ML20205D920
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UNITED STATES E'
i NUCLEAR REGULATORY COMMISSION j
WASHINGTON, D. C. 20555
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September 18, 1987 NOTE T0: Dr. Merley F. Miraglia R. Starostecki S. Yarga FRON:
Richard H. Wessman, Pilgrim Project Manager
SUBJECT:
BEco Emergency Preparedness Letters The attr,ched 3 letters dealing with Pilgrim emergency preparedness were received today. They deal with:
-Exemption From Required Biennial Exercise (until Spring 1988)
-Pilgrim Onsite Exercise - Decenter 9,1987
-Action Plan and Schedule for Dealing with FEMA findings ww Richard H. Wessman, Senior Project Manager Project Directorate I-3 Division of Reactor Projects I/II cc:
J. Sniezek F. Congel D. Mathews B. Boger B. Clayton J. Scinto V. Nerses 4
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O eosamsw Eiecutra Of f>ces 800 Bogston Street Boston. Vassachosetts 02199 September 17, 1987 s eo ce Pr ert - Nuclear BECo Ltr. #87-146 U.S. Nuclear Regulatory Comission Document Centrol Desk Hashington, D.C.
20555 Docket 50-293 License No, DPR-35
Subject:
Boston Edison Company Request for Exemption from 10 CFR Part 50, Appendix E, Section IV.F.
Dear Sir:
In accordance with 10 CFR section 50.12(a), Boston Edison Company requests that the Nuclear Regulatory Comission (NRC) grant a one-time exemption from the requirements of 10 CFR Part 50, Appendix E, Section IV.F., that would authorize the rext biennial full participation emergency prepartdrass exercise for the Pilgrim Nuclear Power Station (Pilgrim) to be conducted in the second quarter of 1988.
The schedule for future biennial exercise; will not be affected by this one-time exemption, but rather will continue to provide that such exercises will be conoucted every second year (1 A, the following biennial exercise will be held in 1989).
The proposed deferral of the full participation exercise has been discussed with the Comonwealth of Hassachusetts (Commonwealth) and local emergency re nonte officials. All of the parties have indicated that they support the preposal.
The 3 quest will not affect the onsite exercise at Pilgrim planned for D aember 9, 1987.
The requested exemption is necessary because the Commonwealth, the local governments withia the ten-mile plume exposure pathway emergency planning zone i
(EPZ) and the two emergency reception center comunities are at present engaged in implementing numerous improvements in their offsite emergency preparedntes programs, with the assistance of Boston Edison.
These improvements include resisjon of the emergency plans of the local governments, revision of the Massachusetts Civil Defense Agency (HCDA) Area II plan as well as the Commonwealth's state-wide plan, the desalopment of revised related procedures, the development and implementation of training programs for j
officials and emergency personnel, and the upgrading of Emergency Operation Centers CEOC's). A substantial commitment of resources and time has been made to accomplish these improvements, and the work is expected to continue through the remainder of the year and early 1988.
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O U.S. Nuclear Regulatory Commission Page 2 4
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In view of these extensive ongoing efforts, the Commonwealth and the local i
gosernments have indicated that they are not abl9 to participate in an exercise during calendar year 1987. Moreover, it is apparent that under these circumstances, conduct of the full participation exercise will be much more o
effective after the ongoing improvements have been implemented.
In granting one-time exemptions authorizing deferral of exercises for licensed plants in I
the past, the NRC has recognized that the most effective and beneficial I
exercises are those which include the full-scale participation of State and i
local governments and that it is appropriate to defer an exercise until
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program revisions or facility improvements have been completed.
Since the last full participation biennial exercise at Pilgrim, Boston Edison has held an onsite exercise at Pilgrim in December 1986; has held e
quarterly onsite drills in March, June and August of 1987; and has scheduled its annual onsite exercise for December 9, 1987 (in which the Commonwealth will exercise various offsite 'bjectives as described in BECo Ltr. #87 -147 "Scheduling of Pilgrim Onsite wrcise").
The previous exercise and drills have included limited participc.'on by the Commonwealth, and the March and June 1987 drills included limited participation by several of the towns.
The towns within the EPZ have also cooperated in the full sc:le siren test reviewed by FEMA, which was conducted on September 29, 1986.
In addition to its activities involving Filgrim, the Commonwealth has also participated in full participation exercises at the Yankee Nuclear Power Station in June 1986 and is scheduled to participate in a full participation exercise at the Vermont Yankee Nuclear Generating Station during the week of November 29, 1987.
This request meets a number of the special circumstances listed in Section 50.12(a)(2)
First, granting the request will provide only temporary relief from the l
applicable re F ation and the licensee has made good faith efforts to comply with the regulation. Over the past year, Boston Edison has assisted Commonwealth and local authorities in a variety of ways to accomplish as many improvements as possible in their offsite emergency response programs.
For example, Boston Edison has developed substantive information for the enhancement of those programs. The major produ:ts of this effort include the "Pilgrim Station Evacuation Time Estimates and Traffic Management Plan Update" (August 18, 1987) prepared by KLD Associates, Inc. and "A Study to Identify Potential Shelters in the EPZ Coastline Region of Pilgrim Nuclear Power 4
Station" (August 1987) pts 3ared by Stone & Hebster Engineering Corporation, as well as information generated in surveys to identify the special needs and transportation dependent populations within the EPZ.
In additien, Boston Edison is providing assistance to the local governments in their offsite emergency program enhancement efforts in accordance with the Massachusetts Civil Defense Act of 1950 (Chapter 639, Section 15 Acts of 1950 as amended).
