ML20195B815

Motion for Summary Disposition of Sapl Contention 5 & New England Coalition on Nuclear Pollution Contention RERP-10, Based on WT Wallace & Ja Macdonald Affidavits & Encl Statement of Facts Re Emergency Monitoring Capabilities

ML20195B815
Person / Time
Site:	Seabrook
Issue date:	05/20/1986
From:	Dignan T PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20195B803	List: ML20195B799 ML20195B811 ML20195B815 ML20195B826 ML20195B835 ML20195B848 ML20195B876 ML20195B886 ML20195B899 ML20195B924 ML20195B939 ML20195B945 ML20195B951 ML20195B956 ML20195B969 ML20195B985 ML20195B992 ML20195C010 ML20195C017 ML20195C022 ML20195C033 ML20195C041
References
OL, NUDOCS 8605290554
Download: ML20195B815 (7)

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t Dated: May 20, 1986 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD -

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PUBLIC SERVICE COMPANY.OF ) Docket Nos. 50-443-OL NEW HAMPSHIRE, et al. ) 50-444-OL

) Off-site Emergency (Seabrook Station, Units 1 and 2 ) Planning Issues

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APPLICANTS' MOTION FOR

SUMMARY

DISPOSITION OF SAPL CONTENTION NO. 5 AND NECNP CONTENTION RERP 10

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Pursuant to 10 CFR S.2.749, on the basis of the Affidavits of William T. Wallace and James A. MacDonald re SAPL Contention No. 5 and NECNP Contention RERP 10 (Wallace Affidavit) and the statement of undisputed facts attached hereto and for the reasons set forth below, the applicants move the Board to enter an order summarily disposing of SAPL Contention No. 5 and NECNP Contention No. RERP 10.

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.- REASONS FOR GRANTING THE MOTION SAPL Contention No. 5 reads:

"The New Hampshire State and local plans are deficient in that they do not ensure that there will be adequate personnel or the timely arrival of personnel trained in radiological monitoring in the plume exposure EPZ following a release of radiation from Seabrook Station.

Neither is there assurance that monitoring can be carried on for the required time frame. Therefore,'the requirements of 10 CFR 5 50.47(a)(1),

5 50.47(b)(1), S 50.47(b)(8),

5 50.47(b)(9), and NUREG-0654 II.I.7, I.8 and I.11 and II.A.4. are not met."

The Wallace Affidavit V 3-5 make clear that adequate personnel will be available to conduct the monitoring function. Contrary to certain assertions by SAPL as part of its basis for SAPL No. 5, S 4 of the Wallace Affidavit also makes clear that the 1-1/2 hour deployment time has no effect on the ability of the state to make assessments and decide on protective actions.

NECNP Contention RERP-10 reads as follows:

"The New Hampshire RERP violates 10 CFR 6 50.47(b)(9) in that it fails to demonstrate that ' adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.'"

The Board admitted the contention only with reference to bases (a)(b) and (d) as stated in the NECNP filing. The first (a) was an argument the three teams at any one time were not enough. The MacDonald Affidavit shows that the

.. three state teams can be augmented by utility teams. In addition, additional teams are necessary if needed under the New England Compact. Wallace Affidavit V 10. Basis (b) dealt with a lack of fixed monitoring locations. New Hampshire has adopted a grid system for locating teams as needed on the basis of available information; this is, if anything, superior to fixed locations. Wallace Affidavit 1-6. The final basis (d) is the same as the SAPL assertion regarding the 1-1/2 hour. deployment time discussed above.

By their attorneys,

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Thomas 7 .~DTgn g Jr.

R. K. Gad III Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100 i

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,. STATEMENT OF FACTS NOT IN DISPUTE

1. Monitoring team capabilities of the New Hampshire Division of Public Health Services (DPHS) are described in Section 2.5.3 of the New Hampshire Radiological Emergency Response Plan and in Volume 4, Section 3, New Hampshire Division of Public Health Services Emergency Response Procedures for Seabrook Station.

2. Section 2.5.3 establishes that Division of Public 4

Health Services will mobilize a minimum of'three two person field teams to monitor ground level radiation. A total of thirteen field monitors are identified in Volume 4, Section 3, Appendix B, Attachment 3 of which two monitors are designated for aerial monitoring as deemed advisable.

This total complement of field monitors provides the Division of Public Health Services with twenty-four hour capability to conduct field monitoring with a minimum of three, two person teams.

3. Field monitoring teams are deployed at the Alert level from Division of Public Health Services' laboratories on Hazen Drive, Concord, New Hampshire to the Incident Field Office at Newington, New Humpshire, for deployment to field monitoring locations. Teams can be deployed to monitoring locations within one and one-half hours after declaration of Alert. Prior to arrival of DPHS monitoring teams, the State of New Hampshire will base its assessment of accident conditions and protective response on results of monitoring i and dose projections conducted by the utility. Seabrook Station has the capability to deploy three field monitoring teams from the EOF within 60 minutes after declaration of Alert. In addition, Seabrook Station has the capability to deploy perimeter monitoring teams from the Control Room, immediately after declaration of an emergency'.

4. A total of thirteen monitors is a sufficient number to conduct field monitoring for the purpose of confirming

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off-site dose projections and for tracking plume direction.

Deployment of field monitoring teams of the State of New Hamsphire and of the utility is coordinated within the Emergency Operations Facility at Newington by field monitoring supervisors of the State of New Hampshire and of the utility. State and utility monitoring teams are deployed according to grid map designations established for-the entire EPZ. The grid map for the Seabrook Station EPZ is shown at Figure 2.5-2 of the New Hampshire RERP. By using the grid map, any location within the EPZ is potentially a designated monitoring point. Field monitoring results are reported by the teams to the field monitoring supervisors at the EOF. The results are analyzed by DPHS and utility assessment personnel at the EOF and used to 4

confirm the results of the dose projection model utilized jointly by the State of New Hampshire and the utility.

5. Appendix C of DPHS procedures contained in Volume 4, Section 3 of the New Hampshire RERP specify operating

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i procedures for field monitoring teams and instructions for conducting radiological monitoring which include obtaining environmental samples in the ingestion exposure pathway.

Monitoring for the purpose of confirming dose projections

-and environmental sampling in the ingestion pathway need not a be conducted simultaneously. Plume exposure pathway ,

monitoring will take precedence over ingestion pathway monitoring. In fact, environmental monitoring in the ingestion pathway is generally conducted during the recovery phase after. protective response actions for the public are completed. The inventory of equipment used by New Hampshire field monitoring' teams is contained in Appendix G of Volume 4,-Section 3. Laboratory analysis capabilities of the State of New Hamsphire are described in Appendix M of Volume 4, Section 3, Division of Public Health Services staffing roster shows primary and backup laboratory staffing for continuous operations.

6. If, for any reason, the State of New Hamsphire ,

requires field monitoring assistance, DPHS procedures contained in Volume 4, Section 3 provide for obtaining assistance under the New England Interstate Radiation Assistance Plan. The plan establishes the mechanism for requesting field monitoring assistance and laboratory analysis assistance from the five other states which are parties to the New England Compact on Radiological Health Protection. The provisions of the plan, including the o

. laboratory analysis capabilities of the parties to the compact, are contained in Appendix M to Volume 4, Section 3.

The New Hampshire Radiological Emergency Plan, at Section 1.4, also provides for support to be provided for radiological monitoring by the U.S. Department of Energy at the request of DPHS.