ML20235X147
| ML20235X147 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 02/28/1989 |
| From: | Bisson J, Callendrello A, Littlefield P ABB IMPELL CORP. (FORMERLY IMPELL CORP.), PUBLIC SERVICE CO. OF NEW HAMPSHIRE, YANKEE ATOMIC ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20235W814 | List: |
| References | |
| OL, NUDOCS 8903130331 | |
| Download: ML20235X147 (50) | |
Text
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- 3 hM 19 11AR -3 A10:23February 28, 1989 AFI C.. .4 M UNITED STATES,'50FWAMERICA',
law NUCLEAR REGULATORY COMMISSION before.the.
ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of )
)
PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443-OL' NEW HAMPSHIRE, et al. ) 50-444-OL
)
(Seabrook Station, Units 1 and 2) ) (Off-site Emergency
) Planning Issues)
)
APPLICANTS' REBUTTAL TESTIMONY NO. 11 (PROTECTIVE ACTION RECOMMENDATION GENERATION)
Panel Members: Anthony M. Callendrello, Manager, Emergency Preparedness Licensing - New Hampshire Yankee Peter Littlefield, Manager, Radiological Engineering Group, Yankee Atomic Electric Company Joseph Bisson, Emergency Planner, Impell Corporation ra 31 g h h 3 w_-_-___________-__---_-_____-__--___ _ _ _ _ _ - _ _ _ _ _ _ _ - - - _ _ _ - - _ _ . _ _ _ -
.x' TABLE OF CONTENTS.
I .' INTRODUCTION .
9... . . . . . . . ... . . ... . .... -
1-II'.
CONCEPT OF PROTECTIVE ACTION.DECISIONMAKING . .:..
A. Purpose'of' Protective ActionsL .. . . . .. . .
l' 1
B.
Basis-for Decision Criteria Used.in SPMCl. . . 2
~
C. Range of Protective Actions'Provided in SPMC . 2
- 1. Shelter-In-Place / Time to Shelter. .. . . -3' D. Plume' Exposure PARS . .. . . . . . . . . . .- . 4-
- 1. PAR-Decision Criteria . . . .. . . .. . . 4
- 2. . PAR Strategies . . .. .. . . . . . . . , . . 5
- a. Meteorological Assumptions . .. . . 5 b.- Key Hole Concept . . .. . . . . . . 6-
- c. Shelter / Relocation . . . . . . . . . 9
- 3. PAR Initiated by Emergency. Classification Level or Plant' Conditions . . . . . . . . -10
- a. SITE AREA EMERGENCY . . . . .. . . 11~
- 1) Seasonal Populations . . . . . 11
- 2) General Public . . . . . . . .- 13
- b. GENERAL EMERGENCY . . . . . . . . . 13
- 1) Seasonal Populations . . . . . 13
- 2) General Public . .. . . . . . 14.
- 4. PAR Initiated by Dose Projections . . . . 17 TII. NOTIFICATION OF PARS . . . . . . . . . . . . . . . 18 A.
Transmittal of PARS Prior to ORO Activation . 19 B. Transmittal of PAR Upon NHY ORO Activation . . 19 C.
Notification of the General Public . . . . . . 22 i
_ - - - . - - - _ , , - - - - _ - - - - - - _ - - - - - - - - - - - - ~ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ~ ~ ~ ~ ~
H )
IV. . DOSE ASSESSMENT PROCESS . . . . . . . . . . .. . . 24 !
A. Use of Meteorological Data . . . . . . . . . . !
25 {
B. Deposition DosesL. . . . . . . .. . . . . . .. 27.
.C. Non-Thyroid Inhalation Doses . . . . . . . . . . 29 .i D. Shelter Dose Reduction Factors . . . . . . . .. '30
- 1. (Cloud) Whole Body Dose Reduction Factor 30 $
g
- 2. Thyroid Shelter Formula . . . . - . . .. .. 32
- 3. Groundshine Factors . . . . . . . . . . . 33 E. Consideration of " Entrapment Phenomenon" . . .. 34 Attachment A: SAND 77-1725, ,page 13 Attachment.B: SPMC, Appendix C, Utility Agreement 2 Attachment C: - NUREG-0654, pages 9 and 16 Attachment D: ~NUREG-0654, Appendix 1 at page.1-16 Attachment E: Plume Exposure EPZ Map Attachment F: Letter from Richard.W. Krimm to Glenn C.
-Woodward 1
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l I. INTRODUCTION I
This testimony was developed in response to Joint Intervenor (JI) contentions raised regarding the process for generating a protective action recommendation (PAR) as described in the Seabrook Plan for Massachusetts Communities (SPMC). It is the Applicant's response to Joint Intervenor (JI) Contentions 17, 18, 19, and 24.
II. CONCEPT OF PROTECTIVE ACTION DECISIONMAKING A. Purpose of Protective Actions The SPMC is based on the planning guidance of NUREG-0654, which states at page 6:
"The overall objective of emergency response plans is to provide dose savings (and in some cases immediate lifesaving) for a spectrum of accidents that could
' produce offsite doses in excess of Protective Action Guides (PAGs)." ,
The SPMC is predicated on the understanding that emergency planning for a nuclear plant is not required to be designed to address any particular accident sequence or a
" worst case accident." NUREG-0654 states further at page 6:
"No specific accident sequence should be isolated as the one for which to plan because each accident could have different consequences, both in degree and nature."
The purpose of the SPMC is consistent with this guidance in that:
"A prompt coordinated response is desirable to achieve the maximum feasible dose reduction under the l
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circumstances associated with a radiological release from Seabrook Station." (SPMC, page 1.1-1).
B. Basis for Decision Criteria Used in SPMC The protective action decision criteria of the SPMC take into consideration emergency classification levels, plant conditions, evacuation times, dose reduction factors, and other conditions that may exist at the time of an accident.
10 CFR 50.47 (b) (10) directs that emergency plans include guidelines for the choice of protective actions during an emergency that are consistent with federal guidance. The cited federal guidance has been identified in NUREG-0654 at J.9 as the recommendations of the U.S. Environmental Protection Agency (EPA) (EPA-520/1-75-001) for plume exposure pathway decisions and the recommendations of the Food and Drug Administration (FDA) (43 FR 58790) for ingestion exposure pathway decisions. The SPMC relies on both the EPA and FDA guidance as the basis for the decision criteria for protective actions. SPMC, Section 3.4.1.
C. Range of Protective Actions Provided in SPMC The SPMC provides for and relies upon a range of protective actions which includes sheltering, evacuation and beach closure (SPMC, Section 3.4.2.A), access control (SPMC, Section 3.6.5), and temporary relocation of the general public (SPMC, Section 3.9.3). This range of protective actions has been developed for the Massachusetts portion of
the plume exposure Emergency Planning Zones (EPZ) as required by 10 CFR 50.47 (b) (10) . i '
1.
Shelter-In-Place / Time to Shelter The SPMC relies on a " shelter-in-place" concept which means those at home are to shelter at home and those at work or school are to shelter in the work place or school building. Specifically, the general public will be 4
instructed to shelter indoors, making sure all windows and doors are closed tightly. In addition, they will be instructed to turn off all fans, ventilation or air t
conditioning systems which bring in outside air. They will also receive instructions to move to the room with fewest windows and doors and to stay turned to the local EBS radio station.
Transients located indoors will be asked to shelter at the locations they are visiting if feasible. Transients without access to an indoor location will be advised to leave the area as quickly as possible in the vehicles in which they arrived (SPMC at page 3.6-11). This concept is the same as that relied on in the NHRERP.
A sheltering recommendation can be implemented in a relatively short time pericd. The EPA has estimated that sheltering times may be a few minutes to half an hour (EPA 520/1-78-001A at page 30) . This time assumes individuals are not already in a suitable shelter and must travel to a shelter. The " shelter-in-place" concept used in the SPMC l
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assumes that individuals take shelter in the building they I are in when the PAR is issued so.that additional travel time
'is not required. Therefore, it is expected that the time to implement this type of action falls within the few minutes.to half an hour estimate of the EPA and consideration'of this time would have no material effect on the choice of protective actions.
