ML20058B421

Discusses Util Evaluation of NRC Ofc of Inspector General Rept 90N-02

ML20058B421
Person / Time
Site:	Pilgrim
Issue date:	10/17/1990
From:	Bird R BOSTON EDISON CO.
To:	Carr K NRC COMMISSION (OCM)
References
90-124, PT-018, PT-18, NUDOCS 9010300189
Download: ML20058B421 (116)

Text

{{#Wiki_filter:Y l f oos a m s m Pdgrim Nucleer twxr State RockyRif Road Plymouth, Massachusetts 02360 I Ralph G. Bird Senior VKe President - Nuclear October 17, 1990 BECo Ltr. #90-124 i Chairman Kenneth M. Carr U.S. Nuclear Regulatory Commission j one White Flint North 11555 Rockville Pike Rockrille, Maryland 20852 i Docket No.: 50-293 License No DPR-35

Subject:

Boston Edison Company - Evaluation of NRC OIG Report 90N-02 i Dear Mr. Carr On July 23,-1990, the Office of the Inspector General.(OIG) transmitted OIG Inspection Report 90N-02 to you which responded. to allegations concerning the NRC Staff's October 14 and December 9, 1988 testimony on the status of-~off-site emergency preparodness for the Pilgrim Nuclear Power Station (Pilgrim Station). Although this OIG report is not directed at Boston -j Edison Company, we evaluated the OIG report because the underlying subject matter of the report: relates to' Pilgrim l Station. The evaluation.and its substantive conclusions are attached for your information. In preparing the enclosed evaluation, we conducted a detailed' review of - the record of the October '14 and December 9,1988 Commission. meetings, as well as a review of-relevant contem poraneous documents. The evaluation' addresses six areas in which the OIG concluded that the NRC Staff's presentations to'the Commission were inaccurate. Based on evaluation of these six areas, Boston Edison Company has concluded: { LT E .. y y 9 C A N z Epc q-G' gI cr

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A'Od/ 9010300189 901017 P DR ADOCK 05000293 Iff. P PNU _ _ ~

i a 'e U. S. Nuclear Regulatory Commission October 17, 1990 Page 2 (1) with minor exceptions, the information presented by the Staff was accurate; in thoso specific instances where Staff information was (2) unclear or in error, it was clarified or corrected prior to the Commission's December 21, 1988 vote on Pilgrim restart; and the Commission's December 21 restart decision was based (3) on full and accurate information on the status of Pilgrim off-site EP. The OIG Report did not address the present status of off-site However, since December of caergency preparedness for Pilgrim. 1988, the towns in the EPE and the Com.cnwealth, with extensive and unwavering assistance from Boston Edison Company, have-continued to improve the off-site emergency response program. This has been' demonstrated in a full scale exercise conducted in October 1989 and a remedial exercise of May 1990 in.which the two-deficiencies identified in the October exercise were remedied.- In meetings attended by Commonwealth officials, FEMA'repre-sentatives have stated that the Pilgrim program is the best in the region. Boston Edison Company believes that it has been conclusively demonstrated that the off-site program'at Pilgrim l providos reasonable assuranco that the health and safety of the l public would be adequately protected in the event of an emergency at Pilgrim Station. [ lajt,,. R. Bird I t / Enclosure cc S,ee Attached Sheet O

l U. S. Nuclear Regulatory Commission October 17, 1990 Page 3 cc Commissioner Kenneth C. Rogers U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, Maryland 20852 Commissioner James R. Curtiss i U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville,' Maryland 20852 Commissioner Forrest J. Remick U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, Maryland 20852 Mr. William T. Russell Associate Director for Inspection and Technical Assessment Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Thomas E. Murley Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Frank J. Congel Director, Division of Radiation Protection and Emergency Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555-Mr. Steven A. Varga, Director Division of Reactor Projects - I/III Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory. Commission Washington, D.C. 20555 l (- f 1 --s

U. S. Nuclear Regulatory Commission October 17, 1990 Page 4 Mr. Robert A. Erickson 4 Chief, Emergency Preparedness Branch U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Ronald B. Eaton Project Manager Division ol Reactor Projects I/II Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. John B. Macdonald Senior NitC Resident Pilgrim Ituclear Power Station Rocky Hill Road Plymouth, MA 02360 Mr. T. Martin Regional Administrator U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 j Mr. Richard Strome Regional Director Federal Emergency Management Agency J. W. McCormack Post Office & Court House Boston, MA 02109 ( I l l t c ye---, a

l I l l BOSTON EDISON COMPANY l EVALUATION OF NRC OIG REPORT 90N-02 i n i i OCTOBER 17, 1990 h -r-e.e..,-

Ia I sosTon torson cournur EVALUATrom or mac OIG REPORT 90M-02 On July' 23, 1990 the Nuclear Regulatory Commission's (NRC) Office of the Inspector General (OIG) transmitted to the Commission its report examining certain_ elements of the NRC 3 Staff's review of the Pilgrim offsite emergency preparedness program (OIG Report). The OIG Report concluded that: 1. the NRC Staff's assessment of-the offsite emergency preparedness program was "not balanced or thorough"; and. 2. certain information provided by the Staff concerning the' status of Pilgrim offsite emergency preparedness during the October 14, 1988 and December 9, 1988 Commission meetings "was inaccurate." i I OIG Report, p. 3. The purpose of this evaluation is to provide Boston Edison's assessment.of the facts at the time the Staff's .[ l testimony was given. It appears that, with minor exceptions, information presented by the Staff to the Commission was i accurate. Those exceptions were corrected or clarified prior to the Commission's December 21, 1988 Pilgrim restart. vote, so that the Commission made its decision based on full and accurate information on the status of Pilgrim offsite emergency planning.- Boston Edison's evaluation was conducted by reviewing is the OIG Report and identifying those areas in which the10IG l I

l P - concluded that the Staff's presentations to the Commission were inaccurate. Six such areas 1/ were identified as follows: 1. Status of Emergency Implementing Procedure Completion 2. Saguish/Gurnet Beach Population Estimates 3. Tides and Access to saquish 4. Status of Letters of Agreement 5. Status of the Public Information Brochure i' 6. Estimates of the Special Needs Population For each of these six areas, this evaluation provides: 1. A description of the NRC Staff statements made at the October 14 and December 9 meetings which are-alleged to be inaccurate by the OIG; 2. A description of the OIG comments which discuss-the alleged inaccurate information; and 3. Boston Edison's understanding of the facts relevant to the particular area. In addition, two Appendices to this evaluation provide: s 1. relevant quotations from the transcript of the October 14 and December 9 meetings which are 4 1/ One area addressed at some length lin the OIG Report is the Staff's representations regarding the extent'to which it met' i with local officials and interested citizens to discuss their emergency planning concerns. OIG Report, pp. 3-4, 11-14. Because any such statements would obviously have been made on the basis of the Staff's own knowledge of those meetings and contacts, this report cannot address that aspect of the OIG Report. f a s m c

w alleged to be inaccurate by the OIG; and 2. relevant quotations from the OIG Report which discuss the alleged inaccurate information'. Appendix II: [ 1. documents (or excerpts thereof) referenced or cited in this evaluation; and 2. other related documentation not referenced in this evaluation but which may provide relevant context for one of the six areas. 1. status of===rgency Inni-- nting Procedura Pa=_nlation Dr. Bellamy of the NRC Staff testified'on-October 14, 1988 that implementing procedures for three EPZ' communities and I the two reception center communities had been forwarded to the Commonwealth of Massachusetts (Commonwealth). In addition, one of the EPZ town's and the two reception center communities' procedures had been forwarded to FEMA-fort a technical review. 'He also testified that of the approximately 300 required implementing procedures, five procedures from Duxbury and Plymouth had not been forwarded to the Commonwealth for review. October 14 Tr., pp. 81-82, 86. On December-9, 1990, Dr. Bellamy testified that the status of emergency plans, procedures, and other documents was consistent with the status as presented'by the NRC Staff on October 14, 1988. He also noted that the emergency plans for-Plymouth andLDuxbury had been submitted to MCDA'and FEMA for ~

i 'l, review and that several school committees had yet to approve-school implementing procedures. December 9 Tr., pp. 167-69. This testimony was criticized in the OIG report because allegedly, the NRC Staff learned the status of emergency implementing procedures from Boston Edison'and-failed to discuss the status of these procedures with local officials.- OIG Report, 1 pp. 3-4; See also pp. 11, 14. The OIG Report alleges two inaccuracies in the Staff's testimony.. First, the OIG Report states that, contrary to Dr. Bellamy's statements that all but five implementing procedures had been sent to the State, none" of the implementing procedures for the Towns of Plymouth or Duxbury had been l " approved for submission to the State." OI3 Report,-p. 4. The OIG Report is correct in this respect. As the Staff has acknowl-edged, Dr. Bellamy's statements were in error. As of the October 14 meeting, neither Plymouth nor Duxbury officials had authorized the transmittal of any of their implementing procedures to.the Commonwealth. What Dr. Bellamy apparently intended to say was that five procedures had not yet been formally reviewed for implementability by local agency heads. 2/ In fact, just before making the inaccurate statement at the October 14 meeting, Dr. Bellamy correctly stated that implementing procedures for 2/ Completion of such formal reviews for implementcollity was a prerequisite to transmittal of the full sets of implementing procedures from the towns to the Commonwealth. i J ,r y..- s-

_ 1 only "three of the EPZ comatunities [Kingston, Carver and Marshfield] and the two reception communities [Bridgewater and Taunton) have. been forwarded to the Commonwealth. October 14 Tr., p. 81. As the OIG Report acknowledges, the NRC Staff revised and corrected Dr. Bellamy's October 14 statements =in transcript corrections submitted to the Commission in a November 15,.1988 memorandum. 3/ OIG Report, p. 14. Thus, by the time of the Commission's vote on Pilgrim restart on December 21, 1988, the Staff had recognized and corrected the inconsistency in its-October 14 testimony. l The second aspect of the Staff's testimony on=the [ status of the implementing procedures which the OIG finds to be l I inaccurate is Dr. Bellamy's statement during the December 9 meeting that "[s)everal school-committees have yet to approve the [ school implementing) procedures." December 9 Tr., p. 169. The OIG Report asserts that in fact "none of the school committees had approved these procedures." OIG Report, p. 14. This-statement in the OIG Report is erroneous, the Staff's statement l was accurate. As reflected in the October 5, 1988 letter from Mr. Mazzilli (Carver. Civil Defense Director) to Mr. Peter Agnes (Massachusetts Assistant Secretary of Public Safety), the Carver 3/ Memorandum from V. Stello, Jr. to Commissioners " Pilgrim Status Update" (Nov. 15, 1988) (November 15 Pilgrim Status 4 Update).

school committee had authorized the school implementing procedure to be forwarded to the Commonwealth and Federal authorities. No j such authorization was given by the other EPZ town school committees. However, as reflected in the October 5,1988 lette-from Mr. Valla (Chairman of the Kingston Board of Selectmen)'to Mr. Tavares (Kingston Civil Defense Director), the Kingston Selectmen authorized the Kingston school department procedure to be forwarded to the Commonwealth, although the school committees were still reviewing it and intended to resubmit a revised-procedure. And, the Marshfield Selectmen had transmitted the school department procedure to the Commonwealth for informal. technical review. Letter from D. McGonagle (Marshfield' Civil-Defense Director) to R. Boulay (Director of Massachusetts Civil Defense) (Aug. 12, 1988). In conclusion, on November 15 the NRC Staff corrected the inconsistency in its October 14 statement regarding submittal-of the implementing proceduren to the Commonwealth.

Secondly, the Staff's December 9 statement regarding school committees' approval of the school implementing: procedures was accurate.

2. Saquish/Gurnet Beach Population Estimates At the October 14 meeting,'Dr. Bellamy engaged in a discussion with Commissioner Carr about the beach population'on Duxbury, Saquish,_and Gurnet beaches. Dr. Bellamy described the-population on the beaches and how the emergency: plans and 4 procedures had been developed to account for the population on

'l i 1 these beaches. October 14 Tr., pp. 97-98. The OIG Report took l issue withs (1) Dr. Bellamy's testimony with respect to the size of the population on the beaches and why the Staff did not use certain larger population figures suggested by some local l citizenar and (2) Dr. Bellamy's failure to mention that there are 1 summer homes on Saguish Beach, and that some people do remain on Saquish Beach overnight.- OIG Report, pp. 5, 40. The Staff's testimony and the statements in the OIG Report can be better understood by first defining the specific geographic locations in question. A map of these areas, Figure 1, is attached. The Saguish Beach /Gurnet Point area is at the end of a five-mile peninsula. The approximately three-mile i stretch leading up to Saquish and Gurnet beaches is called Duxbury Beach. There are approximately 200 homes on the peninsula, and they are virtually c.11 on Saquish or Gurnet. With few exceptions, these homes are summer cottages not served by power, water, or telephone companies. The roadways that access the Saguish area are periodically separated from Duxbury Beach and Gurnet Point by high tides which flood those roadways during a full moon. Access to Saquish/Gurnet is limited (by a seasonal security checkpoint) to residents and guests, who need four-wheel drive vehicles to reach this part of the peninsula. The Duxbury. Beach is open to the public, but population is limited by the fact that only 500 permits are given out for four-wheel drive i l

H ' vehicles to enter the beach area, and by about 1,800 vehicle parking spaces near the entrance to the beach. Thus, in discussing population estimates, numbers of " overnighters" and the effects of high tides (discussed in the next section of this evaluation), it is important to understand specifically which locations on the Duxbury Beach /Saquish/Gurnet i area are being addressed. When the Staff spoke of a beach population in the thousands and limitations on the number of vehicles to 500, it appears to have been discussing the Duxbury Beach population. Similarly, its response to Commissioner Carr's i question that no one overnighted on the beaches also apparently referred to Duxbury Beach. The Staff's references to residents and a summer population of around 700 persons apparently refer to the Saquish/Gurnet area. Finally, its references to the effects r of high tides-relate to egress from the Saguish Beach area. With respect to the criticism in the OIG Report of'the l l Staff for not having used the larger' population' figures suggested l by some local citizens, the Staff apparently obtained their t population estimates from a number of. sources. The relevant portions of the Staff's October 14 testimony (as annotated by the l Staff in the November 15 Pilgrim Status Update) contain references to numerous supporting documents provided by both Boston Edison and local authorities. 1/ A/ The relevant Boston Edison documents cited are the (1) October 26, 1987 letter from Boston Edison to Peter (continued...) l l l ~.

