ML20154E256
| ML20154E256 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 06/13/1974 |
| From: | Feldmann M BOSTON EDISON CO. |
| To: | US ATOMIC ENERGY COMMISSION (AEC) |
| Shared Package | |
| ML20154D739 | List: |
| References | |
| FOIA-88-198, RTR-REGGD-01.007, RTR-REGGD-1.007 NUDOCS 8809160270 | |
| Download: ML20154E256 (1) | |
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office of Regulation i
U.S. Atoe.ic Energy Cor.ission We.shington, D.C.
20545 Dochet No. 50-293 Licerde !!o. DPR-35 Arr.er.dr.ent lio. 2
Dear Sir:
We are hereby advisird you thst we have suspended further work on the Contain.ent Ate: spheric Dilution (CAD) Sys;e.
d=**> ited in A Mnd ert 35 te a i r 1 ~ 1 ? ?.'.?.. Thi: :t f :r.1: t:.h:r. ;;r.iit, t'..: c:.C t. ' t r. Lo L u i..t m eaa Guide 1.7, Centrel of Cochustible Ge.s Cen.:entratier.s in Contair. rent Follow-ing a Less of Ceciant Accident, which is no,7 ur. der censideration by the AIC staff. After issuance of the revised Reguir. tory Guide, the pro.r.osed CAD syste. vi]l be reevalueted and codified as appropriate.
Should you hsve further questions regsrding this ts.tter, please contact US.
Very truly yours, Q
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E. F. Kearney
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g REASON: PhCPOSEC CIVIL PENALTY EOSTON EDISON COMPANY, PILO:IT I ig i
NUCL.AR GE','IR A T ING ST A TI ON : EA '!UM~i; 31-53 LOCKET NU/,Sif 5:-i93:
LICENS~ NUX:EE ?!?.-35 B
THE.'.A3SACHUe IT5 EXECLIIVE OFFICE OF ENERGY RESOURCES (ECE > A PETITIO" TC INTERVEN! IN THE ASCVE REFERENCEO PE00EEDING, t. U E 3 7 ! " "
E INT:.. ALIA T r. - ? A Y.. :.:
OF TH; 5550,000 PROPC3E3 CIVIL ?;. ALTY 5Y 50STON E0130' COMPANY EE ST AYED U"TIL NRC DEP03! ION OF ECEF 'C h
PETITIO" FC ALT E.:':'.IIVE U3E CF THE PP CCEEDS OF PENALTY P A Y E':TS C -
h PAY."E1TE XADI 11 LIEU OF THIS PENALTY. E0ER STILL PRESSES THAT PII IT IO.1 H3' iVIE ECE.13 AWARE T HAT PAYMikT OF T HE PFCPG3EJ PE N ALTY
- 'AY B E IN PECC.:.E55. ZCih HERESY REQUESTS THAT FUETHEE PFC;EII'.1^ CF PAYdD.T OF SAIL PENALTY LY 303 TON EDIStn' COMPANY AND THE NRO A::
DEPOSIT OF 5AI; PAYnE.tT5 IN THE U.S. TRE ASURY BE STAYED U,':TIL DEPOSITION OF EO R'S PETITION. RECEIPT OF FUNDS IN THE.U.S. IFsA50RY MAY OPERATE TC RESTRAIN NRC, DISCRETION AS TO USE. 0F PENALTY P AYMENT' 0?. P AY.9c;ll o 14 LI U CF THE PINALTY A3 REQUESTED IN E0ER'S PETITIC:;.
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JCHN DESMUND E53 SOSTON EDISON COMPANY i
Ilg SINCERELY F AT XE'iNY GENER AL COUN3EL EXECUTIVE OFFICE OF ENERGY RES00RCEi B
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_0ctober 19. 1979 L".".7,$,' *,*[.','
BECo Ltr. #79-207 wese.........-2 e...,-i-,
Mr. Thomas A. Ippolir., Chief Operating Reactors Br:nch #3 Division of Operating Eeactors Of fice of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission License No. DPR-35 Washington, D. C.
20555 Docket No. 50-293 Containmer.t Atmospheric Control System Ref:
(a)
NRC Letter T.A. Ippolito to C.C. Andognini dated 3/14/79.
(b)
BECo Letter C.C. Andognini to T.A.
Ippolito dated 6/6/79.
Dear Sir:
In Reference (a) you reouested that we submit a schedule for the f r.s t a l l a t ion and the testing of a CAD System at Pilgrim Station Unit #1m Your inquiry also requested a detailed description ot any design changes that we propose to make
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in our vciginal syste~. description (FSAR subolttal, A=endeent 35).
In Re ference (b), we inforced you that our current plans do not call for the installation of CAB System and that se were evaluating a systen that incorporates hydrogen reco 5ina:fon capability. Therefore, we reauest that you delete FSAo,
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7ce nd _ent M troa our cocket.
To determine what ch-ag;s are currently required for post LOCA contain~ent cc:bustible gas control, we have evaluated the present station design with respect to 10CF350.40.
Bytueen our analysis, we comtv vich 10CFR50.44_
vith existing equipeent.
However, we recognize that additional system codi-tications esy be appropriate once the TMI-2 Lessons Learned Task Force has cc pleted its lor'3 ter.s reco mendations.
As described in its sNe t term recotmendations (hvRIC-0578), the TMI-2 Lessons Learned Task Torce majority view was that the existing design basis for coc-bustible gas control syste=s needs re-evaluation. We are therefore, unable to co.uit to any syst e. design changes for cocbustibt? gas control at Pilgrim, until a final resolution is issued by the Co. r_ission on the systes design bases.
Re ever, we have revised our operating procedures, as necessary to mitigats the consequences of a TMI type incident in the unlikely event that it occurred and as stated in Reference (b), we vill contii ue to operate with an inerted contain-me.t.
If you have any questions on this subject, please feel f ree to contact us at 0
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ANALYSIS OF EMERGENCY PREPAREDNESS ISSUES AT PILGRIM NUCLEAR POWER STAT (0N RAISED i
IN A PETIT!UN TO THE NRC VATED JULY 15, 1986 JULY 29,1987 l
FEDERAL EMERGENCY MINAGEMENT AGENCY JOHN W. McCORMACK POST OFFICE AND COURTHOUSE BOSTON, MASSACHUSETTS 02109-4595 k
TABLE OF CONTENTS EMi SECT ION 1 - IPT R00VC T 10N..........................
1-3 SECTION 11 -
SUMMARY
..............................'3-4 SECT ION 111 - F EMA AN ALY S is.......................
5-49 APPENDICES:
PREPAREDNESS ISSUES 1
ANALYSIS REPORT OF EMERGENCYPOWER STATION HAISE AT PILGRIM NUCLEAR (MASSPlHG)
MASSACHUSETTS PuBLIC INTEREST GROU?
FEMA, NOVEMBER 6, 1983 ISSUES RELATED To THE P!LGRIM 2
ANALYSIS REPORT ONIIME ESTIMATE FOR PILGRIM NUCLEA STATION, PLYMOUTH, MASSACHUSETTS, FEMA, MAY 1, 1984*
LVACUATION (MCUA) ANALYSIS 3
MASSACHUSETTS CIVIL DEFENSE AGENCYINTERCST RESEARCH Group TO THE MASSACHUSETTS PusLIC (MASSPlkG) REPORT ' BLUEPRINT
,'OR CHAOS 11", JULY 20, 1983 4
1986 EMERGENCY PUBLIC INFORMATION (EPI) BROCHUR P!LGRIM EPZ 5
BOSTON EDISON'S RESPONSA ON THE PETITION DATED OCTOBER 29, 1986 I
COMMONWEALTH OF MASSACHUSETTS POLICY ON DISTRIB 6
OF POTASSIUM [0DIDE (Kl)
SEPTEMBER 5, 1986 FEMA LETTER 70 CO'*JHWEALTH OF 7
ITS VIEWS CONCERNING MASSACHUSETTS REQUESTINGIN THE PETITION; AND INDICATING THE A(LEGATIONS THAT rEMA WAS UNDERTAKING A SELF-INITIATED REVIEW OF THE ABILITY OF THE STATE TO PROTECT THE PUELIC IN THE EVENT OF AN ACCIDENT AT P!LGRIM i
1 INIK00VLT10N 3TATd 3ENATOR GOLDEN, 13, 193b, MASSACHUSETTS THE nASSACHUSETTS ON JULY HYNES AND MILOT, STATE SEP1ESENTATIVES (MASSPlHG), THE PLYMOUTH
.ESEARCH 6ROUP i
SUBLIO INTE9EST INC. (PCNIC), THE INFORMATION COMMITTEE, Jo ANN SHOTWELL AND JAMES COUNTY NOCLEAR ALLIANCE AND ATTORNEYS THE NUCLEAR REGULATORY COM-PLYMOUTH PETITION w!TH 3HANNON FILED A THE NRC (SSUE REQUESTED THAT (NRC).
THis PETIT 10N MISSION (DISON COMPANY, TO THE 50STON AN ORDE4 THE PILGRIM l CAUSE A$ 70 W"HY 90 DER 3 TAT 10N ( P!LSRIM") SHOULD
...T0 SHOW HAVE 175 OPERATING NUCLEAR 4EMAIN CLOSED AND/0RTHE NKl UNLESS AND NOT LICENSE SUSPENDED BY THE LICENSEE DEMON-THAT TIME AT wHICHTO THE NKC AND THE UNTil IS NO LONGER STRATES CONCLUSIVELYITS MANAGEMENT THE THAT PUBLIC: (1) THE DEFICIENCIES NOTED BYTHAT T HAMPERED BY (2) 10 PETIT 10NERS, FULLY COMPLIES WITH MESPONSE PLAN CFh i3047 AND 10 (FR 550 57, l$ GIVEN HIGHAND SUFFICI GENCY PRIORITY MANAGE-ORGAN!!AT10NALTHE LICENSEE, THE FEDERAL EMERGENCY BY (FtMA),
GOVERNMENTS; MENT AGENCY (MCDA) AND 10CA'.
DEFENSE AGENCY INHERENT DESIGN FLAWS THE RENDER PILGRIM THAT AND (3)
THE PETIT!UNERS dHICH l*$ CONTAINMENT STRUCTURE EXTREMEL NOTED BY E
70 THE EXTENT THAT THE PUBL SAFETY wlLL BE ASSURED.
NRC FORWARDED A COPY OF THE PET ON AUGUST 11, 1986, REVIEW.
THEN, ON INFORMATION AND INITIAL TO FEMA FOR REQUESTED THAT FEMA EVALUATE I
OCTOBER 16, 1986, NRC FORMALLY ISSUES PLANNING AND PREPAREDNESS THE OFF-SITE EMERGENCY REPORT OF THAT EVALVA-IHIS !$ A RAISED IN THE PETITION.
TION.
1-c y
. IN EMER-IDENTIFIED SEVEN ALLEGED DEFiclENC;3S IHE PETITION GENCY PLANNING (LISTED AS NUMBERS 14 THROUGH 2 i
T10N) AS FOLLOWS:
THE RADIOLOGICAL EMERGENCY 14 UEFICIENCIES IN RESPONSE PLAN (KtKP) 15 DEFICIENCIES IN ADVANCE [NFORMATION ACCIDENT 16 DEFICIENCIES IN NOTIFICATION D,URING AN 17 UEFICIENCIES IN EVACUATION PLANS 18 UEFICIENCIES IN fled! CAL FACILITIES 19 THE EMERGENCY PLANNING 20NE IS 700 SMALL^
20 LAC < OF COORDINATION AND PRIORITIZATION OF THE KERP A LETTER (SEE APPENDIX 7)
ON SEPTEMBER 5, 1986, FEMA SENT MASSACHUSETTS CIVIL DEFENSE TO ROBERT BOULAY, DIRECTOR, AGENCY WITH A COPY TO BOSTON EDISON REQUESTING CONCERNING THE ALLEGATIONS IN THE PETITION AND FUR PLAN DEFICIENCl.ES DEVELOPMENT OF PROCEDURES FOR CORRECTING ANY FEMR ALSO SENT A LETTER TO SENATOR GOLDEN WHICH MAY ExtST.
REQUESTING A TRANSCRIPT OR DETAILED NOTES OF A JUNE 18,
RESPONSE
MEETING AT THE STATE HOUSE CONCERNING THE EMERGENCY PLANNING ZONE, PLANS FOR THE P!LGRIM PLUME EXPOSURE EMERGENCY WHICH WOULD HELP US IN OUR REVIEW OF THE PETITION.
l IHE BOSTON EDlSON COMPANY PROVIDED INFORMATION BOSTON EDISON'S WRITTEN RESPONSE 15 VIEWING THl$ PETITION.
ATTACHED AS APPENDIX 5 THE STATE INDICATED THAT IT HAD NO i
3-NO TRANSCRIPT WE UNDERSTAND THAT COMMENTS ON THF. PETITION.
AND FEMA HAS, THE MEETING AT THE STATE HOUSE, dAS MADE OF ITS OWN NOTES AND RECOLLECTIONS OF THE THEREFORE, REllED ON MEETING.
IME ANALYSIS OF THESE ISSUES WAS PREP LABO R AT O RY, SASED THE ARGONNE NATIONAL THE ASSISTANCE OF alTH CONCERNING THE CONTENTS OF INPUT FROM MASSACHUSETTS UPON ORAL INPUT JROM MASSACHUSETTS PREVIOUS WRITTEN AND ORAL THE PETITION; RESPONSES PREPAR-THE PETITION; CONCERNING THE ISSUES COVERED BY PLhA REVIEWS OF PREVIOUS NASSPlKb PETITION; ED BY PtMA TO A EXERCISE REPORTS FOR THE EXERCISE MASSACHUSETTS RERP; AND OF THE RESPONSE PLANS FOR THE PILGRIM OF THE MAD 10 LOGICAL EMERGENCY 1982, 1983, AND 1985 ON DECEMBER 30, NUCLEAR POWER STATION IN REPORT CONCERNING THE MAS $*-
OF A 1986, FEMA WAS PROVIDED A COPY Z
THE PLANS TO PROTECT THE PUBLIC IN THE PILOR CHUSETTS AND ENDOR-l THE SECRETARY OF PUBLIC SAFETY REPORT WAS PREPARED BY
{ HEREINAFTER CALLED THE MASSACHUSETTS GOVERNOR DUKAKIS SED BY THE BARRY REPORT AND ALL OTHER RELEVANT FACTORS BARRY REPORT).
IN BOSTON, UUX8URY, AND INPUT FROM PUBLIC MEETINGS INCLUDING A MEETING WITH A AEPRESENT ATIVE OF THE
- PLynouTH, l
INC., AS WELL AS ADDITIONAL ANAL-INFORMATION COMMITTEE, NUCLEAR ALYZED YSIS SY FEMA STAFF AND CONSULT ANTS HAS BE OF THE MASSACHUSETTS RADIOLCGICAL AS PART OF THE ATTACHED REY!EW PLhNS FOR PILGRIM WHICH FEMA INITI ATED l
I
y 11
SUMMARY
IHE DETA! LED ANALYSIS OF ISSUES RAISED IN THE july 15, 1986 PETITION 15 PRESENTED IN $ECTION lll.
10 S T OF TME !SSUES RAISED IN THE 1986 PETITION ARE ESSENTIALLY IDENTICAL T SUBMITTED TO THE NRC IN 1983 8Y ISSUES RalSED IN A PETITION MASSPIRG, AND 70 ISSUES PREVIOUSLY EXAMINED BY NHC AND FEM 3ASED ON A PREVIOUS ANALYS!$ BY FhMA, THE NKC DENIED THE s
1983 MASSPIRG PETITION ON FEBRUARY 27, 1984 Fi.1A REvlEnED THIS NEw PETITION IN LIGHT OF THE STATE RECORD AT T*E TIME OF ITS SUBMITTAL AND INFORMATlor4 TO EOIA AS OF 'iOV E M B E R, 1986 UUR REVIEW WAS LARGELY COMPLETED BY DECEMBER :9, 1986 FEMA DEALT WITH LATER INFORMATION INCLUD-ING FEMA STAFF ANALYSIS OF PUBLIC AND I NT'iR AGE NCY ME ET I NGS THE BARRY REPORT, IN ITS SELF*lNITIATED REVIEW.
IT SHOULD BE WHILE FEMA'S ANALYS!$ OF THE SEVEN AL-l NOTED, M0 WEVER, THAT, LEGED DEFICIENCl!$ [N OFF-SITE EMERGENCY PLANN!NG IND THAT THE INFORMATION IN THE PETITION D10 NOT SUSTAIN TH TENTIONS 3ASE3 ON THE STATE OF THE RECORD AT THE TIME THE GENERAL THRUST PETITION wAS REVIEWED, FEMA AGREES WITH UF SOME OF THE CONCLUSIONS OF THE PETITION FUR THE R CITED IN ITS SELF-lNITIATED REylEW AND INTERIM FlHDING DATED JULY 29, 1987 IME FEDERAL EMERGENCY MANAGEMENT AGENCY WILL CONTINUE REVIEW AND ANALYZE THE STATUS OF EMERGENCY PLANN!N VICINITY OF ALL NUCLEAR POWER PLANTS, INCLUDING P!LomlM, TO INSURE THAT A CORRECT ANALYSIS OF 0FF-SITE EMERGEN
!$ PRESENTED TO THE NUCLEAR REGULATORY COMMIS$10N.
5-111 AN ALYSIS FEMA HAS ADDRESSED EACH OF THE SEVEN ISSUES IN OFF-EMERGENCY PLANNING RAISED IN THIS PETITION BELOW.
14/ UEFICIENCIES IN THE KAD10 LOGICAL EMERGENC (MERP)
PETITIONERS:
SERIOUS DEFICIENCIES EXIST IN THE RERP, FOR PILGRIM, WARRANT-THE EDISON'S OPERATING LICENSE BY ING SUSPENSION OF DOSTON NRC.
IHE DEFICIENCIES ARE OUTLINED BELOW.
!HE COMBINED TO ABROGATE THE "REASONABLE IS THESE DEFICIENCIES BE ADEOUATE PROTECTIVE MEASURES CAN AND WILL EFFECT OF THE EVENT OF A RADIOLOGICAL EMERGENCY," THE STAND-ASSURANCE THAT TAKEN IN 10 CFR 5:0 47 ( A)(1).
ARD SET BY FEMA:
OF THE PETITIONER'S ALLE-FEMA HAS PROVIDED RESPONSES TO EACH GATIONS.
IHESE RESPONSES ARE GIVEN BELOW.
13/ DEFlclENCIES IN ADVANCE lNFORMATION A) PETITIONERS:
IHE ONLY METHOD BEING USED FOR ADVANCE PUBLIC EDUCATIO IN THE PILGRIM EMERGENCY PLANNING 40NE (LPZ) IS THE DIS TION OF PAMPHLETS BY MAIL.
A MASSPlkG TELEPHONE SURVEY CON-DUCTED IN 1983 REVEALED SERIOUS INADEQUACIES IN'THE D T10N, RETENTION, AND UNDERSTANDING 0F THE PAMPHLETS BY AREA i
NO IMPROVEMENTS IN THE ADVANCE INFORMATION PROCE-RESIDENTS.
DURES NAVE BEEN CARRIED OUT SINCE 1983 1
i FEMA:
IN THE PETITION OF THE MAS $-
IHis !$$UE WAS RAISED PREVIOUSLY FOR EMERGENCY AND ACHUSETTS PUBLic (NTEREST RESEARCH GROUP MASSPIRG WITH THE NRC ON JULY 20, KEMEDIAL ACTION FILED BY 1983 NO SUBST ANTIVE NEW ISSUES ARE RAISED BY THE CURRENT (APPENDIX 1)
J IN RESPONSE TO THE 1983 PETITION PETITION.
FEMA STATED:
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PUBL(C {NtoS-ENTITLED "EMERGENCY AND ANSWERS IWO PAMPHLETS QUESTIONS MATION" AND "NUCLEAR ENERGY THE LPl IN bEPTEMBER RESIDENTS IN THE PAMPHLETS WERE MAILED TO ALL 1982 lN ADDITION, ESTABLISHMENTS AND 1931 AND SEPTEMBER OVER' IAL dERE DISTRIBUTED TO COMMERCTHE EPl, INCLUDING HOTELS.
IN DISTRIBUTED IN PUBLIC BUILDINGS BROCHURES HAVE BEEN55,000 POPULATION AND 20,000 120,000 0F BOTH AN AREA 0F APPR0xlMATELY EMERGENCY INFORMATION DEPICTING 1982 IN THE EPl SINCE OCTOBER POSTEAS HOUSEHOLDS.
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HAVE BEEN DISPLAYED A POLL THAT INFORMATION WAS DER!VED FROMTHESE RES IN THE AREA.
MA$$PlRG'S A SUB-SOME OF HAVE RECEIVED EPl BROCHURES, REMEMBERED THEY CONDUCTED OF WHEN ASKED IF THEY THEY STANTIAL 70 RESPONDED THAT THEM.
THOSE POLLED SAID THAT 9% OF MAS $9.lRG ALSO REPORTS lbS RADIO STATION AS A FIRST TO AN AND AN ADDITIONAL 19%
WOULD TUNE TO
- EARING THE SIRENS, dHlCH ARE REASON
- THEY WOULD TUNE TO RADIO OR IV, BOTH OF 4EACT10N ASK 9AS$PikG D10 NOT RESPONSES.
AS THE SIRENS ABLE AND APPROPRIATE SOME REFLECTION PEOPLE *0ULD 00 UPON dHAT CONTINUED TO SOUND.
AND CAN BE PUBLIC ADDRESS CAPABILITYTO THE PUBLIC, EACH $1REN HAS A SPECIFIC INSTRUCTIONSAND THl$ SHOULD USED TO BROADCAST EMERGENCY EFFORT.
IN AN THE PUBLIC EDUCATION INCLUDING TRANSIENTS, OF BE CONSIDERED TO BE PART VEHICLES AL30 ARE EculPPED AND $7 ATE PUBLIC S AF ETYMESSAGES WILL BE BROA OVER LOCAL PA CAPABILITY.
SYSTEMS TO TUNE TO THE EBS STATIO SHOULD BE SUFFICIENT TO AfD RES!-
w!TH THESE PUBLIC ADDRESS IH!S INFORMATION.
AN EMERGENCY.
FOR IN DENTS AND TRANSIENTS PEMA DETERMINED IN 1983 THAT THE PE THE HEALTH AND WAS UNABLE TO PROTECT THE COMMONWEALTH IHE MASSPIRG PETITt0N W AS DENIED BY THAT SAFETY OF THE PUBLIC.
UNDER 10 CFR THE *!NTERIM OtRECTOR'S DECISION f
THE NRC IN SINCE.THAT TIME THE 2 206", FEBRUARY 27, 1984
- HowEvER, TS PUBLIC NAS TAKEN ADDITIONAL. STEPS 70 ENHANC COMMONWEALTH PROGRAM.
INFORMATION PROVIDED BY MCDA AND THE BOSTON 1
ACCORDING TO INFORMATION f
\\ N
EDISON COMPANY, THE ANNUAL PUBLIC E'DUCATION BROCHURE ENT!-
i TLED "EMERGENCY PUBLic INFORMATION: WHAT TO DO IN CASE O AN EMERGENCY AT PILGRlM NUCLEAR POWER STATION" (AP W AS MA! LED TO RESIDENTS, HOTELS AND MOTELS, AND PUBLIC BUILD-IN THE PLUME EXPOSURE EMERGENCY PLANNING 20NE (
INGS AUGUST 1986 (SEE APPENDIX 5).
BROCHURES WERE ALSO MAILED TO RESIDENTS IN 1985 THE 1986 BROCHURE IS IN COMPLIANCE WITH THE GUIDANCE PROVIDED IN NUKEG-Ubb4, FEMA-REP-1, HEV 1, "lRI' illa FOR PREPARATION AND LVALUATION OF KAD10 LOGICAL LMERGENCY RESPONSE PLANS AND PREPAREDNESS IN S U P P O NUCLEAR F0WER FLANTS."
lHE CURRENT BRUCHURE CONTAINS THE FOLLOWING INFORMATION:
EDUCATIONAL INFORMATION ON RADIATION;
- DESIGNATION OF RADIO STAfl0NS FOR EMERGENCY PUBLIC INFORMATION; PROTECTIVE MEASURES (1.E.,
SHELTERING, RESPIRATORY PROTECTION, EVACUATION ROUTES, AND WECEPTION CENTERS);
AND A RETURN POSTCARD AND INSTRUCTIONS FOR PERSONS WITH SPECIAL NEEDS SO THAT ARRANGEMENTS CAN BE MADE TO PROVIDE APPROPRIATE TRANSPORTATION IN THE EVENT OF AN EVACUATION.
s FEMA SPONSORED A STATISTICALLY VALID SURVEY AFTER BER 29, 1986 TEST OF THE P!LGRIM PUBLIC ALERT AND NOTIFICA-T10N SYSTEM.
IHE SURVEY INDICATED THAT 72 8% OF THE PEOPLE REMEMBER RECElvlNG THE PUBLIC INFORMATION BROCHURE.
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FEMA, THEREFORE, CONCLUDES TH AT THE PETITION DOES NOT PROVIDE INFORMATION WHICH SU$iAINS THE CONTENTIONS.
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B) PETITIONERS:
NO INFORMA-1985) PAMPHLETS CONTAIN FOR PURPOSES OF EVACUA-(SEPTEMBER IHE CURRENT PUBLIC TRANSPORTATIONTHE RADIOLOGICAL EMERGE T10N REGARDING T!ON, DESPITE THE FACT THAT (KERP) FOR THE IOWN OF PLYMOUTH PROVIDE TRANSPORT-
"$TAGING AREAS" WHERE PERSONS WITHOUT SPONSE PLAN PUBLIC TRANSPORT.
BE DIRECTED FOR "POSSIBLE" THIRTEEN ATION WILL
~
FEMA:
THE "PETITION OF THE MASS-IN RAISED PREVIOUSLY IMIS ISSUE WAS 6ROUP FOR EMERGENCY AND ACHUSETTS PUBLIC INTEREST HESEARCH THE NKC ON JULY 20, ACTION" FILED BY MASSPlx6 WIT.H REMEDIAL 1963 NO SUBSTANTlvE NEW ISSUES ARE RAISED IN PETITION.
RESPONSE TO THE 1986 PETITION:
INE LOMMONdEALTH STATED IN ITS (APPEND!X 3)
POST OFFICES, FIRE PLANS UTILIZE LISTINGS OF RECOGNIZABLE LOCAL SCHOOLS AND OTHER WELL KNOWN,
' STAGING AREAS.'
ALTHOUGH LOCAL RESIDENTS I
- HOUSES, WE ARE STUDYING THE SITES FOR ARE WELL AWARE OF THESE SITES, FUTURE PUBLICA-USE OF MAPS AND MAY !NCLUDE THEM IN T10NS.
(APPENDIX 1)
ITS RESPONSE TO THE 1983 PETITION:
FEMA STATED IN PROVISIONS IN PUBL tc TQ ANspomTat t0M - IHE LACK OFTRANSPORTATION NOT THE PLANS FOR OTED AS A DE-HAVE ACCESS 70 CARS WAS PREVIOUSLY NREVIS!NG TH FICIENCY AND THE STATE IS TRANSPORTATION HAVE, SPECIAL NO REQUESTS FORBEEN REGISTERED WITH PLYMOUTH INGLY.
SOLICITED.
TO DATE, INFORM AT ION H AS BEtt; ALTHOUGH SUCH IN IHE 1986 PUBL'lC INFORMATION BROCHURES DIREC
) TO RETURN THE NEED OF TRANSPORTATICN OR OTHER SPECIAL HEL II HEADQUARTERS POSTCARD FOUND IN THE 8ROCHURE TO MCDA AREA TO CALL THElR TOWN HALL OR CIVIL DEFENSE O OR ERGENCY.
i AS POS$18LE TO ARRANGE FOR ASSISTANCE BEFOR
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EMERGENCY, THEY ARE TO IF PEOPLE NEED AS$1 STANCE DURING 'AN CALL THE LOCAL CIVIL DEFENSE OFFICE.
