ML20195H004
| ML20195H004 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 01/06/1988 |
| From: | Zech L NRC COMMISSION (OCM) |
| To: | Dukakis M MASSACHUSETTS, COMMONWEALTH OF |
| Shared Package | |
| ML19313A855 | List: |
| References | |
| NUDOCS 8801130394 | |
| Download: ML20195H004 (2) | |
Text
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)o, UNITED STATES NUCLEAR REGULATORY COMMISSION h
WASHINGTON, D. C. 20555 k'
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January 6, 1988
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J CHAIRMAN
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The Honorable Michael S. Dukakis Governor of Massachusetts Boston, Massachusetts 02133
Dear Governor Dukakis:
I am pleased to respond to your letter of December 17, 1987, in which you forwarded the recent report of Secretary Barry concerning the status of emergency preparedness at the Pilgrim Nuclear Power Station.
You expressed concern regarding a number of emergency preparedness and plant-related issues at Pilgrim that remain to be resolved, and requested a clarification of the specific steps the NRC will take to ensure that the concerns identified in the 1986 and 1987 reports by Secretary Barry will be satisfactorily addressed before restart. You also restated the position of the Comonwealth of Massachusetts that an adjudicatory hearing be held before any decision is reached on the plant's future.
The inadequacies in emergency planning and preparedness at Pilgrim have been well documented by the Federal Emergency Management Agency (FEMA) in its self-initiated review. That review was based on infomation provided by Commonwealth and local officials, members of the public, and other sources, including the 1986 Barry report. The Commonwealth, the local governments within the emergency planning zone (EPZ), and the two emergency reception center comunities are in the process of implementing numerous improvements in their emergency response programs with the assistance of the licensee.
These improvements include the revision of the local emergency plans, revision of the Massachusetts Civil Defense Agency Area 11 plan as well as the Comonwealth's State-wide plan, the development of revised procedures, the development and implementation of trainino programs for offsite officials and emergency personnel, and the upgrading of Emergency Operation Centers
- in each of the towns within the EPZ and reception center communities. TI.e NRC is closely monitoring the licensee's restart program, including the licensee's efforts to assist offsite authorities in improving their emergency response programs. We believe extensive progress has been made to date, but we recognize that additienal effort will be reouired before all corrective actions are completed.
In the enclosed letters to Congressman Gerry E. Studds, I indicated some of the steps the NRC has taken and plans to take before considering restart. The NRC staff has held several meetings with Comonwealth and local officials regarding the Pilgrim situation.
Future efforts will include a public meeting in the Plymouth area to receive public coments on the Boston Edison restart plan, a second public meeting in the Plymouth area to provide feedback to the public on the disposition of coments and concerns raised in the first meeting, and a public meeting between the NRC senior staff and State Senator William Golden' ar.d the other petitioners who submitted the July 198610 CFR 2.206 Petition.
In addition, Senator Edward M. Kennedy has scheduled a hearing before the Senate Labor and Human Resources Comittee at which the NPC will provide
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The Honorable Michael S. Dukakis testimony on the NRC consideration of a Pilgrim restart request. Other meetings and forums open to the public will be held as circumstances warrant during the course of our review of the licensee's readiness to restart Pilorim. As I have previously indicated, it is our view that when this series of planned meetings is completed, we will have heard and considered the views of more concerned citizens than would have been likely in an evidentiary hearing. At the same time, the staff's presentations at these meetings and before Senator Kennedy's Committee will ensure that the public, the Comonwealth, and local officials are informed of NRC's progress in reviewing the issues associated with restart.
I assure you that the NRC will not pennit the restart of the Pilgrim plant until the issues raised during the facility's prolonged shutdown are addressed to our satisfaction.
Sincerely, b-Lando W. Zech,
Enclosures:
1.
Ltr. fm L. W. Zech to G. E. Studds dtd. 11/20/87 2.
Ltr. fm L. W. Zech to G. E. Studds dtd. 11/24/87 i
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,i W ASHINGT ON, D. C. 20S66 November 20, 1987 CHAIRMAN The Honorable Gerry E. Studds United States House of Representatives Washington, D. C.
20515
Dear Congressman Studds:
I am responding to your September 17, 1987 letter, in which you and Senator Kennedy urged the Nuclear Regulatory Comission to convene a fomal and comprehensive hearing on the restart of the Pilgrim Nuclear Power Station. The Comission is fully aware of public concern regarding restart of the Pilgrim facility and has gone to unusual lengths to assure broad public participation in the restart decisibn..
The NRC staff and local officials in Massachusetts have engaged in a continuing dialogue on the Pilgrim situation. This dialogue has included at least three public meetings with the Plymouth Board of Selectmen, as ell as meetings with the Plymouth Chamber of Comerce, the Duxbury Board of Selectmen, the Massachusetts Joint Comittee on Energy, the Massachusetts Legislative Comittee on the Investigation and Study of the Pilgrim Station, the Town of Plymouth Advisory Comittee on Nuclear Matters, and others. Most recently, the NRC staff participated in a public forum on the Pilgrim situation at the Duxbury High School on October 29, 1987. This meeting was sponsored by the Duxbury Board of Selectmen.
Representatives from some of these groups also have participated in NRC Region I management meetings dealing with the Pilgrim facility, including the Systematic Assessment of Licensee Perfomance (SALP) meeting held on May 7, 1987. On October 8,1987, the NRC met with r?presentatives of the Comonwealth of Massachusetts in our Region I office.
This meeting, which s
was open to the public, was held to discuss agenda items proposed by the Comonwealth, including emergency preparedness issues, the status of various NRC technical reviews, and inspection activities expected in the next few months.
As the NRC proceeds with deliberations regarding restart of the Pilgrim reactor, additional public meetings will be held in lieu of the evidentiary hearing you have requested. These meetings will be fomal, transcribed sessions where the public's testimony will be heard by NRC j
management.
The following meetings are planned:
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A meeting will be held in the Plymouth area to receive public coments on the Boston Edison Restart Plan. This meeting will be scheduled after the NRC has received the details of the entire plan and after it has been placed in local libraries for public review.
NRC staff will also accept written testimony from those unable to attend the meeting. NRC will consider these coments, as appropriate, for enhancing NRC review and inspection activities.
2.
A second public meeting will be held in the Plymouth area to discuss the disposition of comments and concerns raised during the first meeting.
3.
Before a position on restart of the plant is developed in final form, a public meeting will be held between NRC senior staff and State Senator William Golden and the other petitioners who submitted the July 1986 10 CFR 2.206 Petition. This meeting will discuss NRC's actions regarding the Pilgrim plant and answer questions of the petitioners.
Other public meetings, including those with Boston Edison, will be held as' circumstances warrant. These meetings will be announced pursuant to NRC staff policy on open meetings (43 FR 28058). After the staff completes its reviews and before the NRC allows Pilgrim to restart, the Comission will hold a meeting to be briefed by the staff on the readiness of Pilgrim to resume operations.
The Comission believes it has demonstrated its comitment to comprehensive public participation in the Pilgrim restart decision. Moreover, it is cur view that when the series of planned meetings is completed, we will have heard and considered the views of more concerned citizens than would have been likely in a formal hearing.
Sincerely, N.
Lando W. Ze
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J CHAIR MAN November 24, 1987 The Honorable Gerry F. Studds United States House of Representatives Washington, D.C.
20515
Dear Congressman Studds:
I am responding to your letter of September 18, 1987, in which you requested that NRC take two specific actions regarding the Pilgrim Nuclear Power Station.
First, you asked that we perform an environmental assessment of modifications made to the plant's containment structure before the plant is allowed to restart.
Second, you asked that we de6er, judgment on the plant's venting system until all containment venting issues, including environmental concerns, are thoroughly analyzed and resolved through the ongoing review process.
You also urged us to defer judgment on the plant's venting system until revision a to the Boiling Water Reactor Owners Group (BWROG) Emergency Procedure Guidelines (EPGs) has been completed 4 As part of their Safety Enhancement Program (SEP), Boston Edison Company (BECo), the Pilgrim licensee, proposed the installation of a Direct Torus Vent System (DTVS) as one of several SEP measures to improve containment performance at Pilgrim.
The other SEP modifications do not affect the contain-nent structure per se but are designed to mitigate the effects of abnormal conditions that would develop in containment during an accident scenario.
These modifications are in consonance 3
with NRC goals to enhance containment performance under severe accident conditions but are not required for restart of Pilgrim.
We are, however, ensuring that these modifications do not constitute an unreviewed safety question as part of the restart conditions.
The NRC staff's evaluation of the proposed SEP modifications will include the prospective operation of the DTVS and will address the need for an environmental assessment.
I have enclosed a copy of the staff's initial safety assessment of the SEP modifications in which they did not endorse the use of the OTVS at this time.
BEco will not be allowed to place the DTVS system into service until it i s thcroughly evaluated and approved by the staff.
Concerning revision 4 of the BWROG EPGs,, the staff is not expected to complete its review of that revision until early 1988.
Although the staff has previously approved a strategy k OYWf ri
2-for containment venting for Pilgrim and other boiling water reactors in conjunction with their review of current BWROG EPGs, the proposed revision 4 guidelines recomniend a new approach, with containment venting used as an anticipatory response to elevated containment pressure.
This new approach must be thoroughly evaluated and approved by the staff before specific containment venting modifications may be found acceptable at Pilgrim.
I appreciate your interest in this matter and trust that this letter adequately responds to your request.
Sincerely, M LAl.
Lando W.
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Enclosure:
As stated s
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THE COMMONWEALTH OF MASSACHUSETTS q
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STATE HOUSE BOSTON 02133 4
MICH AEL S. DUKAKIS Govt = Nom December 17, 1987 i
Mr. Lando Zech, Chairman U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Mr. Zech:
In April, 1986, I called for a review of emergency preparedness and other safety issues at the Pilgrim Nuclear Power Station.