This assistance includes the provision of two professional planners to work under the direction of the officials of each town within the EPZ in upgrading its plan, procedures and training; one i
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U. S. Nuclear Regulatory Commission Page 3 professional planner to assist each reception center c wmunity; and four professional planners working under the direction of HCOA in the upgrading of the HCDA Area II and Commonwealth progrsm.
In the first half of 1987 Boston Edison provided introductory emergency training to about 350 personnel within the five towns in the EPZ and enhanced introductory training modules are currently being prepared for review by the HCDA prior to further implementation.
The planners provided ty Boston Edison have also begun to prepare task-based mouules for training of specific categories of emergency personnel and will b1 availa'le to parti:1pate in the training programs.
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addition, Boston Edison is executing agroements with each of the five towns f
within the EPZ, as well as the two reception center communities, for assistance in the renovation of their E0C's. Moreover, four of the five EPZ towns and both reception center communities, to date, have accepted BECo's offer of funding support for full-time civil defense staff positions.
Second, literal compliance with the regulation would not serve its underlying purpose and would result in undue hardship to Commonwealth and local emergency response agencies by requiring an exercise of portions of the offsite emergency plans that are in the prc. cess of significant revision and improvement. This would necessarily involve disruption of the ongoing process of implementing these changes, and consequently, the imposition of additional costs and delay in accomplishing the planneri improvements.
The NRC's emergency exercise requirements clearly were not intended to disrupt the orderly implementation of improvements in sJch manner.
Finally, because granting the request will allow work to proceed without disruption, it will result in a net benefit to the public health and safety.
The NRC has acknowledged that flexibility H appropriate in applying emergency planning requirements. This flexible approach is especially appropriate in l
this case, where granting the request will facilitate more prompt and effective implementation of improvements.
I For all these reasons, Boston Edison asks that NRC grant the requested exemption.
In accordance with 10 CFR 6170.12(c), a fee of one hundred and 1
fifty dollars ($150.00) will be electronically mailed to your offices.
If you should require any additional information in connection with this request, please contact either myself or Mr. Ron Varley of my staff (telephone: 617 -
424-3832).
4 Ralph G. 81rd RAL/diw
U. S. Nuclear Regulatory Comission P.7ge 4 cc: Dr. Thomas E. Hurley, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission The Phillips Building kishington, D.C.
20555 Mr. R.H. Nessman, Project Manager Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Comission 7920 Norfolk Avenue Bethtsda, MD 20814 Mr. Richard Krim, Assistant Associate Director FEMA 500 C Street - Frderal Plaza Washington, D.C.
20472 l
Mr. Edward Thomas FEMA - Region 1 J. H. McCormack Post Office and Court House l
Boston,itA 02109 Mr. Peter Agnes, Jr.
Comonwealth of MA Assistant Secretary of Public Safety 1 Ashburton Place - Room 2133 Boston, MA 02108 U. S. Nuclear Regulatory Comission Region 1 - 631 Park Avenue King of Pruss u, PA 19406 Senior NRC Resident Inspector Pilgrim Nuclear Power Stattor.
Rocky Hill Road Plymouth, MA 0U60 Henry Vickars, Rtqional Director FEr4A - Region 1 J.H. McCormack Post Office and Court House Boston, MA 02109 L,
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comwsotsou Executu Offices 800 Boylston Street Bc$ ton, Massachusetts 02199 September 17,1987 Ralph G. Bird BECo Ltr. #87-147 sene vw;e Prescent - Nacin, U.S. Nuclear Regulatory Commissien Document Control Desk Hashington, D.C.
20555 Docket No. 50-293 License No. LPR 35 s
Subject:
Scheduling of Pilgrini Onsite Exercise
Dear Sir:
In accordance with Mr. Lazurus' discussions with my staff, this letter is to request that Boston Edison's emergency preparedness exercise be conducted at the Pilgrim Nuclear Power Station (Pilgrim Station) on December 9,1987.
i Boston Edison intends to conduct a complete onsite exercise on this date. The Commonwealth will aiso exercise various offsite objectives to support the onsite activities. The proposed scope and objectives are described in the enclosure. The individual on my staff with whom the NRC should interface on this matter is Mr. Stephen Hook, Boston Edison Company, Emergency Operations facility, Obery Heights, Plymouth, MA 02360.
i Boston Edison realizes that in accordance with the reautrements of 10CFR Part 1
50, Appendix E, S:ction IV.F a biennial full participation emergency preparedness exercise, should be ccnducted during calender year 1987. As you are awara, since the last full participation exercise in 1985, Boston Edison has developed a significant amount of information relevant to the updating and i
upgrading of the emergency programs of the Commonwealth of Massachusetts, towns within the plume exposure pathway emergency planning zone (EPZ) and reception canter comunities.
This information includes the "Pilgrim Station Evacuation Time Estimates and Traffic Management Plan Update" (August 18, l
i 1987) prepared by KLD Associates; "A Study to Identify Potential Shelters in the EPZ Coastline Region of the Pilgrim Nuclear Power Station" (August 1987) prepared by Stone & Hebster Engineering Corporation; and a survey of special 1
needs and transportation dependent populations within the EPZ.
The i
Commonwealth 2nd the local governmenh..with the assistance of Boston Edison, are currently fully engaged in implementing information of this type into i
I numerous improvements of the Commonwealth and local programs.
In view of these extensive ongchet efforts by the Commonwealth and local governments, Boston Edison is filing under separate cover a request under Sectica 50.12 (a) of the NRC regulations for a one-time partial exemption fro,a j
i the requirements of 10CFR Part 50 Appendix E Section IV.F., authorizing the l
full participation joint exercise of offsite emergency response capabilities to be conducted in 1983.
