ML20238E342
| ML20238E342 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 12/22/1987 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20238D492 | List: |
| References | |
| NUDOCS 8801050106 | |
| Download: ML20238E342 (42) | |
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1\i UNHED STATES NUCLEAR REGULATORY COMMISSION
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In the Matter of: ) DOCKET NO: 50-443
)
SEABROOK MANAGEMENT MEETING )
- REGARDING UTILITY EMERGENCY )
PLANS )
LOCATION: Bethesda, Maryland PAGES: 1 through 40 DATE: December 22, 1987
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Heritage Reporting Corporation l OfReial Reporters 1220 L si m t. N.w.
Wunungten. D.C. 20005 (2021 628 4848 8801050106 871223 PDR ADOCK 05000443 ,
T PDR
1 1 UNITED STATES NUCLEAR REGULATORY COMMISSION 2
l 3
SEABROOK MANAGEMENT MEETING )
4 REGARDING UTILITY EMERGENCY ) Docket No. 50-443 l PLANS )
5 6
7 Tuesday, December 22, 1987 8
Phillips Building, Room P118 9 7920 Norfolk Avenue Bethesda, Maryland 10 The meeting convened, pursuant to notice, at 1:41 11 p.m.
12 BEFORE: VICTOR NERSE Project Manager 13 Project Directorate I-3 Division of Reactor Projects I/II
. 14 15 16 17 18 19 20 21 22
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24 25 Heritage Reporting Corporation (202) 628-4888
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1 PROCEEDI NGS 2 MR. NERSES: Good afternoon. I am Vic Nerses and I' 3 am the Seabrook Project Manager. This is a meeting between NRC 4 and the licensee to discuss the Seabrook Emergency' Plan for'the -
5 Massachusetts Portion of the EPZ.
6 We have issued a meeting notice and an agenda. The 7 items are there to be discussed. And I want to just say a few 8 things.
9 This meeting is being transcribed, and if you please 10 can remember that when you speak, you will identify yourselves 11 so that the recorder can get the proper name for the q 12 information that is being presented.
13 I also have an attendance sheet that is, going around i i 14 and I would appreciate it if.you will all sign that. And 15 before we go on further, I guess it would be nice if everybody i
16 introduces themselves, and then we'can get.on with the' meeting. l 17 I don't think you need to transcribe that, if.you 18 don't want to, Andy, but it will.give you an opportunity.
19 Frank, why don't you begin?
20 MR. CONGEL: I am Frank Congel, Director of Division I
21 of Radiation Protection and-Emergency Preparedness.
22 MR. NERSES: And I am Vic Nerses, Seabrook Project 23 Manager.
24 MR. STELLO: And I am Vic.Stello, EDO.
25 MR. REESE: Ed Reis, Office.of General Counsel, NRC.
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O w-3 1 MR. MURLEY: Tom Murley, Director of NRR.
2 MR. MIRAGLIA: Frank Miraglia, NRR.
3 MR. MATTHEWS: Dave Matthews, Chief of the Emergency' 4 Preparedness Branch, NRR.
5 MR. KRIMM: Dick Krimm, Fill Emergency Management 6 Agency, System Associate Director for the Office of National 7 Technological Hazards. ,
8 MS. HGCK: Joan Hock, Technological Hazards Division, 9 THEMA.
10 MR. WINGO: Craig Wingo, Chief of Field Operations, 11 THEMA.
12 MR. CUMMING: Bill Cumming, Office of General 13 Counsel, THEMA.
14 MR. SANDERS: Marshall Sanders, Head of the Program 15 Development Branch, Technological Hazards Division of THEMA.
16 MR.'SWEENEY: Rob Sweeney, New Hampshire Yenkee 17 Licensing Rep.
18 MR. THOMAS: George Thomas, Vice President, Nuclear 19 Production for New Hampshire Yankee.
20 MR. GRAM: George Gram, Executive Director of 21 Emergency Preparedness for New Hampshire Yankee. I 22 MR. FEIGENBAUM: Ted Feigenbaum, Vice President, 23 Engineering and. Quality Programs.
j 24 MR. EICHORN: John Eichorn, Chairman and Chief 25 Executive Officer, Eastern Utility Associates.
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4 1 MR. BROWN: Ed Brown, President, New Hampshire 2 Yankee.
3 MR. EDWARDS: I'm George Edwards, Chairman and Chief 4 Executive Officer of United Illuminating.
5 MR. DERRICKSON: Bill Derrickson, Senior Vice 1
6 President, New Hampshire Yankee.
7 MR. DALY: Bill Daly, Licensing Manager, New 8 Hampshire Yankee.
9' MR. DAGEN[ph]: Tom Dagen, Rose and Gray, counsel for 10 the applicants.
11 MR. STRONG: Dick Strong, Director, New Hampshire 12 Office of Emergency Management.
13 MR. CANNON: Paul Cannon, Emergency Preparedness i 14 Branch, NRC.
15 MR. KERN [ph]: Sherman Kern, Office of General 16 Counsel, NRC.
17 MR. LAZARUS: Bill Lazarus, Emergency Preparedness 18 Section Chief, NRC Region 1.
19 MR. FLYNN: Joe Flynn, FEMA Office of General 20 Counsel.
21 MR. BARKER: Steve Barker, NRR.
22 MR. NERSES: Tom wants to say something, to start.
23 Tom Murley has some opening comments. Perhaps you 24 folks would like to have an opportunity to make some opening 25 comments also.
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5 1 MR. MURLEY: Mine were aimed at spec fically some of 4 2 the items on the agenda of the meeting. Why don't I.briefly 3 mention those, and then I understand you might have some i 4 opening, too.
5 The utility plan for Massachusetts was transmitted to 6 FEMA on November 27th. The NRC and FEMA are going to review 7 that plan using the new criteria for reviewing utility plans .
8 that have been published.
9 With regard to a schedule for the exercise, we are 10 not today prepared to define exactly what that schedule is, 11 because NRC and FEMA need time for initial review to find'out, 12 or to come to some judgment as to whether there are potentially 13 major problems with the plant.
