|
---|
Category:EXHIBITS (DOCKETING AND SERVICES BRANCH INFORMATION
MONTHYEARML20008D4651989-06-27027 June 1989 Intervenor Exhibit I-SALP-A,consisting of 890626 Surrebuttal Testimony of Ba Burrows on Issues Re MS-1 Hosps, Recreation/Decontamination Ctrs & FEMA MS-1 Guidance. Ba Burrows Curriculum Vitae Encl ML20008D4921989-06-27027 June 1989 Intervenor Exhibit I-MAG-125,consisting of 871009 Document Entitled, Traffic Mgt & Control. ML20008D4931989-06-27027 June 1989 Intervenor Exhibit I-MAG-126,consisting of Excerpt of Deposition of G Howard.Related Info,Including Rev 0 to Amend 6 to Spmc Implementing Procedure IP 2.13, Public Alert & Notification Sys Including Emergency..., Encl ML20008D4621989-06-26026 June 1989 Applicant Exhibit A-92A,consisting of Applicant 881212 Rev to Request for Admissions from Commonwealth of Ma Atty General.Verified Complaint Form from Commonwealth of Ma, Interlocutory Order & Certificate of Svc Encl ML20008D4641989-06-26026 June 1989 Applicant Exhibit A-92B,consisting of Commonwealth of Ma Atty General 881216 Answer to Applicant Revised Request for Admissions from Commonwealth of Ma Atty General & Certificate of Svc ML20008D4911989-06-20020 June 1989 Rejected Intervenor Exhibit I-MAG-124,consisting of DOT, Federal Highway Admin 1988 Document, Guide for Emergency Highway Traffic Regulation. ML20008D4601989-06-19019 June 1989 Applicant Exhibit A-90,consisting of Fema,Natl Emergency Training Ctr,Emergency Mgt Inst Class Schedule for Integrated Emergency Mgt Course on 841126-29 ML20008D4611989-06-19019 June 1989 Applicant Exhibit A-91,consisting of Seabrook Training Group Document Entitled, Emergency Planning Mass E-Plan EM4002I Table Top Exercise 2,Instructor Guide, w/889023 Preparation & Training Supervisor Review Date ML20008D4591989-06-19019 June 1989 Applicant Exhibit A-89,consisting of FEMA May 1984 Instructor Guide 51, Formulating Public Policy in Emergency Mgt. ML20008D4561989-06-16016 June 1989 Applicant Exhibit A-86,consisting of Excerpt of 751219 Document Entitled, Application of Computer-Aided Dispatch in Law Enforcement-Introductory Planning Guide, Prepared for DOJ ML20008D4581989-06-16016 June 1989 Applicant Exhibit A-88,consisting of Excerpt of Document from Unidentified Author Re Channel Loading Stds in General ML20008D4571989-06-16016 June 1989 Applicant Exhibit A-87,consisting of 47CFR90.313-90.315, Chapter 1 ML20008D5031989-06-15015 June 1989 Intervenor Exhibit I-MAG-123,consisting of Photograph Submitted by Commonwealth of Ma Atty General Re Seabrook ML20008D5001989-06-15015 June 1989 Intervenor Exhibit I-MAG-122G,consisting of Photograph Submitted by Commonwealth of Ma Atty General Re Seabrook ML20008D4991989-06-15015 June 1989 Intervenor Exhibit I-MAG-122F,consisting of Photograph Submitted by Commonwealth of Ma Atty General Re Seabrook ML20008D4951989-06-15015 June 1989 Intervenor Exhibit I-MAG-122B,consisting of Photograph Submitted by Commonwealth of Ma Atty General Re Plant ML20008D5011989-06-15015 June 1989 Intervenor Exhibit I-MAG-122H,consisting of Photograph Submitted by Commonwealth of Ma Atty General Re Seabrook ML20008D4901989-06-15015 June 1989 Intervenor Exhibit I-MAG-121,consisting of 881206 Record of Telcons to Commonwealth of Ma EPZ Town Clerks of Amesbury, Merrimac,Newbury,Newburyport,Salisbury & West Newbury for Most Recent Population Data ML20008D4891989-06-15015 June 1989 Intervenor Exhibit I-MAG-120,consisting of Excerpt of INPO May 1988 Guideline INPO 88-010, Guidelines for Radiological Protection at Nuclear Power Stations. Note Exempting Document from Us Copyright Act Encl ML20008D4881989-06-15015 June 1989 Intervenor Exhibit I-MAG-119,consisting of Attachment 2 Entitled, Calculation of Anticipated Evacuee Loads. ML20008D4941989-06-15015 June 1989 