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U.S. Nuclear Regulatory Comission Page 2 If you have any questions or require additional information, please do not hesitate to contact Mr. Hook at (617) 424-3808.
Ev &
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. Bird Enclosure RAL/div cc: Mr. William J. Lazurus Emergency Preparedness Section Division of Safety and Safeguards U.S. Nuclear Regulatory Commisstor.
Region 1 631 Park Avenue King of Prussia, PA 19406 Mr. Walter Thomas Emergency Preparedness Specialist U.S. Nuclear Regulatory Commission Region 1 631 Park Avenue King of Prussia, PA 19406 Mr. R.H. Nessman, Project Manager Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation U.S. Nuclear Comission 7920 Norfolk Avenue Bethesda, MO 20814 Senior NRC Resident Inspector Pilgria Nuclear Power Station Mr. Edward Thomas FEMA-Region 1 J.M. McCormack Post Office and Court House Boston, MA 02109 Henry Vickers, Regional Director FE.MA-Region 1 J.W. McCormack Post Office and Court House Boston, MA 02109
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PROPOSED EXERCISE SCOPE AND OBJECTIVES
i BOSTON EDISON COMPANY PILGRIM NUCLEAR POWER STATION EMERGENCY PREPAREDNESS EXERCISE f
ig gISE SCOPE AND OBJECTIVES j
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hDDR The 1987 Pilgrim Station Emergency Preparedness Exercise, to be i
conducted on December 9, 1987, will provide the opportunity to evaluate the Boston Edison Emergency Plan and Emergency Plan Implementing Pfocedures.
It will also test the emergency response organ;zation's ability to assess and respond to i
emergency conditions and take adequate actions to protect the health and safety of the public. Whenever practical the Exercise incorporates provisions for "free play" on the part of l
l the participants.
l The scenario will simulate a sequence of events resulting in a i
radiological release to the environment of sufficient magnitude to warrant utilization of Commonwealth and local agencies. The Cossenwealth will exercise various offsite objectives.
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The Exercise will also incorpferate the conduct of the Station's I
semi-annual health physics drill, annual medical drill and our
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l annual Post Accident Sampling System drill which includes the j
acquisition and analysis of a sample, t
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2 Onsite Obiectives (Pilgrim Nuclear Power Station)
A.
Radioloaical Emeroency Prenaredness Plans f
Demonstrate the adequacy of the Emergency Plan and Emergency l
i Plan Implementing Procedures both in terms of management's control of an emergency situation and the usefulness of the procedures.
Demonstrate the capability to successfully and effectively i
critique drill activities.
B.
Notification Procedures 3
Demonstrate the ability of Boston Edison emergency response l
personnel to notify offsite agencies within fifteen (15) minutes j
j after declaration of an emergency.
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I Demonstrate the ability to alert, notify and mobilize j
j Pligrim/ Boston Edison emergency responsa personnst.
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Emeraency Conditions Determine the adequacy of comunication links between emergency facilities, teams, and offsite agencies.
Demonstrate the capability for formal comunications on plant internal comunication links.
Demonstrate the ability to comunicate technical information to the Commonwealth.
D.
Public Information Demonstrate the ability to creata and issue press releases prior to Media Center Activation.
Demonstrate the ability to create press releases and provide information to the media via press briefings and media requests.
Demonstrate the ability to effectively respond to technical questions at the Media Center.
Demonstrate the capability to respond to rumors and exercise
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effective rumor control.
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Emergency Resoonse Facili11n
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Demonstrate the capability for prompt activation of emergency response facilities, c
Demonstrate the effective control and staging of onsite emergency teams.
I Demolistrate the functioral adequacy of the emergency response facilities.
Demonstrate the ability to maintain and update status boards in the i
emergency response facilities.
r Demonstrate the capability to staff and maintain a manpower roster for protracted operations, ensuring sufficient personnel are 4
available for a 24-hour assignment schedule, F.
Comand and Control j
Demonstrate the ability of key personnel to make timely and effective decisions with respect to a radiological emergency.
1 Demonstrate the ability to make periodic and comprehensive verbal updates and briefings la the emergency response facilities.
Demonstrate the transferral of emergency comand and control throughout the event.
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Accident Assessment Demonstrate the ability to assess plant conditions, classify events as they occur and identify projected trends and potential consequences.
1 Demonstrate the ability to make accurate assessment of core damage j
through acquisition and analysis of a sample from the post accident i
sampling system.
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Descastrate the ability to effectively assemble, dispatch and control L
Environmental Monitoring Teams.
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t Demonstrate the ability to perform dose assessments and to determine i
ectual or potential offsite radiological hazards.
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Protective Reinonne Demonstrate the ability to maintain adequate access control and i
j personnel accountability in the TSC/OSC.
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Demonstrate the ability to make timely Protective Action Recommendations (PARS) to offsite agencies, j
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Radioloalcal Euncture Control I
I Demonstrate the ability to implement personnel dosimetry for emergency response personnel.
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Demonstrate the ability to dispatch emergency re-entry and repair j
teams in a timely fashion and maintain doses ALARA.
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i Demonstrate the organizational ability to authorize emergency worker exposure in excess of 10CFR20 limits.
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Emeroency Medical Reinonse Demonstrate the ability to provide first-aid for a contaminated 1
j injuredindividual.
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Demonstrate the ability to provide proper radiological and
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i contamination controls in the hanoling of a contaminated injured l
j individual.