I 14 Nonetheless, we expect we can revisit this schedule 15 question within a couple montha, with you, that is. .Meanwhile, 16 we see no reason why the licensee could not and should not go 17 ahead with your training and planning for the scenario 18 preparation.
19 Those are my comments.
20 MR. NERSES: Okay. John Eichorn has some.
21 MR. EICHORN: As I said earlier, my name is John 1 22 Eichorn. I am Chairman and Chief Executive Officer of Eastern 23 Utility Associates.
24 I also have the honor of serving as Chairman of the 25 Joint Owners of the Seabrook Nuclear Project.
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With us also for the record is George Edwards, 2 Chairman and Chief Executive Officer of United Illuminating 3 Company, who serves as vice Chairman of the Joint Owners 4 Executive Committee.
5 Bob Harrison of Public Service of New Hampshire, 6 President and Chief Executive Officer, was planning to be hetu, 7 but a last minute demand of his time and financial situation 8 caused him to have to change his plans and be in New York.
9 Other than that, he would have been here.
10 I think it would be helpful if I went over just )
i 11 briefly, quickly, some of the major events which have 12 transpired since our last meeting September 16. Of course, as 13 we met on that day, we did tell you and obviously they were l
- 14 submitted, we submitted the New Hampshire Yankee Plan, Utility 15 Plan for Massachusetts a few days afterwards. I believe it was 1 i
16 the 21st.
17 Early in October, of course, the NRC issued a new 18 rule concerning utility plans and how they might be reviewed 19 when they are submitted in place of the state's plan.
20 Also during October, New Hampshire Yankee received a 21 favorable SALP report, to refresh your memory, in the ten 22 categories reviewed. We had seven categories which were ones 23 and three categories which were twos. And those will be worked 24 on to try to get them improved.
25 November 25th, the NRC did lift the stay, and the Heritage Reporting Corporation (202) 628-4888
7 1 Commission lifted the stay ~on the five percent license.
2 Also in November we had published in the Federal 1 3 Register the criteria that will be used, or proposed to be 4 used, in reviewing a_ utility plan submitted in place of a state 5 plan.
6 And I think all of us are aware that during this Fall 7 period we have also had the New Hampshire Yankee,' or New
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8 Hampshire hearings on the ASLB concerning the New Hampshire 9 Emergency Response Plan. These hearings are in recess'for the J l
10 holidays, but should be concluded early in January.
11 I guess perhaps the major thing that has happened and 1
12 transpired since our last meeting though is the publicity and '
13 the actual financial condition of the lead owner, Public l ; 14 Service of New Hampshire.
1 15 I think it might be appropriate for me to say a few i 16 words about that situation for your benefit.
17 There is no question that it is a serious situation, 18 but there is also no question that we believe that there will 19 be an accommodation worked out with their major creditors for a 20 restructuring of the company which will permit them to go ;
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21 forward in a very orderly manner. 1 i
22 As to whether or not it will encompass a Chapter 11 l 23 proceeding is yet to be determined.
24 But let me try to make a synopsis of what we think ,
25 will happen. We believe that there will be a meeting of the l1 Heritage Reporting Corporation (202) 628-4888 1
8 1 minds between public service management and its debtors which 2 will cause some sort of restructuring and will cause a writeoff 3 of certain of the investments that they have made in Seabrook 4 already, which is an accommodation that they don't wish to make 5 until they understand how they are going to be treated for 6 rate-making purposes. But nevertheless, I am sure it will be 7 made.
8 More important that that, though, is probably, in 9
order to make sure that such an accommodation that is arrived 10 at probably with the majority of debtors but not all, in order 11 to make sure that that is to be put in place, they will have to 12 go through some sort of court action, probably under a Chapter 13 11 proceeding.
14 But I think it is important, that even as late as 15 yesterday, when Bob Harrison called me to tell me that he 16 couldn't attend today's meeting, that he reiterated that 17 everyone of their plans that they had proposed or that the 18 debtors have proposed in the reorganization do accommodate the 19 necessary funds for going forward with Seabrook, because they 20 know that they need it and we know that New England needs it.
21 And those are the important messages I would like to get across 22 to you.
23 So we'll be glad to try to answer any questions about 24 this, but I think that is a good summation of it.
25 As for the rest of the participants, we all believe Heritage Reporting Corporation (202) 628-4888
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' 9 1 that we are in relatively good shape for continuing with the 2 project, although it is beginning to get strained.
I 3 With that I think it perhaps best that we go on_with '
4 your formal agenda.
5 MR. NERSES: Bill, you had this' introduction. Did 6 you want to touch upon anything on.the plant itself? It is 7 submitted now and the only thing I know.of that has to be-taken 8 care of are a few things, some revisions that are simple and so 9 on that don't look like any major activity going on regarding 10 the plant. Is that a correct assessment of the situation?
11 MR. GRAM: Yes.
12 MR. NERSES: Other than that, what else is there to 13 say but to point out that we are going to begin the review and
, 14 we have a comment to say about the fact that the review will 15 probably take some months to do.
16 MR. MURLEY: Some months. Right.
1 17 MR. CONGEL: Frank Congel. We have FEMA here with us 1 18 today to discuss at least a tentative outline we have for a j 19 review schedule.
20 At this point we are prepared to answer questions 21 that you may have of us in terms of both the review schedule j 4
22 and the possible plans that you have for the exercise this 23 coming Spring. ;
24 MR. DERRICKSON: Can I just take a moment to go back-25 down memory lane?
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- 10 1 We met a couple of months ago, then previously had 2 met in July. And our main reason for being here today is to 3 try to come to some level of understanding with respect to the 4 schedule for reasons George Gramm and Ted Feigenbaum can 5 address in any detail you want, but there are numbers of things 6 that we have to do and obviously numbers that you have to do in 7 preparing for and conducting an exercise, and it really all 8 boils down to the schedule, which is why we're here, is the 9' bottom line.
10 MR. NERSES: Dick, can you make whatever comments you 11 can make about the schedule for FEMA's review?
12 MR. KRIMM: Certainly. I will be very happy to. I do 13 want to assure you that we are going to process this as
( 14 expeditiously as possible and I think you will find that we 15 work very closely and in a very cooperative manner with the 16 Nuclear Regulatory Commission.
