ML20214R282

Testimony of Dj Perrotti & Gr Bryan Re New England Coalition on Nuclear Pollution (Necnp) Contention III.1 & Contention New Hampshire 20 Concerning Emergency Classification & Action Levels.Related Correspondence

ML20214R282
Person / Time
Site:	Seabrook
Issue date:	09/19/1986
From:	Bryan G, Perrotti D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20214R231	List: ML20214R228 ML20214R247 ML20214R265 ML20214R282
References
OL-1, NUDOCS 8609290130
Download: ML20214R282 (13)

Text

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09/19/86

• DOCKETED USHRC

'86 SEP 23 P3 :10 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION GFFICE y :: .v DOChEl in , M : , tu

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443 OL-1 NEW HAMPSIIIRE, et al. ) 50-444 OL-1 On-site Emergency Planning

)

(Seabrook Station, Units 1 and 2) ) and Safety Issues TESTIMONY OF DONALD J. PERROTTI AND GORDON R. BRYAN REGARDING (CONTENTIONS NECNP III.I AND NEW HAMPSHIRE 20) EMERGENCY CLASSIFICATION AND ACTION LEVELS Q1. Please state your name and position with the NRC.

A1. My name is Donald J. Perrotti. I am employed as an emergency preparedness specialist by the Nuclear Regulatory Commission, in the Office of Inspection and Enforcement , Division of Emergency Preparedness and Engineering Response. I am responsible for the review and assessment of the onsite emergency plan concerning the Seabrook Nuclear Power Station. I was the author of Section 13 in Supplement 4 to the Seabrook Safety Evaluation Report (SER).

My professional qualifications are attached.

Mr. Gordon R. Bryan, COMEX Corporation under contract to Battelle Pacific Northwest Laboratories, Richland, Washington (an NRC consultant), performed a technical review of the emergency action level (EAL) scheme contained in the Seabrook emergency plan and emergency plan implementing procedures against the guidance criteria i 8609290130 860919 PDR ADOCK 05000443 T PDR

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• of NUREG-0654/ FEMA-REP-1, " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness In Support of Nuclear Power Plants," Rev. 1, November 1980. Mr. Bryan's professional qualifications are attached.

Q2. What is the purpose of this testimony?

A2. (Both) The purpose of this testimony is to address certain aspects of those emergency plan contentions admitted for hearing in this proceeding which assert deficiencies in the emergency classification and action levels contained in Seabrook's onsite emergency plan.

Those contentions are designated NECNP III.1 and NH-20, which read:

NECNP Contention III.I:

The emergency plan does not contain an adequate emergency classi-fication and action level scheme, as required by 10 CFR 9 50.47(b)(4) and NUREG-0654, in that (a) No justification is given for the classification of various system failures as unusual events, alerts , site area emergencies, or general emergencies.

(b) The classification scheme minimizes the potential significance of transients.

(c) The Applicants' classification scheme fails to include con-sideration of specific plant circumstances, such as the anticipated time lay for evacuation due to local problems.

(d) The classification scheme fails to provide a reasonable assurance that Seabrook onsite and offsite emergency response apparatus and personnel can be brought to an adequate state of readiness quickly enough to respond to an accident.

(e) The emergency action level scheme fails to identify emergency action levels or classify them according to the required responses.

(f) The scheme is incapable of being implemented effectively to protect the public health and safety because it provides no systematic means of identifying, monitoring, analyzing, and responding to the symptoms of transients and other indicators that transients may occur.

New Ilampshire Contention 20:

The accident at TMI demonstrated the inability of all parties involved to comprehend the nature of the accident as it unfolded; communicate the necessary information to one another, to the Federal, state and local governments and to the public in an accurate and timely fashion; and to decide in a timely manner what course to take to

1 protect the health and safety of the public. The Applicants in these proceedings have not adequately demonstrated that they have developed and will be able to implement procedures necessary to assess the impact of an accident , classify it properly, and notify adequately their own personnel, the affected government bodies, and the public , all of which is required under 10 CFR 5 50.47 and Appendix E and NUREG-0654.

Q3. lias the Staff completed its review of the EALs for Seabrook?