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Re-Entrv and Recoverv l
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Demonstrate the ability to activate the Recovery Center to assist the TSC in accident assessment activities, i
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Demonstrate the capability of the Recovery Center to develop recovery l
plans and strategies.
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3 Offsite Obiectives (Commonwealth of Massachusetts)*
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Demonstrate ability to make initial notifications to EPZ towns.
- 10. Demonstrate ability to continuously monitor and control emergency worker exposure.
- 11. Demonstrate ability to brief the media in a clear, accurate and timely manner.
Demonstrate the ability to make the decision, based on predetermined 13.
criteria, whether to supply and administer KI to emergency workers.
Demonstrate ability to mobilize and deploy field monitoring teams in 18.
a timely fashion.
- 19. Demonstrate appropriate equipment and procedures for determining ambient radiation levels.
i Demonstrate appropriate equipment and procedure for measurement of 20.
airborne radiodine concentrations as low as 10-7 uC1/cc in the presence of noble pases.
- 31. Demonstrate adequacy of ambulance facilities and procedures for handling contaminated, injured and exposed individuals.
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- 32. Demonstrate adequacy of lospital facilities and procedures for handling contaminated, injured and exposed individuals.
J The offsite objectives have been extracted from FEMA Guidance Memorandum EX-3, 06/10/86, Rev. 1.
The Commonwealth of Massachusetts i
has reviewed these objectives ano has agreed to provide EOF, Media l
Center and Ft.1d Monitoring Team functions solely to support the l
onsite exercise. We therefore do not anticipate the Commonwealth's submittal of the above objectives to FEMA, nor FEMA's evaluation of 2
the exercise other than the annual medical drill, i
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,osama Executn,e Of f<es 800 Boy'ston Street Boston, Massachusetts 02199 Mph G. Bird senor vice Presioent - Nyctear September 17,1987 BECo Ltr.#87-148 U.S. Nuclear Regulatory Commission Document Control Desk Hashington, D.C.
20555 Docket 50-291 License No. DPR-35 I
SUBJECT:
Boston Edison Company Action I
Plan and Schedule for Providing Assistance in Addressing FEMA Issues
Dear Sir:
As requested by Mr. Varga's letter of August 18, 1987, transmitting a copy of the FEMA report entitled "Self Initiated Review and Interim Finding of the Pilgrim Nuclear Power Station", we are enclosing an action plan and schedule for assisting the Commonwealth of Massachusetts and local governmentt in addressing the FEMA identified emergency planning issues for Pilgrim leuclear Power Station.
The Commonwealth has reviewed and concurs with our assessments as presented in the action plan and schedule.
The enclosed action plan and schedule identifies various "subissues" derived from the FEMA report and sets forth the current status, the planned assistance to be provided by Boston Edison to the Commonwealth and local governments, the target schedules for resolution, and as necessary, an explanatory concent. As explained more fully in the introduction, the action plan and schedule is part of a comprehensive program of assistance by Boston Edison to the Commonwealth and local governments in upgrading the offs W e emergency respvnse programs relating to the Pilgrim Nuclear Power Station.
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U. S. Nuclear Regulatory Comission i
Page 2 Please do not hesitate to contact either myself or Mr. Ron Varley at (617) 747-8544 if any additional information is required.
Ralph G. Bird RGB/dlw Enclesure cc: Mr. Steven A. Varga, Director Division of Reactor Projects - I/II i
Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Comission Nashington, D.C.
20555 Mr. R. H. Messman, Project Manager Division of Reactor Projects - I/I's Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Comission t
7920 Norfolk Avenue 2
Bethesda, MD 20814 j
Mr. Richard Krim, Assistant Associate Director FEMA I
500 C Street - Federal Plaza Mashington, D.C.
20472 Mr. Edward Thomas FEMA - Region 1 i
J. M. McCormack Post Office and Court House Boston, MA 02109 Mr. Peter Agnes, Jr.
Comonwealth of MA Assistant Secretary of Public Safety 3
1 Ashburton Place - Room 2133 L
Boston, MA 02108 U. S. Nuclear Regulatory Commission I
Region 1 - 631 Park Avenue l
King of Prussia, PA 19406 l
Senior NRC Resident Inspector
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Pilgrim Nuclear Power Station Rocky Hill Road Plymouth, MA C2360 Henry Vic.kers, Regional Director FEM - Region 1 j
J.W. McCormack Post Office and Ccurt House i
Boston, M 02109 i
i BOSTON EDISON COMPANY ACTION PLAN AND SCHEDULE FOR PROVIDING ASSISTANCE IN ADDRESSING FEMA ISSUES i
Introduction In a letter dated August 18, 1987 the Nuclear Regulatory Cor.41ssion (NRC) i transmitted to Boston Edison Company (BECo) a copy of the federal Emergency Management Agency (FEMA) report entitled "Self-Initiated Review and Interim Finding for the Pilgrim Nuclear Power Station" (August 4, 1987) (FEMA j
Report).
It requested that BECo provide to the NRC "an actior, plan and schedule for assisting the State and local governments in addressing the FEMA identified emergency planning issues for."I'gria."
i To prep 4re this action plan and schedule, BECo first reviewed the FEMA Report I
I to idr.ntify the precise issues raised by FEMA. This task was simplified by J.
the fact that in Section III of the FEMA Report ("Evaluation of Issues"), FEMA 9
identified six major issues (A through F) and under each issue stated its current position, including in most instances, the information required to i
resolve its concerns. Using those statements by FEMA, BECo has identified a number of "subissues" that, we believe, collectively cocprise the concerns raised by FEMA.
