ML20214N534
| ML20214N534 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/05/1987 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML20214N479 | List: |
| References | |
| NUDOCS 8706020205 | |
| Download: ML20214N534 (57) | |
Text
_. .
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- ORIGINA'_
UhliEU STATES .
NUCLEAR REGULATORY COMMISSION .
. . IN THE MATTER OF: DOCKET NO: 50-443 MEETING BETWEEN NRC STAFF AND LICENSEE RE: SEABROOK PETITION
/ , ,
s LOCATION: BETHESDA, MARYLAND PAGES: 1 - 55 DATE: TUESDAY, MAY 5, 1987 ACE-FEDERAC REPORTERS, INC.
444 Cap Street 0706020200 070019 3 Washington, D.C. 20001 PDR ADOCK 0000 (202} 347 3700 ,
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, . _ l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 3
MEETING BETWEEN 4
NRC STAFF AND LICENSEE 5
RE: SEABROOK PETITION 6
DOCKET NUMBER 50-443 7 DISCUSSION ON TECHNICAL MERITS I 8 Nuclear Regulatory Commission l Room P-118 1
9 Phillips Building 7920 Norfolk Avenue Bethesda, Mary 1and 1,
Tuesday, May 5, 1987 i 11 The meeting convened at 1:15 p.m., Victor Nerses l 12 presiding.
1
/ 13 PRESENT:
14 VICTOR NERSES, NRC/NRR/PDI-3, PROJECT MANAGER i
JIM MOODY, NHY, RELIABILITY & SAFETY MANAGER 15 PETER LITTLEFIELD, YANKEE ATOMIC, MGR., RAD. ENG.
- SHENGDAR LEE, YANKEE ATOMIC, MGR., RAD. ENG.
l 16- ROBERT E. SWEENEY, NHY Bethesda Office
! KENNETH M. O'GARA, NHY, NUCLEAR LICENSING 17 JOHN DISTEFANO, YANKEE ATOMIC, RADIOLOGICAL ENG.
RICHARD HAMPE, NHCDA 18 T. C. HARPSTER, NHY, DIV. E.P.
l LARRY W. CELL, NRC/!LRB, NUC. ENG.
l S. SPICKLCA NRC/DRPER, METER 0 LOGICAL 19 FALK KANTON, NRC/NRR/EPB STEVE LONG, NRC/NRR/DRPEP 20 RICHARD BARRETT, NRC/NRR/DRPEP FRANK CONGEL, NRC/NRR/DREP, DIR. DREP I 21 MARTIN EBERT, NUS CORP.
TIM MARGULIES, NRC 22 CHRIS BATY, BECHTEL - SERCH TED FEIGENBAUM, NHY, VICE PRESIDENT LINDA CORRE!A, CONGRESSMAN MARKEY'S OFFICE 23 SHERWIN TURK, NRC/00C Q]
25 i
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l 8230 01 01 2 IH/bc 1 PROCEEDINGS 2 MR. NERSES: Welcome. I am Vic Nerses. We have 3 a meeting today that we hope to cover some of the technical 4 merits review work that we have done, and possibly listen to l 5 some of the progress of work that you folks have identified, 6 I guess, back March 25th, that you were going to be working
(
7 on.
8 And before we get started in our meeting, what I 9 would like to do is have a chance to introduce ourselves and l
10 also give our transcriber an opportunity to confirm the l
l 11 seating arrangement that she has set up for us for today.
12 My name is Vic Norses. I am the acting
() 13 Director of Private Directorate 13 and also the project 14 manager for Seabrook.
15 MR. CONGEL: I am Frank Congel, Director of the 16 Division of Radiation Protection and Emergency Preparedness.
17 MR. BARRETT.: I am Rich Barrett, the acting 18 Branch Chief of the Risk Applications Branch.
19 MR. LONG: I am Steve Long, Risk Analyst.
20 MR. FALK: I am in the Emergency Preparedness 21 Branch.
22 MR. SPICKLER: I am in the Radiation Protection
(
23 and Health Effects Branch, and I am the Meteorologist.
24 MR. BELL: I am Larry Bell, Nuclear Engineer,
() 25 ILRB. Prior to reorganization, I was in the Reactor Systems l
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8230 01 01 3 OH/bc 1 Branch and did the dose calculations.
2 MR. EBERT: I am NES Corporation.
3 MR. ARGULIES: Inspection and Licensing.
4 MR. MOODY: Bechtel Tower.
5 MR. HARPSTER: I'm with New Hampshire Yankee.
6 MR. SWEENEY: I am New Hampshire Yankee.
7 MR. LEE: I am with Yankee Atomic.
8 MR. LITTLEFIELD: I am with Yankee, Manager for 9 Radiological Engineering.
10 MR. MOODY: I'm New %ampshire Yankee, manager for 11 Reliability and Safety Engineering.
12 MR. DISTEFANO: Distefano, from Yankee Atomic c
O la Radiolooica1 Eaoineerias.
New Hampshire Yankee.
14 MR. O'GARA:
15 MR. HEMPE: Dick Hempe, National Civil Defense.
16 MS. CORREIA: Linda Correia, C-o-r-r-e-i-a.
l 17 MR. NERSES: Before we go on, I would like to .
18 state that we are sending around an attendance list here and 19 we would have you all sign it if you would be kind enough to 20 sign your names.
i 21 Frank, do you want to start off with any comments 22 on this before we get into the actual meaning?
l 23 I was thinking that we could start in discussing 24 the work that we have done, Design Basis Accident 2
- V 25 Evaluation.
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8230 01 01 4 I H/bc 1 Do you want to start out getting into that, or do 2 you want to preface with some comments?
3 How do you want to do this?
4 MR. CONGEL: I would like to give you a little 5 bit of a history. As people here are most likely aware, we 6 are just a little over two weeks into our new organization.
! 7 With the establishment of the new organization, my group 8 has assumed some of the primary technical responsibility for 9 reviewing your submittal.
l 10 This has resulted in a little bit of a delay, 11 although what I trould like to do today is describe to you 12 some of the results that we have come up with and have some
() 13 dialogue with you.
14 What we are discussing with you is not our 15 complete, nor is it a conclusionary type of thing. It is 16 just to give you a status report.
17 I would like to tell you right now also that, as l
l 18 a result of or as these calculations and evaluations and 19 review are going on, we are having discussions at other 20 levels about the policy matters involved with this j 21 application.
22 As I understand it, today we will be talking 23 about two criteria, primarily two criteria of your 24 applications. The calculation of the design basis accidentt
(;)
1 25 and the rationale for extending protective actions beyond 1
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8230 01 01 5 f^ H/bc 1 the EPZ.
2 So, in your case, beyond the one mile EPZ.
3 That's all I can say right now.
4 MR. NERSES: Jim, do you want to provide some 5 comments?
6 MR. MOODY: Yes. Let me tell you what we were 7 planning. We have a prepared presentation on the DBA 8 criterion -- we do not have anything prepared as far as 9 presentation on criterion 4, although we are prepared to 10 talk across the table.
11 Just to give a little background, we submitted 12 analysis for criterion 1 in December. And a few weeks ago,
() 13 we got the staff's preliminary analysis.
l 14 This is another. You are very familiar with l
15 design basis accidents, so I will not-spend a great deal of 16 time on this except to say that the assumptions used there 1
17 are the standard assumptions according to the regulatory 18 gu, ides in the standard review plans. Essentially, the same 19 source term, 100 percent of the noble gas is 25 percent of 20 the Lodines.
21 Containment spray, that was limited in terms of 22 its elemental iodine removal rate. The containment leakage 23 according to the tech spec value at 15 percent per day.
24 Seabrook has a secondary containment which acts
() 25 to collect leakage from the primary system and then to I
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(]'H/bc 1 release it via the filter system. And we took credit for 2 the filter system in that release. Five percent 3 meteorological disbursion was used to calculate the . doses at 4 the exclusionary boundary.
5 (Slide.)
6 The result of that analysis in the FSAR show that 7 the doses are about 1.7 rem full body, and 77 rem to the 8 thyroid. Those are the two R values at that exclusionary l 9 boundary. Quite a bit lower than the 10 CFR 100 citing 10 criteria, and one of the primary reasons for that is the 11 secondary containment with the filter system.