Intervenor Exhibit I-MAG-122A,consisting of Photograph Submitted by Commonwealth of Ma Atty General Re Plant. K Cater 900118 Memo to Files Indicating That Photographs Placed on Docket on 900118 Encl ML20008D4961989-06-15015 June 1989 Intervenor Exhibit I-MAG-122C,consisting of Photograph Submitted by Commonwealth of Ma Atty General Re Seabrook ML20008D5021989-06-15015 June 1989 Intervenor Exhibit I-MAG-122I,consisting of Photograph Submitted by Commonwealth of Ma Atty General Re Seabrook ML20008D4981989-06-15015 June 1989 Intervenor Exhibit I-MAG-122E,consisting of Photograph Submitted by Commonwealth of Ma Atty General Re Seabrook ML20008D4971989-06-15015 June 1989 Intervenor Exhibit I-MAG-122D,consisting of Photograph Submitted by Commonwealth of Ma Atty General Re Seabrook ML20008D4871989-06-15015 June 1989 Intervenor Exhibit I-MAG-118,consisting of New Hampshire Yankee Div 880626 Memo Forwarding Results of Study to Determine Response Characteristics of Aptec 126BH Probe at Very Low Temps ML20008D4861989-06-15015 June 1989 Rejected Intervenor Exhibit I-MAG-117,consisting of Form 9.1, Emergency Drill/Exercise Controller/Evaluator Audit Form, for 1988 FEMA-graded Exercise W/B Musico,Observer ML20008D4811989-06-13013 June 1989 Intervenor Exhibit I-MAG-112,consisting of Rev 8 to Emergency Procedure Er 5.4, Protective Action Recommendations. ML20008D4851989-06-13013 June 1989 Intervenor Exhibit I-MAG-116,consisting of Commonwealth of Ma Offsite Response Organization 880628 News Release of General Emergency Message Re Evacuation & Sheltering,Seasonal Closure of Beaches & Wildlife Refuge ML20008D4841989-06-12012 June 1989 Intervenor Exhibit I-MAG-115,consisting of 890410 Testimony of Sf Mitchell on Behalf of Atty General,Jm Shannon,Town of Hampton (Toh) & Necnp Re Toh/Necnp Ex 2 ML20008D4821989-06-0808 June 1989 Intervenor Exhibit I-MAG-113,consisting of Util 880809 Ltr Responding to NRC 880722 Request for Clarification Re Three Emergency Response Plans for Plant Recommending Precautionary Protective Actions for Beach Population ML20008D4791989-06-0707 June 1989 Rejected Intervenor Exhibit I-MAG-110,consisting of 890403 Testimony on Behalf of Atty General Jm Shannon Re Joint Intervenor Contentions JI-2 & JI-21 ML20008D4801989-06-0707 June 1989 Rejected Intervenor Exhibit I-MAG-111,consisting of 890410 Testimony of Cj High on Behalf of Jm Shannon,Atty General for Commonwealth of Ma,Concerning Contention JI-56 Re Monitoring Rate ML20008D4781989-06-0101 June 1989 Intervenor Exhibit I-MAG-109,consisting of Commonwealth of Ma Atty General 881219 Answers to NRC Third Set of Interrogatories & Requests for Production of Documents ML20008D4551989-05-31031 May 1989 Applicant Exhibit A-85,consisting of Seabrook Training Group Document Entitled, Emergency Planning Training Program Mass E-Plan Emergency Mgt Lesson EM1002C Instructor Guide, W/ Approval & Review Dates of 890117 ML20246H3911989-05-31031 May 1989 Applicant Exhibit A-59,consisting of Nuclear Advisory Team Handbook,Revised Oct 1987 ML20246H2001989-05-31031 May 1989 Applicant Exhibit A-56,consisting of Offsite Emergency Training for Pilgrim Nuclear Power Station,Module 26,Lesson Plan 26-1S, Overview of Implementing Procedure ML20246H3711989-05-31031 May 1989 Applicant Exhibit A-58,consisting of Commonwealth of Ma Bay Transportation Authority Resource Development Plan, Dtd Oct 1984 ML20246H1181989-05-31031 May 1989 Applicant Exhibit A-55,consisting of App 3 to Hazard Specific Suppl 6 to Radiological Emergency Response Plan ML20246H1821989-05-31031 May 1989 Applicant Exhibit A-55A,consisting of Commonwealth of Ma Comprehensive Emergency Response Plan,App 3,Section C-3 ML20008D4521989-05-31031 May 1989 Applicant Exhibit A-84,consisting of Public Svc Co of New Hampshire 890221 Ltr to