ML20086K879
| ML20086K879 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 10/31/1991 |
| From: | Fleming J AFFILIATION NOT ASSIGNED |
| To: | |
| References | |
| NUDOCS 9112130341 | |
| Download: ML20086K879 (20) | |
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s f:ev sea r OCT 3 so T ' fp,vBG ,e , PETITION OF JANE A. FLEMING @ 2 01's. On July 30, 1991 "The Commission ... approved the ERrr ".. force recommendation that it is not necessary for the NRC to reconsider its reasonable assurance finding regarding emergency preparednese for Pilgrim Station." I, Jane Fleming, am petitioning the Commission to reconsider that approval. You may treat the copy of my remarks I have submittod to you as a fonnal filing of my petition. I also request that you recommend setting the 120 day clock as provided by 10 CFR 50:47. I am aware that 10 CFR 2.206 of the Commission's Rules of Practice provides that petitions of this nature normally are to be filed with the Executive Director of Operations (who in turn refers them to the Director of the Office responsible for the subject matter addrets in the petition)(see footncte 1) I am also aware the Commission always retains the power to take jurisdiction over the issues raised in any petition.(see footnote 2) , The Question of whether the Task Force met it charter and obligations and the question of whether Pilgrim Station's Emergency Preparedness meets the Federal Regulations and Guidelines, is a case which requires careful reconsideratit? by the Commission. As you are well awaru, this petitioner's pocition is, that emergency planning for Pilgrim station is in violation of 10 CFR 50:47 and is not in accordance with NUREG 0654; and that the task' force did not properly achieve the goals set out in its Charter. Because of these facts, the health and safety of the-public is in jeopardy in the event of an accident at Pilcrim which would require implementing emergency plans. The Recommend 1 tion" must be reconsid3 red.
- 1. The statement "The Commission .. _, proved the task force recommendation ..." does not accurately portray the sequence of events that occurred.
My understanding is that the Task Force, as a body, was disbanded before a'ny final recommendation was made. Although the EDO'had the right to racall and seek advice and opinions from individual'aembers, the Task Force as an entity did nQt exist. Therefore, the independence that the " Task Force" as a body enjoyed was no longer in place when the EDO, at an individual, formulated the final recommendation that there was no need for the NRC to reconsider its' reasonable ) 9 LDO --- 007156 9112130341 911203 b" U 7' b d-#" PDR ADOCK 05000293 F PDR
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r t assurance finding regarding energency preparedness for Pilgrim Station. There was no recommendation of an independent " Task Force" for the Commission to approve.
- 2. The Task Force ignored established NRC policy.
The NRC is the ultimate authority on Emergency planning, as has been upheld by the court's on numerous occasions. As the NRC I.G. Audit explained, the NRC's policy is that a fundamental flaw can be ascertained from a review of the plan itself, and should be corrected when found. As illustrated by the examples set forth in Sheet 1 which you have before you, the Task Force ignored this NRC policy, and instead embraced FEMA's philosophy that deficiencies are identified solely through an exercise.
- 3. Others have acted on information since your July 1991
" approval" of the alleged " recommendation."
- a. As shown by the information in the Packet before you, FEMA's I.G.has found that my concerns on the adequacy of staffing and monitoring at the Wellesley Reception Center, and adequacy of transportation, in particular for handicapped, were valid; and have requested that specific corrective actions be taken.
(see footnote 3) '51s Commission's decision clearly overlooked these areas of concern.
- b. During dialogue I had with the Task Force concerning the new LOA format, it promised to " pursue" my questions and concerns. Despite its guarantee that it would do so "The task force did not review the new LOA format."
These LOA's are useless Letters of Intent. In time, thanks to the review and assessment of Dave Rodham,of MEMA, a new and improved LOA will be implemented. . Today, because the Task Force failed to conduct its promised review of the LOA format; the'public has no
" reasonable assurance" that the nec6ssary transportation will be provided. (see footnote 4)
- c. The NRC I.G. is currently considering a number of other concerns I have raised regarding the task force assessment of emergency planning. (see footnote 5) The Office of investigation is investigating what only can be characterized as BECo lies.
In short, others have considered and found valid a number of s important points that the Commission decision apparently did
not consider, even though I and others have presented them to you and your staff in the past.
- 5. The Commission's " approval" could not properly have been based on the findings provided by the Task Forcs.
This is the fundamental basis of my petition. There are too many areas in which the Task Force simply failed to make factual findings, or in which it otherwise fell far ahort of its full Charter obligations,
- a. Describing the current status of offsite EP.
As just one example of this, the Task Force neglected to mention in its findings that the Quick Fix is only an interim measure, for four to aix months. This may be just long enough to get BECo through the exercise, out planning is for an accident that may happen at any time, not just for an exercise 4 to 6 months hence. Sheet II, also in the packet before you, gives a number of aspects in which the Task Force's supposed description of the current status of emergency planning are not correct,
- b. Identifying and assessing the significance of existing EP problems.
The lack of assessment of the current LOA format mentioned above is a prime example. Sheet III, before you, identifies several others.
- c. Accepting " solutions" that do not comport with Federal Regulation and Guidelines.
A number of " solutions" accepted by the Task Force indicate a strong desire to accommodate the utility; but not to protect the public or to comport with Federal Regulation and Guidelines. The now well-known Quick Fix is one of the more bletant examples. Sheet IV, again in the packet before yoa, de. scribes a number of others. e
- d. Disbanding before making an independent recommen-dation as to whether the NRC should reconsider its
" reasonable assurance" findings.
In the Packet before you I have listed 10 of the reasons that your " approval" of the EDO's (not the independent Task Force's) recommendation should be reversed. s
t t In this respect, it is paramount to recognize that the Task Force did clearly determine one issue of critical importance; it correctly found that the 1988 Commission decision of
" reasonable assurance" was invalid.
However, The Task Force quit and disbanded rather than finding the full facts .nd being forced to recommend that the same "no reasonable assurance exists" finding was also mandated today. Since April of 1989, the public has been forced to live with the NRC in clear violation of 10 CFR 50:47, and not in accord with its own NUREG 0654. The public health and safety can not be ignored and jeopardized for another 2 or 3 years until we, (the public, since you and your task force seem incapable of doing the complete job) 93 through the process once again and can once again prove to you that the July 30,1991 decision is invalid also. We deserve better. We deserve that this agency, this Commission, do it's job, and protect the Public Health and Safa;/. In the past, I delineated specific violations of 10 CFR 50:47 as well as areas that do not comport with NUREG 0654. I have resubmitted them today; and you already have my June 1991 statement. Some of the points I previously have raised were partially responded to by the I.G.'s Report and Audits as well as by either Region I Staff or the Task Force. However many were not; and even as to those addressed, the response was often neither complete nor correct. Planning, as it actually exists today, does not_ offer
" reasonable assurance", and does not comport with 10 CFR 50:47 and NUREG 0654. The Task Force did not fully meet its charter obligation. The Commission was presented with neither an independent Task Force recommendation, nor a sufficiently complete and accurate account of the realities of emargency preparedness for Pilgrim Power Station.
I believe that real planning can be achieved; but all the facts must be accurately presenied and assessed, and the > full regulatory weight of the NRC must support this goal. Even the Task Force found that there has been no basis for " reasonable assurance" since 1986. Please, act upon this petition, obtain and reconsider all the facts, set the clock, and allow the public to have, for what will really be the first time, planning that does in fact offer" reasonable assurance", i 4 ______ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ J
o Footnotes (1) In this particular case , Mr Thomas Murley would be the Director of the office responsibl.s for amergency planning. Due to Mr. !!urley's active role in the- 1988 Commission decisions which has now been determined invalid.
~ feel his involvement currently would be inepreopriate.
