ML20058B771
| ML20058B771 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 10/18/1990 |
| From: | Carr K NRC COMMISSION (OCM) |
| To: | Arons B PLYMOUTH, MA |
| Shared Package | |
| ML19324J413 | List: |
| References | |
| NUDOCS 9010300420 | |
| Download: ML20058B771 (2) | |
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October 18, 1990' CHAmMAN Mr. Bruce Arons Plymouth Board of Selectmen 11 Lincoln Street Plymouth, Massachusetts 02360
Dear Mr. Arons:
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I am responding to the August 10, 1990 letter from former-Chairman Alba C. Thompson concerning our Inspector General's eg.y~ f]
recent report on the investigation of the Nuclear Regulatory Commission (NRC) staff's testimony on the status of off-site emergency preparedness during -the October 14 and December 9, 1988 Commission meetings.
These meetings were held to consider l
information pertinent to the restart of the Pilgrim Nuclear Power
- Station, i
The Commission is concerned that the report raises questions about the thoroughness of the staff's assessment of off-site emergency preparedness at Pilgrim and the accuracy of certain information provided by the staff during meetings with the Commission.
The Inspector General has confirmed that there is not evidence suf ficient to substantiate that any member of the:NRC staff intentionally provided inaccurate information to the Commission.
Accordingly, we have directed that the staff' conduct a
" lessons-learned" review to address-whether any staff omission or error occurred and the need for any additional staff guidance or procedures were the circumstances to arise for the staff to again conduct a review of this unique type.
That review'has recently been completed and is currently under review by the Commission.
l In addition to the " lessons-learned" review, a special task force has been established to review the comments and documents presented to the staff at the September 6, 1990 public meeting in Plymouth.
J The special task force will also review the soon-to-be issued FEMA-status report; conduct field verification of issues in dispute; issue an updated emergency preparedness status report; and provide' a recommendation, based on the analysis of any new information on whether the Commission should reconsider-its reasonable assuran,ce-finding.
Regarding the statement in Ms. Thompson's August 10, 1990 letter that she never received a reply to her letter to the-NRC dated-October 31, 1988, a copy of the NRC reply dated December 5, 1988 is enclosed with this letter.
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2 We believe the actions we are taking are appropriate to address the issues raised in the Inspector General's report and the status of emergency preparedness at the Pilgrim Nuclear Power Station.
Sincerely, LA.L Kenneth M. Carr
Enclosure:
December 5, 1988 Ltr fm Chairman Zech to Ms. Thompson I
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CHAMMAN Decemoer 5, 1988 Ms. Alba C. Thompson, Chairman i
Plymouth Board of Selectmen Town of Plymouth 11 Lincoln Street Plymouth, Massachusetts 02360
Dear Ms. Thompson:
I en responding to your letters cf October 19 and 31, 1088, ccncerning the status of emergency planning in the' Town of Plymouth.
The Commission is interested in hearing the views of incal officials ano citi: ens on issues associated with the restart of the Pilgrim facility, including the status of> emergency planning in the towns surrounoing the plant.
Prior to the_ Commission's October 14 meeting, the Nuclear Regulatory Commission (NRC) staff had conducted a series of meetings in the vicinity of the Pilgrim facility to hear'the views of the public on the-possible restart of Pilgrim.
During the October.14 meeting, the Commission heard the views of elected-representatives from.
Massachusetts, including Lt. Governor Murphy, Senator Kennedy, end Representative Studds.
As a result of the Commission's own concern about-the status of emergency planning, we postponeo any decision on the restart of the plant to further evaluate l
this issue.
In addition, the NRC's Executive Director for l
Operations has personal-ly spoken with Mr. Douglas Haofield, Plymouth Civil Defense Director, and staff representatives i
recently met with Civil Defense Directors and other local of ficials in the seven emergency planning zone and reception center communities around Pilgrim, including the_ Town of Plymouth.
These meetings were-held to enable the NRC to obtain first-hand information on the status of the local emergency plans and procedures and'to hear the concerns of. local officials.
I am enclosing copies of documents that summarize these recent interactions.
The Commission has decided to hold a public meeting in our Rockville, Maryland, headquarters building to hear from local officials regarding the status of emergency plans and the readiness of local communities.to protect the public in the event of an emergency.
This meeting has been scheduled for f ns l 'fis)
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on December 9, 1988.
The Secretery of the Commission has informed me that you plan to participate in this meeting.
We welcome your participation ar.d will appreciate hearing your views on this matter.
