ML20062C248

Responds to Re NRC Testimony on Status of Offsite Emergency Preparedness During 881014 & 1209 Meetings

ML20062C248
Person / Time
Site:	Pilgrim
Issue date:	10/18/1990
From:	Carr K NRC COMMISSION (OCM)
To:	Dowd P, Hamadeh A, Vogler D DUXBURY, MA
Shared Package
ML19324J375	List: ML20062C248 ML20062C580
References
NUDOCS 9010300206
Download: ML20062C248 (2)

Text

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, [ rsog% g UNITED STATES

' 8 ' o NUCLEAR REGULATORY COMMISSION

{  ; ,E WASHINGTON, D. C. 20555 j

%,,,,,# October 18, 1990 CHAtRMAN l

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Mr. David J. Vogler, Chairman Ms. Patricia A. Dowd '

Mr. Abdulkader C. Hamadeh .

Office of Selectmen i Town of Duxbury  ;

878 Tremont Street -!

Duxbury, Massachusetts 02332

Dear Chairman Vogler and Members Dowd and Hamadeh:

i I am responding to your August 6, 1990 letter concerning-our '

Inspector General's 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 information pertinent to the restart.of the Pilgrim Nuclear Power Station.

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 3 provided by'the staff during meetings.with the Commission. The  !

Inspector General has confirmed-that there is not evidence sufficient 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.

In addition.to the " lessons-learned" review, a special task force has been established to review the comments and. documents pre-sented tolthe staff at.the September 6, 1990 public meeting in Plymouth.' 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 analysis.of any new informa-tion, on whether the Commission should reconsider its reasonable assurance finding.

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. Mr. David J. Vogler Mr. Patricia A. Dowd Mr. Abdulkader C. Hamadeh

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I should emphasize that, based upon the information currently available, the Commission believes that the status of emergency preparedness at Pilgrim currently provides reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency. In this-regard, the staff advised the Commission on August 3, 1990, that steady improvements in off-site emergency planning and capability have been made, as documented in the most recent periodic status report of June 28, 1990, r. copy of which is enclosed. The information for each town was individually reviewed and telephonically confirmed (in one instarce, the staff received written comments) by-locally-desigr,ated emergency preparedness officials prior to the submission of this status report to the Commission. Additionally, there was a full scale emergency planning exercise on October 12, 1989, and a remedial exercise on May 25, 1990. On August 31, 1990, the Federal Emergency Management Agency (FEMA) issued its Final Exercise Assessment of the October 12 and May 25 exercises. Although FEMA stated that the incomplete status.of some plans and lack of some documentation prevented-it from resolving all of the inadequacies identified in its August 1987 ,

report or certifying .the adequacy of State plans 'and procedures, FEMA observed that State and local organizations generally l

demonstrated excellent knowledge of their response plans and adequately implemented them. The FEMA. report also indicates that the two deficiencies identified during the October 1989 exercise

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were adequately resolved during the remedial exercise. No additional deficiencies were identified. For the foregoing reasons, the staff has concluded that the status of emergency preparedness at Pilgrim continues to provide reasonable assurance that adequate protective measures can and will be taken in the I event of a radiological emergency.

We believe the actions we. era taking are appropriate to= address the issues raised in the In;;*; tor General's report and the status I of emergency preparedness at the Pilgrim Nuclear Power Station.

Sincerely, l

Kenneth M. Carr l

Enclosure:

June 28, 1990 Status Report from J. Taylor to the Commission cc: Ms. Kate O'Brien Nuclear Affairs Committee Mr. Neil Johnson Radiological Emergency Response Plan Committee

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, ,i k UNITED STATES NUCLE AR REGULATORY COMMISSION 5  : W ASHING T ON, D. C. 20655 j

%,*...* JUN 2 81990 I

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l MEMORANDUM FOR: Chairman Carr Comissioner Roberts Comissioner Rogers Comissioner Curtiss '

Comissioner Remick FROM: James M. Taylor Executive Director for Operations

SUBJECT:

STATUS REPORT REGARDING THE PROGRESS OF 0FF-SITE EMERGENCY PREPARE 0 NESS ACTIVITIES

• AT THE PILGRIM NUCLEAR POWER STATION The staff has completed a review of the status of off-site emergency . _.- '

preparedness activities at the Pilgrim Nuclear Power Station. This information, is provided in response to the comitment made to'the Comission (Taylor to Comission letter dated February 5 1990) to keep the Comission apprised of emergency preparedness status. ThIsfirstreportsincethecompletionofthe Pilgrim power ascension program includes the results of the Remedial: Exercise conducted by the Comonwealth of Massachusetts on May 25,1990. The report format is similar to the emerg:.1cy preparedness sumaries previously submitted.

As in the past, the information was gathered in coordination with the Comonwealth and local comunities. .

This action has been coordinated with the Office of the General Counsel, which has no legal objection to this action, j J

YM sM.Tapor . .

xecutive Dsrector for Operations ,

Enclosures:

As stated cc w/encis:

000 SECY(WGlenn)

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l ENCLOSURE CURRENT STATUS OF EMERGENCY PREPAREDNESS FOR THE  !

