ML20245J217
| ML20245J217 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 04/28/1989 |
| From: | Bores R, Fox E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | |
| References | |
| CON-#289-8541 OL, NUDOCS 8905040049 | |
| Download: ML20245J217 (49) | |
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( EllATT.D CORMESPONDOiQA 4/28/89 i 'OtK!7ED "wc UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '89 MAY -l P4 :29 BEFORETHEATOMICSAFETYANDLICENSINGBOARD,hh[6y , , j, ,
- :nay In the Matter of )
) Docket Nos. 50-443 OL PUBLIC SERVICE COMPANY OF ) 50-444 OL NEW HAMPSHIRE, et al. ) Off-site Emergency Planning
)
(Seabrook Station, Units 1 and 2) )
NRC STAFF TFSTIMONY OF EDWIN F. FOX, JR.
AND OR. ROBERT J. BORES CONCERNING .
MAG EXERCISE CONTENTION 19 (PARS)
Q.1. Please state your names and occupations.
A.I. (a) My name is Edwin F. Fox, Jr. I am employed as a Senior Emergency Preparedness Specialist, Division of Radiation Safety and Safeguards, U.S. Nuclear Regulatory Commission, NRC Region I, 475 Allendale Road, King of Prussia, PA 19406.
(b) My name is Robert J. Bores. I am employed as a Senior Technical Reviewer, Division of Radiation Safety and Safeguards, U.S. Nuclear Regulatory Commission, NRC Region I, 475 Allendale !
i Road, King of Prussia, PA 19406.
Q.2. Have you prepared a statement of your professional qualifications?
A.2. Yes. Copies of our statements of professional qualifications are attached hereto.
8905040049 8904ps (DR ADOCK 05000443 PDR I
Q.3. What is the purpose of your testimony?
A.L. The purpose of this testimony is to provide the views of the NRC Staff with respect to MAG Ex Contention 19, concerning the Seabrook Station NRC/ FEMA graded exercise held on June 28-29, 1989
("SeabrookExercise"). That contention asserts as follows:
The Exercise revealed a fundamental flaw in ,
the Seabrook Station Radiological Plan and '
Emergency Response Procedures in that during the Exercise the licensee's personnel did not issue appropriate protective action recommendations (PARS) to the NHY Offsite Response Organization
[or] the State of New Hampshire, as required by 10 C.F.R. G 50.47(b)(10) and the guidance set forth in NUREG-0654, II.J.7 and NUREG-0396.
This licensee failinge coupled with the high degree of reliance placed by NHY's ORO [and) the State of New Hampshire on the PARS provided by the licensee, precludes a finding that there is reasonable assurance that protective measures for the public can and will be taken in the event of a radiological emergency at Seabrook Station.
Q.4. Please describe the role performed by the NRC Staff during the June 28-29, 1988 Seabrook Exercise.
A.4 The NRC Staff essentially performed two functions during the Seabrook Exercise, consistent with its role in evaluating emer-gency preparedness exercises for commercial nuclear power plants throughout the United States. First, the NRC Staff observed and evaluated the adequacy of the Applicants' onsite emergency planning and preparedness to protect the public health and safety in the event of a radiological emergency, as demonstrated in the Seabrook Exercise. This evaluation was performed by an NRC
exercise inspection team, which also verified that the Exercise met the requirements of 10 C.F.R. Part 50, Appendix E, i IV.F.
In addition, pursuant to a Memorandum of Understanding between the NRC and the Federal Emergency Management Agency (FEMA), the NRC Staff regularly participates in evaluating the adequacy of offsite emergency planning and preparedness, through its participation in FEMA's Regional Assistance Comittees (RACs) and in FEMA's evalu-ation of graded exercises. Consistent with this role, the NRC Staff participated in observing and evaluating the adequacy of offsite emergency planning and preparedness for Seabrook Station during the 1988 Seabrook Exercise, through its participation in FEMA's and the RAC's evaluation of these matters.
Q.5. Please describe the role you personally performed during the 1988 Seabrook Exercise.
A.S. (Fox) I served as the leader of the NRC Staff's inspection team, responsible for observing and evaluating the adequacy of all onsite aspects of the Seabrook Exercise. In this regard, I was responsible for the NRC Staff's overall inspection effort, which included planning and operation, chairing entrance and exit interviews and meetings, consolidating the findings of individual inspection team members, preparing the NRC Staff's inspection report, and reporting the results of the exercise inspection to NRC Region I management.
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In particular, prior to the exercise, I assisted in reviewing the-Applicants' proposed exercise scenario to determine whether all major observable elements of the onsite emergency plan would be tested. I also reviewed the NRC Staff's previous inspection reports concerning the adequacy of the Applicants' emergency planning and preparedness, to identify areas requiring corrective action which should be demonstrated during the 1988 Exercise.
After the exercise, I chaired the NRC Staff's inspection team meeting, at which the individual inspection team members presented and discussed their observations, and I was then responsible for preparing the NRC Staff's written evaluation of the exercise results.
(Bores) Prior to the Exercise, I represented NRC Region I at several meetings with the Applictnts and other parties relative to development of the proposed exercise scenario and the extent of play. Based on my reviews of the scenario, and with input from the NRC Region I Emeroency Preparedness Section. I then provided the App?': ants with NRC Region I's comments on the onsite portion of the scenario and associated radiological data. I also provided clarification as to the functional areas te be evaluated by the I
NRC Staff's inspection team.
During the Exercise, I served as Deputy Team Leader of the FEMA evaluation team for the State of New Hampshire. As such, I assisted the FEHA Team Leader in coordinating approximately 60
4 FEMA, RAC and federal contractor personnel in the observation and evaluation of New Hampshire's performance during the Exercise. As part of this responsibility, together with the FEMA Team Leader and a designated principal evaluator for each objective. I formulated the assessment as to whether or not all of the exercise objectives were met, in whole or in part, and whether any areas for improvement were identified. In addition, it was our responsibility to ensure that each of the Deficiencies and Areas RequiringCorrectiveAction(ARCAs)identifiedwithrespecttoNew Hampshire during the 1986 Seabrook exercise were evaluated by FEMA observers for adequacy during the 1988 Exercise. In addition. I was personally responsible for observing and evaluating New Hampshire's performance with respect to various exercise objectives, including Plume Dose Projection and Plume Protective Action Decisionmaking, from my assigned location in the New Hampshire Emergency Operations Center (E0C).
l Q.6. Please describe the manner in which NRC Staff inspection team members were assigned to evaluate the adequacy of the Applicants' q accomplishment of exercise objectives during the Exercise.
A.6. (Fox) Individual team members were assigned to be present at the major emergency response facilities, at which they were to observe the Applicants' emergency response and preparedness activities. j These locations included the Control Room, the Technical Support I Center (TSC), the Operations Support Center (OSC), and the Emer-gency Operations Facility (EOF). Inspection team members were
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e-i assigned to make detailed observations in their respective 1 locations regarding the Applicants' ability to perform various emergency response functions in such areas as: Recognition and i
Classification of Baergencies; Notifications to Offsite Author-ities; Notific' tion of Staff; Activation of Facilities; Accident Assessment; Dose Assessment and Projection; Protective Action 4 Recommendations; and Overall Command and Control. Ry analyzing the Applicants' performance in these functional areas, the inspection team was able to determine that each of the exercise objectives was met.
Following the Exercise, the NRC Staff's inspection team met in a i
debriefing session, which I chaired as team leader. The team members prepared brief written sunnaries detailing the strengths and weaknesses they observed during the Exercise. The individual team members' observations were then discussed by the inspection team, at which time any necessary clarification and supplemental information were provided as appropriate. As team leader, I then summarized the team members' observations and ascertained that the individual team members were in agreement with the inspection summary that would be prepared and transmitted to the licensee and other interested parties.
1 l Q.7. Please describe the guidance, if any, the NRC Staff inspection team utilized in evaluating the Applicants' performance during the l 1988 Seabrook Exercise.
A.7. (Fox) The NRC Staff inspection team conducted its inspection in l
accordance with the guidance contained in the NRC Inspection i'
Manual, Procedure 82301, dated July 1, 1983. Team assignments were described in my letter to the inspection team, dated June 16, ,
1988. l Q.8. Has the NRC Staff prepared a summary of its exercise inspection team findings concerning the adequacy of onsite emergency planning and preparedness as demonstrated in the 1988 Seabrook Exercise?
A.8. (Fox) Yes. The NRC Staff's exercise inspection findings were presented in Inspection Report 50-443/88-09, issued on July 7, 1998 A copy of that report is attached hereto as Attachment 1.
Q.9. Are you familiar with the NRC Staff inspection team's findings with regard to to the generation and issuance of Protective Action Recommendations (PARS) by the Seabrook Station Emergency Response Organization (ERO), made to the New Hampshire Yankee Offsite .
Response Organization (NHY ORO) and the State of New Hampshire?
A.9. Yes.
