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Category:AFFIDAVITS
MONTHYEARML20199D2461999-01-19019 January 1999 Supplemental Affidavit of Js Robinson.* Affidavit of Js Robinson Providing Info Re Financial Results of Baycorp Holding Ltd & Baycorp Subsidiary,Great Bay Power Corp. with Certificate of Svc ML20198P7551998-12-30030 December 1998 Affidavit of J Robinson.* Affidavit of J Robinson Describing Events to Date in New England Re Premature Retirement of Npps,Current Plans to Construct New Generation in Region & Impact on Seabrook Unit 1 Operation.With Certificate of Svc ML20154D7381998-09-21021 September 1998 Affidavit of FW Getman Requesting Exhibit 1 to License Transfer Application Be Withheld from Public Disclosure,Per 10CFR2.790 ML20237A0631998-08-0606 August 1998 Affidavit of TC Feigenbaum Re Length of Fuel Cycles at Seabrook Station & of Future Plans for Fuel Cycle Length. W/Certificate of Svc ML20236M5181998-06-27027 June 1998 Affidavit.* Affidavit of J Parker Re 980506 License Exemption Request from Operator of Seabrook Station ML20236M4871998-06-27027 June 1998 Affidavit.* Affidavit of K Conrad Re 980506 License Exemption Request from Operator of Seabrook Station ML20236M5091998-06-27027 June 1998 Affidavit.* Affidavit of Sn Haberman Re 980506 License Exemption Request from Operator of Seabrook Station ML20236M5231998-06-27027 June 1998 Affidavit.* Affidavit of SA Parker Re 980506 License Exemption Request from Operator of Seabrook Station ML20236M4971998-06-27027 June 1998 Affidavit.* Affidavit of D Bogen Re 980506 License Exemption Request from Operator of Seabrook Station ML20236M5061998-06-27027 June 1998 Affidavit.* Affidavit of C Nord Re 980506 License Exemption Request from Operator of Seabrook Station ML20236M5401998-06-27027 June 1998 Affidavit.* Affidavit of Eh Mecklejohn Re 980506 License Exemption Request from Operator of Seabrook Station ML20216E0351998-04-13013 April 1998 Affidavit of FW Getman (Great Bay Power Corp) Requesting That NRC Withhold Util Response to NRC RAI Re Proposed Acceleration of Decommissioning Funding for Ownership Share of Seabrook Station ML20140B9711997-06-0404 June 1997 Affidavit of FW Getman Per 10CFR2.790,re Great Bay Power Corp'S Filing of Suppl to Petition for Partial Reconsideration of Exemption Order ML20073E1641991-04-19019 April 1991 Affidavit of J Hausner.* Discusses Facility Offsite Radiological Emergency Planning.W/Certificate of Svc ML20065K3421990-11-0202 November 1990 Affidavit of Cole.* Discusses Issue of Whether Commonwealth of Ma School Teachers & Day Care Ctr Personnel Perform Roles Contemplated in Spmc ML20065K3451990-11-0101 November 1990 Affidavit of Mc Sinclair.* Responds to Questions Posed by Aslab in ALAB-937 Re Whether Spmc Provides Adequate Supervision & Care of Children Evacuated to School Host Facility at Holy Cross College.W/Certificate of Svc ML20062C2781990-10-19019 October 1990 Affidavit of a Callendrello Addressing Issue Re Staffing of Seabrook Plan for Massachusetts Communities School Host Facility as Discussed in Aslab 900918 Decision.W/Certificate of Svc ML20062C2651990-10-18018 October 1990 Affidavit of Ds Mileti Addressing Issue Whether Massachusetts School Teachers & Day Care Ctr Personnel Would Respond to Assignments in Emergency to Escort Children on Buses ML20059M6201990-09-24024 September 1990 Affidavit of GL Iverson.* Responds to Statements Made in Mc Sinclair 900907 Supplemental Affidavit.W/Certificate of Svc ML20059B0021990-08-22022 August 1990 Affidavit of RW Donovan Re Staffing Adequacy for Implementation of New Hampshire Radiological Emergency Response Plan for Plant.W/Certificate of Svc ML20059A9981990-08-21021 August 1990 Affidavit of Jc Dolan Re Adequacy of Staffing for Implementation of New Hampshire Radiological Emergency Response Plan for Plant ML20059B0281990-08-21021 August 1990 Affidavit of GL Iverson Re Position of Governor Media Ctr representative.Twenty-second Initial Vacancy Was New Hampshire Public Utils Commission Lead Engineer ML20059A8911990-08-16016 August 1990 Affidavit of GL Iverson Re Adequate Staffing at New Hampshire Radiological Emergency Plan in Event of Radiological Emergency at Seabrook.W/Certificate of Svc ML20056B2251990-08-0606 August 1990 Affidavit of Mc Sinclair.