17 We believe it is in the best interests of everyoody 18 to follow as closely as possible our normal procedure which is 19 to do the review under the new utility plan criteria with the 20 involvement of the Regional Assistance Committee or the other 21 Federal agencies and working very closely with them, with l
22 backup support from our contractor who are the Argon National 23 Laboratories. I think you are all probably familiar with them.
24 FEMA currently projects that under a fairly j 25 optimistic schedule, the FEMA review for the Seabrook plan for Heritage Reporting Corporation (202) 628-4888
V 11 1 Massachusetts communities would take about four months. It.
2 should be remembered that this is a ten volume plan and a 3 thorough review which can support litigation must be performed, 4 with due considerations about complexities involved at the 5 site.
6 It'should also be remembered that this is the first 7 plan to be reviewed against the new utility plan criteria. And 8 not only have the Region I RAC members-never reviewed a utility 9 plan, but they are unfamiliar with the criteria.
10 Realistically, additional time.must be given for j l
11 their application standards similar to but different from the 12 0654.
13 Our review Fchedule is as follows. We really would i 14 start --
I just received your letter which I have not had an 15 opportunity to look at, to the NRC regarding the fact that 16 there is consistency between the plan that has been submitted 17 and the utility plan criteria, and secondly, there is the 18 question vf a redactive issue which needs to be settled.
19 The primary review by members of the FEMA Region I 20 Assistance Committee and the selected staff of the Argon 21 National Laboratories, a FEMA contractor, we estimate will take
- 22 about two months.
23 The second step is that the RAC meeting where all 24 the reviews and all the elements are presented and discussed, i
25 will take about one week.
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- 12 1 Consolidation of all the reviews by Argon into a 2 unified written document would take about two weeks. And 3 basically, what they will have to look at is everything that 4 has been submitted by the various Federal agencies that are 5 part of the Regional Assistance Committee and make sure that 6 there is uniformity. !
7 Then the review of this consensus document for 8 accuracy of interpretation on position will take probably one 9 more week at the regional level and then it will come into 10 headquarters where we will review it, coordinate, verify 11 everything against Agency policy and that will probably take 12 roughly about three weeks because there is a lot of work that 13 has to be done in headquarters.
14 We feel that this is the best procedure to follow 15 because ultimately you have to have a RAC review and if you get 16 the RAC in in the beginning with all the Federal Agencies you 17 are just much better off. )
18 Also the RAC has already reviewed the New Hampshire 19 Plan and it is the same RAC and there should be consistency as ,
i 20 much as possible between the New Hampshire Plan and the Utility I l
21 Plan for the Commonwealth of Massachusetts. !
l 22 I think every site in the United States where we have 23 done the off-site preparedness, which is all the licensed 24 sites, we have had the RAC review, Regional Assistance 25 Committee review. So I think that consistency is very, very Heritage Reporting Corporation (202) 628-4888
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. 13 1 important to continue.
2 I would have to say that based on my experience at 3 Shoreham, we feel that taking a little more time in the 4 beginning will pay off in the long run if we get into 5 litigation.
6 So those are basically the reasons why we have set 7 out the schedule in the manner that we have and we think again, 8 if we can cut down this time, we will, but I didn't want to 9 mislead you because based on our experience, problems occur, 10 things come up during the review process that have to be 11 settled.
12 MR. EICHORN: Mr. Krimm, I don't think I understood 13 when you said you were going to start. You commenced on it and 14 you got sidetracked on something else.
15 MR. KRIMM: We expect to start, we have the letter l
16 that you sent to, which I have not reviewed yet but I think is 17 okay, on the question of your criteria, of your plans that have 18 been submitted coriforming somewhat to the criteria that has ben 1
19 developed under the utility plan crit'eria.
20 You basically had developed the plans before the 21 criteria were submitted.
22 And then the second issue is a legal issue which is 23 the case of the redaction, and Bill Cumming, from our Office of 24 General Counsel, I would just ask to explain that.
25 MR. CUMMING: Well, basically, we have provided a Heritage Reporting Corporation (202) 628-4888
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- 14 1 memo back to NRC.which ycu all are welcome to have copies of.
2 In fact, I think we served it on the Seabrook service list, but 3 basically, we have had discussions with the emergency planning 4.,
element of NRC and we believe we can work out a combination on 5 thdt.
6 And the FEMA position was fairly clear. We basically 7 felt that we needed to have as much substantive information as 8 we could in reviewing the plan. We were certainly willing to 9 allow the home address and individual names, particularly in 10 lower level positions < to be redacted, and we were willing to
'4 11 accommodate any protective orders or decisions by the Nuclear 12 Regulatory Commission which under their standards would be 13 authorized to protect the information.
I 14 So we are concerned, because of our experience in 15 other sites, that there not be a situation where there is some .
16 sort of retaliatory conduct by people who would not be 17 interested in enhancing emergency planning. l 18 (Continued on next page.)
19 20 21 22 23
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. 15 T. ; 1 MR. EICHORN: I don't think I've got an indication of when you 2 are going to start.
l 3 You need to get the information on the redactive 4 issue. We have a certification letter and the redactive 5 information is, Bill, is what I guess you are asking about.
6 MR. CUMMING: Well, we understood that a request had 1
7 been made to you by the Nuclear Regulatory Commission, perhaps 8 that is not accurate?
9 MR. REIS: No, that is correct.
10 MR. KRIMM: So as soon as we can get that in, while t
11 we will begin which optimistically should be right after New i 12 Year's. I mean I am assuming that you will get that 13 information right away, I guess, if you are working on it so 14 that we could start talking about those.
15 MR. GRAM: Did we get a regrest from the Commission 16 on what they need?
17 MR. FEIGENBAUM: We have a list of what they need.
18 And there is no problem providing that information. I l
l 19 So it is available as soon as you need it.
20 MR. KRIMM: Okay, if you can get that in to us 21 immediately the ideal thing would be to begin the week of 22 January 4th.