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Under each subissue BECo has set forth the current status, the planned BECo
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4 assistance to the Commonwealth of Massachusetts (Comonwealth) and local governments, the anticipated schedule for such assistance, and, as necessary, i
an explanatory coment.
The action plan and schedule set forth below is part of a comprehensive 4
program of assistance by BECo to the Commonwealth and local governments in upgrading the offsite emergency response programs relating to the Pilgrim Nuclear Power Station (Pilgrim). Well over a year ago, BECo began developing information which would be useful in the enhancemtnt of the offsite programs.
This effort has resulted in, among other things, the "Pilgrim Station Evacuation Timo Estimates and Traffic Management Plan Update" (August 18, 1987) (ETE) prepared by KLD Associates. Inc. and "A Study to Identify l
4 Potential Shelters in the EPZ Coastline Region of Pilgrim Nuclear Power i
r Station" (August 1987) (Shelter Study) prepared by Stone & Webster Engineering i
Corporation, as well es information generated in surveys to identify the i
special needs and transportation dependent populations within the EPZ. Much
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of this information is relevant to the concerns raised by FEMA and will be l
useful in the resolution of such concerns.ll Thus, as reflected in the action l
plan and schedule, the remaining task is primarily to incorporate such l
Information into enhanced offsite programs.
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ll Some preliminary information regarding the enhancement of the offsite programs was submitted in letters froa BECo to the NRC dated June 4,1987 and l
June 12, 1987, and from LECo to the Commonwealth dated June 30, 1987.
To the extent that such information has not been superseded in the ongoing planning process, it will also be useful. One item in such correspondence involved the possible use of the Edgar Station as a third reception center, which is no
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longer under consideration.
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It is also significant that, even prior to the issuance of the FEMA Report.
BECo, the Commonwealth and the local governments develeped a sequence of actions for the upgrading of the Pilgrim related offsite emergency response programs, and are cooperating in the accomplishment of the following actions:
(1) Revision of the emergency plans of the towns within the EPZ, the reception center communities, and the Massachusetts Civil Defense Agency (MCDA) Area II; (2) Revision of the associated procedures of the local governments and I
MCDA Area II; f
l (3) Conforming revisions of the Commonwealth's state-wide emergency plan and procedures; J
(4) Development and implementation of training programs for officials and y
emergency personnel; and (5) Renovation of the Emergency Operation Centers (EOCs) in each of the 4
towns within the EPZ and the reception center connuniti6s.
BECo has provided and is continuing to provide assistance to the local governments and the Commonwealth in these efforts in accordance with the Massachusetts Civil Defense Act of 1950 (Chapter 639, Section 15. Acts of 1950
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as amanded).
For example, BECo has provided two professional planners to work l
l under the direction af the officials of each town in upgrading its plan, 1
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procedures and training, and one professional planner to assist each reception center community.
BECo and the Commonwealth have also developed an arrangement under which four professional planners are being provided to work 4
under the direction of MCDA in the upgrading of the NCDA Area 12 and Ceasonwealth programs.
This cooperative effort is further illustrated by the i
fact that the professional planners are presently completing training modules on "Emergency Plan Overview" and "Introduction to Radiation", subject to j
MCOA's review, and additional task-based modules will be prepared for training l
of specific categories of emergency personnel.
The planners who are currently involved in assisting the towns and MCDA Area II in developing revised plans I
and proc 6dures will also participate in implema cing the training program.
i Moreover, agreements are being executed with each of the five towns within the d
I EPZ as well as the two reception center communities for assistance in the f
renovation of their EOCs.
In addition, four of the five EPZ towns and both l
retection center ccmmunities, to date, have accepted BECo's offer to fund f
full-time civil defensa st2ff positions, i
The availability of much of the required information and the steps already l
taken, including the retention of experienced profet,sional planners, have i
enabled BECc to estimate target senedules for completion of these efforts.
The major efforts are now directed toward th9 offsite plans that are the fundamental source of the FEMA issues -- the town and MCDA A sa !! plar.s.
The goal for completing revisions of the town and MCDA Area Il plans is about October 31, 1987.
The associated operational procedures should be completed i
by about December 15, i987, and the Commonwealth has stated that revisions of the state-wide plan necessitated by the revisions of the town and MCDA Area II l
plans should be completed by the end of 1987. Renovation of each of the EOCs 1 l i
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will be performed individually, but all such renovations should be completed by April 30, 1988.
Thus, as discussed specifically below, the concerns raised by FEMA, which are encompassed within this overall program, are being addressed in a timely and comprehensive manner. Buton Edison and the Commonwealth are comitted to working jointly to resolve all of FEMA's concerns and to establishing the best possible offsite emergency responst program for the communities around Pilgrim Nuclear Power Station.
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Issue A.
Evacuation of Schools Subistun A.1 (FEMA Reoort. Daae 15)
L "The 1985 version of the town plans for Plymouth, Duxb ry, Carver, Kingston, and Marshfield are inadequate in that they do not identify all private schools and daycare centers within the plume exposure emergency planning zone."
Current Status r
Private schools and daycare centers within the plume exposure pathway I
l emergency planning zone (EPZ) are identified in Figures 10-1 and 10-3 of the "Pilgrim Station Evacuation Time Estimates and Traffic Management Plan i
Update" (August 181987), (ETE) prepared by KLt) Associates, Inc.
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1 Planned BEco Assistance and Schedule
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The list of schools and daycare centers associated with each town will be t
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included in the respective town procedures, rather than in the plans. The t
goal for completing the anticipated revisions to the procedures is about 1
j December 15, 1987.
