ML20207C570

Intervenor Exhibit I-State-35,consisting of as Followup to 870605 Conversation Re Current FEMA Position on Contentions of State of Nh Plans for Facility

ML20207C570
Person / Time
Site:	Seabrook
Issue date:	05/26/1988
From:	Eric Thomas Federal Emergency Management Agency
To:	Strome R NEW HAMPSHIRE, STATE OF
References
RTR-NUREG-0654, RTR-NUREG-654 OL-I-STATE-035, OL-I-STATE-35, NUDOCS 8808090287
Download: ML20207C570 (6)

Text

& - W.Jny- a sua QG 1 Federal cmergency M na/gement Ag/n/e Is ency -35 i

4- Region 1 J.W. McCorrnack Post Omce and Coun House a . Bos:on, Massachusetts 02109 WW U% i O JUN i l 1987

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Mr. Richard H. Strone *t 19 P 6 '.04 Director, New Hampshire Civil 4 s

Defense Agency 7h' hp .g fe v State Office Park South DOCd C A 9 V ICI-Concord, New Hampshire 03301 '" %gg 3 \l5 f.ANCH

Dear Mr. Strome:

This is written as a follow-up to our conversation on June 5, 1987, concerning the document "CURRENT FEMA POSITION ON ADMITTED CONTENTIONS ON NEW HAMPSHIRE PLANS FOR SEABROOK." (Hereinafter called Current FEMA Position.) This document was developed as a part of FEMA's responses to interrogatories in the Seabrook Atomic Safety and Licensing Board (ASLB) proceedings. Our discussion I primarily related to that portion of the Current FEMA Position dealing with the beach population which is found at pp. 38-39 and enclosed with this letter. I 1

l Before further discussing that particular section, it might be I worthwhile to quickly review the history of this filing. The i Current FEMA Position was developed as the result of several l actions including the decision of the Atomic Safety and Licensing l Appeal Board (ASLB) made May 1, 1987, and the subsequent l g-) Memorandum and Order issued by the ASLB on May 4, 1987. These ,

(y actions included a specific request that FEMA develop and file a  !

position on the contentions admitted for litigation in the l Seabrook proceedings by June 5, 1987. The Cut.'nt FEMA position l is, therefore, provided pursuant to the FEMA /Nuc ar Regulatory l Commission Memorandum of Understanding cited in 44 CFR 350, 1 Section 350.3(e). However, the Current FEMA Position should not be viewed as a formal "finding" by FEMA under 44 CFR 350.

The Current FEMA Position is largely based upon the FEMA and Regional Assistance Committee (RAC) reviews which were previously provided to you. The portion of the Current FEMA Position dealing with the beach population is based on a thorough analysis by FEMA and the RAC. The issue of protecting the beach population has been an item of discussion between FEMA, the State of New Hampshire, and the applicant for several years. Our position is based on the guidance provided by NUREG-0654, FEMA-REP-1 applied to the Seabrook site.

We believe that our concern about the protection of the beach population revolves around some rather unusual circumstances which may be unique to Seabrook. Demographically, a substantial portion of the peak summer population in the area travel to the beach each day. Unlike other sites we have reviewed, these daily visitors are not identified with a temporary residence or public facility.

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() In addition, many of the summer residences in the area are unwinterized and therefore afford less shelter in the event of an accident than that found in insulated buildings. These circumstances dramatically impact the acceptability of the two primary protective measures, evacuation and shelter. More specifically, the information providad to FEMA indicates that s I

evacuation from the beaches would require approximately 3.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />.  :

Evacuation time estimates are not required to meet some-specific '

standard. The availability of shelter as an option in the more fast-breaking scenarios is considered to mitigate the need for i some hard time objective for evacuation. However, in this case l the sheltering option is also clouded by the absence of sheltering <

for what is even in the more favorable estimates amounts to l several thousand individuals and the absence of apparently )

effective shelter for many others. Thus, the information provided on evacuation and sheltering compounded one another in a manner of individuals that might be involved. I might add that these numbers apparently hold not simply for the worst-case accident, but for a number of lesser scenarios.

A number of options have been mentioned over the past years which may alter the case as we understand it. In addition to our own discussions on the subject, a wide variety of sources have proposed alternatives which include sheltering, seasonal operation of the plant, and alternative evacuation routes. Although f,

sheltering is an alternative, we doubt if the use of existing public or private facilities would be acceptable.

The solution to the problem may be a variety of alternatives due to the complexity of the issue. However, if the facts set forth in the paragraphs numbered 1-3 of page 39 of the current FEMA position are shown to be incorrect or are modified, then our position will be subject to review and modification as necessary.

FEMA will, therefore, be willing to arrange for the review of any modifications to the New Ha'mpshire emergency plans for Seabrook which might impact evacuation time estimates or the sheltering of the beech population. Any modifications of the standard assumptions made about accident release times, duration and probability, as well as the impact due to any altered operational l schedule for the plant come under the purview of the NRC. l l

1 FEMA will soon be developing its testimony for the September ASLB hearing for Seabrook. Given the expected sequence of events, it is this hearing board that will make the first licensing related evaluation of the New Hampshire plan. It would be very useful to l j

all parties to the Seabrook proceeding if you could tell us prior to our filing testimony: (a) if the facts we have discussed and i set forth in the Current FEMA Position are incorrect; (b) if the i I

State of New Hampshire is considering steps which might change these facts, and (c) if you are aware of intentions of anyone else

(}toexerciseoptionsthatwouldchangethefacts.

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l O we outa, or cour e, de never to meet continues to explore its options.

ita vou > se 8 e aire I hcpe that all of us can continue work together to resolve this issue and achieve our mutual commitment to public safety.

