ML20059B872
| ML20059B872 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 08/22/1990 |
| From: | Kwiatkowski D Federal Emergency Management Agency |
| To: | Congel F Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 9008300131 | |
| Download: ML20059B872 (4) | |
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e Federal Emergency Manage' ment Agency Washington, D.C. 20472 l
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Mr. Frank J. Cornel Director, Division of Radiation Protection ard Drengency Preparedness Office of Nuclear Reactor Regulation Nuclear Regulatory Ccunission Washington, D.C.
20555 Dear Mr. Congel This is in response to your letter of August 3, 1990, requesting that the Poderal Diergency Managenent Agency (FD4A) adc'ress certain allegations contained.in a July 20, 1990, letter fran Mr. Michael C. Sinclair to Judge Ivan W. Smith, Chainnan of the Seabrook Atmic Safety and Licensing Board (ASLB). Mr. Sinclair alleged deterioration in New Hampshira's onengency response capability in the event of a radiological e:tergency at Seabrook, as a result of reduced staffing. As you know, an August 6, 1990, affadavit fram Mr. Sinclair concerning the same issue was attached to the August 7,1990, Motion to Roopen the Record filed by the Seabrook Intervenors.
We have provided to the Nuclear Regulatory Ccmnisnion Of fice of General Counsel the enclosed affadavits and report from FD4A Region I which describe both steps taken by FD4A to address the allegations made by Mr. Sinclair, both in August 1990 ard in April 1990, when Mr. Sinclair first raised the issue in a brief conversation with the Seabrook Rogional Assistance Cmunittee Chainnan. Based on 1) New Hanpshire's procedures for, ard dmonstrated performance in, maintaining staffing and training rosters and 2) the nunbors of personnel currently available to respond to a radiological emergency at Seabrook under the New Hanpshire Radiological Diengency Rosponse Plan, FEMA continues to conclude that staffing is adequate to enable New Hampshire to carry out its plan.
If you have any questions, please feel free to contact nu at 646-2871.
Sincerely,
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DennisH.Kwiatkbki Assistant Associate Director Office of Natural and Technological Hazards p>, o u...
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Enclosures 9008300131 000822 PDR ADOCT 05000443 d1 F
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Comnission:
Kenneth M. Carr, Chairman Thomas M. Roberts Kenneth C.
Rogers James R. Curtis Forrest J. Remick
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In the Matter of
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Docket No. 50-443-OL Public Service Co. of New Hampshire,
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50-444-OL et al.
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Offsite Emergency
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Planning Issues (Seabrook Station, Units 1 & 2)
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August 21, 1990 AFFIDAVIT OF JOHN C.
DOLAN John C. Dolan, af ter first being duly sworn, deposed and says; 1.
I am John C.
Dolan, Chief of the Technological Hazards
- Branch, Natural and Technological Hazards
- Division, Federal Emergency Management Agency (FEMA),
Region I,
- Boston, Massachusetts. 'I am Chairman of the Regional Assistance Committee, established under 44 C.F.R. 351.10(b).
2.
On August 6, 1990, George Iverson, Director of the New Hampshire Office of Emergency Management (NHOEM), wrote to Richard Strome, Regional Director of FEMA, to invite FEMA Region I to review New Hampshire's staffing records in response to the af fidavit of the same day by Michael Sinclair.
Also on August 6th, FEMA received a. request from the Nuclear Regulatory Commission (NRC) Staff to investigate the concerns raised by Mr. Sinclair's affidavit and Motion to Roopen the Record filed by the Seabrook Intervenors.
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3.
On August 16, 1990, I visited the offices of NHOEM in Concord, New Hampshire, along with Joseph Austin, of my staff.
We examined the staffing rosters under the New Hampshire Radiological Emergency Response Plan (NHRERP) and discussed with the NHOEM staff the procedures they used to update those rosters.
As of the close of business August 16, 1990, there were only three vacancies among the 1263 positions needed to staff the NHRERP in the Plume Emergency Planning Zone.
4.
Following the visit to the offices of NHOEM, I prepared a report for the Regional Director of FEMA Region I, which has been forwarded to NRC Staff in response to their request received on August 6.
A copy of that report is attached to this delcaration as Exhibit A.
In the report I have set forth accurately the steps that Mr.
Austin and I
took to investigate Mr.
Sinclair's allegations and the information gleaned from inspection of the records of the NHOEM.
The conclusion expressed in that report is that staffing is adequate for implementation of the NHRERP for Seabrook.
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DOLAN V
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August 21, 1990
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L at Boston, Massachusetts l
Subscribed and sworn to before me this M/4/ day of August 1990.