Pending those revisions, the pertinent lists will be made available to each town prior to October 31,1987.
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BECo is providing professional planners who are working under the direction of MCDA and town officials in preparing the necessary revisions of the town and MCDA Area II procedures.
Subissue A.2 (FEMA Recort. Daae 15)
"Detailed plans and procedures must be developed for these institutions, identifying sufficient resources and arranging for the availability of these resources to evacuate children and staff in the event of an accident at Pilgrim."
Current Status 1
1 BECo is providing professional planners who are working under the direction of town and MCDA officials in revising town and MCDA Area II j
plans and procedures, which will identify sufficient resources and arrange for the availability of those resources to evacuate private schools and daycare centers.
Planned BEco Assistance and Schedule i
1 The goal for completing the plans is about October 31, 1987. The associated procedures should be completed by about December 15, 1987.
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t Arranging for transportation providers is discussed under Subissues A.3 -
A.S.
1 Subissue A.3 (FEMA Resort. naas 15)
"The Commonwealth's current position is that it will r.ot use the vast state j
controlled bus resources of the M8TA and that it can to longer rely on ad hoc
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planning, at least during a fast breaking accident.
Detailed plans and procedures must, therefore, be developed for the early dismissal and evacuation of each community's schools and daycare centers."
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I current Status t
f The updated ETE takes into consideration evacuation of all public and f
private schools, and daycare centers in the EPZ.
The professional planners provided by BECo are assisting town and MCM officials in I
developing plan and procedure revisions relating to these institutions.
l At a meeting with FEMA, NRC and BECo on August 14, 1987, the Commonwealth made clear that, if required, it would use all available resources,
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j including those of the M8TA.
If in the current planning process it is
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1 determined that M8TA buses may oe useful, detailed arrangements providing 1
for the availability and use of M8TA resources will be included in town, i
f MCDA Area II and Cosmonwealth plans and procedures.
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Planned BEco Antistance and Schedule l
The goal for completing revisions of town and MCDA Area !! plans which will address early evacuation and/or early dismissal of schools and daycare centers (and the use of private or public transportation resources for such evacuation or dismissal) is about October 31, 1987. Revisions to the associated procedures should be completed by about December 15, 1987.
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Comment Although current programs may include early dismissal, it appears that early evacuation of schools and daycare centers could be a more approp-l 1
j riate precautionary response.
Nevertheless, the planners provided by BECo will be assisting school, town, and MCOA officials, in accordance uith the I
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incorporate wl.ichever precautionary response is selected in the planning l
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process (id., early evacuation and/or early dismissal).
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l Subittue A.4 (FEMA Renort. nace 15) e "Letters of Agreement with transportation providers not under direct control
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Current Status As described under Subissue A.2, the planning efforts underway will identify the transportation resources available for evacuation of schools and daycare centers.
Planned BEco Assistance and Schtig13 The planners provideo by BECo wi'l assist MCDA and town officials, as appropriate, in obtaining Letters of Agr,eement (LOA's) to formalize agreements with a sufficient number of transportation providers to provide for r:vacuation of schools and daycare centers.
Subissue A.5 (FEMA Recort. cage 15)
"Personnel designitid to drive vehicles during an evacuation must also receive proper training as emergency workers."
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j The professional planners provided by BEco are presently completing i
training moduies on "Emergency Plan Overview" and "Introduction to i
Radiation," which will be promptly provided to MCDA for review.
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I Planned BEco Assistanes and Schedule Additional task based modules will de prepared for specific categories of emergency personnel, including bus drivers.
The goal for completing the specific training module for bus drivers is shortly after completion of applicable procedures on or about December 15, 1987.
The professional planners provided by BECo to assist in the development of plans, procedures and training programs will be available to assist in l
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Issue B. Receetion Center Subissue B.1 (FEMA Reeort. Dage 19)
"(A) new reception center must be found to replace Hanover."
Current Status The planners provided by BECo. in concert with the reception center comunities' Civil Defense Directors, are currently evaluating the feasibility of using two rather than three reception centers.
The updated ETE analysis demonstrates that EPZ evacuation times will not be adversely affected by the use of two reception centers rather than three.
In conjunction with the above effort, the Commonwealth has indicated that' it will continue in its attempt to identify a third reception center to at:ommodate persons evacuating to the north of Pilgrim Station in the event of an emergen:y.
Planned BECo Assistante and Schedule BECo expects that the evaluation of the feasibility of using two reception centers will be completed by about October 1, 1987. Associated procedures should be completed by abcut December 15, 1987.
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Sghissus B.2 (FEMA ReDort. Daae 19)
"(P]Ians and procedures must be developed to register and monitor evacuees."
Current Status The planners prcvided by BECo are assisting the rec 3ption center communities and MCOA officials in revising plans and procedures governing or related to reception center operations.
Those revisions will include l
reception center monitoring and registration of evacuees.
4 Planned BEco Assistance and Schedule The goal for completing the relevant reception center community plans is I
about October 31, 1987.
Associated procedures should be completed by about December 15. 1987.
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Issue C. Reach Ponulation l'
Subissue C.1 (FEM Renort. nace 26) 1 h
"FEMA and the RAC... must receive the following additional information:
(1) an updated geographical description of the beaches and their capacity; r
l Current Status I
i BECo has developed preliminary estimates of the expected maximum number of people on the public beaches within the EPZ.
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Planned BEco 'issistance and Schedule l
l BEco will verify the ptsliminary estimates of the expected maximum number of people on the beaches, and will develop an updated geographical l
description of the beaches by about October 1, 1987.
