ML20234F582

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Affidavit of EA Thomas in Support of Certain Motions for Summary Disposition.* Supports Listed Motions for Summary Disposition,Including Town of Kensington Contention 2. Certificate of Svc Encl
ML20234F582
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 06/25/1987
From: Eric Thomas
Federal Emergency Management Agency
To:
Shared Package
ML20234F494 List:
References
OL, NUDOCS 8707080267
Download: ML20234F582 (7)


Text

1 UNFTED STATES OF AMERICA i

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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In The Matter of:

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Docket No. 50 443-OL

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50 444-OL Public Service Co. of New Hampshire,

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Off-Site Emergency et al.

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Planning Issues (Seabrook Station, Units 1 and 2)

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l AFFIDAVIT OF EDWARD A. THOMAS IN SUPPORT OF CERTAIN MOTIONS FOR

SUMMARY

DISPOSITION l

1, Edward A. Thomas, under oath, do state that the following is true:

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l 1.

I am the Division Chief of the Natural and Technological Hazards Division of Region 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.

I 2.

I also serve as the Chairman of the Regional Assistance Committee (RAC), an interagency committee established pursuant to 44 C.F.R., Part 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 Region 1 (comprising the six-B7070B02b7 070702 PDR ADDCK 05000443 G

PDR

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state New England area).

In this regard, I have reviewed o' supervised I

the review of the radiological emergency response plans of numerous State and local jurisdictions within the New England area, and participated in observing or evaluating the conduct of more than 20 radiological emergency preparedness exercises in FEMA Region I.

I 4.

FEMA and the RAC have reviewed the plans submitted by the State j

i of New Hampshire designed to protect the public in the event of ar. accident i

at the Seabrook Nuclear Power Plant. These reviews were performed under l

my direction by FEMA staff, consultants to FEMA, members of the RAC and other federal employees who assisted the RAC members.

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1 5.

On February 26, 1986, FEMA observed an exercise of New Hampshire's plans to protect the public in the event of an accident at Seabrook. The final report of the evaluation of that exeercise was completed on June 2, 1986, and mailed to the State of New Hampshire on June 6,1986.

6.

I have read and am f amiliar with the emergency planning contentions which are the subject of Motions for Summary Disposition filed in June 1987, i

by the Applicant, the Attorney General of the Commonwealth of Massachusetts, I

and the Town of Hampton.

7.

Based on the continuing review by FEMA and the RAC of the New

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Hampshire radiological emergency response plans as well as the State's j

Compensatory Plan and revisions to the plans and the evaluation of the l

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emergency planning exercise conducted on February 26, 1986.

I am satisfied that, within the scope of the contentions listed below and the matters embraced by these contentions, the New Hampshire Radiological Emergency I

l Response Plans appear to be adequate and no genuine issue of material fact remains to be litigated.

For this reason, FEMA supports the following motions j

i for summary disposition:

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8.

FEMA supports the Applicant's Motion for Summary Disposition regarding Town of Kensington Contention 2.

This contention deals with the means by which the Town of Kensington will receive notification of an emergency at Seabrook.

In its review of Rev. 2 of New Hampshire Plans for Seabrook, dated December 15, 1986, FEMA and the RAC found that the Rockingham County Dispatch Center had both adequate equipment and personnel coverage for providing notification to the towns. The Affidavit of Gary J. Catapano submitted with this motion shows that the police and fire departments of I

l the Town of Kensington each have six radio pagers which can be useu for i

i notification purposes by the Rockingham County Dispatch Center.

9.

FEMA supports the Applicant's Motion for Summary Disposition regarding NECNP-RERP-2.

This contention deals with the areas in which the State requires federal assistance, especially from the U.S. Coast Guard and for shellfish examination.

In the FEMA /RAC Review of December 15, 1986, it was found that the deficiencies noted in Rev. 1 of the New Hampshire Plans with respect to this matter had been corrected..- ______

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A Edward A. Thomas i

i Subscribed and sworn to before me, the undersigned Notary Public, in i

Commonwealth l

the County of Suffolk,J fTL of Massachusetts this day of l

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.)u r L 1987.

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46{ ' 4(

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Notary Public l

j My Commission Expires:

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i DOBi i E.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION.N R -6 P2 di BEFORE THE ATOMIC SAFETY AND LICENSING iBOARD v,~

in the Matter of

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Docket Nos. 50-443 OL PUDLIC SERVICE COMPANY OF

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50-444 OL NEW HAMPSHIRE, et al.

