ML20008D478

Intervenor Exhibit I-MAG-109,consisting of Commonwealth of Ma Atty General 881219 Answers to NRC Third Set of Interrogatories & Requests for Production of Documents

ML20008D478
Person / Time
Site:	Seabrook
Issue date:	06/01/1989
From:	MASSACHUSETTS, COMMONWEALTH OF
To:	NRC OFFICE OF THE GENERAL COUNSEL (OGC)
References
OL-I-MAG-109, NUDOCS 9003050181
Download: ML20008D478 (8)

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USNHC UNITED' STATES OF AMERICA m

NUCLEAR REGULATORY .COMMISsApw 18 P4 :34 ATOMIC SAFETY AND. LICENSING BOARD. '

OFrlCE OF SECRETARY Before'theAdministrativeJbM,flgIC ,

Ivan W. Smith, Chairman Gustave A. Linenberger, Jr. i Dr. Jerry Harbour ~

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In'the Matter of ) Docket Nos. 50-443-OL

) 50-44.4-OL PUBLIC SERVICE COMPANY ) (Off-Site EP)

OF NEW HAMPSHIRE, EI AL. )

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(Seabrook Station, Units 1 and 2) ) December 19, 1988' <

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MASSACHUSETTS ATTORNEY GENERAL'S ANSWERS I TO NRC STAFF'S THIRD SET OF INTERROGATORIES AND_SEOUESTS FOR PRODUCTION OF DOCUMENTS INIEREQQATORY.1: Define the' term "ad hoc" as it is used in any  ;

of your contentions concerning the Seabrook Plan for Massachusetts  !

Communities (SPMC).

RESPONSE: "Ad hoc" means "for this particular purpose only."-

.In the context of the subject contentions, an "ad hoc" response or -l action means one that is not adequately and completely addressed by

.one.or more existing plans.

(7 INTERROGATORY 2: Identify and list all actions to protect

/. .the public in the event of a radiological. emergency at Seabrook Station which -

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(a) you would take.

(b) you might take. '

(c) you could take.

9003050181 890601 PDR 0 ADDCK 05000443 PDR '

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OBJECTION:' The Mass AG objects to interrogatory 2 on the l grounds =that it is-not sufficiently concrete.

The phrase "a radiological emergency at Seabrook Station" is not precise: enough.-  !

t Depending,on the nature and severity of such an emergency, the

-Commonwealth would, might or could take'any number of actions.

Further, the Mass AG objects to detailing what the Commonwealth ~

"might" or "could" do on the grounds that this involves aaly ':

speculatiun.

• l RESEQUEE:- "

s t a t e Eplism : Because no. current plan exists for a ~

. radiological' emergency at Seabrook, State' police officials would look toward the RERP, App. 3, Section C-3 of Area I MCDA Operations:

. plan for Seabrook Station (dated April 1986)'for guidance.- That.

plan directs the' State Police to coordinate theLimplementation of traffic and access control, coordinate law enforcement services with-local communities, maintain communication with Troop A "

Headquarters-and the Topsfield Barracks, and assist the Area I Transportation Coordinator dispatch vehicles from the Topsfield Fair Grounds staging area. The aforementioned plan has been-produced to the Staff.

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Because this plan has not been updated, tested or exercised, the State' Police would not be able to. totally rely on it. For example, the Topsfield Barracks no longer exist. During an emergency, the State Police would have to assess.the development of l

1 the emergency response and alter or disregard the aforementioned i o r-plan where it would impede effective response. A serious problem exists in the simple fact that the plan itself is not readily l

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available to most of those in the state police command strueb.ure.

and it is'not available1st all.to any of the troopers in their vehicles. .

.Qgpartment of Public Works:

The DPW would refer to Offsite Emergency Preparedness Training for Pilgrim Nuclear Power Stati6n,. -i Overview of Implementing Procedures (" PIP"). This was produced t'o.  !

a the Staff. PIP is site specific to Pilgrim. It instructs DPW

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officials to notify and update Maintenance Engine'er: provide liaison; relay state request for assistance; remove road impediments; provide vehicles as requested; clear evacuation' routes of any equipment; clear ~ evacuation routes of any snow and ice; supervise delivery of equipment; inventory and' dispatch' equipment; deliver equipment; issue dosimetry;-track dose of DPW staff. The DPW would endeavor to apply PIP to the situation at hand and, where feasible, would attempt as best it could to apply the resources it' has av,ailable at the time to perform as many of the'above listed functions as it can.

National Guald: Because.no Memoranda of' Understanding with respect to an emergency response at Seabrook have been entered into, the Guard would not rely on any specific plan in! responding to such a radiological emergency. After being alerted of'the- <

L emergency by the MCDA and/or the Department of Public Safety, au 1 project officer would consult.with the assigned MCDA and/or.

Department of Public Safety Official and would, after consultation L and. pursuant to established procedures, mobilize the Guard in order l- to provide the manpower, resources, and equipment necessary, as indicated by the circumstances. Plans setting forth the actions to l

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-i. .1 be t'aken when mobilizing the Guard are Domestic Emergency Standing-1 Operating Procedures (" Mass NG DESOp") an1 the.OpLAN-2

(" Mohawk")

(presently in draft form).

Both plans have'been_ produced to the Staff. .

