ML20059A891

Affidavit of GL Iverson Re Adequate Staffing at New Hampshire Radiological Emergency Plan in Event of Radiological Emergency at Seabrook.W/Certificate of Svc

ML20059A891
Person / Time
Site:	Seabrook
Issue date:	08/16/1990
From:	Iverson G PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:
References
CON-#390-10740 OL, OL-1, NUDOCS 9008240097
Download: ML20059A891 (10)

Text

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.#- USNRC August 16, 1990 UNITED STATES OF AMERICA -)() AtG 17 P2:18 before the ,

r,p icr or SECiitT W ic NUCLEAR REGULATORY COMMISSIdN " $SO:If ' '

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In the Matter of )

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PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443-OL-1 '

NEW HAMPSHIRE,-et al. ) 50-444-OL-1

) (Offsite Emergency (Seabrook Station, Units 1 and 2) ) Planning and Safety (

) Issues)  ;

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AFFIDAVIT OF GEORGE L. IVERSON I, George L. Iverson, being on oath, depose and say follows:

1. I am the Director of the New Hampshire office of Emergency  ;

Management (NHOEM). .

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2. I have read and am familiar with the Affidavit of Michael C. .,

Sinclair dated August 6, 1990, and attached to Intervenors'  !

Emergency Motion to Reopen the Record on the Adequacy of . the .

Staffing of the NHRERP and for Immediate Shutdown, dated August 7, 1990. The purpose of this affidavit is to demonstrate that Mr.

Sinclair, perhaps due to a lack of~ current information, is simply wrong insofar as he suggests that there are significant deficiencies in the staffing of the New Hampshire State and local 1

9008240097 900816 gDR ADOCK 05000443-PDR

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emergency response. functions called- for under the New Hampshire Radiological Emergency Response Plan (NHRERP), Revision 3.

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3. Upon receipt of the July 20,'1990 letter from Mr. Sinclair'to Judge Ivan Smith (Exhibit A to the Sinclair Affidavit), and as a direct result thereof, I directed my staff in cooperation with the i staff of New Hampshire Yankee to perform an updated personnel resources analysis-for the NHRERP. The methodology for developing I the personnel resources analysis parallels the effort undertaken to prepare the Personnel Resources Assessment Survey presented in the New Hampshire phase of the licensing proceeding.

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4. Initial examination of the State and -local personnel resources on August 1, 1990 showed that 22 positions needed to staff. the NHRERP (two shifts) appeared to be vacant. This 1

shortfall is approximately 2 percent and is of a magnitude that is

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to be expected due to normal on-going personnel changes.

5. Efforts continued to assess the staffing needs in accordance with the most current revision (Revision 3) of the NHRERP. At the same time personnel assignments were made from existing staff to fill the identified vacancies. The results of this assessment and-assignment process are that, as of August 15, 1990, there are 3 vacancies in the 1263 positions needed to staff the NHRERP.

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6. Presented below are specific comparisons of the required staffing leavels and the available personnel' resources for the particular State, local and support organizations which have been 4 ,

alleged as deficient.

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7. The Sinclair Affidavit alleges the New Hampshire Department of Health and Human . Services, 'which under the- NHRERP has responsibilities assigned to its Division of Public Health Services ,

(DPHS) and Division of Human Services (DHS), has insufficient staff available tol fill positions for Reception Center staff, Accident Analysis personnel, Field Monitors, = Laboratory Support, and Decontamination Supervisor. personnel. Each is addressed below, i'

8. The DHS provides personnel for staffing of the following positions at the Host Community Reception Centers: Registrars, .

. Message Exchange and Locating Service, Coordination of Volunteers, Information and Recreation Workers, Sorters and Receivers, and

' Student Processors. (NHRERP~ Volume 7 at'Section 5.1). Based on the 1990- population projections for the New Hampshire 'EPZ communities, the total number of staff required to fill these positions is 470. There is no shortfall in personnel to staff

-these DHS positions. The initial assessment identified a shortf all 3

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E of 3 persons.

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9. The DPHS-provides personnel for staffing of positions in the Host Community Reception Centers, State EOC and State IFO as well as providing field monitoring - personnel. .There are. currently sufficient personnel (DPHS supplemented by the Department of Agriculture, Department of Fish and Game, Department of

- Environmental Services, and National Guard personnel) available to staff the 90 positions required under the NHRERP. The initial assessment identified-a shortfall of 9 persons.

