ML14167A079
| ML14167A079 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 06/12/2014 |
| From: | Lampert M - No Known Affiliation |
| To: | Nadiyah Morgan Division of Operating Reactor Licensing |
| References | |
| Download: ML14167A079 (22) | |
Text
NRR-PMDAPEm Resource From: Mary Lampert [mary.lampert@comcast.net]
Sent: Thursday, June 12, 2014 2:55 PM To: Morgan, Nadiyah Cc: Becky Chin
Subject:
June 12, 2014 SUPPLEMENT TO PILGRIM WATCH'S 2.206 PETITION RE KLD Attachments: 06 12 14 SUPPLEMENT KLD PETITION.pdf Attached please find the SUPPLEMENT TO PILGRIM WATCHS 2.206 PETITION TO MODIFY, SUSPEND, OR TAKE ANY OTHER ACTION TO THE OPERATING LICENSE OF PILGRIM STATION UNTIL THE NRC CAN ASSURE EMERGENCY PREPAREDNESS PLANS ARE IN PLACE TO PROVIDE REASONABLE ASSURANCE PUBLIC HEALTH & SAFETY ARE PROTECTED IN THE EVENT OF A RADIOLOGICAL EMERGENCY (June 12, 2014) requested by the PRB Chair, Allen Howe, during the June 12, 2014 Conference.
If you have any difficulty downloading the document, please call mary Lampert at 781-934-0389.
Also, please indicate receipt by return email.
Thank you and enjoy the rest of the day.
Mary 1
Hearing Identifier: NRR_PMDA Email Number: 1363 Mail Envelope Properties (001701cf866f$c1b8f690$452ae3b0$)
Subject:
June 12, 2014 SUPPLEMENT TO PILGRIM WATCH'S 2.206 PETITION RE KLD Sent Date: 6/12/2014 2:54:36 PM Received Date: 6/12/2014 2:55:34 PM From: Mary Lampert Created By: mary.lampert@comcast.net Recipients:
"Becky Chin" <rebeccajchin@hotmail.com>
Tracking Status: None "Morgan, Nadiyah" <Nadiyah.Morgan@nrc.gov>
Tracking Status: None Post Office: lampert@comcast.net Files Size Date & Time MESSAGE 632 6/12/2014 2:55:34 PM 06 12 14 SUPPLEMENT KLD PETITION.pdf 1322452 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
Recipients Received:
June 12, 2014 Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 By Mail & Email: NrcExecSec@nrc.gov SUPPLEMENT TO PILGRIM WATCHS 2.206 PETITION TO MODIFY, SUSPEND, OR TAKE ANY OTHER ACTION TO THE OPERATING LICENSE OF PILGRIM STATION UNTIL THE NRC CAN ASSURE EMERGENCY PREPAREDNESS PLANS ARE IN PLACE TO PROVIDE REASONABLE ASSURANCE PUBLIC HEALTH &
SAFETY ARE PROTECTED IN THE EVENT OF A RADIOLOGICAL EMERGENCY-During the PRB Conference Call with Pilgrim Watch and the Town of Duxbury Nuclear Advisory Committee, Allen Howe, PRB Chair, requested that the Petitioners submit additional documents in support of its petition to the Nuclear Regulatory Commission (NRC) to institute a proceeding to modify, suspend or take any other action1 as may be proper to the operating license of Pilgrim Station in order that the NRC can assure Pilgrims Radiological Emergency Plan and Standard Operating Procedures/Guidelines are based on accurate and credible Evacuation Time Estimates (ETEs).
Petitioners can provide affidavits, upon request, to authenticate the documents. The attached documents include:
x September 18, 2012, Letter from the Town of Duxbury Board of Selectmen and Town Manager to Kurt Swartz, MEMA Director, Don Boyce., FEMA Region 1 Administrator, Michael Slobodien, Entergy Director Entergy NE Emergency Preparedness. It reviews the KLD Pilgrim NPP ETE June 12, 2012 Draft report highlighting inaccurate 1
NRC Enforcement actions include: notices of violation, civil penalties, orders, notice of nonconformance, confirmatory action letters, letters of reprimand, and demand for action.