Q.10. Please summarize the NDC Staff's inspection team's conclusions with respect to the adequacy of the Applicants' protective action recommendations as demonstrated in the Seabrook Exercise.
A.10. The'NRC Staff inspection team concluded that the protective action recommendations generated by the ERO to the State of New Hampshire and the WHY OR0 were appropriate and timely. In other words, as stated in the Staff's inspection. report, the PARS were " prompt and conservative."
Q.11. Please provide a brief description of the scenario utilized during the 1988 Seabrook Exercise, together with a description of significant Exercise events as they relate to the protective action recommendations generated by the ERO.
A.11. In general, the exercise scenario was based on a large break Loss of Coolant Accident (LOCA) coincident with moderate fuel damage.
Containment integrity was breached via a failed penetration assembly resulting in a significant radiological release to the offsite environs.
Initial conditions established that the station was operating at 100% power with all plant parameters normal and stable except for an increasing trend in Reactor Coolant System (RCS) activity. The station had been at or above 90% power for 180 days and was near the end of core life. Several plant components were undergoing maintenance and repair, and were out of service. Approximately one hour before the exercise commencement, a "Hi" alam was received on the RCS Letdown Monitor. Following notification by the Control Room, the Chemistry Department began a confirming sample analysis.
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At about 0905 hours0.0105 days <br />0.251 hours <br />0.0015 weeks <br />3.443525e-4 months <br />, the RCS sample analysis was completed.
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Analysis results indicated 620 uCi/cc gross activity. The shift superintendent declared an Alert at about 0906 hours0.0105 days <br />0.252 hours <br />0.0015 weeks <br />3.44733e-4 months <br />, and a t
controlled plant shutdown was commenced at.20% power reduction per hour. The declaration of an Alert resulted in activation of NHY emergency response facilities and the simulated evacuation of nonessential personnel from the site. The EOF was declared l
functional by the ERO at 1010 hours0.0117 days <br />0.281 hours <br />0.00167 weeks <br />3.84305e-4 months <br />.
At 1130 hours0.0131 days <br />0.314 hours <br />0.00187 weeks <br />4.29965e-4 months <br />, an oxygen bottle in the Emergency Feedwater (EFW) pumphouse was damaged during movement. The high pressure gas leak propelled the bottle into piping and valves associated with the turbine driven EFW pump where the bottle exploded. By rendering the pump inoperable, the missile impact and subsequent explosion resulted in the declaration of a Site Area Emergency (SAE) at about 1146 hours0.0133 days <br />0.318 hours <br />0.00189 weeks <br />4.36053e-4 months <br />. The operators suspended the power decrease pending operability verification of the motor driven EFW pump.
At approximately 1330 hours0.0154 days <br />0.369 hours <br />0.0022 weeks <br />5.06065e-4 months <br />, total weld failure allowed the RCS Cold Leg "B" to separate from the reactor vessel and the subsequent large break LOCA caused a reactor trip and safety injection. Containment Building Spray (CBS) Pump P-9A was out of service as part of the initial scenario conditions; with the ;
subsequent failure of CBS Pump P-98, active containment heat and
iodine removal was lost. .The rapid RCS depressurization caused' significant fuel cladding degradation and an attendant. increase in coolant activity. During the core reflood phase, hydrodynamic -
forces drove some of the previously detected loose parts into; I various fuel assemblies. The resulting severe mechanical. cladding damage and fuel pellet erosion distributed alkaline earth and metal fission products into the reactor cttolant. The increasing inventory of released fission products resulted in containment dose rates exceeding 25,000 R per hour, and a General Emergency was declared at about 1332 hours0.0154 days <br />0.37 hours <br />0.0022 weeks <br />5.06826e-4 months <br />, i
1.0CA-induced containment pressure and temperature stresses caused. ;
a penetration assembly to lose integrity, which allowed the containment atmosphere to be vented to the containment enclosure area. Radioactive gases and steam then circulated through the ,
1 Emergency Exhaust filter fan units and out of the plant vent to l s
i the environment. As the release progressed, the efficiency of the HEPA and charcoal filters were reduced due to water condensation in the filter banks. Shortly after the General Emergency was declared, plant vent Wide Range Gas Monitor readings and offsite monitoring revealed significant releases from the station.
Evaluation of in-plant and radiological conditions resulted in, the issuance of the first protective action recommendation at about
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1339 hours0.0155 days <br />0.372 hours <br />0.00221 weeks <br />5.094895e-4 months <br />. !
CBS pumps P-9A and P-9B were returned to service at 1630 and 1645' hours, respectively, and resulted in lower containment pressure and airborne iodine concentrations. Containment pressure contin-ued to drop until the differential between containment pressure and enclosure area pressure was negligible. With the reduction and eventual subsidence of the pressure driving force, plant vent release rates trended lower.
At 1900 hours0.022 days <br />0.528 hours <br />0.00314 weeks <br />7.2295e-4 months <br /> on Day 1 of the Exercise, exercise activities were suspended until 0800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> on the next day. Exercise activities related to PARS for the plume exposure pathway EPZ, however, terminated at 1800 hours0.0208 days <br />0.5 hours <br />0.00298 weeks <br />6.849e-4 months <br /> on Day I of the Exercise, and the remaining portions of the Exercise scenario and activities related to the evaluation of other Exercise objectives and are not relevant for purposes of this testimony.
Q.12. Please identify the precautionary actions and PARS which were generated by the ERO during the Seabrook Exercise.
A.12. The ERO generated the following precautionary actions and PARS:
l TIME PAR CIRCUMSTANCES l
l 1152 Precautionary action: Plant conditions - Turbine-driven EFW pump rendered inoperable by Close Massachusetts missile impact; with the subsequent beaches and Parker explosion, a Si u trea Emergency River National (SAE) was declared at about 1146 Wildlife Refuge. hours. The SAE prompted this precautionary action.
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TIME- PAR CIRCUMSTANCES 1339 Evacuate 0-5 mi 360' Plant conditions - LOCA and loss in New Hampshire'and of CBS pumps; dose rates of-Massachusetts'(ERPAs 25,000 R/hr in containment; a A, B, C and D); and General' Emergency was declared at Shelter 5-10 mi 360' about 1332 hours0.0154 days <br />0.37 hours <br />0.0022 weeks <br />5.06826e-4 months <br />.
in NH and MA (ERPAs E, F and G).
1545 Evacuate 5-10 mi in General Emergency continued in Massachusetts towns effect. A shift in wind (ERPAE),and5-10mi direction was occurring.
.ERPA F.
Q.13. Please describe the manner in which PAR recommendations were generated during the Seabrook Exercise.
A.13. _ (Fox) The precautionary action and initial PAR were based primarily on information from the control room and the.TSC relating to plant status and prognoses. PARS were developed by the EOF Coordinator, after consultation with New Hampshire and NHY ORO personnel in the EOF. Once developed, information concerning each PAR was posted on a notification form by the EOF Coordinator, and was approved by the ERO Recovery Manager. The PAR was then officially transmitted to the State of New Hampshire I and NHY ORO personnel with decision-making responsibility.
l Please describe the nature of your observations during the Q.14' .
Exercise, as to the PARS that were issued by the NHY ERO.
A.14. (Fox) I observed the TSC staff discuss the information on plant status and prognosis, to be used by EOF personnel. The TSC had I
i direct communications with the EOF, and also had METPAC l
infomation and plant status information available in the Control Room /TSC area to perform the same functions relative to PAR formulation as are performed in the EOF. In addition, the TSC received copies of the DAR notificatf 1 sheets that were transmitted to the State of New Hampshire and the NHY ORO, detailing each of the PARS; I reviewed these forms as they were received in the TSC and determined that the PARS were appropriate and timely. In addition, as inspection team leader, I received input from other inspection team members at the team debriefing session which I chaired following the Exercise, regarding the observations those individuals made in their assigned locations.
I compared their observations to my own observations and took them into consideration in preparing the NRC Staff's Inspection Report concerning the Exercise.
(Bores) I was present at the New Hampshire E00, where I observed the New Hampshire dose assessment activities (METPAC operations), accident assessment by the E0C Radiological Health Technical Advisor (RHTA), and decision-making by New Hampshire officials. From this location, I was able to observe New Hampshire's generation of METPAC projections based on "what if" conditions, METPAC projections provided to the New Hampshire E0C by the ERO, and "what if" projections provided to New Hampshire by the ERO. I was also able to listen to discussions about the ER0's PARS via speakerphone, between the E0C RHTA and his counterparts
l at the New Hampshire Incident Field Office (IFO)/ EOF. Based on these observations, the information available to New Hampshire personnel at the time the PARS.were received, my review of the ER0's PAR notification forms during the Exercise, and my knowledge of the Exercise scenario and expected responses I detemined that the PARS received from the ERO at the EOF were appropriate and timely. In addition, as the FEMA Deputy Team Leader for the State of New Hampshire, I was involved with each of the debriefings of FEMA's New Hampshire evaluation team relative to the dose assessment and decision-making objectives. There was no disagreement among the FEMA evaluators that the protective measures implemented by New Hampshire were timely and appropriate.