IHE LOCAL PLANS SPECIFY BE USED TO MOVE THOSE dlTHOUT THAT CONTRACTOR SCHOOL BUSES MAY PERSONAL MEANS OF TRANSPORTATION.
IF NEEDED, ADDITIONAL BUSES (OR OTHE9 MEANS UF MASS TRANSPORT) w!LL BE RE THE MASSACHUSETTS Civil DEFENSE AGENCY '(MCD HEAD-QUARTERS.
IHE COMMONWEALTH OF MASSACHUSETTS HAS IDENTIFI STATE CONTROLLED RES,0VRCES CLAN A VAST NUMBER OF lN ITS ATATE AVAILABLE lN THE EVENT OF AN ACCIDENT AT PILGRIM.
BUSES WILL BE ACTIVATED AT 9REDETERMINES STAGING AREAS FOR THE DIRECTOR OF CIVIL DEFENSE (CD) AS THE SITES SPECIFIED BY SITUATION REGUIRES.
PLYMOUTH HAS IDENTIFIED 13 STAGING AREAS wHERE THOSE PEOPLE IN NEED OF TRANSPORTATI TO OBTAIN PUBLIC TRANSPORTATION.
[F AN EVACUATION WERE TUNED TO RADIO AND PEOPLE 'a0VLD EE ADV I S ED TO ST AY
- ORDERED, THE PLYMOUTH IV FOR INFORMATION REGARDING THE EVACUATION.
CIVIL DEFENSE DIRECTOR IS RESPONSIBLE FOR COORD MC0A AREA 11 HEADOUARTERS TO ASSURE THAT INFORMA INNEEDOFTRANSPukTA-ING THE ARRANGEMENTS FOR THOSE PEOPLE T10N ARE CONTAINED IN EBS MESSAGES.
l DOES NOT PRO-FEMA, THEREFORE, CONCLUDES THAT THE PETITION VIDE INFORMAT10N WHICH SUSTAINS THE CONTENTION.
10 -
C) PETITIONERS:
IME ADVANCE INFORMATION SYSTEM FOR TOURI NONEXISTENT.
FOR EXAMPLE, NO INADEQUATE OR INFORMATION POSTED TO PROVIDE APPROPRIATETHE NKL IN IV L TRANSIENTS IS SIGNS HAVE BEEN A MEASURE SUGGESTED BY FOR TRANS!ENTS, PART 50, APPENDIX E. IV.0 2 FEMA:
THE "PETITION OF THE IN IHis ISSUE W AS RAISED PREVIOUSLY j
INTEREST RESEARCH OROUP FOR EMEPGENCY MASSACHUSETTS PUBLIC AND REMEDIAL ACTION" FILED BY MASSPIRG ISSUES ARE RAISED IN JULY 20, 1983 NO SUBSTANTIVE NEW THE CURRENT P ET I T 10 N.
~
RESPONSE TO THE 1983 PETITION:
THE (QMMONWEALTH STATED IN ITS (APPENDlX 3)
AND ARE AVAILABLE POSTERS HAVE BEEN DISTRIBUTED,lHE hP1 PAMPHLETS INCLUDE RE THROUGHOUT THE LPl.
PUBLIC INFORMATION STICKERS AND INE SIREN MOVABLE EMERGENCYO!STRIBUTED (SEE ENCLOSED).
HAVE ALSO BEENINSTALLED THROUGHOUT THE EP PUBLIC ADDRESS CAPABILITY WHICH WOULD SE U SYSTEM EMERGENCY INFORMATION.
LOCAL PROVIDE TRANSIENTS WITHAND STATE PUB WITH P A CAP ABILITY.
(APPENDIX 1) STATED:
FEMA'S RESPONSE TO THE 1983 PETITION PUBLIC INFORMATION" IWO PAMPHLETS ENTITLED "EMERGENCY AND "NUCLEAR ENEROY IN THE EPZ IN SEPTEMBERTHE PAMPH To ALL RESIDENTS TEMBER 1982 IN ADDITION, f
UTED TO COMMERCIAL (STABLISHMENTS AN OvER 120,000 0F 80TN IN THE EPl, INCLUDING HOTELS.
BROCHURES HAVE BEEN DISTRIBUTED IN AN AND 20,000 HOUSEHOLDS.
IMATELY 55,000 POPULAfl0N INFORMATION HAVE BEEN Dis-POSTERS DEPICTING EMERGENCYPLAY PRESENTED TO FLMA SY BOSTON LDISON, ACCORDING TO INFORMATION i
l i
11 -
FOR THE >!ASSACHUSETTS (!Vl(
WHO DISTRIBUTE ini BROCHURES PUBLIC INFORMATION BROCHURES WERE DEFENSE AGENCY,' EMERGENCY LIBRARIES, AND DISTRIBUTED TO HOTELS AND MOTELS, RECENTLY
~
AND PLACARDS WERE POSTED AT VARIOUS TOWN DFFICES IN THE AREA, BOSTON EDISON, LOCATIONS THROUGHOUT THE LPl (SEE LETTER FROM b).
DATED OCTOBER 29, 198D, APPENDlX FEMA, THEREFORE, CONCLUDES THAT THE PETITION DOES NO SUSTAINS THE CONTENTluN.
INFORMATION WHICH D) PETITIONERS:
INFORMAfl0N SYSTEM v10LATES 10 CFR INE INADEQUATE ADVANCE 10 CFR PART 50, APPENDIX E. IV U.2,54AND 550 47 (B)(7);
NUREG-06 EV ALU ATION CRITERI A G 1, G 2 AND P.10 0F FEMA:
I FEMA HAS RESPONDED TO THIS ISSUE IN ITEMS A,
B, AND C ABOVE.
lb/ UEFICIENCl!$ If4 NOTIFICATION UURING AN MCCIDENf A) PETITIONERS:
INADE-SYSTEM AND BACK-UP SYSTEMS ARE IHE WARNING SlREN INITIAL NOTIFICAT!UN OF QUATE TO ESSENT! ALLY COMPLETE THETH WITHIN FIFTEEN' MINUTES, AS PLANNING 40NE (LPl)10 CFR PART 50, APPENDIX E.,
IV. D.3 FOR GENCY PLAGUED WITH FALSE REQUIRED BY EXAPPLE, THE $1REN SYSTEM MAS BEEN THE RESPONSE RATHER THAN CORRECT THis PROBLEM, SYSTEM DURING ELEC ALARMS.
HAS BEEN TO DISCONNECT THE SIREN STORMS.
g
12 -
FthA:
IN THE "PETITION 09 THE RAISED PREVIOUSLY THIS ISSUE WAS MASSACHUSETTS PUBLIC lNTEREST HESEARCH 6R THE NRC ON AND REMEDIAL ACTION" FILED BY MASSPlHG WITH r
JULY 20, 1983 No NEW SUBSTANTIVE ISSUES ARE RAISED IN CURRENT PETITION.
SYSTEM EXPERIENCED FALSE WHILE THE ALERT AND NOTIFICATION BOSTON EDISON ALARMS FOR SOME TIME AFTER ITS INSTALLATION, IMPROVEMENTS IN THE SYSTEM.
EXAMINED THE PROBLEM AND MADE fHE ALERT AND NOTIF-FEMA'S REvlEW OF THE S!REN TEST RESULTS, f
AND OPERATIONAL RECORDS PROVIDED BY ICATION SYSTEM DESIGN THls PROBLEM DOES NOT INDICATES THAT 30STON EDISON LOMPANY f
SE9.)
(ALSO SEE APPENDlx 5, PAGE 8, ET.
NOW EXIST.
THAT THE PETITION DOES NOT PROVIDE flhA, THEREFORE, CONCLUDES SUSTAINS THE CONTENTION.
'INFORMATION WHICH B) PETITIONERS:
AUDIBLE WITHIN LARGE BARELY IHE SIRENS ARE INAUDIBLE OR THE PILGRIM NUCLEAR POWER AREAS OF THE EPZ (HEPORTJUNE 19, 1982, FEMA, JANUARY 1983, P.6)
ON STATION SIREN IEST, OF FURTHERMORE, F,EDERAL REGULATIONS R[OUIRE NOTIFICATIO (LRITERIA J.10.C, E.6; "ALL SEGMENTS OF THE POPULATION 10 CFR PART 50, APPENDIX E, IV. D.3).
FEMA:
IN THE 'P'ETITION OF THE THIS ISSUE WAS RAISED PREvt00$LY MASSACHUSETTS Pus'LIC INTEREST RESEARCH AND REMEDIAL ACTION' FILED BY MASSPIRG w ISSUES ARE RAISED IN THE JULY 20, 1983 NO SUBST ANTIVE NEW CURRENT PETITION.
13 -
RESPONSE TO THE 1983 PETITION (APPENDIX 1)
FEnA STATED IN ITS THAT:
MASSPIRG SEEMS 70 HAVE '41$UNDERST000 THE REPORT ON THE "PILGRIM NUCLEAR POWER STATION SIREN kESPONSE EXERCISE FOR THE PILGRIM NUCLEAR POWER STATION, MARCH 3, 1982." THE FIXED SIREN SYSTEM WAS DEllGNED TO BE USED IN CONJUNCTION WITH OTHER METHODS OF
' NOTIFICATION SUCH AS MOBILE NOTIFYING TEAMS, TONE ALERT RADIOS, AND THE EBS.
FEMA IS CURRENTLY DE-VELOFING STANDARDS FOR MEASURING THE EFFECTIVENESS OF FIXED SIRENS.
HOW EV E R, THE 1982 SIREN TEST DEMONSTRATED AN IMPRESSIVE ABIL1TY TO NOTIFY THE PUBLIC USING SIRENS ALONE.
IN OUR OPINION, THE TEST ALSO DEMONSTRATED A CONTINUING NEED FOR THE OTHER FORMS OF PUBLIC NOTIFICATION THAT ARE PRES-ENTLY INCLUQED IN THE PLANS.
FLhA'S REPORT ON THE PILGRIM NUCLEAR POWER STATION SIRF,N IEST Dl0 NOT STATE THAT THE SIRENS WERE INAUDIBLE OR BARE AUDlBLE dlTHIN LARGE AREAS OF THE EPl.
PAGE 6 0F THE REPORT, l
WHICH THE THE PETITIONERS REFERENCE, DISCUSSES WHERE PLMA FEMA STATED ELSEWHERE OBSERVERS WERE LOCATED DURING THE TEST.
THAT WE CHOSE TO LOCATE THE 18 OBSERVERS IN IN THE REPORT AREAS WHERE SIREN OUTPUTS woVLD BE THE WEAKEST.
THOSE FEW IHEREFORE, dE CONCLUDED THAT THE OBSERVERS REPORTS SHOULD NOT BE TAKEN AS AN INDICATION OF WIDESPREAD PROBLEMS.
IT 15 WORTH NOTING THAT FhMA SPONSORED A TELEPHONE SURVEY IM FOLLOWING A SEPTEMBER 29, 1986 TEST OF THE PILGRIM ALERT AND NOTIFICATION SYSTEM WHICH INDICATED THAT 88 2% OF THE P ALERTED BY THE SIRENS ON THE DAY OF THE TEST.
WERE DIRECTLY fthA, THEREFORE, CONCLUDES THAT THE PETITION DOES NOT PRO-VIDE INFORMAT10N WHICH SUSTAINS THE CONTENTION.
l i
1 l
14 -
C) PETITIONERS:
INE DEFICIENT SIREN SYSTEM WOULD Fall TO WARN THE HEARING IMPA! REC; TESTlMONY AT THE JUNE 18, 198b HEARING ON THE PILGRIM XERP BEFORE MASSACHUSETTC LEGISLATORS PROVIDED NO EVIDENCE OF THE EXISTENCE 0F AN ALTERNATE PLAN FOR NOTIF1-CATION OF THIS SEGMENT OF THE POPULATION, A DIRECT v10LA-TION OF THIS STATUTORY MANDATE.
FEMA:
IHIS ISSUE WAS RAISED PREVIOUSLY IN T'HE "PETITION OF THE MASSACHUSETTS PUBLIC INTEREST 6ROUP FOR EMERGENCY AND HEME-DIAL ACTION" FILED BY MASSPIRG WlTH THE NRC ON JULY 20, 1983 NO SUBSTANTIVE NEW ISSUES WERE RAISED IN THE CURRENT PETlY10N.
IN !TS RESPONSE TO THE 1983 MASSPIRG PETITION (APPENDIX 3),
THE COMMONWEALTH OF MASSACHUSETTS STATED:
MCUA AND BOSTON EDISON HAVE WORKED WITH THE MASSA-CHUSETTS OFFICE FOR THE DEAF (MUU) AND THE DEAF LOM-MUNITY LENTER IN PRAMINGHAM, MA IN ORDER TO ADDRESS THis PROBLEM.
BOSTON EDISON OFFERED TO EQUlP HOUSE-HOLDS OF DEAF PEOPLE LIVING ALONE IN THE EPl WITH TELE-TYPEWRITER DEvlCES FOR THEIR TELEPHONE.
THIS DEVICE l$ WIDELY ACCEPTED AS ADEQUATE COMMUNICATIONS i
FOR SERV!NG A DEAF PERSON DURING AN EMERGENCY.
NEWS-LETTERS FOR THE DEAF CARRIED NOTIFICATION OF THIS PROGRAM.
NO SUCH HOUSEHOLDS HAVE BEEN IDENTIFIED IN THE P!LGRIM EPl.
FEMA STATED IN ITS NOVEMBER 3, 1983 ANALYSIS OF THE 1983 MASSPIRG PETITION (APPENDlX 1).
)
IHE COMMONWEALTH OF MASSACHUSETTS AND BOSTON EDISON HAVE WORKED WITH THE MASSACHUSETTS U#FICE OF THE DEAF, THE COUNCIL OF ELDER AFFAIR $ AND THE DEAF s
COMMUNITY CENTER IN FRAMINGHAM IN AN ATTEMPT TO IDENTIFY DEAF RESIDENTS WITHIN THE EPl.
THEY HAvt A(50 ATTEMPTED TO NOTIFY DEAF PEOPLE WITHIN THE i
EPl THROUGH NEWSLETTERS ABOUT EFFORTE TO PROVIDE
)
15 -
DEAF RESIDENTS OF THE EPZ W'ITH TELETY HOUSEHOLDS HAVE BEEN IDENTIFIED THl$ MAY BE BECAUSE MOST INDIVID-DEVICES.
NO SUCH BY THESE EFFORTS. NEEDS LIVE WITH SOMEONE AND CAN UALS WITH SPECIAL THE HOUSEHOLD IN TIMES OF RELY ON OTHER MEMBERS OFPEOPLE AND OTHER INDivlDUALS ALSO, DEAF SPECIAL NEEDS TEND TO CONGREGATE IN URB EMERGENCY.
RECEIVE SERVICES READlLY AND W I.T H AREAS WHERE THEY CAN I
THE PILGRIM EPZ IS NOT URBANIZED.
IDENTIFYING THE DEAF ARE BELIEVED CONFIDENTIAL LISTSIN A MEETING ON AUGUST 19, 1983 WITH To EXIST.
OF PUBLIC MASSPlhb, THE MASSACHUSETTS SECRETARYEXISTING LAWS TO AGREiD TO 00 RESEARCH ON
$1E IF THIS INFORMATION COULD LEGALLY BE SAFETY THE COMMON-PLANNING PURPOSES.
ADLE TO THE MCUA FORHAVE ASSURED FLhM THAT THEY WILL WEALTH Ai4D UTILITY PROVIDE IlY DEVICIS AND WILL CONTINUE THE!R OUTREACH THE LP4 WHO REQUESTS TO ANY PROFOUNDLY DEAF PERSON IN ONE.
4 REQUIRE HEARING IMPA! RED PEOPLE WHO MAY IHE EFFORT TO IDENTIFY ANNUAL EMERGENCY PUBLIC INFOR-IIY DEvlCES CONTINUES THROUGH HOMES WITHIN THE 10-MILE (EPl) BROCHURES MAILED TO ALL MATION THESE BROCHURES CONTAIN A POSTCARD EPZ.
AS NOTED EARLIER, INDIVIDUALS APPRIS!NG LOCAL TO BE USED BY SPECIAL NEEDS NEED.
BOSTON EDISON THE INDIVIDUAL'S SPECIAL OFFICIALS OF SENT A LETTER 70 THE MASSACHUSETTS RECENTLY IDENTIFYING HEARING TO REQUEST THEIR A!D IN DEAF AND HARD OF NEED ITY INDIVIDUALS LIVING IN THE PILGRIM EPL, WHO MAY EDISON LETTER - APPENDlX S).
DEVI,CES (SEE BOSTON
- 1986, INFORMED US THAT AS OF UCTOsER MCUA AND BOSTON 6DISON IDENTIFIED.
DEAF PERSON HAVE BEEN N0 HOUSEHOLDS CONTAINING A
.I
16 -
FEMA, THEREFORE, *0NCLUDES THAT THE PETITION DOES NOT PRO-VIDE NFORMAT10N WHICH SUSTAINS THE CONTENTION.
D) PETITIONERS:
IN TESTIMONY BEFORE MASSACHUSETTS STATE LEGISLATORS ON JUNE 13, 1986, EDWARD A.
IHOMAS, UlV!S!ON CHIEF, NATURAL e
& IECHNOLOGICAL HAZARDS, FEMA, STATED THAT BOSTON EDISON HAD FALLED REPEATEDLY TO DELIVER TO PEftA NECESSARY TECH-NICAL SPEC 181 CATIONS ON THE SIREN SYSTEM.
MR. IHOMAS ADDED THAT HESE DELAYS BY btC0 HAVE FORCED REPEATED POSTPONEMENTS OF THE FULL-SCALE SYSTEM TEST REQUIRED BY FE.g.
9 r E.'u :
aHILE 60$709 f.DISON DID NOT SUBMIT THE NECESSARY TECHNICAL INFORMATION wHEN SCHEDULED, THE COMMONWEALTH OF MASSACHUSETTS FORD ARDED TO FEMA THE "FEMA-H3 REPORT, PustlC ALERT AND NOTIFICATION SYSTEM FOR THE PILGRIM NUCLEAR power STATION" ON JUNE 20, 1985 ADDITIONAL INFORMATION WAS REQUESTED AND PROVIDED TO FEMA BY 30STON EDISON ON JUNE 23,1986 THE ADDITIONAL !NFORMATION WAS ANALYZED AND FOUND TO BE IN SUFFICIENT COMPLIANCE 'alTH THE REQtJIREMENTS OF FEMA-43 70 ENABLE FEMA 70 CONDUCT A TEST OF THE PIL6 RIM SIREN SYSTEM ON bEPTEMBER 29, 1986 THIS TEST INDICATED THAT 88 2% OF THE PEOPLE WERE DIRECTLY ALERTED SY THE SIRENS ON THE DAY OF THE TEST.
FdMA, THEREFORE, CONCLUDES THAT THE PETITION DOES NOT PROYlDE INFORMAft0N WHICH SUSTAINS THE CONTENTION.
O 17 -
E ANS 17/ DEFICIENCl_ES IN EVACUATION L
A) PETITIONERS:
IME EVACUATION TIME ECTIMATES FOR THE PILGRIM EPZ ARE UNREAllSTICALLY LOW.
IMEY Fall TO TAKE INTO ACCOUNT THE PROBABILITY OF SOME PANIC, TRAFFIC DISORDER, TRAFFIC OBSTACLES OUTSIDE THE EP2 I.dD THE FACT THAT THOUSANDS OF PEOPLE OUTS!DE DESIGNATED EvtCUATION ZONES WILL ALSO EVACUATE. ACCORDING TO TESTIMONY BEFORE MASSACHUSETTS LEGISLATORS ON JUNE 18, 1986. BY EDWARD A. THOMAS, DIVISION CHIEF, NATURAL 1 IECNOLO'JICAL HAZARDS, FEMA, THE ' REASONABLE ASSURANCE" ADE00ACY OF 'HE CURRENT
- PLAN l$ BASED ON THE ASSUMPTION THAT COMMUNii!ES OUTSIDE OF THE TEN MILE LFl mAVE DEVELOPED PLANS TO AUGMENT EVACUATION AND SHELTERING EFFORTS.
aHEN ASKED, MR. LUBERING,tSICJ UEPUTY UIRECTOR OF THE hASSACHUSETTS Livlt UEFENSE xGENCY (MLUA), STATED THAT HE *AD NO EVIDENCE THAT SUCH PLANS EXIST.
FURTHER-MORE, i/ACUATION TIME ESTIMATES ARE NOT PROVIDED FOR VARIOUS ADVERSE dEATHER SCENARIOS.
FEha:
IHE CURRENT EVACUATION TIME ESTIMATES ARE BASED ON A SEPTEM-BER, 1980, Study CONDUCTED BY HMM ASSOCIATES, INC. WHICH WAS UPDATED IN AUGUST, 1981 THERE WERE ALSO SUPPLEMENTAL STUDIES ADDRESSING TRAFFIC CONGESTION PROBLEMS OUTSIDE OF THE EPZ IN THE VICINITY OF 3UZZARDS 34Y AND THE $AGAMORE 3 RIDGE AND PRO-JECTING THE IMPACT OF FUTURE POPULATION GROWTH.
IHESE STUDIES WERE EXTENSIVELY REvlEWED BY THE NRC AND FEMA AS PREvl0VSLY i
MENTIONED IN THIS REPORT.
BOSTON EDISON HAS RECENTLY CONTRACTED TO UPDATE THE EVACUATION TIME ESTIMATE F0F THE P!LGRIM NUCLEAR POWER STATION.
IHE PETITIONERS RAISE FlVE SEPARATE ISSUES WITH RESPECT TO EVACUATION WHICH WE HAVE ADDRESSED BELOW:
A) 814,tt - PANIC, AS ACCEPTED BY MOST DISASTER RESEARCH PROFES$10NAL$, WAS DEFINED BY ENRICO L. QUARANTELLI TO MEAN PEOPLE RUNNING FROM AN ASSUMED THREAT OF DANGER, NOT JUST A l
i 18 -
MEl3HTENED SENSE OF ANXIETY l. PANIC ALSO CONNUTES A S OVERWHELMING FEAR TMAT PRODUCES MYSTERICAL 3A !sRATI BEHAVIOR THAT CAN SPREAD 3U!CKLY THROUGM A GROU dESEARCH, BASED ON ACTUAL DISASTER $ HAS REVEAL 1D THAT TH SPECTER OF WILD OR 1RRAT10NAL FLIGHT IN THE FACE OF !
THREAT OR DANGER IS NOT SORNE QUT IN AEALITY.
PEOPLE WILL RATdER THAN MOVE QUT l
0FTEN STAY IN A THRE AT ENING SITU AT IDM OF IT.
RUSSEL DYNES AND OTHER RESEARCHER $2 HAVE CO TMAT THERE 15 NO REASON TO EXPECT THAT PEOPLE WOULD ANY 31FFERENTLY SECAUSE OF A RADIATION THREAT FROM A GENCY AT A NUCLEAR power PLANT THAN THEY WOULD TO ANY OTHER DISASTER.
THEY 64VE ALSO EMPHASIZED THAT A KEY TO THE MAN-l AGEMENT OF PEOPLE IN DANGER !$ THE ABILITY FOR OFFIC 1
PROVIDE CLEAR INSTRUCTIONS AND INFORMATION THAT WIL THAT COULD ATTRACT ON-PUBLic FEARS AND MINIMlZE CURIOSITY LOOKERS wHO MIGHT INHlBIT OR INTERFERE dlTH MEASURES To ot0TECT THE PVBLIC IN DANGER.
OlsAsTER REsEACCH LITERATURE HAS B) TRAF8tc OttonDros -
GENERALLY SHOWN THAT DURING A DISASTER PEOPLE DRIVE AND 00 NOT EXNIBIT ERRATlc DRIVING BEHAV10R3,4. {N AD" 7" i
9 11
/Y THE COMMONWEALTH OF MAS $ ACHUSETTS.l AS DEMONSTR AT TO DEAL WITH TRAFFIC DISORDERS IN NUMEROUS EXERC;$ts AND atAL i
i LIFE $1TUATIDNS.
\\
1 b
1 i
e I
<5 l
19 -
t C) IRAFFIC OBSTACLE? OUTS 1DE THE EPl IMIS ISSUE WAS RAISED BY THE NUCLEAR MEGULATORY LOMMIS$10N AND WAS EXTENS!vELY RE-vlEWED BY $LhA IN A REFORT DATED NAY 1, 1984 (HPPENDlX 2).
~
IN BRIEF, OUR MAY 1, 1984 REDORT INDICATES THE TWO AREAS WHICH MIGHT PRESENT OBSTRUCTIONS TO EVACUATING TRAFFIC QUTSIDE OF THE EPZ ARE THE ROUTE 128, route.3 (south) INTERCHANGE AND THE SAGAMORE BRIDGE ROTARY.
FEMA': ANALYSi$ INDICATED THAT THE COMMONdEALTH OF MASSACHUSETTS HAS UTILIZED THE IN-FORMATION DEVELOPED BY BOSTON E0lSON AND ISSUES IDENTIFIED BY NRC TO DEVELOP AN ADEQUATE TRAFFIC MANAGEMENT PLAN.
IHis 4
PLAN 15 ENTITLED "MASSACHUSETTS STATE POLICE IR00P U HEAD-QUARTERS, MIDDLEBOROUGH, MASSACHUSETTS, HIGHWA't IRAFFIC CONTROL AND ELAN FOR AN EMERGENCY LONDITION AT P!LGRIM 1 l
NPS." IHE PLAN CALLS FOR CONTROL OF TRAFFIC AT THE SAGAMORE 5 RIDGE AND SEVERAL MILES TO THE WEST TO EXPEDITE THE FLOW OF TR AFFIC OUT OF THE EPl.
IRAFFIC FROM CAPE C00 WOULD BE RE-ROUTED TO THE BOURNE BRIDGE.
IN THE MOST SEviPE CASE MASSACHUSETTS PLANS TO CLOSE ROUTE 3 SOUTH AT I T'
..... -!CTION WITH ROUTE 128 IN OTHER CASES THEY WILL CLv."
.~vi 3 SOUTH AT ROUTE 18 WHICH !$ 4 MILES SOUTH OF THE 128/3 INTERCHANGE.
D) SHADOW Eva cu Attan - TH E MA I N EVACUATION ROUTES OUT OF THE P!LGRis EPZ ARE route 3 NORTH; ROUTH 3A NORTH; ROUTE 3 SOUTH; ROUTE 3A SOUTH; ROUTE 6/28 WFST; ROUTE 44 WEST) ROUTE 58 NORTH; ROUTE 58 SOUTH; t0UTE 108 WEST AND ROUTE 495 WEST.
SECONDARY ROADS OUT OF THE cpl 4MICH IMERE ARE ADDITIONAL THE STATE ING AN EVACUATION.
.<00LD ALSO BE UTILIZED DUR PLAN FOA DETAILED TRAFFIC MANAGEMENT E04;ct HAVE DEVELOPED A IC MovtMENT Out OF THE klLGRIM EPZ SO AS TO EXPEDITE TRAFF AT THE PlLGRIM NUCLEAR THE E?2 IN THE EVENT OF AN ACCIDENT THE MASSACKUSETTS THEY d!LL RE A%SISTED SY
?OWER STAfl0N.
OEPARTMENT OF PUBLIC WORKS.