l .i g j The October. 26, 1987 " Pilgrim EPE Public Beach Population AnalysJ4" documented a flyover which. captured.on photograph En actual count of the number of persons on the.- .j Duxbury and Saquish Beachess on July 5, 1987. The flyover showed-l 4,583 people on Duxbury Beach and 654 people on Saguish/Gurnet Beach under " ideal beach weather' conditions"-(85 degrees, clear, sunny, low humidity). Boston Edison's June 30, 1987 letter. provided generally consistent population estimates for Duxbury Beach (i.e., 4,200 persons). Finally, the 1988 Evacuation Time Estimate (ETE) also provided the same documented population data contained in the October 26, 1987 " Pilgrim EPZ Public Beach Population Analysis (4~,583 persons at Duxbury Beach and 654 l persons at Saguish Neck). 1988 ETE, pp. 2-15, Table 2.3. Prior to the December 9 meeting, the Staff received l additional information from local sources which was generally consistent with the data provided by Boston Edison as-well as some information which did not appear to be consistent. -For example, the NRC was told by Mr. Martin (head of the Duxbury Department of Lands and Natural Resources)-that the typical. number of persons at Duxbury Beach would number.about 3,000.- Mr. 1/(... continued) Agnes forwarding " Pilgrim EPZ Public Beach Population 1 Analysis";-(2) June 30, 1987 letter from Boston. Edison to-Peter Agnes regarding information to. resolve concerns in FEMA Self-Initiated Review; and (3)' August 25, 1988 " Pilgrim Station Evacuation Time Estimates and Traffic Management l Plan Update" Rev. 0 (1988). Corrected October 14 Tr., pp. 97-99,.-nn. 27-28. L i

.. ~. ,.n. n . ~. n. .. Martin also told the Staff that the number of people in the area cut off by tides (Saquish) was 400-500. Memorandum from W. Lazarus and R. Hogan (NRC) to W. Russell (NRC Region I) (Nov. 4, 1988). According to a November 1, 1988 memorandum from W. Lazarus and R. Hogan to W. Russell, C. O'Neill, the'Duxbury Civil Defense Director, told Mr. Lazarus and Ms. Hogan that, "some of the estimates regarding the Gurnet-Saquish beach area he has seen have been inflated. He estimated the number for the Saguish Beach at about 4,000 maximum (2,000 typical) on peak days." Memorandum from W. Lazarus and R. Hogan to W. Russell (Nov. 1, 1988) (Duxbury) at p. 3. In addition, a September 30, 1988 letter to the NRC Staf f from Ms. Mary Ott and.Ihr. Donald Muirhead, Jr. forwards a report from Mr. David Quaid citing a population of 3,500 people "on Saguish Beach" on July 3, 1988. An estimated population of 2,000-4,000 people for Saquish/Gurnet appears to be too high. In fact, as discussed above, this figure is consistent with data for the entire. peninsula based upon Boston Edison's actual population count and the estimates for Saquish Beach alone should be considerably-( lower. According to the Plymouth Assessor's Office, there-are 209 houses on Saguish/Gurnet. Therefore, in order'for 2,000-4,000 people to be cn1 this beach, each home would have to be i l hosting 10-20> people. The OIG Report also states that the Commission may have. been misled by Dr. Bellamy's failure to mention the overnight

t residents of Saquish Beach (who would therefore potentially require evacuation 24 hours a day). OIG Report, p. 40. In an i October 25, 1990 memorandum to Chairman tech, Mr. Stello describes a telephone conversation between himself, Mr. Russell,- other NRC Staff members, and Mr. Hadfield, the Plymouth Civil 4 Defense Director. Mr. Hadfield expressed concern over the-fact that some residents lived at the beach year-round, and only-transients did not stay the night. In his October 25 memorandum, Mr. Stello stated "Mr. Russell-assured (Hadfield]'that (the NRC) understood that, [there are year-round residents) and.that the discussion in the transcript related to the transient beach population only and not to permanent residents." Memorandum from= V. Stello to Chairman Zech (Oct. 25, 1988) p. 2. This-communication to the Commission should have corrected any l misimpression that may have been created by the Staff's earlier testimony. In conclusion, the testimony provided by the Staff appears to have been based on the 1988 ETE and Boston Edison's October 26, 1987 Pilgrim EPZ Beach Population Analysis. While other estimates exist, there is nothing in either the OIG Report or any of the documents reviewed which suggests that those other estimates are more accurate than~those upon which the Staff relied. Furthermore, the Staff's failure to mention on. October i 14 the overnight residents of Saquish Beach was'due to the discussion at that point being focused on only the transient-

e l beach population. If this resulted in any misunderstanding, it was explicitly corrected in an October 25, 1988 memorandum to the 'I Commissioners. l 4 3. Tiden Accomm to Bannish l At the October 14 and December 9 meetings, Dr. Bellamy l reported on the length of time that high-tides isolated Saquish Beach from Duxbury Beach and Gurnet Point. October 14 Tr., p. 98; December 9 Tr., pp. 177-78. The OIG Report concluded that his comment at the October meeting was an understatement-and that the Staff had information from a credible source that indicated-that Saquish Beach was isolated for a longer period of time. 'OIG. Report, pp. 13-14. l Dr. Bellamy's statement at the October 14 meeting that the tides " isolate" Saquish for approximately_four hours a month may possibly have been based upon the following statement in. Boston Edison's October 7, 1988 Response to-the draft report, "A Report on Progress Made in Emergency Planning for Response to an I Accident at Pilgrim Nuclear Power. Station" (Response to 1988 l i draft Barry Report): 5/ l [T] hat condition (high tide flooding of'the roadway)_ occurs on approximately two days a j month for about two' hours on each occasion, j a 5/ Our assumption that the Staff may have relied on that j particular Boston Edison communication is based.upon the j fact'that the Staff's corrections to the October 14 3 transcript' cite, among other documents,cBoston Edison's l ~ Response to'the 1988. Draft Barry Report.- San Corrected ) October.14 Tr., pp. 98-99, n. 28. j l q I

~ _ _ 1 I I Response to 1988 draft Barry Report, p. 38. If one failed to recall that there are two periods of high tide in any 24-hour period, one might conclude, based on the above statement, that lunar high tide conditions exist for about four hours.per month. Boston Edison's best estimates are that the road is flooded for a' 1 total of about eight hours a month, not four, since there are two 1 high tides a day. In any event, while neither the source nor the basis for Dr. Bellamy's October 14 statement:ia readily_ apparent,. he accurately stated the status of the issue in his December 9 testimony. The clarified information reported in the December 9 meeting apparently came directly from the November 4, 1988 memorandum from Mr. Lazarus and Ms. Hogan-to Mr. Russell regarding their tour of the beaches =with Mr. Martin of the Duxbury Departmentlof Lands and Natural Resources. Despite the statements regarding Saquish Beach being " isolated" or the road being " impassable," it is not expected that flooding of the access road for approximately.two hours during peak periods of lunar high tides would have any significant adverse effect on evacuation of the people on Saquish Neck. First, passage over the dunes themselves by vehicle or by foot would be possible (although the dunes are environmentally . protected areas). Secondly, the individuals on Saquish Neck-l typically are residents or guests of residents and could' therefore take shelter in their residences during the m- = -

- 14.. i approximately two hour tidal flooding period. Finally, even if it is assumed that flooding delayed movement of the Saquish Neck population for approximately two hours, their maximum estimated evacuation time would not significantly increase. The calculations derived from the BTE show that the maximum estimated evacuation time for Saquish Neck would be about five and a half hours, whereas the maximum estimated evacuation time for the EPZ population as a whole is about seven hours. Therefore, the-addition of approximately two hours would result in a maximum evacuation time that is not significantly different from that for other residents of the Pilgrim EPZ. In addition,11f-the Saquish Neck population was delayed in evacuating by approximately two hours, it would arrive at the normally more congested inland-points along the evacuation route at a later time when the roads would not be as congested. Therefore, all or at least part of I the time lost by flooding could be regained at these critical points along the evacuation route and the total evacuation time for the Saguish Neck population would-increase.little if at-all as a result of the tidal flooding. 4. Status of Letters of Agramment q At the December 9, 1990 meeting, Dr. Bellamy stated that the-form and content of letters of agreement (LOAs) had been approved by the Commonwealth and that LOAs had been executed for ~ 34 of 35 transportation providers. December 9 Tr., p. 172. The 1 OIG report stated that the NRC Staff did not confirm with the

) Massachusetts Office of Public Safety that the form:and content of LOAs had been approved by the Commonwealth and that the. Staff received inaccurate information on the status of LOAs between the Commonwealth and transportation providers. OIG Report, pp. 12, 14. Dr. Bellamy accurately reported the status of the LOAs to the Commission. The form and content of the LOAs had been approved by the Commonwealth. By letter dated October 10, 1988, Massachusetts Assistant Secretary.of Public Safety, Mr. Peter Agnes, transmitted to Mr. Varley, Boston Edison Emergency Preparedness Manager, an approved draft LOA on letterhead of the Massachusetts Executive Office of'Public. Safety, and encouraged Mr. Varley to move swiftly to assure that the LOAs were completed and signed by transportation providers. On October 21, 1988, Mr. Varley wrote to Mr. Agnes explicitly informing him that Boston Edison would "obtain concurrence on the commitment letter. . in the format provided to us by your office." Mr. Varley also attached the authorized format and informed Mr. Agnes that if he had any problems with Boston Edison's approach to contact him. No such contact was j made and the LOAs were subsequently executed by the-transportation providers. Dr. Bellamy's statement that 34 of 35 such LOAs had been signed was also accurate. Prior to the December 9 meeting, 1 Boston Edison staff had just completed obtaining all but one of l

a u - the requisite signatures and had forwarded them to the 3 Commonwealth. Letter from R.A. Varley to Peter.Agnes, Jr. (Dec. 1, 1988). Mr. Varley's December 1, 1988 letter to Mr. Agnes transmitted 32 of the LOAs and noted that-two additional LOAs had been directly forwarded to the Commonwealth by the transportation providers. The OIG Report states that the Commonwealth subsequently disagreed with the statements made by-Dr. Bellamy regarding the status of the LOAs. The basis for that disagree-ment is not apparent, as the LOA-format specified by Mr. Agnes is still being used as of the date of this evaluation. In short, i Dr. Bellamy's statements regarding the status of the LOAs were, l and continue to us, accurate. S. Public Information Brochura Dr. Bellamy reported in the December 9 meeting that the Public Information Brochure (PIB) was being finalized and was on schedule for distribution in December. December'9 Tr., p'. 178.. The OIG Report claimed that this information was-not. confirmed with the Massachusetts Office of Public Safety before presenting it to the Commission. OIG Report,-pp. 12, 13. The status of the PIB in early December was as reported by the NRC Staff. Subsequently, however, the Massachusetts Civil Defense Agency (MCDA) delayed printing, as it had on numerous previous occasions. By letter dated-November 8, 1988,100. Varley informed Mr. Boulay (MCDA Director)-that Mr. Agnes had " expressed

a strong desire to publish the [PIB) prior to the end of this year." In order to carry out Mr. Agnes' desire, Boston Edison-transmitted to MCDA a schedule for completion of the PIB. -Letter from R. Varley to R. Boulay (Nov. 8,-1988). At that time,-two substantive issues remained outstanding:.the manner in which-the 1 Wellesley reception center would be characterized in the PIB, and the content of language describing the nature and effects of-radiation. As of December 8, 1988 (the day before the Commission -1 meeting), these two issues apparently had been resolved.- Letter from R. Varley to R. Boulay (Dec.-8, 1988). The attached schedule called for receipt of the " typeset mock-up" by 4 December 9, 1988 and provision of the PIB to the "mailhouse for mailing" by December 29, 1988. As of December 9, 1988 the PIB was, in fact, at the printers for typesetting and was on schedule for a December 29, 1988 distribution. SAR Memorandum from J. Phillips to J. Bachman (Dec. 9, 1988). According.to the schedule set forth in Mr. Varley's Decembe-8 letter, Boston Edison expected MCDA to do one final proof on December 12, 1988. Boston Edison presented the typeset j document to Mr. Hausner and Ms. Brown _of MCDA et a December 12 4 meeting. According to the' meeting notesiof a Boston Edison planner in attendance, they refused to review it, informed. Boston Edison that Mr. Slaney (also of MCDA) had to review it, and that the five EPZ town Civil Defense Directors had to approve 1

. it as well. Offuita EP Meeting Record from J. Phillips to Pile (Dec. 12, 1988). As documented in Mr. Varley's December 19, 1988 letter to Mr. Boulay, McDA's additional requirements were unexpected prior to the December 12 meeting with MCDA. Therefore, as of December 9, neither the NRC nor Boston Edison had any reason to expect that MCDA would not proof and i approve the final copy on December 12th. As documented in contemporaneous Boston Edison correspondence, the Staff's teati-mony was in accordance with the facts and circumstances as they i were understood by Boston Edison at the time. 6. Rati=ates of t>m special Maeda population At the December 9 meeting Dr. Bellamy reported that identification of the special needs population in the EPE was based on input from Civil Defense Directors and that the numbers received from the Civil Defense Directors compared favorably to the expected number of special needs population for the EPE. December 9 Tr., pp. 175-76. The OIG Report stated that the NRC Staf f was awar.c of the information in the " United St tes Disability census" indicating that the expected number of special needs persons in the total population was higher than the number provided by the Staff to the Commission. OIG Report, p. 12; Saa also OIG Report, p. 34. 1 The Staff's testimony makes clear that its primary sources for special needs population information were the local Civil Defenes Directors and not Boston Edison. The Staff

o i 6 confirmed these estimat s by using overall EPE ponulation data from the 1988 ETE, and multiplying that data by the percentage of the general population expected to have an impairment which would affect the performance of their activities. That percentage was set forth in a document authored by ECDA ("A Guide for Updating Local Comprehensive Emergency Management Plans to Meet ' SARA' Title III Requirements", Annex N). Thus, the sources of the Staff's information are identified in their testimony. The OIG Report states that the Staff was made aware of conflicting information on the sir.e of the special needs population. While we are not aware of whether the Staff had been apprised of such information prior to the December 9 meeting, we understand that the Staff has only recently (within the last j month) located the referenced United States Census survey. This survey encompasses broad-sweeping disabilities and functional l limitations, many of which do not correlate to an ability required to receive or understand an emergency instruction or to take a recommended protective action. Furthermore, the census survey includes disabled persons who have a relative, friend or neighbor who would provide assistance during an emergency, although such persons are not included in the special needs population for purposes of an emergency at Pilgrim Station. Therefore, the Census survey is not specific enough to be of use in accurately estimating the special needs population in the Pilgrim EPZ.