Bidders Inviting Submission of Proposal for Furnishing of 35 Evacuation Bed Buses in Accordance W/Encl Spec ML20008D4661989-05-31031 May 1989 Applicant Exhibit A-60,consisting of Jul 1987 Document Entitled, Commonwealth of Ma Ingestion Exposure Pathway Plan. W/Copyright Matl ML20246H3281989-05-31031 May 1989 Applicant Exhibit A-57,consisting of Comprehensive Emergency Response Plan ML20008D4771989-05-31031 May 1989 Rejected Intervenor Exhibit I-MAG-108,consisting of Attachment a Document Entitled, State of Nh Radiological Health Program,Module 23A Hosp Mgt of Contaminated & Injured Patients,Seabrook Station, Dtd Feb 1988 ML20008D4761989-05-30030 May 1989 Intervenor Exhibit I-MAG-107,consisting of Table Entitled Section 1,Bus Providers. ML20008D4751989-05-26026 May 1989 Intervenor Exhibit I-MAG-106,consisting of FEMA 890221 Responses to Town of Hampton First Set of Interrogatories & Request for Production of Documents to FEMA on 880628-29 Exercise ML20008D4701989-05-25025 May 1989 Intervenor Exhibit I-MAG-102,consisting of New Hampshire Yankee Div 880412 Ltr Forwarding Meeting Notes from 880401 Meeting at Plant W/Nrc,Fema & States of Nh & Me & Informing of Meeting on 880420 to Obtain Scenario Review Comments ML20008D4711989-05-25025 May 1989 Intervenor Exhibit I-MAG-103,consisting of New Hampshire Yankee Div (Nhy) 880506 Ltr Forwarding Meeting Notes from 880420 FEMA-graded Exercise Scenario Review Meeting Between Fema,Nhy,States of Nh & Me & Other Organizations ML20008D4721989-05-25025 May 1989 Intervenor Exhibit I-MAG-104,consisting of Applicant 890109 Voluntary Responses to Town of Hampton 881223 First Set of Interrogatories & Request for Production of Documents Re 880628-29 Exercise.Ropes & Gray 880320 Ltr Encl ML20008D4741989-05-25025 May 1989 Intervenor Exhibit I-MAG-105,consisting of State of Nh 890130 Voluntary Responses to Town of Hampton Informal Discovery Requests Concerning June 1988 Joint Exercise.State 890316 Ltr to Commonwealth of Ma Re Exercise Encl 1989-06-08
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217H9511999-10-21021 October 1999 Memorandum & Order.* Proceeding Re Nepco 990315 Application Seeking Commission Approval of Indirect License Transfers Consolidated,Petitioners Granted Standing & Two Issues Admitted.With Certificate of Svc.Served on 991021 ML20217N2561999-10-21021 October 1999 Transcript of Affirmation Session on 990121 in Rockville, Maryland Re Memorandum & Order Responding to Petitions to Intervene Filed by co-owners of Seabrook Station Unit 1 & Millstone Station Unit Three.Pp 1-3 ML20211L5141999-09-0202 September 1999 Comment on Draft Reg Guide DG-4006, Demonstrating Compliance with Radiological Criteria for License Termination. Author Requests Info as to When Seabrook Station Will Be Shut Down ML20211J1451999-08-24024 August 1999 Comment Opposing NRC Consideration of Waiving Enforcement Action Against Plants That Operate Outside Terms of Licenses Due to Y2K Problems ML20210S5641999-08-13013 August 1999 Motion of Connecticut Light & Power Co,Western Massachusetts Electric Co & North Atlantic Energy Corp to Strike Unauthorized Response of Nepco.* Unauthorized Response Fails to Comply with Commission Policy.With Certificate of Svc ML20210Q7531999-08-11011 August 1999 Order Approving Application Re Corporate Merger (Canal Electric Co). Canal Shall Provide Director of NRR Copy of Any Application,At Time Filed to Transfer Grants of Security Interests or Liens from Canal to Proposed Parent ML20210P6271999-08-10010 August 1999 Response of New England Power Company.* Nu Allegations Unsupported by Any Facts & No Genuine Issues of Matl Facts in Dispute.Commission Should Approve Application Without Hearing ML20210H8311999-08-0303 August 1999 Reply of Connecticut Light & Power Co,Western Massachusetts Electric Co & North Atlantic Energy Corp to Response of New England Power Co to Requests for Hearing.