ML20205E357

Commonwealth of Ma Atty General Supplemental Response to NRC Staff First Set of Interrogatories & First Request for Documents.* Certificate of Svc Encl.Related Correspondence

ML20205E357
Person / Time
Site:	Seabrook
Issue date:	10/24/1988
From:	Talbot P MASSACHUSETTS, COMMONWEALTH OF
To:	NRC OFFICE OF THE GENERAL COUNSEL (OGC)
References
CON-#488-7358 OL, NUDOCS 8810270372
Download: ML20205E357 (14)

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$)k.f UllITED STATES OF AMERICA 11UCLEAR REGULATORY COMMISSIO!1 88 CCT 25 P5 :48 ATOMIC SAFETY At1D LICEllSIl1G BOARD n:

Before the Administrative Judges:

Ivan W. Smith, Chairman Gustave A. Linenburger, Jr.

Dr. Jer ry }{a rbour

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In the Matter of ) Docket tios. 50-443-OL-

) 50-444-OL PUBLIC SERVICE COMPAt1Y ) (Off-Site .P OF f1EW HAMPSilIRE, ET AL. )

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(Seabrook Station, Units 1 and 2)) October 24, l'388

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MASSACHUSETTS ATTORt1EY GEllERAL' S SUPPLEME!1TAL RESPOt1SE TO t1RC STAFF'S FIRST SET OF I!1TERROGATORIES At1D FIRST REQUEST FOR DOCUMEllTS Introduction The following supplemental responses, unless otherwise indicated, should not be interpreted as withdrawing the tiass AG's filed objections to the Staff's First Request. Instead, the Mass AG has narrowed the requests where appropriate.

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Restansa_1 The Mass AG will obtain relevant information from the following agencies:

Massachusetts Civil Defense Agency ("MCDA")

Massachusetts Department of Public Safety ("DPS")

Massachusetts Department of Public Health ("DPH")

Massachusetts Department of Environmental Quality l Engineering ("DEQE")

Massachusetts National Guard ("Guard")

Massachusetts State Police Massachusetts Department of Agriculture ("MDA")

Governor's Executive Office Documents and information gathered from the aforementioned agencies are limited to the time frame of January 1, 1986 to the present and include radiological response plans for commercial reactors within or bordering the Commonwealth; plans and documen'es related to emergency response (both radiological and non-radiological) within the Seabrook EPZ, and/or state emergency planning that effects the Seabrook EPZ.

The documents presently available for inspection include:

Pilgrim Station Radiological Emergency Response Plan; Yankee Rowe Radiological Emergency Response Plan; Vermont Yankee Radiological Emergency Response Plan; Massachusetts Comprehensive Emergency Response Plan ("CERP"); Massachusetts Civil Defense Agency Emergency Operations Center Utilization Plan; Area I Emergency Plan; Massachusetts Ingestion Exposure ,

Pathway Plan; Nuclear Incident Advisory Team Handbook ("NIAT"); '

Technical Review of NIAT Handbook; The New England Interstate  ;

Radiation Assistance Plan; Massachusetts Emergency Response Commission Guide to Local Hazardous Material Planning; all L

i documents and plans revised or current in 1986, which relate to radiological emergency tesponse in the EPZ and host communities; state agency emergency response plans submitted to MCt a.; pamphlets entitled (respectively) When_DLicateLSitlho, R a d i tt ion _Co nt r oLP t c Q I3 m , R adialogic a LEmerg ency_In tarma ti o n Cot f umers_and _Ecod_Etocessars Nuclear _Enctgy_Qucations_and Answets; Erocedutes lo tRadiation_ Accident _Eatients; packet of "Civil Defense Legal Authorities."

The Massachusetts National Guard is in the process of rewriting the entire Domestic Emergency Standing Operating Procedures ("DESOP"). As soon as that document is made 1

available, it will be produced to the Staff. In the meantime, the Mass AG has a current DRAFT copy of the Mohawk operati,ons H

plan of DESOP which will be produced to the St.af f.

Response _2 4

I The function of personnel with regard to each document

identified above is as set forth in each document.

