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475 ALLENOALE ROAD KING OF PAUISIA. PENNSYLVANIA 1e408 MAR 081988 b,
Docket No. 50-293 Boston Edison Company ATTN: Mr. Ralph G. Bird Senior Vice President - Nuclear 800 Boylston Street Boston, Massachusetts 02199
Dear Mr. Bird:
NRC Region I has recently received from the Plymouth Board of Selectmen, a Committee Report entitled, "Environmental Radiation Monitoring - Pilgrim Nuclear Power Station," December 1987.
We understand that you have also received the report and plan to provide written comments to the Town of Plymouth. Please ensure NRC Region I receives a copy of your comments.
Sincerely, Wbf Samue J. CollMs, Deputy Director Division of Reactor Projects cc:
R. Barrett, Nuclear Operations Manager B. M:Intyre, Ch.irman, Departer.nt c/ Public Utilities Chairman, Board of Selectmen Plymouth Civil Defense Director J. D. Keyes, Boston Edison Regulatory Af f airs and Programs E. D. Robinson, Nuclear Information Manager R. N. Swanson, Nuclear Fngineering Department Manager The Honorable Edward J. Markey The Honorable Edward P. Kirby The Honorable Peter V. Forman Sharon Pollard, Secretary of Energy Resources Peter W. Agnes, Assistant Secretary of Public Safety, Commonwealth of Massachusetts Rachel Shimshak, MSSPIRG Public Document Room (POR) local Public Document Room (LPOR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector Commonwealth of Massachusetts (2)
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ENCLOSURE 2 b
NRC Region I Comments on Town of Plymouth Committee of Nuclear Matters Recort "Environmental Radiation Monitoring - pilgrim Nuclear Power Station, O_ecembe r, 1987 1.
With regard to Comment No. 4 in the "
SUMMARY
" on Page 2:
The status of tha environmental TLD system was reviewed in an inspection performed October 5-9, 1987. This inspection determined that the licensee has initiated improvements to its TLD program. The system in use at the t
time of the previous inspection has been eliminated, and replacted with a different system which is maintained by the Yankee Atomic Environmental Laboratory. The Quality Control program for the system was reviewed and found to be adequate. This laboratory has had an excellent reputation for providing reliable data for all types of environmental samples.
2.
With regard to Coment No. 6 in the "
SUMMARY
" on Page 2:
The NRC maintains a capability for responding to abnormal releases of radioactivity whenever it is suspected that there has been a release of sufficient magnitude to be a public health concern, This caoability includes the use of a mobile radiological analysis laboratory for independent analysis of environmental and/or in plant samples, i
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O2*.N171 As THE COMMONWEALTH OF MASSACHUSETTS f
EXECUTIVE DEPARTMENT STATC HoUSC e
BOSTON 02133 MICH Art. S. DUK AKtS s ov a n e.on December 17, 1987 Mr. Lando Zech, Chairman U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Mr. Zech:
In April, 1986, I called for in review of emergency preparedness and other tafety issues at the Pilgrim Nuclear Power Station.
Almost ane 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 faci'ity.
a Thereaf ter, 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 satisf actorily addressed.
17 August of 1987, the Federal E,aergency 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 Energency preparedness for an Accident at Pilgrim Nuclear Power Station."
Dased upon Secretary Barry's report, I continue to rake the finding that adequate plans do not presently exist, that in no event should pilgrim be permitted to restatt unless and until all emergency planning and safety related issues are reco1ved, and that it romains 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 f rom the existing hazards posed by Pilgrim Station.
1 In particular, while Secretary Barry's report identifies the many positive steps taken over the past yeae to improve emergency plans and safety at Pilgrim Station, it also identifies a number of remaining problems.
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% d Lando Rech, Chairman December 17, 1987 Page Two These pending issues include, but are not limited to:
Development of implementing procedures for assisting special needs populations, Development of a Pilgrim-Specific Probabilistic Risk Assessment, Assessment of the need for an additional reception
- facility, Resolution of questions regarding the new Evacuation Time Estimate and Traffic Management Study, and Resolution of safety issues regatding installation of the direct torus vent.
The time has come fo; the Nuclear Regulatory Commission and the Federal Emergency Management Agency to mak; clear what specific steps will be taken to insure that all concerns voiced in both the 1986 and 1987 reports prepared by Secretary Barry will be satisfactorily addressed before Pilgtim Huclear Power station is permitted to restart.
Further, I want to take this opportunity to restate the position taken by Attorney General Jaren Shannon and I, that a-1 e,p'dj,udicator hearing should be held prior to any decision on
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i 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 EdAson Company, owner and operator of Pilgrim Station, has also taken a number of actions regarding nuclear management, reactor esfoty, and emergency preparedness.
Nonetheless, it in still my opin$on 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 edequate plana for response to an accident at Pilgrim Station.
Thus, in spite of progress whicm has been made, I cannot yet say that all safety inaues pertaining to Pilgrim Station which were discussed in my December, 1986, report have been antisf'actorily 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.
J These reporta include a study by the Massachusetta Legislature's Special Joint Commission to Study Safety at Pilgrim Nuclear Power Station, the U.S.
Nuclear Regulatory Cwamission*a (NRC) Systematic Assoassent of Licensee Performance (SnLP),'and a Self-Initiated Review of emergency response piens by the Federal Emergency Management Agency (FEMA).
The Federal Emergency Management Agency has laaued an asseamment of the plans for response to an accident at Pilgrim.
FEMA concluded that their earlier 1982 interim finding that Pilgrim's emergency plans were adequate was no longer valid and was superceded by a new finding that the plena as most recently ravJaed in 1985 were not adequate.
This new findir.g was transmitted to the Nuclear Regulatory Commission, which has taken the position that tauues raised in the FEMA asses
- ament j
rust be "addressed" before restart is permitted.
The NRC has 1
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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, adequete plena must be in i
place before Pilgrim Station la allowed to restart.
i, In part" lar, the FEMA Self-Initiated Review made the finding that off (ite 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 recommandations which Commission members feel must be fulfilled befote 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 Massachusetta Civil Defense Agency enr Office of Emergency Preparedness (MCDA/OEP) han initiated a comprehensive three phase proctaa to completely revise emergency plans for the communities surrounding Pilgrim Station.
The state legialsture 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 Massachusetta.2 On October 6,
1987, the Governor submitted a supplementary budget request of s700,000 for the new program (House Bill 6086, see appendix i
one).
Prompt action on this request 'a important.
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i An important aspect of the process to improve safety at Pilgrim is that state officiala meet regularly with local officials, interested citizens, and representatives of Boston Edison to discusa problems and laaues related to safety at Pilgrim.
MCDA/OEP and Executive Office of Public Safety
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1Since our September, 1946 decialon that adequate emergency planning for Seabrook is not possible, it la the policy of the Commonwealth thet there should not be participation by Messachusetta in attempts to draft plans for that unlicensed t
plant.
22n e.ddition to Pilgria Station, ths Yankee Nuclear Power Station in Rowe, Messachusetta, and the Vermont Yankee Nuclear Power Station in Vernon, Vermont, have energency planning zones within Messachusetta.
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o a officiala meet regularly with senior management representatives of both Boston Edison and the Yankee Atomic Electric Company to l
discusa nuclear safety issues.
The Executive Office of Public Safety and MCDA/OEP also participate in and monitor meetings of federal regulatory authorities.
The Boston Edison Company has taken several actions in part as a response to my report.
The company has offered support to local governmenta under section 15 of chapter 639 of l
the acts of 1950, to easiat in enhancing local response to an accident at Pilgrim and to renovate local emergency operations 1
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 lasued 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 ayates 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 is supporting the efforts of local officials to develop l
improved plans and procedures by making resources, including 1
professional energency plannera, available to each of the seven EPZ and host communities under section 15 of chapter 639 of the acts of 1950.
Under the same provision of the Massachusetta i
General Laws, Boston Edison is also providing each community 1
with material resources to support emergency response and is making physical improvements to each local emergency operations j
center.
This offer to each community includen funding for a full-time civil defense director for the operating life of i
Pilgrim Station.
Four of the seven EP2 and host communition l
l have signed agreements with Boston Edison to accept thia l
1 assistance.
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The Nuclear Regulatory Commission and the Federal Emergency Management Agency are continuing to exercise their regulatory authority over Pilgrim Station.
FEMA la responalble for certifying to the NRC that off-site emergency plana and response are adequate.
In a report dated August 6, 1987, FEMA i
stated that "It3he resulta of our half-initiated review l
indicate that the Massachusetta Plan la inadequate to protect the health and safety of the public in the event of an accident j
at the Pilgrim Wuclear Power Station..."3 i
I 3The TH A Self-Initiated Rev.5 is dit, cussed in greater detail in,section IE i !
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s The NRC closely monitoring all developmenta concerning COOrgency planning, the safe operation of the reactor, and cn-cite safety and management.
For instance, the NRC has three rcoident inspectors assignad to monitor operations at Pilgrim Stction rather than the one inspector assigned to most other i
nuclear plants.
However, on one recent weekend when there were oight probles evente at Pilgrim Station, only two NRC resident iccpectors were easigned to the facility and no inspections waro made during the period the events occured.
Since that tico I have requented that the NRC agree to provida, at a j
a Dinimum, daily random monitoring of operations at Pilgrim Station.
The NRC is inauing a status report on the facility j
ovCry two weeks, and this practice should certainly continue.
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1 STATE RESPONSE TO THE DECEMBER. 1986 REPORT ON SAFETY AT.
e ElkGRIM STATION i
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. Revisions to Off-Site Emeraenev Plans
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i One of the most critical findings of my report on l
cofoty at Pilgrim was that state and local plans for response I
to en accident at Pilgria Station were not adequate to protect i
the public.
The Massachusetta Civil Defense Agancy and Office l
cf Emergency Preparedness, which is responsible for off-site nuclear power plant energency planning under at. 1979, c.796, hco responded by establishing a three phase program destened to l
dcvclop the best possible emergency plans for all EP2 and host I
coccunities.4 They will be assisted in this effort by the l
ncw Nuclear Safety Emergency Prepar edness Program discussed in coction II.B.
Since energency response is first and foremost a t
I rocponsibility of local government, MCDA/OEP has sought to a
cctcblish a ayates whereby local authorities take the principal l
rolo in plan revision with advice and assistance from atete efficiels.
Further, since state and local resources available for this purpose remain atrictly limited, support for thia cffort has been received from Boston Edison en discuased above.
j Federal regulatory guidance suggesta that nuclear utilities should support the costa of of f-site emergency i
prcparedness an a responsibility of operating commercial
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a 4The five cosa.inities comprising the Pilgrin EPZ are Carver, Duxbury, Kingr. ton, Marshfield, and Plymouth. Presently there are two hoa,t communities, Taunton and Bridgewater. It should be not'ed that similar prograan have been initiated
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fcr the cosaunities within and serving the Rowe and Vernon IP2a.
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are attended regularly by the civil defense directors of most of the EP2 and host communities.
An essential component of the phase II prc7ess is that local plans will be reisraated so that they are organized according to NUREG-0654 planning criteria.