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Subissue C.2 (FEMA Renort. naan 26) i
"(2) a detailed analysis of the beach population, including the number of permanent and temporar residents and tne number of day visitors, together l
with their geogra,hica dis,ersion:
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Current Statui The current planning process is based upon the assumption that sufficient l
sheltering capacity for permanent and temperary residents and day visitors on the beaches will ba provided.
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i BECo will identify by about October 1, 1987 the geographical dispersion of the beach population for eAch of the public beaches in the EPZ.
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j Since the current planning process is proceeding on the basis that sufficient sheltering capacity will be found for the entire beach i
population, a breakdown of the number of permanent and temporary residents l
i and day visitors is not presently being developed, r
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Subissue C.3 (FEMA Renort. eage 261 i
"(3) an updated estimate of the length of time it would take to evacuate the f
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beach populat hn; I
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Current Status The t,pdated ETE (Tablas 9-4 through 9-8) contains estimates of the length of time it would take to evacuate portions of t:
,9cor.. passing each of the bs.ches.
Planned BEco Assistance and Schedole None.
Comment I
As part of the effort to upgraJe the offsite plans, including provisions for sheltering and/or evacuation of the beach population, BECo, town and l
HCDA officials are exploring the possibility of precautionary clearing of
'he beac! population at the "Alert" classification stage in irder to f4cilitate implementation of protective actions for this segment of the EPZ population.
Snhin ue C.4 (FEHA Recort. Daaes 26-27)
"(4) s list of suitable buildings available for sheltering the beach populatio- ' each beach, including the capacities of thes. buildings and their distancas from the beaches." I
Current Status "A Study to Identify Potential Shelters in the EPZ Coastline Region of the Pilgrim Nuclear Power Station" (Augu:t 1987) (Shelter Study) has been performed by Stcne & Hebster Engineering Corporation to identify potential sheltering ca; abilities of, among other facilities, municipal and commercial buildings for emergency use by the beach population within the EPZ. The Shelter Study contains a preliminary list of potential shelters in each of the towns that ccztain b%ches.
From the preliminary information contained in the Shelter Study, Stone & Hebster is identifying the specific locations and relative distances from the beaches of the identified shelters.
In addition, a dei;.iled effort is being undertaken in each of the towns to identify and incorporate into their planning program specific snelters that would be utilized for the beach population which will take into account their distances from the beaches.
Planned BECo Assistance and Schedule BECn estimates that the additic 21 Stone & Webster analysis will be completed by about October 1, 1987.
The goal for identifying final shelter locations is about December 15, 1987.
Subissue C.5 (FEMA Reoort. Du!L221 R
"If these buildings are not open to the public, the plans must clearly sta how they util be made accessible and letters of agreement must be obtained appropriate."
Current Status Planners provided by BECo are assisting EPZ town officials in revising plans and procedures to identify how shelter facilities will be made accessible and how the beach population will be made aware of the location and availability of such shelters.
The planni.ig approach is to preferentially ioentify public facilities which will not require the execution of letters of agreement.
Should an insufficient number of public facilities exist, then LOA's will be obtained to formalize L
agreements with private facilities.
Planned BEco Assistance and Schedule The goal for completing the plans for the EPZ towns is about October 31, 1987. The associated procedures should be completed by about December 15, 1987.
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Issue D. Soeciil Needs Pooulation Subissue 0.1 (FEMA Reoort. Pace 35)
The information on mobility impaired persons "must include the updated, comprehensive procedures used to identify the mobility impaired, together with the program in place to periodically review and update all relevant information pertaining to them; Current Status A survey previously performed by BECo identified the general size and characteristics of the mobility impaired population in the EPZ, Planned BECo Assistance and Schedule The planners provided by bECo will be assisti.1g town officials in identifying specific mobility impaired persons (including their locations, specific impairments, and needs) and in developing pro:edures for maintenance and periodic updating of relevant information pertaining to these individuals.
The goal is to identify specific mobility impaired oersons by December 15, 1987 and to develop procedures for annually updating and revising this information by about March 15, 1988.
BECo is committed to working with the responsible Commonwealth agencies to ensure the best possible program for addressing the needs of the mobility impaired population. '1
Subissue 0.2 (FEMA ReDort. Pace 35)
"The resources available to meet the needs of... this group; Current Status The planners provided by BECo are utilizing listings of ambulance resources in the State provided by the Commonwealth Department of Public Health / Emergency Medical Services and other sources to assist town t7d MCDA officials in identifying the specific transportation resources that are available to meet the needs of the mobility impaired population in tha EPZ. The planners are also assisting town and MCDA officials in revising plans and procedures that will provide for the needs of the mobility impeired population.
Planned BECo Assistance and Schedule The goal for incorporating information regarding available transportation resources into town and MCDA Area II plans is about October 31, 1987.
Associated procedures should be revised by about December 15, 1987.
1 Subissue 0.3 (FEMA Reoort. Pace 35) y L
"Letters of Agreement for the use of these resources as apprvpriate."
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Current Status
- Transportation providers from which LOA's must be obtained are being j
identified as described in Subissue D.2.
Planned BEco Assistance and Schedule l
The planners provided by BECo will assist town and MCDA officials, as appropriate, in obtaining LOA's to formalize agreements with a sufficient number of transportation providers to provide for evacuation of the mobility impaired population in the EPZ.
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Issue E.
Transoors ition Dioendent Pooulation Subissue E.1 (FEMA Reoort. taae 40) l "FEMA and the RAC...must recei',e detailed plans and procedures for protection of the transportation dependent,9pulatio, including:
estimates of the number of people involved,"
Current Status Estimates of the number of transportation dependent persons in the EPZ are contained in Table 10-6 of the updated ETE.