In order to fully consider all of the information that will be presented, the Commission does not plan to reach a decision on the restart of the Pilgrim plant-at this meeting.
I know that you, ano your colleagues in the surrounding com-munities, are taking your responsibilities to protect the health and safety of your citizens very seriously, and I commend you for your ef forts to put in blace effective emergency plans and proceoures.
I can assure you that the Ccmmission takes its responsibilities equally _ seriously, and that we will not authorize the Pilgrim plant to restart unless we are convinced that it can he operatec safely and that the public health and safety will be protectec.
Sincerely, W' N f.
Lando W Zec, Jr.
Enclosures:
As stated I
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ENCLOSURE 1 Sumary of Energency Preparedness Peview Process at Pilgrir FEMA is responsible for the review and approval of offsite emergency plans, including determinir.g whether State and local governments can effectively implement these plans in accordance with Part 350 of Chapter 44 of the Code of Federal Regulations (44 CFR 350).
This finding is then forwarded to the NRC for our use unoer the regulations (10 CFR 50.47 ).
In order to assist FEMA in the technical aspects of emeroency planning, a Regional Assistance Comittee (RAC),
chaired by FEMA, is established.
The principal organizations that comprise the PAC are FEMA, NRC, the Department of Health and Human Services, the Department of Energy, the Department of Transportation, the Environmental Protection Agency, the Department of Agriculture, and the Department of Comerce.
The normal review process for revisions to offsite emergency plans and imple-menting procedures occurs when the local governments forwaro emergency plan
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revisions to the Commonwealth and the Commonwealth, in turn, forwards them to FEMA.
FEMA, with assistance from the PAC, reviews the revised plans, makes a determination of adecuacy, and transmits this finding to the NRC, as well as to the Comonwealth.
This review is normally done on an annual basis or, as needed, when a complete plan revision is received.
NRC involvement in this process is normally through our RAC participation with FEMA and through our-State liaison program with the Comonwealth.
The review process does not normally involve interaction directly with local government officials, nor does it necessarily involve detailed review of implementing procedures. Occasion-ally, implementing procedures are reviewed to ensure complete For example, lists of schools in the emergency planning zone (EPZ) planning.
could be included in the plan or in the implementing procedures.
If the plans have sufficient detail, a review of the procedures is not required.
Portions of plans and procedures may be verified by limited demonstrations, drills or training evolutions, at the dis-cretion of state or local entities responsible for those plans and procedures.
Exercises are periodically conducted to confirm training and implementation of-procedures.
For the Pilgrim facility the NRC essentially used the process described above. Draft plans were forwarded to the Comenwealth from the local towns, reviewed by the Comonwealth, and forwarded to FEMA for technical review.
The NPC, as a member of RAC, was a principal reviewer for the submitted draft plans and provided detailed coments to FEMA on these plans.
After FEMA informs NRC of deficiencies in offsite emergency plans, as it did for Pilgrim, it is the NRC's responsibility te decide whether or not to take.
enforcement action.
The cecision is based upon the deficiencies identified and subsequent remedial actions.
Because Pilgrim was shut down and remedial actions were being taken, the staff decided that enforcement actions were not necessary but that specific remedial action satisfactory to the staff was necessary before restart.
In order to reach a position regarding its recommen-dation for restart, the staff sought out additional information on the status of planning from both the Comonwealth and Boston Edison.
It should be noted that Mr. William Russell, Regional Administrator, in a telephone conversation with-Mr. Peter Agnes, Assistant Secretary of Public Safety, in August 1988 offered to have NRC technical staff meet with the local Civil Defense Directors in order to determine the current status of emergency planning and areas of local concern.
This offer was declined by the Comonwealth. Mr. Agnes subsequently suggested that NPC staff review planning documents at the Massachusetts Civil Defense Authority (MCDA) offices in Framingham, Massachusetts. This review occurred on August 22, 1988.
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2 ENCLOSURE 1 The NRC is continuing to assess the progress of emergency prepareoness at Filgrim and to receive ccmments from Ccmmonwealth tr.d local officials.
FEMA review of documents submitted to them is also continuing.
The staff received comments from Mr. Agnes at an October 5,1988 neeting between Dr. Hurley, Pesten Edison Con.peny, and the Commonwealth.
Additicnal material was contained in a report prepared by Secretary Barry and received by the staff cn October 11, 1988.