* Affidavit Re Offsite Radiological Emergency Response Planning for State of Nh & Spmc ML20081E2431990-07-31031 July 1990 Affidavit of a Desrosiers Re Evacuation of Advanced Life Support Patients ML20081E2471990-07-31031 July 1990 Affidavit of B Cohen Re Evacuation of Advanced Life Support Patients ML20081E2401990-07-31031 July 1990 Affidavit of Rl Goble Re Preparation of Advanced Life Support Patients for Evacuation ML20081E2511990-07-31031 July 1990 Affidavit of Sj Plodzik Re Evacuation of Advanced Life Support Patients ML20055G6521990-07-11011 July 1990 Affidavit of T Urbanik Re Licensee Motion for Summary Disposition of Advanced Life Support Patients Issue.* Addresses Issues Re Preparation of Advanced Life Support Patients.W/Certificate of Svc ML20058K8011990-06-25025 June 1990 Affidavit of Am Callendrello.* Addresses Issues Defined by ASLB in LBP-90-12 Re Preparation of Advanced Life Support Patients for Evacuation & Impact on Special Population Evacuation Time Estimates.W/Certificate of Svc ML20058K7811990-06-25025 June 1990 Affidavit of J Bonds.* Addresses Issues Defined by ASLB in LBP-90-12 Re Advanced Life Support Patients & Consideration of Preparation Time for Evacuation Under State of Nh Radiological Emergency Response Plan.W/Certificate of Svc ML20058K7841990-06-25025 June 1990 Affidavit of D Albertson.* Addresses Issues of Advanced Life Support Patient Preparation for Transport.Certificate of Svc Encl ML20058K7941990-06-25025 June 1990 Affidavit of Kj Callahan.* Addresses Issues of Advanced Life Support Patient Preparation for Transport.Certificate of Svc Encl ML20012C6701990-03-15015 March 1990 Affidavit of Rd Pollard.* Advises That Deficiencies Cited in INPO & Other Repts Demonstrate No Basis for Finding That Reactor Complies W/Nrc Regulations or Can Be Operated Safely ML20012C7121990-03-13013 March 1990 Affidavit of Be Beuchel.* Addresses Intervenors Allegations & Whether Significant Safety Issue Present Re Rosemount Transmitters.Supporting Info,Including Beuchel Prof Qualifications & Certificate of Svc Encl ML20006G1151990-02-26026 February 1990 Affidavit of Gc Minor Re Rev of Rosemount Transmitters at Seabrook.* Discusses Potential Safety Impact of Rosemount Transmitter Problems & Need for Changing Faulty Transmitters Before Plant Proceeds W/Power Ascension & Operation ML20011F1291990-02-16016 February 1990 Affidavit of WT Wallace.* Discusses Oct 1988 Amends to State of Nh Radiological Emergency Response Plan.Supporting Info Encl ML20011F1281990-02-16016 February 1990 Affidavit of GL Iverson.* Discusses Oct 1988 Amends to State of Nh Radiological Emergency Response Plan ML19351A7051989-12-0606 December 1989 Affidavit of TC Feigenbaum.* Advises That Further Delay in Obtaining Full Power License for Plant & Reaching Commercial Operations Caused by Further Litigation Will Be Very Costly & Unnecessary.W/Supporting Info & Certificate of Svc ML19332F9701989-11-30030 November 1989 Joint Affidavit of Gc Minor & Sc Sholly.* Opposes Issuance of Full Power OL Until Problems Noted Resolved,Consistent W/ NRC Finding in Confirmatory Action Ltr CAL-RI/89-11.Addl Info & Certificate of Svc Encl ML19332D7011989-11-22022 November 1989 Affidavit of AA Kelsey.* Discusses 1989 Edition of Arbitron Radio County Coverage Rept for Essex County,Ma.Few People in Geographic Area Listen to Whav & Wlyt.W/Certificate of Svc ML20006C4371989-11-21021 November 1989 Affidavit of AA Kelsey.* Discusses Radio Coverage in Merrimac Valley.W/Supporting Info & Certificate of Svc ML19332D5701989-11-17017 November 1989 Joint Affidavit of Gc Minor & Sc Sholly Re New Hampshire Yankee 890921 OL Amend Request (Plant Instrument Air cross-connect to Containment Bldg Air sys,NYN-89116).* Proposed Amend Considered Illogical & W/O Technical Merit ML19332D5301989-11-14014 November 1989 Affidavit of Am Callendrello.* Refutes Intervenors Allegations That Util No Longer Able to Provide Emergency Info to Public as Result of Withdrawal of Agreement Between Util & Wcgy.W/Supporting Info ML19332D5441989-11-14014 November 1989 Affidavit of Gr Gram.* Confirms Util Adherence to 870914 Commitment to Provide Certain Svcs & Equipment for Planning & Implementation of Alerting Sys.W/Supporting Info & Certificate of Svc ML19332D5361989-11-13013 November 1989 Affidavit of Gj Catapano.