ML20029E019

Requests Response to 940324 Ltr Re Wellesley & South Weymouth Reception Ctrs

ML20029E019
Person / Time
Site:	Pilgrim
Issue date:	03/08/1994
From:	Fleming J AFFILIATION NOT ASSIGNED
To:	The Chairman NRC COMMISSION (OCM)
Shared Package
ML20029C520	List: ML20029E017 ML20029E019
References
NUDOCS 9405160084
Download: ML20029E019 (9)

Text

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wy March 8,41994 , ,b ,

I Chairman Ivan Selin -

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l Washington D.C. e Chairman Selin, 4 I was unaware the NRC had suffered such severe financial reversals since you have taken office. Now that I have been, informed of your financial difficulties I feel it is my duty l to lend a helping hand. Enclosed please find my personal  ;

check for $10.00. I did check with the phone company and learned that a call from my home to your agency would cost 1Geents per minute. Your staff kept me on hold for 45  :

minutes which would equal $7.20 considered the extra $2.80 a contribution toward additional expenses. (Perhaps stamps for  ;

thank you notes) ,

Now that this matter is taken care of perhaps we could I deal with the issue at hand.  % p p_7 PILGRIM DOES NOT llAVE A RECEPTION CENTER TO TiiE NORTil. l Dc?c .

We have not had an adequate staff since F-b 1, 1993 as  !

state documents have shown.

1. The MEMA staffing report, which includes more than half y2, __ y the staff highway dept, workers.

2. The letter from the Highway Dept General Council to DECO, stating that as of Dec. the Ilighway Dept. personnel would no gj l longer be available and that BEco had best find their own staff.

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These letters are and have been in the hands of the NRC i for sometime now. As a matter of fact they were sent to me 13 by Jim Partlow when he was working on my 2.206.

( Unfortunately you people choose to ignore Jim's work)

Equipment:

It is my understanding from two reliable sources that l the equipment left Wellesley thru out Dec. and Jan. and is )

now at South Weymouth Naval Base.

My fear is that the statements on page 3 of 3 of the Edir.on status report maybe be less than accurate. Perhaps they are " statements that need to he qualified" If they are {

correct and there are indeed three " spare" portal monitors  ;

about I strongly suggest the " spares" are sent immediately to the South Weymouth Naval Base to bring the total of monitor up to six. Six monitors will be able to monitor 180 people in one hour, 2100 people in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. I remind you Duxbury's  !

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r< mg s',0t 4 y-School population alone is over 3000, the_ Town's population is over 14,000. The figures are notrinclusive of Marshfield, who will also be using the reception center. My figures are based on the "Carr/ Fleming standard" of 2 minutes set in 1989. FEMA attempted to set a new standard in'the 1991 -

exercise but the people monitoring were so untrained for the.'

task they could not monitor 10 people to set a standard.o As t r

• you know, since we had no reception center in Dec of 1993 it was not tested in that exercise. +

I toured the base on Saturday and have the higher,t hopes that eventually we may for the first time have a staffed reception '

center. If we insist that the DECO " stated six" monitors _are all at South Weymouth we still are far shy of the mandated 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> monitoring needs but the people of the Ep2 will have a chance. You owe us that much.

According to the NRC 50-293/94-01 report pilgrim is operating outside of " Design Basis" in almost every' area.

You are playing Russian Roulette with the people of this area at least give us a Reception Center. As I explained you had a chance to regulate with my 2.206. Had you set the clock on just the Reception Center the NRC would have been operating  !

within their own regulations without disrupting the utilities declared timelinc. Now you are out of regulations as wel1 as the Utility. I do hold you personally responsible,.I have personally informed you of the situation and as Chairman of the NRC you do have the power to correct the' problem'. Stop the personal games, I am not the issue,: PUBLIC llEALTH and Safety is the issue.

Sincerely,;,

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J[rie A I'leming l'

Ce gj president Clinton ,

David Williams Sen. Kennedy Sen. Kerry Sen. Lieberman Sen. Robert Dole .

Sen. John G1enn Sen. Nancy Kassebaum Sen. Carl Levin Sen. C l a i bca r n e Pel1 Sen. Jesse Helmns Sen. Moynihan Sen. Graham Sen. Metzenbaum i Sen. Wofford, Sen. Boxer, Sen. Warner O

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Jan.18, 1994 2-President William Clinton White House Washington D.C.

FAX # 202 456 24G1 Mister President, I would appreciate your support in assuring the health and safety of the public. Emergency Planning for Nuclear Power Plants, unlike the natural disasters you must deal with, have a definite form and substance. The FtJc il Regulations (10 CFR 50:47) and guidelines (NUREG bt.24) were developed foilowing TMI. The premise underlying the regulations is quite simple. Get the people out and get them monitored. Monitoring takes place at reception centers. The functions of a reception center is to ; monitor for, radiation, decontaminate if necessary and family reunification.