1 1 I I 1 j 4 In short, at the December 9 meeting, the Staff provided information on the size of the special needs population that was l derived from the local civil Defense Directors themselves. The Staff confirmed those estimates with general population estimates i from the 1988 ETE multiplied by an " impairment" factor contained [ l in an MCDA planning document. This was, at the time of the i Staff's testimony, the best information available on the sise of the special needs population. conclusion Most of the information presented to the Commission by the Staff at the October 14 and December 9 meetings was, to the ] best of Boston Edison's knowledge, accurate. Minor aspects of that information were (as previously acknowledged by the Staff) in error or confusing. The Staff took measures to corrwet or clarify its statements in its corrections to the October 14 transcript and in its December 9 testimony so that by December 21, 1988, when the Commission voted to restart Pilgrim, the Commission made its decision based on full and accurate infor-mation on the status of Pilgrim offsite emergency preparedness. i i . ~ _

1 I I e APPENDIX X l i 1. status of *==raaney imn1===ntina Procedure ea=_alatian Dr. Bellamy of the NRC Staff testified on October 14 as follows: Implementing procedures foe three of the EPZ communities and the two re>;eption I communities have also been fo.'twarded to the 1 Commonwealth and of these, tre procedures for 1 one of the EPE [ Emergency Plunning tone) communities and the two reception communities i have been forwarded to FEMA fer a technical J review. There are five procedures for two EP3 communities for Plymouth and Ducksberry [ sic) that, although prepared, have not yet been approved by the local officials for forward-ing to the Commonwealth for technical review. There are approximately 300 as a round number of required implementing procedures and as I indicated, there are five of those procedures that have yet to be sent to the Commonwealth with any type of approval from the local officials. October 14 Tr., pp. 81-82, 96. On December 9, Dr. Bellamy further testified: The status of emergency plans, implementing procedures and other supporting documents for i the five towns within tne 10-mile EPE and the two reception communities, is consistent with the status presented by the Staff on October 14, 1988. ,--msv

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i t i The emergency plan, implementing procedures, and shelter implementation program from Marshfield, Carver and Kingston have been submitted to the Massoci.'asetts Civil Defense Agency and forwarded to FEMA i for a technical review. The emergency plan and implementing procedures for Taunton and Bridgewater have 3 been submitted to MCDA and forwarded to FEMA for a technical review. The smergency plan'for Duxbury and Plymouth has been submitted to MCDA and forwarded to FEMA for technical review. For Plymouth and Duxbury, the procedures are not complete. Several school committees have yet to approve the procedures. December 9 Tr., pp. 167-69. This testimony was criticized in the OIG Report as follows: l The NRC Staff learned from BECO that all emergency implementing procedures for the EPE communities had been submitted to the State for technical review with the exception of five procedures for the Towns of Plymouth and (T)he staff reported this Duxbury. status and concluded that it evidenced considerable progress towards resolution of emergency preparedness issues. Had NRC i staff discussed the status of the emergency implementing procedures with local officials, they would have learned the information was not correct. According to Plymouth and Duxbury officials, none of the implementing procedures (about 130 procedures) for these communities had sven been approved for sub-i

i ? l ! l l l mission to the state. In fact, many of these procedures were still being developed. [T]he staff reported to the Commission i that several EPz school committees had yet to approve the school implementing procedures. This statement was inaccurate because, as the i staff learned. . during late October and early November 1988, nons of these school committees had approved the procedures. (OIG 4 Report, p. 14; ama also p. 43-44) [S)chool committees were either still developing draft procedures or had gone on record as disap-proving those draft procedures presented to them for review. OIG Report, pp. 3-4, 14, 44; ama also OIG Report, pp. 11, 14. 2. amanish/nurnet anach penulation Ente =mten At the October 14 meeting Commissioner Carr and Dr. Bellamy were discussing people who travel to the beach for l the day as follows: i i [Bellamy). There are a fair number of permits that are issued to those four-wheel drive vehicles. The number is in the several thousands and they have made sure that the plans and procedures indicate that those beaches will be closed at an early stage so that you would not put more people on those beaches if there is any type of event at the Pilgrim Station. Commissioner Carr Do they overnight on those beaches? Bellamy No, sir. They do not. j October 14 Tr., p. 97. The conversation then turned to a discussion of high tides and egress from the beach and Dr. Bellamy told Commissioner Carr that the tides are only an issue.

4 4 for a very small section of that beach and there are approximately 2,000 to 4,000 people at the most that would be there during a bright, sunny, summer weekend. October 14 Tr., pp. 97-98. At the December 9 meeting, Dr. Bellamy stated: An issue that the Staff'has continued to i review in detail is the emergency planning, specifically the evacuation concerns for the Saquish/Gurnet area and the Duxbury Beach south of Powder Point Bridge. f r The town of Duxbury, particularly the i Department of Land and Natural Resources, has the necessary resources to effect an evacua-tion of this area, and this department head believes a peak population for this area is 4000, with 3000 being typical. The head of the Duxbury Department of i Land and Natural Resources has stated that accoss is limited from the Powder Point Bridge south to 500 vehicles, and is strictly enforced. Access to the Saquish/Gurnet area is linIted to the residents and summer popula-tion is less than 700. There are very few l year-round residents, l December 9 Tr., pp. 176-77. The OIG Report took issue with.the Staff's testimony.as follows: [T.1he NRC staff told the Commission that the Sar,aish Beach summer population was less than ',00. The NRC staff did not recall the source of this population figure, and they-could not explain to us why they thought it was more accurate than the. larger numbers made available to them by local citizens. a --.--,,,~,.w a r, ~,,, --w-

1 I i I J , a i, In response to a Commissioner's direct question, the NRC staff reported that no one remained on Saguish Beach overnight. This statement is Jnaccurate because the staff member did not clarify that there are several l hundred homes on Saquish Beach, some of which i are occupied 24 hours a day. (OIG Report, p. 13) By the staff's failure to mention the i 1 700 residents who remain on the beach i overnight Commissioner Carr was left with mistaken impression that evacuation was a problem that could only occur during daylight a hours. OIG Report, pp. 5, 40. I 3. Tiden and hecame to snaulah At the October 14 meeting Dr. Bellamy reported that [T] hose beaches are [ isolated) only approximately four hours a month. October 14 Tr., p. 98. At the December 9 meeting he stated that: The area of the road between Saquish and i Gurnet has been identified as impassable due to periodic high tides for perhaps two hours during consecut1Em high tides, for two days each month, and this is during a full moon. The Staff has returned to this area twice since the October 14, 1988 meeting and our conclusions are based upon direct i observation of the area and information provided presented by the Duxbury' head of the Department of Lands and Natural Resources. December 9 Tr., pp. 177-76 (emphasis added). The OIG Report found that J [T]he Staff's comment during the October meeting that during monthly-lunar high tides Saquish Beach is isolated for four hours a l

l ) J -g. I l I [T]he month was an understatement. Staff had information from a credible source that indicated a more accurate figure was at ] least 20 hours a month. OIG Report, pp. 13-14. i 4. Status of Latters of Aare-- at At the December 9 meeting Dr. Ballamy made two comments about the Letters of Agreement (LOAs): i i The form and content of the letters of agreement are now approved by the 4 Commonwealth. To date, letters of agreement have been executed for 34 of the 35 transportation providers. d December 9 Tr., p. 172. With respect to the status of LOAs, the OIG Report states (T]he NRC Staff informed the Commission i that the form and content of the Letters of Agreement between the State and transporta-tion providers had been approved by tTe State The NRC Staff did not confirm this information with the Massachusetts Office of Public Safety before presenting it to the J Commission. Massachusetts officials later disagreed with these statements. [T]he Commission received-inaccurate information during the December meeting concerning the status of. . the Letters of Agreement between the State and l transportation providers. OIG Report, pp. 12, 14. 1 c

l 1 i i i i I, l i 5. statum of the Public Information Brochure I With respect to the Public Information Brochure (PIB), Dr. Bellamy reported at the December 9 meeting that: 1 i (T]he Staff is aware that the public information brochure has not been issued j since September 1986. An interim brochure was issued in December 1987. The language in the upcoming public information brochure has been approved by the Commonwealth. The brochure is being finalized, and is on schedule to be distributed in December 1988. ) December 9 Tr., p. 178. The OIG Report statest The NRC Staff did not confirm this information with the Massachusetts Office of Public Safety before presenting it to the commission. Massachusetts officials later disagreed with these statements. i . Had the staff taken ths time to confirm the information obtained from BECo they would have learned that progress toward resolution of these outstanding issues [ Including the public information brochure) wits not as advanced as they reported to the Coe. mission. OIG Report, pp. 12, 35. i 6. Estimatan of the apaelal Maeda population With respect to estimates of the special needs j i population, Dr. Bellamy reported at the December 9 meeting that Identification of the special needs population,. based on input from the Civil Defense Directors, is a total of 686 individuals in the emergency planning zone. And I do have that broken down by town. This total number compares favorably to the expected number of special needs 4

1 i ; i population for the EPZ, which is 647 individuals, based on an EPE population of ( 70,274 and a total expected percentage of impaired individuals of 0.92 percent. December 9 Tr., pp. 175-76. The OIG Report states that the Staff was aware of information in the United States i Disability Census indicating that the expected number of special needs persons in the total population was many times higher than the number provided by the staff to the j commission. OIG Report, p. 12; see also OIG Report, p. 34. l t l l 1 i f k I 6 o P i i I -n

_ _ _ _,. y.__.___..__...__.._.._.__._.__.._.. I j 1 i i 1 1 1 APPENDIX II { Reference Documents for Conton Edison Company i Evaluation of 4 i NRC 010 Report 90N-02 J 1 1 i l F i 'l l i 4 l 1 O i l I b l I b, I 1 i t 7- ,,,.....m ...e., m._ .,,._,,m,., .y. ,,~.. ,.e.,

i 1 4 i i O L \\ 1 l STATUS OF EMERGENCY IMPLEMENTING PROCEDURE COMPLETION SUPPORTING DOCUMENTS l + 0 O q i

TOWN OF CARVER l, CIVIL DEFENSE Carver, MA 02330 004 5219 i October 5, 1988 l l 1 Mr. Peter Agnes, Jr. Assistant Secretary Executive Office of Public Safety One Ashburton Place Boston, Massachusetts 02018 l

Dear Mr. Agnes:

The draft report on the status of Pilgrim emergency planning should incorporate the following updates: l 1. Section VII. B should be updated to reflect that on October 4, the Carver l Board of Selectmen authorized submittal of an updated plan, implementing procedures, and shelter implementation plan to MCDA and FEMA. 1 2. Clarification of our position on access control during an evacuation may be I necessary (referenced on page 52h We realize there may be a need for J i residents working out of town to return home to pick up family members in an l emerency. He will strictly control access to Carver immediately following an evacuation recommendation, but during the first hour or so residents would be able tc return for family members. After the first hour or so after the evacuation notice, however, both the Pol-ice Chief and I feel strongly that no return to the evacuated area will be allowed except for emergency personnel. l 3. Regarding school committee sign-off of procedures, the school committee chairman has authorized all procedures to be forwarded for state and federal

• • review.

4. With regard to equipment -- The three school bus radios were. installed 9/28/88. Radios for Council on Aging have been ordered by BECo with delivery expected soon. BECo is awaiting additional information from the' Fire Chief to order the l remotes. 15 radios for the Police Department is a recent request and we are i awaiting an answer from BECo. BECo has ordered the storage vans with delivery expected soon. ) j 4

Mr. Peter Agnes, Jr. ) October 5, 1988 l Page Two i 00 would appreciate your prompt review of the plans and procedures soon to be submitted so that we may move forward with our EP program. Training is now i being scheduled with key response groups and we look forward to working with MCDA and BEco in an exercise and drill program to test our Plans. i Sincerely, rank i carver CD Director ) 1 FRM/hme cc: selectmen Dick Finn BECo l I i i i 1 2 i se

] \\ TOWN OF KINGSTON, MASSACHUSETTS j Offlee ei i h \\ 1 A THE 3ELECTMEN CNEteln 888 6 w movu sa se sner-smostoN. m ennu October 5, 1984 M"r. Dennis Tavares

• Civil Defense Director Office of Emergency Preparedness Town Hall Annex Sia Maple Avenue Kingsten, MA 02344

Dear Mr. Tavares:

The Kingsten Board of Selectmen has reviewed the draf t Radiological Z:norgency

Response

Plan and Implementin .Frecedures and are in basic concurrence with their cong tant and framework. We authorise you to submit this plan, proceduree and supporting material.in their present' fort.s .to the h seachusetts civil Defenie ~Assney 'a n d " ' ( the Tederal. Ltet gency Managment ' Agency for informal technical reviews. We understand these documents are \\ draf ts and are subject to change. i We ask that you forward these draft docurrents to the oppropriate state and federal agencies for their con structive reviews. We also ask that you indicate to l l these reviewers that our School Department Procedure l (27-06) is undergoing further scrutiny by the Kingston Elementa:mt school Committee, and we expect to resubmit i the current draft of IP-06 to include the committee's come:en ts. i si'cerely Y"5 Edward H. Valla i ChaLrman i Env/, Enclosures i ij

sv/I # i f-N /

k cowwowweao= or massacawssm i

August it.1984 Mr. Robert 3. Boulay Director Cor.xnwenith of MassachusettsCivil Defense Agency,& Cffice of E i Eastutive Department 1 4CC Wertester R046. Box 1496 j Framinghte., MA 01701-0317

Dear Mr. Boulay:

1 As the attachet letter indicates, the Marshfield Board of Se I to forsted to FEMA, through your office, the following documen oe technical review: ernal i Ten copies draft of.Narshfield A4diological Emergon'cy 4. Rev. 8. Jul 11, 1984 i b. Ten ecties tishfield Implementing Procedures. Tor, cocies Marshfield Shelter !aplementation Program S c. i c. Ten copies karshfiele Draft PILPJProtosure Cross Referenc I ) The Ortft Marshfield RERP ang !mplementing erocedures oferess anc M;;A 316r. co. vents safe to date. atest fEKA Civil Cefense Agency.The Sca'd has also inclutet three sets of do c usetts He would 4peratinte it if you would promptly forward these docu o FEMA. Very tru1y yours. .h1A:., _4 CanielMc[onag Civil Defense [01 rector i 2 Marshfield Scard of $electmen cc: Richtri Agnew. Tcwn Manager T. Retter. Director, NCDA Area !! (3) taclosures I v. A s t

I (. I SAQUISH/GURNET BEACH POPULATION ESTIMATES SUPPORTING DOCUMENTS (

~ 1 h mosnwaD50N tattutive Othces I 800 soylsten street Beston. Manachusetts 02199 1 October 26, 1987 i Ralph G. Bird senior Vitt hesictat - Nut l ear i Mr. Peter Agnes, Jr. Commonwealth of Massachusetts i Assistant Secretary of Public Safety One Ashburton Place - Room 2133 Boston, MA 02108 ~

Dear Mr. Agnes:

