ML14223A090
| ML14223A090 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 06/16/2014 |
| From: | Lampert M - No Known Affiliation |
| To: | Nadiyah Morgan Division of Operating Reactor Licensing |
| References | |
| MF2656 | |
| Download: ML14223A090 (11) | |
Text
1 NRR-PMDAPEm Resource From:
Mary Lampert [mary.lampert@comcast.net]
Sent:
Monday, June 16, 2014 3:38 PM To:
Morgan, Nadiyah
Subject:
RE: November 22 Supplement to Pilgrim Watch EP Plan Petition Attachments:
11.22.13 PW 2.206 KLD SUPPLEMENT-NOTIFICATION.pdf Here you go.
From: Morgan, Nadiyah [1]
Sent: Monday, June 16, 2014 2:49 PM To: mary.lampert@comcast.net
Subject:
November 22 Supplement to Pilgrim Watch EP Plan Petition Hello Ms. Lampert, During the June 12, 2014 meeting, you mentioned that you submitted a supplement to your petition dated November 22. Unfortunately, I dont have it in my records. Would you please resend it to me?
- Thanks, Nadiyah S Morgan Calvert Cliffs and Pilgrim Project Manager Office of Nuclear Reactor Regulation US Nuclear Regulatory Commission 301.415.1016
Hearing Identifier:
NRR_PMDA Email Number:
1484 Mail Envelope Properties (002401cf899a$81b42730$851c7590$)
Subject:
RE: November 22 Supplement to Pilgrim Watch EP Plan Petition Sent Date:
6/16/2014 3:38:10 PM Received Date:
6/16/2014 3:38:14 PM From:
Mary Lampert Created By:
mary.lampert@comcast.net Recipients:
"Morgan, Nadiyah" <Nadiyah.Morgan@nrc.gov>
Tracking Status: None Post Office:
lampert@comcast.net Files Size Date & Time MESSAGE 638 6/16/2014 3:38:14 PM 11.22.13 PW 2.206 KLD SUPPLEMENT-NOTIFICATION.pdf 179730 Options Priority:
Standard Return Notification:
No Reply Requested:
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Recipients Received:
November 22, 2013 Mr. James Borchardt Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 By Mail & Email: NrcExecSec@nrc.gov AMENDMENT AND 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-Pursuant to §2.206 of Title 10 in the Code of Federal Regulations, Pilgrim Watch (Hereinafter PW) on behalf of its members and members of the Pilgrim Coalition, Project for Entergy Accountability, Cape Cod Bay Watch, EcoLaw, Beyond Nuclear, Greenpeace, and others submits this supplement to its request that the Nuclear Regulatory Commission (NRC) institutes 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).
Based on new and significant information, we wish to amend our 2.206 Petition to read:
The Nuclear Regulatory Commission (NRC) institutes a proceeding to modify, suspend or take any other action 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) and that Entergy will have and demonstrate the 1 NRC Enforcement actions include: notices of violation, civil penalties, orders, notice of nonconformance, confirmatory action letters, letters of reprimand, and demand for action.
2 means to provide early notification and clear instruction to the populace within the plume exposure pathway Emergency Planning Zone2.
We understand that 10 CFR § 50.47 Emergency Plans says, at (2)(b), that NRC will base its finding on a review of the Federal Emergency Management Agency (FEMA) findings and determinations as to whether State and local emergency plans are adequate and whether there is reasonable assurance that they can be implementeda FEMA finding will constitute a rebuttable presumption on questions of adequacy and implementation capability. A rebuttable presumption can be overturned if the evidence contradicting it is true and if a reasonable person of average intelligence could logically conclude from the evidence that the presumption is no longer valid.
PW has provided true evidence contradicting NRC/FEMA findings of adequacy of the KLD Estimates for Pilgrim. Here we add indisputable evidence that notification of the public is insufficient. The only conclusion that the PRB can logically conclude from the evidence is that NRC/FEMAs presumption of adequacy of the Pilgrim Radiological Emergency Plan is no longer valid.
PWs 2.206 (August 30, 2013) showed that Entergys Evacuation Time Estimates (ETEs) for Pilgrim Station are based on nineteen (19) inaccurate assumptions and simply are not credible. This supplement adds another, number twenty (20), that the ETSs are also based on the inaccurate assumption that the public hears and understands the emergency notification siren and its voice message.
2 10 CFR §50.47 (a)(2)(b)(5) says that, Procedures have been established for notification, by the licensee, of State and local response organizations and for notification of emergency personnel by all organizations; the content of initial and followup messages to response organizations and the public has been established; and means to provide early notification and clear instruction to the populace within the plume exposure pathway Emergency Planning Zone have been established (Emphasis added)
3 At 3:45 pm on November 21, 2013 there was a test of all emergency sirens in Duxbury.
That evening the Town of Duxbury Emergency Management Agency conducted a Telephone Survey that more than 1700 Duxbury residents responded. The result of the survey showed 40.3% of the respondents did not hear the sirens; 72.7% did not hear and understand the sirens verbal message; and 67.9% did not know that the sirens would be tested, despite notices in the local papers.