This will enable efficient checks on progress and easier determination of more The compliance with federal regulatory planning requirements.
many laauem raised in my earlier report and other reviews of the plans must be resolved before the phase II procean 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 are 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 casential training cournen to local officials.
For instance, training is being given for the newly installed emergency notification radio ayaten (see section III of this report) and for operation of public alert airen systems.
Whether or not Pilgrim Station
.* e a t e r t a, it will at least in the short run remain a high-level waste storage area, so local officials must know how to operate these ayatema 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 l
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 j
adequate plana have been developed through the phase II process and that all emergency personnel have received or will receive required training, then the possibility of holding a full-scale amargency exercise will be conaldered.
While MCDA/OEP and other state and local agencies are i
pledged to complete the three phase process sa quickly an j
possible given available staff and resources -- our carget data j
is to produce a new revision of the plan by the end of the 1
calendar year -- it bears emphasis that there la no absolute 1
deadline for this work.
Whatever time is required to develop the best possible plana will be spent on this process, and the on'.y measure of satisfactory plans will be that of public safety.
B. Establishment of the huelear Safety Emeraenev Prepardeness Proorer j
l In his Fiscal Year 1988 budget, Governor Dukaki's proposed development of a state program to be responsible fer 1
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oil plcnning, trcining, cnd cxcroicco in cupp3rt of cocrgency prcperdnoco for en cocidont et cny of tho throo nucicor power i
planta 11conocd to epcroto within or cd3ccont te Hooocchucotto.
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The Fiscal Year 1988 budget enacted by the legislature and signed by the Governor creates such a program within the Massachusetta Civil Defense Agency and Office of Emergency preparedness, allocating 9175,000 for its first year of All funda expended for this purpose will be operations.
reimbursed to the Commonwealth through an easeasAent of nuclear l
utilities by the state Department of public Utilities.
The FY '88 budget authorized eleven posit.lona for the new division.
However, insufficient funds were appropriated to i
till all of these Joba.
The first five of these positions have been filled.
The Governor has submitted to the legislature a request for an additional 8700,000 (H3 6086, see appendix onc) ao that all remaining positions created for the new program can be illied as early as January, 1988.
Establishment of this new I
program is an important step towards assuring that the beat possible plana can be developed, tested, and if found to be i
adequate, maintainud for response to an accident at a nuclear r
l power plant and for allocating the planning costa to those reponsible for the hazard.
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C. Exoansion of the Eseraenev Plannino Zone Federal regulatory guidance contained in NUREG-0654 s
auggests that the plume exposure emergency planning zone be ten siles, more or less, with ad3uatmenta made for political boundaries and other geographic considerations.
The limits of j
1 the EPZ as of December, 1986, had actually been established in 1979, and included all of the towns of Duxbury, Kingston, and l
Plymouth, and only those portions of Marshfield and Carver l
lying within ten approximate miles of pilgrim Station.
After consultation with officiala of Marshfield and Carver, these j
towns in their entirety have been designated as part of the l
EPZ, see appendix two.
This was done to be sure that in the event of an accident at Pilgrim Station, state officials can j
make and implement protective actitm recommendations on a consistent "whole town" basta, thua reducing potential confusion regarding those actions.
This is the same protective i
j action policy which la used for the Yankee Rowe and Vermont Yankee Mamnachusetta EPZa.
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i Small portions of tourne, Plympton, and Wareham lie within ten miles of Pilgrim, and officiala of each of these j
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, a
and have discussed with them the responsibilities f,wplied by this designation.
State officials must still complete l
consultation with FEMA and the MRC regarding this sxpansion of the Ep2 before final designation is made.7 i,
i 7The House Ways and Neana Cosaittee recently gave approvat to section one of N.B.
i 5343 which would, among other things, establish a 50 mile EP2 in Mar,tachusetta.
We support this initiative but would require additional resources to applement it. i
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<s It 10 cur fooling thct full Ottcntien cu0t bo focuccd C-on assuring that adequate pione cro d0volopcd for oll croco within ten miles of Pilgrim Station before undertaking new planning for areas in the expanded EPZ.
Therefore, the and the designation of Carver and Marshfield in their entirety, 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 EPZ.
It also should be noted that we rema11. 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 en expanded planning zone to fifty miles.
It should be noted that the resources amaociated with HB 5383 are algnificant and will not be addreamed by passage or our supplementary appropriation request.
D.. Off-Site Monitecip_q, 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 boundaries of Pilgrim Station to better determine if there are low level radioactive relocaen from the power facility.
The state of Illinois has installed a complex syntes to continuously monitor the engineering parameters and radioactive releanes of nuclear power plants.
The Department of Public Health has prepared a report about this ayates and ostimates that it would cost approximately si million to install in the Commonwealth in Pilgrim Station, see appendix three.
E. Revisions to the State and Area II Plena In addition to the seven local radiological emergency response plana, the re'.conae plans for the State and for MCDA/0EP Area II were elao 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 eupport of of activities among the EP2 and host communities, these revlaions cannot be completed before revisinna to local plans are finished.
A task force under the authority of the state Director of Civil Defense mesta regularly to review work in progress.
Under H.B.
6086, recently approved by the House Ways and Means Committee, funds would be made available to the Department of Public.
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Hoolth to furthcr ctudy tho fccoibility of cn off-cito Cenitoring cycteo.
The State Radiological Emergency Response Plan must discusa actions to be taken in response to accidenta 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 Electric Company as well as with the Boston Ed ' son Company. Representatives of the utilities meet regularly with the task force of state personnel to review sork in progresa.
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 *a 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 Response Team (IRT) would be composed of professionala from atate 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 operations 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 seasures.
In regards 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 discusalons at these inspections and senatons involve highly technical matters which could possibly affect public safety.
The Governor *a 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 safety activities are also discussed in section II.H., following.
G. State particioation in WRC Safety Insoections and Meatinaa
' Vermont, New Jersey, and other states around the nation have entered into formal agreements with the Nuclear Regulatory Commission whereby they are permitted to attend and, to a limited degree, participate in safety inspections and meetings 9
for nuc1ccr pcwor picnto, 000 cppOndix four.
Tho Caccenwoolth la considering making such arrangements.
Under an appropriate agreement, a representative of the state would be permitted to attend the on-site inspections and subsequent discussions and have the right ta file diamenting or concurring findings.
Designated state representatives would be trained and certified by the different utilities for unescorted accean to aach nuclear power station.
Since these inspections and meetings involve detailed discussions of the most technical aspects of nuclear power generation, the individuals who represent the state would have to be qualified nuclear engineers.
The state does not presently employ anyone with the skilla and experience necessary to participate in these matters in a 7eaningful way.
We are reviewing agreements between oth'er states and 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 neveral recommendattens for action by the Boston Edison Company which directly relate to off-site emergency response.
These recommendations concerned improved 1
equipment for off-site emergency notification, production of a new evacuation time estimate (ETE), certification of the airen i
alert and notification ayaten, addressing the ability to protect beach area populations, addressing shelter as a protective action, production and distribution of improved public information material, idproving procedures for protection of special ne,eds and school aged populations, and aubnission to the state and NRC of a probabilistic risk ammesament which considers accident scenarios initiated by both j
internal and external events and which specifically based on Pilgrim'a design features to assena the containment conditional failure probability.
In response to the documented need for an improved nystem to promptly notify off-site authorities of an accident j
at Pilgrim Station, Boston Edia... purchased and has installed a radio cystem called BECONS through which state and local authorities can be given immediate notification of eventa at
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the power facility.
This ayaten la now in the final ateges of j!
testing and of receiving licenses for operating frequencies.
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The Federal Communications Commission la in the process of
- l final review of the frequency license, and approval la expected i
before the and of December.
Material has been developed by the utility to train state and local officials in the use of j
BECONS.
BECONS units have been installed in all town warning l
points, at MCDA/OEP Area II Headquarters, Bridgewater, and at Massachusetta State Police Troop D, Middleboro.
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Boston Edison commissioned the New York firm of XLD Associates to undertake a new Evacuation Time Eatinate and traffic management plan for the Pilgria area.
The draft document was delivered to state officials on August 20, 1987 and revised pages based on preliminary comments were delivered to MCDA/OEP on September 8.
Staff of MCDA/OEP is coordinating review of the ETE by a task force of other state' agencies and by officials of all concerned local Jurisdictions.
While this i
review is not complete, serious questions regarding the ETE methodology and resulta have surfaced.
These leaues are covered in greater detail in section VI.A. of this report.
Throughout its history of operation, the public alert i
airen system which wma installed throughout the EP2 by Boston Edison has been plagued by airen failures and the spontaneous sounding of alarms, especially during thunder storma.
Boston Edison has replaced malfunctioning units and done other repair and maintenance to the airen ayates.
FEMA has reviewed all proposed improvements to this airen ayaten and has monitored the results of monthly ayaten testa.
The monthly airen ayaten i
J tests which have been conducted by Boston Edison since 1986 indicate that ayaten reliability exceeda FEMA standarda.8 FEMA conducted a full test of the airen ayaten in the i
Autumn of 1986 which included a telephone survey to determine l
the percentage of the population which heard the alarms.
FEMA has reported that better than 854 of the population heard the airena.
A three-minute-cycle airen test was held for Pilgrim on October.15, 1987, and we have gathered information about the l
results.
Protection of beach populations during the Summer months is a principal public safoty concern raised in our I
- Report, Boston Edison has propossJ to the Muclear Regulatory l
Commissien 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 3
l population can be protected.
Staff of MCDA/OEP have reviewed t
the shelter survey and find it deficient in several aspects, 1
see appendix five.
Also, our review of the new ETE, while incomplete, leaves several questions not answered to our satisfaction.
The.efore. we cannot agr ee that Boston Edison Company has resolved the leaue of protection for beach i
populations.
4RCDA/0EP receives and reviews monthly airen ayates test reports which Boston Edison subsits to FEMA. These are not sount.' testa, but testa of the ayaten's electrical circuits.
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Our December, 1986 report requested that Boston Edison i
"commission a comprshensive shelter survey."
The survey which i
was delivered to and reviewed by the staff of MCDA/OEP was made only for en area between one half and one mile of the coast.
Since the survey did not cover the remainder of the EP2, and for other reasona discussed in section VI.B. of this report, 4
this recommendation has not been fulfilled.
The Boston Edison Company produces an annual public information brochure in cooperation with MCDA/OEP for l
distribution throughout the EP2.
MCDA/OEP staff were working with Boston Edison and the utility *a consultants with a goal of i
lasuing a new EPI brochure by September, 1987.
Howeve.?,
because certain critical planning decia.ons had not been m.ade
-- principally whether or not a third reception center la j
required to replace Hanover Mall -- preparation of the brochute has not been completed.
i Roston Edison informed MCDA/OEP in August that it was j
j conducting a study to determine the adequacy of two reception I
centers instead of three, and that the results would be J
available in early September.
We indicated that we would evaluate auch a report within fourteen days.
To date, we have not received the Boston Edison analysis although we have requested it on several occasions.
Therefore, we are unable to 1
complete preparation and distribution of an EPI brochure.
In I
the alternative, van interim Public Information Brochure will be distributed throughout the EP2.
