ML20073E164

Affidavit of J Hausner.* Discusses Facility Offsite Radiological Emergency Planning.W/Certificate of Svc

ML20073E164
Person / Time
Site:	Seabrook
Issue date:	04/19/1991
From:	Hausner J HAUSNER, J.
To:
Shared Package
ML20073E132	List: ML20073E130 ML20073E164
References
OL, NUDOCS 9104300077
Download: ML20073E164 (6)

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I April 19. 1991 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC-SAFETY AND LICENSING BOARD In the Matter of )

) Docket Noa. 50-443-OL pUBLIC SEVICE COMPANY > 50-444-OL OF NEW HAMPSHIRE, et gl. )

) (Offatte Emergency (Seabrook Station. Unita 1 ) Planning Issues) and 2) )

AFFIDAVIT OF JEFFREY HAUSNER I, Jeffrey Hausner, being on oath, depose and say as follows:

1. I am a self-omployed emergency planning consultant with offices in Arlington, _ Massachusetts. I am recognized as_a quellfied professional in the field of off-site radiological emergency planning, having served as diractor of the Commonwealth of Massachusetta' Nuclear Safety Emergency Preparednaan program for more than three years and as the principal consultant to the Massachusetta-Civil-Defense Agency on radiological emergency response planning 1 for three years prior. My_ total, continuous service in these capacities ran from January, 1985 to April. 1991. I.have also had significant education, training,:and other profanaicnal experience in the field of emergency preparedness and response. My professional resume appears as

" Attachment A" to thia' affidavit.

2. I have reviewed'documenta1 relevant to this matter, including; the Official Transcript of proceedings (docket ~No. 60-443-OL and 50-444-OL) pages 28453 to 28499._the statements offthe New Hampshire Attorney General in this matter,-the statements of Director George Iverson of-the New Hampshire Office.of:

Emergency Management in this matter,' ataf f commenta- of - the U.S. Nuclear RegulatoryfCommission-and the Federal Emergency Management Agency'.in this matter, and the licensee's documents relevant to this matter.-including " Licensee"a Response ~to Memorandum and Order of January 24, 1991". I am familiar with sheltering procedures of-the New Hampshire Radiological Emergency Response Plan (NHRERP).

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3. It la understood and accepted that an incident at a l commercial nuclear power facility requiring off-atte protective action la highly unlikely. Yet a severe accident at a commercial nuclear facility has auch dire possible consequences that development of emergency plans and procedures to protect the public from radiological exposure and contamination as a result of euch an event la a federal f licensing requirement.

4. The purpose of protective action la to reduce the ,

radiological done which members of the public might mustain l in a radiological accident. Emergency plans and procedures abould be developed to implement all anticipated protective i actions without regard to the likelihood that any one of those actions would be recommended.

5. Ad hoc emeTgency response la the taking of a protective action in the abaonce of plans and procedules for its implementation. While in any amergency unanticipated actions may howe to be taken which would require ad hoe t emponse, I find no basta for reliance on ad hoc implementation of an amergency action when recommendation of that emergency action can be anticipated. Because implementation oa* one protective action is less likely than implementation of another action dona not relieve emergency plannera of their obligation to prepare as well as possible to implement that enticpated protective action.

6. If a donc reduction can be achieved by aheltering the resident and trannient population in the beach areas of ERPA-A of the Seabrook Station plane exposure emergency planning zone (EPZ), as opposed to sny other protective action. it la essential that emergency plena and procedures be developed to implement the shelter option, regardlema of the likelihood that it will be ordered.

7. It appears that the State of New Hampahlre does anticipate amplementing shelter as a protective action recommendation for the population in beach aream of ERPA-A under certain conditions. While the probability of these date, time of day, vaather, and accident conditions occuring in combination are extremely remote. they are nonethelena conceivable, and ordering ahelter to achieve the greatent done re6uction for the beach population remaina possible.

8. It appears that the NHRERP procedures only provide that all of ERpA-A. which includen beach areas proximate to Seabrook Station, will be ordered to evacuate if shelter la the recoAmended protective action in a rapidly escalating accident at Seabrook Station. This may be inconsistent with implementation of " keyhole" protective actions recommended in NUREO 0654/ FEMA REP 1. The NHRERP does not contain procedures for ERPA-A sheltering.

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! 9. It la my conclusion that plans and procedures should be developed to implement any and all anticipated actions to protect the permanent and tranatent populations of the beach a

areas of ERpA-A in the EP2 of Seabrook Station. Thus, since the State of New Hampshire say une shelter as a protective action under certain conditions, no matter how likely, plans and procedures to implement the shelter option should be 5 developed as a part of the NHRERp.

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10. Therefore. ainee it appears that in the NHRERP shelter la >

anticipated as an action to protect the realdent and transient beach populations of ERFA-A of the Seabrook Ep2 I believe that plana _and procedures should be developed to implement shelter as a protective action to reduce the radiological done that members of these populations could sustain due to an accident at Seabrook Station.

