ML20244D657
| ML20244D657 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 04/18/1989 |
| From: | Callendrello A, Frank C, Jay Robinson ABB IMPELL CORP. (FORMERLY IMPELL CORP.), PUBLIC SERVICE CO. OF NEW HAMPSHIRE, YANKEE ATOMIC ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20244D592 | List: |
| References | |
| OL, NUDOCS 8904240062 | |
| Download: ML20244D657 (164) | |
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l @iED CORRESPONDS 1 S- 00thliE0 E unikC l '89 APR 20 P5 :21 April 18, 1989 bGC?? ii a .,;n wb UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD t
I ;
In the Matter of )
)
PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443-OL NEW HAMPSHIRE, et al. 50-444-OL l
(Seabrook Station, Units 1 and 2) ) (Off-site Emergency
) Planning Issues)
I. !
APPLICANTS' REBUTTAL TESTIMONY NO. 21 (COORDINATION OF GOVERNMENTAL RESOURCES AND RESPONSES)
Panel Members: Anthony M. Callendrello, Manager, Emergency Preparedness Licensing, New Hampshire Yankee f
Catherino M. Frank, Emergency Planner, Impell Corporation I
John G. Robinson, Director of Environmental Engineering, Yankee Atomic Electric Company I
I 0904240062 890418 PDR ADOCK 03000443 T PDR, ll
TABLE OP CONTENTS 1
I. INTRODUCTION . . . . . . . . . . . . . . . . . . . 1 ]
L II. STATE / LOCAL EMERGENCY RESPONSE CAPABILITIES . . . . 1 A. Participation in Radiological Emergency Response Planning . . . . . . . . . . . . . . 1 l
~B . Existing Commonwealth Capabilities'. . . . . . 8
- 1. State Police . . .. . . . . . . . . . . 11 !
- 2. Massachusetts Department of Public Works (MDPW) . . . . . . . . . . . . . . . . . 12 i
- 3. National Guard . . . . . . . . . . . .. 14 ..
- 4. Massachusetts Bay Transit Authority (MBTA) . . . . . . . . . . . . . . . . . 15
- 5. Massachusetts Department of Public Health (MDPH) . . . . . . . . . . . . . . . . . 16
- 6. Massachusetts Civil Defense Agency (MCDA) 18
- 7. Massachusetts Department of Food and Agriculture (MDFA) . . . . . . . . . . . 19 ;
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- 8. Governor's Office . . . . . . . . . . . . 20
- 9. Executive Office of Public Safety . . . . 21'
- 10. Massachusetts Department of Fisheries and -t Wildlife (MDFW) . . . . . . . . . . . . . 21
[ 11. Massachusetts Department of Environmental J. Quality Engineering (MDEQE) . . . . . . . 22 III. SPMC RESPONSE CAPABILITIES . . . . . . . . . . . . 23 A. SPMC Conceptual Basis . . . . . . . . . . . . 23 B. SPMC Spectrum of Response . . . . . . . . . . 27 !
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- 1. - Determination of Operational Mode . . - . . 27 2L. - Standby Mode . . .... 1 . . . . . . . 28
- 3. Mode 1 . . . . . . . ' . . . . . - . . . . . . 28
- 4. Mode 2 . . . . . . . . . . . . . . . -. . 32 C. Definition of Liaison Roles . . . . . . . - . . 35
- 1. Regulatory Guidance . . . . . . . . . . . . 13 5
- 2. Liaison Functions.. . . . . . . . . . . . . 36 D. SPMC-Assigned Governmental Functions . . . . . 40
- 1. Routine Governmental Functions. . . . . . 41 a '. Security . . . . . . . . . . . . .. . . 43
- b. Public Health . . . . .. . . . . . . 44 c.- -Evacuation . . . . . . . . . . . . . 46
- d. Emergency-Specific Rescue Needs . .. 46
- 2. Mutual Aid Agreements . . . . . . . . . . 48
- 3. State / Local Facilities, Resources, and Communications -. . . . . . . . . .'- . . . . 51 E. SPMC Provisions For Local Communities . . . . 57 F. Coordination of' Response . . . . . . . . . . .
59
- 1. - Resources from Support Organizations . . 59
- 2. Massachusetts Officials . . . . . . . . . 60
- 3. Coordination of ORO and the State of New l Hampshire . . . . . . . . . . . . . . . . . 63
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Attachment A: Brief History and Status of Massachusetts
.- Radiological Emergency Response Plans, 3/80 Attachment B: Executive Order No. 144 l
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l Attachment C: Massachusetts State Police Barracks Location-List Attachment D: Memorandum of Understanding Between the Massachusetts Civil Defense Agency and the Massachusetts National Guard, 6/84 Attachment E: Massachusetts Department of Food and Agriculture, Civil Defense - Manager's Action.
Plan, 12/8/88 Affidavit of Michael S. Dukakis,.4/28/87 I Attachment F:
Attachment G: Memorandum of Peter W. Agnes to Robert Boulay, 1/11/88, and Massachusetts Attorney General's Answer to the Applicants Revised Request for Admissions-from Mass AG, 12/16/88 Attachment H: Merrimac Emergency Operations Plan, 2/83, Page 15 Attachment I: Fire Department Mutual Aid Documents Attachment J: Incident Tanker Mutual Aid Drill, 10/24/88 Attachment K: Mass.-(sic] Casualty Procedures for Watch i Station and Town of Amesbury Mass. (sic] j Casualty Incident E.M.S. Response Plan' 1
'l Attachment L: Merrimac Emergency Operations Plan, Page 4, #6 Attachment M: Town of Salisbury Emergency Response Plan SARA Title III, Page 6 Attachment N: Merrimac Emergency Operations Plan, Pages 8 and 9 I Attachment 0: Merrimac Organizational Chart Attachment P: Merrimac Emergency Operations Plan, Pages 11 and 12 Attachment Q: Massachusetts Civil Defense Agency (MCDA) r- Memorandum, 3/8/88 Attachment R: Letter of Agreement between the State of New Hampshire and New Hampshire Yankee f Representing Both the Emergency and Offsite
/ Response Organizations
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I I Attachment S: Letter of Agreement Between New Hampshire Yankee Division of Public Service Company of New Hampshire and the States of New Hampshire and Massachusetts i
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I. INTRODUCTION This testimony addresses Joint Intervenor (JI)
Contentions 27, 61, 62, and 63. These contentions challenge the adequacy of the SPMC assignments and definition of emergency response areas of responsibility; the SPMC's purported reliance on Commonwealth and local facilities and resources; and the ability of the Offsite Response f
Organization (ORO) to coordinate its actions and integrate use of its resources with those of other organizations including Commonwealth of Massachusetts, State of New Hampshire and local responders. !
The testimony details the extensive emergency response capabilities of the Commonwealth of Massachusetts and the !
local communities in the Seabrook Station EPZ, and the SPMC l provisions for incorporating the SPMC into the government response.
II. STATE / LOCAL EMERGENCY RESPONSE CAPABILITIES A. Participation in Radiological Emergency Response Planning The Massachusetts Civil Defense Agency (MCDA), created l under Massachusetts Special Laws C. 31, S 2, is designated to I
" . . . coordinate the activities of all organizations for civil defense within the Commonwealth, and shall cooperate and maintain liaison with civil defense agencies of other states and the federal government . . .
" As such, MCDA is l
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the principal emergency coordination agency in the Commonwealth. The Commonwealth has stated that in response to an emergency at Seabrook Station the "MCDA would to (sic) look to the CERP for guidance." Massachusetts Attorney General's Answers to NRC Staff's Third Set of Interrogatories and Request for Production of Documents, 12/19/08, page 5.
The Commonwealth's Comprehensive Emergency Response Plan (CERP), Rev. 1, 6/15/84, Applicants' Exhibit No. 57, provides the structure of the State emergency response organization and outlines the responsibilities of State and local .
1 governments in responding to an emergency. At page ONE-1, the purpose of the CERP is stated as:
"The purpose of Part One of this Plan is to .
identify responsibilities and describe actions and procedures required of State and local government in order to respond effectively to the threat or occurrence of any non-military disaster or emergency."
Page ONE-70 addresses the purpose of the Hazard-Specific Supplements to the CERP:
"The procedures set forth above in Part One of this l Plan represent a standardized response to the full i range of disasters to which the Commonwealth is known to be vulnerable, and are sufficiently generalized to be effective in the event of f undefined emergency situations. The Hazard- ;
) Specific Supplements included in this Attachment are intended to amplify the general procedures and t responsibilities of Part One proper. Supplements j- have been developed for these particular hazards for one or both of two reasons:
The nature of the hazard is such that the l generalized preparedness warning or response
, 4 actions described in Part One proper can be supplemented with more specific information.
[or]
The nature of the measures taken in response d' to a specific disaster agent can be more fully developed. An example is the planned response to possible major accidents at nuclear' power. 4 stations . . .
Hazard-Specific Supplement No. 6 (pages ONE-96 through ONE-99 of the CERP) establishes that " Basic responsibility and authority for dealing with_any type of accident involving nuclear materials is assigned by law to the Department of. l Public Health and exercised through its Radiation Control-Program" and that " Coordinating the preparation and execution l
of contingency plans.of local governments and State agencies I 1
so as to carry.out the recommendations of the Commissioner of Public Health is the responsibility of the Secretary of Public Safety and, under Chapter 639 of the General Laws, is I carried out through the Massachusetts Civil Defense Agency." !
Applicants' Exhibit No. 57, pages 105 and 106.
In addition, this Supplement identifies, at ONE-98, response by Commonwealth Nuclear Incident Advisory Teams-f (NIAT). l J "The Department of Public Health in cooperation L with the Massachusetts State Police, operated (sic]
a well-tested system of responses to the threat or 7- occurrence of nuclear incidents. This response, led by the Radiation Control Program of the
[ Department of Public Health, is conducted by Nuclear Incident Advisory Teams (NIAT), with l assistance from the State Police on both initial 1 alerting and emergency response."
Applicants' Exhibit No. 57, pg. 107.
The CERP establishes the formal organization, l responsibilities and interfaces on a state and local level for emergency response within Massachusetts. Development of the Commonwealth's Radiological Emergency Response Plan (RERP Appendix 3 to Hazard-Specific Supplement 6 of the CERP) was initiated in 1975 to provide guidance to State and local officials for responding to radiological emergencies at Pilgrim, Yankee (Rowe), and Vermont Yankee nuclear power plants.
The RERP was developed as an appendix to the Massachusetts CERP to reflect "the fact that radiological emergencies at nuclear facilities are specialized kinds of emergencies. However, they have much in common with both natural disasters and emergency situations caused by man.
Many of the emergency response functions which must be carried out (warning, coordination of emergency services, etc.) are common to all emergencies." RERP, 4/86, Applicants' Exhibit No. 55, pg. 5.
Guidance in the 1975 RERP included provisions for evacuation, reception centers, and incorporation of American Red Cross response for all three plants.
A substantial upgrade to the RERP was undertaken in 1979 incorporating the 10-mile plume exposure and 50-mile I
ingestion pathsay planning zone guidance from NUREG-0396 and i
expanding sections on warning and communication, coordination of emergency operations, public information, and accident 1
assessment. Functional annexes to the RERP " document in j detail responsibilities and procedures associated with various radiological emergency response functions." Brief History and Status of Massachusetts Radiological Emergency Response Plans, 3/80, Attachment A hereto, page 5.
Local communities were recipients of copies of the RERP j as well as area and local plans in December of 1979. The-RERP became effective December 31, 1979. See Attachment A hereto, page 5.
The RERP is organized as follows:
"Section A is the State Radiological Emergency Response Plan . . . Section B is the State's emergency preparedness maintenance program . . . Section C contains the Massachusetts Civil Defense Agency and Office of Emergency Preparedness Area Plan...Section C-1 contains those plans for Pilgrim Nuclear Power Station (MCDA/OEP AREA II), Section C-2
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contains plans for Yankee Nuclear Power Station (Yankee Rowe)
[ and Vermont Yankee Nuclear Power Station (MCDA/OEP Area IV),
I and Section C-3 contains the plans for Seabrook Station L ,
(MCDA/OEP Area I)." Applicants' Exhibit No. 55, pg. '
5.
The 1979 RERP was considered by MCDA to " form an l
f l excellent base for the Seabrook area work," and was projected
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I to " progress in coordination with officials of the State of New Hampshire, with whom Massachusetts (and Vermont) have been working closely on plans for the Vernon (VT) nuclear power station (Vermont Yankee]." See Attachment A hereto, page 7.
Planning by the Commonwealth, in conjunction with the utility, for the Massachusetts communities in the Seabrook plume exposure EPZ was initiated early in 1982. A prototype local plan was completed in October 1983. Later in 1983, MCDA established a task force to revise and complete local plans.
During 1984, emergency planning coordination meetings were attended by representatives of Seabrook Station, FEMA, NRC, Massachusetts, and New Hampshire. Late in the year, revised local plans and a revision of the RERP were submitted to FEMA Region I for technical review.
By mid-1985, emergency planning committees composed of public safety officialc and members of the public were established in the Massachusetts EPZ communities. Planning assistance to state and local officials was provided by personnel under contract to the Commonwealth.
Work continued on the development of the Seabrook- l specific State plan, the Area 1 MCDA plan, and plans and
! implementing procedures for all six EPZ communities and 2 host communities. These plans were sufficiently advanced I I
l that Secretary of Public Safety Barry requested that FEMA perform a technical review of them in February 1986. FEMA I
and NRC representatives performed that review and presented i their findings to the Commonwealth in April, 1986. The
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State, Area I, and local plans were all revised to incorporate the results of the technical review. These are i the April 1986 plans referred to by the Commonwealth in its !
l response to NRC Staff's Third Set of Interrogatories and Request for Production of Documents.
During the period when these plans were undergoing development, other activities were also progressing.
Training of Area I and local responders was ongoing, and at the time the Governor called a halt to all Seabrook-related activities, at least 500 persons including municipal Civil Defense, Department Heads, School and Special Facility, Fire, Police, Emergency Medical Services, and Public Works personnel had received some training. Training was also conducted for approximately 100 Essex County Sheriff's Department Deputies. All six Massachusetts EPZ communities 1
are within Essex County. Further, NHY provided substantial l equipment to State and local responders to improve their I
communication, emergency management, and radiological t
j monitoring capabilities.
The formal town meeting vote by the Town of Amesbury on
) November 18, 1985 to refuse to participate in completing i
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I i their local. radiological emergency response plan led MCDA to authorize development of a state compensatory plan for non-participating communities. A draft of the plan was developed I to " define and establish response of the commonwealth of Massachusetts for radiological emergencies at the Seabrook Station in (sic) behalf of one or more municipalities when municipal response is unable to function or is impeded or impaired by natural or man-made disasters or other conditions." Appendix 5, Compensatory Response Plan, Area I, MCDA/OEP, Radiological Emergency Response Support Plan for Seabrook Nuclear Power Station, 1986, page 1. To provide the capability to respond in support of any of the six Massachusetts communities, Attachments 5-A through 5-F of this plan contain information summaries for each of the six communities.
Following the accident at Chernobyl, Governor Dukakis ordered a halt to all Seabrook-related implementation activities on April 29, 1986. MCDA halted contractor planning activities on June 13, 1986. The Governor announced his refusal to allow any further State or local planning for Seabrook Station on September 20, 1986.
B. Existing Commonwealth Capabilities The Commonwealth of Massachusetts has been prepared to respond to a radiological emergency for over a decade. A structured State response organization is in place and has I I 9
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l been trained and tested in response to simulated emergencies at Pilgrim, Yankee (Rowe), and Vermont Yankee nuclear plants.
Between 1982 and the present, the Commonwealth organization has participated in 12 FEMA-graded exercises for these plants. Facilities and equipment in place to support response to these plants are equally available to support a coordinated response with the New Hampshire Yankee Offsite Response Organization during an emergency at Seabrook Station. !
In addition, Executive Order No. 144 was issued by i
Commonwealth Governor Michael S. Dukakis on September 27, '
1978 "as a necessary preparatory step in advance of actual disaster or catastrophe and as part of the comprehensive plan and program for the Civil Defense of the Commonwealth." ;
Executive Order No. 144, Attachment B hereto. The Order further establishes that "each secretariat, independent division, board, commission and authority of the Government of the Commonwealth (hereinafter referred to as agencies) ;
shall make appropriate plans... for maintaining or providing services appropriate to the agency which may be required on f an emergency basis for carrying out such emergency
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responsibilities as may be assigned by this Order or by subsequent Order... and for rendering such additional f
emergency assistance as the Secretary of Public Safety and the Civil Defense Agency and Office of Emergency Preparedness 1 ,
may require." The Order also directs the promulgation and
' issuance of a Comprehensive Emergency Response Plan'(CERP) which constitutes " official guidance for operations for all agencies and political subdivisions of the Commonwealth in ;
the event of an emergency or natural disaster."
The CERP, at pages One-13 through ONE-25, assigns
" responsibilities for specific State agencies with clear-cut emergency roles and responsibilities... under the provisions of Executive. Order 144." Applicants' Exhibit No. 57, pg. 21.
Eleven executive office-level agencies and twenty-eight division, department, or commission-level organizations are identified. " Responsibilities are further developed, and procedures for carrying them out, are detailed in the Functional Annexes to this State Plan." Applicants' Exhibit No. 57, pg. 18.
Moreover, actions the Commonwealth would take to protect the public in the event-of a radiological emergency at Seabrook Station are identified in Massachusetts Attorney General's Answers to NRC Staff's Third Set of Interrogatories and Requests for Production of Documents, 12/19/88, hereafter f referred to as Mass AG Responses, 3rd Set. At pages 2 V
through 7 of that document, Mass AG describes the anticipated responses of eleven State agencies or departments.
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- 1. State Police State Police officials would "look toward RERP, App. 3, Section C-3 of Area I MCDA Operations Plan for Seabrook Station (dated April 1986) (Applicants' Exhibit No. 55A] for guidance." Identified response actions are coordination of traffic and access control, coordination of law enforcement services with local communities, maintenance of communications with Troop A headquarters, and provision of assistance in dispatching vehicles. An important function not listed in Mass AG's responses but directed by Section C-3 i
is notification. Appendix 1 to RERP, Appendix 3, Section C-3 ;
is the " Massachusetts State Police Troop 'A' Radiological Emergency Response Support Plan." This plan states:
"After receiving the initial notification, the Troop "A" dispatcher will notify MCDA/OEP, MDPH, and the 24-hour dispatch points for the six EPZ communities. If the initial notification begins at an Alert, the Troop "A" dispatcher will also notify MDPW in addition to the above parties."
Applicants' Exhibit No. 55A, pg. 189.
At page 5 of Massachusetts Attorney General's Second Supplemental Response to NRC Staff's First Set of Interrogatories and the First Request for Production of I
Documents, 12/19/88 (hereafter referred to as Mass AG Responses, 1st Set), 923 State Police are described as having been assigned to field operations, with 225 of this number located at Framingham (A-Troop). It should be noted that l
while the Topsfield Barracks has been closed, some of the troopers have been. assigned to the barracks in Newbury, which f
is within the EPZ. A copy of the Massachusetts State Police barracks location list is Attachment c' hereto. Mass AG l
further notes that approximately 45 of the 225 would be on duty on a given shift and that this ratio applies to the other 5. Troops as well. An additional 397 personnel assigned to the Bureau of Investigative. Services and Support Services could be: activated to augment field operations in the event of a large scale emergency.
The total pool of available State Police personnel is thus 1320. The fact that all are not on duty at one time does not affect their identification as available resources.
Approximately 3300 troopers are available through the New England State Police Compact. While this number includes personnel who would be responding in both New Hampshire and Massachusetts, it also provides a reserve to supplement Commonwealth needs.
- 2. Massachusetts Department of Public Works (MDPW)
The MDPW.would refer to "Offsite Emergency Preparedness
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Training for Pilgrim Nuclear Power Station Overview of
. Implementing Procedures (' PIP') (Applicants' Exhibit No. 56]
.. . . The DPW would endeavor to ap' ply PIP to the situation at hand and, where feasible, would attempt as best it could
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l to apply the resources it has available at the time to I perform as many of the . . .
functions (covered in the training) as it can." Mass AG Responses, 3rd Set, pg. 3.