IHF AUGUST 19, 1031 UPDATE 3F THE PIL-() dov_ tost _ytatwt*
EST! MATE FOR e
AN I!ME $$flMATES PROVIDED AN WAS INCLUDED 17. THc AREA 11 341= i/Ae,JATION ADVERSE a?.ATHER CONDITION WHICHTIM hlUA PLAN.
IHE EVACUATION WILL ADDRESS 15 Now SEING PERFORMED FOR 60$'i1N EDISON i
wn!CH IL.
ADVERSE dEATHER SCENARIOS IN MORE DETA THE CONCERNING THE REMARKS ATTRIBUTED TO EDWARD (A) FEMA AND IMDMAS'S COMMENTS wERE THAT:
THRUST OF '!A.
OF MAS $'.CHUSETTS SUPPORT THF DE THE COMMONWEA.TH ETY OF EMER-COMPREHENSIVE PLANS TO DEAL WITH A WID 0F HtVE THE QPTION OF DETER-4 (B) LOCAL GOVERNMENT GENCIES;
! DEN" WILL SG SPECIFICALLY PARTICULAR HAZARue MINING dHICH EMERGENCY PLANS TIFIED IN THE.,R PLANS; (C) AND THAT LOCA i
THE PUBLic CAN SE AND HAVE SEEN USED TO SUCCESSF i
2GENCY FROM HAZARDS NOT SPECIFICALLY RECOGNIZED IN TH l
1HE USE THOMAS PolNTED OUT THREE EXAMPLES OF "t.
PLANS.
1 e
y -
n._-
.w m
,n.
o il -
UF EMERGENCY 3LANS DESIGNED 80R ONE mAZARD TO PROTECT THE PUBLl; FROM ANOTHER MAZARD:
4.
$UCCESSFUL USE OF CRISl5 RELOCAtl0N PLANS TO
- 09E APPROXIMt.TELY %50,000 PEOPLE FROM THE 4
PATH CF "VRRICANE FREDERIC5 IN 1979 O.
OUCCESSFUL USE SY STATE AND LOCAL 30VERN-
+
MENTS JF RAD 10 LOGICAL EMERGENCY RESPONSE I
DLANS AND E3UIPMENT TO PROTECT THE PUBLIC i
IN A S E *. T I O N OF CONNECTICUT DEVASTATED BY
$UDCEN AND CATASTROPHIC FLOODS IN 1962 l
i iUCCESSFUL USE 0F LOCAL RADIOLOGICAL EMER-GENCY RESPONSE PLANS AND E3UlPMENT TO PROTECT l
THE 8UELIC FROM A T0XIC RELEASE OF CHEMICALS r
- ROM & CHEMICAL MANUFACTURER LOCATED NEAR THE WATERForD NUCLEAR power PLANT IN LOUIS!ANA.
IMEREFORE, MR. I40 MAS CONCLUDED, THAT IN CwNSIDERING WHETHER LARGER iMERGENCY PLANNING ZONE WAS REQUIRED To OR NOT A 3
l PSOTECT THE FVELIC ON (APE LOD OR IN OTHER AREA 5 OuTSIDE T8E *VRRENT EMER5ENCY DLANNING *ONE FOR PIL3 RIM ESTABLI$HED i
f SY THE LOMMONwEALTH OF (1ASSACMUSETTS, THE LEGl5LATURE MAY l
1 DANT TO CON $1 DER FUNDING THE COMPREHENSIVE IMPRQvtMENT OF CMtRGENCY PLAN $ FOR THE AREA TO QCAL dlTH ALL MAZARDS IN-CLUDING THOSE OF T0XIC CHEMICAL SPILLS, HURRICANES AND FLOODS WHICH eVERYONE AGREES HAVE A MUCH HIGHER PPORAllLITY i
i OF OCCURRING THAN An ACCIDENT AT A NUCLEAR Pow (R PLANT.
i FEMA, THEREFORE, concludes THAT THE PETITION DOES NOT PRO-VIDE INFORMATION WHICH SUSTAINS THE CONTENTION.
)
J
22 -
s) PETITIONERS:
FOR EVACUATING THE PHY$1CALLY SCHOOL CHILDREN, HOSPITAL
'INERE ARE NO WORKABLE PLANSHOME RESIDENTS, FACILITIES, OR CORRECTIONAL D!$ARLED, NUR$1NG INMATES OF IN LIGHT OF THE DEFICIENCY P AT IENT S, C AMP EPS,
PEOPLE WITHOUT AUTOMOBlLES. CONTRACTUAL AGREEMENTb BELOW (LACK OF IN THE PLAN TO THE PROVIDERS), GENERAL STATEMENTS NOTED IN C.
BE EVACUATED ARE MEAN-PORTATIONTHAT THESE GROUPS WILL SOMEHOW INGLE $$ AND UNREALISTIC."
EFFECT 1
ftMA:
THE "PETITION OF THE IN IHis !$$UE WAS RAISED PREVIOUSLY GROUP FOR LMERGENCY INTEREST KESEARCH MASSACHUSETTS PUBLIC MASSPldG WITH THE NRC ON ACTION" FILED BY AND KEMEDIAL
!$5UES ARE RAISED IN JULY 20, 1983 NO SUBSTANTlvE NEW THE CURRENT PETITION.
IN ITS NOvFMsER 3, 1983, ANAi,Y" FEMA HAS STATED PREV!OUSLY (SEE APPENDIX 1) THAT THE THE MASS'IRG PETITION
$15 0F OF MA$$ACHUSETTS PLANNING FOR $PECI C0xMONwEALTH s
MCDA IN ITS RESPONSE
%UT ACCEPTABLE.
POPULAfivN ($ WEAK HAS STATED THAT IN ADDITION TO THE 1985 NASSPIRG PETITION, RE500Ril5 0F THE (CMMON-RESOURCES THE SUBSTANTIAL To LOCA6 SHOULD LOCAL GOVERNMENTS
=
WEALTH WOULD SE BROUGHT TO SEAR q
NEEDS IN EVACUATING $PECIAL NEED ADDITIONAL AS$ STANCE THAT NURSlNG HOME d
IHE LOCAL PLANS $PECIFY POPULATIONS.
PRIVATE AUTC, INSTITUTIONAL RESIDENTS WILL SE EVACUATED SY AND 30$ES, IF NECESSARY.
FIRE DEPARTMENT AMSULANCES,
- VAN, INE ONLY HOSPITAL LOCATED WITHIN TH THE PROTE,CTich FACTOR AFFORDED f
IN PLYMOUTH.
JORDAN HOSPITAL STRUCTURE AND MATERI ALS WILL BE BY THE HOSPITAL BUILDING $'
SHELTER-IN* PLACE AS THE APPROPR
$UFFICIENT TO ALLOW i
23 -
- ROTECT!vt A,CTION FOR MANY ACCIDENT SCENARIO 5
- MOWEVER,
- 8 tfCESSA2Y, '*0 5 T ;F T-E
- AT!!NTS <0VLD 3E E/ACUATED BY selv&TE AJTO$ OF TmE !*AFF AND PATIENTS DR S
- YMouik..ivil JEF EN S E STAFF.
INTEN517E CARE 31NATED Et SYSTEM 5 OR
- NO NCEO LIFE-SUPPORT PATIENTS AND ORTHOPEDIC AMBULANCES.
SPECIAL CARE IN MOVING wlLL BE TRANSPORTED BY IMROUGm RESPONSE ARDS NCLUDED dlTH THE ANNUAL iPI BRO-
- 00$EHOLDS ALTHIN THE.U-MILE
- duRES O l 5 7 5 ! By T E D T O.g t
- -2, *= vat
- ALLv :!$ABLED ;N01/IDUALS ARE SE!NG : DENT!F i
- An580aTA11;N NEEDS CAN !! : DENT l81ED IN 10
- -A?
!*E : AL ADVANCE.
AS MENTIONED AB0VE IN RESPONSE 70 ISSUE 1S(B), THE LO
- LAN5 SPECIFY TMAT CONTRACTOR SCHOOL B TRANSPORTATION.
IHE j
MOVE IMOSE dlTwou* PERSON AL Mf ANS OF r
P40vl2E5 THAT, IF THERE IS TIME, SCHOOL CHILDREN wlLL 8LAN A
THE!R FAMILIES UNLESS j
BE aETURNED =0ME TO EVACU AT E dlTH
- EC1510N
- 1 MADE AT THE ; TATE OR LOCAL LEvtL, TO EVA l
IN SUSES.
AT CORRECTIONAL FACILITIES ARE 1
l tvACUATION PLANS FOR INMATES
- THREE SUCH FACIL*
INER(.4RE ONL DETAILED IN LOCAL PLANS.
i I
THESE ITIES ALL LOCATED WITHIN THE IQWd 0F PLYMQuTHf (1984 EST.
COUNTY HOUSE OF CORRECTION ARE THE PLYMOUTH USE 255 INnatts), THE ToWF 0F PLYMOUTH Jalt (1984 PEAK AND THE MA5S ACHUSETT5 COR-EST. PEAK U5! - 22 INMATES ),
USE - QS INMAft5).
l I
RECT 10NAL INSTITUTION (1984 EST. PEAK 1
1 4
l I
gy.
ACCORDING 70 T*E 'CaN CF ?LYMOUTH M L.s / OATED "AY.:o),
EACH FACIL!TY MA$ E$7ABLl$HED PROCEDURES FOR SHELTERING 3R EVACUATION OF INMATES AND STAFF.
RECEPT!0N FOR INMATES, IN THE EVENT OF AN EVACUATION, d!LL BE PRovl0E0 BY TME ". A$ $ ACHUS ETTS C OR RF CT I ON AL (NSTIT IN BRl GE' DATER.
IRANSPORT dlLL B E v'l A BUSES AND VANS PRO-VIDEO %Y EACH INSTITUTION, dlTH ADDITIONAL BACK-UP AVAIL-ABLF 840M TdE MATIONAL 30aRD.
A COMPAPl$0N OF THE ANTICIPATED TRANSPORTATION REQUIREMENTS THAT *0ULD BE NECESSARY To EVACUATE THE TRANSIT DEPENDENT POPULATION (INCLUDING MOBILITY IMPAIRED INDIVIDUALS, NUR$1NG MOME RE$1 DENTS, MO5PITAL PATIENTS, SCHOOL CHILDREN AND INAATES AT CORRECTIONAL FACILITIES) WITH THE TRANSPORTATION RESOURCES ARTICULATED BY THE COMMONWEALTH OF NASSACHUSETTS, (ESPECIALLY, THE VAST $ TATE CONTROLLED RESOURCE OF dBIA BUSES) l DOES NOT $UPPORT THE PETIT 10N'S ALLEGATIONS THAT THE AREA ll MCDA AND AND STATE RESOURCES ARE INADEQUATE TO HANDLE i
AN EVACUATION.
FEMA, THEREFORE, CONCLUDES THAT THE PETITION 00E5 NOT PROVIDE INFORMAT!0N SUFFICIENT TO SUSTAIN ITS CONTENTION.
ON THE f
OTHER HAND, FEMA, IN ITs SELF-INITIATED REVIEW HAS ANALYZED l
INFORMATION OF ITS OWN THAT SPEAKS TO THE !$$UES RAISED.
4 l
4
(
25 -
C.1) PETITIONERS:
IESTIMONY SY FEMA AND MCUA 0FFICIALS AT THE JUNE 18, 1986 HEARING ON THE PILGRIM KERP INDICATED THAT THERE ARE NO CONTRACTUAL AGREEMENTS wlTH Ed5 COMPANIES OR SUS DRIVERS, AMSULANCE COMFANIES, OR ANY OTHER TRANSPORTATION PROVIDERS FOR THOUSANDS OF PEOPLE WHO CANNOT ORIVE OR MAY NOT HAVE AN t
AUTOMOBILE.
FEMA:
IHIS ISSUE dA$ RAl$ED PREVIOUSLY IN THE ' PETITION OF THE MASSACHUSETTS PUBLIC INTEREST RESEARCH GROUP FOR LMERGENCY AND MEMEDIAL ACTION" FILED BY MASSPlKG WITH THE NKC ON 2
July JU,.de).
NO SUBSTANTlvE NEd ISSUES ARE RAISED IN THE CURRENT PETITION.
l
)
AT THE PRESENT TIME THERE ARE NO WRITTEN AGREEMENTS WITH PRIVATE SUS COMPAN!ES ALTHOUGH THE STATE HAS REEN CONSIDER" l
ING THE NEED FOR THESE AGREEMENTS $lNCE JULY 1983, (SEE MCDA RESPONSES TO MASSPIRG PEttTION, PAGE 9, APPENDlX lll).
l q
$ STATED IN FEMA's RESPONSE TO THE 1983 MASSPIRG PETITION (APPENDlX 1), ARR ANGEMENTS H AVE BEEN MADE WITH THE MA$$A-CHUSETT5 BAY IRANSPORTATION AUTHORITY (MBTA), A STATE AGENCY THAT, IN AN EMERGENCY, MAY BE DIRECTED BY THE GOVERNOR TO RESPOND.
ACCORDING TO THE CO,MMONWEALTH OF i
MASSACHU$ETTS, AN INVENTORY OF PUBLIC TRANSPORTATION RESQURCES 15 AVAILABLE ON COMPUTER AND THESE RE500RCES l
a SHOULD SE SUFFICIENT 7) *ROVIDE TRANSPORTAft0N TO THOSE WHO NEED IT.
{lli,
_ **lN!TIATED REVIEW AND INTiRIM i
\\
PINDING FOR UPDATED INFORMATION}.
i i
\\
26 -
C.2) PETITIONERS:
NO ORIVER$ HAVE BEEN TRAINE'D IN THEIR SUPPOSED ROLE IN EVACUATION PLANS.
IN FACT, No DRIVER $ MAVE BEEN INFORMED THAT THEY HAVE A ROLE lN EVACUATION PLANS.
FEfiA:
AN EMERGENCY WORKER 15 AN INDIVIDUAL WMC MAS AN ESSENTIAL Mis-
$10N WITHlN THE PLUME lxPOSURE EPl TO PROTECT THE HEALTH AND l
SAFETY OF THE PUBLIC WHO COULD BE EXPOSED TO 10NIZlNG RADIATION FROM THE PLUME OR ITS DEPOSITION.
IHE EMERGENCY WORKER MUST BE TRAINED IN THF BA$1C CHARACTERISTICS OF !ONIZING RADIATION AND j
ITS HEALTH EFFECTS.
IN THl$ CONTEXT, BUS DRIVER $ AND OTHER l
8ER$CNNEL wH0 w!LL DRIVE EVACUAT!0N VEHICLES MAY BE EMfRGENCY WORKERS AND AS SUCH SHOULD BE TRAINED IN THE!R ROLE DURING AN 4
EMERGENCY.
{1li, FEMA-REP-2 (REv.1) "Gu t DANCE ON OFF-SIT E EMERGENCY RADIATION SYSTEMS', PHASE 1 - AIRS 0RNE KELEASE, j
VECEMBER 1985, P. 5-1, AND NUREG-U654, FEMA REP-1, REv.-1, 11 0 1,2, 4 AND 5.}
THE MA$$ACHUSETTS PLAN $ FOR DEALING WITH AN ACCIDENT AT PILGRIM
)
INDICATE THAT THE PRIMARY MEANS OF EVACUATION FOR THE LPl WILL BE PRIVATE AUTOMOBILES.
(111, ici., IOWN OF Pi,vMouTH RADlo-l LOGICAL EMERGENCY RESPONSE PLAN, P.7 ET SEQ.l.
FOR POPULATIONS
{
WHO DID NOT HAVE ACCES$ TO PRIVATE AUTOMollLES, THE PLANS CON-TEMPLATE THE VE2 0F SU$ES OR AMSULANCES.' IF EXTRA SUSES ARE l
NEEDED FROM OUYSIDE THE f.PL, THE TOWNS WoutD CONTACT THE STATE AREA 11 Civlt DEFENSE HEADQUARTER $ WHICH WOULD THEN COORDINATE l
THE PROVlll0N OF SUCH RESQURCES FROM THE VAST REscuRCES AVAILABLE To THE COMMONWEALTH OF MA$$ACHUSETTS ESPECIALLY INCLUDING THE MBTA (10. AT PP.24-331 l
l
e 27 -
THAT APPROPRIATE TRAINING (E.G.,
IN FEMA HAS NO INDICATION NOTIFICATION, RADIOLOGICAL EXPOSURE CONTROL, AND RADIOLOGICAL ACCIDENT $) MAS BEEN PROVIDED.
IHE IQWN OF PLYMOUTHIIVIL i
4 UEFENSE UlRECTOR INDICATED AT THE PtMA $PONSORED PulLIC MEET-r ING ON THE PLANS ON JUNE 3, 1982, THAT A TRAINING PROGRAM I
BUS DRIVER $ W A$ SEING DEVELOPED 'FOR DEPLOYMENT IN THE FOR FALL Or 1982
!ili, TRANSCRIPT OF A PUBLIC MEETING AN THE 1
6 TATE MAD 10 LOGICAL iMERGENCY MESPONSE PLAN, P. 37).
- HOWEVER, at UNDER$TAND TMAT SUCH TRAINING Dl0 NOT TAKE PLACE, AND IN ANY CA51, TRAINING FOR Bu$ DRIVER $ IN RADIOLOGICAL EXPO $URE I
l CONTROL HA$ NOT EVER SEEN PROVIDED TO SUS DRIVERS.
[
t J
l LACK OF TRAINING FOR DRIVER $ OF EVACUATION VEHICLES OR ANY i
j OTHER EMERGENCY WORKER 15 A PROBLEM AND 15 NOT IN ACCORDANCE wlTH FEDERAL GulDANCE.
THE COMMONWEALTH OF MASSACHUSETTS PLAN $ FOR EVACULTING THE PltGR!M EPZ CONTEMPLATE THAT THOSE i
l SU$ DRIVER $ FROM OUT$1DE THE LPZ WILL MA<E ONLY ONE RUN INTO l
THE LPl, PICK UP PAS $ENGER$ AT A DESIGNATED $1TE, AND IMMEDi*
ATELY LEAVE.
IN ADDITION, BASED ON OUR Cl$ERVATIONS OF THE
[
MA$$4CHU$tTTS EXERCl$E$ OV THE PILGRIM PLANS, WE UNDER$TAND
)
i THAT THE STATE WILL CAREFULLY CONSIDER THE DOSE CONSEQUENCES
)
TO THE DRIVER AND His PA$$ENGER$, AND THE OPTIMUM TIME FOR THE EVACUATION TRIP SELECTED.
lhil, hASSACHU$ETTS KAD10 LOG-ICAL EMERGENCY RESPONSE PLAN $$P.A.3, P.8 1, AND P.B.31 I
h l
l 4
_r
28 -
0F AN EVACUAT10N VEHICLE WA$ LIKELY TO BE [XPOSED TO A LARGER DOSE OF RADIATION THAN THE GENERAL PUBLIC, THE STATE DECISION-MAKERS COULD USE AS EVACUATION DRIVERS A t
SUBSTANTIAL P O CI, OF STATE POLICE AND CIVIL DEFENSE WORKERS
- M0 MAvt SEEN APPROPRIATELY TRAINED IN RADIOLOGICAL EMERGENCY RE$ PUN $E.
TH!$ TYPE OF PRIMARILY AA gas RESPONSE
]
I
!$ NOT DESIRABLE N0dEVER, AND THE COMMONWEALTH $6 )ULD 19PaovE !T$ PLAN $ IN THl$ AREA.
IO 8$$157 STATE 4ND LOCAL GOVERNMENTS IN IMPtovlNG THElR PLANNING IN THE AREA 0F bug TRANSPORTATION, DARTICULARLY FOR SCHOOL CHILDREN, FEMA HAS DEVELOPED GUIDANCE MEMORANDUM EV-2, ' PROTECTIVE ACTIONS FOR SCHOOL CHILDREN".
IHit DOCUMENT W ILL ASSIST THE (CMMON*
f dEALTH IN REFINING PLANS FOR IVS TRANSPORTATION, AND DRIVER TRAINING.
FEMA wlLL IN5!ST THAT IMPROVED PLANS AND TRAINING 1
RELATED TO BUS DR! VERS BE DEVELOPED PRIOR TO, AND TESTED l
DURING, THE NEXT EXERCISE OF THE FILGRIM WADl0 LOGICAL l
I LMERGENCY KESPONSE PLANS.
1 IN THE MEANTIME, FEMA sELIEVEs THAT THE ust OF TRAINED j
STATE POLICE AND CIVIL DEFENSE WORKERS AS *SUV DRIVERS !$
i AN ADEQUATE COMPENSATORY MEASURE, AND THEREFORE, THE c
PETITION 00E$ NOT PROVIDE INFORMATION WHICH $USTAIN5 THE j
CONTENTION.
r 4
i-1
29 C.)) PETITitNERS:
FURTHERMORE, THE PROPOSED ROUTE OF SUCH EVACUATION (KOUTE j iiORTH AND KOUTE 44 WEST) ARE COMPLETELY INADEQUATE TO EFFEC-TivELY HANDLE THE ANTICIPATED YOLUME OF TRAFFIC.
IHis !$
PARTICULARLY TRUE DURING THE SUMMER MONTHS DUE TO THE HEAVY VOLUME OF TOURISTS HEADING TO AND FROM CAPE C00 FEMA:
FEMA THOROUGHLY ANALYZED THis !$$UE,1N 1934 AT THE RE0utst OF THE NRC, (SEE APPENDIX 2).
WHILE ROUTES 3 AND 44 ARE THE "AJOR ROUTE 3 LEADING OUT OF THE EPZ, THERE ARE MANY OTHER ROADS aHlCH CAN BE USED To LEAVE THE AREA.
ALL ROUTES LEADING INTO THE LPl d!LL SE CLOSED TO INCOMING TRAFFIC, a
ACCORDING TO THE "STATE POLICE HIGHWAY IRAFFIC LONTROL i
AND NOTIFICATION PLAN FOR AN LMERGENCY AT PILGRIM 1 NFS."
l IHE EVACUAfl0N TIME ESTIMATE FOR THE FILGRIM LPl 'HAS SEEN EXTENSlvELY REvlEWED BY 0lMA AND THE NKC AND FOUND TO BE ADECUATE.
PUSSIBLE BOTTLE NECKS HAVE BEEN IDENTIFIED AND TRAFFIC MANAGEMENT PLANS HAVE BEEN SivELOPED TO allow EVAC-UATION TO PROCEED AS RAPIDLY AS POS$1BLE.
30STON EDISON HAS RECENTLY CONTRACTED TO UPDATE THE EvacuA-710N IlmE ESTIMA1E AND TRAFFIC MANAGEMENT,. PLAN FOR THE PILGalM EPl. (SEE APPENDIX 5, P AGES 11-12).
FEMA, THEREFORE, CONCLUDES THAT THE ISSUES RAISED IN SECTION I
17 0F THE PETITION 00 NOT PROVIDE INFORMATION SUFFIC1ENT TO l
SUSTAIN IT3 CONTENTION. UN THE OTHER HAND, FLMA, IN ITS 1
30 -
NA$ ANALYZED INFORMATION THAT SPEAKS SELF-INITIATED REvlEd 17.C.1 AND 17.C.2 TO THE 155ut$ RAISED 11 IN NEDICAL FACILITIES 13/ ALLEGED DEFICIENCIES A) PETITION:
REQUIRE THAT ARRANGEMENTS VARIOU$ NRC AND FEMA REGULATIONS
$ERvlCES FOR CONTAMINATED INJURED IND BE MADE FOR MEDICAL v! DUALS (10 Crx 150 41 (s M 12);
L.1 AND L. 3 ). IME PLAN ll.t AND IV. L.7; LVALUATION (RITERI ATREATMENT OF v!CTIM5 0F RAD 10-FOR MAKES INADEQUATE PROVISIONA MAbbPlKD 136) $TUDY OF THE T'do THE PLAN IN EFFECT REVEALED THEY MAYE A ACT!vt CONTAMINAfl0N.
TOTAL CAPACITY TO YREAT ONLY EIGHT OR NIN MOSPITALS L!$7ED IN ONE OF THESE (JORDAN HOSPITAL, PLYMOUTM) 15 wlTHIN FOUR MILLS OF THE PLANT, SO 17 MAY NEED TO BE ACT!vE CONTAMINATION.
dvACUATED.
THE OTHER (MORTON HOSPITAL, IAUNTON) (N 1983 HAD ACCIDENTS.
NQ DATA SUGGESTS NO STAFF TRA!NED c'OR RADIOLOGICAL IMPROVED $1NCE 198).
THE $170AT10N HAS MATERIALLY FEMA:
THE ' PETITION OF THE Mass-l HAISED PREVIOUSLY IN IHis !$!UE WAS ACHUSETTS PUBLIC INTEREST RESEARCH GROU MEDIAL ACTION
- FILED SY MASbPlHG wlTH THE NKC ON 1
NO $US$TANTivE NEW !$5UES ARE RAISED IN THE THE COMM0HdEALTH OF MASSACHU-lN ITS RESPONSE TO THE PLTITION i'
20, 1985):
SETTS STATED (APPENDIX 3, JULY UNDER NO CIRCUMSTANCES WOULD WE EXPECT LARGEI a
INDIVIDUAL $.
NUMBER $ OF CONTAMINATED TWR00GH NUREG-0396 MADE IT CLEAR THAT MED l
l FROM REQUIREMENTS RESULTINr.NEED INVOLVE ON NONETHELEss, 0F EXPOSED OR CONTAMINATED INDIVIDUALS. HOSPITA ALL ACCREDITED MAS $ ACHU$ETTSTO TREAT E i
A CAPAllLITY UUAL$.
31 -
FEMA PREVIOUSLY STATED (APPENDlx 1 NOVEMBER 3, 1983):
IHis CONCERN HAS BEEN ADDRESSED IN ACCORDANCE w!TH j
NRC'S Rf0VIREMENTS AS FOLLOWS:
- 1) NUREG-0396 MAKEs IT CLEAR THAT MEDICAL REcu!REMENTs RESULTING FROM POWER PLANT ACCIDENTa NEED INVOLVE ONLY LIMITED FACILITIES FOR TREATMENT OF EXPOSED OR CONTAM-INATED INDIVIDUALS.
IM!S 90517,10N 15 IN ACCORD WITH THE NRC COMM!$$10NER'S MEMORANDUM AND ORDER OF APRit 4, i
4 l
1983 (17 NKC 528 (1983), CL1-83-10) WHICH STATES:
NO ADDIT!0NAL MEDICAL FACILITIES OR CAPAllLITIES ARE RE3UIRED FOR THE GENERAL PUBLIC.
- HOWEVER, 1
FACILITIES wlTH WHICH PRIOR ARRANGEMENTS ARE MADE AND THOSE LOCAL OR REGIONAL FACILITIES dHICH MAvr THE CAPABILITY To TREAT CONTAMINATED INJURED INDIVl*
DUALS $NOULD BE IDENT! PLED....lMERGENCY PLANS SHOULD, nowEVER, IDENTIFY THOSE LCCAL OR REGIONAL MEDlCAL FACILITIES WHICH HAVE THE CAPAllLITIES 70 PRovlDE APPROPRIATE MEDICAL TREATMENT FOR RADIAT10N EXPO $URE.
NO CONTRACTUAL AGREEMENTS ARE NECESSARY AND No ADDI-T10NAL HOSPITALS OR OTHER FACILITIES NEED BE CON
- STRUCTED.
- 2) WE NOTE THAT ALL ACCREDITED MASSACHUSETTS HOSPITALS ARE REQUIRED BY THE COMMONWEALTH TO MAINTAIN A CAPA41LIT l
TO TREAT EXPOSED OR CONTAMINATED INDivlDUALS AND EMER" GENCY PERSONNEL ARE ADylSED IN THE HANDLING OT RADI-ATION VICTIMS.
lN ADDITION, A$ REQUIRED SY NRC REGULA*
T10N$, THE UTILITY HAS MADE ARRANGEMENTS WITH JORDAN g
l HOSPITAL IN PLYMOUTH TO PRovlDE ACUT[ TREATMENT FOR EXPOSED CR CONTAMINATED P(450NNEL.