As you and I recently discussed, periodic submittal of the information developed in response to the issues identified in the Federal Emergency Management Agency's (FEMA) August 4,1987, "Self-Initiated Review and Interim finding for the Pilgrim Nuclear Power Station" ($1R) should facilitate FEMA's review of the resolution of those issues. Accordingly, we are forwarding a copy of a report entitled " Pilgrim EPZ Public Beach Population Analysis," dated October 14, 1987, which addresses subissues C.1 and C.2, as identified in the " Boston Edison Company Action Plan and Schedule for Providing Assistance in Addressing FEMA Issues," dated September 17, 1987 (Boston Edison Action Plan). We are also enclosing for your consideration a draft letter of transmittal to FEMA and a suggested distribution list. l In subissue C.1, FEMA requested, "(1) an updated geographical description of the beaches (within the Pilgrim EPZ) and their capacity." (Page 26 of SIR) The Boston Edison Action Plan (Page 14) stated that preliminary estimates of l the expected maximum number of people on the public beaches within-the EPZ had been developed and were being verified. It also stated that updated geographical descriptions of the beaches were being developed. The results of those efforts in response to FEMA's request are contained in the enclosed report. In subissue C.2 FEMA requested, "(2) a detailed analysis of the beach population, including the number of permanent and temporary residents and the number of day visitors, together with their geographical dispersion." (Page 26 of SIR) The Action Plan (Page 15) stated that the geographical dispersion of the population of each of the public beaches was being developed. It also indicated that a breakdown between permanent and temporary residents and day visitors did not need to be developed since the current planning process is based on the conservative assumption that sufficient sheltering capacity will be identified for the entire beach population. Thus, the enclosed report provides the information requested by FEMA as to geographical dispersion of the population on the public beaches within the EPZ.. l

~ 4 1 Mr. Peter Agnes, Jr. ) i Assistant Secretary of Public Safety October 26, 1987 i Page Two Please do not hesitate to contact either myself or Ron Varley at (617) 747-2544 if you have any questions, j 'vd . G. Bird 1 Enclosure cc: Mr. John Lovering Deputy Director MCDA 400 Worcester Road i Tramingham, MA 01701 Mr. Jeffrey B. Hausner MCDA 400 Worcester Road i Framingham, MA 01701 Mr. Steven A. Varga, Director Division of Reactor Projects - I/II office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 w/o draft letter attachment Mr. R.H. Wessman, Project Manager Division of Reactor Projects - I/II office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission j 7920 Norfolk Avenue Bethesda, MD 20814 Wessman - NRC w/o draft letter attachment U.S. Nuclear Regulatory Commission Region 1 - 631 Park Avenue King of Prussia, PA 19406 w/o draft letter attachment Senior NRC Resident Inspector Pilgrim Nuclear Power Station Rocky Hill Road Plymouth, MA 02360 w/o draft letter attachment 1

l 1 1 1 PILGRIM EPZ PUBLIC BEACH POPULATION ANALYSIS l l ) KLD Associates, Inc, j l ) i October 14. 1987 The purpose of this report is to respond to certain issues raised in the l 4 Federal Emergency Management Agency's (FEMA) August 4,1987 "Self-Initiated Review and Interim Finding for the Pilgrim Nuclear Power Station ($!R)." In 4 particular, the report addresses $1R subissues C.1 and C.2 as identified in the " Boston Edison Company Action Plan and Schedule for Providing Assistance in Addressing FEMA Issues" dated September 17. 1987 (Boston Edison Action Plan). l l Subissue C.) stated: FEMA and the RAC... must receive the following additional information: (1) an updated geographical description of the beaches and their capacity. Attachments A-G are relevant portions of United States Geological Survey quad sheets (modified as described under Subissue C.2 below) which identify each of the major public beaches in the EPZ as follows: Attachment A - Brant Rock Beach and Green Harbor Beach - Duxbury Beach Attachment C *Saquish Neck l I

Page 2 i ~ - Grays Beach l Attachment E - Plymouth Beach Attachment F - Priscilla Beach and White Horse Beach Attachment G - Manomet Beach ) i In addition, estimates of the expected maximum number of people on each of these beaches are contained on Attachments A-G and summarized below: Location Estimated canacity Brant Rock 1,211 Green Harbor Beach 2,609 ) Duxbury Beach 4.583 1 Saquish Neck 654 i Grays Beach 103 Plymouth Beach 1,960 l Priscilla Beach 430 White Horse Beach 2,387 1 Manomet Beach 655 i 14.592 i-o i 4 ? t j j i e~w~- v ww n--*1-vv vwe we+ - - - w - ~,, ,+--r -- + ~

Page 3 i These estimates were developed by counting the number of persons visible on aerial photographs of the beaches and adjacent off-bench areas (LA., paths, homes, parking areas) taken between about IPM and 3PM on Sunday, July 5, i i 1987. At least two independent counts were made for each beach and the highest count selected in each case. The photographs cover virtually all of the area of the major public beaches and each of the areas of high beach population density, On July 5 it was clear and sunny and the temperature was approximately 85 degrees with low humidity. Since July 5 was part of a three-day holiday l weekend during which Massachusetts beaches'likely reach capacity and the weather conditions were highly conducive to maximum beach usage, these numbers are considered to represent reasonable estimates of the maximum number of l persons expected on these beaches at any one time. Although those numbers could, of course, be exceeded on a given day, the excess would be expected to be small and not significant fo* emergency planning purposes. 1 Subissue C.2 states: \\ i (2) a detailed analysis of the beach population, including the number of l permanent and temporary residents and the number of day visitors, together with their geographical dispersion.- Attachments A-G contain histograms which identify the distribution of observed persons on each of.the beaches on July 5,1987. The histograms identify the i percentage of the total population that is located in approximately equivalent segments of each beach. For example. Attachment A depicts Green Harbor Beach and the percentage of the total population of 2,609 persons which is located-in each of 23 segments. l i 4 ,e ,,...,-,-e,. -,,,,,,,-.,,,r,--

l 4 1 f Page 4 Analysis of the population distributions shows that people tend no.t to travel l far from their parked vehicles. For example..on Duxbury Beach (Attachment B), approximately 60 percent of the beach population is concentrated along the 3/4 i mile segment of beach from the entrance to the Duxbury Beach parking field to-the area just south of the Powder Point Bridge. This area encompasses the two major beach parking areas. The remaining 40 percent of the beach-goers are distributed over the remaining beach south of the Powder Point Bridge. These i people have access to off-road vehicles. A total of 521 off-road vehicles were counted along this stretch of beach. This represents an average vehicle occupancy of 3.51 persons per off-road vehicle (0.4 x 4.583/521). Aerial photos of Saquish Neck (Attachment C) indicate that access to the area is achieved principally by automobile via the road from Duxbury Beach, or by boat, and that persons in the area have access to a vehicle, a boat, and/or 4 l one of approximately 200 residences. \\ Similar conclusions may be drawn for Plymouth Beach (Attachment E). Approximately 28 percent o.f persons at the beach are located along that section of beach abutting the parking facilities. The remaining 72 percent of l the beach-goers are distributed along the remaining portions of-Plymouth Beach in proximity to the 565 off-road vehicles counted. The average occupancy for Plymouth Beach off-road vehicles is 2.49 persons per vehicle (0.72 X l 1,960/565). Beach-goers at the other major public facilities (Brant Rock, Green Harbor, 4 Gray's Beach, Priscilla Beach, Whitehorse Beach, and Manomet Beach) all have ready access to adjoining roads where vehicles are parked. 4 i -,.r- -+ ... ~.. .m

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~ g. laecut.a O'hces ) 's 800 Boriston street BWV. t.'estach.sem 02199 t June 30, 1987 Ralph G. Bird EPC# 87-356 semo. vice prevoent.. wcu Mr. Peter W. Agnes, Jr. Assistant Secretary of Public Safety The Commonwealth of Massachusetts Executive Office of Public Safety One Ashburton Place Room 2133 Boston, MA 02108

Dear Mr. Agnes:

The attachments to this letter cre Emergency Preparedness Materials developed i recently by my staff based on our understanding of perceived weaknesses in offsite planning. We believe this information resolves the major concerns being addressed by the Federal Emergency Management Agency in their o self-initiated review: Beach Population and Sheltering Hobility Impaired and ~ Transportation Dependent Individn is, Special Facilities Planning and a . Northern Reception Center. 'We recommend that your. agency send,this information directly to FEMA for , consideration during their self-initiated review.. Prompt review of this 'information should preclude an unnecessary negative finding concerning offsite emergency planning for the protection of the. health and safety of the general public around the Pilgrim Station','and in turn avoid creating unnecessary public concern. I We also recommend that the Massachusetts-Civil Defense Agency use this information to update the State's Emergency' Plan and Procedures as well as those of the five towns with4n-the. ten mile Pilgrim Emergency Planning Zone, j 'He are. prepared to assist you i.n quickly achieving this objective. ~ [ JFC/cae .2 Attachments .e. 9 1 .q. g- ,p "- v, 3 e i e

3 cc: Messrs. ' Ronald Bellamy (with attachments) Robert Boulay ( ) David Canepa ( ). Joseph Costa - (- ) Daniel Daly (' ) Richard Johnson ( ) Richard Krimm (w/o attachments > William Lazarus (with attachments) Richard Levin ( ) David Malaguti ( ) David McLoughlin (w/o attachments ) Thomas Rodgers (with attachments) Hilliam T. Russell ( ) l Al Slaney ( ) Edward Thomas ( ) 4 Henry Vickers ( ) David Vogler ( ) t 4 e i ~ 4 l l l l-

I. Beach PoDulation/Shelterina A. Beaches and Pond Locations 1 Hithin Pilgrim Nuclear Power Station's-ten mile EPZ are five coastal-beaches, and three ponds which have been identified as being patronized by transients, and they are:. 1. Green Harbor Beach - M.rshfield 2. Duxbury (Blakeman's) Beach - Duxbury 3. Gray's Beach - Kingston 4. Plymouth Beach - Plymouth 5. White Horse Beach - Plymouth 6. Morton Pond'- Plymouth 7. John's Pond - Carver h 8. Sampson's Pond - Carver j The geographical locations of these beaches are-shown on Figure I Those beaches and ponds have been identified and statistics compiled through the following efforts: 1. On Sunday August 10,1986 from 1320 1725 and on Friday,. August 15 from 1325 - 1520, beaches of the entire EPZ were viewed and photographed using a helicopter'to access: a. Numbers of people on the beach; b. Numbers of available parking spaces;' c. Accessibility. 1 t 2. Local authorities were contacted to gather information on a. Number of Ticket Sales; t b. Number of Resident Parking Permits; c. Number of Non-Resident Permits; d. Usage Figures e. Restrictions - Residents only; Four Mheel Drive Vehicles Required;- 3. Field Studies were undertaken to supplement and verify existing. data. i I .. =

I. Beach Pooulation/Shelterina (continued) 8. Pooulation-Concern: Assessment of the number of people.using the beaches thatl require sheltering. That is those that-do not have access to permanent structures. The numbers of transients using the beaches.were determined by the same mechanisms listed in I. A. If specific numbers of average vehicle occupancy was not available from the local beach operating agency, a conservative 2.2 persons per vehicle estimate was used, based on actual field studies. Actual estimates of beach populations are shown in Table I-1 C. Shelters Stone & Webster Engineering Corporation was contracted by Boston Edison Company to identify potential shelters in the EPZ coastline region. The-following steps were undertaken to identify. potential shelters within one half to one mile of the coastline beaches. 1. Background information was gathered from: a. FEMA Region 1 Office 5. MCDA c. Red Cross 2. Review of municipal tax records to determine:- l a. Address b. Construction characteristics ~ l c. Floor space 3. Visual Inspection were conducted to: a. Confirm Tax Assessment Information. b. Assign Shielding Factors 1 l Table I-2 contains a listing of potential shelters. Utilizing the information shown in Table I-I and Table I-2 Table'I-3, a matrix reflecting coastline beach and suggested potential shelters was developed. Incorporation of usable shelters,into existing to'wn and State plans should occur over the next several months..>This effort will include physical verification of usability.of shelter and' town / state incorporation into each their plans and procedures. 1 / ,a w-w- v w a + ,v-m-*e ~

Table I i .i ESTIMATED POPULATION - BEACHES AND PONOS e ^ Estimated Vehicle No. of Source of Occupancy - No. of Beaches Vehicles Data (Persons /Veh.) Peoole Green Harbor 300 Capacity 2.2 660 Estimate Aerial Photos t Ouxbury 1400 Ticket Sales 3.0 4200- [ (Blakeman's) 500 Beach 1500 Beach Vehicles {- Gray's Beach 545 HMM Est. 2.2: 1200 Plymouth 243 (.67). Non-resident 2.2

359 i

Beach 163 Whitehorse 265 Capacity 2.2 583 i Beach Estimate Aerial Photos Hvton Pond 243 (.33) - Parking permits 2.5 200 80 John's Pond 120 Carver 2.5 300 Recreation Comm. Sampson Pond 120 Carver 2.5 300 l Recreation Comm. l TOTALS: 3493 ' 9302-t l.. ) l 1 L 1 t -

TR-203A, p. 1 l PII4 RIM STATION EVACUATION TIME ESTIMATES i AND \\ TRAFFIC MANAGEMENT PIAN UPDATE 1 1 j Prepar6d by q ELD Associates, Inc. 300 Broadway ( Huntington Station, NY 11746 L i Prepared for Boston Edison Cos offsite Emergency Preparedness Group h 59 Industrial Park Road Plymouth, MA- 02360 / i. August 25,.1988 Rev. 0 l July 15, 1989 Rev. 1 ~: q .s g d I - -. ~.

i r: j Table 2-3. Estimated Population-- Beaches and Ponds ~ i Estimated Vehicle No. of Source of occupancy No. of 15AEh Vehicles Dg13 (Persons /vah.) h13 Whiteberse 940 Aerial Photos 2.54 2387 Beac8: j Mortam Park 200 Non-Resident 3-600 Ticket sales i Plymouth Beach 772 Aerial Photos 2.54 1960 Saquish Neck 257 Aerial Photos 2.54 654 1 'l Priscilla Beach 169 Aerial Photos 2.54-430 Manoast Beach 258 Aerial' Photos 2.54' 655 Gray's Beach 41 Aerial Photos-2.54 103

l Sampson Pond 120 Carver.

