ML20210T177

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Forwards Draft Statement of NRC Before Subcommittee on Energy Conservation & Power,Us House of Representatives Re Status of Emergency Planning for Seabrook. Draft Statement Should Be Served on Parties & Boards.Served on 861006
ML20210T177
Person / Time
Site: Seabrook  
Issue date: 10/03/1986
From: Gray J
NRC COMMISSION (OCM)
To: Clements B
NRC
References
CON-#486-0969, CON-#486-969 OL, OL-1, OL-OL-1, NUDOCS 8610080320
Download: ML20210T177 (14)


Text

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USflRC October 3, 1986

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NOTE T0: Bill Cle nts c ~r -61986 FROM:

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SUBJECT:

DP. AFT ST F TESTIMONY FOR CONGRESSIONAL HEARING ON SEABROOK The attached draft staff testimony for Congressional hearings on Seabrook was provided to Commission Offices on September 26 and October 3,1986.

This draft testimony deals to some extent with matters in issue before NRC adjudicatory boards in the Seabrook operating licensee proceeding. Please serve copies on the parties and board; in the Seabrook proceeding.

Attachment:

As stated cc:

M. Cutchin w/o attach.

P. Davis S. Sohinki S. Burns OCA i

8610090320 861003ADOCK 05000443 PDR PDR G

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G STATEMENT OF THE UNITED STATES NUCLEAR REGULATORY COMISSION BEFORE THE SUBCOMMITTEE ON ENERGY CONSERVATION AND POWER UNITED STATES HOUSE OF REPRESENTATIVES CONCERNING STATUS OF EMERGENCY PLANNING FOR SEABROOK

l Thank you, Mr. Chairman.

In response to the request of the Subcomittee. I am here to discuss NRC's participation in emergency planning and preparedness activities for the Seabrook nuclear power plant. Before proceeding with ques-tions, I will start with a brief overview statement on the history and status of the issue.

As with all comercial nuclear power plants, NRC participation for Seabrook has included review of the onsite emergency plan, onsite appraisals of the applicant's capability to implement the plan and observation of the emergency preparedness exercise, participation in the hearing process on emergency planning issues, and coordination with the Federal Emergency Management Agency (FEMA) regarding FEMA's review of offsite plans. The latter includes support of the Regional Assistance Comittee (RAC) meetings chaired by FEMA Region I.

Public Service Company of New Hampshire originally submitted its emergency plan, as part of the Final Safety Analysis Report, in June 1981. The NRC staff has reviewed this plan, and subsequent revisions, against the applicable regulatory requirements (10 CFR 50.4'7 and Appendix E to 10 CFR 50) and guidance criteria (NUREG-0654/ FEMA-REP-1). The results of the staff's emergency preparedness re-views are documented in the Safety Evaluation Report (SER, NUREG-0896) and in supplements to the SER the latest of which is Supplement No.5 dated July 1986.

The staff has concluded that the Seabrook Station onsite emergency plan provides an a::ceptable basis for onsite emergency preparedness.

An onsite emergency plan implementation appraisal was conducted by the NRC Region I office in December 1985 with followup appraisals in March and June 1986. Areas

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. examined by NRC inspectors included emergency plan pr9cedures, records, emergency response facilities and equipment as well as interviews with emergency organiza-tion personnel. The results of these appraisal efforts have been documented in NRC inspection reports. An NRC inspection team also observed the applicant's performance during the emergency preparedness exercise held on February 26, 1986.

l The inspectors concluded that the applicant's emergency response actions demon-strated during the exercise were acceptable for public protective measures.

Hearings on onsite emergency planning issues, among others, were held by the NRC in August 1983. A supplementary hearing on certain onsite issues including emergency planning was held during the week of September 29, 1986. A favorable Board finding on whether issues in dispute could affect the public health and safety during limited tests is required prior to issuance of a license author-izing fuel loading. Low-power (up to 5% of rated powc-) could be authorized 4

t following a favorable finding on pending onsite issues. Adjudicatory proceedings l

on offsite emergency planning issues are currently underway but a hearing schedule has not yet been set by the Licensing Board.

