ML20234C186
| ML20234C186 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/04/1987 |
| From: | Bores R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Eric Thomas Federal Emergency Management Agency |
| Shared Package | |
| ML20234B686 | List:
|
| References | |
| FOIA-87-346 NUDOCS 8709210195 | |
| Download: ML20234C186 (10) | |
Text
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% JUN10487c138 38:
NRC-MILLSTONEc11 P02 1/
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. UNITED 5TAYEs
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.g NUCLEAR REGULATORY COMMisslON i
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. REGION I.
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631 PAnK Avtuus
. MING OF PflusstA, pgNNsyty4N' IA 18408 s
Edward A. Thomas, Chairman.
.JUN 01 ggg7
,1 Regional Assistance Connittee-
.j Federal Emergency Management Agenc John W. McCormack Post Office anc' y Court House Boston, Massachusetts 02102-
Dear Mr. Thomas:
Reference:
RAC Coments on Transient-Beach Population for Seabrook Station i
j on the above subject,'the Atomic Safety and' Licensing "j
1 HEMORANDUM AND ORDER on ~ April 22,11987 relative to the:Public Service i
of-New Hampshire petition for a one-mile ' plume: emergency planning uone. :pa
' that document, the' Board concluded that the current studies.provided by! th In.
i one-mile plume EPZ petition. The Board deliberate t
of granting the petition if convincing information'is subsequently provided.:
i I
Even though the beach population issues differ substantially from ths 'above -
litigation, because of it and becaus'e the NRCL staff has;not yet co....
8 review of all issues in the Seabrook and. *BNL" studies, l' recommen.mpleted its 1
RAC not reference these studies.or specific contents in our1present consid-d that the eration of the beach population issues.-
revisec sections for the RAC report.
With that in mind, 1 am proposing 1
i seven through ten.
These proposed'revisiens-involve pages j
For your convenience, a clean,. rewritten copy of the RAC position paper '
ir.corporating these ' revisions is enclosed.
{
Should you have any questions concerning the: abo've/please contact me at FTS a
- a..
485-1213.
I would be very happy to treet with you and/or the. R/sC to'discussf my.
r response.
U 8709210195 070916 "P
PDR FOIA Robert J. Bores-N CONNOR 87-346 PDR
- Technical Assist' ant D1WW of-R@tM $d4 cl and Safeguards,
Enclosures:
As stated
.bec w/ enc):
e, f
i W. Russell
- i J. Allan J. Gutierrez p
W. Kane W. Johnston-T. Matt 1n R. Bellamy j
bfl R. Bores f.
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v JUN O'4 '87 13:38 NRC MILLSTONE 1 LP03
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PROTECTION OF MDf HAMPSHIRE.SEACH POPUL 2 BACKGROUND i
the requirements for emergency preparedness stas from 10 (2), which state that except as prov.ided in 10 CFR 50.47(d).
licensing of a facility for ~ operation up to 55 of ra,ted power (relative to license for a, nuclear power reactor will be issued unless'a find the NRC that there is reasonable assurance that adequate protec e byc base its finding on a review of the FEMA-findings i
a: e The NRC,will,,
whether state and local emergency plans are adequate and wheth reasonable assurance that they can be. implemented, and on the the adequacy and implementability of the licensee's 'ensite eme The FEMA finding is primarily based on the review of the state and emergency plans.
in considering whether there is reasonable assurance that o
implemented.. Paragraph b plans can be-offsite ecergency respons(e) plans for nuclear powe of 10 CFR 50.47 requires that the onsite and planning standards.
Emergency Response Plans and Preparedness in Sup was issued-to provide a comon reference and guidance source 'ar Power Plants",;
local goverrc.ents and licensees tri the development 'of emergency for state and response plans and preparedness for response to a radiological em.
for FEMA, NRC and other federal agencies for use in the review ergency and.
and preparedness.
nuclear power plants was taken from NUREG 0396/ EP i
Basis for the Development of State and Local Governmen/148-016, ' Planning Response Plans in $upport of Light Water Nuclear Power Plants' gical Emarg t Radiolo objective of the emergency response plans is to provide dose sa "The overall some cases imediata life savings) for a spectnam of. accidents that co produce offsite doses in excess of the PAGs" (MUEG 0654).
it attempted to identify the boundathat the planning basis range fr NUREG 0396, intended i
and of potential accident consequences,ry parameters based on available knowledge s
timing of releases, and. release charac-teristics (source ters). It should be noted thist doses in excess of!th PAGs do not equate with loss of life or even aihealth hatard between radiation risk and that of taking a prot The PAGs were constraints to that action.
sence'of Enclosure.