12 (Slide.)
() 13 Now, if we take those loss of current accident 14 doses and extrapolate them using the same methodology that 15 was used in NUREG 0936, that is using a Y over X over R to 16 the three halves power for determining how that dose falls 1 :
17 off with distance. The result was that the whole body doso 18 excoeded neither the upper or lower protected action guido i 19 levels at one mile.
l 20 The thyroid upper protection active guide was 21 exceeded about 1.2 miles, and the lower protective action l
22 guide for the thyroid about three and a half miles.
23 (Slide.)
l 24 With those results, we went back and looked at
([) 25 0936 to see how the results of the other plants that were i
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8230 01 01 7 lH/bc 1 analyzed by the NRC looked.
2 And if you look at whole body dose, you see that 3 somewhere -- this is a cumulative frequency plot that is 4 presented in 0396 versus a whole body dose. Roughly 5 5 percent of the plants exceeded the lower protective action
! 6 quide level and none of them exceeded the upper protective l
7 action guide level at 10 miles. This curve is plotted for a l
8 10-mile distance.
9 (Slide.)
10 A similar curve for the thyroid dose showed that 11 roughly 30 percent of the plants penalized by the NRC 12 exceeded the lower protective action guide for the thyroid t
1
() 13 dose. And again none exceeded the upper protective action 1 14 quide level.
I 15 Based on this, 0396 had a concluding statement 16 that essentially said that, based on the fact that neither 17 the whole body dose nor the thyroid dose exceeded the upper 18 protective action guide level at 10 miles, that this the 10 19 miles was a suitable basis for emergency planning zone l
20 boundary.
( 21 Based on that conclusion, we have used i
l 22 essentially the upper protective action guide levels as our l
l 23 criteria to determine what is a suitable emergency planning 24 zone distance.
h 25 (Slide.)
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( 'H/bc 1 If you take a look at the curves in 0396, which 2 essentially plotted the two-hour whole body dose versus i 3 distance, and we have added Seabrook to the 0396 curve, the 4 Seabrook whole body dose is considerably lower than either j 5 the 50 percent or the 10 percent probability values of the 6 plants analyzed by the NRC.
7 And, essentially, it does not exceed the upper 8 protective action guides at any distance. In fact, it is 9 built of the upper protective action guide at the 10 exclusionary boundary.
11 12 O 13 14 15 16 17 i
18 19 20 21 22 23 24
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H/bc 1 The same curve for thyroid dose applies.
2 (Slide.) ;
3 This essentially shows again that the Seabrook 4 curve is significantly lower than the 50 percent value of-l 5 the plant's analyzed in 0396. It covers the upper 6 protective action guide by two miles.
7 Based on these curves and our interpretation of 8 0396, we have concluded that somewhere around the one mile 9 EPZ would be appropriate based on th) design basis accident 10 analysis criterion.
11 We then received the NRC letter last week, which 12 talked about their analysis for design basis accidents for h,) 13 Seabrook and gave us some plots comparing their analyses .
14 done a couple of different ways versus our analysis.
15 This is the one for the whole body dose. This is 16 the lower protected action guide line here (indicating).
17 It essentially shows again that all three curves, 18 that is, the Seabrook as proposed and our submittal, and the 19 two NRC curves, all fell again below the upper protective 20 action guide level at one mile.
21 (Slide.)
. 22 The thyroid dose, this is the upper protected
- 23 action guide, and this is the lower (indicating) . -
24 And you can see that those three curves now cost h 25 the upper protected action guide at different_ distances.
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8230 02 02 10 m H/bc 1 As stated earlier, the Seabrook curve, the lower 2 one crosses at about 1.2 miles. The NRC design basis 3 accident curve, the middle curve, cross at about one and a 4 half miles. The difference there being the fact that the 5 NRC has calculated 87 rem thyroid-dose at the exclusionary 6 boundary as opposed to our 77 rem.
7 And so that accounts for just the difference, the 8 small difference between those two curves. That is very 9 close agreement between those two analyses..
10 The top curve is based on the same exclusionary 11 boundary dose, but it is now used in Seabrook specific 5 12 percent meteorology to extrapolate the dose beyond the site-() 13 boundary.
14 So it is a dif ferent methodology then used in 15 0396, which just used the common generic exponential factor.
16 of 1.5 for that decrease.
17 It accounts for the fact that now, with the upper 18 curve, it crosses the upper protective action guide at-
- 19 roughly 2.2 miles. Actually, the curve should come down 20 morelikethatwhenyouactuallydraw.asmoothcurveinsteak 21 of a straight line, and it crosses at about 1.2 miles 22 (indicating).
23 There is not really bad agreement. There's a 24 difference of 1.2 and 1.5 and 2.2 miles for the point where
(;) 25 the upper protective action guide is exceeded accofding to i
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11 1 the.two analyses.
/{H/bc' c .2< (slide.)
3 Now, the biggest difference'that we believe L, t4 between the1way'-- the difference'between the '87 rem at.the
<V 5 exclusionary boundary that the NRC has calculated, and the
.,6 '77 rem that we have calculated,.is in the dose conversion 7 ' factors for the iodine nuclides.
8 The NRC.is using, we believe the value is from 9 TID-14 844, which are, based on the ICRP 2 iodine dose 10 conversion factors. Roughly, 1959 publication.
11 Since then, there have been a number of updates in the dose conversion factors published.
i 12 One came out in 4
() 13 regulatory guide 1.109. I don't remember exactly what-year 14 that was put out, but those are the values we are now using 15 in our design basis, accident analysis.
16 And you can.see the iodine 131 or equivalent,.but 17 most of the other isotopes, the conversion factors are 18 substantially lower than the.old ICRP-2 guides.
19 The most recent set of values that we have seen 20 are based on ICRP 30. Those are even lower than the l
21 regulatory guide values, and have been used in WASH-1400 j 22 analyses, and are used in Rule D crack codes that are used 23 in probabalistic analysis today.
24 MR. BARRETT: Do you know which values were used
,m
(,) 25 in 0396?
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. :. L...-..- .- . :-.- ; a. . :.vl. . L 8230 02 02 H/bc l' MR. LITTLEPIELD: I believe what they did, .they 2 just used-the applicant's LOCA' analysis. So, whatever the 3 applicant had used was probably what was.used. I may be ,
4 wrong.
5 MR. CONGEL: .It was probably-2.- That was used 6 for quite a while in the design basis accident. TID 14844.
7- MR. LITTLEFIELDr But we.have' estimated and this 8' is at a little -- but we had estimated that if in fact the 9 NRC had used the reg guide 1.109 values, they probably would 10 have calculated the exclusionary boundary dose of something 11 like 72 rem.
12 '
~
So that change alone was enough to make that kind O 13 of a difference in the dose at the exclusionary boundarv.
14 (Slide.)
15 If they had done that, then they would have .
16 gotten a curve, again, using-the Seabrook site-specific 5 17 percent meteorologic values. That-is, the upper curvei if 18 they had made the dose conversion factors ch'ange, they would 19 have gotten something like that purple curve, which now 20 crosses the upper protective action guide at something.just 21 short of two miles.
22 So it makes that kind of. a difference in the 23 point where you cross.that magic line, depending on.what the 24 dose is,_ that you get at that exclusionary boundary.
h 25 (Slide.) l t
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H/bc 1 Now, to use the upper curve for_just a moment, 2 going back to 0396, to use the value t'o extrapolate the dose 3 from the exclusionary boundary out in distance, which was 4 essentially a 1 over R to the minus -- 1 over R to the three 5 halves, exponent.
6 That value was. referenced in 0396 and apparently 7 came from a Turner workbook on meteorology published in the 8 sixties, which had some curves in there that looked like' 9 they essentially followed a 1 over R to the 1.5 power log.
10 A more recent publication than that, NUREG CR 11 2858, which was a report on design basis accident 12 meteorology, essentially says that exponent 1.5 is good for
() 13 stability classes D, E, F and G out to aboud one thousand 14 meters, and beyond a thousand meters, which is the area that 15 we are really talking about here because that is where we 16 are extrapolating from the exclusionary boundary on out, 17 that, in fact, that factor, that exponent is 1.5.
