ML20154E160
| ML20154E160 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 12/16/1987 |
| From: | Barry C MASSACHUSETTS, COMMONWEALTH OF |
| To: | |
| Shared Package | |
| ML20150E217 | List: |
| References | |
| FOIA-88-198 NUDOCS 8809160239 | |
| Download: ML20154E160 (37) | |
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REPORT ON EMERGENCY PREPAREDNESS FOR AN ACCIDENT AT PILGRIM NUCLEAR POWER STATION I.
INTRODUCTION Since my December, 1986, report, local, state, and federal authorities have been active in numerous ways l
concerning safety at Pilgtin Nuclear Power Station.
The Boston Edison Company, owner and operator of Pilgrim Station, has also taken a number of actions regarding nuclear management, reactor safety, and emergency preparedness.
Nonetheless, it la still my opinion that Pilgrim Station should not be permitted to restart at this time.
Until fully revised plans have been developed and found by the state to be adequate, I must
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continue to make the finding that there are not presently adequate plans for response to en accident at Pilgrim Station.
Thus, in spite of progress which has been made, I cannot yet any that all safety issues pertaining to Pilgrim Station which were discussed in my December, 1986, report have been satisfactorily addressed.
Subsequent to December, 1986, other bodies have made reports on safety at Pilgrim Station and reached the same conclusion we did, that public health and safety would be compromised by the continued operation of Pilgris Station unless and until substantial remedial action had been taken.
These reports include a study by the Massachusetta Legislature's Special Joint Commission to Study Safety at Pilgrim Wuclear Power Station, the U.S.
Nuclear Regulatnry Commission's (MRC) Systematic Assessment of Licensee Performance (SALP), *and a Self-Initiated Review of emergency response plans by the Federal Emergency Management Agency (FEMA).
The Federal Emergency Management Agency has issued an i
essessment of the plans for response to en accident at Pilgrim.
1 FEM A concluded that their earlier 1942 interia finding that Pilgrim's emerg ency plans were adequate was no longer valid and was superceded by a new finding that the piens as seat recently revised in 1945 were not adequate.
This new finding was
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transmitted to the Nuclear Regulatory Commission, which has J
taken the poettion that issues raised in the FEMA assea' ament must km,* addressed" before restart is permitted.
The WRC has i
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f never articulated what it means by "addressed."
The NRC*a I
position does not go far enough to assure protection of public health and safety.
In our view, adequate piene must be in place before Pilgrim Station la ellowed to restert.
In particular, the FEMA Self-Initiated Review made the finding that off-site emergency plans are not adequate to provide reasonable samurance that the public can be protected in the event of an accident et Pilgrim Station.
The SALP report, which grades utility performance in several areas, gave Boston Edison the lowest possible grades for critical safety functions.
The Special Legislative Joint Commission report made several recommendations which Commisalon membora f eel must be fulfilled before the plant is authorized to resume operation.
Since December 16, 1986, action has been taken on several fronts by state government to respond to the findings of my report.1 The Massachusetts Civil Defense Agency and Office of Emergency Preparedness (MCDA/OEP) has initiated a comprehensive three phase process to completely revise emergency plena for the communities surrounding Pilgrim Station.
The state legislature has established and provided initial funding for a Nuclear Safety Emergency Preparedness Progree within MCDA/OEP, which is responsible for off-site emergency preparedness for all three licensed nuclear power i
plants within and ad]acent to Massachusetts.2 On October 6, 1987, the Governor submitted a supplementary budget request of 8700,000 for the new program (House Bill 6086, see appendix one).
prompt action on this request is important.
An important aspect of the process to improve safety at Pilgrim is that state officials meet regularly with loaal l
officials, interested citizens, and representatives of Boston Edison to discuss problems and issues related to safety at Pilgrim.
MCDA/OEP and Executive Office of Public Safety 131nce our September,1946 decialon that adequate energency planning for Seabrook la not possible, it la the policy of the Commonwealth that there should not be participation by Messachusetta in attaapts to draf t plans for that unlicensed plant.
22n addition to P11 grin Station, the Yankee Nuclear Power Station in Rowe, Messachusetta, and the Vermont Yankee Nuclear Power Station in Vernon, Vermont, have energency planning zones within Massachusetta.,
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i of ficials meet regularly with senior manegement representatives i
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of both Boston Edison and the Yankee Atomic Electric Company to discuss nuclear safety issues.
The Executive Office of Public Safety and MCDA/OEP also participate in and monitor meetings of federal regulatory authorities.
The Boston Edison Company has taken several actions in p a r *. as S response to ay report.
The company has offered support to local governmenta under section 15 of chapter 639 of the acts of 1950, to easiat in enhancing local response to an accident at Pilgrim and to renovate local emergency operations contera.
As of this writing, four of the seven EP2 and host communities have accepted the Boston Edison support and the remaining three communities have the offer under conalderation.
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Boston Edison has inaued studies and surveys, including a new Evacuation Time Estimate, a survey of shelter in beach areas, and a survey of special needs populations in the EP2.
I Under supervision of the NRC, Boston Edison has also restructured the management of Pilgrim Station and initiated a reactor "Safety Enhancement Program."
Boston Edison haa installed a new radio system to assure prompt notification of off-aite authorities in the event of an accident at P11 grin Station.
In regard to off-site emergency planning, Boston Edison la supporting the efforts of local officials to develop improved plans and procedures by making resources, including professional emergency plannera, available to each of the seven i
EP2 and host communities under section 15 of chapter 639 of the acts of 1950.
Under the same provision of the Massachusetta General Laws, Boston Edison is also providing each community with material resources to support emergency response and is making physical improvements to each local emergency operations center.
This offer to each community includes funding for a full-time civil defense director for the operating life of pilgrim Station.
Four of the seven EPZ and host communities have signed agreements with Boston Edison to accept this easistance.
The Nuclear Regulatory Commission and the Federal Emergency Management Agency are continuing to exercise their regulatory authority over Pilgria Station.
FEMA is responsible for certifying to the NRC that off-site emergency plans and response are adequate.
In a report dated August 6, 1987, FEMA stated that "ttlhe results of our self-initiated review indicate that the Massachusetta Plan is inadequate to protect the health and safety of the public in the event of en accident at the P11gria Nuclear power Station..."3 1
h, 3The fulA Self-Initiated Raylev is discus 6ed in greater detail in section IV.,
The NRC closely monitoring all developments concerning f-emergency planning, the safe operation of the reactor, and
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on-site safety and management.
For instance, the NRC has three resident inspectors assigned to monitor operations at Pilgrim Station rather than the one inspector assigned to most other nuclear plants.
However, on one recent weekend when there were eight problem events at P11gris Station, only two NRC realdent inspectors were assigned to the facility and no inspections were made during the period the events occured.
Since that time I have requested that the NRC agrae to provide, at a minimum, daily random monitoring of operations at Pilgris Station.
The NRC is iscuing a status report on the facility every two weeks, and this practice should certainly continue.
II.
STATE RESPONSE TO THE DECEMBER, 1986 REPORT ON SAFETY AT p]t, GRIM STATION A. Revisions to Off-Site Eneroenev Plana One of the most critical findings of my report on safety at Pilgrim was that state and local plans for response to an accident at Pilgris Station were not adequate to protect the public.
The Massachusetts Civil Defense Agency and Office of Emergency Preparedness, which is responsible for off-site nuclear power plant emergency planning under st. 1979, c.796, has responded by establishing a three phase program designed to C'
develop the best possible energency plans for all EP2 and host communities.4 They will be assisted in this effort by the new Nuclear Safety Emergency Preparedness Program discussed in section II.B.
Since energency response is first and foremost a rispensibility of local government, MCDA/OEP has sought to establish a system whereby local authorities take the principal role in plan revision with advice and assistance from state i
officials.
Further, since state and local resources available for this purpose remain strictly limited, support for this ef fort has been received f rom Boston Edison as discussed above.
Federal regulatory guidance suggests that nuclear utilities should support the costs of of f-site emergency preparedness as a responsibility of operating commercial 4ihe five consenttles comprising the Pilgrin EP2 are Cerver, Duxbury, Xingston, Norshfield, and Plymouth. Presently there are two host communities, Taunton and Bridgeweter. It should be noted that sistler progress beve been initteted for the cosaunities within and serving the Rowe and Vernon IPZe.
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nuclear reactors.5 The Massachusetts General Lawa h
establish authority for local governments to accept assistance from private entities for the purpose of emergency preparedness.6 Under these provisions, Boston Edison has agreed to support the ef forts of local governments in the MCDA/OEP directed process for revising radiological emergency response plana.
The new Nuclear Safety Emergency Preparedness Program established within MCDA/OEP this year in response to en initiative by the Governor la supported entirely ty state funds which are recovered from the nuclear operators through an assessment by the Department of Public Utilities.
The first phase of the planning procean was to make all obvious corrections to the pl.na.
Phase II is to undertake the mayor planning necessary to address the findings in our December, 1986 report and other reviews of the plans, and to resolve all issues raised by each ommunity in the phase I process.
Phase III will be to trein all personnel with an emergency responsibility and to hold a graded exercise of al'1 plans and facilities.
However, at the conclusion of the three we may determine that no phase process or at any time, emergency plan for the Pilgrim site la or can be adequate to protect the public health and safety.
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During phase one of the three phase planning process, staf f of MCDA/CEP worked with each of the seven communities to completely review existing plans and identify all necessary changes.
To facilitate this process, MCDA/O'lP auggested that each community establish a planning committae composed at least of the directors of all critical local departmenta.
Some towns also chose to include citizen representativas on their committees.
These planning committees have reviewed all work in progress.
Each Frioey since March, 1997, MCDA/OEP has held a staff meeting at Area II headquarters in Bridgewate >
The civil defense directors and other representatives of all seven cortunities as well as representatives of FEMA have been invited to these meetings to discusa problems and 1 saves enectatered in the revision proceae.
Representatives of the losYon Edison Company have also attended these meetings.
Phase one corrections were completed by the third week in August and phase 11 was k egun immediately.
Staff of MCDA/OEP continues to work closely with each community, and the Friday staff meetinga S f9 REG 0654, et page 25, peregraph G.
i 65ection 15 of chapter 639 of the acts of 1950 5-
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are attended regularly by the civil defense directors of most
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of the EPZ and host communities.
An essential component of the phase II process is that local plans will be reforasted so that they are organized according to MUREG-0654 planning critaria.
This will enable more efficient checks on progresa and eenior determination of compliance with federal regulatory planning requirements.
The many laaues raised in my ear 21er report and other reviews of the plana must be resolved before the phase II process can be coepicted.
Section VI of this report contains an ites-by-ites discussion of progresa en these setters.
C.3rtain aspects of the third phase of the process are presently under way.
The training officer of MCDA/OEp in cooperation with a representative of the state Department of Education hea beguh to develop a revised training curriculum for all seergancy response personnel.
MCDA/OEP and Boston Edison have already begun to offer certain essentiel training courses to local of ficials.
For instance, training is being given for the newly instelled energency notification radio ayatan (see section III of this report) and for operation of public alert airen ayatoms.
Whether or not Pilgria Station restarts, it will at least in the short run remain a high-level weste storage area, so local officials must know how to operate these ayatens because there is always a potential need for
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of f-site response to en accident et the facility, whether or not it la on line.
The remainder of phase III training will be offered to state and local personnel as the plans are further developed and as the curricula are better defined.
Boston Edison la assisting with developmant of technical training modules for all energency response disciplines.
If we determine that adequate plans have been developed through the 90).e II process and that all emergency personnel have received or will receive required training, then the possibility of holding a full-scale eastgency exercise will be conaldered.
While MCDA/CEp and other state and local agencies are pledged to complete the three phase process as quickly as possible given e'
.d staff and resources -- our target date is to produce a : +;w t rv
,lon of the plan by the end of the calender year -- is 56c a napnasia that there la no absolute deadline for this woi ?
Whatever time la required to develop the best possible plena will be apent on this process, and the only sessure of satisfactory plans will be that of public safety.
- 2. Establishment of the Muelear Safety Esereency Prepardenegg Proeras
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In his Fiscal Year 1948 budget, Governor Dukaki's proposed development of a state program to be responalble for _ _ _ _.
oil plonning, trcining, and oxorcicco in cupport of coorgoney propordnoco for en cecidont at ony of tho throo nucloor powor plants licensed to operate within or adjacent to Massachusetts.
The Fiscal Year 1988 budget enacted by the legislature and
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signed by the Governor creates such a program within the Messachusetta Civil Defense Agency and Office of Emergency Preparedness, allocating 8175,000 for its first year of operations.
All funda expanded for this purpose will be reimbursed to the Commonwealth through an assessment of nuclear utilities by the state Department of Public Utiitties.
The FY *e8 budget authorized eleven positions for the new division.
However, insufficient funds were appropriated to fill all of these jobs.
The fi st five of these positions have been filled.
The Governor hea submitted to the legislature a request for an additional 9700,000 (HB 6086, see appendix one) so that all remaining positions created for the new program can be filled as early as January, 3988.
Establishment of this new program is an important step towards assuring that the best possible plans can be developed, tested, and if found to be adequate, maintained for response to an accident at a nuclear power plant and for allocating ths planning costa to those reponsible for tha hazard.
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{ '4 C. Exosnoten of the Emercenev Plannino 2one Federal regulatory guidance contained in NUREG-0654 auggests that the plume exposure emergency plann6ng zone be ten ailes, more or less, with adjustments made for polit: el boundaries and other geographic considerations.
TN )fmits of the EPZ as of December, 1986, had (.ctually been established in 1979, and included all of the towns of Duxbury, Kingston, and Plymouth, and only those portions of Marshfield and Carver lying within ten approximata miles of Pilgrim Station.
After consultetton with of ficials of Marshfield and Carvar, U.e s e towns in their entirety.have been designated as part of the EP2, sea ePPendix two.
This was done to be sure that in the event of an accident at Pilgrim Station, state offic'isla can make and implement protective action recommendations on a consistent "whole town" basis, thus reducing potential confusion regarding those actions.
This is the same prntactive e
2 action polic,y which is used for the Yankee Rowe and Ver.nont Yankee Messachusetts EP2a.
Small portions of Bourne, Plympton, and Wareham 11e within ten miles of Pilgrim, and officials of each of these communities have indicated their intorest in being designated part of the EPZ.
Representatives of MCDA/OEP here met with each town to assure them of our support for expanded planning, and have discussed with them the responsib,111 ties implied by this designation,
State officiale must still complete consultation with FEM % and the NRC regarding this expansion of the EP2 before final designation la meide.7 C
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7The posse Weys and Meens Consittee recently geva approval to seetion one of H.B.
5343 whlen wuld, esong other things, establish a 50 alle ET2 in Massachusetta.
We suppert this initiative but vould require additional resources to isp,\\esent l' _ _ _ _ _ _ _ _ _ _ _ _ __
It to our fooling that full Ottontien cuct b3 fccuccd
. on ccouring thot cdequoto plcuo cro devolcped fer c11 croco within ten ailes of Pilgrim Stetton before undertaking new
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planning for arena in the expanded EP2.
Therefore, the designation o,f Carver and Marshfield in their entirety, and the potentiei designation of all or portions of Bourne, Plympton, and Warehen, should be considered the beginning of the procase and not the end.
State officials must still consult with federal and local authorities to determine what level of planning la appropriate and will be required for all areas added to the plume exposure EP2.
It also should be noted that we remain fully committed to the goal of expanded planning that we discussed in our December, 1986 ragort.
Thus we support House Bill 5343 which would in part define an expanded planning zone to fif ty miles.
It should be noted that the resources associated with HB S343 are significant and will act be addressed by passage of our aupplementaay appropriation request.
4 D. Of f-Site Mon i to.* i ne The state Department of Public Health ta continuing with its program for of f-alte monitoring of s ediation in the vicinity of Pilgrim Station.
In addition, the Department of Public Health has agreed to implement a ayaten of obtaining weekly reports of radiation levels within the houndaries of r tigrin Station to bett er determine if there are low level
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radioactive r61 eases from the power facility.
The atste of Illinois has installed a complex system to I
continuously monitor the engineering parameters and radiocctive l
releases of nuclear power planta.
The Department of Public Health has prepared a report about this ayates and estimates that it would coat approximately si million to install in the Consonwealth in P11 gram Station, see appen tx three.
j E. Reviatona to the State ent_prea II Plans In addition to the seven local radiological emergency l
P ana, the response plans for the State and for re 9Pv. 8*
MCDA/0EP Area II were elao found by our report to be deficient.
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The staff of MCDA/OEP in cooperation with representatives of other state agencies and the nuclear operators la working to t
I upgrade these documents.
However, because the State and Area II plans address the coordination ant aupport of of activities among the IP2 and o Tet communities, theac revia!ons cannot be 1
completed before c. ?latons to local plans are titlehed.
A taak i
f orce ',ader th ) cuthority of the state Director of Civil l
Defe.tse meets regularly to review work in progress.