COMMUNITIES SURROUNDING THE PILGRIM STATION 4 Progress continues to be noted in the state of emergency preparedness for Pilgrim in the successful conduct of the Remedial Exercise for the Comonwealth of Massachusetts on May PS, 1990, completion of renovations for the i Massachusetts Civil Defense Agency (MCDA) Area 11 Emergency Operations Center (EOC) and Wellesley Reception Center, continued resolution of Reception Center'  :

issues, and the continued active and visible involvement in the review process i by the Federal Emergency Management Agency (FEMA). ,

On February 1,1990, FEMA. issued a Summary of Deficiencies Report for the-performance of the Commonwealth of Massachusetts during the October 12-13, 1989 fu11< participation exercise. Deficiencies were noted in two areas (objective 3, pertaining to the ability to direct, coordinate and control emergency.

activities and objective 13, pertaining to the ability to coordinate the f formulation and dissemination of accurate information and instruction to the public in a timely fashion after the initial alert and notification-has ,

occurred). A remedial exercise was conducted on May 25, 1990. Preliminary r.

oral comments from FEMA indicated that the deficient areas were successfully ,'

corrected. FEMA has stated that the draft exercise report will be issued by July 1, 1990.

In Plymouth, 91 of 92 implementing procedures have been approved in concept by the Board of Selectmen and all have been forwarded to MCDA fo* review. All implementing procedures except for the school procedure have been forwarded to FEMA for technical review. MCDA is reviewing the school procedure. FEMA has not completed its review.

In Duxbury, all implementing procedures have been forwarded to MCDA and FEMA for technical review. FEMA and MCDA have not completed their reviews. In an agreement with MCDA, Duxbury has taken the lead in identifying and preparing plans and implementing procedures for host schools at the Wellesley Reception Center. Meetings have been conducted with the Needham School System (located neartheWellesleyPeceptionCenter)toexchangeinformationandadditional meetings are scheduled.

In Marshfield, the town is considering naming a host school within the town borders, but greater than 15 miles from the center of the Emergency planning Zone. MCDA opposes this action. Additional meetings are scheduled between Marshfield, MCDA and BECO planners to discuss this issue. There are no other >

major issues identified.

There are no major issues identified in the towns of Carver, Kingston, Marshfield, Bridgewater, and Taunton. Additional emergency plan and implementing procedure-

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' revisions are anticipated to address FEMA issues concerning exercise performance. Each town provided sufficient staff to conduct the October 12-13, 1989 exercise. Personnel to staff those vacancies that still exist are being actively pursued.

Each town completed sufficient training to adequately prepare and participate in the October 12-13, 1989 exercise. Refresher training for 1990 has begun in many towns and is scheduled to begin in the others. This training will be similar to that provided in 1989, but will capture revisions made to resolve l areas identified as needing corrective action as a result of the October 12-13, 1 1989 exercise.

Progress continues on the reception centers. In Taunton, the reception center is fully operational and was fully demonstrated during the October 12-13, 1989 exercise. Renovations to enhance operations are essentially complete. In Bridgewater, all equipment is in the town and available for use at the reception center. Staffing is complete except for Monitoring and Decontamination Staff. Bridgewater has officially requested MCDA assistance in this area as they can not support this function. MCDA is awaiting clarification from the Bridgewater Fire Department regarding this issue. Renovations at the Bridgewater State College are essentially complete. All remaining work is scheduled to be complete by June 1, 1990. In Wellesley, renovations are essentially complete. All equipment is stored at the facility. Red Cross has identified mass care facilities, although letters of agreement have not been e-executed. Parking is available onsite as well as at the Sun Life Company and ,

the Massachusetts Bay Comunity College. Transportation has been arranged for shuttle service from the remote parking areas. All areas are essentially fully staffed. MCDA has stated the reception center will be operational sometime this sumer.

I Regarding the next Public Information Brochure, BECo has comitted to the Comonwealth to produce the brochure in calendar format. Distribution is scheduled for November, 1990.

The staff hat continued to attend planning meetings with town Civil Defense Directors, local elected officials, Comonwealth and MCDA Area II officials that discuss the status of off-site emergency preparedness. FEMA continues to be actively involved with the Comonwealth and local towns, attending many meetings and work sessions, as well as the bi-monthly planning meetings.

The attached emergency preparedness sumaries provide the May 10 1990 status ofselectedemergencypreparednessissuesforeachtownsurroundIngthePilgrim Station, the Comonwealth and MCDA Area 11 as compared to that of January 5, 1990. The staff provided the sumaries to the respective town officials through the Civil Defense Directors of each area and subsequently contacted each official to verify the accuracy of the sumaries.

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CARVER EMERGENCY PREPAREDNESS STATUS AS OF 1/5/90 AS OF 5/10/90-EMERGENCY Renovations at the Plymouth FEMA comments have been PLAN AND Airport Emergency Worker incorporated. Additional- l IMPLEMENTING Monitoring and Decontamination - revisions may be necessary based 1 PROCEDURES Station are complete. upon the content of the FEMA l Recruitment of volunteers to staff Exercise Assessment Report, the facility is underway. There Recruitment of volunteers to staff are no other changes. the Plymouth Airport facility is underway. ,

l TRAINING . Refresher training will be 1.4sson plans and training conducted in 1990. This training' matrices have been revised and -

will be the same as offered in training / retraining has ,

1989 and will capture revisions commenced for 1990. Additi6nal made to resolve areas identified' ' lesson plan revisions may b6 as needing corrective action. The necessary based upon the content Implementing Procedure revisions of the FEMA Exercise l and resultant lesson plan- Assessment Report.

revisions are dependant upon the issuance of the FEMA exercise report.