Hl$ AllLITY WAS l
REvlEWED BY THE MAY 1962 LXERCISE OF THE (MERGENCY P J
.ND FOUND ACCEPTABLE, j
I INESE ARRANGEMENTS ARE DOCUMENTED ON PAGE 133 AND l
ANNEX A 0F THE [MERGENCY PLAN FOR THE PILGRIM NUCLEAR POWtm STAT 108 i
80$ TON EDis0N STATED THAT ADDITIONAL HOSPITALS HAVE BEEN IDENTIFIED AND ARRANGEMENTS HAVE BEEN MADE WITH THEM CON" I
CERNING TREATMENT OF CONTAMINATED INDIVIDUALS OR RADIATl0N VLCTIMS. ( AP P E t.:' X 5, PAGE 15).
l l
4 s
1 32 -
ADDITIONAL RESOURCES ARE AVAILABLE IN OTHER AREA $ AN0 THROUGH i
J THE FEDERAL KAD10 LOGICAL EMERGENCY MESPONSE PLAN.
FEMA, THEREFORE, CONCLUDES THAT THE PETITION DOES NOT 840-l VIDE INFORMATION dMICH $USTAINS THE CONTENTION.
- 8) PETITIONER $:
IME PLAN FAILS TO PROYlDE FOR THE DISTRilVTION OF radio-PROTECTl/E DRUGS FOR THE PREVENTION OF THYRotD TUMOR $ TO THE GENERAL PulLIC 04 70 PERSONS IN 1NSTITUT10NS WHO MAY NOT BE EVACUATED.
IME NKC AND PLhA RECOMMEND D!$TR!SUTION OF SUCH DRUGS AT LEAST TO SUCH INSTITUT10NALIZED PERSONS (hv&LUAT10N CRITERIA, J.10.E. AND J.10 F.J).
l FEMA:
IHl$ 15 $1MILAR TO AN IS$UE THAT WAS RAISED PREVIOUSLY IN THE 1
"PETIT 10N OF THE MA$$ACHUSETTS PustlC INTEREST RESEARCH 6ROUP FOR EMERGENCY AND REMEDIAL ACTION" FILED BY MASSPIRG wlTH THE 4
NRC ON JULY 20, 1083 H0 WEVER THE PETITIONER IN THl$ CASE MAKES THE ADDITIONAL PolaT THAT THERE ARE NO $PECIFIC PROVl$10NS f
IN THE MA$$ACHU$ETTS RADIOLOGICAL EMERGENCY PLANS FOR PROVIDING RADIO PROTECT!vE DRUGS TO INSTITUTIONALIZED PER$0NS AS 15 l
REOUIRED BY FEDERAL GulDANCE.
L t
[N 175 RESPON$E TO THE 1983 MASSPldG PETITION, THE COMMONwEALTw i
0F MA$$ACHUSETTS STATED (APPENDlX 3):
IME MASSACHUSETTS DEPARTMENT OF PusLIC HEALTH (MDPH) HAS ADVISED THAT DtSTRtsuit0N OF POTAS$1uM 10DlDE IN MASSACHUSETTS WILL SE LIMITED TO EMERG-ENCY WORKER $ DURING THE INITIAL PHASE OF AN EMERG" I
l ENCYe INE MDPH PCLtCY l$ SASED uPON THE DRUG'S i
POTENTIAL ADVERSE $1DE EFFECTS IF DllTRilVTED TO i
l THE GENERAL POPULAT10N INDISCRIMINATELY.
FEMA STAf te in ITS RESPONSE TO THE 1983 MASSPIRG PETIT 10N (APPENDlX 1):
1 l
. 1 INE COMMONWEALTH OF hA$$ACHU$dTTS HA$ CAREFULLY REY!EdED THis IS$UE AND FORMULATED A POLICY FOR THE DISTRIBUTION OF P0TA$$1UM IODIDE dHICH l$ THAT IT WILL CNLY SE GivEN TO EMERGENCY WORKER $ UNDER dx-TRAORDINARY CIRCUMSTANCES.
IF THERE WERE A Po$-
$1llLITY OF RADICACTIVE 10 DINES BEING RELEASED, THE COMMONwtALTH wouLD EVACUATE THE AREA OR $HELTER THE FOPULATION RATHER THAN HAVE THEM TAKE RADIO-PERCEPfl0N OF THE DRUG {D UPON THE IHl$ POLICY l$ BAS PROTECTlvt DRUGS.
$ POTENTIAL COMMONWEALTH'S ADVER5E $1DE EFFECTS !F DISTRituTED TO THE GENERAL POPULATION, AND l$ CON $1 STENT WITH CURRENT FEDERAL POLICY. (SEE APPEND!X b)
IHE LOMMON<EALTH'$ PLAN FOR THE DISTRilVTION OF POTA$$1UM l
10 DINE TO INST ITUT ION AL I ZED PEOPLE ls WEAK.
IHE bTATE UlR-E; TOR OF THE DEPARTMENT OF PUBLIC HEALTH, HADIATION LONTROL j
ONIT MAS TOLD US TmAT THE CURRENT MASSACHUSETTS POLICY l$
)
i THAT THE COMMIS$10NER OF PUBLIC HEALTH wouLD ANALYZE THE
$1TUAtl0N AT THE TIME OF THE ACCIDENT TO DETERMINE IF THE ADMIN!$TR.T10N OF XI TO INSTITUT10NALIZED PEOPLE l$ WARRANTED.
BECAUSE OF THE COMPARATivtLY FEW INSTITUTIONS IN THE PILGRIM PLUME EXPO $URE EMERGENCY PLANNING ZONE THE DISTRIBUTION OF Kl TO THE INSTITUTIONS COULD SE ACCOMPLISHED ON AN AD HOC BAS 1$
i U$ INS EXISTING STOC($ MAINT AINED BY NUCLEAR UTILITIES.
IME C0HMONwtALTH'$ PLAN wout0 SE ENHANCED IF THE POLICY FOR THE I
I ADMIN 15tRATION OF Kl TO INSTITUT!0NALIZED PEOPLE WERE CLEARLY
)
$T ATED; AND IF PROCEDURES FOR THE DISTRllDTION OF Kl TO THE INSTITUTIONS WERE MORE FULLY DEVELOPED.
l FEMA, THEREFORE, CONCLUDES THAT WHILE THE PETITION PQlNTS QUT A WEAKNE$$ IN THE MAS $ACHU$ETT$ PLANS, IT DOES NOT PROVIDE l
INFORMATION WHICH $USTAINS THE CONTENTION.
i 4
j
34 -
ULANNING 40NE 15 IOC SMALL
_19/ THE EMERGENCY A) PETITIONERS:
DROTECTION AGENCY (EPA) RECOMMENDS PRO-INE ENvlRONMENTAL TECTivt MEASURES 3Y THE PUBLIC WHEN RADIATICN EXPOSURE !$
LIKELY 70 EXCEED THE EPA's "PROTECTl/C ACTION GUIDE" 0F ONE REM LAANUAL OF PROTECTlvE ACTION bulDE AND PROTEC-TivE ACTIONS FOR NUCLEAR ACCIDENTS, EPA-520/1-75-001, EPA, 1975).
4 fiMA:
INE LOMMONaEALT* OF MASSACHUSETTS KADl0 LOGICAL EMERGENCY sESPONSE "LAN !$ CON 515fENT alTH PEDERAL PRUTECTivE ACTION 3JIDEL;NES.
t
- 8) FETITIONERS:
i NXC aEGULAft0NS REQUIRE THE EXACT SIZE AND CONFIGURATION OF KACH E?l TO BE "DETERMlNED IN RELAtl0N TO LOCAL RESPONSE l
NEEDS AND CAPABILITIES AS THEY ARE AFFECTED BY SUCH CONDI-710NS AS DEMOGRAPHY, TCPOGRADHY, LAND CHARACTERISTICS, ACCESS ROUTES, AND JURISDICTIONAL SOUNDARIES.*
6ENERALLY, THE NRC 4
i PROVIDES THE PLUME (XPOSURE EPl $HOULD BE ABOUT T N MILES IN i
RADj"n(10CFRPART 50 47 (C)(2)).
BOSTON EDISON QMPANY
)
m&$
ITTED THAT THE ONLY FACTOR USED TO CREATE THE PILGRIM EPl d&S JURj$ DICT 10NAL SOUNDARIES (RE$PQNS[ OF $0$ TON EQl50N COMPANY 70 s0MMONwtALTH OF MASSACHUSETT5' P1RST SET OF INTER-t 40GATORIES ON EMtRGENCY PLANNING, JutY 20, 1981,
- p. 21).
l FEMA:
i INE dEGl0NAL A$$15T ANCE COMMITTEE, WHICH is CHAIRED sY FEMA, t
REviEwt0 THE PROPQsED PILGRIM NUCLEAR P0wtR STATION PLUME EXPOSURE EMERGENCY PLANNING LONE AND FOUND IT TO SE ADEQUATE IN SIZE AND THAT IT ADECUATELY ADDRESSED THE DEMOGRAPHIC, TCP0GR APHIC AND L AND USE CH AR ACTERistics, ACCES$ ROUTES,
\\
AND JURI$ DICT 10NAL SOUNDARIES.
i
~
35 -
INE COMMONWEALTH OF MAS $ACHUSETTS INDICATED AT THE PLYMOUTH 4
PUBLic MEETING (JUNE $0, 19Bb) !T WILL REVIEW THE $1zt OF THE PILGRIM PLUME LX*0$URE EMERGENCY PLANNING 40NE AS PART OF AN ONG0 LNG EFFORT TO IMPROVE EMERQENCY PLANS AND PREPARED-NE$$ 'AROUND NUCLEAR POWER PLANTS.
f FEMA CONCLUDES THAT THE PETITION CONTAINS NO EVIDENCE To
$UGGEST THAT THE $1ZE OF THE PLUME EXPOSURE EMERGENCY ELAN-NING 20NE FOR THE PILsRIM NUCLEAR POWER STAft0N !$ T00 $ MALL.
2
)
I P TITIONER$;
j C)
E J
. APE CCD BE31NS JUST ELEVEN 291LES FROM P!LGRIM AND !$
CONNECTED TO THE MAINLAND BY ONLY TWO BRIDGES.
lHERE l
No EMERGENCY PLANNING FOR CAPE COD, NOR PulLIC EDUCATION OF PROTECTIVE MEASURES, NOR WARNING $1RENS.
HOWEVER, THERC f
l ARE PLAN $ TO CLOSE THE C APE CCD BRIDGES TO PREVENT ITS EVAC-i UAT10N, $0 AS TO GIVE PREFERENCE TO EVACUEES WITHIN THE J
PLANT'S IV MILE RADIUS.
IHl$ 15 TOTALLY UNACCEPTABLE To
)
THE PEOPLE ON THE LAPE, WHO WOULD BE IN THE PATH OF A RADIOLOGICAL PLUME IF THE WIND WERE BLOWING TOWARD THE CAPE.
)
LVEN IF THEY WERE ALLOWED TO EVACUATE THE CAPE OVER THE l
CONNECTING BRIDGES, THEY WOULD BE DOING $0 IN THE DIRECTION 0F THE PLANT AND THE SOURCE OF THE RADIATION.
IHE ISSUE OF EVACUATING CAPE C00 !$ EXTREMELY IMPORT /NT IN THE LIGHT OF f
l i
THE LHERN04YL ACCIDENT, $1NCE THLAE THE RADICACTIVE PLUME t
EXTENDED MUCH FURTHER THAN lO-K.LES.
l r
l FEMA-i l
IHl$ !$$UE WAS RAISED PREV 10VSLY IN THE ' PETIT 10N OF THE MA$$ACHU$tTTS PultlC INTEREST RESEARCH GROUP FOR EMERGENCY t
4 AND REMEDIAL ACTION' FILED BY MASSPIRG WITH THE NRC ON i
l JULY 20, 1983 NO SUS $TANTIVE NEW 188UES ARE RAllED IN THE CURRENT PETITION.
)
FEMA $TATED IN ITS RESPONSE TO THE 1983 PETITION (APPENDIX 1):
4
j 36 -
t T. E 4
IHg CONCLUSION IN THE MA'6bFlkb PETITION THAT OLANNING LONE $ MOULD lt IN-
$111 0F THE iMERGENCY l
CREASED TO INCLUDE LAPE LOD AND OTHER AREAS !$ BA$tD l
84EPARED FOR T.45 MASSACHU$tTTS ATTORNEY i
UPON A REPORT IMi$ REPORT WAS PRgPARED BY hHb
$tNERAL'$ OFFICE.4$$0CIATE$ AND 15 (NTITLED REVltw 0F (AL-l l
CULAtl0N OF MEACTOR ACCIDENT LONSEQUENCES ((RA( 'i)
IECHNICAL NESULTS AND l!0V!D P ATHw AYS, (NUREG-1596) STUDY:
l
[
- lMPLICATIONS FOR (MERGENCY PLANNING IN THE OF THE P!LGRIM NUCLEAR PowtR STATION.*
l VICINITY IME REPORT CONCLUDtl *...P40TECTlvt ACT!0N o$ts MAY St CXCEEDED IF THC CURRENT PUIDELINEgLANNING20NESAREU$tD.*
0 THE
$MERitNCY EXTENT THAT THl$ STATEMENT INDICAft$.A NitD t
INCREASETHE$1ZEgFTHEAPP40xlMAT(LY 70
{0-*lLERADIUSPLUMEoxPOSUREPATMwAY 40NE AT i
I L G R I.*, SUCH A CONCLV$10N l$ NOT G F,N E R ALLY l
ACCEPTED Sv T*E SCitNTIFIC COMMUNITY AT 741$
i J
TIME.
4 IME $llt AND CONFIGURATION OF THE EMERGENCY PLAN-
)
NING 40NE FOR PILGRIM !$ SA$t0 UPON NUMLU*Vbb4 I
CRITERIA AND APPROVED BY THE KEGIONAL A$$1 STANCE LOMMITTtt (KAC).
IME $1ZE OF THE LF4 TO BE U$tD FOR RADIOLOGICAL-EM(RGEN(Y RESPON$t wAL DETERMINED
[
SY A JotNT NKL/tPA 1ASK FORCE STUDY.
HE CONCLU*
l
$10NS REACHED ly THE TASK FORCE Att DOCUMENTED IN i
NUK(b-0396, tFA D20/1-78-Ulb.
BOTH NUMLb-Ubb4 AND i
i NURtG-0396 RECOGNizt THAT PAGS MIGHT st ExCttDt0 SEYOND THE TEN MILE PLUME EXPC$URE LPl IN TH( (VENT f
i 0F THE a0RST 80$$1SLEACQlDENTANQMETCgROLOLICAL 1
CONDIT!CNS.
How tV E R, A ItN MILE PLUME.xPOSUR,t tPf das $Y1LL CMO$tN A5 A P'. ANNI NG B A51 $ IN NukEG-r
]
V624 stCAu$t:
i A.
'ROJECTED 00$t$ FROM THE TRADITIONAL DES!GN SAll$ ACCIDENTS w0VLD NOT ExcetD pag Ltvets l
QUTSIDE THE ZONt; l
I PROJECT?D DO$t$ FROM MOST CORE M4LT StGwtNC;i i
WOULD NOT EXCEED PAG LtVit$ 0u7$10 THE ZONt; 8
i FOR THE WOR $T CORE MELT SEQUENCtl, IMMEDIATE C-LIFE THREATENING 00$t$ WOULD GENERALLY NOT l
l QCCUR QUT$1DE THE ZONE; I
I D.
DETAILED PLANNING WITHIN 10 MILES wCULD PROVIDE e
A $US$7ANTIAL BA$t FOR EXPAN$10N OF RESPONSE r
(FFORT$ IN THE EVENT THAT TMll PRovtD NECESSARY.
1 i
i i
i l
I
37 -
3EEN INVESTIGATING ACCIDENT SOURCE TERMS, OF NUCLEAR REACTOR AC-INE NHC *AS
' ROB ABILITl!$ AND CONSEQUENC ESINE RESULT OF THESE $TUDIES, SEv&RAL YEAd$.
REv!$ING NUNtb CIDENTS =0R BE USED IN COMPLETE, ARE EXPECTED TONUKEG-Vb54 MAY INCLUDE RECON $
WHEN OF PLANNING LONE.
T*E REv!$10N Ob54.
THE $1ZE OF THE *MERGENCY ERAtl0N UF NOT NEED $PECIFIC e
C APE C0D !$ SEYOND THE 1U-MILE tPZ AND DOES RAD 10LostCAL EMERGENCY PLANS.
HowEYER, AS NOTED EARLIER IN INo!CATED TO FtMA THAT TM15 RESPONSE, THE COMMONWEALTH HAS PLUME EXPO $URE EMER-IT alLL REVIEd THE ItZE OF THE PILGRIM OF %N ON-3OING EFFORT TO IMPROVE LANNING.'JNE A$ PART l
3 l
3ENCY AROUND NUCLEAR P0aER 8LANTS.
i
- LANS AND 84E*AREDNES$
!"E:QENCY THE EPZ 00 HOT PRECLUDE SPECtric, cETAlttD PLANS DEVELOPED FOR i
10-MILE AREA.
T AtlNG APPROPRI ATE PROTECT!vE ACTIONS BEYOND T l
BECOME THE BA$1l FOR ANY THE DETAILED EP2 PLANS J
IN FACT, I
l actions aE0VIRED AT GREATER DISTANCES.
UEFENSE AGENCY COMPRE*
ACCORDING 70 THE MAS $ ACHU$ETTS Civ!L MANAGEMENT PLANS dHlCH ADDRESS THE VSE O 4
MEN $1VE EMERGENCY A$ Pol $1SLE PROTECTivt RESPON$E TO
$NELTER AND EVACUATION IN MOST COMMUNITIES QUT$lDE EXIST EMERGENCIES CURRENTLY l
PLANNING ZONE.
THE PLUME EXPC$URE EMERGENCY f
0F FEMA wAl JOINED NKC AND THE UEP ARTMENT 0[ LNER LPA AND A REPORT ON THE I
THE NUCLEAR INDUSTRY IN THE PREPARATION OF FOR
{
FEMA ACCEPTED THE RESPON$lt!LITY CHERN0lVL ACCIDENT.
WE RESPON$E AND.PREPAREDNEll.
THE CHAPTER ON EMERGENCY vltw THl$ REPORT AS A NECESSARY PREREQul$lTE FOR A l
l l
l
J
38 -
OF THE V.b. DAD 10 LOGICAL iM F. R G E N C Y PREPAREDNESS PROGRAM.
IT $HOULD IDENTIEY LES$QNS FROM THE CHERNORYL EXPERIENCE THAT CAN BE USED IN REvlEwlNG THE U.S. PROGRAM.
AT TH! s-t flME, 40 WEVER, dE ARE NOT YET IN A P0$1T10N TO DETERMINE j
IF THE LESSONS LEARNED AT CHERN0BYL WILL REQUIRE CHANGES t
IN THE RADIOLOGICAL EMERG*NCY PLANN'.NG.
hiMA, THEREFORE, CONCLUDES THAT THE' PETIT!0N DOES NOT i
PRovlDE INFORMAT10N dHICH $U$TAIN$ THE CONTENTION.
I l
- 0) PETlfl0NERS:
"A$1NG al$ CONCLUE10N UPON NMC DATA, THE ATTORNEY SENERAL l
0F hAS$ACmuSETT$ mA$ CONCLUDED THAT THE $11E OF THE PILGRIM t
LPl l$ INADE0VATE (CCMMENTS OF ATTORNEY 6ENERAL FRANCl$
X.-
i l
3ELLUTTI MELATlvE TO UFF*$1TE LMERGENCY PLANNING FOR THE 1
PILGRIM f40CL E A R power STATION, $USMITTED TO FEMA, AUGUST 1
1982).
1 I
f rthA:
IN dESPONSE TO A JUNE 3, 1982, PUBLIC MEETING ON THE $ FATE I
i i
AND LOCAL UFF*$1TE MAD 10 LOGICAL EMERGENCY PLAN, A$$15 TANT 4TICRNEY 6ENERAL J0 ANN $HOTwtLL OF THE ENVIRONMENTAL PRO
- ECTION O! Vill 0N OF THE MASSACHU$ETTS ATTORNEY 6ENERAL'$
)
0FFICt RtoutSTED $Y A LETTER OF JUNE 16, 1982, THAT THE MEETING RECORD BE LEFT OPEN UNTil THE ENQ OF JULY $0 THAT HER OFFICE COULD SUBMlf FURTHER COMMENTS.
THE ATTORNEY GENERAL'$ OFFICE RETAINED MHW TECHNICAL A$$0CIATES OF SAN J0$E, (ALIFORNIA, TO REVIEW FOR THEM CERTAIN DOCUMENTS RE-LATES TO OFF-$1TE PLANNING AROUND THE EILGRIM NPS.
Iitf l
I MHB REPORT wA$ TITLED "KEVIEW OF CALCULAT!QN OF KEACTOR CON-1 i
l i
39 -
SE;UENCES ('.KAC.) EESULTS AND L100!D EATHWAYS ( NURE':- 159 b )
ELANNING ;N THE VfCINITY iTUDY:
!MPLICATl0NS FOR LMERGENCY 3F THE flLGRIM NUCLJAR POWER $1AT10N".
IN A LETTER DAT5D 1981, -RANC15 A.
OELLOTTI, THE.1A55ACHUSETTS I
AUGUST 4;,
ATTORNEY GENERAL LAG) SENT To FEMA KR.G10N l, FIFTEEN PAGE5 is5UES.
UNE OF THEss COMMENTS ADDRE551NG FOUR GENERAL 0F ISSUES DEALT alTH THE $12E OF THE 10-MILE PLUME EXPOS t2
- ASED ON MMD's TECHNICAL Review 0F THE REFERENCED NRC s0CU"ENTS, I*E ".A55ACHUSETT5 AG INDICATED THAT 80 TEN-dOULD EXCEED THE LEVELS AT T!at 05!5 *OT*E 80*VLAT10N THE EPA PROTECTIVE ACTION GUIDES RECOMMEND EVACUATION, dMICM EVEN AT DISTANCES OF 50 MILES DowNw!ND FROM THE PLANT.
THl5 SITUATION, THE AG BELIEVES, dOULD OCCUR QURING AN $$I-l WEATHER CONDITIONS THAT
- 0RSE CASE ACCIDENT UNDER CERTAIN RESULT IN MAX! MUM DOSE.
IMUS, THE AG BELIEVES THAT THE CURRENT USE OF TwE !U-MILE LFl FOR PILGRIM 15 NOT APPRC-
&RIATE, AND TH AT T*E (Pl SHOULD, THEREFORE, BE EXTENDED FURTmER TO INCLUDE ALL OF LAPE (00 Im!S SAME CONCERN dA5 RA15ED BY MASSPIRG AND A5 REFERRED TO THE NRC FOR THE!R RESPONSE As IT was 1,N DIRECT CONFLICT WITH NRC's REGutAtl0N 10 CFR 50 7 (C) (2).
NRC's RtSPONSE 1
PAGES 10-14 0F NKC'5 'lNTERIM TO MASSPIR6 !$ DISCUSSED ON 10 CFR 2 206 (DOC (ET No. 50-293),"
DIRECTOR'S DEC1510M UNDER
'l (FEsausRY 27, 1934).
1
40'-
THE PLUME t?l FOR THE PILGRIM IHE RESPONSE STATES THAT FACILITY !$ BASED UPON NUREG-0654 GulDANCE CRITER!A.
INE J0!NT NRC/d/4 IASK E0RCE THAT DEVELOPED HU CON 51 DEWED SEVERAL 805515LE RATIONALES FOR ES
$ltE OF THE E??S.
IMESE INCLUDED RISK, PROBAllLITY, COST THE ACCIDENT CONSEQUENCE SPECTRUM.
EFFECTivtNE55 AND AN A FULL SPECTRUM QF IASK E0RCE CMost TO 3ASE LPl $1DE ON
~
PROB-ACCIDENTS AND CORRESPONDING CONSEQUENCES TEMPERED B j
ABILITY CONSIDERAtl0NS.
IT WAS THE CONSENSUS OF TME IASK 3 0RCE THAT A *LUME -94 0F ABOUT TEN M I L E S 40VL D 8 90 V l D,E A N l
ADEVATE PLANNING BASE BEYOND am!CH ACTIONS COU i
A2121 B A515 USING THE $ AME CON 51 DER ATIONS ON AN INTO THE INIT!AL ACTION DETERMINATIONS.
IN ITS STATEMENT 0N "PLANNING BA515 F.OR EMERGENCY RESPONSE TO NUCLEAR power f
ACCIDENTS," 44 FED. REs.
61123 (UCT. 23, 1979), THE Commis-
$10N NOTED THAT AN EPl 0F ABOUT 10 MILES 15 CON 510ERE J
RESPONSE BASE dHICH wCULD SUPPORT 1
LARGE EN0 UGH to PRovlDE A l
4t QUTSIDE THE PLANNING ;QNE SHOULD THl5 EVER l
ACTivi1Y
]
NEEDED.
l IME PETITIONER CONTENDS THAT, BASED UPON THE REFERENCED f
THE CVARENT PILcRin PLunt CRAL 2 RE5uLTS, AN ENLARGEMENT OF LPl 15 w ARRANTED stCAu$t THE PRcaECTtD Dost$ E PROTECTIVE ACTION DUIDES (?AUS) OUT5tDE THE IU-BOTH NURtG-Ub54 AND NUMEG-039b RECOGN!!E, S ASED UPON RE5'VLTS, THAT THE PAGS Ml3HT BE EXCEEDED SEYOND T:.0. TEN M O'
l i
PLVME EXPOSURE !?l IN THE EVENT UF THE DOR $f PO$$18LE ACCIDENT l
i AND *ETEOROLOGICAL CONDITIONS.
90wEvtR, A TEN MILE 8LUME Ex*0$0RE
?! dAS STILL CMosEN A$ A PLANNING BA$ll IN NUKtb-ObD4 BECAUSE:
A.
- ROJECTED DOSES FROM THE TRADITIONAL DE$1GN BA$ll ACCIDENTS w0VLD NOT EXCEED fab LEVELS QUT$lDE THE i
ZONE; j
3 PROJECTED 00$ES FROM Mo$T SEvlRE FUEL DEGRADAT!QN l
$EQUENCES wCULD NOT EXCEED FAG LE'vtLS QUT$lDE THE j
20NE; C.
80R T*E *0R$E 8UEL DEGRADATION SEQUENCES, IMMEDIATE Ll'E THREATENING DOSES wouLD GENERALLY NOT OCCUR UUT-
$1DE **E l0NE; AND i
D.
DETAILED PLANN!NG dlTHIN IV MILES dOULD PRovlDE A $US-i
$TANTIAL BASE FOR EXPAN510N OF RE$PON$t EFFORTS IN THE i
l EvtNT T*AT T*ls PROVED NECESSARY.
j MENCE, AT THE PRESENT TIME, NKC MAS INDICATED 70 FL,3A THAT THERE 15 NO BA$ll FOR REQUIRING (HAT A PLUME EXPOSURE PATH-j day t?! $ MOULD SE GREATER THAN APPROXIMATELY A lV-MILE RADIUS FROM THE PLANT.
i I
L *A, THERE50RE, CONCLUDES THAT THE petit!ON DOES NOT 840 VIDE j
INFORMAft0N aMICH $USTAINS THE CONTENTION.