2.5 300-Recreation Comm. l John's Pond 120 Carver 2.5 300 Recreation Comm. Duxbury Beach 1804 Aerial Photos. 2.54 4583 Green Barbor 1027 Aerial Photos' . 2. 54' 2609 i Brant Rock 477 Aerial Photos-2.541 1211 TOTALS M 15792 n \\ Notes: (1) Aerial Photography was performed on July 5, 1987 under ideal beach weather conditions. (2) Population estimates-derived.from aerial photographs i include EPZ residents at the beach. L i 2-15 Rev. 0 .] l . ~

_77. _ _ _ _ ~ _ I Attachmen 3 l November 1. ICC8 MEMORANDUM FOR: William Russell. Regional Administrator THRU: R. Bellamy. Chief. Facilities Radiation Safety and l Safeguards Branch. DRSS l FROM: W. Lazarus. Chief. Emergency Preparedness Section. FR$58 R. Hogan. Emergency Preparedness Specialist. NRR

SUBJECT:

MEETING WITH CIVIL DEFENSE OFFICIAL 5'1N THE TOWN OF DUX8U8Y-u TO DISCUSS THE STATUS OF' EMERGENCY PREPAREDNESS ON OCTOBER M. l 1988 SACKGROUND A meeting was held in the Duxbury Fire Station on October 26. 1988. The purpose of this meeting was to obtain the latest factual infomation regarding i the status of emergency plans implementing procedures, and facilities'. l directly from the Director of Civil Defense for the town of Duxbury. The Director of Civil Defense was also orovided on-opoortunity to bring any 1 .previously unidentified concerns regarding the status of emergency preparedness to the attention of the NRC. ATTD: DEES Carl O'Neill. Duxbury Civil' Defense Director and Fire Chief Alfred Slaney Planner. Massachusetts Civil Defense Agency (PCDA). William J. Lazarus. Chief. Emergency Preparedness Section. N#C Region I Rosemary T. Hogan Emergency Preparedness Specialist. Office of NPR DISCUSSION Mr. O'Neill presented the following status sumaries and concerns regarding., the state of emergency preparedness in the Town of Duxbury.- t Implementing Procedures There are approximate 1y'38 implementing precedures (IPs), none of'which i bave been sent to FEMA for review. All of the-IPs. except'three, have been reviewed by.cognirent Department Heads. The three IPs which are. still under deve1coment are: Selectmen; Town Manager; and Public. Information Officer. The RERP has reviewed the Fire and Civil Defense IPs and are reviewing the School IP. All IPs will be sent in segments ll to the Board of Selectmen for their review. Copies of.the Plan. IPs,- Shelter Implementation Plan and Evacuation Time Estimate are available in the EOC. -l The following are specific concerns which remain to be resolved. Sebools: The scheel comittee does not agree-with the school-H I

f ) procedure as drafted, but is considering early dismissal of school children at the ALERT. rather than have the buses in standby and evacuate the children at a SITE AREA EMERGENCY. There is'no sound technical basis for the position and in some cases would require three round trips of the school buses. This is contrary to the I reconnendation of the Civil Defense Director and MCDA who would H like to see the procedure remain as it is. There are a few'other J minor concerns involving role co9flict of teachers and the i guarantee of sufficient buses which remain to be resolved. Personnel Resources There are a few personnel shortages which need to be filled, The EOC ~ staff does not have a complete secord shift complement and the police o department needs two additional. Staff for Gurnet-Sequish route alerting if necessary. All other departments appear to have sufficient staff, i Evacuation Time Estimate i The new ETE has been received, but it has not been thoroughly reviewed. Equipment and Facilities The EOC is nearing completion. The facility is expected to be complete in four weeks when the connunication equipment is installed. Some-portable radios, a repeater and a LORAN navigation radio should be delivered within a few weeks. The Board of Selectmen has not approved a reception center comunity. Although the current plan provides for evacuation to Bridgewater or Wellesley, the Selectmen are opposed to Wellesley..There are.- l reservations on the use of Bridgewater, as wel1~, because the evacuation routes to that connunity would be blocked delaying evacuation. r, .The police need a 4 wheel drive vehicle to'be used for route alerting of the Gurnet-Saguish Beach area. Trainino Training has just begun, but is progresting very smoothly.

i Barry Report 1

Mr. O'Neill thought the Barry report accurately reflected the concerns and the status of emergency preparedness in Duxbury. Corission Briefing l Mr. O't:eill indicated that the statements made by Senator Kennedy, l Representative Studds, and Lt. Governor Murphy reflected the status of . -,... _.. -.... - -... ~

• h

>i = Attachment ? emergency preparedness for the town of Duxbury. Ability to implement The Civil Defense Director does not believe the plan could be-implemented at this time because so little training has been completed.. No portions of the plan have been tested. The Civil Defense Director has notified the Selectmen that he believes that training, equipment installation, plan and IP development, mini drills and a town drill could be complete by the middle of February.1880 Special Needs' Population ,1 Identification of the special needs population is slow due to the 'I reluctance of that population to highlight their handicaps; Repeated advertisements in the local. papers reouesting self-identification is continuing. TDDs are available to be delivered to deaf people who l request them. Special needs population evacuation was not identified as. a major concern provided resources arranged by the state are actually available. Beaches The Gurnet-Sacuish procedure is still under review by the Gurnet-Saouish -- I Association. Concerns are that siren coverage may be inadeouste. - There-is no feedback method to detemine if the sirens have actuated and Ouxbury police do not have sufficient resources to run route alerting'as a back-up for siren failure. Route alerting'would take at least 45: minutes to comolete. Chief O'Neill indicated that some of the estimates regarding the Gurnet-Saguish beach area he has seen have been inflated. He estimated the number for the Saquish Beach at about-4.000 maximum (2.000 typical) on peak days. The road to this beach is under water from high tides for a part of 2 days per month (2 to 3 hours)..The water may be waist high in that section. There are 4.000 to 5.000 people.on the Duxbury Beach during the peak-part of the season. The Powder Point Bridge has been re-opened and provides a second evacuation route-for those evacuating the Duxbury-Gurnet-Saouish beach area. This greatly. improves the situation. People are recuested to evacuate at the ALERT and the beach is closed.

SUMMARY

d The major concerns are getting touipment in place and wnrking, completing the-training and drills, and resolving the school evacuation issue, and final -approval.of procedures and plans.. Mr. O'Neill was provided an opportunity to review this memorandutr and his -l coments for clarification have been incorporated. ~..

i Attachment. 's /J/ William J. Lazarus. EP Section Chief, Region ! . j e /s/ 7 Rosemary T. Hogan,. j EP Specialist, NRP cc: J. Dolan, FEMA Region ! 9 J - i F 4 i t l m y-,..r, .,y-- er--.w....d

8 i W Wovember 4, 1988 NEMORANDUW FOR: William Russell, Regional Administrator .\\ THRU: R. Bellamy, Chief, Facilities Radiation Safety and Safeguards Branch, DRSS e FROM: W. Lazarus, Chief. Emeroency Preparedness Section, FR$456 R. Hogan, Emergency Preparedness Specialist, NRR I,

SUBJECT:

TOUR OF THE DUXPURY, GUPNET. AND SAQUISH SEACHES 8ACKGROUND Followine the meeting with Mr. Carl O'Neill to discuss the status of emeroency precaredness in the town of Ouxbury, Mr. O'Neill arranged for us to visit the-Duxbury, Gurnet, and Secuish beach areas which have been frecuentiv identified. as a ma.ior evacuatien concern. Mr. Brad Martin, the head of the Duxbury Decartment of Lands and Natural Resources, agreed to drive us out to $aguish. Responsibilities of Mr. Martin's department include controlling access and patrolling the Duxbury beach to assure that people do not enter the restricted areas such as bird nesting locations. As a result of his duties he is quite l familiar with the area and its problems. Mr. Martin previded the following l observations during the trip. The total number o' 'our wheel drive vehicles allowed access to the Duxbury beach is limited to 500 (by pemit). These vehicles have been seen to evacuate the beach in about a half-hour due to a thunderstorm. Rased on the numbers of 4 wheel drive vehicles allowed (500) plus parking cacacity for about 400 cars at the entrance to Ouxbury Peach, the typical number of persons at the beach would number about 3,000. In addition to the check for a beach permit at the Ouxbury beach, persons who wish to enter the Gurnet Sequish area (during suruner months). riust also pass through a securitv point, further limiting access to that area. The area of the road between Gurnet and Saquish-which ha's been-identified as impassable due to periodic high tides is under water "or-perhaps two hours during consecutive high tides for two days each month (during the full moon). During these high tides the road. floods to a depth of 1 to ? feet and covers about 100 yards of the road. In Pr. Martin's opinion, this shculd not present a serious impediment'to most I - four wheel drive vehicles. In any event it would be passable on foot and people could be picked up by vehicles on the Gurnet Point side. I There are about 250 cottages bevend the section of the read that is sub,ieet to periodic flooding. The area is only open to property owners, and their guests, limiting the number of people who could be in that area to 400 to 500. The twrnet-$aguish area is very light 1v inhabited l in the off-season months. s 4 l ~..

t i (nelosure 3 The contents of this memorandum were discussed with Mr. Martin by telechone en t hovember A,1988, and P.r. Martin indicated that it accurately re'lected the information he provided. N William J. Lazarus. EP Section Chief, Regipn ! i is/ Rosemary T. Hogan. E8 Specialist, NRR e i e e t 9 d M. t

september 30,-1988 Kr. Ronald Bellamy, Safeguards Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA. 19107 Dear Mr. Se11anyt As you know, Duxbury Citizens Urging Responsible Energy is opposed to the restart of the Pilgrim Nuclear Power Station. However, regardless of our position on that issue, we support the development of-the best emergency response plan which can be achieved due to the fact that 16 years of highly radioactive vaste remains on site. at Pilgrim. The town of Duxbury's Emergency Response Committee has made an extraordinary commitment, as have many individuals to insure that the public's health and safety are provided for in the event of an emergency at Pilgrim. Nonetheless, our plan is f ar f rom implementation, and it remains to be seen, as the Governor has stated, if workable plans can be developed to saf cly provide-for the evacuation of the population within ten miles of Pilgrim. We object to the NRC and Boston Edison conclusion that draft plans j i.. any state are satisfactory to protect this area. l We are pleased t'o provide the enclosed report, photographs and nautical charts prepared by Duxbury resident, David-( Quaid. We concur with his findings and commend him for tireless efforts to present factual information on the problems of evacuation and sheltering of the beach / transient pcpulations. In addition, Mr. Quaid has offered to provide i t:urs of the Gurnet/Saquish aren to interested officials. We trust that you vill give these materials careful consideration v..en making derisions on emergency planning. Wo.look forward to your comments. Sincerely yours,

f. hy

. h61,,st/, k ' bl i Mary C. Ott Donald M. Muirhead Jr. .M.D. Cc-Chairmen cc: Gevernor Michael Dukakis Senator Edvard Kennedy j Senator John Kerry Congressman'Gerry Studds Assistant-Secretary Public Safety, Peter Agnes Selectmen: Duxbury Mr. Cramer, Federal Emergency Management Agency q e w..-.-.

_ yy __ _ _ _ _. pave L (New, Asc 21 Summer 5ticct.P.O. Box 1617 Duxbury, MA 023311617 September 17th. 1988 REPORT ON PROBLEMS OF EVACUATION AND SHELTERING OF BEACH / TRANSIENT l POPULATIONS DUE TO THE PROXIMITY OF PILGRIM 1 STATION. This report and the aerial photographs contained with the report were occasioned by the irresponsible letter of October 21st., 1987 to the Nuclear Regulatory Commission concerning beach / transient populations t by Admiral tird of Boston Edison. Quote: "In our submittal of June L 4th.,1987, we conclude that adequate planning is possible for i sheltering beach / transient populations (estimated at approximately 9000 people). Our position was then, and remains, that there is more l than sufficient sh'eltering-capacity available for sheltering the-population of concern". t In a letter to Chairman tech, of the NRC, I asked for representatives of his agency and of Boston Edison to tour the beach-areas with me to-see for themselves that absolutely no sheltering, whatsoever, exists and that much of the beach area harboring a large summer-population is just three miles, downwind from Pilgrim 1 Station. Dr. Ronald

tellamy, Chief, racilities Radiological Safety and Safeguards Branch made an appointment with me and on March 10th.,1988, we toured the entire area.

It being winter most of the area was quite abandoned except for some all-year residents at Gurnet Point. He mentioned that he would like to see the area on a summer's weekend. l Tne aerial photographs were made to fulfill his request and-those of others. The photos enclosed were made on July 3rd. 1988, during the l period between 2:30pm and 3:30pm. The day was chilly so the beaches were about 50% under-utilized. This fact is obvious, when considering the pnotes of the 1/2 empty town parking lot ~ and the same condition at the D;xbury Public Beacn lots. Mr. Alber Samano, Supervisor ~of Off-site Safety, reported at a Duxbury Emergency Response. Committee-meeting, that BECO in '987 had also made an " overflight", on a pleasant summer's weenend, of the beach areas near Pilgrim i Station - and from the photographs estimated the beach population at 16000 pe ople. Photo 01: shows the proximity of-Pilgrim i station to Gurnet Point, slightly over three miles distant. The NRC estimates that the speed of a-radioactive plume from a reactor accident would be 10 miles per hour, which would allow but 20 minutes to evacuate the area. During the summer months the prevailing winds are from the southwest making the beach area downwind of the plant for the entire season of maximum recreational use. Photof2: Is typical of the Duxbury Beach road. As can be seen,'the road is cabled for its entire length to preclude access to the conservation treas. This fencing is broken in only'two places along 4 miles of load for access to the beach and are are referred to locally as crossovers. These crossovers are in extremely soft sand, under some a

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I l i conditions even.four-wheel drive become stuck. Photof3: one of only two crossovers in 4 miles of beach. + Photo 04: At. bottom of photo, a car can be seen exiting a crossover to the-The vegetation and the dunes are protected by. fencing both on-beach. Cars exiting from the beach can the beachside and the roadside. leave only through the crossover at the bottom of_the picture or through the one out of frame at the top. Photo 05: At this hour on a holiday weekend, 2:30pm, the parking lot would norsally be full and overflow cars turned away at the far end of the l bridge. The chilly day held down attendance. Photo f6: this hour, capacity, 2500 ~ The entire parking lot is normally full at When viewing these photos a factor of +1/3 to +1/2 should be cars. added to obtain a realistic impression of the population. j a Photo 07: It was estimated by the Gurnet/saquish security that there were 3500 i i people and 400 to 500 vehicles on saquish Beach on the af ternoon of l July 3rd., 1988. Photo 08: During the monthly astronomically high tides, the marsh. area, between l and 54quish Beach is inundated preventing [ vehicular-i Gurnet Point (A) and the back road at [C). 3]cis the one-traffic across road at At the best of _ lane soft sand principal access to saquish Beach.. times getting through [3] without meeting another vehicle coming f rom tne other direction is by chance, someone must back up. ;In an situation indeed. ere:gency (B) would prove to be avery dif ficult j The roads at.[A] and (C), see Reco..endation for Sacuish Beach: be raised for all-weather ac' cess. The gap at--[B) must PhototS, must be double-tracked to make evacuation at all possible, j i An additional crossover to make a total of three, l For Duxbury Beach: f General recommendation: ' Due to prevailing southwest summer winds,- close Pilgrim 1 Station, June 1st. to October 1st, yearly. ) l Respectfully. submitted, i hn i g.i! s. 2 4-David L. Quaid Resident of Town of Duxbury/Gurnet Point. l i \\ i 4 i l l b

