ML20135E389

Forwards Plant Emergency Preparedness Lessons Learned Task Force Rept

ML20135E389
Person / Time
Site:	Pilgrim
Issue date:	10/16/1990
From:	Rathbun D NRC OFFICE OF GOVERNMENTAL & PUBLIC AFFAIRS (GPA)
To:	Studds G HOUSE OF REP.
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ML20127B494	List: ML20127B490 ML20127B496 ML20135E389
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NUDOCS 9703070024
Download: ML20135E389 (22)

Text

CCT 16 '90 13:59 NRC WF 16B13A P.2 h

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NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 2000G o l

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The Honorable Gerry E. Studds  ;

United States House of Representatives '

Washington, D. C. 20515

Dear Congressman Studds:

In Acting Chairman Remick's letter of September 5,1990, he noted that the staff would be working on a lessons learned study concerning the Inspector General's report on Pilgrim. I am enclosing the report for your information.

Sincerely, f& f. ' s

, Dennis X. Rathbun, Diregtpr 2 Congressional Affairs o  ?

Office of Governmental and R Public Affairs E3:

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, CCT 16 '90 14:00 NRC IF 16B13A P.3

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l PILGRIM EMERGENCY PREPAREDNESS l i LESSONS LEARNED TASK FORCE I THOMAS E. MURLEY, DIRECTOR OFFICE OF NUCLEAR REACTOR REGULATION EDWARD L. JORDAN, DIRECTOR OFFICE FOR ANALYSIS AND EVALUATION OF OPERATIONAL DATA GUY ARLOTTO, DEPUTY DIRECTOR i

OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS  !

l FRANK MIRAGLIA DEPUTY DIRECTOR OFFICE OF NUCLEAR REACTOR REGULATION l l

JAMES M. CUTCHIt, IV ATTORNEY l OFFICE OF THE GENERAL COUNSEL CHARLES E. NORELIUS DIRECTOR DIVISION OF RADIATION SAFETY AND SJfEGUARDS

~ REGION I!!

FRANK J. CONGEL, 0" RECTOR DIVISION OF RADIATION PROTECTION AND EMERGENCY PREPAREDNESS ,

WILLIAM F. KANE DEPUTY REGIONAL ADMINISTRATOR REGION I l

OCTOBER 1, 1990 1

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CCT 16 '90 14:00 NRC W 16B13A P.4

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l PILGRIM EMERGENCY PREPAREDNESS LESSONS LEARNED I

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I. Introduction l

In August 1987 the Federal Emergency Management Agency (FEMA) issued a I report on the adequacy of offsite emergency preparedness at the Pilgrim i

Nuclear Power Station, which concluded that " Massachusetts "' '

radiological emergency planning and preparedness are inadequ 9 protect the public health and safety..." The FEMA report raised issues that the Nuclear Regulatory Commission (NRC) staff determined had to be addressed before the restart of the Pilgrim facility. Da July 23, 1990, the Office oftheInspectorGeneral(IG)issuedReportNo.90N-02onitsinu.stipticn of the NRC staff's review of Pilgrim offsite emergency preparedness. The

. IC concluded that (1) the assessment conducted by the t:RC staff of Pilgrim offsite emergency preparedness was neither balanced nor thorough, and I (2) certain information provided by the str.ff concerning the status of Pilgrim offsite emergency preparedness during the October and December 1988 Comission meetings was inaccurate.

In a memorandum to the Chairman of August 3, 1990, the Executive Director forOperations(E00)statedthattheDirector,OfficeoffluclearReactor Regulation (NRR), had been requested to conduct a lessons learned review and to provide recommendations on how we should proceed in the event we encounter a similar situation in the future. A lessons learned task force was formed by the Director, NRR, which consisted of eight senior members of NRC management including some who were not directly associated with the Pilgrim matter. On August 17, 1990, the Chairman directed that the lessons learned study should specifically address (1) an evaluation

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4 2-of whether any staff omission or error occurred in the Pilgrim review, and (2) the need for any additional staff guidance or procedures were the circumstance to arise for the staff to again conduct a review of this unique type. The task force charter and related correspondance are j enclosed with this report. ,

d II. Background j

In April 1986, the Pilgrim facility was shut down for technical and managenent reasons. On July 15, 1986, Massachusetts State Senator William B. Golden and others submitted a petittor to the NRC.which, in addition to management and containment issues, alleged inadequacies in the emergency plan for Pilgrim. On Decen.ber 22, 1986, Charles V. Barry, the Secretary of Public Safety of the Commonwealth of Massachusetts, sent FEMA a report, " Report to.the Governor on Emergency Preparedness for en Accident at the Pilgrim Nuclear Power Staticn," Decenber 1986. The Secretary of Public Safety also asked FEMA to review a Boston Edison ,