Almost one year ago, I received from Charles V.
Barry, my Secretary of Public Safety, the most comprehensive report to date on that subject.
The conclusions of Secretary Barry's report with which I concurred were that existing emergency plans for Pilgrim Station were not adequate to protect the public health and safety in the event of an accident at the facility.
Thereafter, I made it clear to all parties that Pilgrim Station should not be permitted to restart unless and until all emergency planning and safety related issues were satisfactorily addressed.
In August of 1987, the Federal Emergency Management Agency issued its own review of the Pilgrim plans which reached the same conclusions.
Recently, I received from Secretary Barry the enclosed "Report on Emergency Preparedness for an Accident at Pilgrim Nuclear Power Station."
Based upon Secretary Barry's report, I continue to make the finding that adequate plans do not presently exist, that in no event should Pilgrim be permitted to restart unless and until all emergency planning and safety related issues are resolved, and that it remains to be determined if adequate plans can in fact be developed.
Nevertheless, it continues to be our policy to strive to develop the best possible plans to protect the public from the existing hazards posed by Pilgrim Station.
In particular, while Secretary Barry's report identifies the many positive steps takua over the pa'st year to improve emergency plans and safety at Pilgrim Station, it also identifies a number of remaining problems.
IW 1hY4%h M
s Lando tech, Chairman December 17, 1987 Page Two i
j These pending issues include, but are not limited to:
Development of implementing procedures for assisting
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special needs populations, Development of a Pilgrim-Specific Probabilistic Risk Assessment, Assessment of the need for an additional reception
- facility, i
Resolution of questions regarding the new Evacuation Time Estimate and Traffic Management Study, and l
Resolution of safety issues regarding installation of the direct torus vent.
The time has come for the Nuclear Regulatory Commission and the Federal Emergency Management Agency to make clear what specific steps will be taken to insure that all concerns voiced in both the 1986 and 1987 reports prepared by Secretary Barry 1
will be satisfactorily addressed before, Pilgrim Nuclear Power Station is permitted to restart.
Further, I want to take this opportunity to restate the positiop taken by Attorney General James Shannon and I, that a-7'd judica to r hearing should be held prior to any decision on e
ant's ut pe tatus.
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REPORT ON EMERGENCY PREPAREDNESS FOR AN ACCIDENT AT PILGRIM NUCLEAR POWER STATION I.
INTRODUCTION Since my December, 1986, report, local, state, and federal authorities have been active in numerous ways concerning safety at Pilgrim Nuclear Power Station.
The Boston Edison Company, owner and operator of Pilgrim Station, has also taken a number of actions regarding nuclear management, reactor safety, and emergency preparedness.
Nonetheless, it is still my opinion that Pilgrim Station should not be permitted to restart at this time.
Until fully revised plans have been developed and found by the state to be adequate, I must continue to make the finding that there are not presently adequate plans for response to an accident at Pilgrim Station.
Thus, in spite of progress which has been made, I cannot yet say that all safety issues pertaining to Pilgrim Station which were discussed in my December, 1986, report have been antisfactorily addressed.
Subsequent to December, 1986, other bodies have made reports on safety at Pilgrim Station and reached the same conclusion we did, that public health and safety would be compromised by the continued operation of Pilgrim Station unless and until substantial remedial action had been taken.
These reports include a study by the Massachusetts Legislature's Special Joint Commission to Study Safety at Pilgrim Nuclear Power Station, the U.S.
Nuclear Regulatory Commission's (NRC) Systematic Assessment of Licensee Performance (SALP),'and a Self-Initiated Review of emergency response plans by the Federal Emergency Management Agency (FEMA).
The Federal Emergency Management Agency has issued an saaessment of the plans for response to an accident at Pilgrim.
FEMA concluded that their earlier 1982 interim finding that Pilgrim *a emergency plans were adequate was no longer valid and was superceded by a new finding that the plans as most recently revised in 1985 were not adequate.
This new finding was transmitted to the Nuclear Regulatory Commission, which has taken the position that laaues raised in the FEMA annea' ament must be "addressed" before restart is permitted.
The NRC has l
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never articulated what it means by "addressed."
The NRC's position does not go far enough to assure protection of public health and safety.
In our view, adequate plans must be in place before Pilgrim Station is allowed to restart.
hnparticular, the FEMA Self-Initiated Review made the finding that off-site emergency plans are not adequate to provide reasonable assurance that the public can be protected in the event of an accident at Pilgrim Station.
The SALP report, which grades utility performance in several areas, gave Boston Edison the lowest possible grades for critical safety functions.
The Special Legislative Joint Commission report made several recommendations which Commission members feel must be fulfilled before the plant is authorized to resume operation.
Since December 16, 1986, action has been taken on several fronts by state government to respond to the findings of my report.1 The Massachusetts Civil Defense Agency and Office of Emergency Preparedness (MCDA/OEP) has initiated a comprehensive three phase process to completely revise emergency plans for the communities surrounding Pilgrim Station.
The state legislature has established and provided initial funding for a Nuclear Safety Emergency Preparedness Program within MCDA/OEP, which is responsible for off-site emergency preparedness for all three licensed nuclear power plants within and adjacent to Massachusetts.2 On October 6,
1987, the Governor submitted a supplementary budget request of s700,000 for the new program (House Bill 6086, see appendix one).
Prompt action on this request is important.
An important aspect of the process to improve safety at Pilgrim is that state officials meet regularly with local officials, interested citizens, and representatives of Boston Edison to discuss problems and issues related to safety at Pilgrim.
MCDA/OEP and Executive Office of Public Safety 1Since our September, 1986 decision that adequate energency planning for Seabrook is not possible, it is the policy of the Consonwealth that there should not be participation by Massachusetts in attempts to draft plans for that unlicensed plant.
2In addition to Pilgria Station, the Yankee Nuclear Power Station in Rowe, Massachusetts, and the Vermont Yankee Nuclear Power Station in Vernon, Vermont, have opergency planning zones within Massachusetts.
2
J officials meet regularly with senior management representatives of both Boston Edison and the Yankee Atomic Electric Company to i
discuss nuclear safety issues.
The Executive Office of Public Safety and MCDA/OEP also participate in and monitor meetings of l
federal regulatory authorities.
The Boston Edison Company has taken several actions in part as a response to my report.
The company haa offered support to local governmenta under section 15 of chapter 639 of the acts of 1950, to assist in enhancing local response to an accident at Pilgrim and to renovate local emergency operations centers.
As of this writing, four of the seven EP2 and host communities have accepted the Boston Edison support and the remaining three communities have the offer under consideration.
Boston Edison has issued studies and surveys, including a new Evacuation Time Estimate, a survey of shelter in beach areas, and a survey of special needs populations in the EP2.
Under supervision of the NRC, Boston Edison has also restructured the management of Pilgrim Station and initiated a reactor "Safety Enhancement Program."
Boston Edison has installed a new radio system to assure prompt notification of off-site authorities in the event of an accident at Pilgrim Station.
In regard to off-site emergency planning, Boston Edison la supporting the efforts of local officials to develop improved plans and procedures by making resources, including professional emergency planners, available to each of the seven EP2 and host communities under section 15 of chapter 639 of the acts of 1950.
Under the same provision of the Massachusetts General Laws, Boston Edison is also providing each community with material resources to support emergency response and is making physical improvements to each local emergency operations center.
This offer to each community includes funding for a full-time civil defense director for the operating life of Pilgrim Station.
Four of the seven EP2 and host communities have signed agreements with Boston Edison to accept this assistance.
The Nuclear Regulatory Commission and the Federal Emergency Management Agency are continuing to exercise their regulatory authority over Pilgrim Station.
FEMA is responsible for certifying to the NRC that off-alte emergency plans and response are adequate.
In a report dated August 6, 1987, FEMA stated that "It3he results of our self-initiated review indicate that the Massachusetts Plan is inadequate to protect the health and safety of the public in the event of an accident at the Pilgrim Nuclear Power Station..."3 3The FEMA Self-Initiated Review is discussed in greater detail in,section IV.
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The NRC closely monitoring all developments concerning cnorgency planning, the safe operation of the reactor, and on-cite safety and management.
For instance, the NRC has three rooident inspectors assigned to monitor operations at Pilgrim Station rather then.the one inspector easigned to most other nucicar plants.
However, on one recent weekend when there were oight problem events at Pilgrim Station, only two NRC resident incpectors were assigned to the facility and no inspections l
woro made during the period the events occured.
Sines that ti=o I have requested that the NRC agree to provide, at a minimum, daily random monitoring of operations at Pilgrim a
Station.
The NRC is issuing a status report on the facility ovory two weeks, and this practice should certainly continue.
t 1
STATE RESPONSE TO THE DECEMBER. 1986 REPORT ON SAFETY AT e
PILGRIM STATION Revisions to Off-Site Eueroency Plans One of the most critical findings of my report on cofoty at Pilgrim was that state and local plana for response to en accident at Pilgrim Station were not adequate to protect the public.
The Massachusetts Civil Defense Agency and Office of Energency Preparedness, which is responsible for off-site nucicar power plant emergency planning under st. 1979, c.796, hoc responded by establishing a three phase program designed to develop the best possible emergency plans for all EPZ and host concunities.4 They will be assisted in this effort by the new Nuclear Safety Emergency Preparedneca Program discussed in coction II.B.
Since energency response is first and foremost a t
rocponsibility of local government, MCDA/OEP has sought to a
octcblish a system whereby local authorities take the principal rolo in plan revision with advice and assistance from state efficials.
Further, since state and local resources available for this purpose remain strictly limited, support for this effort has been received from Boston Edison as discussed above.