1
Y VUN 04? 87!13s39 HRC MILLSTONE:1-PO41
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Relative to the adequacy of: emergency..pNparedness for the'$tabrook beach k
, population,-NUREG 0654 elennts J,3 and J.10 appear. to be pertinent to the' 1
situa tion, Element J.9 states, in part f that each state and local plan must -
establish a capability':fotiepleennting protective meas
.iaplement protective meassres shall welude,'.in part?
routes c.d areas sops showing evacuation'-
1 distribution arou. reloc4 tion (reception 1 centers and the population nd the nuclear facility by evacuation artes; the means.
nettfy all segments of resident and transient' populatioct the means forc pro--
to '
tecting persons whosroobility may be' impaired; the means of relocation reception centers / host facilities; proiteted traffic capacities. of evacu;ation routes under emergency conditions;icontrol of ascess: to evacuated areas end, i
organizational responsibilities 'for control;tidentiffention of and means for' dealing with' potentialr%
ocasures; time estimates pedie.cnts to use.cf evacuation rmtes and contingency on a dynamic analysist and th bases for choice of ? recomme 1
i aetions for 'the pluce exposure. pathway'. dsing metjency?canditions, consideration of local protectMn ava'ilable and estireted evacuaticn times.. j REVlfW 0F NEW HAMPSMIRE PLAMLRDISION 2gAUEl$T 1986.
2 J.9
-- The RAC review of eliment: J.9, the.ed,ablishmenbf capability' implementing protective etesures., for bott for I
state at.this' time for this eltmenti.This e1eren s
'inadequdte" for the ;tne, however resobed 'the "bcach population issue", because the PACL had'not yet New Hamp: hire ifaho AuFrently reenm. the subject 'of this. document.
ining 'ali emergency resource needs and the resourcC nailabiliti and distrib. tion to support protective action implementation? The resource netds and I
NH study. ' Based on the RAC and my encinati preparedness for the beach population and those. individuals-in unwutarfred housing. I concWde that these populations can be appropriately protected by Wplementing those provisions of the-current NH~ emergency plant.
this' ares that.hes not ' been chquftely eddressed.Thert appears -t i
J.10.a -- The RAC review of dement 0.10.s reistive to; beach population g
protentive action implementation, im th6 mps of 1
both the, St.atre and local pitns, reve61 no indetaciu.S(An
' inadequacy
- was identified with' re I
mental sampling locatioon however,gardl the sep.of the environ (
' this H unrelated to teach
.popvlatign; proter.tica paesure Wplementatin t>.h bearn population,1 tTil element appears to be'44quate.
f JJUkiO4 487Ii3:4s NRC MILLSTONEL1 P05:
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l J.10.6 -- The RAC review of elesent J.10.b. ups showing populationLdistri.'
bution by evacuation areas around the ' nuclear facil inadequacies for either the.$ tate or local plaes.-
..indit.ata no required of nor recocinended to the State for.this element.actichs.were '
J.10.'c -- Relative to J.10.c. the means for notifying all segments 'of the.
population, the AAC teft the evaluation of the State element 'open' pending completion 4 of the FDE-AF.p-43 now artion of this a
FEMA-REP-10 'Nov. 85) review of the alert / notification ~ system. J Fo the local plans this elesient was rated
- inadequate" becaus were not provided relative to provisions for identifying.siru n
failures and for providing backup notification in those instances of' identified siren failures.
It should be.noted that this inadecuac was generic for all town plans and was-not' app 11 cable onlyLtc the'y -
beach population.'-
i The physical siren system and the administrative. procedures, plans-
. and:means for alerting and notifying the public appear to be in place and adequate. Provisions.for early
.i with both-stren tones and voice mes notification of beach' pulations' sage capsbility are in - ace.'The alert /stren system _can be activated on an individual siren basis, in~ i groups..or as the entire system to provide flexibility to the decision makers to accomodate the circumstances of the even J.10.d - Relative to J.10.d. the means ~ for protecting persons whose i
is impaired. the RAC tdentified no inadequacies at either the State or local level.: Provisions were found adequata for health care facilities. Rockingham County Jail schools, etc. -Relative to i
' individuals with special needs",' however, the AAC left this item
'open' pending a review at a. future'date by FDR of' the lists of such special needs individuals.