* Denies Intervenors Allegations That Util Incapable of Providing Prompt Emergency Instructions to Public in Light of Withdrawal of Certain Agreements.Supporting Info Encl ML19354D5121989-11-0909 November 1989 Affidavit of R Boulay Re Voiding of Emergency Broadcast Sys Ltrs of Agreement.* Since Wcgy Voided Ltr of Agreement W/ Util & Withdrew from Emergency Plan,Broadcast Sys for Merrimac Valley Cannot Be Activated.Related Info Encl ML19354D5141989-10-30030 October 1989 Affidavit of R Sawyer Re Voiding of Emergency Broadcast Sys Ltr of Agreement.* Marked-up Affidavit Discussing Impact of Wcgy Voiding Ltr of Agreement W/Util & Withdrawing from Participating in Emergency Planning.W/Certificate of Svc ML19327B7021989-10-27027 October 1989 Affidavit of Jf Bassett Re Voiding of Emergency Broadcast Sys (Ebs) Ltrs of Agreement.* Discusses Fact That Applicant Has Never Followed Through on Commitment to Provide Ebs Equipment,Per 870914 Ltr of Agreement.Supporting Info Encl ML19327B7061989-10-26026 October 1989 Affidavit of Dj Rowe Re Voiding of Emergency Broadcast Sys (Ebs) Ltrs of Agreement.* Discusses Applicant Refusal to Live Up to Commitments to Commonwealth of Ma Ebs.W/ Supporting Info & Certificate of Svc 1999-01-19
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217H9511999-10-21021 October 1999 Memorandum & Order.* Proceeding Re Nepco 990315 Application Seeking Commission Approval of Indirect License Transfers Consolidated,Petitioners Granted Standing & Two Issues Admitted.With Certificate of Svc.Served on 991021 ML20217N2561999-10-21021 October 1999 Transcript of Affirmation Session on 990121 in Rockville, Maryland Re Memorandum & Order Responding to Petitions to Intervene Filed by co-owners of Seabrook Station Unit 1 & Millstone Station Unit Three.Pp 1-3 ML20211L5141999-09-0202 September 1999 Comment on Draft Reg Guide DG-4006, Demonstrating Compliance with Radiological Criteria for License Termination. Author Requests Info as to When Seabrook Station Will Be Shut Down ML20211J1451999-08-24024 August 1999 Comment Opposing NRC Consideration of Waiving Enforcement Action Against Plants That Operate Outside Terms of Licenses Due to Y2K Problems ML20210S5641999-08-13013 August 1999 Motion of Connecticut Light & Power Co,Western Massachusetts Electric Co & North Atlantic Energy Corp to Strike Unauthorized Response of Nepco.* Unauthorized Response Fails to Comply with Commission Policy.With Certificate of Svc ML20210Q7531999-08-11011 August 1999 Order Approving Application Re Corporate Merger (Canal Electric Co). Canal Shall Provide Director of NRR Copy of Any Application,At Time Filed to Transfer Grants of Security Interests or Liens from Canal to Proposed Parent ML20210P6271999-08-10010 August 1999 Response of New England Power Company.* Nu Allegations Unsupported by Any Facts & No Genuine Issues of Matl Facts in Dispute.Commission Should Approve Application Without Hearing ML20210H8311999-08-0303 August 1999 Reply of Connecticut Light & Power Co,Western Massachusetts Electric Co & North Atlantic Energy Corp to Response of New England Power Co to Requests for Hearing.* Petitioners Request Hearing on Stated Issues.With Certificate of Svc ML20210J8501999-08-0303 August 1999 Order Approving Transfer of License & Conforming Amend.North Atlantic Energy Service Corp Authorized to Act as Agent for Joint Owners of Seabrook Unit 1 ML20211J1551999-07-30030 July 1999 Comment Opposing That NRC Allow Seabrook NPP to Operate Outside of Technical Specifications Due to Possible Y2K Problems ML20210E3011999-07-27027 July 1999 Response of New England Power Co to Requests for Hearing. Intervenors Have Presented No Justification for Oral Hearing in This Proceeding.Commission Should Reject Intervenors Request for Oral Hearing & Approve Application ML20209H9101999-07-20020 July 1999 Motion of Connecticut Light & Power Co & North Atlantic Energy Corp for Leave to Intervene & Petition for Hearing.* with Certificate of Svc & Notice of Appearance ML20195H1911999-06-15015 June 1999 Application of Montaup Electric Co & New England Power Co for Transfer of Licenses & Ownership Interests.Requests That Commission Consent to Two Indirect Transfers of Control & Direct Transfer ML20206A1611999-04-26026 April 1999 Memorandum & Order.