Under H.R.
sfsub, twmetly approved by the Hcuse Waya and Means Committee, f unda em:1d be made available to the Department of Public b
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Hoolth to further otudy the scootb111ty of cn off-cito ponitoring cyotes.
The State Radiological Emergency Response Plan must
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discuna c<ctions to be taken in response to accidents at Yankee Rowe and Vermont Yankee Nuclear Power Stations in addition to Pilgrim Station.
Work on these revisions la being coordinated with the Yankes Atomic Electric Company as well as with the i
Boston Edison Company. Reprcimentatives of the utilities most regularly with the task force ce state personnel to review work in progresa.
F. Dieusalone with the Gover nor's Advlaory Council on Egdiation Protection In response to laausa raised in my report on safety at l
Pilsria Station, we have discussed with the Governor's Advisory Council on Radiation Protection development of a state multi-hazard materials incident response team and enhencing the i
il state's ability to monitor the safe operation of nuclear power plants.
The Incident Response Team (JRT) would be composed of professionals from state agencies, private corporations, and academic institutions who have particular expertise which the state can use in evaluating response to an accident at Pilgrim, Rowe, or Vernon Stations, or the accidental release of another hazardous material.
Members of the IRT would report to the state energency operations center to advise the state Director of Civil Defense, the Commissioner of the Department of Public Health, e..J other people in positions of authority on the possible consequences of the accident and the appropriate mitigating measures.
In regards to en IRT for nuclear matters, members of the Governor's Advisory Council can form the core j
group for auch a team.
The state does not at present employ nuclear engineers or other personnel who can represent the state in nuclear facility alte inspections and safety meetings.
The discussions at these inspections and sessions involve highly technical 1
matters which could possibly af fect public safety.
The 1
Governor's Advisory Council has 1 a asked to advise the state regarding NRC alte safety inspections and discussions through 3
l use of appropriate atete personnel or through expert consultant I
services.
Arrangements for state participation in NRC safsty activities are also discussed in section II.H.,
following.
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G. State Partielostion in WRC Safety Insosetiona and Meetines i
j Vermont, New Jersey, and other states around the nat. ion have entered into f ormal agreements with tr.s Nuclear Regulatory i
Conniasion whereby they are permitted to attend and, to a i
l limited degree, participate in safety inspections and meetings i
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I jor nuclear power plants, see appendix four.
The Consonwealth is conaldering making such arrangements.
Under en appropriate
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agreement, a representative of the state would be permitted to i
attend the on-site inspections and subsequent disc 40elona and have the right to file diskenting or concurring findings.
r Designated at.ata representatives would be trained and certified by the different utilities for unescorted acessa to each nuclear power station.
j Since these inspections and meetings involve detailed discussions of the most technical aspects of nuclear power r
generation, the individuals who represent the state would have l
to be qualified nuclear engineers.
The state does not l
I presently *8P oy anyone with the skills and experience necessary to participate in these matters in a meaningful wuy.
We are raviewing agreements between other states and the NRC and are engaged in discussions with the NRC.
We expect to conclude an appropriate arrangement fer participation in on-atte safety matters.
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III.
BOSTON EDISON RESPONSE TO RECOMMENDATIONS OF THE BARRY l
REPOR1 Our report made several recommendations for action by the Boston Edison Company which directly relate to of f-site energency response.
These recommendations concerned improved j
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equipment for off-site energency notification, production of a l'
alert and notification ayates, addressing the ability to new evacuation time estimate (ETE), certification of the miran pr(tect beech area popula tions, addressing shelter as a protective action, production and distribution of leprovnd public information asterial, improving procedures for l
protett;on of special needs and. school aged populations, and I
j aubnission to the state and MRC of a probabilistic risk asseannent which considers accident acenerlos initiated by both intarnal and external events and which specifically based on Pilgrim'a deatgr features to assena the containment conditional J,
f ailure probability.
In response to hhe documented need for an improved systen to promptly notify off-site authorities of an occident et pilgria Station, Boston Edison purchamad and has installed a radio systea called BECOW3 through which state and local authorities can be given immediate notification of events at 1
the power facility.
This ayaten la now in the final stages of I
testing and of receiving licenses for operating frequencies.
I The Federal Communications Commisalon is in the process of final review of the frequency license, and approval la expected l
before the end of December.
Material has been developed by the i
utility to train state and local officials in the use of j
BECONS.
DECONS unita havo been installed in all town warning (V
pointa, at ECDA/OEP Area II Headquarters, Bridgewater, and at Massachusetta State Police Troop D, Middleboro.
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f Boston Edison commissioned the New Ycrk firm of XLD
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Associates to undertake a new Evacuation Time Estimate and traffic management plan for the Pilgrim area.
The draft document was delivered tc state officials on August. 20, 1987 and revised pages based on preliminary comments were delivered to MCDA/OEP on September 8.
Staff of MCDA/OEP is coordinating review of the ETE by a task force of other state'egencies and by officiala of all concerned local Jurisdictions.
While this review is not complete, serious questions regarding the ETE methodology and resulta have surfaced.
These Assues are covered in greater detail in section VI.A. of this report.
Throughout its history of operation, the public alert airen system which was installed throughout the EPZ by Boston Edison has been plagued by siren failures and the spontaneous sounding of alarms, especially during thunder storms.
Boston Edison has replaced malfunctioning units and done other repair and naintenance to the airen ayaten.
FEMA has reviewed all proposed improvements to this siren system and has monitored I
(ne results of monthly system testa.
The monthly airen ayatem tests which have been conducted by loston Edison since 1986 indicate that ayaten reliability exceeda FEMA standards.8 FEMA conducted a full test of the airen system in the Autumn of 1986 which included a telephone survey to determine the percentage of the population which heard the alarms.
FEMA has reported that be'.ter than 854 of the population heard the I
airena.
A three-minute-cycle airen test was held for Pilgrim on October 15, 1987, and we have gathered information about the results.
Protection of beach populations during the Summer months is a principal public safety concern raised in our Report.
Boston Edison has proposed to the Nuclear Regulatory Commission in a letter dated June 4, 1987, that the results of the new ETE combined with the results of survey of shelter available at beach areas demonstrates that this vulnerable population can be protected.
Staff of MCDA/OEP have reviewed the shelter survey and find it deficient in several espects, sea appendix five.
Also, our review of the row ETE, while incomplete, leavea several questions not anew. red to our satisfaction.
Therefore, we cannot agree that Boston Edimon Compave has resolved the taaue of protection for beach I
popu la t ior.4..
1 8 CLA/0EP receives and reviews sonthly airen systes test reports which H
Boston Edison submita 'to TEMA. These are not sound tests, but testa of the systes's electrical circulta.
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Our December, 1986 report req uested that Boeton' Edison
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"comataston a comprehensive shelter survey."
The survey which was delivered to and reviewed by the (taff of MCDA/0EP was made only for en area between one half and one mile of the coast.
l Since the survey did not cover the remainder of the IPZ, and for other reasons discussed in saction VI.B. of this report, this recommendation has not been fulfilled.
6 The Boston Edison Company produces an annual public information brochure in cooperation with MCDA/OEP for distribution throughout the EP2.
MCDA/OEP staff were workin; f
with Boston Edison and the utility's consultanta with a goal of l
leauing a new EPI brochure by September, 1947.
- Mowever, i
because certain critical planning declaions had not been made
-- principally whether or not a third reception conter is required to replace Hanover Mall -
preparation of the brochure has not been completed.
l Boston Edison informed MCDA/OEP in August that it was conducting a study to determine the adequacy of two reception centers instead of three, and that the results would be available in early September.
We indicated that we would evaluate auch a report within fourteen days.
To date, we have not received the Boston Edison analyaia although we have requested it on savaral occasions.
Therefore, we are unable to 4
i complete Preparation and distribution of an EPI brochure.
In the alternative, an interim Public Information Brochure will be
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distributed throughout the EP2.
This interim brochure will explain the aspects of eastgency response which are not fully i
addressed at precint and which will be completely resolved I
biore a final EPI brochure is distributed in 1988.
Our
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position la clear that in no case should Pilgrim be permitted to teatert until a final and complete EPI brochure has been 1
approved by MCDA/CEP and distributed.
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IV.
FEM A INTERIM FINDINQ),
l On September 29, 1982, FEMA and the Regional Advisory j
Committee (RAC) inaued its interim findings on the adequacy of Pilgia EPE and host community plana.
The 1942 review indicated i
that the plana were adequate to protect the public.
On August j
6,1947, the Fedral Energency Management Agency transmitted to i
us the resulta of their Self-Init1'ated review of Pilgrim eres emergency plane, finding that, "tblocause of the changed l
circumstances discussed in the FEMA review, our finding of I
adequacy contained in the Interia Finding of September 29, 1982 l'
no longer applies and has been superseded by the enclosed finding." This information was also transmitted to the NRC.'
I The FEM A Self-Initiated Review found the emergency l
plans to be deficient in fivi specific areas; 1) evacuation of
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achools, 2) reception center, 3) beach population, 4) apecial
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nee $a pg,pelations, and 5) transportation dependent pcpulations.
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' Each of theco itomo wco iden*.ificd in cur Decocbcr,,1986 report as e deficiency.
The steps being taken by the Commonwealth and
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by Boston Edison to address these deficiencies are discussed throughout this report.
At least one finding of the Self-Initaeted Review is j
based upon a sialapression by FEM A.
In evaluating resources available for transport dependent people, FEMA contended that the Commonwealth would not use Mb7A buses if they are needed to easiat an evacuation in the Pilgrim EPZ.
In fact, the Commonwealth will endeavor to make these buses and all other public resources available to assist in emergency response if they are needed to supplement resources available in the more Assediate vicinity of Pilgram.
FEMA apparently aisconstrued our earlier statement to the effect that we no longer believed j
that it was appropriate to rely upon ad hoe seasures in planning for emergency action to indicate that we would not use available resources.
l The NRC has not stated as of this date if the changed FEMA Interim Finding will be used as the baala for preventing the re-start of Pilgrim station.
In a meeting between j
representatives of Boston Edison and the NRC at the NRC*a offices in Bethesda, Maryland, ors September 24, 19 8'/, the NRC
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indicated only that off-site planning tasues must be i
"addressed" before restart la allowed.
This la not an adequate l
response on the part of the NRC, and we believe that all off-site safety issues must be resolved prior to restort.
The NRC has asked Boston Edison to present an "Action plan" for addressing the deficiencies cited in the FEMA report, and Boston Edison submitted the first draft of the Action Plan to the NRC on September 17, 1947.
We reviewed the utility's Action Plan which was forwarded to the NRC and support Soston Edison's stated goal of completing plan revisions as soon ma j
possible.
We think that it in useful to establish goals and i
objectives to guide planning.
However, as this progress report I
demonstrates, the planning process has a long way to go.9 Stor esemple, the NRC hea wet to receive froa testee Ediasa a final copy of the utility's proposed restert plan. A second revision of a restart plan wee subaltted to the NRC by loston Edison on October 26, 1947, sad was transeitted to we on Bovember 12. We are awaiting recenpt of the final veraton of the seterial and will review it thoroughly as soon as it la available to us.
A l
third terty expert eyelustion of this plan to under conalderation. 1 4
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V.
STATUS OF SPECIFIC BOSTOW EDISON ACTION ITEMS
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A. Manaaesent Iasuea Our December, 1986 report to the Governor was highly critical of Boston Edison *a management of Pilgrim Station.
This finding has been echoed in reports by the NRC, especially in their "Systematic Assoassent of Licensee Performance" (SALP) reports, which thoroughly review a variety of characteristics indicating management performance.
The latest SALP report for P11gris Station was issued by the NRC on April 4, 1987, and evaluated utility performance for the period November 1, 1985 through January 31, 1987.
The SALP report analyses 12 performance criteria, assigning a grade of 1, 2, or 3 for each criterion.
Category 1 is the best grade and indicates that reduced MRC attention may be appropriate.
Category 2 indicat6a that NRC attention should be maintained at normal levels.
Category 3, the lowest grade, andicates that both NRC and licensee attention should be increased.
The April 4, 1987 SALP report indicated that
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management of Pilgrim Station was not good and had, in fact, deteriorated in certain respects since the previous SALP covering the period October 1, 1984 to October 31, 1985.
In the 1987 report, Boston Edison received two Category 1 grados, five Category 2 grades, and five Category 3 grades.
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For three criteria in the 1987 SALP, Boston Edison received lower grades than for the previous reporting period, for two j
criteria the grade increased, and for three criteria the grade I
remained unchanged.
The four remaining criteria had not been l
separately evaluated previously.
These results are cause for concern under any circumstancoa but particularly in light of the fact that the plant was shut down during most of the
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inspection period.
Since December, 1986, Boston Edison has reorganized its P11 grin management and has hired a number of individuala to l
fill key positions.
Most notably, Boston Edison has hired a new Sealor Vice President, Nuclear, Mr. Ralph hard, who reports l
directly to the company's chief executive efficer.
Mr. Bird was recruited from outside of the Boston Edison Company.
The new Seafor Vice President also serves as the Vice President for
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Wuclear Operettuna and personally supervises all activities pertaining to Pilgria Station.
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Wader Mr. Bird *a direction, other positions relating to the safe operation of the reactor and to energency planning j
have recently been filled by professionalb recruited from I
outside teaton Edison, and a few loston Edison employeen have l
been promoted to fill vacancies.
The following other key management positions have been filled by recruits from outside
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the company; 1 >
1 k
f
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-- Exccutivo Acciatent to the Conier Vico Prooident,
- Nuclear,
-- Director of Planning and Restart, I-
-- Emergency Planning Assistant to the Senior Vice President, Nuclear,
-- Operations Section Manager,
-- Nuclear Security Group Leader,
-- Fire Protection Group Leader, and
-- Radiological Section Manager.
In addition, the Director of Outage Management was promoted to Plant Manager in early 1987.
While there are indications that the new management organization and personnel may be taking more effective control of Pilgrin Stetion, recent events suggest that Pilgrim Station continues to have serious management problems.
The NRC is considering a fine against Boston Edison for failure to I
implement plant security procedures, and there have been reports of critics 1 plant personnel working excessive over-time.
We also have concern over the way a decision was implemented to disengage one of two emergency generatora during a period when Pilgrim station lost access to off-site power on November 12, 1987.
j 2n addition to these issues, the Senior Vice President of Boston Edison ordered all work on the Pilgrim reactor and ayatena halted af ter eight individual work related problems occured over the weekend of November 7 and 8, some of which i
were stallar to problems which have recurred at Pilgrin Station 1
over several years.
Four of these problems resulted in the on-atte release of radiation and slight worker contamination.
j Two of the problems were related to security.
The security violations are of particular concern because in the 1987 SALP report "Security end Safeguards" had deteriorated from a Category 2 to a Category 3.
Officials of Boston Edison have met with the NRC to explain their remedial actions concerning plant security.
Je have seen no official report on the question of over-time worked by personnel detailed to critical safety aspects of Pilgrim Station.
Boston Edison public information officers have indicated that five percent of the Pilgrim work force is authorized to work more than sixty hours per week.
Since there era presently more than four thousand people employed at Pilgrim Station, a significant number may have been working long and perhaps excesolve hours.
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In view of Boston Edison's long history of management I
f ailure at Pilgrim Stat on, we feel that sustained management of the nuclear f acility at a high 1r ust be demonstrated j
before the plant should be allcwed tw 4 art.
Events of the past several months raise more questions than they answer and 1
aske it more imperative that, in addition to other asfety (3
requisites we have objective evidence of sustained performance
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V at the highest level of quality, including but not 11stted to i
' top 9 redes in the next SALP report, before restart, even though the next SALP roport will not reflect evaluation of actual on-line operation of the reactor.
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3.
Rosetor Safety.
Our report to the Governor examined aspects of the saf.
operation of Pilgrim Station, particularly the capacity of the General Electric Mark I containment structure to prevent the release of radiation in a severe accident.
Since December, 1986, the nuclear industry has continued its inconclusive debate on the integrity of the Mark I containment structure.
We do not exPeet that this iacue will be settled soon by the NRC.
The N"clear Regulatory Commission la developing a "Draft Gener)
Letter" on raector safety and the Mark I containment
- t. ructure which will identify plant-specific ana)yses necc.sery to implement the NRC's "Severe Accident policy Statement."
However, no letter has been released and there is presently no schedule for its put11 cation and, therefore, no way to assess the adequacy of or estimate the time it will take to implement the NRC's ultimate reconsendations.
The NRC has been considering this matter for more than a year and has discussed structural improvementa and other operating concepts for Mark I unite with the Boiling Water Reacter Owners Group.
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Absent specific federal requirements and guidance, Boston Edison la implementing a "Safety Enhancement Program" (SEP) to improve reactor saf ety for Pilgrim Station and includes both energency operations procedure improvmenta and equipment modifications.