STAFFING A staffing survey conducted by No change.

Carver identified one additional position. Currently 47 of 48-positions are filled.- Recruiting efforts are continuing for the remaining position. .

EQUIPMENT Pagers have been distributed. There are no other identified equipment needs.

EOC Fully operational. Fully operational.

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6 EXERCISE The Pilgrim Nuclear Power No change, Station full participation exercise was held on October 12 13, 1989.

Carver fully participated in this exercise. Preliminary findings ,'

presented orally by FEMA indicated that no significant problems were identified. The FEMA exercise report has not been issued to date.

STATUS REVIEWED BY: Helen Copello. Deputy Civil Defense Director DATE: May 18,1990 By Telecon with NRC C. Conklin. No comments.

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. t DUXBURY EMERGENCY PREPAREDNESS STATUS AS OF 1/5/90 AS OF 5/10/90 EMERGENCY FEMA has not completed the No change.

PLAN AND review of Duxbury's Emergency IMPLEMENTING Plan and Implementing '

PROCEDURES Procedures. The Advisory' Committee has reviewed 10 of 44' procedures.

TRAINING Refresher training will be I.esson plans and training conducted in 1990. This training matrices have been revised and will be the same as offered in training / retraining has 1989 and will capture revisions _ commenced for 1990. Additional made to resolve areas identified lesson plan revisions may be as needing corrective action. The necessary based upon the content.

IP revisions and resultant lesson of the FEMA Exercise '

plan revisions are dependant -

Assessment. Report. --

upon the issuance of the FEMA exercise report.

STAFFING Duxbury was essentially fully - No change.

staffed for the exercise. Some vacancies still exist and additional staff needs were identified during

. the exercise. Recruitment is continuin3 l

l EQUIPMENT Radar for the harbormaster has Duxbury is seeking means to .

, been identitled and procurement procure radar for the i is underway. School radios have harbormaster. The second floor not yet been received. Some of the EOC is operational, crowding was observed in the - however, additional furniture is EOC during the exercise. As a - still needed for this space, result, Duxbury has expanded some EOC functions to existing second floor space. Various equipment, telephones and furniture are required for this

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I EOC Fully operational. Fully operational. l l EXERCISE The Pilgrim Nuclear Power - No change.

Station full. participation exercise l was held on October 12-13, 1989. I Duxbury fully participated in this exercise. Preliminary findings ,

, presented orally by FEMA -

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problems were identified. The -

FEMA exercise report has not been issued to date. Duxbury felt that the exercise was an excellent training session for all personnel. Considerable resources, time and training were- '

expended prior to the exercise. '

Although all aspects of l

emergency response were not tested during the exercise, those areas that were tested worked well ami areas were identified -

where improvements or corrective actions are necessary.

HOST SCHOOLS The Commonwealth has assigned the Massachusetts Crimir.al Justice Training Academy in Needham as an interim host school for Duxbury and Marshfield. The Commonwealth would implement their executive order to assign schools necessary 1 to accommodate ary overflow.

Duxbury is still actively negotiating with Needham to procure agreement regarding the use of Needham schools as host schools for.Duxbury.

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i SPECIAL NEEDS ~ Duxbury still does not have a I l complete special needs list.

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STATUS REVIEWED BY: Carl O'Neill. Civil Defense Director DATE: May 21,1990 By Telecon with NRC C. Conklin. Comments incorporated.

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KINGSTON EMERGENCY PREPAREDNESS STATUS AS OF 1/5/90 AS OF 5/10/90 l

EMERGENCY FEMA comments on Kingston's FEMA comments have been PLAN AND corrective action response were incorporated. ' Additional IMPLEMENTING received on June 29,1989 and revisions may be necessary based PROCEDURES are being reviewed for upon the content of the FEMA i incorporation. Exercise Assessment Report.

TRAINING Refresher training will be lesson plans and training conducted in 1990. This training matrices have been revised and will be the same as offered in training / retraining has 1989 and will capture revisions commenced for 1990. Additional made to resolve areas identified lesson plan revisions may be as needing corrective action. The necessary based upon the content IP revisions and resultant lesson of the FEMA Exercise '

plan revisions are dependant Assessment Report. --

upon the issuance of the FEMA <

exercise report.

. STAFFING 44 of 46 operations positions and All operations and administrative r 7 of 8 administrative positions positions are filled.

are filled.

EQUIPMENT The pager notification system is No change.

operational. There an: no other identified equipment naeds.

EOC Fully operational. Fully operational.

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EXERCISE The Pilgrim Nuclear Power No change.

Station full participation exercise was held on October 12 13, 1989, Kingston fully participated in this exercise. Preliminary findings presented orally by FEMA indicated that no significant problems were identified. The FEMA exercise report has not

• been issued to date.