]
l 20/ LAOK OF COORDINATION AND PRIORITIZATION OF THE REkP i
A) PETITt0NER$t IME NRC $HOULD $U$ PEND THE OPERATING LICEN$t OF THE PitoRlm i
power PLANT UNTIL A REAlllTIC, DETAILED RERP 15 DtvtLQPtD, l
SHowlNG AN ACTUAL CAPAllLITY TO EDUCATE, AltRT, TREAT AND J
EFFICitNTLY EVACUATE ALL PEDPLt WHO MAY St AT R15K FROM A I
CAT ASTROPM tC ACCIDENT AT THE PLANT.
FEDERAL, STATE AND A$ WELL A$ B0$ TON (D!$0N,INSTEAD HAVE LOCAL 40VERNMENT AGENCIES, TO EMERGENCY PLANNING.
i ALL' ACCORDED A Low PR10RITY 0F TRYlNG SERICUSLY TO DEVllt A PLAN THAT WILL PROTECT ALL I
1
a i.
i 1
0F THE PUBLIC, PLANNER $ MAVE SOUGHT TO ACMitVE ONLY MINIMUM l
COM8LIANCE dlTH NKC 4EGULATIONS; AS SECT 10NS 13 THA0 UGH 13 j
I 0F TMis 8tTITION DEMONSTRA.E, TMtY MAVE FA!Lt0 TO 00 t/EN I
THAT.
IMll INSUFFIC! TNT COMMITMENT TO PUBLIC PROTECTION l
15 EVIDENT IN MIS $tD DEADLINES, $ Low PROCCS$ LNG OF # APER-40RK, LACK OF ATTENTION TO OtT A!L AND INAD10VATE SUDGETS j
1 AND $TAFFING.
a f
IO Daft, FEMA MAS LARGELY ACoutt$CED IN PLANS THAT Fall 70 DEMONSTRAft A CAPallLITY TO ADEQUATELY RESPOND TO AN ACTUAL l
EMERGENCY, AND FEMA * $ ACQUlESCENCW M AS BEEN EMULATED BY YMt i
NK(.
wHERE FthA MAS CRITIC 11ED PARTS OF THE PLAN, TML MA$$ACMustTT5 CIVIL dtFEN$t AGENCY (NCUA) MAS NOT RESPONDED
!N A TIMtLY FA$M10N TO FtnA'$ CONCERNS.
FOR EXAMPLE, AC-STATE LEG 15L ATOR$
i CORDING 70 TESTIMONY BEFORE NA$UACHU$tTTS.FLhA, hDWARD A.
MOMAS OF THE AGENCY
- i QN JUNE 13, 19D6, SY i
SENT LETTER $ OUTLINING Ptt$1 STENT FLMA CONCERNS TO MCUA IN VCT08tR, 1985 AND JANUARY, 1986 FthA RECT!V[D NO RESPON$t
[
l 70 Tat sCTOBER LETTfR UNTIL JUNE 3,
1986 AND PdhA NAD '407 i
YET RtCtiVED & RE$kON$t TO TML JANUARY LETTER SY THE T'!ME l
0F THE HEARING.
1 FEMA:
t l
ON JUNE 15, 1981, TMt DIRECTOR OF TMt MA$$ACMUSETTS CIVIL i
DEFEN$t AGENCY (MCDA) ON SEMALF QF TML GOVERNOR OF TML 1
COMMONwtALTH OF MA$$ACHU$tTT5 $USMITTED THE RADIOLOGICAL l
j
[MitGENCY RESPON$1 OLANS FOR REVllW PUR$UANT TO 44 (FK 350, l
AND STAitD THAT IN THE OPIN10N OF ".CDA THE PLAN WA$ ADt0VATE I
l To PROTECT TML Pultic MEALTH AND $AFETY.
UN SEPTEMltR 29, 1
j 1982. FEMA !$$utD AN INTERlM FINDING THAT ALTHOUGH THE PLAN $
{
r s
dtRE NOT PERFECT, *TMt INTERIM FINDING QF FLMA 13 TMx' TML I
STATE PLAN AND LOCAL PLANS TOGETHER ARF ADt00 ATE TO PRO-TECT TMt HEALTH AND SAFETY OF THE PullIC.*D ON MARCH b, 19Wb f
AND OCTOstR 30, 1985 FhhA INFORMED THE MAllACHUSETTS Livlt OtFtN$t AGENCY sY ttTTER THAT stCAu$t or uMRESQLVED EMERGENCY I
l PLANNING IS$UES RAl$tD DURING THE RAC REVltWS OF UCT05tR 1981 l
1
- a3 -
AND iEPTE*BE1 19b2, AND DURING THE ft32 AND 136) EX MAD SU$ RENDED PROCESS!NG THEIR RE0 VE PURSUANT 7 0 a a L.: R 350 FLh4 NAS NOT RESUMED ITS PROC OF THE 350 APPR0 vat REQUEST SECAUSE MCDA HAS N
~
ADE0VATELY ADDRE$5ED THE !$$UES RAISED IN THE LETTERS.
IT SHOULD SE UNDER$T00D TWAT *HILE THE RESOLUTION OF T ENHANCE THE "AS$ACHUSETT5 PILGR!M Kt'RP, NEVERTHELES$
THE
- LANS "AVE BEEN FOUND TO BE ADE0 LATE IN
=IN!"Vi iTANDARD OF PROVIDING A REASONABLE A$$URANCE THAT T-E STATE AND
.] CAL *LANS A#E ADEOUATE TO PROTE: 7 TH AND SAFETY OF THE PUBLic IN THE P!LGRIM tPt.
!111, SELF-INITIATED dEvlta AND INTERIM ?!NDING FOR UPDATED INFORMATION.}
txtRCl$ES OF THE PLANS AND PREPAREDNESS OF STATE AND LOCAL GovtRNMENTS alTH!N THE PLUME lxPOSURE EMERGENCY PLANNING l0NE FOR THE O ltGalM NUCLEAR power STAtt0N 'aERE OBSERVED SY Fth ON MARCH 3, 1952; JuNt 29, 1983, AND SEPTEMsER 5, 198$
A REvlEw 0F THE EXERCISES INDICATES THAT T Mass ACHUSE f ts HAs MOVED PROMPTLY TO CORRECT PLAN OR PERFORM-ANCE PROBLE*$ aHICH WOULD INTERFERE THE PulLIC IN THE EVENT OF AN ACCsDENT AT,. PILGRIM.
THE 1982 AND 1983 EXERC15ES DEMONSTR ATED THAT A CAPABILITY EXISTED STATE AND LOC AL GOVERNMENTS FOR TO PROTECT THE HEALTH AND SAFETY OF THE PUBLIC IN THE EVENT OF AN ACCIDENT AT THE P16G31M NUCLEAR POWER STAT 10N.
44 -
!iOWEVER, FtMA'S OBSERVATION U/ THE EXERC15E CONDUCTED ON SEPTEMBER
),
1985, IDENTIFIED FOUR DEFICIENCIES IN THE EXER-FEMA Now us,ES TME word "DEFICIENCIES" TO MEAN Cist.
DEMONSTRATED AND OBSERVED INADEQUAClES THAT WOULD CAUSE A FINDING THAT OFF-SITE EMERGENCY PREPAREDNES$ WAS NOT ADEOUATE TO PROVIDE REASONABLE A$$URANCE THAT. APPROPRIATE PROTECT!vt MEASURES CAN DE TAKEN TO PROTECT THE HEALTH AND $AFETY OF THE PUBLIC LIVING IN THE VICINITY OF A NUCLEAR POWER FACILITY IN THE EVENT OF A RADIOLOGICAL EMENGENCY.
l UN SEPTEMBER 20, 1985, FEMA SENT A LETfER TO MCDA INFORMING THEM OF THE Ex!$TENCE OF THE FOUR DEFICIENCIES IDENTIFIED FOR 1
THE CARVER ECC AND THE I AUNTON RECEPTION CENTER.
UN UCTOBER 29, 1985, A MEMEDIAL tXERCISE wAS HELD TO DEMONSTRATE CORREC-fl0N OF THESE DEFICIENCIES.
IHE FOUR DEFICIENCIES wfRE CORRECTED.
lSEE bthA 1 DOCLMENT, "KEPORT ON THE KEMEDIAL txERCl5E FOR THE FILGRIM NUCLEAR F0wtR bfATION*, UCTOBER 29, I,
1985).
I IHE COMMONWEALTH OF MA$$ACHUSETTS RESPONDED PROMPTLY TO THE l
DEFICIENCIES IDENTIFIED DURING THE 1985 EXEP.Cl5E.
45 INDI-CATED AB0VE BOTH SY FEMA AND THE PETITION,ERS, THE RESPONSE TO IS$UES WHICH WERE NOT CATEGORIZED AS DEFICIENCIES HA$ NOT l
SEEN TIMELY.
FOLLOWING THE juME 29, 1983 EXERClst NO DEF1- '
CIENCIES WERE IDENTIFIED AND THE COMMONwtALTH PROVIDED A 1
l
- iD -
COMMUNITY LEVEL.
IHE bTATE TKEN PROVIDED A SCHEDULE OF CORRE*TIVE ACT10NS IN A LETTER TO F6MA DATED JUNE 29,.985, FCR a '.L STATE AND LOCAL *0MMUNITY INADEQUAClES NOTED AT THE l
1983 EXERCISE.-
EMA CASERVED, DURING THs 1985 ExERCi$E, THAT hANY OF TH8 PRolLEMS !DENTIFIED IN ThE 1982 AND 1983 EXERCISES HAD SEIN CORRECTED, BUT MA,Y NEW ' AREA $ REQUIRING N
CORRECTIVE ACTION" (ANCA) AND FOUR DEFICIENCIF.$ WERE IDENTIFl!D.
H AD CORRECT ED THE DEF ICIENCIES SY OCTolER l
INE COMMONWEALTH 29,.935 AnD ON UCT0sER 50, 1985 PRoviDED FtNA dlTH A PLAN OF ACTION aMICH, !T FELT, !F IMPLEMENTED =0VLD RESOLVE THE l
" a R E A ', 4ESUIR11G CORRECTi'E ACTION".
UN MARCH 3,.'#bo PthA 1
SENT THE LOMMONaEaLTH THE REPORT ON THE $EPTEM8ER D, 1985
]
EXERtlSE.
INE LOMMONwtALTH, A$ PROVIDED IN EhMA GUIDANCE, 4AS TO PROVIDE EtMA wlTH A SCHEDULE OF CORRECTIVE ACT10N$
TME
- AREAS RE3UIRING CORRECTIVE ACT!0N' dlTHIN 30 DAYS FOR i
OF THE REPORT'$ RECEIPT.
ALTH0uGs FEMA MAD NOT RECElvtD A i
V I
$CHEDULE SY THE TIME THE PETITION WAS FILED, IT DlD NOT PEEL j
Tmt $CHEDULE da$ OVERLY LATE.
THE COMMON' WEALTH HA$ NOT YET, MOWEvtR, $USMITTED ITS $CHEDULE OF CORRECTIVE ACTIONS. IHl$
l
$U3 JECT 15 DEALT WITH IN FEMA'$ SELF* INITIATED RIVIEW ST i
t PP 37-44
)
PETITIONER $:
i ANOTHER EXAMPLE OF THE SER100$ LACK OF C00RDINAT10N WA$ THE F AILURE OF MCUA TO DELIVER TO EthA AN UF"T0*DATE VER$10N OF 1
THE STATE EMERGENCY PLAN.
ACCORDING TO STATEMENTS SY F6hA j
l AND MCUA 0FFICIALS IN THE JUNE 20, 19Bb EDITION OF THE i
l PATRIOT LEDGER OF QUINCY, MA, THE rLAN WAS NOT DELIVERED UNTIL 10 MONTHS AFTER IT WAS PREPARED.
M(UA COMPLETED THE i
i i
i l
I
\\
_ _, _ ~ _ _.. _ _ _ _ _ _ _. _
46 -
i UPDATED PLAN IN August; 19$5 auf Dio NOT DELIVER A Copy 0, IT UNTit JUNE 25, 1986 PtNA HAD FORMALLY REQUESTED A COPY IN OCTOBER, 1985, 3U7 DID NOT FOLLOW UP QN THAT ACDA'S FA! LURE TO RESPOND TO PtnA'S REQUEST AND OF THE' PLAN FEMA'S CVIDENT LACK OF CONCERN AND UNWILLINGNESS T REQVEST.
ARE SYMPTOMATIC OF AN EMERGENCY MORE RES?ONSIVE ACTION 15 UNCOORDINATED AND GivEN LOW PR RESPONSE REGIME THAT 175 ATTENDANT PUBLIC AGENCIES.
SY
~
4 EtMA:
)
IHE BULK OF TME MASSACHUSETTS dEKPS F 'O R THE Pilgrim EPl wHlCH TiMA MAS ON FILE ARE CURRENT.
IHE LAST MAJOR REVl5!ON TO THE P AN WAS IN 1982 AND FEMA HAS THOSE CH,ANGES.
MINOR STATE L
CHANGES TO LOCAL *LANS dERE MADE IN 1985 FEMA REcVESTED
)
COPIES OF THE 8LANS ON OCTOBER 50, '.955, AND FEMA RECEl ED COPIES OF THEM FROM MMM ASSOCIATES IN A LETTER DATED JUN 1986 THE COMMONWEALTH SUBSEQUENTLY INFORMED FEMA THAT 1985 VER$10N OF THE LOCAL PLANS wERE CURRENT.
FEMA wout0 j
EN".0VRAGE ATTEMPTS BY THE COMMONWEALTH OF MASSACHU GivE RADIOLOGICAL LMERGENCY PREPAREDNE$$ PLANNING A ARICRITY.
)
C) ?!TITIONERS:
FuRTHER EvlDENCE Or THis LACK OF COORDINATION AND PRIO
- 7. A T 10 N wAS REVEALED IN MR. IMOMAs' JUNE 13, 19Bb TESTIMONY.
EDISON HAD FAILED REPEATEDLY da. IHOMAS STATjD THAT BOSTONTECHNICAL $PECIFICAtl0NS ON 70 DE61vtR 70 FtMA NECESSARY THE SIREN $ THAT WOULD NOT15Y THE PUBL'C 0F A RADIOLOG PLANT.
MR. "H0M'AS $TATED THAT EMCRGENCY AT THE FILGRIM THES'i DELAY $ BY BOSTON EDISON HAVE FORCED REPEATED IMUS, THE SYSTEM HAS NEVER REEN MENTS OF SYSTEM TESTING.
GIVEN THE FULL *$CALE TEST REQUIRED BY FEMA.
FEMA:
AS NOTED IN THE RESPONSE TO ITEM 16 ABOVE, FEMA RECEIVED THE
. $1REN SYSTEM TECHNICAL S P EC I F IC AT IONS ON JUNE i'), 1985, AND DERFORMED A DETAILED REvlEd 0F THE STATE AND LOCAL 89LL-SCALE SIREN TEST ON 3EPTEMBER 23,.336 4ESULTS OF THE SIREN TEST INDICATED THAT 38 2% OF THE PEOPLE dERE DIRECTLY ALERTdD BY THE $1RENS ON THE DAY OF THE TEST.
HowtVER THE PETITION DOES NOT DEMONSTRATE THAT TH,ESE DELAYS INTERFERED alTH THE COMMONdEALTH'S ABILITY TO PROTECT THE PUBLIC.
- 0) HETITIONERS:
l ImE E"ERGENCY RESPONSE SYSTEM'S LACK OF PR10RITIZAtl0N !$
l FJRTmER DEMONSTRATED BY THE FACT THAT LOCAL Civ!L DEFENSE V
a3 ENC:ES IN THE CO*wuNITIES wlTHIN THE LMERGENCY LANNING
.ONE, ave SERIQUS STAFFING AND suDGETARY PROBLEMS.
AOST LOCAL CIVIL DEFENSE DIRECTORS WITHIN THE EPl ARE UNPAID OR RECElVE ONLY SMALL STIPENDS.
MOST HAVE LITTLE OR NO PAID STAFF.
INE RELIANCE'ON VOLUNTEERS, wHo 0FTEN HAVE MINIMAL j
PROFES$10NAL EXPERIENCE OP. TRAINING, REFLECTS THE UNwlLLING-NESS OF STATE AND LOCAL GOVERNMENT TO MAKE A GENUINE COMM MENT TO EMERGENCY RESPONSE PLANNING.
MAJOR IMPROVEMENTS IN STAFFING AND BUDGETS OF STATg AND LOCAL CIVIL DEFENSE BODIES MUST BE IMPLEMENTED BEFORE PulLIC SAFETY CAN SE ENSURED.
MORE0VER, LEST THE NECESSARY MEASURES TAKEN CONSTITUTE PUBLic SUBSIDlIATION OF THE FINANCIAL REQUIREMENTS OF A J
SAFL NUCLEAR PowtR SYSTEM, BOSTON EDISON SHOULD SE REQUIRED l
I 4
to PRovlDE THE FINANCIAL MEANS FOR THEM.
3 EMA:
J FEMA FEE ($ THAT THIS ALLEGATION 15 TOTALLY WITHOUT MERIT 1
BASED UPON PAST HISTORY WITH VOLUNTEER G O V E 2.d H E NT IN THE U.S.
EACx DAY THOUSANDS OF VOLUNTEERS IN' LOCAL GOVERNMENTS PERFORM ADMIRABLY, OFTEN WITH GREAT RISK TO THElR PER$bHAL l
SAFETY AND WELL*SE!NG.
UNE EXCELLENT EXAMPLE OF THis il THE 1
DEDIC ATION AND COMMITMENT DISPLAYED BY VOLUNTEERS WHO IPATE IN RADIOLOGICAL EMERGENCY RESPONSE EXERCISES AND R 1
l l
1
, POND TO EMERGENCIE$ IN THEIR COMMUNITIES ON A DAILY 3A$13 AS NOTED SY rEDERAL EVALUATOR $'
"0MMENTS IN EXERCISE REPORTS FOR THE EXERCISE $ OF THE iAD!0 LOGICAL LMERGENCY sF.$PON$t PLANS FOR THE ?!L3 RIM fiUCLEAR POWER STATICN IN 1982, 138),
AND 1985, THE DEDICATION AND COMMITMENT OF THE VOLUNTEER $
HAS BEEN CON $l$7ENTsY DISPLAYED.
IHE VOLUNTEER $ HAVE IN-CLUDED LOCAL CIVIL DEFENSE )! RECTOR $ t.ND STAFF, SELECTMEN, lRE DER $0NNEL, PARA
- MEDICS, KED CRos$ VOLUNTEERS, MACES
~
AMATEVR RADIO OPERATOR $,
THE ClVll klR PAT *cL AND OTHERS.
ImE.0LuNTE!;$ ARE <NowtEDGEABLE OF THEIR DUTIES AND CON
- SCIENT10VS IN THE PERFORMANCE OF THESE DUTIES.
ALTHOUGH VOLUNTEER $ RECEIVE LITTLE OR NO $T! PEND $ FOR THE!R SER*
VICES, THEY ARE dORKING TO MAKE THEIR COMMUNITIES A SAFER AND BETTER PLACE FOR THE!R FAMILY AND FRIENDS TO LIVE.
i' MANY VOLUNTEER $ HAVE INDICATED To OUR STAFF THAT THE $AT*
ISFACTION OF mEL81NG PROTECT THE!R COMMUNITY AFFORD $ THEM i
FAR GREATER REaARDS AND INCENTIVE THAN ANY MONETARY COMPEN*
$ATION COULD PROVIDE.
FEMA, THEREFORE, CONCLUDES THAT THE IS$uts RAISED IN SEC-floN 20 or THE PETITION DO NOT PROVIDE INFORMATION WHICH
$USTAINS THE CONTENTION.
i i
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FUDINUILS 1
'HANS, JOSEP.8 i 1., JR.;
SELL, 1808AS L., tvAcuaTioN AN EVALUATION, ENVIRONMENTAL PROTECTION K11%$
AGENCY, tFA-340/0-74-UU2, JUNE,,1974 s'.
Is!D; PG 43 3
IBID; PG 13 j
Stattungt }-13, l
4.
IREADwELL, MATTIE E.,
HusetcANE CARLA 1011; UEPARTMENT OF UEFENSE - UFFICE OF LIVIL dEFEN$E, i
KEGION V, DENTON, IEXA$, PG 16 1
l 3
EEMA RE310N I INTERIM FINDINGS ")CINT STATE AND LOCAL LMERGENCY RESPONSE CAPAllLITIES FOR THE P!LGRim NUCLEAR power STATION, PLYMOUTH, MA$$ACHU$ETTS, SEPTEMBER 1962" l
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)%f)
L O
O FEMA COMMENTS ON THE REPORT TO THE GOVERNOR UN EMERGENCY PREPAKEUNESS FOR AN ACCIDENT AT THE PILGRIM NUCLEAR POWER STATION
- JULY 29,1987 FEDERAL EMERGENCY MANAGEMENT AGENCY
]
JOHN W. McCURMACK POST OFFICE AND COURTHOUSE BOSTON, NASSACHUSETTS 02109-4595 49 c)8tBooop j Agf-
I.
INTRODUCTION un December ::. 1086, the Secretary of Public Safety. Charles Barry, forwarded a copy vf the "Rwport to the Gosernor ori Emergency Preparedness for an Accident at the Pilgria Suelear Power Station" IBarry Report) to.the Federal Emergency Management Agency (FEMA).
He request,ed that TEMA review the
- report, inform him of its findings, and tell him what steps TEMA intended to take.
The Governor and the Dirwetor of the
{
t
'tas.achusett.
cis11 Defense Agency (MCDA) have endorsed the Barry Report and FEMA.
therefore, views this report as the j
authoritatis, and current position of the Commonwealth.
i TEMA has unal):ed the Barry Report and used its analysis in deseloping TEMA's July 09, 1987 report "Self-Initiated Review i
and Interim Finding" (Heretnsfter Self-Initiated Review). The j
Coma.unwealth concluded hat the emergency response plans for l'
in icetdent at the Pilgrim Nuclear Power Station are not I
adequate to protect the health and safety of the public. FEMA has also concluded that the plans are inadequate for the reasons cited in its Self-Initiated Review.
W Many of the issues raised in the Barry Report were previously identified by FEMA.
and date back to the 1981 and 1982 i
j Regional Assistance Committee (RACI reviews
'of the j
Commenwealth's Radiological Emergency Response Plans and the l
1 1
,, _ ~
y
_.._.,_,.,,_,,.__.-__m.
. - _. _ - _, -. - -.,. ~,. - _.
September, 1982 Interim Findings. Other issues raised by the Barry Report provided new information to FEMA which was very useful in conducting its Swif-Initisted Review.
FEMA applauds the diligence and hard work that went into the
- e. amination of its emergency plans Commonwealth's critical N
and welcomes its commitment to develop a
c ompre he r.s i ve prusrsm to resolse the problems identified by both FEMA in its Interim Finding, and the Communwealth in the Barry Report.
FEMA look. forward to working with the Commonwealth on this l
'.mpertant project.
FEMA feels, however, that, for the sake of the record, there are issues in the Barry Report which need to be clarified.
FEMA has, therefore, provided comments on specific sections cf the report below.
I II.
Specific Comments 1.
Warri. Recott First, there are factors beyond the state's control, such as reactor
- design, plant management and the aggressiveness of federal regulators.
that have a direct impact on energency preparedness. (p.11 1
EKg1 Comment:
]
2 I
i
FEMA has reviewed plans submitted by the Commonuealth in 1981 and 1982 and resised local plans submitted in 1956.
FEMA has consistently informed the Commonwealth of weaknes.es in its plans.
The Commonwealth has previously either stated that it was working on improving the plans or pledged to correct the plans.
The Communwealth has primary responsibility to maintain and impruse the radiological emergency response plans in thw in en t of an occident at the pilgrim Nuclear power 1
F t J t i wit.
J 0.
EggIl Recert-l On a number of occa ions over the years,. Civil Defense has requested support from FEMA and from SECo.in accordance with federal regulations.
These efforts led to.i consultant being made available te the Department of public Hva'th and one planner being made available to
(
Massachusetts Civil Defense s u ppo r t ed by utility company grants to the Massachusetts Health Research Institute, Inc.
- However, in view of the fact that Massachusetts Civil Defense has to coordinate planning for three licensed plants affecting Massachusetts.
j (Rowe, MA.
plymouth.
MA and Vernon.
VTl and until involved in planning actisities for the April
- 1986, was j
Seabrook power plant, the resources made available to the r
agency have been totally inadequate. (g.13) r
[13A Comment:
FEMA has provided all the technical assistance on emergency planning requested by the foanonwealth over the I
years.
FEMA also has permitted employees of the
)
3 l
j
)
i i
Commonwealth, either fully vr partially funded by FEMA, the Esdiological Emersancy Response Program.
to work un All other States in Nes England adequately fund their Radiological Emergency
Response
Program.
FEMA is encouraged that the Commonwealth is in the process of obtaining funds for its program.
3.
3pyy Reevrt' 4
i r e. gv ei n e is thu MASSPIRC r e po r t a.,a s published by FEMA on Nosember J, 1983.
This response noted that "(w]hile f
MASSp!RC raises a number of good points, after a detailed i
an31ysibe We (IIMA} Continuo to Bake the InteriS Iindi38 that the Commonwesith of Massachusetts has demonstrated that there is reasonable assurance that the public would at the i
be adequately protected if there were an accident Pilgrim Nuclear Power Station." (p. 15)
I 1
4 f.n!3 Comment-i i
4 FEMA largel) based its response to the MASSPIRG Petition un a review of the plans and information provided in the i
"Massachusetts Civil Defense Agency (MCDA)
Analysis to Blue
]
the Massachusetts Public Interest Group Report 1
Print for Chaos II:
Pilgrim Disaster Flans.
Still a Disaster" (copy attached).
t 4.
Barry Reeort:
I i
)
In May and June 1985, revised state and local plans were I
t l
t
c publisned by Civil Defense and distributed to federal, state and local officials. (p.171 FEMA f.omment' FEMA has not received a
revision to the State Radiological Estersency Response plan since 1982.
In a letter to FEMA dated April 10,,
1987 The Director, Massachusett. Ch il Defense Agency, informed us that the the wperational plan.
1982 ser tun was FF.MA reevased copie. of the 1985 local plans on June 25.
1986.
FEMA's resivw of these plans indicate that the major issues identified in the 1981 and 1982 RAC Reviews and the 1982 Interim Findings have not been addressed.
i 5.
Barry Recort:
On October 30, 1985 FEMA wrote the Massachusetts Civil l
Defensw once again concerning formal approval of the
- pisns, and indicated that the process sas "on hold' pendina recaipt of material called for in the 1981 and 1982 RAC Reviews.
FEMA also requested copies of 1985 l
resised plans.
These plans were ande available to FEMA during the September 1985
- exercise, but evidently were rio t formally delivered until June, 1986.
On June 6, 1986 Cisil Defense responded to FEMA, and indicated that work remained to be done to prepare the plans for the formal
- review, and that a
lack of resources was impeding arogress.
(pp. 17, 18)
FEMA Comment:
FEMA first wrote to MCDA on March 6,
- 1985, informing 5
it that FEMA was sospending processing of the June, 1981 formal emergency plan approval pursuant to 44 request for CFR 330 becau.e "there are a
number of outstanding in the State and local plans and procedures deficionetes which we cannot certify have been c o r r e c t e d .
These issues were raised in the 1961 and 1982 RAC reviews and in the 198 and 1983 exercise reports.
At the September 1986 exercise the revised local plans were utili:ed by local officials; however.
FEMA dad not recei e eupies for review untti Junv. 1986.
6.
Barrv Renort*
Reevetion Community plans _... pilgrim had three (Hanover.
Bridgewater and Taunton). (p. 411 I
I FEMA comment:
Although FEMA knew of problems with the Ndnover Mall Reception
- Center, it was not formally informed of the e
l wi*.hdrawal of Hanover until February 27, 1987.
l I
l 7.
Barry Recort:
l l
(The ETE) is based upon outdated informatior,.