Currently a portion of the population around Pilgrim and Seabrook Nuclear Power Stations are without a functioning reception center. The NRC has been aware of this pending problem since Sept.16, 1992. They were aware the reception center was not adequately staffed Mar.2, 1993 and they have been aware that the entire State staff would be dispersed in Dec. of 1993, as early as June of 1993. It is now Jan 1994 and the NRC is justifying.the adequacy of this reception center by referring to documentation that was developed in Sept. of 1991 and released by FEMA in Dec. of 1992. Three months after Governor William Weld announced the pending sale ,

of the facility. The State, FEMA and the NRC hopes to have a i new facility by April of;1994. In the mean time Federal Regulations and guidelines are not being comported with and ,

the public is placed in a position of unnecessary risk.

I hope you can lend your authority to this current situation and perhaps in your selection of Commissioners to the NRC, you wi11 appoint people who realize Emergency l Planning is the public last and only line of defense. This l issue deserves a realistic and factual review by the  !

Commission.

l The attached letter has been faxed to the Nuclear I J

Regulatory Commission, today, Jan.18,1994.

j Thank You for your time and your suppori.

Sincerely, pa

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l 8 Oceanwood Drive l Duxbury,ma.02332 Jan. 18, 1994 The Chairman and Commissioners (J S NRC i

Washington D.C. 20555 l

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To The Commissioners; l

Today January 18, 1994 Pilgrim Nuclear Power Station does not have an adequately staffed and functioning' reception center to the North You are knowingly allowing Pilgrim and S eabrorsk t o ope r a t e in violation of 10 CFR 50:47 B.8. and out 1 of compliance with NUREG 0654 J.12. l Today, my families health and safety and that of the entire Duxbury and Marshfield EPZ population, as welI as portions of the Seabrook EPZ population, are at risk.

IJn n e c e s:s a r i l y !

I expect a response today. I will not accept outdated information. I expect the Commission to find a spee'dy remedy to this problem. My number is 617-93427451 I am awaiting your cal 1, today.

The games have ended!

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Tite. resp ortslv c.rtess" ~ "ra p" holds , but let me. etarlf y' it.

Y ou. d o stot ha.v e to res p o rtd to me p ers orta Lly , this istt ' t a.rt c.g o titing , but as Chairmart o f thc. N R C y o u. d o Ita.u c. to res p o rtd to my issu.cs. Titc. f a.c.t tite. PLlgrim EP Z at titis momertt Itas rto receptiott center to tite. Month. is a. very .scrious' artd vaLLd .

issu.e . It is cleanly a. violatlott of 10'CFR 50:47. B 8. It is, I assuin c. , part of your oatlt of of ficc. to lLphtold tite pertinc.nt regutatLo ns . Pu blLe Hc.attit. a.rtd Sa.f cty arc. being titreatc. rte.d at this momerit. If tite.re. is a.it a.eeident at Piigrim or S ea.br o o h. , portLorts o f Lite pu.btle are wikitout titc. ma.itdatc.d receptiort certter ,

4 In your rtatc. you. . state there. was a. f ult revLew a.rtd itectrirg of my complaint (2.206 P ctrtLort ) Dr. Titomas Murlc.y a.nd I detcsunined titat was rtot . tite. casc.. Titc. decision seemLitgly overlooke.d two yeaAs of work perf ormed by Jim Pas.tl o w . Titc. Director Itas a. greed to reopc.rt titree major issu.c.s; tite Wcklcsley R c.ec.p tion C c.rtter , tite La.ch. o f com p o rtmen t wl.th. NU R E G 0654 A.3., a.itd tite a.tilities ina.bility ta deuctap art a.ecurotc. catd LLmety PAR, I ttd c.c.d y ou. p la.y c.d a.rt a.ctive paxt ist c.nuctopirte tite. Latter two issa.es that lite DLrector's dc.cisiott overtooked.