In order for full-power operation j

to be authorized, issues involving offsite emergency response planning must be l

resolved.

The NRC is monitoring the offsite emergency planning process and supporting FEMA review efforts through the FEMA RAC. The RAC consists of representatives from nine Federal agencies including the NRC and is chaired by the FEMA Region I office.

FEMA has reviewed drafts of State and local plans that were submitted

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. by New Hampshire and Massachusetts as part of an informal technical review. New Hampshire formally submitted emergency plans to FEMA in December 1985 with the latest revision submitted in September 1986. These plans have.been forwarded to the FEMA RAC for review. Hearings on the New Hampshire plans, scheduled to start in August 1986, have been postponed at the request of FEMA and have not yet been rescheduled. An exercise involving the applicant and New Hampshire was conducted on Februcry 26, 1986. New Hampshire has implemented corrective actions' identified by FEMA as a result of the exercise and has indicated that these changes are included in their September 1986 submittal to FEMA. Although Massachusetts has been preparing its emergency plans, it has not formally sub-mitted these plans to FEMA for review. On September 20, 1986, the Governor of Massachusetts stated that the Commonwealth does not intend to submit emergency plans to FEMA.

Since much discussion has been focused on the Chernobyl accident and the suffi-ciency of the NRC regulatory program in light of the event, I would like to summarize current thinking. The international technical community believes the cause of the accident can be attributed to human error and specific design deficiencies which together resulted in a highly unstable condition at the start of a planned test. The initiation of what was thought to be a routine turbine generator coastdown then resulted in a large, rapid reactivity excursion, an associated rapid power increase, and ultimate destruction of the core, t

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. Reviews of the accident and the RBMK design by the NRC staff have not identified any aspects of the accident which show a clear-cut nexus to U.S. connercial nuclear power plants. This view is based on significant design and operational distinctions, including our judgment that large, fast-acting reactivity addi-tions such as occurred in Chernobyl are not possible in U.S. comraercial nuclear power plants. Chernobyl is, however, the worst nuclear accident and is receiving priority attention to assure we learn everything we can from that accident. These NRC studies will be coordinated with the many on-going national and international activities.

  • p DRAFT Thank you, Mr. Chairman, in response to the request of the.Subconnittee. I am here to discuss NRC's participation in emergency planning and preparedness activities for the Seabrook nuclear power plant. Before proceeding with questions I will start with some broad consideration of the Seabrook site emergency preparedness taking the plant first as a typical light water reactor, secondly as being considered for special treatment or exemption under current regulations and finally in light of the Chernobyl accident.

The role of emergency preparedness around nuclear plants is to provide

... reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency." (10 CFR50.47(a)(1)) Detailed guidance on what constitutes adequacy for such preparedness is found in three principal sources. Appendix E to 10 CFR50 specifies the necessary analysis, the content and the implementing procedures for emergency plans. NUREG-0396-Planning Basis For The Development of State and Local Government Radiological i

Emergency Response Plans In Support of Light Water Nuclear Power Plants, December 1978, provides the joint findings of NRC and the Environmental Protection Agency Task Force for the technical basis of emergency plans. NUREG-0654, Rev.1, Criteria For Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, November 1980,

s provides the joint guidance of NRC and the Federal Emergency Management A The conclusions in NUREG-0396 were based for development of emergency plans.

on a broad consideration of the results of many plant specific safety analyses available at that time as well as the probabilistic risk analysis (FRA) of one plant from the 1975 Reactor Safety Study. The extant guidance is applicable to light water reactor plants rated at 250 MWt or greater (NUREG-0654, p.11).

NUREG-0396 recognized that emergency response plans should not have the objective of preventing doses above Protective Action Guideline (PAG) levels (NUREG-0396, p. 4) but rather have the objective of providing dose savings for a spectrum of accidents that could produce offsite doses in excess of PAGs (NUREG-0654,p.6).