Furtnermore, it rests on a series of highly controversial assumptions.
For example, the pilgria ETE assumes that "people not in the planned evacuation bou..daries for each l
case would not choose to evacuate anyway".
This ignores of the so-called "shadow phenomenon" which i
consideration is a
theory that holds that during a
radiological j
6 1
1 2
4'
I emergency there will be widesp' read spontaneous evacuation.
(p. 44) c mment' FTMA o
FEMA conducted a detailed analysis of evacuation issues for the Pilgrim EPZ in response to a January 20,
- 1984, request from the SRC.
FEMA issued its report on May 1, 1984.
The State Police Traffic Management Plan provides for its control of esacuation router, several males beyond the EPZ boundary, thereby enabling it to prevent people be.s o nd the
FEMA does not disagree with the Commonwealth that an updated Evacuation Time Estimate IETE) may enhance the Ptigrim plans and *ndorses the state and utility efforts i
/
to conduct suet, a study.
3.
Barrv Report:
The federal response tc the dilemma of state planners who 1ack authoritative site-specific data and minimum,ETE l
standards is to point out that sheltering, and not evacuation, is the solution in the cane of the extremely
- severe, fast-breaking accident....
Unfortunately, that j
alternative provides no greater assurance that public i
health can be protected.
(The report then goes on to quote from a
transcript of the 1983 Congressional Oversight Hearings between Congressman P3tterson and Mr.
i
- Krsam, Assistant Associate Director, office of Natural i
and Technological Hazards, c c nc e rn'.n g sheltering.)
(pp.
45, 46) l TEMA Comment:
4 l
7 4
e
4 Congressional oversight Hearing is not the vehicle through which guidance on the efficacy of sheltertnd as a proteetise action is provided to state officials.
Agencies of the Federal Government have published information concoruing shelter.
as a proteettse action.
The Environtaental Protecti,on Agency has published "Protoettsu Action Esaluation Part 11:
Evacuation and Shwltering
,i s Protestise Actions Against.
Nuclear Aevidents insolv'ng Oaseous Releaves.
1978."
This i
2 J oe u nie n t was widely distributed and has been discussed ttmes with state officials over the years.
The U.S.
many De pa r tine n t of Health and Human Services published in 1983 "Preparedness and Response in Radiation Accidents", which evntains information concerning shelter as a protective uetton.
On February 25. 1985.
.lueument to MCDA and the Massachusetts Department of i
Public Health.
In addition a considerable amount of I
information on the subject of sheltering as a protective l
action has been provided to both state civil defense and rad'.clogical health personnel by bo,th FEMA and the NRC.
FEMA is studying the subject of sheltering as a
i protective action.
This study any lead to the i
l developsont of guidelines for saking protective action i
l i
decisions regarding either the use of shelterins versus 8
j 1
I e
evacuatior, or a combination of these two options.
9.
Barrv Reuvrt (Ald hoe plannant is clearly inadequate when a fast-I breaking incident occurs. Ip. 481 1
FEMA Comment:
As ststed in the July 29.
19.t* Self-Initiated Reviet..
this represents a
reversal of the Commonwealth's I
lung-hvid posatton that it euuld e f f ec t i s e l.s implement its p '. a n and protect the publiu utilizing ad hoc re ourev.
Lo
...ist munteipalitien during esseuutions;
)
and FEMA needs further information in order to evaluate the Commonwe41r.h's ability to protect the public in the I
esent of an acsident at Pilgrim.
(Egg.
Self-Initiated 2
Restew. p.08. p.35.]
i it shuuld be noted that s osne ad hoc response is inesitable in esen the best incident specific plans, and sometimes may be the only response possible in some esents such as ebenical spills, dan breaks and hurricanes for which Massachusetts plana a r,e largely far less developed than existing plans for Pild.in.
- 10. Barry Reuor(1 Expansion of the IPZ (pp.63-681 1
FEMA ccmment!
9
)
i
)
NRC and FEMA regulations both define the plume Expc Jre Fathway EpZ as an area about 10 miles in radius (ggg, gg.,
44CFR 350.:Ig. Guidance issued jointly by both agencies indicates that the exact size and configuration. shall be determined by State and local ' of the Ep2 ,ith FEMA and NRC, taking governments in consultation w as demography, into account such local , conditions topography, land characteristica, access routes and local ( l jurisdiction boundaries. (igg, NUREG 0654, FEMA Rep-1. i v.11. p.17] Communities located FEMA encourages emergency planning. I beyond the existing Pilgrim plume Exposure Pathway EPZ i the Commonwealth and approved by FEMA and established by the Regional Assistance Committee may wish to consider i developing plans appropriate to a nuclear power plant part of their comprhensive emergency plans. accident as [111, in addition FEMA's comments on this matter in 1 i Analysis of Emergency Preparedness !ssues at Pilgrim Nuclear Power Plant, July 29, 1987,, pp 34-41). I 1
- 11. lirry Reoort:
Annual Review of Energency Plans (p. 71) 1 The Director of Civil Defense shall publish procedures i for annual review...of the preparedness and respense i plans for Pilgrim... 10
TE'tA C mmtnt: 9 TEMA =ent a copy of Guidance t October 4, 1985. Memorandu:n PR-1 concerning CM PR-1 coratained specifto MCDA on the Annual requirement ic information that Letter of each state Ce r t i f i c a t 1'on. submit July 31 an FEMA 1986 and J4nuary 8.' sent letters Letter of Certification f 1987 requesting on the Annual FE'li rou haa the Commonw sto t recae\\*ad ealth. Femmora.e,s}th. 4 tift ua l I.e t t e r To date. f r ,n 4n ths of Certifictiton a f f i t ma t i ori We that support such revies, Sveretary Barry's Initssted Review, must be done. scetton gtt, (Egg, self. yj I s \\ A l !
EXEchT1Ebhf5CEOFEkkRb[RkSbbRCES .^ 73 Trecont Street .r** Boston, Massachusetts 02108 Fe b ru a ry. 8. 1982 Hon. Leonard Bickwit, General Counsel. Nuclear Regulatory Commission Matomic Building 4 1717 H Street, N.W. Wa shi ngton, D.C. 20555 Dr.a r Mr. Bickwi t,. The Executive Office of Energy' Resources of the i Commonwealth of Massachusettes (E0ER) is the state. agency in Massachusetts responsible for the development J of state energy policy, and is empowered to receive private ) and federal energy related grants. \\ l E0ER is considering proposing to NRC that NRC require' i Boston Edison Company to finance a home weatherization/cen-I servation program or other energy censumer related program, NRC in connection with operation' penalty recently proposed by in an amount equal to the civil of the company's Pilgrim i nuclear generating unit. Such expenditure would be in lieu of final imposition of the proposed penalty or in fulfitiment i of the penalty obligation. Customers within the service i ares of B'oston Edison Company and other utilities which i i receive power directly from the P11gria I unit under long i term contracts would be eligible for the benefits of the program. EOCR would propos'. to NRC, in accordance with 10 C.F.R. 52.205(b), 2.206, or other relevant requlations', that its final order include a reduction, rem'ssion or j mitigation of the proposed penalty, in connection with an 1 order to Edistn to. make payment for the public service, j program as proposed by the state. l Should NRC decline to issue such an order, or decline I to do so without the advance agreement of the utility, the state would proceed under 52.206(a) ("such other action as i may be proper') to request that WRC issue its final penalty ) order in the alternative, i.e. the specified civil penalty, unless the payment for the proposed pubite service ptogran 1s made by a date certain. We know of no precedent, positive or negative, f o'r - j consideration of such a proposal. We are not aware of j any expiteit legal barriers in the appitcable statute d, i i j w-~\\\\_ 1 ...% M 'O W Q Y_." * ~, 9 9,().
.v .o, or regulations which would preclude such a disposition, analogous procedures at SEC, FTC, DOE, and, of course,ies provide a broad range of prer,edents. - ar.d other agenc 4 Before putting Edison, the relevant state and local of ficials, other intere.sted persons, a.id N.R.C. staf f to the burden of dealing with a formal proposal, we would appreciate having 'a preliminary informal opinion f rom your of fice as to whether you feel that there are any legal barriers to either. result, i.e. a direct NRC order to Soston Edison Company to make payments for the proposed program, or an NRC C,rder i to loston Edison requiring payment of the penalty unless payment is made for the program. Obviously, to be useful to those concerned, it would be necessary to have your response as soon as possible. l -l t.et me know 'if we can provide.further information i. which would assist you in responding rapidly to this inquiry'. If for any reason a timely response appears impossible, it would be helpful to know that immidiately. l Si nc e rely, y f ? Pa trick J. Kenny, 1 Gene ra*. Counsel - )I ~ Executive Office of Energy Resources t j Commonwealth of Massachusetts ' 73 Tremont Street J Boston, MA 02108 (617) 727-0538, a 1 1 ) ] i Dictated to Washington for immediate transmittal by hand l to NRC. Signed original will follow by first class mail. i ] l 1 I l d .__,.,_I_
,a.- EOSTON EDISON COMPANY / g ,/ an=e. 6 ces.see soo asners= se. set ec re.. .....-veiere osivs June 6, 7179 l e.c........... .wess.... ..e.... es...,-i., BECo. Lt r. #79-114 l Mr. Thomas A. Ippolito. Chief Operating Reactors Branch #3 Division of Operating Reactors Of fice of Nuclear Reactor Regulation U.S. Nuclear Regulatory Cornission ( Vashington, D. C. 20555 License No. DPR-35 Docket No. 50-293 Containment Atmospheric Control System Ref: (a) NRC Letter T. A. Ippolito to q C. C. Andognini ds.ted 3/14/79 l Dear Sirt In Ref erence (s). veu r e m a t - <' that we submit a schedule for instat t ation aad testin+ of 2 CAD Systet at Pilgrim Station, Unit fl. You also re- [ huested that we include a detailed description of design changes made to the original TS A?. submittal as a result of the revised regulatory guidance. 1 Our current plaes do not call for the installation of a f*An avste-Ve r Ifit'end to retain the present inerted containnent atmosphere requirements, and we a*+ '" *'-- t systen that incorporates hvaroenn recoeSination m aEt14'y-This substantially upgraded system conceptual destra has resulted free your revised regulatory guidence and our continuing'InI7nt to assure protection ot the puette nealtn ans sarety. ~ k Because of the extensive design chances resulting frosi the revised regulatory M L nce, we are unable to comit at this time to any detailed design change. Ve vill sub-it a surarv description of our_ proposed systen and our proposed schedule of leple:entatio'n by Septesber 15, 19% ) If you have any guestions on this subject, please feel free to contact us at your convenience. 1 Very truly yours, i l 7 + u / coe/ 1E * * *
- ivw(V" 7006s w,.*' ycq' S/O
/', EXHIDIT A 1 7590-01 l UNITED STATES NUCLEAR REGULATORY CCMMiss!0N 80s?0N EDISO4 COMPANY PILGRIM NUCLEAR POWER STATION _00CKET No. 50-293 NOTICE OF 15504NCE OF INTERIM OTRECTOR'S DECI$10N ~ Notice is hereby given that the Director Office of Nuclear Reactor j t i Regulation, has issued in interim decision concerning a request filed pursuant i i I to 10 CFR 2.206 by the Honorable William B. Golden which requested that the 1 i Pilgrim Nuclear Power Station remain shut down or have its license suspended because of (1) deficiencies in the licens,ee management, (2) inadequacies in i Jl th.e emergency radiological plan, and (3) inherent deficiencies in the containment structure. ) The Director of the Office of Nuclear Reactor Regulation has detemined j that the Petition, with the exception of the license management issue, should l be denied. The reasons for this decision are explained in the "Interim i ) Director's Decisten Under 10 CFR 2.206 " 00 87-14, which is available for i public inspection in the Coevnission's Public Document Room,1717 H Street, N.W., 4 i Washington, DC and at the local Public Document Room at the Plymouth Public i Library,11 North Street Plymouth, Massachusetts 02360. That portion of the I i Petition concerning licensee management will be addressed in a subsequent 2 response. 1 A copy of the Cecision will be filed with the Secretary for the Ccmission's review in accordance with 10 CFR 2.206(c). As provided in this regulation, the Decision will constitute the final action of the Corrission twenty five l
- m n-6 L n In L E PP-p v u-, v e w
- O
.t. (25) days after issuance, unless the Commission, on its own motion, institutes review of the Decision within that tire period. Dated at Bethesda, Maryland, this 21st day of August IM7 l FOR TFE NUCLEAR REGULATORY CM15510N e f;P Project Directorate J.3 Division of Reactor Projects 1/I! a
l e l CERTIFICATE OF SERVICE I hereby certify that on this 17th day of November,1987, l copies of the foregoing "Petitioner's Memorandum in Opposition to l l Respondent's and Boston Edison Company's Motions to Dismiss" were l mailed, first class postage prepaid to: [ Frank L. McNamara United States Attorney 1107 J. W. McCormack Post Office and Courthouse Building Boston, MA 02109 Edwin Meese Attorney General of the United States constitution Avenue & Tenth Street, N.W. Washington, D.C. 20530 Lando W. tech, Jr., Chairman U. S. Nuclear Regulatory Commission 1717 H Street l Washington, D.C, 20555 l Michael B. Blume U. S. Nuclear Regulato:y Commission Of fice of the General Counsel 1717 H Street Washington, D.C. 20555 R. K. Gad III, Esquire Ropes & Gray 225 Franklin Street Boston, MA 02110 George 5. Dean Assistant Attorney General Nuclear Safety Unit one Ashburton Place - 19th Floor Boston, MA 02100 s4 Wilitim 'S, Abbott Simonds, Winslow, Willis & Abbott 50 Congress Street Boston, MA 02109 (617) 523-5520 I,
- g
}h fv. ~ i 2 '%.h.,.., u#'s, UNiTio sT AT Es [ N UC L E A R R E G U L AT O R Y CO N'..'.'. l SSIO N y(,,(-l g. j ,,.g ; -Y was e.cto.o.c resss f'.'?jf f June 26, 1931 Dock et No. 50-293 Mr. A. Victor Morisi, Mgr. Nuclear Operations support Dept. Besten Edison Corpany M/C Nuclear 800 Boylston Street Boston, Massachusetts 02199
Dear Mr. Mortsi:
RE: Pilgrim 1 - Containrent Atrosphere Control Systen in Boston Edison Co pany's letter of Oct7ber 19,1979 (BEco. 79-207), BEco. referred to their analysis which deconstrated compliance with 10 CFR 50.44. Our letter of October 30, 1979 requetted that this analysis be forwarded to us, and that it contain sufficient detail f or us to evaluate corpliance with 10 CFR $0, GDC 41, 42, and 43. _On P!v 79.19El, your staf f inf erred us of a potential non-cogliance with 10 r F R 'A a'. py June 2.1951. actions were cc pleted at Pilgrim To c;arantee corpliance, and smectate safety concerns were -r e s c h e d. Ine liEC project r.anager requested a subaittal by dCo. regerong ccTliance with the regulation, from its irplecentation t o June 2,1981. Your staf f supplied that response on June 15, 1981' (BEco. 81-127). This response was followed by a reeting with us on June 18,1981. During the rveting it was deterrained, as docu. ented in BECo. 81-127, that pilorim I had not been in coolinee with the ree;1ation f rom the ef fective date of the role (11/27/781 tn Jure z, I n l._ lhts c. :ter of past non-compliance, will be addressed by our Of fice of Inspection and Enf orcerent. The Office of Nuclear Reactor Re?>1atten will assure the current coTpliance of Pilgrim I with 10 CFR 50.44 by perferr.ing a review of your present syste. This letter formalizes the conclusions of that reeting. Further inforcation is necessary for _us to esaluate the comliance of your systes with IU uK 00, App. A, GDC 41, 42, Lad 43. Therefore, in order to determine whether your license should be rodified or suspended, you are required pursuant to 10 CFR 50.54(f), to prcvide to us withiri seven (7) days of your receipt of this letter, a written staterent, signed under oath or affirration, which confirc.s the system's current cot 11ance with 10 CFR 50.44 and includes the following: 1. A detailed system description which addresses, in detail, radJnd&nce in Corpeqents and features, interconnection Capabilities, leak detection capability, auto:atic isolation and containment capability, such that with either a leu of offsite or onsite pewer, accorpanied by the ost lir.iting single f aihre. the syste vill perf orm its safety fe :tien. -( (as built) L ?i.5 and instrcentation dra b p i
- 2. Current
& n <), and electr; cal scWv.i:s f cr the sy stem. (;iD's ~' eju/ , f.p, ui V i< ; - ^
- '. L,y
/ t p / l/ l 3. The pre-operational test data and test procedure (s) used to demonstrate cogliance with App. A, GDC 43, and App. B, XI, of 10 CFR 50. ) 4. A discusstr>n of hcw the explicit requireeents for Design l Control (10 CFR 50 App. 8, XI) were met. Specifically, a) An independent Il design reviu to verify the adequacy of the system design, and b) suitability of parts regarding GOC 4. t 5. A discussion of the design control reasure'. which guaranteed an independent design review f or field changes to the system, from initial installation to present, per 10 CFR 50, App. B. !!!. and a similar discussion for future field changes. 2 6. In order to assure future compliance, your statecent should include a cocritnent to provide Technical Specifications for the system regarding a) surveillance of ducts, piping, filter frares, pressure source I d levels (ie. required capacity for system operation ), or other irnportant l corponents or aspects with the appropriate Limiting Conditions of Operation. l and b) periodic pressure and functional testing te deecnstrate full ccmplis.ge <;r s with GDC 43. Such testing rust reflect the Test Controls of 10 CFR 50, ) VT App. B, XI. Records retention cust co@ly with 10 CFC 50, App. 8,XUI. Y The sub.ittal of such proposed Technical Specifications will be acceptable TS in lieu of the comiteent. Our review of your tutaittel should not preclude t
- Y T }
our cot 11an e with your proposed specifications unless a conflict -exists I etween them and existing specifications. i f)*t. l
- A I
i Sincerely. g Y h. h r-nocas M. Novak, Assistant Director l for Operating Reactors i Division of 1.tcensing 1 cc: See next page l l i t l
--._ _ - __ - _ _._._ m __._ DAILY REPORT - REGIOL I 9/9/80 : Fecility
- dotifIcation Item or Ev Regional Action OPERATIO45 (contd) l l
bilgrimUnit 9/5 SRI fcx The follrwing personnel assignments were ef Information Ites. I fective on 9/1, I (0N 50-293) i l R. Machon Nuclear Oneratians 92nacer (Pilgrhs , M' C.+,,,,,j l Station) - Site; C. Mathis, Deruty 'wlear Operations Nacer - Site; W. Armstrenrn Deputy V", ^ 7 tiuclear Operations Manarier - Site; J. Seery, huclear Operaticas Staf f Assistant (Nuclear Safety) - Site; R. Savigny. Nuclear Staff As-
- ** W s
sistant (Maintenance) - Site: A Morisi, Nuclear 7 % . Operations Support Manager ' corporate: L ~ ^* Merritt. Nuclear Engineering Manja er - Corpor-ate; 11. Berriman. Qual.ty Assurance Manager - C9rl. ora te. Millstone 9/9 SRI fax 9/8 Daily Report Update. On 9/9 the licensee Per TI 2515/33. C;,it 2 perforned a special test trip of the Division (DN $0-336) II e:nergency bus loss of power trip circuit. The 9/8 event which involved the unplanned tripping of the Division I loss of power sensors as repeated. Ttw licensee is continuing his in-vestigation. CD:iSTRUCTIDN tifne !!ile 9/8 telephone 10 CFP 50.55(e) r.otification. An cirbedded Followup per MC 2512. Point from licensee plate ir. the reactor pedestal was welded to Unit 2 8 rebar utilizing ASME requirements rather than (O'l50-410) AWS D12.1. which is applicable. Sleiding was performed by ITT Grinnell. k .,ce ..w.- .4.m,-.y
e{.~ %y ,f,, UNITED STATES .\\h5.,-' r=[# I m se.c t oN, 0. c. goss3 NUCLE AR REGUL AT ORY COMMISSION e Y c' June 24, 1981 / Docket 50-293 .f N ttEMORI.NDUM TO: Thomas A. Ippolito, Chief 1N Operating Reactors Branch f 2 'y }d Division of Licensing v { $y FROM: Mark H. Williams, Project Manager Operating Reactors Branch #2 Division of Licensing
SUBJECT:
Meeting Su-nary - June 18, 1981 meeting with the ,g Boston Edison Company N On June 18, 1981, a meeting w)as held with the representatives of the $y
==% Boston Edison Company (BECo. listed in Encl.1, regarding the past 1 3 coeplignce of Pilgrim Nuclear Power Station Unit I with 10 CFR 50.44 , The meeting was requested by BECo. {d(% On May 29, 1981 BECo. identified an area of potential non-compliance with the regulation at Pilgrim !. Subsequent findings by BECo. resulted in their determination that a meeting was desirable. J a the feetine, ! 3; BEco. stated that Pilerim I had not bean in coMiane with 50,44 f rom g I 'g The ef fective date of the rule to June 2.1981. This non coroliance nrTT(sult of various ina%quaries in Hanagement Controls, l The original systen which was used to 'reet the regulation frem Noveter 197E l to Itay 1950 relied on operator actions 17 otet the single failure .ri te rior gf GF a' Mn June 1981, RECo. determined, as a result of an NRC eerequested revied, that such ope,ator actions could not be assured l () due to the pcstuleted radiation 1oses in the reactor building subsequent l \\d to an accident (BEco. 81-127 C/15/S1). A ne.< systen, recotely r; "ated e which did reet the single failure criterion, was installed in the My 19$0 l outage. Although this system was thought, by BECo., to be in service from May 1980 to June 1931, it was actually disabled during maintenar.ce in July li!C. - l The purge lines were cut and capped rather than installing elbc.is as originally specified on a BEco, design change. An investigation is underaay at SECo. to determine the manner in which the change request was altered. In additicn, it was lat.er discovered by EECo. that even if the lines had not been cut i j in July 1960, the syste : was still inoperable since it was val d cut cf service shortly af ter the May 1980 outage due to undesirable leala;e. Therefore, the unit had not been in compliance with 10 CFR 50.44 at any time in the past. t telephone requeg in ear))flj5yt>aseo on nwT_he Ut rer.+.Lt which resu s eue r cateme tpber W. wnicn requestec Eu.o. w prom;t a basis for tneir letter of OWJu if, 1979, in which BECo. claired conplian:e with the 10 CFR 50.44 with edsting l e w ent. \\ I /}g g e.- YY 5ff'
1,.
- i Boston Edison presented their new prcgram to implement effective Management Controls for Pilgrim I (Encl. 2). The method employed by SECo. forces all work items, regardless of their initiating circumstances (eg. NRC req't, BECo. design change, etc.) into a predeter:nined network. The network integrates all of the requirements of the operational, technical, and administrative disciplines of the company, which produces the final action. SECo.
r demonstrated how this future program would mitigate tha possibility of future occurances similar to the 50.44 violation. BEco, also comitted to review their compliance with all post 1972 regulations i which did not result in a design change at the plant. The. schedule l for their review would be submitted to WRC by June 26, 1981. Subsequent to internal NRC discussion, BECo. was informed that the 50.44 vio14tian would be addressed in two parts. The Office 1 of inspection and Enforcement, Region 1, would address the past non-coepliance. It wac agreed that BECo. appeared to be in compliance with the regulation since June 2,1981 by use of f the new system (SEco. 81-127, June 15,1981). However, the Office of Nuclear Reactor Regulation woule conduct a review of a detailed { I submittal by BECo. to assure such compliance. That submittal [ l would be for,mally requested by a NRC letter to be sent daring the week of June 22, 1981. i i f i V Mar H. Wilitans, Froject Manager i Op ating Reactors tranch f2 Division of t.icensing cc: w/o Enc 12 See Next Page j t l l
y 1 ./ ')[ / r / /. '/ [ I i BECo. Meeting of June 18,1981 i I l NRC BEco. -i M. H. Williams, NRR R. Machon 'T. A. Ippolito NRR ^W. Merritt i E. Blackwood, ole A. V. Morisi J. Partlow, ole J. Fulton i 9 1 1 4 i ) l 1 4 1 l I j i a d
l l kvL v IO \\b -f i Federal Emergency Managment Agency Washingon, D.C. 20472 w ALG 6 1987 MDCPMD(N FOR: Frank J. Congel, Director Division of Radiation Protection ard Dwrgency Preparedness Of fice of Nuclear Peactor Begulation U. S. uclea Reg"1 tory Carission dm FBm: aw Assistant Associate Director of fice of Natural and Technological Mazards Programs Of t' site D ergency Planning at Pilgrim StJMECT: In my mrorandam to you on July 13, 1987, I stated the Federal Drergency Mxu;e ent ;qency (FD%) would deliver to the Nuclear Regulatory Ccrnission (NRO) a findig on the adequacy of the of fsite mergency preparedness plans 15, 1987. 7his is for the Pilgram Naclear Pcwer Station on or abcut August an update of cur previcas interim firdirg which as transmitted to the fiRC on Novecter 2,1983, along with a ecpy of the exercise report evaluating the initial joint State and local of fsite radiolcgical erergency preparedness These reports were provided to the NRC pursuant to the NRC/TD% l exercise. Memrardum of Understandirg of November 1980, and in response to the NRC's request for assistance concerning ecergency preparedness issues at Pilgrim In aMition, in a nerorandum to NRC on March 31, l dated Serecer 6,1983. 1987, FDA indicated that the res;cnse to the related 2.206 petition would i be consolidated with the results of FD%'s self-initiated revied of the overall state of offsite emergency preparedness and other relevant information. FD%'s report, entitled "Self-Initiated Pcview and Interim Firdirg for the Included Pilgrim Nuclear Pcwer Station" dated August 4,1987, is attached. as attachment.s to the report are "FD% Ccrrents on the Paport to the Gowrnor on D ergency Preparedness for an Accident at the Pilgrim Nuclear Pcwor Station" 29,1987 (located at Tab 1 in the attached binder), and FD%'s dated July "Analysis of Dergency Preparedness Issues at Pilgrim Nuclear Powr Station 15, 1986". FD%'s analysis of Raised in a Petition to the NRC datW July the issues raised in the 2.206 petition is dated July 29, 1987, and is located at Tab 2 of the attached birder. Based cri the Self-Initiated Bevies and Interim Firdirg, FD% has concluded that Massachusetts offsite radiological energency plannirg and preparedness are inadequate to protect the public health and safety in the event of an accident at the Pilgrim Nuclear Power Station. Because of the changed cir-cumstances discussed in the report, the firdirg of adequacy ecntained in FD%'s previous interim findir.g no lorger applies and that interim finding is hereby wperseded. 646-2871. If ycu have any questions, pleaso contact me at Attachnents As State $ 10 k m m l$ ~ [ f, A in O-a v u l + v =v y
I h lf ELL 9 Y %&eff i O O SELF-1NITI ATED REVIEW AND INTERIM FINDING FOR THE PlLGRlM NUCLC.AR POWER STAil0N PLYMOUTH, MA \\ AUGUST 4, 1987 l l FEDERAL EMERGENCY MANAGEMENT AGENCY JOHN W. McCURMACK POST OFFICE AND COURTHOUSE BOSTON, MASSACHUSETTS 02109-4595 ^ $ h 0 E f ^4 0 S b O 0I?f'
l TABLE OF CONTENTS 1 I.
SUMMARY
II. BACEGROUND.................'................. 2 9 III. EVALUATION OF ISSUES 9 A. Evacuation of Schools 17 B. Reception Center 20 C. Beach Population 28 D. Special Needs Population E. Transportation Dependent' Population 36 F. Overall Lach of Progress in planning and Apparent Diminution in Emergency 40 Preparedness 48 IV. CONCLUSION.................................. TAB I. FEMA Commentary on Barry Report TAB II. FEMA RESPONS: TO 2.206 PETITION Y e a i l O
c I.