Company (BECo) report, " Evaluation of Offsite Emergency Preparedness in the Area Surroui;aing the Pilgrim Nuc1 car Power Station," January 1987,

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which was prepared for BECo by the Impell Corporation. In a memorandum of March 31,19E7, FEMA informed the NRC that it was ccnducting a self-initihted review of the overall state of emcrgency preparedness (EP) at Pilgrim. FEMA stated that it would prepare a consolidated evaluation that would address issues raised in the petition by State Senator Golden, the report submitted by the Massachusetts Office cf Public Safety, the BECo report, and otner relevant available information.  :

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• On August'6, 1987 FEMA fofwarded its report, "Self; initiated Review and

. Interim Finding for the Pilgrim Nuclear Power Station," to the NRC. FEMA  ;

found that offsite emergency preparedness had deteriorated at pilgrim and j that FEMA could no longer make the finding that the Commonwealth and l l

local plans were adequate. Specifically, FEMA identified six emergency j preparedness issues: the lack of evacuation plans for public and private schools and day care centers, the lack of a reception center for people evacuating to the north, the lack of identifiable public shelters for the beach population, inadequate planning for the evacuation of the special needs population, inadequate planning for the evacuation of the transportation dependent population, and an overall lack of progress in planning and -

apparent diminution in emergency preparedness. FEMA informed the NRC that because of the changed circumstances at Pilgrim, the finding of adequacy contained in FEMA's previous interim finding report no longer applied.

Because the plant was shut down by Boston Edison at the time for reasons other than emergency preparedness, the NRC concluded that there was no additional safety assurance to be gained by taking immediate enforcement action. Boston Edison was working with the Comonwealth and local officials at that time to improve the offsite emergency response plans, and it was apparent that improvements were being made. However, the NRC staff judged the deficiencies identified by FEMA to be significant encush that the NRC stated that the plant would not be permitted to restart until improvements were made in the plans and some demonstration of those improvements was observed.

CCT 16 '90 14:01 tRC WF 16B13A P.7 FCliA informed the staff that it would not be in a position to update the finding made in its self-initiated review until the Comonwealth submitted revised plans for review and some demonstration of the plan changes ir a drill or exercise occurred. Knowing that progress had been made in upgrading emergency preparedness at Pilgrim and that the plant would be ready to restart before completion of the FEMA review, the NRC staff undertook an evaluation of the progress and improvements in emergency preparedness which had occurred in the time period after FEMA issued its August 1987 report.

In a Commission meeting on October 14, 1988, the staff presented its findings addressing the readiness of Pilgrim to restart. Regarding  ;

energency preparedness, the staff determined that adequate progress had '

beEn made on the deficiencies identified by FEMA, based on a review of j plan improvements and cbservation of some demonstrations of those improvements. In addition, the staff determined that an infrastructure

- to handle emergencit:s was in place and would implement the revised plans, and the Comonwealth had demonstrated its response capabilities at other exercises in the State. Therefore, the staff ccncluded there was reasonable assurance that adequate protective actions can and will be taken in the event of c. radiological emergency at Pilgrim. The staff recognized that there was more work to be done in connection with emergency planning at Pilgrim and stated that there must be continued At progress in finalizing the resolution of the outstanding EP issues.

the meeting, Senator Edward M. Kennedy, Congressman Gerry E. Studds, and

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Lt. Governor Evelyn F, Murphy of Massachusetts presented their views on Pilgrim restart arid cr.crgency preparedness issues. They each stated that

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[mergency planning in the Pilgrim emergency planning zone (EPZ) was ina'dequate, and they urged the Comission not to approve restart i of Pilgrim until the deficien:ies had been fully corrected. In addition, there was correspondence from the local officials to the Connission stating that emergency planning for Pilgrir.was inadequate. Therefore, the Corunission decided to hold a second meeting on December 9,1988, to permit State and local officials to present their views regarding the status of emergency preparedness at Pilgrim directly to the Cocr.ission.

