ML20081F617

Response to Interrogatories Re Draft State of Nh Radiological Emergency Response Plan.Certificate of Svc Encl.Related Correspondence

ML20081F617
Person / Time
Site:	Seabrook
Issue date:	10/27/1983
From:	Swiren B Federal Emergency Management Agency
To:	SEACOAST ANTI-POLLUTION LEAGUE
References
ISSUANCES-OL, NUDOCS 8311030157
Download: ML20081F617 (9)

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%......----~~L g UNITED STATES NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY LICENSING BOARD

'83 0 31 g In the Matter of [I~];Q. ?.,,g f D.

PUBLIC SERVICE COMPANY OF Docket Nos. 50-443 OL 5:uilc"f NEW HAMPSHIRE, et al. 50-444 OL (Seabrook Station, Units 1 and 2)

FEDERAL EMERGENCY PANAGEMENT AGENCY'S RESPONSE TO SAPL INTERR0GATORIES Interrogatory 1 Please identify and produce all documents within the possession, custody, or control of the Federal Emergency Management Agency (hereinafter " FEMA")

which contain or refer to any actual or potential revisions or additions to the draft New Hampshire Radiological Emergency Response Plan submitted to FEMA (a) on or about May 12,1983 (hereinafter "the RERP"), including but not limited to any documents relating or refering to the Governnor of New Hampshire's legal authority to order a particular response, including evacution, (b) the 24-hour per day capability .of emergency response personnel to monitor doses received by emergency personnel during a radiological emergency, (c) provisions for d: contamination of emergency personnel wounds, supplies, instruments, and equipment during a radiological emergency, including provision for a means of waste disposal of low level radioactive waste products resulting from such decontamination, and (d) specification of protective measures to be used for the ingestion pathway, including methods for protecting the public from l censumption of co7taminated food stuffs. This includes any identification of procedures for detecting contamination, for estimating the dose committment consequences of uncontrolled ingestion, and for imposing protection procedures such as impoundment,- decontamination, processing, decay, product diversion, and preservation.

Response to Interrogatory 1 (a) Draft New Hampshire Radiological Emergency Response Pl an , dated f

January 18, 1983.

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_ (b) Final Draft of Appendix E, Emergency Planning Zone Evacuation Time Study, dated July 1983.

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• Interrogatory 2 In the opinion of FEMA, does the State of New Hampshire currently have adequate resources within the state to implement the state RERP in such a way that it meets the NUREG-0654, FEMA REP. 1. Rev. 1, Planning Standard J.11.,

-Planning Standard K.5.b., and 10 C.F.R. - 2.47(a)(1) as it relates to those applicable NUREG-0654 Planning Standards.

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R2sponse to Interrogatory 2 FEMA has not formed an opinion at this time as to the adequacy of State resources to implement protective measures for the Seabrook ingestion pathway.

Similarly, FEMA has not. formed an opinion at this time concerning the adequacy of the State's ability -to provide for emergency worker decontami'ation. n FEMA has asked the State tio provide more detailed information- regarding

- capabilit'ies in the above areas in the _ June 23,1983 preliminary comments on the New Hamp' shire State Plan with respect to Seabrook. An assessment will be made at such time as these materials are provided.

Interrogatory 3 If.your answer to interrogatory 2 was in the -negative regarding any areas of emergency response capability referred to, is it FEMA's position that the necessary additional resources can be procured on a timely basis from outside the If so, identify the types, quantities and sources of all such additional State?

resources and specify the time in which they .will be available to the State following its request therefore. Identify and produce all documents and infor-mational sources upon'.which you rely in' support of our answers.

~ Response to Interrogatory 3 As indicated in the response to Interrogatory 2, FEMA has requested additional information from the State in order to determine whether or not the State'does have adequate resources. In tha event that additonal resources as rtquired from outside the State, there are two primary sources which would be available. One is the New England Compact on Radiological Health. Protection,

, which the New Hampshire legislature has ratified. See, N.H. Revised Statutes

1. L Chapter 125-B. LThis compact provides 4r assistance through the sharing of

-rasouces, both personnel and equipment, in radiological health matters, includ-

.ing incidents at commercial nuclear power plants.

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The other outside source would be assistance from the federal government through the Federal Radiological Monitoring and Assessment Plan. Under this plan, federal resources in the areas of radiological accident assessment, dose monitoring, environmental sampling, food protection, etc. would be ava'ilable to supplement a State's resources.