The functions listed in this Pilgrim lesson plan are generic and apply to seven positions. These positions and their duties are as follows:
- 1. MCDA Area DPW Representative: notify and update the Maintenance Engineer; provide a liaison l function; relay State reguests for assistance.
- 2. Roadside Engineer: remove road impediments; provide vehicles as requested; clear evacuation routes of any equipment.
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- 3. Snow and Ice Control Engineer; clear evacuation-routes of any snow and ice.
- 4. Traffic Maintenance Engineer: supervise delivery of equipment.
- 5. Traffic Maintenance Section Foreman: inventory and dispatch equipment.
- 6. Traffic Maintenance Section Worker: deliver equipment.
- 7. Dosimetry Coordinators: issue dosimetry; track dose of DPW staff.
Thirty-one supervisory DPW personnel are available to respond in a radiological emergency. DPW also has approximately 120 individuals trained in radiological i emergency response available to respond to a radiological emergency at Seabrook. Mass AG Responses, 1st Set, pg. 7.
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- 3. National Guard
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National Guard response in Massachusetts is described by J Mass AG as not relying on any specific plan in responding to ,
l an emergency at Seabrook "(b]ecause no Memoranda of j Understanding with respect to an emergency response at Seabrook have been entered into . . .
" "After being notified <
by the MCDA and/or the Department of Public Safety, a project .,
1 officer would consult with the assigned MCDA and/or Department of Public Safety official and would after consultation and pursuant to established procedures, mobilize :
the Guard in order to provide the manpower, resources and equipment necessary as indicated by the circumstances." Mass AG Responses, 3rd Set, pg. 3.
MCDA, in looking "to the CERP for guidance" (Mass AG Response, 3rd Set, pg. 5) would find the following responsibilities specifically assigned to the National Guard:
" Supports civil authorities in maintaining law and order, providing security, and establishing traffic control in disastor areas; Assists local authorities in the evacuation of critical areas and the performance of search and rescue operations; Provides emergency medical care and transportation
} for injured disaster victims; Assists in debris clearance and in emergency repair of critical facilities; f
Provides emergency water supplies and supports emergency mass feeding; l
Provides emergency communications services; Provides engineering personnel to assist in damage assessment; ,
Assists in victim identification and mortuary services."
Applicants' Exhibit No. 57, pages 30 and 31.
"As of October 13, 1988, the ' authorized strength' of troop units assigned to the National Guard was 16,407."
Massachusetts Attorney General's Supplemental Response to NRC Staff's First Set of Interrogatories and First Request for Documents, 10/24/88.
A copy of the signed June 1984 Memorandum of Understanding (MOU) between the Massachusetts civil Defense Agency and the Massachusetts National Guard is Attachment D hereto. The MOU is assumed to be in effect since page 4 of this document states that revisions or changes are to be provided as written amendments.
- 4. Massachusetts Bay Transit Authority (MBTA)
MBTA, upon the recommendation of the MCDA, would implement the 1984 MBTA Resource Deployment Plan (Applicants' Exhibit No. 58), which was developed for response to a Seabrook Station emergency. The stated mission of this plan is to augment the transportation capabilities of the six Massachusetts communities located within the 10-mile Seabrook Station EPZ. Applicants' Exhibit No. 58, pg. 3. The MBTA I would, "in any case, attempt to deploy the number of buses
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needed for each evacuating community, as indicated by the MCDA." Mass AG Responses, 3rd Set, pg. 4.
In addition to 1032 buses, resources maintained by MBTA include 66 police vehicles, 135 vans, 257 heavy equipment and construction vehicles and 390 cars and trucks. Mass AG Responses, 1st Set, pgs. 11 and 12.
- 5. Massachusetts Department of Public Health I (MDPH)
Mass AG states that MDPH NIAT members would respond to a '
Seabrook Station emergency by relying on previous training l
and experience in handling emergencies at other nuclear power plants and the basic guidance provided in the NIAT handbook ;
(Applicants' Exhibit No. 59), "because there are presently no specific emergency plans for responding to a Seabrook emergency." Actions to be taken are: confirmation of radiological czergency; notification to appropriate individuals and agencies identified in the CERP; evaluation of the hazard; comparison of hazard against protective action !
guides in the CERP; recommendation of protective actions; performance of radiation surveys to confirm that ambient i radiation levels are low enough to permit re-entry of the general public. Mass AG Responses, 3rd Set, pgs. 4 and 5.
The Radiation Control Program Director or his designee would evaluate information received from the ORO on offsite l I "'' "" """ ""***"'""'""'"""'""'~"""""""
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I back to the-senior MDPH official in Framingham. This information flow would parallel that utilized for response to Vermont Yankee and Yankee Rowe.
That NIAT members rely on previous training and experience to respond is not unique to seabrook Station.
This direction is the language of the NIAT Handbook itself:
"The philosophy adopted herein is to establish general guidelines for you to follow and to have you rely on your general experience. . . As a NIAT member your response to a radiation emergency will be guided by your professional <
judgment." Applicants' Exhibit No. 59, pg. 6. The planning detail contained in the NIAT Handbook includes site-specific information for a response to Seabrook Station. The implementing procedures in the Handbook are generic and provide directions for responding to any of the four plants (Pilgrim, Vermont Yankee, Yankee Rowe, or Seabrook). The NIAT Handbook is part of the RERP. Applicants' Exhibit No.
59, pg. 5.
Thirteen DPH employees are NIAT members. Mass AG Responses, 3rd Set, pg. 6. In addition, NIAT currently has 35 professional advisors / consultants whose function is to augment the NIAT members' response to an incident.
Applicants' Exhibit No. 59, pp. 18 through 22.
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- 6. Massachusetts Civil Defense Agency (MCDA)
MCDA would " utilize ad hoc measures . . . look to the CERP for guidance . . . rely upon professional experience in extrapolating from other existing plans (like CERP) the appropriate and specific courses of action." Those actions are:
" Alert state officials, FEMA and the American Red I Cross; inform communities, agencies, Secretary of Public Safety and the Governor; activate emergency response organization and facilities; notify and '
mobilize state support agencies; coordinate support I as requested from local communities; coordinate the status of resources available from support 4
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agencies; dispatch representative to utility's EOC; I 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 J provisions of state support to affected ,
communities."
I Mass AG Response, 3rd Set, pg. 5.
I While not stated in the interrogatory response, it is presumed that coordination of State support includes the Area I office of MCDA in Tewksbury, Massachusetts, as this office provides a forward coordination center for State support of locel activities. "Upon notification of threatened or actual disaster . . . State, Area and local Emergency Operating Centers (EOCs) will be activated as rapidly ac possible."
Applicants' Exhibit No. 57, pg. 40.
Approximately 50 civil Defense personnel employed by the Commonwealth vould constitute the response pool for MCDA I I
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I actions. Massachusetts Attorney General's Supplemental Response to NRC Staff's First Set of Interrogatories and First Request for Documents, 10/24/88, pg. 5.
3 7. Massachusetts Department of Food and 3 Agriculture (MDFA) l The MDFA "would refer to Exhibit 3, CERP, when acting in response to radiological energy (sic) at Seabrook . . . If required by MCDA, [M]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 silage (sic) and stored dry feeds)." Mass AG Responses, 3rd i
Set, pg. 6. The Exhibit 3 referred to by Mass AG is
" Procedure for Ingestion Pathway Sample Collection," part of the Massachusetts Ingestion Exposure Pathway Plan (IEPP) ,
July'1987 (Applicants' Exhibit No. 60). As directed in that plan, "If the Governor determines that protective actions must be taken to protect the public from contaminated food, the Department of Food and Agriculture will provide personnel 4 and assistance in implementation of that control."
Applicants' Exhibit No. 60, pg. 20. MDFA is also responsible i
for maintaining data on agriculture facilities within 50 l miles of a nuclear power station and for supplying these data to MDPH. "MDPH is responsible for recommending appropriate I protective actions for the Ingestion Exposure Pathway EPZ i
including milk, water and/or food control." Applicants' I .
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Exhibit No. 60, pg. 19. EBS messages developed at the State EOC would be reviewed by MDPH and a representative of the Governor's Office before release. Applicants' Exhibit No.
60, pg. 43.
Eighteen MDFA personnel would be available to support MDPH. Mass AG Responses, 1st Set, pg. 6. The MDFA Manager's Action Plan lists 4 individuals who could direct DFA's response, 4 emergency operations control personnel (administrative), and 21 emergency key personnel.
I Massachusetts Department of Food and Agriculture, Civil Defense - Manager's Action Plan, 12/8/88, pg. z, Attachment E, hereto.
- 8. Governor's Office The Governor's Office would, when warranted, declare a state of emergency and after " consultation with the Secretary of Public Safety or his designee as to the ad hoc measures to be taken, the Governor would exercise responsibility for the insuance of cmergency public information, coordination (where I applicable) with other States, and authorization of protective actions." The Governor or the Secretary of Public Safety would authorize assistance from State agencies and would request Federal support. Mass AG Responses, 3rd Set, .
pgs. 6 and 7. Protective actions are determined on the basis of input from both MDPH and MCDA.
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- 9. Executive Office of Public Safety The Executive Office of Public Safety, through the Secretary of Public Safety or his designee, would use the CERP for guidance in overseeing and assisting in the coordination of emergency assistance. "The Secretary of Public Safety has an active role in forming ad hoc judgments and recommendations to the Governor as well as exercising authority over state resources." Mass AG Response, 3rd Set, pg. 7.
Current emergency information is supplied direct'.y to the Secretary of Public Safety or his designee for usa in decisionmaking. "The Intelligence Section (at State and Area-level EOCs), will determine the nature and extent of the emergency, and the progress of response actions and will provide the State Civil Defense Director and the Functional f
Service coordinators with pertinent information. This intelligence becomes the basis for command decisions on the l part of the Governor, the Secretary of Public Safety, the State Civil Defense Director, and State operating officials."
Applicants' Exhibit No. 57, pg. 61.
I 10. Massachusetts Department of Fisheries and Wildlife (MDFW)
"The DFW Division of Law Enforcement employe approximately one hundred seven (107) officers." Mass AG Responses, 1st Set, pg. 6. The MDFW would distribute notices I - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ ._
l I
regarding contaminated fish and wildlife. Although Mass AG states that "[t]here would be no plan upon which such action would directly rely," Mass AG Responses, 3rd Set, pg. 7, it is expected that this action would be taken in accordance with the IEPP, 1987, which refers to Massachusetts Department of Fisheries and Wildlife as the Massachusetts Department of Fisheries, Wildlife, and Environmental Law Enforcement 1
(MDFWELE). The IEPP states at Section 4.2.2, Agency Roles, "The MDFWELE may prohibit fishing or shellfish harvesting and, in addition, may destroy harvested fish or shellfish."
Applicants' Exhibit No. 60, pg. 18. This agency "is responsible, under the direction of MDPH, for aquatic sample ,
collection within the ingestion pathway and delivery of samples to MDPH laboratories. MDFWELE will also regulate hunting, fishing, and trapping." Applicants' Exhibit No. 60, I
pg. 21. The 1987 IEPP was provided by the Commonwealth as part of Applicantsi document request, and its omission by
?! ass AG as a plan on which MDFW could rely must certainly be an oversignt.
- 11. Massachusetts Department of Environmental Quality Engineering (MDEQE)
The MDEQE "is not authorized to act as a primary respondent in a radiological emergency." Mass AG Responses, 3rd Set, pg. 7.
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However, the Director of MCDA, or his designee, will consult with the Commissioner of DEQE as part of the E protective action decision-making process. Mass AG Responses, 3rd Set, pg. 5. MDEQE is assigned responsibility l "under the direction of MDPH, for collecting potable water samples within the ingestion exposure planning zones. The MDEQE is responsible for restricting the use of public drinking water supplies found to be contaminated." IEPP, Applicants' Exhibit No. 60, pg. 21. ,
III. SPMC RESPONSE CAPABILITIES A. SPMC Conceptual Basis The SPMC incorporates in its planning bases the assumptions described at page 2 of NUREG-0654, Rev. 1, Supp.
1:
"1. In an actual radiological emergency, State and local officials that have declined to participate in emergency planning will:
- a. Exercise their best efforts to protect the health and safety of the public;
- b. Cooperate with the utility and follow the ;
utility offsite plan; and
- c. Have the resources sufficient to implement those portions of the utility i offsite plan where State and local i response is necessary.
Although it is assumed that non-participating !
State and local organizations will respond and i follow the utility's offsite plan, it is not ;
I assumed that these organizations will be as
} faciliar with the plan as if they had f
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participated in the planning process and exercised with the utility."
SPMC makes specific reference to the presumption that previously nonparticipating State and local officials will respond to a real emergency. "The conceptual basis of this I Utility-sponsored plan does incorporate the assumption that i the Massachusetts State and local governments will carry out their responsibilities to protect the public in an actual emergency." SPMC, pg. 1.1-1. 3 The SPMC is also designed in accordance with the philosophy expressed in NUREG-0654, Rev. 1, Supp. 1, pg. 3, Scoce:
I "The degree of participation that the utility is able to gaic from State and local organizations during the planning process should be reflected in I the utility's offsite plans and preparedness; and the resources to implement the offsite plan.must be identified and committed by the utility and by State and local governments participating in the planning process."
The position of the Commonwealth since September 1986 has been that no State or local planning will be undertaken for 4
an emergency at Seabrook Station. See the Affidavit of Michael S. Dukakis, Attachment F hereto.
The SPMC concept of operation, however, recognizes the years of planning engaged in by the Commonwealth and local communities prior to 1986. "Until State and local government lI
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l emergency planning for Seabrook Station was halted in 1986, there was extensive participation in the planning process by I
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both Massachusetts State and local public safety officials over a number of years. Thus, State and local officials have some familiarity and understanding of Seabrook Station emergency response needs. Although this plan does not rely on manpower or resources from the State / local organizations for implementation of an offsite response, it is realistic to assume State and local participation in the event of an actual emergency." SPMC, pg. 1 4-1.
Because it incorporates and expands upon the emergency planning in place prior to State and local withdrawal, the SPMC constitutes an outgrowth of the Commonwealth's identification in 1986 of the need for a compensatory response plan for non-participating Massachusetts communities. State-level withdrawal from the planning process dictated that the utility-sponsored plan would have to incorporate the capability to compensate for response actions of both State and local levels of government as well as to commit al.1 necessary resources and accommodate any degree of governmental response. "To ensure a smooth integration, this plan has been developed to be consistent
! with the Commonwealth of Massachusetts Radiological Emergency f
Response Plan which is currently used for the operating nuclear power plants located in, or within 10 miles of, the Commonwealth's boundaries "
. . . SPMC, pg. 1.2-2, and ". . .
in particular with the generic sections A and B which
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i s.
describe the. Statewide radiological emergency response program." SPMC, pg. 1.3-1.
In anticipation, therefore, of a "best efforts" response I
on the part of governmental organizations who have ceased to ;j participate in the planning process, the SPMC incorporates three levels of operation to accommodate possible degrees of interaction with State and local governments. The development of these levels of operation'is in accordance.
With the guidance provided in NUREG-0654, Rev. l', Supp. 1, II.A.1.b to " explain how the offsite response organization will function with non-participating State and local governments, and . . . specify the v-irious modes of operation." Actions which will be taken by the ORO are defined by the SPMC. IP 2.14, page 5, and IP 2.14, Attachments 2, 3, and 4 provide specifications for each of the levels or modes of response. These levels are referred to as Standby, Mode 1, and Mode 2. SPMC, pg. 3.1-2. At any of the three response levels the ORO will notify and mobilize ORO personnel and contracted resources, establish I communication with State and local organizations, and l-activate facilities as appropriate for the declared emergency
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classification. "The initial action to determine which mode of operation will be implemented is contacting the Commonwealth of Massachusetts to determine if they have the f
f capabilities to respond." SPMC, pg. 3.1-2.
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B. SPMC Spectrum of Response
- 1. Determination of Operational Mode I Mode 1 through full Mode 2 implementation represents a l
spectrum of response integration as described in the SPMC at pg. 1.1-2:
"The compensatory actkns which are delineated in this plan can range fr v supporting requests for augmented personnel and resources to performing I emergency response actic.us or implementing the total response in place of those organizations."
The SPMC provides Mode 1 and Mode 2 levels of operation to allow for integration of Massachusetts and ORO resources in response to an emergency at Seabrook Station. The Commonwealth of Massachusetts participated extensively in radiological emergency preparedness in support of the two g nuclear power plants in the State as well as for one in the j g State of Vermont.
i During a Seabrook Station emergency this preparation will provide the basis of a planned Mode 1 response. The fundamental concepts of emergency classification, protective action decision-making and public notification are well understood by personnel from the Massachusetts Civil Defense Agency and Department of Public Health, and guidance is available to them in the Commonwealth's CERP. This statement is supported by Massachusetts Attorney General's Answers to NRC Staff's Third Set of Interrogatories and Requests for Production of Documents, 2/19/88, at pages 4, 5, and 6, respectively:
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" DPH NIAT members would respond to an emergency by relying on_ previous training and experience in handling emergencies at other nuclear H power plants."
"MCDA would look to the CERP for guidance . . .
rely-on professional experience . . . "
Thus it is expected that during an emergency, Massachusetts officials will be able to evaluate the situation rapidly and implement those actions that are in.the best interests of their citizens. This decision-making by the Commonwealth determines the ORO's level of response.
- 2. Standby Mode Standby mode is instituted to provide Massachusetts the
-option.for response implementation using. resources of its.own that the Commonwealth deems adequate. During Standby, the ORO continues to perform accident assessment in concert with the Seabrook Station onsite Emergency Response Organization (ERO) and the State of New Hampshire. The ORO maintains a state of readiness during this mode by having personnel report to their assigned locations to enable rapid support of
, the Commonwealth's response. No authority is required to implement Standby mode.
l 3. Mode 1 I
In Mode 1, the ORO responds to requests for resources to support the Commonwealth's planned response. This action is ;
consistent with the stated position of the Commonwealth that i
it will utilize whatever resources it feels are necessary to k
protect the public health and safety. See Agnes Memorandum, 1/11/88, and Massachusetts Attorney General's Answer to the Applicants Revised Request for Admissions from Mass AG, !
12/16/88, Attachment G hereto. The Commonwealth's CERP also expresses at page ONE-96, Hazard-Specific Supplement 6, the.
concept of utilizing whatever resources are available:
"The department [MDPH], utilizing such other public and Drivate resources as may be of assistance, is responsible for assessing any potential or actual accident or hazardous situation involving radioactivity, . . . " (Emphasis added).
Applicants' Exhibit No. 57, pg. 105.
The Commonwealth's response, and that of local communities, is not ad hoc under Mode 1 operation. Mode 1 recognizes that State and local officials will respond to the extent possible to protect the public and anticipates that such response will be in accordance with the established emergency response plans of the Commonwealth and the local communities where such plans exist. These plans all demonstrate that decision- R making structures are in place. Commonwealth of x
Massachusetts CERP, Applicants' Exhibit No. 57; West Newbury ,
I Comprehensive Emergency Management Plan, dated 9/88,
! Applicants' Exhibit No. 51; Amesbury Comprehensive Emergency 5
Management Plan, dated 6/85, Applicants' Exhibit No. 44; City I !
} of Newburyport Emergency Planning Manual, dated 1988, ;
. Applicants' Exhibit No. 48. The CERP, upon which the MCDA i will rely, states in a simplified form that: " . . . only two
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I basic kinds of activities take place -- evaluation activities and resource acolication activities." Applicants' Exhibit l
I No. 57, pg. 37. !
l l The manner in which SPMC or some mixture of SPMC and other resources are activated and deployed is still dictated by the SPMC, and is comparable to the Area I Civil Defense response. That response is to " coordinate assistance to the I six (6) Massachusetts comunities located within the Seabrook Station Plume Emergency Planning Zone (EPZ) . . . activate reception centers as required and collect intelligence and render situation reports to the Massachusetts Civil Defense Agency / Office of Emergency Preparedness (MCDA/OEP) in Framingham." Applicants' Exhibit No. 55A, pg. 8.