18 It is appropriate for D stability only. So what 19 I guess I am suggesting is that by going to the -- the D 20 stability is more in line with what we would normally expect.
21 to see for a 50 percent meteorological value as. opposed to a l
22 5 percent.
l 23 So, if by changing the basis for that dose 24 extrapolation from the three halves power log to a site
(') 25 specific 5 value, it really represents'a fundamental change i
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. H/bc 1 in the way that dose is extrapolated. l 2 And we would'suggest tha't if you'are' going to.use 1
( 3 Seabrook site-specific meteorology, it probably is more
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4- appropriate to use 50 percent values than it is to use 5 j 5 percent values to be in'line with the 0396 assumptions.
6 But, easier th'an that is probably-just to stick' 7 with the three halves power law ~that was used in.0396 and i
8 compares Seabrook on the same basis that the-10-mile EP2 was 4 9 defined for..
1 10 (Slide.)
i 11 I guess, if you make both of the changes that I 12 have just talked about, it is no surprise that now the NRC i
i O 13 c1 ar fa11s virtua111 on too of the Seabrook curve.
14 That is, if you make the change back from this
- 15 three-halves power log and to change'the dose conversion 16 factors, then the NRC essentially falls on top of ours.
17 Most of the differences lie in those two areas of 18 discussion.
4- 19 (Slide.)
20 And, finally, one final thing I would like to 21 talk about. And that is the protective action guide levels ,
22 themselves for the thyroid dose were based roughly on a l- 23 ratio as I guess of the ICRP-2. That is, the ratio from I.
24- thyroid dose to whole body dose is a factor of 5 for the h 25 protective action gu,ide; instead of 1 in 5 rem, the numbers
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2' Since ~ that --those numbers were ' de' fined ' ICRP-26,
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3- has been published. And with another set of risk ratios, if -
'4 you will, between any. organ dose and.the whole body, and it 5 is essentially to make the organ dose equivalent.to the' 6 whole body.
7 The NRC, back in January of-last year, has 8 proposed a revision to 10 CFR 20, the basis of which is the 9 new ICRP 26 values for weighting factors and dose 10 equivalents.-
11 Back in November of last year, or approximately 12 earlier than that, the ACRS started discussions about the O la u or nu bers that were used for thyroid protective action 14 guides, essentially concluded tha't those-numbers were way 15 too low based on ICRP 26, and sent a letter to-the 4-!
16 Commission asking that the Commission.try and expedite the 17 change in those thyroid protective action guide levels on i'
)
18 the part of EPA to bring'them more in line'with-ICRP 26 19 technology and essentially raise those numbers up to.a-more j ,
-20 appropriate value.
21 22 t:
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I 8230'02'03- 16 Q'/bw wW 1 In January of this year, the president _has.
2 . approved in the Federal Register, the EPA guidance for 3 occupational exposure for federal agencies, and again, that-4 is based on ICRP 26. Essentially, all ICRP 26 is, it uses a 5 weighting factor of .03 for the thyroid, which'says that 1 6 rem exposure to the thyroid.is equivalent to some 30 times 7 or 30 rem exposure of thyroid _is equivalent'to something on-8 the order of 1 rem to-whole body. If you, in fact, try to
~
9 decine today, based on ICRP 26, the set'of protective action--
10 guides, my guess is, you would end up with something'like 30 11' rem for the lower protective action guide and-maybe a number 12 of 50 rem for the upper, if you used the non-stochastic O 13 limit' recommended by'ICRP'26.
14 If you ignore that, then you have a number of '150 15 rem for the upper protection action guide.
16_ So I believe that based on our current-best 17 understanding that we have on the international agencies 6n 18 radiation biology, those protective action guides are low by- -
19 a factor of about 6 in their present state.
20 In any case, if you plotted what might be a new.
^
21 set of protective action guides for the thyroid on the dose 22 curves, now looking at the- lower and the upper _ values of 30 23 and 50 rem, you could see it does not much matter how you do 24 the LOCA analysis itself.- Virtually-all of the numbers O 25 beyond one mile are below the upper protective action' guide t-ACE-FEDERAL RseonTsas, INC.
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2 The bottom line of all of this'is that there 3 appears to be a number of good reasc'rs based on the most 4 current values for things like dose ansessment, dose.
5 conversion factors. And the protectire action guide levels 15 that would warrant something on the ord?r of 1: mile EPZ for 7 Seabrook.
8 That is the end of my prepared statement, Jim.-
9 (A pause.)
10 MR. MOODY: Comments or questions?
11 MR. NERSES: They want to go ahead, Steve.
12 Comments or questions.
O 13 MR. BARRETT: I have a question, and it is 4
14 probably the simplest that will be asked here this I
15 afternoon, so why don't we do it first?_. We'go~all the ay
- 16. back to the beginning of the presentation where you are 17 comparing the 10 mile doses from 0396 with your calculations
, 18 for Seabrook, and you'see this. All of the comparable doses-19 appear to be much closer in.
20 Is that due entirely to inclusion of-the 21 secondary containment'in the analysis? Is that the primary 22 reason?
23 MR. LITTLEFIELD: I think that the secondary i
24 containment, possibly the containment spray system, are the 25 primary reasons for that; yes.
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8230H02 03 18 fouW/bw 1 MR. LEE: A major factor for_ loads or offsite 2 dose at Seabrook is large leak type containments.
3 Secondly, we have the spray system which releases 4 the iodine, and the third one is with a filter system, 5 filters out items, 60 percent bypass. It reduces a lot of 6 the iodine in the release.
7 MR. LITTLEFIELD: I think that is the major 8 reason.
9 MR. BARRETT: The major one being the third one.
10 MR. LITTLEFIELD: Yes.
11 MR. BARRETT: If you had analyzed a number of 12 other plants, if a number of other plants have been analyzed O 13 to get the guidelines on 0396, presumably, there would be a 14 lot of large dry containments with sprays.
15 MR. LEE: Seabrook is one of the largest
- 16. containments, 2.7 million cubic feet. It is one of the 17 largest, so the leak rate, a small amount of the iodine that-18 can be released per day, and it sprays up to the filter.
19- MR. LITTLEFIELD: There is a lot of dry 20 containment in sprays that have a lot of other things. They 21 would all be factored into that curve. They have a lot of 22 BWRs, some PWRs without sprays.
23 MR. BELL: It seems to me that 0396, in one way 24 or another, mixes apples and oranges, and it takes a design O 25 basis accident, which is using TID 14844, and it is a i
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3 On that basis, the study itself may, be. f aulty.
4 You can not mix apples and oranges.
5 MR. LITTLEFIELD: 'I agree, Larry. It is 6 difficult for us to go on.from that base.
7 MR. LEE: Because of that, it is not consistent 8 . with the design basis?
9 MR. BELL: When they took the results from the 10 FSAR, those results were calculated, based on site 11 meteorology and TID 14844. And when they extrapolated-it 12 out, they were not using site meteology,.they were using O 13 some kind of an averaging meteorology that may.or may not.be 14 applicable on a design basis case. And therefore, you are 15 taking an engineering result that was done under one premise
- 16. and applying an entirely different premise.to it, which is.
17 not logical.
18 MR. LITTLEFIELD: It may-not have.been to have I l
19 been tco bad of a assumption, which is the interesting 20 thing, when you consider the fact that you are talking about 21 meteorological conditions that are amenable to wind shift.
22 In other words,--there is a very-stable meteorology with low' 23 wind speeds and 0396 addresses those kinds of things.you :)
l 24 see, breaks and shi-f ts. And so maybe'there is some. valid b 25
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8230.02 03 20 pb6W /bw 1 am not a meteorologist.
2- MR. SPICKLER: lThe 1.5, if: you look back at TID .
3 14844, it is not in the sigma type.of parameters-that we see-4 today, but it was 11 CYCZ&N. And if you work it out, you
.5 see the relationship is to 'the three halves power and' the 6 original TID 14844. We diverged from:it over the years,' and.
7 instead of using the canned parameters as in TID 14844, we 8 decided to let the meterological data at the sites determine ~
9 what the parameters were. And we-shifted from.using those 10 stylized CYCZ&N values that TID 14844 had to the Pascal 11 Gifford sigma Y and sigma Z parameters. And we used DF.