* Informs That Montaup,Little Bay Power Corp & Nepco Settled Differences Re Transfer of Ownership of Seabrook Unit 1.Intervention Petition Withdrawn & Proceeding Terminated.With Certificate of Svc.Served on 990426 ML20205M7621999-04-15015 April 1999 Notice of Withdrawal of Intervention of New England Power Co.* New England Power Co Requests That Intervention in Proceeding Be Withdrawn & Hearing & Related Procedures Be Terminated.With Certificate of Svc CLI-99-06, Order.* Joint Request for ten-day Extension of Schedule Set Forth in CLI-99-06 in Order to Facilitate Parties Settlement Efforts Granted,With Exception of Date of Hearing. with Certificate of Svc.Served on 9904071999-04-0707 April 1999 Order.* Joint Request for ten-day Extension of Schedule Set Forth in CLI-99-06 in Order to Facilitate Parties Settlement Efforts Granted,With Exception of Date of Hearing. with Certificate of Svc.Served on 990407 ML20205G0921999-04-0505 April 1999 Joint Motion of All Active Participants for 10 Day Extension to Permit Continuation of Settlement Discussion.* Participants Request That Procedural Schedule Be Extended by 10 Days.With Certificate of Svc ML20205G3091999-03-31031 March 1999 Petition That Individuals Responsible for Discrimination Against Contract Electrician at Plant as Noted in OI Rept 1-98-005 Be Banned by NRC from Participation in Licensed Activities for at Least 5 Yrs ML20204E6401999-03-24024 March 1999 Protective Order.* Issues Protective Order to Govern Use of All Proprietary Data Contained in License Transfer Application or in Participants Written Submission & Oral Testimony.With Certificate of Svc.Served on 990324 ML20204G7671999-03-23023 March 1999 Comment Supporting Proposed Rule 10CFR50.54(a) Re Direct Final Rule,Changes to QA Programs ML20207K1941999-03-12012 March 1999 North Atlantic Energy Svc Corp Participation in Proceeding.* Naesco Wished to Remain on Svc List for All Filings.Option to Submit post-hearing Amicus Curiae Brief Will Be Retained by Naesco.With Certificate of Svc ML20207H4921999-02-12012 February 1999 Comment on Draft Contingency Plan for Year 2000 Issue in Nuclear Industry.Util Agrees to Approach Proposed by NEI ML20203F9471999-02-0909 February 1999 License Transfer Application Requesting NRC Consent to Indirect Transfer of Control of Interest in Operating License NPF-86 ML20199F7641999-01-21021 January 1999 Answer of Montaup Electric Co to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests Motion Be Denied on Basis of Late Filing.With Certificate of Svc ML20199H0451999-01-21021 January 1999 Answer of Little Bay Power Corp to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests That Ui Petition to Intervene & for Hearing Be Denied for Reasons Stated.With Certificate of Svc ML20199D2461999-01-19019 January 1999 Supplemental Affidavit of Js Robinson.* Affidavit of Js Robinson Providing Info Re Financial Results of Baycorp Holding Ltd & Baycorp Subsidiary,Great Bay Power Corp. with Certificate of Svc ML20199D2311999-01-19019 January 1999 Response of New England Power Co to Answers of Montaup Electric Co & Little Bay Power Corp.* Nep Requests That Nep Be Afforded Opportunity to File Appropriate Rule Challenge with Commission Pursuant to 10CFR2.1329 ML20206R1041999-01-13013 January 1999 Answer of Little Bay Power Corp to Motion of New England Power Co for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* with Certificate of Svc ML20206Q8451999-01-12012 January 1999 Written Comments of Massachusetts Municipal Wholesale Electric Co.* Requests That Commission Consider Potential Financial Risk to Other Joint Owners Associated with License Transfer.With Certificate of Svc.Served on 990114 ML20199A4741999-01-12012 January 1999 Answer of Montaup Electric Co to Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Nepco 990104 Motion Should Be Denied for Reasons Stated.With Certificate of Svc ML20206Q0151999-01-12012 January 1999 North Atlantic Energy Svc Corp Answer to Petition to Intervene of New England Power Co.* If Commission Deems It Appropriate to Explore Issues Further in Subpart M Hearing Context,Naesco Will Participate.With Certificate of Svc ML20199A4331999-01-11011 January 1999 Motion of United Illuminating Co for Leave to Intervene & Petition to Allow Intervention out-of-time.