This interim brochure will explain the aspects of emergency response which are not fully l
addressed at present and which will be completely resolved i
biore a final EPI brochure is distributed in 1988.
Our l
4 position la clear that in no case should Pilgrim be permitted to restart until a final and complete EPI brochure has been approved by MCDA/OEP and distributed.
I J
i IV.
EEELJWTERIM FINDINGS l
On September 29, 1982, FEMA and the Regional Advisory i
Committee (RAC) issued its interim it.. dings on the adequacy of j
P11 gin EPZ and host constinity plans.
The 1982 review indicated l
that the plena 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, "tb3ecause of the changed 4
I circumstances discussed in the FEMA review, our finding of 1
adequacy contained in the Interim Finding of September 29, 1982 j
no longer applies and has been supeceeded by the onclosed finding."
This information was elao transmitted to the NRC.
)
f The FEMA Self-Initiated Review found the emergency
]
plans to be deficient in five specific areast 1) evacuation of schools, 2) reception center, 3) beach population, 4) apecial 4
l needs populations, and 5) transportation dependent populations.,
1 i
Each cf theco itcco w o idcntificd in cur D ccabor, 1986 report as a deficiency.
The steps being taken by the Commonwealth and by Boston Edison to addreas 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 4
assist an evacuation in the Pilgrim EP2.
In fact, the Commonwealth will endeavor to make these buses and all other public resources available to assist in emergency response if i
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 hoe measures in l
planning for emergency action to indicate that we would not une available resources.
The NRC has not stated an 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 the NRC*a i
offices in Bethesda, Maryland, on September 24, 1987, the NRC indicated only that off-site planning inauen must be "addressed" before restart is allowed.
This is not an adequate i
response on the part of the NRC, and we believe that all off-aite safety laausa must be resolved prior to restart.
l i
The NRC has asked Boston Edison to present an "Action Plan" for addressing the deficiencies cited in the FEMA report, i
and Boston Edison submitted the first draft of the Action Plan l
to the NRC on September 17, 1987.
We reviewed the utility's l
Action Plin which was forwarded to the NRC and support Boston Edison's stated goal of completing plan revisions as soon as l
possible.
We think that it is useful to establish goals and objectives to guide planning.
However, as this progress report long way to go.9 demonstrates, the planning process has a 1
S or example, the NRC has yet to receive from Boston Edison a final copy of f
t the utility's proposed restart plan. A second revision of a restart plan was i
submitted to the NRC by Boston Edison on October M,1947, and was transmitted to da on November 12. We are awaiting receipt of the final version of the seterial and will review it thv oughly as soon as it la available to us.
A i
third party expert evaluation of this plan la under consideration. 4 i
l 1
l i
. ~
8 V.
STATUS OF SPECIFIC BOSTON EDISON ACTION ITEMS A. Manaaaaant Inaues 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 Assemament of Licensee Performance" (SALP) reports, which thoroughly review a variety of characteristica indicating management performance.
The latest SALP report for Pilgrim Station was inaued by the NRC on April 8, 1g87, and evaluated utility performance for the period November 1, 1985 through January 31, 1987.
l The SALP report analyses 12 performance criteria,,
assigning a grade of 1, 2, or 3 for each criterion.
Category 1 l
is the best grade and indicates that reduced NRC attention may i
be appropriate.
Category 2 indicates that NRC attention should i
be maintained at normal levels.
Category 3, the lowest grade, indicates that both NRC and licensee attention should be j
increased.
The April 8, 1987 SALP report indicated that management of Pilgrim Station was not good and had, in fact, 1
)
deteriorated in certain respects since the previous SALP covering the period October 1, 1984 to October 31, 1985.
j In the 1987 report, teaton Edison received two Category j
i grades, five Category 2 grades, and five Category 3 grades.
]
For three criteria in the 1987 SALP, Boston Edison received l
J lower grades than for the previous reporting period, for two l
criteria the grade increased, and for three criteria the grade l
remained unchanged.
The four remaining criteria had not been I
separately evaluated previously.
These results are cause for j'
concern under any circumstances but particularly in light of l
the fact that the plant was shut down during most of the l
lj, inspection period.
l f
Since December, 1986, Boston Edison has reorganized ita 1
P11 grin management and has hired a number of individuals to fill key positions.
Most notably, Boston Edison has hired a
ll new Senior Vice president, Nuclear, Mr. Ralph Bird, who reporta l
i; directly to the company's chief executive officer.
Mr. Bird l*
was recruited from outside of the Boston Edison Company.
The I
new Senior Vice President also serves as the Vice President for Muclear Operations and personally supervises all activities I'
pertaining to Pilgrim Station.
Under Mr. Bird's direction, other positions relating to 1
the safe operation of t,he reactor and to emergency planning j
have recently been filled by professionals recruited from
)
outside Boston Edison, and a few Boston Edison employees have been promoted to fill vacancies.
The followitig other key 4Il management positions have been filled by recruits from outside
!j the company:
!* :f l
i
~ - - - - - - -. ~,
-- Executivo Aoolotent to tho Ocnier Vico Frcoident,
}
- Nucleer, l
-- Director of Planning and Restart,
-- Emergency Planning Assistant to the Senior Vice
)
President, Nuclear, l
I
-- Operations Section Manager,
- $ Nuclear Security Group Leader,
-- Fire Protection Group Leader, and
-- Radio)ogical Section Manager.
In addition, the Director of Outage Management was promoted to l
Plani Manager in early 1987.
)
a i
While there are indications that the new management 1
organization and personnel may be taking more effective control j
of Pilgrim Station, recent events suggest that Pilv ia Station t
r j
continues to have serious management problems.
The NRC la 1
conaldering a fine against Boston Edison for failure to i
]
implement plant security procedures, and there have been i
reports of critical plant personnel working excessive f
over-time.
We also have concern over the way a decision was i
implemented to disengage one of two emergency generatora during I
a period when Pilgrim station lost access to off-site power on 1
November 12, 1987.
I i
)
In addition to these issues, the Senior Vice President i
of Boston Edison ordered all work on the Pilgrim reactor and 1
l ayatens halted after eight individual work related problema l
j occured over the weekend of November 7 and 4, some of which l
were similar to problems which have recurred at Pilgrim Station l
over several years.
Four of these problema resulted in the i
1 on-alte release of radiation and slight worker contamination.
- two of the problems were related to security.
i The security violations are.of particular concern t
i because in the 1947 SALp report "Security and Safeguarda" had l
deteriorated from a Categcry 2 to a Category 3.
Officials of
{
Boston Wdison have met with the NRC to explain their remedial i
actions concerning plant security.
We have aaen no official
]
report on the question of over-time worked by personnel l
}
detailed to critical safety aspects of Pilgria Station, Boston Edison public information officers have indicated that five I
percent of the Pilgrim work force is authorized to work more i
i than sixty hours per week.
Since there are presently more than
)
4 four thousand people employed at P11gris Station, a significant
)
number may have been working long and perhaps excesolve hours.
I
{
In view of Boston Edison *a long history of management j
failure at Pilgrim Station, we feel that austained management j
of the nuclear facility at a hi*h level must be demonstrated g
I before the plant should be allowed to restart.
Eventa of the past several months raise more questions than they answer and I
make it more imperative that, in addition to other safety
]
requisites,we have objective evidence of sustaaned performance j
at tns highest level of qualf,ty, including but not limited to 1
9 top grcdoo in tho n xt SALP rcpsrt, betcro rootort, Cv0n though the next SALP report will not reflect evaluation of actual on-line operation of the reactor.
i
- 3. 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 Decem5er, i
1986, the nuclear industry has continued its inconclualve debate on the integrity of the Mark I containment structure.
We do not expect that this inaue will be settled soon by the j
i MRC.
t l
The Nuclear Regulatory Commission la developing a "Draft Generic Letter" on reactor safety and the Mark I containment structure which will identify plant-specific i
analyaea necessary to implement the NRC*a "Severe Accident
]
Policy Statement."
However, no letter has been released and theru la presently e;.,iedule for its publication and, 1
j therefore, no way se
.es.s the adequacy of or estimate the i
time it will take to implement the NRC*a ultimate recommendations.
The NRC has been conaldering this matter for 1
more than a yaar and has discussed structural improvements a nd l
other operating concepts for Mark I units with the toiling i
Water Reactor Owners Group.
Absent specific federal requirementa and guidance, l
l Boston Edison la implementing a "Safety Enhancement Program-(SEP) to improve reactor safety for P11 grin Station and 1
includes both emergency operations procedure improvmants and
)
equipment modifications.
The utility has indicated that they have spent approximately s30 million on this program.
One key l
element of the equipment
- modifications la installation of a direct torus vant.
Boston Edison han indicated that the.' are b
prepared to complete instalation of the torus vent as soon as I
they are so authorized by the NRC.
I According to Boston Edison, the torus vent, if i
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 satter and release radioactive gasses to the environment.
The release of these gassoa, by relieving the containment pressure, would prevent a rupture of the containment structure and the subsequent release of aure damaging solid and liquid radioactive meterials.
In theory, a gaseous radioactive plume 1.
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 J
atructures.
l l
l 1 - - - - - -
There arc, however, conflicting vicwo Cn whethOr o direct torum vent would provide effective containment pressure relief in the event of a' rapidly developing accident.
Therefore, it must be demonstrated that the direct torus vent would significantly increase public safety under certain accident scenarios.
C. Po11cv Issues Reaardina the Torum Vent The torus vent introduces a vital policy question.
Under what and whose authority can one plan in advance to make 1
use of the vent?
Activating the vent would result in the release of a gaseous radioactive plume.
Thus, if the equipment i
la installed and a severe accident does occur,.ho may arthorize torus venting and the subsequsnt radioactive release?
The utility la 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 regulaten utility execution of these responsibilities.
However, state and local government share exclusive rempor.aibility for the protection of public health and safety for all areas beyond the boundaries of the power statLon.
Boston Edison han not installed the torus vent, pending direction t' rom the NRC.
It is our understanding of the NRC licensing scheme, that it would be necessary to amend Pilgrik's operating license befoe a torum vent could be installed.
Such an amendment would involve "significant hazarda considerations" and, as auch, would require that a hearing be held prior to thw l
J amendments authorization.
If the NRC authorizes installation, if any -- the Commonwealth can or it la not clear what role should play in that decision.
If the vent la installed, with l
or without concurrence from state authorities, a question l
arises that the state will have to resolve as to what authority l
is available to state officials to advano for or against venting during a severe reactor accident.
It la presumed that genes can be held in the containment ayaten for a period of time before venting.
During this period, state officials muut decide the beat protective l
action for the public, either to shelter or evacuate, based upon accident noenaments made by the state Department of public l'ealth and the utility.
The length of time that gasses can be l
held and the expected duration and composition of the release, i
when compared to the axpected evacuation time, the shelter i
available to the population at risk, and the time it la expected for the effected population to take to shelter, will l
j asterkine the most appropriate action.
I Thus, state officials aunt at least coordinate l
implementation of the best protective action with the containment venting.