assumptions and that It is insufficient to provide reasonable assurance for the citizens of Duxbury. Petitioners showed that the Final ETE did not make substantive changes in response to the Town of Duxburys complaints. (Attachment 1) x July 30, 2012 email from Chief Kevin Nord, Emergency Management Director Town of Duxbury, to Ed Hartnett, Pilgrim Emergency Planning highlighting some problems with the ETE. (Attachment 2) x March 25, 2013 Email to Kevin Nord, Chief Town of Duxbury, and others from John Giarrusso (MEMA) that included a January 18, 2013 email from John Giarrusso to Tom White (Pilgrim EP) identifying significant issues in the current draft in the final ETE that MEMA would believe the study to be invalid. The final KLD draft was issued on December 23, 2012, therefore, John Giarussos statements pertains to the final draft - no resolution to the final document. (Attachment 3) x Email chain from March 4, 2014 to May 22, 2014 between Aaron Wallace, Emergency Management Director Town of Plymouth, and Rebecca Chin, Town of Duxbury Nuclear Advisory Committee regarding transients to the Town of Plymouth during holidays.
Plymouth EMD concluded that he, will always agree that the estimates used for transient/resident populations are lower than we actually see during our peak holiday event timelines. (Attachment 4) x Excerpts from the Town of Duxburys Harbormaster and School Standard Operating Procedures (SOP) demonstrating that: (1) The ETEs assumption that evacuation begins when the sirens sound (General Emergency Stage) is incorrect. Evacuations will begin as soon as the word gets out. The Harbormaster SOP, as an example, shows that the word of will get out to the general public beginning at the earlier Alert stage when the 2
Harbormaster and Beach team clear the waters and beach. The SOPs throughout the EPZ are essentially the same as Duxburys. (2) The ETEs assumption that parents will not pick up students at school is incorrect. The Duxbury School SOP provides for parent pickup impacting the number of vehicles evacuating. Imagine a household with both parents/guardians at home (not unusual with telecommuting) with children in different schools. Two, not one, vehicle would evacuate. (Attachment 5)
We look forward to the PRB accepting our petition so that Pilgrims ETE will be re-done using valid assumptions and accurate input data that is necessary to provide reasonable assurance.
Respectfully submitted, Mary Lampert Rebecca Chin Pilgrim Watch, Director Town of Duxbury, Nuclear Advisory 148 Washington Street Committee, Co-Chair Duxbury, MA 02332 31 Deerpath Trail North Tel 781-934-0389 Duxbury, MA 02332 Email: mary.lampert@comcast.net Tel. 781-837-0009 Email: rebeccajchin@hotmail.com 3
ATTACHMENT 1 4
5 6
7 8
9 10 ATTACHMENT 2 11
12 ATTACHMENT 3 Kevin M. Nord Chief of Department Town of Duxbury nord@town.duxbury.ma.us www.DuxburyFIRE.com
Original Message-----
From: Giarrusso, John (CDA) [1]
Sent: Mon 3/25/2013 8:52 AM To: Aaron Wallace (awallace@townhall.plymouth.ma.us); Bob Heath (kemakingston@comcast.net); DPH-OEMS-GRogers; Chief Kevin M. Nord; Paul Taber (ptaber@marshfieldpolice.org); Rick Ferreira (temadirector@tmlp.net); Robert James Work; DPH-OEMS-TWalsh Cc: Viveiros, John L (CDA)
Subject:
Pilgrim ETE Study Here is the email I sent to Pilgrim station concerning the current ETE.
John John Giarrusso, Jr.
Planning, Preparedness, & Nuclear Section Chief MEMA (W) 508-820-2040 (C) 603-817-0560 From: Giarrusso, John (CDA)
Sent: Friday, January 18, 2013 2:32 PM To: White, Thomas Cc: Packard, Christine (CDA); Viveiros, John L. (CDA); Mannion, James A. (CDA)
Subject:
Pilgrim ETE Study The Massachusetts Emergency Management Agency (MEMA) has completed its review of the draft 2012 Evacuation Time Estimate (ETE) Study for Pilgrim Nuclear Power Station. We have identified the following issues with the current draft:
- The draft ETE study does not include a review of the Traffic and Access Control Points (TACP), one of the most critical aspects of the ETE. There are 13
issues and incorrect information that need to be reviewed and corrected for Plymouth, Duxbury and Bourne. We are requesting that all TACPs be reviewed by KLD with the state and locals that are included in the ETE study.