The utility has indicated that they
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have spent aPproximately s30 million on this program.
One key element of the equipment
.odifications la installation of a direct torus vent.
Boston Edison has indicated that they are prepared to complete instalation of the torua vent as soon as they are so authorized by the NRC.
According to Staton Edisor*, the torus vent, if instelled, could be used to relieve pressure in the reactor containment during a severe accident.
The venting system would "acrub" containment effluent of solid and liquid matter and release radioective gasses to the environment.
The release of I
these gessoa, by relieving the containment pressure, would prevent a rupture of the containment structure and the subsequent release of more damiging solid and liquid radioactive materials.
In theo:ry, a gaseous radioactive plume would dissipate quickly and present less threat to public i
healus then a liquid and solid release which could deposit i
long-lived radioactive elements on inhabited ground and
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atructures.
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There are, however, conflicting viewo en whether o direct torus vent would provide ef f ective containment pressure
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relief in the event of a rapidly developing accident.
Therefore, it must be demonstrated that the direct torus vent would algnificantly increase public safuty under certain accident scenarios.
C. Poliev Inauen Renardine the Torua Vent The torus vent introduces a vital policy question.
r Under what and whose authority can one plan in ar$vance to make use of the vent?
Activating the vent would result in the release of a gaseous radioactive plume.
Thus, if the equipment is installed and a severe accident does occur, who say authorite torus venting and the subsequent radioactive release?
The utility la responsible for the safe operation of the reactor, for controling an accident, and for prevent.ng insofar possible the unauthorized environmental release of l
as radiation.
The NRC regulates utility execution of these r e s ponsib ili t ie s.
However, state and local government share exclusive responsibility for the protection of public health 4
and asfety ior all arass beyond the boundaries of the power station.
Boston Edison has not installed the torus vent, pending direction from the NRC.
It la our understanding of the NRC l
licensing scheme, that it would be necessary to amend Pilgrim's
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operating license befoe a torus vent could be installed.
Such an amendment would involve "significant hazards conalderations" and, as such, would require that a hearing be held prior to the amendments authorization.
If the NRC authorizes installation, it is, not clear what role if any -- the Commonwealth can or should play in that declaion.
If the vent la installed, uith er without concurrence from state authorities, a question arises that the state will have to resolve as to what authority la available to state of ficials to advise for or against i
Santing during a severe reactor accident.
I It la presumed that genes can be held in the containment ayaten for a period of time before venting.
Dsring i
this period, state of ficials must decide the best protective i
action for the public, sither to shelter or evacuate, based l
upon accident esosaments made by the state Department of Public Maalth an1 the utility.
The length of time that geoces can be I
held and the expected duration and composition of the release, when c< spared to the expected evacuation time, the shelter l
available to the population at risk, and the time it la expected for the ef fected population to take to shelter, will 1
i deteralma the most appropriate action.
j Thus, state officiala must at least coordinate implementation of the beat protective action with the containment venting.
Safore the NRC authorizes Boston Edison (d
to install the torus venting system, there should be art j :
eW1uation of theso policy e attero Ond whot if cny rolo ototo agencies and officials can or will take in the event of a severe accident at Pilgrim Station.
This proposal raises such significant safety laaues that a public hearing should be required so that the Commonwealth would have an opportunity to express its opinions on the matter.
During the September 24, 1987 aceting between Boston Edison and the NRC, Dr. Murley of the NRC indicated that he still had reservations about authorizing torus vent instalation.
Dr. Murley stated his reservations about l
authorizing installation of the torus vent in 3 letter to Roston Edison dated August 21, 1987.
We are hot at present aware of any loston Edison response to the NRC letter.
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D. Need for a Pilaria-Seeelfie Probabalistic Risk Aaseassent It la taportant to note that until a plant-specific l'
"Probabelastic Risk Assessment" (PRA) is available for Pilgria Station, it la tapossible to determine the relative level of risk of a severe accident at P11 grin Station and the dominent sequence of events that would lead to a severe accident.
A PRA, as we discussed in our December, 1986 Report, la a comprehensive analysis of k tant mechanical and operations ayatens conducted to ascert n the sequences of events that could lead to a severe accio
.it.
Given that every nuclear power plant la unique, both in mechanical and operating systems, a plant specific PRA la necessary to determine the specific scenarios that could lead to severe accidents, as well as to isolate the specific vulnerabilities of each plant.
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Although the NRC recognized that plant-specific dcaign and equipment characteristics are important factors in a plant's vulnerability to a severe accident, it has not required
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e Pilgria-specific PRA, but has relied on the analysis of the i
MUREG-1150 program.
The NUREG-1150 p7ogran performa PRAs for representative reactor and containment types.
In the case of the General Electric Mark I type plant, the NRC rolles upon a FRA for the Peach Bottom plant in Pennsylvania.
The use of representative PRAs la open to critician and plant specific PRAs are being developed by some utilities.
Although I an informed that the Pilgria PRA la undaar devolepnent, Docton Edison has not to dete made it available to the state, taking the position that it la not yet final.
In light of the importance of the PRA in determining the raaka posed by Pilgrim Stetion, I recommead that the plant not be l
allowed to restart until we have been provided with a Pilgria-specific PRA and have had the opportunity to verif y and anaese its resulta.
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V 1*.
STATUS OF SPECIFIC OFF-S?TE EMERGENCY PLANNING MATTERS Our report focused attention on several inadequacies of the plena for response to en accident at Pilgrim Station.
The most significant action taken to address inadequacies in the plans was the implementation by the Massachusette Civil Defense Agency and Office of Emergency Preparedness of the three phase procesa discussed in section II.A., above.
This work has been supported by Boston Edison through easistance given to each EP2 and host community under section 15, chapter 639 of the acts of 1950.
Substantial progress has been maos through the three phase process towards completely revising all radiological energency response plana.
However, the process la far from complete and our position remains that at present the energency and we reserve the right i
plans for Pilgrim are not adequate to determine if the plans ultimately are adequate to protect the public.
Draft revisions to the loca) plena exist in part for each of the five EP2 communities. In some cases, the draft revisions are up to 85% complete as of this writing.
When j
officials of all communities and staff of MCDA/OEP indicate that initial drafts are complete, the drafts will be submitted i
i to the Fedral Emergency Management Agency for informal technical review.
FEMA *a asseaament will provide en independent professional asses sment of plan adequacy.
- However, the Commonwealth has the responsibility to make our own final evaluation of the plana.
Following la en.iten by item discussion of cartain 4
of f-aite energency planning lasues which were raised in the Barry report or which have surf aced since December, 1986.
A.
Evaeustion Time Estimete_ and Traffic Maneaesent Plan i
In our Report to the Governor, we recommended t'.st Roston Edison. "proceed with all dispatch to complete the preparation of a new Evacuation Time Estimate study."
Roston I
Edison commissioned the New York firm of XLD Associates to i
prepare a naw Evacuation Time Estimate (ETE) and Traffic j
Mensgenent Plan for the Pilgrim area.
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An Evacuation Time Eatinate (ETE) la essential as a i
planning tool and on a critical resource in evaluating
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protective actions should there be en actual emergency at a nucleer power plant. The ETE available when we made our 4
l evaluation in December, 1946 was produced in 1979, based upon 1970 census data, and was inadequate.
On August 4,
- 1947, i
Soston Edison transmitted to us a new ETE and traffic management plan, and revised pages were received on September 3.
Although we have not yet completed review of the new ETE s
and have many reservations about it as discussed below, it is a significant improvement over previous material. !
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Since the revised pagoo woro roco1ved, o took force of state emP oyees has met regularly to review the ETE and traffic l
p management plan.
The charge to this task force has been to A
evaluate whether the traffic management plan upon which the estimates of evacuation times are based are reasonabin and fossible, and to determine what resources are needed for its succesful implementation.
If the traffic management recommendations cannot be laplemented succesfully, the estimated evacuation "clear times" are without meaning.
The group will not fintah its review before the end of November, but certain findings are emerging.
The Commonwealth does not have adequate resources to implement the traffic management plan.
Therefore, the clear times in the ETE cannot be achieved.
For instance, the Messachusetta State Police, Troop D, Middleboro will be responalble for establishing control of traf fic seeking to enter the emergency zone, as well as for directing traffic on state roads within the avecuation area.
Officera of Troop D have indicatec that they would not normally have sufficient personnel available to implement all of their actions in a timely manner.
Troop D is continuing to evaluate available personnel against personnel needs as documented in the ETE.
In addition, Troop D may not have adequate radio frequencies and hardware to manage emergency communications.
This is especially true because of the expected high voluna of emergency communications during a nuclear accident and the ram $
to coordinate the actions of state and various local police
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departments.
The Commonwealth has only one State Police mobile l
l commend post which la normely stationed at Troop A, Framingham, although at any time it may be in use anywhere in the state.
It may be necessary to have a mobile command post available immediately to ef f ectively manage traf fic access points in areas as remote as the intersection of Routes 124 and 3 in I
Braintree and the Cape Cod bridges.
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All of these findings are reflected in a memorandum
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f rom Troop D, Middleboro, see appendix aix.
The traffic management plan goes to great detail in eyelveting the trof fic control devices which will be required j
to implement en orderly and prompt evacuation.
These devices include traffic cones, traffic barricades, warning lights, and I
special evacuation route algna.
The State Department of Public l
Works la evaluating the resources it hem available against the i
requirementa documented in the ETE.
The DPW can draw upon its 1
resources state-wide, however, it is not yet clenr how long it would take to deliver all required material to the EP2.
The recommended resource requirements in the ETE 1
inclues 364 cones, 389 barricades, and 203 warning lights.
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state and local police agencies and departments of public works I
have been asked to evaluate these recommendations based upon
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their own experience.
However, it is neceasery to assure
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delivery times for thoco recourcOc bezoro cno con b3 cocured of adequate plan implementation.
The State DPW only has emergency mobilization procedures for snow removal and certain highly localized events.
These procedures may or may not in fact be adequate to meet needs during a mesa evacuation, and MDPW in reviewing them to determine if new protocola are needed and if material delivery times can be verified.
An examination of the details for traffic control 1
points indicates that very few are recommended to be staf f ed by more than one traffic guide.
However, for many of these points, the guide must fulfill several functions, including 1
directing trafile in the recommended pattern, answering questions for vehicle occupants, checking his or her personal r
dosimetry, clearing vehicles to travel against the recommended pattern if the driver can demonstrate that he or she la en emergency worker, has a need to return to pick up family, or J
has another reasonable purpose.
It la doubtful that one guide can accomplish all of these functions and, therefore, quite possible that the personnel requirements -- especially for local police officers -- of the traffic management plan are r
underestimated.
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The largest burden of controling an evacuation falla to local police departments.
MCDA/OEP has provided all local l
chiefs of police 10 with a copy of the ETE ano asked for their commenta and observations.
As of this date, we have not received comments from any local Jurisdiction.
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Besidea effective and timely implementation of the traffic management plan, the other most critical element of the ETE is the estimation of traf fic demand.
That is, the number
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of vehicles which would be on the road at any one time an evacuation la declared must be estimated, as well as the time l
l that it takes for drivers to mobilize and start their evacuation trip.
Further, the need for supplementesy l
transportation resources, including ambulences, buses, and chair vans must be established and their mobi) ration, arrival, pick-up, and total travel times must be estimated, j
l The new ETE goes into exhausting detail to document
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traffic demand estimation.
However, certain assumptiona and I
findinga remain open to question.
In particular, the estimated i
i populetion at the EP2 beaches and gonda la a critical inaue not j
yet addressed to our satisf action, and the estimated i
l 101s addition to 1P2 and host cosaunities, traf fic and access control i
reccoaandations avat be implemented by the cosavaittaa of Pembroke, Hanson.
Nattf as, Plyapton, Warahen, Bourne, Sandwich, and Braintree.
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' transportation requirements for preoplo with cpeciol.nocdo cust be examined further.
The ETE estimates that peak use of area beaches and ponda la 8,211 pote.na using 2,990 vehicles.
The evacuation times for the bear.hu are based upon surveys of the parking It does not capacitina at indi tdual beach and pond areas.
appear that these sagures include people who are at beaches and ponds but do not hava access to personal transport, such as ch13dren who were dropped off by parents or people who have walked. bicycled, or otherwise gotten to a beach but who would be picked up by a vehicle in the event of an evacuation.
The ETE seat treet in greater detail the laaus of people who will drive to the beaches and ponda to pick Jp far.ily and friends after en evacuetion has been declared.
In other words, the total beach and pond population aunt be estimetsd and an accounting must be made of the departure of the antire beech and pond population.
The ETE*a recommendations regarding transportetton for special needs populations la based upon a survey endertaken by Boston Edison in the Summer of 1957.
Representatives of the state of fice of Handicapped Aff airs and the plymouth Commisaton on Handicapped Affairs have indicated that the Loaton Edison survey was poorly conceived and does not make an acarate estimate of the EP2*a special needs populationa.11 Nonetheless, the Boston Edison survey has provided more j
information on special needs requirements than has been J
t' available previously.
However, it la clear that further work has to be done in this area before we will have an adequate i
estimate of the transportation requirements of people with i
1 special needs, l
This additional work can perhaps be done through a i
I further survey, through e statistical analysis of the general population, or some combination of these methods.
With a j
better knowledge of the requirenants for ambulances, chair t
vens, and buses for people requiring special transportetton asasistence, we will be able to determins if the. ETE has j
properly estimated the avecuation times f or this population.
i An estimation of available resources to assist people with special needs la being undertaken as a part of phase II of the
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three phase planning procean.
Until that evaluation la i
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complete, we cannot may if adequate resources are available.
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11The Sodton Edison survey any not have reached all realdesta of the LPZ i
i and wea act worded in a way to elicit a response from all people who sight need assistence in eveevating or taking shelter.
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One broad conaldorotion which to not cxcoincd by thio ETE and Traffic Management plan is the effect that will be felt l
f rom the f ailure of any one component..
That is, the clear times appear to be based on the assumption that all all traffic management recommendations will be succesfully taplemented in a timely manner.
However, there is no beats for thic assumption and the f ailure to properly man and control a "priority 1" traf fic control point can have a profound effect on tL affic patterna.
Further, a major unanticipated event, auch as an over-turned truck on a mejor route, even if cleared rapidly, might quickly cause wide-spread traffic problema.
The ETE abould investigate and recommend alternative evacuation strategies in the event that any one of the major evacuation routes, such as Route 3, were blocked.
Also, it does not appear that the ETE has given consideration to the possibility i
I of a severe Winter storm of the magnitude which can occur in l
Southeastern Massachusetts.
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We are particularly concerned about the matter of l
Winter storna because of the possibility of converging event.a.
In the very recent past, a severe atorm teaulted in pilgrim's loss of access to of f-site power.
Subsequently, pilgrim lost one of two emergency generators.
If the reactor had been on line at the tima, this aequence of eventa could have resulted in an accident requiring off-site response at the same time that there were more the ten inches of snow on the ground.
Given these possibilities, we feel that the ETE abould more e
extensively document expected evacuation times during severe j
storna.
The ETE la computed from highly complex traffic models which are beyond the understanding of all but the acet kncwledgeable prof esatonal specialista.
profesalonale employed by the Stata Department of Transportation's Centrat j
Transportet.Lon planning Staff have done e review of "3-DYNEV,
the model developed and used by the firm preparing the ETE.
CTPS is continuing to review the model and Sta results based 4
j upon intornetton supplied by consultants who examined 1-DYNEV f or the Seabrook adjudicatory process.
A letter from CTpS f
staff shows that they do have certain reservations about the J
i pilgria ETE modeling, see appendix aeven.
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At the present time we are not prepared to determine if i
the eav ETE la en adequate basis for the development of plans j
for response to en accident at pilgria Station.
Further study by state officiela is necessary and I intenJ to have the ETE I
and the model upon which it is based evaluated by an independent thard party expert is evacuation modeling.
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.--_..---._,..-.m...
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l to Shelter as a Protgsiljug Action Our report recommended that loston Edison "commission a l
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comprehensive shelter survey."
In the event of an accident at t
Pilgrim Station, there are two main actions which can be recommended to protect the public; evacuation and shelter.
In i
order to assure that the public can be adequately protected, it is necessary to establish two findings in regards to shelter; that,a) the highly vulnerable beach population can take l
adequate protective cover in the event of a rapidly escalating j
accident with an early release of radiation, and b) that each i
EPZ community can provide adequate protective shelter for the i
realdent and transient population seeking assistance.
On August 20, 1947, Boston Edison delivered to MCDA/OEP a shelter survey which was reviewed by agency staff and found to be deficient in several respects.
For example, the survey was completed only for areas lying between one half and one mile from the coast.
The survey also failed to adequately evaluate the quality of shelter available in individual structures but was, rather, an undifferentiated catalogue of I
attuctures proximate to beach areas.