J Response _3 (a) State police attend basic training for five (5) months at the State Police Academy. After this, they train for three (3) months with a senior officer. Every year, officers attend at least four (4) days of "in service" training at the Academy regarding new laws or procedures. All officers are certified as "first responders

• with the American Red Cross ("ARC")

I 'w a n i ng that they attend a CPR coutse offered by ARC every year. They receive fire rms qualification every six (6) q

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months. In addition, a wide variety of advanced training courses are available (Lin. ballistics, public speaking, criminal justice, breathalyzer, photography.)  !

(b) The MCDA, as the state coordinating agency for emergency response, participates in annual exercises and i directs monthly meetings for state agency personnel who would ,

be responsive in an emergency.

(c-g) A generic state emergency response is premised on I the use of personnel and equipment from local emergency forces. As such, information pertaining to these categories of l personnel should be addressed to the appropriate local and/or ,

t private entity.

(h) In addition to meetings directed by the MCDA, the DpH i receives training regarding radiological incidents through  ;

courses offered by FEMA, and the National Emergency Training i l

Center. ,

(i) The National Guard is trained by the federal (

government. However, the MCDA offers training the National y Guard with respect to state response to emergencies. (nb: the f federal government, however, trains the National Guard with l L

respect to civil disturbances.) To supplement basic training. l i

the Guard has manuals regarding radiological monitoring, survey .

and decontamination. Additional information is being collected [

with respect to the type and frequency of training offered by f MCDA. (

I (j) See Response 3(c-g).

I (k-m) See original objections.

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Response _4 The Seabrook EPZ is contained in "Area I." Area I Emergency Plans, as described in Response 1, will be produced.

Response _3 The number of relevant Civil Defense personnel employed by the Commonwealth is approximately fifty (50); the number of State police employed by the Commonwealth is approximately twelve hundred (1,200).

Information pertaining to the assigned strength of any unit or units of the National Guard is classified information.

However, the Mass AG will produce a list, provided by the National Guard, which provides the location of units in Massachusetts. As of October 13, 1988, the "authorized strength" of the troop units assigned to the National Guard was 16,407. That number constitutes what the United States Department of the Army and the United States Air Force heve assigned to the Massachusetts National Guard.

Response _1 In large part, the documents listed in Response 1 speak for themselves. Because a state response to an emergency is premised on local effort, requests of this sort should be addressed to the appropriate local entity.

Except for approximately thirty (30) commercial automobiles, the MCDA has no equipment of the type requested.

Additional information regarding radio equipment is being gathered.

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The State Police has the following equipment: one (1) I airplane; three (3) helicopters; twelve hundred (1,200)

I vehicles (including cruisers, vans, trucks, motorcycles); one (1) mobile emergency command post. Additional information regarding radio equipment is being gathered. l The National Guard has listed the following equipment as [

available on October 13, 1987: }

Military vehicles - 1300 (capable of transporting personnel, with seating capacity from 6-16.) ,

Military radios - 800 vehicle mounted; 300 pottable. L Commercial type - 75 sedans (4-5 passengers); 30 vans / ,

vehicles carryalls (6-8 passengers); 15 buses (

(25-44 passengers).

Military aircraft - 3 fixed wing (2-12 passengers); 50 [

rotary wing (2-6 passengers).

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It should be noted that because National Guard equipment could be on loan to another state or could be in repair, the aforementioned figures are approximations and can change according to availability. [

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I Response 1 The Mass AG stands by his original objection that he is not  !

obliged to conduct analyses or computations. [

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l Besponse..a  ;

i See Response 5 and 6. [

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O Ecsponac_2 Relevant plans specifically concerning radiological response have been listed in Response 1. Manuals in the possession of the flational Guard which concern radiological monitoring, survey and decontamination will be produced.

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! Respons e_1.0 To the extent that plans listed in Response 1 have I provisions for the handling of contaminated individuals, they contain the information sought. In addition, the DpH conducts i

periodic surveys of hospitals to assess their capability in 1 terms of their ability to provide services for radiologically 1

contaminated individuals.

Response 10a

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Correspondence dated after January 1, 1986, between the DPH f and various Massachusetts hospitals will be produced, i

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\ Besconne 11 See the Massachusetts Ingestion pathway Exposure plan and j the pamphlet on Radiological Emergency Information for Farmers and Food processors described in Response 1. The Mass AG withdraws his objection to this request to the exter.t that it 1

seeks information concerning reactors other than Seabrook, f

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Response _12 l

See Response 3(b); Reaponse 5; Response 6.

