ML20059H810
| ML20059H810 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 12/07/1993 |
| From: | Fleming J AFFILIATION NOT ASSIGNED |
| To: | Selin, The Chairman NRC COMMISSION (OCM) |
| Shared Package | |
| ML20059H416 | List: |
| References | |
| RTR-NUREG-0654, RTR-NUREG-654 2.206, NUDOCS 9401310170 | |
| Download: ML20059H810 (5) | |
Text
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To the Chairmen of the NRC Dec.7,1993 1
, % mentoneM Resonnse tn Diractor'e Decisinn Under 10rFR 2.206*O Il 16 23 On November 26,1993 I received the Director's Decision to the 2.206 I presented to the Commissioners on ;
Oct. 30, 1991. The petition was accepted, as such, by i Chaarman Selin during that meeting. The majority of the work on the petition for the last two years was handled by Jim Partlow. Unfortunately, it appears, neither the l recommendations to the Director nor the Director's Decision l reflect the work and understanding of Jim Partlow. I want to ;
thank Jim, for the work he did and mainly for the time he j took to understand the goals I attempted to achieve thru this ,
Petition, mainly bring Emergency Preparedness for Pilgrim !
Nuclear Power Station into compliance with 10 CFR 50:47 and l NUREG 0654.
Staff's recommendation and the Director's Decision are blatant examples of the typical petty, vindictive and insipid attempts of Staff to diminish the importance and validity of the issues as well as demeaning the information and input I have made to the Emergency Preparedness process. In doing so, it appears Staff is once again attempting to mislead the Commission on the actual status of Emergency Preparedness.
How has Staff diminished the importance of issues and allegations and, once again, has attempted to mislead the Commission?
- 1. Staff has omitted pertinent and conclusive evidence established and documented by staff and the Final SALP, that the utility was unable to develop complete, accurate and timely information to enable the state to develop an accurate PAR.
petition.
Staff states this information is not related to the Staff chooses to ignore the fact that both the Chairman and the EDO were actively involved in enveloping l this information within my petition. Staff also informs me '
that the change I effected in the Final SALP was the first i time a SALP report was changed. Yet, this issue the very base 1 of all Emergency Planning is not "related to (my) petition" ?
(Since the Director's letter states this issue is not related to my Petition, I assume I can discuss this issue with the Commissioners.) .
- 2. Although my position that Emergency Preparedness is to be j evaluated against the standard set in 10 CFR 50:47 and NUREC '
0654 has been clearly stated and documented since 1988 and is clearly stated again in the 2.206 petition I presented.
Staff presents a lengthy arguments with the false assumption 1 I do not adhere to this philosophy. Staff argues the dose reduction issue, I have always agreed with the Commission's position on dose reduction. My zoal is to bring Pilgrim into compliance with the Federal Regulation and guidelines or as 9401310170 940118 1 PDR ADOCK 05000293 jaf 2.206 P PDR
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l the S6aff simplistically refer to them The Sixteen Standards for Emergency preparedness.
(This ploy was.so obvious and my position is so well established, documented and so clearly in line with the NRC.
position, I assume this does not need to be addressed. Staff-always forgets I learned E.P. from the NRC, but I learned from those on the Commissioners' Staff) AND THEY TAUGHT ME WELL!
- 3. All though Staff in the Director i s Decision reference the fact emergency. planning is not static; it relies. heavily on
" Documentation of Convenience",. outdated.and currently invalid documentation that is no longer applicable'to evaluating emergency preparedness. (e.g. Wellesley Reception Center) Staff uses 1991 documentation to find-Wellesley adequate and actually _ states it will be.testedLin the 91 Exercise, but does not inform'the Commission of the multitude of problems and inadequacies that did occur during that Exercise, nor does Staff inform'the Commission of the l l
well documented problem that are, currently present. Such as our Covernor decided in Sept 1992 to sell.the Wellesley Reception Center.
This I must add is an area. Jim Partlow spent many hours on, all his work was. conveniently ignored.by Erickson.
(The Director's Decision did not address the Wellesley Reception Center from Dec.1991 to date, therefore I assume this may be discussed with the Commissioners.)
- 4. Staff has intentionally misconstrued my statements to diminish the importance of the issue and simplify the problem. My position on the monitoring of School Children i does not deal with WHERE ,
it addresses IF or WHEN. Due to !
FEMA implementing the Krima's Memorandum, the school children !
of this EPZ have been skimmed out of the Reception Centers !
and will not receive monitoring when ~ evacuated. The Krimm's Memorandum (20%), when ever adjudicated, has been found to !
be without substance. j i
(The Director's Decision did not address this' area therefore I assume this can be discussed)
- 5. Staff attempts to mislead the Commission by ignoring the standard set in NUREG 0654 A 3. by stating on page.2 of the:
Director's Letter and 27 of the Directors Decision, l j
"However, such actions and measures are not considered-necessary and essential to adequate radiological emergency planning and preparedness."