10. The NHOEM provides personnel for staf fing positions within the State EOC, State IFO and Media Center. There is currently a total of 85 NHOEM personnel and volunteers available to staff the 86

-positions required under the NHRERP. The 86 required positions assume a compensat ary response for non-participating EPZ communities. The.e is one vacant second shift NHOEM position of Joint Telephora Information Center Media Relations / Rumor Control Supervisor. The initial assessment identified a shortfall of 4 persons.

11. Local community organizations also provide personnel to support implementation of the NHRERP. In four communities (Hampton, Kensington, Rye and South Hampton) who have recently 4

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begun planning or who do not yet participate.in planning, the State

emergency response organization is capable of _ providing a - full j compensatory response. In the remaining 13 communities, Kingston  ;

has a shortfall of one person for staffing the second shift RADEF officer position and Exeter has a shortfall of one person for the second shift Health officer position. The initial assessment appeared' to indicate a shortfall ~of 5' persons in the 13-communities. I

12. The NHRERP also .elies upon non-government as well as government transportation resource providers for buses, ambulances and wheelchair vans. The most current numbers for these resources and drivers indicate that there are more than sufficient resources available to implement the NHRERP.

13. The shortf alls in staffing that existed lit the State and local ., _

organizations have been or are being filled in an orderly and officient manner as part of the on-going resource maintenance program. In my opinion, the identified shortfalls reflect normal changes within the State and local organizations and are not related to State budget cuts.

14. With respect to paragraph 8 of Mr. Sinclair's Affidavit, I do 5

not know,how Mr. Sinclair ' formed . the impression ef.my views <as expressed therein. I can- only believe- that- Mr. Sinclair- ,

misinterpreted in his own mind our conversation. However, as set forth above,,it is my opinion that adequate staff is available to implement'the NHRERP in the event of a radiological. emergency.at seabrook.-

U j George L. Iverson -j l

Merrimack County, NH August 16, 1990 '

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l The-above-subscribed George L. Iverson appeared before me and made .1 oath that he had read the foregoing affidavit and that the-statements set forth therein are true- to the best of his knowledge. 4 Before me, l

NotargfPublic" 9 My Commission Expires

-l F$RRELYN M. HAKIM, Notary Putdic .

My Commission Empires October 26,1993 4

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. DOCKETED USNRC CERTIFICATE OF SERVICE

'90 A% 17 P2 :19-I, Thomas G. Dignan, Jr. , one of the attorneys for the Licensees herein, hereby certify that on August 16, 199 mad service of the within document by depositing copies thy (t 9y#$[

Federal Express, prepaid, for delivery to (or where ind NC y depositing in the United States mail, first class postage paid, addressed to) the individuals listed below:

Kenneth M. Carr, Chairman Thomas M. Roberts,' Commissioner '

U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission One White Flint North One White Flint North 11555 Rockville Pike 11555 Rockville Pike Rockville, MD 20852 Rockville, MD 20852 Forrest J. Remick, Commissioner James R. Curtiss, Commissioner U.S. Nuclear Regulatory U.S. Nuclear Regulatory.

Commission Commission One White Flint North One White Flint North 11555 Rockville Pike 11555 Rockville Pike Rockville, MD 20852 Rockville, MD 20852 Kenneth C. Rogers, Commissioner William C. Parler, Esquire U.S. Nuclear Regulatory General Counsel Commission Office of the General Counsel one White Flint North One White Flint North 11555 Rockville Fike 11555 Rockville Pike Rockville, MD 20852 Rockville, MD 20852 G. Paul Bollwerk, III, Chairman Mr. Howard A. Wilber Atomic Safety and Licensing Atomic Safety and Licensing 1 Appeal Panel Appeal Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission  :

Fifth Floor Fifth Floor 1 4350 East-West Highway 4350 East-West Highway Bethesda, MD 20814 Bethesda, MD 20814 Alan S. Rosenthal, Esquire Mr. Thomas S. Moore Atomic Safety and Licensing Atomic Safety and Licensing l Appeal Panel Appeal Panel U.S. . Nuclear Regulatory U.S. Nuclear. Regulatory Commission Commission Fifth Floor Fifth Floor 4350 East-West Highway 4350 East-West Highway Bethesda, MD 20814 Bethesda, MD 20814 l

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Administrative Judge Ivan Smith Administrative Judge Kenneth A.