The reference cited in JI-18 Basis A as implying that the time required to implement a sheltering response may significantly influence its effectiveness,.has been misstated. 'The statement in SAND 77-1725 at page 13 is:
"The time required to implement a shelterina/ relocation strategy significantly influences the effectiveness of each of the resnonse stratecies discussed here" (emphasis added).
The time referred to is the time to implement sheltering / relocation strategies that consider doses resulting from groundshine after the plume passes. The effect of time to take shelter is not relevant as long as the sheltering is accomplished before a radioactive release begins. Cited page 13 frem SAND 77-1725 is Attachment A hereto.
D. Plume Exposure PARS
- 1. PAR Decision Criteria The SPMC provides specific criteria for determining protective action strategies during an emergency. The l i
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criteria are emergency classifications, in-plant conditions, meteorological conditions, dose projections, field measurements and sample analyses. (SPMC, section 3.4.2, Table 3.4-1, Table 3.4-2, Table 3.4-3, Table 3.9-1, and IP 2.5.)
~2. PAR Strategies
- a. Meteorological Assumptions The decision criteria in the SPMC rely on the utilization of real-time meteorology, therefore, neither the SPMC nor its implementing procedures contain meterological assumptions. The PAR strategies in the SPMC (i.e., the i
. keyhole approach, see Section 2.b. infra) account for various meterological conditions which may exist along coastal areas.
Real-time meteorological information such as wind speed, wind direction and temperature differentials (used to determine the atmospheric stability) are obtained from the Seabrook Station meteorological tower. Regional weather '
forecasts from Weather Services International (WSI), which include predicted movement of weather fronts through the area, are obtained from the Seabrook Station Emergency Response Organization (ERO).
Information regarding shoreline meteorology, including wind shifts and sea breezes, is made available to the New Hampshire Yankee (NHY) Offsite Response Organization (ORO) from the Seabrook Station ERO at the Emergency Operations
Facility (EOF) (SPMC, Appendix C, Utility Agreement 2, Attachment B hereto). In accordance with the agreement, the NHY ORO, Seabrook Station ERO and the State of New Hampshire agree to exchange all information, including meteorological data and offsite radiological projections and measurements, l
to facilitate a rapid and accurate assessment. Therefore, as the effects of wind shifts and sea breezes become known to the ERO, they will be relayed to the NHY ORO and the State of New Hampshire assessment personnel.
In this connection, Attachment 6 of IP 2.5 also provides the potential results of high and low wind speeds which are applicable to the Seabrook Station site because they are presented in broad, general terms. These types of meteorological effects on plume behavior are not specific to any particular nuclear power station site, but rather are general facts for consideration and can be applied to the Seabrook Station site. The intent of this attachment is to provide the NHY ORO decisionmakers with information regarding how various weather conditions influence the behavior of a radioactive plume. For example, decisionmakers are informed that wind-shifts or a zig-zag plume path could result if the wind speed is low, and that greater dispersion and possibly a change in the area requiring protective actions are potential results if a high degree of air turbulence exists.
l l
- b. Key Hole Concept j l
The SPMC directs decisionmakers to recommend protective actions by Emergency Response Planning Areas (ERPAs) (SPMC, Section 3.4.2 at 3.4-4), not sectors (22.5 degree segments).
The SPMC identifies ERPAs for evacuation using a response area shaped approximately like a keyhole. Protective actions for the keyhole response area would include a 360 degree region centered on the power plant, plus an extended downwind region. This approach is consistent with the recommendations in NUREG-0654 at pages 9 and 16 (Attachment C hereto).
In'accordance with the guidance provided in NUREG-0654, Appendix 1 at page 1-16 (Attachment D hereto), IP 2.5 at Attachments 1, 2 and 3 identifies protective actions for Massachusetts communities. These PARS are based upon two keyhole sizes, a two-mile 360 degree radial distance plus an cxtended downwind area to five miles, and a five mile 360 degree radial distance plus an extended downwind area to ten miles.
The six Massachusetts communities within the 10 mile EPZ have been grouped into two ERPAs (see Attachment E hereto).
One, ERPA B, includes the Massachusetts communities which are completely or partially within a five mile radius from Seabrook Station: Amesbury and Salisbury. The other, ERPA E,
includes the Massachusetts communities which are outside a five mile radius: Newburyport, Newbury, West Newbury and Merrimac.
1 L - _ - _ _ _ - _ - _ _ - _ - _ _ - - - - -
e Under the SPMC, implementation of a PAR is on an ERPA basis (SPMC at 3.4-4). This means that if a protective action is recommended for the Massachusetts area between 2 and 5 miles of Seabrook Station, it will apply to all of Amesbury and Salisbury, rather than partially by sectors.
Similarly, if a protective action is recommended beyond 5 miles it will be applied uniformly to all of the remaining four Massachusetts EPZ communities. (SPMC, IP 2.5 at Attachments 1, 2 and 3). This planning also is consistent with the philosophy used for the development of Seabrook Station's evacuation time estimates (ETEs). (NHRERP, Vol. 6)
The effects of wind shifts and sea breezes are accounted for by the keyhole approach. In the event that windshift or sea breeze conditions exist, the boundaries of the initial response area can be expanded. Should a windshift occur, its first impact would be on the area close to the power plant in the new wind direction. However, that area would be included in the 360-degree region of the original keyhole. Post-windshift response efforts can then be focused on the previous ur,affected area in the downwind region outside the 360-degree region. Attachments 1 and 2 of IP 2.5 are Massachusetts-specific, representing only the Massachusetts portion of the total keyhole area. These attachments are consistent with the decision flowcharts used by l
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( .,
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L decisionmakers-for Seabrook Station and the State of New Hampshire.
L c .. . Shelter / Relocation The SPMC provides-for a protective action strategy that 1
includes. identification of " hot spots" after plume passage, and relocation of the general public (SPMC, Sections 3.3.2 and 3.9.3). 'The decisionmaking criteria in the SPMC relies upon the guidance established by the EPA (Relocation PAGs, L
Draft #1338J, 6/27/86). These criteria are consistent with those used in the NHRERP (NHRERP, Vol. 4A, Appendix T).
NUREG-1210 was not used as a guidance document for the
-SPMC because it (NUREG-1210) was developed as a pilot training manual and is intended to be the foundation for a course for NRC response personnel. As stated in the preface of NUREG-1210: '"These materials do Dol Provide guidance or license requirement for NRC licensees" (emphasis in original)
(NUREG-1210, Vol. 1 at page iii).
The post-plume radiological assessment activities outlined in the SPMC (Sections 3.9.2 and 3.9.3) are aimed-at identifying " hot spots", determining the projected whole body integrated dose resulting from the first year exposure to ground depcsition, and evaluating the need to relocate the general public residing in contaminated areas.
The environmental sample analyses and radiation survey results are used by the Dose Assessment Technician to l
calculate the projected first-year whole body integrated dose (SPMC, IP 2.2, Attachment 7). The projected first-year whole body integrated doses, in turn, are used by the Radiological l Health Advisor and the Accident Assessment Coordinator to j determine the need to temporarily relocate the general public in contaminated areas, and to identify areas requiring decontamination (SPMC, IP 2.5, step 5.3.4).
- 3. PAR Initiated by Emergency Classification Level or Plant Conditions Four emergency classification levels have been established by the NRC and examples of initiating conditions for each are provided by Appendix 1 of NUREG-0654.
A notification of UNUSUAL EVENT classification indicates events that are either in progress or have occurred which indicate a potential degradation of the level of safety of the plant. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs; An ALERT classification indicates events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant. Any rel. eases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels; A SITE AREA EMERGENCY classification indicates events are in progress or have occurred which involve actual l
1
l or likely major failures of plant functions needed for protection of the public. Any releases are not expected to exceed EPA Protective Action Guideline exposure levels except near the site boundary; A GENERAL EMERGENCY classification indicates events are in progress or have occurred which involve actual or imminent substantial core degradation or melting with the potential for loss of containment integrity. Any releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite beyond the site boundary.
