ML20116D566

Discusses Issue of Protective Clothing & Breathing Apparatus for Harbormaster & Staff

ML20116D566
Person / Time
Site:	Pilgrim
Issue date:	09/29/1992
From:	Lampert M AFFILIATION NOT ASSIGNED
To:	Chilk NRC OFFICE OF THE SECRETARY (SECY)
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ML20116D551	List: ML20116D566
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NUDOCS 9211060044
Download: ML20116D566 (11)

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l' sDuxbury_ Nuclear Advisory Committee Town. Hall,- Duxbury,: Massachusetts- 02332

-September 29=,

1992-i,m

_Duar(Secretary"Chilki-g JRE: EmergencyfPlanning-Protective Clothing & Breathing Apparatus for_Harbormaster + Staff

'(Note:_the use of the term " protective clothing" is

-in the most general, " layman sense" and-does not mean the." spacesuit" PC's'used by nuclear workers

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in commercial-nuclear' power _ plants)'

Emergency, Planning--Radiological r

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The: Duxbury Nuclear l Advisory 7 ommittee is in the _ process C

of, reviewing the

Implementi rocedures for an Emergency at 1

ithesPilgrim Nuclear-Power S ion.

These procedures are

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Ldeveloped;by the1 utility.and are then. reviewed by our Ecommitteef thefappropriateftown department heads and-the town civil-defense; director, whoithen makefrecommendations to the town"selectment The selectmen approve or_ recommend

'appropriatefchanges-inathe: plan, and their comments are sent on to the MassachusettseEmergency: Management Agency', FEMA _and itheiNRC.

Harbormaster and Beach Personnel--Protective Clothing Onefplanning issua, involves-the-Duxbury.Harbormaster-and fotherfpersonnel who,f n the event'of-a radiological. emergency b

i are expected--to'notifyfthe_.public and assist them:in finding shelter or! evacuating..These1 personnel;will be outside, eduringlthe emergencye until'all necessary notificationLand/or (transportation assistance hasLbeen accomplished.

.A'particular question-has arisen--Do these personnel

/need protectivs(clothing and-special breathing apparatus?

The.Duxbury Harbormaster, Duxbury-Nuclear Advisory

• Committee,1and the.Duxbury Board;of Selectmen,-_say, "yes"._

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ThenDuxburynBoard'of Selectmen,:at their May 4,-1992 meeting l

1 voted-. unanimously;toirequestyfrom Boston Edison' protective Hs

clothingland breathingiapparatus for-thefHarbormaster and his.

(staff.: This< amounted'to' twelve-people that would need a set c":

of/ foul? weather' gear-and aLfull face respirator.

.A formal

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7 requestz was madeLto' Boston Edison:on July l10, 1992.

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The request was denied by BEco, August 6, 1992, in a letter to the Duxbury Civil Defense Director which stated, "On this matter we must defer to the' position of the Massachusetts Department of Public Health as stated in a letter from the Director of the Radiation Control Program of the Commonwealth of Massachusetts, Mr.

Robert Hallisey, dated March 13,,1991.

In this letter, Mr.

Hallisey addressed Duxbury's concern with the determination that protective clothing and/or breathing apparatus would be of very limited value.

We' agree with the position expressed by MDPH and must decline your request for assistance in this matter."

Who Should Be Responsible?

The NRC Task Force (Findings on 1ssues of Offsite Emergency preparedness for Pilgrim Nuclear Power Station, 1991) said that this issue should be resolved by the Massachusetts Department of Public Health.

Boston Edison also stated in a letter to the Duxbury Civil Defense Director dated August 6, 1992, that MDPH la the agency to develop protective action policy in this matter and Boston Edison's role is to " assist...with the implementation of their policies".

However, it appears the ErDDS Bureau of the Massachusetts Department of Public Health was given the responsibility; and herein lies the problem.

