuatina the runy thousands of teachocers who have access to no adeotate shelter as a protective action in the event of an accident at Seabred;.

We understand that the plans contain no consideration of shelterinc the "day trippers" tocause on strrer days when there are a laroe number of these recole, it is not pcesible to fird reasanably accessible shelter for thern. B ere are an additional nurrer of rersons who would be in or have access only to shelter in urwinter-ized cottages and rotel rces. B e protection afforded by shelterino in these structures will definitely be less than that af forded by a nornal wocd f rre house.

(3) De Evacuation Tire Estirate for the Seabrook EP2 subritted by the State of Ncv Ha-cshire irdicates at pp.10-1 et.sec. that in ocod weather Wn the beaches are at 60 to 100 percent of canacity it will take three and one-half hours to clear the teaches, and a tctal of frcri four hours and fif ty ninutes to five hours and fif ty ninutes to evacuate all the population on the reaches frcn the EP2. In scre situations such as stdden bad weather follcwing CP2 a peak strrer day, the total evacuation tire for portiers of the 1 range up to sewn hours and fif ty ninutes.

Berefore, using the stardard guidance for the initiation ard duration l

)

O of radiological releases, and the current New Harpshire PEPP includirg FTE, l it appears that thousards of pecple could be trapped during an accident at Seabrook involvira a rajor release of radioactivity without adequate shelter ,

for as ruch as the entire duration of tht.t release. Berefore, even if all l the other inadecuacies and deficiencies cited in the PAC Paviews of the New l Ha pshire Plans, ard the Review of the Exercise of these plars were to be corrected, FEMA wculd not he able to conclude that the New Hroshire State and local plans to protect the public in the event of an accident at the Seahred:

Ntriear Pcwr Plant are adecuate to reet our reculatory standard that such l

plans "adecuately protect the public health and safety by providire reasonable l assurance that appropriate prctective reasures can te taken offsite in the event of a radiolcgical crerrency." (See, 44 CETt 350.5(b)).

Ov

__ _