ML20245H553
| ML20245H553 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 08/10/1989 |
| From: | Ellen Brown PUBLIC SERVICE CO. OF NEW HAMPSHIRE, YANKEE ATOMIC ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20245H526 | List: |
| References | |
| OL, NUDOCS 8908170177 | |
| Download: ML20245H553 (21) | |
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'.k l ATTACHMENT A August 10, 1989 UNITED STATES OF AMERICA before the NUCLEAR REGULATORY COMMISSION
)
In the Matter of
)
)
PUBLIC SERVICE COMPANY OF
)
Docket Nos. 50-443-OL NEW HAMPSHIRE, et. Alu
)
50-444-OL
)
(Emergency Plannir.g (Seabrook Station, Units 1 and 2)
)
Issues)
)
)
AFFIDAVIT OF EDWARD A.
BROWN I, Edward A. Brown, hereby depose and say as follows:
1.
I am President and Chief Executive Officer of the New Hampshire Yankee Division (NHY) of Public Service Company of New Hampshire.
I have held this position since 1984.
Among my duties are those executive responsibilities and management authorities commensurate with directing the licensing, start up and operation of Seabrook Station while I
ensuring that safety and quality remain at the highest level L
and in keeping with all license requirements.
l 2.
I am also Chairman and Chief Executive Officer of J
Yankee Atomic Electric Company (YAEC), which operates the l
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- 4 Yankee plant in Rowe, Massachusetts and has demonstrated its competence through 28 years of safe, efficient operation of that plant.
YAIC's PreSd19nt and Chief Operating Officer 1
I reports to me and he has the direct responsibility for the l
continued safe, high quality operation of the Yankee-Rowe plant.
3.
I graduated from the United States Military Academy a, West Point in 1952 with a Bachelor of Science Degree in Engineering.
After completing my military service in 1956, I joined New England Power Service Company (NEPS).
I held a wide variety of engineering, administrative, and management positions at NEPS from 1956 to 1976.
In 1976, I was elected President of NEPS, and in 1982 I was appointed Chairman and Chief Executive Officer of that company.
In 1984, I was elected Chairman of YAEC, and President and Chief Executive Officer of New Hampshire Yankee Division (NHY) of Public Service Company of New Hampshire.
In 1989, I assumed the additional responsibilities of Chief Executive Officer of i
YAEC.
I an also a graduate of the Advanced Management Program of the Harvard Graduate School of Business Administration.
4.
The Seabrook Station Emergency Response Organization (ERO) is the integrated collection of station and other personnel trained in and responsible for implementing the Seabrook Station Radiological Emergency Plan
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(hereinafter referred to as the onsite plan).
Initially established in 1985, the organization includes onshift l
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personnel, other station personnel, corporate personnel, and Yankee Nuclear Services Division personnel.
The purpose of this affidavit is to describe the manner in which the onsite plan and.the ERO have already been demonstrated to be adequate and to fully meet NTsc regulations; state the unjustifiable hardships.that would be incurred if another onsite exercise is conducted and additional litigation and delay follows; and further state why the public interest of the people of New England will be served by avoiding unnecessary litigation.
5.
'In October, 1986, Seabrook Unit i received a 40-year operating license from the NRC with a restriction to zero power. operation.
Fuel was loaded in the reactor and Seabrook Unit 1 became an operational plant.
Since that time Seabrook Station has been operating in accordance with its licensed Technical Specifications, with required shift coverage in the Control Room, and with the operating organization and corporate support elements in place to assure public health and safety.
The NRC Staff had provided its evaluation of the operational organization in Supplement 3 to the Seabrook Station Safety Evaluation Report, Cha7ter 13, dated July, 1986.
On May 26, 1989 Seabrook received a 1
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low power operating license and in June, low power physics testing was completed.
6.
NRC evaluation of the ERO and the onsite plan began as early as late 1985 with the Emergency Plan Implementation I
Appraisals.