The question - whether any protective clothinq or breathing apparatus is required at all - requires an assessment of the health inpact of the release of radiation into the environment.

The question 21v ald have been directed to, and the response provided by, the Bureau of Environmental Health Assessment at MDPH, directed by Suzanne Condon.

Instead, Robert Hallicey, Director of the Radiation Control program in the Bureau of Environmental Monitoring at MDPH responded.

Mr. Hallisey's "world" is oriented towards chemistry and engineering.

His technical staff goes out and measures pollutants, and assesses the shielding capabilities of certain barriers.

Presumably, his staff would

-appropriately answer the question of which breathing apparatus would provide the best protection.

However, he and his staff do not have the expertise required to answer the question whether any breathing apparatus was needed in the first place.

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- l-Hopefully, this issue will be ironed out and the proper bureaus at MDPH will be asked to respond to the portions of these public policy. issues that they are trained to address.

In the meantime, we have a problem.

One DPH " resolution" (which is on the " books" and is the

" reason" BECO gives for its refusal to provide the protective clothing requested by the town of Duxbury) seems to raise far more questions than it answers; and, we hope you can provide us assistance in analyzing this problem.

If the proper health professionals address the issucs raised by Robert Hallisey's March 13, 1991 response, we will be on our way to reso v ng. this important public health issue.

li Mr Hallisey's Response In a March 13, 1991 letter to the Duxbury Civil Defense Director, a copy of the pertinent page of which is attached, Mr. Robert Hallisey, the Director of the Radiation Control Program of the Massachusetts Department of Public Health, said that there was "no need for protective clothing and breathing. apparatus"-since the " goal in emergency planning is to avoid any-unnecessary ~ radiation exposure to individuals in the event of an accident."

On the other hand, the Harbormaster appeared before our committee in October, 1991 and said Pithout protective equipment'neither he nor his assistants could safely perform theft functions.

He pointed out that-these functions

included notification of-boaters in Duxbury and Plymouth Bays

(which, as shown on the onclosed map are directly in front of the Pilgrim. Plant), residents of Clarks Island (5 miles from the plant) and beachgoers (5 to-7 miles-from.the plant).

He also noted.that these tasks are to be largely performed in an open boat.

Further, his sit'uation was somewhat unique;

.he and his personnel were the only emergency workers required to head. south,'towards thL Pilgrim Nuclear Power Plant, while yat the same time, the rest of the population was being instructed to evacuate in-precisely the opposite direction.

The NRC's position'that the harbormaster can safely perform his tasks without protective equipment is irternally inconsistent.

The NRC Task Force on Emergency Preparedness concluded that "the1 preferred protective action for the emergency-workers'would be evacuation rather than having tht.

. don breathing apparatus".

But it also said that the k

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Harbormaster!and 1'.s personnel would " determine the required assistance to the--residents of Clarks Island including ad hoc

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-measures if nocessary",-and if the Harbornaster is evacuated there is no one else_available to perform his. functions._

Mr.;Hallicey's major " solution" to this assertion:is- __

that_"the most probable occurring time frames are expected to allow ample preparation and evacuation if a radiological releaseLis expected".

In other-words, Mr. Hallisey hcpen to know: about-an accident long enough _before it happens so that the harbormaster and his personnel _can warn and evacuate teveryone before there is any real danger.

-Emergency-planning should not rest on such a "best case" analysis.

This is particularly true here since, according to-LFJREG-065.1, a boiling-water reactor has a potential for a release in 0-to 30. minutes.

However, just as it would be e'

Wrong to plan only1for."best case" accident. scenarios as Mr.

Hallisey did;11t would be as wrong to plan only for " worst case" scenarios.

Logic' dictates planning for a reasonable

" middle ground".

Mr. Hallisey's~ statements that " assuming a fast-breaking accident-occurred":

a.