The Commissioners were briefed on-the status of emergency preparedness at Pilgrim on October 14, 1988 and staff meetings were held with local officials of communities surrounding Pilgrim in late October.-
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..n MEMORANDUM FOR:
Chairman Zech FROM:
Victor Stello, Jr.
Executive Director for Operations
SUBJECT:
PHONE CALL WITH MR. J. DOUGLAS HADFIELD, CIVIL DEFENSE-DIRECTOR FOR THE TOWN OF PLYMOUTH, MASSACHUSETTS At your request, I called Mr. Hadfield on Friday morning (October 21)~to discuss his letter to you dated October 17, 1988. With me were Mr. James Taylor, Mr. William T. Russell, Mr. James Snierek, and Mr. William G. Kennedy to_ prepare notes of the discussion. After introductions, Mr. Hadfield and I discussed his-concerrt.
Mr. Hadfield explained that the list of special needs people was not up to date, altheugh a three-year old list had been updated with a few people that had responded to a recent newspaper article. Although Mr. Hadfield stated that he did not personally know of any others who should be added, he felt that othars probably needed to be added who were not on the list due to con-fidentiality concerns. When I asked why the list had not been updated, he responded that a survey by the state department of' handicap affairs was necessary but that funding had not been provided by the state or utility..
Mr. Russell added that he understood that the utility was willing to fund the survey but was awaiting the specifics.
I summarized that the current list was the best infomation available today and Mr. Hadfield agreed.
The next subject was the status of implementing procedures. Mr. Hadfield explained that none of Plymouth's implementing procedures have been submitted to the Massachusetts civil Defense Agency (MC0A). Three of the most critical implementing procedures have not been approved by the Selectmen.
(In fact, close to 60 have yet to go through the Board of Selectmen.) Two of the three-exist in draft form and have been approved by their respective department heads (for Fire and Police departments). The third procedure was for the schools.
The school superintendent decided to involve the two school couaittees in the appreval of their procedure and a meeting was planned for Monday evening (October 24) to get public input. When the procedure for=the schools is acceptable to the school connittees, it will have to be approved by the Selectmen. However, in Mr. Hadfield's professional opinion, all three -
implementing procedures were acceptable.
Nr. Hadfield also explained a concern for a point discussed at the October 14th Cemission meeting. He was concerned that the discussion about the beach population on page 97 and 98 of the meeting transcript may leave the impression that no one stayed there overnight when, in fact, there are residents who live-in the beach area, some year round, and it is only the-transients who are not pemitted to stay overnight. Mr. Russell assured him that we understood that and that the discussion in the transcript related to the transient beach popu-1ation only and not to permanent residents.
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l Chairman Zech 2
The next concern raised by Mr. Hadfield was that he was not sure that the individual procedures would work together.
I agreed that this aspect could only be evaluated by an integrated test; however, I explained that it was our i
experience that when a good job had been done on the individual procedures, like those at Pilgrim, the exercises usually go well and do not identify i
significant problems.
Mr. Hadfield acknowledged our experience.
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We then went back to the status of the implementing procedures and the staff's l
presentatior, to the Comission. Mr. Hadfield was concerned that no one on the NRC's staff could have sten his procedures because they have not been l
forwarded yet.
Mr. Russell acknowledged that there were two places in the l
meeting transcript where the staff had not stated the complete status in l
response to Comissioner questions. The staff had accurately characterized the.
l Plymouth status during the prepared presentation.
He added that the staff was going through the transcript and would clarify the statements where necessary.
Mr. Hadfield did provide infonnation that was new to Mr. Russell. in that the Jordan Hospital administrator was not yet satisfied with their procedure but that a draft existed. Mr. Hadfield and I agreed that the procedures were not " final" until after an exercise and will always be living documents subject to revisions.
The next issue raised by Mr. Hadfield was a question of manpower. He stated l
that no polls had been taken in Plymouth although the experience is that in emergencies, usually riore people volunteer than are necessary.
I acknowledged this.
We discussed the limitation on speakers at the NRR public meeting on October 5 and the Comission meeting.
I explained the Comission's policy on hearing speakers at their meeting and our expectation that the Comonwealth would integrete and present all local public concerns.
I also stated that given the apparent loss of public confidence after the NRR meeting, we probably should have allowed Mr. Hadfield and the other local. official to present their statements. He stated that he recognized the need to impose some limits on pblic meetings.
The last issue discussed was a question Mr. Hadfield had concerning any NRC requirements for calibration of radiological survey instruments.