* Petitioners Request Hearing on Stated Issues.With Certificate of Svc ML20210J8501999-08-0303 August 1999 Order Approving Transfer of License & Conforming Amend.North Atlantic Energy Service Corp Authorized to Act as Agent for Joint Owners of Seabrook Unit 1 ML20211J1551999-07-30030 July 1999 Comment Opposing That NRC Allow Seabrook NPP to Operate Outside of Technical Specifications Due to Possible Y2K Problems ML20210E3011999-07-27027 July 1999 Response of New England Power Co to Requests for Hearing. Intervenors Have Presented No Justification for Oral Hearing in This Proceeding.Commission Should Reject Intervenors Request for Oral Hearing & Approve Application ML20209H9101999-07-20020 July 1999 Motion of Connecticut Light & Power Co & North Atlantic Energy Corp for Leave to Intervene & Petition for Hearing.* with Certificate of Svc & Notice of Appearance ML20195H1911999-06-15015 June 1999 Application of Montaup Electric Co & New England Power Co for Transfer of Licenses & Ownership Interests.Requests That Commission Consent to Two Indirect Transfers of Control & Direct Transfer ML20206A1611999-04-26026 April 1999 Memorandum & Order.* Informs That Montaup,Little Bay Power Corp & Nepco Settled Differences Re Transfer of Ownership of Seabrook Unit 1.Intervention Petition Withdrawn & Proceeding Terminated.With Certificate of Svc.Served on 990426 ML20205M7621999-04-15015 April 1999 Notice of Withdrawal of Intervention of New England Power Co.* New England Power Co Requests That Intervention in Proceeding Be Withdrawn & Hearing & Related Procedures Be Terminated.With Certificate of Svc CLI-99-06, Order.* Joint Request for ten-day Extension of Schedule Set Forth in CLI-99-06 in Order to Facilitate Parties Settlement Efforts Granted,With Exception of Date of Hearing. with Certificate of Svc.Served on 9904071999-04-0707 April 1999 Order.* Joint Request for ten-day Extension of Schedule Set Forth in CLI-99-06 in Order to Facilitate Parties Settlement Efforts Granted,With Exception of Date of Hearing. with Certificate of Svc.Served on 990407 ML20205G0921999-04-0505 April 1999 Joint Motion of All Active Participants for 10 Day Extension to Permit Continuation of Settlement Discussion.* Participants Request That Procedural Schedule Be Extended by 10 Days.With Certificate of Svc ML20205G3091999-03-31031 March 1999 Petition That Individuals Responsible for Discrimination Against Contract Electrician at Plant as Noted in OI Rept 1-98-005 Be Banned by NRC from Participation in Licensed Activities for at Least 5 Yrs ML20204E6401999-03-24024 March 1999 Protective Order.* Issues Protective Order to Govern Use of All Proprietary Data Contained in License Transfer Application or in Participants Written Submission & Oral Testimony.With Certificate of Svc.Served on 990324 ML20204G7671999-03-23023 March 1999 Comment Supporting Proposed Rule 10CFR50.54(a) Re Direct Final Rule,Changes to QA Programs ML20207K1941999-03-12012 March 1999 North Atlantic Energy Svc Corp Participation in Proceeding.* Naesco Wished to Remain on Svc List for All Filings.Option to Submit post-hearing Amicus Curiae Brief Will Be Retained by Naesco.With Certificate of Svc ML20207H4921999-02-12012 February 1999 Comment on Draft Contingency Plan for Year 2000 Issue in Nuclear Industry.Util Agrees to Approach Proposed by NEI ML20203F9471999-02-0909 February 1999 License Transfer Application Requesting NRC Consent to Indirect Transfer of Control of Interest in Operating License NPF-86 ML20199F7641999-01-21021 January 1999 Answer of Montaup Electric Co to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests Motion Be Denied on Basis of Late Filing.With Certificate of Svc ML20199H0451999-01-21021 January 1999 Answer of Little Bay Power Corp to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests That Ui Petition to Intervene & for Hearing Be Denied for Reasons Stated.With Certificate of Svc ML20199D2461999-01-19019 January 1999 Supplemental Affidavit of Js Robinson.