ML20235L433

Informs That FEMA Would Appreciate Opportunity to Discuss Parameters,Time Frames & Other Matters Prior to NRC Making Formal Request for Fema/Regional Assistance Committee Review of Proposed Onsite Emergency Preparedness Plan for Plant

ML20235L433
Person / Time
Site:	Seabrook
Issue date:	09/02/1987
From:	Krimm R Federal Emergency Management Agency
To:	Congel F Office of Nuclear Reactor Regulation
References
NUDOCS 8710050467
Download: ML20235L433 (2)

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, j' Federal Emergency: Management Agency

, / ' W4shington, D.C. 20472 o o b SEP 2 1987:

l MDOPJNDUM FOR: Frank J. Congel .

i; Director, Division of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulation U. S. celear tory Commission FIOM:: ad r

, Assistant Associate Director Office of Natural and Technological Hazards Programs -

l

SUBJECT:

. Participation in Meetings Regarding Propose Seabroo ' Utility l.-

Based' Plan for the Connenwealth of Massachu[sett On several occasions recently, the Nuclear Regulatory Commission '(NRC) has inquired as to' whether or. not the Federal Emergency Management Agency .

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(FEMA) would attend a meeting'of NBC and utility representatives to discuss a proposed Seabrook offsite radiological emergency. preparedness (REP) plan which-may be submitted by Public Service of New Hampshire (PfNH) in lieu of a submittal by Massachusetts. . As we discussed before, aM as stated to you in my memorandum of April 24, 1987, FEMA would appreciate the opportunity.

to discuss the parameters, time frames and other inatters prior to NRC 3 s making.any formal request for FEMA / Regional Assistance Canmittee (RAC) ,

F teview under the provisions'of the joint NRC/ FEMA Memorandum of Under

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standing (M3U). . This type of discussion should also, in our view,' precede any meetirg involving FEMA and utility representatives related to'l) a j

, pixposed utility plan for Massachusetts, .2) submittal to.the FEMA / RAC of 1 any projected plan for review,.and 3) the possible exercising of such a plan.

'In addition, the Shoreham experience has clearly demonstrated that even in the  !

best of. circumstances, there are a number of legal authority issues which 1 temain open regarding a utility-based plan' evaluated under existing guidance ]

and regulations. . Therefore, the preferred approach, would be to have -

i- evaluative stardards ard criteria for a utility-based plan developed and in place before any utility plan is submitted by NRC to FEMA in accordance with the M30.

Also, before initiating 'any utility-based plan review we would like NRC to advise us of any consideration being given to several other risk mitigation )

! features. discussed in' the past including: 1) special design features at 1 L the Seabrook plant such as double containment; and, 2) reduction of plant l operations during the sunmer nonths. Addressing these issues may assist in 1

the tesolution of the so-called " beach population" issue. Further, we

. would want to discuss the impact of the disposition of the propcsed rule

- on the criteria for a utility-based plan review.

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- PDR ADOCK 0500

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Finally, the impact of practical matters bearing on the issue of a Seabrook utility plan review cannot be overlooked. The following issues should be taken into consideration:

1) FEMA Region I workload requirements and priorities and its limited staff are currently devoted to exercises and plan reviews at operating sites

like Pilgrim and Maine Yankee and testinony on the New Hampshire plans for Seabrook. As you know, the Seabrook Atanic Safety and Licensing l Boatr3 (ASIB) offsite hearings are scheduled to resune on September 28,

1987. Of necessity, the same staff will be expected to perform these responsibilities.' The performance of a utility-based plan review would still further reduce the staff resources which can be devoted to operatirg sites. The importance of activities related to public safety for operating sites, in our view, precludes devoting limited staff resources to review a proposed utility-based plan for a nonmperating site in the near term, particularly in the absence of evaluative planning standards and criteria.

2) During the preparation of the FY 88 budget, other options were being considered by the Jtility. Due to the uncertainty surrounding the submittal of offsite plans, FEMA was not able to incorporate tasks related to a utility-based plan into its budget. Thus, the substantial costs associated with reviewing, exercising and litigating a potential Seabrook utility-based plan for Massachusetts have not been planned for in FEMA's budget and were not incetporated in the President's submittal for Fiscal Year 1988.

Based on the abovementioned concerns, it may be advantageous to review the entite subject of utility-based plans. If it is convenient, I would like to meet with you on September 10, 1987, to discuss the items mentioned above, as well as any issues you might want to add to the agenda. To accaiplish our goals as efficiently as possible, I suggest that the meeting also include Victor Stello and other staff as appropriate. Dave McLoughlin and members of the FEMA Headquarters staff would also be available to attend in order to tesolve issues of concern about Seabrook. As you may know, such a high-level meeting was very helpful in resolving litigation issues related to the Shoreham plant.

I will call you in a few days to schedule a firm date, time and loc . tion.

In the interim, should you have any questions, please feel free to contact ne at 646-2871.

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