(Since Staff did not appropriately represent the issue in the Director's Decision I assume this issue can be discussed-with the Commissioners.)
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- 6. Staff diminishes and misrepresents the important and positive improvements that have been achieved in the area of transportation over the last two years. These improvements have achieved almost entirely by MEMA and FEMA's acceptance of my input into this area. (Since the vast majority of my criticism have been accept ed by MEMA and FEMA and implemented into planning,over the last two years, I do not feel the need to discuss this area any further with the Commissioners)
I will send information in writing.
In their attempt to diminish my information Staff has effectively neutered the input and intervention of both the Chairman and the EDO of the NRC. Not to mention the total dismissal of the work Jim Partlow has done on this petition for over two years. The Decision's conclusions and dismissal of allegations are not founded in valid reasoning or professional judgements.
I have decided to present my arguments to the commission in a piecemeal fashion and will present the entire document and supporting documents next Tuesday when I will be present in Rockville. Today, Tuesday, Dec. 7,1993 I will present one issue Staff misrepresented.
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- 1. Lack of Compliance with NUREG 0654 A.(3).
To bring you right up to date I have just returned from a i' demonstration against the E.P. Exercise held today. The demonstra tion was organized by the majority of the Plymouth Emergency Preparedness Support Groups, or emergency workers.
the Plymouth Police Union, Fire Dept. Union and Public Works I Union at Memorial Hall Plymouth. The Union's positions are:
they will not participate in Emergency preparedness hennusa:
1.they have not been adequately trained, 2.they do not have adequate numbers of personnel,
- 3. communication systems are outdated, 4.the transportation schedules are unrealistic, 5.and the S ta t e and BEco have refused to listen to their concerns, criticism and suggestions about planning.
Jim Partlow and I have discussed and work on this issue for sometime now. The Director's Decision does not reflect that. Jim requested clarification of the issue from FEMA and the response explained Duxbury's position rather than Plymouth's. Duxbury is not the town at issue.
None of these support groups have even been asked to sign a signature page or a letter of agreement. They were unaware that NUREG 0654 A.3. was within the Federal Guidelines. They have been currently informed.
- 2. On April 27,1992, I received a written commitment from George Davis, Executive Vice President of Boston Edison to bring Emergency preparedness into compliance with NUREG 0654 A (3). I present ed this letter with my statement to Chairman Selin, The Chairman directed the statement and the Davis letter to Jim Partlow.
Mr. Davis commitment.has not yet been accomplished nor for that matter has any of the support organizations signed the signature page. I In the Director's letter and with in the text of the Decision it appears that staff is unaware of the Federal Guideline NUREG 0654 A (3). The Director's letter states and again on page 27 of the Decision it is stated:
"The NRC and FEMA do no t discourage agencies a.nd support organization from extending their planning and preparedness as far as they deem prudent and practicable, whien may include agreements and arrangements beyond those specifically described in Federal Regulations and Guidance. However,such actions and measures are not considered necessary or essential to adequate radiological emergency planning and preparedness. Thus, this allegation has no merit" Obviously Staff is not familia.- with NUREG 0654 A (3) jaf .206 m mumemes m m
which I specifically cited in my statement to Chairman Selin.
In accepting my statement and forwarding it to Jim Partlow he seemed to acknowledge and understand the existing Federal Guideline and how they are applicable in planning.
To help staff with their lack of familiarity with NUREC0654 A 3. as it appears on page 32 of that document; "3. Each plan shall include written agreements referring to the concept of operations developed between Federal, State, and local agencies and other support organizations having an emergency response role within the Emergency Planning Zones. '
The agreements shall identify the emergency measures to be provided and the mutually acceptable criteria for their implementation, and specify the arrangements for exchange of information. These agreements may be provided in an appendix to the plan or the plan itself may contain certain descriptions of these matters and a signature page in the plan may serve to verify these agreements. The signature l page format is appropriate where response functions are j covered by laws. regulations or executive orders where .
separate written agreements are not necessary." :
Staff should note that A.3. states
" support organizations having an emergency response role within the Emergency Planning Zone."
This means support groups such as State police, Coast Guard, Highway Departments, Town Employees, etc, who will i perform there role within the EPZ. The Director *s Decision :
spends a great deal of time and effort explaining why the Red Cross, which performs its role outside the EPZ in Congregate ;
Care facilities. Although the statement I presented to the j Chairman May 1, 1992 does not include any reference to the i Red Cross. By the way, the Red Cross has signed letters of '
agreement for various services it will provide. (See footnote 6 of the Director's Decision) The Red Cross' knowledge and understanding of the role they will play in Emergency planning was tested in the 1991 Exercise and the Red Cross did fine, certainly far better than the utility.
I do not only encourage but insist, due to the track-record of BECo's material false statements on this issue.
(e.g. National Cuard and former " Host Schools"), that MEMA obtain I.etters of Agreement from all support groups in and out of the EP2.