The principal ayect of concern at the Seabrook site is the large transient population on the beaches during the summer months. The present federal guidance (NUREG-0654, App. 4) specifically addresses the need to consider such transient populations in preplanning and indicates the ways in which roadway characteristics, population size, vehicle availability and evacuation times Certainly it would be an oversimplification to associate should be evaluated.

the total time for complete evacuation of a population group with all members If a substantial part of the group is able to evacuate even of the group.

before any exposure to the accident release begins, a substantial dose savings In Table 2 NUREG-0396 gives guidance on the initiation and is achieved.

duration of release in severe accidents. The accompanying text takes pains to point out that significant plume travel times are associated with the most adverse meteorological conditions that might result in large potential

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r gi exposures far from the site. Thus 1t is not reasonable to associate the highest doses with minimum transit times to points offsite.

The developers of the technical basis for planning, NUREG-0396, also considered the possibility of wind shift, especially at the low wind speeds associated with the highest exposure conditions (NUREG-0396, App. I', pp. 122ff.) That consideration prompts the federal guidance-to advise protective actions in parts of the EPZ which are not affected by the current wind direction. A wind change can remove the exposure threat from one area and shift it to another.

One ameliorating aspect of wind change is that it substantially lengthens the time and distance a plume must travel to reach a certain distance from the plant. The effect of precipitation was also considered. Rainfall is usually a very efficient scavenger of particles in the atmosphere (NUREG-0396, App. I, p.

I-25.) If the rainfall is occurring at the plant at the time of the release, it will significantly reduce the travel of the released material, bringing it to' ground at or near the plant. On the other hand, if rain falls on a plume of released material after that material has travelled to some high population location, then it can increase the exposure for that population.

Taking all of the emergency preparedness into account, and treating the Seabrook plant as a typical light water reactor, the Seabrook site is not really an extraordinary case, although it does Lave some unique features.

As with all NRC's participation in the review of Seabroct has recognized that.

commercial nuclear power plants, NRC participation for Seabrook has included

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review of the onsite emergency plan, onsite appraisals of the applicant's capability to implement the plan and observation of the emergency preparedness exercise, participation in the hearing process on emergency planning issues, and coordination with the Federal Emergency Management Agency (FEMA) regarding FEMA's review of offsite plans. The latter includes support of the Regional Assistance Comittee (RAC) meetings chaired by FEMA Region I.

Public Service Company of New Hampshire originally submitted its emergency

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The NRC staff plan, as part of the Final Safety Analysis Report. In June 1981.

has reviewed this plan, and subsequent revisions, against the applicable regulatory requirements. The results of the staff's emergency preparedness reviews are documented in the Safety Evaluation Report (SER, NUREG-0896) and in

. supplements to the SER the latest of which is supplement No. 5 dated July 1986.

The staff has concluded that the Seabrook Station onsite emergency plan provides an acceptable basis for onsite emergency preparedness.

An onsite emergency plan implementation appraisal was conducted by the NRC Region I office in December 1985 with followup appraisals in March and June l

1986. Areas examined by NRC inspectors included emergency plan procedures, records, emergency response facilities and equipment as well as interviews with emergency organization personnel. The results of these appraisal efforts have been documented in NRC inspection reports. An NRC inspection team also observed the applicant's performance during the emergency preparedness exercise l

held on February 26, 1986. The inspectors concluded that the applicant's emergency response actions demonstrated during the exercise were acceptable for public protective measures.

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o I Hearings on onsite emergency planning issues, among others, were held by the

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NRC in August 1983. A supplementary hearing on certain onsite issues including emergency planning was covered during the week of September 29, 1986. A favorable Board finding on whether issues in dispute could affect the public health and safety during limited tests is required prior to issuance of a license authorizing fuel loading. Low-power (up to 57,of rated power) could be authorized following a favorable finding' ort pending onsite issues.

Adjudicatory proceedings on offsite emergency planning issues are currently underway but a hearing schedule has not yet been set by the Licensing Board.

In order for full-power operation to be authorized, issues involving offsite emergency response planning must be resolved.