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Federal Emergency Management Agency Region ! J.W. McCormack Post Office and Coun House Boston, Massachusetts 02109 4
August 21, 1990 l
MEMORANDUM FOR:
Grant C. Peterson Associate Director State and Local Programs and support FROMt h
Richard H. Strou 9
Regional Director FEMA Region I
SUBJECT:
staffing Levels Under the New Hampshire Radiological Emergency Response Plan l
This is to describe steps taken by Federal Emergency Management Agency Region I to address concerns raised in the August 6,
- 1970, affidavit of Michael C. Sinclair related to staffing to respond to a radiological emergency at the Seabrook Nuclear Power Station under the New Hampshire Radiological Emergency Response Plan (NMRERP).
In his affidavit and in his July 20, 1990, letter to Atomic safety and Licensing Board Judge Ivan Smith, Mr. Sinclair expressed the concern that expenditure reductions instituted for the State of New Hampshire in February 1990, including employee layoffs and a hiring freeze, had caused staffing of emergency response positions under the NMRERP to fall below minimum acceptable levels.
On August 6,
- 1990, George Iverson, the, Director of the New Hampshire office of Emergency Management (NHOEM), requested FEMA to review the New Hampshire staffing records.
We also received on August 6, 1990, a request from the Nuclear Regulatory Commission (NRC) to examine the questions raised by Mr. Sinclair.
on August 16, 1990, Jack Dolan and Joseph Austin of FEMA Region I visited the office of N!!OEM to examine the rosters of personnel assigned as responders under the NRRERP and discuss procedures used to update personnel resources data.
Infomation in the rosters is current as of August 16, 1990, as a result of an updated personnel resources assessment performed by the staff of NHOEM in cooperation with the staff of New Hampshire Yankee (NNY).
The asnessment shows a total of 1263 positions needed to staff the NMRERP in the plume Emergency Planning Zone (EP2), including both the State and local level, for two shifts.
The number increases to 1312, if host community activities are included.
The results of the assessment reveals that only 3 of these positions have vacancies as of close of business August 16, 1990.
A vacancy in the position of Health officer in the Town of Exeter was filled on the afternoon of August 1'
16, 1990.
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4 The three current vacancies are in the following positionst 1) the second shift Joint Telephone Information Center Media Relations / Rumor Control Supervisor, 2) the Town of Ki~gston second shift RADEF officer and 3) second shift Governor's Media Center Representative.
Efforts are being made to fill these positions in 1
an organized manner, as part of the ongoing staffing maintenance
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procedures.
In. compliance with FEMA periodic requiremente under Guidance-Memorandum PR-1, New Manpshire submitted its Annual Letter of certification (ALC) on January 31, 1990. This contained a detailed report on staffing and training records and was reviewed by the Seabrook Regional Assistance Committee Chairman prior to the issuance of FEMA's February 1990 updated review and evaluation of Revision 3 of the NHRERP.
t Since June 1988, FEMA has followed a :program of reviewing, about every 6 months, the staffing and train;.ng rosters specified in the NHRERP.
Prior to issuance of the February 1990 review, FEMA had also reviewed New Hampshire's procedures for reviewing and maintaining training and staffing resources under the NMRERP.
Under New Hampshire's procedures, the staffing rosters listing i
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- names, and home and business telephone numbers of emergency response personnel are updated quarterly.
This process, described in more detail below, also provided the information for guarterly updates to the NMRERP Emergency Phone Listing, The NHCEM verifies the accuracy of the rosters of personnel from i
State agencies.
They verify their own roaters, then call the t
designated point of contact at each State agency to verify those rosters.
Sometimes, NHOEM verifies host community rosterst at other times, NHY personnel perform the verification.
Other miscellaneous Government and private agencies are also called by NHOEM.
Among these
- are, for
- example, Federal Aviation p
Administration, private resource providers with which there are J
1etters of agreement, the American Red Cross, Civil Air Patrol, etc.
The rosters of communities in the plume EPZ were verified by NNY Community Relations personnel who took the roster to the Emergency Management Director or Town Clerk of the community.
The local officials updated the rosters and telephone numbers and returned them to the NHY Community Relations Officer.
NHY personnel spot checked names and telephone numbers and, upon completion, forwarded the updated rosters to NHOEM.
New Hampshire also maintains computerized records of the specialized training received by its responders.
The computerized database is updated subsequent to the completion of training sessions to reflect the training received by each responder.
Based on 1)
New Hampshire's procedures for, and demonstrated
.. e o
performanoe in, maintaining staffing and training rosters and 3)'
' the numbers of personnel currently available to respond to a radiological emergency at seabrook under the NMRERP, FEMA continues to conclude that the staffing is adequate to enable New Hampshire to carry out its plan.
In our view, three vacanoics in-1312 positions, as identified above, reflect normal changes V.ich would take place within any organisation of the size of the response corps" called for by the NHRERP.
a If you have any questions about this information, please feel free to call me at FTS 22369540.
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i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Commission:
Kenneth M. Carr, Chairman Themas M. Roberts Kenneth C. Rogers James R. Curtis Forrest J. Remick
]
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In the Matter of
)
)
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Docket No. 50 443 OL.
i 1
Public Service Co. of New Hampshire,
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50 444 OL et al.