(2) The regulation itself states in partinent part, that
"[this) review power does not limit in any way either the- 1 Commission's supervisory power over delegated staff actions or the Commission's power to consult with the staff on a formal of informal basis regarding institutions of i proceedings under this section."=See Petition fpr Eneroency add Remedial Action, CLI'78-6, 7NRC 400,409 (1978)
(3) FEMA I.G. letter to Jane Fleming 9-27-91 (4) Task Force Findings pg 2-134 See also Bus LOA and New Improved LOA format. (5) NRC letter.to Jane Fleming File No. NRR-91-A-0034 (6) See Letters Dated Feb. 25,1990 anc Sept 6, 1991 See also-Jane Fleming June 1991 statement.
t Sheet I Task Force Dependence on Exercise and FEMA to makg slej;pyrination _whether &4 nat A flaw exists. 2-89..." FEMA will evaluate the adequacy and timeliners of EBS messages during the 1991 exercise and will monitor the State's effort's to address the issue concerning the EBS authentication process backup communication with the EBS station..". 2-90 2.10 Exercise - The whole section flies in the face of the NRC policy. The Task Force did not acknowledge or assess the fact that no one ddentified any reason why the EBS didn't identify the relocation center of the Duxbury School Children. In fact, there was no satisfactory reason. William Russell of the NRC was in the Duxbury EOC during the 2 1/2 hour search for the supposed buses going nowhere. He failed to notice what the rest of the EOC was in near panic about. 2-96.... "No letters of agreement exist with regard to the congregate care centers. This item is being pursued by MCDA (now MEMA) and will be evaluated by FEMA in the 1991 exercise." Evaluate what?? This clearly does not comport with NUREG 0654 II A. 3. page 2-127 (concerning the fact the task force did not determine transportation needs of the towns) - "(The task force identified as an issue more appropriately examined by FEMA, the comparison of estimates of resource needs in town procedures and those in the BEco matrix.) The world knows that Jack Dolan of FEMA has refused to look at transportation issues for over three years. 2.15 Shelter 152-3 FEMA will evaluate everything in the exercise, including the NRC response in accordance with its Incideat Responso Plan. I'm glad that FEMA will be checking up on you guys and I'm sure they are well qualified to. But this turns the issue of "ultimste authority" on its head. e 0
i L 2.14 Public Information 151 " FEMA'will continue to review the public information materials annually." The "public infornetion materials" include " Facts About Radiation" which the NRC has already found flawed. Since when is FEMA is expert in Radiation and the world of nuclear? 2.13 TransoortatinD ; t 2.13.2 - Adequacy of New Letters of Agreement " FEMA will l monitor implementation of this procedure." Although flaws in the LOA were identified to them, FEMA did not notice them. When Margaret Lawless was asked directly , how she would determine the number of drivers available she ! stated she would refer back to the old LOA's. There's "[un] reasonable assurance" if I ever saw it; particolarly when you recall that the " LOA's" now in place are worthless Letters of Intent.
- Adequacy of assignments - It seems agreed that major changes to documents need to be made, but the Task Force said that " FEMA Will monitor the incorporation of these. changes and evaluate'them in the 1991 exercise." ,
Why should the NRC wait for an exercise to evaluate documents that it has already found flawed? -Fix the flaws now. Bridaewater Reception Center- 2-105 " FEMA will monitor the resolution of (outstanding) issues as'part of its ongoing 1 plan review." ! 1 i l a i
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Sheet II Task Force ilnys describina the Current Status ,qi XE 2-38..." Task Force did not conduct a detailed review of Duxbury School plans and procedures." 2-42.... "The Task Force finds that the concept of monitoring school childcen at reception centers acceptable." (This is not feasible under the plans as they now exist) 2-95... " Communications between EOC and the reception center has been provided." (The " Quick Fix" eliminated the communication officer between the EOC and the reception conter.) 2-94 Decontamination of Vehicles "MDPH has approved the dry wipe method." (But again under THE Quick Fix there will not be any decontamination of vehicles, wet, dry or damp, until the National Guard arrives.) 2-95 Reception Center: Wellesley ...." However the task force believes that one additional portal monitor is necessary at the Wellesley Reception Center...." (But, again, under the Quick Fix there will only be two portal monitor operators, even with the third monitor added.) By the way, also add 3300-5000 additional people. The Saquish-Gurnet population has been falsely told by BECo they , can either Le nonitored in Marshfield or will go with the rest of Pir:ceth people. Traffic Management mrkes that impossible. they are evacuated through Duxbury; and they will go with Duxbury to Wellesley. 2-97 ... " FEMA and the NRC do not require letters of agreement between the State and the Red Cross." (Maybe they don't but NUREG C654 clearly does.[A.3,pq-32)) {
Issue Decontamination inr the Handicat,ned 2-123... " Eleven Hospitals have entered into agreement with the Massachusetts Dept. of Public Healtn to provide certain services for evacuees from the plume EPZ. PT-ll7, att. 25" PT-117 trip report Jan 7-11 (... Special Needs) PT-134 Trip report Mar.5-6,1991 (... Hospital,-and Special Needs) 2-125 Task Force Assessment A. " ...docontamination issues at MCI in Bridgewater are resolved." B. " Hospitals - Understandings of commitments regarding the support that hospitals would provide are inconsistent." + A March 7, 1991 (the day after the trip) a letter from "BECO" Bob Hallisey of Massachusetts Dept. of Public Health to Carl O'Neil of Duxbury stated, in section 5, entitled Hospitals Handlina 21 Jniured add HandicaDoed Pooulation, that the hospitals under agreement are strictly for injured contaminated; and that a non-injured contaminated person is not included in this grouping. To make this point perfectly clear - There is no decontamination-in place for handicapped people (See enclosed copy of letter) 2-05... "As a guideline to evalunte what constitutes sufficient accommodations for the handicapped, the task force used FEMA Guidance Memorandum 24, " Radiological Emergency Preparedness for Handicapped Persons," Apr 1984. The State's , plan to handle the decontamination of handicapped individuals by sending them to a nearby hospital is adequate." (What hospital? See above reference. What transportation is available?) 2-127 " ...the task force was also unable'to determine the precise configuration and capacity of committed ambulances from available records" If a contaminated person arrived in his own vehicle would one be safe in assuming the vehicle is also contaminated? Will-they allow contaminated vehicles to. leave?. Is:any alternate transportation available? The attached picture shows-a fireman being decontaminated at Quincy Hospital, one of the Hospitals designated and under 4 _._____m _..._-___..___.__-_m - . . - - _ _ . - - - - -
agreement. Does the Commission find-this decor.tamination method acceptable for the Handicapped? 2-93... BECO provided update on outstand!ng squipment issues A for Wellesley EOC - " Maps showing routes to the CCC's had been provided" (Maps may have been provided. However, the question was that the CCC are not only without LOA's; they are not even aware they have-been designated CCC. The local officials who are aware of their possible use are Civil Defense Directors who have no control over school buildings. s a m
l . Sheet III Task Force flaws in identifying and assessing the sianificanna af IE problers. 2-134 - Availability of Drivers and their commitment to respond. MCDA stated that some of the drivers indicated the needs of their own families would be a priority. What companies? How many drivers? Did the task Force delete these drivers from their figures? 2-135 - Task Force determined that schools providing their own transportation do not need LOA's. However, the transportation owned by SacreJ Heart School is also being used to evacuate Camps. LOA's are needed, if for nothing else... Clarity. 2-43 Camp Squanto - This is clearly a planning problem not a training problem as assessed by Task Force. (see last page of JAF June 12,1991 tastimony) 2-43 Poll of Teachers: " Teachers are expected to participate" (Perhaps a case of Great Expectations; Sea below Training) 2-44 Training: 98 of 349 School Personnel (not teachers), including school administrators, janitors, nurses and secretarial staff have received training. Very few teachers have participated in training. (Perhaps they meant what they said in the poll) One can expect but one can not force teachers and other personnel to partlnipate. 2-73..." Most four wheel drive vehicles in an emergency rhould be able to negotiate 6 inches of water". (True, if they are on a hard surface, not necessarily true when dealing with the soft, wet sand of the beach and incoming tide.) (Ask George Mulley, I.G.'s office) 2-74..." Task Force find regulations provide acceptable flexibility for accounting for tidal situation." (only if Task Force accepts BEco's well developed false philosophy... an accident will take 24 hours to develop. What if a release occurs in 2 hrs, 4 hrs, 6 hrs . Planning should cover a full spectrum of scenarios, "vt only the one most convenient for the utility) 2-79 Fopulation Saguish-Gurnet : BECo 654 number was pres 9nted in 1988, discredited by everyone, yet it reappears again in 1991. Doesn't anyone enforce Title 18 sec.1001? 1
p 7 2-81 Clark's Island's major problem - at low tide, notification ar/ evacuation are virtually impossible. Task Force assessed .he low tide situction by taking a boat tour . at two hours off high tide. This is four hours away from low tide; and our average tide is about 10-11 feet. (see also recent Nuclear Advisory Committee Meeting for more problems and changes to be made in plans. CDD informs us that although changes will be requested, the exercise will use an Aug 2, 1991 draft which is strictly communication and notification. If this is done, BECo will avoid an exercise that could determine whether or not people can be evacuated. 2-82... " Local emergency . esponse of ficials are f amiliar with low tide at Clark's Island. Depending on severity of the emergency (e.g.whether a release has occurred, wind direction etc..) when evacuation is ordered, these officials will determine the required assictance to the residents of Clark's Island including ad hoc measures if necessary."