/ \\ e [ UNitto rTArte 'S NUCLEAR REGULATORY COMMISSION e, 5 yeasmlfteTON, D C.se868 %,,,,, /l 0:teber 25,1996 l. a t i Mr. J. Douglas Nadfield Civil Defense Dire:ter for the icwn of Plyscuth, Massachusetts 83 Court $treet i Plymouth, Massachusetts 02380

Dear Mr. Hacfield:

Enclosed ts the memorencum covering our telephone coversation cf October 17, 1988. I would appreciate receiving hour review and 'coment within the next few days. Thank you for your professional ir.sTghts in cur discussion. 1 .Y ..Or Stalio Dr. // Executive 01fe,ctor fitfr Ope-atfe':s

Enclosure:

At stated 4 1 I ~ "

h s*h o / s% I UNiftestAfts t m l i, g , j l NUCLEAR REGULATORY COMMIS$10N wasamtom s. s swee g's.ev/ l t HEMCFM DUM QR: Chairman Zech n0M: Victor Stello, Jr. Executive Director for Operations-5tl8.*!CT: PHONE CALL WITH MR. J. DOUGLAS HADFIILD CIVIL DEFEN DIRECTOR FOR THE TOWN OF PL1' MOUTH, MASSICHUSETTS i At your request, ! called Mr. Nadfield on Friday-eerning (October II) to discuss his letter to you dated October

17. 1984. With me were Mr. James Taylor,

'i Mr. Wi'111:n T. Russel'. Mr. James sniezek, and Mr. William G. Kennedy to :repare notes of the dise'ssion. After introductions, Mr. Hadfield and ! discussed his concerns. Mr. Hacfield explained that the list f special'needs people was not up to date, altacugh a three year olc lif t had been updated with a few people:t had, respended to a recent newspap'er article.: Although Mr. Hadfield stat i i that he did not personally know of any others who should be added, he fe that others probably needed= to De added who were not on the list due to fider.tiality cencarns. When I asket, why the list had not been updated., responded that a survey by the state department of handicap affairs wa necessary but that funding had not been provided-py the state or utility. Mr. Russell added that he understood that the utility was w1111ag to fu survey but was awaiting the specifics. I sumerized that-the current list was i the best infomation available teday and Mr. Hadfield agreec. 1 The next subject was the statu: of implettenting procedures. Mr. Hadfield - j i explained that none of 21ymouth's implementing precedures hue 'been sub 1

4 c Chair::an Zach -2= tc the Massachusetts Civil Defense Agency (MCCA). Thme implementing precedures have act been approve'd by the Selectman. Two of the three exist in draft for.t and have been approved by their respective department heads'(for Fire a Policedepartments). The third procedure was for the s'chools. The school suurintendent decided to involve the two schoci coenittees in the approv their procedure and a meeting was planned for Monday evening (Octo o get public input. When the procedure for the schools fs acceptable to the schoci committees, it will have to be approved by the Selectmen. . However. in Nr. Hadfield's professional opinion. all three implementing procedures acceptable, Mr. Hadfield also explained a concern-for a point discussed at'the Oct 14th Comission meeting. He was ' concerned that the discussicn about the peculation on oage 97 and 98'of the meeting transcript may leave th { that no one stayed the e overnight when, in fact, tnere are resfdents who'. live - in the teach area. some year round, and it is only the transients who ar l e nct permit ed to stay overnight. Mr. Russell assured him that we understood that and that the discussion in the transcript related to the transient be lation on'y and not to permanent r6sidents. The next concern rsfsed by Mr. Nadfield was that *ts was not sure that I individual procedures would woric togetner. I agreed that this aspect cou only be evaluated by en integrated test however, I explaned that it was o experitnet that when a gcod job had been done on the individual procedum 1 i A - _, N. #f P9 O' *Q t a r-em oJ m e a -e.

] s 1 l e - 1 ( ( Chairman Zech, 1, itki thuis ct Pilgrts, the exercises usually go well and do not ident (, significant problems. Mr. Hadfield acknewledged our experience.. l ilt then went back to the status of the implementing procedms and t ~ presentation to the Comission. Nr. Hadfield was concerned that no one on h the NRC's staff could have seen his procedures because they have not b forwarded yet. Mr. Russell acknowledged that there 'were two places in ~the maatirg transcript where the staff had not stated the comp 1'ete status in response.o Cornissicner cuestions. The staff had accurately characterized the pl.mcuth status during the pt-4;2 red presentation. [ He added that the staff was-l g:ing through the transcript and would clarify the statettnts whe] Mr. Macfteic did provide infomation that was new to'Mr Russell in that thelcidan Nespital administrator was not yet satisfied with their procedure but th at a draft existed. Mr. Hadfield and I a5 reed that the procedures:were not " final" untti after an exer:ise and wel always be living_decuments subject q The next 1ssi.e raised by Mr. Hadfield was a puestion of manpower He stated i that no polis hac been taken in P1ssouth although the experienca is t n-emergencies, usually more people volunteer than are necessary. I acknowledged this. l We discussee the limitation on speakers at the NRR public setting on-. j l October 5 and the Commission meeting. I explained the Caetssion's hear *ng speaters at their setting and our sapectation that the Cosn onwealth .......... -.. ; 3 "-'::. _ ': :: !" ' " ~T" KIT ~' ~ ~

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Chairman Za:..- a-would inte5 rata and present all local. public concerns. I also stated that given the apparent loss of public ccnfidence after the NRR meeting, we q pr:bably should have allowed Mr. Madfield and the other local official to present their statements. He stated that he rec:gnized the need to impose sore t limits on public meeitngs. The last issue discussed was a question Mr. Maaftald had concerning any hRC requirenants for celibration of radiological survey instruments. ! explainac that we had requirements for those'inside the plant but looked to civil defense auth:rities to apply cannon sense to keep tneir instruments in-w:rking cendition. He stated that the questions stesmed from the fact - est FEMA will only reimburse the state based on a four. rear cycle, i i i Mr. Hadfield stated that the abcVe covered all of his concerr.s but still ~ re:uested a meting. In response to Mr._Hadfield's reovest. I agreed to cirect Mr. Russell to have one of his professionals meet with Mr. Nadfield. A Tuesday afternoon reeting (October 25) was tentatively agreed to. Finally 'I asked Mr. Hadfield if he agreed with me that the overall. planning and state of preparedness was substantially and'significantly 4 improved in all areis over what had existed in 1985. - He agreed saying that l they were '11gnt years ahead". We also agreed that the real issues were - j-cetplate planning n rsus ad hoc response. ~

i t 4 Chatman Zech 5-i Mr. Hanficid has reviewee this description of our discussion anc agrees ) with its contents. i l l i Victor Stallo, Jr. I Imecutive Director for Operations 1 cc: C:missioner Roberts Ccmissioner Carr Comissioner Rogers Cemissioner Curtiss $ECY i l 00C } l .) i i 4 1 i i .h v. -v.. .e.-~.- ~o a

1 O TIDES AND ACCESS TO SAQUISH SUPPORTING DOCUMENTS 1 i O l 1 l l O + }

80mWapes0M 9dgne Nuclear femet sunen - ) eetty Md Road ~, mymove.uainaanween oneo o Ralph G. Sirti i sen, v.ce pewort wweg., October 7, 1988 BECo Ltr. MS-143 l 4 U.S. Nuclear Regulatory Consission

• Attn: Document control Desk Washington, D.C.

20555 Docket No.: 50-293 License No.: DPR-35 Re: Boston Edison Company Comments on Draft 1 of "A Report on Progress Made-in Emergency Planning for Response to an Accident at Pilerim Nuclear' Power Station"

Dear Sir,

I The eaclosed letter was transmitted today to Mr. Agnes of the'- 1 Commonwealth of Massachusetts Executive office of Public Safety. It provides Boston Edison's comments on the draft report entitled "A Report i on Progress Made in Emergency Planning for Response-to an: Accident at Pilgrim Nuclear Power Station." This transmittal is for your information.. Please contact Mr. Ron Varley, Manager of Emergency Preparedness with-i any questions. l caw 1 Enclosure

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4

e.e. cussear Regulatory Commission October 7.o1933 Page Two i cc: Mr. M1111am T. Russell Re tonal Administrator l .dujlearRegulatoryCommission g g 475 Allengale Road King of-Prussia, PA 19406 2 Mr. D. G. Mcdonald Project Manager Division of Reactor Projects I/II i U.S. Nuclear Regulatory Commission l Mail Stop #14D1 One Mhite Flint North 11555 Rockville pike Rockville. MD 20852 Senior NRC Resident inspector Pilgrim Nuclear Power Station i i .a 4

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1

s t 29. The problems conestning evacuation of so remote an area (?.a, saquish), especially under adverse weather conditions, have not beo 4. dressed at this time. For instance, elevating the $4quish access roaw should be considered if such action would not be prohibited by environmental regulations. During extreme high tides this road is virtually impassable by any vehicle. (p. 43) COMMENTS: Provisions for the evacuation of Saguish have been incorporated into the draft plans and procedures, and include roles for the Plymouth Police Department, Saguish Special Police, Plymouth Harbor Master Duxbury Public Works Department Duxbury Harbor Master and Duxbury Police Department. The Duxbury Police Department has not yet concurred with its draft procedure, d With respect to the " virtual impassability" of the Saquish access road during high tides, that condition occurs on approximately two days a month for about two hours on each occasion. In any event, based upon numerous discussions with the Saquish. Association and aerial photography commissioned by Boston Edison, we believe that with the addition of a simple cross-over between the front beach road and back road, full access can be provided to and from Saquish at all times. There are of course details that must be worked out but, we are continuing to discuss this matter with the $64uish Association. Enciesure 3 November 4,1988 PEMDRANDUW F0P.: William Russell, Regional Administrator THRU: R. Bellamy, ?hief, Facilities Radiation iafety and safeguards d anch, DR$$ s FROM: W. Lasarus, Chief, teoreency Preparedness lection FR$459 R. Nogan, Emergency Preparedness Specialist, 81RR k $t!NECT: TOUR OF THE DUXPURY, GURNET, AND $AQUISH 8tACHt$ BACKGROUND Fel10 wine the meeting with Mr. Carl O'Neill to discuss the status of emereeney precaredness in the town of Dunbury, Mr. O'Neill arranged for us to visit the Dunbury, Gurnet, and Seouish beach areas which have been frecuentiv identified j as a ma.ior evacuatich concern. Mr. Brad Martin, the head of the tuabury becartment of Lands and Natural Resources, agreed to drive us out to $49uish. Resoensitsilities of Mr. Martin's department include controlling accats and patrolling the Dumburv beach to assure that people do not enter the itstricted areas such as bird nesting locations. As a result of his duties he it quite a f amiliar with the area and its problems. Mr. Martin previded the follt. wing observations curing the trip. The tetal number o' 'our wheel drive vehicles allowed access to the DuxWry beach is limited to 500 (by pemit). These vehicles have been sete to evacuate the beach in about a half. hour due to a thunderstorm. 8tased on the numbers of a wheel drive vehicles allowed (BOO) plus parking CaDecitY for about 400 cars at the entrance to Duxbury aeach, the typical number of persons at the beach would number about 3,000. In addition to the check for a beach permit at the Duxbury beach, eersons who wish to enter the Gurnet $aquish area (during suruner months) rivst also pass through a security point, further limiting access to that i area. The area of the road between Gurnet and Samuish which has been identified as ircassable due to periodic high tides is under water *or perhaps two hours during consecutive high tides for two days each month (during the full moon). During these h<gh tides the road floods to a deeth of 1 to ? feet and covers about 100 yards of the road. In Pr. Martin's opinion, this sheuld not present a serious impediment to most four wheel drive vehicles. In any event it would be passable on foot i anc people could be picked up by vehicles on the Gurnet Point side. There are about 250 cottages bevend the section of the read that is sub,iect to seriodic flooding. The area is only open to property owners, the number o' people who could be in that and their guests limitingsurnet-549uish area is very lightiv inhabited area to 400 to 500. The in the off-season mor.ths. v. s ) ...m....... l

.. _, ~, _. -. ~ l I i l The contents of this memorendum we~ fiscussed with Mr. Martin by telechone en j hovember e,1988, and Mr. Ma"' .c.c.cated that it accurately reflected the infomation he provided. N William s.i Lazarus, 4 EP Section Chief, Region ! is/ Rosemary T. Hogan, to $Pecialist, NRR i 6 i e 0 0 6 i n,, .e -m,--

l ( STATUS OF LETTERS OF AGREEMENT SUPPORTING DOCUMENTS ( O h

b $le $mmareeadh t'8usachuseM ~ 9 $reca/4e hlf ce f $$/$c fef / he YJllxden bce j Michael S. Dukakis $3/en, JJac$xJr//J W/Ocf Chuln V, Barry i Sterreary October 10, 1988 Mr. Ronald Varley Boston Edison Company Emergency Preparedness Division 59 Industrial Park Road Plymouth, Massachusetts 02360

Dear Mr. Yarley:

Attached is the draft letter of agreement regarding transportation providers which you agreed to have sent to the Massachusetts Civil Defense Agency and Office of Emergency Preparedness by companies which have indicated their-willingness to participate in emergency response for an accident at Pilgrim Station. This matter is a pending, unresolved issue regarding emergency preparedness, and an issue of great importance. Therefore, your prompt attention to resolving this matter is vital. Thank you for your cooperation. Sincerely, I O. 3-et(r W. Agnes, Jr. I Secretary l) Assistant PWA/pjh cc: Director Robert J. Boulay Deputy Director John L. Lovering Mr. Buzz Hausner Mr. R alph G. Bird, BECo i

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?Aadon, Jmw4me& Ct/C6 fit!) 717.trrs Mr. Robert Boulay I Director, Massachusetts Civil Defense Agency and Office of Emergency Preparedness P. O. Box 1496 400 Vorcester Road Fremingham, Massachusetts 01701

Dear Mr. Boulay:

In response to the State's request, this letter further clarifies our commitment (date) to provide emergency assistance in the evacuation of persons from the Pilgrim nuclear power plant emergency planning zone in the event of an emergency, that may involve a release of radiation outside the plant. Our drivers are aware of the Company's involvement in the emergency response program, and have been or are receiving emergency response training. We understand that we may be asked, on occasion, to participate in trainine drills or exercises, and to provide updated estimates of available resources. Based upon our typical operations, we expect that the following resources could be made available. Estimated mobilization times (EMTs) are in parentheses, and are defined as the approximate time between our receipt-of a request to mobilize and the time most vehicles and drivers would be ready to provide assistance. w

0 o,. f. i 1 Type Total Number Expected To Be Number Expected To of Resources Available During Be Available Resources Operatine Hours Durinn Off Hours ) i Buses / Drivers xx/xx xx/xx (EMT) xx/xx (EMT) Vans / Drivers Liftvans/ Drivers Ambulances / EMS Teams In the event of an emergency, you may communicate with our Company by calling: (insert names and telephone numbers, specifyinc primary and backup ooints of contact for full 24 hour period). (Insert name of provider) Signature Date s Title f r