Mode 1 of the SPMC is not defined as "the mere provision !
of resources to support an unplanned emergency response." As shown in IP 2.14, Att. 1, the use of ORO resources is coordinated through the NHY Offsite Response Director. The ORO Massachusetts State Liaisono provide information and advice to the Commonwealth, and the Local Liaisons to the I local officials on the capabilities of ORO and the correct ORO interfaces for State / local application of ORO resources.
All requests for assistance can be directed to the ORO counterpart or to the appropriate Liaison. "The NHY Offsite Response Director has been authorized by the President of New I i
Hampshire Yankee to commit the resources of the Company-(money, manpower, facilities, and equipment) through the
'NHY Offsite Response Organization, to respond in the Commonwealth of Massachusetts to protect the public . . .
SPMC, pg.;3.1-1. ,
The SPMC is intended to provide detailed guidance to ORO members for implementation of an emergency response. As such, it is not' intended that State and local officials will, in all cases, follow.the specific mechanics of SPMC procedures. What is intended is that the Commonwealth and the local communities will utilize,the provisions in the SPMC for determining and implementing protective actions, implementing traffic and access control, use of reception and host facilities, monitoring / decontamination facilities, and
. transportation operations in the absence of any other planned and tested response strategies. In at least two of these functions, protective actions and traffic / access control, the SPMC uses criteria and strategies nearly identical to those l
relied on by the Commonwealth.
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- b. Mode 1 operation (use of ORO resources) expects that the !
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Commonwealth will respond in a planned manner, utilizing the plans, procedures, personnel and equipment identified in its l
12/19/88 responses to NRC Staff's First and Third Set of Interrogatories in conjunction with the site-specific i J. response available only in the SPMC. The deployment of ORO
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_ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - l
l resources to support the Commonwealth's planned response is not ad hoc, because it is implemented through the ORO command and control structure. The Commonwealth's plans, moreover, provide far more than an ad hoc response.
- 4. Mode 2 In Mode 2 operation the ORO is authorized by the Commonwealth to take responsibility for specific functions, which may include the following: activation of public notification' system and broadcast of Emergency Broadcast System (EBS) messages, recommending protective actions to the public for both plume and ingestion exposure pathways, 1
recommending recovery and reentry actions to the public, directing traffic, performing access control, and removing obstructions (including private vehicles) from roadways.
Once authorization is granted, for any or all areas of implementation, these areas are carried out by the ORO.
IP 2.14 contains the details of how the Commonwealth's level of response it determined and how authorization from 7 the Commonwealth is conferred on the ORO. IP 2.14 Attachment 8, Emergency Response Responsibility Checklist, lists 10 major emergency response functions. This chart could be used by each Local EOC Liaison to track areas for which the community has indicated that it uas sufficient resources to respond. No individual Liaison would be required to enter information for more than one community. Certain functions,
l such as Accident Assessment, are the responsibility of the State and of the ORO but not of local communities. In addition, not all functions shown would be implemented simultaneously, e.g., Evacuation Support (7) and Recovery (10). Use of this form is limited to recording resource or response needs which are to be reported to the ORO EOC.
.Information regarding the level of response is gathered through the two contacts the Offsite Response Director is procedurally (IP 2.14) directed to make at the onset of an emergency. After verifying pager notification, the Offsite Response Director obtains current emergency conditions'and the name and telephone number of the MDPH Duty Officer from the Seabrook Station Control Room. The Director then calls MDPH, eithe r from the location where notified or while enroute to the ORO EOC, to relay emergency status and capabilities of the ORO and specifically to ask how the Commonwealth intends to respond. This call is not the initial notification received by MDPH of an emergency at i Seabrook Station, as MDPH will have already been notified by the Massachusetts State Police. Applicants' Exhibit No. 55A, pg. 189. The Offsite Response Director has been provided h I with 24-hour telephone numbers for MCDA, MDPH, and State {
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( Police Troop A.
I On reporting to the ORO EOC and obtaining copies of the !
State Notification Fact Sheet, the Offsite Response Director j
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calls the Massachusetts State EOC in Framingham to provide MCDA with current emergency information and to determine who is directing the Commonwealth's response. The Offsite Response Director then confers with the appropriate Massachusetts official and requests authorization to implement the SPMC. The Offsite Response Director documents such authorization, as it is received, and determines the extent of ORO implementation of the SPMC on the basis of the Commonwealth's response. ,
Understanding by the Offsite Response Organization of l the content of State authorization is ensured since ,
authorization is the result of conferring with the appropriate State officials. The details of authority conferral are described in IP 2.14, Paragraphs 5.2.2 through 5.2.5. Step 5.2.5 identifies specific individuals who are expected to be directing the Commonwealth's response. All required telephone numbers are available in SPMC, Appendix H, pages H-83 and H-84. Authorization of the ORO to respond, 3 including the identities of the persons giving and receiving such authorization, is documented on IP 2.14, Attachment 7.
Objective #37 in the 1988 Graded Exercise was evaluated L
by FEMA as having been met. This objective required that the !
) ORO demonstrate the capability of utility offsite response organization personnel to interface with nonparticipating State and local governments through their mobilization and 1
provision of advice and assistance. FEMA Final Exercise 4 B
Report, Applicants' Exhibit No. 43F, pages 248 through 250, l 1
and pg. 276. The Control Cell, which acted as the nonparticipating governments, was staffed by FEMA evaluators who simulated a low level of SPMC knowledge.
FEMA specifically noted:
"The FEMA Control Cell did not commit any state or local resources or personnel to assist in the NHY ORO response. Legal authority was requested and received for appropriate response activities (as specified in the NHY ORO Plan, IP 2.14)."
Applicants' Exhibit No. 43F, pg. 250.
C. Definition of Liaison Roles
- 1. Regulatory Guidance NUREG-0654, Rev. 1, Supp. 1, II.C.5, establishes the ;
need for liaison personnel as pr.rt of an offsite response organization.
"The offsite response organization shall identify liaison personnel to advise and assist State and local officials during an actual emergency in implementing those portions of the offsite plan
% where State or local response is identified." ,
, Further definition is provided in NUREG-0654, Rev. 1, b Supp. 1, pg. 2, Assumptions:
"Therefore, the utility's offsite response plan and L the offsite response organization will provide compensating actions through the use of liaisons to deal with the coordination of information and <
resources with State and local governments and to ,
) provide advice and assistance to responding State and local governments in implementing their
} assigned roles and functions under the utility's l
) offsite response plan." 1
I I 2. Liaison Functions Liaison functions are specifically designed to establish and maintain immediate communication with State and local organizations, thereby enhancing the coordination of emergency response activities and compensating for the lack of Seabrook Station-specific planning and training by State and local responders. The roles of State and Local EOC Liaisons are defined in the SPMC at Section 2.1 and at IP 1.11 and IP 1.8, respectively.
State Liaison functions are divided among three liaisons: two who establish communications and coordinate joint ORO/ Massachusetts Civil Defense Agency activities at Emergency Operations Centers at Framingham (State) and Tewksbury (Area I), and one who establishes communications and coordinates joint ORO/ Massachusetts Department of Public Health activities. These State Liaisons will report to the two MCDA EOCs and to the appropriate MDPH office. SPMC, Section 2.1, pg. 2.1-23.
IP 1.11 directs the State Liaisons to: maintain communications with the Commonwealth; coordinate requests for support from, or supply information to, MCDA and MDPH; support MCDA and MDPH in implementing recovery actions; provide identification of available ORO resources; document requested resource use; ensure that all decisions or actions I I
taken by MCDA or MDPH are communicated to the ORO EOC; and update the commonwealth agencies on decisions or actions taken by the ORO.
Major responsibilities of the Local EOC Liaisons are to:
establish communications with the Local EOC Civil Defense Director / Senior Local EOC Official, or other local official as listed in SPMC, Appendix H, New Hampshire Yankee Offsite Response Communications Director.y; apprise the local EOCs of current event classification and plant conditions; request the status of local community response capabilities; explain the capabilities of the ORO (SPMC,,pg. 2.1-22); and provide such additional services for local emergency workers and institutionalized individuals who cannot be evacuated. SPMC, pg. 2.1-23. The Local EOC Liaison will report to the local community EOC and function from that location, thereby eliminating the need for communications by the local governmental responders to equivalent ORO personnel. SPMC Section 3.5, pg. 3.5-2 explains the issuance of extra dosimetry to the Local EOC Liaisons for use by the local community's emergency workers.
State and Local EOC Liaisons are issued copies of the SPMC, including Appendix M, NHY Offsite Response Emergency Resource Manual, and Appendix J, NHY Offsite Response Traffic Management Manual, for their reference in advising government officials on the capabilities of the ORO. These volumes, as I I
. _ _ _ _ _ = _ _ _ _ _ _ - _ _ . . _ - _ _ _ _ . _ _ _
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l well as appropriate maps and sample EBS messages, are taken j to the State or local offices by the Liaisons for use by them and by local officials in integrating response to an emergency. These materials contain the Seabrook EPZ-specific information which may be otherwise unavailable because of State and local nonparticipation in the planning process.
Local EOC and State Liaisons are available to state and local government to explain both the roles assigned to these organizations in the SPMC and the capabilities for expanded l response. By using SPMC Tables 2.2-1 and 2.2-2, liaisons can explain which local and State government levels correspond to the command and control functions of the NHY Offsite Response Organization. Attachments 5 and 6 of IP 2.14 provide a more detailed cross-reference of State and local governments with specific functions and appropriate ORO positions. Any government official would be able to move from this chart to the appropriate implementing procedure, particularly since the official will do so under the guidance of the State or Local EOC Liaison. Note however that the SPMC does not
) assume that government responders will attempt to implement the SPMC's actual procedures in an emergency, given the lack L
of current participation by Massachusetts organizations in the planning process. Local EOC Liaisons could also utilize SPMC pgs. 3.6-9, 3.8-2; Section 4.0; Table 2.2-1; and SPMC Appendices H, J, and M to provide guidance and advice.
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No State or local emergency response personnel are !
required to communicate or coordinate actions with individual counterparts in the utility organization because the contact
-point at each State or local EOC is the ORO Liaison. The SPMC, however, does not preclude such one-to-one communication. Rather than being either cumbersome or time-consuming, as alleged by Interveners, such communications by i'
Commonwealth or local communities for specific assistance would require contact with at most approximately 10 ORO personnel other than the-Liaisons. SPMC, IP 2.14, Attachments 5 and 6. The presence of Commonwealth representatives at the EOC or the Emergency Operations ,
3 Facility (EOF) further enhances communications between organizations.
Knowledge of the overall structure, function, operation, and available resources of the SPMC is ensured through the training required for State and Local EOC Liaison positions.
All Local EOC and State Liaisons receive a total of
, approximately 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> of classroom training in: Emergency b
Plan Overview, Emergency Management, Transportation, Procedure Checklists, Tabletop, Protective Action Decision-i making, and Communications. SPMC, pgs. 6.3-1 through 6.3-8; Table 6.3-1. Local EOC Liaisons receive an additional hour of training in Staging Area Operations. State Liaisons to MDPH receive Dose / Accident Assessment, Dosimetry
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l Recordkeeping, and EOC Operations, totaling an additional 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> of training. State liaisons to MCDA receive EOC Operations (1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />) in addition to the 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> all liaisons I receive. In addition, a guidance document has been prepared detailing the anticipated Commonwealth response to an actual emergency, based on the information supplied by the Commonwealth and local communities to Applicants during discovery. Copies of the State and local plans and other guidance material cited will be placed in the ORO EOC and the Staging Area for reference. Training on this detailed !
anticipated response will be conducted for appropriate positions in the ORO, including State and Local EOC Liaisons.
Drills and walkthroughs in which State and Local EOC Liaisons have participated also provide significant training on the overall functions of the ORO. FEMA has found that the Liaisons adequately demonstrated interface with non-participating State and local governments through their mobilization and provision of advice and assistance during the 1988 Graded Exercise. Applicants' Exhibit No. 43F, pgs.
248 through 250.
D. SPMC-Assigned Governmental Functions The SPMC states clearly at page 1.4-2 that "The Seabrook Plan for Massachusetts Communities does not rely on previously developed State and local government resources but is intended to be compatible with, and capable of integrating lI 5
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!I 1 State and local government responses should the governments I
choose to implement these resources in a real emergency." !
's Therefore, specific procedures for requesting such resources I as may be available to these governments are not included in the SPMC.
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- 1. Routine Governmental Functions The SPMC does rely on State and local personnel to continue to perform routine governmental services under the assumption that State / local officials will "have the resources sufficient to implement 1bose nortions of the l utility offsite plan where state and local response is necessary." NUREG-0654, Rev. 1, Supp. 1, pg. 2. (Emphasis added.)
s On a local level, the SPMC expects the routine l l
- governmental functions of law enforcement, fire and rescue, snow plowing, public health, and emergency medical services to continue during a radiological emergency response. Such assistance is supported by the existing structures of State and local governments. This assumption is appropriate in light of the response capabilities and actions identified by the Commonwealth.
Mass AG Responses, 1st and 3rd Sets, 12/19/88.
This concept is also consistent with the philosophy t
expressed in the CERP, Applicants' Exhibit No. 57, at pg.
16:
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" Emergency and disaster do not change the basic j responsibilities.of_ State and local governments, but rather increase the.need for' fulfilling them promptly and adequately under emergency conditions."
Also_at pg. 16:.
"The State emergency organization thus conforms to
'the normal governmental structure, but is limited to those elements with specific emergency functions. As such, State government response is an extraordinary extension of response and activity, coupled with business as usual."
The Commonwealth's CERP-assigns responsibility to local .
organ'izations for emergency medical services, law enforcement, fire and rescue and public health and~ sanitation in the event of a_ radiological emergency. RERP, Applicants' i Exhibit No. 55, Table A4-1, page 82. In addition, the CERP and local emergency response plans define emergency functions as' extensions of normal operations. CERP, Applicants' Exhibit No. 57, pg. 16; Amesbury-Comprehensive Emergency Management Plan, Applicants' Exhibit No. 44,_pp. 22, 57, 69, 88; West Newbury Comprehensive Emergency Management Plan, Applicants' Exhibit No. 51, pp. 10, 41, 51, 66. The- ,
f Commonwealth CERP and local plans thus support the concept that emergency response for routine governmental functions is ')
a logical extension of normal duties.
In Answers and Responses of the Massachusetts Attorney General to the Applicants' Interrogatories and Request for ,
1 Production Concerning JI Contentions 6 and 27-63, 12/19/88 l
(hereafter referred to as Mass AG Response JI 6, 27-63), Mass AG defines normal emergency functions and describes how the particular problems of security, public health, timely evacuation, and emergency-specific rescue needs in response to a Seabrook Station emergency allegedly differ from those met by normal emergency functions. i I
- a. Security
"' Normal emergency functions' as used in Contention JI 27 Basis B.2 is intended to have the same meaning as those i words have in the SPMC at Plan 2.4-4.'" Mass AG Responses JI 6, 27-63. Security is expanded to, security and law !
enforcement. Mass AG presents " protecting against looting and enforcing an evacuation order against those not inclined to leave voluntarily" as security issues resulting from large scale evacuation which are " completely unlike ' normal' conditions." Mass AG Responses JI 6, 27-63, pg. 6.
Security, as defined by Mass AG, is law enforcement and therefore is not required in the SPMC as an ORO function, since it is expected that local communities will retain this ;
! responsibility using the resources present in each community.
The problems described by Mass AG are situations which would i
occur in any emergency for which evacuation on any scale is I necessary. In addition, the Commonwealth has identified a I
i resource pool of 1320 State Police personnel who would be available to supplement local resources for security {
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functions. Mass AG Responses, 1st Set, pg. 5. Massachusetts National Guard also " supports civil authorities in maintaining law and order, [and) providing security . . .
CERP, Applicants' Exhibit No. 57, pg. 30.
- b. Public Health Mass AG states that "under ' normal' conditions, those local agencies responsible for law enforcement and rescue needs are not confronted with issues of public health and the risks of radiation. During a Seabrook radiological emergency l the public would turn for information and assistance on such j l
matters to those in the local communities responsible for
' normal emergency functions.'" Mass AG Responses, JI 6 63, pages 6 and 7.
The Massachusetts Department of Public Health is designated as the lead agency for providing information, assistance, and technical support regarding radiation as it affects the public health. " Basic responsibility and authority for dealing with any type of accident involving
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nuclear materials is assigned by law to the Department of l i Public Health . . . The Department . . . is responsible for I assessing any potential or actual accident or hazardous
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situation involving radioactivity, and for advisina state and local authorities and private interests of the measures which should be taken. The Commissioner of Public Health may proclaim a public health emergency relative to such
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situations." (Emphasis added). Applicants' Exhibit No. 57, pg. 105. The SPMC assigns a Liaison to interface l
I specifically with MDPH, thereby providing additional i
radiological assessment input for public health decisions.
Further, the local communities are provided information ;
through EBS messages and the news media. Local EOC Liaisons are available through the ORO to advise the community emergency response organization of recommended protective actions. No other public health functions are required for I performance by the ORO. The actions to be carried out by i!
local law enforcement and rescue agencies would not differ in kind from those required under other emergency situations such as a severe chemical spill or a transportation accident involving radioactive materials. i I Local plans indicate that routine public health i
I functions such as disease control and sanitation will be carried out by the local response organizations in an emergency. Merrimac Emergency Operations Plan, 2/83, pg. 15 Attachment H, hereto; West Newbury Comprehensive Emergency I Management Plan, Applicants' Exhibit No. 51, pg. 66; Amesbury j Comprehensive Emergency Management Plan, Applicants' Exhibit No. 44, pg. 88; Newburyport Emergency Planning Manual, Applicants' Exhibit No. 48, pg. 30.
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- c. Evacuation Mass AG states that the " manpower demands on local law l
enforcement agencies if an evacuction is to be carried out as effectively as possible would be enormous. Such an immediate and extensive demand on traffic management personnel across the extent of the Massachusetts EPZ would bear no resemblance to ' normal emergency functions.'" Mass AG Responses JI 6, 27-63, pg. 7.
Timely evacuation (JI-27B.2) is one of the planning bases integral to the concept of operation of the SPMC. As such it is already incorporated in the overall scope and extent of the ORO's planned emergency response and cannot, contrary to Joint Interveners' use of the phrase in JI-27, be viewed as something "in addition" to the emergency response.
Because timely evacuation is considered in the SPMC, the ORO includes. sufficient personnel and contracted resources to accomplish such an avacuation without use of local resources.
s No procedural responsibility is assigned by the SPMC to local communities in effecting an evacuation. In addition, Mass AG's statement ignores the availability of ORO Traffic Guides to perform traffic management and also the Commonwealth's own response that State Police would also perform this function, f assisted, according to the CERP, by Massachusetts National
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Guard.
- d. Emergency-Specific Rescue Needs
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I l Mass AG states that a " variety of circum' stances resulting from a Seabrook radiological emergency could result in rescue needs that are markedly different in kind and scope from ' normal emergency functions.' For example, local rescue agencies may be requested to evacuate individuals from a variety of institutions. A full-scale evacuation could well result in emergencies-within-the-emergency that themselves call for rescue services. None of these circumstances are
'normally' faced by rescue agencies." Mass Ag Responses, JI lI 6, 27-63, pg. 7.
The transport of individuals would seem to be within the normal capacity of rescue agencies at any time. The SPMC assigns no responsibility to local rescue agencies to effect evacuation of individuals from institutions in the event of an emergency at Seabrook Station. The SPMC provides adequate resources and personnel to accomplish evacuation without reliance on local resources. SPMC Section 3.6. If large-scale evacuation of individuals is removed as a local level of response, local rescue agencies will not be called upon to l perform any sarvices except those falling within their normal l capabilities.
Should local agencies wish to supplement their rescue functions, the Massachusetts National Guard " assists local authorities in the evacuation of critical areas and the performance of search and rescue operations; provides I _47_
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- I emergency medical care and transportation for injured disaster victims . . . CERP, Applicants' Exhibit No. 57, pg. 30. In addition, it is the responsibility of the Division of State Police to assist " local authorities in search and rescue operations." Applicants' Exhibit No. 57, i pg. 32. Mutual aid is an additional source of supplemental rescue response.