The emergency classification is determined and declared by Seabrook Station ERO personnel. Consistent with NUREG-0654, the SPMC provides for actions to be recommended to the Commonwealth of Massachusetts upon the declaration of two emergency classifications, SITE AREA and GENERAL EMERGENCY.
- a. SITE AREA EMERGENCY
- 1) Seasonal Populations The SPMC recognizes that summer transients at the beach areas represent a special population and require separate consideration. Special consideration is given to the general public at the beach areas within the Massachusetts portion of the EPZ by the provision for a precautionary beach closure recommendation at a SITE AREA EMERGENCY (SPMC, Sections 3.4.2.A and 3.6.1.E). The ORO will, between May 15 and September 15, automatically recommend to Massachusetts
officials the closure of beaches as a precautionary action.
(SPMC, IP.2.5.) This recommendation is made regardless of the size of the beach population. Therefore, there is no need to perform an assessment of the beach population beforehand. The intent of this action is to remove the transient beach population from the immediate beach area at the first indication that the potential exists for a radioactive release.- The early closure of the Massachusetts beach areas is also intended to alleviate traffic congestion at these areas in the event that evacuation is ordered at a later time.-
The State of New Hampshire may choose to close New Hampshire beaches within two miles of Seabrook Station at the ALERT classification. The recommendation to close Massachusetts beaches is not made at an ALERT classification because of their distance from Seabrook Station. The distance from Seabrook Station to the closest Massachusetts beach areas is greater than two miles. Actions for areas at distances greater than two miles from the site are not considered appropriate at the ALERT classification. In this i
regard, the SPMC is consistent with the planning in the NHRERP, which includes provisions for closure of New Hampshire beaches within only a two-mile radius at the ALERT classification and only under limited circumstances (NHRERP, I
Vol. 4A, Appendix U), but does not provide for closing New l l
Hampshire beaches beyond two miles.
At a SITE AREA EMERGENCY, the NHY ORO will, between May )
15 and September 15, recommend a precautionary closure of Parker River National Wildlife Refuge, Plum Island Beach, i Salisbury Beach and ocean access (SPMC, IP 2.5, step 5.2.1.b).
- 2) General Public Protective actions for the general public would not be required at the declaration of a SITE AREA EMERGENCY. At the SITE AREA EMERGENCY any radioactive releases are not expected to exceed EPA protective action guidelines except near the site boundary. The distance from Seabrook Station to the Massachusetts border is greater than two miles. This planning in regard to protective actions is consistent with the NHRERP.
- b. GENERAL EMERGENCY
- 1) Seasonal Populations At a GENERAL EMERGENCY, the NHY ORO will recommend beach closure (if not previously recommended) regardless of other PAR (s) that may be issued for the general public. IP 2.5 will reflect in the next revision of the SPMC that the beach !
closure recommendation is to be made at a GENERAL EMERGENCY regardless of the time of year. Two general public PARS and associated beach actions are:
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M If a sheltering PAR is issued for the general public, the Massachusetts beaches within the EPZ are closed and the transient beach population without access to indoor locations (i.e., day trippers) leave the area, while the general public (i.e., residents and motel guests with access-to an indoor location) shelter; If an evacuation PAR is issued, the transient beach population is evacuated along with the general public.
This approach to protective actions for beach transients as a special population is consistent with NRC regulations and FEMA /NRC guidance since sheltering for all population groups is not required by either 10 CFR
- 50. 47 (b) (10) or NUREG-0654.
The beach population and the general public will be notified of beach closure through the Vehicular Alert and Notification System (VANS) and Emergency Broadcast System (EBS) by the NHY ORO upon receipt of authorization to do so from the Commonwealth of Massachusetts (SPMC, Section
- 3. 6.1. E) . Statements of the beach closure are included in prescripted EBS messages. The EBS messages will advise the transient beach population to leave the beach area and provide instructions for the resident population.
- 2) General Public Protective actions such as shelter or evacuation for members of the general public in the Massachusetts portion of i
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the EPZ are considered upon declaration of a GENERAL EMERGENCY.
Attachments 1 and 2 of IP 2.5 will be used to determine i protective action recommendations for the general public based on in-containment radiation levels.. The in-containment radiation level as measured'by the Post LOCA or Hatch monitors and the wind direction determine which' Massachusetts communities are to be affected by a shelter or evacuation recommendation.
If the Post LOCA monitor indicates that in-containment radiation levels are less than 5,000 R/hr, and the wind direction is towards-Massachusetts (i.e., from 304' to 101'), the NHY ORO will recommend shelter for Amesbury and Salisbury in addition to beach closure (if not recommended
'previously). If the wind direction is towards New Hampshire, the NHY ORO will recommend beach closure only.
If the' Post LOCA monitor indicates that in-containment radiation levels are between 5,000 and 10,000 R/hr and the wind direction is towards Massachusetts, the NHY ORO will recommend evacuation for Amesbury and Salisbury (including Salisbury Beach), shelter for the other Massachusetts EPZ communities, and closure of Plum Island Beach and Parker River National Wildlife Refuge (if not recommended previously). If the wind direction is towards I
)
l New Hampshire, the NHY ORO will recommend shelter for all six Massachusetts communities in addition to beach closure.
If the Post LOCA monitor indicates that in-containment radiation levels exceed 10,000 R/hr, and the wind direction is towards Massachusetts, the NHY ORO will recommend evacuation of all six Massachusetts communities.
If the wind direction is towards New Hampshire, the NHY ORO will recommend evacuation for Amesbury and Salisbury (including Salisbury Beach), shelter for the remaining four Massachusetts EPZ communities, and closure of Plum Island Beach and Parker River National Wildlife Refuge (if not recommended previously).
The SPMC uses in-containment radiation levels, as
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indicated by the Post LOCA and Hatch monitors, to assess the potential for a release of large amounts of radioactivity based on the guidance in NUREG-0654 at page 1-17 and IE l Information Notice No. 83-28: Criteria for Protective Action Recommendations For General Emergencies. The in-containment radiation level is a measurable and observable parameter that can be used to assess the status of core and in-containment radiation conditions. Its use is intended to provide NHY ORO decisionmakers with a basis for formulating PARS at a General Emergency prior to a release. The in-containment radiation level is not used as an " indicator of the imminence or magnitude of containment failure." Moreover, the SPMC's use
offin-containment radiation level as indicated by the Post LOCA and Hatch monitors promotes consistency with PAR development by New Hampshire decisionmakers (NHRERP, Vol. 4A, Appendix U). Other plant conditions are evaluated by l
Seabrook Station ERO personnel and may influence the PAR made to the NHY ORO.
- 4. PAR Initiated by Dose Projections While initially protective actions will be recommended based on in-containment radiological conditions, data regarding actual or projected releases of radiation will be used to refine protective actions to ensure the greatest dose-savings (SPMC, IP 2.5 at 5.2.2, 5. 2. 5 and 5. 3.1C) . However, previously recommended evacuations underway would not be rescinded for the affected areas.
The calculation which compares the dose savings of shelter and evacuation is performed via the PAR Worksheet (SPMC, IP 2.5, Attachment 3). This worksheet incorporates a three step process in the dose savings analysis.