- Harbor master is the official in charge.
- Clark's Island is inaccessible at low tide, no matter what ad hoc methods are used.
- Protective clothing for Harbor Master... the task force determined MDPH should Iesolve this issue but, concludes that the preferred protective action for (Harbormaster) would be evacuatien rather than don breathing appr.ratus.
In other words, the man the task force says (on page 2-82) will handle it even after a release, is the same man that (on 2-37) the task force suggests evacuate. You can't have it both ways; either get the man protective clothing (as he has specifically and repeatedly requested), or acknowledge Clark's Island will not be notified or evacuated. Time Estimates... Dr Thomas Urbank, II, Ph.D., P.E. reviewed the time estimates that BECo had prepared by a New York firm of so called Professionals. Yet, the mother of a swimmer with a stop watch in her car was able to blow apart the ridiculous 5 hour estimate for people to get from Duxbury to Wellesley theory. On site reality speata louder and clearer than the assumed professionals and papers in New York, i l _ _ --- 1
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.15 SHELTER 2-152..."The towns within...(EPZ) have planned for the option of sheltering.... including;the beach population...":
Beaches are to be evacuated at alert; shelters do not activate until. site area. .7 l b
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B. .. 9 Sheet IV. Acceptance of certain solution by the Task Force to accommodate tha utility, hLt nnt tg protect the public. BECO and MCDA agree (see gift) that 32 persons are_ adequate to handle the Wellesley Reception Center. Previously it'was acknowledged that a minimum of-50 trained National Guardsman were necessary. What criteria did the Task ForceLuse tc. accept this change. Whst studies were done?. What new information came into the judgement that-now:32 poorly trained could handle what once took 50 well' trained? BECO wrongly came up with'the quick-fix and. bought MCDA's approval lfor-$50,000.- What bought 1 the task force's approval? Table 2.10 Transportation Providers-I challenge every transportation provider that I challenged on June 6, 1991 with the exception cf JUDCO and Phillips. In particular I challenge TREMBLAY. 2-167 Task force assessment _(Direct Torus Vent) a...the task-force is not-certain that the, declaration ofranc emergency and. notification of offaite-authorities _would' , always precede activation-of the'DTVS.....TheLtask forca d considers _it-ir.portant.that-BECo developrandoimplement' i appropriate controisifor_lts staff: responsible?for amargency j classification." The public certainly feels this is important as-well, who is' making sure something issdone?- 2-168 ...WetLwell will scrub out;90%Lof.non-noble gas fission products before-released. But1non-noble gasses:are only a. small percentage'of'a potentialirelease.- LWhat; about noble: , gases and= iodine?- 2.18.1.1 Environmental' Monitoring capabilitios- : NRC does not endorse fixedisite_ monitoring. FEMA has_ identified' problems with state tield' team-monitor _ ,
-FEMA'will continue to work with-the state to resolve 1 problem.. l When did FEMA.become the radiation:authoritiva.:
The assescment states "This system:in. conjunction 1withLfield teams by BECO and-The' state.is! intended.to weet NUREG-0554 HJ h
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The question is not the intention; but the fact of whether it meets NUREG 0654 H. _ . - _ _ _ . _ . . _ _ _ _ _ - ._ --__-_1
Why finding of " reasonable as4urance" should be reversed
- 1. Reception Center to the North not adequate
- 2. Transportation not adequate.
- 3. Monitoring of school children not adequate j 4. Monitoring of Hardicapped not adequate.
- 5. Decontamination o' Handicuoped non-existent.
- 6. Planning for evacuation at Saquish-Gurnet and Clark's Island not adequate.
- 7. Interfacing of plans not adequate.
- 8. Public Information not adequate.
- 9. Direct Turus Vent interfacing with emergency planning issues not resolved
- 10. Congregate Care facilities not under agreement.
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( Federal Emergency Management Agency / Z. - 1 I Washington, D.C. 20472 Ms. Jane Fleming SEP 271991 8 Oceanwood Drive Duxbury, Massachusetts 02338
Dear Ms. Fleming:
This is in response to your complaint concerning the Pilgrim offsite Emergency Preparedness Task Force. You requested that the " , FEMA Inspector General investigate 6 . categories of issues. I investigated 3 issues and the others are being investigated by the Nuc3 sar Regulatory Cemmission (NRC) Inspector General, who has the ' statutcry authority to . invest 4. gate the remaining issues. The issues I investigated were (1) adequacy of_ staffing at the Wellesley Receptier. Center, (2) transportation of handicapped parsons to the-reception centers, and (3) inherent " conflict-of-interest" of staffing the center with utility employees. After investigating these issues, we found- no issue that Yhuld result in a reversal of' FEMA's finding that'offsite radiological emergency planning and preparedness _were adequate to protect the public health and safety in the event'of an accident at the pilgrim plant. However, we are requesting followup _ on ts a (2) of the ; , issues. ' Asl_ecumev of Staffina Your concern focured on the Wellesley Reception-cent 2r. Because the National Guard could not be deployed to the center until'4 to
.8. hours astar notification, an initial-response organization made: a up of approximately 32 persons would perform the initial monitoring -
, and-decc.ntamination activities until the National Guard arrived. Upon examination of the documents-provided by the state, it was thei professional judgment of the' state, FEMA and NRC officials that 32 trained personnel could operate the equipment necessary >to perform the monitoring responsibilities until the arrivaliof the-Guard. _ , FEMA Guidance Memorandum PR-1. dated october 1, 1985, requires that' "Each organization shall update its plans.and agreeuents as needed, , review and certify it_to be current on an annual basis." turing the yearly. update _-cycle, a more . definitive analysis of,the adequacy of staffing at the Wellesley Reception Center could be accomplished because (1). a portal monitoring tino estimate study is scheduled.to be completed during that .timeframe, and - (2). initial 1 results from ; the -December - 12, full - scale - biennial exercise will = be 1991, available. -During the-update cycle, if a determinationLis made that the- initial -level of:- 32.' is -inadequate for - monitoring at Wellesley, then an increaps or change to-- the - make-up of the: Wellesley staffing.will be recommended and can be accomplished. e # _ _ _ _.______._m___.__._m _ _ _ _
- gT 04 '91 14: 00 ras IG d Persons in the T_rancDortation of Handicappeified to to transport an alleged shortf allhandicapped pers ,