STATUS REVIEWED BY: Frederick Woodworth. Deputy Civil Defense Director DATE: May .18,1990 By Telecon with NRC C. Conklin. No comments I

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i MARSHFIELD EhERGENCY PREPAREDNESS STATUS AS OF 1/5/90 AS OF 5/10/90:

1 EMERGENCY The Marshfield School Nuclear This issue is still unresolved, PLAN AND Evacuation Committee (consisting however Marshfield is actively 1MPLEMENTING of school principals and the working towards resolution. ,

PROCEDURES superintendent) are looking at '

utilizing a host school within Marshfield but 15 miles beyond -

the EPZ. MCDA opposes this action. A meeting is scheduled for 1/17/90 with state, town and BECO planners to discuss -

possible options.

TRAINING Refresher training will be lesson plans and training ,

conducted in 1990. This training matrices have been revised an'd will be the same as offered in training / retraining has 1989 and will capture revisions _ commenced for 1990. Additional made to resolve areas identified lesson plan revisions may be -

as needing corrective action. The - - necessary based upon the content IP revisions and resultant lesson of the FEMA Exercise plan revisions are dependant Assessment Report.

upon the issuance of the FEMA exercise report.

STAFFING All key positions are filled. No change.

-Recruiting for volunteers for remaining non key positions is ongoing.

EQUIPMENT The pager notification system is No change. i i not acceptable to the Civil I Defense Director. Negotiations - l l

are ongoing with BECO regarding an alternate system.

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EOC Fully operational. ~ Fully operational.

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EXERCISE The Pilgrim Nuclear Power No change.

Station full participation exercise was held on October 12 13, 1989.

Marshfield fully participated in this exercise. Preliminary findings presented orally by FEMA indicated that no signitkant problems were identified. The FEMA exercise report has not been issued to date. ,

STATUS REVIEWED BY: Maureen Robinson. Civil Defense Administrative Assistant DATE: May 18.1990 By Telecon with NRC C. Conklin. No comments

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PLYMOUTH EMERGENCY PREPAREDNESS STATUS AS OF 1/9/90 AS OF 5/10/90 EMERGENCY 91 of 92 IPs have received - All procedures are in the process PLAN AND Selectmen REVIEW AND of revision after the actual IMPLEMENTING APPROVAL IN CONCEPT. All exercise. From revision stage, _ ,

PROCEDURES 92 IPs have been forwarded to they go back to the Radiological MCDA for review and Plymouth Emergency Response Planning '

has authorized MCDA to forward Committee, then back to the all IPs but the School IP to Board of Selectmen. No' time FEMA for technical review. frame can be given at this time ,

for completion.

Clarifying information added by Plymouth.~ The Saquish/Gurnet egress issue has still not been resolved. The School Dept. IP has still not received School Committee Approval by either C mittee. ,

TRAINING Refresher training will be Refresher training has started conducted in 1990. This training (Emergency Worker Monitoring  !

will be the same as offered in and Decontamination Station 1989 and will capture revisions staff in March). ' New hires in made to resolve areas identified ' Town Departments have received as needing corrective action. The Introductory Training only. Some IP revisions and resultant lesson additional new hires are left to plan revisions are dependant do.

upon the issuance of the FEMA l exercise report.

l STAFFING Plymouth was essentially fully No change..

staffed for the exercise. Some vacancies still exist and recruitment is continuing, EQUIPMENT There are no current identified There is no change regarding  ;

i equipment needs. EOC equipment needs. Other  !

. departments, outside of the EOC, l have some requests due to

shortcomings during the. October, 1989 exercise. No action has -

been taken by BECO as of this date.

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EOC Fully operational. Fully operational.  ;

EXERCISE The Pilgrim Nuclear Power Plymouth is working on problems Station full participation exercise encountered during the exercise was held on October 12 13, 1989. and is awaiting the FEMA report Plyrnouth fully participated in this for additional changes, exercise. Preliminary findings presented orally by FEMA indicated that no significant .

problet;.; were identified. The FEMA exercise report has not been issued to date.

STATUS REVIEWED BY: J. Douglas Hadfield. Director, Office of Emergency --

Preparedness and Alba Thompson. Chairman, Board of Selectmen.

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l. DATE: May 18,1990 By facsimile transmission to NRC C. Conklin. Comments incorporated.

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BRIDGEWATER EMERGENCY PREPAREDNESS STATUS l

AS OF 1/5/90 AS OF 5/10/90

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EMERGENCY FEMA comments on FEMA comments have been ,

i PLAN AND Bridgewater's corrective action incorporated. Additional l 1

i IMPLEMENTING response has been received on revisions may be necesst.'y based PROCEDURES June 29,1989 and is being upon the content of the T.iMA l reviewed for incorporation. Exercise Assessment Report.

l TRAINING Refresher training will be Lesson plans and training conducted in 1990. This training matrices have been revised and j will be the same as offered in training / retraining is scheduled to 1989 and will capture revisions commence in May,1990.

made to resolve areas identified Additional lesson plan revisions as needing corrective action. The may be necessary based upon the l IP revisions and resultant lesson content'of the FEMA Exercid l plan revisions are dependant Assessment Report.

upon the issuance of the FEMA l

exercise report.

EOC STAFFING Key and support staff are being All key staff positions are filled, re identified. There are some Some vaca.icles in support vacancies and recruitment for positions, such as runners, volunteers is ongoing, message handlers, etc, still exist and are being actively recruited.