Conducted by the NRC Staff from December 9-13, 1985, and from March 24-28, 1986 with a follow-up inspection from June 9-13, 1986, the appraisals consisted of selective examinations of the emergency response program.
The NRC Staff reviewed procedures and representative records; inspected facilities, training, and equipment; conducted interviews; and made observations.
The results of these appraisals are documented in NRC Inspection Reports Nos. 50-443/85-32, 50-443/86-18 and 50-443/86-30 respectively.
No violations were cited L.d all open items have been addressed and closed out.
7.
Most significantly, the onsite plan has undergone three NRC graded exercises conducted in February 1986, December 1987 and June 1988.
In each exercise all major j
facilities related to the onsite emergency plan were activated and drilled, including the Control Room, the j
Technical Support Center, the Emergency Operations Facility, the Operational Support Center and the Media Center.
In the evaluation of each exercise, the NRC determined that the emergency response ections were adequate to provide i }
o m
r protective measures for the health and safety of the public (see NRC Inspection Report Nos. 50-443/86-10, 50-443/87-25, and 50-443/88-09).
No violations were everL noted by the NRC during these exercises and all their comments were addrecced and closed out.
I 8.
Excluding security, there are over 500 individuals currently members of the Emergency Response Organization assigned to either the Contral Room, the Technical Support Center, the Emergency Operations Facility, the Operational support Center or the Media Center.
The average experience level of these individuals is over two and one-half years.
Over half have participated in one of three graded'onsite exercises, and a quarter have participated in two.
Many of the newer ERO members are in less critical positions as part of large staffs, such as EOF Administrative Support (47),
' Auxiliary Operator (47), Control Room Communicator (46) and others.
As one focuses on theldecisionmaking positions,
.which are tabulated in Attachment A to this affidavit, the experienes level therefor is even greater.
They are all at least three deep with an overall ERO experience level of about three and one-third years.
At least one person currently assigned to each position listed on Attachment A participated in the June, 1988 graded exercise, with additional substantial participation in the two earlier graded onsite exercises..
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-9.
The matrix provided as Attachment B to this affidavit depicts a breekdown of the drills and exercises related to the onsite plan, the minimum frequencies with which they are required to be conducted according to NHY procedures, and the actual frequencies with which they have been conducted since receipt of the fuel load license in October 1986.
It shows that by the end of 1989, NHY will have conducted four exercises, 13 combined functional drills and numerous other facility and functional drills.
In addition to the drills and exercises, training of the ERO is conducted on a procedurally prescribed schedule.
Each ERO member has received initial qualification training and must receive annual requalification training.
- 10. - Since receipt of the fuel load license in October, 1986, NHY has also actually had to implement portions of the onsite plan in response to two situations that were classified as " Unusual Events."
Both involved minor equipment failures.
The first instance. occurred in February, 1987, and in the NRC Inspection Report (Inspection No. 50-443/87-08) which examined the event and NHY's response, the l
NRC criticized NHY for taking too long to notify the 1
Commonwealth of Massachusetts.
The second " Unusual Event" occurred on December 19, 1988.
This time the NRC reported that "[a] licensee strength was identified on December 19, - _ - _ _ _ _ _ _ - - - _
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1988 when it was-discovered that meteorological tower data was lost for a period of six minutes.
Operator actions were prudent and in accordance with procedures.
" and further noted that "[a]ll notifications to the Commonwealth of Massachusetts, State of New Hampshire and the NRC were made promptly and in accordance with NRC Regulations and the SSREP" (NRC Inspection Report No. 50-443/88-17 at 11 and 3).
11.
Finally, in a Safety Evaluation Report (SER)
-written by the NRC on Emergency Planning and Preparedness (attached to NRC Letter from Victor Nerses to Edward A. Brown dated July 28, 1989), the NRC states in Section 13.3.3 of the SER that "[t]he results of these inspections and observations of' exercises, which are documented in pertinent exercise reports, verify the continued adequacy of the Seabrook onsite emergency preparedness program."