Planners provided by BECo are assisting town and HC0A of;'icials in developing revised plans and proceoures the.t will reflect these estimates and address protection of the transportation dependent population.
Planned BEco Assistance and Schedule The goal for completing town and HC0A Area II plan revisions addressing the transportation dependent population is about October 31, 1987.
Associated procedures should be completed by about December 15, 1987.
Subissue E d (FEMA Report. Daae 401
"[L]ists indicating the resources needed and identified,"
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Current Status Table 10-7 of the ETE identifies the estimated number of buses required to provide for the transportation dependent pooulation.
The professional planners provided by BECo are working with town and MCDA officials to va*1fy the actual number of buses needed, and to identify those buses that will be :4vailable for emergency use.
Planned BECo Assistance and Schedule The goal for incorporating information on needs and available resources in town and MCDA Area II plans is about October 31, 1987. Associated procedures should be revised by about December 15, 1987.
Subissue E.3 (FEHA Reoort. naae 40) x
"[A]ppropriate letters of agreement."
Current Status As described under Subissues E.1 and E.2, the planning efforts underway I
will identify the transportation resources available for evacettion of transportation dependent persons.
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Planned BECo Assistance (~1 Schedule Planners provided by BECo will assist town and MCDA officials, as appropriate, in obtaining LOA's to formalize agreements with a sufficient number of transportation providers to provide for evacuation of the transportation dependent population in the EP2.
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1119e F.
Overall Lack of Proaress in Plannina and Anoarent Diminution in Emeroency Preoaredness Subistue F.1 (FEMA Reoort. Daaes 43. 47) 1 1
"(1)(T]he Commonwealth has failed to correct the numerous problems noted in FEMA's review of its plans and during its exercises... including issues from:"
(a) ti.e 1981 Regional Assistance Committee (RAC) review; (b) the 1982 RAC review; (c) the March 3, 1982 Exercise; (d) the June 19, 1983 Exercise; and (e) the September 5, 1985 Exercise.
Current Status i
BECo has reviewed the issues remaining open from the referenced RAC reviews (including those identified in FEMA's October 30, 1985 letter to the Commonwealth) and exercises, and believes that tnsse issues can be resolved through the current effort to revise the relavant plans and procedures, through training on the applicable procedures and through the procurement or repair of equipment.
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i Planned BECo Assistance and Schedule The goal for completing town and MCDA Area II plan revisions addressing the issues identified by FEHA (Issues A-F) is about October 31, 1987.
SECo expects that the remaining issues identified in prior FEMA reviews will be addressed in the subsequent effort to revise the associated procedures and train emergency response personnel, and in the upgrading of the overall state of emergency preparedness.
Subissues F.2 - F.7 (FEMA Recort. Dage 47)
"(2) [The Commonwealth) has not updated its plan, and so advised FEMA of its actions on an annual basis...; (3) it has not implemented State and local training...; (4) it has not pursucd an adequate program of public education and information for the media...; (5) and it has not... submitted to FEMA the required Annual Letters of Certification for calendar years 1985 and 1986.
(6) In addition, representatives of the Commonwealth have indicated that the state and local plan is inadequate; and (7) they have been unable to answer numerous questions posed by the public and by local officials in public meetings..."
Current Status See Comment.
Planned BECo Assistance ad_1chedule See Comment.
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Coment Subissues F.2 - i.7 relate primarily to relationships between FEMA and the Commonwealth or to alleged past events involving the Commonwealth.
Although it is inappropriate for BEco to address these matters, much of the information being developed and actions being taken under Issues A-E and Subissue F.1 are relevant to Subissues F.2 - F.7.
In addition,should the Commonwealth desire any further assistance from BECo under the Massachusetts Civil Defense Act of 1950 (Chapter 639, Section 15, Acts of 1950 as amended), BECo will provide such assistance.
Subissue F.8 (FEMA Reoort. Daaes 47-4(1
"[A]dditional areas of plan weakness are identified in the... FEMA Report,
' Analysis of Emergency Preparedness Issues at Pilgrim Nuclear Power Station Raised in a Petition to the NRC Dated July 15, 1986.'"
Page 33 of the FEMA Report on the July 15, 1986 petition states that the L
"Comonwealth's plan would be enhanced if the policy for the administration of KI to institutionalized people were clearly stated; and if procedures for the distribution of KI to the institutions were more fully developed."
farrent Status Supplies of KI have been made available by BEco and arrangements have been made to have a small supply in each of the towns in the EPZ under lock and key controlled by the local civil defense director. As noted in a memorandum dated August 10, 1987 from Robert Hallisey, Comonwealth Department of Public Health, Director, Radiation Control Program, to Gerald Parker, Commonwealth Department of Public Health. Assistant !
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Commissioner, Bureau of Environmente.) Her.Ith Services, it would be possible to address FEMA's concern by "spel1[ing) out that the local civil defense J1 rector could transfer this supply to an institution within his/her community if needed."
BEco Planned Assistance f.nd Schedule i
If requested by the Commonwealth, the professional planners provided by BECo could assist in the revision of plans and procedures to clarify this policy.
Comment BEco's review of the FEMA Report on the July 15. 1986 Petition indicates that the only "additional area of plan weakness" identified in that report which is not encompassed by Issues A-E and Subissues F.1-F.7 is FEMA's recommendation concerning the Commonwealth's policy and procedures for administration of KI to institutional 1 zed persons.
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