I explained that we had requirements for those inside the plant but looked to civil defense authoritias to apply comen sense to keep their instruments in
- working condition. He stated that the questions stemed from the fact that FEMA will only reimberse the state based on a four year cycle.
Mr. Hadfield stated that the above covered all of his concerns but still requested a meeting.
In response to Mr. Hadfield's-request. I agreed to direct Mr. Russell to have one of his professionals meet with Mr. Hadfield. A Tuesday-afternoon meeting (October 25) was tentatively agreed to.
Finally, I asked Mr. Hadfield if he agreed witFme that the overall planning and state of preparedness was substantially and significantly improved in all areas over what had existed in~1985. He agreed saying that they were " light years ahead". We also a complete planning versus ad hoc response. greed that the real issues were L
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Chairman Zech -
Mr. Hadfield has reviewed this description of our discussion and agrees.
with its contents. We have accomodated his coments which are provided in the attached letter dated October 26, 1988.
wa :w.1 signed q s
Mc t or Ste12,ef Victor Stello, Jr.
Executive Director for Operations-cc: Comissioner Roberts Comissioner Carr Comissioner Rogers Comissioner Curtiss SECY OGC I
J. D. Hadfield
Enclosure:
As stated 4
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E;MERGENCY PREPAREDNESS
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.st r u, lose Mr. Victor Ste11o, Jr.
3:eoutive Director for operations United statts suolear Regulatory consission washington, t. c.
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Dear Mr. stollo,
I have reviewed the memorandum severing our telephone l
conversatten rf October 17, 1988.
After reviewing the document, I have the following_esaments.
Page 2 'rbree implementing procedu"ar inte not been approved by the Selestmea.'
This statement gives the tapression that.there are
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only three procedures remaining that have not yet been approved by the seleetsen.
In fast, elese to 40 have.yet to go through the Board of selectmen.
The statement should be changed to include this fact. taeluded in this statement should be the fact.that 3 of the most eritical-taplementing procedures have yet to be seen by the selectmen.
(These are the ones mentioned further on in the paragraphe pire, polies, and ashesis.)
Other than t.he above mentioned abanges, I agree wikh the senoraadas.
Sinceroly, hah
..,,, 7 J. Douglas I:tofield Director l
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November 1,1988 l
REMORANDUM FOR:
William Russell, Regional Administrator
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THRU:
R. Bellamy, Chief. Facilities Radiation Safety and Safeguards Branch, DR$$
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l W. Lazarus, Emergency Preparedness Section Chief FRS&SB R. Hogan, Emergency Preparedness Specialist, NRR
SUBJECT:
l MEETING WITH CIVIL DEFENSE OFFICIALS IN THE TOWN OF P DISCUSS THE STATUS OF EMERGENCY PREPAREDNESS ON OCTOBER 25
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BACKGROUND This meeting was conducted in the Plymouth E0C on October 1
25, 1988.
The purpose of the meeting was to obtain the latest factual information regarding the status of emergency plans, implementing procedures, and facilities,_
directly from the Director of Emergency Preparedness for the Town of Plymouth.
The Emergency Preparedness Director was.also prcvided.an opportunity to bring any previously unidentified concerns regarding the status of emergency preparedness to the attention of the NRC.
ATTENDEES J. Douglas Hadfield Director, Office of Emergency Preparedness Alba C. Thompson, Chairman, Board of Selectmen William J. Lazarus, Emergency Preparedness Section Chief, NRC Region I.
1 Rosemary T. Hogan, Emergency Preparedness Specialist, Office of NRR DISCUSSION Mr. Hadfield, and Ms. Thompson presented the following status sumaries anc concerns regarding the state.of emergency preparedness _ in the-Town of l
Plymouth.
Imolementino Procedures (IPs)
This status is based on Mr. Hadfield's coments, review of th". IP status list that was provided at the meeting conversation with Mr. Hadfield to clar(attached), and a tel'. phone 1988.
ify discrepancies c.. October 28,.
Of the 57 IPs identified on the attached list, all exist at'.least in-draft form.
The review process involves a review by the cognizant department head, then review by the RERP Comittee, and finally' review-and approval "in concept" by the Board of Selectmen.
As of the date of this meetin procedures,g, 34 IPs have been ' approved in concept".Of the remaining 17 have been through tie RERP Comittee -and are awaiting review by the Board of Selectmen..That leaves 4 procedures which have not been reviewed by the RERP Comittee. ' One of the 4-(Special' Needs-
l Plymouth t
Officer) has been approved at the department head level and is awaiting review by the RERP Comittee.