-' the release would be principally noble gascs with

possiblyLvery' low amounts of iodine and particulates";

- b.-- - thero-would'be a time delay, depending upon-wind

-speed'before this' gaseous plume _ reached Duxbury"; and,

-c.-

"the. exposure of: concern would be whole body gamma doses, and Mhus; protective clothing and breathing apparatus would befof-very limited value"-

appear to.us to be internally inconsistent, apparently defying _ common:sonse,-and-generally puzzling.

They also

raisela4 number of questions. for example:

ar 'Is Mr. Hallisey correct in his_ assumption that

" noble gases" are apparently not important?

b.

IsLit realisticfto assume that, at-most, there-will

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"possibly" be "very low amounts of iodine and particulates?"

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'c.

Given the distances involved, and particularly if L

,yountake~1nto' account the on-shore wind that occurs much of

t the time, is the " time delay" between release and when "this gaseous plume reaches Duxbury" long enough for the unprotected Harbormaster to do his job?

It is not unusual for the area to experience 20 mile an hour winds in a non-storm weather pattern.

Clark's Island, a responsibility of the Duxbury Harbormaster, is 5 miles from the Pilgrim Nuclear Power Plant.

d.

Under what conditions will the " exposure of concern" be only "whole body gamma dose"?

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e.

Is it not liXely that alpha and beta particles would be emitted during an accident?

Is it true that they cause their biological damage through inhalation and ingestion?

Accidents happen; and, by definition, provide the unexpected.

The resin spill at Pilgrim in 1982 was not expected, f.

Given all of this, is it really fair (particularly to the Harbormaster and his personnel) to conclude that f

" protective clothing and breathing apparatus would be of very limited value"?

If you have comments on the issue in general, and Mr.

Hallisey's statements in particular, that would assist us in evaluating the need.for " protective clothing and breathing apparatus", the committee would greatly appreciate your forwarding them to me, or simply giving me a call:

Mary Elizabeth lampert 148 Washington Street

Duxbury, MA 02332 (617) 934-0389 We thank you for your time and efforts on behalf of the 6

" ordinary citizens" who are forced to function in today's scientific and technologically oriented society without the necessary scientific expertise. We depend on scientists, like you, who are willing to help the public.

Sincerely yours, G

. G WL 4,uut q Mary Elizabeth Lamper*

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Secretary Samuel Chilk, NRC, Washington DC 20555

. Set.ator Edward Kennedy

-Senator John Kerry Representative Gerry Studds Senator Edward Kirby Chairtaan Carmen Buell OSHA Selectmen Towns of: Duxbury, Kingston, Plymouth Duxbury Civil Defense Director Duxbe./ Harbormaster Center for Atomic Radiation Studies Childhood Cancer Research Institute C-10, Newburyport Citizens Awareness Network-Rowe MassPirg Dr. Douglas Crawford-Brown Dr. Richard Clapp.

Dr. Sidney Cobb Dr. Robcrt Goble Dr.-Karl Kelsey Dr. Tony Robbins Dr. Gregg Wilkinson

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Dr. Thomas Winters M

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David R W Harch 13, 1991 Carl D. O'Neil, Chief /

' Civil Defense Directo,r Duxbury Fi ' Department P.O. Box 11.

'Duxbury, MA 02331 D'eahChiefO' s

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, The -following is in response to your letter of January 4,1991,ing to

- me,.-me well as : your letter of January 11, 1991, to John Lover concer6ing emergency planning issues for the Town of Duxbury.-

I sincerely-apologize for the delay 1.n responding to these. letters; however, I was under the mistaken impression that you had been contactedLdirectly concernfng 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, 1901, letter to John Lovering of the H.C.D.A.,

as follows:

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Protective clothing for personnel We do not believe.that there is a need for protective clothing 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 prsparation (7d evacuation if a

radiological release is expected.