Federal regulatory guidance suggests that nuclear utilities should support the costs of off-site emergency prcparedness as a responsibility of operating commercial e
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4Tho five communities comprising the Pilgria EPZ are Carver, Duxbury, Kingston, M rchfield, and Plymouth.
Presently there are two host communities, Taunton and Bridgewater.
It should be noted that similar programa have been initiated icr the communities within and serving the Rowe and Vernon EPZa..
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i are attended regularly by the civil defense directors of most of the EpZ and host communities.
An essential component of the phase II process is that local plans will be reformated so that they are organized according to NUREG-0654 planning criteria.
This will enable more efficient checks on progress and easier determination of compliance with federal regulatory planning requirements.
The many issues raised in my earlier report and other reviews of the plans must be resolved before the phase II process can be completed.
Section VI of this report contains an item-by-item discussion of progress on these matters.
Certain aspects of the third phase of the process cre presently under way.
The training officer of MCDA/OEp in cooperation with a representative of the state Department of Education has begun to develop a revised training curriculum for all emergency response personnel.
MCDA/OEp and Boston Edison have already begun to offer certain essential training courses to local officials.
For instance, training is being given for the newly installed emergency notification radio system (see section III of this report) and for operation of public alert siren systems.
Whether or not pilgrim Station restarts, it will at least in the short run remain a high-level waste storage area, ao local officials must know how to operate these systems because there is always a potential need for off-site response to an accident at the facility, whether or not it is on line.
The remainder of phase III training will be offered to state and local personnel as the plans are further developed and as the curricula are better defined.
Boston Edison is assisting with development of technical training modules for all emergency response disciplines.
If we determine that adequate plans have been developed through the phase II process and that all emergency personnel have received or will receive 4 required training, then the possibility of holding a full-scale emergency exercise will be considered.
While MCDA/OEp and other state and local agencies are pledged to complete the three phase process as quickly as possible given available staff and resources -- our target date is to produce a new revision of the plan by the end of the it bears emphasis that there is no absolute calendar year deadline for this work.
Whatever time is required to develop the best possible plans will be spent on this process, and the only measure of satisfactory plans will be that of public safety.
i B. Establishment of the Nuclear Safety Emeroency Prepardeness procram l
l In his Fiscal Year 1988 budget, Governor Dukakis i
proposed development of a state program to be responsible for i
oli picnning, training, cnd exorcicoo in cupport of cocrgency prepardness for an accident at cny of tho throo nuciocr power plants licensed to operate within or adjacent to Massachusetts.
The Fiscal Year 1988 budget enacted by the legislature and signed by the Governor creates such a program within the Massachusetts Civil Defense Agency and Office of Emergency Preparedness, allocating 8175,000 for its first year of operations.
All funda expended for this purpose will be reimbursed to the Commonwealth through an assessment of nuclear utilities by the state Department of Public Utilities.
The FY '88 budget authorized eleven positions for the new division.
However, insufficient funds were appropriated to fill all of these Jobs.
The first five of these positions havo been filled.
The Governor has submitted to the legislature a request for an additional 8700,000 (HB 6086, see appendix one) so that all remaining positions created for the new program can be filled as early as January, 1988.
Establishment of this new is an important step towards assuring that the best program possible plans can be developed, tested, and if found to be a d e q u e t'e, maintained for response to an accident at a nuclear power plant and for allocating the planning costs to those reponsible for the hazard.
C.
Expansion of the Emeroency Plannino Zone Federal regulatory guidance contained in NUREG-0654 suggests that the plume exposure emergency planning' zone be ten miles, more or less, with ad3ustments made for political boundaries and other geographic considerations.
The limits ofs the EPZ as of December, 1986, had actually been established in 1979, and included all of the towns of Duxbury, Kingston, and Plymouth, and only those portions of Marshfield and Carver lying within ten approximate miles of Pilgrim Station.
After consultation with officials of Marshfield and Carver, these towns in their entirety have been designated as part of the EP2, see appendix two.
This was done to be sure that in the event of an accident at Pilgrim Station, state officials can make and implement protective action recommendations on a consistent "whole town" basis, thus reducing potential confusion regarding those actions.
This is the same protective action policy which is used for the Yankee Rowe and Vermont Yankee Massachusetts EPZs.
Small portaons of Bourne, Plympton, and Wareham lie within ten miles of Pilgrim, and officials of each of these communities have indicated their interest in being designated part of the EPZ.
Representatives of MCDA/OEP have met with each town to assure them of our support for expanded planning, and have, discussed with them the responsibilities implied by this designation.
State officials must still complete consultation with FEMA and the NRC regarding this expansion of the EPZ before final designation is made.7 7he House Ways and Means Committee recently gave approval to section one of H.B.
7 5383 which would, among other things, establish a 50 mile EPZ in Massachusetts.
We support this initiative but would require additional resources to implement it.
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It ic cur fooling thot full attention cuct bo focuced on assuring that adequate plans are developed for all areas within ten miles of Pilgrim Station before undertaking new planning for areaa in the expanded EP2.
Therefore, the designation of Carver and Marshfield in their entirety, and the potential designation of all or portions of Bourne, Plympton, and Wareham, should be considered the beginning of the process and not the end.
State officiala must still consult with federal and local authorities to determine what level of planning is appropriate and will be required for all areas added to the plume exposure EP2.
It also should be noted that we remain fully committed to the goal of expanded planning that we discussed in our December, 1986 report.
Thus we support House Bill 5383 which would in part define an expanded planning zone to fifty miles.
It should be noted that the resources associated with HB 5383
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are significant and will not be addressed by passage of our l
supplementary appropriation request.
l D.
Off-Site Monitorino The state Department of Public Health is continuing with its program for off-site monitoring of radiation in the vicinity of Pilgrim Station.
In addition, the Department of Public Health has agreed to implement a system of obtaining weekly. reports of radiation levels within the boundarica of Pilgrim Station to better determine if there are low level radioactive releases from the power facility.
The state of Illinois has installed a complex system to continuously monitor the engineering parameters and radioactive releases of nuclear power plants.
The Department of Public Health has prepared a report about this system and estimataa that it would cost approximately 91 million to install in the Commonwealth in Pilgrim Station, see appendix three.
E.
Revisions to the State and Area II Plana In addition to the seven local radiological emergency response plans, the response plans for the State and for MCDA/OEP Area II were also found by our report to be deficient.
The staff of MCDA/OEP in cooperation with representatives of other state agencies and the nuclear operators is working to upgrade these documents.
However, because the State and Area II plans addreas the coordination and support of of activities among the EP2 and host communities, these revisions cannot be completed before revisions to local plans are finished.
A task force under the authority of the state Director of Civil Defense meets regularly to review work in progress.
Under H.B.
J 6086, recently approved by the House Ways and Means Committee,
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funds would be made available to the Department of Public l.
Hoelth to further otudy the fossibility of an off-cito monitoring system.
The State Radiological Emergency Response Plan must discuss actions to be taken in responsa to accidents at Yankee Rowe and Vermont Yankee Nuclear Power Stations in addition to Pilgrim Station.
Work on these revisions is being coordinated with the Yankee Atomic Electr.ic Company as well as with the Boston Edison Company. Representatives of the utilities meet regularly with the task force of state personnel to review work in progress.
F. Dieussions with the Governor's Advisory Council on Radiation Protection In response to issues raised in my report on safety at Pilgrim Station, we have discussed with the Governor's Advisory Council on Radiation Protection development of a state multi-hazard materials incident response team and enhancing the state's ability to monitor the safe operation of nuclear power plants.
The Incident Responso Team (IRT) would be composed of professionals from state agencies, private corporations, and academic institutions who have particular expertise which the state can use in evaluating response to an accident at Pilgrim, Rowe, or Vernon Stations, or the accidental release of another hazardous material.
Members of the IRT would report to the state emergency operstions center to advise the state Director of Civil Defense, the Commissioner of the Department of public Health, and other people in positions of authority on the possible consequences of the accident and the appropriate mitigating measures.
In regardo to an IRT for nuclear matters, members of the Governor's Advisory Council can form the core group for auch a team.
The state does not at present employ nuclear engineers or other personnel who can represent the state in nuclear facility site inspections And safety meetings.
The discussiona at these inspections and reasions involve highly technical matters which could possioly affect public safety.
The Sovernor's Advisory Council has been asked to advise the state regarding NRC alte safety inspections and discussions through use of appropriate state personnel or through expert consultant services.
Arrangements for state participation in NRC aafety activities are also discussed in asetion II.H., following.
G.
State Participation in NRC Gefety Inspections and Meetinos Vermont, New Jersey, and other states around the nation have entered inte formal agreements with the Nuclear Regulatory Commission whereby they are permitted to attend and, to a limited degree, participate in safety inspections and meetings
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for nuclear power plants, see appendix four.
The Commonwealth is considering making such arrangements.
Under an appropriate representative of the state would be permitted to agreement, a attend the on-site inspections and subsequent discussions and have the right to file dissenting or concurring findings.
Designated state representatives would be trained and certified by the different utilities for unescorted access to each nuclear power station.
Since these inspections and meetings involve detailed discussions of the most technical aspects of nucioar power generation, the individuals who represent the state would have to be qualified nuclear engineers.
The state does not presently employ anyone with the skills and experience necessary to perticipate in these matters in a meaningful way.
reviewing agreements between other states and We are the NRC and are engaged in discussions with the NRC.
We expect to conclude an appropriate arrangement for participation in on-site safety matters.
III.
BOSTON EDISON RESPONSE TO RECOMMENDATIONS OF THE BARRY.
REPORT Our report made several recommendations for action by the Boston Edison Company which directly relate to off-site emergency response.
