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- ATTACHMENTS

CHRONOLOGY OF KEY MEETINGS/DISCUSSIONS INVOLVING
NRC AND PSNH AND FEMA STAFF RELATIVE TO REDUCED EPZ

July 30, 1985

NRC/PSNH meeting -- discussion of SSPSA submittal according to NRC this included "the regulatory process including the reassessment of emergency preparedness requirements"

September 9, 1985

NRC/PSNH staff and counsel conference call --
Discussion of a possible rulemaking petition and
idea that a 10-mile EPZ is not necessary at
Seabrook -- based on source term research

October 10, 1985

PSNH counsel, and NRC legal staff discussion -"reduce or eliminate the entire EPZ - Taking Seabrook PRA applying new source term data

Discussion that "once technical analysis is done subject to peer review group ... if the peer review group raves, then sometime in Nov. 1985 will come in with a package"

October 11, 1985

NRC/PSNH staff conference call -- NRC staff notes that feedback about the approach Seabrook was taking on demonstrating the ability to reduce the EPZ appeared to be different from what he understood in an earlier discussion (with PSNH staff)

" (NRC staff) noted that what he explained to (PSNH staff) in previous discussion was that the approach Seabrook will need to take is to compare the risk of Seabrook to the risk of typical reactor (WASH 1400) used as a basis for the regulation. (NRC staff) suggested Seabrook review NU REG-0396 -- in the comparison it would be good to compare feature by feature"

" (NRC staff) said Seabrook should not be developing the case that Seabrook ..." (incomplete note)

October 22, 1985

Seabrook coordination meeting with FEMA, NHY, NH and MA state civil defense staffs - Includes discussion of impact of the probabilisitic risk assessment on emergency planning issues

FEMA staff notes that Brookhaven is reviewing the

t and time-to-failure aspects of the PRA

Discussion of the size of the EPZ and legal
analysis work
Seabrook coordination meeting with PEMA, NHY, NH

Nov ember 26, 1985

72-431 0 - 87 - 2

CHRONOLOGY - 2

and MA state civil defense staffs - Further
discussion of the PRA and impact on emergency
planning issues

December 1985

"Seabrook Station Risk Management and Emergency Planning Study," Pickard, Lowe, and Garrick

February 1986

NUREG/CR-4540, "A Review of the Seabrook Station
Probabilistic Safety Assessment: Containment
Failure Modes and Radiological Source Terms,"
Brookhaven National Laboratories

April 1986

*Seabrook Station Emergency Planning Sensitivity Study," Pickard, Lowe, and Garrick

NRC, PSNH, PL&G meeting to discuss PSA program

July 9, 1986
July 21, 1986

PSNH submits the Risk Management and Emergency
Planning Study (RMEPS) and the Seabrook Station
Emergency Planning Sensitivity Study to NRC for
review

July 25, 1986

NRC staff meeting -- " (PSNH staff) says - before they go for it - give them a reading by October -what are the merits of this piece of work -- does it provide some basis to go forth with exemption" NRC staff notes "What do we (Emphasis added) have to justify to change EPZ? ... need to consider technical and legal" (emphasis in original)

July 29, 1986

PSNH requests that NRC expedite the technical
review of RMEPS as follows:

"A future submittal, depending on the results of the technical review, may request a change to the emergency response plan process for Seabrook Station. We cannot, at this time, specify what action such a future request may seek, but it is important that we address as soon as possible what options are available to us relative to full power licensing. This is important in light of the apparent strategy of the State of Massachusetts to delay the process." (emphasis added)

July 18 or 29, 1986 NRC staff meeting -- " (NHY) wants to know if this

could serve as a technical argument. If not, he won't file. Point out which technical arguments are good vs. no "

"Seabrook has thrown away containment failure"

"Did they include any real data vs. generic -- May have to go back and tidy up PRA, but probably not

CHRONOLOGY - 3

August 5, 1986

NRC Staff and PSNH meeting -- "NRC is beginning an expedited review of the study to assess the technical adequacy of PSNH's analysis to support the study's conclusions."