EQUIPMENT The pager notification system has Bridgewater has agreed to been deliured and installed as purchase this radio utilir.ing town well as hand held radios and the' funds.

l CB unit. An additional 2 meter I

radio'need was identified.

EOC Fully operational. Fully operational.

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j RECEPTION Renovations have commenced All renovations are complete CENTERS but are currently on hold because except for the Diesel Generator.

Bridgewater Fire Department has The Diesel Generator has been stated they cannot support the installed, and remaining work is i monitoring and decontamination scheduled for completion by June efforts required. Bridgewater is 1,1990. MCDA is awaiting in the process of officially clarification from the Fire requesting assistance from Department regarding this issue.

MCDA regarding this issue. There is no other change to date.

MCDA has been informed of the problem.

EXERCISE The Pilgrim Nuclear Power No change.

Station full participation exercise was held on October 12 13, 1989.

I Bridgewater fully participated in this exercise. Preliminary findings ~

presented orally by FF.MA ,

indicated that no significant problems were identified. The FEMA exercise report has not been issued to date.

STATUS REVIEWED BY: J. Pinault. Assistant Emergency Management Officer. ,

DATE: May 18,1990 By Telecon with NRC C. Conklin. No comments.

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TAUNTON EMERGENCY PREPAREDNESS STATUS i AS OF 1/5/90 AS OF 5/10/90 l

EMERGENCY The Emergency Plan and No change.

l PLAN AND Procedures have been revised to IMPLEMENTING incorporate FEMA comments l PROCEDURES and to reflect the change in the Reception Center location. .

These revisions have been ,

prosided to MCDA.

TRAINING Refresher training will be 1.esson plans and training conducted in 1990. This training matrices have been revised and will be the same as offered in training / retraining is scheduled to 1989 and will capture revisions commence in July,1990.

made to resolve areas identified Additional lesson plan revisions as needing corrective action. The may be necessary based upon th'e IP revisions and resultant lesson content of the FEMA Exercise plan revisions are dependant Assessment Report.

upoa the issuance of the FEMA enicise report.

EOC STAFFING All operations and administrative No change.

positions are filled.

EQUIPMF.NT All equipment has been delivered No change, and is in place. There are no identified equiprnent needs.

1 I EOC Fully operational. Fully operational.

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RECEPTION Renovations have commenced All renovations are essentially CENTERS and are scheduled for completion complete. Exterior lighting work by 4/1/90. remains to be completed.

EXERCISE The Pilgrim Nuclear Power No change. 1 Station full participation exercise was held on October 12 13, 1989.

Bridgewater fully participated in this exercise. Preliminary findings presented orally by FEMA indicated that no significant problems were identified. The FEMA exercise report has not been issued to date.

STATUS REVIEWED BY: Robert Spendn. Civil Defense Director '

DATE: May 18,1990 By Telecon with NRC C. Conklin. No comments. ,

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i MCDA AREA II EMERGENCY PREPAREDNESS STATUS i

4 AS OF 1/5/90 AS OF 5/10/90 EMERGENCY Procedure revisions are Procedure revisions based upon PLAN AND continuing based upon known exercise observations, as well as IMPLEMENTING exercise observations, other revisions for program PROCEDURES enhancement are continuing.

Area II has not received FEMA comments regarding their Implementing Procedure submittal. I l

TRAINING Refresher training will be Many of the lesson plan revisions i conducted in 1990. This training can be made prior to the I will be the same as offered in issuance of the FEMA Final l 1989 and will capture revisions Assessment Report. Training in, made to resolve areas identified support of the Remedial Exercise as needing corrective action. The has commenced.

• IP resisjons and resultant leston plan revisions are dependant upon the issuance of the FEMA exercise report.

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l STAFFING Area 11 is fully staffed utilir.ing Although discussions are ongoing l l MCDA and National Guard with the National Guard l l personnet. MCDA Area 11 is regarding staffing at Area !!, no I I

currently working on an formal agreement has been agreement to ensure long term executed.

continuity and trainhg of the National Guard staff.

EQUIPMENT See status of EOC. No change.

l EOC The renovations are complete. No change.

I Equipment, communications and telephones are in place. There are several areas requiring additional rework and/or

equipment and MCDA Area 11 and BECO have agreed upon these areas. The EOC is very large. The old operations room is dedicated for communications support staff. The new operations room has ample space for the Area 11 staff as well as for representatives from the f towns. There are several private 1 offices available for the towns ,

i and MCDA as well as a '

combination classroom / conference room.

EXERCISE The Pilgrim Nuclear Power On February 1,1990, FEMA Station full participation exercise issued a Summary of Deficiencies was held on October 12 13, 1989. Report for the Commonwealth MCDA Area 11 fully participated operationt.. Deficiencies wer_e. '

in this exercise. Preliminary noted for objective 3, ability to ,

direct, coordinate and control findings presented orally by FEMA indicated that no emergency activities and objective  ;

significant problems were 13, ability to coordinate the identified. The FEMA exercise formulation and dissemination of report has not been issued to accurate information and i date. instruction to the public in a timely fashion after the initial alert and notification has >

occurred. A remedial exercise is scheduled for May 25,1990. '

STATUS REVIEWED BY: Thomas Rodner. Director MCDA Area !!-

DATE: May 21,1990 By Telecon with NRC C. Conklin. Comments incorporated.