Information you available provided ident event of a radiological emergeni n of handicapped of buses doavailable number reception centers %nin relation the to the transportat in buses time, of handicapped persons snap an shot Pilgrim plant. report Vere only a there are established policies the persons, the numbers Task Force Each year used in thethese figures change ily,is th dasituation. Decause to deal with re revised and a s certification that and procedures During the update c'*cle, increase emergency preparedness plans a can be accomplished. de. the plans are current is maf buses or changes in the number o to Conflict-of-Intercat t", according to the FEMA staf f , emerge offsite thesemonitoring activities hasand It is not a " conflict-of-interes employees perform utility Having utility of ficials performthe
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have purformingsituation existsrf for the activities.before, includingA similar orm. all occurred function.where utility personnel would until state pe employees are decontamination t minationIn addition, the NRC and the seabrook Power Plantof f site monitoring tivities. ilityand employees. decon st a trained to perf orm allowed these ac of f site planning by ut U.S. Courts have h t an inherent conflice of-interei Without documentable it evidence t awould existhandicapped at Wellesley , I have compla n . adequacy and situationto substantiate this staffing and the and Local Programs have referred FEMA's Stateissues can be considered aseme I transportation issues to d, support Directorate (SLPS) Offsite i current update cycle.tso canthat thenthe be reviewed and rev se Associate l requested that the SLPs part of thethe Pilgrim Nuclear Power P an I have fice of the Inspector Genural of the where appropriate. lve these issues. Director advise you and theSine Ofactions rely, that they take William . idball 1 Acting Assistant InspectorGe k
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o., UNITED STATES 8(
n NUCLEAR REGULATORY COMMISSION j ) 3 'I EDO PrinciWT"f6MSfp61Mlence Control
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FROM: DUE: 12/03/91 EDO CONTROL: 0007158 DOC DT: FINAL REPLY: Jono A. Fleming TO: NRC FOR SIGNATURE OF: ** GRN ** CRC NO: DESC: ROUTING: 2/206 PETITION - EMERGENCY PREPAREDNESS AT Taylor PILGRIM Sniezek LThomoson DATE: 00/00/00 Blaha Murley, NRR ASSIGNED TO: CONTACT: TTMartin, RI OGC Scinto SPECIAL INSTRUCTIONS OR REMARKS: J 0 I
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4 OFFICE OF THE SECRETARY DOCKETING AND SERVICE BRANCH CONTROL TICKET TICKET NUMBER: DSB-91-166 UTILITY / PILGRIM DOCKET FACILITY: NUMBER: 50-293 DOCUMENT TYPE: ADJUDICATORY DOCUMENT TITLE: PETITION AUTHOR: JANE FLEMING AFFILIATION: REPRESENTING ' SELF RECEIPIENT: COMMISSION
SUBJECT:
DOCUMENT DATE: / / DOCKET DATE: 10/31/91 CROSS-
REFERENCE:
ACTION OFFICE: EDO ACTION: APPROPRIATE ACTION DUE: / / COMMISSION ACTION EXPIRATION DfiTE: / / DISTRIBUTION: COMM. CHILK, OGC, CAA, OCA, OPA, GP A , sE DO , BATES & RECORDS NOTES: OGC REVIEWED: EDO TO CONSIDER AS 2.206 PETIf]ON SPECIAL HANDLING: DSB NUMBER: 4 4 e
'o,, UNITED STATES
.2 o NUCLEAR REGULATORY COMMISSION
{ , WASHWGTON,0, C. 20666
%o ,,,+y[ October 22, 1991
?ile No. NRR-91-A-0034 Ms. Jane Fleming-8 Oceanwood Drive Duxbury, Massachusetts 02332
Dear Ms. Fleming:
On June 17, 1991, you. telephoned-the Chairman's. office and expressed-several-concerns about the_.way emergency ~ planning issues for:.the.P_ilgrim~ Nuclear Power Station were being handled.- On June 21,-1991, you_provided_ additional.- documents to support your contentions. The staff reviewed your concerns and the documentation-you provided and. concluded that the substance of-the issues raised-had been considered by-_ the Pilgrim Offsite Emergency Preparedness Task-Force. ' With' respect to your concerns on-how the Task Force dealt with;the issues,Jwe have conveyed your conceras and dccuments to the NRC-Inspector General!s off. ice for whatever action isideemed appropriate. The NRC 0ffice ofilnvestigations-has-also been notified of your concerns regarding statements made._by the licensee. 4
-Sincerely,
.,i J
Frank'J.sCbhgel,.-Director
~ Division:of. Radiation! Protection-and. Emergency Preparedness-
'Of.fice of Nuclear = Reactor-Regulation-J
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THERGENCYhDONSEInnu acD.begeg MCDA may request Mn9tneN3 neg - tv ,. w e 4
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. vehicles and vehicl'e operators as necessary in the event oQn emergency at This transportation kSy be requested to the Pil rim Nuclear FcWer Station. (Ster.id assist n the evacuation of schools, day care centers, nursing homes, ecial-facilities and the general publicW uirnuj isWeds hospitals t HCDA Area II will initiate this call at tne time of an emergency [o$ ~
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ner sp training for the Company and the vehicle operators. MCDA will provide emergency responst v
,7,.n av (company name) i 7 TRANSPORTATION COMPANY: _
confirms its commitment to provide emergency assistance in the evacuatien of } persens from the Pilgrim Nuclear Power Station emergency planning area in the c~. event of an erergeocy. Our drivers are aware of the Company's involvement in the emergency rssponse program, and have been or are receiving emergency response training. He understand that we may be asked, on occasion, to participate in training, drills, or exercises, and to provide U datedccrowbw,_A' ^ ( estimates of available resources.--lJ to,1) Tku,4 %.x v Based upen our typical operations, we expect that the followlik resources is based on a could be n.,e available. Estimated number of vehicles total estimatec mobilization time of approximately t c thre%(. u'r t har ten lour ble 6b' a receipt ofm' lT smobilize andMe mt vehicivir-nc drivers wouTr be reacy to provide a unce , g gm g - The coccany has the responsibility of notifying HCDA at (50B)S97-3101 of any major changes of resources or contact persons and their phonc numbers. Total Estimated Number bk Ih u p Tvee Vehicle Resource Total Resources of Vehicles Available On Hours /Off Hours -{x , M
/
(, Buses Vans _
/
/
Lift / Wheelchair f Vans f
,. g L/ Arbulances
/ 1 E O Station Hagons F.QA N@J TRANSPORTATION PROVIDER Signatu_re i
Signature ' Title T3 _ Date Date,
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se ph se0.Q h i y T
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ALG-ay-1991 16180 FROt1 SKl & RV.QUET617 934 9008 TO r . .. LETTER OF AGREEMENT EMERGENCY RESPONSE TRANSPORTATION PILGRIM NUCLEAR POWER STATION EMERGENCY PLANNING ZONE Massachusetts Emergency Management Agency (hereinafter
" HEMA"), formerly kr.own as Massachusetts Civil Defense Agency
("HCDA") and (name of transportation provider, hereinafter the " Company") agree , thatt r
- 1. MEMA, in the event of an emergency at the Pilgrim Nuclear Power Station, will request the Company to prov.ide vehicles and vehicle operators to assist in the; emergency evacuation of schools, day care centers, nursing homes, hospitals and other designated facilities, as well as special a needs and general population determined to be transportation dependent. ~
- 2. MEMA Area II (formerly MCDA Area II) will,Ein the
' event of such an emergency, notify the Company of the need for its services at the - stage'according to Area II.
procedures or such other procedures as may then be specified by MEMA.
- 3. The company will provide emergency assistance transportation in the event of an emergency evacuation from the Emergency Planning Zone of the' Pilgrim Nuclear Power Station.