12 curves,.the G curves, et cetera and all of the Pascal-k~) 13 Gifford and Moore modifications on that, based on the low 14 wind speed fusion and modifying our criterion with regard'to 15 probability and taking into account the-actual distances
- 16. around the site and the actual directions.-
17 We came up with the present modeling that we.use 18 now in Reg Guide 1.145, which is what was used in our 19 analysis here. That gives you a bit of the history, but I 20 think that the three halves, itLis in Turnerfs work, but 21 goes back,. basically, hand to hand with the parameters in-22 TID 14844.
23 MR. LITTLEFIELD: It goes back beyond that.
24 MR. SPICKLER: It goes back to the. TID 14844. If 25 you look at the original CYCZEN values in the. equation that t
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2 MR. LONG: Let's go back to what is written in 3 0396 and read a couple of sentences.
4 "For ground level releases without a wind shift.
5 Those decreases with downwind distances are in proportion to 6 R to the minus 8 power, where A is between 1.5 and 3, 7 depending on the stability class prevailing at the time."
8 And then they say, "For the NRC Staff assumption 9 conditions, EG Class F conditions with low wind speed and 10 for average dispersion conditions, EG Class D stability, a 11 value of 80 equals 1.6 provides a good approximation for 12 doses -- for purposes for projecting dose rates with O 13 distance from an exclusionary boundary."
14 It is not clear, if they thought they were 15 picking one or the other, they kind of threw them both
- 16. together.
17 MR. LITTLEFIELD: If you look at the curves in 18 Turner's workbook, it looks like they are parallel for D&F, 19 which would lead you to believe that the same exponent is 20 applicable to both cases. I am not sure that the words are 21 in Turner's workbook that would support that, but it would 22 lead you to believe that, but whatever work has been done 23 -subsequent to that now would lead you to believe that is 24 only true out to certain distances.
G 25 MR. LONG: When they wrote 0396, they were t
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5 MR. SPICKLER: Your comment about the NUREG' -
6 document. They-are not requirements or-guidance documents.
~
7 They are just information documents, and we do.not apply 8 them in our dose calculations. We are talking about design 9 basis accident calculations. We followed the Pascal-Gifford 10 curves as modified a la Reg Guide 1.145. So there is a-11 confusion that many people think'that_because something is 12 in a NUREG document that it is automatically endorsed b'y the C:) 13 NRC. It is not. It is -- NUREG, by'the nature ofEit, is an 14 information document. The_only documents that are hard and 15 fast, more hard and fast areLregulatory guides'and standard
- 16. review plans. l 17 Those are the documents that we stand behind and 18 say, if you do your analyses a la these-documents, we will H 19 buy them. So although I hear what you_are saying about'the i 20 NUREG documents, it really -- it .is not germane, 'as far as 21 the application toward design basis accidents analyses. l i
22 MR..LITTLEFIELD: We have gone-beyond design q 23 basis accident analysis. We are talking about the emergency 24 planning zones, O 25 MR. SPICKLER: I understand i
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4 MR. SPICKLER: Information document.
5 MR. BELL: You have gone -beyond it, it is true, 6 but what you are using is only the analysis only,.the basis 7 of the framework. You've got to stay 1within that framework 8 all the way down the line. You cannot depart at some point
.! 9 and throw something else into it.
10 Now if you want to use a different-premise' for 11 calculating your doses, okay. That is something else. You
~
4 12 say within that premise. Once you start a design basis
() 13 analysis, then you have to stay within that-framework. You 4
14 cannot use 5 percent meteorology calculating your dose and i
15 then use 50 percent meteorology and calculating the dose for j 16. the PAG or for the EPZ zone.
j 17 MR. LITTLEFIELD: I would agree, except what you
) 1& have said, that 0396 has already done that. They-have 19 thrown us into that new regime of apparently using one set l.
20 of conditions to do one thing, although they may not.have l 21 realized what they were doing at-the time.
1 I
22 MR. BELL: But that is information. It is not i
l 2'3 the way we do analysis. It is an information document. It 24 is not a licensing basis. What you are talking about here (N 25 is a licensing basis. What they did in the NUREG is.not a i;
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2 MR. LITTLEFIELD: It is the only basis we have 3 for the 10-mile zone.
4 MR. MOODY: It is a licensing basis for the 10
- 5 mile EPZ. From what I undestand, the DVA analysis, they did 6 something that might be equivalent, from the results of the 7 DVA analysis,~the same as they did for severe accidents.
8 There is the best estimate, 50 percent for accident 9 frequency, best estimate for consequence analysis. They 10 took the DBA results and extended it with "the best estimate 11 three halves power, possibly." I am just throwing that out.
12 I don't know. That is the licensing basis that we have O 13 right now. -
14 MR. BELL: Is that in the regulatory guide or is 15 that your review plan?
16 MR. MOODY: O Reg 0396, and it is referenced in 17 the regulations. l l
18 MR. CONGEL: That is true. I know what Larry is l 1
19 getting at. When you do a design basis accident study, I 20 think all of us here know that the parameters to which you 21 calculate are used to set certain levels of equipment that 22 may be specific to the site where that piece of equipment 23 sets. All of the reactors of certain types start out the l
24 same way and how many filters you need or whether the kind O 25 of systems you need.at the end of the design stage is t
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3 of the site, meteorological-characteristics, and so1on.
4 That part is for setting the final design, and'it really is 5 not necessarily related to setting esposure or even 6 acceptable or even implied acceptable. exposures to.the 7 general population. Part 100,'for example', is;a 8 calculational approach that is used for the designers to 9 determine what levels of equipment and protection-are 10 necessary in a system to make it satisfactory for that side.-
11 What we have discussions going on_here about, I 12 thinking using the framework of what.we know about. accidents O 13 and accident scenarios. Once'we have the reactor configured 14 in an acceptable manner at the site, you can'use an analysis 15 to determine some of the finer structure, within a bigger
- 16. structure, like A 10-mile EPZ is what is generally 17 required. How do you take into consideration site-specific 18 conditions? ,
19 This document gives you some flexibility in ,
t 20 determining how you take into consideration local ;
21 conditions, how much of a variation you can-get, I don't
-1 22 know. You cannot hang your hat entirely on the methodology l 1
I 23 presented here. I do not regard.this as the ultimate in 24 radiation protection matters for the general public. And O 25 'certainly-thi.s document was intended to take into i
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. ouwbwi 1- consideration maybe transient populations. I know'one 2 example that came to mind is a Midwestern plant, where just 3 the'end of the boundary intersected another state, was it 4
4 neessary to activate the whole state for this corner? 'Those-5 kinds of things.
2- 6 Now where you are using it, or you are using it t 7 in part to develop a technical base for a significant 8 change. So we have to be careful how far you1can push the 9 analysis.
10 What I want to do this afternoon is listen to 11 your thinking and your technical basis, but'I wanted to step 12 in, because the discussions that you are-having are starting
(-) -
13 to get into the area where we are naot keeping clear what is 14 done for engineering and calculational purposes and.what is 15 necessary to protect the public health and safety. Indeed, t
- 16. there is that difference. There is a distinction, and that
}~
17 is what Larry was getting at, and I agree with him.
18 We are in an area now where,-like I said, we are 19 entertaining an application,on your part for a technical i 20 basis for shrinking, and that is the point.-I don't see any 21 need to go any further.
! 22 Is there more discussion on either side, where we !
I i 23 can talk about the technical basis of the presentation on i
24 design basis accidents?
(2) 25 MR. BELL: We did that already.
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f 2 MR. KANTOR: Does'the design basis ~LOCA give'you 3 your highest dose?
, '4 MR. LITTLEFIELD: Yes.
- i. -
] 5 MR. FEIGENBAUM: Are we going'to discuss at'all, I
i 6 Jim, what the criterion is that maybe the NRC feels we i
i[ 7 should be using, so that we can -- apparently we have some 4
! 8 flexibiity to adjust making changes to the plan.
l 9 specifications, bypass fractions, those kinds of things. We I
- 10 would like to come to at least some understanding as-to what i
11 criterion you will be judging our technical basis on, so
) _
12 that we can go back and make adjustments, if necessary.