In the cover letter accompanying the SER, the NRC concludes that "the Staff review has found that onsite emergency preparedness continues to be acceptable and is adequate for full power operation."
i 12.
In summary, the Seabrook Station organization completed the transition from the posture needed to support a i
plant under construction to that needed to assure safe operation of the facility approximately three years ago.
Construction of Seabrook Station was completed in July, 1986, and Seabrook has actually been functioning as an operational I
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e.g facility since it received its zero-power license in October 1986.
The. Emergency Response Organization,.which is an important element of the overall operational organization, has been in place for ar. proximately three and one-half years-and in that period has been continuously trained,. drilled, exercised and evaluated.
It is an experienced, well-trained
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organization, that has already proven itself capable of providing an_ adequate response to protect the health and safety of the public.
- 13..Any further delay in obtaining a full power license and. reaching commercial operations which might be caused by litigation of an onsite plan, besides being unnecessary, will also be very costly.
Each day that full power commercial operation is delayed equates to an additional plant cost of
$1.7 million, which must ultimately be borne by the companies, their shareholders, or their customers.
- Further, each day of delay results in a loss in revenue to the Seabrook Joint Owners of about $2.8 million to $3.6 million per day.
14.
However, it will not only be the Joint Owners and their ratepayers and shareholders who will be hurt by unnecessary delay.
The power that Seabrook Station can produce is needed now to satisfy New England's growing demand for power.
New England is experiencing one of the highest j i 1
rates of growth in the nation.
Since August of 1987, New Ena'and has experienced severe shortages of electrical power during both the summer and winter peak demand periods.
It 1
has only been through aggressive action by the New England Power Pool (NEPOOL), which manages the power supply for New England, that service throughout the area was maintained.
During 1988, challenges in power system operation occurred frequently, whether it was generation shortage throughout the region or a transmission limitation.
Emergency actions taken to meet these challenges and decrease the high demand included enforcement of interruptible power contracts with industrial users, voltage reductions, and public appeals to cut back on electricity usage.
A study commissioned by the Greater Boston Chamber of Commerce in September, 1988, estimated that the total impact of non-accidental energy supply shortages on the Massachusetts business community alone, during the preceding,12 month period, was l
approximately $86.8 million.
15.
The electricity capacity shortage situation is not likely to change for the better anytime soon.
New E gland's economy has been growing significantly, with a parolial increase in electrical energy consumption (KWH) and peak electrical power demand (MW).
In fact, as recently as July 27, 1989, NEPOOL reported a new summer peak power dema..d.
It was only because all available power plants vare running 1 I
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1 steadily, with no unplanned outages occurring, that this peak demand was met.
This growth has placed an unprecedented strain on the New England electric system, ;ince there has I -
not been a corresponding increase in electric generating facilities.
With the decrease in electrical reserve mart.n has come an increase in the frequency of use of NEPOOL emergency operating procedures.
During the oil crisis of the early 1970's, these emergency operating procedures were used on many occasions. 'As that crisis eased and non-oil generating facilities were brought into production, emergency operating procedures were not used again in New England from 1974 through 1983.
Emergency lcad relief measures were implemented by NEPOOL more times in 1988 than at any time-since the early 1970's.
16.
New England's electrical energy consumption increased 5.2%
n 1988, nearly equaling the'5.3% growth experienced in 1987.
Since A983, electric energy consumption has grown at a compound annual growth rate of 4.6%.
Along with growth in energy consumption, winter and summer peak demand has been increasing at an average rate of 4.5% per year since 1983.
17.
With the continuation of sustained load growth in New England during 1988 and into 1989, NEPOOL and New England utilit:.es were required to make optimum use of virtually l
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every generator and transmission line in the New England regi"2.
18.