* Company Requests That Petition to Allow Intervention out-of-time Be Granted.With Certificate of Svc ML20198P7181998-12-31031 December 1998 Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Moves to Intervene in Transfer of Montaup Seabrook Ownership Interest & Petitions for Summary Relief or for Hearing ML20198P7551998-12-30030 December 1998 Affidavit of J Robinson.* Affidavit of J Robinson Describing Events to Date in New England Re Premature Retirement of Npps,Current Plans to Construct New Generation in Region & Impact on Seabrook Unit 1 Operation.With Certificate of Svc ML20195K4061998-11-24024 November 1998 Memorandum & Order.* North Atlantic Energy Services Corp Granted Motion to Withdraw Proposed Amends & Dismiss Related Adjudicatory Proceedings as Moot.Board Decision LBP-98-23 Vacated.With Certificate of Svc.Served on 981124 ML20155J1071998-11-0909 November 1998 NRC Staff Answer to North Atlantic Energy Svc Corp Motion for Leave to File Reply.* Staff Does Not Object to North Atlantic Energy Svc Corp Motion.With Certificate of Svc ML20155D0041998-10-30030 October 1998 Motion for Leave to File Reply.* Licensee Requests Leave to Reply to Petitioner 981026 Response to Licensee 981015 Motion to Terminate Proceedings.Reply Necessary to Assure That Commission Is Fully Aware of Licensee Position ML20155D0121998-10-30030 October 1998 Reply to Petitioner Response to Motion to Terminate Proceedings.* Licensee Views Segmentation Issue as Moot & Requests Termination of Subj Proceedings.With Certificate of Svc ML20155B1641998-10-26026 October 1998 Response to Motion by Naesco to Withdraw Applications & to Terminate Proceedings.* If Commission Undertakes to Promptly Proceed on Issue on Generic Basis,Sapl & Necnp Will Have No Objection to Naesco Motion.With Certificate of Svc ML20154K8751998-10-15015 October 1998 Motion to Withdraw Applications & to Terminate Proceedings.* NRC Does Not Intend to Oppose Motion.With Certificate of Svc ML17265A8071998-10-0606 October 1998 Comment on Integrated Review of Assessment Process for Commercial Npps.Util Endorses Comments Being Provided by NEI on Behalf of Nuclear Industry ML20154C8171998-10-0606 October 1998 Notice of Appointment of Adjudicatory Employee.* Notice Given That W Reckley Appointed as Commission Adjudicatory Employee to Advise Commission on Issues Related to Review of LBP-98-23.With Certificate of Svc.Served on 981006 CLI-98-18, Order.* Grants Joint Motion Filed by Naesco,Sapl & Necnp for Two Week Deferral of Briefing Schedule Set by Commission in CLI-98-18.With Certificate of Svc.Served on 9810061998-10-0505 October 1998 Order.* Grants Joint Motion Filed by Naesco,Sapl & Necnp for Two Week Deferral of Briefing Schedule Set by Commission in CLI-98-18.With Certificate of Svc.Served on 981006 ML20153H4471998-10-0101 October 1998 Joint Motion of Schedule Deferral.* Naesco,Sapl & Necnp Jointly Request Temporary Deferral of Briefing Schedule as Established by Commission Order of 980917 (CLI-98-18). with Certificate of Svc ML20154F9891998-09-29029 September 1998 License Transfer Application Requesting Consent for Transfer of Montaup Electric Co Interest in Operating License NPF-86 for Seabrook Station,Unit 1,to Little Bay Power Corp ML20154D7381998-09-21021 September 1998 Affidavit of FW Getman Requesting Exhibit 1 to License Transfer Application Be Withheld from Public Disclosure,Per 10CFR2.790 ML20153C7791998-09-18018 September 1998 Comment Supporting Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Util Endorses NRC Staff Focus on Operability & Funtionality of Equipment & NEI Comments ML20151Z5611998-09-18018 September 1998 Order.* Pursuant to Commission Order CLI-98-18 Re Seabrook Unit 1 Proceeding,Schedule Described in Board 980904 Memorandum & Order Hereby Revoked Pending Further Action. with Certificate of Svc.Served on 980918 ML20151Y0331998-09-17017 September 1998 Order.* All Parties,Including Util,May File Brief No Later than 981007.Brief Shall Not Exceed 30 Pages.Commission May Schedule Oral Argument to Discuss Issues,After Receiving Responses.With Certificate of Svc.Served on 980917 ML20153E8771998-09-16016 September 1998 Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide (Ki) as Protective Action During Severe Reactor Accidents. Recommends That NRC Reverse Decision to Revise Emergency Planning Regulation as Listed 1999-09-02