.However, sissuming

-a fast-braking accident occurred..

the release would be principally; noble gases with possibly very very low amounts. of iodine 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 linited value.-

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DUXBURY CIVIL DEFEi!CEIV e an Post Office Box 1153 i

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DUXBUR Y, MASSACHUSETTS 02331

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TEL. 617-934 7159 TOWN OF OUXBURY i

FAX 617-934-6530 July 10, 1992 Mr. Ronald A. Varley, Maneger Emergency Preparedness 110 Long Pond Road Plymouth,liA 02360 L

Dear Mr. Varley:

The Duxbury Board of Selectmen, at their itay 1,1992 meeting, voted h.

unanimously to-request from BECo protective clothing and breathing apparatur for the Harbormaster and his staff. This amounts to twelve people that would neec' a full set of foul weather gear and a full face respirator for each energency worker.

I request that Boston Edison Company provide (12) full sets of foul weather gear acceptable to the Harborraster and (12) full face resoirators (Wilson 5000 $eries equivalent)_ with appropriate filter cartridges. This equipment-is being requested to provide these emergency workers some protection from radioactive contamination since they may be required to perfora ener5ency work in arets where-no shelters are availabic in a reasonable period of time, should sheltering or evacuatior, be required.

Your prompt attention to this request is necded since these workers are

- presently working in remote areas each day. Please contact ce if you need more information or have any questions.

Sincerely

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Q Chief arl D. O'!!eil Civil Defense Director CON /km

'cc:

fir. Thomas J._ Groux, Town Manager ftr.. Alfred Slaney Regional Planner, MEIM Mr. Donald Beers Harbormaster

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Po?d RECEIVED to gPo PNmoutn Massachusett:02360 AUG 121992 lowr 4 or DUX8URY 00ARD OF SELEtrMEN Emergency Preparedness Department I'

August 6,1992 EP92 324 Mr. Carl D. O'Neil Civil Defense Director P.O. Box 1153 Duxbury, MA 02331

Dear Mr. O'Neil:

We have received your request for respiratory protection equipment and protective clothing for the Harbormaster and his staff.

With respect to this issu<> it is important to bear in mind that the Massachusetts Department of Public Health along with the Massachusetts Emergency Mar,agernant

' Agency are the agencies who establish protective action policies for the Commonwealth. Boston Edison's role is to assist these agencies with the implementation of their policle.

On this' matter we must defer to the position of the Massacuusetts Department of Public Health as. stated in a letter sent to you from the Director of the Radiation

. Control Program of the Commonwealth of Massachusetts, Mr. Robert Hallisey, dated March 13,1991. In his letter, Mr. Hallisey addressed Duxbury's concern with the dete.rmination that protective clothing anri/or breathing apparatus would be of very limited value. We agree with the position expressed by MDPH and must decline yot'r request for assistance on this matter, in a separate but related matter; futare requests for equipment support should follow the guidelines outilned in Administrative Procedure AP-06," Equipment Maintenance Prcgram", for the Town of Duxbury. This procedure describes the mechanism the Town is to use for requests for new equipment. The process within this administrative procedure a!!ows for Boston Edison and the town to quickly review and respond to Agency / Selectmen requests.

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p oe Mr. Carl O'tJeil EP92 324 Par ~e 2 As stated earlier, if there is a need for further information regarding the protective rinthing issue, please enntact the Massachusetts Department of Public Heal h or the t

Massachusetts Emergency Management Agency.

Sincerely,...

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'd Ronald A Varley Manager, Emergency Preparedness BY/jlm Abdule C. HamadW, Chairman Board of Selectmen /

cc:

Tom Groux, Town Manager Donald Beers, Ouxbury Harbormaster Robert Hallisey, Director Radiation Control Program Richard Strome, Regional Director FEMA f"

A. David Rodham, Director MEMA Alfred Slaney, Regional Planner, MEMA Ron Markovich, BECo Offsite Division Manager Richard Finn, BECo Sr. Community Representative Barney Yt.tman, BECo Community Representative File 8.3.1 i

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