These recommendations concerned improved equipment for off-site emergency notification, production of a new evacuation time estimate (ETE), certificatjon of the siren alert and notification system, addressing the ability to protect beach area populations, addressing shelter as a protective action, production and distribution of improved public information material, improving procedures for protection of special needs and school aged populations, and submission to the state and NRC of a probabilistic risk assessment which considers accident scenarios initiated by both internal and external events and which specifically based on Pilgrim's design features to assess the containment conditional failure probability.
In response to the documented need for an improved system to promptly notify off-site authorities of an accident j
at Pilgrim Station, Boston Edison purchased and has installed a l
radio system called BECONS through which state and local authorities can be given immediate notification of events at the power facility.
This system is now in the final stages of testing and of receiving licenses for operating frequencies.
l The Federal Communications Commission is in the process of final review of the frequency license, and approval is expected before the end of December.
Material has been developed by the utility to train state and local officials in the uue of BECONS.
BECONS units have been installed in all town warning points, at MCDA/OEP Area II Headquarters, Bridgewater, and at i
Massachusetts State Police Troop D, Middleboro.
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Boston Edison commissioned the New York firm of MLD Associates to undertake a new Evacuation Time Estimate and area.
The draft traffic management plan for the Pilgrim document was delivered to state officials on August 20, 1987 i
end revised pages based on preliminary comments were delivered to MCDA/0EP on September 8.
Staff of MCDA/OEP is coordinating review of the ETE by a task Jorce of other state' agencies and by officials of all concerned local Jurisdictions.
While this review is not complete, serious questions regarding the ETE methodology and resulta have surfaced.
Tnese issues are covered in greater detail in section VI.A. of this report.
Throughout its history of operation, the public alert airen system which was installed throughout the EPZ by Boston Edison has been plagued by airen failures and the spontaneous sounding of alarms, especially during thunder storms.
Bonton Edison has replaced malfunctioning units and done other repair i
and maintenance to the airen system.
FEMA has reviewed all proposed improvements to this airen system and has monitored the results of monthly ayaten testa.
The monthly siren system tests which have been conducted by Boston Edison since 1986 indicate that system reliability exceeds FEMA standards.8 FEMA conducted a full test of the siren system in the Autumn of 1986 which included a telephone survey to determine the percentage of the population which heard the alarms.
FEMA has reported that better than 85x of the population heard the sirena.
A three-minute-cycle siren test was held for Pilgrim on October 15, 1987, and we have gathered information about the results.
Protection of beach populations during the Summer months is a principal public safety concern raised in our Report.
Boston Edison has proposed to the Nuclear Regulatory Commission in a letter dated June 4, 1987, that the results of the new ETE combined with the results of survey of shelter available at beach areas demonstrates that this vulnerable population can be protected.
Staff of MCDA/OEP have reviewed the shelter survey and find it deficient in several aspects, see appendix five.
Also, our review of the new ETE, while incomplete, leaves several questions not answered to our satisfaction.
Therefore, we cannot agree that Boston Edison Company has resolved the isnue of protection for beach populations.
8 CDA/0EP receives and reviews monthly airen system test reports which MBoston Edison submits to FEMA. These are not sound tests, but tests of the ayaten's electrical circuits..
Our December, 1986 report requested that Boston Edison "commission a comprehensive shelter survey."
The survey which was delivered to and reviewed by the staff of MCDA/OEP was made only for an area between one half and one mile of the coast.
Since the survey did not cover the remainder of the EPZ, and for other reasons discussed in section VI.B. of this report, this recommendation has not been fulfilled.
l The Boston Edison Company produces an annual public information brochure in cooperation with MCDA/OEP for distribution throughout the EPZ.
MCDA/OEP staff were working with Boston Ediscn and the utility's consultants with a goal of issuing a new EPI brochure by September, 1987.
- However, because certain critical planning decisions had not been made
-- principally whether or not a third reception conter is required to replace Hanover Mall preparation of the brochure has not been completed.
Boston Edison informed MCDA/OEP in August that it was conducting a study to determine the adequacy of two reception centers instead of three, and that the results would be available in early September.
We indicated that we would evaluate such a report within fourteen days.
To date, we have not received the Boston Edison analysis although we have requested it on several occasions.
Therefore, we are unable to complete preparation and distribution of an EPI brochure.
In interim Public Information Brochure will be the alternative, an distributed throughout the EPZ.
This interim brochure will explain the aspects of emergency response which are not fully addressed at present and which will be completely resolved bfore a final EPI brochure is distributed in 1988.
Our position is clear that in no case should Pilgrim be permitted to restert until a final and complete EPI brochure has been approved by MCDA/OEP and distributed.
IV.
FEMA INTERIM FINDINGS J
On September 29, 1982, FEMA and the Regional Advisory Committee (RAC) issued its interim findings on the adequacy of Pilgin EPZ and host community plans.
The 1982 review indicated 5
that the plans were adequate to protect the public.
On August 6, 1987, the Fedral Emergency Management Agency transmitted to us the results of their Self-Initiated review of Pilgrim area emergency plans, finding that, "[b3ecause of the changed circumstances discussed in the FEMA review, our finding of adequacy contained in the Interim Finding of September 29, 1982 no longer applies and has been superseded by the enclosed finding."
This information was also transmitted to the NRC.
The FEMA Self-Initiated Review found the emergency j
plans to be deficient in five specific areas; 1) evacuation of schools, 2) reception center, 3) beach population, 4) special l
needs populations, and 5) transportation dependent populations. i
Each of these items was identified in our December,.1986 report as a deficiency.
The steps being taken by the Commonwealth and by Boston Edison to address these deficiencies are discussed throughout this report.
At least one finding of the Self-Initiated Review is based upon a minimpression by FEMA.
In evaluating resources available for transport dependent people, FEMA contended that the Commonwealth would not use MBTA buses if they are needed to assist an evacuation in the Pilgrim EPZ.
In fact, the Commonwealth will endeavor to make these buses and all other public resources available to easiat in emergency response if they are needed to supplement resources available in the more immediate vicinity of Pilgrim.
FEMA apparently misconstrued our earlier statement to the effect that we no longer believed that it was appropriate to rely upon ad hoc measures in planning for emergency action to indicate that we would not use available resources.
The NRC has not stated as of this date if the changed FEMA Interim Finding will be used as the basis for preventing the re-start of Pilgrim station.
In a meeting between representatives of Boston Edison and the NRC at tne NRC's offices in Bethesda, Maryland, on September 24, 1987, the NRC indicated only that off-site planning issues must be "addressed" before restart is allowed.
This is not an adequate response on the part of the NRC, and we believe that all off-site safety issues must be resolved prior to restart.
The NRC has asked Boston Edison to present an "Action Plan" for addressing the deficiencies cited in the FEMA report, and Boston Edison submitted the first draft of the Action Plan to the NRC on September 17, 3987.
We reviewed the utility's Action Plan which was forwarded to the NRc and support Boston Edison's stated goal of completing plan *. visions as soon as possible.
We think that it is useful to tastablish goals and objectives to guide planning.
However, as this progress report long way to go.9 demonstrates, the planning process has a 9For example, the NRC has yet to receive from Boston Edison a final copy of the utility's proposed restart plan.
A second revision of a restart plan was submitted to the NRC by Boston Edison on October 26, 1987, and was transmitted to us on November 12.
We are awaiting receipt of the final version of the material and will review it thoroughly as soon as it is available to us.
A third party expert evaluation of this plan is under consideration.
V.
STATUS OF SPECIFIC BOSTON EDISON ACTION ITEMS A. Manaaement Issues Our December, 1986 report to the Governor was highly critical'of Boston Edison's management of Pilgrim Station.
This finding has been echoed in reports by the NRC, especially in their "Systematic Assessment of Licensee Performance" (SALP) reports, which thoroughly review a variety of characteristics indicating management performance.
The latent SALP report for Pilgrim Station was issued by the NRC on April 8, 1987, and I
evaluated utility performance for the period November 1, 1985 through January 31, 1987.
The SALP report analyses 12 performance criteria, assigning a grade of 1, 2,
or 3 for each criterion.
Category 1 is the best grade and indicates that reduced NRC attention may be appropriate.
Category 2 indicates that NRC attention should be maintained at normal levels.
Category 3, the lowest grade, i
indicates that both NRC and licensee attention should be increased.
The April 8,
1987 SALP report indicated that management of Pilgrim Station was not good and had, in fact, deteriorated in certain respects since the previous SALP covering the period October 1,
1984 to October 31, 1985.
In the 1987 report, Boston Edison received two Category 1 grades, five Category 2 grades, and five Category 3 grades.
For three criteria in the 1987 SALP, Boston Edison received lower grades than for the previous reporting period, for two criteria the grade increased, and for three criteria the grade remained unchanged.
The four remaining criteria had not been separately evaluated previously.
These results are cause for concern under any circumstances but particularly in light of the fact that the plant was shut down during most of the inspection period.
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Since December, 1986, Boston Edison has reorganized its Pilgrim management and has hired a number of individuals to fill key positions.
Most notably, Boston Edison has hired a
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new Senior Vice President, Nuclear, Mr. Ralph Bird, who reports j
directly to the company's chief executive officer.
Mr. Bird i
was recruited from outside of the Boston Edison Company.
The new Senior Vice President also serves as the Vice President for Nuclear Operations and personally supervises all activities pertaining to Pilgrim Station.
Under Mr. Bird's direction, other positions relating to the safe operation of the reactor and to emergency planning have recently been filled by professionals recruited from outside Boston Edison, and a few Boston Edison employees have been promoted to fill vacancies.
The following other key management positions have been filled by recruits from outside the company;
Executive Assistant to the Senior Vice President,
- Nuclear, Director of Planning and Restart, Emergency Planning Assistant to the Senior Vice President, Nuclear,
-- Operations Section Manager, Nuclear Security Group Leader, a-Fire Protection Group Leader, and Radiological Section Manager.