. This open item is EPZ and is NOT unique to the beach population. generic to' the entire The RAC also recoernended that the protection factors for special are when considering evacuation of these facilities. fa previsions use no designated protection factors for sp(The current-ities when calculating pro ecial facil.
administration decisions.)jected thyroid doses for purposes of KI J.10.e '-- Element-J.10.e. provisions for use of Kl. is not ' applicable to t evaluation is con,sidered here. beach population 'at least not in Therefore no quate'.
The RAC rated this element'"ade '
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H JUN,04 '87 13:41 NRC MILLSTONE 1 P06 L
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O J.10.f -- Element J.10.f, decision making for use of 11 is applicable to the beach population end.L therefore, t directly here.
The RAC rated this element ' adequate".
s not considered J 10.g -- Relative to J.10.g. the. means of relocation lthe' RAC f visions to be
- adequate" et both the
. ound pro-did, however.: have a number of reconsne$ tate and local levels. The MC -
to plan and procedure inconsistencies in the bus and ambu the mechanism for 'detensining precisely the n' nce-i These inconsistencies, howeverpersons to be accoasnodat(
were jud ed not. to result in a, lack of resource provisions 3
adequate y accomodate those ~ needing transportation..
J.10.h -- Relative.to J.10.h. relocation centersi th for reception centers and host facilities were ? adequate
- a provisions d
tional needs or recommendations were identified..
No addi-J.10.1 -- Relative to J.10.1, projected traffic capacities of evac routes, the RAC indicated that the appropriate traffic cap 4
uation were provided.
No inadequacies were identified for this element.
e I
J.10.j -- Relative to J.10.j. control of access to evacuated ar found no inadequacies.
eas, the'RAC' provisions to perform this function.The State hat, responsibility and a workers and access logs.for this element concerned ' rad i
rgency J.10.k - Relative to J.10.k. identification of and mean i
' potential impediments to the use of evacuation routes, the ng'with considered by the State for possible improvemen und found to be 'adequste", equipment. procedures and letters Inventories of' were
'.10.2 -- Relative to J.10.1, evacuation time estiretes th J
i the "Seabrook Station Evacuate Time Estimate'5tude R RfRP) and concluded that although the study was "y" (Vol. 6 of the adequate" in terms of format. there still exist a number essentially issues that are of concern and need be addressed.
4 technical concerns can be grouped into'several areastThe bulk of times ~4ppear to be overly pessimistic in that the'
- worst the evacuation-tions" were generall data or conditions; y utilized whenever there were uncertainties in case situar 1
inconsistencies in data or results were not satisfa clear; ctority explained; the bases for data /results were
-(
and maps and tables had some inconsistencies.
JUN'04'87'i3:42 NRC MILLSTONE 1 P07 5
(ETEs) is not to provide data showing that necessarily'T4 evacuated prior to plume arrival, but rather to provide the decision mak a
evacuate a given area (s)ers with the best estlante of times needed to appropriate decision can be made relative to whet area (s) and the timing of such recoseendations.
J.10.m -- Relative to J.10.m. bases for choice of protective actions fo plume exposure pathway, the RAC left this iten 'osen', citi r the J.9 in its concents.
No specific actions were asred of nor recom-mended to the $ tate to resolve this issue.
As with 'J.9, there which has not Feen adequately addressed by the Sumary In reviewing the RAC cortments relative to the adequacy of p was left ' inadequate * (lack of detailed prov
. rovisions concerning the identification of stren failures and backup notifica.
tion capability). Element J.10.d was left 'o of lists of ' individuals with special needs' pen' pending FEMA review specific to the beach population but is generic to the EPZ.This item is J.9 and J.10.m were lef t "open', basically awaiting RAC re.
Elements the " beach population issue", but citing no specific inadequacies As noted above, no additional or unique action $ appear to b to adequately protect the beach populations.. Element J 101 although rated ' adequate', can be considered 'open" pending the provision of additional clarification of data / assumptions /results the evacuation time study.
Overall, there appears to be no precluding adequate protection of the beac those persons residing in unwinterized shelters).