The federal agencies involved are; the Federal Emergency Management Agency, the Nuclear Regulatory Commission, Department of Energy, Department of Agricul-ture, Department of Commerce, Department of Defense, Department of Health and Human Services, Department of Transportation, Environmental Protection Agency, and the National Communications Systems. The specific responsiblities of these agencies can be found in the 45 Fed. Reg. 84910 (Dec. 23, 1980).

Interrogatory 4 In the opinion of FEMA, does the NHRERP meet the requirements of 10 C.F.R. 50.47(b)(11) and NUREG-0654 K.5.b. and has it made a sufficient showing that the means for _ radiological decontamination of emergency personnel, wounds, supplies, instruments, and equipment have been established? Furthermore, is FEMA satisfied that there has been a showing that there exists a means for waste disp > sal? Whether the response is in the affirmative of negative, state the basis for your answer in detail, describing the documents and informational sources upon which you rely.

Response to Interrogatory 4 Section 2.7.5 of the New Hampshire State Plan, in conjunction with the DPH decontamination procedure in Appendix H, describes the State's plan for decontamination of emergency workers, their vehicles and equipment. Section 2.8.'4 provides for medical treatment associated with radiation exposure.

However, the State has not provided FEMA with sufficient details for an assessment of State capabilities and resources in the area of radiological

. decontamination for emergency personnel and equipment. FEMA has requested more detailed information from the State in this area per our June 23, 1983 prelimin-ary comments on the NHRERP in respect to Seabrook.

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Interrogatory 5 In the opinion of FEMA, does the NHRERP make an adequate showing that 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day capability exists to determine the dores received by emergency personnel as required by NUREG-0654 K.3.7. Whether your response is affirmative or negative, cite in detail the documents or informational sources upon which you rely. ,

Response to Interrogatory 5 Section 2.7.2 of the State Plan provides for emergency workers to receive both low range and high range self reading dosimeters, along with a permanent record dosimetry device (TLD). The State DPH is responsible for monitoring emergency worker exposure and maintaining exposure records.

Section 3.2. of the State Plan provides for NHCDA to conduct training for emergency workers including the area of radiological exposure control.

However, until equipment availability and training of emergency workers in its use can be assessed, FEMA cannot form an opinion on the adequacy of the State's capability in this area.

Interrogatory 6 In the opinion of FEMA, does the NHRERP meet the criteria set forth in "

NUREG-0654 J.11. , as well as 10 C.F.R. 50.47(b)(10)? In particular, does the NHRERP, in the opinion of FEMA, provide the criteria for deciding whether dairy animals should be put on stored feed? Does the plan identify procedures for detecting contamination, for estimating the dose committment consequences of uncontrolled ingestion, and for imposing protection procedures such as impound-m:;nt, decontamination, processing, decay, product diversion, and preservation?

Does their exist, to FEMA's knowledge, maps for recording survey and monitoring data, key land use date (e.g., farming), dairies, food processing plants, water sheds, water supply intake and treatment plants and reservoirs? Are such maps included in the NHRERP? Does, in the opinion of FEMA, tne NHRERP make provision for maps showing detailed crop information that may be used including referencing to their avaialbility and location?. If so, do such maps start at the facility and include all of the 50 mile ingestion pathway EPZ? Does, in the opinion of FEMA, the NHRERP contain up-to-date lists of the name and locations of all

facilities which regularly process milk products and other large amounts of food cr agricultural products originating in the ingestion pathway Emergency Planning Zone, but located elsewhere? Regardless of whether your response is affirmative

!. or negative, please cite the specific documents or informational sources upon which you rely for your answer.

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Resoonse to Interrocatory 6 Section 2.6.6 of the State Plan describes the protective action options for the ingestion pathway EPZ, consisting of milk control, water control, and food control. Section 2.6.7 outlines the decision process and criteria to be used by the State in selecting protective actions to be taken in the' ingestion pathway EPZ.-

FEMA has requested the State to provide detailed information in its June 23, 1983 preliminary comments in the NHRERP for Seabrook on the location of all agricultural facilities in the ingestion pathway EPZ.

Maps showing detailed ingestion pathway information as described in this interroga' tory are generally large and not normally contained in the RERP.

They are usuall'y maintained at the appropriate E0C's.

FEMA has not formed an opinion at this time regarding the State's adequacy in the. area of protective response for the ingestion pathway EPZ. An assessrcent will be made when detailed information is submitted, or made avaialble, to FEMA.

Signed this 27th day of. October, 1983.

8-9D, BRUCE J. SWIREN Emergency Management Specialist Federal Emergency Management Agency Then appeared ' before me Bruce J. Swiren and having been duly sworn stated that the aforegoing statements were true and accurate to the best of his information and belief.

/ "' k $m NOTARY PUBLIC Date: /c -2 7 - E.]