A3. (DP) Yes. The review and evaluation of the EALs for Seabrook against the requirements of 10 CFR 50 and the guidance criteria of NUREG-0654 is completed. The Staff provided its detailed evaluation of the EALs in SER Supplement 4, May 1986. Subsequent inspec-tions have verified that the corrective actions , identified in Sec-tion 13.3.2.3 of Supplement 4 have been completed.

Q4. Does the Staff now consider the EALs to be complete?

A4. (DP) Yes. The information that previously was missing has been incorporated. Based on the Staff's review to date of the Seabrook EALs, I conclude that the Applicants' emergency plan provides an adequate planning basis for an acceptable state of emergency preparedness witl1 regard to the emergency classification system planning standard of 10 CFR 50.47(b)(4) and the guidance criteria of NUREG-0654.

0 QS. Have the Applicants performed a comparison between their emergency action levels and NUREG-0654?

A5. (DP) Yes. On April 2, 1986, the Applicants provided a cross reference of the Seabrook EALs against the example initiating conditions of Appendix 1 to NUREG-0654. The cross reference list was reviewed and found to conform to Appendix 1 to NUREG-0654.

As stated in SSER-4, the staff has determined that the emergency classification and action level scheme meets the guidance criteria of NUREG-0654.

Q6. Have the Applicants completed their training of operators related to the use of the EALs?

A6. (Both) The training of operators, including the use of EALs in accident condition classification , was assessed during an onsite appraisal of the implementation of the Applicants' emergency plan and procedures on December 9-13, 1985 and followup appraisals on March 24-28 and June 9-13, 1986. The appraisals included interviews and walk-throughs with the shift crews and a review of training records and emergency plan implementing procedures. As a result of these appraisals, the Staff has concluded that the training of operators at Scabrook, including their use of EALs in accident condition classi-fication, is acceptable.

Q7. With respect to the classification of fire events, have the Applicants changed their treatment of such events?

A7. (Both) The classification of fire events is found in Figure 5.6, Item 16, of the emergency plan and in an identical figure in procedure

ER-1.1, Form ER-1.1 A. The flow chart in ER-1,1 is the classi-fication flow chart that would be used by the operators in the event of an emergency. Previous versions of the emergency plan and procedure identified a fire that is contained and controlled and potentially affecting safety systems as an Alert and an uncontrolled, uncontained fire affecting safety systems as a Site Area Emergency.

On April 11, 198G, the Applicants revised Figure 5.6 of the emergency plan to identify that 1) a fire in the protected area lasting longer than ten minutes with no impact on safety related equipment is a Notification of Unusual Event, 2) a fire potentially affecting safety related systems is an Alert, 3) a fire defeating one train of safety related equipment is a Site Area Emergency, and 4) a fire defeating both trains of safety related equipment is a General Emergency. A similar revision was made to procedure ER-1.1 to make it consistent with the emergency plan.

Q8. How does the amended classification of fire events compare with the treatment of such events in NUREG-0654?

A8. (Both) The amended classification of fire events in the emergency plan , Amendment 59 to the FSAR, and procedure ER-1.1, Revision 5, conforms to the guidance criteria contained in Item 10, pg 1-5, Item 13, pg 1-9, Item 11, pg 1-13 and Item 7, pg 1-19 of Appendix 1 to NUREG-0654 and this classification has been determined to be acceptable by the Staff.

Q9. With respect to the classification of control room evacuation, have the Applicants changed their treatment of such events?

A9. (Both) The classification of control room evacuation is found in Figure 5.6, Item 17, of the emergency plan and in an identical figure in procedure ER-1.1, previously described in Answer 7. A previous version of the plan and procedure identified a control room evacuation other than fire (emphasis added) a) anticipated or required with safe shutdown capability established as a Notificathn of Unusual Event, b) with safe shutdown capability established but plant conditions unstable as an Alert, and c) with safe shutdown capability not established within 15 minutes as a Site Area Emergency. On April 11, 1986, the Applicants revised Figure 5.6 of the plan by deleting the words "other than fire", and identifying a control room evacuation anticipated or required with safe shutdown capability established as as Alert and evacuation of the control room without safe shutdown capability established within 15 minutes as a Site Area Emergency. A similar revision was made to ER-1.1 to make it consistent with the emergency plan.

Q10. How does the amended classification of control room evacuation compare with the treatment of such events in NUREG-0654?