- 1. The projected dose is calculated assuming no protective actions are taken. If the EPA Protective Action Guides (PAGs) are not exceeded then no protective actions are required. If the EPA PAGs are exceeded then;
- 2. the projected dose is calculated twice; once assuming an evacuation and once assuming sheltering;
- 3. the shelter and evacuation doses are compared to see which provides the lower dose. The protective action that results in the lower dose is then selected.
u li III. NOTIFICATION OF PARS The NHY ORO requires authorization from the Commonwealth of Massachusetts to notify the general public and to implement protective actions because the authority for implementing protective actions'for the public in Massachusetts lies with the Governor (Radiological Emergency Response Plan, Appendix 3 To Hazard Specific Supplement No. 6 at page A.4-3). This is consistent with the approach the commonwealth anticipates in the event of an emergency at Seabrook Station. Specifically, "After consultation with the Director of Public Safety or his designee as to the ad hoc measures to be taken, the Governor would exercise responsibility for the issuance of emergency public information, coordination (where applicable) with other states, and authorization of protective actions." (Emphasis added.) Massachusetts Attorney General Answers to NRC Staff's Third Set of Interrogat .es and Requests for Production of Documents at pages 6 and 7.
The Seabrook Station Radiological Emergency Plan and the SPMC provide for the recommendation of protective actions to the Commonwealth for a spectrum of accidents from fast-breaking to those that escalate more slowly.
The provisions for public notification as set forth in the SPMC allow for the recommended time requirements in
e, b
NUREG-0654 II.E.6 and Appendix 3(b) (2) (a) to be met, once-authorization to perform this function has been granted by the Commonwealth of Massachusetts. The planning, procedures and equipment specified.in the SPMC give the NHY ORO the capability to notify the general public throughout the Massachusetts portion of the 10 mile EPZ within about 15 minutes.
A. Transmittal of PARS Prior to ORO Activation Should an emergency which requires protective actions be declared initially, the Short Term Emergency Director will notify Massachusetts officials within 15 minutes of the declaration, provide them with the utility's PARS, and request authorization from Massachusetts officials to activate the public notification system and issue EBS messages (SPMC, Section 3.2.5). The licensee's responsibility for making PARS, which is directed by 10 CFR 50.47 and recommended by NUREG-0654 (J . 7 ) , is assumed by the decisionmakers at the onsite facility (i.e., Control Room, Technical Support Center, or Emergency Operations Facility) which has command and control of the onsite ERO.
B. Transmittal of PAR Upon NHY ORO Activation The NHY Offsite Response EOC will be declared operational by the Offsite Response Director when the Assistant Offsite Response Directors, the Radiological Health Advisor, the Public Notification Coordinator, and the Public
Information Advisor determine that their staffing is sufficient to undertake their functions (SPMC, IP 3.1 at' step 5.1.4). Until that time, the Seabrook Station onsite ERO retains the responsibility for recommending and transmitting PARS to Massachusetts. Upon activation of the NHY Offsite Response EOC, the NHY ORO assumes from the Seabrook Station !
ERO the responsibility for recommending protective actions to the Commonwealth and obtaining authorization from the Commonwealth to issue protective action recommendations through activation of the public notification system and issuance of EBS messages (SPMC, Section 3.2.5).
The SPMC provides for the notification of Massachusetts officials concerning protective measures for both the plume exposure pathway and ingestion exposure pathway through the NHY Offsite Response Director and the NHY ORO Massachusetts State Liaisons. The Governor of Massachusetts, or designee, is contacted by and receives PARS from the NHY Offsite Response Director. The NHY Offsite Response Director provides briefings to officials of the Commonwealth of Massachusetts on the emergency situation, including the need for any protective actions, and obtains authority from the Commonwealth before notifying the general public and implementing certain actions (SPMC, Section 3.1).
The SPMC provides for three NHY ORO Massachusetts State Liaisons to be dispatched to Massachusetts emergency
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facilities. The functions of the NHY ORO Massachusetts State Liaisons are designed to establish and maintain communications between the NHY ORO and state agencies at the state emergency facilities thereby enhancing the coordination of emergency response activities.
Two liaisons coordinate NHY ORO activities and establish communications with the Massachusetts Civil Defense Agency (MCDA) EOC at Framingham (State) and Tewksbury (Area I). The third liaison coordinates NHY ORO activities and establishes communications with the Massachusetts Department of Public Health (MDPH).
All three NHY ORO Massachusetts State Liaisons are directed procedurally to maintain communications with the Commonwealth; to coordinate requests for support from, or supply information to MCDA and MDPA; to support MCDA and MDPH in implementing recovery actions; to provide identification of available NHY ORO resources; to document requested resource use; to ensure that all decisions or actions taken by MCDA or MDPH are conveyed to the NHY ORO; and to update the Commonwealth on decisions or actions taken by the NHY ORO.
The NHY ORO Massachusetts State Liaisons are issued copies of the SPMC, including Appendix M; the NHY offsite Response Emergency Resource Manual; Appendix J; the NHY Offsite Response Traffic Management Manual; and Appendix L; t
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1 the Seabrook Station Ingestion Pathway Database for the Commonwealth of Massachusetts, for their reference in 1
advising government officials on the capabilities of the NHY ORO. !
In addition, the SPMC also provides work space at the NHY Offsite Response EOC for Massachusetts state
~ representatives (SPMC, Section 5.2.1 and Figure 5.2-2) that the Commonwealth will send to the NHY Offsite Response EOC
'(Massachusetts Attorney General's Answers to NRC Staff's Third Set of Interrogatories and Requests for Production of Documents at page 5). Representatives from the Commonwealth will have full access to the NHY Offsite Response EOC.
C. Notification of the General Public The means of providing public alerting and notification to the resident and transient population within the six Massachusetts communities is through activation of the VANS which consists of sirens that are mounted on vehicles maintained at continuously staffed staging areas located throughout or near the Massachusetts portion of the EPZ and EBS (SPMC, Section 3.2.5). The EBS messages will be broadcast with the activation of the VANS (SPMC at page 3.7-5 and IP 2.13 at step 5.1.11). The regulatory requirement applicable to the prompt notification system timing is contained in 10 CFR 50, Appendix E, Section D.3 which is, "The design objective of the prompt notification system shall l
be to have the capability to essentially complete the initial notification of the public within the plume exposure pathway EPZ within about 15 minutes."
There is no regulatory limit for the amount of time that may be taken by offsite officials in arriving at protective action recommendations. However, FEMA guidance states that the nature of the emergency will dictate the time available (FEMA Guidance Memorandum AN-1 at page I-5). Furthermore, the decisionmaking time available to offsite officials should not be calculated in the 15-minute notification requirement (FEMA Guidance Memorandum AN-1 at page I-3). FEMA has also indicated a similar position on this subject in a letter from Richard W. Krimm to Glenn C. Woodward (Attachment F hereto).
Additionally, the regulations do not set any quantitative standard with regard to the overall length of time required from the declaration of a particular emergency classification to the notification of the public.
Prior to the activation of the NHY ORO, the Seabrook Station Short Term Emergency Director is in contact with the Commonwealth of Massachusetts and, if authorized by Massachusetts officials, will direct the VANS and EBS to be activated (SPMC at page 3.2-17, IP 2.1 at page 19, Appendix G at page G-13).
Upon activation of the NHY Offsite Response EOC, the NHY ORO assumes responsibility for contacting the Commonwealth of
Massachusetts for purposes of recommending protective actions, sounding of the sirens and issuance of EBS messages.
The latter two activities are performed upon receiving authorization from Massachusetts officials (SPMC, IP 1.1, Attachment 2, IP 2.13 at Step 5.1.11 and Appendix G at page G-13). The EBS Station is contacted via a dedicated ringdown circuit and instructed to broadcast either a pre-recorded message already on hand at the station or an authorized prescripted EBS message that is telecopied to the station (SPMC, IP 2.13, step 5.1.11.C). The sirens are activated remotely from the NHY Offsite Response EOC (SPMC, IP 2.13, step 5.1.11. D) . The SPMC provides for the capability of notifying the public within about 15 minutes, consistent with FEMA Guidance Memorandum AN-1.
The ability of the NHY ORO to alert the public within the Massachusetts portion of the EPZ and broadcast an EBS message within about 15 minutes of obtaining authorization from Massachusetts was demonstrated satisfactorily during the Exercise. (FEMA Final Exercise Report, 9/3/88, at Objective
- 12, page 214.)