* Affidavit of Js Robinson Providing Info Re Financial Results of Baycorp Holding Ltd & Baycorp Subsidiary,Great Bay Power Corp. with Certificate of Svc ML20199D2311999-01-19019 January 1999 Response of New England Power Co to Answers of Montaup Electric Co & Little Bay Power Corp.* Nep Requests That Nep Be Afforded Opportunity to File Appropriate Rule Challenge with Commission Pursuant to 10CFR2.1329 ML20206R1041999-01-13013 January 1999 Answer of Little Bay Power Corp to Motion of New England Power Co for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* with Certificate of Svc ML20206Q8451999-01-12012 January 1999 Written Comments of Massachusetts Municipal Wholesale Electric Co.* Requests That Commission Consider Potential Financial Risk to Other Joint Owners Associated with License Transfer.With Certificate of Svc.Served on 990114 ML20199A4741999-01-12012 January 1999 Answer of Montaup Electric Co to Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Nepco 990104 Motion Should Be Denied for Reasons Stated.With Certificate of Svc ML20206Q0151999-01-12012 January 1999 North Atlantic Energy Svc Corp Answer to Petition to Intervene of New England Power Co.* If Commission Deems It Appropriate to Explore Issues Further in Subpart M Hearing Context,Naesco Will Participate.With Certificate of Svc ML20199A4331999-01-11011 January 1999 Motion of United Illuminating Co for Leave to Intervene & Petition to Allow Intervention out-of-time.* Company Requests That Petition to Allow Intervention out-of-time Be Granted.With Certificate of Svc ML20198P7181998-12-31031 December 1998 Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Moves to Intervene in Transfer of Montaup Seabrook Ownership Interest & Petitions for Summary Relief or for Hearing ML20198P7551998-12-30030 December 1998 Affidavit of J Robinson.* Affidavit of J Robinson Describing Events to Date in New England Re Premature Retirement of Npps,Current Plans to Construct New Generation in Region & Impact on Seabrook Unit 1 Operation.With Certificate of Svc ML20195K4061998-11-24024 November 1998 Memorandum & Order.* North Atlantic Energy Services Corp Granted Motion to Withdraw Proposed Amends & Dismiss Related Adjudicatory Proceedings as Moot.Board Decision LBP-98-23 Vacated.With Certificate of Svc.Served on 981124 ML20155J1071998-11-0909 November 1998 NRC Staff Answer to North Atlantic Energy Svc Corp Motion for Leave to File Reply.* Staff Does Not Object to North Atlantic Energy Svc Corp Motion.With Certificate of Svc ML20155D0041998-10-30030 October 1998 Motion for Leave to File Reply.* Licensee Requests Leave to Reply to Petitioner 981026 Response to Licensee 981015 Motion to Terminate Proceedings.Reply Necessary to Assure That Commission Is Fully Aware of Licensee Position ML20155D0121998-10-30030 October 1998 Reply to Petitioner Response to Motion to Terminate Proceedings.* Licensee Views Segmentation Issue as Moot & Requests Termination of Subj Proceedings.With Certificate of Svc ML20155B1641998-10-26026 October 1998 Response to Motion by Naesco to Withdraw Applications & to Terminate Proceedings.* If Commission Undertakes to Promptly Proceed on Issue on Generic Basis,Sapl & Necnp Will Have No Objection to Naesco Motion.With Certificate of Svc ML20154K8751998-10-15015 October 1998 Motion to Withdraw Applications & to Terminate Proceedings.