In addition to the IPs on the attached list, there are 34 shelter procedures.
The model for these 34 procedures (Shelter Manager Procedure) has been ' approved in concept' by the 8 card of Selectmen.
Review and approval of all of the IPs at the local level is expected to be complete in 10 to 12 weeks. The IPs which have not yet been approved at the department head level include Saquish..
Monitoring and Decontamination, and Jordan Hospital.
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The following items were identified as specific concerns which restin to be resolved before some of these-IPs can be. approved:
police: Division of responsibilities between the Plymouth Tolice and state police needs to be determined, as the procedu%s identify 40 access points and 40 traffic control are only 78 police officers available from Plymou$nts and there th.
The need for-protective clothing for police manning positions in the EPZ during radiological emergencies has not yet been determined.
Schools: The Joint School Comittee met on October 24, 1988 to review the school procedures.
There are 8 elementary. 1 intemediate, and 2 high schools involved.
The outcome of that review was not known at the time of this meeting.
In a telephone conversation on 10/28/88, Mr. Hadfield related that the committee did not approve the school procedure, but that-they had authorized-training for the elementary school teachers. Concerns have been raised regarding the appropriate way to notify parents of.
evacuation of the children; legal questions regarding transportation of school children out of the town; and the question of whether teachers would participate in the evacuation of the school children.
Still being considered is a change to the school procedures which would have children sent home at'the ALERT level rather than holding them at the. school and then evacuating them at the $1TE AREA EMERGENCY as the state would like. This is apparently being considered because children'would be moved before-the parents knew there was a broadcast-at the ALERT level. problem, since there is no ESS A joint comittee is attempting to resolve differences between Carver and Plymouth,in the procedure i
for the Carver (Regional) High School (which is shared by Plymouth l
andCarver).
I lbinital: Jordan Hospital has serious problems with their implementing procedure as it deals with the evacuation of patients.
Details of the concern were not known at this time...A second concern raised by Mr. Hadfield was that the Jordan Hospital is also the hospital which would be used for treatment of any
- injured / contaminated workers from the site in case of an accident,.
and he wasn't clear on how they would be handled if the hospital was evacuated.
The Jordan Hospital procedure was considered by i
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Pl> south 3
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i Mr. Hadfield to be the biggest obstacle to the completion of the IPs.
i Mr. Hadfield acknowledged that he had copies of the latest drafts of all implementing procedures in the E0C.
2 1/2 inch binders whereas the total previous town plan was a littleT i
more than an inch thick, personnel Resources i
Police need to work out division of responsibilities with the state police because there are too /ew Plymouth police to handle all the access control and traffic control points.
Soecial Needs Poeulation The town is still working to get people with special needs to 'self-identify'.
An advertisement is being placed in the local newspaper once per month for the next six months requesting that people with special needs contact the Emergency Prestredness Office-to have their names placed on a confidential list witch could be used to assist them in the event of an accident.
list maintained by the town.This process is hoped to update completely the Barry Reoort Mr. Hadfield indicated that although he had a problem with the state-complete regarding the status and problems faced by Plym not sure if the concerns with the Jordan Hospital procedure wereHe was-reflected in that report.
Reoresentation at the Commission Briefine on October
- 14. 1988 Mr. Hadfield and Mrs. Thompson both indicated that th concerns at the Commission briefing, although their comments lacked the specifics which they were bringing out in our meeting.
Saouish - Curnet Point Area At the present time there is not an adequate procedure for the protection of the 200 - 400 summer residents plus another 200 - 300 campers who would be in the Saguish - Gurnet. Point area.
The homeowners are working on development of a plan. The concern is that only road off the Saquish Beach area is under water for som.part of the.
time during the full moon each month, and that a boat is the only way e period of out during that time.
-1 Plymouth 4
i Imolementation of the plan When asked whether he thought he could isolement the plan and question due to the incomplete state of development; rev training.
make such an assessment. Individual department heads would be in a better p be pemitted until effective plans are in place, but that she was 3
l saying that a full scale exercise was necessarily required to make that-'!
deterstnation.
Mr. Hadfield did indicate that there was no question-l that they were ahead of where they were in the plannin years ago, and that they had made great improvenants g process a few i
Mr. Hadfield was provided a copy of this meno and indicated that it accur reflected the status he presented during our discussions.
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Willia'a J.
az q EPSe:tionChief,&Region !-
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S l-cc: J. Dolan, FEMA Region I
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