IV. DOSE ASSESSMENT PROCESS The SPMC dose projection procedure (SPMC, IP 2.2) uses data provided by METPAC, a computerized atmospheric dispersion model operated by the Seabrook Station ERO.
METPAC calculates plume arrival time for various downwind
distances, projected whole body and thyroid dose rates, atmospheric dispersion factors, and projected whole body and thyroid integrated doses for 2, 4, 6 and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of exposure.
METPAC also possesses graphic capabilities which allow a visual representation of the plume and affected areas. The METPAC model relies on real-time meterological data and assumed or measured isotopic release information as input for its calculations. The METPAC input data plus the METPAC summary printouts are provided to the NHY ORO periodically (i.e., at approximately 15 minute intervals) by the Seabrook Station ERO during an emergency.
In the event that a METPAC printout is unavailable, the NHY ORO uses a calculation method which relies on an HP-41 CX hand calculator for dose rate projections. This method also uses real-time meteorological data as input for dose rate projections. It is less sophisticated than METPAC in that it provides dose rate projections and atmospheric dispersion factors, but not a graphic representation of the plume.
However, under similar meteorological conditions, the dose rate projections calculated using the HP-41 CX method are consistent with those calculated by METPAC.
A. Use of Meteorological Data The meteorological data available immediately to the NHY ORO assessment personnel include the local meteorological parameters from the Seabrook Station meteorological tower and
l l
regional forecast information from Weather Services j International (WSI). !
The Seabrook Station meteorological tower provides real- .
time wind velocity, direction and temperature differentials.
This information is input directly into the Main Plant l
Computer System and is available at the Main Plant Computer '
System terminal at the Emergency Operations Facility (EOF) .
At the EOF, the information is entered on the METPAC Input Data Logs and used as input data for METPAC calculations.
The METPAC Input Data Logs, in addition to the actual METPAC printouts, are distributed at approximately 15 minute intervals to the NHY ORO assessment staff by the Seabrook Station Dose Assessment Specialist.
The regional forecasts from WSI are available to the NHY ORO via Seabrook Station ERO. The WSI weather information includes predictions on the movement of weather fronts through the area. In addition, WSI provides data from inland weather stations which the NHY ORO uses to assess shoreline meteorology, including wind shifts.
The NHY ORO assessment personnel use the data from the Seabrook Station meterological tower to initially identify the direction of a potential or actual release and the affected downwind communities. In addition, the information from the meterological towers is used by the NHY ORO w
assessment personnel when projected' dose rates are calculated' using the HP-41 method.
Data obtained from Seabrook Station meteorological tower L are sufficient for dose rate. projections and determining the' affected downwind area. Moreover, these' data and the WSI forecasts are incorporated into PAR decisionmaking in a timely. manner.
The NHY ORO Accident Assessment Coordinator obtains.the wind speed and direction from the Seabrook Station EOF Coordinator (SPMC, IP 2.5 at step 5.3.1) in order to complete the PAR worksheet (SPMC, IP 2.5, Attachment 3),
thus, local meteorological parameters are incorporated into PARS. Since meterological' conditions can change within-short time periods, the dose assessment procedure includes a note to remind the Accident-Assessment Coordinator to use the most recent METPAC printout and Input Data Log for his assessments (SPMC, IP 2.2 at page 4).
The Accident Assessment Coordinator also obtains the latest regional weather forecast from WSI prior to suggesting a PAR to the Radiological Health Advisor (SPMC, IP 2.5 at Step 5.3.2).
B. Deposition Doses The EPA PAGs are specific for radiation exposure received directly from the airborne plume (EPA-520/1-75-001, Chapter 2). The intent of the EPA PAGs is to initiate protective action for direct whole body and inhalation j
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_ _ _ _ _ _ _ _ _ . . ,_ - . - - - - , - - - - - - - - - - - - -- ~
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(thyroid) exposure resulting from plume passage. The dose rates from deposited material'are expected to be low relative to doses from the passing plume and only significant over extended exposure periods. The EPA considers whole body exposures from deposited material to be a long term dose, and maintains that "it is not practical to consider the long term doses as part of the plume PAGs" (EPA-520/1-75-001, Appendix C). Accordingly, the SPMC does not include the whole body dose contributions from ground, autcmobile or skin deposition in its decision whether to shelter or evacuate in the plume exposure pathway because it has adopted the EPA guidance. In this regard the SPMC-is consistent with Commonwealth of Massachusetts plans for the Pilgrim and Yankee Rowe plants.
The.SPMC provides for the evaluation of doses from deposited material as part of post-plume assessment activities (SPMC, IP 2.2,-Attachment 7). The method used in the IP 2.2 for calculating projected whole body integrated doses resulting from exposure to radioactive ground deposition during the first year after a radiological accident follows the guidance established by the EPA (Implementation Guidance for Relocation PAGs, Draft #4194C, 6/03/86). The calculation of the projected first year I integrated doses relies upon measured data, such as environmental sample analyses and field radiation surveys,
s.
which provide the best basis for realistic dose projections from ground deposition.
The projected first year integrated' doses are used by the Radiological Health Advisor to determine the timing of reentry or the need for relocating non-evacuated members of the general public residing in areas'that have been subject to radioactive deposition.
C. Non-Thyroid Inhalation Doses The decision criteria in the SPMC consider inhalation exposure to only the thyroid because thyroid exposure is the expected controlling mode except under circumstances "when thyroid dose is reduced" by iodine blocking or "there-is a long delay [after shutdown] prior to releases" (NUREG-0654, Section~D, Table 3, page 18).
Under the SPMC, the only circumstances under which the
" thyroid dose is reduced" are if protective actions, either sheltering, evacuation or use of potassium iodide (KI), have been implemented. Since the Commonwealth's policy on KI precludes its use for the general public, this condition need not be considered. Under either evacuation or sheltering conditions, protective actions for inhalation dose to other organs also have been taken. Moreover, if "there is a long delay [after shutdown] prior to releases," time is available to notify the general public and implement PARS, thereby
-eliminating the risk of radiation exposure completely.
Accidents in which the inhalation dose to an o'rgan other than the. thyroid may be the controlling element are those-which occur at other types of facilities in the uranium fuel cycle and in research, medicine and industry, other than commercial nuclear power plants. (EPA-520/1-75-001, Appendix C at page C-10).
D. Shelter Dose Reduction Factors
- 1. (Cloud) Whole Body Dose Reduction Factor As described in Section A.4.d supra, one of the means for selecting a PAR is, in accordance with the SPMC, IP 2. 5, Attachment 3, a comparison of the dose savings from evacuation and sheltering. The SPMC includes a 0.9 cloud dose reduction factor, which is identical to that used in the NHRERP, to be used in performing this comparison.
The 0.9 dose reduction factor is applied to all housing within the ERPAs to facilitate the implementation of a single plume exposure PAR for the ERPA. Since PARS are applied uniformly to Massachusetts communities within an ERPA (SPMC, Section 3.4.2.A), the formulation of PARS considers only one dose reduction factor. The SPMC adopted its 0.9 dose reduction factor from "Public Protection Strategies for Potential Nuclear Reactor Accidents: Sheltering Concepts with Existing Public and Private Structures" SAND 77-1725.
Also, based on the documents, Structure Shielding From Cloud and Fallout Gamma Ray Sources for Assessing the
'l
{
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Consequences of Reactor Accidents, EG&G, Inc., Las' Vegas, Nevada, EGG-1183-1670-(1975), and Public Protection Strategies:for Potential Nuclear Reactor Accidents:
Sheltering Concepts With Existing Public and Private Shelters by Aldrich, et alt, February 1978, and their analysis of typical structures to be found in the Northeast region of the United States, Seabrook Station EPZ' structures have a cloud dose reduction factor of at least 0.9; and this-is, therefore, a reasonable dose reduction factor to be assumed by the SPMC.