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In a memorandum, see appendix five, transmitted to Boston Edison by State Director of Civil Defense, MCDA/OEP staff aske several recommendations on developing adequate i
information so that Civil Defense personnel in each EP2 l
community can develop "Shalter Utilization Plana." Until
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ahelter utilization plana have been developed, it la lapossible to say that shelter as a protective action has been addresseed.
i Shelter utilization plena are especially laportant for beach areas.
They aunt consider not just the available shelter space, but the time it will take people in remote beach areas to reach odequote shelter.
Duxbury beach is approximately seven miles long and portions of Plymouth beach is sa much as
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two siles from the nearest structure.
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Until noston Edison producen an a shelter survay which is adequate in the opinion of the llCDA/CEP staff, and until each community has had the opportun$ty to develop a shelter ut111:stion plan, this taaue remains an open and deficient 1
plannine topic.
C. Protective Actiona for Peocle with Snecial Needa 4
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Among the planning taauen discussed in my earlier report, none demand more attention than provisions for people a
with repecial needs.
This population aey include the elderly j
and the tafirm, people who are mobility impaired, visually impaired, have a hearing loss or are profoundly deaf, and
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pec,ple with.s number of other conditions which might be cause f
for e afecial service in the event of an accident at Pilgria
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Stellon.
People with apacial needs may require attention in 24-
_. - - ~
involvecent in thio offert, in June cf 1947, Bacten.Edicen undertook a survey of special needs people without th..
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knowledge, advice, or participation of any state age, icy or personnel.
Representatives of the stase Office of Handicapped Affairs and the Plymouth Commission for Handicapped Affairs have indicated that the Boston Edison survey was poorly conducted.
The results of the survey, representing the response of about 1,400 individuals, have been provided to the State Director of Civil Defense and are subsequently being turned over to designated public safety repro;entatives in each of the five Ep2 communities.
Thia information would also be useful in and available for response to other lif s threatening attuations such as a chemical spill.
It la the policy of state public safety officia10 thst every individual in the EP2 be given tha opportunity to
- dentify him or herself and his or her need.
However, it say not be necessary or even prudent to compile exhaustive lists of special needa populations.
What la most important la to have 1
en understanding of the dimenalons of the special needa j
population and to be prepared to provide the variety of services -- alert and notification, transportation, special medical care, et cetera -- to the numbers of people expected to need easister.ce.
D. Medical Services for Radiological Victima L'
While not specifically addressed in our December, 1986 report, a recent Guidance Memorandum from the Federal Emergency i
Management Agency 12 has focussed attention on the topic of d
j medical services for people who are contaminated by radiation tad physically injured, for people who have ingestad radioactive material, and individuela who are severely i
irradiated.
The *saue la receiving more serious public j
attention as a rea'J3 t of the formidable medical respones which l
the Soviet Union rounted af ter the Chernobyl accident.
It is i
incumbent on state of ficiale to demonstrate that adequate medical f acilities are available to meet the demand after a l
l aevere accident at any of the nuclear powar f acilities in New England, even though federal r$gulatory guidance does not set minimum requirements for treatment cepecity.
Boston Edison is also working to identify appropriate medical f acilities for off-site contaminated injured people in accordanea with FEMA Guidance Memorandus MS-1.
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12fina GR RS 1, "Redical Services." Washington, D.C.,
Es enbar 13, 1946.
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'three main areas of radiolcgicol ocorg0ncy reOpanco; cicrt cnd notification, evacuation, and reception and long term shelter.
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In response to this topic, MCDA/0EP organized an informal task force of representatives of several state agencies which represent special needs constituencies and representatives of local special needs agencies.
The task force has met several times to discuss the complex details of providing the required services and la presenty formulating recommendations for action by the state and utility to insure that all needs are met.
As one of the first actions under the new Nuclear Safety Energency Preparedness Program, MCDA/OEP has formed a j
formal task force to addresa emergency planning for special needs populations.
The T(ak Force on Special Needs la formulating guidelines and recommendations for state agenutes and the Boston Edison Company for undertaking a statistical j
analysis of expected special needs in the Pilgrim EPZ and the l
resources which will be needed to fulfill those needs.
The task force la also examining the need for a furth6r survey of individuela with special needs.
Based upon the estimated demand and resources needed f(r providing energency notification to, and transportatt.on and care for people with special needs, plans and procedures will be developed for each EP2 and host community plan and for the State and Area l
Radiological Energency Response P3 ana.
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In regard to alert and notification, people who are profoundly deaf will be unable to hear airena or route alert loud hailers which will notif y the public of a severe accident.
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Further, they will have dif ficulty communicating with emergency f acilities and public saf ety personnel.
The task force met 1
with repraaentatives of Boston Edisen and urged that the I
utility install teletype equipment in each town warning point i
ao that there could be immediate and effective communications I
with the deaf population throughout the EP2.
'.'he utility has agreed to make teletype equipment eve 11able to all homes and
)
facilities where there is a need.
Staff of the state i
l Consiesion for the Deaf and Hard of Hearing have agreed to advise poston Edison on the inac.allation of teletype equipment
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and training for its operation.
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Boston Edison la proceeding with these recommendations, but it la not yet known when all equipment will be installed in town warning points, when training will be provided to all shif ts of local town warning officera, or how many teletype units have been distributed throughout the EP2.
i Following my December, 1946 report, MCDA/OEP took the initiative of forming a group of state agencisa concerned with 3
services for special needs populations who met with Boston Edia,on officials on several occalatons to discusa a cooperative y
effort to better identify EP2 raaidents with special needs in j
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the event of a nuclear accident. Notwithetending our.ac,tive 1 i
Tho Hoccechucetto Doportcont of Public H001th'o, Pediation control Program is responsible for maintaining the I
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handbook of the state Nuclear Incident Advisort. Team (NIAT).
The NIAT bandbook containa e list of all hospitala throughout the state which are prepared to treat victims of severe J
1rradiation or who are contaminated and injured.
The list 1
includes the tractment capacity of each facility.
DPH is also responsible for certifying hospitala for treatment of radiation victime.
E. Eneroency Cossunleations As indicated in section III, above, Boston Edison ham responded to the recommendation of the our December, 1946 i
report that they install a new radio ayates for notification of l
off-site authorities in the event of an accident at Pilgris Station.
This ayaten, called BECON, is, as of this writing, in the final stages of testing and is awaiting a radio frequency license from the Federal Communic 1tions Commission.
Action on that license is expected before the end of December, 1987 Boston Edison has also begun compliance with another recommendation regarding emergency communications, by reviewing how the organizations providing huses which serve schools in the P11 grin EP2 contact drivera when buses are needed for early dismissal.
Boston Edison has determined that tone alert radion
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are not needed in school buses, as discussed in my December, 1986 report.
Boston Edison is, however, considering whether or not they will provide paging devices to school bus drivera.
The utility has purchased tone alert radios and will make them available to special f acilities auch as nuraing homes and schools throughout the EP2 and to homes and businesses which may have difficulty hearing public alert airena.
As 1
indicated in section VI.C., Boston Edison has indicated that they will comply with the recommendation of MCDA/OEP and the state special needs task force, that teletype equipment be j
i installed in each town warning point and is of fered to all EP2 residents with a severe hearing losa, to assure that provasions have been made for emergency communications with the profoundly deai.
F. Procedures for Protection of School Acad Children As noted in our report to the Governor, procedures for j
the emergency response of schools were week or non-existant in j
earlier versions of the Pilgria plana.
This is a matter of the gravest concern, and the development of new and enhanced i
pra:edures for the protection of school-aged children has been 1
a priority issue in phase II planning.
It la our intention to see that each school has its own definitive plan on alert and (e
notification, shelter, and evacuation.
Since planning for f
i response by schools is a peculiarly local matter, development 27-l 4
' of thoco Pleno hoc been o rcopuncibility of lecci c,chool cnd public safety officials, working with their town planning C
committee and school of ficials.
However, staff of MCDA/OEP will provide easistancve throughout the process and review the plans for adequacy and effectivenosa.
planning for protection of school children la based upon identifying an adequate number of buses and drivers to assure evacuation with a13gle bus trips.
In the event of an evacuation children would be taken to a designated reception conter and remain in the enre of school personnel until the child la reunited with his or her f amily.
parents of school children will be notified annually of the school'a designated reception center and, in the event of an actual evacuation, the Energency Broadcast Syster would make f requent of ficial announcements on the precise destination of the children of each school in the EP2.
Regular and coordinated training programs are essential if these plana are to be effective.
Contrary to what some teachers have maintained, it la our belief and a present operating assumption of the planning process that teachers will respond in a professional manner, remaining with and not abandoning the children who have been given to their care.
Phase !!! of the MCDA/OEP planning process will include training for teachers, bus drivera, and other school personnel on their roles and responsibilities in energency response.
(
C. Protaduras for Soeciel Fac111tias The development of adequate special facilites proceduras has been a ma3or goal of Phead II of the three phase process implemented by MCDA/DEP in cooperation with local of ficials and supported by Boston Edison.
Boston Edison has done an inventory of special facilitica in each of the five EPZ communition. This information, along with draft emergency response proceduras for individual special facilities, will be supplied to local Public saf ety of ficials for their review as part of the utility support of fered under section 15, chapter 639 of the acts of 1950.
The Phase II work of discussing plena and procedures with the *Peretoca and responalble of ficials of special f acilities is only Just begining.
In the town of paymouth, l
alone, nearly fif ty special facilities have been identified.
Each local civil defense director working with the town's planning cuosittee will be reviewing evacuation and early closing plans and procedures with the superintendants of their schals. Deepit als are required to have and to test evacuation plena and prac*dursa as a state licensing requirement.
phaea 131 of the MCDA/OEP planning process will include trainlag for the personnel of special f acilities on their roles C-and responath111 ties in energency response and a review,of l
l h.hese plans will be a part of the planning process.,
H. Provision of Eseroenev public Informat,1on-Our December, 1986 report recommended that hoston Edison improve deliver y of Emergency Public Information (EPI),
and, ** report on additional methods that could be utilized to convey IPI to the public..., and study the extent to which EP1 information reaches the realdents of the EP2 and la understood by those people."
To date, no report has been received from Boston Edison by of ficials of the Commonwealth on this matter.
Federal regulations require that an EPI brochure be distributed annually to all realdenta of a nuclear power 1
station EP2.
In the past, Boston Edison has made thia distribution in August or September of each year.
Because several critical planning tasues remained unresolved, Boston Edison informa us that they will delay their annual distribution until December.
loston Edison hea taken one step to broaden the reach of their EP1 by purchasing space in all EP2 telephone directories.
These directory pages give beste emergency j
information and suggest that readera contact a Boston Edison j
telephone number for additional information.
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MCDA/0EP arranged for a meeting between membora of the j
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state speial needs task force and Boston Edison's EP1 consultant contractors in June, 1987.
At that meeting several reconsendations were rede for improving access to EPI for the entire EP2 population.
Members of the task force will review the EP! brochure to see to what extent their recommendations have been incorporated into the next final edition and to make i
reconnendations for improving f uture brochures.
It must he emphaatzed that en interim Public Information Brochure will be distributed throughout the emergency planning zone, as discussed in the end of section III of this report.
One of the f
most critical leaues which must be fully addressed prior to
^
distribution of a final EPI brochure la procedures for I
assisting special needs populations.
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- 1. Fenources for Emercenev Renoonae In my December, 1946 report, it was noted that plans i
for response to an accident at Pilgrim Station lacked evidence of the ability to provide sufficient emergency resources on a i
timely basta.
In particular, it is necessaary to demonstrate that an adequate number of busea,' ambulances, and chair vans will be available for all transport dependent persons, and that I
these vehicles will be available in a timely manner to support j
a safe evacuation.
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toston Edioon to conducting o curvcy of 011.prayoto transportation companies in southeastern Massachusetta to determine what vicarious transport resources are available
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Individual agreemente aunt be negotiated with all i
nearby.
j operators of buses, ambulances, and chairvana to make available their equipment and drivers to the EP2 consunities in support of response to a nuclear accident.
Tbia process must also identify an adequate pool of drivers to ensure rapid and fu11 mobilization of all necessary vehicles.
These arrangements j
need to be concluded as a part of Phase II of the MCDA/OEP three phase process to revise Pilgrim area plana.
All j
appropriate documenta^. ion will be reviewed by staff of MCDA/OEP before it la included in local plans and in tne revised 4
MCDA/OEP Area II plan.
4 No guarantae can be given that all drivers will respond to a nuclear emergency, and written agreements offer no
)
absolute assurance.
However, we feel that adequate training j
will help reassure drivers of their safety in energency response.
The atste. with the support of Boston Edison, will l
provide training in personal radiation protection for all drivers who P.ight respond to an accident at Pilgria.
The l
curriculum for this training is presently being developed under the direction of the MCD4/CEP training officer, and the training will be offered as a part of Phase III of.the agency's three phase procesa for revising the Pilgria plana.
J. Recention Centera 1
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Replacement of Hanover Mall as a reception center for i
the northern portion of the EP2 remains one of the most i
difficult pending lasues regarding off-alte energency response l
1 for en accident at Pilgria Station.
The noston Edison Company i
has been asked to study the physical f acilities at Taunton l
i state Hospital and Bridgewater Community College.
The study j
was espected to be completed in September, 1947, but is not now
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expected until December according to Boston Ediaore officiale.
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This study will determine what physical alterations must be 1
made, what equipment must be provided, and what additional I
plans avat be developed so that we can with only two reception f
f acilities meet the needs of the EP2 population for reception, i
radielegical sonitoring, and, if necessary, decontamination of I
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people and vehicles, either with or without a third reception center.
j Once we have received this study from Roaten Edison, it wi tn be reviewed by staff of MCDA/OEP to determin9 if it is acurate and if its recommendations are reasonable and 1
implesantable.
Based upon the study and upon oth*er l
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domssentation including the Evacuation Time Estimate, we will determine if the two current facilities are adequate -- given the coaP etion of recommended improvements -- and if a third l
reception center la necessary.
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Thoro 10 no fedorc1 or otcLe requirement for three reception centers for the Pilgria EP2.
Federal guidance states f
only that reception and radiological monitoring services be provided for up to twenty percent of the total EPE population i
and that radiological monitoring must be accomplished within twelve hours.
However, the legitimate concern of EP2 realdents
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that their protection has diminished through loss of the Hanover reception center will be taken into consideration throughout this procesa.
l M. Pileria Restart Process Since P11 grin Station remains shut down under s' confirmatory action letter by the U.S. Nuclear Regulatory t
Comatasion, The Boaton Edison Company must follow a regulatory I
procedure leading to full operation of the power plant.
Boston i
Edison has not as yet made a formal request to the N.R.C.
for l
permission to restart Pilgria Station.
Boston Edison j
. repeatedly has stated that they will not seek permission from 4
the NRC to restart Pilgria until approval la first received from the company's board of directors.
4 i
Noreover, the NRC Region I staff has indicated that an antanaive on-site inspection will be conducted and evaluated j
before any decision la made to recommend restart.
Ultimately.
the restart declalon will be made be the NRC Commissioners.
There la disagreement about the opportunity to be given to the
(
atate and public to be heard prior to restart.
We went the NRC to hold a full adjudicatory hearing in the EPZ while the NRC 4
l has recommended only that they hold public meetings.
We will continue to insist, as you and the Attorney General have done j
through the filing of your recent petition, that no consideration be given to restarting Pilgria Station until a
]
f ull adjudicatory hearing la conducted.
t The NRC has not indicated what consideration will be given to eff-site energency prepardoness in their restart d e l iberet t or.a.
This la very troubling.
When the rules and guidance regarding energency planning were first laaued in 1980, planning was said to be as critical to safety as 9
i engineering to the extent that the NRC declared that energency l
planning inaues must be fully addressed for all nuclear power l
s t a tiona. The Pilgria case will test the entent to which the 4
WRC remains committed to this fundamental tenet.
VII.
CONCL111DN I
Ovr position remains the same as it was in December of
)
1986. Fokral authorities should not permit Boston Edison to restart Pilgria Station unless and until all safety leaues have i
1 besa fully resolved, including sustained improvement of the
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nuclear management as demonstrated through, among other Andicators, the highest grades in an MRC Systematic Aaamaament 1 1
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'of Licensee Perferocnco, icpicacntotten Cnd cccp1Cticn cf o a
reactor safety program which satisfies all questions regarding
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the Mark I containment, and development of adequete off-site radiological emergency response plana.
We also feel that a succesful graded exercise of all off site plans and facilities must be held, and that the WRC sunt hold a full adjudicatory hearing within the P11gris EPZ before Pilgrim Stetton la authorized to restart.
The process which leads to the satisf actory resol'ation of all of our safety concerna cannot succeed without a cooperative effort of state and local officials, the Boston Edison Company, and federal regulatory authorities.
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Charles V.