23 MR. FEIGENBAUM: The only question that.has to be l i
24 addressed is whether you want copies of this information or !
25 whether you want access to it, at a facility to be determined?
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16 1 And thet we can discuss and;as soon as that is 2 workr.d out, I can gat the inform tion.
3 MR. CUMMING: The . logistics are t hat we would like to
- have copies of the information.th' rough and a part to NRC, to l
5 us, at, FEMA. s 6 MR. MATTHEWS And I will frterject here, that the a
j 7 information, I am sorry, Dave Matthews, the information 8 submittai details have yet to be resolved between our ,
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9' respective staffs, of hhw Hampshire Yankee and the NRC, and l 10 tnat process is ongoing at'the moment. "
11 MR. BROWN: Can I ask what -- Jhin is Ed Brown --
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12 what does that mean the information ef'the submittals?
13 MR. MATTHEWS: The mechanism ty which you would 1
, 14 submit the additional information that was originally removed
[ . 15 from the plans and has it been identified yet, in terms of the j
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l 16 amount of.protreition that can be~-afforded it. !
17 Ard so , at this point in time, un!.ess New Hampshire 18 Yankee is willing to make a submittal on the open docket of i 15 that information, it is -- the mechanism by which you will 20 . submit it hat vt been arrived at.
21
- loa * *eremple- if'you veres hw" desire it to continue,to 22 be prctecten, you may have tyi go tc) the Hearing Board and ycu 23 know,Tove to nave a protective order developed for that 24 purpose, 25 MR. FEIGENBAUM: This is Ted Feigenbaum. I would Heritage Reportinq -Corporation ,
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' 17 1 suggest that your attorneys and our attorney discuss this right 2 after this meeting and I am sure we can come to an 3 accommodation today.
4 MR. BROWN: This is Ed Brown again, and I would just 5 ask for the record, because I.just don't understand, why the 6' start of a review is dependent upon the actual transmittal of 7 this redacted information because that is not necessarily the 8 essence of the plan.
9 MR. KRIMM: I will ask' Bill to comment. Dick Krimm 10 and I am going to --
11 MR. CUMMING: There was a second issue and I am not 12 certain whether the-letter which I have not seen was, in fact, 13 the response to what we requested, but we did want a very clear 14 statement from the Applicants that they wished to; proceed with 15 . Plan Review, under the new, as we refer to it, UPEC, Utility 16 Plan Evaluation Criteria. ,
1 17 We felt'that that that was a judgment that the 18 utility had to make and that we did not want to make for them.
19 So I assume that that is satisfactory so that was certainly one 20 issue which apparently has been resolved, or that we would hope 21 will get resolved.
22 And hopefully we can work out the redaction issue l
23 after this meeting. ;
24 MR. GRAM: This is George Gram, and your statement is 25 correct, I believe that all.you are. concerned with are t
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a 18 1 addressed in the memo dated the 18th of December.
2 MR. KRIMM: Thank you.
3 MR. BROWN: I am sorry, we would, I was trying to 4 figure out what it was that you were saying. This is Ed Brown 5 again.
6 Would you please repeat that so that I can understand 7 what you are saying because I did not really understand it.
8 MR. CUMMING: FEMA had raised two concerns, legal 9 concerns on nur transmittal back to the Nuclear Regulatory 10 Commission.
11 The first concern was that there was a clear 12 statement on file with the Nuclear Regulatory Commission that 13 the Applicants wished to proceed to have their plans reviewed, 14 under the UPEC, Utility Plan Evaluation Criteria.
15 Apparently such a letter has been received virtually 16 at this meeting, and we assume that will satisfy our request on 17 that standpoint.
18 The second legal issue dealt with the redaction and 19 as I have previously stated, we believe that we can accommodate 20 that. We are willing to meet with you all after the meeting, 21 and the NRC has apparently some concerns that we were not aware 22 of and I am sure that they can be worked out.
23 But FEMA is certainly willing to do what it can to 24 enhance the review process and avoid the situation where 25 information somehow is a cause for retaliatory conduct against Heritage Reporting Corporation (202) 628-4888
4 19 1 response organizations.
2 MR. STELLO: I am not sure I follow all of what is 3 going on. This sounds like an esoteric detail beyond what we 4 should be, even attempting to resolve at this meeting.
5 If you want to provide a plan and the names are 6 withheld, we either can or we cannot do it, and there is or is
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/ not a procedure to do it. And why don't you get us the names 8 with some understanding that we will do what we can to protect 9 them and if they are protected they are and if they aren't, 10 they aren't, and then get on with it.
11 I don't know why we cannot doathat quickly?
12 MR. REIS: One of the things is after the Commission 13 came down with its order, saying the stay might be lifted, they 14 indicated that something had to be cleared up with the redacted 15 names.
16 We certainly felt that you would go back to the Board 17 at that point and seek a protective order to protect those 18 names.
19 We have been waiting for th'at procedure to go 20 forward.
21 MR. FEIGENBAUM: That was what the Commission 22 indicate in their order was a condition for the 5 percent power 23 license and to support the FEMA review.
24 We are prepared to provide that information 25 tomorrow, if necessary to get off the dime here and get going.
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- 20 1 MR. STELLO: Well, let me see if I can get squared 2 away, can we get the information from them with the 3 understanding that whatever the legal processes we need to 4 follow, will be followed and we will be bound by.that answer 5 whatever it is, and we can get on with it?
6 So that this is not an issue.
7 MR. EICHORN Yes, that is right.
8 MR. STELLO: Can we do that?
9 (A chorus of yeas.)
10 MR. STELLO: Then let it be so and move on.
11 MR. TURK: Let me urge one thought and this is 12 Sherwin Turk. The utility until now has asserted that the ;
13 information which has been deleted from the plan has been i 14 deleted because they seek to protect it.
15 At the time that that information is submitted to us, 16 we cannot guarantee that it will be protected any further, so 17 that is a choice that they have to make or the' utility has to 18 make as to whether they submit-the information --
19 MR. STELLO: But we can accept it on the basis that 20 we would be bound by whatever legal decision is made. If it _
i 21 can be protected, we will and if it cannot, it is released, 22 they understand that.