A10. (Both) The amended classification of control room evacuation in the emergency plan, Amendment 59 to the FSAR, and procedure ER-1.1, Revision 5, conforms to the guidance criteria contained in Item 20, pg 1-10 and Item 18, pg 1-14 of Appendix 1 to NUREG-0654 and this classification has been determined to be acceptable by the Staff.

IYNALD J. PERIUITI OFFI OF TNSPFLTIm AND ENEmCENEb7 STATEENT OF PROFESSIWAL QJALIFICATImS I am mployed as an Dnergency Preparedness Specialist in the Dnergency Preparedness Branch, Division of Dnergency Preparedness and Engineering Response, Office of Inspection and Enforcanent, U.S. Nuclear Regulatory Cmmission. I have responsibility for the review and evaluation of radiological energency plans submitted by reactor applicants and licensees to assure that proposed plans meet the regulatory requiranents and guidance of the Cmmission. I also function as a Team Leader and Team Member on Energency Preparedness Appraisal Teams engaged in the onsite inspection of the inplanentation phase of licensee emergency programs. I observe nuclear power plant emergency drills and exercises involving State and local goverrment response agencies and participate in inter-agency critiques. I served as the staff's expert witness for onsite anergency planning during the evidentiary hearings for the Waterford 3 and Perry 1 oper-ating licenses and for the Clinch River Breeder Reactor construction permit.

Fran December 1976 to October 1980 I was mployed at the NRC's Region II Office of Inspection and Enforcement in Atlanta, Georgia. I was the lead inspector for Region II anergency planning inspections at nuclear power reactors and fuel facilities. My responsibilities included planning, conducting and docunenting inspections of licensees' unergency plans and procedures, energency facilities and equipment , emergency training, tests and drills, and coordination with offsite support agencies. Fran April 1977 to August 1978, I assisted my inmediate supervisor who served as Chairman of the Federal Regional Advisory Cmmittee (RAC) in the review of State Radiological Energency Plans. During

4 October 1978 I assisted in the review and approval of emergency plans for two nuclear fuel facilities. During the period of March - August ,1979, I par-ticipated in the Conmission's coverage of envirornnental monitoring programs at 'Ihree Mile Island, where I served as Energency hbnitoring Tean Leader; in that capacity, I was responsible for coordination with State and Federal agencies engaged in measurenent and evaluation of envirorinental radioactivity levels in the vicinity of the %11 nuclear plant.

Fran 1973 to 1976, I was mployed at Florida Power and Light Cmpany's Turkey Point Nuclear Power Plant, as Health Physics instructor. My duties included radiation safety training of plant personnel (general sployees and technicians), special project reports such as providing background material for managenent emment on proposed changes to the Code of Federal Regulations, and maintaining radiation exposure records for plant personnel.

From 1953 to 1973, I served in the United States Anny. As a manber of the U.S. Anny Engineer Reactors Group during the period 1961 - 1973, I perfonned a variety of jobs with varying degrees of responsibility as rank and experience were gained. Among my more responsible jobs were shif t health physics techni-cian at the PM-3A Naval nuclear power plant in hkthrdo, Antarctia (1965-1966),

Senior Health Physics / Process Chanistry instructor at Ft. Belvoir, Virginia (1966-1972), and Project Officer for the SM-1 Anuy nuclear power plant (1972-1973).

I received an Associate of Arts Degree from the New York State Regents,-

Albany, NY, in 1973. In addition, I attended Army service schools including Special Nuclear Weapons Disposal and the 52-week Nuclear Power Plant Operators course. I have empleted the following U.S. Public Health Service courses:

Basic Radiological Health Radionuclide Analysis by Ganma Spectroscopy Envirormental Radiation Surveillance s Analysis of Radionuclides in Water Occupational Radiation Protection Chanical Analysis for Water Quality Statistical Methods - Quality Control in the Laboratory Operational Aspects of Radiation Surveillance Reactor Hazards Evaluation I attended the " Radiological Energency Response Operations" course at the Nevada Test Site and the " Planning for Nuclear Ibergencies" course at liarvard University.

I have successfully empleted the NRC's Pressurized Water Reactor Technology and the Boiling Water Reactor Technology courses.

I am and have been a msnber of the Health Physics Society since 1974.

t i

l STATEMENT OF PROFESSIONAL QUALIFICATION GORDON R. SRYAN, JR.