I agree, my originat a.cces.s to the f oruncx Cita.Lrmatt a.rtd C ommi sslott was tutp reec.d en.ted , I u.rtdcxs-tand titat I was t}te first membcx of tite public to ha.ve. a. privcttc. a.ppolit.tmc.rtt witit titc. Clta.irma.rt af Llte NRC. Aeaitt, titis is atot a- personat ,

titLrt9 The issu.cs I brou.9tt I to Citairma.rt Carr were valid . My dcsirc. to improue clncxgertey plartrtLotg wa s recoestized cutd my wLLtingrtcss"ta tectrat a.rtd worh. titrottgit tite. sys. tem was a.p precs.at ed . And my pcxsistc.rtee paid of f . I stilt attempt to work throu.gh thc. system, but, it Itas become increasingly dif ficutt, i am quitc'prolLd of tite f a,ct that i . set precedeutec ist attowlite " mere" membess of thc. pu.btie a.ecess to the C ommiss t oat . Af ter all it is tite Pu. bile's Heaktit a.rtd Sa f ety you. axe ma.ndated to protect. I httow titat my krtowledgc. irt thc.

f Letd af emerg ettey prepareditess , irt' particular, Pilgrim *s emerg ertey preparedttcss , lettds me tite. cortfidertec o to present a.ceuAate a.nd LLmcty istf armatiort to tite CommL-ssiott. I assunc.

ollter me.mb cx o f the pu.blic anc. equatly krtowledgea.ble ist thein.

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Tite response Rort Ea.t o n prepared f or you. was rto t j responsive to the statemertt- I made to you, o rt Jan. 15, 1994.

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FEDERAL REGULATIONS, GUIDELINES AND ADJUDICATIONG PERTAINING TO RECEPTION CENTERS Federal Regulation:

10 CFR 50:47 (b) (8 ) Adequate emergency f acilities and equipment to support the emergency response are provided and maintained.

10 CFR 50 : 47' ( b ) ( 10 ) A range of protective actions have been developed for the plume exposure pathway'EPZ for emergency workers and for the public. Guidelines for the choice of protective actions during an emergency, consistent with

.Foderal Guidance, are developed and in place, and protective action for the ingestion exposure pathway EPZ to the locale have been developed.

NURFG 0654/FCMA-REP-1 J.12 Each organization shall describe the means for registering and monitoring of evacuees at the relocation center 7 in host areas. The personnel and equipment available shall capable of monitoring within about a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> period all residents and transients in the plume exposure area.

N.B. In Sept of 1988 j.12 was reinforced; the word "should" was replaced with shall, as highlighted above. Although 0654 in a guidance, not a regulation, this reinforcement of I language may now make this an enforceable action.

Krimm's Memorandum dated Dec. 24, 1985 signed by Richard W.

Krimm, FEMA. The memo iaas an internal FEMA memorandum. Its stated purpose was to provide " interpretive guidance" to NUREG 0654 j.12.. The memo determined that emergency preparedness plans should include trained personnel and equipment at relocation centers for monitoring a minimum of '

twenty percent of the population within the EPZ. ( emer ge ncy planning zone)-

Major cases li tigating Krimm 's Memorandum:

28 NRC 51". (1988) ALAB-905 In the matLor of Long Island Lighting Company

( Shor eham ) Nov. 29, 1988 30 NRC 3 31 (1999) ALAB-924 in the mat.ter of Public Service Company of New Hampshire

( Seabroo k ) Nov 7, 1989 DUXCURY'$ SCHOOL POPULATION Approximate 1y -3 , 0 0 '

Duxbury's total population Approximately 14,000 Mar 3hfield's School population Approximately 640t tthis ic EPZ population only 1

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Although, when litigated it was determined to-be without substance", the Krimm's Memorandum has been implemented by FEMA and supported by virtue'of " negative consent" by the NRC. It is of interest to note that on June 20, 1989 Victor Stello EDO in a Memo to the Commission su ggm s ted for clarity, a rulemaking decision of the 20%

monitoring of evacuees. No rulemaking has been f~orthcoming.

The NRC is on record.to be "in concept, in support of the mo ni t or i ng of. school children" This statement was made directly referring to the Pilgrim.EPZ and the Duxbury School Population.

The Krimm's Memorandum has been implemented within many EPZ without regard to demographics or meteorological conditions. The pcpulation orcup most negatively impact by thic i the school population who essentially have been skimmd out of the reception centers and sent to so called Host School under the " precautionary transfer". -

Using Pilgrim as an example allow me to explain the practical flaws within this system.

1 Meteorological factors; In 1989, Spengler and Keller

( l :a r va r d .) performed a Wind Study for the Coastal Areas around P i l s;i i m in connection with the " Southeastern Massachusett '

Health Study" On Oct.12,1989 I presented the Wind Study to C ha i r ma n Carr ,NRC not only as it pertained to the Cancer 5tudy, but also with the implications the rapidly changing coastal breezes would 'effect. Emergency Planning (E.P.)

The end result, the NRC accepted the. premise of rapidly changing wind direction and determined that the entire school pcpulation of the EPZ should be evacuated simultaneously.

This rapid change in wind direction will effect the entire population and potentially result in a far larger expecure of the EPZ population than say, for example, a mid western plant with a constant wind direction. Planning in our coastal area.must be prepared for the rapid shifts in wind direction and the potential e<posure of the entire EPZ.