( i 13 MR. CONGEL: At this point, as I said when we i
i 14 first started out, we want to' hear what you have to say, 15 since it is an application for an exemption, and I think you i
- 16 know we have never had an application of this sort before.
)'
17 We want to evaluate what you have, look at in the context of 1
j 18 what is required on our part, both legally and technically, 19 to grant such an exemption.
j 20 So right now I cannot give you any advice back, 21 because we do nto have any set criteria, except what is in i 22 the regulations. At the point we are at right now, we are 23 looking at the technical submittal. We had some questions, s
24 and as you know, we have had some interactions. We talked tg 25 about some technical submittals. That is where we are at.
l
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82,30 04 04 28 LWbw 1 We are not in any position to give you feedback yet,:just'
! 2 ' questions on what you have submitted..
, -3 MR. FEIGENBAUM:~ You understan'd on what criteria
- 4 you set with, what methodology you agree on. We can.go back
'5 and make some adjustments..
j 6 MR. CONGEL- I. understand that.
i 7. MR. MOODY: That was my. fourth objective,.the i .
} 8 fact that we have used the upper PAG as our criteria, and if ,
9 that is'not acceptable, we need-to know exactly what tha't4 10 criteria is and the calculational methods. Otherwise, we
]
i 11 cannot go any further, really.
4
! 12 MR. CONGEL: That is a fair enough question, but l # ~
13 I can tell you now.that we'are not in a pos'ition where we
{ 14 can come back and say that we need this little piece changed 1
! 15 and that little piece changed, because the overall i
l 16 evaluation is a package, and there is no set' calculational 17 procedure for determining whether we have a yes, no, go, no- ,
j 18 go situation. So we have to look at the overall package. [
l 19' What I want to do right now is make sure that we ;
20 accurately understand what you have submitted, and if we l 21 have any questions, we can ask them now, but that is as far P
! 22 as I can go this afternoon.- j 23 MR. FEIGENBAUM: .The only. point I want to make ]
! 24 is, we do not want to go too far down the road where you 4
O 25 draw conclusions without having -- without us having the i
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8230 04 04 29 ouWbw 1 benefit of knowing what your final acceptance criteria was 2 and your methodology.
3 MR. CONGEL: I appreciate that. And I will get 4 back with you as soon as I can. I really have to evaluate 5 the overall picture, and as I said at the beginning, there l 6 is even some policy involved here, because -- let's discuss 7 just a little bit of what 396 did. We really started out 8 with a judgment. I saw a judgment because it was not a 9 specific model that people start out with within parameters 10 in the nuclear industry, running it through a computer and 11 then out pops ten miles. We all know there was a lot of 12 judgment and feeling involved in coming up with ten.
O 13 After the value was established and there was a 14 general consensus that that kind of a zone would, in 15 general, be sn*ficient for protecting the public, it would l
16 also serve as a basis for expanding beyond the zone, if a l 17 need arose. An analysis such as was done in 0396 was done I
18 pretty much to see, after the fact, if we could learn any 1 19 more about the ten miles or if the kind of engineering l 20 judgment, scientific judgment, that went into the ten miles 21 was good, was consistent. I think that is what 396 did.
22 Now we are coming up with a question that you are 23 proposing to us, looking at the basis as you understand it
)
24 technically, as we understand it technically, to see if U,_
25 support could be given for -- once you do a realistic i
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buWbw I assessment and take into consideration your plant-specific 2' factors, could you support a different or a smaller radius?
3 I am giving this little speech, simply _because, 4 knowing that we do not have a model where.you put' input 5 parameters and out comes ten miles, I can look at your 6 specific parameters, but I can't come up in a very simple or 7 easy way, as we all appreciate here, with a number other 8 than 10. I have to do some very careful looking.
9 The looking I have to do is an overall, big 10 picture view. And I repeat, I will discuss the details of 11 what you have today, but I cannot give you any feedback yet.
12 MR. FEIGENBAUM: Then, really, the ball is in the O 13 NRC's court at this point.
14 MR. CONGEL: Perhaps in the area of design basis 15 accidents. I think my technical guys have other technical 16 questions -- if not, we could talk about another -- we can 17 talk about criterion 4.
- 18 MR. LONG
- I would like to say one thing on the 19 DBA. One thing we put our fingers on when we did the 20 analysis here was Seabrook site specificidispersion is 21 somewhat worse than we have expected than the average when 22 we have dealt with other plants. The documents, in the 23 context of 0396 in the few years after dealt with stability 24 and something like two meter per seconds, one speed, for O 25 what they would consider to be a design basis dispersion L
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~ ~m 8230 04 04 31 buWbw 1 characteristic, and you would use that as a default, if'you 2 did not have your site-specific meteorology, when you did 3 your initial calculations.
4 The Seabrook dispersion looks somewhat worse than 5 that, and I think that is a factor that we have to keep in 6 mind, as we proceed in this. If we do end up setting 7 different radius over deciding whether to exempt from the 8 existing 10-mile radius, we may need to come back to you and 9 talk to you about how we would put various pieces of it 10 together. Just so'we are cl' ear, that is really the issue 11 that got raised. We have not resolved it, but that is the 12 basis of the discussion here,-the underlying factors.
O 13 MR. LITTLEFIELD: I'm tempted to say, Steve, that 14 has two impacts. Obviously, one impact is decreases 15 dispersion. The other impact is a slower cloud travel time.
16 One works against the other. Sometimes they may tend to 17 offset for planning purposes, if not for design basis 18 accident alone. There are other places in your rationale or 19 petition in 0396 or however you want to think of the whole 20 picture, where the travel time of the cloud would come into 21 play also. We recognize that.
22 MR. LEE: Also, in the low wind speed and l 23 stability conditions, the winds tend to shift. ,
24 MR. SPICKLER: It is in the 1.145 analysis'. It O 25 is in there.
1 i
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8230 04 04 32 ouWbw. 1 MR. LEE: A two-hour dose will not belthe whole 2 two hours. Because of the wind shift, people standing even-3 in one place would not receive as whole two-hour. dose, 4 because the wind will shif t 'tx) other places.
5 MR. SPICKLER: If.you recall, I said when we 6 developed the Reg Guide 1.145 methodology, we altered the -
7 Pascal-Gifford signal sigma y curves to take into account-8 very, very wide shifts. We essentially turned an F-9 stability into something-better than a D-stability in close, 10 inside of 800 meters, taking that into account. It depends 11 on how much more above and beyond that you are talking 12 -about, but in the time frames that we are. talking about, we O 13 are not talking very much greater spread than the big. spread 14 that we are putting into, because of the low wind speed 15 diffusion parameters. Don't forget that. That is inherent 16 in Reg Guide 1.145, which goes way beyond what Pascal did 17 when he came up with the original' parameters.
18 So I hear you, but it is a minor point, because 19 of the alteration we have made in the model.
20 I am sorry. I didn't want to get-into the same 21 discussion.
22 MR. CONGEL: Is there_anything else on that 23 particular topic?
24 MR. MOODY: No. Any questions, we are prepared H O 25 to help you on, as usual. If you need any information about -
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2 MR. CONGEL: I appreciate that.
3 MR.: MOODY . I indicated that we did not have a 4 prepared presentation on Criterion 4, but we are prepared to 5 discuss the' status of that review.
~
6~ MR. CONGEL: Could you give a brief introduction 7 of our concerns as we have discussed them.
8 MR. KANTOR: As Frank discussed, on the planning-9 basis, as described in 0396 and some of the background, when 10 you get to the fourth rationale, there is even less in:the.
11 way of specifics. There is a-lot of judgment that went into 12 the fact that the 10-mile was thought to give an adequate O 13 response base. To move beyond 10 miles, there are no-14 specific criteria or standards that were used to evaluate 15 that in other applications.
- 16. We just assumed that there was a full range of 17 planning for the ten miles that provides us a sufficient 18 base, a sufficient-justification to go beyond the ten miles 19 is necessary.
20 Now we start looking at your application, your 21 requests for the waiver exemption. So far, I think what swe 22 have seen before us is-the affidavit of John Robinson, which 23 discusses the fourth rationale.
24 You can correct me if I missed something U 25 someplace.
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8230 04 04 34 o Wbw 1 And in the affidavit, it just' really makes 2 statements that, if you have a planning to one mile, you 3 will -- you will have an equivalent response base, if you 4 would, at 10 miles. It is equivalent.