The 1970 U.S. Housing Census cited in JI-18 specifies only " year-round housing units" throughout the Commonwealth of Massachusetts and the statistics may, in fact, be applicable to the year-round housing in the six Massachusetts communities within the 10-mile EPZ. However, there is a considerable number of seasonal housing units without basements in these communities, particularly in Salisbury, Newburyport and Newbury, which are considered ar.d factored into the PAR decisionmaking criteria. Additionally, the statistics cited by the Joint Interveners indicate that a l significant portion (approximately 7%) of the year-round housing units in the six Massachusetts EPZ communities do not have basements. These types of housing afford less protection than the year-round housing units with basements referenced in the contention.
l
Results from a study conducted by Stone and Webster Engineering Corporation indicate that 52 percent of the houses in the Salisbury and Plum Island (Newburyport and Newbury) beach areas have no basements and are of wood frame construction. When this statistic is considered together l with the 7% value for year-round housing without basements, the use of a 0.9 dose reduction factor in the SPMC is appropriate. Therefore, the dose reduction factor of 0.9 is used in the SPMC to reflect the lower protection afforded by the housing units that do not have basements.
- 2. Thyroid Shelter Formula The' formula used in the SPMC to determine a sheltered thyroid dose is a function of the duration of a radioactive plume and is intended to provide an estimate of the effectiveness of sheltering as a protective action in situations where the thyroid dose is the controlling element.
The air exchange rate assumed by the formula is two exchanges per hour. In addition, the rate of air exchange is consistent with those cited by the EPA for seasonal structures (EPA-520/1-78-001A at Table 2).
The thyroid sheltering formula is applied to all housing units within the ERPAs to facilitate the implementation of a single plume exposure PAR for the ERPA. Since PARS are uniformly applied to the Massachusetts communities within an l
l L__---------
ERPA (SPMC, section 3.4.2.A), the formulation-of PARS.
considers only one rate of air exchange.
Sheltering provides inhalation dose protection only for a short period of time and, generally, becomes ineffective after two hours (EPA-520/1-75-001. at page 1.38). The formula used in the SPMC is consistent with the EPA guidance in that it indicates that the effectiveness of shelterin< decreases as the plume Aretion increases.
- 3. Groundshine Factors Dose reduction factors for groundshine are not part of the SPMC relocation criteria because their use is not applicable to the type of guidance established by-the EPA for relocating the general public. EPA guidance evaluates the need for relocating the general public based upon the.
projected integrated whole body doses from deposited radioactive material to unprotected individuals during the first year following an accident (Relocation PAGs, Draft
- 1338J, 6/27/86, U.S. Environmental Protection Agency).
Because it is not reasonable to expect people to stay sheltered in their homes for an extended period, the use of dose reduction factors as part of a post-plume evaluation is not appropriate. Rather than considering continued sheltering as a post-plume recommendation, the SPMC provides for a recommendation for temporary relocation of the general
\
}.-
1 s public, if necessary, followed by a return to the area when ,
radiation levels are reduced below EPA acceptable limits. {
I E. Consideration of " Entrapment Phenomenon" The SPMC does not ignore the possible scenarios inappropriately labeled " entrapment phenomenon" at the Massachusetts beach areas. The SPMC provides for the closing of Salisbury and Plum Island beaches and the Parker River National Wildlife Refuge as a precautionary measure to be taken at the SITE AREA EMERGENCY.
The rationale for this precautionary beach closure recommendation is to allow the transient beach population to leave the immediate beach area, thus removing then from the area prior to escalation to an emergency that could require sheltering. Further, beach closure will alleviate potential traffic congestion in the event that evacuation of the resident population may be necessary at a later time.
Precautionary beach closure is recommended between May 15 and September 15 (SPMC, Section 3.4.2.A, IP 2.5 at step 5.2.1) which is the time period during which peak beach population can occur and is also consistent with the time period that the State of New Hampshire will issue its own recommendations for New Hampshire beaches (NHRERP Vol. 4A, Appendix U).
Traffic congestion at the beach areas is accounted for thorough use of the various scenarios for the evacuation time
.~
estimates _(ETE) included in Attachment-4 of IP 2.5. The information provided on this' attachment includes the time estimates for 5- and 10-mile evacuations for selected times during the week and day under.two general conditions. Two of.
these summer ETE scenarios deal with peak beach population; one during good weather and the other with sudden rain.
' Reduced roadway capacity due to bad weather is considered through the selection of the ETE (SPMC, IP 2.5, Attachment 4) and through use of Attachments 6, 7 and'8 of IP 2.5. Specifically, Attachments 6, 7 and 8 deal with factors such as low and high wind speeds, atmospheric stability classes, rainfall, flooding, hazardous materials, fires, extreme temperatures, and road maintenance which can be used to take actions to improve the implementation of a particular protective action.
Under conditions such as blizzards or flooding which could prevent the movement of the public'for some time, the NHY ORO will recommend sheltering until evacuation is possible.
l l
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Attachment A (page'l of 1) .i
~
c .. ; ~ l
, ' .x 1
i j
1 todoors at their present location, er to cove indoors if they ar e outside, pr et'erably occupying base =ents if they a re availaele.
Additional tenefit might te der ived. f rom a strategy o f employing preferential sheltering locations (strategy (3) stove); for example, directing people to those nei,ghboring homes vtta base-ents or to nearby large buildings such as . schools, puelic of fi:e buildings or puolle f allout sheltses.
The :::e requ' ired to imple=ent a sneltering/ relocation ;
s t rategy significantly inf1;ences tne effeettveness of eacn of the response strategies discussed here. *deally, snelter-access by the public would be accomplished prior to the arrtval of the cloud of radioactive material. If this cannot te accomplished, ine
' ef f ectiveness (dese reducticn) diminishes almost linearly with increasing outside exposure time (6). Radiation exposure from radionuclides depostted on the ground and other surf aces conclaves long af ter cloud passage and, in many instances, in a relatively short time results in a dose se h greater than the dose from
, the otner exposure pathways. Therefore, the time intervel between the cloud passage and the puolic relocatica is also very i:portant and should be sinimized.
IV. REPRESENTATIVE SHIEI. DING FACTORS In order to evaluate the three sheltering / relocation strategies identified above, shielding f actors representative of each strategy must be obtained. The durson and Profio [4] shielding factors presented in Tables 1 and 2 above say be used to evaluate pref erential sheltering in specific building types (strategy (31). However, the. ressining two strategies r equire some kncvledge or estimate 1
of the frequency distribution of the occupancy for various types of btt11 dings as well as the ava11a.b111ty and occupa.ncy of basen.ents .
--36--
13 L____--______-__-
_ , . _ . _ , . _ _ _ - - - - - - - - -- ' - ' ' - " - - - ~ ~ - - - ~ _ . _ _ -
I 2 Attachment.3 Icage 1 0f A)
.1 1
- )
A.endment ; I Page ' :f 4 l .ET E: CF_AGREEuSNT --
LE.JWEEN THE 37 ATE OF NEW HAHPSHIAE-
_A NO .
o NEW - VP_SH!: E vaNXEE EPRESENT!NG SOTH TjE EMERGENCY ANO CFFSITE RESPONSE ORGANIZATIONS
- DURPCSE:
The curecse Of tre Letter :' Agreement is to estaolisn rac1ological.
emergeacy creoarecness, notif cation ano resconse snoulo an event at Sea:recx Stati:n recutre Raciciegical Emergency.:esocnse P'an activatten .
- . OEF*N*T0NS:
A.
.Emercenev Coer.ations Centers (EOCs) -
Facilities estaolisnec cy tne State of NH anc t e NHY CR0 wnere emergency resoonse c mmanc anc control occurs. The State of NH EOC is located in Concord, NH, land tne NHY ORO E;; s co :cated W1tn tne NHY EOF.
- 3. Emercency Ceerst Station. Newingten. NM s ese.t t-Stv (EOF) - A center estaclisnec at Newingt:rc cecrcinate tne ceoloyment of NHY ERO cers:nne' to evaluate ef' site ac:1 cent aitn offsite autner ties. conoitions anc to maintain. communications C. EOF C:orcinater - an NhY ERO memoer wno ::orcinates acci:ent assessment anc crotective acticn recommendations witn of fsite authorities, ne
- noucts tnese functions within the EOF.