23 That is what I just said. They will give it to us 24 with the understanding that whatever the legal cnswer that 25 comes out of the system, we either can protect it or we cannot.
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21 1 And if we cannot, so be it, and if we can, so be it, 2 but when they give it, they give it with that understanding.
3 MR. TURK: And I would say with the further 4 understanding that we are not making any commitment that we 5 would even agree that it should be protected.
6 We may not --
7 MR. STELLO: It may not be legally possible for us to 8 do it, I don't know. If it is not, they understand that and 9 they accept it on that basis. That is the point I thought I 10 was making, is it clear now?
11 MR. BROWN: Yes.
12 MR. FEIGENBAUM: I think to get the process rolling.
13 MR. BROWN: Let us talk for a minute.
I 14 (Pause.)
15 (Off the record.)
16 (Back on the record.)
17 MR. STELLO: Well, let's say something, let's put the 18 ball in their court.
19 We are not going to get it resolved outside of this 20 meeting, this is the place to do it. You got the ball, do it, 21 tell us what you are going to do.
22 MR. TURK: Let me make one comment, if I can, two 23 gentlemen walked in during the meeting and they didn't identify 24 themselves because they came in late. These are Frank 25 Ostrander and John Traficonte from the Massachusetts Attorney Heritage Reporting Corporation (202) 628-4888
4 22 1 General's office.
2 And Mr. Traficonte has indicated to me that if the 3 NRC gets information the Massachusetts AG's office, the 4 Attorney General's office wants it as well.
5 And you should bear that in mind.
6 MR. KRIMM: I think -- this is Dick Krimm from FEMA 7 and the other thing is too, is that once this information does 8 go to the Regional Assistance Committee, which it has to go at 9~ some point, you know, it is difficult to keep it.
10 MR. FEIGENBAUM: Mr. Krimm, this is Ted Feigenbaum, 11 and you indicated, yourself, that this plan consisted of 10 12 volumes of information?
13 MR. KRIMM: Yes.
14 MR. FEIGENBAUM: And the kind of information you are 15 looking for is a minuscule portion of the total submittal. What 16 I am trying to understand is why the review has not proceeded 17 from the day it was submitted, without this information?
18 MR. CUMMING: I thought I explained that to you. We 19 believe it is a very important judgment for the Applicants to 20 make that they proceed under the newly developed criteria. And 21 to be honest, as our counsel and FEMA we are not willing to 22 have FEMA make that judgment for you.
23 MR. BROWN: Well, this is Ed Brown and I thought that j 24 we had responded to that issue and said that we would agree, is 25 that correct?
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1 MR. STELLO: That issue is behind us.
2 MR. NERSES: Yes. )
3 Hold on, please, this is Vic Nerses and first of all i
4 I want to say that I think and I don't see any reason l
5 why -- you have got the letter in and that starts the ball. .{
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I 6 Now, the question of just when to get started?
7 I think that Mr. Eichorn was interested in the date 8 that you would start on the plan. I think the other information 9 which has to do with the redacted information, can be worked'
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10 out.
11 Certainly that portion of the plan does not have.to 12 go into the review at this point in time. j 13 Mr. Krimm, would that be unreasonable?
14 MR. KRIMM: Okay, I am going to let my general 15 counsel answer the question.
16 MR. NERSES: Bill?
17 I mean is there any reason for us not to be able to l 18 say, that portion of the plan that has the redacted 19 information, has, in fact, yet to be dealt with as far as'the 20 review is concerned and we can get started with the rest of the i
21 package?
22 Or, are you saying that you cannot do that until such 23 time as that information has been worked out? l 24 MR. CUMMING: I thought that our position was clear 25 in our transmittal to you but basically we said that it.could
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l 1 proceed as long as we had all the information but individual 2 names and home addressee.
3 MR. NERSES: Fine. Knowing that, then there is no 4 reason to believe then that we can get on with reviewing the 5 plan.
6 The question now Mr. Eichorn has been asking, I think 7 is can we specify a date at which time that plan would, the 8 review would begin?
I 9- MR. EICHORN: I thought that I heard Mr. Krimm say '
10 January 4th.
11 MR. KRIMM: Yes.
i 12 MR. EICHORN: Fine, 13 MR. NERSES: Okay, are we all set? f I
14 MR. EICHORN: Fine, yes.
15 MR. NERSES: I just wanted us to get back on track ;
16 and not get caught up on that. I don't need the whole room to 17 resolve that issue, okay?
l 18 MR. FEIGENBAUM: Can we just talk briefly in light of 19 the fact that the plant has been built and ready to operate now 20 for 18 months. '
21 Is there some way that we can work expeditiously or 22 maybe creatively to minimize the length of time for the review, 23 FEMA's review?
1 1 24 Obviously, we need to have your review before we 25 exercise the plan and we need to have your review before we can Heritage Reporting Corporation (202) 628-4888
i l
25 1 litigate the plan in hearings which I am sure will occur.
2 Can we talk a bit about methods to work maybe more 3 efficiently to get this review done before the four months?
4 MR. KRIMM: Richard Krimm.
5 We have gone over this, I have to tell you, very 6 carefully and we tried to give it very honest approach, which 7 maybe a little bit on the optimistic side, a goal is to cut 8 this time as much as possible.
9 But we don't want to mislead you about problems --
10 this is based on our experience in the past -- that do occur in 1
11 this. '
12 I have talked to the other federal agencies who are a i
13 part of the Federal Radiological Preparedness Coordinating ]
14 Committee, which are federal agencies which are also involved 15 in the Regional Assistance Committee and to get their l 16 cooperation in the review of this plan. i 17 But we are going to do it as rapidly and as 18 efficiently as we possibly can. It is not something that we 19 are just going to have sitting on our desks.
20 MR. STELLO: Let me suggest that thoroughness is far ,
i 21 more important than speed. If something gets fouled up in the j 22 review process and then you are in the process of litigation 23 and we have to go back to the square one again. That is going 24 to take much, much longer.