On' December 21, 1988, the Commission, after consideration of the information provided by the State and local officials, the elected Massachusetts representatives, BEco, and the NRC staff, voted to authorize the NRC staff to allow restart of the Pilgrim facility. The decision to allow restart was predicated on a controlled power ascension program with established hold points which required NRC approvd before the licensee could proceed to the next hold point. Continued progress in resolving the energency planning issues was one of the factors considered in the approval process. The power ascension program was completed on February 12, 1990.

The IG investigation was initiated based on two letters receiveo in June and July 1989 which alleged that the NRC staff provided inaccurate inforraation and misrepresented certain facts on offsite emergency preparedness to the Commission during its meetings on October 14, 1988, l and December 9, 1988. As noted above, the IG report was issued on l

July 23,1990.

OCT 16 '90 14:02 tRC W 16B13A p,9 3

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A full participation exercise was conducted at Pilgrim by FEMA on October 12-13,1989. Two deficiencies were identified which were 2

resolved in a remedial exercise held on May 25, 1990.- In a report issued

, on August 31, 1990, Fetu stated that notwithstanding the progress made, the inccmplete status of some plans and lack of some dicumentation prevents FEMA from resolving all the inadequacies identified in its August 1987 self-initiated review, and from certifying that the State plans and procedures are sufficient to meet the criteria of NUREG-0654/FElM-REP-1.

III. Lessons Learned as a Result of Task Force Study I Members of the task force were provided copies of the IG report and background information documents to review before meeting as a group to discuss the lessons learned and to offer possible alternatives to the review process used by the HRC staff to determine the status of offsite emergency preparedness if faced with a similar situation in the future.

On September 17 and 18, 1990, the task force met to discuss their initial i findings and met again on September 24, 1990, to finalize their report.

The following discussion sun:arizes the principal lessons learned that were ider.tified during the task force's deliberaticns on the Pilgrim case.

1. EARLY CO MISSION GUILANCE ON POLICY DIRECTION i

If, for any reason, FEMA withdraws its reasonable assurance finding for offsite emergency preparedness, the NRC staff shculd promptly review the new FEMA findings and make a formal documented

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determination of NRC's position regarding its reasonable. assurance

!- finding concerning emergency preparedness for the plant in question

- in accordance with 10 CFR 50.54(s)(2) and (s)(3). If the !!RC staff l 4

finds that the state of emergency preparedness does not provide reasonable assurance that adequate protective rcasures can and will I

l be taken in the event of a radiological emergency, and if the

deficiencies which caused the staff to make the finding are not corrected within 120 days of that finding, the staff will make l

recorrtendations and the Commission itself will determine whether the rtactor shall be shut dcwn until such deficicimies are rer..edied or 3

whether other eniorcerrier.t action is appropriate. A decision to 4 undertd:e au HRC rtvieu of offsite emergency preparedness should be made by the Commission itself.  ;

2. NRC-FEMA RELATIONSHIP The task force believes that for effcctive State and local involvement in the development of acceptable offsite emergency preparedness, it is imperative that there be a continuing, active FEMA presence. With FEMA's continuing involvement, the inadcquacies identified by FEMA (or NRC) will continue to be addressed in t. teara effort resulting in a cosa.cn ugreer..cnt that "reascnable assurance' l has been achieved, or that differences have been clearly identified.

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The task force four.d that there is a need to reexamine the.

relationship and respcasibilities of the NRC and FEMA with regard to i l offsite emergency planning. This recxamination should focus on the Memorandum of Understanding (MOU) between the agencies to c1carly deliner.te responsibilities in a situation where FEMA withdraws its finding of reasonable assurance for a plant with an operating license.

As part of this reexamination, NRC and FEMA should develop a coninon I understanding of the requirements for a finding of reasonable assurance. Further, such examination should address FEMA's role in continuing to work with State and local governments in a timely manner following a determination of a lack of reasonable assurance. J Such examination should recognize that under Executive Order 12657, .

t issued on November 18, 1988, upon certificction by a utility that l State or local governments decline or fail (1) to prepare adequate [

offsite cuergency plans, or (2) to participate adequately in the j preparation, demonstration, testing, exercise or use of such plans, FEMA is directcd to take actions to ensure that adequate offsite ]

plann and procedures are in place. FEMA assistance is to include advice, technicel assistance, and arrangements for facilities and resources, and to make plans and arrangements for Federal response.