The NRC is monitoring the offsite emergency planning process and supporting FEMA review efforts through the FEMA RAC. The RAC consists of representatives from nine Federal agencies including the NRC and is chaired by the FEMA Region I office. FEMA has reviewed drafts of State and local plans. that were submitted by New Hampshire and. Massachusetts as part of an informal technical review. New Hampshire formally submitted emergency plans to FEMA in December 1985 with the latest revision submitted in September 1986. These plans have been forwarded to the FEMA RAC for review. Hearings on the New Hampshire plans, scheduled to start in August 1986, have been postponed at the request of FEMA and have not yet been rescheduled. An exercise involving the applicant and New Hampshire was conducted on February 26, 1986.

New Hampshire has implemented corrective actions identified by FEMA as a result of the exercise and has indicated that these changes are included in their September 1986 submittal to FEMA. Although Massachusetts has been preparing its emergency On plans, it has not formally submitted these plans to FEMA for review.

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v the Governor of Massachusetts stated that the Commonwealth September 20, 1986, does not intend to submit emergency plans to FEMA.

The owners of the plant conducted a plant specific PRA a few years ago, the Seabrook Station Probabilistic Safety Assessment (SSPSA). The NRC encourages owners to conduct such studies since they have frequently demonstrated their value in understanding and in improving the' safety of the plant. Recently, the owners submitted to the NRC two documents based on the PRA, PLG-0432, Seabrook Station Risk Management and Emergency Planning Study,

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December 1985 (RMEPS) and PLG-0465, Seabrook Station Emergency Plannirg Sensitivity Study, April 1986._ The owners have indicated that they conducted these studies to help evaluate emergency planning options for Seabrook Station.

They have indicated that they may request an exemption from some portion of the current emergency preparedness requirements.

There has been public discussion for some time 'of the possibility of revising current regulatory requirements, including those for emergency preparedness, in light of our greatly improved understanding of severe accident behavior, far The NRC better than that which was the basis of the 1975 Reactor Safety Study.

is not willing to prejudge the outcome of any such generic consideration, nor is it willing to prejudge a specific case for exemption from some requirements But the technical basis for emergency preparedness requirements

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in once case.

is clear and both generic reconsideration and plant specific reconsideration may be justified. Certainly, if a sufficient technical basis exists to shcw that different accident characteristics and release characteristics are justified, then adequate protective measures can be achieved with different We have drawn no conclusions now; we have only undertaken the requirements.

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7-We will review of the revised technical basis, offered by the Seabrook owners.

be pleased to speak to the Committee again when we have determined what changes I

if any the applicants seek and when we have completed our review.

Since much discussion has been focused on the Chernobyl accident and the sufficiency of the NRC regulatory program in light of the event, I would like to summarize current thinking. The intern'ational technical community believes the cause of the accident can be attributed to human error and specific design deficiencies which together resulted in a highly unstable condition at the start of a planned test. The initiation of what was thought to be a routine turbine generator coastdown then resulted in a large, rapid reactivity excursion, an associated rapid power increase, and ultimate destruction of the l

The mechanics of core destruction by fuel vaporization, fuel-coolant core.

interaction (steam explosion) and the forcible ejection from the plant appear to be unique to plants of Chernobyl design.

Reviews of the accident and the RBMK design by the NRC staff have not identified any aspects of the accident which show a clear-cut nexus to U.S.

comercial nuclear power pla.its. This view is based on significant design and operational distinctions, including our judgment that large, fast-acting reactivity additions are precluded in U.S. commercial nuclear power plants because of inherent shutdown mechanisms, operational safety improvements made Similar as a result of TMI, and on the strength of U.S. containment systems.

views have recently been expressed in the report of the Select Panel For Post 4

Chernobyl Safety Review, chaired by Frederick Seitz of Rockefeller University and Hans Bethe of Cornell University (Seitz, F. and Bethe, H. to the Honorable w

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1 8-John H. Sununu, August 29,1986). Chernobyl is, however, a serious warning and the characteristics associated with it are receiving priority attention to either confirm that current regulatory practices and policies are sourd, or to identify potentially needed improvements. These NRC studies will be coordinated with the many ongoing national and international activities. Any new requirements arising from these investigations will be evaluated in accordance with the Commission's rules and 'p'ractices.

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