SUMMARY
On September 5, 1986, the Federal Emergency Management Agency informed the Commonwealth of Massachusetts that it was (FEMA) undertaking a review of its September 29 1982 Interim Finding for the pilgria Nuclear power Station because of concerns raised during seecings in the Spring of 1986 and information received subsequent to those coetings from local officials, the Commonwealtn. and other interested parties. FEMA identified six issues during the course of that review: Lack of evacuation plans for public and private schools ond daycare centers. Lack of a reception center for people evacuating to the north. Lack of identifiable public shelters for the beach population. Inadequate planning for the evacuation of the special needs population. Inadequate planning for the evacuation of the transport dependent population. Overall lack of progress in planning and apparent diminution in emergency preparedness. FEMA has Analyzed these issues pertaining to the radiological energency response plan and has reviewed the plan and exercise reports in conformance with applicable standards. F1KA concludes that the plan and preparedness for the state ) 1
1 and local governments within the plume exposure pathway for the Pilgria Nuclear Power Station are not adequate to protect the health and safety of the public in the event of an accident at the Pilgria Nucle'ar Power Station. This Interia Finding supercedes the Interim Finding of September i 29, 1982. II. BACECROUND On June 16,
- 1981, the Director of the Massachusetts Civil Defense Agency and Office of Emergency Preparedness (MCDA) sucmitted to the Federal Emergency Management Agency (FEMA),
on behalf of the Governor, the State Comprehensive Emergency Response Plan, together with its Annexes, for Massachusetts and the local consunities within the Plume Exposure .Energency-Planning Zone (EPZ1 for the Pilgria Nuclear Power Station located in Plymouth, Massachusett's. In his letter of transmittal which accompanied this plan he
- stated, as required by Federal Regulation (111, 44 CFR 350.7),
that "this plan is, in the opinion of the Massachusetts Civil Defense
- Agency, adequate to protect the public health and safety of the Commonwealth's citizens within the designated energency planning zones of the Pilgria Station and provides 2
s
for appropriate protective measures to be taken by the State and ' local governments in the event of a radiological emergency at the Pilgrim Station". FEMA and the Regional Assistance Committee (RAC) reviewed this plan and issued a repor, of its review in October, 1981. a As a consequence of this report the Commonwealth revised the plan. FEMA and the RAC reviewed this revision and issued a l second report containing an analysis of areas where the plan was weak in September, 1982. FEMA has received no response from the Commonwealth regarding further revision of ita i plan. In the interim, FEMA sponsored a public meeting, held on June 3. 1982, to discuss the Commonwealth's Radiological Emergency
Response
Plan for the Pilgrim Nuclear Power Station. The following issues were raised by the public at the meeting: The ability to evacuate communities within the 10-mile EPZ. The ability to evacuate Cape Cod beyond the 10-mile EPZ. Reliability and effectiveness of the sirens. Training and education of
- teachers, school bus drivers, and hospital perconnel.
1 Information brochures for the
- public, ir:1uding transients.
l 3
e Policy on the use of radioprotective drugs. Protection of the elderly and others with special needs.8 The Commonwealth responded to all these concerns, stating that the plan,"provide (s) adequately for safe and orderly evacuation of communities within the 10-mile EPZ"8 and pledging to work tuward further improvement of the plan. d FEMA then issued an Interim Finding for the Pilgria Nuclear Power Station on S.ptember 29, 1982. It found that although there were problems with the plan, "the state plan and local plans together are adequate to protect the health and safety of the publie."8 Exercises testing this plan were cor. ducted on March 3,
- 1982, June 29, 1983, and September 5, 1935: a Remedial Exercise was conducted on October 2J.
1985; and FEMA observed a Drill on August 15, 1984. "Deficiencies", '"2reas requiring corrective action", and "areas recommended for ieprovement" 4 Follow-up to the June 3, 1982 Public Meeting. TIMA, p. 1 i 8 Ibid., p. 1 8 Interia Findings Joint State and Local Radiological Emergency Response Capabilities for the Pilgria Nuclear Power Station Plymouth, Mas sachus e t t s. FEMA. September 29, 1982,
- p. 5.
4
l were identified. As FE.!A now uses the ters. "defleiencies" ) are problems identified in plan implementation which preclude e a finding that a plan is adequate to protect the health and safety of the public. "Areas requiring corrective action" are defined as inadequacies in State and local government performance observed during an exercise; although their correction is
- required, they are not considered, by j
themselses, to so adversely impact public health and
- safety, as to preclude a
finding that the plans and preparedness are adequate to protect public health and safety. "Areas recommended for improvement" are defined as i proble.a arer.s observed during an exercise that are not ) considered to adversely impact public health and safety. No deficiencies remain outstanding from FEMA's evaluation of l these v.sercises. Many "areas requiring corrective action" and "areas recommended for improvement",
- however, have not been addressed to date.
a By March,
- 1985, status of off-site radiological energency response planning for the Pilgria Nuclear Power Station 4
was: (1) aany planning problems remained unresolved from the October, 1981 RAC Review; (2) the Commonwealth had not l responded to the September, 1982 RAC Review; and (3) it j had not provided FEMA with schedules of corrective I i actions for tae problems ider.tified in the 1982 and 1983 i 5
) exercises, which tas required by FEMA guidancel had been due within 30 days following the issuance of the exer'cise reports. On March 6, 1985 FEMA, therefore, informed the Commonwealth by letter that, because of unresolved emergency planning
- issues, it was suspending processing of the Massachusetts request for formal emergency plan approval made pursuant to 44 CFR 350.
On June 20, 1985 the Commonwealth sent FEMA a schedule, both of actions it had taken and specific measures it was planning to take, to correct the problems identified in the 1983 exercise; plus general steps taken to correct problems identified in the 1982 exercise.
- However, the plan improvements the State promised have not yet been delivered to FEMA.
In its evaluation of the September 5, 1985 Pilgrim Exercise FEMA found that many of the previously identified problems had been corrected, but it identified new problems and four "deficiencies". The Commonwealth corrected the "deficien-cies", as evidenced in an October 29, 1985 Remedial Exercise. It has not
- yet, however, provided FEMA a
schedule of ) corrective actions for the 1985 exercise. TEMA guidance requires the submittal of a schedule of corrective actions 1 ) within 30 days of the issuance of the exercise report. i I 6 l 1
l l \\ \\ l l on October 30, 1985 FEMA again informed the Commonwealth by letter that the processing of the " 350" request was not progressing because of the many, unresolved issues identified in the 1981 and 1982 RAC Review.. and observed during the exercises. FEMA also requested copies of the 1985 version of the local plans, which were provided in June 1986. The 1 commonwealth replied to FEMA's letter on June 6,
- 1986, at which time it outlined the initiatives it was taking in order to resolve the outstanding
- issues, and indicated the areas in which improvements had been ande in the state plan and procedures.
This reply did not,
- however, constitute a schedale of correc tive actions because it did not provide a date by which plan improvements were to be completed. In sun, the Self-Initiated Review was based on the 1982 Massachusetts Radiological toergency Response plan and the 1985 version of the local plans.
TEMA first became aware of potentially strious problems with the commonwealth's plan during a series of meetings with the j commonwealth and local communities in the Spring of 1988. Issues raised at these meetings, and information received 1 subsequen61y, indicated that FEMA should review its Interia Finding concerning the energency response plan for the pilgria .9uclear power Station. Based on the information it 7
received. FEMA decided to conduct a review of the emergency response plan and preparedness for the Pilgrim Nuclear Power Station and so informed the Commonwealth in a letter to MCDA on September 5, 1986. On December 22, 1986, the Secretary of Public Safiety. Charles
- Barry, forwarded to FEMA a copy of the "Report to the Governor on Emergency Pr.paredness for an Accident at the Pilgrim Nuclear Power Station" (hereinafter called the Barry Report). This report stated that the Massachusetts plan and its preparedness are inadequate to protect the health and safety of
- he public in the event of an accident at the Pilgrim Nuclear Power Station.
7EMA was subsequently informed that the Governor
- and the Director of the Massachusetts Civil Defense Agency 5 had endorsed the Barry Report.
In the course of its self-initiated review, FEMA has i treated this report as the authoritative and current position of the Connonwealth. e l l Letter from Charles Barry, Secretary of Public Safety to 4 Edward A. Thomas. December 22, 1086. i
- Letter from Robert J. Boular. Director MCDA. to Edward A Thomas, April 10, 1987.
i S
i III. EVALUATION OF ISSUES FEMA's Self-Initiated Review of t r. a Commonwealth of Massachusetts plan to protect thq.public in the event of an accident at the pilgria Nuclear Power Station is based on:
- 1. Information provided by State officials at a meeting held June 18,1986 by members of the Massachusetts legislature concerning the i
Commonwealth's plans to protect the public in the event of an accident at Pilgrani 2. Information provided by the
- public, and State and local officials at a meeting held in I
Duxbury June 25, 1986; i 3. Information provided by the public, and State and local efficiate at a meeting held in Plymouth on June 30, 1986; 4. Information provided in the Barry Report; 5. Other information provided the Commonwealth of Massachusetts concerning the Pilgria plan as 9
referenced in this report; 6. The existing Massachusetts Radiological Energency ' Plans for an accidGnt at Pilgrim which consists of the 1982 version of the state
- Plan, the 1985 version of the local plans, together with procedures and clarification submitted since 1982; 7.
The transcripts of a public meeting on the Massachusetts plan for coping with an accident at Pilgrim sponsored by FEMA June 3, 1982; 8. FEMA and Regional Assistance Committee reviews of
- plans, and exercise of
- plans, as referenced in this raport.
FEMA's review identified six areas of major concern: Lack of a reception center for people evacu-ating to the north. Lack of evacuation plans for public and i private schools and daycare conta-a. Lack of identifiable public shelters for the beach population. 10 4
Inadequate planning for the evacuati.on of the special needs population. Inadequate planning for evacuction of the transport dependent population. 8 Overall lack of, progress in planning and apparent diminution in emergency prepated-ness. A. Evacuation of '3chools Issue 1 FEMA's regulations call for the Agency and the RAC to use a guidance document jointly developed by FEMA and the NRC (Egg, 44 CFR 350.5). This document is known as NUREG-0654 FEMA-rep-1, Rev. 1. It indicates that state and local emergency plans shall include "means for protecting those persons whose mobility may be impaired due to such factors as institutional or other confinement" and further indicates that such plans aust describe the "seans of relocation" for the population (Eig, NUREG-0654 FEMA-REP-1, II.J.10 (d); 11.J.10 (g); Appendix 4; and FEMA Guidance Memorandum EV-2). i (154 previous UnderstaAdlag 1 l ) The local plans lirted schools and provided information on 4
l I i how those schools would be evacuated. Questions concerning the evacuation of schools were raised at the June 3,
- 1982, public meeting.
L MCDA responded as follows: On the lack of buses, we have made arrangements with the MBTA to provide us with back-up buses on an on-call needed basis to support Plymouth... on school SOP's I know that the superintendent of schools has been working very diligently on that.' The Town of Plymouth responded: We now have updated list of the drisors and their phone numbers. We have lists of alternate drivers. We know the location of all of the buses when they're not on the road and Mr. Nicholas (Superintendent} assured me through established early dismissal procedures that those buses can be obtained and brought to the schools.' The Massachusetts Public Interest Research Group (MASSPIRGl alleged in "Blueprint for Chaos II: Pilgrim Disaster Plans Still a Disaster", dated July 20,
- 1983, that there were no workable plans to evacuate the schools. MCDA responded to the MASSPIRG report:
Existing plans and preparedness programs deal realistically with each of the "special population groups" identified. Local officials and representatives of schools. !!2ve been deeply involved in this 1 process. Nonetheless, MCDA recognizes that the Transcript of " A Public Heeting on the State and Local of f-Site . Radiological Emergency P an". June 3, 1982, p. 66. l Ibid., p. 67 12
l 1 l l specifics of such plans require constant attention and coordination with responsible local officials. 1 we recognize that more comprehensive plans are desirable. We will be working in this area during the ( coming year.' In its cesponse to the MASSPIRG Pe,tition FEMA concluded: Although this is a weak area in the
- plan, it is made clear that all of the resources' of Area II as well as State resources will be brought to bear should it become necessary to evacuate special population groups.
Transportation resources and special equipment have been inventoried and are considered adequate. The i Plan provides that, if there is time, school children will return home to evacuate with their families, or, it decided at the State or local
- level, be evacuated in buses.'
Although detailed proceduras for school evacuation and early dismissal were not provided to FEMA. in consideration of the vast resources listed in the state's emergency plan for assistance to municipalities during evacuations (particularly the resources of the Massachusetts Bay Transportation Authority, the State Police, and the National Guard). FEMA found that the plan was acceptable. a r 4 MCDA Analysis to The Massachusett Public Interest Group Report 9 "Blue Print for Chaos 111 Pilgrim Disaster Plans. Still a Distiter*.. p. 8 ' Analysis of Energency Preparedness Issues at Pilgria Nuclear Power Station Raised by the Massachusetts Public Interest Group (MAS 3PIRC), i FEMA. November 3
- 1983, p.
8 13
i Issue ljentifiestion During the June 30, 1986 public meeting in the Town of Plymouth a citizen. whose children were in private schools, inquired about plans for their evacuation. FEMA promptly researched the matter and discovered for the first time that private schools were not included in the local plans.t* FEMA vigorously discussed this problem with representatives of both the Commonwealth and Boston Edison Company immediately following the meeting. In his December 16, 1986 report to the Governor, Secretary Charles Barry stated that "ad hoc planning is clearly inadequate when a fast-breaking incident occurs".StHe further indicated that it would be necessary for the Commonwealth to obtain Letters of Agreement with private bus I companies to support the evacuation of the population needing transportation. The Commonwealth also informed FEMA that it would no longer contemplate using the resources >f the MBTA in case of an energency at Pilgria. 4 is Meeting Notes. Edward A. Thomas, June 30, 1986 88 Report to the Governor on Emergency Preparedness for an Accident at the Pilgrim Nuclear Power Station (Barry Report), Secretary of Public Safety. December 16, 1986, p. 48 14
ELMA Current position i The 1985 version of the town plens for P'emouth, flux bury,
- Carver, Kingston, and Marshfield are inadega. c in tnat they do not identify all private scho,'is and d vea e centets within the plume exposure amergency planning :ene.
Detailed I plans and procedures must be develo' ped for those institutions, identifying sufficient resources and arranging for the availability of these resources to evacuate children ( and staff in the event of an accident at Pilgria. The Commonwealth's current position is that it will not use the vast state controlled bus resources of the MBTA and that it can no longer rely on ad hoe planning, at least during a fast-breaking accident. Detailed plans and procedures must, therefore, be developed for the early dismissal and evacuation of each community's schools and daycare centers. In addition. Letters of Agreemeng with transportation providers not under direct control must be obtained. Personnel designated to drive vehicles during an evacuation i aust also receive proper training as emergency uorkers. Until this is accomplished the Massachusetts Radiological Energency
Response
Plan is inadequate with respect to 15 l
i i l FE.! A -REP - 1. Rev.1, evaluation criteria J.10 (d) NUREG-0654, and (g). The existance of this ' inadequacy" prec1udes a* i finding by FEttA that there is a reasonable assurance that the r l public health and safety can be protected in the event of an accident at Pilgrim. k I i i l i 1 ( 1 l l l I i \\\\ r l 4 i l il } 4
B. Reception Centar f Issue FEMA's regulations call for the Agency and the'RAC to use a guidance document jointly developed by FEMA and the SRC (Egg, t 44 CFR 050.51 This document is known at NUREG-0654. FEMA-REP-1. Rev. 1. It indicates that state and local emergency plans sust describe relocation centers where will be monitored and registered (Egg, NURIG-0654 evacuees FEMA-REP-1, Rev. 1, II.J.10.h and J.121 I 3 Previous Understanding on June 16,
- 1981, the Commonwealth submitted its plan to FEMA for review and approval pursuant to 44 CFR 350. The plan included provision for three reception centers.
FEMA reviewed it in 1981 and provided the Commonwealth consents cencerning the reception centers. The Commonvealth revised its plan and, in September '.942, FIMA and the RAC found the revisions for registering and monitoring evacuees acceptable. The 1982,
- 1983, and 1985 17
)
e exercise each tested a reception center. In 1985 the Taunton Reception Center was found to have a "deficiency".~ The October 20, 1985 remedial exercise demonstrated that corrective actions had been taken,and were acceptable. e Issue Identification on February 07 1987 Robert J.
- Boulay, Director, Massachusetts Civil Defense
- Agency, informed FEMA by letter that the Commonwealth had relieved the Town of Hanover of "their responsibility to serve as a reception community in the event of an accident at Pilgrim Station".58 No alternative site has been identified.
l l EL14 Current Position i NUREG-0654/TEMA-REP-1 provides guidance on the registration and monitoring of evacuees. J.10.h states: i Relocation centers in host areas which are at least 5 siles, and preferably 10 miles, beyond the boundaries of l l n8 Letter from Robert J. Boulay, Director, MCDA, to Edward A. Thomas. Chief, Natural and Technological Hazards Division. February 27, 1987 l 18
the plume exposure emergency planning zone.88 and J.12 states: Each organization shall describe the means.for registering and monatoring of evacuees at relocation centers in host areas. The personnel and equipment available should be capable of monitoring within r4 bout a 12-hour period all residents and transients in the plume exposure EPZ arriving a't relocation centers. The Commonwenith's plan does not now provide a re,ceptio,n, monitoring, and decontamination cabability for upproximate-ly 60,000 people evacuatias to the north. The use of ths reception centers to the west and.outh is not in accordance with the existing state plan; ht us t bten suggested as a viable option by the Commonwealth; and is not lik.ely to be logistica11y feasible.
- FEMA, therefore, finds that the t
i Massachussetts plan is inadequate with respect to NUREC-0654 FEMA-REP-1. Rev. 1. eriteria J.10 th) and J.12. The existence of this "inadequacy" precludes a finding by FEMA that there is a reasonable assurance that the public health and safety can be protected in the event of an accident at Pilgria. l Before this inadequacy can be corre ted a new reception ) center must be found to replace Hanover; plans and procedures aunt be developed to regis ter and soriitor the evacuees; and submitted to FEMA for review. l 18 Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Prepa.edness in support of Nuclear Power Plants., i 1 NUREC-0654 / FEMA-REP-1, Rev. 1 November, 1980., pg. 63 19
i I C. Beach Population Issue. FEMA regulations require the development of a range of protective actions for emergency workers and the public in the plume exposure EFZ and that guidelines for the choice of l protective actions be in place. ( gig,, 44 CFR 350.5ta)(10)]. l The primary guidance document tjointly developed by FEMA 4 and the NRC) used by FEMA and the RAC in reviewing off-site emergency plans is NUREG-0654 FEMA-REP-1 Rev 1. That guidance document indicates on page 13 that "[t]he range of times between the onset of accident conditior.s and the start of a major release is of the order of one-half hour to i, several hours". This statement is amplified on page 17 i j Table 2 to indicate that (a) the major portion of a release any occur in a time period ranging from as little as one-half I hour to one day after the release begins and (b) that the travel time of the release to exposure point can range from one-half hour to two hours at five ailes, and one hour to l four hours at ten miles. 1 l i 20 1,
j l l i in a fast breaking The appropriate protective action response accident is prompt notification of the public within,the' i plume Exposure Energency Planning
- Zone, either to seek i
. shelter (in their present location or in public shelters) or, if conditions permit, to evacuate, Because ut the possibility that a large portion of this group inay not have access to suita'ble shelter, or the ability
- r. o lease the EpZ
- rapidly, protection for the beach popuistion requires careful analysis to determine whether appropriate protective actions can be laplemented as required by Evaluation criteria J.9, NUREC-0654, FEMA-REP-1, Rev.
1. [134 previous Understanding The issue of the beach population was raised at the June 3, 1982 seeting with respect to the large tourist population, j paul Cahill, Director, Massachusetts 01vil Defense Agency at i the time, stated: ) l We do have planning contingencies. .We have done time study estimates and clear zone times for the maximum peak population during July, which would be 132,000 People within the ten-mile radius.t* 1 Transcript of "A Public Meeting on the State and Local Off-site j I Radiological Energency Plan", June 3, 1982, p. 24. 21 e' i
l MASSPIRG in its July 20. 1983 study on emerg'ency planning - for Pilgria expressed its opinion that the location of public shelters should be included o'n maps in all emergency l information materiala. The Commonkealth responded as follows: The MASSPIRC repurt repeatedly confuses facilities for j t e m po r a r,v quartering (shelter areas to which vvacuens l are referred to from reception centers) and "shelter" as i protective action in the event of a rapidly developing avuident wherv evacaatiun is not feasible. For shelter as a protective
- action, plans call for residents to shelter in-house, and for visitors to shelter in any available building. Since many available buildinas could potentially be utilized for shelter, sapping in this i
case would be confusing.is In 1982 FEMA and the RAC reviewed the issues related to protectise actions for the beach population. The analysis included an examination of the evacuation time estimate for the .drim EPZ as presented in the MCDA Area II Plan, Utilizing a 1990 population estimate of 152.100 people, this evacuation time estimate provides for a "clear time" for the entire IPZ of 5.9 hours (good weatherl and 8.2 hours (adverse J weather). While the evacuation time estimate did not examine l specifically t',e evacuation of the beaches. wose of the data I indicate evacuation times for specific areas which include i l Massachusetts Civil Defense Agency (MCDA) Analysis to the Massachu-setts Public Interest Research Group (MASSPIRC) Report "Blueprint 1 I for Chaos II: Pilgria Disaster Plans. Still a Disaster.". p. 2 22 i e
i the beaches. The estimates are given below: Location No rma.1 Adverse (Hoursi (Mourst 2 2 mile radius 2.75 3.2 4 West 5 miles 4.5 6.3 South 5 miles 3.4 4.25 North 10 miles 4.3 5.5 j 4 j Most of the beach population in the Pilgria EPZ are permanent I I or temporary residents (as opposed to "day trippers"). FEMA's discussions with MCDA and local officials indicatsd
- that, although the peak beach population might be r
approximately 20,000 people, those who would not have ready I l access to buildings which would provide adequate shelter ranged only from several dozen to possibly several hundred people. In discussions held in
- 1982, State and local officials assured FIMA that they could provide shelter for l
i these people on an ad hoc basis. FEMA and toe RAC, upon 4 l reviewing the information from the Commonwealth and 1 c empirically examining the area around the beaches, agreed 4 with the Commonwealth's position that if nheitering in place i j were to be the rec.$ amended protective
- action, adequate shelters could be provided promptly on an ad hoc basis to those who would need it.
l l 23 I
t Issue Identification l In a reversal of the Commonwen,1th's previously stated
- position, the December 16, 1986 report frou Secretary of public Safety, Charles Barry, to the Governor states:
people at beaches might be particularly vulnerable during a fast-breaking accident at a nuclear power station because they may not have shelter nearby and $ndividuals may be a good distance from their automobiles. The variability and changeability of coastal weather is another major consideration.t* The report concludes discussion of this issue: L'nd e r present circumstances, the risks faced by the pilgrim beach population cannot be assessed.t' FESt % Current Position i
- o The Commonwealth had previously indicated to FEMA that i
I the number of people at the beaches in the Pilgrim EPZ who may be without ready access to buildings appropriate I for shelter in a radiological
- accident, ranged from several dozen to several hundred.
FIMA has reviewed the l matter
- and, based on a visual observation and preliminary I
to Report to the Governor on Emergency Preparedness for an Accident at the Pilgrim Nuclear Power Station (Parry Report 1, Secretary of Public Safety, December 16 1986, pp. 51, 52, 53. I l' Ibid, p.51. i 24 l 1 e r-.
- analysis, believes that the numbar of beach goers who say are greater than the previous State,
requ' ire public shelter i estimates and actually may range from several hundred to one, or even two, thousand. In additio.n. the Commonwealth states in the Barr> Report that it does not know whether there are i suffleient nearby buildings which could provide adequate shelter on soce of the beaches. The Commonwealth also que s i. l u n s ..h e t h e r or not it still has the capability to implement protective actions on an ad hoc basis during a fast-breaking accident. There
- are, of course, several mitigating factors to be 5
considered when examining protective actions for the beach population within the Pilgrim EPZ.
- First, the beach population appears to be made up largely of permanent or 4
3 tempurary r e s id r.n t s who have access to buildings designed to minimize air infiltration and therefore, capable l of providing effective shelter;
- second, the beaches are 1
spread in different directions throughout the EPZ, ranging in distance from as near as 1.5 miles (White Horse) to as far as i 10 miles (Green Harbor) from the plant, making it unlikely \\ that the entire beach population would be af fected initially i q l during an accident;
- third, the evacuation network in the Pilgrim plume exposure iP2 is extensive and easily accessible; fourth, the beach population is not concentrated 1
4 25 i
l along any one or two evacuatio,n routes;
- fifth, the Commonwealth has developed workable plans fo'r diverting corridor and shadow evacuation traffic from the evacuation network,tt thus maximizing its ability to quickly evacuate i
the population most at risk. I Although these factors indicate that protective actions for the beach population may well be adequate currently and, if not. readily correctable. FEMA can no longer state with confidence that a reasonable assurance exists that the beach population can be protected through prompt adequate Before FEMA and the RAC can make a determination sheltering. un this issue it must receive the following additional information: 1) an updated geographical description uf the beaches and j j their capacity; 2) a detailed analysis of the beach i population, including the number of permanent and temporary 1 residents and the numbsr of day visitorni,together with their l geographical dispersion; '3) an updated estimate of the length i of time it would t.ke to evacuate the beach population; and ] ) a 1Lat of suitable buildings available for sheltering the 4) ) beach population at each beach. !ncluding the capacities of l FEMA reviewed these plans aa part of its May 1, 1984 "Analysis
- Report on issues Related to the Pilgrim Evacuation Time Estimate".
26 l i __._____r____
..-. =.. -....- _ t j buildings, sad their distances from the beaches. If i i l these buildings are not open to the
- public,
/ these the plans must clearly state how ther will be i d l l made accessible sad letters of agreement must be obta ne 1 1 a n ss appropriate. t J [ t 2 t j. i 1 4 j i t ) { I 1 4 V a ( e l a l t I i a 27 k
..n.---..,.--..-_,__n_
,.n,..w,-,w,v.. m-w. n- ,g-_n .,,-.,,--,,,-m,,nn-n. n..., - ,,.,.n,
4 4 b. Speelul Needa Population Issue FEMA's aviulations call for the Agency and thw RAC to use s guidance documwrit jvintly deseloped tsy FEMA and the dRC (igg. 44 CFR 230.51 This document is known as SUREC-0654 FEMA rep-1 Rev. 1. It indicates that state and local emergency plans shall include "seans for protecting those persons whose mobility may be impaired cue to such factors as institutional or other confinement" and further indicates that such plans aust describe the "means of relocation" for the population (111 NUREC-0654 FEMA-RIP-1.II.J.10 (d); J.10 (g); C.1 (d); and C.01, i [pj& previous Understandina I The 1985 version of the Town Annexes of Massachusetts plans state that: Because it is not always possible to maintain current lists of the handicapped individuals within local communities, an inventory of local transportation i 28
\\ \\ I resources, buth publie and private, that ould be called upun tu assint 4ny individuals having special needs will be maintained Although this has not yet been tested as a specific exercise objective, FE!!A's observations during exarcises in the past have indicated that the towns asintain some listing of mobility impaired individuals or those who may be in nursing homes. 1 Existing local plans do not include a list of the resources the towns plan to use in assisting uobility impaired people during an evacuation, although they state: Coordination of additional transportation (buses, trucks, vans) including transportation for the I handleapped (chair-lift vans. ambulances) will be provided thruush CEP/CED, using standard energency resource management procedures and evallable local and State resuurces. In the saae vein, the MCDA. Area 2 plan states: Resources to assist handicapped individuals, in the control of such specialized agencies as area councils on aging, visiting nurses associations, handicapped service i
- agencies, area hospitals and nursind homes, and private service suppliers, including chair-lift vans and other equipment resources,
'can be accessed by local communities and through MCDA. Area 2 Headquarters in Bridgewater as available. In 1981 the RAC. expressed its concern reg &rding planning for i the mobility impaired population: 4 l 29 4
J The State's and locals' plans to implement protective measures for the plume exposure pathway shall include means for protecting these persons whose mobility may be impaired due to such factors as institutional or other confinement. The local plans require t.h a t handicapped persons inform the town of their special transportation needs. Also the pilgrim 1 Area operations plan has a listing of nursing homes and jails without explaining the necessary protective measures. These issues need to be better addressed, i ihe remmonwealth responded to the RAC's concern in this f j ma rin e r : l It has been the experience of the State that handicapped I persons are not eager to make it publicly known that they may need special assistance in evacuating for fear that this would make them and their property more vulnerable if this information fell into the wrong hands. The State Civil Defense Agency is working to l identify these individuals through various organizations l that deal with the handicapped. The RAC in turn replied that the Commonwealth needed to: lu)pdate the Plan with information on the progress being i made to identify the handicapped and provide for their protection. The revised RAC comment in September 1982 stated: No information is found in P.R.l.7 "Protective or elsewhere that P.R.4.[ty impaired. The i i, Alternatives
- ur in P.R.2 mobil proviiles protection for the State is now working on this and other special transportation related problems with special interest Area Directors and the local officials.
groups. I The, issue of plans for the evacuation of the special needs was raised at a June 3. 1982 public meeting population sponsored by FEMA on the Radiological Energency Response Plan 30 i I i . ~. -.,_.