August 6, 1986

Brookhaven National Laboratories (BNL) compiles project description for Review of the Emergency Planning Sensitivity Study for Seabrook

August 6, 1986

NRC Staff, BNL, and PSNH onsite walk through --
"Objective to reexamine emergency planning basis --
wanted enhanced mathodology for site specific
planning -- determine risk impact of different
options

August 11, 1986

Internal NRC staff memorandum -- "It is important
to decide what direction NRC is going to take on
this issue before a detailed technical review can
start. A decision chart set up in the form of
three questions is attached for your consideration"

August 13, 1986

NRC staff notes -- PSNH request - "NRC will give them top priority ... preliminary review in 3 months - normally takes - out of ordinary"

"Sense of urgency - no discussion of it holding up licensing"

"There are so many options - get rid of Mass. So they don't have to submit" (emph. added)

August 14, 1986

Meeting at BNL with NRC staff and PSNH -- NRC staff notes - "Do review in short period of time to get positive response or questions needed to get there"

NRC staff - "Unique features of Seabrook containment - Let's try to make it more unique show it's better than average (emphasis added)

August 27, 1986

NRC staff and PSNR meeting -- "Review group to (NRC
staff), coordinated with the utility, with a list
of goals ... We need to think about what this group
can do in 3 months"

"What are possibilities -- 3 mile EPZ with plume?

-- l mile EPZ"

"Agenda (What they could do to show they're
different to get credit)" (original '()'l

"Shrinking of planning zone vs. evacuation zone ... may be able to reduce evacuation zone but not planning zone" (emphasis in original)

CHRONOLOGY - 4

August 28, 1986

NRC staff memo outlining staff review plan for
Seabrook EPZ Sensitivity Study:

"Goals of review:

1. To provide a technical assessment of the
adequacy of the Seabrook Station Emergency Planning
Sensitivity Study to support its conclusion that
the degree of public protection afforded by a 1
mile emergency planning radius around the Seabrook
Station is equivalent to the degree of protection
that was perceived for a 10 mile emergency planning
radius at the time the 10 mile generic planning
radius was established in NUREG-0396.

2. In the event it is concluded that the Study does not adequately support its conclusion at the 1 mile radius, to determine the radius at which the study can support a conclusion of equivalent protection."

September 26, 1986

Advisory Committee on Reactor Safeguards (ACRS) Subcommittee meeting -- PSNH staff comments: "Step one was for us to write and submit (the safety assessment). We really need to know the conclusion of the NRC as to our results so that we can move forward. We really can't move forward until we know we have some level of agreement."

PSNH: "We started this effort some time ago because we had been getting indications from the State of Massachusetts that in fact what happened last Saturday night happen ... I am not sure whether we would have done it anyway. But given the fact that we have had some difficulty in Massachusetts prompted us to do this in 1985. If nothing else, it certainly lended a sense of urgency to the situation."

ACRS Member: "Can you go ahead by just agreeing with NRC and FEMA that your plans are okay and Massachusetts can sit up there and suck its thumb all it wants?"

PSNH: "... the exercise in New Hampshire will come
possibly after the decision in Long Island. So we
are going to know before we finish with New
Hampshire whether or not that path is really
viable.

"We are trying to learn from everybody. We want to look at every possible alternative and everything we can do so that we increase our range of options in case one option doesn't work."

CHRONOLOGY - 5

ACRS Member: "How far is the nearest point in
Massachusetts from the plant?"

[blocks in formation]

ACRS Member: "If you had an emergency zone of 2 miles 690 feet you would be in the clear?"

PSNH: yes."

"I think the answer to that question is

October 10, 1986

ACRS full committee meeting

ACRS: "The two reports that we have looked at have
both been reviewed by an outside, independent group
of experts in each case, and these experts
concurred with the results of the findings.
However, when we asked in terms of the containment,
I questioned why there wasn't a containment expert
on the independent review groups, and they pointed
out that the staff, NRC staff, through a contract
with Brookhaven National Laboratory, is reviewing
that aspect. So it will be reviewed."

ACRS: "I would hope the (NRC) staff develops some kind of safety philosophy, if it hasn't, that it uses to guide itself in decisionmaking concerning these matters. ... I'm speaking for my self but let me strongly suggest that you try to develop some, what I'll call general philosophy in this regard, and then some, what you might call generic quantitative guidelines, before trying to make an ad hoc decision on a specific case. "

ACRS: "But let's face it. They wouldn't be
reviewing this PRA at this time if they didn't
think there was something like a change in the
prior guidelines for emergency planning in the
wind. Otherwise, I would like them to tell me why
they are taking time away from other tasks like
finding out how good a mark 2 containment is,
etc. ?"

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