ML20236C228
| ML20236C228 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/19/1987 |
| From: | Perrotti D Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20236C217 | List: |
| References | |
| CLI-87-02, CLI-87-03, CLI-87-2, CLI-87-3, OL-1, NUDOCS 8710270065 | |
| Download: ML20236C228 (12) | |
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i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION I
BEFORE THE COMMISSION In the Matter.of
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Docket Nos. 50-443 OL-1 FUBLIC SERVICE COMPANY OF
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50-444 OL-1
. NEW HAMPSHIRE, et al.
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On-site Emergency Planning
-(Seabrook Station, Units 1 and 2)-
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and Safety issues AFFIDAVIT OF DONALD J. PERROTTI-1, Donald J. Perrotti, be.Ing culy sworn, hereby state as follows..
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I am employed as an Emergency Preparedness Specialist, l]
Emergency Preparedness Branch, Divir!on of Radiation Protection and Emergency Preparedness, in the Office of Nuclear Reactor Reg'ulation,
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'l U.S. Nuclear Regulatory Commission.
I have been. Involved in the review and evaluation of the Seabrook Station onsite emergency plan and emergency. preparedness since January 1986,.and. serve as the NRC Staff's principal emergency planning reviewer for the Seabrook Station.
A statement of my professional qualifications has previously been filed in this proceeding as an attachment to my Affidavit of May 1,1987, filed in support of the "NRC Staff's Response to Applicants' ' Suggestion of j
Mootness and Request for Vacation of Stay,'" dated May 1,1987.
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2.
The purpose of this Affidavit is to present a summary evaluation of the "Seabrook Plan for Massachusetts Communities" ("SPMC")
J submitted by the Applicants on September 18, 1987, in light of the threshhold standards established by the Commission in CLI-87-02 (April 9, 1987) and CLI-87-03 (June 11, 1987).
In particular, this 8710270065 871020 PDR ADOCK 05000443 g
Affidavit addresses the questions of (1) whether the SPMC constitutes a
" bona fide utility offsite emergency plan for Massachusetts";
and (2) whether the SPMC " demonstrate (s) en summary review that adequate emergency planning is 'at least in the realm of the pos sible. '"
in connection with the first of these issues, this Affidavit also addresses the questions of whether the SPMC "provides measures to be taken by the utility to compensate for the absence of governmental participation in emergency planning," and whether the SPMC is, " intended for actual implementation as a utility emergency plan, nnd one intended to be subjected to Staff and FFMA review and litigation on that basis"
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(CLl-87-03, slip op. at 5 and 6).
3.
I have performed a summary review of the SPMC, in light of the requirements established in CLI,87-02 and CLl-87-03.
Basdd upon this review, it is my conclusion that (a) the SPMC appears to constitute a i
bona fide utility plan for Massachusetts, (b) the SPMC provides measures to be taken by the utility to compensate for the absence of state and local I
governmental participation in emergency planning within the Commonwealth j
of Massachusetts,
(c) the SPMC appears to be intended for actual l
implementation as a utility emergency plan, and intended to be subjected to Staff and FEMA review and litigation on that basis, and (d) the SPMC
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demonstrates on summary review that adequate emergency nianning for
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Massachusetts portions of the EPZ is "at least in the realm of the possible." The reasons for this conclusion are as follows.
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Results of Summary Review.
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(a) Overview The' SPMC addresses the emergency planning standards of 10 J
CFR Part 50 end the guidance of NUREG-0654.
The SPMC indicates that j
l it.was-developed to be integrated and coordinated with the radiological j
emergency. response plans promulgated by the State of New Hampshire for
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l Seabrook and by_ the Commonwealth of Massachusetts (currently in use for i
l other nuclear power plants located -in or near Massachusetts).
In the I
l event of an emergency, the SPMC provides for full participation by New
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l Hampshire and ' for varying levels of Massachusetts state and local govern-
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mental participation.
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An organization identified as the "New Hampshire Yankee
- Offsite
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l Response Organization" (NHY-ORO) is to provide compensatory personnel,
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resources and ' actions for Massachusetts portions of the Seabrook. EPZ.
1The SPMC describes' the Massachusetts communities located within the plume exposure pathway EPZ: principal highways are lilustrated; special facilities are identified; population data are given; and other relevant aspects of emergency planning are addressed.