Based on a NEPOOL draft 1990 Annua Maintenance Schedule, it is projected that, in 1990, New England will experience capacity deficiencies in 35 of 52 weeks without power from Seabrook.
In some cases the deficiencies range as high as 1300 MW, which corresponds to a power plant larger than the size of'Seabrook Station.
New England is in a severe capacity shortage situation. 'NEPOOL is very restricted in scheduling planned outages during the summer and winter peak periods.
This places heavy maintenance demands in the spring and fall, which results in additional I
capacity deficiencies within this time period and thus results in capacity shortages throughout the entire year.
19.
A report published in November, 1988, by the State of New Hampshire, State Electrical Enorgy Needs Planning Committee, recognized the impcrtance of Seabrook operation in meeting the electrical demands.
As stated under their recommendations, "[t]he Committee urges the Nuclear Regulatory Commission to promptly resolvt all outstanding i
questions relating to the Seabrook Nuclear Power Plant".
r.Q Edward A.
Brown i
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1 STATE OF NEW HAMPSHIRE Rockingham, ss.
August 10, 1089 Edward A. Brown, being on oath, deposas cnd says thrt he a
is the author of the foregoing affidavit and that the statements set forth therein are true to the best of b'.s knowledge.
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ATTACHMINT 8 SHEET 1 0F 3 DRf tt MD ExtPtt!r DESCRIPTIONS MD retowNegrs The follcaing are mininum frequencies required. Additional drills may be held as determined by the Direc or of Cmergency Response and Inclementation.
DR1LLS ACTUALLY HELO TYPE DESCRIPT!0H TREQtfCNCY 1989 1986 1987 Conminientions Drills N a rcus drills of vr.rious offsite and 1370) 140 onsite energoney conriunications systems to Weekly, fronthly, ansure capability in accordance with Quarterly,Samia requirements.
annua lly, Annually Augmentation This drill will test the ability to make Semi-annually 20) 3 2
(CallOut) Drill shift sup entation as specified in the
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Medical Emergency This drill involves the response to Annually IUI 1
4 Det11 simulatedcontaminatedinjured/illin-dividuals including participation by offsite aneulance services and nadical treatnant facilities. The drill tests the capabt11 ties of earrgency vehicle access to plant amas, on-stte Health PhAles support, first aid, off site services and on site and off-site conmunicatiopt.
Post Accident This crill involves the use of the Post.
Annually 1
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Sanoling Drt11 Accident Sasoling System (PASS) and alternate nean1 of analysis and sangling, and the response to actual radiation lowls associated with senpling procedures and Aad/ Chem response personnel.
Scheduled as part of a Health Physics Drill.
tiealth Physics Dril)
This drill involves the response to, and Semi annually 20) 2 3
analysts of, sisulated elevated airbo ne area inwwnd sewton, sinJ dirim.6 s edleLluia sneeurements. The drill tests the capabilities of Health Physics response pereennel and equipment.
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ATTACW4ENT B SilEET 2 0F 3 DRf tt e ND trtoC15C DTSCRIPT10kS AND FRTOLTNCl[$ (CONT'01 DRILLS ACTUALLY FELD TYPE DESCRIPT!DN FREQUENCY 1989 1988 1987 Radiological This drill involves on.stte and off-site Annually 1
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Monitoring Drill nonttoring including the collection and analysis of environmental sapples and provisions for communications and record keeping. The det11 tests Health Physics nonitoring connunications and analysis capabilities.
f f re Det11 This drill tests the f esponse of the Fire In accorcance 6
26 12 Brigaes and is conducted periodically in with the accoreance with the Seatrook Station Fire seabrook Station Protectionetenual. One drill including Fire Protection off-site fire support will be conducted
- Manual, annually.
Annually for off. site support.
Control Room Ort 11 III This drill tests the response of the on.
As nosood to 2III 3
3 shift emergency orgaitration and should support the include simulated emergency notifications. (mergency callout and communications. Response by Preparooness emergency teams and dose assessment Training personnel may also be tested.