In addition, the Director of Outage Management was promoted to Plant Manager in early 1987.
While there are indications that the new management organization and personnel may be taking more effective control of Pilgrim Station, recent events suggest that Pilgrim Station continues to have serious management problems.
The NRC is considering a fine against Boston Edison for failure to implement plant security procedures, and there have been reports of critical plant personnel working excessive over-time.
We also have concern over the way a decision was implemented to disengage one of two emergency generators during period when Pilgrim station lost access to off-site power on a
November 12, 1987.
In addition to these issues, the Senior Vice President of Boston Edison ordered all work on the Pilgrim reactor and systems halted after eight individual work related problems occured over the weekend of November 7 and 8, some of which were similar to problems which have recurred at Pilgrim Station over several years.
Four of these problems resulted in the on-site release of radiation and slight worker contamination.
Two of the problems were related to security.
The security violations are of particular concern because in the 1987 SALP report "Security and Safeguards" had Category 2 to a Category 3.
Officials of deteriorated from a Boston Edison have met with the NRC to explain their remedial actions concerning plant security.
We have seen no official report on the question of over-time worked by personnel detailed to critical safety aspects of Pilgrim Station.
Boston Edison public information officers have indicated that five percent of the Pilgrim work force is authorized to work more than sixty hours per week.
Since there are presently more than four thousand people employed at Pilgrim Station, a significant number may have been working long and perhaps excessive hours.
In view of Boston Edison's long history of management failure at Pilgrim Station, we feel that sustained management of'the nuclear facility at a high level must be demonstrated before the plant should be allowed to restart.
Events of the past several months raise more questions than they answer and make it more imperative that, in addition to other safety requisites,we have objective ovidence of sustained performance at the highest level of quality, including but not limited to l
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1 top grades in the next SALP report, before restart, even though the next SALP report will not reflect evaluation of actual on-line operation of the reactor, l
B.
Reactor Safety Our report to the Governor examined aspects of the safe operation of Pilgrim Station, particularly the capacity of the General Electric Mark I containment structure to prevent the release of radiation in a severe accident.
Since December, 1986, the nuclear industry has continued its inconclusive debate on the integrity of the Mark I containment structure.
We do not expect that this inaue will be settled soon by the NRC.
The NucJear Regulatory Commission is developing a "Draft Generic Letter" on reactor safety and the Mark I containment structure which will identify plant-specific analyses necessary to implement the NRC's "Severe Accident Policy Statement."
However, no letter has been released and there is presently no schedule for its publication and, therefore, no way to assess the adequacy of or estimate the time it will take to implement the NRC's ultimate recommendations.
The NRC has been considering this matter for more than a year and has discussed structural improvements and other operating concepts for Mark I units with the Boiling Water Reactor Owners Group.
Absent specific federal requirements and guidance, Boston Edison is implementing a "Safety Enhancement Program" (SEP) to improve reactor safety for Pilgrim Station and includes both emergency operations procedure improvments and equipment modifications.
The utility has indicated that they have spent approximately $30 million on this program.
One key element of the equipment modifications is installation of a direct torus vent.
Boston Edison has indicated that they are prepared to complete instalation of the torus vent as soon as they are so authorized by the NRC.
According to Boston Edison, the torus vent, if installed, could be used to relieve pressure in the reactor containment during a severe accident.
The venting system would "scrub" containment effluent of solid and liquid matter and release radioactive gasses to the environment.
The release of i
these gasses, by relieving the containment pressure, would prevent a rupture of the containment structure and the subsequent release of more damaging solid and liquid radioactive materials.
In theory, a gaseous radioactive plume would dissipate quickly and present less threat to public health than a liquid and solid release which could deposit long-lived radioactive elements on inhabited ground and structures.
There are, however, conflicting views on whether a direct torus vent would provide effective containment pressure relief in the event of a rapidly developing accicent.
Therefore, it must be demonstrated that the direct terus vent would significantly increase public safety under certain accident scenarios.
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C. Poliev Issues Recordina the Torus Vent The torus vent introduces a vital policy question.
Under what and whose authority can one plan in advance to make i
use of the vent?
Activating the vent would result in the release of a gaseous radioactive plume.
Thus, if the equipment la installed and a severe accident does occur, who may authorize torus venting and the subsequent radioactive release?
The utility is responsible for the safe operation of the reactor, for controling an accident, and for preventing insofar as possible the unauthorized environmental release of radiation.
The NRC regulates utility execution of these responsibilities.
However, state and local government share exclusive responsibility for the protection of public health and safety for all areas beyond the boundaries of the power station.
Boston Edison has not installed the torus vent, pending direction from the NRC.
It is our understanding of the NRC licensing scheme, that it would be necessary to amend pilgrim's operating license befoe a torus vent could be installed.
Such an amendment would involve "significant hazards considerations" and, as such, would require that a hearing be held prior to the amendments authorization.
If the NRC authorizes installation, the Commonwealth can or it is not clear what role -- if any should piny in that decision.
If the vent is installed, with or without concurrence from state authorities, a question arines chat the state will have to resolve as to what authority is available to state officials to advise for or against venting during a severe reactor accident.
It is presumed that gases can be held in the period of time before venting.
During containment system for a this period, state officials must decide the best protective action for the public, either to shelter or evacuate, based upon accident asessments made by the state Department of public I
Health and the utility.
The length of time that gasses can be held and the expected duration and composition of the release, when compared to the expected evacuation time, the shelter available to the population at risk, and the time it is expected for the effected population to take to shelter, will determine the most appropriate action.
Thus, state officials must at least coordinate implementation of the best protective action with the containment venting.
Before the NRC authorizes Boston Edison l
to install the torus venting system, there should be an
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evaluation of these policy matters and what if any role state agencies and officials can or will take in the event of a severe accident at Pilgrim Station.
This proposal raises such public hearing should be significant safety issues that a required so that the Commonwealth would have an opportunity to express its opinions on the matter.
During the September 24, 1987 meeting between Boston Edison and the NRC, Dr. Murley of the NRC indicated that he still had reservations about authorizing torus vent instalation.
Dr. Murley stated his reservations about authorizing installation of the torus vent in a letter to Boston Edison dated August 21, 1987.
We are not at present aware of any Boston Edison response to the NRC letter.
D. Need for a Pilorim-Soecific Probabalistic Risk Assessment It is important to note that until a plant-specific "Probabalistic Risk Assessment" (PRA) is available for Pilgrim Station, it is impossible to determine the relative level of risk of a severe accident at Pilgrim Station and the dominant sequence of events that would lead to a severe accident.
A PRA, as we discussed in our December, 1986 Report, is a comprehensive analysis of plant mechanical and operations systems conducted to ascertain the sequences of events that could lead to a severe accident.
Given that every nuclear power plant is unique, both in mechanical and operating systems, a plant specific PRA is necessary to determine the specific scenarios that could lead to severe accidents, as well as to isolate the specific vulnerabilities of each plant.
Although the NRC recognized that plant-specific design and equipment characteristics are important fectors in a plant's vulnerability to a severe accident, it. has not required a Pilgrim-specific PRA, but has relied on the analysis of the NUREG-1150 program.
The NUREG-ll50 program performa PRAs for representative reactor and containment types.
In the case of the General Electric Mark I type plant, the NRC rolles upon a PRA for the Peach Bottom plant in Pennsylvania.
The use of representative PRAs is open to criticism and plant-specific PRAs are being developed by some utilities.
Although I am informed that the Pilgrim PRA is under development, Boston Edison has not to date made it available to the state, taking the position that it is not yet final.
In light of the importance of the PRA in determining the riska posed by Pilgrim Station, I recommend that the plant not be allowed to restart until we have been provided with a Pilgrim-specific PRA and have had the opportunity to verify and assess its results.
VI.
STATUS OF SPECIFIC OFF-SITE EMERGENCY PLANNING MATTERS Our report focused attention on several inadequacies of the plans for response to an accident at pilgrim Station.
The most significant action taken to address inadequacies in the plans was.the implementation by the Massachusetts Civil Defense Agency and Office of Emergency preparedness of the three phase process discussed in section II.A.,
above.
This work has been supported by Boston Edison through assistance given to each Ep2 and host community under section 15, chapter 639 of the acts of 1950.
Substantial progress has been made through the three phase process towards completely revising all radiological emergency response plans.
However, the process is far from complete and our position remains that at present the emergency plans for pilgrim are not adequate and we reserve the right to determine if the plans ultimately are adequate to protect the public.
Draft revisions to the local plana exist in part for each of the five Ep2 communities. In some cases, the draft revisions are up to 85% complete as of this writing.
When officials of all communities and staff of MCDA/OEp indicate that initial drafts are complete, the drafts will be submitted to the Fedral Emergency Management Agency for informal technical review.
FEMA's assessment will provide an independent professional assessment of plan adequacy.
- However, the Commonwealth has the responsibility to make our own fina) evaluation of the plans.
Following is an item by item discussion of certain off-site emergency planning issues which were raised in the Barry report or which have surfaced since December, 1986.
A.
Evacuation Time Estimate and Traffic Menacement plan In our Report to the Governor, we recommended that Boston Edison, "proceed with all dispatch to complete the preparation of a new Evacuation Time Estimate study."
Boston Edison commissioned the New York firm of KLD Associates to prepare a new Evacuation Time Estimate (ETE) and Traffic Management plan for the pilgrim area.
An Evacuation Time Estimate (ETE) is essential as a planning tool and as a critical resource in evaluating protective actions should there be an actual emergency at a nuclear power plant. The ETE available when we made our evaluation in December, 1986 was produced in 1979, based upon 1
1970 census data, and was inadequate.