O.n .1Ag issue of comolinnee wi th Ji1IEEG AS14i A.3- the Director't Decision finding my allegation to be without merit il n21 valid.
Pilerim's Emerrency preparedness il D21 13 comoliance with NUREG D311 A.1.
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Chairman Selin Soston Edison
+) O P.R. Meeting May 1, 1992 Chairman Selin, it is very nice to see you again, especially in our neighborhood. I want to thank you and especially Boston Edi. son for this very gracious invitation to the public. I know you support a policy of openness but this is a rather newly developed attitude for Pilgrim. We do welcome the opportunity to address you personally , with our concerns.
In this area concerns fall into two broad categorges; HEALTH and SAFETY.
Health concerns have been discussed heavily lately with Mass. Dept. Of Public Health. I wish you were present at the Public Health Meeting last night to hear first hand some of the concerns we the Public have. I will leave with you a l copy of the testimony that at least I presented, perhaps you l could pass it on to your staff members who are currently j preparing the NRC's testimony concerning the State's Air ;
Emissions Standards. !
Last night we did receive a tentative commitment from MDPH to consider setting forth a standard that may help reduce emissions from Pilgrim and in the long run may help reduce the elevated numbers of cancers we experience in this area.
I As you know my first allegiance is to safety, Emergency Planning in particular. The Chairman and Commission did graciously extend to me the privilege of addressing the full l Commission on this topic last fall. I did so in the form of I a 2.206 petition, which you did accept as such. I am happy to report the NRC is giving a great deal of attention to this petition.
There are two updates regarding that petition I would like to personally inform you of:
First: The recent commitment I have received from George Davis. Vice-president of BECo. to secure either Letters of Agreement or signatures verifying agreement from all Emergency Planning Support Groups. This action will bring the Utility in compliance wi th NL* REG 0654 A.3. This. to my knowledge, will be the first time ever in the History of Pilgrim's Emergency Planning that we will have documented proof of real and actual commztments from the necessary support groups. No more will we have to rely upon the supposed secret agreements only whispered to a select few.
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Had BECo done this years ago they would not have faced the ;
embarrassing National Cuard issue.
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The Second Issue are the problems that surfaced during the Dec. Exercise -namely the onsite - offsite communication I
link. The NRC through Jim Taylor, Tim Martin and especially l Ebe McCabe has identified a multitude of problems in this ;
critical area. Essentially what I am discussing,_is the i utilities ability to develop the necessary information concerning accident status and being able to disperse that information to the proper State agency , MDPH, so they in l turn can have the ability to make a proper protective action guideline for the EPZ public. This is the most essential and basic area of planning. Without a proper PAG we have -!
nothing. This area was riddled with. flaws. l It is my understanding that the NRC and the Utility have !
agreed upon the corrective actions in both planning and ;
training that must be taken. This is being initiated by the !
Utility and will be followed up.on by the NRC. MDPH is not '
yet cooperating fully but I am sure now that we have a new and willing BECo Bob, they will come along. '
These two areas alone strongly indicate.that there is NO REASONABLE ASSURANCE. When you and the rest of The Commission voted on the Task Force Recommendation or Jim i
Taylor's recommendation to be accurate Not'to set the 120 j day clock; you had not-been made fully aware ofthese problems. Yet, I had identified both these areas.to the Task Force. l I am only one person. without' power, yet, I initiated l the actions to bring about correction of both these areas.
You. Chairman Selin have the power to correct all the hundreds of flaws that still exist in planning. Please, when my 2.206 Petition comes before you for consideration. set the 120 day clock and give to us the public the planning that the Faderal Regulation 10 CFR 50:47 mandates we should have.
Jane A Fleming l
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BOSTON EDISON Exscutive Offices 800 Boylston Street Boston Massacnusetts 02199 George W. Davis Executive vice Prescent April 21,1992 Mrs. Jane Fleming 30 Oceanwoods Drive Duxbury, MA 02332 Oear Jane:
Thank you for the enjoyable lunch. The Windsor House is special and will be aoded to my very !!mited list of the area's " good places to eat". I was disappointed that time did not permit a tour of the house. Another reason to return.
As you suggested, more formal, and binding arrangements witn EP participants than current exist are desirable. I will work to that end - both through Mr. Rocham and tne BECo. P organization.
Although I have moved my office to Boston, my wife and I continue to reside in Plymouth. We enjoy the area and the many friends we have made here. As you can appreciate, being a part of Pilgrim during the short 3 years,we have been here has posed some unusual challenges. I am satisfied, how,:,ver, th'at the plantis being operated and maintained professionally. Also, good progress is being made in realizing the goal of Pilgrim as a good neighbor Obviously, more needs to be done in both of these imocratives -- and it will be done.
Your daughter's swimming prowess is impressive - reflecting a lot of dedication and persistence on her part -- and sacrifice on yours. I wish her the best of luck in the weeks ahead.