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Offsite Emergency
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Planning Issues (Seabrook Station, Units 1 6 2)
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August 22, 1990
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AFFIDAVIT OF RICHARD W. DONQyg[
i Richard W. Donovan, having been duly sworn, does declare:
1.
I am Richard W. Donovan, Radiological Emergency Preparedness (REP) l Program Manager for the Federal Emergency Management Agency (FEMA), Region X, Bothell, Washington. Until August 3, 1990, I was FEMA Region I Regional Assistance Committee Chairman for Seabrook.
2.
On April 26, 1990, I was visiting the offices of New Hampshire Yankee for the purpose of visiting a designated congregate care center, discussing.
.:i Seabrook Plan for Massachusetts Communities (SPMC) plan review items, and gathering data as part of my final review, evaluation and findings for the Seabrook Alert and Notification System (ANS).
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I 3.
Mr. Michael Sinclair was also at NHY offices at tha; time end he asked t
i to speak to me briefly as I was leaving the bauf offices.
Mr. Sinclair act;ed ne if I was aware of the impact of the New Hampshire Covernor's freeze on the State.
I indicated that I was aware that certain planning positions in the New Hampshire Office of Emergency Management (NHOEM) and the Division of Public Health and Services (DPHS) were vacant. He stated that the impact of the freeze, in his opinion, was Breater. He did not, to my recollection, indicate any percentage shortfall. He asked if I would look into the staffing situacion.
4.
I replied that FEMA was aware of the freeze, that I had previously discussed the impact with the State of New Hampshire, and that New Hampshire had indicated the freete impact was only affecting certain REP planning positions
[as distinct from emergency response positions).
I pointed out that my tenure as Seabrook RAC Chairman was coming to an end shortly (May 30] and that I had I
only one more trip planned in two weeks for the FEMA ANS acceptance test.
l indicated that FEMA had its normal verification process, that is, review of staffing and training rosters and a scheduled Seabrook exercise for December 1990.
5.
Following this conversation, I visited NHOEM's of fice in Concord, N.H.
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I met with NHOEM staff and discussed the following subjects:
status of REP contracts between the utility (NHY) and the State to fund positions, conduct REP training and maintain preparedness; whether the freeze was affecting the State's capability and preparedness program; and the State's expectations on how long the freste was going to last.
Declaration of Richard W. Donovan, page 2.
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e-3.
Mr. Michael Sinclair was also at NHY offices at that time and he asked to speak to me briefly as I was leaving the NHY offices.
Mr. Sinclair asked me if I was avere of the impact of the New Hampshire Covarnor's freeze on the State.
I indicated that I was aware that certain planning positions in the Now Hampshire Office of Emergency Management (NHOEM) and the Division of Public Ilealth and Services (DPHS) were vacant.
He stated that the impact of the i
freeze, in his opinion, was greater. lie did not, to my recollection, indicate any percentage shortfall. He asked if I would look into the staffing situation.
4.
I replied that FEMA was aware of the freeze, that I had previously j
discussed the impact with the State of New Hampshire, and that New Hampshire had indicated the freeze impact was only affecting certain REP planning positions j
[as distinct from emergency response positions).
I pointed out that my tenure as Seabrook RAC Chairman was coming to an end shortly [May 30) and that I had only one more trip planned in two weeks for the FEMA ANS acceptance test.
I indicated that FEMA had its normal verification process, that is, review of staffing and training rosters and a scheduled Seabrook exercise for December 1990.
5.
Following this conversation I visited NHOEM's office in Concord, N.H.
I met with NHOEM staff and discussed the following subjects:
status of REP contracts between the utility (NHY) and the State to fund positions, conduct REP l
training and maintain preparedness; whether the freeze was affecting the State's capability and preparedness program; and the State's expectations on how long the freeze was going to last, w:
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6.
NHOEM staff confirmed that:
A.
Certain REP planning positions (as distinct from emergency response positions) were vacant as a result of the freeze; B.
These ' freeze related vacancies" did not affect the State's ability to staff the New Hampshire Radiological Emergency Response Plan (NHRERP);
C.
New Hampshire Yankee had indicated that monies would be provided In IT 91 (7/90 to 6/91) to meet all State and local governments' request to maintain planning and preparedness; and D.
The freeze was expected to be removed within the next two months.
7.
I had completed an extremely thorough plan review and evaluation of the NHRERP in February 1990. As part of the process, I reviewed the New Hampshire i
Annual Letter of Certification (ALC) that was submitted on January 31, 1990.
The ALC contains a report on staffing and training records.
I compared this January 1990 report with my records and the report submitted to me in the fall 1
of 1989. The January 1990 report was representative of the stafting rosters 1
maintained by New Hampshire and clearly indicated that adequate staff had been i
designated and trained for their assignments in the NHRERP.
l 8.
As a result of my interviews with NHOEM staff and reviews of their records I concluded that the small number of vacancies that existed did not
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N.
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Richard W. Donovan l
Subscribed and sworn to be E
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day of August, 1990.
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