Program.
Technical Support This drill tests the response of personnel As needed to 3(I) 4 3
Center (TSC)Det11(2) assignea cuties in the TSC. C u p drills support the may te hold independently to test Emergency mopenses by individual groups (e.g.. does Training assessment. communications. technical Program.
assessment)andthenintegratedto exerciso TSC operations as a whole.
Operational Support This drill tests the response of personnel As nosoed to 2(II 4
3 Center (OSC) Drill (2) assigned duties in tne 0$C. The drill support the includes femation, ortefing, dispatching Emergency and debriefing of emergency teams and Preparedness sesociated lleelth Physics support. Actual Training I
connunications with the teens thould be Program.
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$HEET 3 0F 3 onnt se trEnci';t orstolpt10N_S at rot 00tNCIES (CONT'01 DRILLS ACTUALLY llELD TYPE OtSCRIPT!CN FREQUENCY 1969 1988 1987 turgency Operations This drill tests the response of personnel As needed to 2III 6
4 Facilit assigned duties in the Erwrgency suWort the Daill()(EOF)
Operations Facility.
Emergency Preparedness Training Program.
MediaCenter(HC)
This drill tests the response of pr.'sonnel As needed to 10) 5 3
Drill (2) assigned duties in the Media Center.
support the Emergency Propersanets Training Progree.
Contined Functional A combination of one or more drills As needed to 20) 5 3
Orills O I described above which test differtrit supoort the facets of NHY emergency response to e'isure Energency a coordinated effort.
Properedness Trainino Program.
Emercise U I The Exercise tests the integrated Annually 10) 1 1
capability of the NHY Energency Response Organization to respond to an energoney, U) Numbers include activities thtt Art currently planned to be held prior to the end of 1989.
UI If the f acility was drilled as part cf a cortined functional drill or drilled individually, credit is given for a Ort 11 in the drills actually held column.
UI Three socitional coetined functional drills and one graced exercise were also conducted in 1986.
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gg111989"'l[
CERTIFICATE OF SERVICE l
I,JeffreyP. Trout,oneoftheattorneysforjheAppfikkSta i
herein, hereby certify that on August 11, 1989, I made, sesflegc gjsJ o
the within document by depositing copies thereof with(V V[T 7 h<5\\
Federal Express, prepaid, for delivery to (or where indicated, b depositing in the United States mail, first class postage'pl1~a, j
addressed to) the individuals listed below:
Lando W.
Zech, Jr., Chairman Thomas M. Roberts, Commissioner U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission i
One White Flint North One White Flint North 11555 Rockville Pike 11555 Rockville Pike Rockville, MD 20852 Rockville, MD 20852 Kenneth M. Carr, commissioner James R. Curtiss, Commissioner U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission one White Flint North One White Flint North 11555 Rockville Pike 11555 Rockville Pike Rockville, MD 20852.
Rockville, MD 20852 Kenneth C. Rogers, Commissioner William C.
Parler, Esquire U.S. Nuclear Regulatory General Counsel Commission Office of the General Counsel One White Flint North one White Flint North 11555 Rockville Pike 11555 Rockville Pike Rockville, MD 20852 Rockville, MD 20852 G.
Paul Bollwerk, III, Chairman Howard A. Wilber Atomic Safety and Licensing Atomic Safety and. Licensing Appeal Panel Appeal Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East West Towers Building East Wes: Towers Building 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 Bethesda, MD 20814 Alan S. Rosenthal, Esquire Marjorie Nordlinger, Esquire Atomic Safety and Licensing Office of the General Counsel Appeal Panel one White Flint North U.S. Nuclear Regulatory 11555 Rockville Pike Commission Rockville, MD 20P52 East West Towers Building 4350 East West Highway Bethesda, MD 20814
s.
p e-Administrative Judge Ivan Smith Administrative Judge Kenneth A.