5 An example here says that the one-mile planning 6 zone will assure that adequate resources in all aspects of 7 emergency planning are in place prior to commencement of 8 operation.
9 There are several statements like that in the 10 affidavi'., and so f ar we have not seen enough information 11 for us to form a basis or a judgment on whether indeed there 12 is an adequate response base. So we would be looking to you O 13 to provide us some specifics on the type of information that i 14 we could review and reach a conclusion on, whether, indeed, 15 there is an adequate response base. Like I say, so far, all (
)
16_ we have seen is this affidavit and the statement's in there 17 that the re'sponse base does exist, but nothing in the way of 18 specifics or details.
19 At this point, I would like to ask, what is your 20 thinking along those lines? How do you see supporting this 21 fourth rationale with the one mile planning zone?
22 MR. HARPSTER: First, let me handle part of the 23 EPZ separately, which is the New Hampshire site.
24 As you are aware, we have a plan in New Hampshire U 25 -- as you know, we do have a state -- in the State of New
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_,. . , .4 8230 04 04 35 buWbw 1 Hampshire, it has submitted a plan which covers over 60 2 percent of the EPZ. Within the first two miles, in all 3 directions, that plan outlines the framework, what resources 4 would be available, how protective action decisions would be 5 made, how communication systems would function. It 6 integrates with the on-site plan, the notifications. This 7 has been demonstrated in the past in exercises. In the 8 State of New Hampshire, through its laws, has the ability i 9 and, specifically, the governor, to invoke other powers, if 10 it were actually an emergency.
11 So having reviewed that, let me talk about the 12 extension into the Massachusetts side. First, the State of
() 13 Massachusetts had in place generic level plans which 14 presently are used for three other nuclear plants. And this 15 is important because you have to recognize how emergency.
- 16. planning and emergency response take place in Massachusetts.
17 It functions on three levels. The command and control 18 functions, the-decisionmaking is done at the state level, 19 and it is done through the authority.of Massachusetts state 20 law. There are specific statutes which gives the governor 21 the authority in a nuclear emergency to do certain things.
22 These things are the same, whether at Seabrook, Yankee Rowe, 23 Pilgrim or Vermont Yankee.
24 These are state level actions that people at the U_ 25 state civil defense agency and the Department of Public
(
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8230 04 04 36 t,uWbw 1 Health are trained to take certain actions. They have done 2 them for the other plants, and they do them in other 3 emergencies. For example, the recent flooding.
- 4 When you get to specifically Seabrook, what is 5 different is, there is now a different area plan. Area one 6 versus one of the other five areas in the State of' 7 Massachusetts, and there are six specific communities which 8 are different than the other communities.
i 9 i
10 11 12 0 13 14 15 16 17 18 19 20 :
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, (7Wbur 1 The types of actions that are takenlin-the-area
'2 and local plans are not unique actions for a radiological ~
i 3 event and in fact are the same actions that were taken j' 4 recently in the flooding. There are decisions made, 5 . recommendations at the state level.. Those actions are 6' implemented through communications within-the area, w'ithin j 7 the towns.
8 There is nothing unique within those towns about
- 9 moving people, calling them up on the phone with the radio ,
2 10 network that has been' established. You do not use a j
- 11 different radio is it is a radiological emergency.-
l ~
12 So there is a framework there aside-from the l
O 13 oecific state otan.' There i e aucte r iaciaent aavi orv j 14 team, the NIAD as it is called in Massachusetts, that is
- 15 staffed not only by the Department of Public Health people.
16 but a variety of consultants from universities and other i 17 professional organizations.
18 The manual that they use for that response is a
.l j 19 generic manual. The procedures they use are the same, and
) 20 those are the actual distinguishing implementing procedures
! i
- 21 for a radiological event, that those procedures are the same l 22 whether it is Seabrook, whether it is Yankee Rowe, whether 1 i .I a
23 it is the portion of the vermont Yankee EP2.within d 24 Massachusetts. It is the data base that makes the
! O 25 distinction for s,ecific areas that they have to respond to.
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g 8230 05 05 36 Wbur 1 Again, talking about the framework that is in 2 place.that would allow emergency actions to take place, in 3 New England we have a series of compacts, and let me 4 describe some of them to you because they are very important 5 when it comes to having resources available, having police 6 powers to expand to.
7 First, there is an interstate civil defense 8 compact which all of the New England states belong to, and 9 we would be happy to provide you with the legal references 10 for all of these.
11 There is the New England Compact of Radiological 12 Health Protection. Again, Massachusetts is'a participant in
() 13 this. Beyond that, there is a New England State Police 14 Compact.
15 All of these compacts are vehicles by which the 16 government of Massachusetts and the Civil Defense Agency 17 have the framework to request additional resources at the 18 state level in the event of any type of emergency.
19 In addition to that, as you know, there is a 20 federal response plan. Ther,e are plans in place and 21 vehicles to obtain resources to do dose assessments, to 22 assist in communications many other ways through the federal 23 response plan. This is something that everyone is mandated 24 to plan for.
(}) 25 So that is kind of a summary description in .
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- (Wbur 1 ~s hort,1 that these things are in place. These are'not things-2 that.have not been exercised., These things have beenLused.
3- The state level plan has been exercised. In June of last' year-it was exercised last at Yankee Rowe,-and in 5 fact FEMA showed no draft-reports of that state level plan.
6 At the Framingham EOC they evaluated that with regard to the ,
7 coordination, and the coordination that has been exercised 8 at Vermont Yankee, again that has been evaluated by FEMA. I 1
9 The coordination has been demonstrated between the states of 1
10 vermont, Massachusetts, New Hampshire. So again this all 11 goes to supplant that framework, which is there to expand 12 upon.
() 13 And I guess with that I would be happy to answer.
14 any specific questions.
15 MR. FEIGENBAUM: There are a couple of other 16 things. I want to make sure these are crystal clear.
17 Our petition waiver calls for a one-mile EPZ.
18 Massachusetts is slightly over two miles away. So of course 19 the initial expansion is already -- out to two miles is 20 already covered by the New Hampshire plan that is in effect 21 in New Hampshire.
i 22 In addition to that, regardless of what comes out -
23 of our petition request for the one-mile EP2,-New Hampshire I
24 Yankee has signed an agreement with Civil Defense of New
()' 25 Hampshire to continue to plan out to 10 miles regardless of i
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-8230 05 05 40 1 what decision the NRC or what licensing action it takes with
()Wbur 2 regard to Seabrook's EPZ.
3 So that 10 miles for over'60 percent -- close to 4 70 percent of the EPZ will be in effect. ,-
5 So I just wanted to put that on-the record.
6 MR. HARPSTER: Let me go back and just review one 7 thing which I think is very important because we are talking ,
i 8 about ad hoc expansion.
9 What is important is certain elements of the 10 framework there. These things have all been recently 11 demonstrated, but aside from our integration with the state
~
12 and our ability to call on the statewide plan, which has
() 13 been demonstrated in the recent flooding, the state-14 established mass care centers. They exercise all the 15 communications because there was substantial flooding in 16 Merrimac County. Those communities had to activate their 17 ELCs. West Newbury, Massachusetts actually requested 18 assistance of us.
- i. 19 These things hapret. There is provision in place 20 to make them happen. I triak t.,,t we could go through just 21 the things that took place in the recent flooding and 22 demonstrate that most of your fundamental aspects of 23 emergency planning that have to take place below~the state 24 level at that area and town level actually happened in the 25 recent flooding, and I think they were implemented quite t
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i f Wbur 1 successfully by those towns and'by that area.
2 MR. KANTOR: What plans exist at the local 3 community level?
4 MR. HARPSTER: ' They vary from community to-5 community. The original plans-that were developed by the 6 towns in the 1985-86 timeframe and were submitted for 7 informal technical review at FEMA have been upgraded, and in 8 fact they have been informally reviewed twice by-both the 9 NRC and FEMA.
10 All of the comments that were made by FEMA were 11 incorporated into those. They have been substantially 12 upgraded, and it is my understanding that the State of O 13 Massachusetts, in discussino ith the other sites, the 14 ongoing upgrades, used those plans as the model for other 15 sites.to use.