Q.15. Do you agree with the NRC Staff inspection team's conclusion that the PARS generated during the 1988 Seabrook Exercise were " prompt I
and conservative", i.e., that they were timely and appropriate?
A.15. (Fox) Yes. This conclusion is based upon (1) my personal observations of events which transpired in the TSC, in which TSC personnel discussed plant conditions and provided that information to the E0F, and later discussed the PARS made by EOF staff personnel;(2)myknowledgeofplantconditions, meteorological conditions, and the time at which various significant events occurred during the exercise; (3) my review and evaluation of the PAR notification forms as they were generated during the Exercise and received in the TSC; and (4) my discussions with inspection team members and my participation as chairman in the inspection l
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l team debriefing session, in which I obtained input from the team i
members who were present in the E0F where the PARS were actually '
issued.
(Bores) Yes. This conclusion is based on (1) my observations of the New Hampshire staff at the NH E0C; (2) the discussions I ,
heard between the NH EOC and NH IFO staffs on this subject; (3) my knowledgeoftheExercisescenarioandexpectedresponses;(4)my review of the ERO's PAR notification forms during the Exercise; and (5) my discussions with the members of the FEMA evaluation team for New Hampshire who had evaluated the dose projection and protective action decision-making objectives, including those evaluators who had observed the interface between the NH IFO and EOF ERO staffs in formulating the PARS.
Q.16. Please provide the basis for your opinion that the PARS generated by the ERO during the 1988 Seabrook Exercise were timely and appropriate.
A.16. As a preliminary matter, we note that FEMA and the NRC share the philosophy that the initial protective actions (or precautionary actions) should be based primarily on plant conditions rather than on dose projections. It is prudent to take such actions when.it appears that plant conditions are unstable and that the plant may be headed into a core damage situation. Dose projections at this time remain hypothetical, in that the magnitude of a release, if any, can only be assumed; the time of release cannot be accurately
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predicted; the duration of the release usually cannot be predicted; and meteorological conditions for the time of release cannot be accurately predicted.
In addition, even if the time of release, magnitude of release, duration of release, and meteorological conditions at time of release were known, there are inherent problems in placing primary reliance on dose projections. Dose projection is not an exact science; projections could vary by orders of magnitude from the '
actual dose (dose rate) at any specific time and location. Also, the time required to make the projection decreases the amount of time available to implement the initial protective actions (or precautionary actions) before the plume reaches the populated area.
Consistent with this approach, the ERO's precautionary action and initial PAR were based primarily on existing, known plant condi- !
tions. Although current meteorological conditions were known and thereleaserate(followingtheLOCA)wasreadilyavailable,other factors -- such as the duration of the release, changes in release rates and release composition, and changes in meteorological conditions -- could not be accurately predicted. The actions taken were timely and appropriate to protect those members of the public who were most at risk, first. Subsequent actions were based on a better understanding of plant conditions and prognoses for mitigating the accident, on dose projections using the best I
4 available data and data trends, and on confirmed measurement data.
These subsequent protective actions refined the initial actions, which had been based solely on plant conditions and known facts.
The following discussion addresses the appropriateness of the specific PARS generated by the ERO.
(a) The Precautionary Closure of Massachusetts Beaches (1152 Hours)
The issuance of this precautionary recommendation by the ERO was appropriate and prudent, based upon the plant conditions which existed at the time. The early closure of the Massachusetts beaches and the Parker River National Wildlife Refuge at this time of day (1152 hours0.0133 days <br />0.32 hours <br />0.0019 weeks <br />4.38336e-4 months <br />) helped to prevent a potentially much larger number of recreational area users from entering these areas and from causing a lengthier- evacuation of these areas later, if plant cond!tions should worsen. As a result, when the order to evacuate this are: was declared later in the day, the number of people in these areas was relatively small and could therefore be expected to leave the area in less time than if the beaches were filled.
At the same time, no further protective action appeared to be necessary at the time this precautionary action was taken.
Although the ERO declared a Site Area Emergency at about 1146 hours0.0133 days <br />0.318 hours <br />0.00189 weeks <br />4.36053e-4 months <br />, shortly before this precautionary recommendation was issued, the plant situation was still relatively stable.
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i Containment integrity and Reactor Coolant System integrity were l
both maintained, core cooling was maintained, and there were no evident threats to plant stability. Thus, there was as yet no reason to believe that further protective actions were necessary at that time.
(b) Evacuate 0-5 mi 360 in New Hampshire and Massachusetts; Shelter 5-40 mi 360* in NH and MA (1339 hours0.0155 days <br />0.372 hours <br />0.00221 weeks <br />5.094895e-4 months <br />) .
This PAR was issued shortly after a General Emergency had been declared at 1332 hours0.0154 days <br />0.37 hours <br />0.0022 weeks <br />5.06826e-4 months <br />, due to a large loss of coolant accident, high radiation levels in containment and a release to the environment. While there had already been high radioactivity levels in the coolant, these other plant conditions could not have been anticipated based on ongoing trends. The NRC'.s general response strategy for severe accidents is to evacuate people near the plant, unless the release is likely to be a " puff release" or there are constraints to evacuation (see NUREG-1210, Vol. 4). The removal of the population from within a two-mile radius of the plant and five miles downwind greatly reduces the possibility of early acute t.ealth effects due to radiation releases -- and may prevent all exposure, depending on the time of plume arrival relative to this population.
In the present scenario, although a core melt situation was not indicated to be underway, certainly there were indications that
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some core damage had occurred, as evidenced by the high radiation !
l levels in containment. Further, because containment had been j breached and a release was underway, it would not have been reasonable te assume that there would be a short-term, puff release; nor were there any kno'in constraints to evacuation.
Therefore, evacuation of the population near the plant and five l
miles downwind of the plant was warranted, consistent with the i i
NRC's response strategy.
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The ER0's PAR of a 360' evacuation out to 5 miles is consistent with this strategy (although it is somewhat more coi;servative), in its recommendation to evacuate in all directions to the equivalent downwind distance of 5 miles and to shelter the rest of population within 5 to 10 miles from the plant.
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No further evacuation would have been warranted at this time.
First, as far as it was known at the time, a core melt situation was not in progress, and plant systems were operating to keep the reactor core covered; thus, any radiation releases which might be expected at the time would not be likely to cause exposures in excess of the EPA's Protective Action Guides (PAGs) beyond the evacuated areas. Second, the evacuation of populations from areas beyond five miles from the plant could adversely impact the evacuation of those persons who were most at risk due to their closer proximity to the plant. Third, the recommendation of a 360* evacuation to five miles eliminated the potential for
l near-tem changes in the PAR which might be caused by shifting wind directions. Fourth, evacuation to five miles provided ;
protection for those persons most at. risk while plant operators performed a more detailed assessment of plant and field conditions (including an assessment of which systems remained operable, generation of prognoses as to when inoperable systems might be returned to service, the measurement of releases, plume projections with respect to populations downwind of the plant, and field measurements of released activity). Finally, the recommendation to shelter in the rest of the EPZ (5-10 miles from the plant) was appropriate, in that it afforded public officials a better opportunity to provide these persons with emergency information and protective action recommendations; in the event that a determination should be made to expahd the area being evacuated, this population would be in a better position to receive such notification and to effect a more timely departure.
(c) Recommendation to Ev:cuate 5-10 mi in Massachusetts (Towr.s in ERPA E) and New Hampshire ERPA F (1545 hours0.0179 days <br />0.429 hours <br />0.00255 weeks <br />5.878725e-4 months <br />).
At the time this PAR was generated, releases from the plant were continuing, and plant operators were continuing to experience problems in returning needed equipment to service. Accordingly, no near-term termination of the release could be anticipated.
Further, wind direction was shifting clockwise so that the plume would travel closer to populations southwest of the plant, and there were forecasts of further wind shifts to follow later, in
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the direction of that population. Based on these consideration.s, l
and the existence of additional dose projections and field I
measurennts, it appeared that the plume wauld later significantly impact ERPAs E and F. In order to further minimize doses to this po ulation, it appeared prudent at this time to recommend the protective action of evacuation for these ERPAs. At the same time, based on existing and shifting wind conditions, there did not yet appear to i,a any reason to evacuate other portions of the EPZ in New Hampshire.
Q.17. Is there any significance to the fact that further PARS were not issued later in the Exercise?