Demographics: When the Krimm's Memo is applied to a densely por~.'ated area it becomes apparent rapidly that f i na nces are l

the major concern. Within the Pl] grim EpZ the school population alone exceeds the 2 0 *. cap that Krimm"s I c ericioucle developed. The Util t/ developed the concept of mt :.chool' A " Host School" will register children and t i d< famil {

.a reunification but >ffers no monitoring for  !

ootential contamination. Children are oore vulnerable to the

frects of radiation than adultc. Yet, children are not

.ansidered in t hr4 planning procesc for reception centers. I i

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Pilgrim' states the children will be evacuated before there is a release.

Flaws in that statement 1 A release at a boiling Water reactor can occur in 0 - 30 minutes. ( NUREG0654 )

2 There is at least a three hour delay built into the mobilization of school children.

J. Onct a bus is enroute it can De exposed. A school bus offerc less than 1: dose reduction.

4 If the bus is exposed the driver wears a dosimeter and will 'e now . In the last three exercises the bus drivers displayed a complete lack of training in dosimetry 5 Communications with buses have failed in each exercise 6 In all three exercises especially Dec. 1991 the utility was unable to develop a complete and accurate protective action. they also did not receive the retraining the NRC staff recommended in the field of developing protective actions.

The list of potential human and mechanical failures is e n d l " .. s . La h y risk our most vulnerable population group?

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- 1 Executive Directort.of-Operations - ' r.

U.S..N.R.C Washington 20555

Dear Jim,

On Sept 15, 1992, The Boston Globe published the Gover nor 's intention to consolidate the DPW and sell the Wollesley DPW garage. Oct. 1, 1992 was the target dato to make this proposal official The property has been appraisea at $28 million and the consolidation predicted a four year savings to be $25 million. Needless to say, this has been a uell received proposal in the State. The one flaw.to the plan; the Wellesley DPW Garage is the Relocation Center for P11 grim and Seabrook.

On Monday Sept. 21, 1992 I called David Rodham the Director of MEMA to check the validity of the newspaper -

story. He confirmed the facts while driving to the Wellesley DPW garage to attend the first of many meetings on this very opic On St.pt. 24, 1992 I presented the preliminary information concerning this tu Jim Partlow, NRR. ey a cnan e 'ing,  ! also informed Ab Mocheni of he the potantial

t. !cring of Wellesley and ask him to pass this on to Dob r r'ckson, I followed this up the next morning with a call t. o

% Aby informed me Bob was "on travel, therefore he hadn't in ormed him. I then called Ebe McCabe , and discuss the ikilesley Reception Center Issue as well as other issues.

On Sept. 30, 1992 Craig Wingo of FEMA informed me, that nc had just received documentation from Northeast Utilities

, _ .a t stated: the Governor's proposed sale of Wellesley DPW

_i 'ge was a rumor Wingo felt the proposed sale was not going to happen, based on the Northeast Utility information, furthermore Bob Erickson was on his other line to discuss this. It Was during this onversation with Wingo, FEMA, that I first became aware of the fact Seabrook would also be usinq

'Jellesley as a reception center. Ebe McCabe confirmed the

ta teme nt concerning Seabrook. ( This dual use brings in a

ny r iad of new problems that I won't discuss now.)

I then contacted Dave Rodham, MEMA, to determiac if the

.,atus had changed. David assured me that this proposal was i ndeed goi nc: forth. David further indicated that it was his

>nse that he would like to have a new reception center lined I

, b Jan.1, 1993.

With t hi s secani na l" co nf l i ct i na information I cont act ed

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With this seemingly conflicting information I contacted the NRC through secretary Chilk's office and the Chairman's office through Public Affairs. I informed both' offices of the contradictory information, as well as my fear that once again, without any verification of the Utilities supposed

" facts", a document of convenience would be accept as truth..

Both offices assured me they would pass this on to the approprlate people.

The next day, to reconfirm the facts Rodham presented to me, I started inquiries through out the state. From the Gover nor 's of fice , the Secretary of Tra nsportation,. the Highway Dept. down to the "Right of Way" Dept. and the project manager, in charge of preparing of the property for sale. All agree that the proposal became official Oct. 1, 1992. The cense was the consolidation would take place over the next three months (leaving us without a set up staf f ) and the preparation for sale up to a year due to the toxic waste problems on site This information I relayed back to Ebe McCabe,'his initial response concerned me. In essence he stated the the Utilities were obliged to report the tr uth to the NRC. I reminded him of my concern of a " convenient truth" rather than a " factual truth" to often has become the " accepted truth" After running through many quotable quotes, I reminded Ebe of one of my favorites: "If man does not learn from history, he is doomed to repeat it." I reminded Ebe the NRC has on too many occasions in the uorld of Emergency Planning accepted without verifying. the utilities

" convenient truths" My last call of the day was to you Jim, and after our traditional parry of who is ultimately responsible for amergency planning. As promised I have put my, what I as an individual, have been able to learn into uriting.