.MBTA: The MBTA would pull buses from scheduled routes and -

attempt'to deploy additional personnel .nat would be required.to assist in evacuation of the EPZ. The MBTA would rely on and attempt to implement the 1984 deployment plan if MCDA recommended to do-so.

The MBTA would, in any case, attempt to deploy the number of buses needed for each evacuating community, as indicated by the MCDA.

The aforementioned plan was mailed to the Staff with-

.these Answers, under separate cover.

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-QeDartment of Public Health: Because there are presently no- 4 specific emergency plans for responding to a Seabrook emergency, e DPH NIAT members would respond to an emergency by relying on previous training.and experience in_ handling emergencies at other nuclear power plants. NIAT member actions would correspond to those set out in the NIAT handbook which was-produced to the

' Staff.

The NIAT handbook would be relied on as a basic guide for

r this response. Actions to be taken pursuant to the NIAT handbook ,

are: confirmation of radiological emergency; notification to appropriate response individuals and agencies as identified in the 1 Comprehensive Emergency Response Plan ("CERP") (CERP has also been produced to the' Staff); evaluation of the hazard; comparison of hazard against protective action guides as detailed in CERp; recommendation of protective actions; performance of radiation surveys to confirm that ambient radiation levels are low enough to

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permit re-entry of the general.public. .

MCDA: The MCDA would, upon authorization, utilize ad hoc l measures as determined by.the Director or his. designee. MCDA would J to look to the CERP for guidance. Where applicable and advisable, 1 MCDA would'use its best' efforts to take the following actions:

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alert state officials, FEMA'and the American Red Cross; inform communities, agencies, Secretary of public Safety and the Governor;-

1 activate emergency response organization and facilities; notify and mobilize state support agencies; coordinate support as requested from local communities; coordinate the status of resources available from support agencies; dispatch representative to <

utility's EOC;' recommend protective actions; coordinate public notification; coordinate interstate response and maintain contact with civil defense agencies in other affected states; assist with media support; gather and analyze intelligence; coordinate .

provisions of state support ~to affected communities.

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The Director of MCDA, or his designee, after consultation with the Commissioner of Public Health, the Commissioner of DEQE, local ~'

officials and possibly a nuclear engineer, meteorologist-or other such private person as the situation warranted, would most likely-  ;,

have responsiblity for making ad hoc judgments.as to protective actions to maximize dose reductions. These ad hoc judgments: would ~

be made in conjunction with one or more state and local officials, t

, r and, after consultation with the Secretary of Public Safety, or his designees, would result in a recommendation by the Secretary of Public. Safety to the Governor. However, because there is no s'ite 1

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l- i specific plan for the Seabrook EPZ, upon authorization the MCDA would have to rely upon professional experience in extrapolating from other existing plans (like CERP) the appropriate and: specific-actions and course of action. Even with MCDA's expertise and familiarity with existing plans like CERP, the lack of planning' at.

the local and area level, as well as the inadequacy of-staff, >

facilities and communication infrastructure would impede .

ey,editioNhandorderlyresponse. Also, because of the unfamiliarity of respondents at those levels with the MCDA and=AD I hoc' response or with actions upon which the MCDA would base such a response, the MCDA would anticipate great difficulty in coordinating the necessary materials, personnel and resources.

Deoartment of Food and Aariculture: DFA would refer to ,

Exhibit 3, CERP, when acting in response to radiological energy'at seabrook. That document has been produced to the Staff. If required by MCDA,.DFA would make ad hoc judgments'when formulating advice to farmers.as to how to minimize the effects of the ..

emergency (i.e.:

confine cows, switch to sileage and stored dry feeds).

1 Governor's Office: If circumstances required a declaration of I a state of emergency, the Governor or his designee would issue such' i

a. declaration in accordance with the Civil Defense Act. After f I consultation with the Secretary of Public Safety or his des.ignee as i to the ad hoc measures to be taken, the Governor would exercise 1 1

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responsibility for the issuance of emergency public information, coordination (where applicable) with other states, and l l

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l authorization of protective actions. . The Governor or the Secretary of-Public Safety, on a recommendation by the Director of Civil E Defense, would. authorize assistance from appropriate State. agencies within their capability,-and would request federal agency support' allowable under existing Federal statutory authority, to render!'

assistance'to a stricken community.

FlJhatis2_and Wildli t e : DFW would, if circumstances dictated, distribute notices regarding contaminated fish and wildlife. There 4 would be no plan upon which such action would directly rely. . .l Executive Office of Public Safetv: The Secretary of Public Safety, or his' designee, would oversee and assist in the coordination of emergency assistance, looking to the CERP for'

-general guidance.

As set forth in the earlier answers.concerning MCDA, and the Governor's Office, the Secretary of Public Safety has ]

an active role in forming ad hoc judgments and recommendations to the Governor as well as in exercising authority over state j cesources, 9 f'

-QEQE: The DEQE is-not authorized to act as a primary l 1

respondent in a radiological emergency. i i

s INTranOCATORY 3:. j Identify and list all resources to take the actions identified in response to the prior Interrogatory (Interrogatory No. 2) you -

( (a) have.

) (b) may have.

Q1JECILQH: The Mass AG objects to interrogatory 3 to the extent that it seeks what resources the Commonwealth "may have."

It is unclear what "may have" adds to the inquiry concerning what