- 4. MEMA will provide. emergency response training'to vehicle operators and other amergency evacuation personnel of
.the Company; and the Company understands that it will be asked.to participate in such training, and-in emergency evacuation' drills and exercises.
- 5. The Company has mado the vehicle operators tad other.
emergency evacuation personnel aware of the company's committment to provide vehicles and vehicle operators in the event of an emergency evacuation. The Company's vehicle operators and other emergency evacuation personnel will partipate in emergency response training, drills-and exercises.-
. . . . . . , , ~ -
. . . . . ._.-~La- . - - - --- - - - - .- - - ---
e
- c. Tne Cccesm .;11.' rov:ce rerA witn t.e
- follcuing
- rforget son. *N:n informaticuill se .:: stet aw;aily a.'s in tr.e event of any significant thinges t .creto:
t, Lontact Person: haue Vnot.e D. Trirsoortatica Fa.eurces t:+ ts :<v.aec: pc d ,thi:.e lct a 2 ist; w.s: n+.m.u at: steo (s.e:+r nutter f ' vtnt;!ei, c' traver$ a m a:.t ava:In:te of li:r.e/o!f h w or, r.o;r 1:-(f nost hia ' 4- .. . -- _
. - s. . .
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OxE!*nilr! Lii' V;Y 5 _
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':calances n _
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i__ M ati:.n ;;i.gcns ,,_,,_ - /__ ., ! IEKl) / / - i C. 55Utlated Mobili:ation Time: [En!J 'The Lcepany EApects tnat the above resources will be Hade availaD!p based
- .4 a total est Eated mobili:stion tite , tetween receipt Dy tr.e Comparcj of a request to provide assistante and the tin -
tr.e venicle ard vehicle operators will be in the Emergercy Planning Zone ready _ to provice assistan:e. Massachusetts Emergency
'tianagement Agercy (Company Name)-
Ey: By:
Title:
-Title: Dates lDate
h 17AA170 08 8 _C' q s,,.,,u gpagsraa amn 1
)r O p a w n aie f 2 d b % M uo9%mvzeJwe VM.am F. Weld ,
Govemor . David P. Forsberg secre m , cavid H. Mugan March 13, 1991 Commasoner , Carl D. O'Neil, Chief / Civil Defense Director Duxbury Fire Department P.O. Box 1153
'Duxbury, MA 02331 .
De[r Chief O' .: .
, The following is in response to your letter of January 4,1991,. to -
me, as well as your letter of January 11, 1991, to John Lover'ing concerhing emergency planning issues for the Town of Duxbury.- I sincerely apologize for the delay in responding to these letters; ' however, I was under the mistaken impression that you had been contacted directly concerning these issues. I would like to first respond to the two issues in your January 4, 1991, letter to me and then address the three issues raised in your January 11, 1991, letter to John Lovering of the H.C.D.A., as follows, ,
- 1. protective Clothing for personnel We do net. believe that there is a need for protective clothin/
- and breathing apparatus for the harbormaster and conservation administrator. Our goal in emergency planning is to avoid any unnecessary radiation exposure to individuals in the event of an accident.. In this respect, the most probable occurring time frames are expected to allow ample time for preparation and evacuation if a radiological release is expected.
However, assuming a fast-braking accident occurred, the release would be principall/ noble gases with possibly very very low amounts of iodina and particulates. Also, there would be a time delay, depending upon wind speed, before this gaseous plume reached Duxbury. This means the. exposure of concern would .be whole body gamma dose,"and thus protective
' clothing and breathing apparatus would be of very limited value. .
a
Page 2
- 2. Desienated Shelters Sheltering is the ' protective acElon .of choice in the event of '
- gaseous releases of shgrt duration passing %ver populated areas. Sheltering is effective when doors . and windows ara -
closed and air intake from the outside is eliminated or minimized. E.P.A. says that sheltering- in place is ef fective s ;- for up to a two hour period. Additionally, the type of material of which the building is constructed has some ef fect in terms of protection
- from gamma radiation from gaseous plumes. Sheltering. individuals in the lowest portion of the building and in the center section of the building would be the most. effective. _ We would be- more tLan happy to of fer the services of. individuals from the Radiation Control Program at M.D p.H., in assisting you in confirming your selection.of sheltering locations in Duxbury. ,
*3. Tmiiterinir of 15ctob"1 populations To be answered directly b'y M.C.D.A. ,
- 4. ." Latch Key" Children To be answered direc'tly by M.C.D.A. ,,
- 5. Hospital Handline of Iniured and Handicapped populations As you know, Chief O'Neil, this is.. one area of great confusion and concern to individuals. It is our understanding that hospitals only accept injured or L sick individuals and our -
programs have been directed toward assuring-that - there is sufficient capability at these hospitals to handle all' - contaminated, . injured. It .is not- our intent that--large , [ numbers of individuals would be sent - to , hospite.ls for this , l monitoring activity. . Individuals who-are not~ injured _do not l need to be sent to the hospital .for monitoring and subsequent decontamination if necessary.- We have-conducted surveys of hospitals to ' find out the number of injured and contaminated - . individuals that can be handled 'at thel hospitals.- We need to- - all strive to educate the public . and emergency planning - - individuals relative to- the fact: that- a. contaminated - L
- individual is- not necessarily an injured individual, nor- does
-that individual necessarily; need -to go to a hospital'. :
4 ( l . *
- t >
, , . . , , ,.,-,-e . . e .v. , m, , . . - - , . . .-
Page 3 - individual, nor does that individual necessarily need to go te a hospital. . ., We trust the above satisfactor,ily addresses your concerns, a'nd we look forward te working closely with you in the future on emergency planning issues. Sincerely. -
<C-Robert M. Hallisey, Director Radiation Control Program
.,.s..
- pjd, .
ce; John Lovering, M.C.D.A Bu== Hausner, H.C.D.A. " Ed Fratto, M.C.D.A.
- Tom Rodgers, M.C.D.A. ,.
Tom Matthews, M.D.P.H. Duxbury Ecard of. Selectmen . 1 8 e I ( 3 9 4 g. I l
~.'
. . . - , , . -,.-..,..a,.., ,, , . , . , - , - - , ,.
FEB. 25. 1990 i PANih SLOUGH
'NJEF. PEACTOR PROJECTS SEC 3A fil l H ! ON 11F REriCTUR PROJECTS 4 Ti <*.LLEH1> ALE ROAD e' 84 3 0s WU:(-J1 A P A , j v que-i 8 HAP A. kAl#DY BLUUGH z
- -OHE NolllH0 AVO. I SPOKE WITH YOU AND ALLEGED THAT. IN r w ij f t o ic: THE Pt i.G:lM NUCl. EAR POWEP STATION TO OPERATE
- r,u?? m 3'0WER WITHOUT EMERGENCY PLANNING- IN PLACE: THE NRC
. , L. .; .'-
- 'i oLATI ON Ui- J'I8 (NN REGULATION NUREG 06S4 AND 10 CFR Ws: C. lH OUR CONVERSATJON YOU INITIALLY OMITTED THE
-rEr?iet to io_cro 60: 47 WHET > YOU READ THE ALLEGATION BACK Vi
;; .;,HE , . hut CORPECTED THE OMISS10N WHEN-I POINTED 1T OUT TO t i 'IU51
. #9, m;J a TAEE !SSUE WITH THE ASSUMPTION THAT " REASONABLE
,JA c; OP G PROVIDED. CLEARLY IN ORDEP TO A1. LOW r a l.nR U.! To RUN A80L'E S4 POWER THERE COULD BE NO FINDING, BY
- in i9C sit 4FF, OF "REhSONABl.E ASSURANCE WHICH WOULD OR i.'nW O CONF ORT VI TH THE CRI'IERIA ESTABLISHED IN 10 CFR 50 :47.