* NRC Does Not Intend to Oppose Motion.With Certificate of Svc ML17265A8071998-10-0606 October 1998 Comment on Integrated Review of Assessment Process for Commercial Npps.Util Endorses Comments Being Provided by NEI on Behalf of Nuclear Industry ML20154C8171998-10-0606 October 1998 Notice of Appointment of Adjudicatory Employee.* Notice Given That W Reckley Appointed as Commission Adjudicatory Employee to Advise Commission on Issues Related to Review of LBP-98-23.With Certificate of Svc.Served on 981006 CLI-98-18, Order.* Grants Joint Motion Filed by Naesco,Sapl & Necnp for Two Week Deferral of Briefing Schedule Set by Commission in CLI-98-18.With Certificate of Svc.Served on 9810061998-10-0505 October 1998 Order.* Grants Joint Motion Filed by Naesco,Sapl & Necnp for Two Week Deferral of Briefing Schedule Set by Commission in CLI-98-18.With Certificate of Svc.Served on 981006 ML20153H4471998-10-0101 October 1998 Joint Motion of Schedule Deferral.* Naesco,Sapl & Necnp Jointly Request Temporary Deferral of Briefing Schedule as Established by Commission Order of 980917 (CLI-98-18). with Certificate of Svc ML20154F9891998-09-29029 September 1998 License Transfer Application Requesting Consent for Transfer of Montaup Electric Co Interest in Operating License NPF-86 for Seabrook Station,Unit 1,to Little Bay Power Corp ML20154D7381998-09-21021 September 1998 Affidavit of FW Getman Requesting Exhibit 1 to License Transfer Application Be Withheld from Public Disclosure,Per 10CFR2.790 ML20153C7791998-09-18018 September 1998 Comment Supporting Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Util Endorses NRC Staff Focus on Operability & Funtionality of Equipment & NEI Comments ML20151Z5611998-09-18018 September 1998 Order.* Pursuant to Commission Order CLI-98-18 Re Seabrook Unit 1 Proceeding,Schedule Described in Board 980904 Memorandum & Order Hereby Revoked Pending Further Action. with Certificate of Svc.Served on 980918 ML20151Y0331998-09-17017 September 1998 Order.* All Parties,Including Util,May File Brief No Later than 981007.Brief Shall Not Exceed 30 Pages.Commission May Schedule Oral Argument to Discuss Issues,After Receiving Responses.With Certificate of Svc.Served on 980917 ML20153E8771998-09-16016 September 1998 Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide (Ki) as Protective Action During Severe Reactor Accidents. Recommends That NRC Reverse Decision to Revise Emergency Planning Regulation as Listed 1999-09-02
[Table view] |
Text
. _. - -
^ '
l , l '
, gf% /df, >
, L
- t go -4yi/A'y-db i DOCKETED . d[f/ .
![
USNHC UNITED' STATES OF AMERICA m
NUCLEAR REGULATORY .COMMISsApw 18 P4 :34 ATOMIC SAFETY AND. LICENSING BOARD. '
OFrlCE OF SECRETARY Before'theAdministrativeJbM,flgIC ,
Ivan W. Smith, Chairman Gustave A. Linenberger, Jr. i Dr. Jerry Harbour ~
-i
)-
In'the Matter of ) Docket Nos. 50-443-OL
) 50-44.4-OL PUBLIC SERVICE COMPANY ) (Off-Site EP)
OF NEW HAMPSHIRE, EI AL. )
)
(Seabrook Station, Units 1 and 2) ) December 19, 1988' <
)
MASSACHUSETTS ATTORNEY GENERAL'S ANSWERS I TO NRC STAFF'S THIRD SET OF INTERROGATORIES AND_SEOUESTS FOR PRODUCTION OF DOCUMENTS INIEREQQATORY.1: Define the' term "ad hoc" as it is used in any ;
of your contentions concerning the Seabrook Plan for Massachusetts !
Communities (SPMC).
RESPONSE: "Ad hoc" means "for this particular purpose only."-
.In the context of the subject contentions, an "ad hoc" response or -l action means one that is not adequately and completely addressed by
.one.or more existing plans.
(7 INTERROGATORY 2: Identify and list all actions to protect
/. .the public in the event of a radiological. emergency at Seabrook Station which -
(a) you would take.
(b) you might take. '
(c) you could take.
9003050181 890601 PDR 0 ADDCK 05000443 PDR '
, O lb {b W
' ~
ge: .
i l '
OBJECTION:' The Mass AG objects to interrogatory 2 on the l grounds =that it is-not sufficiently concrete.