A.17. No. By 1800 hours0.0208 days <br />0.5 hours <br />0.00298 weeks <br />6.849e-4 months <br /> on Day 1 of the Seabrook Exercise, all major objectives of the Exercise relative to the plume exposure pathway had been realized. Also, by 1700 hours0.0197 days <br />0.472 hours <br />0.00281 weeks <br />6.4685e-4 months <br />, the releases had been reduced to a small fraction of their earlier values. Conse-quently, at 1800 hours0.0208 days <br />0.5 hours <br />0.00298 weeks <br />6.849e-4 months <br />, with the concurrence of the NRC and FEMA exercise evaluators, the exercise controllers suspended the plume exposure pathway portion of the Exercise. During the next hour of exercise play, radiological assessment personnel were provided with the " footprint" of plume deposition, which was to be assumed to occur daring that evening and night. The provided data indi-cated that the wind had further shifted completely around, first )
toward the west, and then toward the north-northeast. The data also indicated that precipitation had occurred after the wind had shifted toward the north-northeast, comencing at about 2145
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l hours. However, there was no reason for ERO personnel to generate further PARS, inasmuch as the portion of the exercise related to the plume exposure pathway had already been suspended.
It should be noted, however, that even if exercise play had not been suspended, there appeared to have been little need to expand the evacuation zone to include ERPA G, for which the PAR of shelter had previously been generated. Projected doses in ERPA G would be expected to be lower due to (a) dispersion since the time the plume was released (b) the decay of short-lived radionuclides, (c) the long travel distance (initially several miles south, then west, then more than five miles north of the plant), and (d) known exposure duration (because the release was terminated). In any event, based on the ERO's performance in
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generating PARS, there is no reason to believe that the ERO would I have later failed to generate appropriate PARS, if the exercise had continued beyond 1800 hours0.0208 days <br />0.5 hours <br />0.00298 weeks <br />6.849e-4 months <br />.
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Q.18. Are you generally familiar with the METPAC computer model?
A.18. (Bores) Yes. The METPAC computer model is an atmospheric dispersion and dose assessment model developed for use in i
emergency planning by the Applicants; specifically, METPAC may be j i
described as a variable trajectory, segmented plume model. The j NRC Staff reviewed and accepted the use of METPAC during an Emergency Response Implementation Appraisal conducted in March 1986; the NRC Staff's findings are documented in Inspection Report 1
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No. 50-443/86-18, issued May 15, 1986. The NRC Staff has observed and evaluated the Applicants' use of METPAC in three annual exercises, including the June 1988 Exercise. In one of those exercises, held in February 1986, members of the NRC Staff participated as players and compared METPAC dose projections with the projections obtained through use of the NRC's dose projection model (IRDAM); the results were favorable.
Q.19. Please explain the role of METPAC in the generation of PARS at Seabrook Station.
A.19. The METPAC model is utilized as one of several inputs in the formulation of PARS as part of the NHY ERO decision-making process. METPAC does not, by itself, generate the PARS; rather, it indicates whether the PARS of sheltering, evacuation or a combination of the two, should be considered, based upon calculated, projected integrated doses; and it highlights those towns which are likely to be affected.
Q.20. To what extent would it be appropriate for an emergency ret,ponse organization to rely upon a computerized dose projection model such as METPAC?
A.20. Initial protective action recommendations should be based primarily on plant conditions, rather than on dose projections generated by computer models or otherwise. The output from METPAC, or any computer model, can only be as good as the assumptions which are fed into the model. For example, if the
- - i
. release start time, release duration, release rate, isotopic mix, and other relevant factors are not known accurately early in an accident (for instance, due to-the inherent uncertainties in prediction and sampling), then the computer output may prove to be incorrect. However, as confidence is gained due to the avail-ability of additional data,' confirmed measurements, etc., the projections made by computer model become more reliable for use in refining subsequent protective actions.
.Q.21. How was.the METPAC output used in the generation of PARS during the'1988 Seabrook Exercise?
A.21. During the 1988 Seabrook Exercise, the precautionary action and initial PAR were developed and generated based upon plant conditions, before any release had occurred and before METPAC dose projections using " actual" release data were available. METPAC projections played more of a role in the final PAR issued at 1545 hours0.0179 days <br />0.429 hours <br />0.00255 weeks <br />5.878725e-4 months <br />, than they did in the earlier PAR. Plant conditions had not changed appreciably since the earlier PAR; on the other hand, wind changesandthedurationofexposure(projectedintegrateddoses) indicated that additional protective actions may be warranted.
Q.22. Please provide a brief summary of the meteorological conditions that were presented as part of the Exercise Scenario.
A.22. A table summarizing the meteorological conditions that were presented as part of the Exercise scenario is attached to this testimony as Attachment 2.
Q.23. During the Exercise, did the ERO consider wind direction in its formulation of PARS?
A.23. Yes. Wind direction is an input to METPAC, and was considered in the formulation of protective action recommendations. In addition, it should be noted that the PARS were issued for specific towns (later translated into ERPAs by the State of New Hampshire and the NHY ORO) based upon sectors downwind from the plant, reflecting ERO awareness of wind directions.
Q.24. Did the Seabrook Station ERO consider weather forecast information regarding possible wind shifts, in formulating its PARS?
A.24. In general, the ERO's approach was to closely monitor the meteorological conditions and anticipate how protective actions might be affected, but not to act upon general forecast data per se. The ERO was aware of a wind shift forecast and discussed this potential wind shift. The ERO also closely monitored meteorological outputs as well as subsequent weather forecasts.
, The ERO made their precautionary action and initial protective action recommendations based on plant conditions and trends, and on currently known meteorological conditions. Following a more complete evaluation of the situation -- including a better understanding of plant conditions, the status of precautionary and protective actions taken previously, dose projections made for various segments of the population (using actual and hypothetical meteorological conditions), trends in meteorological conditions L__________---_-- - - - _ _ _ _ - - _ _ _ _ _ _ - _ - - _ _ _ _ _ _ . - . _ . - . . _ - _ . - _ _ _ _ __ _ _ _ _ . _ _ -_
over the past several hours and a comparison of these trends with short-term weather forecast information -- the ERO issued an additional PAR at 1545 hours0.0179 days <br />0.429 hours <br />0.00255 weeks <br />5.878725e-4 months <br /> recommending the evacuation of towns located within two additional ERPAs. That PAR did consider near-term weather forecast data in relation to the changes in meteorological conditions that had occurred.
Q.25. Gentlemen, does this conclude your testimony?
A.25. Yes.
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' 04/29/89 01:54 ' f4C RI DCCKET ROOM NO.827 P002
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- . Attachment 1 a
/#,,,,,4 -
i UNITED STATE 8 NUCLWAR REGULATORY COMMISSION
@ REGION I
, are ALLsNoats meas g**"* me or enusma.esswnvAma mes ,
JUL 4 71988 Docket No. 50-443 License No. CPPR-li5 Public Service Company of New Hampshire ATTN: Mr. Robert J. Harrison President and Chief Executive Officer P. O. Box 330 Manchester, New Hampshire 03105 Gentlemen:
Subject:
Inspection No. 50-443/88 09 A routine safet ins was conducted b Mr.pection Fox ofofthis youroffice annual emergency preparedness exercise i
. June 27-29, 198 at the Seabrook Nuclear, and Power other members Station of an HRC Seabrook, Newteam, on Hampshire. Discussions of our findinos were presented,by Mr. Fox to Mr. .
George Thomas and others of your staff at the conclusion of the inspection.
Areas examined during this inspection included observation of the annual exercise preparednessandinspections f9110w upand of exercises findings as identified described during in the previous NRC Regionemergency; inspection report which is enclosed with this letter. Within these areas the inspection consisted of selective examination of procedures and repre, sentative records, interviews with personnel and observation of the emergency exercise by team members. .
Within the scops of this inspection, no violations vere observed. It was determined that your emergency response actions were adeguate to provide protective measures for the health and safety of the public.
No reply to this letter is required. Your cooperation with us in this matter is appreciated.
Sincerely.
Ronald R. Bellasw, Chief Facilities Radiological Safety and Safeguards Branch l Division of Radiation Safety and Safeguards
Enclosures:
- 1. NRC Region ! Inspection Report No. 50-443/88-09 O
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Public Service Company of g New Hampshire cc w/ enc 1:
T. C. Feigenbaus Vice President, Engineering and Quality Programs W.J. Hall,RegulatoryServicesManager Station Manager D. E.Agnes, P. W. Moody, Assistant Secretary of Public Safety, Commonwealth of Massachusetts Euleyse's Legal Project Public Document Room Room local Public Document (POR) (LPOR) (NSIC)
Nuclear Safety Infcreation Center NRC Resident inspector State of New Hempshire Commonwealth of Massachusetts Seabrook Hearing Service List FEMA Region 1 I
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'04/29/89 01:54 PRC R1 DOCKET ROOM NO.827 P004
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Seabrook 1 Service Hearina List Thomas Dignan, Esq E. Tupper Kinger Esq.