Before the NRC authorizes Boston Edison j
to install the torus venting system, there should be.an _
s J.
evaluation of these policy matters snd what if any rolo ototo agencies and officials can or will take in the event of a severe accident at Pilgrim Station.
This proposal raisen auch significant safety issues that a public hearing should be required so that the Commonwealth would hcve an oppcrtunity to express its opinions on the matter.
During the September 24, 1987 meeting t.
w Baaton Edison and the NRC, Dr. Murley of the NRC indices.
.t he still had reservations about authorizin, torus ven instalation.
Dr. Murley stated his reservations <
t authorizing installation of the torus vent in a 16 cer 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 Piloria-Soecific_Probabalistic Risk Assessment i
It is important to note that un' oil a plant-specific j
"Probabalistic Risk Assessment" (PR.*.)
is available for Pilgrim Station, it la impossible to determine the relative level of risk of a severe accident at Pilgrim Station and the dominant l
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 ayatema conducted to ascertain the sequences of events that could lead to a severe accident.
Given that every nuclear l
power plent 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 l
as to teolate the specific vulnerabilitics of each plant I
Although the NRC recognized that plant-specific design f
and equil-snt characteristics are important factcra 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-1150 program performa PRAs for representative reactor and containment types.
In the case of l
the General Electri: Mark I type plant, the NRC relies 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.
l Although I am informed that the Pilgrim PRt. As under j
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 asses < its results.
l
. i l
- s J.
VI.
STATUS OF SPECIFIC OFF-SITE Ef!ERGENCY 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 Defer.se 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 towarca 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 plans exist in part for each of the five Ep2 communities. In some cases, the draft revisions are up to 854 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 Emerguncy Management Agency for informal technical review.
FEMA's assessment will provide an independent profcasional assessment of plan adequacy.
- However, the Commonwealth has the responsibility to make our own final 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.
i A.
Evaeustion Time Estimate and Traffic Manecement plan In our Report to the Governor, we recommended that Boston Edison, "proceed with all rispatch to complete the preparation of a new Evacuation Time Estimate study."
Boston Edison commissioned the New York firm of MLD Associates to prepare a ncw Evacuation Time Estimate (ETE) and Traffic
^
Management Plan for the Pilgrim area.
An Evacuation Time Estimate (ETE) is essential as a j
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 Decembar, 1986 was produced in 1979, based upon 1970 census data, and was inadequate.
On August 8, 1987,'
8 Boston Edison transmitted to us a new ETE and traffic management plan, and revised pages were received on September j
8.
Although we have not yet completed review of the new ETC j
and have many reservations about it as discussed below, it is a significent improvement over previous material.
1 l
s Since the revised pages waro recoived, o took forco of state employees has met regularly to review the ETE and traffic management plan.
The charge to this task force hos been to evaluate whether the traffic management plan upon which the estimates of evacuation times are based era reasonable and feauible, and to determine what resources are needed for its succesful implementation.
If the traffic management recommendations cannot be implemented succesfully, the eatindted 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 udequate resources to implement the traffic management plan.
Therefore, the clear times in the ETE cannot be achieved.
For instance, the Massachusetts 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 area.
Officers of Troop D have indicated that they would not normally have sufficient personnel available to implement all of their actions in a timely manner.
Troop D is continuing to evaluate available personnel against personnel needs as documented in the ETE.
In addition, Troop D may not have adequate radio frequencies and hardware to manage emergency communications.
This is especially true because of the expected high volume of emergency communications during a nuclear accident and the need 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.
l It may be necessary to have a mobile command post available 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.
f 1
All of these findings are re#2ected in a memorandum j
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 j
to implement an orderly and prompt evacuation.
These devices include traffic cones, traffic barricades, warning lights, and special evacuation route signs.
The State Department of Public works is evaluating the resources it has available against the requirements documented in the ETE.
The DPW can draw upon its resources state-wide, however, it is not yet clear how long it would take to deliver all required material to the EPZ.
The recommended resource requirements in the ETE include'364 cones, 389 barricades, and 203 warning lights.
t State and local police agencies and departments of public works l
have been asked to evaluate these recommendations based upon their own experience.
However, it is necessary to assure a
i
-2o-l j
--n-,_
,,,--,,,,,.,n..
,,c-__.--
9 delivery times for these rocourcon boforo cno con bo occured of adequate plan implementation.
The State DPW only has emergency mobilization procedures for snow removal and certain highly localized events.
These procedures muy 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 materialelivery times can be verified.
An examination of the details for traffic control points indicates that very few are recommended to be staffed by more then one traffic guide.
However, for many of these points, the guide must fulfill several functions, including directing traffic in the recommended pattern, answering questions for vehicle occupants, 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 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 possible that the personnel requirementa -- especially for local police officers -- of the traffic management plan eru 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 comments and observations.
As of this date, we have not received comments from any local Jurladiction.
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 i
evacuation trip.
Further, the need for supplementary transportation resources, including ambulances, buses, and chair vana must be established and their mobilization, arrival, pick-up, and total travel times must be eatinated.
The new ETE goes into exhausting detail to document traffic demand estimation.
However, certain ensumptions and findings remain open to question.
In particular, the estimated population at the EPZ beaches and ponda is a critical issue not yet addressed to our saticiaction, and the estimated 10!n addition to EPZ and host communities, traffic a$d access control reccomendations must be implemented by the communities of Pembroke, Hanson, Malifax, Plympton, Warehen, tourne, Sandwich, and traintree.
l l
. e transportation rcquiroccnto for pocplo with opscial nocdc must be examined further.
The ETE estimates that peak use of area beaches and ponds 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 c.ppear 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.
Representatsves of the state Office of Handicapped Affe. irs 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 th,e Ep2's special needs populations.11 Nonetheless, the Boston Edison survey has provided more information on special needs requirements than has been available previous 1f.
However, it is 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 perhaps be done through a further survey, through a statistical analysis of the general population, or some combination of these methods.
With a better knowledge of the requirements for ambulances, chair vans, and buses for people r6 quiring special transportation assistance, we will be able to determine if the ETE has i
properly estimated the evacuation times for this population.
An estimation of available resources to assist people with special needs is being undertaken as a part of Phans II of the three phase planning process.
Until that evaluation is complete, we cannot say if adequate resources are available.
11The Boston Edison survey any not have reached all residents of the EPZ and was not worded in a way to elicit a respo'se from all people who might n
need eseistance in evacuating or taking shelter..
k
-v,.----.-.
_-,..y_. - - -,. - -
_y_
Ono brood cancidoretion which 10 not cromincd by thic 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 timely manner.
However, there is no basis for this assumption and the failure to properly man and control a "priority 1" traffic control point can have a profound effect on traffic patterns.
Further, a major 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 ma3or evacuation routes, such as Routs 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 Massachusetta.
We are particularly concerned about the matter of Winter storma 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 abould more extensively document expected evacuation times during severe storms.
i The ETE is computed from highly complex traffic modeis which are beyond the understanding of all but the most knowledgeable professional specialista.
Professionals employs 4 by the State Department of Transportation's Central Transportation Planning Staff have done a review of "I-DYNEV,"
the model developed and used by the firm preparing the ETE.
CTP1 is continuing to review the model and its results based upon information supplied by consultanta who examined I-DYNEV for the Seabrook adjudicatory process.
A letter from CTPS stsif shows that they do have certain reservations about the Pilgrim ETE modeling, see appendix aeven.
At the present time we are not prepared to determine if the new ETE is an adequate baala 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 ll independent third party expert in evacuation modeling.
I o
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._w
B.
Shelter as a prot ctive retion Our report recom;mnded that Boston Edison "commission a comprehensive shelt er sur voy."
In the event of an accident at Pilgrim Station, there er a two main actions which can be recommended to protect th e public: evacuation and shelter.
In order to* assure that the public can be adequately protected, it is nscessary to establish two indings in regards to shelters that, a) the highly vulner(51% beach population can take adequate protective cover ir. the event of a rapidly escalating accident with an early rolesc' of radi.ation, and b) that each Ep2 community can provide adeqsate protective shelte.r for the resident and transient populat1>' seeking assistance.
On August 20, 1987, Boston 2dison delivered to MCDA/OEp a shelter survey which was reviewed by agency staff and found to be deficient in several raspects.
For example, tha survey was completed only for areaa 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 Ep2 community can develop "Shelter Utilization Plana." Until shelter utilization plans have been developed, it is impossible p rotective action has been addressed.
to say that shelter as a Shelter utilization plans are especially important for beach areas.
They must considor not just the available shelter space, but the time it will take people in reacte beach areas to reach adequate shelter.
Duxbury beach is approximately seven miles long and portions of plymouth beach is as much as 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 comr. unity has had the opportunity to develop a shelter utilization plan, this inaue remains an open and deficient planning topic.
I C.
protective Actions fer people with Special Needa l
I Among the planning inauen discusand 19 my marifer report,,none demand more attention than provisions for people with special needs.
This population may include the elderly g
and the infirm, people who are mobility imp. red, visually g
4 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 attentton in 1
three main croco of rcdiologicci osargency rocpenoo; clort cnd notification, evacuation, and reception and long term shelter.
In response to this topic, MCDA/OEP organized an informal task force of representatives of several state agencies which represent special needs constituencies and The task representatives of local special needs agencies.
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 on<s of the first actions under the new Nuclear Safety Emergoney Preparedness Program, MCDA/OEP has formed a formal task force to address eastgency 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 statistrual i
analysis of expected special needs in the Pilgrim EPZ and the resources which will be needed to fulfill those needs.
The is also examining the need for a further survey of task force individuals with epecial needs.
Based upon the estimated demand and resources needed for providing emergency notification to, and t?cansportation 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 urable to hear sirens or route alert loud hailers which will no',1fy the public of a severe accident.
Further, they will have diificulty communtcating with emergency facilities and public safety personnel.
The task force met with representatives of Boston Edison and urged that t5e utility install teletype equipment in each town warning point so that there cauld be immediate and ex'fective communications with the deaf population throughcut the EPZ.
The utility has agreed to make teletype equipment ave!)skle 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 recommend.3tions, but it is not yet known when all equipment will be installed in
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'f town warning points, when training will be provided to all shifts of local town warning officers, or how many teletype j
units have been distributed throughout the EPZ.
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Following my December, 1946 report, MCDA/OEP took the initiative of forming a group of state egencies 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.act.ive 1
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involvoocnt in this effort, in June of 1987, Booten Edicen undertook a survey of specir' naeds people without the knowledge, advice, or particavation of any state ageacy 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 renponse of about 1,400 ir.dividuals, have been provided to the State Director of Civil Defense and are subsequently being turned over to designated public adfaty representatives in each of the five EPZ communities.
This information would also be useful in and available for response to othtr life threatening situations such as a chemical spill.
It is the policy of state public safety officiali. that every individual in the EPZ be given the opportunity to identify him or herself and his er her need.
However, it*may not be necessary or even prudent to compile exhaustive lists of special needs populations.
What is most important is to he<w an understanding of the dimensions of the special needs population and to be prepared to provide the variety of alert and notification, transportation, special services to the numbers of people expected' to medical care, et cetera need assiste.nce.