PO B0X 2153 P00L550. WA. 98370 (206)779-4596 EDUCATION:

M.S., Administration / Computer Systems, The George Washington University,1970 lettis Atomic Power Division. Westinghouse Electric Corp.,1960 M.S.

(Equivalent), Reactor Engineering, U.S. Naval Nuclear Power Training,1958 l B. A., Economics / Math Brown University,1951

$UMMARY OF EXPERIENCE Twenty eight years of technical, operational, and management experience in commercial and Navy nuclear power plants including construction, operation, training, maintenance, ins! action licensing, emergency preparedness, security and safeguards, Senior management experience with staffs to 3000 persons, annual budgets to $30 million, and connruction projects to $780 million.

Technical experisace in the construction. maintenance, and operation of Navy nuclear power plants; one of the first '00 Navy qualified reactor operators; qualified and served as reactor operatr, chief operater, engineering officer of the watch, chief engineer and AEC Representative. Idaho Branch Office.

Commanded several Navy activities ir.cluding 3 nuclear submarines, a sub-arine tender, a submarine squadron 2 subearire bases, a training command, and a shore based repair facility.

EMPLOYMENT EXPERIENCE:

COMEX Corporation (1982-Present) - Sonice Engineering Consultant providing support to the Nuclear Regulatory Comm t,$1on (NRC) through the Battelle Pacific Northwest Brookhaven. Lawrence Livermore, and Idaho National Engineering Labs and Scientific Applics:1ons Inc. in performing nuclear power plant emergency preparedness and safs pards and se:urity inspections, audits.

and appraisals. Conducted emergency act. ion level (EAL) reviews (5): detailed control room design reviews (DCRDRs)(41 safety parameter display system (SPOS) audits (2): emergency response facility (ERF) appraisals (4): eforgency 1

response (7): securitydata systems (ERDS)

& safeguards surveys inspections ( (2',2)temergency preparedness annual observed emergency exer- appraisals cises (38); and NRC headquarters emergncy response team det11s (3). Hork experience with NRC headquarters and all 5 NRC regional offices at about 55 US commercial nuclear power plants. Marine facility design and comercial real estate (1979-1981).

U.5, NAVY (1951-1978)

Commanding officer of the US Naval Subnerine base at La Maddalena, Sardinia and the Trident base at Bangor, Washirgton.

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United States Consul in Sardinia. Italy. i Commanding Officer of the Trident Training Facility and Trident Refit Facility at the Bangor Washington Trident subterine base.

Commanding Officer'of three nuclear news ed submarines, a submarine tender, and a submarine squadron.

Flotilla Assistant Chief of Staff f6r Readiness and Training.

AEC Rep Idaho Branch Office, NRTS, IdeSo.

Chief engineer, $5W nuclear power plant.

Qualified reaeter operator and chief opi* ster on the Wei.tinghouse $1W proto-type; qualified at all engineering department watch stations on the Westinghouse $$W reactor; qualified for tapervision and maintenance of US Navy nuclear power plants.

AFFILIATIONS:

New York Academy of Sciences, 1985 2 resent American Nuclear Society, 1982-Present The Retired Officer's Association, 1980-Present Rotary Club of Poulsbo-North Kitsap, 1978-1983 City College Steering Comittee, 1977-1980 American Radio Relay League,1978 ' resent Kitano County Chamber of Commerce, 1975-Present AWARD $i Elected to the New York Academy ef Sciences 1985.

legion of Merit and 11 lesser personal awards.

, Twelve theater and campaign awards.

^

Kitsap County Chamber of Commer:e Tyee award, 1978.

$$A Commemorative Medal Evergreen Eagles,1976.

SEAdkCO: U!i!QUE ADDENDlF.

l 36dged for unescorted access at Seabrook, 12/B5 - On site. Emergency Preparedness (EP) appraisal.

- In effice. Operations and health physics l 2/86 '

revisa of t'ne 1936 EP exercisa scenarie.,

2.'03 In office. Seabroek EAl. review.

2/C1 - On site. EP sppraisal, annual EP exercise, ar,d EAL ravir? n utings.

3/C5 - la ef f f es. Sacbrock EAL rsview. -

3/E 5 - Cc. sf :e. C; speraisal and EAL revfew fnestings.

6.isi - In of'Sco. EAL review.

9/i? Se..b.v ok itcensing hearings d

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