Sincerely, I s
,bM^-9 G. W. Davis N
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Dc.cemo ca. 9 , f 9 8 3 To xhe. Cita.un.ma.rt a.rtd Commissiottes.s of the. r,IRC j i
R t.s p o rts e t o cite Dhe cator ' s D e.cisio n urtd c.n 10 CFR 2.206 l l
Prota.c.tLuc. Ac.tiort R ssomme.rtda.tiert '
i Part III My cAtegat4 ort wa.s : Irtterf a.c.L.ng wLthin the. pta.rt4 L.6 rtot i a.dc.quata.. Pa.gc. 2 2 of the. (dd)
The u.pda.ted aLLega,tLoit waA ; The. u.t< LLty was u.rtabtc. to dc.v cton 1 eomplc.tc. aa a.cc.u.ra.tc. prete.ctLu a. Ac.tLort a.nd c.ommu.rt.i.ca tc. tha t irtf ormatiort to the. propc4 Sta.4c. Au,thoritie.s 4rt a.it a.ccMatc. 1 artd tincty ma.rtnes."
Tlte. Dirc.ctor* s De.cisioit f ouatd :
- t rt ears e Iet ALort , sinc.e.
istf orma.tLort re.garding .titis mattaa. 44 wt4L docwne.Atc.d in the.
Ta.4h. Force. report (NUREG-7 43 8 ) irt SECY-91-19 0, and ist su.bsequ.ent statu.s re. ports , aitd has be.srt duty cortsidered by 4 the, Comm4ssiott , I f 4nd sto basis f or th.cs aitagatiort. "
r Th.c. DLac.ctor's Le,ttc4 44a.te.s :
"This 4te.m is stot relate.d to your pe.tttLort., howe.ver it witt '
being a.ddre.44e.d and re. solve.d throu.gh. th.e. NRC irtspsetLort i process. The. pea 444e.nt ' NRC re. port W444 be, made. a.va.4.4a.646 to ;
th.e. pu.bl.d.c whtst issu.a.d . '
The " pertt.ste.rtt" Re. port was issu.a.d Lt is the. :
FINAL SYSTEMATIC ASSESSMENT OF LECENSEE PERFORMANCE (SALP) REPORT NO. 50-293/91-99 l
The.
Addertdum to thc Firtat SALP irtdLca.te.d ,
- a. weahrtess Lrt pr.ote.c44ve, a.c.tiort re, comme.itdatiott (PAR) procc. dura. h.rtowledge.. Tite. irtspc.c. tors cortcLu.de.d -Jtat titerc. Was a.it 4rtdica.tc.d nee.d f or PAR proce. dure c4aA.4.4 Lea tiort citd/oir. trairtirts f or aA4 e. mea.ge.rtcy resportse. organ 4zadd. orts wito ma.y particd.pate. ist P A R d e.v e t o p m e.rt t .'"
( lt Ls my u.rtdcA sta.stdiae tha.t th.c. cha.rtgc. t c4f c.c.ted ist th.c.
f LitaA SALP ls th.c. f L4.44 citan9c. Of a. SAL P c.Ver sf f c.ctc.d b y a.
mere individu.at.}
Tite. 04 rec. tor a.ppears conf u 6e.d Lit orte. area he. .sta.tes mu atte.ga.tlors ha.s rto ba sis aLthou.gh. Lt e.f f scre.d a. chartge. a.rtd a.ddertdu.m a.dde d to a. SALP . t rL his LLLtes. he. LtLLs me. this are is rtot retc.te.d to my petittort, atthou.gh. three pa.ges of his DLre.cton.'s DecLstort aA.e. de.dicate.d to th.is issu.e..
To ctars4 y some. Of .the tortf u.siort ia.4 2 . 2 0 6 p 6
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- E 133: ;4:54 FG1 CMMUNIT/ F h 3 TO C015041C2 :.11 Th.c. Tash. F orcc. *Lrtding 4tAtc.:
P LaA4 and imptc.mcitt4.rtg proceduc.4 f or t.Jtt Mas 4a.cJta4c4t4 0LvL4 Dc,4 c.nsc. Age.rtcy MCDA (itow ititow a4 MEMA ) aAd tite.
Dc.oartme.rt.t 0f ?u.bL4c Hcalt)t a.it.d MCDA Arca. II tte.e.d to be ca.dc. I cortai4%e.rtz wi, tit tJt04e of L occi CommlutrLLes.
- St&tc. p ta.rt4 rte.e.d apec.Lfic proec. dure 4 4o guidc. of fic.uz.L*,
wh.o must meite pitotc.ctiv e. a.c.tiort de.cL4Lorta."
Irt the. Dirc.c. tor ' 4 De.c444ert ort pa.g e4 2 2 a.rtd 2 3 th.c. D4re.ctor of MEMA 44 q u.o te.d :
Titc. 4e.cortd are.a. L4 the. de.vetoprne.rtt of proce.dures ort pr.otectLv e. a.c.tiort dc.ci4Lort-ma.k.<.rt9 The. 4pe.cif Le procc.dt.ut.cs \
uthich provide, grtidance, f or prote.c.tive, a.ctLort dc.c.isiort a.se.
c.arr utity b tistg it.e.vLewe.d by FEMA a.rtd w4LL be c.Valu.a.ted in titc.