i4r iin: S~A N S TESTIMOI6 ON THE STATUS OF EMERGENCY 5"L Alli) .fl1G . GIVEN ON DEC5;MBER 9. 1988, HAS BEEN THE SUBJECT OF rW . ilSPEC TOP GENERhL INVESTIGATION. LOCAL GOVERNMENT AF51CIALS AND CITIZENS HAVE IN'THE PAST REFUTED, AND r*bHTlHUE TO F.ItJD IT NECESSARY TO CORRECT OR- REFUTE, I i l l i
_ . = . - - . - .-. j . p l I l t a l E e t, s t a t eine n t s nade then and on numerous other occantons. Pr obablu mos t important, what was. or is currently. In plac+ nas detactencien tnat tar out-weign wnat is reautred tiu 1D C.I.R. So.*i. section LO.$7(a) reoutres the NRC to bese its findings on a res1ew of FEMA's tinoinos sno determinations as to wnether state or local plans are adeouate. etc. 1he Town of bunturu nas not yet submitted plans for tinel review bu FEMA (see 3ocument set by the Selectmen to the Chairman's. Of f a ce in Atavat 1999). f- u r t h e r , it could heroly be clearer thet FENS's review of the state and local plans was not when power essention beoan. end still 15 not. Complete. This belno so, tne T&C did not. and could not, base t19 dings on FEMA's e evirw Inceec, the oniu completoo determination at FEMA is i t t. JWe tga gg,ta gn o+ Palorim's EP2 plans as inadequate. i.e c t i on 50.47(b) recuiren that procedures for notarication of state ano local oroan1:stions by the Licensee nave been estaolished. In tact, communications with state and local oroan t:ations are Et 11 seriously flawed. In the j vctooer 12. 1989 exercise the-s)rens in Dunbury did not l ocerate properly, as was noteo to the NRC on numberous c:centon2. Additionally, the e5 Ply broadcast system is not reliabJe, as noteo in occunientation presented to Commissioner Care on the dau of the exercise. Commissioner Curtis was informco of these riews on December 6, 1989. With respect to Sec. 50.47(b)t7), the public information l booklet 83 not released until Auoust. 1989, some 8-9 months i arter power ascension beoan. It's therefore obvious that l this requirement was not met when the NRC permitted the power l asension proc'oduce to oegin. Moreover, nearly all the information in the booklet, even when It finally was issued. j was inaccurate; nothing was correct except for sub-area designations and civil detense directors' phone numbers. This information was presented to CokMYsEYoner Carr on October 12, 1989. Accordino to 50.47(b)(8). adeouate emergency facilities and equipment to support the emergency response must bc provided and maintained. When the power ascension program went into ettect there were no functioning receptionncenters. Now, over 14 months later. .ie reception center for Duxbury is still not complete (though~ l have heard that some' improvements in this respect have recently been made). The . inacequacy of the reception center is accentuated by the fact that there are no host schools for Dunbury; yet the school
) ch11cren that thus must be sent to the reception conter
-ontritute 20% of Dunbu.y's total population. Even the pi .* ed, and completeo, reception center would not be a dout 'te to handle-any addtional members of Duxbury's popuJ Jon.
_ x -- -
\- .. 3 - l The last or glaring tallures to comply ,1 1 10 C.F.R 50.47 coes ont
- a. bO.*7(b)(91 reoutres that adeauste methods anc*
s y t t enic tor monitorino actual or potential ottsite consecuences of raolological emergency conditions be in use. t Fligr ini s ot t-si t e monitorino is inadeauste to per f orm tIfh1E t e st. either accurateau or etticientlu, in any event. l l. carect torus ventitia is used. there is absolutely no mon 1*ersna in place. I b. 50.47sb1t10i recuires development of a range of crotective actions. Her e ., no shesterina has been seriousiu ceveloped; buildings have not beeh rmalisticallu evaluated t-" dose reduction tectors shee inf ormation presentea to bfMre (. a r r c.n v: toner 12. 1Y89). evacuation is inaceoustes onig 21"/ buses are available end et Transportstion for 4 east 457 are vraoutred. Pecauce the EPl is subject to constant'jy changino coestal wind directions (see wand stuoy conducted by Drs. Spengler and heller), the only reelistic epproach as evact'stion of the entire zone. C. 7he r eQuired arrangements for medical serC1Ce5 tor comtaminated injured incividuale (50.47(b)(12)) have not oeen made. There are intrteen hospitals currently under
,+greement, but t he me::1 mum number that any can handle an 1.J hours as only two or three: all tocether they can handle onlu 30 contaminated inavrec. Given the size of the popula;aon involved, this is not reasonaole-assurance. .
- d. SG.47(b)913) reautres general plans for recoveru re en t r g ; the ma,iority of .3ar t i c i pan t s in the October ei:er c i se considered recover![ Centry to be weak and inadcQuate.
- e. Finally, the reauired radiological emergency training (50.47(b)(14)) had not taken place when the NRC l
permitted Pilgrim to ascend abovo 5%. There are still'many emeraency personnel. e.g.,' teachers who:are responsible for l The largest segment of.the population, who have not yet received any training. In short. it is apparent that the reouirements of 10 ' l C.F.R S0.47(a) and (b) had not been met when the NRCLacking permitted Pilgrim to ascent above 5% rated power. such compliance, the provisions of 50.47(d) are e:: press that the Commission, properly, could only authori:e fuel ' loading or low power-operations.
.. There was no .iusti fication tor cermitting what it did.
*'/ Sincerely, l Qg , '
^
1 Ns ** N k& N %Q- .- y [2 -be
l s I lik , h. b.'!i n d y BlouQh blid T.T. Martin UM M; F:tr.1rJU 1 1.JilG OF PRUSSIA. PA. Sept.t5 lv90 he a 8. Nun 1y cind HR. Marlin, in Response t o your Jul y 13. 1990 letter concerning
-ne Ju l y :st . t v89 a l l ev:s t ion : "The NRC is in violation of iOCFR SO:.17 by allowing Pilgrim Nuclear Power Station to opernte at above M power wi thout emergency planning in p t A t: e . " ] have decir.lers too t ake advantage of the NRC public
! f o -i r i n y fies . t ti . 199n end present this testimony at the he. ring. In ricing this ellegat ion will become part of the v.-)iten t r a r,s e r l p t a in t triir t. De dedlt with i n yotti current l revleu of emet 9ency p l ein n t n u . ] also expect a formal r...pontw r n im you )n llyht of the tact this is pott of an ongo i ng .i l I v or.t i on thit you er e responslDie to responding io t , i. t ... .h n i e , i wp..e r .:: P*99 01n0 t 0CF R 60 : 47( d ) In ref er ence to the NRC m - ] ci .s toeir iiniting on F.E.H.o. e findings .I will dete to ne 1. i: w teprn? ino theii response on pages 16 and 17. e.o . ' s e i.. fse. i n g i i n 31 .n/dgemrent of t.h l s v i o l a t. l ot t I wiiI wait
. .e t. f m f.0. 9 nitice to complete the audit that is now a.ig.iny.