Chairman, Atomic Safety and McCollom Licensing Board 1107 West Knapp Street U.S. Nuclear Regulatory Stillwater, OK 74075 Commission East West Towers Building 4350 East West Highway Bethesda, MD 20814 Administrative Judge Richard F.
H. Joseph Flynn, Esquire Cole, Atomic Safety and Office of General Counsel Licensing Board Federal Emergency Management U.S. Nuclear Regulatory Agency Commission 500 C Street, S.W.
East West Towers Building Washington, DC 20472 4350 Fast Wust Highway Bethesda, MD 20814 Mr. Richard R.
Donovan Diane Curran, Esquire Federal Emergency Management Andrea C. Ferster, Esquire Agency Harmon, Curran & Tousley Federal Regional Center Suite 430 130 228th Street, S.W.
2001 S Street, N.W.
Bothell, WA 98021-9796 Washington, DC 20009 Robert R.
Pierce, Esquire John P. Arnold, Esquire Atomic Safety and Licensing Attorney General Board George Dana Bisbee, Esquire U.S. Nuclear Regulatory Assistant Attorney General Commission Office of the Attorney General East West Towers Building 25 Capitol Street 4350 East West Highway Concord, NH 03301-6397 i
Bethesda, MD 20814 Adjudicatory File Sherwin E. Turk, Esquire Atomic Safety and Licensing Office of General Counsel Board Panel Docket (2 copies)
U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission One White Flint North East West Towers Building 15th Floor 4350 East West Highway 11555 Rockville Pike Bethesda, MD 20814 Rockville, MD 20852
- Atomic Safety and Licensing Robert A. Backus, Esquire Appeal Board Backus, Meyer & Solomon U.S. Nuclear Regulatory 116 Lowell Street Commission P.O.
Box 516 Washington, DC 20555 Manchester, NH 03105 1
- sa
.t'
);
Philip Ahrens, Esquire Mr. J.
P. Nadeau Assistant Attorney General Selectmen's Office Department of the Attorney 10 Central Road General Rye, NH 03870 Augusta, ME 04333 Paul McEachern, Esquire John Traficonte," Esquire Shaines & McEachern Assistant Attorney General Maplewood-Avenue Department of the Attorney P.O.
Box 360 General
'Portsmouth,,NH 03801 One Ashburton Place, 19th Floor Boston, MA 02108 Mrs. Sandra Gavutis Mr. Calvin A. Canney Chairman, Board of Selectmen City Manager-R7D 1 - Box 1154 City Hall Route 107 126 Daniel Street Kensington, NH- 03827 Portsmouth, NH 03801 l
'
- Senator Gordon-J. Humphrey R. Scott Hill-Whilton, Esquire U.S. Senate Lagoulis, Hill-Whilton &.
Washington,- DCL 20510 Rotondi l
(Attn:
Tom Burack) 79 State Street Newburyport, MA 01950 l
- Senator Gordon J. Humphrey Barbara J. Saint Andre, Esquire.
l One Eagle Square, Suite 507 Kopelman and Paige, P.C.
Concord, NH 03301-77 Franklin' Street (Attn:
Herb Boynton)
Boston, MA 02110 Mr. Thomas F. Powers, III Mr. William S.
Lord L
Town Manager Board of Selectmen i
Town of Exeter Town Hall - Friend Street 10 Front Street Amesbury, MA 01913 Exeter, NH 03833 Ashod N. Amirian, Esquire Judith H. Mizner, Esquire 145 South Main Street 79 State Street, 2nd Floor l
P.O. Box 38 Newburyport, MA 01950 Bradford, MA 01835 l
Gary W. Holmes, Esquire Richard A. Hampe, Esquire j
Holmes & Ells Hampe and McNicholas 47.Winnacunnet Road 35 Pleasant Street Hampton, NH 03842 Concord, NH 03301 h
f
+
/el(pey P. Trout ___
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