The phrase "a radiological emergency at Seabrook Station" is not precise: enough.- !
t Depending,on the nature and severity of such an emergency, the
-Commonwealth would, might or could take'any number of actions.
Further, the Mass AG objects to detailing what the Commonwealth ~
"might" or "could" do on the grounds that this involves aaly ':
speculatiun.
s t a t e Eplism : Because no. current plan exists for a ~
. radiological' emergency at Seabrook, State' police officials would look toward the RERP, App. 3, Section C-3 of Area I MCDA Operations:
. plan for Seabrook Station (dated April 1986)'for guidance.- That.
plan directs the' State Police to coordinate theLimplementation of traffic and access control, coordinate law enforcement services with-local communities, maintain communication with Troop A "
Headquarters-and the Topsfield Barracks, and assist the Area I Transportation Coordinator dispatch vehicles from the Topsfield Fair Grounds staging area. The aforementioned plan has been-produced to the Staff.
!~
Because this plan has not been updated, tested or exercised, the State' Police would not be able to. totally rely on it. For example, the Topsfield Barracks no longer exist. During an emergency, the State Police would have to assess.the development of l
1 the emergency response and alter or disregard the aforementioned i o r-plan where it would impede effective response. A serious problem exists in the simple fact that the plan itself is not readily l
1
s -
i 7,,
+
available to most of those in the state police command strueb.ure.
and it is'not available1st all.to any of the troopers in their vehicles. .
.Qgpartment of Public Works:
The DPW would refer to Offsite Emergency Preparedness Training for Pilgrim Nuclear Power Stati6n,. -i Overview of Implementing Procedures (" PIP"). This was produced t'o. !
a the Staff. PIP is site specific to Pilgrim. It instructs DPW
^
officials to notify and update Maintenance Engine'er: provide liaison; relay state request for assistance; remove road impediments; provide vehicles as requested; clear evacuation' routes of any equipment; clear ~ evacuation routes of any snow and ice; supervise delivery of equipment; inventory and' dispatch' equipment; deliver equipment; issue dosimetry;-track dose of DPW staff. The DPW would endeavor to apply PIP to the situation at hand and, where feasible, would attempt as best it could to apply the resources it' has av,ailable at the time to perform as many of the'above listed functions as it can.
National Guald: Because.no Memoranda of' Understanding with respect to an emergency response at Seabrook have been entered into, the Guard would not rely on any specific plan in! responding to such a radiological emergency. After being alerted of'the- <
L emergency by the MCDA and/or the Department of Public Safety, au 1 project officer would consult.with the assigned MCDA and/or.
Department of Public Safety Official and would, after consultation L and. pursuant to established procedures, mobilize the Guard in order l- to provide the manpower, resources, and equipment necessary, as indicated by the circumstances. Plans setting forth the actions to l
L. ,
u
- - . ~ - .
P 3
a
-i. .1 be t'aken when mobilizing the Guard are Domestic Emergency Standing-1 Operating Procedures (" Mass NG DESOp") an1 the.OpLAN-2
(" Mohawk")
(presently in draft form).
Both plans have'been_ produced to the Staff. .
.MBTA: The MBTA would pull buses from scheduled routes and -
attempt'to deploy additional personnel .nat would be required.to assist in evacuation of the EPZ. The MBTA would rely on and attempt to implement the 1984 deployment plan if MCDA recommended to do-so.
The MBTA would, in any case, attempt to deploy the number of buses needed for each evacuating community, as indicated by the MCDA.
The aforementioned plan was mailed to the Staff with-
.these Answers, under separate cover.
i
-QeDartment of Public Health: Because there are presently no- 4 specific emergency plans for responding to a Seabrook emergency, e DPH NIAT members would respond to an emergency by relying on previous training.and experience in_ handling emergencies at other nuclear power plants. NIAT member actions would correspond to those set out in the NIAT handbook which was-produced to the
' Staff.
The NIAT handbook would be relied on as a basic guide for
- r this response. Actions to be taken pursuant to the NIAT handbook ,
are: confirmation of radiological emergency; notification to appropriate response individuals and agencies as identified in the 1 Comprehensive Emergency Response Plan ("CERP") (CERP has also been produced to the' Staff); evaluation of the hazard; comparison of hazard against protective action guides as detailed in CERp; recommendation of protective actions; performance of radiation surveys to confirm that ambient radiation levels are low enough to
-4 -
l n- . 2
hif l
,4s ,
permit re-entry of the general.public. .