The identification, assignment, and establishment of l
police and fire and rescue responsibilities is discussed in Sections 2.0 and 2.4 of the SPMC. SPMC Table 2.0-1 complies with the direction of NUREG-0654, Rev. 1, Supp. 1, II.A.2.a to include these functions in a " clear and concise summary such as a table "
. . . The SPMC describes Table 2.0-1 as providing "a listing of the offsite agencies or individuals responsible for primary and support functions in response functions in an emergency." SPMC, pg. 2.0-1. This description and the intended use of the table are in accordance with the guidance provided in NUREG-0654, Rev. 1, supp. 1, at pg. 8 to " identify similar functions and responsibilities and interfaces for an anticipated State and local response to an emergency."
- 2. Mutual Aid Agreements Mutual aid agreements to provide assistance to the six communities in the Massachusetts segment of the EPZ are not limited to agreements among these six communities or with New I I
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Hampshire EPZ communities. For example, aid is available to 1
the six Massachusetts communities in the case of fire from !
additional communities such as Haverhill, Rowley, Groveland, l Georgetown, Methuen, Ipswich, Andover, Boxford, Lawrence, North Andover, and Middleton, all of which are outside the Seabrook plume EPZ. Fire Department mutual aid documents are Attachment I hereto.
Mutual aid, including response by communities outside the Seabrook EPZ was exercised in Merrimac on 10/24/88 in the Tanker Mutual Aid Drill. Participating Massachusetts communities were Groveland, Merrimac, Byfield, West Newbury, and Amesbury. The New Hampshire communities of Danville, Hampstead, Kensington, Kingston, and East Kingston also participated. Groveland, Hampstea3, and Danville are not within the Seabrook Station EPZ. See Attachment J hereto.
Mass Casualty Mutual Aid support has also been established involving ambulances, Emergency Medical .
Technicians, fire department rescue services, and backup fire department coverage. See Attachment K hereto.
Current planning by the Commonwealth and local communities also indicates that acquiring supplemental resources through mutual aid agreements is an acceptable planning basis. The Comprehensive Emergency Response Plan (CERP) for the Commonwealth, at page ONE-30, contains the following language:
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Pg. ONE-30:
" Disaster conditions will often overwhelm a community's abilities to cope with its effects.~ In, such cases, a community should first-look for assistance from its neighboring cities and towns -
either through existing mutual aid arrangements, or on an emergency basis."
Applicants' Exhibit No. 57, pg. 38.
Local emergency, response plans for Massachusetts communities within the Seabrook EPZ also. indicate that mutual aid agreements are to be activated in times of emergency.
Town of West.Newbury Comprehensive Emergency Management Plan, Applicants' Exhibit No. 51,.pgs. 17, 41, 51, 58, and 66; City of'Newburyport Emergency Planning Manual,Section I, Fire, Police and Ambulance, Applicants' Exhibit 48, pgs. 20, 24,.26 and 34; Amesbury Comprehensive Emergency Management Plan, Applicants' Exhibit No. 44, pgs. 29, 57, 69, 78, and 88; Merrimac Emergency Operations Plan, pg. 4, #6, Attachment L J hereto; and Town of Salisbury Emergency Response Plan SARA Title III, pg. 6, Attachment M hereto.
Mutual aid responders will be allowed through access control points staffed by either ORO or State of New Hampshire personnel. SPMC, pg. 3.6-15; SPMC, Appendix J, pg.
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9-1; State of New Hampshire Traffic Management Manual, Rev.
0, pg. 1.2-2. Local EOC Liaisons and State Liaisons are available to the local and State governmental structures to
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> ensure that information concerning mutual aid response is properly relayed to the ORO EOC.
- 3. State / Local Facilities, Resources, and i Communications I The CERP states that the means are already in place for coordinating State and local response at the State EOC. !
"The EOC is available to respond on a 24-hour basis to any emergency situation that may arise. It is I equipped to sustain such response as long as necessary . . . Besides the EOC at Framingham which headquarters the Massachusetts Civil Defense I Agency (MCDA), each Area is equipped with a staffed EOC. Each of these has the communications equipment necessary to carry out extensive coordinative tasks, involving all levels of j government."
Applicants' Exhibit No. 57, pg. 63.
State Police and other Executive Order 144 Agencies, 1
deploy representatives to the State EOC to provide a j I coordinated response. Applicants' Exhibit No. 55, pg. 210.
The CERP also provides for augmentation of EOC staffs.
" . . . Additionally, Administrative Order No. 13 I directs all State agencies to make available their resources, including personnel, for performance of civil defense functions in time of need."
Applicants' Exhibit No. 57, pg. 63.
The SPMC does not rely on the use of Commonwealth communications systems for coordinating local response.
l Pages H-83 through H-90, Appendix H, SPMC, show the extensive systems available to the ORO for communications with both the !
Commonwealth and the local communities for coordinating local J I I
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available at the Framingham EOC according to the j I Commonwealth's CERP. See Applicants' Exhibit No. 57, pages l
73 and 74. Section C-3, Area I MCDA Operation Plan for Seabrook Station, of the Commonwealth's RERP, 1986, Applicants' Exhibit No. 55A, describes radio capabilities available to link the MCDA Area I EOC with the MCDA Framingham EOC, the Massachusetts National Guard, the Massachusetts Department of Public Works, the Massachusetts State Police, and the six local EPZ communities. In particular, the Area I Plan states that a " control station located at the Area I EOC in Tewksbury, Massachusetts is the States' [ sic] ' link' ... to the local communitico...
Additionally, this control station is interfaced with the MCDA rticrowave system. This system allows the remotes located in Framingham, Massachusetts at the State EOC and Massachusetts State Police Troop 'A' Headquarters to operate the Tewksbury control station in order to communicate with the local municipalities... the remotes at MSP, the State EOC and the Tewksbury Area I EOC have the ability to transmit an
'ALLCALL' signal which will alert all of the stations on this list simultaneously." Applicants' Exhibit No. 55A, pg. 18.
The list referred to, contained in Applicants' Exhibit No. 55A at pg. 26, includes Civil Defense and/or Police for each of the six Massachusetts communities. Figure 5, I -
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I communications Channel, graphically portrays communications I
capabilities linking the Area I EOC with other emergency response organizations. Applicants' Exhibit No. 55A, pg. 34.
Mass AG Responses, 1st Set, pgs. 8 through 10, describe a statewide radio system on 45.36 MHz which links the Framingham MCDA EOC with the MCDA Area I EOC in Tewksbury; a backup radio system on 45.32 MHz; the National Warning System, a dedicated telephone line linking Civil Defense Headquarters and its four Area Headquarters, fire stations, I police stations and National Guard; and a dedicated radio at l
the State EOC providing interface with the Emergency Broadcast System.
The SPMC does not rely on the Commonwealth making available laboratory facilities. SPMC, pg. 1.4-2. Therefore >
no procedures for making these " resources" available are required in the SPMC. Laboratory facilities for sample receipt and analysis are directly available to the ORO under agreements in existence between Yankee Atomic Electric company and New Hampshire Yankee. (SPMC, Appendix N, Action Plan: Yankee Nuclear Services Division Radiological Services / Support for the NHY Offsite Response Plan.) The SPMC, at pgs. 3.3-11 and 3.3-12, states: "The Seabrook Station EOF or Yankee Atomic Laboratory will serve as the l central point for receipt of all environmental and food samples collected by the Sample Collection Teams.
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Environmental samples (e.g., soil, vegetation, surface water) ]
may be analyzed at the Seabrook Station EOF . . .. Other samples, particularly those requiring preparation prior to .
l analysis, will be prioritized by the Accident Assessment Coordinator, and transported to and analyzed at Yankee Atomic Environmental Laboratory." The Letter of Agreement k.etween Yankee Atomic and New Hampshire Yankee covering services provided at the Environmental Laboratory is included at pg.
C-138, Appendix C, SPMC. Table 3.3-3 lists sample analysis capabilities for Yankee Atomic Environmental Laboratory facilities. Federal laboratory support is available through the FRERP as stated in the SPMC at pg. 3.3-12: "The Food and Drug Administration Laboratory in Winchester, Massachusetts and Brookhaven National Laboratory in New York would be two of the Federal laboratories available through the activation of FRERP."
Other laboratory capabilities are available through the ,
New England Interstate Radiation Assistance Plan, which is provided as Appendix B of the SPMC. The SPMC states, at pg.
3.3-13, "If additional laboratory capabilities are needed, the Assistant Offsite Response Director, Support Liaison, will coordinate the activation of the New England Compact with the Commonwealth of Massachusetts or the State of New Hampshire."
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Implementation of the SPMC does not rely on the availability of local resources, e.g., EOCs. However, local governments are expected to be able to support local decisionmaking and routine governmental response consistent with their role described in the CERP, Applicants' Exhibit No. 57, at pg. 15:
" Maintaining the safety and well-being of the I citizenry reauires (emphasis added) that local government . . .
- 3. Develop and maintain a capability to receive l warning of threatening disaster agents, . . .
- 4. Maintain emergency forces (e.g., police and I fire) adequate to respond effectively to limited local emergencies; I 5. Develop or maintain the capability to rapidly augment existing emergency forces through the use of auxiliaries or through mutual aid arrangements;
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I Effectively utilize such resources through the coordination of a local official authorized by ordinance to perform such functions; . . . "
In addition, local plans indicate the existence of functional EOCs and communications systems.
Merrimac Emergency Operations Plan at page 8:
I "4. The Emergency Operating Center (EOC) will be activated at the designated location in the Town Hall, School Street . . . "
and at page 9:
"3. Establish communications with MCDA Area I I Headquarters, and with towns and cities with whom mutual aid agreements have been made."
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See Attachment N hereto.
Amesbury Comprehensive Emergency Management Plan, Applicants' Exhibit No. 44, at pg. 110:
"4. Adequate communications equipment is available to provide necessary support for emergency situations."
l The Amesbury EOC is currently located in the Senior 1
l Citizen's Building. The Amesbury Police Station is the backup location.
West Newbury Comprehensive Emergency Management Plan, Applicants' Exhibit No. 51, at pg. 17:
"The West Newbury EOC is the primary site for all emergency operations and is located in the Civil I Defense Building. In the event the West Newbury EOC should become unusabic, the Pentuckett (sic]
Regional High School will be used as an alternate EOC."
Under EOC Activation Checklist, West Newbury's plan lists the following step: "8.. . . Notify MCDA Area I Headquarters." Applicants' Exhibit No. 51, pg. 25. ,
At page G-1, West Newbury's plan also stat'n the adequacy of communications equipment for emergr.acies, using exactly the same language as Amesbury, above. Applicants' Exhibit No. 51, pg. 83.
The City of Newburyport's Emergency Planning Manual 1988 Stater inder Civil Defense:
"The EOC is fully equipped with radio communications with all units of the municipal, I I
county & state government, as well as area towns and cities."
Applicants' Exhibit No. 48, pg. 29.
As part of its effort to enhance the preparedness of state and local organizations in Massachusetts, NHY provided a significant upgrade to their' communications systems. The total cost of the communications systems provided was approximately 1.4 million dollars.
l Local EOC Liaisons-utilize telephones at the ORO Staging-Area to provide initial communications with the local EOCs.
Information from the local facilities is relayed to the ORO EOC by the Liaisons. When authorized to-report to the' local EOCs, Local Liaisons are issued cellular telephones which j provide direct links between the local communities and the ORO EOC. SPMC, IP 1.8.
E. SPMC Provisions For Local Communities The SPMC contains provisions throughout that are specific to the Massachusetts EPZ communities. In particular, the traffic management plan, the allocation of transportation resources, local notification lists, and special facility information are all specific to the six
, communities. SPMC Appendices H, J, and M.
Rather than " totally ignoring the established routines" existing in the six communities, as alleged in JI 27 Basis C, the SPMC accounts for them by allocating routine governmental l
responses to the local organizations, supplemented, where the communities deem it necessary, by existing mutual aid i 1
agreements. The SPMC identifies at Table 2.0-1, Figure 2.0- l l
1, Section 2.2-1, and IP 2.14, Att. 6, the categories of response recognized as local responsibilities and presents ORO counterparts of the local organizations. The correspondence of ORO functions to local functions demonstrates a basic understanding of the " established" emergency response structure in each community. The local i
structures presented are consistent with those that were developed in 1985 and 1986 when the six EPZ communities were actively involved in developing emergency plans, and with the !
emergency response structures of other Massachusetts local communities for which radiological emergency response plans exist. Organization charts from Amesbury, West Newbury, and Merrimac emergency plans show the structures of local response organizations. See Applicant 3' Exhibit No. 44, pg.
44; Applicants' Exhibit No. 51, pg. 30; Attachment O hereto, respectively. The emergency response structure for the City
) of Newburyport is described in Applicants' Exhibit No. 48 at )
pages 16, 20, 26, 28, 29 and 30. )
Should local governments seek to expand their responses, l
local plans have been developed by most of the communities or '
the Commonwealth to guide those responses. In the case of expanded local response, the resources of the ORO can be .
effectively integrated with the local response through the Local EOC Liaisons.
F. Coordination of Response
- 1. Resources from Support Organizations The only support organizations identified in the SPMC are those under assignment to provide services.to the ORO.
l To clarify the definition of " support organization," Section !
2.0 of the SPMC will be revised to remove the reference (pgs.
2.4-3 and 2.4-4, Section 2.4.2.F) to local governmental organization functions under the heading " Support Organizations." The SPMC contains no procedural steps for j notifying contracted support organizations of the mix of authorization in effect for the emergency response, because there is no mix of authorization to be communicated to them.
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Should a Mode 1 response be implemented, command and control of the support organizations remains with ORO management, and there is no need to discuss mix of authorization. Allocation 9 of and requests for resources are relayed from State or local !
l officials to the ORO State and Local EOC Liaisons. Support )
) resources under contract to the ORO will be mobilized in
! accordance with the SPMC.
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The distinction between ORO direction of ORO resources J and their at-the-scene operational control by State or local organizations is analogous to the distinction made in the 1
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Merrimac Emergency Operations Plan pgs. 11 and 12, Attachment P hereto, which state:
"A distinction is made between (1) operational control and (2) direction of emergency forces.
OPERATIONAL CONTROL consists of the functions of I assignments of tasks, designation of objectives and such other control necessary to accomplish the i mission. DIRECTION OF EMERGENCY FORCES includes
$5 the authority to commit (sic) to, or withdraw from, emergency operations. Direction is retained at all times by the appropriate civil or military I authority . . . When Merrimac's civil forces are sent to another community, operational control is exercised by the authority at the scene of the a operations, but direction is retained by Merrimac g' authority."
Similarly, in Mode 1, Traffic Guides, for example, would be notified, mobilized, and dispatched by the ORO as determined by the SPMC (direction of emergency forces) but could perform their traffic or access control functions at their assigned locations under the guidance of State or local police (operational control).
The relationship between the ORO and its support organizations is clearly defined in the Letters of I Agreement / contracts contained in SPMC Section 2.4, pages 2.4-1 through 2.4-5; Appendix C; IPs 1.1, 1.3, 1.6, 1.10, 2.7, 2.9, 2.10, and 3.2; and Applicants' Exhibit No. 41.
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- 2. Massachusetts Officials The Massachusetts State-Police are not identified in the SPMC as a distinct emergency response organization for other g
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I than law enforcement and notification functions. The SPMC anticipates that the State Police, in relying on Section C-3 of the RERP, 4/86, for guidance, will perform its normal notification function to inform the Massachusetts Department of Public Health, MCDA, and local governments when notified of an emergency by the Seabrook Station Control Room.
Notification of the State Police is automatically carried out through use of the Nuclear Alert System (NAS) by the Seabrook Station Control Room in the event of an emergency. SPMC, pgs. 3.2-1 and 3.2.-2.
In addition, the March 8, 1988 Massachusetts Civil Defense Agency (MCDA) memorandum, Attachment Q hereto, indicates that MCDA has planned actions in response to receiving notification through routine Massachusetts emergency communications channels of an emergency at Seabrook Station.
The control room phone number for Seabrook Station is already in the possession of MDPH. The Commonwealth's Nuclear Incident Advisory Team (NIAT) Handbook, 4/88, contains NHY's unlisted Seabrook Control Room number.
Therefore, MDPH has at its disposal a mechanism for directly contacting Seabrook Station and for verifying the identity of l the NHY Offsite Response Director by callback to the Seabrook lI Station Control Room. Applicants' Exhibit No. 59, pg. 35. l l 1 I l
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Since the State Police, as an Executive Order 144 )
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Response Agency, deploy a representative to the State EOC I
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(Applicants' Exhibit No. 55, pg. 210, the ORO State Liaison for Framingham functions as Liaison with the State Police, if I necessary.
The SPMC does not rely on the presence of Massachusetts i State or local officials at the NHY.Offsite Response EOC or the licensee's EOF for coordination of Massachusetts and ORO response activities. Such coordination is provided through the activities of ORO liaisons assigned to three State facilities: the Massachusetts State EOC, the Massachusetts Civil Defense Agency Area I EOC, and offices of the Massachusetts Department of Public Health. Liaisons are assigned as well to local EOCs in the six EPZ communities.
IP 1.1, 1.8 and 1.11. However, MCDA has indicated tnat it will send a representative to the utility's EOC. Mass AG Responses, 3rd Set, 12/19/88, pg. 5.
Representatives of both MCDA and MDPH could operate out of the Massachusetts Government Room which is designed for i their use at the ORO EOC. IP 2.14 will be revised to direct the Offsite Response Director to specifically inquire whether MDPH and MCDA intend to dispatch representatives to the Offsite Response EOC. Because the NHY Offsite Response EOC functions as the ORO command center for direction and control of the integrated offsite response for Massachusetts, any I I
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I Massachusetts representative (s) 1ccated at the EOC or the EOF will be provided with or have access to all available emergency information.
- 3. Coordination of ORO and the State of New Hampshire In JI-27, Basis G, the Joint Interveners cite SPMC Appendix C, page C-la-id in support of their allegation that.
the SPMC fails to indicate planning to coordinate ORO activities with those of the State of New Hampshire. These pages reference " Letter of Agreement between the State of New Hampshire and New Hampshire Yankee Representing Both the Emergency and Offs 4.ce Response Organizations," signed 3/23 and 3/24/88. Twenty-two items representing areas to be coordinated appear in this agreement. See Attachment R hereto.
Volume 5 of the NHRERP contains (as second letter in volume) " Letter of Agreement Between New Hampshire Yankee Division of Public Service Company of New Hampshire and the States of New Hampshire and Massachusetts," signed by New Hampshire and NHY, 5/13 and 5/16, 1986. Sixteen items repres ?nting areas to be coordinated appear in this agreement. Attachment S hereto, Examination of both agreements shows that the first five i items are the same in each with the substitution of "ORO" for
" Massachusetts"; nine of the remaining ten items in the I I !
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NHRERP are covered in the SPMC agreement (the exception being Item L which deals with coordinating termination of emergency status) ; six of the SPMC items do not have counterparts in the NHRERP letter. These six, however, are discussed elsewhere in the NHRERP as follows. Item F (ORO/NH coordination of EBS/public notification) is discussed in NHRERP Vol. 4, Section 3, NHOEM Director's Procedure, and in I volume 4, Appendix G; directions covering item G (coordination of precautionary actions) are contained in the same procedure. Item H (coordination of radiological monitoring) is addressed in NHRERP, Vol. 4A, Section 9, Field Monitoring Team Coordinator procedure. Item Q (notification of the FAA by New Hampshire) is covered in NHRERP Volume 4, Section 4, EOC Operations Officer Procedure; Item R (Notification of Boston and Maine Railroad by New Hampshire) is included in Volume 4, Section 6, NHOEM Agency Liaison procedure, and in Volume 4, Appendix C.
SPMC Appendix C, page C-la-1d, demonstrates that effective coordination has been planned with New Hampshire,
'i particularly when examined in light of the NHRERP letter.