- 3. :ncicent rield Odf ce <!FO) - A center establisnec in tne vicinity of the New Hamosnire cortien of the Seaorook Station Emergency Planning Zone, wnere the State of New Hamosnire resoonse and assistance to loca' communities is coorcinatec.
The IFO is co-located witn tne NHY ECF.
E. Media Center concucting joint NhY ERO, NHY CRO, State of NH, and Federal briefings
- A center Cecicated to the news media for ne ourcose Of l concerning emergency conc 1:1ons. (
Town Hall in Newington. NH. The Mecia Center is locatec at tne I
'F. New wnmosnire vankee Emercency o esconse Or ani:stion INHY E401 -
The licensee's organt:ec cersonnel rescense to a Seaor:ox Station
- aotological Emergency.
l l
- 3. 1 New -amosn re vankee Offsite Gesconse Creans:stion INHv C00[ -
New Hamosnire Yankee's c a:ensation organization for tne C mmonwealtn
_ _ - _ _ - _ - - - - - - - - - - - - - - - - _ _ _ _ _ _ _ ___ -- - - - - - - - - - - - - - - - - - - - - - - - - - - - ~ ~ ~ ' ~ - - ' ' ~~~ ~~
Attachmen 3 (p ye 2 of 2)
Amendment 2 Page 2 :f a
(' \
'\ l
". Nuclear Alert j y_s,t e m iNASI -A communication system fce initta' notification to tne State of New Hampshire anc t e NHY CR0 of an-emergency at Sesoreck Station; and the means of communication cetween tne tnree organizations for exc.nange of information curing tne cerioc of t e emergency.
II. AGREEMENT
'he State of New camosntre anc New Hamosnire Ya'nkee. earesenting =ctn tre NHY E:0 anc 1.e NHY CRO, agree as folicws; A. d
~5e NHv E90 snal' "0ti y tre NH State P0 lice and tre NHY CR0 Centact ::1nt at nin F ' teen it5) minutes a'ter an event nas :een
- ass 1fEmergency.
General ac as an enustai Event, Alert, Site Area Emergency or Commercial ~his notification snail be mace over tne NAS.
teleocene is tre cackuo to the NAS.
8, The initial message content used in tne contact specified in A.
aoove, is in agreement among the emergency response procecures of each of tne tnree organizations. After the initial contact, ;
aeditional information sna11 ce provided to the NH Division of Publiq Health Services Emergency 4esconse Initiator anc the NHY ORO 01 rect:r' wnen eacn makes a call-bacK to the NHY ERO.
This information is soe-c1ftec in crocecures response tne follow-voof notification form containeo in the emergency the tnree organizations.
C.
The tnreeclan esocnse organizations snall excrange and ccorcinate emergency enanges tnat crier to implementing tne enange. certain to those elements of interface The tnree organi:ations sna",'
Ocore1nete tne effective cate of suen changes.
D.
The NHY ERO snail crevice soace for representatives from the State of New Hamosnire and the NHY ORO at tne EOF anc the Mecta Center.
This incluces soace at the LOF for the coeration of tre State EOC.
of New Hamosnire IF0, and for the coeration of the NHY CR0 E.
The three organizations agree to exchange all information (i.e.,
radiological releases, meteorological cata, offsite radiological projections anc measurements, and onsite tecnnical data) known and availaole to facilitate a rapid and accurate evaluation of tne emerger:y.
F.
The NHY CRO anc the State of New Hamosnire agree to coorcinate the notification of the cuoli: cy the puolic alert anc nctificatice system arc tnrcugn ESS.
G.
~he NHY CAO anc State of New namosn1re agree to c:orcinate t9e evaluation and implementation of precautionary actions for : ecial populations within the oiume exposure EPZ.
- - _ A A --------
Attachment 3 (case'3-of 2)
Arendment .
Dage 3 of 4
-H.
~he tnree organ 1:st1ons snali coordinate clume exoosure EPZ f'elo radiological mon 1tcring efforts.
, .ceoleyment This coordination is to incluce the of each organization's offsite monitoring teams (i.e., tne State of New Hamosn1re teams within the New Hampshire portion of the -
clume E?Z, the NHY CR0 teams within tne Massacnpsetts cortion ano the NHY ERO teams tnroughout the EPZ), the review and exchange of all monstering results, and tne radionuclice analysis of particulate anc raciosocine air samoles at tne NHY EOF.
- ~he NHY ERO agrees to assist the State of New Hamosnsre anc ine Nmv
- RO in ingestion catrway samo11ng and analysis efforts.
~his incluces assistance to tne State of New Hamosn1re coercination cf ingestien catnway evaluations witn tne State of Maine.
ass 1 stance can include samoling cersonnel The scooe of the ano ecu1pment anc racionuclice analysis capacility.
J. Once the EOF is act1vated, coint for contact the EOF Coordinator of the NHY ERO is tne for tne State of New Hamosnire and tne NHY ORO for ractological assessments and protective action recommendation-discussions.
The tnree control organizations agree to coordinate news releases anc rumor' activities.
timely, coorcinatec manner *hrougn tne MediaAl'so, Center.Information tne tnree organizations agree to participate in a cer ocie emergency creoarec-ress ecucation and orientation orogram fer a ews mecta representatives.
- he State of New Hamosn1re and the NHY CR0 agree to tne methodology estaolisnec ey the NHY ERO to oroject offsite radiological consequences.
The NHY ERO agrees to provice any soecial projections tnat are oeyone the routine scope of the radiological assessment effort, as long as tne metnocology used can cover tne request.
M.
The State of New Hamosn1re and the NHY ORO have reviewed and agree to the crocedure established oy the NHY ERO to classify emergency c:nos-tions, nnien includes the Emergency Action Levels.
N.
The NHY ERO agrees to make the radiological analysis services of the Yankee Atomic Environmental Lacoratory availaole to the State of Ne w Hamosnire and the NHY CRO.
The oriority for samole crocessing by t9e Yankee atomic Environmental Lacoratory would oe estaolisnea througn
- oint Healthagreement Cervices atmy the NHY ERO, NHY CR0 anc the NH Division of Puolic the time of an incident.
~heoatr.way tion State of zone)
New Hamosn1re agrees to notify the State of Maine (inges -
for all emergency classifications anc coorcinate the evalation onno anmmm ~- of
- offsite raciolo61 cal con 0GeeGa800 aieR nueneP404mo ""
a Attachment 3 - (page 2 Of N
- -. 1 Atenc:ent 3 4 Page d.of a 8
The State of NH agrees to notify and coordinate tne resoonse actions of the Unitec States Coast Guare for the waterway portions of the plume EPZ.
Q.
The State of NH agrees to notify the Federal Aviation Administration for any necessary air soace restrictions.
R.
The State of necessary NH: agrees restrictions ontorail notify the Boston and Maine Railroac for any travel. -
- 5. The State of NH agrees to recuest assistance availaole tnrough New Englanc state agency cemcacts in resoonse to a recuest ey the NHY CRO.
~.
- he State of NH agrees to arrange for the clearance of NHY ERO ano NHY CR0 emergency resoonse personnel througn EPZ Access Control Points in'NH.
'J . This agreement may ce amenced at the parties. any time oy written agreement oetween-V.
This agreement snall te effective as of tne last cate signed celow.
J STATE OF NEW HAMPSHIRE NHY EMERGENCY RESPONSE CRGANIZATICN O C Sy u 'W 01 rector, Offic'e of Emergency By .M i '
a i Management vice Prdstcent - Gc lear Production bN $0 Sfak/6 Date
~'Oate NHY OFFSITE RESPONSE ORGANIZATION t
By C at
)dd e 7 V, -
By Yo ' / /
Director. Public Healtfi Services JAecutive Director. !