ADDIT 10RAL PLAN DISCUSSION 0654 criteria (after RAC coments are resolved) in e NUREG neans that the plan should be adequate to provide reasonable assuranc.
This.
public health and safety can be protected during a spectrum of e that scenariot. In addition the offsite land uses an,d demography.particular attention was given to specific by a nucter of organizations.high seasonal populations have been i
Evacuation Time Study, incorporates many of the results of th years and expands on other studies and provides additional data and clarification es ot.her areas.
While the scope of Volume 6 includes the entire EPI in attention was focused on the beach areas-the seasonal >opulatio
,particular evacuation during an emergency under a va.
t of conditions in all were examined in this study).riety of conditions (ninety-five s r
For surnmer accident L
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JUN-04'S87-13a43 NRC MILLSTONE.1'
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ebout 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 10 minutes to about 4 hou
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L evacuate individual areas has been given.
Similar evacuation time estimate rom I
-(ETEs) for the population area within a 2.eille radius of r to 1
2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 20 minutes to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 40 minutes according to the studies s
i these studies tended to maximite paraseters in the.
Again I
evacuation times.
direction of increasing,-
uations.) As noted earlier, the ETEs are required i
of the times likely to be needed to evacuate a given area un
~
snakers with the best information (neither unde circumstances at the time of the acetdent.
make the optimum decision relative to the type and timing of reconynendations for a given situation.
on The. State and local plans include many special' consideratio j
the beach populations.
i Some of those considerations are listed below.
ng i
1.
public access to the beach at the Alert emerge classification level, no offsite action'would'be ordinartly warra.
g.
At this protect the public, but its consideration here would provide addit nted to time to clear the beaches or-prevent additional.public access' t beach just in case the situation worsens.
Emerge,ncy classification, one would ordinarily exp e
Note: Even at the Site Area tective actions would not, be necessary to protect the public 1
2.
An alert and notification systesn has been installed with the to provide siren coverage.
The strens can be activated individually selected groups or as the total system, can be rotated f s
i in' or fixed in any direction, and can also carry voice ressages instructions.
The system has backup' activation capability locally in town.
y i
3 Administrative provisions and coordination of emergency inst broadcast have.been provided to enable the decision ske o be i
to get the most appropriate message aired in 'a timely manner fo Spectrum of-possible scenarios y
The' scope of r the.
from that when the emergency or.ganirations' aresituations cov.ered range.
following a slowly developing situation to the unittely case wh fully staffed and are-prior to emergency organizations being abl e
situation.
e -.
4 Procedures and resources have been provided to assist the pu evacuating the beaches for directing and contro11teg traffic c in providing transportation,n for those without vehicles and'for re, for impediments or obstructions along evacuation routes.
moving
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- CUW 04 '87~13:44' NRC MILLSTONE 11"
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9, dq 5.
Provisions have also been made to coordinate New Hampshire decisions..
i regarding New Hampshire beach populations with Massachusetts for consid-1 eration regarding the Massachusetts beach areas' y
f DISCO $SION The foregoing discussions have indicated that'the current NH' plans meet or
.i will meet the criteria of NUREG 0654 in a generic sense.
Specific and oetailed procedures have been provided to assure early notification and evacuation of the beach population can be effected should the plant' status.
appear to be threatening.
The. review of these plans and' procedures-do not lations which warrant unique ~ solution or provisions b i
)
incorporated.
1 Relative to the. beach population, the distance to the Seabrook Station from the nearest beach area is almost two miles. This distance provides additional time to evacuate beach areas from the' time of release until the front edge of the plume arrives overL the beach area (assuming the wind is blowing:to the i
beach)'
This distance also can' provide considerable dis >ersion and' dilution' of the plume activity'in. traveling f rom the site to the
>each.-
(The magnitude of concentration decrease is dependent on existing meteorological ~ conditions, but could be-several orders of-magnitude.-)
1 Note:
If dispersion and dilution i
are small, then the impacted, albeit " hot
- area must' be small: and the presumably easier to protect.
d corresponding number of affected persons is also considerably smaller and It is also noted that when large, seasonal beach crowds'are likely= to be present (on. hot and sunny days), the typical wind pattern 1s from the off--
shore, cooler surface to the onshore 1
wanner ' surfaces of the land masses.
This means that any ' sea breezes" wou,ld likely prevent the plume from '
traveling directly to the nearby beach areas when the beaches are most heavily c
populated.