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APPENDIX ONE k
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- en emeegy ee or briese Dreesebre aret, m.areres headsed and e'r*'F-etwa. deseab te eres.ieers endessanse meh segerd se AN ACT MAKteso AM APPROPRIATtopt PotTItE FISCALYEAR EMDIMO JUNE shie hae hem preceded forehee.enes se espredseees lillRTIETit.MINETEEN HUNDRED AMD E900 TTY.Et00tT.TO PROVIDE FOR
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i SUrl*LEMENTING A CERTAIN EXISTIfeO APPROralATION.
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dVe De it enactedby the Senesc endHosase ofRepresenterives In Generet i
SECTION 3. This act shall take effect upon its passage.
- Cours assembled. and by the sootherity ofthe same. asforrow.:
I SECTION 1. To provide for supplementing a certain item in 2 the general appropriation act the sum set ferth in section two
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e 3 subject to the provisions of law regolating the disbursement of 4 public funds and the conditions pertaining to appropriations in n., y 5 chapter one hundred and ninety-nine of the acts of nineteen 6 hundred and eighty-seven. for the fiscalycar ending June thirtieth.
i 7 nineteen hundred and eighty eight the som so appropriated to 7))77
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I SECTION 2.
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APPENDIX TWO
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THE COMMONWE AL.TH OF M ASSACHUSETTS M.'
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civg Clitmst atthCT ah0 08FCt Of tutmClarCT Pat,antomill 400 er08tCintta 20A0 J
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e u w a sea u, wars ti m e r ROBERT J MVt.AY MICHAtt 5 OUKAKIS DatCi*/
aCV1RMOS July 24, 1987
' Mr. Edward A. Thomas, Chief Natural and Technological Hazarda Division Federal Energency Management Agency John W. McCormack Post Office and Court House Boston, Massachusetta 02109
Dear Mr. Thomas:
This la to advise you that in accordance with Mannschusetta law, St. 1979,
- c. 796, codified am Massachusetta General Lawa c. 33 Appendix, section 13-2b. and federal regulations, 10 CFR 50.47 and 44 CFR 350.7 the Commonwealth of Massachusetta has determined that the pluma exposure pathway emergency planning zone for the Pilgrim Nuclear Power station should be reconfigured.
The reconfigured EPZ will include the entirety of the l
towns of Carver and Marshfield, both of which presently have only a portion of their jurisdiction within the EPZ.
1 Accordingly, based upon our analysis of local conditions and geographical boundaries, the history of off-site emergency l
planning at Pilgrim Station, and our consideration of the views of state, local, utility, and federal officials, we requent
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that you acknowledge this determination.
On July 14, 1987, we held a consultation meeting in accordance with 44 CFR 350.7 and 10 CFR 50.47 which was i
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attended by representatives of this agency, the Executive j
Office of Public Safety, the U.S. Nuclear Regulatory l
' Cosaiselon, and the Boston Edison Company.
1 As discussed at the July 14 meeting,'it la also our intention to designate other towns which have a portion of t
their geographical territory within ten sites of Pilgrim b
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Thio docignotion will teko ploco ef ter we have completed consultation with each of the concerned f*,{
communities.
Thank you for your cooperation with this very important matter. ;
Sine ly, obert J. 5ou4 7 Director I
Assistant Secretary Peter W. Agnes, Jr.
cet Deputy Director Jc.hn L. Lovering Assistent Commisaloner Gerald Parker, MDPH Mr. Ralph Bird, Boston Edison Cnmpany Area 11 Director Rodger Mr. Al Slaney, MCD A Area 11 Chief Executives of Carver and Marshfield Civil Def ense Directors of Carver and Marahfield I
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' p' THE COMMONWE ALTH OF M ASSACHUSE7TS rD EXECUTIVE DEPAkf utNT
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July 24, 1987
'Mr. William T. Ruano11, Administrator U.S. Nuclear ' Regulatory Commission, Region 1 631 Park Avenua Xing of Prussia, Per:nay 1v a ni a 19406
Dear Mr. Thomas:
This la to advise you that in accordance with Massachusetta law, St. 1979, c. 796, codified as Massachusetta General Lawa c. 33 Appendix, section 13-2b, and federal regulations, 10 CFR 50.47 and 44 CFR 350.7, the Commonwealth of Massachusetta has determined that the plume exposure pathway l
for the Pilgrim Nuclear Power Station emer?ency P anning zone i
abould be reconiigured.
The reconfigured EPZ will include the entirety of the towns of Carver and Marahtield, both of which presently have of their,)urisdiction within the EP2.
only a portiers local conditions and Accordingly, based upon our analysis of the history of off-aite emergency I
geographical boundaries, and our consideration of the views planning at Pilgrim Station, of state, local, utility, and lederal officiala, we requent 1
that you acknowledge,this determination.
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On July 14, 1987, we held a consu1tation meeting in accordance with 44 CFR 350.7 and 10 CFR 50.47 which was l
attended by representatives of this agency, the Executive l
office of Public Saf ety, the U.S. Nuclear Regulatory
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Consission, and the Boston Edison ConPany.
i As discussed at the July 14 sieeting, it la also our
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Antention to designate other towns which have a portion of
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their geographical territory within ten at.'.se of Pilgria l
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Thio dooignotion will, toko ploco hsve conpleted consultation with euch of the concerned station as efter we communities.
Thank you for your cooperation with this very important matter..
Sine
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Oh Robert J.N g lav f
Director Assistant Secretary Peter W. Agnes, Jr.
ces Deputy Director John t..
f,overing MDPH Assistant Commissioner Gerald Parker, Hr. Ralph Bird, Boston Edison Company Area II Director Rodger Mr. Al Slaney, MCDA Area II and Marshfield Chief Executives of Carver Civil Defense Directors of Carver end Marshfield I
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Comonwealth of Massachusetts Civil Defenst Agency and Office N
ATTH: Mr. Rcbert J. Boulay Director O
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400 Worcester Road
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Dear Hr. Boulay:
In y'our letter of July 24, 1987, ycu requested we acknowledge that you have determined the plure exposure emergency planning zone (EPZ) should be reconfigured for.the Ptigrim Nuclear Power Station to include the towns of Carver and Parshfield in their entirety. We subsequently undtrstand that this reconfiguration has now been deferred to enable priority attention be given to your ongoing efforts with the current EPZ comunities, the Boston Edison Company and FEMA in irproving emergency planning and preparedness within the l
current EPZ. Ve enceurage these ef forts to improve energency preparedness.
Sincerely.
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William T. Russell Regional Administrator i
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NUCLEAR 1DWER PLANT REAL TIME MONITORING SYSTEM (TELEMETRY is inventiqatino the The Massachusetts Department of Public Health feasibility and usefulness of a real time monitoring systen for nuclear power plants which would involve the transmission of onooino radiation levels at selected locations within the boundaries and of f-site of nuclear power plants to a State f acility.
This system would allow a State agency to know immediately if and when radiation was released into the environment.
Presently only the 3 tate of 1111 noir system in place.
Most of our has a comprehensive real time telemetry information has been received f rom Illinois and the cost estimates are developed based upon figures obtained f rom the manuf acturer of the equipment used in this system.
The program in Illinois involved approximately six years development attention.
Since the state-of-time and once in place needs constant i
the-art in this area changes rapidly, the equipment must be constantly up-dated, modified, or replaced.
l The Illinois Department of Nuclear Safety's Remote Monitoring System (HMS) incorporates three major components:
gross qamma detectors radially positioned around each nuclear power stations on-line auto-mated, isotopic caseous ef fluent monitors which sample f ron maior I
engineering release points: and an on-line reactor parameter data enm-In addition, on-munication link to each f acility's on-site computer.
line Ifquid ef fluent monitors, which will be located at each plant's J
installation at two sites liquid discharge points, are scheduled f orM1 RMS componenta are connected th within the next year.
cated data connunications links to the Illinois Department of Nuclear i
l Saf ety Radiological Emergency Assessment Center (REAC) located in i
springtield, Illinois.
At the REAC technical staff, comprised of nuetear engineers, health ohysicists, and other nuclear safety spe-cialists review the data and perform analyses of plant conditions.
J This REAC staf f in divided into two analytical groups, one concerned 1
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with the status of reactor safety systems and the other with envitnn-pental assessment.
An estimate of the cent of a monitoring system similar to the existinq The
' system was obtained f rom Reuter Stokes in Cleveland, Ohio.
following is an estimate for a basic system for a single power plant l
which would allow Massachusetts to add on as neuded or,an new tech-nology becomes available:
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Page 2 Breakdovn of Costs Remote Sensor
$16,000 16x16,000
$255,000
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Computer
$100,000
$100,000 (This computer should be able to handle up to 64 remote sensors)
Spare parts
$18,000
$ 1g,000 Installation per
$'12,000 16x12,000
$192,000
=
sensor Phone charges
$2,000/ month 12x2,000
$ 24,000
=
Personnel
$150,000
$150,000 (One of Each -
Scientist, Electronic Enqineer, computer operator, & Clerical) i Calibration
$400/ unit 16x400 f
6,400
=
Maintenance & Repairs
$30,000
$ 30,000
(
Total Estimated Cost
$776,400 (Per power station per year with 16 remote sensors)
It should be noted that each power station in this country that employs this telemetry systep has had 10-16 remote sensor stations.
Outside of the U.S.
le.g. Finland or Korea) an average of 10 is com-
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pon.
The State of Illinois estimates that their cost of the telemettv system average calls for two million dollars / reactor.
This was due to the cost of development of the, system, as well as the fact that the cost of the remainder of the Radiation Control Program was included in their budget process.
The Hassachusetts' estimates above are based on a proposed Program for monitoring a single nuclear power plant.
)
Information sheets on tne Illinois emeraency planning and assessment 1
activities are attached.
I e
s pjd be Attachments (5)
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THE ILLINOlS PLAN FOR RADIOLOGICAL l
ACCIDENTS The Illinols Plan for Radlological Accidents (IPRA) details the
- f program for state wide, integrated management of nuclear acc dents, especially those which might occur at a nuclear power reactor. The primary purpose of the Plan is to provide a coordinated responso by state and local governmental officials i
for the protection of the citizens of Illinois. The Plan includes:
l general planning to cover the urgency of any nuclear accident; site specific planning to protect citizens living near nuclear plants; a concept of operations so that the Plan can be effectively carried out; and sa effective allocation of resources and personnel.
The Plan pre assigns the dulle s and i
responsibilities that would be taken by all the twspondents to a nuclear accident, thus enabling actions to be made quickly and efficiently.
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l The Illinols Department of'Huclear Safety (IDNS) and the Illinols i
Emergency Services and Disaster Agency (lESDA) share the responsibility for developing the Plan. Speellically, the IDHS is
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responsible for the technical functions of thle effort, and the l
IESDA is responsible for the operational aspects.
The Plan is updated annually for accuracy, and appropriate components are distribu:ed to
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- state, 10 county, and 37 municipal orgenIrations in Illinois, as well as to appropriate organitations l
In the contiguous states of town and Wisconsin.
Major operations speellied !n the Plan include:
l o Accident Classification.
f; o Operational Response Level.
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o Initial Notification.
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o Accident Assessment.
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o Command and Coordination Responsibilities.
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o Protective A:llons:
Shelter; Evacuation; Traffic and I
Access Control; and Food. Water and Milk Control.
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n o Parallel Actions:
Puulle information; Radiation Exposure 1
l Control; Law Entorcement and Crime Prevention; Fire and Rescue; Emergency Medical Services; Social Services; and 1
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Re. entry.
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o Operation Centers: Location and Responsibilities.
g o Notification of the Pubile.
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b o Emergency Announcements:
Inf ormation, Shelter, t.nd l
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Evacuation.
- Eil E," E u T
- i7 7 n E E ii S i I
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2 l
RADIOLOGICAL EMERGENCY j
ASSESSMENT CENTER j
.C I
The Radiological Emergency Assessment Center (REAC) in Springfield l$ the command center for the Illinois Department of Nuclear Safety in the event of a nuclear emergency occurring in the State of Illinols.
REAC houses the custom designed, 5
state.of the art Integrated computer system which continuously Identilles and measures all radioactive components being i
released by nuclear facilities into the environment.
The REAC Commander, supported by a highly trained and experienced technical st a f f, directs the implementation of all tasks associated with the radlological aspects of a nuclear Incident.
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support ientures of the REAC compt.hr system include:
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o Computer Room, 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Radio Communications Center, Commander's O!! ice, and Emergency Command Center.
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o Dedicated air c onditioning, emergency standby generator, end special powcr conditioning to maintain operability during a potential power failure, j
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o Eight computer graphics monitors to display engineering drawings, color maps, graphs, and charts.
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o A giant screen projector used to provide a seven foot wide 1
Image for large group presentations.
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l t, Status boards to record the changing technical conditions of each power station and in the immediate environs.
1 o Maps of the 10 mile and 50 mile Emergency Planning Zones for each reactor.,
i o Radio console capable of communication with emergersey Reid teams around nuclear power reactors.
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o Forty channel tarn recorder for permanent records of all communications.
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o An extensive technical library of controlled documents Including detailed operating procedures and design features 1
i of each Illinois nucl ear power station (includes over 50,000 engineered drawings).
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l REACTOR PARAMETER DATA LINK The Illinois Department of Huclear Safety (IUNS) hks Installed a
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direct data communication link between the Department's central computer and each nuclear reactor's control roorb
.i computer for the mo!.itoring of nuclear power reactors and their i
safety systems.
This DNS Data Link (DDL) was developed for early notification of events that could lead to nuclear accidents.
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DDL is an essential element in providing continuous plant safety i
assessment, early detection of abnormal conditions, and l
i evaluation of nuclear plant transients.
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i The DDL signals received in the Radiological Em'ergency Assessment Center (REAC) are the same signals available to the nuclear plant personnel on site.
The Department selects particular pernneters to,be transmitted to REAC from an index I
contalning all available plant system information.
Parameters l
l selected by the Department provide detailed information on the
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operating characteristics of all essential plant safety systems.
l Vajor features of the DDL include:
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o 1000 1300 parameters (signals) per reactor transmitted l
every two minutes.
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o 9 reactors cucrently providing data and 4 additional l
reactors to subtnit data prior to commencing operation.
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l o Technical parameters include:
reactor power levels, i
reactor water
- levels, steam generator water levels, i
contalnment temperatures, engineered safety system availability, and essential pump flow rates.
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i o System software for displaying either current or historical multiple signals.
l Features to be developed include:
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i e Analytical software to monitor current data and :st off an i
I storm upon detection of abnormal conditions.
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i o Expert System software to diagnose abnormal Indications and predict the probable sequence of future events faster than the accident progresses.
o Continuing software development will increase the speed l
I and reliability of analysis, thereby further ensuring the I
protection of the health and safety of the citizens of lilinols. -
, C.,
i m=.==,":P== "" - '~ "" """mi:r i
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THE B ADIOACTIVE G ASEOUS EFFLUENT MONITORING SYSTEM
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The Illin ot.9 Department of Nuclear Safety utilizes a
custom designed automated system to monitor gases routinely released by nuclear power plants.
The Radioactive Gaseous Effluent Monitoring Systems (RAGEMS) is designed to Identify and quantify the radioactive. components of the gaseous l
discharges to the environment so that appropriate emergency actions can be intilated in the event of a nuclear accident.
Although a complete system is currently Installed only at the LaSalle nuclear power plant, units will be installed at the Zion and Dresden nuclear power plants in the Fall of 1986. The Department will be Installing this equipment in the rest of Illinols's nuclear power stations over the next five years.
The RAGEMS is a state of tho ari, computerized system which continuously transmits data from the nuclear power plant to the Department's central computer which is located in the Radiological Emergency Assessment Center (REAC) in Springfle'ld.
1 This system includes the following features:
o Dedicated computer at the power plant sites for operation and analysis.
I o Minimum detection level of 10*I3 microCurles/ cubic centimeter.
o Maximum accident detection limit of 105 microCurles/ cubic centimeter, i
o Collection and analyses of radiation In three forms: lodines, particulates, and noble gases.
o Automatic background level checks.
o Automatic check source verifications. -
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o Remote computer access to determine operational status
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and data.
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o Signal alarms in the event of high radiation levels or J
failure of a system function.
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o Detection of specific isotopes based on radiation energy.
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o Accelerat,ed operation rates designed to maximize data
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collection during an accident,
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Ittd:Ptat. tu b;il 41'te Ol'948tEl (I'lli
)
i
ENVIRONMENTAL F:ADIATION C
MONITORING SYSTEM A ring of environmental radiation monitors (pressurized lon chambers) is installed around each reactor site that would measure a change in radiation levels resulting from a radioactive release at the reactor site.
This system serves a inullitude of
- purposes, it wil.1 dellne the existence of a radloactive release sulliclently large to impact upon the environment, as well as detect a release through an unmonitored release path, in addition.
i the system provides a backup capability should the effluent monitoring system be Inoperable and also reveals the presence el atmospheric conditions (wind shear) which could result in plume dispersal not following anticipated direction of travel.