BOSTON EDISON Emergency Prepareoness Department $9 inovstr.pt Park R060 P'ymouth Messa:hssetts 02360 October 21. 1988 EPBB-1272 c l Mr. Peter Agnes Secretary of Public Safety The Commonwealth of Massachusetts Executive Office of Public Safety One Ashburton Place, Room 2133 Boston, MA 02108

Dear Mr. Agnes:

l Your correspondence of October 10, 1988 (attached) requests that Boston Edison give prompt attention to obtaining clarificN. ion of transportation agreements. In response, I have directed my planning staff to contact all transportation providers that previously signed letters of agreement committing resources to a Pilgrim Nuclear Power Station emergency. Planners have been instructed to schedule meetings with these providers to introduce and obtain concurrence on the commitment letter clarifying bus companies' informed consent in the format provided to us by your office. The MCDA staff will be provided copies of our visitation schedule so they may accompany our staff if des' ired. Should you have any problems with our approach, please contact me. Sincerely. l f1 av i R. A. Var Manager - Emergency Preparedness Enclosure cc: R. Boulay 1 Buzz Hausner Al Slaney i RB/cs ~ ID 1895 i ~ ._.-m_.,

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} e,cs>a ep,y aa> x,9 h e Y dtbr den h er .%chael S. DJabs i hoJ/en, JJaclMJr04 W/Ocf '~ Chutes v. Ben $remey l October 10, 1988 Mr. Ronald Varley Boston Edison Company Emergency Preparedness Division 59 Industrial Park Road Flymouth, Massachusetts 02360

Dear Mr. Varley:

1 Attached is the draft letter of agreement regarding transportation providers which you agreed to have sent to the Massachusetts Civil Defense Agency and Office of Emergency Preparedness by companies which have indicated their willingness to participate in emergency response for an accident at Pilgrim Station. This matter is a pending, unresolved issue regarding t emergency preparedness, and an issue of great importance. Therefore, your prompt attention to resolving this matter is vital. Thank you for your cooperation. Sincerely, I f A '( ) g Jr 4 Yet r W. Agnes, Jr. l Assistant Secretary PWA/pjh i cc: Director Robert J. Boulay l Deputy Director John L. Lovering Mr. Buzz Hausner Mr. R alph G. Bird, BECo i i

h WlWW N A A / 8-!"9An4MWir Michae Dukaku & g4,g cg.g say ga ji_ia,,,,a p,,,,,,.,,,,, Mr. Robert Boulay I Director, Massachusetts Civil Defense Agency and Office of EmerEency Preparedness P. O. Box 1496 400 Worcester Road l Framingham, Massachusetts 01701

Dear Mr. Boulay:

In response to the State's request, this letter further clarifies our commitment (date) to provide emergency assistance in the evacuation of persons from the Pilgrim nuclear power plant emergency planning zone in the event of an emergency, that may involve a release of radiation outside the plant. Our drivers are aware of the Company's involvement in the emergency response program, and have been or are receiving emergency response training. We understand-that we may be asked, on occasion, to participate in training drills or exercises, and to provide updated estimates of available resources. Based upon our typical operations, we expect that the following resources could be made available. Estimated s mobilization times (EMTs) are in parentheses, and are defined l as the approximate time between our receipt of a request to mobilize and the time most vehicles and drivers would be ready to provide assistance. l. --m, a e Q + a ye

Type Total Number Expected To Be Number Expected To of Resources Available During Be Available Resources Operatina Hours Durinn Off Hours Buses / Drivers xx/xx xx/xx (EMT) xx/xx (EMT) Vans / Drivers Liftvans/ Drivers Ambulances / EMS Teams In the event of an emergency, you may communicate with our Company by calling: (insert names and telephone numbers, specifyinc primarv a,n d backup points of contact for full 24 hour period). (Insert name of provider). Signature ,Date Title t ww --

N Emergency Prepreovss Department $9 incastrial Park Roac Plymosth Massa:hssens 02360 December 1, 1988 EP88-1452 Mr. Peter W. Agnes, Jr. l Assistant Secretary of Public Safety The Commonwealth of Massachusetts Executive Office of Public Safety One Ashburton Place Room 2133 Boston, MA 02108

Dear Peter,

In accordance with your October 10, 1988 letter (attached) and cur subsequent phone conversation, enclosed are 32 letters from transortation providers which clarify their prior commitment to assist in the event of an emergency at Pilgrim Station. I understand that two of the companies forwarded their letters directly to your office and the one remaining letter should be. 4 forthcoming in the near future. The enclosed letters were executed in the form agreed upon by the Commonwealth and were,obtained over the last several weeks by Boston Edison planners. He will promptly forward the remaining letters once.they are received. S'ncerely, s . A. Va ey Manager - Emergency Preparedness

Attachment:

Letter, Peter Agnes to Ronald Varley i (October 10, 1988) Enclosures /cs 10 2008 pr ~~ '

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U V i l STATUS OF THE PUBLIC INFORMATION BROCHURE SUPPORTING DOCUMENTS ( 4 (

a = if /. A t BOSTON EDISON r - v :. N m esi;+t

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November B, 1988 EPBB-1357 Mr. Robert Boulay, Manager Massachusetts Civil Defense Agency and Office of Emergency Preparedness 400 Worcester Road Framingham, MA 01701

Dear Mr. Boulay:

In a recent telephone conversation with Mr. Peter Agnes, he expressed a strong desire to publish the Public Information Brochure prior to the end of this year. In order to accomplish Mr. Agnes' request, we have had several discussions with the printing and mailing companies to determine deadlines for submittal of the Brochure. As a result of these discussions we have determined that, in order to accomplish the mailing prir to the end of 1988, the mail house must have the final, printed copy no later than December 15, 19BB. Therefore, the attached schedule has been developed with the printing company responsible for publishing the Public Information Brechure and the mail house responsible for the mailing of the Brochure. As you can see, a minimum of six weeks is required by the printer and mail house to produce and mail the Brochure. In addition, time will be required for proofing the layout and printing the envelopes. Based on discussions with Ms. Diane Brown of your office, we understand that MCDA must approve the Brochure prior to having it typeset, and then must have additional approval time allocated af ter the approved information has been l typeset. While both approval points are included in the attached schedule, minimum time has been allowed to proofread the typeset version in order to meet the requirement this year for annual dissemination of information. We strongly encourage MCDA to dispense with the second approval-point so that the Brochure can be published in a timely fashion. Regardless of the mechanism chosen, decisions will need to be made in the immediate future in order to address the annual dissemination of public information. l He believe that a typeset document that has already been approved for content dnd layout need be proofread for typeset errors only, and should not require further revisions. Moreover, any changes made in either format or content once the document has been typeset will cause considerable further delays. { i j

Mr. Robert Boulay EPBB-1357 Page Two Ms. Brown has advised our office that she cannot be held to a schedule or a deadline for approval of the Brochure. If this is in fact the case we will not be in a position to fulfill Mr. Agnes' goal. Please contact either myself or Albert Samano as soon as possible if you concur with the attached schedule. Thank you for your prompt attention to this matter. I Sincerely. I ,e - J M anager Emergency Preparedness AS/dm Attachment cc: Mr. Peter Agnes Mr. Buzz Hausner 10#1947 8 r i

Attachment EP88-1357 L CURRENT PUBLIC INFORMATION BROCHURE PUBLICATION SCHEDULE Action Comnleted Bv 1. MCDA choice of cover photo November 7, 1988 (complete) 2. EOC telephone numbers finalized November 11, 1988 I 3. Hellesley" related portions finalized November 11, 1988 1 4. MDPH Radiation Section finalized November 11, 1988 5. MCDA approval of text / maps November 11, 1988 6. PIB to printer November 11, 1988 7. Order envelopes November 14, 1988 8. Proof typeset galleys of PIB November 21. 1988 9. MCDA approval of typeset galleys November 22, 1988

10. Printing of PIB November 23, 1988

11. PIB delivered to mail house December 1, 1988

12. Mailing of Brochure December 15, 1988 s

e 1 1

p 1 r. Emergency Prepareoness Department $9 Inoustrei Park Roac p mouth Massa:huse!:S02360 y December 8, 1988 l EP88-1478 l l Mr. Robert Boulay, Director l Massachusetts Civil Defense Agency and Office of Emergency Preparedness t 400 Worcester Road P. O. Box 1496 Framingham, MA 01701-0317

Dear Mr. Boulay:

Boston Edison Company has been working with the Massachusetts Civil Defense Agency since May of 1987 to publish a revised Public Information Brochure for the Pilgrim Nuclear Power Station. The brochure had been delayed due to two issues that have recently been resolved. On November 11, 1988, MCDA submitted an approved version of the radiation section for the brochure. On December 7, 1988. HCDA approved language allowing the State Department of Public works facility at Hellesley to be included as an interim reception center. Based on receipt of the above information, a schedule has been developed for production of the brochure and is. attached for your review. i The copy will be delivered to the printer on December 7,1988. The mechanicals will be available for MCDA review on December 12, 1988. He would 4 like to schedule a review meeting with your staff on that-date. Final approval of brochure content and layout must occur at that meeting in order to have any chance of printing the brochure prior to the end of 1988. We are taking extraordinary measures to complete this project this year. The schedule has been revised several times, and in order.to meet the new schedule, all outside vendors have agreed to work considerable over-time hours during the upcoming holidays. The schedule, at this point in time, is very tight and a one day delay will prohibit them from meeting scheduled deadlines.- Therefore, if the final approval of the mechanics is delayed beyond December 12, neither MCDA nor BECo will meet the annual requirement for i dissemination of this information. t Manager - Emergency Preparedness i Attachment JP/cs ID 2027 L-

i REVISED PUBLIC INFORMATION BROCHURE SCHEDULE t c ACTION ITEM i DEADLINE DATE 1. Draf t to printer 12/07/88 2. Typeset mock-up received 12/09/88 3. MCDA review / approval and return 12/12/88 to printer l l 4 Printing complete 12/16/88 5. To binding / die cutting 12/19/88 6. Label envelopes and stuff 12/27/88 7. To ma11 house for mailing 12/29/88 i 4 ~

NOTE TO: Joe Ba hman. New England Lithograph FROM: Juli. c41111ps. Boston Edison Co. DATE: December 9, 1988 dC23ECT: Public Information Brochure Typesetting Following are the changes needed for the typeset copy of the broenure you are producing for us.

1. 1.

Fase 10. Added sentence, first paragraph. "For more detail on sub-areas, refer to the sub-area maps in the Transportation Section of this booklet. " 50. Fase 20. New map - take out the text under " WHITE HOR $E' LEACH" that says "E Mile Radius".

1. 3.

Fase 01. Delete the Eox under the map that gives the computer file codes: LTE NUMEER PEV CODE PAGE A 002-PI ek1 PI-SUBAREA #2 1 of 1 TITLE: Cubhram #2

1. 4.

Page 20. Delete the Box under the map that gives the computer file codes: LT~ NUMEER REV CODE PAGE _A 003-PI wk1 PI-SUEAREA #3 1 of i TITLE: Cubarea c? 45. Fage 23. Delete the box under the' map that gives the computer file codes: LTR NUMEER REV CODE PAGE _A 004-PI ski PI-S UB ARE A #4 1 of 1 TITLE: Subaren #4 n6. Fage 24. Delete the box under the map-that gives the computer file codes: ) LTR NUMBER REV CODE PAGE j A 005-PI mk; PT-SUEAREA #5 1 of 1 TITLE: subarea #5 n7. Fage 25. Delete the box under the map that gives the computer file codes: 1 LTP NUMBER REV -CODE PAGE A 'J06-PI ski PI-RUPAREA #6 1 of i T I T 1.E - subares :6

l 88. Page 26. Delete the box under the map that gives the 4 computer file codes: LTR NUMBER REV CODE PAGE A 007-PI ski PI-SUEAr*EA #7 1 of 1 TITLE: Subarem #7

1. 9.

Page 27. Delete the box under the map that gives the computer file codes: LT; NUMBER REV CODE FAGE A 008-PI mk1 PI-SUEAREA #8 1 of 1 TITLE: Subarea #8 UO. Page 28. Her. vier street lines on map should be dotted lines, as on other rnaps. Also, delete the box under the map that gives the computer file codes: LTR NUMBER REV CODE PAGE _A 009-PI eki PI-2DBAREA #9 1 of 1 TITLE: Subaren #9

1. 11. Page 29.

Heavier street lines on map should be dotted lines, as on other maps. Also, delete the box under the map that gives the computer file codes: LTR NUMEER REV CODE PAGE A 0010-PI th! PI-SUBAREA #10 1 of i TITLE: Subarem #10

1. 12. Page 30.

Delete the box under the map that gives the computer file codes: LTR NUMEER REV CODE PAGE A 0011-PI sk! PI-SUBAEEA #11 1 of 1 TITLE: Subarea #11 h0 - {kL Q SY P&M c & #1d A 04n M L A.A d ci i s 9n d L M y " f &R 26L -rnt ld%Lk Matthk. b ,a. ht dh L

l l Evacuation Routes and Reception Centers Follow evacuation routes chown on the map to leave the area, t They are the quickest, safest ways in an emergency. All areas outside of the shaded areas on the map are far enough away from Pilgrim Station that evacuation is not needed. You should [ evacuate UNLY if you are in a sub-area named over EBS. To find your sub-area, check the map on page xx. For more detail on sub-areas, refer to the sub-area maps in the Transportation Section of this booklet, o To Taunton Etnie Mortitg1 and Hest Scheels If you sre located in sub-areas 1, 2, 3, 5, 6 or if you have school children in the Plymouth School System: Take Route 44 West to Route 25/495. Follow Route 25/495 West to Route 138 South to East Brittania Street. Turn right (west) onto East Erittania Street to Danforth Street. Turn left (south) onto Da.fortn Street and continue south to Taunton State Hospital. 1 Or, take Route 3 or 3A South to Route 6 (Cranberry Highway) West, to Route 25/495. Follow Route 25/495 West to Route 138 South. -Follow Route 138 South to East Britannia Stree,, Turn right (west) onto East Brittania Street and continue west to Danforth l l Street. Turn left (south) onto Danforth Street and continue 1 l l south to the Taunton State Hospital. 12

i j 8059aN CDA$CN CO@ANY PILGtIM STATION o cn-stic sp MerTINo como l j i VI(c oirt />ll>l12 rw /I: 30 c;. in. To FRoM %d' hju' LLC.Go.s \\ l caesn'W4ECe, c>t$u'tr eP IfCIVIOUALS PEENT (NMS/cGPANY Gt AIENCY) l /M(' thi.' $rn.< &n<m 05a hesn av i l & & d.. ' (LL laat 2i,<s,w. %s' b,i IL,h l CJ U St& ECT F E rTING / Tf8 Or W 42 M V o e>f / h d t-N I< u e. 9 (Pis) l C34ENTS dLi ntit U A ttw dAt -4, Mhe2 (7 th-Pid.u.. m., ao i.ar-A <,. ee u -m a run.<. v v v hn.,V,. ar 8, im a.c Tc 0 u-w < A 4 Nooa n > a n/ a <r-v 3 : 3r- "71% ed%tw OdEJ4dw 4Lm bl TI' o.,,,. Y u O A b }M' NLt-t 'st ' ' ' 17 r_,.-, +- 13 t i..e k - u o V1 the I