D. Medical Services for Radioloaical Victims Whilo not specificelly addressed in our December, 1986 report, a recent Guidance Memorandum from the Federal Emergency F,anagement Agency 12 has focussed attention on the topic of medical services for people who are contaminated by radiation had physically injured, for people who have ingested radioactive material, and individuals who are severely irradiated.
The issue is receiving more serious public i
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 adequnte medical facilities are available to meet the demand after a savore accident at any of the nuclear power facilities in Nes England, even though federal regulctory 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 Gui6anct Memorandum MS-1.
12 EMA GM MS-1, "Medical Services." Washington, D.C., November. 13, 1986.
F,,
The Massachusetto Dopertacnt of Pubide Hoolth's Radiation Control Program is responsible for maintaining the handbook of the stcte 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 irradiati,on or who era contaminated and in3ured.
The list includes < Me treatment capacity of each facility.
DPH is also responsible for certifying hospitals for treatment of radiation victims.
E. Esercency 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 provAde 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 indit sted in section VI.C.,
Boston Edison has indicated that they will cemply 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 loos, to assure that provisions have been made for emergwr.cy communications with the profoundly deaf.
F. Procedures for Protection of School Aced Children As noted in our report to the Governor, procedures for i
the emergency response of schools were weak or non-existant in earlier versions of the Pilgrim plans.
This is a matter of the gravest ccncern, 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 definitiva plan on alert and notification, shelter, and evacuation.
Since planning fcr response by schools is e peculiarly local matter, deveAopment 1.
1
of these plans has been o rocponcibility of iccol o.chool and public safety officials, working with their town planning committee and school officials.
However, staff of MCDA/OEP the will provide assis+4ncve throughout the process and review plans for adequacy and effectiveness.
Planning for protection of school children is based upon identifying an adequate number of buses and drivers to assuro evacuation with single bus trips.
In the event of an evacuation children would be taken to e designa+.ed reception remain in the care of school personne1 until the center and child is reunited with his or her family.
parents of school children will be notified anr.us11y 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 EP2.
Regular and coordinated train.ag programs 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 the planning process that teachers will respond in a professional manner, remaining with and not abandoning the children who have been given to their care.
Phase 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.
l G. Erocedures for Soecial Facilities The development of adequate special facilites procedures has been a major goal of Phase II of the three phane process implemented by MCDA/OEP in cooperation with local officials and supported,by Boston Edison.
Boston Edison has done en inventory of special facilities in each of the five EPZ 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.
l The Phase II work of discussing plans snd procedures with the operators and responsible efficials of special
- a the town of Plymouth, facilities is only Just bogining.
j alone, nearly fifty speciol facilities have been identified.
Iach local civil defense cirector working with the town's j
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planning committee will be reviewing evacuation and early I
closing plans and procedures with the superintendants of their l1 ochools.
Hospitals 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 t.cining for the personnel of special facilities on their roles and responsibilities in emergency response and a review,,of I
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these plano will bo o p rt of the picnning precoco.,
H. Provision of Eneraency 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 publie..., 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 informs us that they will delay their annual distribution until December.
Boston Edison has taken one step to broaden the reach d
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 additieaal information.
MCDA/OEP arranged for a meeting between members of the state spcial 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 l
discussed in the end of section III of this report.
One of the most critical issues wh>ch must be fully addressed prior to distribution of a final EPI brochure is procedures for assisting special needs populations.
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I. Resources for Emeraenev Resoonse i
In my December, 1986 report, it was noted that plans
! I for response to an accident at Pilgrim Station lacked evidence I
of the ability to provide sufficient emergency resources on a d
i timely basis.
In particular, it is necessary to demonstrate that an adequate number of buses, ambulances, and che'ir vans will be available for all transport dependent persons, and that these vehicles will be available in a timely manner to support i'
a safe evacuation.
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V Boston Edison is conducting a survoy of c11,privoto transportation companies in southeastern Massachusetts to oetermine what vicarious transport resources are'available nearby.
Individual agrearents must be negotiated with all operators of buses, ambulances, and chairvans to make availeble their equipment and drivers to the EP2 communities in support of response to a nuclear accident.
This process must also identify an adequute 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 revian 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 assurance.
However, we feel that adequate + raining will help reassure drivers of their safuty in emergsney response.
The state, with the support of Boston Edison, will provide training in persons 1 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 MCDhvoEP training officer, and the training will be offered as a part of Phase III of the agency's three phase process for revising the Pilgrim plans.
J. Reception Centers Replacement of Hanover Mall as e reception center for the northern portion of the EPZ remains one of the most difficult pending issues regarding off-site emergency response for an accidunt at Pilgr.im 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 acco'. ding to Boston Edison officials.
This study will determine what physical alterations must be made, what equipment must be provided, and what additional 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 acurai.e and if its recommendations are reasonable and implementable.
Based upon the study and upon other
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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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Thoro io no fedoral er ototo rcquircocnt for throo reception centers for ths Pilgrim EP2.
Federal guidance states only that reception and radiological monitoring services be provided for up to twunty percent of the total EP2 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.
i X. Piloria Restart Process Since Pilgrim Station remains shut down under a confirmatory action letter by the U.S. Nuclear Regulatory i
Commia. ion, 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 wt?4 not seek permission from the NRC to restart Pilgrim until approval i t. fitat received from the company's board of directors.
Moreover, the NRC Region I staff has indicatcd that en intensive on-site inspection will be conducted and evaluated before any cecision la made to recommend restart.
Ultinately, 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 adjudicatory hearing in the EPZ while the NRC has recommended only that they hold public meetings.
We will l
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 Filgrim Station until a full adjudicatory hearing is conducted.
The NRC has not indiceted what consideration will be given to off-site emergency prepardeness in their restart deliberations.
This is very troubling.
When the rules and guidance regarding emergency planning were first issued in l
198J, planning was said to be as critical to safety an engineering to the extent that the NRC declared that emergency planning inauen 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 a13 seisty issues have been fully resolved, including sustained improvement of the nuclear management as demonstrated through, among other
.ndicators, the highest grades in an NRC Systematic Amassament of 1.icensee Performance, implementation cnd cocpiction of a reset.y safety program which satisfies all questions regarding the Mat.- I esntainment, and developmait of adequate off-site radiological emergency response plans.
We also feel that a succesful graded exercise of all off-s\\te plans and facilities must be held, and that the NRC must hold a fu21 adjudicatory is hearing 91 thin the Pilgrim EPZ before P/.lgrim Station authorized to restart.
The process which lesda to the satisfactory resolution of all of our safety concerns cannot succeed without a cooperative effort of state and local officials, the Boston Edison Company, and federal regulatory authorities.
Date Charles V.
Barry Secretary of Public Safety e
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APPENDIX ONE
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In tt.c Year One Thousand Nine Hendred and Eighty-Seven.
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a er before December first. nineteen hundred and eighty-seven, detailing the activities undertaken with regard to AN ACT MAKING AN APPROPRIA110N FOftTHE FISCAL YEAR ENDING JUNE this line item; and provided forther, that no expendienres TillRTIETit. NINETEEN HUNDRED AND ElGitTY.EICIIT.TO PROVIDE FOR
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SECTION 3. This act shall take effeet upon its passage.
Couri assembled. and by the outherity of the same, asfollows:
I SECTION I. To provide for supplementing a certain item in 2 the general appropriation act, the sum set forth in sectioh two 3 subicet to the provisions of law regulating the disbursement of 4 public funds and the conditions pertaining to approprhtions in
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- g p pm y 6 hundred and eighty-seven. for the fiscal ycar ending June thirtieth, 7 nineteen hundred and eighty-eight, the sum so appropriated to
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I SECTION 2.
EXECUTtvE OFFICE OF FtJBtJCSAFETY.
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... O.dDr/ense Areary 80004t00,' #Fer~in'nestM pertaleing se reselear safety emergency I
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the rescal year as provided by the departmens of pobhe siirnies e d shou hr eredmed e she seecr=I foad8; previded feether, saias feeds approprissed hercia may be spent for the developeras and evalenties of redaclogical emergemey response ptses for merlear 3-acrating y!.ats licer.acd to ope ase et fes power and located wishin the commen-weakh; provided forther, th-J in me case miay fonds from 8
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APPENDIX TWO i
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THE COMMONWEA1.TH OF MASSACHUSETTS IF8c' l c EXECUTIVE CEPARTMENT h
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July 24, 1987 Mr. Edward A.
Thomas, Chief Natural and Technological Hazards Division 1
Federal Emergency Management Agency John W. McCormack Post Office and Court House l
Boston, Massachus,etta 02109
Dear Mr. Thomas:
This la to advise you that in accordance with Massachusetta law, St. 1979, c.
796, codified as Massachusetta General Laws c. 33 Appendix, section 13-2b, and federal regulations, 10 CFR 50.47 and 44 CFR 350.7, the Commonwealth of Massachusetts has determined thut the plume exposure pathway emergency planning zone for the P11 grin Nuclear Power Station
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abould be reconfigured.
The ruconfigured EPZ will include the entirety cf the i
towns of Carver and Marabfield, both of which preacntly have only a portten of their Jurisdiction within the EP2.
Accordingly, baassd upon our analysia of local conditions and i
geagraphical boundaries, the history of off-site emergency planning at Pilgrim Station, and our conss.leration 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 uttended by repreae'ntatives of this agency, the F.xecutive Office of Public Safety, the U.S.' Nuclear Regulatory
- Commission, and the Boston Edison Company.
As discursed at the July 14 meeting, it la also our intention to dealgnate other towns which have a portion of their geographical territory withJn ten miles of Pilgrim l
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Thio dooignotion will toko pisco efter we have completed consultation with each of the concerned
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communities.
Thank you for your cooperation with this very important matter.
Sine ly, Y
obert J. BouTay Director Assistant Secretary Peter W.
Agnes, Jr.
cc:
Deputy Director John L. Lovering Assistant Commissioner Gerald Parker, NDPH Mr. Ralph Bird, Boston Edison Company Area II Director Rodger Mr. Al Slaney, MCDA Area II Chief Executives of Carver c.nd Hershfield Civil Defense Directors of Carver and Marsh. field 9
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P o. soa um FRAusNGHAM.WAS4 4170143t7 ROBERT J. BOULAY MICHAEL S. DUKAntS twatetca covtamoa e
July 24, 1987
'Mr. William T.
Russell, Administrator U.S. Nuclear' Regulatory Commission, Region I 631 Park Avenue King of Pruania, Pennsylvania 19406
Dear Mr. Thomas:
This la to advise you that in accordance with Massachusetta law. St. 1979,
- c. 796, codified as Massachusetta General Lawa c. 33 Appendix, section 13-2b, and federal regulations, 10 CFR 50.47 and 44 CFR 350.7, the Commonwealth of Massachusetta han determined that the plume exposure pathway emergency planning zone for the Pilgrim Nuclear Power Station should be reconfigured.
The reconfigured EPZ will include the entirety of the towns of Carver and Marshfield, both of which presently have EP2.
only a portion of their Jurisdiction within the Ac-ordingly, 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 officiais, we request that you acknowledge this determinatior,.
On July 14, 1987, we held a consul'tation 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.