25 It is most important that a thorough job be done and Heritage Reporting Corporation (202) 628-4888
26 1 I think I heard Dick make that point at the beginning and I 2 just want to make sure that we don't try to tal.e shortcuts 3 especially on a case like this.
4 What he is giving you is well within the reason of 5 our experience with others and this is complicated. I don't 6 think you want to try to find ways to invent how to cut out 7 doing the. review.
8 I think the thoroughness of the review will' serve us 9 all best in the long run.
10 MR. BROWN: This is Ed Brown and we agree with that, 11 but the only problem were have, of cource, is that, you know, 12 thoroughness does not have to be translated into time always.
13 MR. STELLO: I agree with you.
14 We want it efficient, we want it effective, we want 15 it as quickly as possible. But quality has not been said and I i
16 that is why I said it. Quality first.
17 MR. BROWN: Yes, and we agree with that.
l 18 MR. STELLO: It is just with that to the extent that l
19 we can improve on the schedule, every effort will be made to do 20 so, I assure you. 4 1
21 MR. BROWN: Is it possible to leave that question 22 open on what the length of time is, because I think that if we l 23 leave this meeting today with the. understanding that it is four <
24 months, it is going to be at least four months. I am not sure, !
25 but we will see that improve.
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1 MR. KRIMM: Mr. Brown, this is Dick Krimm again, and 2 we feel four months is a realistic and somewhat even optimistic 3 schedule, but it is a position our agency, to work on this, and- j 4 to get the cooperation of the other federal agencies, as 5 expeditiously and as efficiently as possible and we will try to 6 make it less than four months.
7 But I cannot guarantee that based on previous 8 experience.
9 MR. STELLO: We will do our best.
10 Then I guess the rest of the schedule that goes form 11 then on is pretty much dictated by the exercise and the hearing 12 process and with all of their both predictability and i
13 unpredictability.
14 I think it would be probably.not a useful expenditure 15 of our time here today to try to lay the rest of that out?
I 16 Do you agree? H 17 MR. BROWN: I agree.
18 MR. STELLO: Okay. j 1
19 I think that people that ha've watched this process 20 can sit down and go from there. We have put the bounds on it, 21 the best and the worst. ,
)
22 MR. FEIGENBAUM: Dick, Ted Feigenbaum.
23 I would like to suggest since the schedule is very l
24 important to us and that we want to assure ourselves, or at 25 least plan for when the information will be coming back from 4
l Heritage Reporting Corporation (202) 628-4888 !
- 28 1 FEMA and the NRC.
2 Could we have a smaller, lower level of staff meeting 3 to status how the review is going periodically?
4 MR. STELLO: Arrange it with Vic.
5 MR. FEIGENBAUM: Perhaps once a month until the 6 review is complete. j g
7 MR. NERSES: We can talk about that and I am sure we l 8 can work something out.
9 MR. BROWN: One last question relative to the 10 Massachusetts Emergency Plan, it has been transmitted to FEMA, 11 and the question is, is that a formal or an informal I i
12 transmittal that has taken place?
i 13 MR. NERSES: Formal. !
I 14 MR. KRIMM: Formal.
15 MR. STELLO: Formal. ,
i 16 MR. BROWN: Okay. I 17 MR. NERSES: Any other questions?
l 18 (No response.)
19 MR. NERSES: Any comments?
20 MR. STELLO: George --
21 MR. MURLEY: I just want to reiterate that I 22 indicated in my opening remarks that we do plan to get together 23 after we have done this initial review in a month or two, or a 24 couple of months let's say, to relook at the schedule for the 25 exercise so that we can contemplate that.
Heritage Reporting Corporation (202) 628-4888
29 1 We expect that there would be Staff discussions as 2 we go along on this.
3 MR. STELLO: Yes, and I would hope that any time that 4 we find a problem that we will let you know as soon as we know.
5 Where are we on the agenda?
6 MR. NERSES: I think that that completes the agenda.
7 MR. STELLO: No, no.
8 Training -- status --
9 MR. BROWN: Item Number 3, the question with the 10 schedule is that the development of a criteria to review the 11 E-Plan, in other words, what, is there a target date for the 12 review of the E-Plan exercises?
13 For the development of the criteria for the review of 14 the exercise?
15 (Continued on the next page.)
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1 MR, STELLO: I do not know that I understand the 2 question. We published in the Federal Register the criteria 3 that is going to be used for the evaluation of'the plant.
4 MR. BROWN: Of the plant.
5 MR. STELLO: And that is of the written and the 6 exercise. That'is the way that we are going to evaluate it. .
7 MR. BROWN: Thank you. That was a misunderstanding l 8 on our part then.
9 MR. STELLO: Okay.
10 MR. FEIGENBAUM: Tom, in relation to what you were i
11 saying on the exercise schedule, maybe we could just briefly I l
12 discuss once the plan is reviewed what you see are the steps to l 13 an exercise from there.on out assuming FEMA started January 14 4th. Four months, January, February, March, April. That would 15 be on May 1st that we would have a report from FEMA or 16 thereabouts.
I 17 As you know, the last time that we were here that we ~
18 presented a schedule which showed a spring.1988 exercise. We 19 would like to the maximum extent possible to. hold that date in 20 the spring time frame. And we were thinking in terms of late 21 May. And I would like to have your thoughts on where you think 22 we are headed.
23 MR. MURLEY: I will let Dave Matthews speak to that 3 in particulars. In general, we do not sea any reason why parallel activities cannot go en. But we need to do some Heritage Reporting Corporation -
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- 31 1 initial reviews to assure ourselves that there are not major 2 gaps and major problems in this before we ourselves expend 3 significant resources on planning and so forth. But Dave may 4 be able to talk in particulars.
5 , MR. MATTHEWS: I think that the next step would be 6 when' FEMA ccmpletes the review to a. sufficient point that they.
7 believe that they have an assessment available of the plan and ..
8 its feasibility of supporting an exercise. That they would let 9 us know that, and we would let you know that. And at that j 10 point in time, I believe that we would be willing to entertain l
11 meetings where we would begin to address the subject of an i l
12 exercise scenario and the development of that, and we would be j 13 willing to receive your proposal at that point in time.
