ML20085C425
| ML20085C425 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 08/08/1991 |
| From: | Fleming J AFFILIATION NOT ASSIGNED |
| To: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML19336D643 | List: |
| References | |
| CCS, NUDOCS 9109300100 | |
| Download: ML20085C425 (11) | |
Text
p J
6 Jamer Taylor
..'ecutive Director of Operations SNRC
[
Washington D.C.
20555 August 8, 1991 j
Dear Mr. Taylor,
The issue of monitoring children has long been a focal point in Duxbury.
Part of Duxbury's agreement with 11eedhata was an assurance that the children would be monitored upon entering fleedham High School.
(See Exhibit A, attached)
However, under existina Emergency Preparedness plans, school children from Duxbury will not be monitored for rad!rlogical contamination in accordance with 10CFR(b)(8) and 11UREG 0654 (j)(12).
The Student Relocation Center at 11eedham High School has no monitoring capabilities.
I am asking for your help and support to facilitate monitoring of Duxbury's School Popu.ation in the event cf a radiological accident at Pilgrim.
The June 10, 1991 Letter from the Duxbury School Superintendent clearly detines the School's position on this issue (See Exhibit B, attached). Although the original of this letter was hand delivered to Mr. Robert Ericcson during the Task Force Public tweting on June 12, 1991, ambers of the Task Force were not aware of this, and the information in the letter was not assessed by the Task Force.
Rather, in itn preliminary findings, t u Task Force stated that it had:
" reviewed Epitdani of Draft 0 and 1C cf the procedures (PT-33, Documents E and F), which describe a precautionary transfer of students to the host schcel in fleedham at the Site Area Emergency clannification level (and possibly at the Alert Level) and the alternativeu to follow if an evacuation is the direct response for a
, particular school and the huses have not departed.
Basically, the buses will tm
'ent to the Wellesley Reception Center before going 'o the host school."
The statement that "The task force reviewed portions of Draf t[s )
which describe a precautionary transfer of students" ant's position, er( W[
does not recognize tMLSchool, S
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Noro important, it points up an ongoing flaw in the NRC's standard operating procedure.- The NRC looks at individual sections of one.impicmenting proceedure without considering the whole picture..
In this case, to describe "a precautionary transfer of school children" is an exercise in futility.
The evacuation time of school children cannot be determined without considering the arrival time of buses.
one can say buses will be requested at any level within the emergency classification system,.but the only real issue is j
when will the buses arrive?
i
-q The "new" LOA format does-not really address when the i
buses will arrive; and is ambiguous in even defining when bases may be requestod.
One sentence states that i
" transportation may be requested when directed by tne Govertiur", i.e., after-the Governor declared a State of Emergency; but the next is "that Area II will initiate the call according to procedures." The Task Force assured me that i
it would make a determination concerning these ambiguous htstements.
It did not.
Another level of amoiaulty is added by the fact that Area II's procedures and local procedures cent.';n different instructions.- This-flaw.was identified by the Task Force, e.g.:
" Plans and Implementing procedures for NCDA and~the l
Department of Public Health and MCDA Area II need to be made consistent with thouc of the local communities.
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" Transportation proceauros need to-be. netter coordinated among.NCDA Area-II. transportation providers, and the towns.
e
" State plans need specific procedures to guide officialc L
who must make protective. action decisions."
L However, i t-has not been corrected, i
t I; have enclosed a copy of a "new and improved Letter of
' Agreement"'that I. developed-at the request;of David Rodham Director:of MEMAL(formerly'MCDA).
Mr. Rodhan will determine whether1to implement this new fermat_by the middle of
~ September.
If ycu have any suggestions or comments, he and I
- would appreciate receiving them before then.
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i The bottom line remains the same.
The Duxbury School population, ages 6 weeks and up, is the portion of the population that is the most susceptible to the negative effects of radiation.
However, this critical population is not being provided with the most basic. requirements of any workable-plan - evacuation and monitoring.