An discussed at the July 14 meeting, it la also our intention to dealgnate other towns which have a portion of near geographical territory within ten miles of Pilgrim
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This designation will take plces Station asnave completed consultation with each of the concerned after we C.
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Thank you for your cooperation with this very important matter...,
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Agnes, Jr.
cc:
Deputy Director John L. Lovering MDPH Assistant Commissioner Gersid Parker, Mr. Ralph Bird, Boston Edison Company Area II Director Rodger l
Al Slancy, MCDA Area II Mr.
Chief Executives of Carver and Marahfield Directora of Carver and Marshfield Civil Defense e
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Dear Mr. Boulay:
In your letter of July 24, 1987, you requested we acknowledge that you have detertnined the plume exposure emergency planning zone (EPZ) should be reconfigured for.the Pilgrim Nuclear Power Station to include the towns of Carver and Marshfield in their entirety. We subsequently understand that this reconfiguration has now been deferred to enable priority attention be given to l
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your ongoing efforts with the current EPZ comunities, the Boston Edison l
Company and FEMA in improving emergency planning and preparedness within the l
current EPZ. We encourage these efforts to improve energency preparedness.
i Sincerel,",
1 William T. Russell Regional Administrator i
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I E. Thor.as, FEMA !
R. Bird, Beto 4
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11UCLEAR POWER PLA11T REAL TIME mot 1ITORIt1G SYSTEM (TELEMETRY)
Ihe Massachusetts Department of Public Health is investigatino the feasibility and usefulness of a real time monitoring system for nuclear power plaG s which would involve the transi.:f ssion of onacing radiation levels et selected locations within the boundaries and off-site of nuclear power plants to a State facility.
This system would allow a State agency to know immediately if and when radiation was released into the environment.
Presently only the State of Illinois has a comprehensive real time telemetry system in place.
Most of our information han been received from Illinois and the cost estimates are developed based upon figures obtained from the manufacturer of the equipment used in this system.
The program in Illinois involved approximately six years development time and once in place needs constant
- a. t te n t ion.
Since the state-of-the-art in this area changes rapidly, the equipment must be constantly up-dated, modified, or replaced.
The Illinois Department of tiuclear Safety's Remote Monito:ing System (RMS) incorporates three major components:
gross gamma detectors radially positioned around each nuclear power stations on-line auto-mated, isotopic caseous effluent monitors which sample fron maior engineering release points; and an on-line reactor parataetar data com-munication link to each facility's on-site computer.
In addition, on-line liquid effluent monitors, which will be located at each plant's liquid discharge points, are scheduled for installation at two sites within the next year.
All RMS components are connected throuqh dedi-cated data communications Hisks to the Illinois Department of fluclear Safety Radiological Emergency Assessment Center (REAC) located in Springfield, Illinois.
At the REAC technical staff, comprised of nuclear engineers, health ohysicists, and otnet nuclear safety spe-cialists review the data and perform analyses of plant conditions.
This REAC staff is divided into two analytical groups, one concerned with the status of reactor safety systems and the other with environ-mental assessment.
An estimate of the cost of a monitoring system similar to the existing system was obtained from Reuter Stokes in Cleveland, Ohio.
The following is an estimate for a basic system for a single power plant which would allow Massachusetts to add on as needed or as new tech-nology becomes available e
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Breakdown of Costs Remote Sensor
$16,000 16x16,000
$256,000
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Computer
$100,000
$100,000 (This computer should be able to handle up to 64 remote sensors)
Spare parts
$18,00J.
$ 18,000 Installation per
$'12,000 16x12,000
$192,000
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ser.sor knone charges
$2,000/ronth 12x2,000
$ 24,000
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Personnel
$150,000
$150,000 (one of Each -
Scientist, Electronic Engineer, Computer Operator, o Clerical)
Calibration
$400/ unit 16x400 6,400
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Maintenanct & Repairs
$30,000
$ 30,000 Total Estimated Cost
$776,400 (Per power station per year with 16 remote sensors)
It should be noted that each power station in this country that employs this telemetry systen has had 10-16 remote sensor stations.
Outside of the U.S. (e.g. Finland or Korea) an average of 10 is com-mon.
The State of Illinois estimates that their cost of the telemetry system average calls for two million dollars / reactor.
This was due to the cost of development of the system, as well as the fact that the cost of the remaindar of the R'adiation Control Program was included in their budget process.
The Massachusetts' estimaten above are based on a proposed program for monitoring a. single nuclear power plant.
Information sheets on the Illinois emergency planning and assessment activities are attached.
spjd Attachments (5)
D
THE ILLINOIS PLAN FOFi RADIOLOGICAL
/
y ACCIDENTS s.
The Illinois Plan for Radiological Accider;ts (IPRA) details the program for state wide, integrated management of nuclear accidents, especially those which might occur at a nuclear power reactor. The primary purpose of the Plan is to provide a coordinated response by state and local governmental officials for the protection of the citizens of Illinois. The Plan includes:
general planning to cover the urgency of any nuclear accident; site speelfic planning to protect citizenstliving near nuclear plants; a concept of operations so that the Plan can be effectively carried out; and an effective allocation of resources and personnel.
The Plan pre assigns the dulles and responsibilities that would be taken by all the respondents to a nuclear accident, thus enabling actions to be made quickly and ef ficien tly.
The Illinois Department of' Nuclear Safety (IDNS) and the Illinois Emergency Services and Disaster Agency (lESDA) share the responsibility for developing the Plan.
Spee!!!cally, the IDHS is responsible for the technical functions of thlm effort, and the IESDA is responsible for the operational aspects.
The Plan Is-updated annually for accuracy, and appropriate components are distributed to 18
- state, 10 county, and 37 municipal organizauons in Illinois, as well as to appropriate organizations in the contiguous states of los r sad Wisconsin.
v Major operations specifled in tiu Plan include:
o Accident Classification.
o Operational P.esponse Level.
o inillal Notification, o Accident Assessment.
o Command and Coordination Responsibilities.
o Protective Actions:
Sheiter; Evacuation; Traffic and Access Control; and Food, Water and Milk Control.
o Parallel Actions:
Public Informationi Radiation G) c wa Control; Law Enforcement and Crime Prevention; Fire 2 w Rescue; Emergency Medical Services; Social Services; a n.,
Re entry.
o Operation Centers: Location and Responsibilities.
o Notification of the Public.
o Emergency Announcements:
Information, Shelter, and Evacuation.
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"'ElEM.1T *.Y [SEUEi
RADIOLOGICAL EMERGENCY ASSESSMENT CENTER e.
The Radiological Ernergency ' Assessment Center (REAC) in Spri qfield !s the command center for the lilinois Department of
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Nuclear Safety in the event of a nuclear emergency occurrink in the State of lillnois.
REAC houses the custom detilgned, state of the art integrated computer system which continuously identifies and measures all radioactive components being released by nuclear facilities into the environment.
The REAC Commander, supported by a highly trained and experienced technical sta f f, directs the implementation of all tasks associated with the radiological aspects of a nuclear incident.
Support features of the REAC computer system include:
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o Computer Room, 24 liour Radio Commun!cetions Center, Commender's Office, and Emergency Command Center.
o Dedicated air conditioning, emergency standby generator, and special power conditioning to maintain operability c Ing a potential power failure, o Ei, computer graphics monitors to display engineering dra.,ngs, color maps, graphs, and charts.
o A giant screen projector used to provide a seven foot wide Image for large group presentations.
o Status boards to record the changing technical conditions of each power station and in the immediate environs, o Maps of the 10 mile and 50 mile Emergency Planning Zones for each renctor.
o Radio r.
N capable of communication with emergency i
field 1: we
.e,nd nuclear power teectors.
- s' o Forty channel tape recorder for permanent records of all communications.
o An extensive technical library of controlled documents including detalled operating procedures and design features of each Illinals nuclear power station.(Includes over 50,000
- i engineered draw!ngs).
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FIM Di@Il i$
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REACTOR PARAMEiER DATA l.lNK The Illinow Derertment of Nuclear Safety (IDNS) has installed a direct data canmunication link batween the Department's central computer and each nuclear reactor's control room computer for the monitoring of nuclear power reactors and their safety systems.
This DNS Data Link (DDL)' was developed for early notification of events that could lead to nuclear accidents.
DDL is an essential element in providing continuous plant safety assessment, early detection of abnormal conditions, and evaluation f nuclear plant transients.
Tho DDL signals received in the Radlolog) cal Em' erg ency Assessment Center (REAC) are the same signals evallable to the r.uclear piknt personnel on site.
The Department selects particular parameters to be transmitted to REAC from an Index containing all available plant system Informatlun.
Parameters selected by the Department provide detailed information on the operating characteristics of all essential plant safety systems.
Major features of the DDL Include:
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4 o 1000 1300 parameters (eignals) per reactor transmitted i
every two ulnutes.
J o e reactors currently providing data and 4 additional l
reactors to submit data prior to commencing operation.
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o Technical parameters includs:
reactor power levels, i
reactor water levele,, steam generator water levels, l
coatsinment temperatures, engineared safety system availability, and essential pump flow rates, I
o System software ior displaying either currant er historical multiple s!gnets.
Features to be deve!oped includa:
o Analytical software to mentior current data and set off an i
alarm upon detection of abnormal conditions, j
l o Expert System software te diagnose abnormal Indications l
and predlet the probable sequence of future everk faster j
than the accident progreres, j
c Continuing sof tware developm 'nt will lacrease the speed and enllability of analysis, thereby further ensuring tha protection of the health and safety of the citizens of Illinois. -
PoR 7.*RThEA D90AM AT10N COM ACT P "' ILIPC** Dirt. Of MKttAA 8 APETY. 1918 OUTER PARE DRIW.
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2 THE RADIOACTIVE GASEOUS EFFLUENT JylONITORING SYSTEM 1
The Illinois Department of Nuclear Safety utilizes a
custom designed automated system to monitor poses routinely released by nuclear power plants.
The Radiot:tive Gaseous Effluent Monitoring Systems (RAGEMS) is designed to identify and quantify the radioactive components of the gaseous discharges to the environment so that appropriate emercency actions can be initiated in the event of a nuclear accident.
Although a completo system is currently installed only at the LaSalle nuclear power plant, units will be Installed at the Zion and Dresden nuclear power plants in the Fall of 1986. The i
Department will be installing this equipment in the rest of Illinois's nuclear power stations over the next five years, The RAGEMS is a state of the art, computerized system which i
continuously transmits data from the nuclear power plant to the j
Department's central computer which is located in the Radiological Emergency Assessment Center (REAC) in Springfield.
This system includes the following features:
o Dedicated computer at the power plant sites for operation and analysis.
l o Minimum detection level of 10 13 microCurles/ cubic centimeter, j
o Maximum accident detecflon limit of 105 microCurios/ cubic centimeter.
)'
o Collection and analyses of radiation in three forms: lodines, particulates, and noble gases.
o Automatic background level checks.
o Automatic check sourcs verifications.
o Remote computer access to determine operational status and data.
o Signal alarms in the event of high radiation levels or i
failure of a system function, o Detection of specific isotopes based on radiation er.ergy.
o Accelernt,ed operation rates designed to maximize data
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collection during an accident.
