ML14338A180
| ML14338A180 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 12/03/2014 |
| From: | Lampert M - No Known Affiliation |
| To: | Nadiyah Morgan Division of Operating Reactor Licensing |
| References | |
| MF2656 | |
| Download: ML14338A180 (9) | |
Text
NRR-PMDAPEm Resource From: Mary Lampert [mary.lampert@comcast.net]
Sent: Wednesday, December 03, 2014 2:52 PM To: Morgan, Nadiyah
Subject:
Pilgrim Watch's Supplement to its August 30, 2013 Petition -KLD Attachments: PILGRIM WATCH SUPPLEMENT TO ITS AUGUST 30 2013 2 206 PETITION 12 03 14.pdf Hello Nadiyah:
Attached please find Pilgrim Watchs Supplement to its August 30, 2013 Petition.
If you have difficulty in downloading the document, please call Mary Lampert at 781-934-0389 Please acknowledge receipt by return email.
Thank you and enjoy the remainder of the day.
Mary 1
Hearing Identifier: NRR_PMDA Email Number: 1738 Mail Envelope Properties (00a501d00f32$929082b0$b7b18810$)
Subject:
Pilgrim Watch's Supplement to its August 30, 2013 Petition -KLD Sent Date: 12/3/2014 2:51:47 PM Received Date: 12/3/2014 2:54:40 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 330 12/3/2014 2:54:40 PM PILGRIM WATCH SUPPLEMENT TO ITS AUGUST 30 2013 2 206 PETITION 12 03 14.pdf 244080 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
Recipients Received:
December 3, 2014 Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 By Email: NrcExecSec@nrc.gov PILGRIM WATCHS DECEMBER 3, 2014 SUPPLEMENT TO ITS AUGUST 30, 2013 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 TOWN OF DUXBURY TELEPHONE SURVEY-SIREN TEST I. INTRODUCTION 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 Town of Duxbury Nuclear Advisory Committee, 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).
The new and significant information petitioners add to the KLD petition is based on the November 20, 2014 Town of Duxbury Emergency Management Agencys Telephone Survey of 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 Duxbury residents that followed the Pilgrim Nuclear Power Station Siren Test in Pilgrims Emergency Planning Zone Communities. The survey asked questions to determine if Duxbury citizens were able to hear the siren; hear and understand the voice message; if they were aware that the sirens would sound, and if so how they heard about the test. The survey is attached.
Duxburys Telephone Survey results are relevant to the petition. Duxburys Telephone Survey showed that Entergys Evacuation Time Estimates (ETEs) for Pilgrim Station are based on inaccurate assumptions and simply are not credible. The ETEs absurd conclusion that even in the worst case scenario everyone in the EPZ will be evacuated in about six hours is based on fundamental flawed assumptions and data, shown in the petitioners August 20, 2013 filing and the Supplements of September 3, 2014 and December 4, 2014.
The ETE incorrectly assumed that mobilization of the general population will commence within 15 minutes after siren notification (ETE, 2-5, 5-1). However the new Duxbury survey showed that, despite media notices of the time and date of the test, only about 2/3 of the respondents heard the siren and only 20% understood the sirens voice message.
The ETE also incorrectly assumes that those in the EPZ will follow a staged keyhole evacuation. (ETE, 7.2) A Staged Evacuation is where one area is told to evacuate and other areas are told to shelter-in-place until directed to evacuate. (NUREG/CR-70002, 1.31) No part of Duxbury is geographically inside the area that will be directed to evacuate initially - a 2 mile ring around the reactor and a wedge, defined by wind direction, in the area from 2 miles to 5 miles from the reactor. The ETE thus is based that no one in Duxbury will evacuate initially. The survey showed that most of those in Duxbury, a community that is 6-10 miles from Pilgrim, will hear the sirens and understand that something is afoot at Pilgrim, but that only about 20% will understand the voice message instructing them not to evacuate. In a real emergency many will
3 hear the siren, and will grasp enough of the message to understand that this is not a test, but very few will understand that they are being directed to not evacuate. Based on the survey data, the only realistic assumption is that most Duxbury residents will evacuate, increasing the number of people and vehicles on evacuation routes, and slowing evacuation times.
Also, the only reasonable assumption is that the results of the Duxbury Telephone Survey would be replicated in other EPZ communities more than five miles from Pilgrim, further increasing evacuation delays well beyond predicted by the KLD survey.
II. FACTUAL BASIS Pilgrim EPZs sirens were tested on November 20 at 3:45 PM. The Town of Duxburys Emergency Management Agency conducted a telephone survey after the siren test and asked residents whether they were in Duxbury at the time of the test and, if so, did they hear the siren and its voice message. Also, they were asked whether they had been aware that the sirens would be tested that presumably would increase the probability that they would hear the siren than if, as in a real emergency, there was no forewarning. The sample size was more than 1,000.2 (See Attachment) In summary:
x 65.42% of respondents heard the sirens.
x Only 21.03% of respondents were able to hear and understand the sirens verbal message.
x 23.61% of respondents were aware when the sirens would be tested.
2 The Duxbury sample size is statistically significant. Consider, in comparison, that NUREG/CR 6953-PAR Study Focus Groups and Telephone Survey Results sample size of 800 completed surveys was considered statistically significant as a representation of the overall 10-mile United States EPZ populations public response.
4 III. Conclusion Petitioners have shown by presenting results from two actual surveys, the Cape Cod Telephone Survey (discussed in Petitioners August 30, 2013 petition) and the Duxbury Telephone survey (discussed herein) that that KLDs assumptions and findings are incorrect and cannot justify its ludicrous estimate that the entire EPZ can be evacuated in six hours.
The Cape Telephone Surveys finding that 50% of the population would self-evacuate even if they were told that they were not in the EPZ shows that the population will not follow a staged evacuation; in fact, far larger numbers will evacuate and traffic estimates considerably slowed.
(Petition, 12) The Duxbury Telephone survey showed that the number of evacuees that will choose to evacuate and not follow a staged evacuation will be even larger because only 21.03%
of respondents were even able to hear and understand the sirens verbal message that in a real emergency would instruct them not to evacuate until it was their turn. We have clearly shown that a staged evacuation, along with many other planning assumptions, is simply a myth to show the plan works but it is simply paper.
The significance of Petitioners filings is that because Pilgrims ETE relies on false assumptions and underestimates evacuation times there is no reasonable assurance to ensure appropriate protective action is implemented; the population will achieve a timely evacuation; that public health and safety will be protected in the event of a radiological emergency; or that the NRC can satisfy its statutory requirement to protect public health and safety. We hope the PRB will take appropriate measures so planning will rest on facts on how folks will actually respond in a real accident so that more families will be unharmed.
5 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 December 3, 2013
6 APPENDIX Town of Duxbury Emergency Management Agency Siren Test Survey, November 10, 2014
7