D c.c c.m b e4 ( 9 7 ) e.xc4c44e.. I Artd Lit the. Dirc.ctor' 4 De.c44Lort R4c)tard H. Strome, d4ACL44c.d t tite, re.viae d v c444 ort of tite. Sta.to pearts , MDPH'4 pro cc.dwtc4 as cortta.utc.d Lit NIAT. Tite.4c docume.rtro , S t t o m e.. 2.rplad it4 prov4de. i th.c. g ui.d e44.it e.4 a.std aro ec. dure.4 f oe o f f 4c.4 a44 mahx.rtg P A K ' 4.
Th.c. doctune.rtta will be. revie.w b y FEMA a.nd eva.tuate.d in the.
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Tit 44 44 whe$e. the. Dirc.ctor 4topa 44 will be. re.vic.wed in 91.
- L was a.rtd th.c. a b o v e. S ALP firm P 9 y re.co gnl.z e.d tJte myrLa.d of p >:.o b tem 4 that o ccurre.d .
The. D Lrc.c. tost. a.Dpcnta h.esLtArt.t to u.Dda.te. Latf armatiort thAt wou.td LrtdLca tL %Jte, currc.nt 4 tn +rr A Lrt p ta.rtrtLrtg . It 44 atow DEC. l 1995 the. c.uArutt 4ta.tR4 Lrt plann.4.rtg Itas detcrmirtc.d tita t th.e.
utiLi.ty did rtor dc.velop a. compte.te., a.ccura.te. or time.ty p AR .
Hor was the Utr.LLty a.ble. ta commu.nica.te the. PAR to .thc. Sta te.
Of ficaat in a. correc.t and timc4y f a4hiort.
will c.x.ptaa.A the, ft44 tory of wity tits.4 444u.e. 44 ist my p e.titLort and ) tow 4tc4f 4 p o44tiort iteattre.d the. 4rtte.rv e.rik40rt of th.c. Chauunan. a.rtd EDO of .th.e. NRC .
i citd ED07 How has Staf f rteatsre.d the. <.nteruc.n.tLort of tJtL ChaAsman Ort pa.ge. two of th t D4re,c, tor' 4 Lette.r to me.
( N o v .19,19 9 3 ) tre. D4rectro. re.f e,44 to a. docu.mert wh4 cit thA Dire.cror m44re,c4e.4e.n44 es a.it un44grte,d tertc4 to Cha4tman
, 5 clin. Th44, Lnde.g.d, wts an orat presenta.ttoat I ma.dc.
i pe44ona4ty to Chairman SeAin. ort Ma.y 1, 1992 at a. Bo4 tort EdL4 cit Pu.bt4c. ReL444crt4 me.e44rtg.
O.fithirt tha. ora.t prest.rttari. ort as usLL as th.c. Wr4.ttc.rt draf t I hcitdc.d t.ite. Chwr.ma.rt I cte.arly 44&te.d th.erc. wert .f.uro L44u.es pcatLnanx 4o my 2. 2 0 6 .cha.t would and Lrtdeed dLd u.pdarc. *Jte. Cha.4rma.rt ort:
1.
Th.e. tttMitica ina.0Lli.ty to de.veLop artd prope.nly commu.nica.ts, th.c. Lrtf orma.tious rtt.ces4ary f or .tha. Stets to de.ve. top th.c. correct Pro &tive. ActLort H46..susp 7
1 Tha va tidtty and au.44tanc.c. of .the. 4 2 m of the. 44comprara.
4a4camation, of tha. -Protect 4Vc. AcALon w&4 de4&rm44& MAU. th e; SALP Soc.rd. The In444a4 Salg Re. port Emergtncy ptanning evetu1. tion. omitted a. re. view of a.n.y docunent4 and rsport4 thcz }
4nd4cated th.a. prob 4em4 .that occuA. daarn.g .the. De.c. - 19 91 '
ExeA.:44e.. To b e, c.xac.c th.e. NRC c.v" Dn" *J n.g 4ta.f f ov srtoolt.sd thz l myria.d ef prob 4cm4 tha4 ' c.xi4ted I 044gina44y 4de.n.t.Q4td thtm l ro 74m Taylor. EDO, Not a 4444 den,c in4pe.c, tor a,4 th.a. report l fa44 cay ide.4444444. At th.c Sa,4p Ma.ert.ng I 4abmitte.d ta4timon.y ,
ind4c.2. ting the. obv4on4 omm4 tan.cs of pe.4.tinant documcatst4cn l and cue.n*" atty by th.t. F4ns4 Satp the. $ sty wa.4 change.and c.n a.ddc.n.du.m ws4 a.tta.ched to ind4cated ." , , .a. ne.e.d f or P AR }
procedua.c. c&c.4444ca. tion and/ or tn.ain4n.g f or att emergency scapon4e. orga.nitat4on. pcA4cnnc4 wh.o ma.y pcAt4cipa,4c. in PAR davciopment." l I undc44tand tha.t thdA 44 4u.ppo4e.d4y th.e. fir 44 44m4. a.