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ENVIRONMENTAL RADIATION
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MONITORING SYSTEM A ring of environmental radiation monitors (pressurized lon l
chambers) is Installed around each reactor site that would measure a change in radiation levels resulting from a radioactive release at the reactor site.
This system serves a multitude of
- purposes, it w!i.I define the existence of a radioactive release t
sufficiently large to impact upon the environments es well as detect a releass through an unmonitored release path. In addition, the system provides a backup capability should the effluent monite.Ing system be Inoperable and also reveals the presence of atmospheric conditions (wind shear) which could result in plume dispersal not following anticipated direction of travel.
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1 The Environmental Radiation Monitoring System h.'s the following features:
o Up to 16 monitors per site (one detector for each 22.5 degree segment) at a distance of approximately two miles ' tom the reactor site.
o Minimum detection level of one microRoentgen per. hour, j
i (Natural background levels are approximately 7 10 microRoentgens per hour.)
o Maximum detection limit is 10 Roentgens per hour (one million times normal background levels).
o Automatic transmission of radletion readings to Radiological Emargency Assessment Center computer system every eight minutes.
o Transmission of alarm signals to REAC in the event of high radiation levels or failure of environrnental monitoring system components.
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APPENDIX FOUR t
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THE COMMONWEAL.TH OF M ASSACHUSETTO
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J nh EXECUTIVE DCPARTMENT STATE HoVSE 80SfoN 02133 I
s wic u a rt. s. o u m o s savsamon July 7, 1988 Mr. Lando Zech, Chairman U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Chstraan Zech:
We are writing concerning arrangements for state participation in the Augmented Team Inspection for the Pilgrio Nu: lea r Powe r plant.
The inspection has been requested by Boston Edison Company, but as of yet N.R.C. Region One has not, fixed the date.
We have informed Regional Director Russell that we are prepared to abide by the inspection protocol (copy enclosed) as a condition of participation in this inspection, but that the conditions for participation are overly restrictive.
In particular, we are concerned that the Cormonwealth will be limited to one observer throughout the inspection and one additional participant in the entrance and exit interviews.
We believe that in view of the history of problers at the Pilgrim plant and the comprehensive nature of the planned inspection, it i s essential that the Commonwealth be afforded the opportunity to have additional observers participate in the inspection, as well as the entry / exit interviews.
Furthermore, we are concerned that under Region One's policy, the Commonwealth's role'wlil be limited to observation of N.R.C.
Inspectors and will not include the opportunity to review Itcensee behavior and performance.
This policy will hinder, if not nelate, an opportunity to participate meaningfully in t:1e inspection process.
Moreover, this policy appears to be inconsistent with paragraph three of the inspection protocol which encourages state observers to report their assessments of licensee performance and behavior to the N.R.C.
inspectors, cbs m
y av i
Lando Zech, Chairman July 7, 1988 Page Two We look forward to concluding er angements with Region One for participation in the Augmented eam Inspection as goon as these matters are resolved.
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'ames Y. Shannon fe hs 61 4. 'D
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I,ttorney General o'v e r n o r
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cc:
William Russell, Administrator l
NRC - Reglon one I
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NUCLEAR REGULATORY COMMISSION n
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CEGION I 631 PA%K AVF NUE
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C:tNG CF PRUS$4A. PENNsWLVANIA 194%
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g July 13, 1987 Richard T. Dewitng, Ph.D..'P.E.
Commicioner Depar kent of Env'ironmental Protection 401 East State Street CN 402
-Trenton, New Jersey 08625
Dear Commissioner Dewling:
lhls letter is to confirm the general agreement reached as the result of our meetings with Or, Berkowitz and his staf f regarding the surveillance of th nuclear power plants operating in New Jersey.
that there was a need to have a more formal ray of coordinating HRC and Stat *,
activities related to plant operations and that the Department of Environmental Protection's Bureau of Huclear Engineering (BNE) will be the interface with the NRC on a day-to day basis.
The areas addressed by tttis letter are:
State attendance at NRC meetings with licensees relative 1.
to licensee performar.ce, including; enforcement conferences, t
I plant inspections and licensing actions, i
NRC and BHE exchanges of information regarding plant enne
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ditions or events that have the potential for or tre of safety significance.
as observers,,1RC enforcement We agree that New Jersey officials' may attendconferences a i
Licensee Performance (SALP) reviews, with respect to nuclear power plants We shall give timely notification to operating in New Jersey (PSE&G, GPUN).
the BNE of such meetings, including the issues expected to be addressed.
Although I do not expect such cases to & rise frequently, we must reserve the right, to close any enforcement conference that deals with highly sensitive 1
- safeguards material or information'that is the subject'of an ongoing investi-
'yation by the NRC Office of Investigation (01), where the premature disclocure of information could jeopardize effectrive regulatory a: tion.
In such cases, v2 7
, vould brief you or your staff af ter the enforcement conference and would c.,/'-
J-expect the State to maintain the confidentiality of the briefing.
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With regard to NRC inspections at nuclear power plants in New Jersey, we agreeTe the
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that the BNE staf f may accompany NRC inspectors to ebserve inspections.
extent practicable, HRC will advise the State sufficiently in advance of our In inspections such that State inspectors can make arrangements 'to attend.
order to assure that those inspections are effective and meet our mutual needs.
I suggest the following guidelines:
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The State of New Jersey will make arrangements with the licensee to have New Jersey participants in NRC inspec-tions trained and badged at each nuclear plant for unescorted access in accordance with utility requirements.
a 2.
The State will gl.ve NRC adequate prior notif'ication when planning to accompany NRC inspectors on inspections.
3.
Prior to the release of NRC inspection reports, the State will exercise discretion in disclosing tu the public its observations during inspections. When the et,nclusions or observations made by the New Jersey pirticiprnts are sub-stantially different from t. hose of the NRC inspectors, New Jersey will make their observations available in writing to the NRC and the licensee.
It is understood 4
that these com.iunications will becoma publicly asa11able f
along with the f(RC inspection reports.
I With regard to communications, we agree to the followir.g:
1.
The NRC shall transmit technical infor.aation to ENE relative to plants within New Jersey concerning operations, design, i
external events, etc.; for issues that either have the potential for or are of safety significance, 2.
The NRC shall transmit all Preliminary Notificatichs rol:.ted to nuclear plant operations for New Jersey facilitia s to tha BNE routiraiy.
3.
The BNE shall communicate to the NRC ariy concern or cuestion regsrding plant c:,nditions or events, anct any State ir.fornatten about nucir.sr power plants.
l Please let me know if these agreements are sati. factory to you.'
L Sincerely, j
'l ll Oristnal stenea 37 WILI.IAN t. Russnz, i
William T. Russell i
i Regional Administrator I
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i APPENDIX FIVE l
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g IO34 THE CSMMONWEALTH CF M ASSACHUSETTS
[*J.<D I
Il c EXECUTIVE DEPARTMENT CML O(FINS ( A0(NCY 0 n0(NCY P#tPAMDh(SS
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gh PRAMe*0MAM. 4 917914HP d
RoBEpi J. BoVLAY EcHAEL s. DUKAKis DantCTOR gg September 18, 1987 Mr. Ralph Bird Senior Vice President Boston Edison Company 800 Boylston Street Boston, Massachusetts
Dear Hr. Bird:
My staff has teviewed the August, 1987 "Study to Identify Potential Shelters in EPZ Coastal Reainn of the Pilnrim Nuclear Power Station," which was prepared for you by Stone and Webster.
We find that this study is deficient in several resoects and that additional work is required to provide information to local officials which is sufficient to support development of implementable shelter utilization plans.
I have attached a copy of a memorandum orepared by my staff which details our specific concerns regarding this study.
If you have any questions or observations reoarding our I
evaluation, please contact Buzz Hausner of my staff.
Thank you for your cooperation in this matter.
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obert ulay Director Q
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Assistant Secretary, Peter W.
Agens, Jr.
Deputy Direcc6r, John L. Lovering Mr. Buzz Hausner i
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I THE COMMONWEAL.14 CF MASSACHUSETTS As m ut;M I
EXECUllVE DEPARiZENT O
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C8V14 MetNlt A0tNCV WO O' I&
notNCY Pat? AntDNill
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%4j noDEnf J.BoVLAY W!CHAEL 5. oUMAKIS PRIClOR 90vgMNOR 10:
DIRE TOR BOULAY
.FROM:
BUZ 4 USHER IN RE:
SHELTER SURVEY OF PILGRIM EPZ PREPARED BY BOST0ll EDIS0ll COMPANY DATE:
SEPTEMBER 11, 1987 t
.n............
We have made a preliminary review of the shelter survey of the Pilgrim EPZ which was nrepared t'y the 00ston Edison Cemoany and itc' consultants.
While this document compiles some very useful*
data, we feel that more work must be done to estimate the errectiveness of shelter as a protective action.
Our principal concern is that we must be able to put data in the hands of local officials which are sufficient for the development of shelter utilization plans for all areas of all five communities within the Pilgrim EPZ.
With this in mind, we have the following comments.
The survey only covers an area approximately one mile wide along the coast.
The shelter capabilltles of the entire EPZ must be surveyed and reported.
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TM survey does not separate out those structures which cu,'d "most reasonably" be used as shelters from those where sholter is less appropriate.
For instance it would help to have a separate list nr public buildings and facilities for each town, including an estimation of the actual useable shelter space and protective factors for shelter under government authority.
Hany of the shelters listed, such as jewelry stores and pharmacies _are. clearly not suitable.for pubile shelter.
In a severe emergency, every available resource will of course be put to use.
However, to l
develop an implementable shelter utilization plan, j
local officials must be able to' match estimated needs with the noat appropriate resources available.
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' Dir5ctor Boulay
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Page 2 Regaiding protection of the beach oooulation, the surve t identifies shelters within.a mile of the coast butr,oes not indicate the distances that beach goers e
wour.d have to travel to find shelter.
In addition, the survey must demonstrate that adequate proximate shelter is available for the total population at the individual beaches.
For instance, Ouxbury beach is about seven miles lona and the survey should indicate the distance peonle at Saquish Head are required to travel to reach adequate shelter.
Further, an implementable shelter utilization plan must demonstrate that the nearest shelter would not be full to capacity before the people at the most remote"hoints of the beaches arrived.
The survey must identify adequate shelter which is handicapped accessible.
The survey does not distinguish between available space and usable space.
For instance, residents of Plymouth i
have indicated to us that some basements listed in the survey are no more than crawl spaces.
Crawl spaces cannot be considered for public shelter.
Further, in most buildings, a good deal of floor area will be occupied by machinery, counters, office furniture, et cetera.
The survey must identify accurately the actual useable shelter space available in each structure.
Stone and Webster uses c FEHA nuclear attack value of ten square feet per person to estimate the potential population which can b3 sheltered.
Local Civil Defense Officials may wish to allocate'more space -- UD to twenty square f eet per person -- in their utilization plans.
The value used in the survey overestimates the l
potential capacity of various bul) dings.