[Table view] |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY C0m!S$10N l
l Before the '
ATOMIC SAFETY AND LICENSING BOARD
$ T Tn7 he matter or: 1
'1 PUBt.!C SE9VICE COMPANY OF NEW MAMPSHIRE ') Occket hos.: 50-443 and 50-444 (Seabrook Station. Units 1 and 2 June 11, 1986 AFFIDAVIT OF EDWARD A. THOMAS I, Edward A. Thomas, being on oath, hereby depose and say as follows:
- 1. ! &m the Division Chief of the Natural and Technological Hazards Division of Regicn I of the Federal Emergency Management Agency (FEMA). As such, one of my responsibilities is the management of FEMA's Radiological Emergency Planning Program in New England.
- 2. I also serve as the Chairman of the Regional Assistance Comittee (RAC), an interagency comittee established pursuant to 44 CFR 350.
- 3. Since 1981, I have been responsible for leading and coordinating the FEMA and RAC reviews and evaluations of State and local radiological emergency planning and preparedness in FEMA Regien 1 (comprising the six-state New England a rea) . In this regard, I have reviewad or supervised the review of the radio-logic:1.sret gency response plans of nar.erous State and local jurisdictions l within the New Engiend area, and participated in observing and/or evaluating the conduct of cvkr 20 radiological emergency preparedness exercises in FEMA Ragion I.
- 4. FEMA and the RAC have refiewed the plans submitted by the State of New Hampshire designed to protect the public in tne event of an accident at B606130218 860611 PDR ADOCK 05000443 Q PDR
the Seabrook Nuclear power Planto These revie:S were performed under my direc-tion by FEMA staff, consultants to FEMA, members of the RAC and other federal employees who assisted tne RAC members.
- 5. On February 26, 1986, FEMA otserved an exercise of New Hampshire's plans to prot _ect the public in the esent of an accident at Seabrook. A draft report of that exercise was issued April 30, 1986. Th6 final report of the ,
exercise was completed June 2, 1986, and mailed to the State of New Hampshire June 6, 1986.
- 6. I have read and am familiar with the emergency planning contentions admitted by the Licensing Board's Orcers of April 1 and 29,1986, as to which the Applicants and/or the State of New Hampshire sought sumnary disposition by motions cated May 20, 1986.
- 7. Based upon FEMA and the RAC's review of the New Hampshire radiological emergency response plans and the emergency planning exercise conducted on Febru-ary 26,1986, as well as the State's compensatory plan and aavisions to the plans which have been made, FEMA and the RAC have identified certain unresolved issues of material fact within the scope of the following contentions, which issues are are identified, in part, as followst A. Hamton Falls 1 (Implementation of Hampton Falls Plan)
In the event the town of Hampton Falls does not implement its emergency plan, the state of New Hampsnire is to implement the state compensatory plan for the town. However, the Compensatory Plan was found to have significant deficiencies in the February 26, 1986 exercise thus affec-ting Hampton Falls which was a nonparticipating corsnunity in that exer.
cise. See. Exercise Report, Section 2.1.2, New Hampshire IF0, pp. 24-29, 3: staffing shortages and equipment shortages. g , also Section 1.2.4, Field Implementation of the State's Ability to Satisfy Combined Partici-pating and Nonparticipating Community Needs According to the Compensatory Plan, pp. 29-44, 3 : transpoetation resource shortages and evacuation procedures.
. In addition, the review by the Regional Assistance Committee (RAC) of 4/30/86 of the New Hampshire State Compensatory Plan found the plan l deficient in a number of areas, including, but not limited to: (1) i 1
allocation of responsibilities showing increased requirements for vart- !
ous agencies, (2) staffing, (3) notification, (4) comunications, (5) l
)
resources and facilities for emergency operations, (6) scope (not all >
communities in the EPZ had been planned for), (7) information about mobility impaired individuals, (8) route information (including maps) for buses, and (9) dosimetry. (M.reviewbyRACoftheNHCompense-tory Plan, 4/30/86).