- The ETE study was to include the three reception centers, but the draft ETE study does not currently contain any information for the reception centers.
We request that the reception centers be included in the ETE as originally intended. In addition, Bob James, Braintree's Emergency Management Director, conducted a detailed review of the traffic and access control points for the Braintree reception center, and produced a report detailing the corrections that needed to be completed in the 2012 ETE study. Although Mr. James provided a copy of his findings to Entergy, the information contained in it has not been incorporated into the draft ETE study.
- The regional groups listed in the draft ETE study decreased from 35 to
- 27. It is unclear why this number of groups has been reduced, or what impacts the reduction has on the draft ETE study.
- Table 8-2 lists the school populations and demand estimates for vans for the entire emergency planning zone (EPZ). As written in the draft ETE study, this information is incorrect and is missing some established daycare centers.
We request a thorough review of the information to identify errors and discrepancies, correction of identified errors and discrepancies, and revision of evacuation time estimates, if necessary.
- Table 8-5 lists the summary of transportation resources. Some of the information is incorrect - in particular, the names resources and the assets available by each resource. We request the table be thoroughly reviewed to identify errors and discrepancies, and information be corrected to address identified errors and discrepancies.
- Table 8-3 lists the host facilities. There are some inaccurate information pertaining to the schools and the host facilities. We request the table be thoroughly reviewed to identify errors and discrepancies, and information be corrected to address identified errors and discrepancies.
We view these identified issues as significant and in need of immediate correction. We realize that many issues were identified and raised at the September draft ETE study review meeting. However, neither MEMA nor the EPZ communities have been provided an updated version of the study for review, and therefore we do not know if these issues have been addressed.
As such, we are requesting a meeting with Entergy, KLD Associates and the EPZ communities to discuss the issues listed above as well as any additional issues the towns may not have yet been able to resolve.
If the issues articulated above and at the September meeting are not resolved before the finalization of the study, we believe the study to be invalid as it will lack the appropriate information to effectively calculate the evacuation time estimate.
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I know we all share the same goal - ensuring the health and safety of the people living and working within the EPZ . I appreciate your assistance in this matter.
Thanks John John Giarrusso, Jr.
Planning, Preparedness, & Nuclear Section Chief MEMA (W) 508-820-2040 (C) 603-817-0560 15
ATTACHMENT 4 From: Aaron Wallace [2]
Sent: Thursday, May 22, 2014 9:06 AM To: Rebecca Chin
Subject:
RE: July visitors to Plymouth Good morning, We received a general update on the planning and release of the Cape Cod Traffic (ETE) study and discussed the States timeline for release of the updated Cape Cod Traffic Plan. With regard to a USDOT/FHWA Regional Evacuation Plan, our USDOT representative did state that the Federal Highway Administration was currently in the process of filling a position to bring a senior engineer on to potentially begin work on this project. A lot of potentials, were still awaiting a project confirmation and timeline.
Again our hope to see USDOT engage with MassDOT and the NE regional EMAs & Highway Authorities to begin a planning scope for a region wide traffic evacuation plan similar to what is currently in use in the Gulf Coast and in the final stages within Metro-NYC & NJ.
MEMA is currently working on a regional evacuation plan however, the draft portion which we reviewed from the contractor was very basic and boilerplate and lacked considerable focus on the Cape, Islands, MA EPZs or coordination with border States. Were pushing for better planning and communication between our federal and state planning partners, it doesnt appear the focus on anything outside of Metro-Boston & I-495 is driving their coordination objectives.
Thank you, Aaron From: Rebecca Chin [3]
Sent: Wednesday, May 21, 2014 3:19 PM To: Aaron Wallace
Subject:
RE: July visitors to Plymouth Hi Aaron, I was wondering if you had any additional information from your meeting with the U.S.
Department of Transportation that you mentioned below. Any update would be appreciated.
Thank you, Becky From: Aaron Wallace [4]
Sent: Thursday, April 24, 2014 2:42 PM 16
To: Rebecca Chin
Subject:
RE: July visitors to Plymouth Good afternoon, The KLD numbers have been identified as being under a baseline than wed expect to receive from our regional planning commission. Weve provided KLD data with improved census data and transient numbers on multiple occasions. We neither approve or disapprove of their calculations because of the variances on time, population, and route conditions which vary by the minute/hour/day.