MCDA: The MCDA would, upon authorization, utilize ad hoc l measures as determined by.the Director or his. designee. MCDA would J to look to the CERP for guidance. Where applicable and advisable, 1 MCDA would'use its best' efforts to take the following actions:
alert state officials, FEMA'and the American Red Cross; inform communities, agencies, Secretary of public Safety and the Governor;-
1 activate emergency response organization and facilities; notify and mobilize state support agencies; coordinate support as requested from local communities; coordinate the status of resources available from support agencies; dispatch representative to <
utility's EOC;' recommend protective actions; coordinate public notification; coordinate interstate response and maintain contact with civil defense agencies in other affected states; assist with media support; gather and analyze intelligence; coordinate .
provisions of state support ~to affected communities.
i.
The Director of MCDA, or his designee, after consultation with the Commissioner of Public Health, the Commissioner of DEQE, local ~'
officials and possibly a nuclear engineer, meteorologist-or other such private person as the situation warranted, would most likely- ;,
have responsiblity for making ad hoc judgments.as to protective actions to maximize dose reductions. These ad hoc judgments: would ~
be made in conjunction with one or more state and local officials, t
, r and, after consultation with the Secretary of Public Safety, or his designees, would result in a recommendation by the Secretary of Public. Safety to the Governor. However, because there is no s'ite 1
m, -._
.h 6
^
\S
?Nbl .
l- i specific plan for the Seabrook EPZ, upon authorization the MCDA would have to rely upon professional experience in extrapolating from other existing plans (like CERP) the appropriate and: specific-actions and course of action. Even with MCDA's expertise and familiarity with existing plans like CERP, the lack of planning' at.
the local and area level, as well as the inadequacy of-staff, >
facilities and communication infrastructure would impede .
ey,editioNhandorderlyresponse. Also, because of the unfamiliarity of respondents at those levels with the MCDA and=AD I hoc' response or with actions upon which the MCDA would base such a response, the MCDA would anticipate great difficulty in coordinating the necessary materials, personnel and resources.
Deoartment of Food and Aariculture: DFA would refer to ,
Exhibit 3, CERP, when acting in response to radiological energy'at seabrook. That document has been produced to the Staff. If required by MCDA,.DFA would make ad hoc judgments'when formulating advice to farmers.as to how to minimize the effects of the ..
emergency (i.e.:
confine cows, switch to sileage and stored dry feeds).
1 Governor's Office: If circumstances required a declaration of I a state of emergency, the Governor or his designee would issue such' i
- a. declaration in accordance with the Civil Defense Act. After f I consultation with the Secretary of Public Safety or his des.ignee as i to the ad hoc measures to be taken, the Governor would exercise 1 1
1 l
responsibility for the issuance of emergency public information, coordination (where applicable) with other states, and l l
l
~
1 1
O
[' .
il ,
(._
.\;
l authorization of protective actions. . The Governor or the Secretary of-Public Safety, on a recommendation by the Director of Civil E Defense, would. authorize assistance from appropriate State. agencies within their capability,-and would request federal agency support' allowable under existing Federal statutory authority, to render!'
assistance'to a stricken community.
FlJhatis2_and Wildli t e : DFW would, if circumstances dictated, distribute notices regarding contaminated fish and wildlife. There 4 would be no plan upon which such action would directly rely. . .l Executive Office of Public Safetv: The Secretary of Public Safety, or his' designee, would oversee and assist in the coordination of emergency assistance, looking to the CERP for'
-general guidance.
As set forth in the earlier answers.concerning MCDA, and the Governor's Office, the Secretary of Public Safety has ]
an active role in forming ad hoc judgments and recommendations to the Governor as well as in exercising authority over state j cesources, 9 f'
-QEQE: The DEQE is-not authorized to act as a primary l 1
respondent in a radiological emergency. i i
s INTranOCATORY 3:. j Identify and list all resources to take the actions identified in response to the prior Interrogatory (Interrogatory No. 2) you -
( (a) have.
) (b) may have.
Q1JECILQH: The Mass AG objects to interrogatory 3 to the extent that it seeks what resources the Commonwealth "may have."
It is unclear what "may have" adds to the inquiry concerning what