Chairman, Atomic Safety and McCollom Licensing Board' 1107 West Knapp Street' U.S. Nuclear Regulatory Stillwater, OK 74075 Commission East West Towers Building 4350 East West Highway j Bethesda, MD 20814 Administrative Judge' Richard F. H. Joseph Flynn, Esquire Cole, Atomic Safety and Office of General Counsel Licensing Board Federal Emergency Management  :

U.S. Nuclear Regulatory Agency ,

Commission 500 C Street, S.W. l East West Towers Building Washington, DC 20472 4350 East West Highway Bethesda, MD 20814 ,

Mr. Richard R. Donovan Diane Curran, Esquire Federal Emergency Management Andrea C. Ferster, Esquire Agency- Harmon, Curran & Tousley Federal Regional Center Suite 430 1 130 228th Street, S.W. 2001 S Street,RN.W. ,

Bothell, WA 98021-9796 Washington, DC 20009 '

Robert R. Pierce, Esquire George Dana Bisbee, Esquire Atomic Safety and Licensing Associate A'torney General l Board Office of cae Attorney General U.S. Nuclear Regulatory 25 Capitol-Street l Commission Concord, NH 03301-6397 East West Towers Building 1

-4350 East West Highway Bethesda, MD 20814 Adjudicatory File Mitzi A. Young, Esquire Atomic Safety and Licensing Edwin J. Reis, Esquire

Board Panel Docket (2 copies) Office of the General Counsel U.S. Nuclear Regulatory U.S. Nuclear Regulatory l Commission Commission '

East West Towers Building _One White Flint North, 15th Fl.

4350 East West Highway 11555 Rockville Pike Bethesda, MD 20814 Rockville, MD 20852-l l

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• Atomic Safety and Licensing Robert A. Backus, Esquire Appeal Panel Backus, Meyer & Solomon U.S. Nuclear Regulatory 116 Lowell Street Commission- P.O. Box 516 Mail Stop EWW-529 Manchester,- NH 03105 Washingten, DC 20555 Philip Ahrens, Esquire Suzanne P. Egan, City Solicitor Assistant Attorney General Lagoulis, Hill-Whilton &

Department of the Attorney Rotondi General 79 State Street j Augusta, ME 04333 Newburyport, MA 01950 :l 4

Paul McEachern, Esquire John Traficonte, Esquire i Shaines & McEachern ' Assistant Attorney General )

Maplewood Avenue Department of the Attorney i P.O. Box 360 General I Portsmouth, NH 03801 One Ashburton Place, 19th Floor-  !

Boston, MA 02108

• Senator Gordon J. Humphrey R. Scott Hill-Whilton, Esquire U.S. Senate Lagoulis, Hill-Whilton & L Washington, DC 20510 Rotondi j (Attn: Tom Burack) 79 State Street i Newburyport,. MA 01950

• Senator Gordon J. Humphrey Barbara J._ Saint Andre, Esquire i One Eagle Square, Suite 507 Kopelman and Paige, P.C.  ;

Concord, NH 03301 101 Arch Street (Attn: Herb Boynton) Boston,.MA 02110 Ashod N. Amirian, Esquire Judith'i. Mizner, Esquire i 145 South Main Street 79 State Street, 2nd Floor j P.O. Box 38 Newburyport, _MA 01950  :

Bradford, MA 01835 i

Gary W. Holmes, Esquire Marjorie Nordlinger, Esquire  !

Holmes & Ells Office of:the General Counsel  !

47 Winnacunnet Road One White Flint North I Hampton, NH 03842 11555 Rockville Pike Rockville, MD 20852 Mr. Jack Dolan .

Federal Emergency Management  !

Agency - Region I J.W. McCormack Post Office &

Courthouse Building, Room 442 Boston, MA 02109 I

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• i George Iverson,- Director N.H. Office of Emergency Management State House Office Park South

'107 Pleasant Street Concord,--NH 03301 '

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