ML20071A232

Affidavit of Ja Macdonald Supporting Twentieth Motion for Summary Disposition of Contention Necnp III.2.Radiological Emergency Plan Adequate.Certificate of Svc Encl

ML20071A232
Person / Time
Site:	Seabrook
Issue date:	02/11/1983
From:	Macdonald J YANKEE ATOMIC ELECTRIC CO.
To:
Shared Package
ML20071A209	List: ML20071A208 ML20071A232
References
NUDOCS 8302180475
Download: ML20071A232 (5)

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AFFIDAVIT OF JAMES A. MACDONALD ON NECNP III.2

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I JAMES A. MACDONALD, being on oath, deposes and says as follows:

1. I am Manager of the Radiological Protection Group, employed by Yankee l Atomic Electric Company. My professional qualifications appear in the Operating License Application (FSAR Chapter 13).

2. The Seabrook Station electric power systems design and design basis of structures, systems and components important to safety for protection against natural phenomena meet the requirements of GDCs 2 and 17 of 10CFR50, Appendix A. The connection of these design considerations and bases with the Radiological Emergency Plan is unclear.

The Radiological Emergency Plan (REP) establishes the means for initial emergency response by on-site station personnel, notification of off-site authorities and augmentation of the on-site staff with the remainder of the company emergency response organization as described in Section 8 of the REP. The implementation of emergency response actions by the emergency response organization is indeed geared to an emergency condition or conditions at either of the two units or both simultaneously. The major response functions of emergency classification, off-site authority notification, company emergency response personnel notification and activation, on-site accident diagnosis and prognosis, and off-site radiological condition assessment and protective action recommendation are all performed regardless of the type of accident and whether one or both units are af fected.

A point-by point analysis of the 10CFR50.47(b) bases cited for this contention is as follows:

50.47(b)(1) As stated above, the REP addresses station emergency conditions - regardless of whether more than one unit at the site is affected. The principle off-site consideration to be made by the emergency response organization is whether the accident condition (s) produces or has the potential to produce off-site radiological consequences for which consideration of public protective action is necessary. The station emergency response organization and those of of f-site authorities are geared to satisfy this principle function.

An off-site radiological threat from one unit would be sufficient for off-site authorities to implement public protective action. A simultaneous threat from the second unit would be met with the same response.

50.47(b)(2) The Shift Superintendent is notified by inr or both Unit Shift Supervisors. Based on the information on existing conditions provided to the Shift Superintendent, he makes a determination of the emergency classification and assumes the responsibility to make off-site authority and company emergency response personnel notifications. Two people are not only not necessary for this step, but would be a detriment. One and only one person on shift must be charged with the responsibility for relating site conditions, especially abnormal and emergency, to all remaining shif t and nonshif t personnel and off-site authorities.

8302180475 830214 PDR ADOCK 05000443 O PDR

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As stated earlier, the emergency response organization is geared to site emergencies - one or both units. No duplication is necessary or advisable.

50.47(b)(3) As indicated throughout the above discussions, the ,

emergency response organizations - both on-site and off-site - would '

respond to an emergency at the station site - whether one or both units were affected. The technical capacity required of response groups is the same.

50.47(b)(4) If the emergency response organization is geared to handle simultaneous emergencies in both units - as it is - then it can handle an emergency in one and a " minor impairment" in the other, simultaneously.

50.47(b)(6) As indicated earlier, the Shif t Superintendent is solely responsible for state police notification. He obviously only requires one communication link for this action, and inter-unit confusion is avoided by this plan arrangement. Each Unit Shift Eupervisor and staff can concentrate on emergency condition mitigation and termination at their respective unit.

i 50.47(b)(7) First, the Technical Support Center (TSC) personnel do not disseminate emergency information to the public (see Radiological Emergency Plan, Section 8.2.2.15). Second, the REP establishes an organizational chain of command whereby the TSC personnel report to the Emergency Director. This would be the case for both single unit and dual unit emergencies. This is how each TSC function is indeed coordinated.

50.47(b)(8) The emergency facilities described in Section 6 of the REP are all, with the exception of the dual Technical Support Centers, singly established facilities for emergency response organization implementation for emergencies at the station site - one or both units. The TSCs are duplicated so the shif t personnel for each unit can be assisted by a support staff dedicated to each unit and the emergency difficulties each may be experiencing.

50.47(b)(9) First, the regulation cited does not state that the Applicant's emergency plan must " provide for radiological monitoring equipment with a sufficient range of measurement to identify the full amount of radiation which could be released in a core melt at both units of the Seabrook reactor". Rather, it states the need for

" Adequate methods, systems, and equipment for assessing and monitoring actual or potential off-site consequences of a radiological emergency condition. . .".