Jim Partlow has my original documents, newspaper articles and a letter from the town manager.*

Ebe McCabe has the secretary of Transportation's response (Sept 28,1992) to Rodham and Groux Essentially it states they are aware of the Reception Center, it is being considered but the utilities are Tenants at Will. i.e. the State can throw them out when ever they choose.

Bottom line Jim, you are now in, as you described it,

'a heads up situation' M T understand it Erickson and group have the alleged utility .bcument. If its statemente ar. as Craig Wingo has described them and if the are as unfounded as my questioning of the proper authorities seem to indicate, then, I would hopo thic document in question is

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never entered into the files of planning with the potential of misleading staff members and perhaps once again the Commission. Secondly, I would expect the NRC to take the proper actions against the utility.

In summary. .J i m , there are three key issues:

1. The consolidation of the DPW staff within three months Leaving the reception center without a setup staff

2. The ultimate sale of the DPW garage, leaving us without even a physical plant to use as a reception center.

3. The possibility Northeast Utility created a document of

" convenient truth" with the intention of misleading Federal Agencies.

Si ncer ely .

Jane A. Fleming

• ,,. un aside the town manager's letter has started round five in the School Conunittee and School Superintendente versuc the non-elected town manager battle over monitoring of School Children.

The School committee holds firm: the children of Duxbury will be monitored whenever they are evacuated. Ofcourse we do need a reception center to accomplich this.

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yket,No.50-293 .Sune 29, 1993 s fs Mr. E. Thomas Boulette, Ph.D ( ') /

( I' Senior Vice President - Nuclear N' , /(\ .

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Dear Mr. Boulette:

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SUBJECT:

REPLACEMENTFACILITY'FORTHEWE\LERLEYRECEPTIONCENTER Enclosed are three letters relcted to the impending loss of the Wellesley Reception Center (WRC), currently schedtled for December 1993. In the letter to Mr. Congel, dated June 9,1993, the Federal Emergency Management Agency (FEMA) asked the U.S. Nuclear Regulatory Commission (NRC) to coordinate with you and the Seabrook licensee to provide whatever assistance is needed by the Massachusetts Emergency Management Agency (MEMA) to resolve the issues of a  :

replacement facility before December 1993. I know your staff is woiking to effect a timely soluticn to this issus, ino I wouk. ragtmst that ycer staff provide ne with a schedule of your progress to date, and monthly upuates until the new reception center is functional I feel it is important to emphasize to you the concern we share with FEMA.that l an alternate reception center be identified, that trained personnel be available, and that appropriate plan and procedure changes be made at the time the WRC is no longer available.

Sincerely, Original signed bv:

Ronald B. Eaton, tenior Project Manager Project Directorate I-3 .

Division of Reactor Projects - 1/11 '

Office of Nuclear Reactor Regulation

Enclosures:

1. Ltr. 6/9/93 FEMA to NRC

2. Ltr 6/8/93 FEMA to MEMA

3. Ltr. 4/27/93 MASS Highway to BECO cc w/ enclosures.:

See next page DISTRIBUTION: PDI-3 Reading WButler OGC RErickson, 9H15 Docket File SVArga Slittle ACRS (10) ,

NRC & Local PDRs JCalvo REaton JLinville, RI l OFFICE PDI-3:LA PDI-2fFM PEP k PDI-3:D.ff_b NAME SLi tbtb REathn:dt REk[$ son WButler t_DATE __

6////93 h f)'f/93 kN/93 hh%/93 0FFIC]Al. RECORD COPY DOCUMENT NAME: A:\WRC.LTR

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,,'7, fgj NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20$55-0001 June 29,1993 Docket No. 50-293 C

Mr. E. Thomas Boulette, Ph.D Senior Vice President - Nuclear Boston Edison Company Pilgrim Nuclear Power Station sto n Rocky Hill Road Plymouth, Massachusetts 02360

SUBJECT:

REPLACLMENT FACILITY FOR THE WELLESLEY RECEPTION CENTER Enclosed are three letters related to the impending loss of the Wellesley-Reception Center (WRC), currently scheduled for December 1993. In the letter to Mr. Congel, dated June 9, 1993, the Federal Emergency Management Agency (FEMA) asked the U.S. Nuclear Regulatory Commission (NRC) to coordinate with you and the Seabrook licensee to provide whatever assistance is needed by the Massachusetts Emergency Management Agency (MEMA) to resolve the issues of a replacement facility before December 1993. I know your staff is working to j effect a timely solution to this issue, and I would request that your staff provide me with a schedule of your progress to date, and monthly updates until the new reception center is functional.