'he tact sML the NRC un-s oware that the State of Ma. was l
not om na e n e: e s on concerni ng c:mer gency p l ann i ng , and t h.s 1 l iim UPC tn=isesea theit by congnenc i ng wi th the power ascension uuv i ci tot ce the fa ri t e to do their Job on emergency planninij. is well known anci accept ed. Unfortunetely by using that prisiusopny the NRC neglected their primary tunctions protection of pulille health and safety. In the review the , In :: .O n pirrt o rio , you did ignore reliable information vuotuittea to you and focus on BECO's misstatements , half ruthw or iten. Your own etaff has initiated many falue utetements concerning the ststus of emergency planning and con t i nui.fi to c.lo so with Craig Conklin"s erroneous status teports.This must end. the NRC must truly examine the status of emergency planning and properly assess it. For years I have recluest ed that a member of Chairman Carr's office be twns tT tn av:cas the discrepancies between the real1ty and tne fictitious statement's Region ] continues to make. I Peuton I has always been agalnst that idea. the reason why eerms otiv iuus. 0801.A'11UUS OF 10 CFR 60:47 IN PILGRIMS EPZ EMERGENCY el,Aulliins WellCH PREct.UDE A F1NDJ NG OF REASONABLE ASSURANCE fur THE TOWN OF DUXbORY i i p et t,:.y. l', j t p t ( ,'t } g t t, gy g- .. QG } l g.g l g. y = =
"Ecch or ganizat ion shal l describe the means for t egistering and moni toring of evacuees at relocationi centers
/t\
4 in host areas. The personnel and equipment available should be cspabie ot monitoring with!n about a 12-hour periad d3.1. r et4i den t s and transients in the plume exposure EP2 arriving it r e l oc. , i t o n cen tet o. " I we . NUFp 350.6) [cee, NUREG-0654. FEMA-REP-1. 11.J.10.h
.u. ,
ii inne, inCFR 60 47 h(H) lhe lhtlonal Guard han been char ged with the
" mpan-io Iitles of monitorinu the evacueers at the Vellesley Merco' ion Cr nt er . The National Guard has stated their r i ,.o i n.9 t J ou- of arrivaI vilI be 12 h ou r *'t . MCDA otaten pctn.ips the ihIionni Guar d wl I I arrtve in 6-12 hours. In /
5'+"r m+nerio i '. is chutous the per sonal vi l l not be ri wn: tu perform the necessar y moni t oring wi thi n the
'i i l rJ 't i t ft , J silt' t t' a fDe .
nop<mo t he ahove stated point there is the obvious i :n t os m ont,ei s and timrt. Although MCDA inciutu the Portal
'v n i '.or o c an mon i t or one person evety 2ar 3 seconds, Dr.
Mm -I t s he r 16my of the NRC maintsins that, one per<nn every
-s minutes is a ter mote realistic assessment. Using Dr .
n e ' i m y <> t a rpir es and the 3200 people which equals the pl+nned for 204 of the Duxbury population . It will take 80 noiw i to monitor the planned for Duxbury population alone. Elgntv hout s cer tainiy does not ful1 111 the mandated 12 hour irquireroent and t.hese figures have not included the Marnn t l e l a popu l a t.1 on . Ti e time factor alone preclude any ' reasonable
.wiuinoces" on determine by Federal Regulation and %
w i oe l i n-8. fu addition other blatant deficiencies also I t.ti The i r.ek of Sanitary or decontamination tilities f or the h a nd i c appect . The lack of Letters Of Agreement or si.m,tuce paces signed by support groups or back up . congregate care f ac! 11 tles or transportat ton pr ovider s .f r orn l ceception center to congregate care.facillt'les . The lack l
.n irsining for t h e?We$ l ensberflib.ti.C..::p e r son n e l leaves g.tanotov tur the Wellesley reception center att hoc at best.
l inre a t t.sened review *. of the July 20, 1990 tour of W.iraley for o more complete listing of problems)
.-~--~ ,
Tr sne:por ta t 1on Dependant Population "Sr,te ena Ioca1 pians must describ< the "means at ce!ocation" for the population." umee 214 c t r nu.51 (see, NUREG-0654. FEMA-REP-1.II.J 10 (9)1 (eee 10 CFRG0:47 b.(10) Tren*< porta t i on dependent popill ation include peopl e without access to a private automobile, school children and children tn day care while school is in sesslor., hospital
)
.. and nursing home residento, and other mobility-impaired persons.a fatte Barry Report .Dec 16. 1986. pp. 51, 52.53.)
.E
lhe curs <*nt buu matrix and Letters ot' Agreeteent prepMr ed by 14091on Edison enrireview by MCLi indicate that 016 t v ise.-r are enquireo tu evacuato the entire EPZ. 384 ovmen wiil be frecessary for the precautlonary transfe.r of m:n oo l cheidten elone. Upon careful analysis of the current Le t t e tm of: Avreement there are only 292 buses available vitnin the t it Mt a hours with and addltlonal 45 avallable - vithin 4 hours. Again on numbers alone it is clear that any
" re monabl e assurance" has been precluded, t se bus Analysis attached)(see also LOA's)
I, your Ietter ut July 13,1990 you state the staff has not received a copy of the Spengler and KeiIer Wind Study. , Tnto utuoy entanlishes the necessity of evacuattori of the hg e n t. l r e School population of the EP2. This reality was g
.wmontu r a t ed l ei t he May 2es,1990 remedi a l dri l l , when -
F , F .11. A . ceiled for the Precaut1onary transfet of alI school bed
%M
~
mi t an en in the EPe. The wind Study was presented to k i.hc a rionn Chi t on Oct. 12.1989 according to the letter f r om ch a i rtoun Cart 4 Ottice dated Nov.13 more recent phone conversations with Chaltman Carr's staff 1989 and according to YA g
' nit. intorn.,tlan was indeed sent to Region I for review, 11 M 900 h6ve misplaced this inf ormat ion 1 Will be h6ppy to send you another copy teen -.siached Ici ter ctated Nov. 13. 1989)
Hvs we.w ! - i t ce .l.n r R WO . b ) Isee. NUREG 0654. FEMA-REP-111.J.10 (usill .Jiu 8 9): Appendix 4; and E.E.M.A. Guidance memorandum-I:. !-2 f see also, name references'as reception' centers) A Gent ieman
- s AgreemenL i s-the most accurate description of the-current status of host schools for Duxbury. Superintendente of Schools , Drs. Kennedy'and Titrell . trom Duxbury. and Needham-have personally agreed on the une at Needham Schoole as Host Schools for-Duxbury's chi 1dren. The Town of Needham's School Committee-has: voted to accept the children of.Duxbury but again we find the State has failed to do their Job.-The State has not drawn nor insued-L.ettern of Agreement w1th:the Town of Needham.
No'1P*n nave been written forJNeedham nor-redratted for Ouxhury. There has.been no--training of Needham.personnei, no mhps have'been. drawn. noJinstructions have--been written , no nions nove been printed. FurthermoreEthe: Town'of-:Duxbury incints upon and has been promised Needham. our children . utiI De mon)tored betore enterino their schools..No equ i pinen t is in place. Thi8 offers nelther
- reasonable assurance" nor warm
- )
wsucences to the phrente of Duxbury that'aur children wlll he protected in: case of- a radiological accident at Pilgrim. l' (This inLormet ton was contirmed by Dr. Donald ~ Kennedy on Sept. ti . .I 990 ) w-.-..- - - - . - e - - - y , - - , , . - - . - ,1,r---- w . , , - - ,,,-.,m -meeU,
- t In your letter you state the NRC was aware; prior to the occision to allow' Pilgrim to operatea above 5%:of the lesue or host school- and the (unacceptable) solution of' inup l einen t l og the F.>.eecu t i ve Order to sol ve this probl em. I p lleve this to be a false statement. On Oct. 8, 1989 It was Ate mlned that the Host . School BECO had named for Duxbury were totally unaware of this designation and totally um.>i i i i nw to por t i c 1 pa te . Thl=3 was months after the nectation w e mace to ascend above 5%. If the NRC was aware et thau then it tur no other r eason than moral obligat toi ,
you snnoin have informed the necessary officials to correct hhCU e tiogue otatement.
;poni,1 flee n o ,
lhe $! .t e und local emergency plans shall include 1 m . ins feu pr oc iect i nu those persons whose motil l i ty has been i nnto ! : co our to such f actores os institutional or other mu / i nemen t ' and fur thet Indicates that such plans must u mcr i tie the "means of relocation" for the population. ( 4. e -i.1 CFP 360.G) [see NUREG-0664. FEM A-R EP- 1, I I . J .10 ( d ) :
- 1. J o t g ) : c. > t (d): and G 2) (see 10 cfr 50:47 b.(10))
4 -m . aluu 10CFR 60:4'/(b) (12)) THE OptCIA1. NEEDS POPULATION HAS NOT YET BEEN IDENTIFIED !