Giant strides etn be made towards satisfying the first requirement by adopting _the new and improved Lotter of Agreement developed at the request-of MEMA.
The second requirement, monitoring, can be met simply by putting two monitors permanently at the Needham High School.
The
- exact procedure has been carefully outlined in the enclosed letter sont by_the Duxbury school superintendent to Mr.
Robert Ericcson in June. (See exhibit B).
In February, Bosten: Edison indicated.that they had extra
^
monitors available.
Let's put them to use.
Today, I obtained the actual cost of these monitors.
According to Ron Varley, DECO and Dick Cooper, NRC, the monitors cost S14,000
- each.
Dick Cooper further stated that BEco participated in the designing of these monitors.
That being the case, I'm
- sure their cost is even lass. For a mere S28,000. BECo could
- have one aspect of planning that does comport with the rederal Guidelines.
Compared to the $17,000,000 SECO says it
' has already spent., this is a " drop in the bucket"; and unlike
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much of what has been done it could actually_have positive i
tesults.
- The major argument advanced by DECO to avoid providing-tne additional' monitors is that all the towns will want ther, There'are two clear answers to the contention.
First, it i s 4
a classic example of BEco's continued obfuscation of~the real issues - if, as I believe, all. student relocation centers should comport with Toderal Regulation, that towns other than Duxbury may not have asked for the protection to which they are entitled is no_ excuse for BEco refusing to provide it,
- Second, and far less important, at least some of the other towns have established a fundamentally different procedure:
unlike-Duxbury they provide for the school population first to go to the major _ relocation-center (which may not have and then to the host sufficient-monitoring capability), _
schools.
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There are, thus, a number of important questions that have not been answered:
1.
Who will make the determination that Duxbury's school population should be sent to Needham or l
Wellesley?
-2.
How will this information be_ delivered to Duxbury?
3.
Who will receive the information and then who takes L
the information1and disperses it to the appropriate authorities in Duxbury?
4.-
Are the bus drivers equipped with two sets of maps, one for Needham, one for Wellesley?
5.
Are all buses euuipped with the proper communication 7
equipment in case tne directives' change mid-route?
6.Are there two sets of_information to post at'the schools to inform parents of the location of their i
children?
The Task Force found that the existing procedures but it i
peripherally relating to these issues. were acceptable, did so by reviewing a-portion of draft IP's that are inccmplete~and in many instancou inaccurate and, pernaps most impcrtant,-have not yet been examined by the proper town authorities.
BECO says'this is finet However, the people of Duxbury do not accept, and cannot properly be forced to rely solely on, BEco approval.
The reality as that, according to the "new" LOA _ format, buses will be: requested "gamarine" and-will arrive in Duxbury g
three to five hours later.than "sometime".
The school population will then be transported to either Needham Hign Schcol.(where ng monitoring is available) cr.to the'Wollesley Relocation Center (where only inadequate monitoring is available.-(See, " Quick Fix", Exhibit C).
I:should_also point out that although some parents have received.information stating their children will be_sent to Meedham High' School (which is itself not accurate since existing procedures provide that:-they will be sent either to Moedtam or to Wellesley), but most have received absolutely no inf ormation concerning the probable whereabouts of their
-children.in the event of a Nuclear Accident.
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-However, this petition is for my children and the children,of Duxbury. I am asking for your help in thir.
- request, once again I remind you that nothing asked for Duxbury exceeds the requirements established in 10-CFR 50:47 and NUREG 0654.
4 Thanx You for your time and your anticip ned help in this matter.
Sincerely, fgti [/
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Jahn A. Fleming V'
cet. Admiral Kenneth Carr chairman Ivan Selin David Williams, Inspector General Sen. Edward 14. Kennedy Sen. John Kerry Rep. Gerry.Studds Theodore J. Flynn,-Chairman Duxbury School committee Gail LeBart, President Duxbury PTA le C b1
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