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Resconse 13 The Operational plan is being produced and it speaks for itself.  ;

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Reanonae 14 l Limited to the time period January 1, 1986 to the present, r i

document (s) will be produced. [

Respona.e_15 i

See original objection. .

Respanse._16 i See original objection.  !

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j Rnsnons_e 17 {

, i The documents speak for themselves.

• Response __18 [

i See original objection.

I Response _12  !

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See original objection. i i

i Response _.20 l

See original objection. I i

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Resp.ons.e_2.1 "The beach" or the "the beach area" of the Massachusetts portion of the Seabrook EPZ includes the barrier beach islands of (1) Plum Island; and (2) that island on which Salisbury Beach is situated, from the state line in the north to the sourthern tip of the Salisbury Beach State Reservation.

Response _22 i

other than the data on beach area vehicles that was submitted to the ASLB, and consequently to the Staff, during the NHRERP proceedings, the Mass AG has no additional l

information at this time that would be responsive to this interrogatory.

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Rc30onse_23 i

j Other than the information and studies which were supplied to the parties and filed with the ASLB in the NHRERp proceedings, we have no such studies.

Response _2.4 Other than the information and studies which were supplied to the parties and filed with the ASLB in the NHRERP proceedings, we have no such studies, i

Response _21 See original objection.

o Respons e_Z5_thLeuctL2.8 The Mass AG io still seeking information, for the period after January 1, 1986 to the present.

Respectfully submitted, JAMES M. SHA!111011 ATTORt!EY GEt1ERAL COMMO!1 WEALTH OF MASSACHUSETTS f 1 -w By: [_N h PamelaTaIbot Assistant Attorney General Department of the Attorney General fluclear Safety Unit One Ashburton Place / 19th Floor Boston, MA 02108 (617) 727-2200 DATED: October 24, 1988 LOMiU uwC Ut11TED STATES OF AMERICA 11UCLEAR REGULATORY COMMI581dy!T 25 PS :48 Yo I?

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In the Matter of )

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PUBLIC SERVICE COMPAt1Y OF ) Docket flo.(s) 11EW HAMPSHIRE, ET AL. ) 50-443/444-OL (Sea'orook Station, Units 1 and 2) ) (Off-site EP)

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CERTIEICATE_DE_SERYlCE I, Pamela Talbot, hereby certify that on October 24, 1988 I made service of the within MASSACHUSETTS ATTORt1EY GEllERAL'S SUPPLEMEt1TAL RESPO!!SE TO !1RC STAFF'S FIRST SET OF It1TERROGATORIES A!1D FIRST REQUEST FOR DOCUMEllTS, by First Class Mail, by hand-delivery as indicated by (*)

or by Federal Express as indicated by [**] to the following parties:

Sherwin E. Turk, Esq. Docketing and Service U.S. 11uclear R'ayulatory Commission U.S. Nuclear Regulatory Commission office of General Counsel Washington, DC 20555 15th Floor 11555 Rockville Pike Rockville, MD 20852 Ivan Smith, Chairman Gustavo A. Linenberger, Jr.

Atomic Safety & Licensing Board Atomic Safety & Licensing Board U.S. t1uclear Regulatory U.S. fluclear Regulatory Commission Commission East West Towers Building East West Towers Building 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 Bethesda, MD 20814 Dr. Jerry Harbour Robert R. Pierce, Esq.

Atomic Safety & Licensing Board Atomic Safety & Licensing Board U.S. tiuclea r Regulatory U.S. 11uclear Regulatory Commission Commission East West Towers Building East West Towers Building 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 Bethesda, MD 20814 NOTE: The above mentioned document was also faxed to Sherwin E. Turk on October 24, 19E8.

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}{ . Joseph Flynn, Esq. Stephen E. Merrill ,

Assistant General Counsel Attorney Gennrul l Office of General Counsel George Dana Bisbee Federal Emergency Management Assistant Attorney General )

Agency Office of the Attorney General 500 C Street, S.W. 25 Capitol Street Washington, DC 20472 Concord, NH 03301 Docketing and Service Paul A. Fritt. sche, Esq.