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Off-site Emergency Planning

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(Seabrook Station, Units 1 and 2)

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CERTIFICATE OF SERVICE I

hereby certify that copies of "NRC STAFF'S

RESPONSE

TO MOTIONS FOR

SUMMARY

DISPOSITION OF OFF-SITE EMERGENCY l

PLANNING CONTENTIONS" in the above-capticned proceeding have been served on the following by deposit in the United States mall, first class or - as indicated by an asterisk,

by deposit in 'the Nuclear Regulatory Commission's internal mall

system, or as indicated by double asterisk, by express mall, this 2nd dry of July,1987.

Helen Hoyt, Esq., Chairman

  • Gustave A. Linenberger, Jr.*

Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Dr. Jerry Harbour

  • Ms. Carol Sneider, Esq.**

Administrative Judge Assistant Attorney General 1

Atomic Safety and Licensing Board Office of the Attorney General U.S. Nuclear Regulatory Commission One Ashburton Place,19th Floor i

Washington, DC 20555 Boston, MA 02108 Beverly Hollingworth Richard A. Hampe, Esq.

I 209 Winnacunnet Road New Hampshire Civli Defense Agency Hampton, NH 03842 107 Pleasant Street Concord, NH 03301 Sandra Gavutis, Chairman Calvin A. Canney, City Manager Board of Selectmen City Hall RFD 1 Box 1154 126 Daniel Street Kensington, NH 03827 Portsmouth, NH 03801 1

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Stephen E. Merrill Paul McEachern, Esq.**

Matthew T. Brock, Esq.

Attorney General

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Shaines & McEachern George Dana Bisbee Assistant Attorney General 25 Maplewood Avenue Office of the Attorney General P.O. Box 360 25 Capitol Street Portsmouth, NH 03801 Concord, NH 03301 Roberta C. Pevear Angie Machiros, Chairman State Representative Soard of Selectmen Town of Hampton Falls 25 High Road Drinkwater Road l

Newbury, MA 09150 Hampton Falls, NH 03844 Allen Lampert Mr. Robert J. Harrison Civil Defense Director President and Chief Executive Officer Town of Brentwood Public Service Co. of New Hampshire 20 Franklin Street P.O. Box 330 Exeter, NH 03833 Manchester, NH 03105 Charles P. Graham, Esq.

Robert A. Backus, Esq.**

McKay, Murphy and Graham Backus, Meyer & Solomon 100 Main Street 116 Lowell Street Amesbury, MA 01913 Manchester, NH 03106 Diane Curran, Esq.**

Philip Ahren, Esq.

Harmon & Weiss Assistant Attorney General

,e 2001 S Street, NW Office of the Attorney General Suite 430 State House Station #6 Washington, DC 20009 Augusta, ME 04333 Edward A. Thomas Thomas G. Dignan Jr., Esq.**

Federal Emergency Management Agency Ropes & Gray 442 J.W. McCormack (POCH) 225 Franklin Street Boston, MA 02109 Boston, MA 02110 H.J. Flynn, Esq.

William Armstrong Assistant General Counsel Civil Defense Director Federal Emergency Management Agency Town of Exeter 500 C Street, SW 10 Front Street Washington, DC 20472 Exeter, NH 03833 Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel

  • Board

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Jane Doughty Docketing and Service Section*

Scacoast Anti-Pollution League.

Office of the Secretary 5 Market Street U.S. Nuclear Regulatory Commission Portsmouth, NH 03801 Washington, DC 20555 Maynard L. Young, Chairman William S. Lord Board of Selectmen Board of Selectmen 10 Central Road Town Hall - Friend Street South Hampton, NH 03287 Amesbury, MA 01913 l

Michael Santosuosso, Chairman Peter J. Matthews, Mayor Board of Selectmen City Hall South Hampton, NH 03287 Newburyport, MN 09150 Mr. Robert Carrigg, Chairman Judith H. Mizner, Esq.

Board of Selectmen Silvergiate, Gertner, Baker Town Office Fine and Good Atlantic Avenue 88 Broad Street North Hampton, NH 03862 Boston, MA 02110 R. K. Gad ill, Esq.

Mrs. Anne E. Goodman, Chairman Ropes & Gray Board of Selectmen 225 Franklin Street 13-15 Newmarket Road Boston, MN 02110 Durham, NH 03824 Gary W. Holmes, Esq.

Honorable Gordon J. Humphrey Holmes & Ellis United States Senate 47 Winnacunnet Road 531 Hart Senate Office Building Hampton, NH 03842 Washington, DC 20510 Elaine 1. Chan Counsel for NRC Staff l

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