1 The only real difference between the two letters is the substitution of "ORO" for " Massachusetts." No extensive training is required for New Hampshire officials to L
accommodate this difference.
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Numerous references in the SPMC and directions in the )1 implementing procedures document planning to coordinate j i
response efforts with the State of New Hampshire. Areas (
addressed cover notification (distribution of Nuclear Alert System extensions, coordination of emergency response communications networks, activation of external agencies and compacts), activation of public alert and notification systems, issuance of EBS messages, radiological surveying / sampling, total population exposure, and recovery activities. SPMC, pgs. 1.1-3, 2.0-1, 3.2-12, 3.2-15, 3.2-16, 3.3-2, 3.3-10, 3.3-13, 3.7-5, 3.9-1, 3.9-3, 3.9-7, 4.1-1, 4.6-1; IP 1.1, especially Attachments 2, 3, 4, 5; IP 2.1, Section 5.2.8 B; IP 2.3, Section 5.1.2.B; IP 2.5, Sections 2.1, 5.1.5, 5.1.6, 5.1.7, Attachment 2; IP 2.6, Sections 2.1, 5.1.4, 5.1.5, 5.1.6, 5.3.3.
ORO personnel are co-located with State of New Hampshire personnel at the ORO EOC/NH IFO, Newington,,NH; at the Joint t
Telephone,Information Center, Newington, NH; and at the Media Center, Newington Town Hall, Newington, NH to enhance coordinated response by both organizations.
! There is no requirement that the SPMC indicate that i
State of New Hampshire personnel have read or been trained on the plan for another state. The combined functional drills
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and the 1988 Seabrook Station FEMA-NRC Graded Exercise have provided practical training for New Hampshire personnel on
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areas in which coordination with the ORO is required by either SPMC or NHRERP. Coordination sessions were conducted for the me.nagement of the ORO, the Seabrook Station ERO, and the New Hampshire emergency response organization on May 18 and 19, 1988.
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ATTACHMENT A i
(Brief History and Status of Massachusetts !
Radiological Emergency Response Plans, 3/80) 0 4
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i BRIEF HISTORY AND STATUS OF MASSACHUSETTS RADIOLOGICAL EMERGENCY RESPONSE PLANS i
MARCH, 1980 l
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Massachuset,cu Civil Defense Agency and l Office of Emergency Preparedness 1
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Attachmsnt A (Page 2 of 9) j g,;.-
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I I This material was prepared by the Massachusetts Civil Defense Agency I .
for inclusion in a Cabinet Task Force report to the Governor on.
the implications of the Three Mile I Island Accident for Massachusetts.
Because of its general nature, it has been reproduced, in the expect-ation that it will prove informative to many others with an interest in I the Massachusetts radiological response planning effort.
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Radiological Emergency Response Plan 1 I
OVERVIEW I The Massachusetts Radiological Emergency Response Plan (RERP) is a hazard specific supplement to the State's Comprehensive Emergency Response Plan (CERP).
j ne plan.vas initially developed in 1975 to provide guidance and assistance to i State and local officials with responsibilities for responding to radiological ]
j emergencies at nuclear power staticos (and elsewhere); to Federal or private agencies who are asked to assist in such response, and to individual citizens I who c.ay be at risk in the event of radiological emergency.
The discussion below reviews the history of radiological emergency response I planning in Massachusetts; the status of plans as of April,1979; the extensive effort undertaken over the balance of 1979 to review and upgrade the plans; and remaining radiological emergency response planning issues.
PLANNING HISTORY ANE STATUS AS OF APRIL,1979 There are two nuclear power stations (NPSs) in Massachusetts; the Yankee Rove I NPS in Rowe, and the Pilgrim I NPS in Plymouth. A third facility, the Vermont Tankee NPS is located in Vernon, Vermont, about three miles north of the Massachusetts border on the Connecticut River. Tankee Rove was among the earliest I .co==ercial nuclear power stations, beginning operation in 1960.
During the 15 years following coc=issioning of Yankee Rove, nuclear power opera-tions in and around Massachusetts were carried out without benefit of any formal response plans for evacuation or other protective action in the event of an accident at a nuclear power station. Throughout this period, guidance from the I U.S. Atomic Energy Commission (AEC) and its successor regulatory agency, the U.S. Nuclear Regulatory Commission (NRC) indicated that the public safety was amply provided for through a combination of redundant reactor design safety features (" defense in depth") and engineered safeguards (such as containment I structures, cleansing sprays, etc.) designed to limit the amount of radioactivity reaching the atmosphere in the unlikely event of a serious accident.
In 1975, the NRC adopted a new posture, based upon the findings of the Reactor Safety Study (Wash 1400) which indicated that despite redundant design features and engineered safeguards, an accident involving high level radioactive releases to the atmosphere, and a potential threat to public health and safety, while statistically very unlikely, was nonetheless possible. The NRC issued guidance titled " Guide and Checklist for the Development and Evaluation of State and Local Covern=ent Radiological Emargency Rasponsc I'lans in Support of Fi=ed W:10::
I Facilities" (NUREG 75-111). This guidance consisted of detailed checklists for the development of plans for of f-site e:41uation of radiation hazards, limited evacuation of populations near the plant (the guidance suggested evacuation I plans f or the " low population zone" an area defined separately for each NPS ranging from 2.75 miles to 5 miles from the wcility), and for effecting other protective actions, including those associated with the food chain.
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B Attachment A (Page 4 of 9)' 2 c
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Early Plans During 1975 and 1976, the Massachusetts Civil Defense Agency (MCDA) working with ,
the Massachusetts Department of Public Health (MDFB), the State Police, the Department of Public Works (DPW), other State agencies, and the affected local :
governments developed response plans for a five mile radius around each power station. These were. simple, straightforward plans designed to accomplish five things:
- 1. Rapid notification by the utility to the State of any accident To assure that State authorities would be alerted as soon as possible of any I accident involving an actual or potential threat to public safety, each NFS, at the request of the State, installed a microwave system linking the utility directly to the State Police. The State Police, in turn, using telephones I with a State Police beeper back-up would immediately call officials of the Department of Public Health's Radiation Control Unit, which would call the utility's E=ergency Coordinating Center on r. dedicated unlisted telephone to I get an i=cediate deter =ination of plant status. Where appropriate, MDPH vould dispatch members of its Nuclear Advisory Team (NIAT) to monitor off-site radiation levels and reco==end appropriate actions to local officials.
- 2. Rapid notification of officials in surrounding communities l Rapid notification of local officials in the vicinity of each NPS was accom-I plished through utilization of the National Attack Warning System (NAWAS).
This system permita direct voice transmission between the NAWAS State Warning Point at State Police Headquarters, Boston; the alternate State Warning Point at MCDA Headquarters, Framingham, and 27 sub-State warning points, which I
I include MCDA Area IV and Area II Headquarters in Belchertown and Bridgewater respectively, State Police in Middleborough anr'. Northampton, and pointa in Taunton, Brockton and Greenfield. Police and fire nets are used to notify I e'ach involved community, with back-up notifications flowing over civil defense and county police nets. In periodic tests, notification to involved communities can usually be carried out within 5 minutes of receipt by State Police of an I alert message by the utility.
Alerting of the General Public 3.
I Alerting of the general public of an accident, and notification of appropriate protective action was accomplished in the plans through utilization of local police, fire. DFW and other vehicles. Detailed route plans were prepared as a I part of local radiological emergency r_esponse plans, over which alerting vehicles vould travel, conducting a street-by-street notification using sirens and loud-hailers. Estimates indicate'that such a notification could be carried I out in 35-45 minutes under ordinary conditions, but would require up to one hour in adverse weather conditions.
- 4. Evacuation Very c.atailed evacuation plans were drawn up by of ficials of each cocununity within a 5 mile radius of each NPS, and supporting Area plans were prepared by I MCDA, MDPH, DPW and the State Police. Estimates indicate that the vorst case evacuation (Plymouth during a summer weekend) could be evacuated out to 5 miles in about 5-6 hours. (Analyses of population and road network for the ten-mile I radius also indicate 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for mn h evacuation time.)
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Attachment A (Paga 5 of 9)3
- 5. Care of Evacuated Citizens I
The plans developed during 1975-76 provided for reception and care of ;
evacuated citizens at centers established in Plymouth itself for people i evacuating the Pilgrin area; and in Greenfield or Buckland for people evacuating the area around the two Yankee plants. Provision was made for
- utilization at reception centers of Red Cross Chapter personnel and resources.
1979 PLAN REVISIONS I Reasons for Change When the Governor's Special Nuclear Cabinef Task Force was assembled in April, 1979, their compelling reasons to upgrade and expand the existing RERP vere I apparent:
- 1. New Federal Guidance .
In December,1978, the NRC' and the U.S. Environ = ental Protection Agency issued a joint task force report titled " Planning Basis for the development I of State and local response plans in support of Light Water Nuclear Power Plants" (NUREG 0396). This draf t guidance proposed a new concept, " flexible planning zones", and reco= mended a plume exposure planning zone of about ten i
I miles, within which detailed plans for evacuation, shelter and other protective actions designed to limit radiation dose from inhalation or direct exposure to a passing plume should be developed. A so-called " ingestion pathway" zone, extending to about 50 miles of each NPS was also recommended. In this zone, the guidance suggested that State plans provide for the capability to monitor water, cattle feed, and produce; and, as necessary, to interrupt the food chain. This new guidance was based upon analysis which indicated that in I most severe accidents, including most core-melt accidents, EPA's " protective action guides" (exposure levels beyond which public authorities should take specific actions to avoid further exposure) would net be exceeded.
- 2. The Accident at Three Mile Island The March,1979 accident at the Three Kile Island nuclear power station did I not increase the likelihood of a similar accident in Massachusetts, nor was there anything about the Three Mile Island accident which would indicate that accidents more serious than those previously considered vere possible.
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Three Mile Island did radically alter the public perception of the likelihood of serious accidents at nuclear power stations, and greatly increased the awareness of public officials at all levels of government to the need for I emergency response. -
Consequently, the Three Mile Island accident presented an opportunity to revise i and upgrade existing plans while the 'avareness and concern'of both the general i public and of governmental officials remained high, and an opportunity to initiate both plume-exposure planning in the areas between 5 and ten miles of each power station, and ingestion pathway planning in areas beyond ten miles.
- 3. Likelihood of new regulation Since 1975, the NRC has maintained a Regional Advisory Committee, made up of I representatives from various Federal agencies, which has a responsibility to provide technical assistance to States in the development of their radiological emergency response plans. The RAC also reviews these plans against existing
Attachment A (Page 6 of 9)
. ..y I Federal guidelines (NUREG 75-111) and, where appropriate, " concurs" in their. technical adequacy.
]
I While videly misunderstood as an " approval" process, RAC review is voluntary. (The NRC has no legal authority to regulate either States or localities.) In 1977, Massachusetts informally submitted its plan to the I RAC, which advised that most critical plume exposure response functions, such as communications, notification and evacuation vere adequately covered, ;
but that capabilities associated with sN h functions as provision of medical I services and food chain functions repired further documentation.
Issuance of the joint EPA /NRC task force report on emergency planning (NUREG 0396 - December,1978), and the subsequent accident at Three Mile Island (March, 1979), led State officials to expect that the existing voluntary concurrence process would become mandatory, and that guidelines I reco=nended in the joint EPA /NRC report would be adopted as enforceable regulations with respect to Nuclear Power Stations.
The three reasons for undertaking a planning effort involving upgrading and I expanding existing radiological emergency nesponse plans were, in stc=ary:
- 1) reducing the threat to public safety posed by the existing plants, as suggested by NUREG 0396; 2) taking advantage of the increased public awareness of this I particular hazard to develop effective plans for com= unities in a vider radius of the plants; 3) anticipating regulatory action which could result in closure of plants because of inadequate State and/or local response plans.
Local Planning Process Massachusetts, like several other New England States, depends very heavily upon I the capabilities of local emergency forces (police, fire, public.vorks) in responding to any emergency or disaster situation. Consequently, carrying out
.the protective actions associated with any radiological emergency vill depend upon I local capabilities, and well-developed local plans. In June, 1979, the Massachusetts Civil Defense Agency began a major planning effort to assist local governments in improving or developing radiological emergency response plans.
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I Public officials (selectmen, police, fire, civil defense, etc.)'from all towns within a ten-mile radius of each NPS vere invited to one of three meetings (one for each site) where planning history and requirements were discussed, and local input accepted. ,
The regional meetings were followed up by dizens of meetings at the local level, vhere local planning committees were established, planning data gathered, and l I local plans prepared. Department of Public Health, State' Police, Department of Public Works, Red Cross and others assisted in this process. By November, 1979, each of the thirty evacuation and reception. communities in Massachusetts had I completed detailed plans for carrying out the various protective actions recommended by the State Radiological Emergency Response Plan (RERP).
Each local radiological plan consists of a basic plan outlining responsibilities I and operational concepts; and annexes for evacuation, shelter, access control, protective actions for food and water, exposure control, public information, and various support services.
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l Attachment A (Page 7 of 9)
^ '. 5 ,
State Radiological Emergency Response Plan The State Radiological Emergency Pasponse Plan (RERP), which includes the local plans described above, was developed in accordance with guidance issued by the U.S. Nuclear Regulatory Commission in a document entitled NUREG 75/111 " Guide and Checklist for Development and Evaluation of State and Local Government Radiological Emergency Respons '
Plans in Support of Fixed Nuclear Pac 111 ties".
- The planning basis adopted for the RERP is consistent with that recommended in NUREG 0396, referenced above, and incorporates a ten-mile plume exposure emergency planning zone (EPZ). The RERP provides for implementation of ingestion exposure (food, water, milk) protective actions on a Statewide basis.
The new RERP represents a substantial upgrading over previously existing plans.
Sections on varning and communications,. coordination of emergency operations., public information, and accident assessment have been expanded to assure that any Federal planning guidelines are met. Ten functional annexes, listad belov, have been added, which document in detail responsibilities and procedures associated with various radin-logical emergency response functions.
(RERP Functfr,nal Annexes Listing)
Protective Response - Pluma Exposure Pathway Protective Response - Ingestion Exposure Pathway Radiation Exposure Control Medical and Public Health Recovery and Reentry Interstate Coordination Federal Radiological Assistance Training and Exercises Plan Maintenance and Updating Fesources The Radiological Emergency Response Plan was submitted to the U.S. Nuclear Regulatory Commission (NRC) for their concurrence review on December 18, 1979. Copies of the State RERP and the relevant area and local plan vere distributed to each local communit I involved in evacuation and/cm reception during the following two week period. The RERP was implemented, by action of the State Civil Defense Director, affactive December-31, 1979.
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REMAINING ISSUES ,- -
Since the accident at Three Mile Island, the regulatory environment in which nuclear power stations generate electricity, and states and localities develop plans to respond to any emergency at these plants, has been in a state of constant flux. Site-specific and general reviews of emergency plans have been conducted by the NRC and by various study commissions. Various rules have been proposed by the NRC which have not yet been adopted and which, if adopted in their present form, could require major expen-
} ditures by utilities and/or government, and substantial further revision of state and J local plans. A few of the remaining issues involving new or proposed Federal rules and oversight are briefly described below.
Attachment A (Page 8 of 9), , ' . ',
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- 1. " Prompt alert" provisions .
One elemant of proposed NRC rulemaking would require utilities to assure that the means exist to notify 100% of the public within five miles of a reactor of any accident within 15 minutes of the s'ccident; and to carry out a similar nor.ification to 90% of the public in the same time frame. The notification systems now a part of the RERP would not meet these criteria, since they depend upon existing local capabilities which would require from 35-45 minutes to accomplish this task. Meeting the requirement, which MCDA views as a very arbitrary one since NRC cannot identify any accident sequence which would result in so short a time-frame, would demand large expenditures (perhaps millions) by utilities.
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Utilities .thusf ar have been reluctant to make such a comaitment until rulemaking is complete, and definitive design andards have been established for these systems. (Both Boston Edison and Yankee Atomic have, however, expressed a villing-ness to work with local comunities 'should the rule become final, and both have initiated surveys to determine what kind of systems could meet the proposed alerting require =ent.) MCDA strongly urges that any such systems, when installed, be adaptable for public warning for all hazards, and has requested federal funding support for impacted localities through the Federal E=ergency Management Agency.
- 2. Non-definitive Federal guidance The nost recent Federal guidance on development of RERPs was issued .% January, 1980, one month after completion and submission of the Massachusetts 'lRP. This guidance (NUREG 0654, " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants")
issued jointly by the U.S. Nuclear Regulatory Commission (NRC) and the Federal Emergency Management Agency (FEMA) introduces requirements that go beyond any earlier guidance. Despite the 'f act that the document was issued "for interim use and coment," it is being used as the basis for review of state and local plans by Federal authorities.
Atte.npting to meet such constantly changing criteria, particularly when the I l
criteria are applied before comment and criticism are received, puts the state and local communities very much in a position of shooting at moving targets.
- 3. Uncertainties of concurrence procedure As noted above, the Federal government has for some years provided comment and
.'. technical assistance to states relative to their RERPs through a purely voluntary, I vell-understood " concurrence" process. At the regional level (New England) a
( Regional Advisory Consmittee (RAC) consisting.of representatives of various Federal agencies (HEW, DCPA, FDAA, DOT, and'bthers) chaired by the NRC reviewed state plans.
f Pursuant to a Presidential directive issued in December, 1979, and a subsequent memorandum of understanding between the NRC and the newly-organized Federal
) Emergency Management Agency (FEMA), the responsibility for operating the inter-
)
agency Regional Advisory Committees (RACs), and for conducting reviews of state !
plans was transferred to FEMA. This transfer of authority is consistent with the l general emergency preparedness role of FEMA, and is supported by MCDA, but has nonetheless had the short-term effect of involving many Federal officials in the concurrence process with little or no previous exposure to peacetime radiological emergency response planning. The likely result is a delay in receipt by
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Attachme'nt A (Page 9 of 9) l
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- I Massachusetts of a formal Federal concurrence in the new RERP.
- 4. Seabrook Nuclear Power Station planning I
MCDA expects to begin the development of radiological emergency response plans for Massachusetts communitica in the area of the Seabrook (NH) nuclear power '
station in April, 1980. While the facility, now under construction, is not expected to go on-line before 1984 at the earliest, and detailed evacuacf on plans I
developed at this early date would be of little value then, regulator requirements i and public perception of potential difficulties in evacuate g some involved armas make an early start advisable.
The newly-developed State RERP will form an excellent base for the Seabrook area work. The emphasis will be upon developing local plans for implementation of evacuation and other protective actions for towns within (roughly) the ten-mile I " plume exposure" emergency planning zone around the Seabrook site. Work will progress in coordination with officials of the State of New Ha=pshire, with whom Massachusetts (and Vermont) have been working closely on plans for the Vernon ("'")
nuclear power station. For the short term, MCDA plans involve holding a soies ,
of meetings in the area with local public officials at which planning history ani l requirements vill be covered in depth, together with the schedule and rescurces I for developing local plans. Resort areas with limited roadway netverks and high peak population densities vill be emphasized.
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ATTACHMENT B {
(Executive Order No. 144) l 1
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Attachment B (Page'l of 3)
Cot 910NWEALTH OF MASSACHUSETTS By His, . Excellency -
MICHAEL S. DUKAKIS . .
Governor EXECUTIVE ORD' E R NO. 144 . .
(Revoking and superseding Executive Order No. 25)
WHEREAS, it is the responsibility of th's Commonwealth of Massachusetts to preserve the' health and welfare of its
' citizens in the event of emergencies or disasters by' insur-ing the ef fective deployment of . services and resources,; and
- WHEREAS, such emergencies or disasters may result from -
aniamy attack or by ' riot or other civil disturbances, or .
from earthquakes, hurricanes , . tornados, floods, fires., and l
/ _other natural causes; and -
WHEREAS, the ei<perience 'of recent years suggests the inevitability of natural disasters and the increasing capa-bility of potential enemies of the United States to attack this commonwealth and the United States in greater aind ever-growing force; and, WHEREAS, the effects of such emergencies or disa.sters
- may be , mitigated by ef fective planning and operations: - -
NOW, THEREFORE, I, Michael S. Dukakis, Governor of the.