U.S. Nuclear Regulatory Office of the Public Advocate Commission State House Station 112 Washington, DC. 20555 Augusta, ME 04333 Roberta C. Pevear Diana P. Randall State Representative 70 Collins Street Town of Hampton Falls Seabrook, NH 03874 Drinkwater Road llampton Falls, Nil 03844 Atomic Safety & Licensing Robert A. Backus, Esq.

Appeal Board Panel Backus, Meyer & Solomon U.S. Nuclear Regulatory 116 Lowell Street Commission P.O. Box 516 Washington, DC 20555 Manchestor, NH 03106 Atomic Safety & Licensing Jane Doughty Board Panel Seacoast Anti-Pollution League U.S. Nuclear Regulatory 5 Market Street Commission Portsmouth, Nil 03801 Washington, DC 20555 Matthew T. Brock. Esq. J. P. Nadeau Shaines & McEachern Doard of Selectmen 25 Maplewood Avenue 10 Central Road P.O. Box 360 Rye, Nil 03870 Portsmouth, N}i 03801 Sandra Gavutis, Chairperson Calvin A. Canney Board of Selectmen City Manager RFD 1, Box 1154 City Hall Rte. 107 126 Daniel Street Kensington, N}l 03827 Portsmouth, Nil 03801 l

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Senator Gordon J. Ilumphrey Angelo Machiros, Chairman  :

U.S. Senato Board of Selectmen ,

Washington, DC 20510 25 liigh Road '

(Attn: Tom Burack) Newbury, MA 10950 ,

Senator Gordon J. Humphrey Edward G. Molin 1 Eagle Square, Suite 507 Mayor (

Concord, Nil 03301 City Hall )

(Attn: Herb Boynton) Newburyport, MA 01950 Donald E. Chick William Lord Town Manager Board of Selectmen Town of Exeter Town Hall '

10 Front Street Friend Street Exeter, Nil 03833 Amesbury, MA 01913 Brentwood Board of Selectmen Gary W. Ilolmes, Esq.

HFD Dalton Road flolmes & Ellis Drentwood, Hit 03833 17 Winnacunnet Road Hampton, NH 03841 Philip Ahrens, Esq. Ellyn Weiss, Esq.

Assistant Attorney General Harmon & Weiss Department of the Attorney Suite 430 General 2001 S Street, N.W.

State House Station #6 Washington, DC 20009 Augusta, ME 04333

' Thomas G. Dignan, Esq. Richard A. Hampe, Esq.

Hopes & Gray llampe & McNicholas 225 Franklin Street 35 Picasant Street Boston, MA 02110 Conco r d, 11H 03301 Beverly Hollingworth Ashod H. Amirian, Esq.

209 Winnacunnet Road 376 Main Street flampton, Nil 03842 Haverhill, MA 01830 William Armstrong Michael Santosuosso, Chairman Civil Defense Director Board of Selectmen Town of Exeter Jewell Street, RFD 2 10 Front Street South flampton, Nil 03827 Exeter, Nil 03833 Robert Carrigg, Chairman Anne E. Goodman, Chairperson Board of Selectmen Board of Selectmen Town Office 13-15 Newmarket Road Atlantic Avenue Durham, NH 03824 North flampton, Nil 03862 Allen Lampert Sheldon J. Wolfe, Chairperson Civil Defense Director 1110 Wimbledon Drive Town of Brentwood McLean, VA 22101 20 Franklin Street Exeter, NJ 03833 O

e Charles P. Graham, Esq. Datbara St. Andre, Esq.

Murphy & Graham Kopelman & Paige, P.C.

33 Low Street 77 Franklin Street flewbu r ypo r t , fu 01950 Boston, MA 02110 Judith II. Mizner, Esq. R. Scot t liill-Whil ton, Esq.

Lagoulis, Clark, Ilill-Whilton Lagoulis, Clark, !!ill-Whilton

& McGuire & McGuire 79 State Street 79 State Street flewbu L y po r t , MA 01950 flewbu t ypo r t , MA 01950

--Pamela Talbot Assistant Attorney General fluclear Safety Unit Department of the Attorney General One Ashburton Place Boston, MA 02108-1698 (617) 727-2200 DATED: October 24, 1988

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