'l The Environmental Radiation Monitoring System has the following g
features:
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o Up to 16 monitors per site (one detector for each 22.5 degree segment) at a distance of approximately two n;lles from the j
reactor site.
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o Minimum detection level of one microRoentgen per. hour, i
(Natural background levels are approximately 7 10 microRoentgens per hour.)
l o Maximum detection Ilmit is 10 Roentgens per hour
(
(one million timee normal background levels),
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1 o Automatic transmission of radiation readings to Radiological 1
Emergenwy Assess, ment Center computer system every eight l
- minutes, o Transmission of alarm signals to REAC in the event of high l
radiation levels or fallure of environmental monitoring system components.
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NaNm u$o"ts IN tt so (6et I
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4 APPENDIX FOUR
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$Hr=acvtnyt kiwC C 8 P vista., Pthwsytycnig gg404 g
0, Ogc0 November 5, 1982
/
cc:.J. Allan R. Starostecki f,
- 1. Martin R. Shepherd
,.F-Trenneman Cormonwealth of Pennsylvania R. Hoefitng Departinent of Environmental Resources W. Kerr OSP ATTH: Thomas M. Gerusky, Director Resident inspectors i Bureau of Radiation Protection PA facilities Post Office Box 2063 Harrisburg, Pennsylvania 17120 FNB - 11/15/62
Dear Mr. Cerusky:
/
Thank you for your letter of August 24, 1982 and your interest in having personnel of the Pennsylvania Deprtment of Environmental Resources accompani NRC ngtonal-based or resident inspectors as observers on inspections of nuclear pewer plants located in the Conrnonwealth of Pennsylvania.
For any inspection that you wish to observe, your point of contact in the gegion ] office is Richard Starostecki, Director, Division of Project and Resident Programs.
If accompanirent is approved by regional managem nt, he will make appropriate arrangerents with either the regional or resident ins pe ctors. Lisually one week's advance notice will be required of your in-terest in acco.mpanying our inspectors.
You should make separate arrange ents on a centinuing basis with specific licensees to assure your entranc: to th.ie facilities.
(
Because of the nature of investigations, which are nomally conducted by a separate office of the Comission, and the requirement for a degree of cen-fidentiality in the condu:t of invatisations, ac:cmpaniment of investigat:-:
nomally would rot be permitted.
Enclosed with this letter is a Protocol for Acccmpantrent on NRC inspections that you are requested to corplete and return to this office.
The Protocol su.rurites NRC policy in NRO ir.spection accompantr-tnt and yccr' apraement t) abide by the criteria contained therein.
Again, thank you 'for your interest in our regulatory progran and wt. look -
forward to coopeJation with you.
~
l Sincertly.
7,.
I Ron C
Iy s
Regional Administrator
Enclosure:
As Stated
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Wac4 &
Protocol for Accompaniment on NRC Insnections
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C Persons employed by the Pennsylvania Department of Environrnental Resources s ay accorpany HRC staf f on inspections conducted by HRC Region 1 inspection personne). under the following tems and conditions:
Specific approval for each accmpaniment will b) obtained from the 1.
HRC Region 10ffice prior to accompanying an HRC inspection.
2.
Accompaniment is limited to no r. ore than two individuals on any single inspection.
in Individuals accompanying NRC inspectors shall not{on. any manner,HRC inspecto 3.
interfere with the orderly conduct of the inspect are authorized to refuse to pennit continued accompanirnent by an individual whose conduct interferes with a fair and orderly inspection i
i
. or whose conduct does not follow the terms and conditions includei within this Protocol.
The reports of information obtaked by Str.te I
participants under this Protocol should be subject to supervisory l
review as are all findings of HRC inspectors.
is.C inspectors will not normally object to the presence of individuals 4
acco Oanying them during inspections or discussien.. with the Itcer.ste The NRC i
.regarding inspection r.atters covered by the accogani: rent. re i
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froa any portion of an inspection or a discussica if the p.esence of su.h individuals has the potential for irtpeding the ins;ector's ability to l
t carry out his inspection.
i i;otwithstanding the other provisions of t'ils Prctml, individu %
5.
acco: praying NRC inspectors will not norra11y bt p wideil access to proprietary infonntion or infonatien concerning t'.n physical m wit /
Uceptions to this provision will be considered plan for a facility.
c.) a case by cast basis and e.sy require executic, :f ';.7ropr,iato a
ncn. disclosure agraements.
l 6.
Individvah acevnpanying NRC inspectors pursuant to this Protocol do so at their om risk.
The Nuclear Regulatory Comission will accept no responsibility for injuries and exposures to hannful substances I
eich may occur to such individuals during the inspection and will i
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. assure no liability' for any incidents associated with the acconpaniment.
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Individuals accompanying HRC inspectors agree to waive all claims of Tiability against the Comission.
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The NRC will not make arrangements for' the persons accompanying the
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NRC inspector to gain access to the licensee's facility, but wi))
'l infom the licensee that the NRC has no objectior to the specific
..J individuals accompanying the NRC inspectors.
Arrangements to gain access to the licensee s faellities are the responsibility of the accompanying individual, subject to not disclosing the date of the j
inspection.
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/ arnta.o M
Tor the Comonwealth of Pronsylf4nia j
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$UBAGRECHCNT 1 FtRTAINihG TO LOW.tEVEL RA010AC11VE VA51C PACKAGC A TRANSPORTAtl0N INSPECTION $
BETWEEN THE s
Com0 WEALTH OF PENNSYLVANIA AND THE
.e U.S. KUti. TAR RCGULATORY COMMISSION i
i This Subagreerent is entered into under the prov Nuclear Regulatory Cemission effective November 4.1986.
i fulfilling its obligaticns under the (c..
l The Co-ren ealth of Pennsylvania, ir Level Radioactive Paste Folicy Menceents Act of 1965 conte.vplat 1
ns.te perietic inspctions of the areas cf low level ef su:S nste are destined for disposal at a Icw level radioactive waste i
(
disposal f aciif ty.
The United States Nuclear Regulate y CotrMssion (hP.C or Co nission) ih ttatutory responsibility to icsp2ct its licensees to da In the and trtnsportation of 1,cv level radioactive waste destired for dispost.1.
f exe'rcist of this responsibility, the Comission regu l
i
)icensers' procedures fe.- quality assura.Tec, packaolog. rarking, lateling These prnprar. reviews usually t ave besn found adequate te ensure Itcensee cc pitance with the Comission's regulations regardin leading of vehicles.
radioactive vaste packaging and transportation withcut the need for Com inspection of each individual shipment.
Under Sectica U41. of the Atomic Cnergy Act of 1954, as amnded, the Comissica in carrying out its licensing and regulatory responsibflities unde the Act is authorized to enter into a Meterandum of Understanding (av i
with any 5 tate to perform inspections or other functions on a cooperat 1
While the Cosveission does not conduct as the Comission deems apprcpriate.
en site insP:ctions of every low level radioactive wa 1
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Policy Amendments Act of 1985, the Comonwealth of Pennsylvants, and t i
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Appalachtas Corpact.
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.Accordinlly, this Suba reement between the Comon
~l NRC esta 1(shes mutual y agreeable procedures whereby the Comonwealth perform inspection fanettons for and on behalf of the Comission I
reacter and sattrials licensees' facilities which generate low level radio-i j
1-active vaste.
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C It 15 hereby agreed between the Comission and the Comonwealth as f l
l The Comission hereby authorties the Comonwealth to perform, for and on :
beha)f of the Comission the following functions with respect to l
1*
Radioactive Weste Policy Amendmnts Act of 19 j
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Comission licensees located within the Comonwealth:
t J
Inspections to determine comp 114nce with th
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(a) radioactive waste destined for disposal at a comercial Icw level j
radleective waste disposal sitel and l
(b)* Nottf tcation of Comission licensees and the Comission i
All enforcement actions f
any findings disclosed by such inspections.
(such as hotices of Yiolations, Civil Fensities or l vndertaken by the Ccmission.
l The Cocanwealth agrees to utt)tte persennel knowledgeable in radiatl waste psckaging requiremnts, and packaging and tir.ntportt.t'en s;fsty, ions. The Comenwealth agrets to perfonn its functions under this kRC nay provide trainir.g regulat 5tb:greescat at to cost or e7perse to th' 12.
l nso to the Co?.en:t:31th.
t to caploycts of the Comenwealth at no cap *toa does not norns11y eulustt (cacept trasel and per died, ine CoWss j
the (cmonwealth's abtitty to perform suth functionst hoaever, prior (c
(
f Correnvealth qualtitcation of inspectors, Coritenwtalth unageren.,
accorpanied by en htC representttive. Will asse33 its intpectors pre.
]
paredness to conduct independer.1, inspecticns.
1 1
i Tha authority to inspect hRC liciastes pursuarit to tha precedirp pSryr.1' I
ts Itatted to the licensees' icw level waste packages and low level trans-1.
portation activitits. Specifically, this cuthority is Ital:tJ to:
i (a) Review, fer understanding, the Itcenset's writtein proceduitst i
(b) Ir.sp*Citon 9f the 1ttenset's written records; and j
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(c) Inspection of coepleted packages and transportation activities.
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the avtherity does not include assessment of the adequacy of the licenl t
quality control programs, training J
writtee procedures, plant equipmentSpectfitimplementin
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N berete etch may be podified, as required. g proced e
nr, grams or staf f tag.
I the Co l h shali not vadertake to awnd or revoke Comission IIce In tatik any action authertaed hereunder This Swbigreesent, i
3.
hoever, shall not be cor.strued to preclude the Comonwealth from eser.
a' cising any authority lawfully available to it under its own laws.
u Efforts vill be made by both parties to avoid duplicative enforcement
(
4, inspection finding'.
Howeve..
l acttaa against an NRC licenste for the samt this is not Mant to preclude appropriate cceplementary actions for the j
such 45 termination of a user peruit t>y the saw fasrection findir.g:ferce-ent action.
l (c. nc..talth a nd h:.C en 1
iw
3 M
Nothing herein shall be deered to authorize the Comonwealth to inspect otherwise enter the prerises of any licenstG of the f. omission which is 3,
Feder,a1 instrumentalit; without the prior consent of the Itcensee.
Nothing herein shall be dtened to preclude or affect in any manner the s
49thority*of the Combston to perform any or all of the functions 6.
described herein.'
Nothing herein is intended to restrict or expand the statutory author of HRC or the Comonwealth or to af fect or var 7.
1954, as amended.
herein shall be deemed to parait the Comonwealth to irpose patkag ng or transport standards beyond those contained in Feder Nothin 8.
regula ions, lhe principal NRC contacts under this Subagreement shall be the Ererg Preparedness and Radiological Protection Branch Chief for reactor c),
sees and the fluclear flaterials Safety and Safegu The principal temonwealth wt:tt Safety and Safeguards. Region I, NRC.shall be the Chief, Radiation Protecticn.
515 Subagretrent shall become ef f active upon signing by the Secr:tary, Spartrent of Envircreental Resources, Coraonwea)th of Penns
/
10.
sse Regional Admin;strator, Region 1 Nuclear Regulatory Comissi sha)) renain in of fect permanently unless terminated by either party ci i
thirty days print written notice.
CWi t-1987 at
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Cated Unis
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c'ay of '
l FOR THt NVCttAR REcutATORY CCP.'115510N
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4!% T. /~ ~~d i
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Eglenal Administratc r
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fl FOR THE Com0WEAllH OF PEMNSYLVAOA t
f t w 5ecretary, Department of Enytrcr en; SEPli1987 f
cs.
Cated: _
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' ly.PLEMt$T!$G PROCEDURES 5U8AG ttMENT 1 PERTAI l'
RADICACTIVE WA57[ PACKAGt AND TRANSPORTATION INSP stivt[N THE CO. 0hWEA!.TH OF PENh5YLVANI A AND THE NR V
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TRAINING Pennsylvania staff attendance at NRC Sponsored Courses l
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Pennsylvantt stif f nay attend NRC spoMored training ccurses l
when rutua,11y agreed upon by Pennsylvania and NRC.
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j Atter. tar.cc at any sa-ticular course will te scheduled o'..
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a space available basis.
I Staf f applytr.; for attendance r.ust fulfill any necesst.r/
3.
course prerequisites.
Attendance wt)) norrally be itedted to 12 tridividual; et 4
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any one particular course.
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Pennsylventa y111 pay any transportation and per dien expenses except for ccurses of fered in conr.ection with it.o, gree: erd 5.
i' 5 tat: Progrc: shore N*tt psys for trevel and per (it.n cf State prsonnel sticcted to atte.d.
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On.the.Jcb Training On.the.jeb testning wt)) be provided to the Pennsylvanta staff in the conduct of inspections to deterniae ccr.pitance with the l
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i requireNnts in 10 CFR Parts 20, 61 and 71.
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The training icccapanteents wtil normally be Itatted to NRC t,
)ttensees located in the Comonwealth of Pennsylvania.
7
.The training acccapaniments will follow the protocol set out
)
3.
198 letter to Mr. Gerusky, Under 4
.in P.r. Naynes' Noveder 5les of'the individual accompanying the
. 'i the protocol, the activit
' NRC inspector will,* be 1 tatted to observation and fastitartratio i
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t The hRC with plant activities and the NRC inspection process.
inspector wt11 be responsible for initisting action to correct r
any prc, gram defletencies identified during the inspection through NRC's noreal inspection and enforcement process.
Corrmonwealth of Pennsylvanta l'$ff accompanying the NRC inspectt' wi)) normally be limited to two persons - the senior staff mir 4.
l responsible for the program and the cogntrant inspector for ttt l
plant being inspected.
Cephasis will te placed on training two senior pennsylvania sta" i
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who can learn this area quickly and who in turn, can begin te train other Pennsylvania staff.
The training ray also involve pre inspection planning at the t
f.
Regional office or in the !W.C resident tiispection office pri:r l
The Comonwealth inspection staff is exp::D to the inspection.
to heve revi2wed prior insp2ction reports, inspection findin';li U l
ar.d enforcement actions for the f act) tty being inspected, also espected that the Comonwealth inspectors are thoroughly I
inowledgeable of the NRC inspecticn procedures and reference i
l r.ateria) cited in those procedures. These are inportant parts i
f j
3 preparing for the inspection.
l ih2 training accompantrents vill be provided by a Reglen bas *'
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inspector who reutinely inspects waste packaging and transp:,.-
g activities, not the resident inspectoe or TMI 2 insp:ction st..
t 8.
The contect for the training accompantrent' inspections at l
reactors will be the Chief. Dneroency Praparedness and Radic-legical Protection tranch. Olvisuon of Radiation Safety and j
l The sintlar contact for r.aterials intpections vill Safeguards.
be the Chief. Nuclear Materials Safety and Safeguards tranch.
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Division of Radiation Safety and Saferluards. If either of the above are not available the contact whil be the Regional State Liaisen Officer, 3
I C.
Initietton of Independent Inspections by Pennsylvania $taff l
The Comonwealth will ensure that its inspectors are q;ualified f
1.
in accordance,with NRC Inspection and Enfortement Manual Charter l
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Y 1245, or its equivalent, and wll) keep NRC inferined of the Comenwealth inspectors that hase been so qualified and certt-fled. Prior to Comonwealth qualification of inspectors.
Comonwealth management, accor0 anted by an NRC representative.
)
will assess the perfomance of its inspectors during an Inspection to detemine their preparedness to conduct indepen-Following the acccmanteent, the NRC repre-l dent inspections.
sentative wt)) provide a crLtique to the inspector and his Periodically. Comonwtalth management will supervisor.
attenpany its inspectors during the perfomance of inspecticns i
i to verify the inspecter's continued effectiveness.
Finally, htC r monwealth managerer.t of problets identified i
,:(1) inforn e
l turtn; the hM revlee of Comon=talth inspection findings fer l
ap;repriate corrective action,
'2, Ccmonutalth inspectors may perd "'g11y acccmpany NRC taspec-i package and transportattet l
I tors during NRC's prograrr st' l
trspections to rattntain f ar isrb with a licenste's program j
and 1.RC inspecticn require G;
at Comonwealth and tJC r.t>
also r.eet periodically to o
infomation and discuss changes in procedures.
Cow
.alth inspectors may also coa-('
tatt the region based and resident insoectors prior to or durtr;
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the Co r.cnwealth's independent inspection at the Fite.
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Arrartt ents to gain' access to a..y licensee's f act11ty are a I
1 responsibility of the Comorwalth. Specifically, indhiduals I
piarning to conduct inspections at reactor factitties s!.ov1d i
.i i
rett a) 1.censet require.iet.ts for site access.
i FA0Ct0Vit:510 It F0tt0k'ID DY PEN!($Yt.VANI A FOR !!(CPECT10:i5 CO pCER TH[ $Ut AGRID'.[N1 l
A, pennsylvania will perfom tha following inspection activities i
relating to 10 CFR 71:
i i
- 3. Isantne the licensee's written waste shipment records. As the situation allows observe completed packages so as to:
,a, Verify that the Itcenset has marked the package with the through 310)ge markings which a 1 and specific packa appitcable genert required (49CFR172.300 i
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Verify that for hRC. certified packages, or 001 revalidateo packages of foreign origin, the.outside of the package is darably and legibly m rled with the package identtitcation s
earting indicated in the COC or the DOT Ccepetent Authority Certiftcatt.