'[here ace not sutrictent transportat tori providers to ti.neport school children who are transferred first i let v.i n n e the special needs population. The Wellesley Reception Centet as of July 20,1990 has no sanitary facilities nor rJenon taroi no t i on capabl i 1 t l es f or the hendicapped. The MCDA hhs not made a determination as to whether or not the cen)gnated " injured contaminated" hospatal have the c8patu i 1 t y to also handle contaminated handicapped. Again numbere come into play. The 13 designated "In. lured contaminated " hospital have the capability of handling 2 or 9 per. tons in 12 hours collectively that is 39 percons in a 1:t hour period of time. This limited capability again pii+cluden a rcaennable assurance" due to the riumbers of; h Antaledppert popu l at ion alone. (to (12) llo wherre in pianning are l a tch key chi ldren considerec1.
(see attaened review of Wellesley Reception Center.and Ir snispor tie 1on prov iders LOA's and ~ Bus Ana 1 yet s1 SHELTER 1NG.....
-) F.E.H. A. regulations reclulre the development of a range of projective actIone for....the publIc in the plume exposure
T i .
~
W2 *pri t hM guldei1Dec tor the choice of protect ive hetIout<
- er. In piace.
(see 4 4Cli P %U , !. ( 6 ) (10)) (he 1 FM SO:4W D) (9)) inoce nos been tio realit4 tic done reduction study done of
.ne I t oi s o f t h i n Duxbut y . The so-called shelter study vau e determination of square footage only, in the case of the Per cy w sitet Pool neither beco nor the State took into rie l or* r ei t i on I h o t. 4 50 sq. ft. happen to be under water.
t h e. supposed st udy nierel y at tempted to make numbers f i t . The, needed so many sq. tL. per person therefore they came up with the appr opriate numbers. No thought was given to
</ s u r e n t une of the bul lding ot construction of the building.
Tuere is a definit.e need to step back and do a dost reclot:t i on 9 t.udy that will determine which buildings will estectively act as shelters and which parts of those bulIdlny ottet the greatest protection. This is a goal that i s e cos i t y attainable at a minimum cost. The buildings alreedy exist, send an expert into determine which buildings and what sections will of f er pr otection. As at todsy Sept. 6.1990, the Saquish- Gurnet rewsdents and t.he daily beach population have nothing in i iAce toe evu:uation nor sheit.ering. The evecuatIon route uuuvs, ii there were any. would pick up the transjent and reansportat. ton dependent population on the mainland side of the country's Iongest wooden bridge. Imagine the Iast day
. ,1 w he io i h.sery r:h i l d 10 etod over ha9 lett school di.d tred to tne beSch. The si rer.s sound and every chi ld t- etv running tor the Dridge and every tour wheel detve H,ru.s up and stnr(U crlving for the bridge. The Bridge is in~ longest wnocen Dridge in the country, this is great rnouledge tor t.r i v i a l pursult but iL spe 1 I e di sast.er tor
* ,eo,iion. We don't even naed a Nuclear Accident tor dimnster we Just neca a talse sounding of the strens.......
1ne above mentioned ceficiencies were all identitled in tne Ang.ti.1987 F.E.M.A. REPORT en t i t l ed " Se l f- Initiated Review and Intecim Finding for the Pilgrim Nuclear Power Station Plymouth. Ma." These issues are some of the same that the NRC was found to have reported incorrectly in the recent IG's r eport and these issues are some of the issues that are etItI current i y kliown noj; to' be_yAthilftCJdu.t.Ly_JA:Lol.v.ci1 to offer " reasonable assurance" to the health and safety of the Citizens of Duxbury. i And stiI1 the 1let of violatlons of 10 CFR 50:47 continues. Communication.... 10 Cl'R 00. 47 ( b) O,)
; T.T. Martin in your July 13, 1990 letter concerning communication . you states" the staff is aware of no serious il6ws.During the October 12-13. 1989 exercise, r
, J ..
cc.mmunicottons worked properly." The staff is not aware of any problem with the Emergency Broadcast-System" Well T.T. ofice again this IN an-drea where~the NRC stati should have read 1hg_1YR9_F.E.M.A. P.N.P.S.FXERCISE 18h).L. _t!.Qi.WL.PDJ.RCLige 13. Th (3_nu,Lggt i ve vatt.,Loluid- to by gitr_pl LLif _tuo de f I gj.gitt139 e1ted bv F.E.M.A. 1_f I rnav 4001r J11FQ..L.LLA4. "Tili 2.QD111tllLtdQg laetor _yhlch Ied ty i-1.!1" JiLU.h.9.Jt L.lb LS - defICl.gncy fon,,the State gpd Area 11 h ,.!LC l
' wer e the confused and incomplete messages to the public via l F. . H . M .
Prooltsms orose corycerning the E.B.S. Inessagtts." ut e/ s ous l y F.f..M.A."s revleW differs greatly with the NRC's v e 7 9:t v 'i t What amfi/.ca liie more ta the fact t.haL W1111am-l Mo e.sti i i of t he NRC was pr ee<ent - 1 n t he Duxbury E.O.C. to o .1 ( n ur < t i t -n. h o nel Ihe cc:sfuelon that re-Jult trnm these
;omnion i e t,t I on de t i o I ency anct other communIcetion pr001 ems .
it? r 1. t m liL'C' " 't e ov a t y of no serjouS f(dW" l' N? e 41 % auPCal PtJVleN Of the ' Q(.'T .12.19(14 Exercise)
,/
w 8 D ei uay 3rit;O4 U 109 1 O F.E.M.A. the t'Itio l draf t o r t.ner eeine di e i tiriii le not yet complete. Therefore it is not
*nis.n whethe+r oc out correction was demonet, rated,
- t. -era e neIyns9 ni Moy Pts.1990 Remedl a l Dr i l 1 )
i V[l **i!iff.mul'81&orifl9 1 se e 10 Cr r 50 t 47 (b) .(9)
&v Ino unclosed information on Direct Torus Venting preparea oy David Dixon especially'take note of the need to Lle any direct vent.ing to emergency planning.
Tr nining of Emergency Worker to CFR SO:47 (h) (14) You agree with me that training =la not coinp l e t e t o add t o my l i st of untrained personal 1 The mb,lority of Duxbury School. Personnel- - 2 The ent i r e Emer gency Worker Personne l . f or - the Town of l thedham ,- Duxbury's Host School s - 3.The E.d.C. Staif for: the WelIestey.Receptlon.Centec You state key response personnel.hav_e received' training. Perhaps this is-true but certainly..notithe personnel - uecessary to eftect.tvely bring:about a 19uccesstul
" precautionary transfer of Duxbury; School: Children.
Io conelunion1wlth this alaring 1let:of.v'iolatton of 10 CFR' Sn:47-J can etate with reasonable assurance " THE NRC 1S.IN: vlot.ATION OF.10 CFP 00:47 BY ALLOWING'PILGRJM NOCLEAR POWER FI AT10N TO OPERATE AT ABOVE 5%- POWER WITH 00T EMERGENCY. f bl.Aiell t4G 1H PLACE. "
-Sincerely.
.I Jane A.-Flemino .
cc.
l ,
- ,. . ,4 l
1 Sept. F. , 19v0 Pulal lu Heet ing ( tra tie included lie tr6nscrlpt [ i n t;e- reviewerts
- Chis t
- iritin 1;enneth Corr i
D-v i ri W) I I t hms lii'ipect or Geriera l I i 1 i
.a h
I t 1 1 (~ f \ L f ( l-
)
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