The NRC reviews the data to determine if the ETE sufficiently provides accurate estimates of vehicle and population timelines for emergency management planning under certain conditions modeled. Ground conditions will never meet the models baseline at all times, we have to factor for those variances realistically.
Tomorrow Im meeting with a representative from the U.S. Department of Transportation, I will address your population data figures and discuss alternatives for capturing better information for our local planning needs. I will always agree that the estimates used for transient/resident populations are lower than we actually see during our peak holiday event timelines.
Thank you, Aaron From: Rebecca Chin [5]
Sent: Thursday, April 24, 2014 2:21 PM To: Aaron Wallace
Subject:
RE: July visitors to Plymouth Hi Aaron, I did talk with Cheri Thomsen - she didnt have any data figures - I talked with someone at Plimoth Plantation who was not helpful or forthcoming with visitor information. Below is what information that I have and wondered if you might have better luck talking with the Plimoth Plantation people.
The Patriot Ledger issue just before Thanksgiving 2013 - 10,000 visitors to Plimoth Plantation on Thanksgiving and the Friday after, about what it gets in an average non-holiday week.
By my calculations: 10,000 divided by 7 = 1428 visitors per day.
KLD report: Special Facilities Data, Appendix E, Table E-5. Recreational Areas within the EPZ - page 244 17
Sub area 3 - 2.2 miles from Pilgrim: Plymouth Plantation = 1050 transients & 410 vehicles. Where did they come up with their numbers as KLD does not list a contact phone number for Plymouth Plantation in the report?
Supposedly, the KLD report does factor in additional visitors in Plymouth over the 4th of July. Where do their numbers come from?
Becky Chin, co-chair, Duxbury Nuclear Advisory Committee.
781-837-0009 From: Aaron Wallace [6]
Sent: Tuesday, March 04, 2014 11:14 AM To: Rebecca Chin Cc: Chief Kevin M. Nord
Subject:
RE: July visitors to Plymouth Good morning:
Those numbers are much higher, I will refer you to our Economic Development office which deals directly with local special events planning and permitting. Cheri Thomsen is our local lead and can provide you the numbers their committee works off of from Public Safety and Planning.
POC: Cheri Thomsen (508-747-1620) Ext. 144 Department Link:
http://www.plymouth-ma.gov/Public_Documents/PlymouthMA_Planning/Economic%20Development Thank you, Aaron From: Rebecca Chin [7]
Sent: Tuesday, March 04, 2014 10:52 AM To: Aaron Wallace
Subject:
July visitors to Plymouth Hello Aaron, I was wondering if you track visitor numbers to Plymouth for holidays. I saw in the paper that 10,000 visitors come for Thanksgiving and was interested in the 4th of July.
If you have the data, I would appreciate it.
Thank you, Becky Chin, co-chair, Duxbury Nuclear Advisory Committee.
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ATTACHMENT 5 TOWN OF DUXBURY HARBORMASTE R
STANDARD OPERATING PROCEDURE DUX-11 (Rev. 14, 10/11)
PART 2 RESPONSE ACTIONS HARBORMASTER ALERT (3) Notify persons on tidal waters of subarea 12 closing by reading the following emergency message over PA System or other available method:
"This is Duxbury Harbormaster (staff). There is an emergency at the Pilgrim Nuclear Power Station.
Please leave the beach and tidal flats now. Tune to your radio for further information."
PART 2 RESPONSE ACTIONS BEACH TEAM LEADER ALERT
- 8. Supervise beach alerting activities.
- a. Direct personnel to broadcast the "ALERT" classification message (see Beach Alerting Instruction Sheet).
- 9. Upon completion of beach alerting and evacuation:
- a. Notify Harbormaster of completion.
- b. Assign "Bridge Team" and "Blakeman's Bathhouse Team" to maintain beach security.
19
TOWN OF DUXBURY SCHOOL DEPARTMENT STANDARD OPERATING PROCEDURE (Rev 16, 08/13
- 3. Principals
- Coordinate sign-out of any children picked up by parents.
20