- Commonwealth, acting under the provisions of the Acts of ' .'
1950, Chapter 639, and in particular, Sections 4, 8,-16 and 20 thereof, as amended, and all other authority conferred, upon me by law, do hereby issue this Order as .a necessary*
l preparatory step in advance of actual disaster or catastro--
ph.e and as par,t of the comprehensive plan an.d program for the Civil. Defense of the Commonwealth. -
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- 1. The Secretary of Public Safety, through the State '
J.
Civil Defense Director, shall actias State Coordinating -
l Of ficer in the event of emergencies and natural disasters and shall be responsible for the coordination for all .
activities undertaken by the Commonwealth and its politi- .
cal subdivisions in response to the threat or occurrence
~
of emergencies or natural disasters. , .
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Attachment B (Page 2 of 3) 4 s
- 2. This coordination shall be carried out through
.and with the assistance'of the Massachusetts Civil Defense '
Agency.and Office of Emergency Preparedness, as provided under the Acts of 1950, Chapter 639, as amende'd.
- 6 ,
- 3. Each secretariat, independent division, board, conadssion' and authori,ty of the Government of the Common- '
' wealth (hereinaf ter referred to as agencies) shall make ,
appropriate, plans for the protection'of its personnel,
. aquipg.ent and supplies (including records.and documents). -
against the ef fects of enemy attack or natural disaster, .
And for ' maintaining 'or providing servi'ces appropriate' to
. the agency which may be required on an emergency basis.
Each agency shall make appropriate plan's for carrying cut such emergency respons.ibilities as may be assigned in this Order or by subsequent order of the Governor and for rendering such additional emergency assistahce as the Secretary of Public Safety *and the Civil Defense l Agency and office of Emergency Preparedness may req 6 ire.
- 4. The responsibility for such planning shall rest , , )
1 with 'the head' of each agency, provided that .sugh agency head may designate a competent person in the service of ~
- . the agency to be and act as the Emergency Planning Offi- ,
car of the Agency. It shall be the function of said Emergency Planning Of ficer to supervise and coordinate such planning by the agency , subject to the direction and control of the head of the agency, and in cooperation
- with the Secretary 'of Public Safety and the State Civil '
Defense Agency and Office of Emergency Preparedne,ss.
- 5. Each agency designated. as an Emergency Respon'se Agency by . tie Director of Civil Defense shall as' sign a minimum of two persons .to act as . liaison of ficers between' such' agency and the Civil Defense. Agency and Of fice of
, Emergency Preparedness for. the purpose of coordinating resources, training, and operations within such agency.
To the extent that training and operational requirements
- dictate, the liaison officer shall be under the direction
. and authority of the State Civil Defense Director for such -
l periods as may be required. ,
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- 6. A Comprehensive Emergency-Response Plan for the-
- Commonwealth shall be promul'gatedland issued and shaAl constitute of ficial guidance for operations for all' -
l agencies and political subdivisions of the Commonwealth in the event of an emergency or natural disaster. , .
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Attachment B (Page 3 of 3)
PO*d t101
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'A+ 3 Given at the Executive Chamber in Boston' this.Z7 day 4 of September
.I*..' 2 4) in the. Year o thousand iji ,
Our Lord, one hundred and seventy ..
p:8 '
e - eight, au the independence,of 4 y 8 the Uni ates, the two hhn-
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, , dredth ,ird.
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IICHAEL S. pux/ IS' '
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J;overqor
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Co onwea3.th of sachusetts ' ',
11 ,
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PAUL GUZZI ' '
. Secretary of the Commonwealth, ,
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l GOD SAVE THE COMMONWEALTH OF MASSACl!USETTS l .. .
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i ATTACHMENT C (Massachusetts State Police Barracks Location List) i 1
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ATTACHMENT D (Memorandum of Understanding Between the Massachusetts Civil Defense Agency and I
the Massachusetts National Guard, 6/84)
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I
Attschm3nt'D (Pags-2 of 13) 1 i
l MEMORANDUM OF UNDERSTANDING BETWEEN THE ADJUTANT CENERAL, MASSACHUSETTS AND THE DIRECTOR, MASSACHUSETTS CIVIL DEFENSE AGENCY i AND l
OFFICE OF EMERGENCY PREPAREDNESS' ,
I FOR i EMERGENCY SUPPORT OF
( SEABROOK NUCLEAR POWER STATION I
June 19848 g i
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- This Memorandum of Understanding supersedes the Massachusetts National Guard Resources Deployment Plan for Seabrook Nuclear Power Station, dated April 1984 ,
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i Attachm:nt D (Paga 3 of 13)
MEMORANDUM OF UNDERSTANDING BETWEEN THE ADJUTANT CENERAL, MASSACHUSETTS
(% AND
' THE DIRECTOR. MASSACHUSETTS CIVIL DEFENSE AGENCY AND OFFICE OF EMERGENCY PREPAREDNESS ,
(MCDA/0EP) .I l
SUBJECT
]
1 Emergency Support of Seabrook Nuclear Power Plant f 1.0 PURPOSE I
i The purpose of this Memorandum of Understanding (MOU) is to outline the deployment of the Massachusetts National Guard (Mass NG) resources in support of the Commonwealth of Massachusetts Radiological Emergency Response Plan to an emergency at the Seabrook Nuclear Power Station located in Seabrook, New Hampshire.
2.0 MISSIONS
- a. Support the Manachusetts Bay Transportation Authority (MBTA) with a refueling capability in the Emergency Planning Zone (EPZ) (see Appendix A) during an evacuation ordered by the Governor of the Commonwealth. This would be accomplished by placing diesel tankers in strategic locations (Appendix B).
- b. Augmentation of emergency medical service transportation in the six (6) Massachusetts communities located within the EPZ by supplying ambulances and medevac helicopters (Appendix C). j i .
- c. Augmentation of EPZ communities during a gubernatorial-ordered evacuationwithlawenforcementperhnnel, f
! d. Augmentation of EPZ comunities with vehicles (wreckers) capabla of keeping emergency routes open (Appendix D).
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Attcchm:nt D'(Paga 4 of 13) 3.0 ASSUMPTIONS
- a. That an emergency can occur at the Seabrook Nuclear Power Station (SNPS) which may require relocation of all Massachusetts residents ,
presently living within the EPZ.
- b. That the Governor of the Commonwealth will declare a state of emergency under the provisions of Chapter 33, Section 38 or 41, Massachusetts General Laws, ard cal / $c / b ilA & wnt b N* O */ 6 ** M b
- c. sielt 68 atMt dvf ,f
- c. That relocation may bn crdered during a condition wherein the population could be in danger of exposure to radiation.
I'
- d. That protective actions may have to be taken by individuals charged with the implementation of this MOU.
- e. That an incident at SNPS requiring the implementation of this MOU would occur at the least opportune time. j f f. That sufficient resources to implement this MOU, as outlined herein will be deployed within six (6) hours of the Governor dociating an emergency.
- g. That Route I-95 will be closed to n'orthbound traffic from the Route 1 off ramp in Danvers to the New Hampshire border. Only emergency l vehicles will be allowed to utilize this segment of the interstate.
- h. That there are sufficient facilities at the Topsfield State Police barracks Route 1, to acconsnodate Massachusetts National Cuard l'
personnel and sufficient space at the Topsfield Fairgrounds to park a
equipment required to implement this MOU.
4.0 IMPt,EMENTATION
,. i
- a. The Adjutant General will order to State Active Duty the necessary resources to accomplish the mission.
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'Attachmtnt D.(Paga 5'of 13)
- b. The State Police barracks at Topsfield will be used as a comand post and, predicated on the situation, the Massachusetts National Cuerd Liaison Officer will receive instructions for the deployment of resources from The Adjutant General.
- c. The Cor::nonwealth of Massachusetts will reimburse to the Federal Government all surface and air requirements, repairs, labor, and. fuel etc.
5.0 RESPONSIBILITIES
- a. Director, Masrechusetts Civil Defense Agency and Office of Emergency Preparedness (MCDA/CEP) will notify Massachusetts National Guard Headquarters through Command Channels of the level of emergency at SNPS.
- b. The Adjutant General will:
(1) Htve his staff review the Massachusetts National Guard Domestic k Tmergency Plan (DESOP).
(2) Upon receipt of orders from the Governor through the Secret'ry a of Public Safety, mobilize personnel, and provide equipment.
required to accomplish the mission.
(3) Dispatch a Liaison officer to the Command Post located at the Topsfield State police barracks and one to Tewksbury State Hospital.
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- c. Liaison officer duties:
f
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( l') Review this MOU upon arrival. I (2) Establish communications with Hea4uarters STARC, Boston.
l (3) Deploy resources in accordance with orders from The Adjutant
' General, k 1
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Attachment D (Page 6 of 13)
(4) Maintain a Staff Journal.
6.D EFFECTIVE DATE AND AWUAL REVIEW This memorandum is effective when signed by The Adjutant General, Massachusetts National Guard and the Director, Massachusetts Civil Defense Agency and Office of Emergency Preparedness, or their designated representatives. This agreement will be reviewed annually by both TAGMA and MCDA/OEP 90 days prior to the anniversary date of the signing. All revisions or changes will be accomplished as written amendments, hereto.
, A> , ( .g Di fo[,*M ^ THO Y C. SVACORCIA
, Massachusetts Civil Defense Agency eneral N A) and The Adjutant General
(' Massachusetts National Guard Office of Emergency Preparedness Date Dm APPENDIX A: Seabrook Station Emergency Planning Zone APPENDIX B: Recommended Location of Diesel Tankers APPENDIX C: Emergency Medical Service Vehicles APPENDIX D: Recommended Location of Wreckers N
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Attachment D (Page 7 of 13)
APPENDIX A (SEABROOK STATION EPZ MAP) TO THE MEMORANDUM OF UNDERSTANDIWC BE NEEN THE ADJUTANT CENERAL AND HCDA/0EP FOR EMERCENCY SUPPORT OF SEABROOK NUCLEAR POWER STATION.
SEAE:OOK STATION EMERGENCY PL ANN:N G ZONE yy 7 ,., 1 ---
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Attachment D (Page 8 of-13)
TAB A TO APPENDIX A (SEABROOK STATION EMERGENCY PLANNING ZONE)
LIST OF LOCAL CIVIL DEFENSE DIRECTORS Community Name Office # Home #
Amesbury Richard Clark 363-2388 388-9691 Merrimac Robert Paris 685-0911 346-8091 Newbury Chief George Reil 465-3737 462-6975 Newburyport Lance Broat 465-7382 465-8054 Salisbury Daniel Girard 465-3121 465-5031 (For radio contact only)
West Newbury Clifford Wallace 363-2021 363-2021
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=m Attachment D (Page 9 of 13)
TAB B TO APPENDIX A (SEABROOK STATION EMERGENCY PLANNING ZONE)
. COMMUNICATIONS A. MCD/0EP
- 1. Radio - 45.36 MHz, 162.2 TL, 45.32 MHz, all areas 153.965 MHz B. Area I, MCDA/0EP 3
- 1. Radio - 45.36 MHz and 45.32 MHz, 153.965 MHz 2-meter amateur radio and citizen band
- 2. Telephone - 617-944-1184, 617-851-7251 i C. Massachusetts National Guard
- 1. Radio - 45.36 MHz, 40.6 MHz, 49.185 MHz
- 2. Telephone 617-782-1502, 617-782-7842, 617-787-1157 m
D. Mae:achusetts Department of Public Works
- 1. Radio - 47.14 MHz, 47.28 State-Wide
- 2. Telephone -
(1) District #5 617-774-3190 t
(2) Maintenance:
I Newbury - 617-462-2961 Haverhill - 617-372-0162 Danvers - 617-774-3190 Peabody - 617-535-3424, 617-535-3292 Salisbury - 617-465-8096 E. State Police
- 1. Radio - 42.32 MHz
- 2. Telephone -
_- (1) Troop A - Framingham 617-879.67(2 (2) Topsfield barracks 617-887-231{
I F. MBTA .
- 1. Radio - 453.90 MHz (160 buses system wide)
- 2. Telephone - 617-727-5000, 617-727-5176, 617-727-5177
( C. EPZ Communities I A-3 I
Attachment D (Page 10 of 13)
APPENDIX B (RECOMMENDED LOCATION OF DIESEL TAlTKERS)
RECOMMENDED LOCATION OF DIESEL TANXERS
!.acation Ouantity of Diesel Fuel Northbound lane I-95, one mile south of 5,800 Callons Route 110 Northbound lane I-95, one mile south of 6,200 Callons
__ Route 113 Northbound lane I-95, one mile south of 1,800 Callons Route 133 (Move tankers to DPW (Scotland Road) located in Newbury. East of I-95 when above mission is complete.)
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Attachmnt D (Paga 11 of 13)
TAB A TO APPENDIX B (RECOMMENDED LOCATION OF DIESEL TANKERS)
- r. The'following is a list of the exact fuel locations and capacities in District {
- 5 MDPW. j f
Diesel Tank Capacity ,
1 Salisbury, Rabbit Road 5,000 callons i Rowley, Route 1 5,000 Ca11ons Andover, Route 125 5,000 Ca11ons Peabody, Route 1 5,000 callons Manchester, Route 128 5,000 callons Ipswich, Route 1A 5,000 Ca11ons Haverhill, Routes 495/97 5,000 callons
)
Lawrence, Marston Street 5,000 callons Rer.ular Cas Tank Capacity Rowley, Route 1 8,000 Callens Andover, Route 125 8,000 callons Danvers, Routes 1/62 5,000 callons Newbury, Route 95/ Scotland Road 8,000 Ca11ons No Lead Gas Tank Capacity salisbury, Rabbit Road 8,000 Ca11ons Peabody, Route 1 8,000 Callons
- Manchester, Route 128 8,000 Callons l
2 Ipswich, Route 1A - 8,000 callons Haverhill, Routes 495/97 i 5,000 Ca11ont 5
Danvers, Routes 1/62 8,000 callons Newbury, Route 95/ Scotland Road 8,000 callons
. The Ipswich location is only open during an emergency.
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Attachment D (Page 12 of 13)
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APPENDIX C (EMERGENCY MEDICAL SERVICE VEHICLES)
EMERGENCY MEDICAL SERVICE VEHICLES RECOMMENDED DEPLOYMEb7 Community Number of EMS Vehicles ,,
Amesbury 20 Merrimac '
3 i
Newbury 1 Newburyport 40 P
Salisbury 1
- West Newbury J TOTAL 67 .
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Attachment D (Page 13 of 13)
APPENDIX D (RECOMMENDED LOCATION OF WRECXERS)
)< RECOMMENDED LOCATION OF WRECXERS Location Number of Wreckers
- 1. At junction of Route U.S. I and One (l')
State Route 110. Salisbury
- 2. On Route U.S. I at the Newburyport One (1)
Circle, Newburyport I
- 3. On Route U.S. lA, that portion that one (1) travels west at the entrance to State Reservation Salisbury
- 4. On Route I-95, northbound lane, at One (1)
Route 133 (exit to Rowley)
- 5. On Route I-95, northbound lane, at one (1)
Scotland Road, Route 110 (exit to Salisbury)
- 6. On Route I-95, northbound lane, at one (1)
State Route 110 (exit to Salisbury)
- 7. On Route I-495, northbound lane at one (1)
- Exit 53 q.
- 8. On Route I-495, at Exit 54 One (1)
- 9. On Route U.S. lA at the Newbury/ One (1)
Rowley line TOTAL Nine (9)
NOTE: The exits from Route I-95 are not numbered.
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l ATTACHMENT E-(Massachusetts - Department of Food'and Agriculture,;
-Civil-Defense - Manager's Action Plan, 12/8/88) 1
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. BOARD OF F000 & AGRIClA%#!chment E (PagdT M d)A
,. Joseph Arena -Chairman Ralph Baldasaro, Chester Christopher Scangas, Marblehead Henry Easterbrooks, Dudley Alan Wilson, Lexington Mary Nourse, Whately Arthur Wyman, Bridgewater MASSACHUSETTS DEPARTMENT OF F000 & AGRICULTURE CIVIL DEFENSE - MANAGER'S ACTION PLAN DEPARTMENT OF F000 AND AGRICULTURE Leverett Saltonstall Building Phone: (617) 727-3000 100 Cambridge Street Boston, MA 02202 August Schumacher, Jr. - Commissioner 727-3002 Vacant - Secretary to the Commissioner Charles Costa - Assistant Commissioner Catherine Clement - General Counsel 727-3004 O! VISION OF ADMINISTRATION Richard P. Connaugnton - Director 727-3003 James T. Walsh - Head Administrative Asst. 727-3001 DIVISION OF AGRICULTRUAL DEVELOPMENT Vacant - Director of Agricultural Development Janet Christensen Chief - Bureau of Markets 727-3018 James Alicata - Chief - Bureau of Land Use 727-0465 Vacant - Public Information Officer l
DIVISION OF ANIMAL HEALTH Mabel Owen - Director 727-3015 Dr. Victor LaBranche - Supervising Veterinary Health Officer 727-3016 Edward Hageman - Supervisor of Poultry Products (413) 283-5214 O! VISION OF FAIRS S_tepnen F. Quinn - Director
[ (617) 727-3037 Robert Bennett - Program Coordinator II 727-3037 Peter Bundy - Director - Division of Equine Programs 727-3037
) DIVISION OF REGULATORY SERVICES Lewis F. Wells, Jr. - Director 617-545-9265 727-3008 t Jeffrey Carlson - Chief - Bureau of Pesticides 727-7712 Warren Shepard - Chief - Bureau of Plant Pest Control 727-3031
} James Cassidy - Chief - Bureau of Farm Products 727-3018 David L. Sheldon - Chief - Bureau of Dairying 727-3008 i
John B. Kelley - Chief - Bureau of Milk Marketing 727-3026 k (
STATE RECLAMATION & M0500!TO CONTROL BOARD Margaret havey - Executive Secretary 727-3035 L
(2) Attachmint E (Paga 2 of 3)
'A. When the present office quarters are not useable the Department of Food and Agriculture will relocate to the department's satellite office in i Lancaster, MA )
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B. Chain of Command
- 1) August Schumacher, Jr.
- 2) Lewis F. Wells, Jr.
- 3) David L. Sheldon
- 4) Warren Shepard C. Emergency Operations Control Personnel Keeps proper records of incoming and outgoing messages. Takes all incoming calls pertaining to the emergency.
- 1) Margaret Brennan 3) Barbara Scoff
- 2) Sandra Pepe 4) Joyce Reardon D. Emergency Key Personnel
- 1. Kevin Ascolillo 11. Jeff Carlson
- 2. Micnael Foley 12. Margaret Havey
- 3. James Walsh 13. James Cassidy
- 4. Steven Quinn 14. Robert Cassidy 5, Peter Bundy 15. George Porter
- 6. Mabel Owen 16. Jack Kelley
- 7. Charles Costa 17. Mark Buffone
- 8. Janet Christensen 18. Gail Kapreilian
- 9. James Alicata 19. Paul Gosselin
- 10. Craig Richov 20. Wayne Tolland
- 21. Thomas Falter
( irtment of Food and Agriculture Assets A. Forty three autos well distributed throughout the State.
B. Three Veterinarians -
- 1) Dr. Victor LaBranche - Haverhill, MA - Supervising Vdterinary Health Officer 374-4510 ;
- 2) Dr. John Sickles - Rochester, MA 763-2686
- 3) Dr. Winthop Brielman - Pittsfield, MA 442-3437 C. Toxicologists
- 1) University of Massachusetts Medical School - Worcester, MA 508-856 0011
- 2) Tufts New England Veterinary School North Grafton, MA (508) 839-5302 -
Jamiaca Plain Laboratory (617) 522-2125 ., '
O. Two Entomologists
- 1) Lewis F. Wells, Jr. - B.S., M.S. U. of MA.,
- 2) Mark Buffone - B.S. Degree, U. of MA t
E. Others knowledgeable in diary, fruit, produce, and poultry.
F. Others knowledgeable in farm marketing.
G. Outside Contacts. '
FEDERAL STATE CROP REPORTING SERVICE 1 Aubrey R. Davis - Agricultural Statistician in Charge (603) 224-9639
) 6 Loudon Road
. Concord, N.H. 03301
Attachment E (Page 3 of 3)
(3)
CIVIL DEFENSE AND DISEASE OUTBREAK EMERGENCY PROCEDURES A. Objectives of this plan,
- 1) To set forth General Guidelines to follow during disease outbreaks affecting agriculture in Massachusetts.
