ML20205P919

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Applicant Motion for Summary Disposition on Seacoast Anti- Pollution League Contention Numbers 7 & 33.* Motion Based in Part on WT Wallace & Wn Colburn Affidavits.Statement of Matl Fact as to Which There Is No Dispute Encl
ML20205P919
Person / Time
Site: Seabrook  
Issue date: 03/25/1987
From: Dignan T
PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20205L804 List: ... further results
References
RTR-NUREG-0654, RTR-NUREG-654 OL, NUDOCS 8704030405
Download: ML20205P919 (6)


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LG; Dated: : March 25, 1986 UNITED STATES OF-AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMI SAFETY AND LICENSING BOARD C

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In the Matter of

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PUBLIC SERVICE COMPANY OF

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Docket Nos. 50-443-OL NEW HAMPSHIRE, et al.

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'50-444-OL

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Off-site Emergency.

(Seabrook Station, Units 1 and 2) )

Planning Issues

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APPLICANTS' MOTION FOR

SUMMARY

DISPOSITION ON SEACOAST ANTI-POLLUTION. LEAGUE CONTENTIONS NOS. 7 and 33 Pursuant to 10 CFR 2.749, on the basis of the within

~ Affidavits of William T. Wallace, Jr. (2), Affidavit of William N. Colburn, and Affidavit of Richard H.

Strome,.and for the reastns set forth below, Applicants move the Board to enter an. order granting summary disposition in favor of the Applicants with respect to Seacoast Anti-Pollution League (SAPL) Contentions Nos. 7 and 33.

8704030405 870325 PDR ADOCK 05000443 0

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REASONS FOR GRANTING THIS MOTION Both SAPL Contentions concern Reception Center resources and practices.

Reasserted'SAPL Contention 7 contends that State and local plans fail to meet the requirements of 10 CFR 50.47 (b)(11), 50.47 (b)(10) and NUREG-0654 because means of evacuee and emergency worker decontamination supplies and equipment have not been shown, and there has been ne showing that adequate means for waste disposal exist.

SAPL Contention 7, subsequent to initial admission by the Board was limited by the Board in its Memorandum and Order of November 4, 1986 to the adequacy of personnel and equipment (including that for collection and storage of radioactively contaminated water) to accomplish the monitoring and decontamination of the numbers expected at the decontamination centers located at the Host Community Reception Centers.

SAPL Contention No. 33 Contends that the NHRERP fails to meet the requirements of 10 CFR 6 50.47 (d)(1), 50.47 (b)(8),

50.47 (b)(9),

50."' (b)(10) and NUREG-0654 in that there is no demonstration Chat adequate provisions for the registration and monitoring of evacuees at reception centers will be conducted within about a 12-hour period.

This is due to reducing the number of reception centers from six to four communities to provide support for this effort and that the processing rate of evacuees has not baea established in the plans.

The procedures and equipment for sampling and disposition of waste water for the washing of evacuees and their vehicles are contained in Rev. 2, Vol. 4A, Appendix F of the New Hampshire RERP.

The list appearing in Appendix.

F10 is to verily that the discharge water from decontamination centers does not exceed values for permissible concentrations identified in New Hampshire Rules for Control of Radiation.

Decontamination water is controlled by dilution.

Sampling is conducted to ensure concentration limits are maintained in accordance with New Hampshire Rules for Control of Radiation.

Procedures for environmental monitoring to establish Radioactive material concentration, the equipment used and the personnel assigned deemed sufficient to the task are described in paragraphs 4-5 of Doctor Wallace's Affidavit on Contention SAPL 7.

Equipment required is listed in NHRERP Volumes 4A, Appendices FlO and G.

Contaminated waste on Decontamination Center close-down will be disposed of by the State through established contract procedures with qualified radioactive waste handlers in accordance with DPHS Radiological rules promulgated by DPHS Radiological Health Program.

In regard to SAPL Contention 33 that there are no adequate provisions for registration and monitoring evacuees at reception centers, the Affidavits of Doctor Wallace (Contentions SAPL-7 and SAPL-33), William N. Colburn (SAPL-7 and SAPL-33) make clear that the State will have sufficient personnel and equipment resources capable of monitoring within about a 12-hour period all residents and transients.

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in the PEP-EPZ expected to arrive at the several Host Community Reception and Decontamination Centers.

By their attorneys, as C.- @ an, Jr.

George H. 6 ewald Kathryn A.

Selleck Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100 l

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v STATEMENT OF MATERIAL FACT AS TO-WHICH THERE IS-NO DISPUTE (SAPL 7 and 33)

Staffing needs at the Decontamination Centers will be-met by Host Community firefighters, mutual aid firefighters and DPHS.

2.

NHRERP Volume 4A, Appendix F4 describes the staffing functions and levels at the Decontamination Centers.

3.

Decontamination Center supervision and administrative support will be provided by DPHS.

The balance of the staffing levels will be provided by the communities.

4.

Of the total of 94 personnel required for maximum staffing levels at a Decontamination Center, as indicated in Appendix F4, 68 are designated for monitoring functions.

5.

A maximum of 376 personnel are required for operation of the four designated decontamination centers, 272 of whom are the maximum staffing required to monitor evacuees arriving at reception centers within the first 12

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hours.

6.

Based on summer weekend population figures, 8,700 evacuees are anticipated to arrive at the Manchester Reception and Decontamination Center.

The other 3 Host communities have lower numbers of evacuees anticipated.to arrive.

7.

Initial evacuee monitoring will take an average of one minute per evacuee at the Registration Area.

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As stated in the Wallace Affidavit, staffing levels at the Manchester Reception Center and Decontamination Center are adequate to provide reasonable assurance o'f meeting the FEMA guidelines described in FEMA Memorandum from Richard W.

Keim to NTH Division Chiefs and FEMA Regional Offices dated December 24, 1985.

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Each Host Community will have 80 CDU-700 meters.

10.

The New Hampshire Department of Health and Human Services is responsible for establishing and administering Host Community Reception Centers.

11.

Each center will be served by DPHS Emergency Service Units (ESUs) consisting of Department Personnel.

12.

The ESUs will function as a trained cadre for the operational supervison of volunteers who will provide evacuee registration, a message exchange and locating service, informational / recreation, mass care referral and student pick-up coordination.

13.

In addition to ESU core staff, there are approximately 550 Department employees in twelve field offices and over 300 Department employees stationed at State Offices, Concord.

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