My commission expires: R N'o'/f74

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'83 00131 Pl2:23 ctRTIFICATE OF SERVICE OFFtE OF SE .2. ',1 00CXE.isiG i. SEi<vii.'

BRANCH I, Brian P. Cassidy, state that I served a copy of FEMA's Response to SAPL's Interrogatories by mailing in a franked envelope upon the parties  ;

identified in the attached service list on this 27th day of October, 1983..

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SERVICE LIST Helen Hoyt, Esq., Chairman Aininistrative Judge Atcraic Safety and Licensing Board Panel U.S. Nulcear Regulatory Ccmission trashington, D.C. 20555 Dr. Jerry Harbour' Administrative Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Ccmnission Uashington, D.C. 20555 Dr. Emmeth A. Luebke L A:i-inistrative Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory ConInission 1:ashington, D.C. 20555 Roy P..Lessy Office of the Executive Legal Director U.S. Nuclear Regulatory Agency 1:ashington, D.C. 20555 Edward L. Cross, Jr., Esq.

George Dana Bisbee, Esq.

Environmental Protection Division Office of the Attorney General State House Annex Concord,IE 03301 Jo Ann Shotwell, Asst. Attorney Office of the Attorney General Environmental Protection Division One Ashburton Place, 19th Floor Boston,IR 02108 Nicholas J. Costello lst Essex District Uhitehall Road I

Amesbury,!% 01913 Sandra Gavutis Town of Kensington, New Hampshire RFD I East Kingston, NH 03827 Edward J. Meany l 'Itun of Rye, New Hampshire 155 Uashington Road Rye,'NH 03870

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Devarly Hollingworth 7 A Street Hr:pton Beach, la 03842 fir. Robert J. Harrison President and Chief Executive Officer Public Service Co. of New Harpshire P.O. Box 330 l'atnchester, la 03105 Robert A. Backus, Esq.

116 Lcuell Street P.O. Box 516 Manchester, IE 03105 Senator Gordon J. Humphrey U.S. Sentate ua,shington, D.C. _20510 (Attn: 'Itzn Burack)

':tyxcas G. Dignan, Jr. , Esq.

Ropes & Gray 255 Franklin Street .

Boston, la 02110 Atar: tic Safety and Licensing -

Appeal Panel U.S. Nuclear Regulatory Ccx:ntission Washington, D.C. 20555 Jane toughty Field Director Seacoast Anti-Pollution League t

5 Itarket Street '

Ports:Touth,la 03801 Calvin A. Canney City Hall l 126 Daniel Street ,

Ports::cuth, is 03801 Roberta C. Pevear Tcun of Hampton Falls, New Ha".pshire Drinkwater Road Hampton Falls, NH 03844 Uilliam S. Jordan, III, Esq.

Ellyn R. Weiss, esq.

Harmon &-Weiss 1725 I . Street, N.U.

Suite 506 Uashington, D.C. 20006 l

Phillip Ahrens, Esq.-

! Assistant Attorney General State House Station #6 Augusta, IE 04333

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nomic Saf ty and Licensing Board Panel U.S. Nuclear Regulatory Comission

Washington, D.C. 20555 -

John'B.'Tanzer' Tcwn of-Hampton, New Hampshire 5 Morningside Drive Hampton, NM .03842

-Letty Hett

'It:wn of Brentwood RFD Dalton Road Brentwood, NH 03833 Docketing and Services Section Office of the Secretary U.S.' Nuclear. Regulatory Ccunission

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-Washington, D.C. 20555 David R. Lewis, Esq.

' Law Clerk to the Board

. Atomic Safety and Licensing Board-U.S. Nuclear and Regulatory Comission

Washington, D.C. 20555 N of Ibrth Hampton Ibrth Hampton, NH 03862 LR.K. Gad III, Esq.'

Ropes and Gray 1 255 Franklin Street Doston,!R 02110

-Patrick J.'McKeon Chairman of Selectmen,-Rye_

New Ha=oshire 10 Central Road I

,' --Rye, NH;103870 Anne Verge, Chairman Board of Selectmen I. Y Town Hall South Hampton, NH 03842 Mr. Maynard B. Pearson

'Ibwn of Amesbury, -Mass.

40 rionroe Street

-(Aw sbury,.MA 01913

-Senator Gordan J. Humphrey 1.Pillsbury Street' Concord, NH' 03301

-(Attn: -Herb Boynton) i Charles Cross, Esq.

Shaines, Madrigan, tr McEaclwr-t 25 Itaplewood Avenue P.O.Dox 366'

[ ,Portsmouth,-NH- 03801