John A. Ritscher, Esq. Assistant Attorney General Roots and Gray Office of Attorney General 225 Franklin Street 208 State House Annex Boston, Massachusetts 02110 Concord, New Hampshire 03301 Mr. Bruce Beckley Project Manager George D. Bisbee, Esquire New Hampshire Yankee Assistant Attorney General P.O. Box 330 Office of the Attorney General Manchester, New Hampshire 03105 25 Capitol street i Concord, New Hampshire 03301 Dr. Mscray Tye, President Diane Curran, Esquire Sun Valley Association Harmon and Weiss 209 Summer Street 2001 $ $treet, N.W.
Haverntil, Massa:husetts 08139 Washington, D.C. 20009 Robert A. Backus, Esquire D. Pierre G. Cameron, Jr. , Esquire Backus, Meyer and Solomon General Counse) 116 Le, ell Street Public Service Company of P. O. Box 516 New Hampshire Manchester, New Hampshire 03106 Manchester, New Hampshire 03105 i
Phil. lip Ahren, Escuire Mr. Alfred Sargent, Chairman Assistant Attorney General Board of Selectejen. ..
Office of the Attorney General Town of Salisbury, .MA '01960 5 tate House Station e6 Augusta. Maine 04333 Steven Oleskey, Esquire Senator Gordon J. Humphrey office of the Attorney General ATTN: Mr. Thomas Burack One Asburton Place U. $. Senate P. O. Box 330 531 Hart Senate Office Building Boston, Massachusetts 02108 Washington, D.C. 20510 Ms. Otana P. Randall Mr. Calvin A. Canney, City Manager 70 Collins $treet City Hall Seabrook, New Hampshire 03874 126 Daniel Street Portsmouth, New Hampshire 03801 Richard Hampe, Esquire New Hampshire Civil Defense Agency 107 Pleasant Street Concord, New Hampshire 03874 .
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Board of Selectmen Mr. Owen S. Durgin. Chairman RFD Dalton Road-Brentwood. New Hampshire 03833 Durham Board of Selectmen Town of Durhan
, Durham, New Hampshire 03824 Ms. Roberta C. Pevear Administrative Judge
' Town of Hampton Fa11s Jerry Harbour Drinkwater Road Atomic Safety and L.icensing Board Hampton Falls, New Hampshire 03444 U.S. Nuclear Regulatory Commission Washington, D.C. 20565 Ms. Anne Verga Mr. Guy Chichester, Chairman Chairran, Board of Selectfren To n nail Rye Nuclear Intervention Comx.ittee c/o Rye Town Hall South Ham.; ten. New Hatpshire 03827 10 Central Road Rye, Hew Hampshire 03870 Mr. Angie Fachiros, Chairman Jane $pector Boarc of Selectmen Federal Energy Regulatory Comm.
for the Town of Newbury 825 North Capitol Street, N.E.
25 High Reac Room 8105 Newbury, Massachusei,ts 01950 Washington, D.C. 20426 Ms. Resemary Cashman, Chairman Mr. R. $weer.ey Boarc of Selectmen New Hampshire Yankee Division Town of Awesbury Town Hall
- Public Service Company of
, New Hampshire Arresbury, Massachusetts. . _ 01913, Suite 610, Three Metro Center Bethesda, Maryland 20814 ,
{
Honorabie Peter J. Matthews Mr. Donald E. Chick, Town Manager Mayor, City of Newburyport Town of Exeter '
City Hall Newburyport, Massachusetts 01950 10 Front Street Exeter, New Hampshire 03823
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Administrative Judge Administrative Judge Alan 5. Rosenthal, Chairman Thomas 1. Moore, Esquire Atomic Safety and Licensing Appeal Atomic Safety and Licensing Appeal Board Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington 0.C. 20555 washington 0.C. 20655 Administrative Judge Administrative Judge Howard A. Wilber Emmeth A. Luebke Atomic Safety and Licensing Appeal Atomic $afety and Licensing Beard Board ,
U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Washington, D.C. 20555 1 i
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Edwin J. Reis. Esquire H. Joseph Flynn, Esq.
Office of the Gereral Counsel Assistant General Counsel U.S. Nuclear Regulatory Commission Washington, D.C. 20$$$ Federal Emergency Management Agency 500 C. Street, 5.W.
Washington 0.C. 20472 Edward A. Thomas Federal Emergency Management Agency Carol $. $neider Esq.
Assistant Attorney General
' 442 J. W. McCormack (POCH) Office of the Attorne Boston, Vassachssetts 02109 One Ashburton Place,19th y General Floor Boston, Massachusetts 02108 Paul McEachern. Eso. Richard A. Naaps, Esq Shair.es and P:Eschern Haaps and McNicholas 25 Veolewood Avenue portsmouth, New Hampshire 03801 35 Pleasant Street Concord, New Hampshire 03301 J. P. Nadeau Allen Lampert Boarc of Selectmen 10 Central Street Civil Defense Director Rye, New Hampshire 03870 Town of Brentwood 20 Franklin Street Exeter, New Hampshire 03833 William Armstrong Sandra Gavutis, Chairman Civil Defense Director Board of Selectmen Towe of Exeter RFD #1, Box 1154 10 Front Street Xensington, New Hampshire 03827 Exeter, New Hampshire 03833 Anne Goodman, Chairman Board of Selectmen Wilitam $. Lord Board of Selectmen 13-15 Newmarket Road Durhae, New Hampshire 03824 Town Hall - Friend Street Anesbury, Massachusetts 01913 Michael Santosucsso, Chairnan Jerard A. Creteau, Constable Board of Selectmen 82 Beach Road South Hampton, New Hampshira 03827 i P. C. Box 5501 i Salisbury, Massschuseits 01950 Stanley W. Knowles, Chairman Board of Selectmen Judith H. Mitzner P. O. Box 710 Silverglate, Gertner, Baker, Fine, i Good, and Mitzner l North Hampton, New Hampshire 03862 88 Broad Street Boston, Massachusetts 02110 Norman C. Kantner Gary W, Holmes, Esq.
Superintendent of Schools Holmes and Ellis School Administrative Unit No. 21 47 Winnacunnet Road Aluani Drive Hamptor., New Hampshire 03442 Hampton, New Hampshire 03842 1
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Charles P. Graham, Esquire McKay, Murphy and Graham Mr. Robert Carrigg, Chairman 100 P.ain Street Board of Selectmen Amesbury, Massachusetts 01913 Town Office Atlantic Avenue North Hampton, New Hampshire 03870 Jane Doughty Seacoast Anti-PcIlution League 5 Market Street Portsmouth, New Hampshire 03801
...,,=.r. =-. . .
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'04/29/89 01:55 NRC RI DOCKET ROOM NO.827 P000 r
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U.S. NUCLEAR REGULATORY CON 4!$$10N REGION !
Report No. 50 443/88-09 Docket No. 50 443 License No. CPPR-135 Priority Category C Licensee: Pubitc Service _ Company of New Hemoshire F. D. box JJU panenester, new Hampshire 03105 Facility Name: Seabrook Nuclear Power $tation Inspection At: $sabrook, New Hampshire Inspection Conducted: Juns 27 27.1988 Inspectors-tfDR55 C. Amato EPS C. Gordon EPS
$.Palescbat EPS D. Ruscitto,,R3. $4& brook- - -
D..Perrotti, NRRi ..' -
J. Jamison, PNL '
Approved By: e _
- v. J.Mtarus, cMer, tys, b case 4
FR558, DRS$
inspection Sunistry: I Inspection on June 27-29. 1988 (Recort No. 50443/0809]
Areas Inspected: Routine, announced emergency preparedness inspection and I conservation of sne licensee's annual full-participation emergency exercise )
performed on June 28-29, 1988. The inspection was performed by a taas of seven NRC Region I, headquarters and contractor personnel.
Results: No violations were identified. Eseryoncy response actions were l acequate to provide protective measures for the health and safety of the public.
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04/29/89 01:55 NRC RI DOCXET ROOM NO.827 P009 I .
I l OETAIL5 1.0 Persons Contacted The followino licensee representatives attended the exit meeting held on June 29, 1988.
E. Brown, President and Chief Executive Officer D. Bovino Exercise Coordthator P. Casey, Senior Emergency Planner T. Feigenbaum, Vice President Engineering / Quality G. Gram, Executive Director, Emergency Preparedness and Community Affairs T. Harpster Director Energency Preparedness Licensing D. Moody,$fationManager P. Stroup Director, Emergency laplementation ad Response G. Thomas, Vice President Nuclear Production J. MacDonald, Radiological Assessment Manager .
The team observed and interviewed several licensee emergency response personnel,during functions the exercise. controllers and observers as they performed their assi 2.0 Emergency Exercise The Seabrook Nuclear Power Station full participation exercise was conducted on June 28 1988 from g:00 AM to 7:00 PM. The State of New Hampshire 11 local lowns and the State of Maine participated. The Commonwealth of Massachlisetts* and -6 Locabtowns in New_ Hampshire did not participate. The State of New Hampshire compensated for the local . -
non participants. The New Hampshire Yankee Offsite Response Organization (NHY ORO) compensated for the Commonwealth non-participants. The licensee. New Hampshire, Maine and NHY ORD conducted field monitoring activities, an ingestion pathway exercise and recovery and reentry activities on June 29, 1988. The Federal Emergency Management Agency (FEMA) observed all off-site activities.
