ML20247G538

Intervenor Exhibit I-MAG-59(a),consisting of Summary of Site Visit Re Plant Exercise Program.Consistency Issues Listed, Including Inadequate Evacuation Time Estimates

ML20247G538
Person / Time
Site:	Seabrook
Issue date:	04/12/1989
From:	AFFILIATION NOT ASSIGNED
To:
References
OL-I-MAG-059A, OL-I-MAG-59A, NUDOCS 8905310004
Download: ML20247G538 (4)

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Initial gradedIestreise for this type of situationR(non-pa.rtielpating orgsalaation) would require that $4 of the 35 exereise' objoetives be domeostrated.

Following the exit laterview, NHY senior management (President of NHY),

e-L requested a separate meeting with Mr. Yleker, NRC NQ, and myself. They L

requested a postponement of the graded exerolse for the week of 5/23 to the week of 4/38. Mr. Ytokers suggested that they meet the schedule milestones 4

for 0 4 !/s and scenario submission that I outilned for the exercise process In the esit inte= view in order to allow additional time for coordination, l

review, etc.

I requested Mr. Ylekars to inform Region H of the azeretse date change since it may impact them. I advised him that I would inform FEMA Eq of the esereise data change.

On 2/98, la your absence, I laformed Mr. Sanders (seting for you) of Seatrookt request for change la enereise date, and FEMA RPs concurrence.

I also requested that Mr. Sanders leform you of my concern. regarding I

consistency between the FEMA Review and Evaluation of the seabrook Plan for Massachusetts Communttles and the FEMA Review and Evaluation of the '

Saabrook Plan for New Hampshire.

These concerns are based on the prinelple that PENA HQ had reviewod and eonourred la the identifloation of the inadequaeles for the Seabrook Plan for Masrechusetts Communf tles and the same polley positlen should be eoesistently applied to the review and

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evaluation of the Seabrook Plan for New Hampshire and Maine.

i The " consistency issues" are as follows:

e The Evastation Time Estimates (ETE) study for New Hampshlre is by sones

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0-8 miles, 3-5 miles, and 8-10 miles..The ETE was loged (nadequate for 1

Maassehusetts beesuse the concept of operation of protective action is by community, not sons.

I note that the ETE not only determines evaeustion time settmates for uns in the destelen process, the ETE defines the Traffle Management Plans e.g., Aeoess Control Points (ACP) and Traffle Centrol Folats (TCPk therefore, there are inadequate plans and arrangements to establish ACPs and TCPs for each community. The ETE included beach evacuaties time estimates as part of the sees estiastes, therefore, the eveesatles route and time estimates may be lavalid for Beach Protection Astisit. The evaeustion and time estlastes for New 19mm are

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based on the same The esosept for protective act is by community. Therefore, the Traffle Management Fless are inadequate and the eveesatles time estimates do not provide a deelsion makers to make Protective Action (FAs)ppropriate information for deelsions.

We ident! fled the Seabrook Plan for Massaebusetts preparedness for 8peolal Populations (bandleap, sehools, health feellities, group homes, etc.) as untos e.g., there are not plans on a feellity by faeultF basis as ed in Appendia 4 of NUR30 0454l FEMA REP-1 and OM 31: and la! Populations are treated tbs same as the general puidis. FEMA's guidance speelfles speela! considerations for handicap persons (GM 24) and for school ehudron (GM EV-2). The Seabrook Plan for New Hampshire also does not contain geela! Fopulatloa plans on a faelllty by faellity basis and 8905310004 890412 s

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consider school ehlldren the same as the general publie. I point out that although some FEMA staff consider the GMs to de guidance only, the ageoey's position is that offsite organlaatton plans and preparedness must meet the guidance or the latent of the guidanos (if they those to ignoes the

. appresen specified by FEMA's guidance). Regions de not have the freedom to ignore guidance promulgated by FEMA HQ. If the is not met er the intent not addressed la offsite plan and proper we (FEMA, the Region, and HQ) must identify the review artteria as inadequate.