(b). Organization The personnel of NHY-ORO and their duties are described, with respect to their primary and support functions to be assumed when so E
authorized by the Governor of Massachusetts.
The SPMC describes the i
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response functions of federal, state, local, and private agencies.
The plan briefly describes the state's emergency response organization; functional interfaces with NHY-ORO are tabulated; and NHY-ORO
. counterparts to key positions within state and local organizations are l
shown.
Key positions in the NHY-ORO are identified, along with a description of the various responsibilities for primary and support
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respon:e functions, i
The SPMC provides a
detailed description of the NHY-ORO structure.
The plan provides for two alternate shifts with a third shift as backup, except for an evacuation function which is assumed to be performed over a relatively short period of time, for which one shift and a 20% backup is provided.
The plan describes the modes of operation for i
NHY-ORO from the standby mode (provide resources only when the state l
actually responds) to Moce 3
(no response by state and local organizations).
The responsibility to determine the mode is assigned to the Director of NHY-ORO, who has been given complete authority by the President and Chief Executive O fficer of New Hampshire Yankee to commit the i
necessary resources identified in the plan and funds (up to an authorized a
s level) needed to mitigate offsite consequences.
The SPMC Identifies offsite support organizations, such as the Red Cross.
Emergency Broadcast Stations (EBS) are described and provisions are made for public service announcements to be made by local radio station (s) in the event that NHY-ORO has not been authorized by the State to utilize the EBS.
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The plan contains letters of. agreement (LOAs). Some of the LOAs are J
missing. information.
_The' Applicants' had ~ stated that it 'did not submit this information.because of a concern that there not be any unwarranted Invasion 'of f the privacy of. those individuals 'and organizations relled upon to implement the plan.
(c) Notification -and Mobilization The SPMC. describes generally the method for alerting, notifying and mobilizing NHY-ORO personnel, _ and also addresses the potential notification of resident and transient mem'bers of the general public.
Key l personnel s are notified.at - the Notification of Unusual-Event (NUE) classification.
All NHY-ORO personnel are notifled at the Alert 3
classification through a notification link on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> - per day _'_ basis.-
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Notification and. ' mobilization steps ' are described for all _ em'ergency j
classification levels from NUE thrcugh General-Emergency.
At the Site Area. Emergency. classification level, the NHY_-ORO will recommend that Massachusetts-notify the public; when authorized by the Commonwealth, l
NHY-ORO will notify the.public through the public alert and' notification system (ANS).
Alternate notification provisions-have been made In the event th6t NHY-ORO does not receive authorization from the Commonwealth i
to notify the public through the established ANS.
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(d) Accident Assessment The SPMC describes various accident assessment capabilities and
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responsibilities; the methods for developing protective action l
t recommendations (PARS); the monitoring and decontamination needs of tho l
general public; and offsite monitoring and laboratory support for analysis
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of' environmental samples. The SPMC provides that NHY-ORO will
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consider recommending precautionary protective actions at the' Alert i
classification.ievel and will recommend protective actions at Site Area Emergency or General Emerge.ncy classification levels.
(e)
Public information and Protective Measures The SPMC describes various protective measures, including public evacuation, and addresses persons necding special assistance, special facilities, beach populations and transients.
The plan Mso describes those facilities and organizations which are to provide assistance.
Two mobile _ units are to be positioned at reception centers for monitoring of evacuecs.
The plan addresses resources, traffic control, re-entry, i
population exposure estimates, and monitoring / decontamination.
The plan incorporates the Environmental Protection Agency's protective action guidelines ( PAGs ).
Medical and pubil'c health support is addressed.
A public information program is described, including maps and information printed in English and French.
Sample posters _,
an Information brochure, leaflets, and other materials are included in the Applicants' SPMC submittal, (f)
Emeroency Response Facilities The plan describes various offsite emergency response facilities, including the Emergency Operations Facility (EOF) which pr.ovides for overall command and control; the State of New Hampshire's incident Field Office (IFO): and NHY's Offsite Response Emergency Operations Center (EOC).
The plan identifies areas within the EOC set aside for representatives of the Commonwealth of Massachusetts and the Federal government, and a Joint Media Center.
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The emergency response facilities are to be activated at an early stage.
The EOC is to be activated upon the declaration of an Alert or higher classification.