The Town of Duxbury Telephone Survey also supports PWs amendment to the original petition that until Entergy has and has demonstrated the means to provide early notification and clear instruction to the populace within the plume exposure pathway Emergency Planning Zone we do not have reasonable assurance.
BASES
- 1.
The KLD Pilgrim Evacuation Estimate December 12, 2012 Final Report KLD-TR-5103 (Hereinafter, ETE) trip generation times rest on the false assumption that advisory to evacuate starts with the siren notification and the general public is mobilized starting 15 minutes after the siren notification.
3 NRC Electronic Library, Accession Number ML13023A031
4 And at 5.1 the ETE says that notification consists of receiving (hearing) the notification and interpreting the information that is transmitted or hearing and understanding the voice message.
The Telephone Survey conducted by the Town of Duxbury Emergency Management following the November 21, 2013 all-siren test showed that this assumption is incorrect.
Despite the fact that 32.1% were aware that the sirens would be tested on Thursday, November 21 at 3:45 pm and hence would be more likely to hear and understand the siren, 40.3% of the respondents did not even hear the sirens; and 72.7% did not hear and understand the sirens verbal message. Therefore for that sizable population trip generation times would be delayed and not proceed as modeled by KLD.
- 2. The Duxbury Telephone Survey shows that Entergy does not have the means to provide early notification and clear instruction to the populace within the plume exposure pathway Emergency Planning Zone,4 as required by 10 CFR §50.47 (a)(2)(b)(5). NRCs assures on its website that, A prompt Alert and Notification System (ANS) is in place to notify the public within a 10 mile radius of a nuclear power plant. This system will be activated within approximately 15 minutes of a decision by the responsible local or State 4 10 CFR §50.47 (a)(2)(b)(5) says that, Procedures have been established for notification, by the licensee, of State and local response organizations and for notification of emergency personnel by all organizations; the content of initial and followup messages to response organizations and the public has been established; and means to provide early notification and clear instruction to the populace within the plume exposure pathway Emergency Planning Zone have been established (Emphasis added)
5 government agencies of a need to take protective actions5. Clearly the ANS must not simply be in place; but in addition, the ANS must have the capability of being heard and understood by the public and that must mean by more than 32% of the public.
Conclusion The evidence brought forward in the August petition and added now show that critical assumptions underlying KLDs ETE for Pilgrim Station are not credible. A crediblely-based ETE analysis for Pilgrim Station would lead to a significant lengthening of the time required for the EPZ to evacuate. Absent an honest and credible ETE, the population does not have reasonable assurance. In addition, as this supplementt shows the public notification system is insufficient and again demonstrates that the public does not have reasonable assurance and that NRC regulations are not met.
This is no time for emergency planning violations. Just this year, Pilgrim has had 18 Event Reports to the NRC, an unprecedented number for the industry. The vast majority were equipment related. Pilgrims number of shutdowns this year is more than ten times the number of shutdowns than the national average. On November 6, the NRC announced that it had dropped Pilgrims performance rating because of shutdowns with complications, placing it among 15 plants in the country requiring more oversight. And only a few days later, the NRC told Entergy that Pilgrims rating is likely to drop again next month, placing it among the 8 worst performers. Pilgrim is an old reactor losing money, not investing in maintenance and cutting personnel. We need and deserve you to act so that in the event of a disaster we have a chance.
5 http://www.nrc.gov/about-nrc/emerg-preparedness/prepare-for-radiological-emerg.html
6 Respectfully submitted on behalf of the Petitioners, Mary Lampert Pilgrim Watch, Director 148 Washington Street Duxbury, MA 02332 Tel 781-934-0389 Email: mary.lampert@comcast.net November 22, 2013
7 ATTACHMENT Siren Survey 13 Site TOWN OF DUXBURY Scheduled By Keith Nette Send Time 21 November 2013 6:15PM (ET)
Voice Completed 21 November 2013 6:46PM (ET) (First attempt completed at 21 November 2013 6:38PM (ET))
l Download (Greeting recording and text in default language)
The emergency sirens for a radiological emergency at Pilgrim were tested Thursday afternoon, November 21st at 3:45pm.
Question 1 Were you in Duxbury then Response Rate 100% (1715)
yes (1,125)
no (537)
Dont Recall (53)
Question 2 Did you hear the emergency siren test?
Response Rate 95% (1622)
Yes (59.7%)
(968)
No (40.3%)
8 (654)
No Response (93)
Question 3 When the siren was tested, what best describes where you were?
Response Rate 83% (1407)
Inside with windows open (174)
Inside with windows shut (747)
Outside (243)
In a car (243)
No Response (308)
Question 4 The siren includes a verbal message, were you able to hear and understand and what is said?
Response Rate 79% (1351)
Yes (27.3%)
(369)
No (72.7)
9 (982)
No Response (364)
Question 5 Were you aware that the sirens would be tested on Thursday at 3:45pm?
Response Rate 78% (1334)
Yes (32.1%)
(428)
No 67.9%
(906)
No Response (381)
© 2004 - 2013 Blackboard Connect Inc. All rights reserved. more details Privacy Policy Terms of Use ConnectSupport@blackboard.com 866-360-2155 Note: PW added the percents to the no and yes responses