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i 9 BOSTONEDISON Emergency Preparedness Department s9 IndustnalPark Road 1 Plymouth, Massachusetts 02360 l December 19, 1988 EP88-1515 i i Mr. Robert Boulay, Director Massachusetts Civil Defense Agency and Office of Emergency Preparedness 400 Worcester Road P. O. Box 1496 Framingham, MA 01701-0317

Dear Mr. Boulay:

As I stated in my December 8,1988 letter to you, final MCDA approval of the content and layout of the Public Information Brochure for the Pilgrim Nuclear i Power Station emergency planning zone was required no later than December 12-in order to have any chance of printing the brochure by the end of the year. Since MCDA had submitted an approved version of the radiation section of the brochure on November 11, and had approved specific language related to the Wellesley facility on December 7, it was my understanding that the entire text had been approved by MCDA. I had therefore assumed that there would be no j difficulty in meeting the December 12 deadline. l At the December 12 meeting, however, Mr. Hausner informed us that approval of the Brochure for printing and mailing would not be possible until Messrs, i Lovering and Agnes, as well as all of the town Civil Defense Directors had reviewed and approved the brochure again. Therefore, it is now clear that the brochure cannot be published this year. 't would like to encourage you to take whatever steps are necessary to permit us to move ahead with the brochure as-early as possible in 1989. Sincerely, Ronald.b.VarNy Manager - Emergency Preparedness cc: R. Bellamy /cs ID 20S2 ,,e ,e-. -n.- o r w-.

i l~l NED I ~' I l~l QAD Unit #1 ~ BOSTON EDISON COMPANY l]l NHSD PILGRIH STATION TELEPHONE CALL RECORD IZI NOD ~ l[ EP l TO Buzz Hausner. MCDA OATE 3-14-89 TIME 3:00 P. COMPANY /0FFICE Mass Civil Defense PHONE NO. 820-2032 FROM Juli Phillir.s COMPANY /0FFICE B,ston Edison Co. PHONE NO. 747-9422 In'ormation p ro c hu re

SUBJECT:

Printing of Public f The following questions were asked of Mr. Hausner to determine when we will b e able to print the PIB: I 1. MCDA had extended the deadline for town review of the PIB to 3/2/89. Have all those reviews been received by MCDA? Julia Gabaldon had stated an the AREA II meeting on 2/23/89 and in a telephone conversation with myself that if towns did not respond bv that deadline, MCDA would assume they had no addition comments. l Do you concur? ANSWERS: I don't know if all reviews have been received from the towns. I will check with Al Slaney. Yes, if towns did not respond we will assume they have no furthet comments. ? 2. Is MCDA ready to approve and release the Brochure fo r printing? ACTION REQUIRED: (YES) O es /1 Copies To: vile SIGNED d' b'- [,./ R. Ynvl ev / / ~. A. e-no DATE 3A 4-89 Page. I of 2 BECo Form X.5104

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A??AC M N? C04(NTS A N SW E R: No. i 3. What are the outstanding issues that' prevent MCDA from releasing I the B rochu re for printing? ANSWER: All th ree reception centers a re not complete. 4. What is the time frame you estimate to r e s o"l v e these issues? _ ANSWER: Impossible to say. l \\ 5. What app roxima t e date or time frame do vou ant icipat e being a bl e to release the Brochure for publica t ion a nd. dis t ribut ion ? ANSWER: Impossible to say. 6. Bos t'on Edison has an anhual commitment to print a brochure. We had the Brochure typecet in December, but af ter our December meeting with you and your request for additional town review, we requested I an extension on that commitment from our Quality Assurance Dept. That deadline is April. Do you t hink we will be abic to print the Brochure by April? ANSWEE: Impossible to say. I will not say that is. impossible to meet that deadline, but it is' imposs ible to say yes or no a' t this time. 7. Because we need to respond to our Quality Assurance Dept. on this ' commitment, I am documenting these responses f or a status report to them. Mr. Varley will send copies of this information to Mr. Boulay, M .b h a

seem asm Pilgrim Nuclear Power station Rocky Hill Road . Plymouth, Massachusetts 02360 Ralph G. Bird serpor %ce President - Nucleat June 30, 1989 Mr. Charles V. Barry Secretary of Public Safety One Ashourton Place Boston, MA 02108 l

Dear Secretary Barry:

l At our last meeting on June 19, 1989 concerning the offsite emergency response program for Pilgrim, several issues relating to preparations for the upcoming full-participation exercise were discussed. In particular, you directed MCDA representatives to meet with Boston E91 son officials in order to discuss the l following four key issues and to provide you with status reports on those issues: (1) Implementation of the Hellesley reception center; (2) Publication of the public information brochure (PIB); (3) Implementation of Area II EOC renovations; and (4) Progress on training of Commonwealth emergency response personnel. The purpose of this letter and the attached memorandum is to provide Boston Edison'.s perspective on these issues, and on several other matters which we believe must be resolved if we are to achieve our joint goal of a successful exercise in October. The attached memorandum discusses each of the' issues and provides recommendations for their prompt resolution. It identifies those issues which we do not believe are or should be legitimate exercise impediments, as well as i those issues which could impact the exercise. It'also discusses certain items which are unrelated to the exercise but which, nevertheless, warrant prompt attention. The following paragraphs summarize the more detailed conclusions and recommendations contained in the memorandum. O The exercise is now scheduled for' October 12-13.-1989. That is only 103 days away. Only about 73 days remain until the " dry run" exercise. We strongly believe that a number of activities must immediately be undertaken by the Commonwealth to enable all parties to promptly complete their exercise preparation efforts, and to assure a timely and successful exercise.

) HEMORANDUM i DATE: June 30, 1989 i St;%ECT: Boston Edison Company Analysis of Critical Emeroency Preoaredness Issues j I. INTRODUCTION I i -l The purpose of this memorandum is to provide Boston' Edison Company's perspective on the status of.the four key issues identified by Secretary' l i Barry in the June 19, 1989 meeting regarding offsite' emergency response planning for Pilgrim, as well as to provide our perspective'on several other issues which we believe are potential impediments to the conduct _ of l a successful emergency response exercise i,n: October..The four key-issues identified by Secretary Barry are-(1) Implementation of the Helle 31ey reception. center;' (2) Publication of the public information brochure (PIS); (3) Implementation of Area II EOC renovations; and. i '(4) Progress on training of Ccmmonwealth emergency response personnel. In ads r.lon to these issues, the following' matters are discussed: (5)? Implementation of.the Bridgewater State College reception center:L -(6). Identification and training of Area II!EOC emergency response; personnel; (7) Training of local personnel; and ~' -(8) Status of planning-in-the Town.of Duvbury. t O \\ i l-'

m B. Publication of the Public Information Brochure (PIB) The PIB was typeset 1 December-1988 after extensive Commonwealth and local review. However, MCDA would not authorize printing at that time bec'ause it felt that the towns should have one more chance to review all the changes incorporated to that point. That opportunity was provided. On March 14, 1989, Mr. Buzz Hausner of MCDA advised the Company that, even thougn additional town comments had not been received, we could not proceed with the PIB until all three reception ~ centers were operational. In May 1989, MCDA submitted the'PIB to f FEMA for an informal technical review. FEMA's comments were received I and were incorporated by Boston. Edison in a revised draft. These changes were pi.cided to MCDA on June 19, 1989. ) At the June 19 meeting, MCDA representatives indicated that they had " additional" local comments to be reflected in the PIB..These-have-now been incorporated. Also at that meeting', Mr~. Agnes stated that I agreement on Wellesley renovations was necessary for release of the - L PIB. On June 28, MCDA staff telephoned to provide. additional 1 comments. These include comments deleting items.MCDA had added in j their prior reviews. j i There has been an unending cycle of reviews of the PIB and of conditions placed on the Commonwealth's. formal approval of-the PIB. The PIB has, in fact, been complete and readynfor publication for months. In addition, sin'ce Wellesley has been designated as a i i I x ~ +mr

m ..?: I reception center and since Commonwealth officials have made clear it i i would be used.in an-emergency, there is no reasonable basis to, delay ) PIB publication for final' agreement on Hellesley improvements. In view of the fact that Pilgrim-is presently operating, that schools will be returning to session in the Fall, and that it will take 6-8 weeks to publish and distribute the PIB, Boston Edison has decided to move forward to complete PIB. publication and distribution. He have notified MCDA that any further comment's will be reflected in the next annual edition (1990). If Commonwealth approval is not received by mid-July, we will delete references to MCDA concurrence and distribute the PIB as part of our commitment to provide. adequate advance public information to the. public around P.ilgrim. 1 l Recommendation 5: i The Commonwealth should promptly approve the'PIB for. publication as a' joint-Commonwealth - Boston Edison document. Boston Edison will'immediately initiate publication andl distribution of the t Brochure..{:s . it 1-C. Imolementation of Area II COC Renovations i l L i Discussions with MCDA on Area II renovations began :in ' January 1989. l Following conceptual agreement on what was to be provided.four ~ architects and engineers developed blueprints of the-proposed work. These vere provided.to Mr. Tom Rodgersin corresportience dated June _12 l ' 8 -- +..

-4 a u i 1 l ESTIMATES OF THE SPECIAL NEEDS POPULATION SUPPORTING DOCUMENTS I i t i i 1 - l 4 4 i -l 1 H ( j r h i 1 ~l l 1.---

LOCAL i Y\\ h ,A R D O J S M 4 TEb 7 PLANN/NC l h / \\ l -g 1 t osie on.ini l E E E E 5 em, 1 i (k lf l A GUIDE FOR UPDATING LOCAL j ~ COMPREHENSIVE EMERGENCY MANAGEMENT. PLANS-l f TO MEET. ' SARA'. TITLE III REQUIREMENTS' e 'l MASSACHUSETTS E MERGENCY-L RESPONSE COM MISSION. l [' ~M ASSACHUSETTS CIVIL DEFENSE! AGENCY.- and L OFFICE OF EMERGENCY PREPAREDNESS; 3 ,i it MICH AEL S., DU K AKIS CH AR LES. Y, B ARRY : ROBERT. J. BOUL AYL l GOVERNOR S E C., P U B LIC' S AFETY DIR. MCD A - i, i Prepared by MCDA Planning Division a Do ugla s P. For b e s, P.E., Dire ct o r

stars I SPECIAL NEEDS NON-INSTITUTIONALIZED POPULATION Hazard Zone Radius - Total Population in Hazard Zone - Population without Transportation - (1980 Census - Block Statistics) Busses Needed (45/ bus) PREV ALENCE OF IMPAIRMENTS PT.EVENTINO PERFORMANCE OF ACTIVITI J Emergency Action Impeded Impairment 5 of population Number Notification Hearing .085-Orthopedic Problems .635 Walking to a pickup point Severe Visual 115 (Mobility Impaired ) Other impairmer:t .105 TOTAL # MOBILITY IMFAIRED: i j l Bould need an ambulance Would need chair van 'Woul.d need a bus' SOURCE OF TRANSPORTATION NAME ADDRESS TEL. # CON TA CT - i \\ l N u=ber, type, capacity - a ll i, Memorandum of Understanding Yes N o-DESTINATION ADDRESS TEL.

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i .) Memorandum of Understanding Yes No Note: Survey of actual needs to be conducted. Item E needs to be-then updatd. J 4

l a. l 1 l PILGRIM STATION-EVACUATION TIME ESTIMATES AND 'i i TRAFFIC. MANAGEMENT PIAN UPDATE I i q 3 Prepared by t KLD Asecciates, Inc. 300 3roagway Huntington Station,_NY 11745 l (- 1 i ] i 1 Prepared for q Boston Edison.Co.. offsite Emergency Preparedness Group 59 Industrial, Park Road

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Plymouth,-MA 02360-z 1 I 4 i l l August'25, 1988- 'Rev..O' .a ~ j L. h i s s -s a 1 i _]

1 1 Town Clerks Rate Population Vehicles 19MD M 1pJl Percent-(5) 1988 1988 Plymouth (3 ) 39,700 40,000 1.6 40,665 15,640 Kingston(2 ) 7,832 7,491 0.2 7,506 2,487-Carver (3) 5,639 5,782 5.2 6,083 2,340 Duxbury 13,689 13,880 2.3 14,199-5,461 Marshfield (4) 1,822 1,801 1.1 1,821 700 TOTALS 70,274 27,028 l Notes (3 ) Plymouth - Town Clerk population estimates for 1986 obtained in 1988 are lower than those obtained by KLD in 1987. Consequently, the .1987 population projections used in the ETE was approximately 720 people more. than-the current 1987.. Town Clerk estimates. The 1988 population projections are based on the 1987 Town Clerk estimates and the revised estimated growth rates. l (2) Kingston - Town Clerk population estimates for 1987 are lower than 1986 population estimates. This data is reflected in a lower overall. growth rate. (3 ) Carver - Carver has a total estimated 1986 and 1987-population of 9,723 and 9,969, respectively. It is estimated that 58 percent of.the population of carver l resides within the.EP2. I (4) Marshfield - Town Clerk population estimates for 1986 and 1987 are 22,780 and 22,507, respectively; It is estimated that 8 percent of the population.of-Marshfield resides within the EPZ. t L (5) Growth rates were computed on the basis = of 1980 Census I data and 1987 Town -Clerk population estimates.' Population projections for 1988 are derived by applying the estimated growth rate to 1987 population estimates. 1

2. As sume these vacations,.in aggregate, are uniformly' q

dispersed' over 10 weeks, i.e.- 12 percent of the population id on vacation during each two-week interval. ' 2-10 Rev. 0 l l u

Secretary Charles Barry June 30, 1989 Page 4 It is very Important that you take'whatever action is necessary to: (1) eliminate the existing, legitimate impediments to the conduct of a successful October exercise; and (2) clarify unequivocally that those issues which are not legitimate impediments will not be permitted to jeopardize our joint exercise preparation efforts. Boston Edison is committed to working closely and cooperatively with the-Commonwealth to resolve the issues discussed in the attached memorandum. We believe that significant progress in that regard can and must be accomplished before our next meeting on July 17, 1989. He recommend that the issues and recommendations contained in this letter and in the attached memorandum be part of the agenda for that meeting. Thank you for your assistance and cooperation in our :,oint effort to provide an effective offsite emergency response program for Pilgrim. Very truly yours, ObJ R. G.~ Bird cc: Robert Boulay Henry Vickers Ronald Bellamy Ronald Varley l \\ e 9

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