On August 8,
- 1987, i
Boston Edison transmitted to us a new ETE and traffic management plan, and revised pages were received on September 8.
Although we have not yet completed review of the new ETE and have many reservations about it as discussed below, it is a significant improvement over previous material.
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a task force of Since the revised pages were received, state employees has met regularly to review the ETE and traffic management plan.
The charge to this task force has been to evaluate whether the traffic management plan upon which the estimates of evacuation times are based are reasonable and feasible, and to determine what resources are needed for its succesfu'l implementation, If the traffic managevent recommendations cannot be implemented succesfully, the estimated evacuation "clear times" are without meaning.
The group will not finish its review before the end of November, but certain findings are emerging.
The Commonwealth does not have adequate resources to implement the traffic management plan.
Therefore, the clear times in the ETE cannot be achieved.
For instance, the Massachusetta State Police, Troop D, Middleboro will be responsible for establishing as well control of traffic seeking to enter the emergency zone, as for directing traffic on state roads within the evacuation Officers of Troop D have indicated that they would not area.
normally have sufficient personnel available to implement all of their actions in a timely manner.
Troop D la continuing to evaluate available personnel against personnel needs as documented in the ETE.
In addition, Troop D may not have adequate radio frequencies and hardware to manage emergency communications.
Tnia is especially true because of the expected high volume of a nuclear accident and the need emergency communications during to coordinate the actions of state and various local police departments.
The Commonwealth has only one State Police mobile command post which is normaly stationed at Troop A, Framingham, although at any time it may be in use anywhere in the state.
It may be necessary to have a mobile command post evailable immediately to effectively manage traffic access points in areas as remote as the intersection of Routes 128 and 3 in Braintree and the Cape Cod bridges.
All of these findings are reflected in a memorandum from Troop D, Middleboro, see appendix six.
The traffic management plan goes to great detail in evaluating the traffic control devices which will be required to implement an orderly and prompt evacuation.
These devices include traffic cones, traffic barricades, warning lights, and special evacuation route signs.
The Stats Department of Public Works is evaluating the resources it has available against the requiremanta documented in the ETE.
The DPW can draw upon its resources state-wide, however, it la not yet clear how long it would take to deliver all required material to the EP2.
The recommended resource requirements in the ETE include 364 cones, 389 barricades, and 203 warning lights.
State and local police agencies and departments of public works have been asked to evaluate these recommendations based upon
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their own experience.
However, it is necessary to assure
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delivery times for these resources before one can be assured of adaquete plan implementation.
The State DPW only has emergency mobilization procedures for snow removal and certain highly localized events.
These procedures may or may not in fact be adequate to meet needs during a mass evacuation, and MDPW is reviewing them to determine if new protocola are needed and if materia 1' delivery times can be verified.
An examination of the detcils for traffic control points indicates that very few are recommended to be staffed by more than one traffic guide.
However, for many of these i
pointa, the guide must fulfill several functions, including directing traffic in the recommended pattern, answering questions for vehicle occupanta, checking his or her personal dosimetry, clearing vehicles to travel against the recommended pattern if the driver can demonstrate that he or she is an j
emergency worker, has a need to return to pick up family, or has another reasonable purpose.
It la doubtful that one guide can accomplish all of these functions and, therefore, quite especially for possible that the personnel requirementa of the traffic panagement plan are local police officers underestimated.
The largest burden of controling an evacuation falla to local police departments.
MCDA/OEP has provided all local chiefs of police 10 with a copy of the ETE and asked for their commenta and observations.
As of this date, we have not received comments from any local Jurisdiction.
Besides effective and timely implementation of the traffic management plan, the other most critical element of the ETE is the estimation of traffic demand.
That is, the number of vehicles which would be on the road at any one time an evacuation is declared must be estimated, as well as the time that it takes for drivers to mobilize and start their evacuation trip.
Further, the need for supplementary transportation resources, including ambulances, buses, and chair vana must be established and their moeilization, arrival, pick-up, and total travel times must be eatinated.
The new ETE goes into exhausting detail to document traffic demand estimation.
However, certain assumptions and findings remain open to question.
In particular, the estimated population at the EP2 beaches and ponda is a critical issue not yet addressed to our satisfaction, and the estimated 10In addition to EP2 and host communities, traffic and access control reccomendations must be implemented by the communities of Pembroke, Hanson, Halifax, Plympton, Wareham, Bourne, Sandwich, and Braintree..
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l transportation requirements for people with special needs must l
be examined further.
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The ETE estimates that peak use of area beaches and ponda is 8,211 persons using 2,998 vehicles.
The evacuation times for the beaches are based upon surveys of the parking capacities at individual beach and pond areas.
It does not appear that these figures include people who are at beaches and ponds but do not have access to personal transport, such as children who were dropped off by parents or people who have walked, bicycled, or otherwise gotten to a beach but who would be picked up by a vehicle in the event of an evacuation.
The ETE must treat in greater detail the issue of people who will drive to the beaches and ponds to pick up family and friends after an evacuation has been declared.
In other words, the total beach and pond population must be estimated and an accounting must be made of the departure of the entire beach and pond population.
The ETE's recommendations regarding transportation for special needs populations is based upon a survey undertaken by Boston Edison in the Summer of 1987.
Representatives of the state Office of Handicapped Affairs and the plymouth Commission on Handicapped Affairs have indicated that the Boston Edison survey was poorly conceived and does not make an acurate estimate of the Ep2's special needs populations.11 Nonetheless, the Boston Edison survey has provided more information on special needs requirements than has been available previously.
However, it la clear that further work has to be done in this area before we will have an adequate estimate of the transportation requirements of people with special needs.
This additional work can perhapa be done through a further survey, through a statistical analysis of the general population, or some combination of these methods.
With a cetter knowledge of the requirements for ambulances, chair vana, and buses for people requiring special transportation assistance, we will be able to determine if the ETE has properly estimated the evacuation times for this population.
An estimation of available resources to easiat people with special needs is being undertaken as a part of phase II of the three phase planning process.
Until that evaluation is complete, we cannot say if adequate resources are available.
llThe Boston Edison survey may not have reached all residents of the EPZ and was not worded in a way to elicit a response from all people who might need assistance in evacuating or taking shelter..
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e One broad consideration which is not examined by this ETE and Traffic Management Plan is the effect that will be felt from the failure of any one component.
That is, the clear times appear to be based on the assumption that all all traffic management recommendations will be succesfully implemented in a I
timely manner.
However, there is no basis for this assumption a "priority 1"
and the failure to properly man and control a profound effect on traffic traffic control point can have patterns.
Further, a ma]or unanticipated event, such as an over-turned truck on a major route, even if cleared rapidly, might quickly cause wide-spread traffic problems.
The ETE should investigate and recommend alternative evacuation strategies in the event that any one of the me]or evacuation routes, such as Route 3, were blocked.
Also, it does not appear that the ETE has given consideration to the possibility of a severe Winter storm of the magnitude which can occur in Southeastern Massachusetts.
We are particularly concerned about the matter of Winter storms because of the possibility of converging events.
In the very recent past, a severe storm resulted in Pilgrim's loss of access to off-site power.
Subsequently, Pilgrim lost one of two emergency generators.
If the reactor had been on line at the time, this sequence of events could have resulted in an accident requiring off-site response at the same time that there were more the ten inches of snow on the ground.
Given these possibilities, we feel that the ETE should more extensively document expected evacuation times during severe storms.
The ETE is computed from highly complex traffic models which are beyond the understanding of all but the mest knowledgeable professional specialists.
Professienals employed by the State Department of Transportation's Central Transportation Planning Staff have done a reviev of "I-DYNEV,"
the model developed and used by the firm preparing the ETE.
CTpS is continuing to review the model and its results based upon information supplied by consultants who examined I-DYNEV for the Seabrook adjudicatory process.
A letter from CTPS staff shows that they do have certain reservations about the Pilgrim ETE modeling, see appendix seven.
At the present time we are not prepared to determine if the new ETE is an adequate basis for the development of plans for response to an accident at Pilgrim Station.
Further study by state officials is necessary and I intend to have the ETE and the model upon which it is based evaluated by an independent third party expert in evacuation modeling.
,B. Shelter as a Protective Action Our report recommended that Boston Edison "commission a comprehensive shelter survey.
In the event of an accident at Pilgrim Station, there are two main actions which can be recommended to protect the public; evacuation and shelter.
In order to* assure that the public can be adequately protected, it is necessary to establish two findings in regards to shelter; that, a) the highly vulnerable beach population can take adequate protective cover in the event of a rapidly escalating accident with an early release of radiation, and b) that each EP2 community can provide adequate protective shelter for the resident and transient population seeking assistance.
On August 20, 1987, Boston Edison delivered to MCDA/OEP a shelter survey which was reviewed by agency staff and found to be deficient in several respects.
For example, the survey was completed only for areas lying between one half and one mile from the coast.
The survey also failed to adequately evaluate the quality of shelter available in individual structures but was, rather, an undifferentiated catalogue of structures proximate to beach areas.
In a memorandum, see appendix five, transmitted to Boston Edison by State Director of Civil Defense, MCDA/OEP staff make several recommendations on developing adequate information so that Civil Defense personnel in each EPZ community can develop "Shelter Utilization Plana." Until shelter utilization plans have been developed, it la impossible to say that shelter as a protective action has been addressed.
Shelter utilization plans are especially important for beach areas.
They must consider not Just the available shelter space, but the time it will take people in remote beach areas to reach adequate shelter.
Duxbury beach is approximately seven miles long and portions of Plymouth beach is as much as j
two miles from the nearest structure.