2.1 Pre-exercise Activities NRC Region I and FEMA Prior to the emergp<
representatives rey exercise,d hi meetings an had telephone discussions with scope and content licensee of representatives the exercise scenario. As to discuss a result,objectives,hanges minor c were madt in order scenarioto clarify certain and ensure thatobjectivesIo the scenar prrevise certain portions of the idedtheopportunityfor the licenses to demonstrate the stated o octives as well as ; hose areas previously identified by NRC and F A as in need of corrective action.
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'04/29/89' 08 55 NRC RI DOCKET ROOM NO.827 P010 C ?
! 3 NRCobserversattendedalicenseebriefingonJune 17, 1988, and participated in the discussion of emergency response actions expected during the various phases of the scenario. The licensee stated that controllers would intercede in exercise activities to prevent scenario deviation or disruption of normal plant operations.
The exercise scenario included the following events:
- Fuel damaged by loose parts:
Damage to a turbine driven emergency feedwater pumpi
- Larne break Loss of Coolant Accident (LOCA) due to a total weld falTure;
- Venting of the containment into the containment enclosure building with a subsequent elevated, filtered release to the atmospherst
- Declaration of Alert, Site Area Emergency and General Emergency Clusificationst
- Calculation of offsite dose consequences; and
- Reconnendation of protective actions to off site officials.
2.2 Activities Observed During the conduit cif .the,1,1canseets exercise Hven NR .. team...... . :..
membefs made deteHed-oHervstions-of thsact$v'at'ish"an(d augment ~ ~ ~ " "
ation of the energency organization, activation of emergency response facilities, and actions of emergency response personnel during the operation of the emergency response facilities. The following activities were observed:
- 1. Detection, classification, and assessment of scenario events;
- 2. Direction and coordination of the emergency responsel
- 3. Augmentation of the emergency organization and response facility activation; I
4 Notification of licenses personnel and offsite agencies of pertinent planij status information:
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- 5. Communications /information flow, and record keeping; e
L 04/29/89 01:55 NRC RI DOCKET ROOM NO,827 P011
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- 6. Assessment and krojection of offsite radiological dose and consideration of protective actionst
- 7. Provisions for inplant radiation projections ,
- 8. Performance of offsite and inplant radiological surveys:
- 9. Maintenance of site security and access control
- 10. Performance of technical support, repair and corrective actions; -
- 11. Assembly, accountability and evacuation of personnel;
- 12. Preparation of information for dissemination at the Emergency News Center; and
- 13. Management of recovery and reentry operations.
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3.0 Exercise Observations l
3.1 Exercise Streneths The NRC team noted that the licensoe's activation and augmentation of the emergency facilities, and use organization,ilities of the fac were generally consistentacttvation of with their emergency resoonse plan and implementing procedures 4 - --
The team also noted the followl actions that rovided str "-
positive indication of their ab ity to cope wi h abnormaT
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ffr" conditions:
- 1. Very cood command and control of all emergency response faellities (ERF's) was demonstrated
- 2. Plant conditions were quickly recognized and classified:
- 3. Shift turnover was accomplished smoothly and with no apparent loss of control,of the situation
- 4. TheERF'swereictivatedinatimelysanner;and l
- 5. Protective Action Recossendations fPAR's) were prompt and conservative. 1:vacuationtingJstdmateswereeffectively utilized in determining the PAR 8.
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3.1 Exercise Weaknesses!
The NRC identified the following exercise weaknesses which a s to be evaluated and corrected by the licensee. The licensee co ucted an adequate self critique of'the exercise that also identift these areas.
- 1. The Technical Support Center (T$C) and Emorgency Operations Facility E0F e engineering judgement (and or did not recoenfze er address technicalstaff displa concerns (50- 43/88 08 01). For extaple:
Neither the EDF or TSC staff ouestioned a release of greater than 7000 curies per second with only clad damage and ne core uncovery;
- Efforts continued to restors the Emergency Feedwater Pump after a large break LOCA; A questionable fix for the Contalement Building $ pray system; i
- A lack of effort to locate and 1: elate the release paths and
- No effort was noted to blowdown Steam Generators to lessen the heat load in containment.
- 2. 0$C have multiple The TSCand entrances andektts operational Shat are not Support contre Center (! led).1 As"a reiulti contamination entered withoutcontro"s frisking were and-itineffective at times at1ertennel u cou' dn't be deteisined if --
continuous accountability was,.or could be, maintained (50-443/88 09 02).
- 3. No apparent consideration was elven to the de arting first shift to account for possible dose when leavi the plant during the release, as they were not given dos notry (50-443/88 09 03).
- 4. The response to'some questions [n the Media Center were not adequate such as: the NAC's re e in an emergency and wh reactor trip wasn't performed earlier (50 443/88 09-04). y a 1
4.0 Licensee Actions on Previp'usly !dentified Items The followine items were identified dur previous inspection I LInspection Report No. 50 443 upon observations made by l
the NRC team during the exerc/87 26).ise the fo lowing opens itse were acceptably demonstrated and are closed:
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4 (Ct.0$E05 87 25-01 IFl: The simulator Shift Supervisor did not use classification procedures and failed to recognize the loss of both Radiation Monitoring Systems trains as en Unusual Event.
(CLOSED) 87 25 02 IFI: Ldek of a Post Accident Containment tir sample prevented dose assessment personnel from estimating the containment atmosphere iodine concentration.
5.0 Licensee Criticue The NRC team attended the licensee's post-exercise critique on June 29, 1988 during which the key licenses controllers discussed observations of t$e exercise. The licensee indicated these observations would be evaluated and appropriate corrective actions taken.
6.0 Exit Meetine and NRC Criticue The NRC team met with the licensee representatives listed in Section 1 of this report at the end of the inspection. The team leader sumarized the observations made during the exercise.
The licensee was informed'that previously identified items were adequately addressed and no violations were observed. Although there were areas identified for corrective action, the NRC team dotermined the nicensee's that within the performance scope andthat demonstrated limitations of implement they could the scenario,ir the Emergency Plan and Emergency Plan Implementing Procedures in a manner which would adequately provide protective measures for the health and safety of the public. i Licensee management acknowledged the findings and indicated that appro-priate action would be taken regarding the identified open items. ,
At no time during this inspection did the inspectors provide any written information to the licensee.
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Attachment 2 TIME PERIOD l WIND DIRECTION;W1ND SPEED: STABILITY: PRECIPITATION I 15 MIN AVERAGE: (FROM) :(MPS/ MPH) ! CLASS I _- 1 1 ____,,_l-
- (IN/15 MIN) 1
! l
! 1345-1400 : W 281 : 0.45/1.0 l A I O I
! .-- I : l_ l_ t i 1400-1415 : WNW 292 : 0.45/1.0 i B I O I
! !- ! I_ l l l 1415-1430 : W 280 i O . 4 5 /1. CI~ 1 B I O I I : : _ I 1430-1445 : W 279 1 0.45/1.0 i B ! O I
- ! : 1
_ I
- 1445-1500 : WNW 289 i 0.45/1.0 i B O I
- I
- 1500-2515 : WNW 299 0.89/2.0 B i 0 1
_ 1 : __ I
~-
- 1515-1530 1 NW 309 : 1.34/3.0 i B i 0 1
- I
- I :
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- 1530-1545 : NW 319 : 1.34/3.0 i C i 0 l I , i t_ ___
! ! I 1545-3600 : NNW 329 : 0.99/2.0 : C : O l I l ,___ - ! !
! 1600-1615 : NNW 339 _ ! 1.34/3.0 1 C t 0 i l : _
t ! :
- 1615-1630 : N 349 l 1.34/3.0 1 C O I l _
- 1__ l 1 I i 1630-1645 : N 359 1 1.34/3.0 : C 0 :
! ! : , I : . I
- 1645-1700 : N9 : 0 89/2.0 1 D I O I
- : I ! - t _
- 1700-1715 : NNE 19 1 1.34/3.0 1 D : 0 I i __
- : ,, I : !
! 1715-1730 : NNE 29 i O.89/2.0 : D : 0 :
- l !_ l t
- 1730-1745 : NE 39 l 1.34/3.0 : D : 0 1
- ! !_ _ __ l ! - I f 1745-1800 : NE 49 1 0.89/2.0 : E I O !
- l 1 ! l l l 81800-1815_ :_ _ _ENE _ _l59 ! 1.34/3.0 t E : O i
- ! _ l 8 1
- 1815-1930 : ENE 69 1.34/3.0 1 E I O I I I !_ ! ! - I i 1830-1845 t E 79 -: 1.79/4.0 : E I O I I t !_ ! ! 1 1 1945-1900 : E 89 1 1.34/3.0 : E l 0 I
. . _I _.
