ML20207C582

Intervenor Exhibit I-State-36,consisting of Discussing Participation in Meetings Re util-based Emergency Plan for Commonwealth of Ma

ML20207C582
Person / Time
Site:	Seabrook
Issue date:	05/26/1988
From:	Krimm R Federal Emergency Management Agency
To:	Congel F Office of Nuclear Reactor Regulation
References
OL-I-STATE-036, OL-I-STATE-36, NUDOCS 8808090291
Download: ML20207C582 (3)

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'v' SEP 2 1987

'88 JUL 19 P6 :04 MDORN4tCM FOR: Frank J. Congel f\Ct.< :Jrkr1 Director, Division of Radiation Ptrtection

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and Emergency Prepamdness Office of Nuclear Reactor Regulation U. S. uclear egu tory Ccmission FIOM: cnard . A rL...

Assistant Associate Dittetor office of Natural aM Techrolcgical Hazards Progra:rs RBJD:T: Participation in Meetirgs Regarding Pttsosed Seabrook Utility Based Plan for the Ccrronwealth of Massachusetts on several occasions recently, the Nuclear Regulatory CaTmission (NBC) has irquire3 as to whether or not the Federal Emergency Management Agency (FFA) would attend a reeting of NPC and utility representathes to discuss a prgesed Seabrook offsite radiolcgical emetgency preparedness (REP) plan khich ray be submitted by Public Service of New Harpshire (PSM) in lieu of a subnittal by Massachusetts, As we discussed before, ard as stated to n ycu in my metrorandum of April 24, 1987, FEA vculd appreciate the cpportunity

() to discuss the parameters, tL e frames aM other ratters prior to NPC raking any fotnal request for FWA/~degional Assistance Ccmittee (RAC) review uMer the provisions of the joint NPC/ FEMA Meerandum of Under-standire (mU). Wis type of discussion shculd also, in our view, precede any reetirq involving FUA ard utility representatives related to 1) a proposed utility plan for Massachusetts, 2) subnittal to the FWA/ PAC of  :

any projected plan for review, aM 3) the passible exercisire of such a l plan.

l In addition, the Shoreham experience has clearly deronstrated that even in the I best of circumstances, there are a nuri:er of legal authority issues which i tirain cpen regardirg a utility-based plan evaluated under existirg guidance I aM regulations. Retsfore, the preferred appttach, wculd be to have l evaluative staMards ard criteria for a utility-based plan develcsd and i in place before any utility plan is sutnitted by NRC to PFA in accordance with the NU.

Also, before initiatirg sny utility-based plan tuview we would like NRC to Mvise us of any consideration being given tc several other risk mitigaticn features discussed in the past includirg: 1) special design features at the Seabrook plant such as dcuble contain ent; and, 2) reduction of plant cperations durirg the su.mer conths. Mdressire these issues ray assist in the tesolution of the so-called "beach gpulation" issue. Futther, we would want to discuss the inpact of the disposition of the prqcsed tule on the criteria for a utility-based plan review.

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Finally, the inpact of practical trattets bearing on the issue of a Seabitok utility plan review cannot be overlooked. ne follcuing issues shculd be taken into consideration:

1) FSA Pagion I workload requirments aM priorities ard its limited staff are currently devoted to exercises and plan reviews at operating sites like Pilgrim ard Maine Yankee aM testinony on the New Harpshire plans for Seabrook. As you kam, the Seabrook Atcnic Safety and Licensing Board (ASIB) offsite hearings are scheduled to resure on Septeter 28, 1987. Of necessity, the saxe staff will be expected to perform these responsibilities. he performance of a utility-based plan review would still further reduce the staff ruscorces which can te devoted to i operatirg sites. Se insortance of activities related to public safety '

for operating sites, in our view, precludes devoting li;nited staff resources to review a prcposed utilitv-based plan for a ren--9perating site in the near tetn, particularly in the absence of evaluative planning staMards ard criteria.

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2) Durirg the preparation of the FY 88 budget, other cptions wett being  !

considered by the utility. Due to the uneettainty surrcunding the '

subnittal of offsite plans, FD'A was not able to incorporate tasks related to a utility-based plan into its budget. Thus, the substantial O coste essociated with revietre, exercieire erd 11tieetine e votentie1 Seabrook utility-based plan for Massachusetts have not been planned for in FWA's budget ard were not incorTorated in the President's submittal for Fiscal Year 1988. t Based on the abcnerentioned concerns, it may be advantageous to tuview the 1 entire subject of utility-based plans. If it is convenient, I would like l to meet with you on Septerrber 10, 1987, to discuss the iterrs rentioned above, as W11 as any issues you might want to add to the agenda. To j accceplish our goals as efficiently as possible, I suggest that the neetirn  !

also include Victor Stello and other staff as appropriate. Dave McLoughlin i ard ne:rbers of the FDA Headquatters staff would also te available to attend in order to resolve issues of concem abcut Seabrook. As you ray know, such a high-level neeting was very helpful in resolvirn litigation issues related to the Shorvham plant.

I wil1' call you in a few days to schedule a firm date, tire ard location. I In the interim, should you have any questions, please feel free to contact ce at 646-2871.

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