- 8. Kensington 6. South Hampton L__ South Hampton 3 [ Letters of Agreement)
- 1. With respect to the Midway Excavators, according to the NHRERP, Volume 5 Letters of Agreement, the New Hampshire Towing Association -
has the resources necessary to provide emergency towing services in the event of major emergencies and agrees to do so for fair compensa- '
tion (Letterof 11/27/85. unsigned).
However, the RAC review (6/2/86) of Volurre 5 expresses concern that :
the letter is unsigned and cites "only a general willingness to
' provide emergency towing as needed'", but does not indicate a -
comitment of specific numbers of vehicles or drivers. There are no letters of agreement with specific towing companies, inclucing Midway Excavators. !
j 2. In addition to the above, the exercise of February 26, 1986, ir.di. ;
cated that there were insuffitient buses and drivers for the buses.
T
($3e,, the Exercise Report, Section 2.1.4, Field Implementation... of the Compensatory Plan, pp. 39 45 3: lack of availability of buses, e l lack of driver resources.)
I l
1
_ . _ . . - . . _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ - . _ _ _ _ _ . _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _____.______.__________/
~
. . 1 4-C. South Hampton 8 NHLP4, SAPL 18. SAPL 25 (Special Needs Population)
FEMA and the RAC have found that additional work must be done to identify the special needs populations.
The State of New Hampshire plan describes the evacuation and relocation _
. +
of mobility impaired institutionalized people (Section 2.6.5, p. 2.6-9 of the NHRERp of 11/85). However, specific procedures to identify individuals with special needs ahead of time are not in the plan. The local plans require the municipal Transportation Coordinator to maintain an (unpublished) list of the residents requiring evacuation by special vehicles but the methods for compiling this list are not described (Local RERPs, Sections !!.G - Protective Response). The State plan now provides for identifiestion of special needs persons by the return of postcards to be sent out to all residences within the EPZ as part of the public information bro:hure. Howevet, this approach is neither sufficiently comprehensive por has it teen implemented. In addition, deficiencies in providing transportation resources for special needs population were identified in the exercise. (See paragraph B supra.)
- 0. RERP 2 (Federal Assistance) '
1, Volume $ of the NHRERP, The Letters of Agreements, includes a copy of a Memorandum of Understandirg between the State of NH and the Coast Guard supposedly signec on 7 February 1984 It is unclear that this is the case, oecause the copy of the MOU ooes not show a signature -
(see also, RAC review of Volume 5, indicating that the MOU is unsigned.
6/2/86).
The text of the unsigned MOU indicated that the Coast Guard is "always prepared to assist in any incident involving danger to any waterfront area, waterfront facility, and personnel thereon." In the event of an emergency at the Seabrook Station, the Coast Guard response would
-S-consist of control, notification, and restaiction nf waterborna traffic from an established dangerous area which the Captain of the Port.
Boston, MA, would designate as a safety zone.
However, the Coast Guard was t nable to meet the exercise objective to alerf the boating public within the plume exposure EPZ within 15 minutes l 1
because, apparently, an incorrect telephone number was listed and called, !
creating a significant delay (See Exercise Report, State EOC, Section 2.2,pp.17-23).
Whether notification of the boating population without radios and out of earshot of the sirens can be accomplished by the Coast Guard as contemplated by the New Hampshire Plan in a timely manner is unnnuaa '
until the Alert and Notification Report has been reviewed by FEMA. i
- 2. With respect to the Letter of Agreement with FAA, the NHRERP, Volume 5, Letters of Agreement, indicates that the letter is "on file" ,
at the NHCDA offices. No text has been provided to FEMA, .
E. Rye 2 (Rannie Webster Nursing Home)
There is presently no radiological emergency response plan for the Rannie Webster Nursing Home. No plan or mention of this special facility is presently referenced in the Rye local plan dated 11/85.
(See, Rye plan page 1-11, see. Rye plan Appendix F, page F-1.)
(Note that a letter from New Hampshire Attorney General, Environmental l Protection Bureau, to the U.S. Nuclear Regulatory Commission dated May 14, 1986, states (page 7) that reference to this facility "is now being incorporated into the Special Facilities section of the Rye RERP.")
F. 5APL 17 and NECNP NHLP-3 (Not_1fication and Consnunications)
The Exercise Report identifies deficiencies in the existing emergency communications system.
l There are numerous " Deficiencies" and " Areas Requiring Corrective ,
Action" pertaining to communications systees or procedures identified in the exercise report. These are listed below along with a brief description. (DEF = Deficiency; ARCA = Area Requiring Corrective Actiq _n .)