S ALP h.as b e.sn. c.hAn9e. a.n.d i ha.ye h.c.ard thAt 44 e4pLeiLLEy 4mporta.nA 44nce, I am ju44 c4 individual.. Wha 4 44 thc.
imp 04Canc.a. co tha. 2. 2 0 6 proce44,--h.sa.a 44 an. 444u.a. that ha4 been prove.n con.ciu.44ve4y---44 4ta.f f g4& owed 4L to be, p444 of my partition. th.ty c4A non coma, u.p w4tA 4AAnt. fu44444044404 there4 ort Stef f 4 tate.4 inacc,uAa.taly tA4.4 44 i4. n.44 4d"#*4 to my pe44t4on.. ( Af ter alt the. Comm4444.on won.'4 hAow 4At d44444 tace..) And on,ct a, gain. the. 444f f m444 tad 5 th4 Comm4444cn.
- 1. Th.e. Utilitis4 Ana.bitLty 4o de yeLop - a. c.om9464L and 1c. curate. PAR a.nd .th. sir in.a.btLLty to commganicstL c CCuASLc. and com94che. in4 ornation to the. propcA. StAtc. Authon444c4.
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On page two of thz 04re.ctor'4 L4 ten (Nov. 19,1993) to me.,
the. D4re.ctor m44chaAAc.tcAize.d my 4tatsmaat to the Chalanan a.4 "incroventn44 in, c.ommu.nicat40n. betwe.e.n. on444s and of f eita.
orec.nitat4ons." l The. D44tetor goe4 on. to 4ta.te. "thaA th44 4 tem 44 n.ot.retaAed to my petitioni" To claA.<.f y rhe. Otra.cror conf u.44cn. th44 l inda ed us4 not a. Ee.ttes, buz a.n. Oral prs 4e.n.tst40n. madL d4rc.cAly to Chairman Setia on. May '1, 19 9 2 st a. Boston Ed440n.
Pu.biic Relation. Ms. eking, 4044cwing my orat prese.n. tat 4on. I l otA4on44Ly h.anded a. written draf 4 of my ora 4 pre 4entation,to ChAinnan Satin.. In. a.ccept4n.g the, writte.n. dra,f L of my on&L preseAAAt4cn. the ChadAnan a.ppe.aA. 40 hAve. x cAsar ,
ut.dc44tanddag thaA th44 wa4 a part of my pe44 tion.. The. CC#A.on-the. Chriana.n. Look, with, this u.pdats; dativering thA 4tLtement to the. Staf f MenbeA. in, charge, of my pett'Lon. 4 . e. . Jin parttow. c44Ar4y 4r"'4""*t4 to me, thaA th e. Chs4rnax ws4 f atty awa.re. that .tA44 4nde.ed ws4 a.n u.pdare. to tha, pet 4 tion. he, accc.cted c4 au.ch, o n. O ct. 30,1997. (I ch.a.cA thia ind ormaAion wtth Jim PaA4 tow on. Nov. 2 9,' h.t. a.gre.g.d ws.th. my sn4Ly444 )
The f a.c4 that th.e. ChaAAnan .
origina4Ly 1 c.e.ptsd ay 2.206 pstLtion.14 4ach, antic.CCAntad MV Y
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u.paa44ag of rac. pmuuse vis Prc4e.44 c440 at tac,P.R. mootdag ws4 te.x4 of my 4tateme.rtt.
th.c. ELt. cur 4ve. Dinzctor of 0peAat40a4, 14m Ta.yLor. Ths 4a.24 that I ha.ve had ma.rty c.ommu.rt4cctioit4 ott th.44 444u.a. w4th both Ju Ta.ytor artd 74m Pa.sttow with the. clear undca.4tand4rts that 14thou.sh thi4 444u.c. Would be. hartdtc, throu.gA the. Sa4p Roard cs we.tt a4 w4th4.n. .thc. c.ortf 4 rte.4 of my pc4444crt. I am 4ure. the.
04re.c4cr w 4 cArorte.ou.44y m444c.d og Sta.f f to be44 cue. that thia L44ae 44 not a. paA4 of my pt.4<.t4crt. l l
A4 a f ath.e4 po4nt of ciaA4f 4 cation. wh.en I f4r44 utzrodu.ced thi4 matter to 14m Ta.ylor a.nd Ae. turste.d it over to i E b c. Mc ca.b e., there, wa.4 c. 44.c44a. conf u.444on. wAe.n. R4 chard cooper arte.mpted to ma.ite, 4A44 part of .the, a44e.gg,t4 cit proce44 , chru.