Until Boston Edison produces an a shelter survey which is adequate in the opinion of the MCDA/OEP staff, and until each community has had the opportunity to develop a shelter utilization plan, this laaue remains an open and deficient planning topic.
C.
Protective Actions for Peoole with Special Needa Among the planning issues discussed in my earlier report, none demand more attention than provisions for people with special needs.
This population may include tha elderly and the infirn, people who are mobility impaired, visually impaired, have a hearing loss or are profoundly deaf, and people with a number of other conditions which might be cause for a special service in the event of an accident at Pilgrim Station.
People with special needs may require attention in._
three main areas of radiological emergency response; alert and notification, evacuation, and reception and long term ehelter.
In response to this topic, MCDA/OEP organized an informal task force of representatives of several state agencies which represant special needs constituencies and representatives of local special needs agencies.
The task force has met several times to discuss the complex details of providing the required services and is presenty formulating recommendations for action by the state and utility to insure that all needs are met.
As one of the first actions under the new Nuclear Safety Emergency Preparedness Program, MCDA/OEP has formed a formal task force to address emergency planning for special needs populations.
The Task Force on Special Needs is formulating guidelines and recommendations for state agencies and the Boston Edison Company for undertaking a statistical analysis of expected special needs in the Pilgrim EPZ and the resources which will be needed to fulfill those needs.
The task force is also examining the need for a further survey of individuals with special needs.
Based upon the estimated demand and resources needed for providing emergency notification to, and transportation and care for people with special needs, plans and procedures will be developed for each EPZ and host community plan and for the State and Area Radiological Emergency Response Plans.
In regard to alert and notification, people who are profoundly deaf will be unable to hear sirens or route alert loud hailers which will notify the public of a severe accident.
Further, they will have difficulty communicating with emergency facilities and public safety personnel.
The task force met with representatives of Boston Edison and urged that the utility install teletype equipment in each town warning point so that there could be immediate and effective communications
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with the deaf population throughout the EPZ.
The utility has agreed to make teletype equipment available to all homes and facilities where there is a need.
Staff of the state Commission for the Deaf and Hard of Hearing have agreed to advise Boston Edison on the installation of teletype equipment and training for its operation.
Boston Edison is proceeding with these recommendations, but it is not yet known when all equipment will be installed in town warning points, when training will be provided to all shifts of local town warning officers, or how many teletype units have been distributed throughout the EPZ.
Following my December, 1986 report, MCDA/OEP took the initiative of forming a group of state agencies concerned with services for special needs populations who met with Boston Edison officials on several occaisions to discuss a cooperative effort to better identify EPZ residents with special needs in the event of a nuclear accident. Notwithstanding our. active --
involvement in this effort, in June of 1987, Boston Edison undertook a survey of special needs people without the knowledge, advice, or participation of any state agency or personnel.
Representatives of the state Office of Handicapped Affairs and the plymouth Commission for Handicapped Affairs have indicated that the Boston Edison survey was poorly conducted.
The results of the survey, representing the response of about 1,400 individuals, have been provided to the State Director of Civil Defense and are subsequently being turned over to designated public safety representatives in each of the five Ep2 communities.
This information would also be useful in and available for response to other life threatening situations such as a chemical spill.
It is the policy of state public safety officials that every individual in the EpZ be given the opportunity to identify him or herself and his or her need.
However, it may not be necessary or even prudent to compile oxhaustive lists of special needa populations.
What is most important is to have en understanding of the dimensions of the special needs population and to be prepared to provide the variety of l
services -- alert and notification, transportation, special to the numbers of people expected to medical care, et cetera need assistance.
D.
Medical Services for Radiolooical Vict. ins While not specifically addressed in our December, 1986 report, a recent Guidance Memorandum from the Federal Emergency Management Agency 12 has focussed attention on the topic of medical services for people who are contaminated by radiation and physically injured, for people who have ingested radioactive material, and individuals who are severely irradiated.
The issue is receiving more serious public attention as a result of the formidable medical response which the Soviet Union mounted after the Chernobyl accident.
It is incumbent on state officials to demonstrate that adequate medical facilities are available to meet the demand after a severe accident at any of the nuclear power facilities in New England, even though federal regulatory guidance does not set minimum requirements for treatment capacity.
Boston Edison is also working to identify appropriate medical facilities for off-site contaminated injured people in accordance with FEMA Guidance Memorandum MS-1.
12 FEMA GM MS-1, "Medical Services." Washington, D.C.,
November 13, 1986..
The Massachusetts Department of Public Health's Radiation Control Program is responsible for maintaining the handbook of the stste Nuclear Incident Advisory Team (NIAT).
The NIAT handbook contains a list of all hospitals throughout the state which are prepared to treat victims of severe irradiation or who are contaminated and injured.
The list includes'the treatment capacity of each facility.
DPH is also responsible for certifying hospitals for treatment of radiation victims.
E.
Emeroency Communications As indicated in section III, above, Boston Edison has responded to the recommendation of the our December, 1986 report that they install a new radio system for notification of off-site authorities in the event of an accident at Pilgrim Station.
This system, called BECON, is, as of this writing, in the final stages of testing and is awaiting a radio frequency license 'from the Federal Communications Commission.
Action on that license is expected before the end of December, 1987.
Boston Edison has also begun compliance with another recommendation regarding emergency communications, by reviewing how the organizations providing buses which serve schools in the Pilgrim EPZ contact drivers when buses are needed for early dismissal.
Boston Edison has determined that tone alert radios are not needed in school buses, as discussed in my December, 1986 report.
Boston Edison is, however, considering whether or not they will provide paging devices to school bus drivers.
The utility has purchased tone alert radios and will make them available to special facilities such as nursing homes and schools throughout the EP2 and to homes and businesses which may have difficulty hearing public alert sirens.
As indicated in section VI.C.,
Boston Edison has indicated that they will comply with the recommendation of MCDA/OEp and the state special needs task force, that teletype equipment be installed in each town warning point and is offered to all EPZ residents with a severe hearing loss, to assure that provisions have been made for emergency communications with the profoundly deaf.
F. Procedures for Protection of School Acad Children As noted in our report to the Governor, procedures for the emergency response of schools were week or non-existant in earlier versions of the Pilgrim plans.
This is a matter of the gravest concern, and the development of new and enhanced procedures for the protection of school-aged children has been a priority issue in phase II planning.
It is our intention to see that each school has its own definitive plan on alert and notification, shelter, and evacuation.
Since planning for response by schools is a peculiarly local matter, development --
of these plans has been a responsibility of local school and public safety officials, working with their town planning committee and school officials.
However, staff of MCDA/OEp will provide assistaneva throughout the process and review the ple.ns for adequacy and effectiveness.
Planning for protection of school children la based upon identifying an adequate number of buses and drivers to assure evacuation with single bus trips.
In the event of an evacuation children would be taken to a designated reception center and remain in the care of school personnel until the child is reunited with his or her family.
parents of school children will be notified annually of the school's designated reception center and, in the event of an actual evacuation, the Emergency Broadcast System would make frequent official announcements on the precise destination of the children of each school in the EpZ.
Regular and coordinated training programa are essential if these plans are to be effective.
Contrary to what some teachers have maintained, it is our belief and a present operating assumption of th's planning process that teachers will respond in a professional manner, remaining with and not abandoning the children who have been given to their care.
phase III of the MCDA/OEp planning process will include training for teachers, bus drivers, and other school personnel on their roles and responsibilities in emergency response.
G.
Procedures for Special Facilities The development of adequate special facilites procedures has been a major goal of phase II of the three phase process implemented by MCDA/OEP in cooperation with local officisla and supported by Boston Edison.
Boston Edison has done an inventory of special facilities in each of the five Ep2 communities.
This information, along with draft emergency response procedures for individual special facilities, will be supplied to local public safety officials for their review as part of the utility support offered under section 15, chapter 639 of the acts of 1950.
The phase II work of discussing plans and procedures with the operators and responsible officials of special facilities is only Just begining.
In the town of plymouth, alone, nearly fifty special facilities have been identified.
Each local civil defense director working with the town'a planning committee will be reviewing evacuation and early closing plans and procedures with the superintendants of their schools.
Hospitala are required to have and to test evacuation plans and procedures as a state licensing requirement.
phase III of the MCDA/OEp planning process will include training for the personnel of special facilities on their roles and responsibilities in emergency response and a revieg,of -
these plana will be a part of the planning process..
H.
Provision of Emeroency Public Information Our December, 1986 report recommended that Boston Edison improve delivery of Emergency Public Information (EPI),
and, "report on additional methods that could be utilized to convey EPI to the public..., and study the extent to which EPI information reaches the residents of the EPZ and is understood by those people."
To date, no report has been received from Boston Edison by officials of the Commonwealth on this matter.
Federal regulations require that an EPI brochure be distributed annually to all residents of a nuclear power station EPZ.
In the past, Boston Edison has made this distribution in August or September of each year.
Because several critical planning issues remained unresolved, Boston Edison informa us that they will delay their annual distribution until December.
Boston Edison has taken one step to broaden the reach of their EPI by purchasing space in all EPZ telephone directories.
These directory pages give basic emergency information and suggest that readers contact a Boston Edison telephone number for additional information.
MCDA/OEP arranged for a meeting between members of the state speial needs task force and Boston Edison's EPI consultant contractors in June, 1987.
At that meeting several recommendations were made for improving access to EPI for the entire EPZ population.
Members of the task force will review the EPI brochure to see to what extent their recommendations have been incorporated into the next final edition and to make recommendations for improving future brochures.
It must be emphasized that an interim Public Information Brochure will be distributed throughout the emergency planning zone, as discussed in the end of section III of this report.
One of the most critical issues which must be fully addressed prior to distribution of a final EPI brochure is procedures for assisting special needs populations.
I.