- 2) To set forth procuedures relative to handling technical or environ-mental hazards affecting agriculture in Massachusetts.
- 3) To ensure that during an emergency the functions and duties of the Department of Food and Agriculture will continue as nearly normal as possible.
- 4) To make known the Department's Assets and the location of same.
- 5) To make Department personnel knowledgeable about the Department's plan and their role in same.
B. Concept of Operations.
- 1) The commissioner or his deputy may call the M.C.D.A. to ascertain an emergency or discuss what may become one.
- 2) The Commissioner or his deputy will then, notify the Department Liaision Officers to report to the M.C.D.A. Headquarters, if necessary.
- 3) Cause a proper record of all incoming and outgoing messages and all actions taken relative to same to be kept by the emergency operations control personnel.
- 4) The Commissioner or his deputy immediately after notifying the Liaison Officers, notify other key department personnel to be available if needed.
- 5) All overtime hours worked shall be kept accurately.
- 6) If the emergency occurs after normal working hours the Commissioner I or his deputy may operate the E.0.C. from his or her home. Then an orderly relocation from home to department headquarters may be made at the beginning of the next normal working day.
- 7) Ater the end of the emergency all reco'rds kept pertaining to messa-
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ges, actions, expenditures, and overtfme shall be given to the Department Liaison Officers -
i Revise 12/8/88 I
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ATTACHMENT F (Affidavit of Michael S. Dukakis, 4/28/87)
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Attachment F (Page 1 of 3) t
- AFFIDAVIT OF MICHAEL S. DUKAKIS Raving been duly sworn, I hereby depose and say as follows:
- 1. I as Michael S. Dukakis and I as the duly elected Covernor of the Coannonwealth of Massachusetts.
- 2. On September 20, 1986, I announced my decision not to submit to the Federal Emergency Management Agency (" FEMA") or to the Nuclear Regulatory Commission ("NRC") radiological emergency response plans for the Coansonwealth of Massachusetts for th.a Seabrook Station energency planning zone. (EPZ).
- 3. My decisien not to substit plans for the Commonwealth was based on I careful review of draf t radiological energenc'y response plans for Seabrook that were prepared for the Commonwealth with2he help of the utility. The plans were reviewed by myself, my staff, and several outside consultants with expertise in the area of nuclear power and safety.
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Attachmsnt F (Pr.ga 2 of 3)
. . . . 1 4 Based on that careful reviev..which took a period of many months, and thousands of hours on the part of my staf f. I determined that no '
radiological emergency response plan for the Seabrook Station emergency 3, planning ' zone can be -devised which "in the opinion of the state (is) adequate to protect the health and safety of its citizens living within the emergency planning zone. " 44 C.F.R. S. 350.7(d). I refer the reader to my statement of September 20,1986 (attached).
- 5. The Plans entitled "Seabrook Station Radiological Emergency Response Plans for the Commonwealth of Massachusetts" that New Hampshire Yankee submitted to the NRC on April 8,1987, are not the plans of the Cot:monwealth of Massachusetts.
. 6. All Seabrook emergency preparedness planning has been concluded by the Commonwealth. Appropriate state and local agencies have been so notified.
Because of the fundamental conclusion reached in my September 20 statement regarding the inherent and irremediable inadequacy of emergency I ,
planning for Seabrook Station, no radiologic ~al emergency response plans for i= .
the Seabrook Station emergency planning sonas have been or will be submitted
{ to FrMA or to the NRC by the Commonwealth of Massachusetts, nor will the 7
Consonwealth enter into any tests, drills, omises, training, or planning.
Attachmant F (Page 3 of 3)
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Signed under the pains and penalties of perjury this twenty-eighth day of April, 1987. :
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overnor . hael S. Dukakis Then personally appeared the above named Michael S. Dukakis and made oath that the above statements are true.
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Notary Public A
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i ATTACHMENT G
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(Memorandum of Peter W. Agnes.to Robert Boulay, 1/11/88, and Massachusetts. Attorney General's Answer to the Applicants' Revised. Request- 3 for Admissions from Mass AG, 12/16/88)- .i I
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Attachmsnt G (Pag 3 l'ofl3) j Q^ C/72/Til2/ll 1744 gg n? a Dpa4asA app Mkhae D& -
gggggg Chules Bury Q jg, _, pp,p, ,,,,,,,,,,
MEMORANDUM TO : ' ROBERT . BOUL AY, DIRE '5A FROM: PETER W.
l N{d g [. ASSISTANT SECRETARY DATE: JANUARY 11 , 1988
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RE: PHILOSPHY 08 EMERGENCY PLANNING (1) Testimony given bef ore Senator Kennedy's hearing last week created a controversy about the Commonwealth's policy towards persons with special needs. Some people have mistakenly assumed that it is the Commonwealth's policy to
. provide radioprotective drugs such as potassium iodide to certain'special needs populations instead of taking other protective actions such as evacuatt.on,_or sheltering. I sought to establish in my testimony that this was not a correct statement of out, policy, and that to my knowledge it was not something thas ever had been proposed. . ,
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-(2) While we must take sters to correct any similiar j misimpression other people may have, I believe we need to go further and make explicit what I consider to be implicitly the i
Commonwealth's existing policy. In this regard, I .suggest that we consider the following statement as an expression of the
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Commonwealth's policy and propose th'at we include it in all emergency plans, and guidance material prepared or distributed
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by the Civil Defense Agency:
PROPOSED POLICY STATEMENT t
EMERGENCY PLANNING AND PREPAREDNESS ACTIVITIES JOR NATURAL
[' OR MAN-MADE DISASTERS IN THE COMMONWEALTH OF-MASSACHUSETTS SHALL BE GUIDED BY THE TOLLOWING PRINCIPLES:
l L FIRST, EACH AND EVERY HUMAN LIFE IS OF EQUAL AND INESTIMABLE VALUE: i l
Attachmant G (Pcgn 2 of'3)
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MEMORANDUM TO ROBERT.BOULAY RE: EMERGENCY POLICY JANUARY 11, 1988 e PAGE TWO SECOND, DURING AN EMERGENCY, THE COMMONWEALTH WILL MAKE EVERY EFFORT AND EXHAUST EVERY RESOURCE, PUBLIC AND PRIVATE, TO i SAVE LIVES, REDUCE INJURY AND SUFFERING, AND PROTECT PEOPLE !
FROM EXPOSURE TO HARM;
-l THIRD, DURING AN EMERGENCY, PROTECTIVE ACTION JUDGMENTS WILL BE MADE ON THE BASIS OF HUMAN NEED. THERE IS NO SUCH THING AS AN ACCEPTABLE LEVEL OF DEATH, INJURY OR SUFFERING.
- 3. I would appreciate it if you would review the proposed statement and give me your comments and those of your staff before we make a recommendation to the Secretary.
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Atttchmtnt G.(Pago 3 of 3) I
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' received l / L l,% (9$ l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before the Administrative Judges:
Ivan W. Smith, Chairman Gustave A. Linenberger, Jr.
Dr. Jerry Harbour l
)
In the Matter of ) Docket Nos. 50-443-OL
) 50-444-OL i PUBLIC SERVICE COMPANY ) (Off-Site EP)
OF NEW HAMPSHIRE, EI AL. )
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(Seabrook Station, Units 1 and 2) ) December 16, 1988
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i MASSACHUSETTS ATTORNEY GENERAL'S ANSWER TO THE APPLICANTS REVISED REOUEST FOR ADMISSIONS FROM MASS AG The Massachusetts Attorney General responds to the Applicants' Revised Request for Admissions dated December 12, 1980 as follows:
REOUEST NO. 1: It is the policy and position of the Commonwealth of Massachusetts to utilize fully every available resource, public and private, to the extent allowed by the laws of Massachusetts, and to the extent necessary and/or appropriate, to respond to a radiological emergency.
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ANSWER: Admit. .
BEOUEST NO...7: The following ivents have occurred in the two zoning litigations concerning Applicants' use of the Haverhill Staging Area: I a) in the first litigation, on or about April 7, 1988, Judge John T. Ronan entered the Order ,
attached hereto as Exhibit 1; I 1
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ATTACHMENT H (Merrimac Emergency Operations Plan, 2/83, Page 15)
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Attachmant H (Pagn 1 of 1)
I[ .Merrinse Emergency Cperations Flan i
H EA L"M
- 1. ::munizatien for prevention of disease.
- 2. Inspection of fcod, water and other materials suspected of contamination by sewage, chemicals. radioactive material or .
disease threatening a6ents, id cooperation with the state
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health department.
3 Surveillance of emergency temporary housing.
4 Emergency interment cooniination.
5 Insect and rodent control.
- b. For detailed organization, duties and responsibilities of the HEAL"E DEPARTMENT, see ANNEX E.
SCHOCIS j i
I /T The school system of Merrimac, while not normally under the direct -
command or authority of the selectmen, will respond to the authority of the selectmen as set forth under Massachusetts General laws.
Chapter 40 Section 19, as amended, and will work cooperatively with I .
the various public safety and health agencies acting under the provisions of Chapter 639 of the Acts of 1950, as amended.
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- 1. .?rotection of its school population including students, faculty
'and staff. 'Ihis may involve retention of the personnel 1,.
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school shelter facilities or releasing them to their homes or :
other shelter facilities. l I 2. Development and dissemination of procedures to be followed by all students, parents, and school personnel in disaster emergencies.
3 Esergency feeding and housing.
- 4. Cooperating with health departaemt in assisting with emergency I sedical and relocation centers.-
5 Providing trained shelter managers for facilities having good shelter capabilities.
I 6. Providing for access to school buildings during times that school is not in session.
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ATTACHMENT I (Fire Department Mutual Aid Documents, l
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Attachmsnt I (Paga 1 of 8) l
.g SHEET FOR USE WITH MUTUAL AID ASSIGNMENT CARDS BEVERLY CONTROL COMMUNITIES :
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HAVERHILL CONTROL COMMUNITIES : ,
Beverly - BEV -
Amesbury - AMS Danvers - DAN Andover - AND Essex - ESX
- Boxford -'BDX Gloucester - GLO Byfield - BYF-Hamilton - HAM Georgetown - GEO Ipswich - IPS -
Groveland - GRO i Lynn - LYN Haverhill - HAV '
Lynnfield - LYF Lawrence - IAW .i Manchester - MAN Merrimac - MER Marblehead - MHD Methuen - MTH Middleton - MID Newbury - NBY Nahant - NHT Newburyport - NPT North Reading - NRD North Andover - NAD Peabody - PEA Rowley.- ROW Rockport - RPT Salisbury _SBY Salem - SAL West Newbury - WNB Swampscott .- SWP Topsfield - TOP
- METROFIRE COMMUNITIES :
Wenham - WEN Boston - BOS
- CHEI14SFORD CONTROL COMMUNITIES : Cambridge - CBG Chelsea - CHL Billerica - BIL Everett - EVT Che'msford - CllM Malden - MAL
._ Iowell - LOW Medford - MED s Tewksbury - TWK- Melrose - MEL Wilmington - WIL Reading - RDG '
Revere - REV
- NEW ItAMPSHIRE COMMUNITIES : Saugus - SAU Somerville - SOM Atkinson - ATK Stoneham - STO-Exeter - EXE Wakefield - WKF Hampton - HPN Winchester - WIN Campton Falls - HAF W$nthrop'- WTP l Kensington - KEN ,Woburn - WOB Newton - NEW Burlington - BUR North Hampton - NHA * - In these areas, only the
! -Pelham - PEL , consnunities which appear on Plaistow - PTW -
, any of the Essex County Rye - RYE .
cards are listed.
!- iSalem - 51J4 - ~ {
l Seabrook - SBK !'
South Hampton - SHA Windham - WDM L .
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I ATTACHMENT K-(Mass.- [ sic] Casualty Procedures.~for Watch Station and Town of Amesbury Mass. [ sic]
Casualty Incident E.M.S. Response Plan) l
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l gl Attachment K g g g g g g H-t-N = I MASS. J.SUALTY PROCEDURES FOR LIATCH STATION l When a, call is received trom the scene that a MASS. CASUALTY exist, the f oll owing procedures will be f ol l owed :
The dispatcher will confirm with the scene to assure that a MASS CASUALTY INCIDENT has been reported.
The tone will be activated and BOX 555 will be transmitted j over the f ire al arm system. three rounds, The following radio transmission shall be made "THIS IS THE AMESBURY FIRE DEPT. TRANSMITTING BOX 555 FOR A MASS CASUALTY INCEDENT THAT EXIST AT ( LOCATION ). ALL PERMANENT AND CALL FIREFIGHTERS REPOPT TO FIRE HEADQUARTERS.
ALL POLICE. CIVIL DEFENSE AND HOSPITAL PERSGNNEL REPORT TO YOUR RESPECTIVE STATIONS" (repeat).686 (time)
Automatic Notification and Responce Procedure.
- 1. All Amesbury Firefighter/EMTS and c al l firefighters will be dispatcned to the scene pref erabl y on the second rescue and engine company.
- 2. Amcare Ambul ance Co. to respond with all EMT I personnel and all ambul ances aval iabl e. 462-1321
- 3. Merrimac Rescue squad and Ambulance respond to the scene. 346-8321 4 Tone Amesbury Civil Defense Channel # 8 Activate our tones 162 Announce All MEMBERS REPORT TO E.O.C. AND FESPOND WITH E.M.S. TRAILER TO ( LOCATION.) (REPEAT) 401 (TIME)
- 5. Tone So. Hampton Fire Dept. to cover Headquarters, all EMTS to the Scene.
- 6. Eng. companies from Salisbury and Newburyport to headquarters to cover.
NOTE ON MOCK M.C.I. DRTLLS: "This is a dril l " wil l be announced before and after everi announcement.
Note Dispatcher keep track of the Number of Ambul ances each services has avail able and is sending.
ALWAYS GET ONE ADDITIONAL AMBULANCE FOR STATION I COVERAGE.
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CHARLES A GOUIN EMS Coordinator AFD updated 3/12/89
A achmsnt'K-(Paga'2 of 4)
Ambulancer
- 1. A'MCARE '62-1321 1
. 2. MERRIMAC' 346-8321
- 3. .SEABROOK- 1-603-474-34'34 4.- HAMPTON 1-603 C26-3315 5.- kENSINGTON 1-603-772-5191
- 6. KINGSTON 1-603-642-5512
- 7. BYFIELD 462-2244
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- 8. 5HANAHAN 1-372-8511
- 9. EXETER 1-603-772-1212-
- 10. EMT AMBULANCE 1-603-772-5912.
RESCUE SOUADS MERRIMAC 346-8321 NEWTON 1-603-382-5212 WEST-NEWBURY 363-5163 BOSTON MED FLIGHT 1-800-233-4554
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,7 ; A thmsnt K (Paga '3 of 4
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TOWN OF AMESBURY MASS. CASUALTY INCIDENT E.M.S. RESPONSE PLAN l '.
Contract incident C-MED on response to an unconfirmed or confimed Mass. Casualty -
(M.C.I.)..
2.
The first ambulance crew arriving on-scene will be responsible for creating an EMS comand structure. One EMT should assume the " EMS Command" role while the other EMT assumes. the " Communications Officer" role. These roles may subsequently be assumed by more senior EMS officials,
- a. EMS comander performs primary scan of scene.
- b. Communications officer sets up EMS command post.
- 3. i Communications Officer:
- a. . Notifies Fire Headquarters of Mass. Casualty incident, -
the need for additional personnel; i.e. box alam, -
rescue squad, engine company, additional EMT's, etc., -
the approximate number of ambulances needed for transporting to the one or two closest hospital emer-gency rooms. Notifies Salisbury Fire Department to respond to the Mass. Casualty Equipment trailor.
- b. Notifies Amesbury and/or Anna Jaques Hospital of Mass. -
Casualty incident, with the approximate number of injured. I-
- c. After the E.M.S. Comander has completed his primary scan, the approximate number of priority 1 and priority .
2 patients should be relayed to the closest receiving .
T' emergency room. That receiving hospital will be told to institute their Mass. Casualty Plan and prepare for incoming injured. '
If it is determined by the E.M.S. Comander that because of a high number of Priority 1 and 2 patients, that more than one emergency room facility is necessary, then the E.M.S. Communications Officer will inform the second closest emergency room to place the Mass. Casualty Plan in effect. The Leading Officer will then alternate ,
- transporting ambulances between both recdiving emergency rooms. .- '
(Note) It is to be understoodithat the receiving hospital emergency room during a Mass. Casualty Incident are triage and advanced life support stabilization areas. In-hospital
\- capabilities should not be used to detemine the number of J .. ,
injured. Each hospital emergency room is capable of
,, stabili:ing.
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Attachmant g's'4 of:4) -- '
, 2.
After advanced life support stabilization and emergency .
- room triage, determination can be made with.C-MED as' to which of the in-hospital medical facilities are to be utilized. - Transport ambulances will be provided by C-MED from outlying area. ,
- d. Notifies C-MED of type of incident, approximate number. i of patients, and need for additional ambulances and equipment.
- e. Updates C-MED after primary scan with more' definitive update. Giving approximate number of patients and ,
breakdown of priority.
- 4. EMS Comander:
- a. Assigns triage officer (s) and Loading officer
- b. Designates ambulance and equipment area
- c. Make decisions to call for additional. support equipment. Can use C-MED for this. .
5.
Ambulances arriving at the scene will be directed to the staging area while awaiting assignment.
- 6. Triage officers being placing METTAb on patients in the field.
7.. EMS Comander and Loading Officer to set up three treatment areas with a loading area adjacent to treatment areas.
- )
- a. Patients triaged to priority 1, 2, or 3 treatment area. --
1
- b. Patients are retriaged at treatment area.
- 8. Comunici,tions and Loading officers coordinate patier.:. transports with C-MED.
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9 .- Communications officer contacts C-MED to request hospital assignment for~ patients being loaded into ambulances. This is passed on to Loading officer and EMT driving an6ulance.
- 10. Ambulances depart scene with radio silence. Notification to C-MED only if patients' condition deteriorates,
- 11. Communications officer gives update of scene with number of patients l
left every 15 minutes. ~
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- 12. Ambulances clearing hospitals should cheek with C-MD for assignment. l Monitor radios before talking. -
- 13. The above steps are carried out until all patients'are transported.
NOTE: ' Responding EMS vehicles will switch to and remain o' n H.E.A.R. or ED channel radios to contact C-MED throughout M.C.I..
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ATTACHMENT L (Merrimac Emergency Operations Plan, Page 4, #6) l I
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P.errtrac Emergency Operations Plan
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- 3. ASSlD? TIC"S .'
1 2e following assumptions with regard to disaster emergency' situations 'I l
may be made: ,
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- 1. Severe ice and sleet storms may paralyze the entire ana and cake f traffic movement extrenely hazardous, if possible at all, in many areas.
- 2. Obtaining shelter supplies for shelters that are not stocked would j be a major problem. 1 1
3 Notification of emergency personnel would be hampered if communication 1 lines were disrupted.
l 4 Some advance warning may be received in most natural disasters.
3 I.ittle er no warning may be expected in a nuclear attack or any incident of a military nature. .J s i
- 6. Existing mutual aid a6reements, verbal and written, in effect at
, the time of disaster would be used if it is feasible to do.so.
7 Crowd control of curious and thrill seekers would be a serious problem.
- 8. Fire incidents and accidents will increase due to panic during
- disaster emergencies.
9 Accidents on major highways may prevent emergency assistance i from reaching our area quickly..
- 10. Bare may be interruptions in service of utilities during a disaster emergency. -
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- 11. Existing ambulance service would be inadequate in a severe disaster.