14 MR. FEIGENBAUM: Well, you are not saying-that we
-15 have to wait for the review to be. complete before we can 16 determine whether an exercise is appropriate. I mean that 17 could happen before.
18 MR. MATTHEWS: No, I did not mean to imply that the 1 19 review had to'be comp)nte before you would determine whether.or 20 not an exercise was appropriate. I do not believe that we 21 would start planning for FEMA observation and NRC observation 22 of an exercise by a date certain.until the plan review had been 23 further along.
MR. STELLO: I thought that I heard Dr. Murtha say that they could get back in two months to deal very Heritage Reporting Corporation
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32 1 specifically with that issue, and I would think that the answer 2 would be imminent at that time.
3 MR. FEIGENBAUM: So we might be able to set an 4 exercise window.
5 MR. STELLO: Conceivably.
6 MR. FEIGENBAUM: After two months.
7 MR. MURLEY: Perhaps sooner. It depends on what we 8 are finding in our review.
9 MR. STELLO: Now we are up to item number five.
10 MR. GRAM: This is George Gram. I passed out a 11 handout that covers three major items to bring everybody 12 up-to-date on the status of the follow-up activities that have 13 to go on after submitting a plan on the training, drills, and 14 status of facilities.
15 In the area of training, all of the basic training, 16 positions, and specific training modules and classes have been 17 completed for the primary off-site response organization. It 18 is over 800 people. And we are now in the process of 19 completing support personnel training such as bus drivers and 20 ambulance EMTs.
21 In the area of drills, the page that I handed out is i 1
22 a listing of all of the tabletop, and walk-through, and drill l 2; specific exercises that have been conducted to date. You can see that it is pretty extensive. And al o I would like to point out the locations. We have been using the existing Heritage Reporting Corporation (202) 628-4888
33-1 facility locations. The Haverhill facility is the staging 2 area, and Beverly and North Andover-are reception centers.
3 All of the equipment for facilities have been 4 procured. Communication equipment has been installed in all of 5 the facilities. And as we run our drills at each one.of these 6 facilities, we have drill critiques that identify enhancements 7 that we can do for logistics and things like that to improve 8 our efficiency. l 9 Are there any questions on where we stand?
10 MR. MURLEY: You have covered everything in here.
11 Does this include your notification systems, that is 12 to say have you or do you expect to exercise those, if there 13 are radios, or if there are sirens, and that sort of thing?
14 MR. GRAM: This includes, all of the equipment and 15 facilities are the personnel notification systems and the 16 public notification system. Our. intent and our planning based 17 on recent developments'is that we would exercise whatever 18 public notification systems required at the graded exercise.
19 MR. MURLEY: Okay. !
l 20 MR. FEIGENBAUM: Tom, I have got a question for you. 1 21 As far as during the course of the review that NRC i 22 and FEMA is going to conduct, I am sure that there will be some 23 questions that will arise. Let's establish the interfaces between our organizations, so that we can make the review as quickly as possible.
I Heritage Reporting Corporation (202) 628-4888 t
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+ 34 1 1 MR. MURLEY: Yes, do you want to do that now, you 2 mean, or after the meeting, or how do you want to do it?
3 MR. FEIGENBAUM: I guess that what I want to 4 understand is are we going to work through the NRC in response 5 to FEMA's questions or deal directly with FEMA?
6 MR. MURLEY: .Yes. Your major contact ought to always ;
i 7 be with the project manager. That is the best way. He will l
8 get to the right person, whether it is' Frank Congel'or Dave L .
. Matthews, and we will get to FEMA and get you an answer and so 9
10 forth.
11 MR. FEIGENBAUM:
~
Well, depending on where the review 12 is done whether it be in the region or down here in Washington, 13 New Hampshire Yankee is prepared to put staff wherever is 14 appropriate to help you in your review.
15 MR. MURLEY: Sure.
I 16 MR. STELLO: I think that.is physically directed to 17 FEMA. To the' extent that you could do that, that would help 18 them as they get started with the review.
i 19 MR. EDWARDS: I did not hear the question that Mr. j 20 Stello just answered.
21 MR. FEIGENBAUM: George, I was suggesting'that during 22 the course of the review if FEMA requires responses to '
23 questions that we would put'the necessary emergency planning staff right here in Washington or wherever the review is. going i
to be done to help facilitate the review.
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35 1 MR. MURLEY: I would think that we could deal with 2 this like we deal.with any other application or-any other 3 licensee. If you want frequent meetings, work with Nerses.
4 And we will meet as long or as often as you want as long ar 5 there are substantive things to discuss. It certainly does not 6 need to require Dick Stello and me at every meeting or Mr.
7 Eichorn or Mr. Brown at every meeting.
8 So if you think that you want to set up monthly 9 meetings and as long as there are substantive issues to discuss 10 among the staff, I would say fine. There will be public 11 meetings obviously.
12 MR. FEIGENBAUM: Well, this way if there was 13 information flowing back to us as far as what-FEMA sees as
! 14 potential problems with our plan, that we could put those back 15 into our plan and start wcirking on them.
16 MR. STELLO: Whenever we get.information that 17 indicates that that is a problem, we will let you know. We 18 would ask FEMA to do the same and we will get_it maybe to you 19 redundantly twice, FEMA to do it and we will do it.
20 I am running short on time. The last item on the 21 agenda is the NRC-FEMA support for'the exercise. You know that j 22 an exercise like this does require obviously resources, and we l 23 at FEMA have a very close working relationship.
And I do not remember the number. Does anybody remember the number in the case of the Shoreham exercise, the Heritage Reporting Corporation (202) 628-4888
36 1 expanded exercise? There were quite a few additional people.
2 Do you remember how many?
3 MR. CUMMING: There were 38 evaluators.
4 MR. STELLO: How many?
5 MR. CUMMING: There were 38.
6 MR. STELLO: There were 38.
7 MR. MATTHEWS: That was just evaluators. I think 8 that the number of people involved from the two agencies 9 exceeded 100.
10 MR. STELLO: So it will mean a special impact on us, 11 and we will work that out when the time comes. And we 12 obviously are going to do whatever it takes to get the job 13 done.