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CC,MMONWEALTH OF MASSACHUSE*ITS EMERGENCY PREPAREDNESS STATUS AS OF 1/5/90 AS OF 5/10/90 EMERGENCY MCDA EOC procedures were No change.

PLAN AND submitted to FEMA for technical IMPLEMENTING resiew on August 10,1989.

PROCEDURES TRAINING Refresher training will be Many of the lesson plan revisions conducted in 1990. This training can be made prior to the will be the same as offered in issuance of the FEMA Final 1989 and will capture revisions Assessment Report.

made to resolve areas identified as needing corrective action. The IP revisions and resultant lesson pitn resisions are dependant upon the issuance of the FEMA ,

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STAFFING All EOC positions are fully No change, staffed.

EQUIPMENT There are no outstanding Several status boards currently in equipment needs, although EPZ use at the MCDA Area 11 EOC ,

and Ingestion Pathway Zone have been identified as being (IPZ) maps need to be updated, needed at the EOC. EPZ and IPZ maps need to be updated. i EOC Fully operational. Fully operational.

RECEPTION Renovations are essentially Renovations are essentially CENTERS complete at the Wellesley complete at the Wellesley DPW  !

Reception Center. A large EOC Reception Center. An EOC has has been constructed with ample been constructed with room for room for support staff including: support staff including: enclosed an enclosed security access area; security area; message control a message control area; a area; reception center manager's Reception Center Managers office; conference room; office; executive conference operations room; operations room; large EOC operations officer's office; emergency room; Operations Officer room; response coordinator's office; and Emergency Coordinator's office; a communications / radio room.

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and a communications office. Furniture, most equipment, radios Furniture and equipment is on and telephones have been premise and scheduled to be installed. There are two installed by 1/5/90. Telephones segregated areas for and radios are scheduled to be decontamination. Each area has installed by 1/12/90. There are a collection and change area, segregated areas for shower stalls, lavatories, toilets, f decontamination. Each area has and a clean clothing area. Waste L a large collection and change water collection bladders are .

area, five shower stalls,10 stored on the premises and would lavatories, several toilets, and a be connected to the drains upon clean clothing area. Waste water facility activation, however, the =

storage bladders are stored on connectors, which need to be premise and will be hooked up to custom manufactured, have not the drains upon facility activation. yet been made. The connectors All plumbing renovations are are the only outstanding scheduled to be complete by plumbing items, but they are 1/12/90. MCDA expects the crucial to operation of the '

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Reception Center to be fully facility. The Red Cross, MCDA a operational by 3/1/90. The Red and BECo are identifying .,

Cross, MCDA and BECO have facilities for mass care shehers.

identified 40 facilities for mass These arrangements are not care use. All routes have been complete, nor have the necessary traveled to ascertain distances letters of agreement been and travel times. The Red Cross executed between tne Red Cross will perform a detailed shelter and the four towns involved. _

survey and select approximately Traffic routes are currently being '

12 of these facilities as designated checked and corrected so that ,

mass care facilities. The accurate maps will be available remainder will be available for for both the public and the --

overflow as required. MCDA MBTA. Host school expects this activity to be arrangements for Duxbury and complete by 6/1/90. Duxbury has Marshfield school children are -

the lead in working with not complete. An Executive Needham to develop host school Order for seizing public facilities plans (see discussion under for this purpose has been drafted Duxbury). MCDA is also and would be used as an interim ,

i working with the State Criminal plan until schools can be Justice Training Center which is designated for the school available to host Marshfield children. The Wellesley DPW school children. The Emergency RERP has not been updated Plan is essentially complete with since August 1989, however, no minor revisions necessary updates are scheduled until 2 dependant upon Implementing staffing has been completed and Procedure (IP) revisions. 20 of IP revisions made. The only

21 IPs have been drafted and staffing vacancy is for the four have been approved. The Department of Education EOC remaining IP, Disaster Assistance Representative. Annual refresher Team (Counseling) has been training has been temporarily conceptualized but not yet halted at the facility. The drafted. The Emergency Plan outstanding certificate of and IPs are scheduled to be occupancy will not be issued by finalized and approved by 6/1/90, the state until certain problems, Staffing is essentially complete for such as the falling ceiling tiles in both EOC and Reception Center the EOC, provision of computer Operations. The only known equipment, and renovation of vacancies are state agency 5:ihrooms for the handicapped representatives in the EOC for public, have been corrected. The Education and Social Services. National Guard cannot schedule Annual refresher training is training until November,1990, scheduled to cover all major and therefore their training changes and willinclude EOC schedule has been pushed back.

tabletops and Monitoring and It is estimated that the Wellesley Decontamination walk throughs. DPW Reception Center will be MCDA's goal is to have all operational sometime this ~ .-

training complete by 6/1/90. summer. ,

There is room to park approximately 800 contaminated cars at the Wellesley site. An 4 agreement is in place with Sun Life to park approximately 1200 cars and there is additional  ;

capacity of approximately 900 at i the Massachusetts Bay Community College, a state run facility. The Massachusetts Bay Transit Authority will provide shuttle transportation from the remote parking areas. MCDA has scheduled 6/1/90 as the date the Wellesley Reception Center i will be fully operational.

i i

TRANSPORTATION Refresher training will be Many of the lesson plan revisions PROVIDER conducted in 1990. This training can be made prior to the TRAINING will be the same as offered in issuance of the FEMA Final 1989 and will capture revisions Assessment Report.

made to resolve areas identified as needing corrective action. The

IP revisions and resultant lesson plan revisions are dependant upon the issuance of the FEMA exercise report.