Second, the radiological assessment capability at Seabrook Station is described in Section 6.2.2 of the REP. More detail is available in Section 12.3.4 of the FSAR. This information demonstrates the regulatory requirement is set.

50.47(b)(10) Emergency Planning Zones are established in accordance with 10CFR50.33(g). The Seabrook Station EPZ has been established l accordingly.

, 50.57(b)(ll) As indicated in Section 10.4.4 of the REP, each emergency center will be equipped with the radiation protection gear necessary for the emergency response organization personnel assigned to duty in that center. In accordance with the regulation, the REP establishes (see Table 10.2 of the REP) emergency dose limits in accordance with the EPA Emergency Worker and Lifesaving Activity Protective Action Guides.

50.47(b)(13) As indicated in Section 12.2.4 of the REP, general plans for establishing the Recovery Organization are specified - all that is prudent beforehand and the regulation requires.

50.47(b)(15) As indicated in Section 12.2 of the REP, the Seabrook Station emergency planning arrangements include a training program for each and every member of the emergency response organization - as the regulation requires. This training of these personnel in their emergency response roles prepares them for site emergency situations - one or both units.

Based on the above, I feel there is no issue relative to NECNP III.2 on which factual hearings are warranted.

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.$rtines A. MacDonald COMMONWEALTH OF MASSACHUSETTS Middlesex, as February 11, 1983 Then appeared before me the above suscribed James A. MacDonald and made oath that he was the author of the foregoing affidavit and the statements set forth therein are true to the best of his knowledge, f -

'(pfndM, Jr. ,gotary Public

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Allen L i Hy Co sion Expires August 5, 1988

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CERTIFICATE OF SERVICE I, Thomas G. Dignan, Jr., one of the attorneys for the Applicants herein, hereby certify that on February it, 1983, I made service of the within " Applicants' Twentieth Motion for Summary Disposition (Contention NECNP III.2)," by mailing copies thereof, postage prepaid, to:

Helen Hoyt, Chairperson Rep. Beverly Hollingworth Atomic Safety and Licensing Coastal Chamber of Commerce Board Panel 209 Winnacunnet Road U.S. Nuclear Regulatory Commission Hampton, NH 03842 Washington, DC 20555 Dr. Emmeth A. Luebke William S. Jordan, III, Esquire Atomic Safety and Licensing Harmon & Weiss Board Panel 1725 I Street, N.W.

U.S. Nuclear Regalatory Commission Suite 506 Washington, DC 20555 Washington, DC 20006 Dr. Jerry Harbour E. Tupper Kinder, Esquire Atomic Safety and Licensing Assistant Attorney General Board Panel Office of the Attorney General U.S. Nuclear Regulatory Commission 208 State House Annex Washington, DC 20555 Concord, NH 03301 Atomic Safety and Licensing Roy P. Lessy, Jr., Esquire Board Panel Office of the Executive Legal U.S. Nuclear Regulatory Commission Director Washington, DC 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555 Atomic Safety and Licensing Appeal Robert A. Backus, Esquire Board Panel 116 Lowell Street U.S. Nuclear Regulatory Commission P.O. Box 516 Washington, DC 20555 Manchester, NH 03105

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Philip Ahrens, Esquire Edward J. McDermott, Esquire Assistant Attorney General Sanders and McDermott Department of the Attorney Professional Association General 408 Lafayette Road Augusta, ME 04333 Hampton, NH 03842 David L. Lewis Jo Ann Shotwell, Esquire Atomic Safety and Licensing Assistant Attorney General Board Panel Environmental Protection Bureau U.S. Nuclear Regulatory Commission Department of the Attorney General Rm. E/W-439 One Ashburton Place, 19th Floor Washington, DC 20555 Boston, MA 02108 Mr. John B. Tanzer Ms. Olive L. Tash Designated Representative of Designated Representative of the Town of Hampton the Town of Brentwood 5 Morningside Drive R.F.D. 1, Dalton Road Hampton, NH 03842 Brentwood, NH 03833 '

Roberta C. Pevear Edward F. Meany Designated Representative of Designated Representative of the Town of Hampton Falls the Town of Rye Drinkwater Road 155 Washington Road Hampton Falls, NH 03844 Rye, NH 03870 Mrs. Sandra Gavutis Calvin A. Canney Designated Representative of City Manager the Town of Kensington City Hall RFD 1 126 Daniel Street East Kingston, NH 03827 Portsmouth, NH 03801

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