16 So those plans have been submitted recently as IN the Seabrook station radiological emergency plan, but those 18 are good plans. They are far more detailed and have a 19 better base for successful emergency response than virtually 20 any other plans that I have seen around the country.
21 MR. KANTOR: Are there existing all-hazard type 22 plans at the local level?
23 You mentioned the-response to the flood. What 24 plans did they actually use in responding to the flood?
h 25 Their existing all-hazard plan, or did they use the e
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[))Wbur 1 l Massachusetts plan that has been developed?
2 MR. HARPSTER: We really have not gone back to 3 look at-specifically which plan they used. I-don't know 4 that we would be able to document which plan they'used.
I
- 5- What we do know is,they performed'the elements 6 that are within those plans.- They communicated with the
-7 area emergency operation center, which is the way 8 implementation of the information gets ' passed down from the 9 state, and that is the way that the information gets to the -
10 towns, that same communication network that would be used in .
11 a radiological emergency. The same telephone lines was used 12 to get the information to people in the Merrimac Valley and-l
() 13 other towns that needed to respond to the flooding.
14 There were people evacuated. They did coordinate 15 with federal agencies. The communications all worked.' The -
16 emergency broadcast system that is in place has nothing to 17 do with the nuclear plant that was required aside from 18 Seabrook, and that is in place.
19 These elements are all there now, irrespective of 20 whether they all followed step by step the procedure and 21 plan that they had developed to use for Seabrook. They did; .i l
l 22 perform those elements within the plans.
23 .MR. FEIGENBAUM: They actually moved people?
24 MR. HARPSTER: There was substantial flooding ~in
() 25 the Merrimac Valley, and many people moved from the towns.
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['Wbur 1 MR. KANTOR: How many people;were evacuated? -
2 MR. HARPSTER: I don't know the numbers.
3 MR. KANTOR: Can you describe the decisionmaking 4 process that you had in the plant and you would. notify 5 offsite? How would that work?
6 MR. HARPSTER: In accordance with'our own site 7 emergency response procedures, the operators in the control 8 room would pick up the telephones and notify the state 9 police, and at that point they would be notified in 10 accordance with our procedures the type of event that they 11 had.
12 We did have an event recently. The notification
() 13 was made, albeit somewhat late. There was a-lot of 14 confusion on whether or not the State of Massachusetts would 15 participate.
16 The fact that notification was made to the state
, 17 police, a call was made to the state Civil Defense Agency, 18 the Department of Public Health, just as the plans say it 19 should within the State of Massachusetts.
20 So there are procedures in place, and in fact 21 those are the same procedures whether it is Seabrook or 22 Pilgrim, to notify the state warning point. The state 23 warning point, which is the state police, then notifies the 24 state Civil Defense and the state Public Health Agencies.
() 25 MR. KANTOR: Your notification system covers the i-ACE-FEDERAL REPORTERS, INC.
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-l 1 10-mile EPZ; that, I assume, is installed and operational .
-( Wbur 2 throughout the entire EPZ?
3 MR. HARPSTER: That'is correct. We had actually.
~
4 made a commitment to have that system installed.and-5 operational-prior to 5 percent power, and-I think that' 6 system has been operational since_early July of last year, 7 and.that has-been' documented in several'NRC. inspection 8 reports.
9 MR. KANTOR: But with-your request for waiver, 10 'how do you envision the notification system being handled?
11 MR. HARPSTER: That would not change. ..We fully 12 intend to maintain the full alert notification system that-O 13 is in 9 1 ace now in eeth New aampshire and Massachus ees.-
14 There would be no changes-in that.
15 MR. KANTOR: And your.public education program?
16 MR. HARPSTER: In fact, let me go back.: We have 17 offered to Massachusetts to participate as we have in New 18 Hampshire -- sign an agreement to plan for : the- full 10 miles 19 in Massachusetts irrespective of the success of the waiver.
20 We intend to keep those things in place. There would be no 21 retrenchment from that.
22 MR. TURK: Is it your position now thatlin the ,
.l 1
23 event of an emergency, assuming the petition is granted, in '
24 the-event of an emergency the. state would utilize plans that h 25 have previously been developed?
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[Wbur 1 MR. HARPSTER: Yes. I believe that is our-2 position. Those plans.are the plans that are essentially -
3 without the upgrades used at the other plants which have 4 EPZs within the State of Massachusetts. The state level
~
5 actions are the same irrespective of the plant.
6 The actions-really do.not become unique for_the 7 plants until you get down to the area, the town, and the 8 host community level. So the state would use those plans.
9 They are the best available. They were developed under the 10 direction of the state, and in fact were upgraded at'the 11 direction of the state.
12 MR. FEIGENBAUM: Terry, Falk. asked about public O 13 information bevond the one mi1e.
14 What are the plans in that area?
15 MR. HARPSTER: Our plans are-full dissemination 16 of public information within the 10-mile area in all forms 1[ because of our EPZ and the transient population. -We have 18 developed and reviewed probably more sophisticated public 19 information because of the transient nature of some of the 20 EPZ. We will have a full range-of public information 21 materials out to deal with both the permanent resident 22 population and the transient population irrespective of the 23 distance, whether it'is one mile or 10 miles.
24 MR. KANTOR: Do you plan to submit additional O 2s information to dot ter your rationate, u99ert --
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[ Wbur: 1 MR. HARPSTER:' Yes, we-do plan to submit
- 2. additional.information.
3 MR.'"KANTOR: 'Some'of the things 1you have talked' 4 about will be included'in that?
5 MR. HARPSTER: They certainly-will. .
6 M R .' 'KANTOR: I am not-sure'how or'.what. form that 7 would take from a legal standpoint,'and-I am asking plans-8 for submitting the additional information,~what form it 9 might take, when we might see that.
10 MR. FEIGENBAUM: I take it that is tantamount to-11 really a request for additional information based on your.
12 question, your original question. -We would'aubmit a O ta eachnic 1 1eeeer to the staff as oare of our eachnicat case.
14 MR. KANTOR: The present submittal contains'very _
15 little detailed information in-that regard.- That-is my 16 original premise that we started from.
1[ MR. FEIGENBAUM: We will-submit a technical 18 letter.
19 MR. MOODY: Most of this-information ---is there 20 anything new that is not in the public-record that you have~
21 described here? Most of it will be reference material?
22 MR. HARPSTER:-- I don't think we have submitted in 23 one piece, I think, a description of-the plans as'we have 24 described them. They-contain part of what I:have described O 25 eoday, bue there is nothin, that describes this series of i
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-8230'05 05 47 I Wbur. 1 things, really,.which are a framework'of the actions that' 2 you would expand upon.for Falk's original question and the 3 questions from Frank'. We never submitted ~ anything that 4 would describe those actions yet.
~
5 MR. NERSES: I missed the first part of tha 6 conversation that you got~into the discussion-on this ching,
- 7. but as I listened to what-you have said here, if you had the 8 word "go," you would not have to do one iota of a thing; 9 everything is in place.
- 10 Is that true? -Everything is in place, and if you -
1 11 were to go with the thing right now, you could go?
12 MR. HARPSTER: For 5 percent power, that is
() 13 correct.
14 MR. NERSES: Everything is in place?
I 15 MR. HARPSTER: Correct.
16 MR. NERSES: You would not have to compensate or l If do anythingt everything is there?
18 MR. HARPSTER: That is correct.
19 MR. FEIGENBAUM: What kind of timeframe are we 20 talking about for submittal of basically a summary and what 21 you have gone over today?
22 Just so the NRC can establish their resources for -
23 continuing their review.
+
24 MR. HARPSTER: We could submit that within~a i ..~
Q, 25 week.
J J
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-('Wbur 1 MR. NERSES: Any other questions from Falk to 2 Ted? Does anybody else have any questions?
3 MR. LITTLEFIELD: Not right now.
4 MR. HARPSTER: Let me point out one other thing.
5 This ties the discussion together.
6 One thing, when you do the analysis and you look 7 at dose and distance -- if I could put'another hat on -- you
-8 have to look at the population distribution in the mile 9 portion of Massachusetts. If you look at the population 10 breakdown within the two to three miles of the plant, which 11 is across the Massachusetts state line, there are only 2000 12 people. I can give you the precise numbers.