The sea breeze would also dilute a short tert plume even if;a portion of it was recirculated to' beach areas.
')
1he-analyzed severe accident scenarios (core melt with early containment failure) indicate that the major portion of the dose to 'the affected popula-tion from such an event:is due to exposure to deposited radioactive materials t
on the ground surfaces rather than from the passing plume. The
~
risk / consequence codes generally used the population-is exposed to this groun(d deposition for 24-hours-a:
arrival of the first portion of the plume and to any additional plumes *over
(
that area. -In other words.'the codes assume that no pn>tective actions' are:
1mplemented for 24-hours after the release reaches the beach.(or other areas -
~!
of ' interest).
In view of the NH plans' for beach closure and. access control as j
j i
OJUNLO4'871W4$.
NRC MILLSTONE 1 P10 8
o early as the Alert classification, the and the relatively short (2 to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />) plume travel time-to the beach areasf protected in the event of an accident at Seabrook Sta there, were a prompt P us, even if population were cau, severe, contaminating release and a porLion of the beach evacuation process,ght in or under'the plume ~ for two hours during the their exposure to ' deposited radioactivity would only be approximately 2/24 or less than one-tenth of the code. assumed dose.
addition, they would be avoiding any additional exposure to the ploe(s) a In leaving this area.
The overall objective of emergency response plans, as-cited'in NUREG
...to provide dose savings (and.in some cases, immediate life savings) for a.
spectrum of accidents that could produce offsite doses:in excess of the PAGs.
~
It has never been the intent of emergency preparednessfemergency plans to guarantee that no one would ever be exposed to radiation, or exposed in excess of the EPA PAGs as a result of any accident or postulated accident.
the purpose is to minimize the risks.(produce dose. savings) to the extent'Rath possible under the circumstances of the given accident..In this context, it is clear that it would be inappropriate to judge'the adequacy of emergency planning on the basis of whether or nct the plans 'and preparedness can guarantee that no one would be exposed in excess of the PAGs as a result'of-any accident scenario.
by decision makers and are not levels of acceptable or unaccep The adequac reasonable y of emergency pTaris must be based on a finding that. "there is' assurance that adequate protec
-i in the event of a radiological emergency."tive measures can and will be. taken Edward Christenb
$ pence Perry of FEMA, dated Junedefined the NRC position relative to " r i
in his letter to 18, 1986, (copy attached).
This position i
appears to be applicable to'the protection of <the Seabrook area. beach popu.
1a tions.
A similar analysis for persons inhabiting non-winterized facillities would parallel the above.
to be less at risk than the beach population with no shelter; wo smeller number than the beach population; and would generally.be treated as part of the local population group.
front would be considered part of the beach population during da season.)
since precautionary evacuation for nearby areas. eppears to be the acce protective ' action strategy if the-EPA'PAGs are projected to be exceeded, the sieltering potential of buildings, other than identified special facilities, is generally not considered for populations within about a.
2 mile radius.
Persons inhabiting unwinterized' buildings in. this area would be treated in the same manner as other (year round) residents.-i.e.
evacuated.
hoc basis by the decision makers. Persons outside this area may be considere unwinterized buildings is generic to all sites with neart)y beach or re areas and that this situation is not unique to Seabrook.
advanced in comparison with.those at other applicable sites.
-JUN 04 '87113r46 HRC MILLSTONE.1 P11 9
CONCLUSIONS
'Following are some of the areas considered above which were utilfred i arriving at a conclusion relative to the beach populations.
NH state and local plans essentially meet NUREG 0654 criteria generically Special provisions for beach populations. in place No identified problems requiring unique.or unaddressed solutions-t Provisions fe early warning of beach populations Adequate transportation resources available for those needing public trahsit arrival and dilution and dispersion of plumeBeaches are beach when beaches are most populatedSea breezes wou ETEs for beaches are relatively small i
" Reasonable assurance" does not equate with " absolute safety" guarantee of no exposures or exposures above the PAGs 4
Based on the above, it appears that contingent on the completion o the State to resolve the other RAC concerns with the New Hampshire and possible accidents and are adequate to provide re beach and unwinterized housing populations will be protected and that th plans will essentially meet the criteria of NUREG 0654 and the intent of t NRC regulations in this area.
Attac%!nt:
Letter from Christenbury to Perry dated June 18, 1986