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Af(tant Suffolk County. Massachusetta . April 19. 1991

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The above subscribed Mr. Je#frey Hausner appeared before me_and made oath that he had read t.he forgoing affidavit and that the statementa set forth therein are true to the beat of his j knowledge.

g/(,eior.p x_p u Notary Publ.tc My Commission Expiraat Y [3 y i r

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UNITED STATES OF AMERICA NUCLEAR REGULATORY CONMISSION eM.I ilF

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ATOMIC SAFETY AND LICENSING BOARD Before the Administrative Judges 91 Am 23 P6 :32 Ivan W. Smith, Chairman ,rs !a s mw wv i Dr. Richard T. Cole Ddhi b"h ' ' ' a ta ,

Kenneth A. McCollom

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In the Matter of ) Docket Nos. 50-443-OL

) 50-444-OL

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PUBLIC SERVICE COMPANY 0F NEW HAMPSHIRE, EI AL. )

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(Seabrook Station, Units 1 and 2) ) April 22,f1991

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CERTIFICATE 0F_ SERVICE I,-Matthew Brock, hereby certify that on' April 22, 1991, I made i ,

service of the within Intervenors opposition to Licensees Motion for Summary Disposition by Federal Express as indicated by .(*), by hand ,

! as indicated by (**), and by first class mail tot l

• Ivan W. Smith, Chairman

• Kenneth.A. McCollom-Atomic Safety & Licensing Board 1107 W. Knapp St.

U.S. Nuclear Regulatory Stillwater, OK 740*i5 Commission East West Towers Building -* Docketing and Service '

I 4350 East West Highway U.S.-Nuclear Regulatory Bethesda,-MD -20814 Commission-11555 Rockville Pike Rockville, MD 20852

• Dr. Richard F. Cole Paul McEachern, Esq.

Atomic Safety & Licensing Board Shaines & McEachern U.S. Nuclear Regulatory' Commission 25 Maplewood Avenue East West- Towers Buildin? P.-0.- Box 360-4350 East West Highway - Portsmouth, NH 03801 -

Bethesda, MD 20814 m.

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Robert R. Pierce, Esq. ** Thomas G. Dignan, Jr.1/

Atomic Safety & Licensing Board Katherine Selleck, Esq.

U.S. Nuclear Regulatory Commission Ropes & Gray East West Towers Building One International Place 4350 East West Highway Boston, MA 02110 Bethesda, MD 20814

• Mitti A. Young, Esq.

H. Joseph Flynn, Esq. Edwin J. Reis, Esq.

Assistant General Counsel U.S. Nuclear Regulatory Office of General Counsel commission Federal Emergency Management Agency Office of the General Counsel 500 C Street, S.W. 15th Floor Washington, DC 20472 11555 Rockville Pike Rockville, MD 20852 Atomic Safety & Licensing Robert A. Backus, Esq.

Appeal Board Backus, Meyer & Solomon U.S. Nuclear Regulatory 116 Lowell Street Commission P.O. Box 516 Washington, DC 20555 Manchester, NH 03106 ,

Atomic Safety & Licensing Board Jane Doughty U.S. Nuclear Regulatory Commission Seacoast Anti-Pollution League Washington, DC 20555 5 Market Street Portsmouth, NH 03801 Charles P. Graham, Esq. Barbara St. Andre, Esq.

Murphy & Graham Kopelman & Paige, P.C.

33 Low Street 77 Franklin Street >

Newburyport, MA 01950 Boston, MA 02110 Judith H.'Mizner, Esq. R. Scott Hill-Whilton, Esq.

79 State Street Lagoulis, Hill-Whilton '

2nd Floor & Rotondi Newburyport, MA~ 01950 79 State Street

• Newburyport, MA 01950 Diane Curran, Esq. Ashod H. Amirian, Esq.

Harmon, Curran, & Towsley 145 South Main Street Suite 430 P.O. Box 38 2001 S Street, N.W. Bradford,.MA .01835- .

Washington, DC 20008 Senator Gordon J. Humphrey Senator Gordon J. Humpi; rey U.S. Senate One Eagle Square, Suite 507 Washington, DC 20510 Concord, }nt 03301 (Attn Tom Burack) (Attnt Herb Boynton) q 1/ Hand delivery was'made on April 23,,1991 by 10:00am

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T' i John P. Arnold, Attorney General Phillip Ahrens, Esq.

Office of the Attorney General Assistr.nt Attorney General 25 Capitol Street Department of the Attorney Concord, NH 03301 General Augusta, ME 04333 i'

Jack Dolan George lverson, Director N.H. Office of Emergency Federal Emergency Management Management f- Agency State House Office Park South Region 1 107 Pleasant Street l J.W. McCormack Post Office & Concord, NH 03301 Courthouse Building, Room 442 1

Boston, MA 02109 COMMONWEALTH OF MASSACHUSETTS 4

JAMES M. SHANNON ATTORNEY GENERAL-C 7 .

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Matthew Brock Assistant Attorney General Dopartment of the Attorney General one.Ashburton-Place <

Boston, MA 02108-1698 (617) 727-2200 DATED: April 22, 1991 ,

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