1900-1915 I E 90 1 1.79/4.0 1 E ! O I I___ 1 : 1 I i 1915-1930 : SSW 200 : 3.13/7.0 I E O I l _
_t ~
- 1 i
- 1930-1945 : SSW 199 : 3.50/0.0 i E 1 0 l I I _! _ .__ l _l
_f i 1945-2000 l SSW 200 14.47/30.0 1 E ! O I 1 __ _ __t _
l ! !
I 2000-2015 : SSW 201 14.47/10.0 1 E i 0 1 1- t ! ,,___ _ t __l - _ ._ t
! 2015-2030 1 SSW 200 14.47/10.0 t E I O I 1
! I _
! ! ! __ _ i 2030-2045 : SSW 199 14.47/10.0 i E 1 0 l i ! .
! I i i
! 2045-2100 i SSW 200 14.47/10.0 : E I O t I ! ! ! l l
- 2100-2115 : SSW 201 14.47/10.0 1 E i __ O I
~
2115-2130 l' SSW 199 4.47/10.0 E l O !
! ! _. .. I I I I 2130-2145 : SSW 200 14.47/10.0 t E I O I I ! .I ._ ! ! 1 1 2145-2200 ! SSW 202 !4.47/10.0 1 E : 0.13 :
~~ 2200-2215 SSW 200 4.47/10.0 E I O.15 I l I.. ! ! !
1 2215-2230 : SSW 199 14.47/10.0 : E I O.15 i l 1 1 ! _t
- 2230-2245 i SSW 200 14.47/10.0 i F I O.20 i l__. I _i__ l :
THE SOURCE OF THIS MATRIX WAS THE EXERCISE SCENARIO
- THE PLUME EXPOSURE PATHWAY PORTION OF THE EXERCISE TERMINATED AT 1900. ALL DATA USED AFTER THAT TIME WAS FOR THE INGESTON PATHWAY PORTION OF THE EXERCISE.
_ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ - . _ _ _ _ _ .- - - J
e PROFFS9 TONAL QUALIFICATIONS OF EDWIN F. FOX, JR.
EDUCATION Bachelor of Science in Civil Engineering Virgina Military Institute, Lexington, VA., 1961 Master of Science in Nuclear Engineering North Carolina State University, Raleigh, NC., 1975 PROFESSIONAL POSITIONS 1961 to 1975 U.S. Army Corps of Engineers Commissioned Officer 1976 to 1977 Quality Assurance Engineer, Virginia Electric Power Company, North Anna Nuclear Power Plant 1977 to 1982 Technical Trainer, Technical Training Center Nuclear Regulatory Commission (Washington,D.C.)
1982 to 1986 Technical Advisor, Office of Inspection and Enforcement Nuclear Regulatory Commission (Washington,D.C.)
1986 to Present Senior Emergency Preparedness Inspector, Re.gion I Nuclear Regulatory Commission (King of Prussia, PA)
As a Quality Assurance Engineer at North Anna, Mr. Fox was responsible for auditing the pre-operational and start-up phase of the reactor. In these audits, he identified numerous issues which were required to be and were corrected prior to criticality.
Mr. Fox was primarily responsible for the technical training program for reactor construction inspectors while a member of the NRC Technical Training Center. As such, he developed, oversaw, and attended all courses associated with this training. These included Non-Destructive Examination Welding and Concrete Technology and Codes, and Management Oversight Risk Tree Analysis (MORT).
l During his tenure as a technical assistant in the Office of Inspection and Enforcement (I&E), he was responsible for reviewing the operational status of each operating reactor in the country on a daily basis, and analyzing all operational events in order to provide a sumary of these to I&E managers. At the same time, he participated in numerous emergency exercises involving both nuclear power plants and accidents in the transportation of radioactive material.
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In October 1986, Mr. Fox was appointed as a Senior Emergency Preparedness Specialist in the Emergency Preparedness Section, Region I, U.S. Nuclear Regulatory Commission. Mr. Fox has been the lead NRC inspector for the emergency preparedness implementation appraisal of various nuclear power facilities and has conducted numerous emergency preparedness inspections of nuclear power and research facilities in Region I. He is the NRC Regional Assistance Committee (RAC) member for FEMA Region II and is one of the NRC RAC members for FEMA Region III. As . such, he has reviewed and evaluated numerous state and local emergency plans and has assisted FEMA in the observation and evaluation of state and local governments' implementation of those plans during numerous exercises.
Mr. Fox is a Vietnam veteran (two tours), having served fifteen years on active duty as an U.S. Army Corp of Engineers and Intelligence Officer. He is currently a Lieutenant Colonel in the U.S. Army Reserves. His awards include two Bronze Stars, Vietnamese Cross of Gallantry, Vietnamese Honor Medal and the Army Commendation Medal as well as a number of Army Reserve Medals and both the Airborne and Combat Infantryman Badge.
Mr. Fox has been a practicing registered professional engineer through the U.S. Army for approximately the past 18 years.
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l April 1989 ROBERT J. BORES SENIOR TECHNICAL REVIEWER l FACILITIES RADIOLOGICAL SAFETY AND SAFEGUARDS BRANCH DIVISION OF RADIATION SAFETY AND SAFEGUARDS i
U. S. NUCLEAR REGULATORY COMMISSION, REGION I j 1
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PROFESSIONAL QUALIFICATIONS RELATIVE TO EMERGENCY PREPARE 0 NESS 1
EDUCATION: B. S. - Physics and Math, University of Wisconsin, Stevens Point, Wisconsin - 1964 M. S. - Radiological Health, Rutgers University, New Brunswick, I New Jersey - 1966 Ph.D. - Radiation Biophysics, Rutgers University, New Brunswick, New Jersey - 1976 EXPERIENCE:
Joined the Atomic Energy Commission (AE;",) in 1972 as a Radiation Specialist at Region I. Inspected all types of AEC licensed byproduct material programs and detemined program compliance with AEC regulations and program safety. In 1973, was assigned to Environmental and Special Projects Section and was primarily responsible for inspection of all aspects of environmental monitoring programs at nuclear fuel facilities and nuclear power plants. Also inspected emergency preparedness programs at these facilities and responded to a number of incidents / emergencies in that capacity. In 1979, became Section Chief of Environmental and Special Projects Section, responsible for inspection and enforcement activities at all Region I facilities involving environmental protection, emergency preparedness and radiological measurements. Was cognizant supervisor in NRC Region I for development and implementation of emergency preparedness appraisal program. Supervised staff who provided many of NUREG 0654 criteria related to licensee activities.
Supervised the development and implementation of the NRC Thermoluminescent Dosimetry (TLD) Direct Radiation Monitoring Network currently in place at all U. S. concercial nuclear power plants. In 1982, was assigned as Acting Branch Chief of Radiological Protection Branch until permanent Branch Chief was selected. In 1983, selected Technical Assistant to the Division Director, Division of Radiation Safety and Safeguards, responsible for assisting the Division Director in establishing policies and guidance for the Division, conducting appraisals of division activities and performing special projects for the Division. In January 1989, became Senior Technical Reviewer.
Facilities Radiological Safety and Safeguards Branch as a result of reorganization. Responsibilities remained essentially the same as when Technical Assistant.
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4 In 1979, during and after the Three Mile Island-2 accident, served as the NRC onsite liaison to other federal and state agencies perfoming radiological monitoring and assessment activities. Collected, sampled and evaluated all USNRC environmental monitoring data relative to the Three Mile Island accident.
Evaluated and compiled the whole body analysis data of the Harricburg, Pennsylvania area residents subsequent to the TMI-2 accident.
In 1982, responded to the R. E. Ginna Nuclear Power Plant steam generator tube rupture event as the NRC Site Team Environmental Team Leader, responsible for the coordination of the NRC environmental sampling and analytical efforts in response to that event.
In 1986, participated with the NRC Lessons-Learned _ Task Force that reviewed the rupture of a hot UF6 cylinder at Sequoyah Fuels Corporation Gore.
Oklahoma, to develop lessons-learned in emergency response / emergency preparedness area.
Subsequent to 1979, participated in approximately 20 NRC emergency exercises with various utilities and licensees in various capacities and positions, including participation in the Federal Field Exercise at the St. Lucie plant in March,1984, as the NRC Liaison to the Federal Radiological Monitoring and Assessment Center (FRMAC).
In December 1985, participated in the Federal Relocation Tabletop Exercise as NRC liaison to FRMAC in developing / exploring federal, state and local response actions to a contaminating eccident relative to recovery and relocation.
In June 1987, participated in Federal Field Exercise-2 (FFE-2) at Zion, Illinois, as one of the three Chief Data Controllers / Evaluators for the FRMAC during this exercise.