Resources for Emeroency Response In my December, 1986 report, it was noted that plans for response to an accident at Pilgrim Station lacked evidence of the ability to provide sufficient emergency resources on a timely basis.
In particular, it la necessary to demonstrate that an adequate number of buses, ambulances, and chair vans will be available for all transport dependent persons', and that these vehicles will be available in a timely manner to support a safe evacuation.
l Boston Edison is conducting a survey of all private transportation companies in southeastern Massachusetts to determine what vicarious transport resources are available i
nearby.
Individual agreements must be negotiated with all j
operators of buses, ambulances, and chairvans to make available their equipment and drivers to the EPZ communities in support 1
of response to a nuclear accident.
This process must also identify an adequate pool of drivers to assure rapid and full mobilization of all necessary vehicles.
These arrangements need to be concluded as a part of Phase II of the MCDA/OEP three phase process to revise Pilgrim area plans.
All appropriate documentation will be reviewed by staff of MCDA/OEP before it is included in local plans and in the revised MCDA/OEP Area II plan.
No guarantee can be given that all drivers will respond to a nuclear emergency, and written agreements offer no absolute casurance.
However, we feel that adequate training will help reassure drivers of their safety in emergency response.
The state, with the support of Boston Edison, will provide training in personal radiation protection for all drivers who might respond to an accident at Pilgrim.
The curriculum for this training is presently being developed under the direction of the MCDAVOEP training officer, and the training will be offered as a part of Phase III of the agency's three phase process for reviaing the pilgrim plana.
J.
Reception Centers as a reception center for Replacement of Hanover Mall the northern portion of the EP2 remains one of the most difficult pending issues regarding off-site emergency response for an accident at Pilgrim Station.
The Boston Edison Company has been asked to study the physical facilities at Taunton State Hospital and Bridgewater Community College.
The study was expected to be completed in September, 1987, but is not now expected until December according to Boston Edison officials.
This study will determine what physical alterations must be made, what equipment must be provided, and what additional l
plans must be developed so that we can with only two reception facilities meet the needs of the EPZ population for reception, radiological monitoring, and, if necessary, decontamination of people and vehicles, either with or without a third reception i
center.
Once we have received this study from Boston Edison, it will be reviewed by staff of MCDA/OEP to determine if it is acurate and if its recommendations are reasonable and implementable.
Based upon the study and upon other documentation including the Evacuation Time Estimate, we will determine if the two current facilities are adequate -- given and if a third the completion of recommended improvements reception center is necessary.
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There is no federal or state requirement for three reception centers for the Pilgrim EP2.
Federal guidance states only that reception and radiological monitoring services be provided for up to twenty percent of the total EPZ population and that radiological monitoring must be accomplished within twelve hours.
However, the legitimate concern of EP2 residents that their protection has diminished through loss of the Hanover reception center will be taken into consideration throughout this process.
K.
pilarin Restart Process Since Pilgrim Station remains shut down under a confirmatory action letter by the U.S.
Nuclear Regulatory Commission, The Boston Edison Company must follow a regulatory procedure leading to full operation of the power plant.
Boston Edison has not as yet made a formal request to the N.R.C.
for permission to restart Pilgrim Station.
Boston Edison repeatedly has stated that they will not seek permission from the NRC to restart Pilgrim until approval is first received from the company's board of directors.
Moreover, the NRC Region I staff has indicated that an intensive on-site inspection will be conducted and evaluated before any decision is made to recommend restart.
Ultimately, the restart decision will be made be the NRC Commissioners.
There is disagreement about the opportunity to be given to the state and public to be heard prior to restart.
We want the NRC to hold a full ad3udicatory hearing in the EP2 while the NRC has recommended only that they hold public meetings.
We will continue to insist, as you and the Attorney General have done through the filing of your recent petition, that no consideration be given to restarting Pilgrim Station until a full adjudicatory hearing is conducted.
The NRC has not indicated what consideration will be given to off-site emergency prepardeness in their restart deliberstions.
This is very troubling.
When the rules and guidance regarding emergency planning were first issued in 1980, planning was said to be as critical to safety as engineering to the extent that the NRC declared that emergency planning issues must be fully addressed for all nuclear power stations.
The Pilgrim case will test the extent to which the NRC remains committed to this fundamental tenet.
VII.
CONCLUSION
'Our position remains the same as it was in December of 1986.
Federal authorities should not permit Boston Edison to restart Pilgrim Station unless and until all safety issues have been fully resolved, including sustained improvement of the nuclear management as demonstrated through, among other indicators, the highest grades in an NRC Systematic Asaessment _
of Licensee Performance, implementation and completion of a reactor safety program which satisfies all questions regarding the Mark I containment, and development of adequate off-site radiological emergency response plans.
We also feel that a succesful graded exercise of all off-site plans and facilities must be held, and that the NRC must hold a full adjudicatory hearing 91 thin the Pilgrim EPZ before Pilgrim Station is authorized to restart.
The process which leads to the satisfactory resolution of all of our safety concerns cannot f
succeed without a cooperative effort of state and local j
officials, the Boston Edison Company, and federal regulatory authorities.
Date Charles V.
Barry Secretary of Public Safety
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APPENDIX ONE l
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'2 IIOUSE - No. 6086 1
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[0ctober 1l$987]' 'E IIOUSE - No. 6086 3
i n.
EIJC C0!!!!!TDitlIltaIIIJ Of JHaWWaffjtIWells
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provided further that in no case may funds from this account be used for the development evaluation or imp?cments: ion of radiological emergency response plans In the Year One Thousand Nine llundred and Eighty-Seven..
for Seabrook station; provided further, that the secretary shall file a report with the joint committee on cncrgy on or before December first, nineteen hundred and cighty.
seven. detailing the activities undertaken with regard to AN Acr MAKING AN APPRGPRIATION FOR THE FISCAL YEAR ENDING JUNE this line item; and provided further, that no expenditures TIIIRTIETff, NihETEEN llUNDRED AND EIGIITY-EIGIIT. TO PROVIDE FOR
- I of the e rc f pub ety in I ig than SUPPLEMENTING A CERTAIN EXISTING APPROPRIATION.
-encven positions s700.000.
d.dex n i
Be it enactedby she Senafe and House ofRepresenfatives in General i
SECTION 3. This act shall take effcct upon its passage.
Court assembled, and by the authority of the same, asfollows:
I SECTION 1. To provide for supplementing a certain item in 2 the general appropriation act, the sum set forth in section two 3 subject to the provisions of law regulating the disbursement of 4 public funds and the conditions pertaining to appropriations in
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pe f
- 5. chapter one hundred and ninety-nine of the acts of nineteen 6 hundred and eighty-seven, for the fiscal year ending June thirtieth, 7 nineleen hundred and eighty-eight, the sum so appropriated to 8 be in addition to any amounts available for the purpose.
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I SECTION 2.
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EXECUTIVE OFFICE OF PUBLIC SAFETY.
. r..:
Ctair;s.y x;, a.
. Cin! Defense Agency 8800C100 * #ForNatte're pertaining to nuclear anfety emergency
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preparedness; provided,that she director of the office of civil defense and cmcrgency preparedness may :: ster into agreements with other gate agencies for the purposes of N...s " ' #
undertaking this effort; provide:1 further, that the costs of
%y-f :#tg '
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this effort. including fringe be nefiss and indirect costs. shall be assessed on nucicar regulatcry commission licensecs operating nuc! car power generating facilitics in the commonwealth; provided furth r that the department of public utilitics sha!! develop an cquitable method of i
apportioning said assessments among said licensces; provided further.that said assessments shall be paid during j
g the fiscal year as provided by the department of pubtse a
utilitics and shall be credited to the general funds; provided I
fursher, that funds appropriated herein may be spent for the development ard evaluation of radiological cmergency 7
g response plans for nuctcar generating plants licensed to operate at full power and located within Ibc common-westth; provided further. that in no case may funds from I
'g this acrount be wer.: toimplemens.&ntaricalcencreency
, e....
@c;k THE COMMONWEA1.TH OF MASSACHUSETTS EXECUTIVE DEPARTMENT i
Civ1C OtFtH$( AGENCY ANoOFFICE OF (WEACENCY PREP AREONESS l
C 400 WOAct$itR RoAo P.O. Box lage F RAWINGHAM. M ASS. 01791431F t
ROBERT J. BOULAY MICHAEL S. DUKAKIS DAECTOR GovtRNCR
.i July 24, 1987 Mr. Edward A.
Thomas, Chief Natural and Technological Hazards Division Federal Emergency Management Agency John W. McCormack Post Office and Court House Boston, Massachusetts 02109
Dear Mr. Thomas:
This is to advise you that in accordance with Massachusetts law, St. 1979, c.
796, codified as Massachusetts General Laws c. 33 Appendix, section 13-26, and federal regulations, 10 CFR 50.47 and 44 CFR 350.7, the Commonwealth of Massachusetts has determined that the plume exposure pathway emergency planning.one for the Pilgrim Nuclear Power Station
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should be reconfigured.
The reconfigured EPZ will include the entirety of the towns of Carver and Marshfield, both of which presently have only a portion of their Jurisdiction within the EPZ.
Accordingly, based upon our analysis of local conditions and geographical boundaries, the history of off-site emergency planning at Pilgrim Station, and our consideration of the views of state, local, utility, and federal officials, we request that you acknowledge this determination.
On July 14, 1987, we held a consultation meeting in accordance with 44 CFR 350.7 and 10 CFR 50.47 which was attended by representatives of this agency, the Executive Office of Public Safety, the U.S.
Nuclear Regulatory
' Commission, and the Boston Edison Company.
As discussed at the July 14 meeting, it is also our portion of intention to designate other towns which have a their geographical territory within ten miles of Pilgrim C
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APPENDIX TWO f
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