Verify that for non exempted packages, the licenseg provides b.
for and accce.plishes labeling of each package with the appropriatt category of RI.D10 ACTIVE (Nhtte-1, Yellow ll, er Ye)1ow.111) label, one each on two oppostte sides of the paclage; and accurately completes the entry of the rcquired infoinaticn.to the blank spaces jhereon (49 CFR 172, Subpart
().
lictr.ste provides 'for and accompl{shes Ytrify thtt th.a nnitoring of each con *.e'.ed package to als'Jra that b'.trr.'.
c.
radiatten are rmovable surf ace contaminetton are,d'hin t>t ailcwat,le 11.9tts (4g CFR l's3.47*(t)), 49 CFR 173.411 173.43, and 10 CRI 71.ti7(i) and (j ).
the licenst;'s wrW.en t aste shipment records
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P.
sitvation 411cus, observe actut) transpert operations 50 as to:
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ttrify ee*her the itcensee prepared the required shippir.g a.
p :ps. 4;cu.nttien, so as*to cccurately include 61) of tr; epritcM.t required elteents of inferration, it.cludinj 11.1 e',ipptr's carttitca'.e. (h0TE: for 11censte t.rtvat ritor
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vehicle ship' rents, the certtitcate is not reg'Jired ( 9 CIR 1
177,SubpartC).)
Ter non.erclustve use sht;c.ents, verify that, the 11censt.'
b.
trovides to a highway carrier or applies direr.tly to a rcil
. vehicle, the required placards whenever he delivers any quantity of P.A010ACT1Yt Yellow 111 labeled packages to such carrier for transport (49 CFR 172.506*hnd 508).
For exclustve use shipments, verify that the Itcensee c.
sisures that the package and vehicle radiation /contamin-atten levels are within the regulatory)Itmits (4g CFR 173.475(t) and 10 CFR 71.87 (1) and (j ).
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Yertfy that escept for uranium or thortum oess, the i
transport vehicle is placarded by the Itcensee when d-delivering to a cart 'er any thclusive.use shippent for which placarding is requireo D9 CFR 172, Subrart F, and 49 CFR
,173.425(b)(7)).
' For esclusive use shileents, verify that shipping paper j
documentation provided by the Itcenset to the carrier contains satisfectory instructions for vdntenance of r
an)usive use shipent controls (49 CFR 173.441(c) Jnd 49 Ut 173.05(b)(9)).
91fy tnt for esclusive.use shirHnts of ICw stecific l
sctivity raterials, the licenste has prisided fcr the l'
adittenti specific requiry-ents (49 Crt. };3.425 (b)(1)
Ilro'.)h(v)).
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Verify that the 11:. ente. e.acvidet for r.:,-ificatten (o the i
censigt.et before ship-the dates of snipent and i
' 1 lo6 dint /.. 1ording o op ratir.'.
l o pe.t:r! t,rrival, eny t N ang/cr instmtions whar. eve r 4,n,..,,n.txte pt f r :lle r.s ct rit.
I reckages cer.taining 'highuty route cont elled cuanticles" j
are involved (49 CFR 173.ti(t.) and 10 CIT. 71.49),
i 3t the )icenste provides for a.*>sete notificctiem Verify t:
c.
to the t'sverr.n of a 1. tate, or his desig.uc, of an y shtFc r t e
I of rt.$tonti'it vaste req. iring Type C pMkag(ing t,hrev;h. tt. \\
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I or acrcss a state boundary (10 CFR 71.7/).
h0TE: This re. *
'quirerent is not the seme as that required for safeguarts purposes pursut.nt tc 10 Cf R 73.72.)
)
I Review the itcensee's records and reports to varify that a syste r.
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j is in place to:
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P.atntain on flie for two yeari af ter tht: rent a record of
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each sht;went of 11 censed material (nich is not enerpt
'. therefrum) and thct such records eentain the required
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, f.j,
information (10 CFR 71.87 and 10 CFR 11.fl(s)).
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- b. ' Report to the Director, hK55, within 30 days,in theany instances i
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where there has been a significant reduetton r
ef fectiveness of any packaging during its uset providing l
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additionally the details of any defects of safety signifi-cance to the packaging after first use and the means employed to repair such defects to prevent their recurrence (10 CFR 71.95).
Immediately report to DOT. when transporting Itcensed material as a private carrier, any incident that occurs in c.
which as a direct result of the radioactive r.aterial:
any person is killed; re'ceives ir. juries requiring hospitaliza-tion; property damage exceeds $50,000; or fire, breakage, spillage, or suspected radioactive contamination occurs (4 CFR 171.15 and 49 CFR 171.16).
Pennsylv.ia will perform the following inspection activities relat".g 1.
to 10 CF Parts 20 ard 61:
Rev'.s the licensce's records ard, as the situat'..i allows.
obt:. >e actual packages and transprt activities to verify tia.
1.
em shiprnent of radioactive waste intended for off-site disp:i
te a brelcr or a licensed land dispval facility is accompani$.
ship.nent r:anifest which includes all of tne required Lf-in*:. ration [10 CFR 20.311(b) and (c))..
Pv' < the licer.see's documentation and records to detemine 2.
F.;r procedures have been estahlisi:ed and are ceing niin-it'te rd to properly classified all le.i-level waste; according tc h CFR 61.55.
the licensee's"documentation and records ta detemine Re levi 3.
wi.n.ner procedures have been established and are Ning main-ta' red, to properly r.haracterize low-level waste {it confor. mar:e w' o the requirements of 10 CFR 61.56).
Review the licensee's records and as the situation allows.
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observe actual packages and transport activities to verify that each package of low-level waste intended for shipment to a licensed land disposal facility is labeled, as appro-
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priate, to identify it as Class A. 8. or C waste in accor-
. derce with the classification criteria of 10 CFP 61.55 (10 CFR20.311(d)(2)).
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Review the Itcensee's records and, as the situation allows,
' observe actual pa'ckages and transport activities to verify P
' that the licensee has forwarded to recipients or delivered to waste collectors at the time of shipment, a copy of the waste manifest. Verify that acknowledgement of receipt of the manifest is obtained.
Verify that the licensee has a procedure in place to effect an investigation in any instances wherein acknowledgement of receipt of the shipment less not teeen received
' within the specified period. Verify that procedures are in place to report such investigations to the appropriate NRC Regional Of fice and file the required written report [.10 CFR 20.311(d),(e),(f), and (h)).
Review the licensee's records to verify that the appi'ceble 6.
disposal site license conditions are being inet.
Verify that th:
licensee has or, file a cu. rent version of the disg: 51 cite Itcense.
Inspections perforted by the Comenwealth for ar.d on bett'.' of the C.
Comission are not to include those elements of NRC insre* ion prc:t-1 dures dealing with cvaluation of the licensce's writter, pocsd9res.
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equip:r.ent, quality control pr.sg.t.:.is, training programs o
- teffing.
111.. DOCUMENTATION OF INSPECTION FINDINGS, Following each inspection, the Com.onwealth will document the e. mas covered and findings of the inspectico in an inspection repor. osing guidance set out in CliC Inspection am'. Cnforce..ent mnual Chu : rs 0610 and 0611. Following Comonwealth management approval, the report will be sent to the HRC contact listed in Section 9 of the.5'i'n1.ec-ment with a copy to the licensee. The Comonwealth will cou.pi r.e and forward the inspection report to the hRC within 30 days of ccv.ple-tion of the inspection. Following appropr'iate NRC review, the report wl)) be placed in the Public Document Room and a request sent to the Itcensee by the NRC for proper corrective action if deemed e.ecessary.
, For those inspections performed by the Comonwealth which resvit in deficiencies in compliance with NRC regulations, the Cocinontaalth shall identify the deficiencies in the cover letter transmitting the report, arx In specify that any enforcement action is a responsibility of the N 7-shipment departs the plant gate are identified, such findings should be furnished to the licensee and the NRC Resident inspector before the It is the Comission's sole dis-shipment departs the licensee's site.
cretion as to whether the licensee will be requested or requi,id.,to take I.
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l corrective action or to respond' to discrepancies in compliance with HRC s
Commonwealth
- regulations as a result of findings from these inspections.
inspectors will provide support to NRC during any hearings and other meetings relating to their inspections, as required.
i IV.
CHANGES TO IMPLEMEHilHG PROCEDURES l
These implementing procedures may be changed by autual written agreement
'.between the Director, Division of Radiation Safety and Safeguards, NRC, and the Chief, Division of Nuclear Saf ety, Comonwealth of Pennsyls ania.
FOR THE NUCLEAR REGULATORY COMMISSION
%..A' 0'ivision of Radiation Saf ety and Safeguards
$O Dated:
AW.SF' C
FOR THE COMMONWEALTH OF PENNSYLVANI A l
lJA~, P D4 Division of Nuclear Safety
- St? 7 /G
/977 Dated: -
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NUCLEAR REGULATORY COMMISSION e^,:
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E 631 P Ar,( AV(NUC KING CF PRUSSI A, Pc NNSYLVANI A 19104 E
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. July 13, 1987 RichSrd T. Dewling, Ph.D..' P.E.,
Commissioner Department of Eav'ironmental Protection 401 East State Street CH 402 Trenton, New Jersey 08625
Dear Commissioner Dewling:
This 1ctter is to confirm the general agreement reached as the result of our neetings with Dr. Berkowitz and his staff regarding the surveillance of t nuclear power plants operating in New Jersey.
that there was a need to have a more formal way of co Protection's Bureau of Nuclear Engineering (BHE) will be the interface with the HRC on a day-to-day basis.
The areas addressed by this letter are:
State attendance at NRC meetings with licensees relative 1.
to licensee performance, includir.g; enforcement conferences, plant inspections and licensing actions, NRC and BNE exchanges of information regardirg plant con-2.
ditions or events that have the potential fcr or are of 1
safety significance.
We agree that New Jersey of ficials' may attend, as obs ticensee Performance (SAtP) reviews, with respect to nuclear power plants 1
We shall give timely notification to 1
operating in New Jersey (PSE&G, GPUH).the BNE of such me Although ] do not expect such cases to arise frequently, we must reserve the right to close any enforcement' conference that deals with highly sensitiveinves i
'.
- Safeguards saterial or information'that is the subject' In such cases,6
~ M of information could jeopardize effectrive regulatory action.
? would brief you or your staff af ter the enforcement conferen
. s..
. expect the $ tate to maintain the confidentiality of the briefing.
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...,s With regard' to NRC inspections at nuclear power plants in New Jersey, we agre<
Te il that the BNE staf f may accompany HRC inspectors to observe inspections.
extent practicable, NRC will advise the State sufficiently in advance of our In inspections such that State inspectors can make arrangements to attend.
order to assure that those inspections are etfective and meet our mutual need I suggest the fullowing guidelines:
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The State of New Jersey will make arrangements with the licensee to have New Jersey participants in NRC inspec-tions trained and badged at each nuclear plant for unescorted access in accordance with utility requirements.
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'The State will give N'lC adequate prior notification when I
planning to accompany HRC inspectors on inspections.
I 3.
Prior to the release of HRC inspection reports, the State will exercise discretion in disclosing to the pubile its observations during inspections. When the conclusions or observations made by the New Jersey participants are sub-stantially different from those of the NRC inspectors, New Jersey will make their observations available in writing to the NRC and the licensee.
It is understood that these com.tunications will become publiciy asall.able clong with the H,RC inspection reports.
With regard to comunicatiens, we agree to the followir.<j:
1.
The NRC shall transmit technical information to ENE relative
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to plants within New Jersey concerning operations, design, external events, etc. ; for issues that eithcr have the potential j
for or are of safety significance, 2.
The HRC shall transmit all Preliminary Notifications rol:.ted
'C to nuclear plant operations for Nes Jersey facilit.ies to t;.e I
BN[ routinely.
3.
The BHE shall comunicate to the NRC ariy concerr or o.uestion reg.irding plant conditions or events, anci any State ir.Toratier about nuclear power plants.
Please let me know if these agreeme'nts are satisf actory.to you.
(
Sincerely, Original Stened W 1
.. 311.1.!AX f. RussI2.1,
... William T. Russell c:..
' Regional Administrator
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APPENDIX FIVE
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b THE COMMONWEALTH OF M ASSACHUSETTS 4 " *38.6 J
- Extcutivt otPARTWENT
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September 18, 1987 Mr. Ralph Bird Senior Vice President Boston Edison Company 800 Boylston Street Boston, Massachusetts
Dear Mr. Biro:
l My staff has reviewed the August, 1987 "Study to Identify Potential Shelters in EPZ Coastal Reoinn of the Pilarlm Nuclear Power Station," which was prepared for you by Stone and Webster.
We find that this study is deficient in several resoects and l'
that additional work is required to provide information to l
local of ficials which is suf ficient to support develooment of implementable shelter utilization plans.
I have attached a copy of a inemorandum orecared by my staf f which deteils our specific con;: erns regarding this study.
i If you have any cuestions or observations reoarding our evaluation, please contact Buzz Hausner of my starf.
f Thank you for your cooperation in this matter.
Sinc obert ulay Director Q
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Agens, Jr.
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Deputy 01rectdr, John L.1.overing
'I Hr. Buzz Hausner G
N1 11tE COMMOt1 WEAL 111 OF MASSACllVSE115 N *84,',
tztCUllyt Ctr Aft 1 MENT p
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(,H Att s. ounAnis nootnr J ecut A' PmtC109 y a,,C,sg TO:
01 TOR BOULAY FROM:
BU2 USNER IN RL:
SHELTER SUR'!EY OF P1LCR1H EPZ PREPARED BY B0510ll E0150ll COMPANY DATE:
SEPTEABER 11, 1987 1
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We have made a preliminary review of the shelter survey of the Pilgrim EPZ which was prepared t'y the Boston Edison Company and its consultants.
While this document compiles some very useful data, we f eel that more work must be d0ne to estimate the errectiveness or shelter as a protective action.
Our principal concern is that we must be able to put. data in the hands or local of ficials which are suf ricient f or the deveinoment
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or shelter utilization plans for all areas of all five communities within the Pilgrim EPZ.
With this in mind, we have the following comments.
The survey only covers an area approximately one mile wide along the coast.
The shelter capahilities of the entire EPZ must be surveyed and r6 ported.
1 The survey does not separate out those structures which could "n.ost reasonably" be used as shelters f rom those where shelter is less appropriate.
}
For instance. It would help to have a separate list or a
public buildings and f acilities f or each town, 1-including an estimation of the actual useable shelter space and protective f actors for shelter under
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government authority.
s I.
Hany of the shelters listed, such as jewelt stores and pharmacies.are clearly not suitable for pubfic 1
)F shelter.
In a severe emergency, every available
. resource will of course be put to use.
Itowever, to develop an implementable shelter utilization plan, local orricials must be able to' match estimated needs with the rnost appropriate resources available,.
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Director Boulay 1
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Regarding protection of the beach oooulation, the survey identifies shelters within.a mile of the coast but does not indicate the distances that beach goers l
would have to travel to find shelter.
In addition, the f
survey must demonstrate that adequate proximate shelter is available for the total population at the individual
- beaches, For instance, Duxbury beach is about seven miles long and the survey should indicate the distance peonle at Saguish Head are required to travel to reach adequate shelter.
Further, en implementable shelter utilization plan must demonstrate that the nearest shelter would not be full to capacity bef ore the people at the most i
remote' points of the beaches arrived.
l The survey must identify adequate shelter which is handicapped accessible.
The survey does not distinguish between available space
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and usable space.
For instance, residents of Plymouth have indicated to us that some basements listed in the
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survey are no more than crawl spaces.
Crawl spaces cannot be considered for public shelter.
Further, in r
most buildings, a good deal of floor area will be
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occupied by machinery, counters, office furniture, et 4
cetera.
The survey must identify accurately the actual I
useable shelter space available in each structure.
f Stone and Webster uses a FEMA nuclear attack value of ten sauare f eet per person to estimate the ootential population which can be sheltered.
Local Civil Defense Of ficials may wish to allocate more space -- uo to twenty square f eet per person -- in their utilization i
plans.
The value used in the survey overestimates the i
potential capacity of various buildings.
We doubt that 17,000 people can be sheltered at Duxbury High School, or that 89 Buildings.,700 can be sheltered at the 5 Cordage Park i
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The survey must demonstrate that public shelters are
. free f rom asbestos and other environmental hazards.
1 The report. estimates residential "shelterinq capability" in individual communities as between 53%
and 81%.