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- 12. Extrose precautions sust be taken to prevent health hasards j f and the spread of communicable disease during a disaster.
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ATTACHMENT M i l
(Town of Salisbury Emergency Response I Plan SARA Title III, Page 6) !
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Attcchm2nt'M (Paga-1 of 1)
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T0ifW OF SALISBURY y EMERGENCY RESPONSE PLAN
!I' SARA TITLE III
- POLICY .ON NEWS MEDIA /. PRESS STATEMENTS:
The on-scene coordinator. / incident commander will appoint a news media spokesperson who will handle total-on-site dissemination of information. A11*other on-site personnel will be prohibited from responding directly to the media and will refer media to the appointed news media spokesperson. Control /' emergency operation center will also be provided the same news' release / information. l
- POLICY ON LIABILITY:
Agency response and handling of a Hazardous Material incident will in no way. transfer or negate any liability by owner, shipper, carrier.or other responsible party for the damage created or cost incurred to control, dispose,
. monitor or otherwise mitigate the incident. Responding agencies will not be prohibited from collecting expenses incurred as a result of work involving the incident.
C
- MUTUAL AID RESPONSE:
Mutual aid response outside the Town of Salisbury, shall be in accordance with individual agencies SOPS and other pre-existent agreements.
RESOURCES:
_ Refer to accendix A .*
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l ATTACHMENT N (Merrimac Emergency Operations Plan, Pages 8 and 9) f I
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Attachm2nt N (Paga 2 of 2)
Merrimac Emergency Operations Plan I 'I ...
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- 2. EMERGENCY FHASE_ j The EMERGENCY PHASE is that period of time _ during which the damage or destruction is occurring, with.'or without warning. Action will be taken immediately to evaluate the emergency, warn the l population of the area, make use of all available personnel, equipment and resources to minimize the effects of the disaster. ,
(The numbering sequence in the EMERCENCY ACTIONS is not meant I- to establish priority in performance as all actions are to be undertaken as soon as possible).
i A. EMERCENCY ACTIONS
- 1. Immediately alert the populace affected by the t emergency, giving them whatever guidance or I- instruction is required.
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- 2. Fully activate the designated E00 at the basement I. of Town Hall, School Street, on a round-the-clock basis and provide for water, food and sleeping facilities.
3 Establish communications with MCDA Area I
- Headquarters, and with towns a.nd cities with I 4.
whom mutuc1 aid a6reements have been made.
Conduct emergency operations in the most expedient i
manner to protect life and property.
I 1
RECOVERY HtASE I 3
The RECOVERY HIASE is that period immediately following the energency when actions will be taken to restore the community l I
to normal conditions. In the ebut all local resources are exhausted the state and federal governments can be expected I. to provide assistance in accordance with the provisions of applicable laws.
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i ATTACHMENT O (Merrimac Organizational Chart) l l
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ATTACHMENT P (Merrimac Emergency operations Plan, Pages 11 and 12) i i
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Merrimac Emergency Operations Plan
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conformity with this plan and its annexes. External agencies will
.1 also be given approprir.te notice. The phase of the emergency may j also be determined at this time.
A. COMMAND AND CONTROL OF OPERATIONS -
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The civil defense director will coordinate all emergency 1
. H operations, subject to the direction and control of the-Board j of Selectmen within community jurisdiction in accordance with mission assignments contained in this plan and its annexes. As the situation develops, the selectmen may make such other assignments of command and control as they consider necessary.
Command and. control of disaster-recovery operations is subject to the authority of the governor in a declared State of Emergency.
1 A distinction is made between (1)' operational control and ~f (2) direction of emergency forces. OPERATIONAL CONTROL consists !
J of the functions of assignments of tasks, designation'of objectives and such other control necessary to accomplish the mission. DIRECTION OF EMERGENCY FORCES includes the authority to comit to, or withdraw from, emergency operations. Direction is retained at all times by the appropriate civil or military l
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- l authority.
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I When Merrimac4 forces are operationally enga6ed within the i town boundaries, both operational control and direction of
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energency forces are retained. When Merrimac's civil forces !
i are sent to another community, operational control is exercised 3
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Attachmsnt P (Paga 2 of 2)
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1 Morrimac Emercuncy Upurallunu th j
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I- by the authority at the scene of the operations, but direction i
w is retained by Merrimac authority. Conversely, forces sent l
l to the aid of Merrimac come .under the operational control of l-I- Merrimac authority but remain under the direction of the parent agency. .
c VI. CONTINUITY OF COVERNMENT In order to insure continuity of govenurent under all circum stances l
the provisions of town meeting rules will be invoked the l I
l I. conditions described therein and the line of succession are as l follows:
- 1. Board of Selectman
- 2. Tcwn Clerk l VII. MISSION ASSIGNMEN'IS ,
!)
BOARD OF SEIECTMAN i
- 1. All normal functions and zuspensibilities to the community as chief executive.
- 2. Direct and control all emergency operations.
3 Control of all news releases and public information.
! DEPARTMENT HEADS
- 1. Provide protection for all, departmental personnel. !
- 2. Develop, maintain and activate all departmental alerting, ,
warning and operational procedures.
I 3 Prepare, maintain and activate SOP's consistent with the basic operations plan and appropriate annex.
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l ATTACHMENT Q .
(Massachusetts Civil Defense 3 Agency (McDA) Memorandum, 3/8/88) i i
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Attachm3nt Q (Pags 1 of'1)
.e . . _ _ _ . . . . . . . . .. .. . . _ , _ . . _ . .
usu21A122n R 161988 .
TO: All MCDA Per n FROM: Director Boula f.
DATE: March 8, 1988
SUBJECT:
Searock Nuclear Power Piant Communications Recent activities concerning communications from Seabrook Nuclear Power Plant indicate a need for clarification:
- 1. When a communication is received stating that an actual 1
)
emergency situation exists at Seabrook NPP, the following. personnel will be immediately notified:
A. Operations Officer (or designated back-up)
B. Director C. Deputy Director
- 2. When a ecmmunication is received stating that Seabrr0k NPP is conductir.g an Exercise or Drill, the following actions will be taken:
A. Notify caller that "MCDA does not participate in Seabrook NPP Exercises or Drills."
B. Immediately notify the following personnel:
- 1) Operations Officer (or designated back-up)
- 2) Director
- 3) Deputy Director
) 3. When a package or letter is sent to or delivered from Seabrook to MCDA, take thee following actions:
i A. Do not sign for anythink. .
B. Accept the package or letter but do not open it.
C. Give the letter or package to one of the following f . persons.
- 1) Director
- 2) Deputy Director BJB/kan j . _ _ . . _ . . _ .
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ATTACHMENT R :
(Letter of Agreement between the State of New ;
Hampshire and New Hampshire Yankee Representing l Both the Emergency and Offsite Response Organizations)
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Attachmsnt R (Paga 1 of 4)~
I. -i Amendment 3 Page 1 of 4 LETTER OF AGREEMENT i
,I BETWEEN THE STATE OF NEW HAMPSHIRE f
AN,,0 NEW HAMPSHIRE YANKEE REPRESENTING BOTH THE EMERGENCY AND OFFSITE RESPONSE ORGANIZATIONS !
I I. PURPOSE:
l 5 The purpose of the Letter of Agreement is to establish radiological emergency preparedness, notification and response should an event at Seabrook Station require Radiological Emergency Response Plan activation.
I II. DEFINITIONS:
I A. Emercency Operations Centers (EOCs) - Facilities established by the State of NH and tne NHY ORO where emergency response command and control occurs. The State of NH EOC is located in Concord, NH, and the NHY ORO EOC is co-located with the NHY EOF.
B. Emergency Operations Facility (EOF) - A center established at Newington I Station, Newington, NH to coordinate the deployment of NHY ERO personnel, to evaluate offsite accident conditions and to maintain communications with offsite authorities.
C.
EOF Coordinator - An NHY ERO member who coordinates accident assessment and protective action recommendations with offsite authorities. He i conducts these functions within the EOF. l
- 0. Incident Field Office (IFO) - A center established in the vicinity of the New Hampshire portion of the Seabrook Station Emergency Planning Zone, where the State of New Hampshire response and assistance to local communities is coordinated. The IFO is co-located with the NHY EOF.
1 E. Medis Center - A center dedicated to the news media for the purpose of I conducting joint NHY ERO, NHY QSO, State of NH, and Federal briefings concerning emergency conditions; The Media Center is located at the Town Hall in Newington, NH.
1 F. New Hampshire Yankee Emercency Response Organization (NHY EROI -
The licensee's organized personnel response to a Seabrook Station Radiological Emergency.
G. New Hampshire Yankee Offsite Response Organization (NHY ORO) -
New Hampshire Yankee's compensation organization for the Commonwealth of Massachusetts. I I C-la
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1 Attachmsnt R (Pags 2 of 4)
Arendcant 3 I
Page 2 of 4 i
H, Nuclear Alert Sy_ stem (NAS) - A communication system for. initial notification to the State of New Hampshire and the NHY ORO of an emergency at Seabrook Station; and the means of communication I between the thret organizations for exchange of information during the period of the emergency.
III. AGREEMENT The State of New Hampsnire and New Hampshire Yankee, represe:1 ting both '
the NHY ERO and the NHY ORO, agree as follows:
A. The NHY ERO shall notify the NH State Police and the NHY ORO Contact Point within fifteen (15) minutes after an event has been classified as an Unusual Event, Alert, Site Area Emergency or B General Emergency. This notification sna11 be mace over the NAS.
Commercial teleonone is the backup to the NAS.
I B. The initial message content used in the contact specified in A.
above, is in agreement among the emergency response procedures of each of the three organizations. After the initial contact, ,
additional information shall be provided to the NH Oivision of Public Health Services Emergency Response Initiator and the NHY ORO Director wnen each makes a call-back to the NHY ERO. This information is soe-cified in the follow-up notification form contained in the emergency response procedures of the three organizations.
C. The three organizations shall exchange and coordinate emergency j resconse plan changes that pertain to those elements of interface i I- prior to implementing the change. The three organizations shall coordinate the effective date of such changes. ,
I D. The NHY ERO shall provide space for representatives from the State of New Hampshire and the NHY ORO at the EOF and the Media Center. This includes space at the EOF for the operation of the I .
E.
State of New Hampshire IF0, and,for the operation of the NHY ORO EOC.
The three organizations agree te exchange all information (i.e.,
I radiological releases, meteorotpgical data, offsite radiological projections and measurements, ano onsite technical data) known and available to facilitate a rapid and accurate evaluation of the emergency.
F. The NHY ORO and the State of New Hampshire agree to coordinate the
?
notification of the public by the public alert and notification system ar.d through EBS.
G. The NHY ORO and State of New Hampshire agree to coordinate the evaluation and implementation of precautionary actions for special I populations within the plume exposure EPZ.
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I Attachmsnt R (Paga 3 of 4)
Arend:ent 3 I 1
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The three organizations shall coordinate plume exposure EPZ field I
radiological monitoring efforts. This coordination is to include'the deployment of each organization's offsite monitoring teams (i.e.. the State of New Hampshire teams within the New Hampshire portion of the plume EPZ, the NHY ORO teams within the Massachusetts portion and the 3 NHY ERO teams throughout the EPZ), the review and exchange of all g monitoring results, and the radionuclides analysis of particulate and I
radioiodine air samples at the NHY EOF.
'I I.
The NHY ERO agrees to assist the State of New Hampshire and the NHY ORO in ingestion pathway sampling and analysis efforts. This includes
-g assistance to the State of New Hamoshire coordination of ingestion i g pathway evaluations with the State of Haine. The scope of the assistance can include sampling personnel and equipment and radionuclides analysis capability.
-l3 J. Once the EOF is activated, the EOF Coordinator of the NHY ERO is the i
point for contact for the State of New Hampshire and the NHY ORO for radiological assessments and protective action recommendation discussions.
K. The three organizations agree to coordinate news releases and rumor control activities. Information shall be released to the public in a I timely, coordinated manner through the Media Center. Also, the three organizations agree to participate in a periodic emergency prepared-ness education and orientation program for news media representatives.
L.
The State of New Hampshire and the NHY ORO agree to the methodology established by the NHY ERO to project offsite radiological consequences.
' The NHY ERO agrees to provide any special projections that are beyond E the routine scope of the radiological assessment effort, as long as E the methodology used can cover the request.
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H.
The State of New Hampshire and the NHY ORO have reviewed and agree to the procedure established by the NHY ERO to classify emergency condi-tions, which includes the Emergency Action Levels.
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N. The NHY ERO agrees to make the radiological analysis services of the Yankee Atomic Environmental Laboratory available to the State of New l Hampshire and the NHY ORD. The priority for sample processing by the I Yankee Atomic Environmental Laboratory would be established through joint agreement by the NHY ERO, NHY ORO and the NH 01 vision of Public Health Gervices at the time of an incident.
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- 0. The State of New Hampshire agrees to notify the State of Haine (inges-tion pathway zone) for all emergency classifications and coordinate the evalation of offsite radiological consequences with authorities in I that State during an event which is classified as either a Site Area Emergency or General Emergency at Seabrook Station.
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I Attachment R (Pago 4 of 4)
I Amendment 3 I
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Page 4 of d I
I P. The State of NH agrees to notify and coordinate the response actions of the United States Coast Guard for the waterway portions of the plume EPZ. )
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I Q. The State of NH agrees to notify the Federal Aviation Administration for any necessary air space restrictions.
I R.
The State of NH agrees to notify the Boston and Haine Railroad for any necessary restrictions on rail travel.
S.
The State of NH agrees to request assistance available through New England state agency compacts in response to a request by the NHY ORO.
T. The State of NH agrees to arrange for the clearance of NHY ERO and I NHY ORO emergency response personnel through EPZ Access Control Points in NH.
U.
This agreement may be amended at any time by written agreement between the parties.
V. This agreement shall be effective as of the last date signed below.
I STATE OF NEW HAMPSHIRE NHY EMERGENCY RESPONSE ORGANIZATION I By k . [l h Director,~ Office of Emergency By hi a Vice Pr(sident i Mclear Hanagement Production I 3/2s/Dateee
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Date NH OFFSITE RESPONSE ORGANIZATION By uau By & c/ /
Director, Public Healtfi Services ecutive Director, /
ergency Preparedness and Community Relations g
~a nw Date
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I ATTACHMENT S I (Letter t Agreement Between New Hampshire Yankee Division or Public Service Company of New Hampshire and the States of New Hampshire and Massachusetts)
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Attachment S (Page 1 of 3)
IIITER OF AGREEMDTP BETWEEN
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.i NEW HAMPSHIRE YANKEE DIVISION OF PUBLIC GERVICE CDMPANY OF NEW HAMPSHIR_E_
AND THE STATES OF NEW HAMPSHIPI AND MASSACHUSETTS I. PURPOSE:
The purpose of this latter of Agreement is to establish conditions regarding radiological mergency planning, notification and response should an event at Seabrook Station require Radiological Emergency Plan activation.
II. DEFINITIONS:
A. Emeraency Operations Facility (EOF) - A center established at Newington Station, Newington, N. H. to coordinate the deployment of New Hampshire Yankee mergmey personnel, to evaluate off-site acci-dent conditions and to maintain conrnunications with off-site authorities.
B. EOF Coordinator - The EDF Coordinator is an mployee of New Hampshire Yankee who coordinates manitoring activities and protective action recommendations with State representatives. He conducts these func-tions within the EOF.
C. Media Center - A ceter dedicated to the news media for the purpose of conducting joint State, Federal, and New Hampshire Yankee briefings concerning mergency conditions. The Media Center location is the Town Hall in Newington, N. H.
D. Nuclear Alert System - A cosmication syste for initial notifica-tion to the State of an emergency at Seabrook Station; and the means of communication between the States and New Hampshire Yankee for ,
exchange of information during the period of the mergency.
l E. Response Manager - An mployee of New Hampshire Yankee who manages the New Hampshire Yankee emergency response organization, provides protective action recommendation 8 to State officials and establishes a recovery organization. ;
F. Site Emergency Director - An mployee of New HanpshLe fankee who has the responsibility for the conduct of emergency operations at the station.
D%46.1
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Attachment S (Page 2 of 3)
I. III. AGREEMBT:
{ The States and New Hampshire Yankee agree to the following:
A. New Hampshire Yankee shall notify the two State Police Agencies promptly after an event has been classified as either an Unusual I Event, Alert, Site Area or General Emergency. W e notification shall be made by New Hampshire Yankee using the Nuclear Alert System.
Comnercial telephone connunications will be used as the backup means of notification. 1 B. We initial message to contact the States shall be as specified in New Hampshire Yankee and States' Dnergency Plans and Procedures.
!I Additional information shall be provided to the States' represen-tatives returning the call to the station. This infomation is spe-cified in the follow-up notification contained in the procedures of the States and New Hampshire Yankee.
C. New Hampshire Yankee and the States shall exchange and coordinate radiological ernergency plan changes that pertain to those elements of I interface prior to implementing the change. New Hampshire Yankee and States shall coordinate the effective date of these changes.
I D. New Hampshire Yankee shall provide space for representatives from each State at the EOF and the Media Center. h e States agree to maintain with New Hampshire Yankee a current list of persons with authority to respond who will be allowed access to the EOF and Media Center. New I Hampshire Yankee will provide space at the EOF for the operation of the New Hampshire Incident Field Office.
I F. . New Hampshire Yankee and the States agree to exchange all infomation (radiological releases, off-site radiological conditions and on-site technical data) known and available to pemic a rapid and accurate evaluation of the emergency.
F. We EDF Coordinator will be the person to be contacted by the States' representatives upon activation of the EOF.
G. Infomation shall be released to the public in a timely, coordinated malner through the Media Center, if activated, or by coordination bet-ween the EOF and States. All news releases to be made by New Hampenire Yankee shall be approved- by the Response Manager.
H. New Hampshire Yankee and the States agree to exchange public infor-macion material for review prior'to distributing the material to the I public. .
I. We State Health Departments agree to the method established by New Hampshire Yankee to project off-site whole body dose rates.
J. he State Civil Defense Agencies and Health Departments have reviewed and agree to the procedure established by New Hampshire Yankee to classify emergency conditions, which includes the Rnergency Action Levels.
DM446.2
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11 Attachment S (Page 3 of 3) f' .. '., the ewne .*f i radi st ci:al merzen :v, *:.r. 4.rp45;r.- Y d e e
-Hrouzh Yantw ' omt.:. o mke the Y inkee E .. .r.3n .e c.4'. :as" . -
located in Westm:s, "4u achusette, available en this sc it. < : r sarple a.alvs u.
t.. An incident shall be deemed to have ter9inated hen tie States i .3
- ew Ha.
m pshire Yankee jointiv aaree that there is no !:nter 2 .ect i r either ti) consideration of further protective actions er (sti :r.
veill,nce related to off-site protective actions. Claso out .:f e emergency classification shall be outlined in respective rao!>l.c _ ,
M. The State of New Ha.:pshire agrees to promptly notify the St.;te .
Maine (ingestion pathway zone) and coordinate off-site ra:itoi:.ti:.J.
consequences with authorities in that State during ar. event w-tea 12 classified as either a Site Area or General Faergency at Seabron'-
Station.
N. The State of New Ha.:pshire and Camionwealth of td. massachusetts agree t-notify the United States Coast Guard, as specified in the notifica-f tion procedures of the states.
O. This agreenent may be amended at any time by written agreenent bet-ween the States and New Hampshire Yankee.
P. This agreecent shall be ef fective as of the last date signed beltu:
STATE OF NEW HAMPSHIRE CytOWEALTH OF MASSACHUSC 4 BY h BY WIL DEFD15E DLRECOR CIVIL CEETNSE DIR9"iOR l3 m/W S4,.
DATE8 IRTE BYDIRECOR,d " ' PUBLIC 7 W HEAllW "" -l.% BY DIRECIDR, RADIAILON ONDOL
. SERVICS PROGRAM 13 m M N.
DATE DATE NEW HAMPSHIRE YANKEE RY dwdbY VIC PRESIDert,, NUCLEAR PRODUCION
\ $bf 4, /for,,
l DATE
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