14 MR. BROWN: And I have one comment that I would like 15 to address to that. Because we understand or recognize what 16 your problems are and resources. And frankly, I do not think 17 that we can provide any answers right now or provide any clues 18 as to how one can get around it. Our concern is that if it is 19 going to take two months before we can begin to talk about an 20 exercise, then that is going to take some time to sit down and 21 discuss what the objectives are going to be and the scope.
22 And there are some notifications here. I understood 23 that there is a required 120 days prior to the proposed l exerciso that we have to submit the objectives. What I am getting at is if it is going to be two months before we can Heritage Reporting Corporation *
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37 1 begin to discuss objectives, then that says that an exercise is i
2 well out into the late summer or fall. ]
3 MR. STELLO: Why can you.not do that now?
i 4 MR. BROWN: We can. That is what we would'like to -
5 do.
6 MR. STELLO: That is what Dr. Murley suggested that 7 you work on now.
8 MR. BROWN: I. thought that we understood that it 9 would be a couple of months. So we will go ahead'and do'it.
10 MR. MURLEY:- What I said was that I do not think that-11 we are in a position to schedule an exercise date today.- l l
12 MR. STELLO: But he did comment go ahead and start 13 doing those things, and they can be in parallel.
I 14 MR. BROWN: Okay.
15 MR. STELLO: And to the extent that they need to be 16 adjusted, fine. That is easy.
17 MR. BROWN: Will do.
18 MR. FEIGENBAUM: Well, all right. Then we need to 19 set up a separate meeting at another time with FEMA and start 20 talking about the objectives.
21 MR. STELLO: When you are ready.
22 MR. EDWARDS: John, let me say something.
I 23 MR. BROWN: Yes, go ahead, please. 1 MR. EDWARDS: You talked whether John, Ed, or I need to be here. We do not have much more importantito our company Heritage . Reporting Corporation (202) 628-4888
1 O
38 1 than this plan. And I fully appreciate everything that has 2 been said about quality and safety. And-I fully understand the' 3 standards by which this plan is going to be and should be i
4 implemented.
5 We have our constituencies that we must answer to. l l
6 Believe it or not, there are Governors in New England that do 7 want Seabrook to run, mine being one, Governor O'Neill.of 8 Connecticut. We have stockholders and we have a regulatory 9 commission. And it is awfully difficult for me as CEO of the l
10 second largest owner of the company, which is the'second 11 largest owner, to say that I do not know when it is going to 12 happen, that I have to wait two months on the NRC or FEMA.
13- And I understand the process here. But I would hope I 14 that we as responsible individuals can meet periodically, so 15 that we can deal with this. Because it is putting a terrible 16 financial strain on a lot of us. And I feel like as people.who 17 have been through a process like this, notiquite like this l 18 though, can work out solutions. If it is going to work, okay.
19 We will know that earlier than four months perhaps. If it is 20 not going to work, we will know that earlier than four months.
21 So I think that frequent communication, Dr. Murley, is.very, 22 very important.
23 MR. STELLO: I do not think that you ought to construe Dr. Murley's remarks to indicate that neither he nor I are willing to meet whenever it is necessary to meet. But I.
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- 39 1 think that maybe his remarks, or if they were not, I will say 1
2 it for me, that what I do not want to do is to engage.in 3 meetings that are so-detailed that all of us find it 4 counter-productive for us to even be there. ;
5 A lot of those meetings now need to go on, and I 6 think that Dr..Murley's comment was let's get on with those. :
7 If there is a need for us to get together from time to time, we 8 will do it. But what is most'important now is the work to get 9 done. That is how we are going to get to the end of this road 10 by people taking off their jackets and rolling up their sleeves 11 and digging in, and that is what we need to do.
12 And I think that we need a lot of those working 13 meetings, so let's get on and have them. But if there11s a 14 need for us to get~together, I know what it means.to you, and 15 we will do it. And we do not want to be an obstacle, but we 16 want our job done and we want it done right to the best of our 17 God given ability, and we will do that. And I know that you 18 want it that way, too.
19 MR. BROWN: I would like to say also that to the best 20 of our ability that we are going to make sure that it is a 21 quality plan and that'it is going to do what it is intended to 22 do. We take this whole thing extremely seriously, and by God 23 we are going to make it.
I have one other matter. I am sure that most of you have heard that Bill Derrickson is going to be leaving us at i
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. 40 1 the end of this month, but will be staying on the pipeline as a 2 consultant for us, and will continue to be involved somewhat in 3 the licensing process. I just wanted to make sure that all of 4 you were aware of that o' organization change.
5 MR. STELLO: I guess that New England was too cold 6 for you.
7 MR. BROWN: He is leaving the right time of the year 8 anyway.
9' MR. STELLO: The right time of the year.
10 Is there anything else, does anybody else have 11 anything else to bring up?
12 (No response.)
13 MR. EICHORN: We would like to wish you a happy 14 holiday before we leave.
15 MR. STELLO: Thank you.
16 (Whereupon, at 2:38 p.m., the meeting was concluded.)
17 18 l
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1 CERTIFICATE .;
2 # J 3 This is to certify that the attached proceedings before the -
l 4 United States Nuclear Regulatory Commission in the matter of:
5 Name: Seabrook Management Meeting Regarding Utility i, Dnergency Plans !
7 Docket Number: 50-443 8 Place: Washington, D.C.
9 Date December 22, 1987 1 l
j 10 were held as herein appears, and that this is the original. j 11 transcript thereof for the file of the U ited States Nuclear
- 1 12 Regulatory Commission taken stenographically by me and,' ]
1 13 thereafter reduced to typewriting by me or under the dire $ tion 14 of the court reporting company, and that the transcript is a-( 15 true and accurate record of the foregoing proceedings.
1G /S/ 0% Ad i l * 'O h b)1tb l W 17 (Signature typed):
Andrew M. Emerson 18 Official Reporter 19 Heritage Reporting Corporation 20 21 ,, , y l l 22 j J
23 24 25 Heritage Reporting Corporation (202) 628-4888 ]
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