TRANSPORTATION MCDA and BECO have asked No change.

PROVIDER all providers to resubmit the LETTERS OF letters of agreement including AGREEMENT updating of available resources.  :

BECO has stated all but one letter has been received and there are no significant changes in resources noted. The entire package will be submitted to I MCDA when the remaining agreement is received.

PUBLIC Distribution completed 9/30/89. BECo has committed to the r INFORMATION Commonwealth to produce e BROCHURE calendar format brochure.

Distribution is scheduled for November,1990.

EXERCISE The Pilgrim Nuclear Power On February 1,1990, FEMA

. Station full. participation exercise issued a Summary of Deficiencies was held on October 12 13, 1989. Report for the Commonwealth The Commcawealth fully operations. Deficiencies were participated in this exercise, noted for two objectives. A Preliminary findings presented remedial exercise is scheduled for orally by FEMA indicated that no May 25,1990, significant problems were identified. The FEMA exercise i report has not been issued to date.

STATUS REVIEWED BY: Jeffrev Hausner. Director, Nuclear Safety and Emergency Preparedness DATE: May 18,1990 By Telecon with NRC C. Conklin. Comments incorporated.

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PATRICIA DOWD wk I"'

O DAVID J. VOGLER ABDULKADER C. HAMADEH August 6, 1990 Kenneth Carr, Chairman I U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dear Chairman Carrt The Office of Inspector General's report of July 23, 1990 on the NRC Staff review of Pilgrim off-site emergency preparedness clearly demonstrates that the Commission's December 1988 authorization to restart Pilgrim was based on false and incomplete information about the status of off-site emergency preparedness.

As you may know, the Duxbury Selectmen called for a congressional investigation of the behavior of NRC staff in the review process in letters sent to Representative Gerry Studds and Senator Edward Kennedy on October 19, 1988.

Our review of the 01G report, including the NRC staff comments and OIG responses in Appendix 1, leads us to believe that the NRC staff at.tively mis- {

represented the status of off-site emergency preparedness in addition to providing an assessment that was, in the words of the OIG report, "neither balanced nor thorough" and relying on information obtained from the Boston Edison Company rather than responsible local officials. The NRC staff Comments Numbers 8 and 20 (pages 28 and 38) illustrate our point. When staff members continue to refer to 3 a memorandum entitled, " PILGRIM NUCLEAR POWER STATION MEETINGS REGARDING EMERGENCY PREPAREDNESS", as evidence of a meaningful dialogue with local officials about emergency preparedness issues even after the 01G report made it clear that none of those meetings were held for the purpose of discussing emergency preparedness and they followed a format that precluded any meaningful dialogue, then staff members are actively misrepresenting the review process - a much more serious concern than failing to be balanced and thorough in their assessment.

In addition to the failure of the NRC staff to provide an objective assessment of off-sito emergency preparedness, it appears that the Commission itself ignored the statement and supporting information provided by Duxbury Selectmen Patricia Dowd and other officials at the December 9. 1988 Commission meeting. Moreoever, on October 26, 1988 Duxbury officials direc;1v provided NRC staff members from Region I with information to correct the inaccurcies and misrepresentation of 1 the NRC staff at the October 14, 1988 meeting.

i 878 Tremont Street

• Duxbury, Massachusetts 02332 * (617) 9344586

. gogg .

Chairman Carr Letter

.8/6/90 Page 2 k'e believe that the disregard for the safety of the citizens of Duxbury t

evident in the NRC staff assessment requires the immediate dismissal of those t staff members responsible for providing the Commission with inaccurate and l incomplete information. Since the NRC decision t o authorize the restart of l Pilgrim was based on incomplete and inaccurate-information and since the Commission itself appears to have ignored direct evidence on off-site emergency i

preparedness presented by the local officials, we call on you to reconsider your December 21, 1988 decision to authorize the restart of Pilgrim and to initiate a second review and assessment of off-site emergency preparedness. Finally,

because we believe that the failings of the review process evident in this case require congressional action to ensure t hat the public safety is protected in future decisions, we are calling once again for a congressional investigation of the decision to authoriec the restart of Pilgrim.