FEMA is to utilize to the maximum extent possible the resources of f the utility and State and local governments before it relies upon ,

its own and other Federal resources.

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3. NRC STAFF PROCEDURES There may be special circumstances in which FEMA is unable to participate in the review of offsite emergency preparedness for an operating nuclear power plant. In such a case, the NRC may need to

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i consket its own review to determine the current state of reasonable t assurance relative to continued operation of the plant. Such a case i existed for Pilgrim.

4 The task force examined the process used by the NRC staff to evaluate

- the progress and improvements in the area of offsite EP at Pilgrim.

From this examination, the task force found that no specific plan or O

procedure had been established to formally document progress or improvements. To carry out a decision by the Comission to conduct

! an NRC review of offsite EP, the staff will develop a comprehensive action plan including the following' elements:

• Plan and procedures for conducting the review.

• Management and organization for the revich including a dedicated SES manager.

• Identificaticn of resources needed to execute the plan. l

• Consider the establishment of a temporary flRC office in the 1

area of the affected plant. l

• Engagement of local officals to obtain their views.

• Public r..eetings to cbtain yfews of general pubitc.

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l Final public meeting to inform the public of the results cf l

the NRC's fact fir. ding and to solicit any additional consents.

• Development of a comprehensive, fully documented, report to the Commission regarding findings.

4. COMMUNICATION BETWEEN THE COMMISSION AND Tile STAFF The current process of communication between the staff and the Commission allows for direct questioning of the staff during presentations to the Commission. In general, staff presentations are made by HRC staff management and do not deal with the level of detail on offsite EP that was addressed during the Commission n.eetings on the restart of Pilgrim. The staff members who responded to Consission questions on some of the details of offsite EP did not have extensive firsthand information or did not refer to the l background documents. Some of the transcript responses were corrected .

later, although son:e which did not get additional qualification, could have been misunderstood. In situations involving complex emergency preparedness issues that are under dispute, a written report should be provided to the Consissioners before an open meeting to discuss the issues. If questions arise during the meeting that the Connission considers to be relevant and material to its decision, and the staff is not prepared to give a factual answer, the question (s) should be referred to the EDO in a staff requirements namorandum (SP.M) and respcnded to in writing. This process will provide a more accurate, documented record.

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The task force believes that the in.portance of accurate staff ,

l presentations to the Comission should be obvious. However, the Pilgrim experience indicates that a more formalized process may be l required to reduce the potential fer misunderstanding, especially during exchanges between Comissicners and staff that go beyond prepared statements. From a critical look at some statements given to the Comission at its meetings to discuss Pilgrim restart, the task force believes that written responses to Comissioners' questions would be better considered and qualified by the staff so as to reduce questionable iriterpretation.

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5. COMMUNICATION BETt!EEN THE C0rJIISSION AND OTHERS WITH DIFFERING OPINIONS REGAkDING EMERGENCY PREPAliEDNESS The staff presentations to the Comission are a distillation of views on the issues being considered. While the staff attempts to consider and resolve differing opinions of parties outside the NRC, it is r.ct always successful. In this regard, in certain circumstances, the Commission may wish to consider having State and local officials present their views on staff reports and fir, dings directly to the Comission, recognizh.g that these parties may strongly hold to views that are opposite those of the staff.

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6.[. GENERIC GUIDANCE TO THE staff -

The task force censidered that the lessens learned above might apply to areas other than emergency prepartdness. The staff must take care  :

to properly qualify cral responses to Comission questions. This is >

cspecially true when the staff is not certain of the answer and would best serve the Comission by providing a written response. The i statements that most often come into question are those made to the

• Comission in direct response to a Comissioner's question during the staff presentation. Accordingly, the Comission may want to consider issuing generic guidance to the staff on how to cormunicate with the

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Ccmmission on sensitive issues. However, the task force recognizes

. that an overly formal communication process may inhibit the interaction in staff discussions during Ccmission meetings. t IV. Evaluation of Staff Omission or Error 1

In an August 17,1990, memorandum to the EDO, the Chairman requested the lessons learned study to evaluate whether the staff made any omission or error in its review of Pilgrira offsite emergency preparedness. In response to this request, the task force has reviewed the prepared staff statements and responses to questions made at the October 14, 1988, and December 9,1988, Commission meetings; the hovember 15, 1988, submittal to the Comission, " Pilgrim Status Update;" the July 23, 1990, IG report; and the transcripts and report of interview of the IG with certain NRC