I feel it is important to emphasi7e to you the concern we share with FEMA that~

an alternate reception center be identified, that trained personnel be.. '

available, and that appropriate plan and procedure changes be made at the time the WRC is no longer available.

Sincerely,

/,,-, J , /y {/ r onald B. Eaton, Senior Project Manager roject Directorate I-3 Division of Reactor Projects - I/II-Office of Nuclear Reactor Regulation

Enclosures:

f. Ltr. 6/9/93 FEMA to NRC

2. Ltr. 6/8/93 FEMA to MEMA

3. Ltr. 4/27/93 MASS Highway to BECO cc w/ enclosures:

See next page p 3 0 /-&7-c=YI "

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< o Mr. E. Thomas Boulette ~ Pilgrim Nuclear Power Station CC:

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Mr. Edward S. Kraft, Mr. H. Vernon 0heim I Vice President of Nuclear Manager, Reg. Affairs Dept.

Operations & Station Director Pilgrim Nuclear Power Station Pilgrim Nuclear Power Station RfD #1 Rocky Hill Road RfD #1 Rocky Hill Road Plymouth, Massachusetts 02360 Plymouth, Massachusetts 02360 Mr. David F. Tarantino .

Resident Inspector Nuclear Information Manager U. S. Nuclear Regulatory Commission Pilgrim Nuclear Power Station {

l Pilgrim Nuclear Power Station RFD #1, Rocky Hill Road 1 Post Office Box 867 Plymouth, Massachusetts 02360 l Plymouth, Massachusetts 02360 l Mr. Thomas Rapone Chairman, Board of Selectmen Secretary of Public Safety 11 Lincoln Street Executive Off!re of Public Safety l Plymouth, Massachusetts 02360 One Ashburton P'i:ce  !

Boston, Massachusetts 02108 Office of the Commissioner .

Massachusetts Department of Mr. David Rodham, Director Environmental Protection Massachusetts Emergency. Management One Winter Street Agency Boston, Massachusetts 02108 400 Worcester Road P.O. Box 1496 Office of the Attorney General Framingham, Massachusetts 01701-0317 One Ashburton Place Attn: James Muckerheide 20th F1cor -- -

Boston, Massachusetts 02108 Chairmen, Citizens Urging Responsible Energy Mr. Robert M. Hallisey, Director P. O. Box 2621 Radiation Control Program Duxbury, Massachusetts 02331 Massachusetts Department of Public Health Citizens at Risk 305 South Street P. O. Box 3803 i Boston, Massachusetts 02130 Plymouth, Massachusetts 02361 Regional Administrator, Region 1 W. S. Stowe, Esquire U. S. Nuclear Regulatory Commission Boston Edison Company 475 Allendale Road. 800 Boylston St., 36th Floor King of Prussia, Pennsylvania 19406 Boston, Massachusetts 02199 Mr. Paul J. Hamilton Licensing Division Manager Boston Edison Company 25 Braintree Hill Park Braintree, Massachusetts 02184 I

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Enclosure 1

,ft,.fgkg Federal Emergency Management Agency

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v JJJ 9 1993 Mr. Frank J. Congol, Director Division of Radiation Safety and Safeguards Office of Nuclear Reactor Regulation U.S. Nucicar Hegulatory Commission Washington, D.C. 2055S

Dear Mr. Congel:

We have received a copy of the cnclosed April 27, 1993, lotter from-Edward J. Corcoran II, Chief Counsel to the Massachusetts Highway Department (MHD), to tho Senior Vice President-Nuclear of the Boston Edison Company (BECo) informing DECO that " DECO's use of [the KHD maintenance facility in Wellesley) shall terminato an of December 31, 1993." The Wellesicy MHD facility currently servcc as the reception conter for the communitics of Duxbury and Marshfield in the event of an accjdent at the Pilgrim Nuclear Power Station and for the communitics of Newbury and Newburyport in the event of an accident at the Scabrook Nuclear PoWor Station. We remain highly concerned with the Massachusetts Emergency Management Agency's (MEMA) efforts to identify a new reception center facility (or facilities) to replace the facility at.Wellos)ey. .

We have been aware for some time that MHD was concidering selling or leasing its Wellos}ey maintenance facility as part of its consolidation and privatization plan. However, the December 31, 1993, termination of the agreement for the use of the Wellesley facility dictates that a suitable replacement facility for the Wellesley reception centor be identified as soon as possible.

Encloced is a copy of a June 8, 1993, letter from Richard W.