Sincerely,

%k

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, Patricia A. Dowd DavidJ. Nog 1pr Abdulkader C. Hamadeh Chairman cc Senator Edward M. Kennedy Senator John F. Kerry Senator John Glenn l Representative Silvio R. Conte Representative Edward P. Boland l Representative Joseph D. Early Representative Barney Frank l Representative Chester G. Atkins l Representative Nicholas Mavroules l Representative Edward J. Markey Representative Joseph P. Kennedy. II Representative John Joseph Moakley Representative Gerry E. Studds Representative Brian J. Donnelly Assistant Secretary Peter Agnes, Public Sa fety Nuclear Affairs Committee Radiological Emergency Response Plan Commi'; tee BOS/tg

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Nuclear Affatre Committee Town of Dunbury Dunbury, Massachusettu August 13, 1990 henneth Carr, C h a a r nian U. S. Nuclear Regulatory Commicsson u nhinaton. DC 20$55

Dear C h a t r rria n C a r r :

The rtatutes and regulatione governing the Nuclear Regulator';

Comnii ss,1on are founded on the premise that t he Conimi s sion's decittons will be bened on eccurate information, tairly and  !

conipletely essossed and presented to the. Conirnissioners by ths 14PC atoff. In the cace of the Commissions' 1900 outhorication to=

restart t he Pilgr im S te t t er, power plant, and to ascend above L".

power in April 1999, t he f undanien t al rareiraise f ailed. The July 27 1990 report of the ottice of the Inspector Gwneral could herdly i have been niore clear that the inf orniation provided by the staf f tc '

the Comn.ie cien, end on whi ch the Commission based i t s: December 21, 1900 decision perniitting restart. did not meet the test. It is also clear that permission to ascend above-UX In April 1984 *e sinil lor ly based on inaccurate information. At the IG founds (1) "The statfs' as so u snien t ... tras neither balanecd nor thorougn." It "r elle d on inf ernint ion provided f rom the Donten Gda son Conipany" even though, "In light et DCCO's ves t ed i nt er :n.t in re. tarting Pilgrim. l'ECO was not the best source for the tiRC l cteff to rely on...."

tii) The staff "did not contact recconsible ... en.er g e r. cp ctficiels in a t insely manner" .

l (iii) The staff "did not reconcile differences.in credible i ntorn.at ion t hey received from various sciur ces. "

.v) The Staff'*did not.Nalidate i t.f ornic t ion they stes,.idJ. s iv) The s t a f f was redpensible f or - prov i Wi n ci .n o .n ci.u e e t c nornor.ratinn of the r,tatun.of P1Igrim off-cite. emergency prepn odnets for t he Con.niis cioner's considaret:en" but'"portsei'  !

of thu staff's presentations ... were inaccurate."

In short, the IG found that,when the Commission decidec. At  ;

required o9 10 CFR 50.47(r.)(1-), that "there is reasonable ensurance that adeounte protective measures can and w111-be taker in the event of'a radiological emergency",-it'did not do co Da wJ on a proper staff a s se s sn.a n t .

.00N e h0tttift .

r C

s henneth Carr Page O The August 6, 1990 letter t o you t r orn t he Duxbury Solectrneen tcopy enclosed) pet rits out "the disregard toe the safety nt the i citi: ens of Duxbury evident in t he NRC utaf f asse ssnien t .

• We t)olleva that the decision process also showed a disregard for tha entire regulatory uchene. Cont *ary to the July 29, 1989 decision of the United States Court of Appeals for the Firnt Circuit, t h ter c jg no tsa ro l s for assuneing either t he Deceniber 1980 or the Apri1 1989 decacion was a ctrii n i s t r a t i ve l y cor rect . ,

Wu strorgly urge t he NRC t o rescind i ts. Decuniher 1908 and April 1980 decisions, coridu c t another Assesvnient et the s)tuation, and this t i n,e insure that there 14. nieani ng f ul local input and ,that discrepencies between what is reported by EECO end what as cald by the local towns are properly reconciled. In this resp <tet, we un cior s t an d that the NRC plans to rneet in P1gniout h in Sept vinber to review local evacuatton plans. We enh thet we, and the other affettoc towns, be caven the tactuel t e st i niong (and cupperting documenta:lon) to be orerented by M CO and t he NRC v.taf f ruiticiently in cdvance of t he p; antied nicet i ng i o per rni t u t, to review it for accuracy and cornple teness, and that the civil '

defense oirectorc. piected offic?sle and other bgencier ano cornnii t t eu:. of the affe:ted i outri be given the opportuniig to to?tity.

Finally, it should be plaar that we view the NRC st a e t' r i dare11ction et its s t ai*u t ory rez conni bili t itto at an entrc'tely ser a ous mat ter . We intend to an. t he appropriate Congre mlonal Nen 51 q h t Con. nit t tees and other frderal and st ate of f 1 cielo t o t al e u.rintuver t r e p t, are necessary to inwui'e that the NRL doe 1 t h 8.* j o'3 at w es t created to do, ano that coca:lons reached on t he twa i: c' aloppy E r. d inaccur6te :.taff wer6 do not atand.

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M Paire Conani ' pre l cc; Mm . iduard M. hennecy Rep. I'r;an ' ., Otom :1y Grin . J o h n F' . Kerry Pe p. Cerry L. Ct S t. n . John Gaenn Rep. John voncph . .a o h 4 e,i Rep. Silvio R. Conte Rep. Joorph P. K e r.r. c d y , II Rep. Edward P. Poland Rep. Edward J. harl:op Hep. Joseph D. Early Rep. Ni:holas Mavrouleu Rep. Cher.ter G. Atkana Atty. Gen. .l anie s shonnen Hep. Barney Franh Anst. Sec. Peter Ag rie t . D F'S l

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