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staff. The task force did not review the entire record of the !!RC staff's review of Pilgrim offsite EP._

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4 The task force has broadly interpreted the Cor.r.iission's charge to evaluate . I

omissions and errors and has identified 14 instances in which questions i f may arise concerning the completeness or accuracy of statements made by l i

the staff to the Comission. We found that in some of these statements l ,

the staff failed to fully qualify responses to Commissioners' questions to 1 2

indicate that they did not have the firsthand knowledge necessary to i i

provide the level of detail sought. However, the task force believes that any omission or error resulted from an effort by the staff to communicate

! fully with the Commission _at the time. As noted above, the task force 4

recognizes the need for the staff to communicate fully and accurately with j ,

the Connission. The. unique circumstances presented by the Pilgrim l emergency preparedn'ess review led the task force to the lessons learned l that are presented in Section Ill. The task force believes that the adoption of these lessons learned in any future review of a unique situation similar to pilgrim offsite emergency preparedness would result in a more formal process that would reduce the likelihood of such omissions and errors as are discussed in the following items.

1. During the October 14, 1988, Comission meeting to discuss the status of the Pilgrim facility and to consider a possible vote on allowing restart, in the staff's prepared statement discussing the status of eraergency preparedness, the staff stated that "In order to assess progress, the NRC staff has... discussed the issues with... local tcwn emergency planning officials." [80]

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! The statement, while truer should have beert qualified to clarify that the staff did not discuss all of the issues with all of the

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, officials, and that in many instances the local officials held views different from the staff.

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2. In its prepared statement, the staff stated "We have... toured the area, with special emphasis on the beaches and the local J

emergency operating centers." [80]

< The statement, while true, implies a level of activity beyond that i

performed. The statement should have been qualified to make it

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j clear that all the emergency operating centers (EOCs) were not j . visited, and additional visits to beaches by NRC staff were limited.

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3. In the same prepared statement to di'scuss the status of implementing procedures, the staff stated "There are five procedures for two EPZ communities for Plymouth and (Duxbury) that, although prepared, have not yet been approved by local officials for forwarding to the Comonwealthfortechnicalreview."[82] In a later response to a question from Chairman Zech, the stsff presenter stated, "There are approximately 300 as a round number of required implementing procedures and as I indicated, there are five of those procedures that hcVe yet to be sent to the Commonwealth with any type of approvalfromthelocalofficials."[96]

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This was an inaccurate statement. The staff acknowledged this error and provided a correction to the transcript to the Commission on October 21, 1988. The correction indicated that the five procedures were undergoing review by the local officials, and the five procedures, as well as all the procedures for Plymouth and Duxbury, had not yet been approved by the local officials for forwarding to the Com.onwealth for technical review.

4. In response to a question from Comissioner Rogers, the staff presenter stated, I have visited the local emergency operating centers and those facilities are there and they are ready to be used in an emergency." [92]

The statement should have been qualified because it could imply that the staff had visited all seven EOCs and assessed their preparedness.

At the time the statement was made, the staff had only visited the Duxbury E0C and understood from discussions with individuals present in the EOC that they believed it was ready. This statement was subsequently corrected in the October 21, 1988, submitta?. to the Comission. The staff provided additional clarifying information in the November 15, 1988, submittal to the Commission indicating that the staff had toured each of the seven local EOCs following the October 14, 1988, meeting.

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.. 5. In response to a question from Chairman Zech regarding the amount of interaction with local officials and whether they were conversing with and working with the staff, the staff presenter responded, l

,- " Pretty much so. I have a number of the public that call me quite 1

regularly. that are here today and we converse probably on a daily I basis. Yes, sir." The Chairman then asked if the staff had any I difficulty as far as local officials are concerned with articulating the Federal responsibilities. The staff presenter responded, No, sir. There's been no problem in that area and I have in any number of occasions been up in front of a large number of members of the public and elected officials to make sure that they understand the responsibilitics of the Federal community, the NRC, the Commonwealth

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. and the local officials. Some of these meetings have dragged on till 1:30inthemorning, sir."[95-96]

The staff statement should have been qualified to indicate that the staff had interacted primarily with Commonwealth officials on  ;

technical issues related to emergency planning. The staff was aware of the concerns of local officials through attendance at meetings held by the steff and others at which EP issues were raised. On November 15, 1988, the staff provided this clarification to the Commission.