Served as the NRC representative to the Regional Assistance Committee (RAC) for the review of numerous state and local plans, including the New York State and county plans for the R. E. Ginna site, the Nine Mile Point site, and the Indian Point site; the New Jersey plans for the Oyster Creek and Salem sites; the LILCO offsite plans for Shoreham; and the Pennsylvania plans for the Limerick site; the state and local plans for the Maine Yankee site; the Connecticut plans for the Millstone and Haddam Neck sites; the New Hampshire state and local plans and the draft Massachusetts state and local plans for the Seabrook site. Continues to serve at the NRC RAC member for the Seabrook site. :
Served as federal observer for FEMA for about 20 utility / state emergency exercises.
Served as the Chaiman of the NRC Region I Radiation Safety Connittee from 1982 to 1989.
Member of the Federal Monitoring and Assessment Center (FRMAC) Working Group on Evaluation and Assessment, revising plans and procedures for the federal response to any severe radiological incident.
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PREVIOUS JOB EXPERIENCE:
1966-1968 Taught in the Radiological Health Training Program, Rutgers University 1969-1972 Served in several capacities in the Biology Department, Brookhaven National Laboratory, performing radiation dosimetry for the department and research activities AFFILIATIONS: Health Physics Society Delaware Valley Society for Radiation Safety PUBLICATIONS:
Bores, Robert, " Neutron Tissue Dosimetry - A Comparison of Mathematical and Experimental Approaches," Critical Essay in partial fulfillment of requirements for M.S. Degree, Rutgers Vaiversity - 1965.
Bores, Robert J., review of book, The Fundamentals of__X-Ray and R_adium Physics, by Joseph Selman. M.D., Fifth Edition, in Radiation Botany,14, 217, 1974.
Bores, R, J. and P. J. Bottino, " Design and Dosimetry of a Sr-90/Y-90 Beta Irradiation Facility," Health Physics, 26,99-101, 1974.
Bores, Robert James, "The Effects of Low Dose Alpha Radiation of the Growth Rate of Single Sporangiophore of the Fungus Phycomyces Blakesleeanus " Ph.D.
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Thesis Rutgers University, 1976.
Bottino, P. J., R. J. Bores, and A. H. Sparrow, " Relative Biological Effectiveness of Beta, Gamma and X-Irradiation for Seedling Growth and Survival in Barley and Somatic Mutations in Tradescantia," presented at Radiation Research meeting in 1973.
Gotchy, R. L. and R. J. Bores, "The Public Whole Body Counting Program Following the Three Mile Island Accident " NUREG 0636, NRC, 1980.
Stohr J. P. and R. J. Bores. " Nuclear Regulatory Commission Region ! )
Environmental Monitoring Inspection Program," in Effluent and Environmental I Radiati_on Surveillance. ASTM STP 698, J. J. Kelly Ed., American Society for Testing and Materfals, pp 179-192, 1980. i Bores, R. J., "The Scope of NRC, Requirements for Arrangements for Medical Services for Contaminated Injured Individuals," in Symposium _on the Health Aspects of Nuclear Power Plant Incidents; Bulletin of the New York Academy of ,
Medicine, Vol. 59, No. 20, pp. 956-961 December 1983.
Criteria for Adequate Radiation Control Programs (Environmental Monitoring), A Report of Task Force E-10, Conference of Radiation Control Program Directors, Inc., 1986.
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1 Coordinated the development and authored major portions of:
NRC Region I Emergency Response Supplement to NUREG 0845, 1982 NRC Region 1 Radiation Safety Manual, 1/87 Made significant contributions to:
NUREG 0654/ FEMA-REP-1, " Criteria for Preparedness and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," NRC, 1979
" Emergency Preparedness Appraisal Program" IE Manual Chapter TI 2515-55, NRC, 1980 NUREG 1198, " Release of UF6 From - Ruptured Model 48Y Cylinder at Sequoyah Fuels Corporation Facility: Lessons-Learned Report, NRC, June 1986 D
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-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'89 MAY -1 P4 :29 ;
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
'In the' Matter of ) 51 d$bYet! Nod. 5b N3 OL PUBLIC SERVICE' COMPANY OF 50-444 OL NEW HAMPSHIRE, y al. Off-site Emergency Planning-
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(Seabrook' Station, Units 1 and 2). )
i CERTIFICATE OF SERVICE I' hereby certify that copies of "NRC STAFF'S PRE-TRIAL BRIEF ON INTERVENERS' EXERCISE . CONTENTIONS" and "NRC STAFF TESTIMONY OF EDWIN F. FOX, JR. AND DR. ROBERT J. BORES CONCERNING MAG EXERCISE CONTENTION 19 (PARS)"in the above captioned proceeding have been served on the following by -deposit in the United States mail, first class or, as indicated by an asterisk, by deposit in the Nuclear Regulatory Comission's internal mail system, or as indicated by double asterisks, by express mail, this 28th day of April 1989:
IvanW.. Smith, Chairman (2)* Philip Ahrens, Esq.
Administrative Judge Assistant Attorney General Atomic Safety and Licensing Board Office of the Attorney General U.S. Nuclear Regulatory Commission State House Station Washington, DC 20555 Augusta, ME 04333 Richard F. Cole
- John Traficonte. Esq.**
Administrative Judge Assistant Attorney General Atomic Safety and Licensing Board Office of. the Attorney General U.S. Nuclear Regulatory Commission One Ashburton Place, 19th Floor Washington, DC 20555 Boston, MA 02108 Kenneth A. McCollom** Geoffrey Huntington, Esq.
Administrative Judge Assistant Attorney General 1107 West Knapp Street Office of the Attorney General Stillwater, OK 7407S 25 Capitol Street Concord, NH 03301 Thomas G. Dignan, Jr., Esq.**
Robert K. Gad, III, Esq. Diane Curran, Esq.**
Ropes & Gray Hamon, Curran & Tousley One International Place 2001 S Street, NW Boston, MA 02110-2624 Suite 430 Washington, DC 20009 Robert A. Backus, Esq.**
Backus, Meyer & Solomon 116 Lowell Street Manchester, NH 03106
i 2-H. J. Flynn, Esq. : Judith H. Mizner. Esq.**
Assistant General Counsel- 79 State Street Federal Emergency Management Agency Newburyport, MA 01950 500 C Street, S.W.
Washington, DC 20472 Robert Carrigg, Chairman Board of Selectmen Paul McEachern, Esq.** Town Office i Shaines & McEachern Atlantic Avenue !
25 Maplewood Avenue North Hampton, NH 03862 i P.O. Box 360 Portsmouth, NH 03801 William S. Lord (
Board of Selectmen Charles P. Graham, Esq. Town Hall - Friend Street ]
McKay, Murphy & Graham Amesbury, MA 01913 100 Main Street Amesbury, MA 01913 Mrs. Anne E. Goodman, Chairman Board of Selectmen Sandra Gavutis, Chairman 13-15 Newmarket Road Board of Selectmen Durham, NH 03824 RFD #1, Box 1154 Kensington, NH 03827 Kensington, NH 03827 Hon. Gordon J. Humphrey Calvin A. Canney United States Senate City Hall 531 Hart Senate Office Building 126 Daniel Street Washington, DC 20510 Portsme:th, NH 03801 Richard R. Donovan **
R. Scott Hill-Whilton, Esq.** Federal Emergency Management Lagoulis, Clark, Hill-Whilton Agency
& McGuire Federal Regional Center 79 State Street 130 228th Street, S.W.
Newburyport, MA 01950 Bothell, Washington 98021-9796 Allen Lampert Peter J. Matthews, Mayor Civil Defense Director City Hall Town of Brentwood Newburyport, MA 01950 20 Franklin Exeter, NH 03833 Michael Santosuosso, Chaiman Board of Selectmen William Armstrong South Hampton, NH 03827 Civil Defense Director Town of Exeter Ashod N. Amirian, Esq.**
10 Front Street Town Counsel for Merrimac Exeter, NH 03833 145 South Main Street P.O. Box 38 Gary W. Holmes, Esq. Bradford, MA 01835 Holmes & Ellis 47 Winnacunnet Road Barbara J. Saint Andre, Esq.**
Hampton, NH 03842 Kopelman and Paige, P.C.
77 Franklin Street Boston, MA 02110
Ms. Suzanne Breiseth J. P. Nadeau Board of Selectmen Board of Selectmen Town of Hampton Falls 10 Central Street Drinkwater Road Rye, NH 03870 Hampton Falls, NH 03844 Atomic Safety and Licensing Robert R. Pierce, Esq.* Board Panel (1)*
Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board Panel Washington, DC 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555 Ms. Elizabeth Weinhold 3 Godfrey Avenue Atomic Safety and Licensing Hampton, NH 03842 Appeal Panel (5)
U.S. Nuclear Regulatory Commission Washington, DC 20555 Docketing and Service Section*
Office of the Secretary U.S. Nuclear Regulatory Connission Washington, DC 20555 ,
IL, l Sherwin E. Turk Counsel for NRC Staff i
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