ML20205T453

Affidavit of EA Thomas on Kensington Contentions 2,7 & 10, Seacoast Anti-Pollution League Contentions 5 & 14 & New England Coalition on Nuclear Power Contentions RERP 3, RERP 10 & RERP 12

ML20205T453
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 8606130215
Download: ML20205T453 (3)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION .

hEFORE THE ATOMIC SAFETY AND LICENSING BOARD ~T In the Matter of )

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PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443 OL NEW HAMPSilIRE, et --

al. ) 50-444 OL

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(Seabrook Station, Units 1 and 2) )

AFFIDAVIT OF EDWARD A. TIIOMAS ON KENSINGTON CONTENTIONS 2, 7 AND 10; SAPL CONTENTIONS 5 AND 14; AND NECNP CONTENTIONS RERP 3, RERP 10, AND RERP 12 EDWARD A. T IIO M A S , being first duly sworn, deposes and says:

1. I am presently employed by the Federal Emergency Management Agency (FEMA), as Division Chief, Natural and Technological Hazards Division, FEMA Region I, in Boston, Massachusetts; as such, one of my i responsibilities is the management of FEMA's Radiological Emergency Planning Program in New England. I also serve as the Chairman of the Regional Assistance Committee (RAC), an interagency ccmmittee estab-lished pursuant to 44 C.F.R. 350.

2. Since 1981, I have been responsible for leading and coordi-nating the FEMA and RAC reviews and evaluations of State and local radiological emergency planning and preparedness in FEMA Region I (comprising the six-state New England area). In this regard, I have reviewed or supervised the review of the radiological emergency response plans of numerous State and local jurisdictions within the New England area, and participated in observing and/or evaluating the conduct of fO 3 i - . _ . _ _ - _ _ _ _ _ _ __ . _ _ _ _ -

over twenty radiological emergency preparedness exercises in FEMA Region I.

3. HEMA and the RAC have reviewed the state and local radio- ~7 logical emergency response plans submitted to FEMA by the State of New Hampshire, which were designed to protect the health and safety of the public in the event of a radiological emergency at the Seabrook Nuclear Power Plant. These reviews were performed under my direction by FEMA staff, consultants to FEMA, members of the RAC and other federal employees who assisted the RAC members.

4. On February 26, 1980, FEMA observed an exercise of New Hamp-shire's plans to protect the public in the event of an accident at Seabrook. This exercise was conducted under my general supervision.

A draft report of that exercise was issued April 30, 1986. A final report of the exercise was completed June 2, 1986, and mailed to the State of New Hampshire on June 6,1986.

5. I have read and am familiar with the emergency planning contentions admitted by the Licensing Board's Orders of April 1 and 29, 1986, as to which the Applicants and/or the State of New Hampshire sought summary disposition by motions dated May 20, 1986.

6. Based upon FEMA and the RAC's review of the New Hampshire radiological emergency response plans and the emergency planning exer-cise conducted on February 26, 1980, os well as the State's compensatory plan and revisions to the plans which have been made, I am satisfied that , within the scope of the contentions listed below and the matters embraced by these contentions, the New Hampshire radiological emergency

c i

3 response plans appear to be adequate and no genuine issue of material

't fact remains to be litigated. These contentions are as foll%s:

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$ML Contention 5 and hECitP Contention RERP 10 (Radiation Field Monitoring);

hECNP Contentico RERP 3 and SAPL Ccatention 14 (French Language ]nformation anc Communications);

Kensington Contentions 2 anc 10 (Kensington Communications); and Xensington Contention 7 and NEChP Centention RERP 12 (Radioproter.tive Orugs),

EdwaTd A. Thomas ~~

Subscribed and sworn to before om 4 Notary Public in the County cf Suffolk, CorWonwealth of Massachusetts, this lith da/ Of June, 1986, ,

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Notary Publfc y commission expires: h[" / 7[(

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