I for pilgrim and at a July 1. 1982 meeting between FEMA. MCDA d i and the pilgrim Alliance. The Commonwealth stated that It had been trying for some time to develop a listing o( all the handicapped persons in the various communities without success, due to the reluctance of handicapped people for security reasons, to have their names un lists. The Commonwealth suggested that the Pilgrim Alliance contact the {. i office of Elderly Affairs and the local Council on Aging and cooperate with the ongoing effort vf the Commonwealth to enhance planning in this area. j. In its 198: Interim Finding. FDiA indicated that plans for ]- the evacuatlun of special needs individuals were often vague. 1 In consideration of the enormous resources listed in the State's Emergency Plan for Assistance to Municipalities l l Durins Esacuations, hot.ever. and the fact that efforts were 1 then actively underway to identify persons who needed special assistance. FEMA accepted the
- plan, notwithstanding its i
concern about its vagueness, e The issue of planning for the mobility impaired was then ] raised in the July 20, 1983 MASSPIRC study on energency planr.ing for Pilgrim. The study alleged that there was no i i confidential list of all physically disabled persons in the EPZ and that there were no workable plans for their 4 31 a
. ~ h i evacuation. to the MASSPIRC report was as follows: MCDA's. response to develop up-to-date lists of McDA has worked for years the handicapped. This effort, has included notices in and continues. Practical plans for local newspapers resources available to the evacuating such people using through Executive Order 144 personnel, (such as chairlift vans) as well as local and private retources State do ex1.t.8' In ita ..ffset to .dentify the mobility impaired and to locate the resources necessary to assist them during an the Cummonwealth has encl. sed a post card for evacuation, their use in its emergency public information brochures. l the Commonwealth and its efforts Based upon this assurance by l to identify mobility impaired individuals FEMA concluded l although the planning for special needs population was j
- that,
- t. e a k, it <.as minimally acceptable.
J l l latut fdentifleation l At a pubile meeting in Plymouth on June 30,
- 1986, a
f the Commonwealth's office of Handicapped representative ft Affairs stated that no contact had ever been sade with her MCDA Analysis to The Massachusetts Public Interest Gro 8' Print for Chaos II: 32
office by rianners developing radiological emergency response
- plans, tithough this statement was in contradiction to what MCDN official'. had previously led FEMA to believe, no state representative denied the allegation at the meeting.
1 I On Decembwr 16,
- 1986, Secretary of public Safety, Charles 1
Barrr, sent s report to the Governor concerning the ?ilgria I-Emergene,s plan. The report was accepted by the Gover,nor and 1 J the Director uf 'lCDA. The Barry Report states: 4 plans should contain a geod estimate of transportation I needs and lists of locally available vehicles of each type. Having identified needs uhich cannot be met, the plans should identify buses, ambulance..and chair vans available beyond the EPZ which can be mobilized. Where l necessary, letters er agreement should be concluded with prisate companies which will supply vehicles in an emergency... ) The current plans for transportation dependent populstions in the Pilgrim EPZ communities are far too 1 l rudlavntary... While some progress has been made in identifying mobility impaired individuals, much work on i 4 tnis mattee remains to be done.t* j i In addition the Commonwealth has determined that the j preferred source of bus transportation for the P11gria i energency plan will be use of local, private bus companies, j l Massachusetts no longer plans to use the MBTA to provide J j Report to the Governor on Emergency Preparedness for an Accident f to at the Pilgria Nuclear Power Station (Barry Report). Secretary of Public Safety, December 16, 1986, pp. 51, 52, 53. I I 33 1 i l I
transportation resources to the communities in the Pilgria EPZ in the event of a nuclear accident. Although letters of ' agreement i.ith private bus companies do not currently i
- exist, the Commonwealth plans tr.
work with the companies to obtain them.88 i 4 1 @ Current Position 4 l l FEMA and the RAC reviet.ed this matter in 1981 and 1982 and j accepted the Commonwealth's posillon that sufficient spe:ial 1 plans were currently in
- place, for the mobility impaired; sufficient resources had been identified, i
additional work was underway, and ad hoc response capability I coulo further enhance this effort. Since
- then, howevar.
O questions have arisen as to the amount of effort that has l been expended and is being expended '.o identify mobility l i lapaired individuals and to plan adequately for their needs in the event of an incident at the Pilgria Nuclear Power 4 Station. No significant revision to the Commonwealth's plan l has been submitted to FDIA since 1982. Report to the Governce on s.n..rsency Preparedness for an Accident i
- at the Pilgria Nuclear Power Station (Barry Reporti. Secretary of Public Safety. December 16, 1986, p. 51 et. seg.
1 34 i l = l l i e
- Nuw, the Csemunwealth has indicated that tt no lunger plans to use the
- sast, readily accessible, state controlled resuurces af the
'lBTA for evacuating the mobility lapaired population of the pilgrim EPZ. To date it has offered no substitution for this resource. The Commonwealth's own Office uf Kandicapped Affairs has made uncontrsserted statements that adequate planning for the I mobility impatred has not been implemented. i FEMA .therefore, can no longer state with confidence that a easunable assurance exists that the health and safety of mobility impaired people can be protected in the event of an accident at the Pilgrim Nuclear power Station. Before FEMA and the PAC can make a determination un this issue additional i f, information is needed. This information must include the
- updated, cumprehensive procedures used to identify the t
l motility
- impaired, together with the program in place to periodically review and update all relevant information i
pertaining to them; the resources available to meet the needs of the this group; and letters of agreement for the use of these resources as appropriate. i 1 i I ) l I 35 J I e*
I Transportation Dependent Population E. 11.ML1 and the RAC to use a regulations call for the Agency FEMA's jointly developed by FEMA and the NRC (( ggt J guidance document as NUREC-0654 44 CFR 150.51 This document is known I (EMA. rep.t. Rev. 1 It indicates that state and local "means of relocation" for .mergency plans aust demeribe the NUREG-0654, FEMA-REP-1, !!.J.10(g)]. the population (Eti, l l i E133 Previeut yndetstanding 1 the Massachusetts The 1985 Pilgrim Area Town Annexes to l l Plans state: State Radiological Emergency Response \\ 7 1 l would be private (T]he primary means for evacuation... auto...[ Thel plan recognizes that while not every i I i individual has access to a vehicle at a given time, among neighbors considermole sharing of vehicle spaceContractor sch. col r l will accommodate most evacuees... nova those without personal 'aeans i buses may be used to l of transportation. i In 1981 the FEMA /RAC Review questioned the adequacy of the state and local plans to implement relocation from the of the 198 revision of the The FEMA /RAC Review Pilgria EPZ. 36 J
State Plan. ;ndiested that further planning i. a s needed in to an automobile. i.*ithout access order to protect persons. evacuating the Pilgrim EP2. to be provided for those The i ssue of how transportation 1 s-to an automobile temporaril) sr permanently i.ithout access -as brought up again at the June 3. 1982 publie meeting to this concern was that concerning Pilgrim. MCDA's response l it had made arrangements with the Massachusetts Bay l (a stai-saencyl to provide buses to Trans portation 4.nhari ty Pilgria EPZ on an "as needed" basis. the 1983 study raised in MASSPIRG's July 20, l This issue was also on emergency planning for Pilgrim which claimed that a substantial segment of the population will require public l MCDA responded to the [ transportation in order to evacuate. MASSp!RG report as follows: l According to studies conducted there are sufficient privately owned vehicles to provide the general population with transportation during an evacuation. Mass-transportation resource lists provide additional capability if required. Needs have been assessed and a mass transit inventory i these needs.88 has been prepared to meet ) __MCDA Analysis to The Massachusetts Public Interest Group Re 1 Frint for Chaos II: Pilgria Disaster Plans. Still a Disaster".. 88
- p. 8.
j i 37
- ___y,
were not available. detailed procedures While specific. enormous resources listed in in consideration of thefor assistance to municipalities f E!!A. State's Emergency Plan the state had made the evacuation and because for use of the resources from other state during an (including the vast and readily accessible arrantements was agencies of the ?!BTA), found that this planning resources adequate. issue [ dent i f icat ion l (June 18, 1986). Duxbury 1 i At publie meetings in Boston (June 25, 1986) and Plymouth (June 30, 1986), questions i l transportation for l Commonwealth's provision for l about the to an automobile were repeatedly people without ready access was that this l The Commonwealth's general response J raised. l natter needed further study and analysis. l F 4 from Secretary of Public Safety. i The December 16, 1986 report l Charles Barry to the Governor states: l include people without i Teansport dependent populations school children and automobile, I access to a private 34 i !L
I while achool is in session. and other in das care residvnts, home ch11dron and nursing hospital mobility-impaired persons.good estimate of transportationvehicles of shuuld contain a of locally available t, the identified needs which cannot be meand c Plans l needs and lists ambulance, mobilized. Where Having J plans should identify buses, type. available beyond the IPZ which canshould be concluded wtt be vehlules in an Intters of agreement which w i,11 mupply necwsmary.. companies private dependent emergency. transportatiott far too for eommunities are plans better plans to provide for thepopul the Pilgrim EPZ curreret Th* in l populettens
- Clearly, t
needs of all transportation dependen rudiment 4ry.... prepared.: Le s.an and must I Pilgr5.n Ep ) C_u r r e n1 f,1,'Q p o s i t i o n 1981 and 1982 and l reviewvd this matter in in-place and the RAC that planning TEMA the Commonwealth's position additionally provided s accepted utilize to with plans Since i together was minimally adequate. on an ad hoc basis
- recently, resources public meetings and, l
then, questions have arisen at of the j in the Barry Report itself as to the adequacy of the transport pre-planning for evacuation states in the Barry Commonwealth's The Commonwealth l population. provide adeguate resources j dependent that it can no longer Report dness for an Accident to the Governor on Energency Prepare (Barry Report), Secretary i at the Pilgrim Nuclear power Stat on 31, 52, 33. Report 88 6, pp. of Public Safety. December 16, 198 3 39
an ad hoc basis. In on fast-breaking accident that it is no advised FEMA during a ' Commonwealth has MBTA to provide transportation the addition planning en using the I longer resources. on update of the Massachusetts received of the state Although it has not believes that,sany 1980. FEMA well be plan listed in the plan any since resuurces at transportation event of an accident in the to the Commonwealth it no indicated that
- asatlabi, the Commonwealth has Because accessible resources.
pilgrim. to use its vast and with loager plans FEMA can no longer state j the MBTA. tLe health however. f a reasonable assurance exists that including can be confidence that and safety uf the transport dependent population the pilgria N.uclear at in the event of an accident protected I O pou r Station. l on this a determination I l TE!!A and the RAC can aske i for I receive detailed plans and procedures Before we aunt including: l
- pulation, issue.
pr,otection of the transport dependent po lists indicating
- involved, I
estiantes of the number of people and appropriate letters l i d, the resources needed and identif e l of agreement. I i 40 ) I
and Apparent in Planning Overall Lack of Trogress l F. Diminution in Energency Preparedness to 44 CFH 350.7, the consonwealth On June 16, 1981, pursuant its for formal approval, of Massachusetts submitted to FIHA, protect the to energency, response radiological The RAC l plan for at Pilgria. public in the
- vent af an accident 1981 in October, issued its report the plan and the RAC reviewed the revtet.ed t
l the Cosimonwedi th, Following sestsion by 1982. in September, plan and issued another report emergency response plan was the public setting concerning tts on June 3, 1982 N A l sponsored by FEMA in Plymouth, Massachuse raised by local were several issues During the meeting issues were: offietals and citizens. These within the communities The ability to evacuate ic-mile EP2. Cape Cod beyond the 10-mile The ability to evacuate EP2. l Reliability and effectiveness of the sirens. i school bus Training and education of
- teachers, I
drivers, and hospital personnel'. brochures for the
- public, including Information transients, Policy on the use of radioprotective drugs, i
with special Protection of the elderly and othere i 41 - - ~ _ w - - _ _
reeds.ta f 4 The Commonwealth committed itself to addressing these issues and resolving the problems brought to its attention. Exercises testing the Commonwealth's emergency plan were conducted on March 3 1982. June 29. 1983 and September 5. 1985; a no fault drill was held on August 15, 1984 and a i 1 Remedial Exercise was performed on October 29. 1985. i During these exercises "deficiencies". "areas requiring i corrective action". and "areas recommended for laprovement" I were identified. As TEMA now uses the tera. "deficiencies" I are problems identified in plan Laplementation which preclude ) a finding that a plan is adequate to protect the health and safet.v of the public. "Areas requiring corrective action" are defined as inadequacies in State and lucal government ) psrformance observed during an exercise; although their correction is
- required, they are not considered, by themselves, to adversely impact public health and safety.
- Areas recommended for laprovement" are defined as problen observed during an exercise that are not considered to l
areas l adversely impact public health and safety. The Commonwealth Follow-up to the June 3, 1982 Public Meeting. FEMA. p. 1 1 42 1 1 l i
1 "deficiencies". For example, moved quickly to solve the FEMA identified four has \\985 exercise the september 5 all by during Massachusetts had resolved them defickincies,' and October 29, 1985. sinor i.h e n considered in the plan,' difficulties individus11y, plus numerous "areas requiring corrective Many l l include remain uncorrected. These unresolsed prob ems t action" virtually everything identified in the 1982 RAC review; i outstanding from the reports on the March 3 sany issues 1983 Exercises; all issues identified in the '.982, June 29, the deficiences which were l September 5, 1985 Exercise (except t i promptly remedied). I 1982 public meeting of the transcript of the June 3, A review the Consonwealth indicates that to receive local input held that l to keep the commitments it ande at failed genere11y has Many of the improvements time to upgrade its energency plan. the public meeting relate l energency planning promised at f in i such as to items discussed in other sections of this rev ew, school
- children, and the transportation dependent people, other planning and preparedness l
- However, beach population.
remain outstanding Lasues, not directly related to the above, i
- 1981, 1982 RAC
- Reviews, and 1985 Exerciur f
((gg,
- gatu, for tow trucks and letters of agreement Report). For example, i
I 43 I l
been obtained; a schedule for snow plow sperstors hase not been submitted; and a not of emergency workers has i training not been forthcoming. schedule for the required drills has h on March 6. 1985 and october 30, 1985 FEMA advised the Director of Civil Defense
- that, because the Massachusetts to many of its comments on f-Commonwealth had been unresponsive planning
- problems, FEMA must cease processing the l
for formal approval of the State and Commonwealth's request l in the event of an accident the public local plan to protect The Report of Secret.cy of Public Safety Charles l f at pilgrim. i issued in December, 1986 generally acknowledges that
- Barry, the problems identified by TEMA in its plan reviews and valid and should be addressed in an l
esercise reports are l In addition, Secretary Barry concluded that arderly fashion. the Massachusetts plans to protect the public in the event The Commonwealth at Pilgrim are not adequate. of an accident responsive to submitted plan improvements has not, to date, FEMA-REP-1 (a violation of NUREG-0654. l FEMA's many concerns evaluation criteria N.5, P.4 and P.10). During the past fifteen months representatives of FEMA have 4 participated in numerous public and interagency meetings LEMA has observed that the Commonwenith's plan. concerning 44
t withstand scrutiny in the emergency plan for pilgria does no report and that thera l in this areas described elsewhere resolving the the actually uf progress in general lack FEMA is a discussed sunts. identified with it, l numerous problems personnel who 1 Civil Defense l noticed that State h plan has also recent meetings were often unfamiliar with t e l to answer questions or otherwise attended were unable
- and, therefore, about matters addressed in the the publie and media squaint FEMA's observation of the from current plan.
Furthermore, emergency personnel it and local between state interaction of coordination lack that there has been a between these levels of government in training and plan is apparent l f maintainence. 2 an annual training FEMA has not received any evidence th;t workers at the state sesd local J for emergency ) f XUREC-0654. program as required by evaluation criterier. O o 2 has been developed er implemented. Based
- levels,
) l we doubt that FEMA-REP-1. Rev.1. the public avetings, on TEMA's obse rvations at l such a program is being carried out. F Idison Company has understands that the Boston local governments to participate (IMA d invited State and of the recently FIMA is not aware l planning drills. in energency however, nor has it 1 1 extent of State and local participation. l l' 45 1 l i,
l l l l l l l l been apprised of the
- scope, depth and results 'of the 1
dril'Is, l 1 l l The Commonwealth of Massachusetts has not submitted the Annual Letter of Certification, re, quired by FEMA in Guidance Memorandum PR-1. October 1, 1985 "in order to facilitate the monitoring of, REP planning and preparedness requirements as prescribed in NUREG-0654 FEMA-REP-l; and 44 CFR 350". On ^etober 4, 1985 FEMA sent a letter to MCDA informing it of the requirement to submit a letter of certification by January 31, 1986 for calendar year 1985. FEMA repeated its request on July 31, 1986; and on January 8, 1987, requested both the 1985 and 1986 Annual Letters of Certification. To date it has received no response to any of its requests. FEMA therefore has no basis for believing that the Communication Drills (N. .4). Medical Emergency Drill (N.2.c), Radiological f Monitoring Drill (N.2.d1 and Health Physics Drill (N.2.el set forth in NURIC-0654, FEMA-RF.P-1, Rev.
- 1. have been conducted l
l and Jocumented as required under evaluation criteria N.3.4. In
- addition, FEMA has no assurance that a means to evaluate the observer comments and implement chrrectiveactionshas l
been developed as required under evaluation criterion N.5. For the following
- reasons, therefore, FEMA can no longer state with confidence that a reasonable assurance exists that 46
the health and safety of the publie can be protected in the event of an accident at the Pilgrim Nuclear Po'we'r Station: (1) the commonwealth has failed to correct the numerous problems noted in FEMA's review of its plan and during it's exercises as required by 44 CFR 450.9(a), and evaluation criterion N.5 of NUREC-0654 FEMA, REP-1. Rev. 1; (2) it has not updated its plan, and so advised FEMA of its actions. on 4n annual basis as required or evaluation criterion P.4 of NURIC-0654 FEMA-REP-1 Rev. 1; (3) it has not implemented required by evaluation criterion i State and local training as 1 0.5 of NUREC-0654 FEMA-REP-1 Rev. 1; (4) it has not pursued an adequate program of public education and information for the sedia as required by evaluation criterion 0.5 of NUREC-06%4 FEMA-REP-1 Rev. 1; (5) and it has not, despite numerous r* quests, submitted to FEMA the required Annual Letters of Cet'ifica'. ton for calendar years 1985 and 1986. (6) in addition, representatives of the Commonwealth have indicated that the state and local plan is inadequate; and (7) they have been unable to answer numerous questions posed by the public and by local officials in public meetings as required by evaluatir.n criteria: 0.1, 0.2, 0.5 0.1, 0.2
- o. 4, and 0.5 and P-1 of NUMEO-06 5 4, FEMA-REP-1 Rev. 1.
We also note that additional areas of plan weakness are identified in the attached FEMA Report. "Analysis of i 47 i
l 1 Emergency Preparedness Issues at Pilgrim Nuclear Power J Station Raised in a P*titlen to the NRC Dated July 15, 1986. While FDtA did not find these areas of plan weakness were sufficient to sustain the contentions raised in the
- petition, resolution of these weaknesses would certainly i
enhance the State's ability to protect the, public. FEMA will l ( 1 therefore be i:losely mon i t.o ri n g the State's progress an ]' i resolving these matters. l I P 1 j l 5 I .j I I 2 ) 1 i 4: I i i J __i
e IV. CONCLUSION s FIMA has analyzed the information provided at the Spring, ) 1986 neetins: as well as additional information provided by the Commonwealth and the public subsequent to those meetings. Based on this analysis and a review of the Massachusetts plan FEMA determines that the Massachusetts plan is inadequate to the health and safety of the public in the event'of protect i the pilgrim Huclear power plant and cannot be an accident at implemented until the inadequacies noted in this Self-I Initiated Review and Interim Finding are corrected. Because of the changed circumstances discussed above, the finding of adequacy contained in the Interim Finding of of September I 29, 1982 no longer applies and that Interim Finding is hereby superceded. l ) FEMA will continue to work
- with, and provide technical assistance to, the Commonwealth of Maenachusetts in its effort to fulfill its responsibility to develop a
radiological energency re.>Lonse plan to protect the health i and safety of its citizens. 1 l 49 l J 4 1 l
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'1 *?f.c f f [ a / /gober30,1979 - ~ ~.. Docket No. 50-293 l Mr. G. Carl Andugnini Boston Edison Corpany M/C PNCLEAR 800 Boylston Street Boston Massachusetts 02199
Dear Mr. Andegnint:
In your letter of Octobe-19. 1979 you stated that an'analysin of the present Pilgrim Nuclear Power station (PNPS) desien inmated 'ha t ther station complies with 10 CFR 50.44 relying on existing equipment. s Therefore, you have concluded that a Containment Air Dilution (CAD) system is not required and requested that we delete FSAR A endment 35 frcen your docket. Since the staff had concluded during the original licensing review of PNPS that a hydrogen control system socwiu y, v1'vec ror the facility, a we will need additional infomation in orcer to cetemine (nat this capability exists as you have stated. We request that you submit within 60 days of your receipt of_ this letter. _an analysis of the eiistire moittent which demonstrates confomanfeW ~ 10 CPR bo.4C'71 ease include suf ficient detati for us to evaluate'~ ,~ equipment coglihace with 10 CFR 50 Appendix A Criteria 41, 42 and 43. Your subatttal should also include proposed Technical Specifications for the existing equirr.ent that would be used for post-LOCA hydrogen control. We have included an excerpt from the latest version of GE-BWr. STS (?NREG 0123 Revision 2) for your use a*s a model in preparing appropriate specifications. Your cooperation with us is appreciated. Sincerely. N
- ppolito, lef Thomas Operating Reactors Branch f 3 Division of Operating Reactors
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5 ANNGTON, D C MacM641 i N H M4 4600 That 'ellu Thacopes iMa me em [ March 25, 1988 REDOW OF WFORMAU05 Director ACT REquun Office of Administration [474 -J $ = / T/ U.S. Nuclear Regulatory Commission kd %39EY 9fh Washington, D.C. 20555 i In re Freedom of Information Act Request l No. 88 __, Concerning Pilgrim Nuclear Power 1 Station i Dear Sir In accordance with the provisions of the Freedom of f Information Act, 5 U.S.C. 5552 and Part 9, Subpart A of 10 C.F.R., it is requested that the records identified below be made available for inspection and copying: 1. Records of any votes taken by the Commission, an1 records or transcripts of Commission meetings, with respect to the i shutdown of the Pilgrim Nuclear Power Station, or the restart thereof, on or after April 12, 1986. 1 2. All SECY papers, attachments thereto, records and other materials supporting or forming the basis for positions taken therein on the subject of the Pilgrim Nuclear Power Station, prepared on or after January 1, 1980. t 4 3. All records prepared or dated on or after Januacy 1, 1980 (but excluding documents included on Docket Po. 50-293 accession listings available from the Public Document Room) of NRC Megion I, the Office of the Executive Director for Operations, the Office of :nspection and Enforcement, the Office of Investigations, the Office of Nuclear Reactor Regulation, the Office of Nuclear daterials Safety and Safeguards, the Advisory Committee for Reactor Safeguards, the office for Evaluation of Operational Data, and the NRC l Emergency operations Center which (tscuss, refer to, take positions one or form the basis for decisions concerning, the performance of the Pilgrim Nuclear Power Station in the 2 following areas: i ,,.m o n I O O O / A 9 7sO f n p v c e7 " w I v ( )f T. = A. Management B. Staffing C. Organization and Organization Structure D. Radiation Protection E. Quality Assurance F. Surveillance G. Maintenance H. Offsite Emergency Planning I. Fire Protection J. Security K. Management Response to NAC Regulatory Activities 4. All records of Region I, the Office of Nuclear Reactor Regulation, the Commission, the Office of Inspection and Enforcement, or other Staff or Commission offices relating to, discussing or forming th basis or support for, the Director's Decision (DD-87-14 ) dated August 21, 1987. 5. All recorda (other than those categories of documents excluded from Item 3) of any office referred to in Item 4, above, discussing, describing, assessing, evaluating, or otherwise relating to actions by the NRC staff, FEMA, the ACRS, or other NRC or Commission of fices, to follow-up or monitor actions by Boston Edison Company, the Commonwealth of Massachusetts, other jurisdictions within the 10-mile emergency planning zone for Pilgrim Nuclear Power Station, to address issues raised in the Director's Decision (DD 14) dated August 21, 1987. 6. All records of the NRC offices referred to in Item 4 discussing, describing, assessing or evaluating, or otherwise relating to actions of the NRC staf f to evalua' the July 1987 Restart Plan, and other actions by Boston Edison Company, its agents or contractors, relating to the restart of the Pilgrim Nuclear Power Station. 7. All records of communications (whether written or oral and occurring from April 12, 1986 to the present) between any of fice of the NRC Staf f, or of the Commission or of fices reporting directly to it, and Boston Edison Company, concerning the status or startup of the Pilgrim Nuclear Power Station. 8, All records of communications (whether written or oral, and occurring from April 12, 1986 to the present) between any of fice of the NRC Staf f or of the Commission or of fices reporting directly to it, and FEMA, other Federal or State agencies or goveramental entities, or persons concerning the status, startup, or issues relating to startup, of the Pilgrim Nuclear Power Station. l )
F 9. All records in the possession of any NRC Staff or Commission office pertaining,to (a) the evaluation by PEMA, NRC, or any other entity or agency, of the adequacy of offsite emergency plans for the Pilgrim Nuclear Power Station, and (b) the conduct and/or evalustion of drills, full scale / full participation or partial scale / partial participation exercises conducted or planned for the Pilgrim Nuclear Power Station. For purposes of this request, "record" or "document" is defined to include, but not be limited to, notes, memoranda, reports, meeting minutes, logs, transcripts, letters, position or policy papers, interpretations of requirements, and guidance documents, and refers to draf ts as well as any final version of any record or document requested. Sine ly, J l 6 / k eE Jo son, Esq. (202)944-438 GEJ/veg i}}