JM Ta.y4cr I was a.bta to 4 top 4Aa4 action, cnd h.tti.D th44 444u.a.
W4thirt th.e. cortf 4 rte 4 of my 2.206. But, wh.cn the. Irt4t4"4 $ ALP ;
came out and. tA44 entire. 144u.c wa4 oveA4ook.e4 I preacate.d th44 444u.a. to 4As. SALP Committee, and c.ve.rfis*14y art Addendum wa.4 a.dded to the. F4rta.4 SALP ich4cA d44ca44e.d 40mq. of tac. ;
444u.c4 brou.gh.t f or.th.. Urtf ortunate4y, tac. SALP d4d not \
4dentif y a44 444ur ! ratatd large4y in part , tha4 FncaA Cortsc4, Sob E44cA4 ort a.std Staf f d4d stot, 4Aru. theJp owet admi444 cit, rec.d the. n.e. port I pre.4cated.
The. Adde.rtdum to tat. F4nal S ALP va44d4f 4cA ma.rty of my 444u.c4. I wi44 ttta cA a, c.op y of the. e.ntira, re. port to tA44 4rt ordc4 f or th.t. Commi444 ort to be, prope.rty inf orme.d. Theac a4c.
two m44-44cte.me.nr w4 thin. th.c. c.ddendum bevortd the. omm4444 ort 4.
Ftr4t, The. ini.tial 4 dan.tLfLcat40rt af th44 444u.e. wa.4 during a.
cortucr4at4en. w4th 24m 7a.ylor E00, ryor a re44 dest 4 nape.ator.
Sc.cortd ac. cording to FEMA'4 eLcrciac, ana4g444 th.ere. wa4 art 44a.c.cau4c. Prote.c44vc. Ac.tiott de.velope.d by MDPH.
FEMA Entrc.i,Ae. Report pa.ge. 5 5 The. u.t444ty a.t the. EOF waa 40me.What ( extreac49 ) 44ow 4rt dc.ve4cping an. of f-44ta. PAR at th.a. GeacAa4 Emerge. rte.y ECL, A4 a ac4u14 , the. MEMA/MDPH EOF 44cf f 444u.s.d 4A4ar own 4rtiti"4 PAR to the Stetc. ECC. Whe.n. th.e. etility u4 tim =tc4y 444r4cd theJ4 PAR 44.wa4 d4f f tre.nc f a.om th.c. Liti44.c4 MEMA/MDPH EOF FAR. Th& MEMA/MDPH S44a.f f thert 4c.v44e4 th.gis ut4tial PAR to b e. eA+ 4rttic44y cort 444te.rtt wi.th th,e. ut444.ty P AR. "
Th44 44 a.rt inac.cusa.Lt. P AR cu e.rs .the. Adde.rtdum to the. SALP re. port c.oveAnlu.p the, grav4ty of the. 4M"ntion.. If tac,Et4444y ca.n. stot dt.ve40p tha. c.omplete, and proper inf orma44crLAnd f orther a prette44Ve, a.c44 ort THERE IS No EMERGENCY PLANNING. 9
1a suom u aola ti ve to mu pekt440rt.
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f December S.1993 To the Chairman and Commissaoners of the NRC from Jane A. Fleming Resoonee la Dire-+er'r Deeirinn t'nd er 10CFR 2,00 G Part 11 l Transportation If there is one area in which planning has greatly improved over the last two years, it is transportation. !
happily and proudly take credit for the majortty of the improvements. The Task Force Findings statementi
"_ Transportation procedures need to be better coordinated amont MCDA Area II. transportation providers. and the Towns.'
provided me with a partial springboard. The findings of FEMA's IG. which resul ted in the TWG analysis of my work gave me another great boost. This is an area we should all take delight in the improvenants that have been achieved in the last two years..
In this area I will address the director's decasion concerning the following:
3I31 Imolementine New fmoroved Letters gi trreement page ~11- Daractor's Decssion (dd)
Petitioner alleges that transportation is not adequate.
page (dd)
FEWA response to document marked enclosure and entitled
" Buses or the Lack Thereof" and staff's misrepresentatron of that this "is an exhaustive analysis that refutes _her allcration and substant aates a conclusion that transportation i resources are adequate.' I page (dd)
Staff's twisting and distortion of fact on this itsue even surprised me. '
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F EM A ' s TWG (transportation working group) did do an exhaustive analysis of my transportation analysts and in the majority of issues FEMA found in concurrence with my analysis They did uncover a few issues I was not aware of. A few of the issues we did not agree on. MEMA agreed wi th me and made the corrections I had requested. By the end of the analysts FEMA. MEMA and I were in fairly close agreement.
I was also delighted to learn that MEMA and FEMA accept ed my mobi l i r.a t t on time definition and premise. Now an jaf2.206p 1
most cases the buses with the lowest mobilitation time will !
he used to evacuate the school children. The definition
" Estimated Mobilization Time" that ! developed was accepted by MEMA and then FEMA it is now included in the NEW Letter.of-Agreement.
