ML20205T458

Affidavit of EA Thomas Re Radiological Emergency Preparedness Exercises

ML20205T458
Person / Time
Site:	Seabrook
Issue date:	06/11/1986
From:	Eric Thomas Federal Emergency Management Agency
To:
Shared Package
ML20205T438	List: ML20205T436 ML20205T441 ML20205T453 ML20205T458 ML20205T463
References
OL, NUDOCS 8606130218
Download: ML20205T458 (8)

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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

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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.

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($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.)

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. . 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 _

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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 .)

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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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