Sincerely,  ;

1 81 8meda Edward A. Thomas ,

Chief Natural and Technological' Hazards Division i

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SECNP CONTENTION RERP-8 The New Hampshire RERP does not provide a "reasonable assurance pVhat adequate protective measures can and will be taken in the event of a radiological emergency," as required by 10 C.F.R. 50.47(a)(1). in that the plan does not provide reasonable assurance that sheltering Nor does is an the plan provide "adequate protective measure" for Seabrook. as required tdequate criteria for the choice between protective measures by i 50.47(b)(10) and NUREG-0654. I !!.J.10.m.

l JD% RESPCNSE to Revised Tcwn cf _Ha eton Contention VIII to Revision 2 (of l

the New Ha:*pshire RERP for SeaorcoK) , SAPL Contention 16, and NEUiP Contention l

KEPS-8 l

These three contentions all deal with wnat is fundecentally the sam issue: protection frcn a radiological release for beach-going population l at Seabrook who do not have ready access to any of fective fotTn of shelterire.

This group includes both "day-tripprs to the beach and those persons wPo only l have access to unwinterized or other types of construction which will offer a lesser degree of protection than that of fered by standard residential or camercial buildirgs. 1 i

Backcround - This issue has been of great concecn to FEMA frcrn our l carliest detailed involvement with the preparation of plans and the achieve- l l

ment of a level of emergency preparedness which would achieve our regulatory ,

A(/ standard set for that 44 CFR 350.5 of adequately protecting the public l health and safety by providing reasonable assurance that appropriate l protective measures can be taken offsite in the event of a radiological J emergency at the Seabrook Nuclear Power Plant. , ,

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In December 1985 the State of New Kmpshire suMitted plans for protecting 1 I l the public in the event of an accident at SeabrocA to FD% for review puts suant to 44 CFR 350. Those plans were forwarded for review by the Regional ll l

Assistance Ccmnittee (RAC), an interagency greep established pursuant to 44 CFR 350 to both assist state and local government in the development of  ! l! i radiological emergency response plans and to evaluate the adegaacy of such plans. On Decencer 31, 1985, FD%, as chair of the RAC, requested that i the rembers of the RAC (as well as the other FD% staf f who were reviewirq  !

the New Harpshire Plans) imediately focus on the issue of the protection t !

of beach pcoulation and the occupants of unwinterized acecwodations. This mercrandtn is attached as Appendix C to this response to interrogatories. I, )

i PD% Position - Since the time of cur Deember 31, 1985, ner:orandum .

on the subject of the protection of the public on and near the beaches t l around Seabrook, the State of New Hampshire has refined and inproved its  ; l amergency plans and sutmitted a detailed Evacuation Time Estimate which ,

sheds a considerable arnount of light on this issue. The facts rilevant [

to understandirg this issue are that: ',, !l V

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. 39.

' ' OEC:o CCumICG e _',o-8 (Cont . )

k (1) ne primar,y guidance doctrient used by FEMA and the PAC in reviewing off-s ite emergency plans is NUREG-0654, FEMA REP-1, Rev. 1, a (3 doctrnent jointly developed by fem and the NRC. That guidance V docurrent indicates on p.13 that "(t)he rarge of times between the onset of accident conditions and the start of a major release is of the order of one-half hour to several hours". n is statement is further clarified on p. 17, Table 2 to indicate that (a) the major portion of a release may occur in a ti.me period ranging frcrn as little as one-half hour to one day af ter the release begins and (b) that the travel time of the release to exposure point can range frm one-half hour to two hours at five miles, and one hour to four hours at ten miles.

(2) On peak strrner days there are thousands of beachgoers in the Seabrook EP2 in areas beginning approximately 1.7 miles frm the plant. We current mw Hampshire plans contemplate evacuating the many thousands of beachgoers who have access to no adequate shelter as a protective action in the event of an accident at Seabrook.

We urderstand that the plans contain no consideration of sheltering the "day trippers" because on sumer days when there are a large nunber of these pecple, it is not possible to find reasonably accessible shelter for them. B ere are an additional number of persons who would be in or have access only to shelter in unwinter-ized cottages and trotel rocms. We protection afforded by shelterirn in these structures will definitely be less than that af forded by a norm 1 wocd frame house. .

O (3) he Evacuation Time Estimate for the Seabrook EP2 sutrnitted by the b State of Sw Hampshire iridicates at pp.10-1 et.seo. that in gocd l weather when the beaches are at 60 to 100 percent of capacity it i will take three and one-half hours to clear the beaches, and a ,  !

total of f rcn four hours and fif ty minutes to five hours and -

fif ty minutes to evacuate all the population on the beaches f rom the EP2. In scrne situations such as sudden bad weather follosing a peak stmer day, the total evacuation time for portions of the EP2 l range up to seven hours and fifty minutes. )

Werefore, using the standard guidance for the initiation and duration I of radiological releases, and the current New Hampshire RERP including LTE, '

l it appears that thousands of people could be unable to leave durirn an  !

cccident at Seabrook involvirn a msjor release of radioactivity without i adequate shelter for as much as the entire duration of that release. 6 h erefore, until these issues are resolved even if all the other inadequacies and deficiencies cited in the PAC Mviews of the New Hanpshire Plans, and the Review of the Exercise of these plans were to be corrected, FEMA would i rot be able to conclude that the Nw Kanpshire State and local plans to ,  !

protect the public in the event of an accident at the Seabrcok Nuclear ,

Ibwer Plant are adequate to meet our regulatory standard that such plans  !

• adequately protect the public health and safety by providing reasonable casurar.ce that appropriate protective measures can be taken offsite in the g event of a radiolcgical emergency." (See, 44 Cm 350.S(b)).

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