These figures indicate that a significant i
number of residents do not have adequate domestic shelter and emphasize the need for a full study of 1
public shelter capacities throughout the entire EPZ.
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Directer Roulay o
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Further, even if it can be e'stablished that the vast majority of resiaences of fer adeouate shelter, local officials must be prepared to offer public shelter of a known protective capability to residents who demand assistance.
This report makes no definitive statement of what constitutes adequate shelter to protect peoole f rom the ef f ects of a radioloolcal release f rom Pilorim Station.
This is necessary to determine what f acilities are most appropriate for a local shelter utilization plan and to determine the public chelter needs of each community.
In summa ry, we w'o"uld say tha t this survey is a useful beginning but that much more work is required bef ore we can assess our ability to develoo implementable shelter utilization plans consistent with the public saf ety concerns in Secretary Barry's report to the Governor.
cc:
Assistant Secretary Peter W.
Agnes, Jr.
Deputy 01 rector John L. Lovering
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APPENDIX SIX f.
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State Tolice. Troop "D", Headquarters Hiddleboro, Hassachusetts September 50, 1987 To:
Captain Charles F. llenderson, Consoanding Troop "D" From:
Lieutenant Edward H. Begin #908
Subject:
Review of and Recommendations for Han Power and Equipment Needs relative to Evacuation Time Estimates and Traf fic Hanagement Plan Update Final Draf t prepared by KLD Assoc., Inc. for Boston Edison Co., Emergency Operations Yacility, Plymouth, Hass. dated August 18, 1987, i
1.
On August 19, 1987, I attended a meeting r' Secretary Charles V.
Barry's of fice relative to the proposed traf fic r.anegement plan update re l
an evacuationvithin the Emergency Planni'.y Zone (EPZ) at the Pilgrim Nuclear Power Station (PNPS) loested in the icv, of P1yciouth. At that time, a copy of the final draf t for review prepared by KLD Associates. Inc. for Boston Edison Company was presented to me for review and recommendations relative g
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Location of traffic control posts.
8.
Evacuation routes,
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Personnel resources and I
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Ceneral review.
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Based on personal knowledge of traffic patterns within the area to be affected and traffic intensity data provided by sources mentioned in
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the plan submitted by KLD, which I assume to be correct, the following re-j commendations are being subreitted for your approval.
3.
ne traffic control posts (TCP) and access control posts (ACP) sub-mittt! by KLD appear to be essential in order to complete full evacuation.
j However,1 do have reservations relative to ACP BR-1 and BR-2.
(See attached 3
Table L-1. L-51 and L-52) Wie location, with its.close proximity to Boston would create mtssive gridlock in the area thus preventing any emergency re i
sponse from agencies coming from or through that area.
It would also feny
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access to residents of the EPZ who with to return home for their f amilies.
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nis ACP could be used more effectively if information could be transmitted tomotorists traveling in the area. no information could be provided by the radio media and also electronic message signe erected near j
I ACP la 1 and 2.,An additional four to six police of ficers on motorcycles h,
would be required in that area in addition to the four recommended by KLD to handle the tral!!c problems in the area in addition to the abcve additional requirements. A mediure sized mobile communications van manned by at least
.if three otticers would be utilized at ACP BR 1 and 2 to better handle traf fic and other related probleris in the area. This van should have the capability It h, to commnicate with all State Police agencies as well as local polf.ce.
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m Capt. C. F. Handarsen Septetber 30. 1987 r
- 4. Continued should also have the capability to utilize the telephone comunication system via a cellular mobile unit contained within the van. A large 10 KW hour mobile generator would be needed to handle all power requirements at that ACP. Wis equipment would be stored and maintained at 8 tate Police Norwell to better feel 11 tate implementation.
5.
Another area of question is ACP BO.1.
This area, due to its close proximity to PHPS and large volume of traf fic reqdires a large mobile commun-Acation vehicle capable of communicating directly with all State and local agencies involved in the evacuatloa and in addition PHP5 itself.
It should also have three cellular mobile telephones to handle the additional commun-ication needs that would arise from such an incident. This vehicle would be set up at a prearranged area at the Sagamore Rotary which would have been prepared with a power module which could accoevoodate the electrical and communication hookups necessary to power the comunication vehicle. A large mobile generator would also be heeded in the event of a power outage.
Additional manpower requirements to properly operate the consnunication vehicle would be needed.
6 It is also necessary to equip each officer assigned to duty at the various Acr and TCP's with hand held radios. This equipment shot '.d be com-parable and compatible with equipment currently in use within the Division of State Police.
7, I further recomend that telephone equipment be installed in
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spe.ci!!c vehicles in use by personns1 within the Division so that caminunication could be provided without further straining the t'adio conununication system which would be taxed to the maximum in the event of any evacuation at PHPS.
Wie equipment should be available to the 1) Deputy Superintendent. 2) Com-manding O!!1cer of Field Operations. 3) Bureau Convnander of Eastern Fields.
- 4) Troop Coomander and 5) ent, ire command staff at Troop "D".
Protective clothing and beathing apparatus should be supplied to officers assigned within the five mile radius of PHPS EPZ. Personal radiological monitoring devices should be issued
- .o all personnel assigned and training should be provided periodically in its proper usage. All ACPa and TCPa should be equipped with j
a power module mentioned earlier so that if necessary, emergency lightihg and i
telephone consunication could be brought into service if the need became evident. Telephone communicati.on is eBvious, because of informatio s which.
should not be monitored ly private citizens and news media.
3.
I also reconviend that a contingency of state Police of fic'.cc be trained and maintained on a twenty-four hour bseis to respond to the various ACP's and TCP's in the event of an emergency at pHPS. This could be accom-plished by espanding the "55" Team now deployed in Troop "D'.
An additional eeven troopers and two NCO's would bring the total strength to twenty-five Wie contingency of officers in addition to available personnel would men.
i be able to respond to the various ACP's and TCP's within one hour of noti-j j
fication of an A1.ERT condition.at PHPS.
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Capt. C. F. Henders:n September 30, 1987 7
f 9.
It must be not+d that the personnel requirements can only be eset C.
the ACP's and TCP's located on major limited access highways, Route 6 at Route 3. Route 495 Route 128. Route 25. and their iseediate approaches.
This is due to the availability of manpower at al ort notice and also the need for minimum manning requiresients - one desk of ficer and two patrols at the five troop mainland substations and at least one commissioned officer, one patrol supervisor and one civilian State Police dispatcher at the trocp headquarters. These minimum requiresients are absolutely necessary due to excess activity which would be generated as a result of any evseustion order.
10.
If the emergency Insted for an extended period (days), additional
. manpower would be solicited from other areas (District Attorney's of fices, neighboring T ep "A" and other sobrces) so that assistance could be pro-vided to lot.1 egencies at the remaining ACP's.
11.
The equipment and manpower needs described above are in addition to recommendations of ferred by Kt,D and are minimura requirements.
It may be that additional manpower and equument may be necessary in the event of an emer-gency. I do believe however that the State Police can provide the services necessary at the d, scribed locations if the equipment and manpower requests are made available.
12.
In additio6 to the aforementioned personnel and equipment require-ments, an adequate supply of printed handouts explaining evacuation routes, reason for evacuation and other perintent data should be available for dis-('
tribution at ACP's and TCP's. This would expedite any need for instructions j
to evacuees thus allowing a smoother flow of traf fic at these points.
f EDWARD H. BEG 1H
- 908 1,ieut., Mass. State Police DilQ Middleboro IJIBidv Enes.
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'Brief Explanation of }lanpower Availability within Troop 'D" Total hanpower availability of' Troop 'D' A/O 9-21-87 1 61 This fl Ure describes the total strength including six officers assigned 6
to the island stations at Nantucket and Hartha's Vineyard.
0 cix officers at e currently on extended sick leave. Three are currently ansigned temporary duty within %e Bureau of Investigative Services,
. One officer in unavailable for duty due to a suspension. This leaves a 10 total-vorking strength of 140 officers currently available for assignment on the mainland.
Typical working troop strengu,not counting the personnel mentioned above, varies during each 0 hour0 days <br />0 hours <br />0 weeks <br />0 months <br /> period from 55 uniformed officers working during the day Honday thru Friday to between 17 and 25 uniformed officers working on the remaining two shitto Honday, thru Triday and veckends.
Minimum manning requirments are one desk officer and two patrols at each of five molnland statune. In addition to the above, one coemissioned officer and an INO is assigned duty at the troop headquarters. One civilian Stetta 3I police Dispatcher is also assigned on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis at the tm.op heodquarters.
Typical day strength Hondny thru Triday Sypical Eve strength Sunday thru Saturday 53 + or-5 t
- 5 44 -0 Typical flid strength Sunday thru Saturday 20 15 - 3 Typical weekend Day dtrength 25 45 - 8 The remaining personnel are on time off (days off, Vocation, holidays owed, sick leave, personal days) but are available for re-call on an overtime basis.
hanpower requirments in the event of an evacuation at f!!rS LIT.
KLD Inc.
2B State Police 15 4
i Personnel available for service less minimum manpower requirments.
Typical day Honday thru Triday 30 Typical evo Sun, thru Sat.
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4 Typical aid Sun, thru Sat.
3(45)
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by supplementing the existing Troop 'D" 55 team with an additional 7 troopers and 2 Mco's bringing the total compliment to 27 officers. This group of otticers vould be trained and equipped to respond within one hour of notification of an emergency at PNPG. The remaining 1B officera needed would be drawn from gigting manpower and so trained and equipped.
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APPLl4 DIX 2
- Equipment Requirtents P
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- 1. Fif ty portable radion which would supplement existing equi eent
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t ev.trently in use within the division at Troop 'D".
- 2. Pour 10 KV cenerators to be used at access control points described.
( ACP-BR-1, Bit-2, BO-1, GA-1)
- 3. Hine mobile cellular telephones to be utilized as described.
- h. Two nobile communications vans, one large, one medium to be equipped as described. ( 0 11 - 1 & 2 DO-1)
- 5. one hundred sixty tour dosimeter /one per man.
- 6. Six air packs to be used by personnel assigned within the 5 alle radius of I'NPS. (TCP P,eh, P-7, P-8, F-15)
- 7. six suits or protectivs' clothirig to be used by personnel assigned within 5 alle radius of pNrs.
(Gnas as 6) 4 D. sufficient power siedules'to provide a source or power and telephone communications tob* erected at described sites.
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- A power module vould be a perranentherected, all weather source of electrical power sufficient to handle any lightin6 requirments at that site. It would also be equipped with telephone jacks so that communication by telephone could be easily 16plemented.
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O APPENDIX SEVEN I
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CONTAAL Thb tohe'spg TR ANCPO RTATIO N somn. u A opit s.3,ea 0171st3?800 PL ANNIN']
STAPF C
Hovember 19, 1987 Mr. Buzz Hausner Civil Defense Agency Executive Department The Commonwealth of Massachusetts 400 Worcester Road l
P.O. Box 1496 01701-0317 l
Pramingham, Massachusetts I
Dear Mr. Hausner:
1987, I have j
As requested in your letter of September 28, reviewed the testimonies of Avishai Ceder and Thomas J. Adler regarding the Seabrook Station evacuatior, time estimates (ETEs) to see if they have any bearing on your consideration of the Pilgric Station ETEs.
Dr. Ceder focuses spect fically on the behavioral assumptions and parameters of the I-DYNEV traf fic simulation model, and
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the model can not provide realistic ETEs within a concludes that Furthermore, he believes reasonable degree (i 10%) of accuracy.
that the model is likely to produce ETEs which err on the low side.
Dr. Adler concentrates on the input de.ta to the simulation model, the ETEs were underestimated, especially for and concludes that the summer scenarios, and that the complete set of ETEs should be redone.
the ETEs Each cite a number of reasons for believing that First, there are Seabrook-specific ones.
were underestimated.
One of then relates to the estimation of evacuation traf fic from i
Dr. Adler testifies that the ETEs for summer-the beach area.
f weekend scenarios should reflect the times required to evacuate beaches which are at 100% of capacity, not at 2/3 capacity (as was done by K1,D Associates, having observed 2/3 capacity to be typical of actual use).
This and other Seabrook-specific issues will not l
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be consented on here.
f Second, there are also a number of technical casveptions 1
j which may not be agreed upon among all people in the profession.
l One of these assumptions is the saturation discharge headway for
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Dr. Cedar recommended 2.7 seconds / vehicle, based intersections.
(R. J.
Salter, Highway Traffic on an observation of 80 vehicles Analysis and__ Design, Addison Wesley,1974), while KLo used 2.4 gi b i,
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,e........ t..... r e...,, wra u.w he<* weissea se" tais *a i
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- Hr. Buzz Hausnor N vecb]r 19, 1987 seconds / vehicle, taking the high end of the range from a low of 2.1 to a high of 2.4 documented in the Highway capacity Manual
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(Transportation Research Board, 1985).
No attempt will be made here to resolve differing views about these technical assumptions.'
However, there are some major issues raised in the testimony which have direct bearing on your consideration of the Pilgrim i
ETEs, and which are addressed here.
Simulat ton of _ Normal Behavior The Seabrook ETEs are the result of simulation of normal travel behsvior.
Effects of potential abnormal or unstable travel behavior in highly congested and stressful situations were not taken into account.
Dr. Ceder points out that only one driver needs to behave in an unstable manner to create a significant disturbance for a long line of vehicles (e.g., a single impatient vehicle occupying part of an intersection and thereby reducing intersection capacity significantly for the cross-flowing traffic).
Dr. Ceder also points out that more traffic accidents are likely to occur during an evacuation, because the traffic safety circumstances during the evacuation process are, in his view, analogous to the circumstances which commonly exist during roadway construction / maintenance work, and that traffic incidents such as
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vehicle breakdowns due to overheated engines, empty gas tanks, or mechanical failures are very likely to occur during the evac-uation.
Dr. Ceder concludes that these traf fic accidents and traf fic incidents will cause additional delays for the evacuating traffic.
l Dr. Adler goes one step further and raises the question of
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whether people will stay with or abandon their cars if circumstan-ces make auto travel considerably slower than walking.-
It is likely that at least some of the events described above would occur during an evacuation.
However, there are no empirient data to quantify the probability of their occurrence and the severit.y of their ispacts.
Therefore 4 "what-if" analysis is appropriate.
It is suggested that KLD Associates develop Pilgrim e
ETEs for a range of reductions in roadway capacity for a selected I
scenario.
Trips f rom Work to Home
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The return-hose-f rom-work tri the Evacuation Planning tone (EPZ)ps by employees who reside in were not included in the trip
'l assignsvnt/ simulation models for the ETEs.
The effects of these trips were implicitly considered by assuming that the capacity of i
two-way road section will be reduced to a level corresponding to a 904/10% split of evacuating vs. returning traffic.
Dr. Adler O
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Buzz Hausner
~3-Noveabar 19, 1987 suggests that these work-to-home trips should be explicitly modeled.
As you may recall, this topic is discuss ed in my
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september 8, 1987, memorandum to Dr. Michael D. Meyer of the MDPW.
It is recommended that a sensitivity analysis be performed by including these trips in the trip assignment / simulation process for one of Scenarios 3 through 7, to determine the effect of these t r ip on the ETEs.
ppparent_ Errors 0:. Adler points out two apparent errors in the modeling pro-ac, one error 3s in the calculation of the capacity of freeway ampe under congested Clow conditions (service volume at level of n,;.- *).
While the documentation says that the volume at level i
of serv' 4 F is assuat$ to be 85% of the volume at level of ser-vic E, the ac(ti31 volume used is approximately 94% of the volume at level o* service E.
It is suggested that a sensitivity analy-sie be perforced by running the model with corrected capacities for a scenario, and that the ETEs for all scenarios be manually adjusted according to che findings of that sensitivity analysis.
A second error relates to the interpolation method.
The I-DYNEV model produces the number of vehicles that have passed l
through a given area (e.g.,
the edge of the EPZ) at half-hour intervals.
An adjustment procedure is necessary to determine when, during the last 30-minute intarval, the area actually cleared.
KLD Associates performed the interpolation for all C
exiting roads combined instead of interpolating individual roads separately and choosing the maximum value.
As a result, the ETE i
computations are biased on the low side by as much as 25 minutes.
'The Pilgrim ETEs should be corrected.
The correction work does not require running the model.
l Concluding Remarks The recommendations made here are focused on (a) correcting apparent errors, (b) refining the modeling process where the model may have been over-si mpli fied, and (c) per f orming li mi ted what-i f analyses for uncertainties during the evacuation.
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It is suggested that any time and etfort available beyond what is spent on the above recommendations would be best utilized j
f in refining the Pilgrim traf fic-management plan.
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j Sincerely, e n r & d h.t y i
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Yong 5. Chang 1
Technical Director g
YBCapak p
l cc Dr. Michael D. Meyer MDPW
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Matthew Currie, MDPW l
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