Upon arrival at the EOC, the NHY-ORO Director will establish contact with the Seabrook. EOF, the New Hampshire EOC and 4
~lFO, and the Governor of Massachusetts.
The SPMC describes the communication systems and identifies various major items of equipment required to support the operation of the NHY Offsite Response Emergency Operations Center.
i The plan also describes the NHY-ORO staging a.rea; the emergency l
worker facility; monitoring trailers; reception centers; and congregate care centers (to be set.up, administered and controlled by the American i
Red C ross).
The plan addresses - Massachusetts and local emergency facilities, including the Massachusetts EOC, State Police and loc $1 EOC, although the plan indicates that implementation of the SPMC does not rely j
' on the use of these facilities.
I (g) Training and Exercise The SPMC describes the NHY-ORO training program, and provides a matrix for NHY-ORO members showing the specific training which they
- require, in addition, " table-tops" and other drills and exercises are described.
The plan provides that training and information sessions will i
be offered to state and local emergency response personnel and other
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support organizations, including state
- agencies, communication and transportation personnel, reception center and decontamination personnel, and special facilitics and local support staff.
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k W (h) implementing Procedures The SPMC contains procedures intended to implement the plan.
Instructions are provided; responsibilities are assigned; and check lists, precautions and prerequisites are included.
(l)
Supporting Plans The SPMC provides a list of supporting plans, including the Comn.onwealth of Massachusetts Comprehensive Emergency Response Plan, i
the New Hampshire RERP and Procedures, the Federal Radiological Emergency Response Plan, the New England Compact on Radiological Health Protection, and the New England State Police Assistance Compact.
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5.
In a public meeting held on September 16, 1987, the Applicants stated that they have completed their re,cruiting of personnel to serve as
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emergency-response workers in NHYJORO; 1,471 required positions have i
been filled, and an additional 693 persons are available for assignment.
l The positions which have been filled include-664 contracted emergency j
responders (e.g., bus drivers and tow truck drivers).
In addition, the Applicants indicated that all emergency response facliities are located on company-owned property, are under contract, or are covered by a letter of agreement.
The number of such items as radios, dosimeters, J
ambulances, and tow trucks exceed the Applicants' requirements.
Training of NHY-ORO personnel is ongoing at this time; sessions began on September 14, 1987, and training for specific positions is expected to be completed by October 23, 1987.
Drills are scheduled to begin during early November, and the Applicants have Indicated an interest in having a FEMA graded exercise of the SPMC in early 1988.
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6.
On September 18, 1987, the app!! cants submitted the SPMC for NRC and FEMA review.
In addition, on September 21, 1987, the Applicants filed a motion requesting that a schedule be established by the Atomic Safety and Licensing Board for litigation of the plan.
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In sum, based upon the above considerations, it is my conclusion that the SPMC is a bona fide utility plan; that it appears to be intended for actual implementation by the Applicants if necessary; that it provides compensatory measures to be taken by the Applicants to compensate for the absence of governmental participation in an emergency response; that it is intended for review by the NRC and FEMA, and for litigation on that basis, in addition, the SPMC demonstrates that emergency planning for Massachusetts portions of the Seabrook EPZ "is at least in the realm of the possible". '
Abb kk' Donald J.~ Pcrrotti Subscribed and sworn to before me this 19th day of October,1987 n
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Notary Public My commission expires: 07/01/90 4
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DeCEETED USNRC UNITED STATES OF AMERICA
'87 p 21 A9'28 NUCLEAR REGULATORY COMMISSION (C EihG itV l
E BEFORE THE COMMISSION BRANCH j
in the Matter of
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Docket Nos. 50-443 OL-01 PUBLIC SERVICE COMPANY OF
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50-444 OL-01 l
NEW HAMPSHIRE, et g.
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On-site Emergency Planning
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and Safety issues (Seabrook Station, Units 1 and 2)
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CERTIFICATE OF SERVICE' l
I hereby certify that copies of "NRC STAFF'S RESPONSE TO APPLICANTS'
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MOTION FOR VACATION OF STAY" in the above-captioned proceeding have j
been servcd on the following by deposit in the United States mall, first class or, as indicated by an asterisk, by deposit in the Nuclear Regulatory Commission's internal mail system, this 20th day of October 1987.