Krimm, FEMA Deputy Associate Director for Stato and Local Programs and Support, to MEMA Director A. David Rodham regarding the imminent unavu11 ability of the Wellesley facility, its impact ,

on radiological emergency planning and preparedness at Pilgrim and Seabrook and the issues which need to be addressod.

FEHA.would like NRC to coordinate with BEco and the North Atlantic Energy Service Corporation, the licensee for Se,abrook, and ask the utilities to provide whatever assictance is needed by MEMA to resolve thjs issue bcfore' December 1993. FEMA is '

availabic at your convenionce to discuss issues related to the identification of the new reception conter(s).

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.. y (k,f If you have any questionsa r e 6 ace feel froe to contact me at (202) 646-3026 or (f4argaret Lawless of my staff at (202) 646-3027. [

Sincgoly, pH $.

C aig S/ Wingo Assistait Associato Director Offico of Technological Hazards Enclosures

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v JUN - 8 1993 .

Mr. A. David Rodh'an Director #

Massachusetts Emergency Management Agoncy

-400 Worcester Road P.O. Box 1496 Framingham, MA 01701-0317

Dear'h . IMdh5m:

Tho Fodoral Emargency Managomont Agency (FEMA)'has received a copy of tne enclosed April 27, 1993, letter fro.m Edward J.

Corcoran II, Chief Counsel to the Massachusetts Highway ,

Dopartment (MHD), to the Senior Vice President-Nuclear of the Boston Edison Company (BECo) informing BECo that "BECo's use of

[the MHD maintenance facility in Wellesley) shall terminata as of December 31, 1993." As you know, the Wellesley MHD facility '

currently servos as the rocoption contor for the communities of Duxbury and Marchfield in the event of an accident-at the Pilgrim Nuclear Power Station and for the communitlos'of Newbury and Newburyport in the evont of an accident at the Seabrook Nuclear Power Station. Wo remain highly concerned with-the Massachusetts Emergency Management Agency's (MEMA) efforta to identify a new -

reception center facility (or facilities) to replace the facility at Wollooloy.

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We have been aware f or son,o timo that MED was considering selling-L -or leasing its Wellesley maintenance facility as part of its j

consolidation and privatization plan. However, the December 31, 1993, termination of the agreement for the.use of the Wollonley facility dictatus that a suitable roplacement' facility for the

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Wellesley.rocoption center bo identified as soon.as possible.

FEMA understands, through discussions with your etaff,-that MEMA >

'is considering using two rocoption center facilities--one for the.  !

affectod Seabrook communities and another for the affected Pilgrim towns--to replace the Wollesley KHD maintenance facility. ,

Changing. reception conters will nocessitate substantial plan changos to the Massachusotts Radiological Emergency Response Plan ,

o (MARERP) for Pilgrim and Seabrook. For example, plans and procedures, public information 'uaterials, amargency broadcast-system mossages and other documents such as traffic managoment

' manuals will have to be amended to address issues concerning the new rocoption contor(s). In addition, a now evacuation time ectimate study will have to be conducted for oach site and its findings incorporated into the MARERP. New staff may have to be r

. Ek. I identiflod, aEd the staff for the now ruception ,contor(n) will have to be trail nod on the net-up of the racility as well an on monitoring, docentamination and registration activition.

Moreover, now congregate care contors and host schools may also havo to be identified which would roquire additional plan and map I changos. The revised planning documents must be submitted to l FEMA for review and approval. -

0 i FEMA requesta MEMA to develop and submit a. plan with miloatonoa notablished for accomplishing the necausary tanka to resolve the leauon concerning tho withdrawal of the Wellesley reception j center an an availablo facility for radiological cmorgonoy  !

preparednesa purposos.

Given the critical importanco of reception center functions in radiological emergency planning and preparedness, Unlessi alternath! reception conter facilitia; and~ trained persdnnel:,%re '

available at tho timo the Wollosley f acility is no lengdr:

avai1able, ineluding appropriate , plan ,and; procedure changesjYdrEMC bolieves that this could affect the health and safetycoBeth'ets&6 1 public reniding in the Pilgrim emergency planning zone (EP2}g4W3  !

tho' Massachusetts portion of the Seabrook.EPZ in-the 'eventsme;a l radiological emergency. ,

l If pl%nning and proparednoss issues concerning the now recoption center (s) are resolvsd by December 1993, FEMA requests that the new Pilgrim reception contor be demonstrated as part of the 1993 Pilgrim exorciao. If outstanding leaues remain at tho time that exercise is conducted, FEMA would liko to sco.the now rocoption conter demonstrated once those inauos have been resolved. If there in a separate reception conter facility for Seabrook, we would like to 300 that facility demonstrated ao part of the 1994 Seabrook oxorcise. It is no longer useful to demonstrate the Wallooley reception center during the Pilgrim 1993 exerciso because of tho imminent unavailability of the MHD facility.