1ergencyPrecarecness/
and Community Relations i
1W 323 E
Attachment C (page 1.'or.2'
- s- .g.
l D. Plannino Basis (continued) days. For the plume exposure pathway, shelter and/or evacuation would likely be the principal inmediate protective actions to be recomended for the general public. When evacuation is chosen as' the preferred
\
protective measure, initial evacuation of. a 360' area -
around the f acility is desirable out to a distance of ,
about two to five miles although initial efforts would, of course, be in the general downwind direction. This concept is indicated in Figure 1. The precise boundaries of such evacuations and sectors evacuated at extended downwind distances would be largely determined by political-boundaries and sould not fit the precise pattern of Figure 1.
The possible administration of the thyroid blocking agent, potassium iodide, should also be considered. The U.-S.
Department of Health and Human Services (DHHS) is preparing guidance on the potassium iodide issue which will be considered by NRC and FEMA. The ability to best reduce potential exposure under the specific conditions during the course of an accident should determine the appropriate response.
- b. Ingestion exposure pathway -- The principal exposure from this pathway would be from ingestion of contaminated water or foods such as milk, fresh vegetables or aquatic foodstuffs.
5/ Potassium Iodide as a Thyroid-Blocking Agent in a Radiation Emergency, U. S. Department of Health, Education and Welf are (now U. S. Department of Health and Human Services), 43 FR 58798 of Decenter 15, 1978.
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% s,s's' C 50,187 NOTE: Numbers are derived from the Seabrook Station Evacuation Time Study and Traffic Management Plan Update, August 12, 1986, KI.D Associates Inc. and from data compiled through the aerial survey of seacoast areas in Massachusetts and New Hampshire conducted July 18, 1987 by Avis Airmap of Braintree, Massachusetts. These figures are subject to update as part of the continuous planning process. ,
o Attachment ?-(page 1 of 3) t o L
[ j?hh t Federal Emergency Management Agency
( ;; ' Washingbn. D.C 20472 '
MEJORNCCM FCR: n C. ibodard -
gg g Natural and Technological Haz=rds Civisir F:&,:
a c. .a rc !. A rim ~
Assistant Associate Director Cf fice of Natural and ecnnolcgica1 Hazards Progra. s s'.?JEC :
Clarification for Alert andof the 15-Minute Notification Desion Cb]ectrie Systens Sis is in resronse to your Maren 18, 1996
. clarification on how to confirn the 15-minute design objective for alert andne
). notification systems outlined in NUP_T,-0654/FE?A-REP-1, 3ev.1, Appendix 3.
late to your hypothetical scenario.I will respond to each of the q;estions ra
- 1. Se 15-minute design objective is considered satisfied if an alen sional can te activated and an instructional message Can be broadcast oVer the Em Broadcast System (E3S) or other systems within the 15 minutes imediately! -
loving the decision by authorized of fsite of ficials to issue protective action
~
reccrr,endations to the puolic via the alert and notification systen. In your hypothetical scenario XX: 25 to X.X:40 is the significant 1 alen and notification system.tne discussions are c:rpleted 3rd neat XX:i followirg XX:25, an alert terefore, within the 15 minutes i.rediately on the air. signal nust te activated and the EBS message must ce Please note that ttens 4 and 5 of your scenario apparently indicate that off-site officials, the systen after until the decision is made, decide to delay tne activation of XX:40.
It is acceptable to establish a future time for acti-vation of the system once a decision is reached to activate it; hcwever, the capability :mst still exist and be confirmed that the alert ard notification the decision point, which in your scenario is XX:25 (e.g. XX:
25 + 15 Minutes =
XX:40 the ti.e at which the EBS is on the air). .
- 2. Padiolcgical Be amountHealth of time available Officials to will or others offsite official:=
vary and te a function for discussions of the with
_-} severity of the energency and the rate at which it is escalating.
De time available for these discussions and the entire decisiomakino process may l rarge frcrn virtually zero time to several hours or nore. Guidance will te i fortheming on hcw axing process. Notenuentnattire is allcwable during exercises for this decision-i virtually zero tire for decisionmaking and be required to activate the j ard notification system irrediately.af 5 ter being notified by onsite officials.
' Attachment F (page 2 Of 3)-
o
- 3. Sre an wr as # 2
- 4. By ckfinitien,- the " Site Area C ergency" classification is far less severe than the "Ceneral Energency" classification. Mcwver, the 15 minutes is
- still significant because it merely penains to the aininistrative and the mechanical capability to activate an alert signal and broadcast an instruo-tional nessage system af ter to warn the the decision is ade to use the alert and notification public.
cisionnakinc, a totally separate . process. mis capability should not to confused wi
- If the' capability exists at the
- ~eneral D.ergency" it surely exists at all other classification levels.
For.tnis reascn the energency action level at which the capability is co-served and confimed is net i.~crtant as long as all cf the steps in the .
secuence can te ocser/ed and ti. :ed. ~he " Site Area Ehergency* ' classifica-tion may not c:ntain a protective action reccmendation; hcwver, there should'still te an ERS broadcast to explain why the sirens have been acti-vated. ~herefcre, there is no reason why the 15 minute sequence could not be observed in its entirety and confirned.at this stage.
q 2ere is no doubt that the 15-ninute sequence wuld be much nore critical
/ at the " General Enen;ency" sta:e tecause f ailing to rapidly issue protective action reccmendations at this stage (e.c.,' within 15 minutes) could result in threats to puolic health and safety by increased and unnecessary radiation exposure.
acceptable Guidance will beti.provided decisiorrnaking e duringinexercises.
upccrning guidance necoranda on gaucirr; In answer to your cuestion, you are correct in startino ities to activate the'systen. the 15 minutes with the decision by offsite author-5, 2e nenoranden frm Ebad L. Jcrdan to Richad W. Krirrn references the reg-ulatory rer;1remnt recu:remnt to alert and notify tne puclic within 30 minutes. 21s censiders a fast-breaxing accident in wnien there is !!:tle or no time availacle for decisiccakirn eitner by onsite or offsite officials before activatirg the alert and notification system. In such a fast-breakinc accident, decisiorr,aking ti.e available ray aoproach zero in which case the onsite officials.are allowed 15 minutes to notify offsite authorities ard offsite authorities are allowed 15 minutes to notify the public of protective action reccrrendations through the alen and notification syste . Therefore, the capability must exist (for the worst case) to ccro;ete the entire sequence within a total of 30 minutes startira with classification of the accident by the licensee.
- 6. De statement in the me,orandum frcrn Jordan to Kri rn is intended to acknculedge that accidents will vary in severity ard that decisiorr,aking ti.e available during an accident will be a function of its severity. Ir. csther wcds, more decisomaking tire will be available in a less severe or sicwly evolvino ac-
.) cident than will be available in a fast-breaking accident. ft: wever, regardless of the anount of decisierrnaking time available, the capability rust exist to complete the alert art notification sequence offsite within 15 minutes of a
" decision" to warn the punlic. 2erefore, decisicrrming ti, e is distinct fran ard should not ce conf used with confirninc the 15-minute design oojective.
.. _a
- f. .
Attachment F~(page 3'of 3L. _
3,
- 3. .
7.
he sirens need to be sounded withi,n 15 minutes at the " Site A
- . stage only if this stage has beeh picked to confim tne 15-m. rea DTr ency" If the " Site' Area Dwrgency" stage activation is chosen to confim the 1 .
minute capability, the entire sequence must te emoleted within the a 15 minutes. Please re e-6er that EmerT;ency" stace, . it certainly exists at the. " Site Area C, H:vever, for purposes of. exercises thrs capability only needs to be de non-strated and clocked at one er the other e ert:ency action levels.
53.Lin' the situation of joint onsite/offsite decisio c
point' fication system. ~at.which the officials reach 'a decision to .
the utility may have responsibility for pnysically .
activattro sten.
!! you. have any questions, please call Bob Wilkerson at 646-2861.
't Info CDFy All Feoicnal ctmi Chiefs
.5!
O i
. a' i
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