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Alan S. Rosenthal, Esq., Chairman
- Dr. Emmeth A. Luebke
' Administrative Judge Administrative Judge j
Atomic Safety and Licensing Board 5500 Friendship Boulevard i
U.S. Nuclear Regulatory Commission Apartment 1923N Washington, DC 20555 Chevy Chase, Maryland 20815 Dr. Jerry liarbour*
Ms. Carol Sneider, Esq.
Administrative Judge Assistant Attorney General Atomic Safety and Licensing Board Office of the Attorney General i
U.S. Nuclear Regulatory Commission One Ashburton Place,
19th Floor Washington, DC 20555 Boston, MA 02108 j
Beverly Hollingworth Richard A. Hampe, Esq.
209 Winnacunnet Road New Hampshire Civil Defense Agency l
Hampton, NH 03842 107 Pleasant Street l
Concord, NH 03301 1
1 Sandra Gavutis, Chairman Calvin A.
- Canney, City Manager l
Board of Selectmen City Hall l
RFD 1 Box 1154 126 Daniel Street j
Kensington, NH 03827 Portsmouth, NH 03801 i
Stephen E. Merrlil Paul McEachern, Esq.
j Attorney General Matthew T. Brock, Esq.
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George Dana--Bisbec '
Shaines S McEachern
. Assistant Attorney. General.
25 Maplewood Avenue i
Office' of the Attorney General P.O. Box 360
- 25-Capitol Street -
Portsmouth, NH 03801
' Concord, NH 03301 i
Roberta C. Pevear Angle Machiros,. Chairman State Representative
. Board of Selectmen Town of Hampton Falls 25 High Road-Drinkwater Road Newbury, MA' 09150 Hampton Falls, NH 03844 l
Allen Lampert Mr. Robert J. Harrison -
1 Civli. Defense Director President and Chief Executive Officer I
LTown ~ of Brentwood Public Service Co. of New Hampshire j
20 Franklin Street P.O. Box 330, j
Exeter, NH 03833 Manchester, NH 03105-l 1
Charles P. Graham, Esq.
Robert A. Backus, Esq.
j VcKay, Murphy and Graham Backus, Meyer & Solomon 100 Main Street 116 Lowell Street Amesbury, MA 01913 Manchester, NH 03106~
E' Diane Curran, Esq. -
Philip Ahren, Esq.
- Harmon S Weiss '
Assistant Attorney General 2001 S. Street, NW iOffice of the Attorney Gener'al Suite 430:
State House Station #6' i
Washington, DC 20009 Augusta, ME 04333 Edward A. Thomas Thomas G. Dignan Jr., Esq..
l Federal Emergency Management Agency Ropes S Gray 442 J.W. McCormack (POCH) 225 Franklin Street Boston, MA 02109 Boston, MA 02110 H.J. Flynn, Esq.
William Armstrong Anistant General Counsel Civil Defense Director Federal Emergency Management Agency Town of Exeter 500 C Street, SW 10 Front Street
. Washington, DC 20472 Exeter, NH 03833 Atomic Safety and Licensing
. Atomic Safety and Licensing Appeal Panel
- Boa rd*
U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission i
Washington, DC 20555 Washington, DC 20555 Jane Doughty Docketing and Service Section*
Seacoast Anti-Pollution League Office of the Secretary 5 Market Street U.S.
Nuclear Regulatory Commission Portsmouth, NH 03801 Washington, DC 20555 Maynard L. Young, Chairman William S. Lord L
' Board of Selectmen Doard of Selectmen i
- 3.-
10' Central Road.
Town Hall - Friend Street
- South Hampton, NH 03287 Amesbury, MA 01913 Michael Santosuosso, Chairman Peter J. Matta ws, Mayor Board of Selectmen City Hall South Hampton, NH 03287 Newburyport, MN 09150 j
' Mr. Robert Carrigg, Chairman Judith H. Mizner, Esq.
Board of Selectmen Silverglate, Gertner, Baker Town Office Fine and Good Atlantic Avenue 88 Broad Street North Hampton, NH 03862 Boston, MA 02110 R. K. Gad lil, Esq.
Mrs. Anne E. Goodman, Chairman Ropes & Gray Board of Selectmen 225 Franklin Street 13-15 Newmarket Road Boston, MN 02110 Durham, NH 03824 Gary.a. Holmes, Esq.
Holmes & Ellis 47 Winnacunnet Road I
Hampton, NH 03842 Edwin J. Re s' Deputy A stant General Counsel e
p.