We identified the Plan for Massachusetts Communities, the preparedness, and concept operation for the Protective Action (PA) for transient peoulation as inadequate e.g., the plan ealled for shelter of the beseh popustions the process to resen the shelter FA caued for a dose projection to be calculated.

Fonewlag Three Mlle Island, federal regulatten and guldense was changed to require auelear power plant operators to maka FARs based on plant statues e.g., de not wait for a release, make a does projection, then a PAR. Appendia 1 of NUREG 0684l FEMA REP 1 must he ecosidered and applied when one reviews J9 and J10M. Part 1 of REP 1 speelfles a keyhole he e.g., a see' area around the faellity out to a distamos of 3 to 5 m

9). Appendia 1 of REP 1 Identiftes a general emergency as plant sendt that' eould result la radioactive release poster than the EPA-Proteetloa Action Guides beyond the site hoendeMes.

Plant conditions Gmergency Astlea levels) should deterslae Emergepey Classified Levels (ECL) and combinations of EAls and ICLs should determias the appropriate FAEs. Note, NRC Lts 11eeeeee to review the EAL + ECL

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• PA concept of opers each estendar year with offsite authorities, thus stresslag the eeneept of operaties of predetermined FAs based on EAL/ECL l

combination. Appendia 1 speelfles that evneustlea should be considered the appropriate FA for a 03 (BCL).

Appendia 1 references shelter as appropriate saly when the duret:en of the release is knowas e.g., contreued venting of containment. I note that NUREG 1818 states that centro 13ed vaaties of anatalamant may not be a viable option staos there le no assuranee that valves een be elesed enee they are opened. Therefore, with the easeption of a sostroued sentalament vesting eltuation, evaesstion is the only appropriate PA for a GB (ECL). 'Iberefore, a PA of sheltering toe transleet and permanent populatten withis a distaneo of 2 to 5 muss is inadequate as a FA. Neto, in view of the feet that transleet population is prehably unlaformed of the emergency plan, ANg, eveeustles restes. etc,1 nave adreested that pressutionary erseenties (at a ECL lower than that for permanent populatten)is the only appropriate FA for transient population.

J9 and 214M must be reviewed la the contest of 1 of NURBO 9684) FEMA REP 1. Therefore, the current New He proposal should be evalented as inadequate.

I would like to point out thet the subjoet of techsleal assistanse was not discussed by NRY. FEMA Headquarters and the Regiae ! Regional Director had autha?lsed and eemetreed in the concept of provedtag teobaleal l

assistanee to NRY. NRC Esadquarters stated that they cosaldered the 1/SS/84 (NRC to FEMA) meme as aethertsing techsleal assistanos sad they strongly enseureged me to be responsive to any requests from NHY. Maoe I talk daily to the NRC Heeskparters Seabrook project manager or his staff, our esordinaties and comm'alestion hos been aseellent.

Mr. Ylekers stressed the feet that he supeets me to be communlestire with NHY and ces in *cc te.e6 emee,:.eee e.--

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_y that he does not want commonloation to be a problen.. Consequently, I, NRC. Needguarters, and NHY have eschanged schedules, fax telephone numbers, and we discuss items and lasues on a daily basis. - Note: The FEMA

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l' manus 1. for orgaalaaties responsibility ass'gns the Regional Director the responsibility to develop and maintala pregeredness for toehnological and naturst emergeneles for State and leeal government, publie and private organizations, and the geners! public, thereby autherising sentact with putnte and private organization.

In eenelusion, my site visit was positive and tive. I have developed an i

eseellent relationship with NRC Rt end NRC NQ s

, and a good working relat:enship with the staff of NNY.

NRC RI and FEMA RI wiu soordinate and implement the esereise process as presortbed in GM17 (or RK4 when it is distributed). I stron encourage you and your staff to address the above psference ocasisteney issuem e. g g.,

sinos your staff cosmwred 'I the review and evaluation of the Seabrook Plan for Masseehusetts Communities, the same palley principles should apply to the review and evaluation of the sealwook Plan for New Hampshire.

If you have may questions, please cau.

ees Henry Viekers, RD FEMA Region !

Elehard Erlem, stent William Curning,00C Joe Eauer,INEL Ed Tamaman, ANL

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