6. In response to a request by Chairman Zech to discuss areas that are difficult to evacuate, the staff presenter stated "Tne beach popu-lation area -- I have toured that beach population -- it is required

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~ocT ib '90 [4:07 N CIN [6813N P.20 to get on and off that beach with a_four wheel dr1ve vehicle. You l

could not take your car on it. So, there-is some limited access.

,There are a fair number of permits that are issued to those four-l wheel drive vehicles. The number is in the several thousands and they have made sure that the plans and procedures indicate that those  :

beaches will be closed at an early stage so that you would not put more people on those beaches if there is any type of event at the PilgrimStation."[97-98]

l The statement should have been qualified to specify the beach or beaches being discussed, such as Saquish and Gurnet, Duxbury, or-Plymouth, and to specify the maximum number of people and the maximum number of four-wheel drive vehicle permits at any one of these beaches.

7.. In response to Comissioner Carr's question, "Do they overnight on

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those beaches?" the staff stated "No, sir. Theydonot."[98]

The statement should have been qualified to reflect that the staff was only referring to the transient population.

8. In response to a question from Comissioner Carr regarding the ability to leave the beach and the duration of lunar high tides, the staff stated, "Yes, sir, and those beaches are -- (isolated) only approximately four hours a month."[98-99]

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This statement was too facile for this complicated. issue,.which warranted more consideration and an in-depth study with a written response.

9. During the December 9,1988, Commission meeting, the staff stated, "The status of emergency plans, implementing procedures and other supporting documents for the five towns within the 10-mile EPZ and the two reception communities, is consistent with the status presented by the staff on October 14,1988."[167]

The statement is inaccurate because, as previously indicated, the staff had determined that the status of implementing procedures that was presented on October 14, 1988, was in error, which caused the staff to submit clarifications to the Commission on October 21, 1988.

10. In the same statenent on December 9, 1988, the staff stated, "34 ofthePlymouthprocedureshavereceivedselectmenapproval."[168]

The statement should have been qualified to say that, although the Selectmen had reviewed and then forwarded the procedures to the Commonwealth for informal technical review, they had not formally approved these procedures. .

j 11. In the same statement on December 9, 1988, the staff stated,

! " Implementing procedures have been drafted for all schools and approved l

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at the department head levet. Subsequently the school superintendent i l

for Marshfield has indicated his dissatisfaction with this plan.

Several school comittees have yet to approve the procedures." [169] i The statement should have been qualified to clearly indicate that, even though the procedures had been reviewed, forwarded for informal technical review, and used for training, none had been formally approved. ;

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12. In the same statement, when discussing transport 6 tion providers, the I staff stated, "The form and cor. tent of the letters of agreement are now approved by the Commonwealth." [172]

.9 The statement should have been qualified to indicate that there appeared to be an understanding between the parties in form and i I

content but that formal agreement had not been made. l 8  :

13. In the s me statement, when discussing the cvacuation concerns for the Saquish and Gurnet area and for the portion of Duxbury Beach that is south of' Powder Point Bridge, the staff stated, "The town of Duxbury, particularly the Department of Land and Natural Resources, hcs the necessary resources to effect an evacuation of this arca, and this department head believes a peak population for this area is 4000, with 3000 being typical. The head of the Duxbury Department of Land and Natural Resources has stated that cecess is limited from the Powder Point Bridge south to 500 vehicles, and is strictly enforced.

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"Kccess to the SaguishTCufnet area is ilmited to the residents and

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suuaer population is less than 700."[176-177]

,0CT 16 '90 14:08 NRC W 16B13A P.23 The statement should have been qual,1fied to specify that the beach populations from Saquish and Gurnet and the portion of Duxbury Beach that is south of Powder Point Bridge should have been added together to obtain an accurate estimate of the possible number of evacuees l

from the area south of the bridge.

14. In the same statement, in discussing the public information brochure, the staff stated, "The language in the upcoming public information brochurehasbeenapprovedbytheCommonwealth."[178]

I The statement should have been qualified to state that although the '

Comonwealth had reportedly reviewed the draft brochures and e

, iridicated to BEco what changes needed to be made, they had not formally approved the brochures.

NOTE: The words in parentheses in Item Nos. 3 and 8 reflect the correction that was provided to the Commission on October 21, 1988. The numb,ers -

in the brackets refer to the transcript pages in the October 14, 1988, (104 page version)-and December 9,1988 Comission meeting transcripts.

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