13 From three miles to four miles -- 2,738.from two 14 to three miles, which is the first one. From mile three to 15 four we have 4,687 people. ,
16 If I could show you the map right now that the 17 NRC sends to each site, the Geological Survey map showing 18 the EPZ, where population centers are shown in red, in 19 houses in towns, and marshes and things like that are shown 20 in green, you would primarily only see green until you get 21 out almost to four miles. You would then- begin to run into 22 the Town of Salisbury, and from four to five miles you pick 23 up an additional 8,449 people.
)
1 24 In other words, in those first three miles out to j
()
i 25 five miles from the plant, the total permanent resident l l
l l'
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Wbur 1 population is 15,874 people. This is not a dense population 2 area.
3 There are two major interstates that run through-4 that area.
5 MR. NERSES: What is the population in the 6 summertime?
7 MR. HARPSTER:- Let me give it to you in a 8 different fashion. Salisbury, which is the principal area 9 of concern, is largely outside the four-mile circle, the 10 6,726 permanent resident population. On a peak summer 11 weekend, the population of the Salisbury whole area, 12 including the beaches, goes to 26,702.
C) 13 sa senses ra e i= out to cour ile , you v2 14 MR. HARPSTER: That is the entire--- that is all 15 the way out. That is the beaches and everything within the 16 total geographical area of Salisbury.
If MR. NERSES: I see.
18 MR. HARPSTER: Within five miles you pick up 97 19 percent of Salisbury, i
20 Amesbury, which is the first large population 21 center -- and you just start to get that between four and 22 five miles -- the total permanent resident' population is 23 14,258. The population, summer weekend, 17,454, an 24 additional 3000 people.
O 25 .nd most of that popu1aeion is somewhere from j ACE-FEDERAL REPORTERS, INC. ;
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1- four-miles out, so.when you are looking.at dose versus
. distance and the risk incurred to the. population, there is 2
1 3 'very little inside of five miles, and when.you get inside of 4 four miles there is amazingly less.
, 5 MR. FEIGENBAUM - If . this information would be 6 helpful to you, we can submit it with.the rest of our 4
i 7 technical input to you, if'it.would be helpful.
8 MR. KANTOR: The population'information, I assume l
! 9 it is in the emergency plan?
10 MR. FEIGENBAUM: Is it broken down like that?
11 MR. NERSES: What is the date on this thing? How I ,
12 recent is this information?
() 13 MR. HARPSTER: That is the most recent j 14 information. That is the information that was developed by i
15 the consultant to the State of Massachusetts, KLD
{
16 Associates. I have just had their consultant break it down 1[ in a different fashion for me so I could deal with the ;
18 particular areas of concern.
~
[ 19 But this information was presented to .the State
- 20 of Massachusetts as a result of the KLD Associates study.
1
. 21 MR. KANTOR: Is that the evacuation time estimate
{ 22 study?
I 23 MR. HARPSTER: It is just not quite broken.out 24 like that because it was --
I
() 25 MR. KANTOR: It might be helpful if'the i
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! Wbur 1 information would include the population in that form.
There was a statement made in the affidavit.that
~
2 3 I wanted to ask for some clarificati,on on. The statement 4 says that: -
5 "The one-mile plume exposure 6 emergency planning zone reduces the
'7 -competition for' emergency planning 8 resources by members of the 9 public who would'not really benefit.
10 but would reduce the effectiveness 11 of emergency protective actions for 12 those -individuals considered most O 13 t ri k.-
14 I think that must be something that I just don' t 15 understand that statement.
16 MR. HARPSTER: I didn't understand it.
17 MR. KANTOR: "The one-mile plume.
18 exposure emergency planning zone 19 reduces the competition for 20 emergency planning resources by 21 those members of the public who 22 would not really benefit but 23 would reduce the effectiveness 24 of emergencp protective actions O 25 for those individuais considered ace-FEDERAL REPORTERS, INC.
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8230 05 05 52 Wbur 1 most at risk."
2 MR. HARPSTER: Let me take a shot at it. I am 3 not sure that I follow the entire statement.
4 But one 'of the concerns that everyone in 5 emergency planning has is when you try and distribute 6 limited resources over a 10-mile EPZ you decrease the 7 effectiveness of your protective actions and your ability to 8 get resources to any one segment of the EPZ.
9 It is highly unlikely that you would have a 10 radioactive plume covering 360 degrees for 10 miles. In 11 effect, NRC recommends when they participate with the site 12 that your initial protective action' for general emergency O 13 conditions on1y he to evacuate 360 desrees ewo mites and 14 five miles downwind in the adjacent sectors.
15 There is a lot of philosophy behind that if you 16 want to apply your resources most effectively, and I believe 1[ that is the basis for that statement, to allow us the 18 ability to more effectively apply the resources to a well-19 defined area than to plan for'a large area with a fairly 20 small population density in comparison to other sites.
21 MR. FEIGENBAUM: Are there other areas that need 22 to be addressed to continue your review for . the fourth 23 rationale?
4 24 MR. KANTOR: None that I can offer at this time.
h 25 Just to reiterate that up to now we have not had that much' ACE-FEDERAL REPORTERS, INC.
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-8230 05 05 53 1 to look at-in this regard.'
-(].Wbur t
2 MR. TURK: I want to..ask a question related tol ;
3 your lasti question. - ,
4 Are you requesting a review 'of the plans for.
5 Massachusetts and the -towns within Massachusetts? Are you 6 going to be asking NRC to look at the review?
7 MR. FEIGENBAUM ' That was the purpose of our 8 letter, of the letter of April 8th, some additional formal 9 request if necessary -- we are going to be meeting on +
10 Thursday with Tom Early and other people in the project to 11 discuss. ,
12 At this point we would like to know how the NRC O 13 is going to review thae Massachuseets 9 1 aa for the 14 radiological emergency response and try to come up with a i
15 schedule as to what that review -- how long it would take, 16 what you need from us to continue your review.
If our submittal of that package was essentially a 18 request to perform a review.
19 MR. TURK: Looking only at the petition -- just 20 with respect to the petition for waiver, do you foresee a 21 need for review of the Massachusetts town plans?
22 MR. FEIGENBAUM: I think that really has to come 23 from the NRC. You really have to make that decision for the 24 waiver, how much of a review you need to do of those plans.
O 25 MR. Mooor I agree.
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()Wbur 1 MR. CONGEL: I agree, too.
2- MR. MOODY . You have to look at the DBA, the 3 severe accident analysis, the risk results, and whether-that 4 is necessary or not. I think that is a separate question. 1 5 MR. NERSES: Any other questions? Anybody else?
6 MR. KANTOR: One more question.
7 Has Massachusetts totally withdrawn from 8 coordination of the emergency planning?
9 MR. HARPSTER: Yes.
10 MR. KANTOR: Nothing at the agency level?
11 MR. HARPSTER: No. We continue to offer to 12 provide them with any training. We continue to send them
() 13 any updates.
J 14 We continue to do all we can to assure that in.
15 the event that they change their mind they will be ready and 16 they have the latest updates. We send them all of our 17 planning documents.
18 But they are not formally participating in any 19 fashion now.
20 MR. KANTOR: Including the Civil Defense people?
4 21 MR. HARPSTER: That is correct.
22 MR. NERSES: Any more questions?
23 MR. KANTOR: No.
24 MR. NERSES: Anybody?
() 25 I would like to adjourn this meeting.
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Wbur 1 Thank you. . .
2 (whereupon, at 2:47 p.m., the meeting was l
l 3 adjourned.)
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h CERTIFICATE OF OFFICIAL REPORTER This is to certify that the attached proceedings before-the UNITED STATES NUCLEAR REGULATORY COMMISSION in the matter of: .
NAME OF PROCEEDING: MEETING BETWEEN NRC STAFF AND LICENSEE RE: SEABROOK PETITION DISCUSSION OF TECHNICAL MERITS DOCKET NO.: 50-443 PLACE: BETHESDA, MARYLAND
- DATE: TUESDAY, MAY 5, 1987 were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission. .
(sigt)
(TYPED)
BARBARA L. UHITLOCK Official Reporter ACE-FEDERAL REPORTERS, INC.
Reporter's Affiliation r3 V
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