Page 23, ARCA #1 = Busy telefax machine at State EOC 6elayed messaggs.
Page 27. DEF. #2 = Insufficient number of telephone lines at IFO.
Page 28, ARCA #2 = Busy telefax machine at IFO delayed cessalas.
Page 28, ARCA #3 = Local Liaison Officers at IFO not properly expediting comunications. .
Page 28, ARCA #4 = Additional telephones c.eeded at IF0, ,
Page 33, ARCA #1 = Busy telefax macnine at IFO delayed messages.
Page 47, ARCA #1 = Some breakup of radio communications between Statt Police troopers and the IFO.
Page 59 ARCA #1 = Potential conflicting use of Sheriff's communics-tion system from State EOC or IFO to Rockingham Co, staging area.
Page 65, OEF. #1 a Adequacy of 3 telephone lines at the Brentwood EOC not demonstratad.
Dage 66, ARCA #3 = Radio contact from Brentwood ECC to Manchester l
I reception center not possible on CD radio.
Page 71, DEF. #1 = Adcquacy of available teisphone lines at Greenland i EOC not denonstrated, 1
I Page 77 DEF. #1 - Adequacy cf the single telephane line at the Kingston ECC not otmonstrated.
Page 82, DEF. #1 = Adequacy of available teleprane lines at the East l Kingiton EOC not demonstrated.
Page 82 DEF. #2 = Plans for alert /nstification of two special facilities l at East Xingston are not in viace.
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. . . Page 86, DEF. #1 a Adequacy of available telephone lines at New Castle EOC not demonstrated.
Page 91, DEF. #1 - Adequacy of 2 telephaone lines at the Newfields EOC not demonstrated.
Page. 93, ARCA #3 = Local industrial facility not notified by NewfieldsT EOC.
Page 95, DEF. #1 = Adequacy of available telephone lines at Newton EOC not demonstrated.
Page 101, DEF. #1 = Adequacy of available telephone lines at Portsmouth E0C not demonstrated.
Page 108, DEF. #1 = Adequacy of 3 telephone lines at the Seabrook EOC not den)nstrated.
Page 109, ARCA #3 a Local school has outdated telephone number for the Seabron E00.
Page 113. DEF. #1 - Adequacy of 2 telephone lines at the Strathar EOC not denonstrated. -
G. SAPL 7 (Decontamination)
- 1. The NHRERP provides for tie decontamination of both emergency workers and the general public. (SeeNHRERPSection1.3.3,page1.3-10;section 2.7.5, pages 2.7-9 and -10.) Decontamination is performed at State cecontamination centers located at reception centers and at the IF0/ EOF.
(See, NHRERP Section 1.3.3, sage 1.3-10; Section 2.4.2, pages 2.4-4 and 2.4-7; Section 2.7.5, pages 2.7-9 and -10.) Specific procedures for i
! cecontamination are described in Appendix F to the DPHS Procedures in Part 7 of the NHRERP. A deficiercy was observed in the number of personnel and amount of equisment needed to demonstrate the number of people expected at the one reception center at which this was tested.
(See, Exerciss Report pp. 53-55.)
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. . o 20 The capability to screen, monitor and decontaminate emergency corkers was partially demonstrated during the February 26,1986, exercise and is described in the exercise report dated June 2,1986. At the Manchester reception center / decontamination center the available monitoring /decon.
-tam 4 nation peasonnel were well trained (m, exercise report pages 53-E4h However, a deficiency was observed (3, report page 54) since ability to monitor the expected numbu of people was not demonstrated.
A limited demonstration of nonitoring/ decontamination procedures also took place the the EOF (see, Exercise Report page 38).
- 3. Tne plans for the disposai of wastes are described in the NHRERP. -
g, Sectic,1.3.3, page 1.3-10; Section 2.7.5, page 2.7-10.) These plans have been reviewed and found to be adequato,by the RAC.
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- 8. In addition to the matters discussed above, FEMA a'ad the RAC are continu-ing to review matters addressed by Kersington-4 (. sheltering). At this time FEMA ,
and the RAC have not completed the review of this subject. Therefore, I am unable ,
to formulate an opinion aa to whether or not issue (s) of material fact remain to be litigated with respect io the contention.
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Edward A. Inomas Subscribed and sworn to before me, a Notary Public in the County of Suffolk, Commonwealth of Massachusetts, this lith day of June, 1986.
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/ Notary Public M conunission expires:__
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