It should be noted that even at the present time staffing capabilitica for the Wollesley facility are of major concern, i The April 27, 1993, latter from Mr. Corocran states that, "all  ;

MHD functions and employees will have boen relocated from' Wellenley by December," and that the MHD employees currently assigned to reception centar functions will not be available to porf orm their duties at that time. It is FEMA's position that j whonever sufficient trained MHD staff for the Wellanley facility I are no longer availablo, alternato trained staff must be provided. FEMA requests MEMA to provido a schedule for the withdrawal of MHD personnel from th,oir ansigned ronponsibilition at the Wellesloy rocoption center. Staffing routers and training records for new personnel should be submitted to FEMA to document the availability of replacement staff for the MHD pornonnel.

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7EMA is available at your conveniunca to discuna issusc relatod to the identification of the new rocoption conter(s) and the nncessary plan modifications.

If ycu have any questions or concorns please feel froo to contact r.e at (202) 646-3692 or Craig Wingo, Assistant Associato Director of the offica of Technological Hazards, at (202) 646-3026.

Sincerely,

?s n-Richard W. Krimm Doputy Associate Director Stato and Local Programs and Support _

Enclosure 3

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Ms. Jane Fleming ,

8 Oceanwood Drive Duxbury, Massachusetts 02332

Dear Ms. Fleming:

Office of Nuclear Reactor Regulation, dated NovemberThis , Director, 17, 1992, in response to your letter October 5, 1992.to James M. Taylor, Executive Director of Operations, dated continued availability of the Wellesley Reception Center.In your le We informed the they consider in Massachusetts. them in their evaluation of ness The two possible issues were:

radiologi 1.

three months, leaving the reception center without  ;

2.

The u e asultimate a e sale n ce of the DPW garage, resulting in no physical plant to i J n, k gcu0c1g Ccgcc]0]_

OnDecembedf,199 Massachusetts' _ EMA issued its " Technical Assistance Review for State and Local Community Plans in Support of Seabrook Nuclear ,

Power, Station," which included an evaluation of the Wellesley Reception!

Center.

FEMA, evaluated the Wellesley Reception Center and determined tha j meets applicable criteria in NUREG-0654/ FEMA-REP-1 Revision 1. i FEMA stated in Response Plan), MHD will provide staff and ency also m I

' ' Personnel from several organi7.ations also staff the facility." .

i Emergency Management Agency officials usetts are aware Seabrook and Pilgrim emergency plans on the Wellesley Reception , we Center believe that the possible issues you raised have been dulyand considered are not of concern for the foreseeable future.  !

Sincerely, c) I' p

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1. p# Rdbert A. Erickson, Chief Emergency Preparedness Branch.

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- Division of Radiation Safety and Safeguards I

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3.d.g/ mum.. 5 kgn PwiCtlhed i L Ghsw Lew etQ w w hmnJ.KmsMn LudMo T. ytopy

$x.wy g,;,m April 27, 1993 CIRTITIID XAIL genton .Idison Company ssonier Vies President -

Nucitar 300 seylston Straat lenten, XA 0: 10t Re:

Notice to Tarninata Licanza A~res=ent f or wallsalay Xaintenanca tac lity Daar Air!

DepartmentThis la(MHD), to provida n:tico that the Mast,achusetts Highvay for:arlv Xnown as the Mannachusetta Department of Public Werks, is exercising its right to terminata the 11canso agreaeant betvaan Boston Edison C0 pany-.(33CO) r the- Division cf CapitalPlanningandoperations,andtheDepr.rtrant, October 6, 1989, dated located in Welleslay.for BECO's use of XHD's =a ntananca facility said property shall terminato asNotica is hereby given that DICQ's uso of Oscamber 31, 1993.

The Departrient recognizas SIco's need for ita national readiness to uns the preparty SIco's to uma unc of Wallasley fer that purpose. test in Cecae.ber and hereby Autherl:os its evn personnal, ce BICO should ha prepared have been r,1ccat4d fr:: Welleelcy by Dacember, all MHC functions and uployaas' vill sites tha forthe Department vill assist in its efforta to identify new rece sono of 21ptien cantera. 'es also suggest tha.t 33C0 explors nearby the =aintsnance itary facilitita, dspct inincluding the National Cuard sita Wallasiny.

Massachumatts Highway Department-By __ f I Edvard TJ Corocran II Its Chief Counsel

. c: cirector, connissioner, Massachusotta Divisien ofMassachusetts tr.srgency Mana capital Planning and ocarations d/