The above quote of Staff taken out of context. refers to the format of the letters of agreement . the format was indeed a worthless Lotter of Intent. The Task Force dad not
- eview that format but M EM A finally did and threw it out. ;
There nown exist a NEW LETTER OF AGREEMENT f ormat that was
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There now exist a NEW l.ETTER OF AGREEMENT forest that was ortgrnally amplemented at Seabrook and now d Pilgtta. I not -
only approve of ths LOA forcst currsntly in use. I wrote it. -
, I wrote 11 at ihe request of David Radham . Director of MEMA.
We have also hive greatly streamlaned and facalatated the once lengthy and ridiculous task of identifying the number of ,
buses needed and mobilization of them.
We are hoping to ha've a communication drill to determine exactly how long does it take to mobilise the buses.
(Notification of area !! transportation officers.
notsftcation of transportation pt'ovaders and actual contact with Individual bus desvers and their estimated arrival time
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to the bus then travel time to evacuation location er. schools ,
etc.)
It seems on the assue of t r ans po r t a t i on FEM AJ *.!EMA and I ar e ,
all singing from the same Hymn Book. Where as the NRC E.P. l group.
"The Task Force fouad that, although some of the LOA's were !
not cicar. concase or consastent. as a group ther were .
adequate to meet tte guidance of NUREG 0654" The Director's Decision found "no basis for Ms.(MRS) Fleming's unsupported allegations."
The Director's Decision f ailed to states When Mrs Fleming stated Transportation was inadequate she was correct. Due to the efforts of Mrs Fleming. FEMA and MMA transportation has greatly improved. since the Task Force disbanded. The E.P.
Staff also. obviously, forgot to say Thank You to Mrs Flemang for all her work in this area.
The c.haracteriration that BoS Erickson uses on page 7 of the (dd) to describe me reminds me of a quotable quote 1 once read.
"You learn the most about a persons character when he describes another" The terms " attacked. challenged the veracity of.
questioned the sincerity of" are all interesting when applied to the above quotable quote.
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1 1*ll take the time to correct one of bob's petty statements. The others I know the Commission can do on thcar own. And yes I realize calling bob's remarks petty, makes me petty as well. That man does brang out the worst in me.
"She challenged the veracity of private compenses that provide transportation resources an support of emergency planning."
No. bob. I never challenged the veracity of t he transportation providers. it was due to their honesty on the LOA *n I was able to challenge Boston Edison blatant misuse of the information provided.
It was their honesty that has provided me with the information to do my bus analysts year after year.
It was their honepty that ultimately caused the positive changes.
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a,4 h A l l ee n t i on ,that, ,thg, I,gg,k Fo r c e m d i s band ed be f o r e a f,,1 p,gJ,, r e c ouss e n d a t i o n y,gg m ad e .
Page Director's Decision The statement that Staff quotes on page is an accurate portrayal of a phone conversation I had with James Taylor, EDO of the NRC. If staff has a problem with this statement I suggest they speak to Jim Taylor. If the " facts are to the contrary" as Staff indicates I would be surprised.
Jim Taylor has always presented me with accurate and honest facts.
Staff goes on t o s t a t e " All, member s o f t he task force-concurred" Some members explained'to me they signed off, not necessarily in agreement with SECY 91-190.
As I stated the Task Force was disbanded before the Final Recommendation was made.
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Dir*ct Torus Vent Director's Decision pages 24-26 My allegation wasythe issues concerning direct torus vent ' I interfacing with emergency planning'are not yet resolved.
The director'sdecision goes through a detailed explanations of '
the actions BEco has taken since the Task Force' Findings were issued that have hopefully resolved the issues.
have been changed to interface E.P. and venting. IThe-I.P.'s have not reviewed them. I will accept the fact venting will not occur without E.P. being activated.
I do find it interesting the Director's Decision did not pass
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judgement that this allegation was with or without merityor '
substance. Only that the issue I raised was resolved %
. tag Oniek M M conf 1iet o_f, i n t e r e s t (dd) pages 6,7.16, !
First, the FEMA I.C.
stated he had insufficient evidence to substantiate the complaint regarding " conflict of Interest" That is not stating there is no conflict.
My allegation was"what criteria did the NRC use to find 32 poorly trained BEco Boys could'do the work of152 well' trained .
l Nat ional Guard'f It was the NRC's responsibility to justify i the acceptance of such a reduction of staff. It was not an !
attack onon depicted thepage Commonwealth
- 7. as the director's decision The Commonwealth did indeed shortly remove the BECo Boys from planning due to the " perceived conflict of Interest". -In the Dec.91 exercise they were not used.
My other issue was Staff acceptance of a utility interim solution is only acceptable when the " clock has been set" or the State withdraws from planning. Neither had happened.
The Director determined these allegations unsupported.
Only unsupported by the NRC once again. Eveyone else supported and acted on my position.
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