We doubt that 17,000 peoole can be sheltered at Ouxbury High School, i
J or that 89,700 can be shelteled at the 5 Cordage Park b
Buildings.
J The survey must demonstrate that public shelters are
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free from asbestos and other environmental hazards.
l The report _ estimates residential "sheltering capability" in individual communities as between 53%
and 81%.
These figures indicate that a significant number of residents do not have adequa'te domestic 1
J shelter and emphasize the need for a full study of L
public shelter capacities throughout the entire EPZ.
Director '):;ulay Page 3 Further, even if it can be ektablithed that the vast majority of residences offer adeouate shelter, local officials must be prepared to offer public shelter of a known protective capability to residents who demand assistance.
This report makes no definitive statement of what constitutes adequate shelter to protect peoole from the ef f ects of a radioloalcal release from Pilorim Station.
This is necessary to determine what facilitie.s are most appropriate for a local shelter utilization plan and to determine the public shelter needs of each community.
1 In summary, we would say that this survey is a useful beginning but that much more work is required before we can assesr. nur ability to develop implementable shelter utilization plans consistent with the public safety concerns in Secretary Darry's report to the Governor, l
cc:
Assistant Secretary Peter W. Agnes, Jr.
Deputy Director John L. Lovering j
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4 APPENDIX SIX i
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e qolice.Tro,op"D", Headquarters ezasgar State Hiddleboro, Massachusetta September,30, 1987 Tot Captain Charles F. Henderson, Coussanding Troop "D" Front Lieutenant Edward H. Begin #908 Subjects Review of and Recommendations for Man Power and Equipment Needs relative to Evacuation Time Estimates and Traffic Management vlan Update Tinal Draft prepared by KLD Assoc., Inc. for Boston Edison Co., Emergency Operations Facility, Plymouth, Mass. dated Augu e 18. 1987.
1.
On August 19, 1987 I attended a meding at Secretary Charles V.
Barry's offico relative to the proposed treffic management plan update re an evacuationwithin the Emergency Plannias Zone (EPL) st the Pilgrim Huclear Power Station (PNPS) located in the Town of Plymouth. At that time, a copy of the final draft for review prepared by KLD Associates. Inc. for Boston Liison Company was presented to me for review and recommendations relative A.
Location of traffic control posts, B.
Evacuation routes, C.
Personnel resources and D.
Ceneral review.
2.
Based on personal knowledge of traffic patterns within the area to be affected and traffic intensity data provided by sources mentioned in the plan submitted by KLD, which 1 assume to'be correct, the following re-commendations are being submitted for your approval.
3.
ne traf fic control posts (TCP) and access control posts (ACP) sub-mitted by l'.LD appear to be essential in order to complete full eva:uation.
However, I do have reservations relative to ACP 3R-1 and BR-2.
(See attact.ed Table L-1. L-51 and L-52) W ie location, with its.close proximity to poston, would create massive gridlock in the area thus preventing any emergency re-sponse f rom agencies cosine, iton or through that area. It would also deny access to residents of the EFZ who wish to return home for their families.
4.
W ie ACP could be used more effectively if information could be transmitted to motorists traveling in the area. D e information could be provided by the radio media and also electronic message signe erected near ACP BR 1 and 2.
An additional four to six police officers on motorcycles would be required in that area in addition to the four reca====ded by KLD to handle the traffic problems in the area in additten to the above additional requirement s.
A medium sised mobile communications van manned by at least three officers would be uti11:ed at ACP 3R 1 and 2 to better handle traf fic and other related prob) ens in the area. His van should have the capability to communicate with all State Police agencies as well as local police 4 It
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l Capt. C. F. Henders:n 5:ptcubtr 30, 1987 i
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- 4. Continued should also have the capability to utilise the telept.one communication system via a cellular mobile unit contained within the van. A large 10 KW hour mobile generator would be needed to handle all power requi ements at that J
ACP. Wie equipment would be stored and maintained at state Police Norwell to better facilitate implementation.
3 5.
Another area of question is ACP 50.1.
This area, due to its close
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proximity to FHFS and large volume of traf fic, reqdires a large mobile consnun-l 1 cation vehicle capable of communicating directly with all state and locci agencies involved in the evacuation and in addition FNFS itnelf.
It should I
also have three cellular mobile telephones to handle the additional commun-l 1 cation needs that would arise from such an incident. This vehicle would be i
eet up at a prearranged area at the Sagamore Rotary which would have been prepared with a power module which could accoannodate the electrical and comununication hookups necessary to power the communication vehicle. A large mobile generator would also be heeded is the event of a power outage.
Additional manpower requirements to ptoperly operate the communication vehicle vould be needed.
6.
It is also necessary to equip each officer assigned to duty at the various ACP and TCP's with hand held radios. This equipment should be com-parable and coepatible with equipment currently in use within the Division of State Police.
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7 I further recomunend that telephone equipment be installed in specific vehicles in use by personnel within the Division so that cosununication f
could be provided without further straining the fadio communication system I
which would be taxed to the maximum in the event of any evacuation at FNFS.
l Ris equipment should be available to the 1) Deputy Superintendent, 2) Com-manding Of ficer of Field Operations 3) Bureau Comunander of Eseern Fields,
- 4) Troop Commander and 5) entire com:nand staf f at Troop "D".
Protective I
clothing and beathing apparatus should be. supplied to of ficers assigned within i
the five mile radius of FNPS EFZ. Personal radiological monitoring devices should be issued to all personnel assig ed and training should be previded periodically in its proper usage. All ACPs and TCrs should be equipped with
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a power module mentioned earlier so that if necessary, emergency lighting and j
i telephone communication could be brought f ato service if the need became l
evident. Telephone communicati.on is o.bvious, because of information which, should not be ownitored by private citisens and news media.
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I t1eo recosamend that a contingency of State Police officers be
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trained and maintained on a twenty-four hour basis to respond to the va: tous i
ACF's and TCF's in the event of an emergency at FMPS. This coeld be accom-I plished by esponding the "55" Team now deployed in Troop "D".
An additional l
seven troopers sad two MCO's would bring the total strength to twenty-five l
This contingency of of ficers in addition to swallable persommel would l
men.
be able to respond to the various ACP's and TCP's within one hour of moti-
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fication of an ALERT condition.at FNFS.
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Capt. C. F. Hendarern 8:ptemb3r 30, 19R7 a
9.
It must be noted that the personnel requirements can only be met i
at the ACP's and TCP's located on majo: limited access highways. Route 6 Route 3. Route 495.. Route 128. Route 25. and their immediate approaches.
1 This is due to the availability of manpower at short notice and also the need for minimum manning requirements - one desk officer and two patrols at the five troop mainland substations and at least one commissioned officer, one patrol supervisor and one civilian state Police dispatcher at the troop headquarters. These minism.m requirener.ts are absolutely necessary due to excess activity which would be generated as a result of any evacuation order.
b 10.
If the emergency lasted for an extended period (days), additional manpower would be solicited from other areas (District Attorney's offices.
I neighboring Troop "A" and other sobrees) so that assistance could be pro-i vided to local agencies at the remaining ACP's.
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The equipment and sianpower needs described above are in addition to reenmendations of ferred by KLD and are minimum requirements.
It may be that i
, additional manpower and equipment may be necessary in the event of an emer-gency. I do believe however that the State Police can provide the services
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necessary at the described locations if the equipment and manpower requwsts are made available.
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In addition to the aforementioned personnel and equipment require-ments, an adequate sopply of printed handouts amplaining evacuation routeo.
reason for evacuation and other perintent da,ta should be available for dis-tribution at ACP's and TCP's.
This would expedite any need for instructiont j
to evacuees ti.as allowing a smoother flow of traffic at these points.
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4 EDWARD H. BEGDI
- 908 l
Lieut.. Mass. State Police i
Dilq. Middleboro i
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e APPENDIX 1 Urief Explanation of }lanpower Availability within Troop 'D" Total Hanpowtr availability of Troop "D" A/o 9-21-87 164
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This fista describes the total strength including six officers assigned to the island stations at Nantucket and Hartha's Vineyard.
6 Six officerbare currently on extended sick leave. Three are currently ansigned temporary duty within the Bureau of Investigative Services.
. One officer in unavailable for duty due to a suspension. This leaves a 10 tol 1, working ett ength of 148 officers currently available for assignment on LM mainland.
Typical working troop strengu,not counting the personnel mentioned above, veries during each 0 hour0 days <br />0 hours <br />0 weeks <br />0 months <br /> period from 55 uniformed officers working during the day Mcnday thru Triday to betyen 17 and 25 uniformed officers working on the remaining two shif ts llendy thru Triday and weekends.
llinimum manning requirments are one desk officer and two patrols at each of five mainland estations. In addition to the above, one commissioned officer
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and an lico is assigned duty at the troop headquarters. One civilian State 3I Police Dispatcher is nico assigned on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis at the trop headquarters.
Typical day strength liondny thru f riday 55 + or-5 typical Eve strength Sunday thru Saturday 25 44 - 8 Typical 111d strength Sunday thru Unturday 20 45-3 Typical weekend Day strength 25 45 - 0 l
The remaining personnel are on time off (days off, Vacation, holidays owed, sick leave, personal days) but are available for re-es11 on an overtine basis.
hanpower requirments in the event of an evacuation at, TNTS IJ7,.
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KLD Inc.
P3 State Police 45 i
4 Personnel available for service less minimum manpower requirments.
Typical day Honday thru Friday 30 Typical eve Sun. thru Sat.
0(44)
Typical aid Sun, thru Sat.
3(+5) i by supplementing the existing Troop 'D" $5 toen with an additional 7 trok>ers
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and 2 Nco's bringing the total compliment to 27 officers. This group of officers I
would be trained and equ.ipped to respond within one hour of notification
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of an emerr,ency at THFS. The remaining 1B officers needed would be drawn from exigting manpower and so trained and equipped.
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i APPEND 11 2 Equipment Requirments I
- 1. Fif ty portable radina which would supplement existing equipment J
currently in use within the division at Troop "D".
2.( ACP-BR-1,bR 2, 50-1, SA-1) Tour 10 KW generatora to be used at acc j
- 3. Nine mobile cellular telephones to be utilised as described.
- h. Two mobile communications vans, one large, one medium to be equipped as described.
(08-142 DO-1)
- 5. one hundred sixty retr dosimeter /one per man.
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- 6. Six air packs to be used by personnel assigned within the 5 mile radius of PNTS.
(TCPF.ek,P-7,F-8,F-15) l
- 7. six suits or protectiv' c1, thing to be used by personnel assigned
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within 5 mile radius of TNPS.
(Gameas6)
- 8. surricient power sedules'to provide a source or power and telephona 3
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communications toyfrected at described sites.
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- A power module would be a perennent%yerected, all weather source of electrical i
power sufficient to handle any lighting requirments at that site. It would l
ales be equipped with telephone jacks so that communication by telephone j
could be easily implemented.
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APPENDIX SEVEN I
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'TRAN_PORTATION
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Bosm MA o2116 3968 g
(617 973-7100 PLANNIND STAPP November 19, 1987 4
1
. Mr. Buzz Hausner Civil Defense Agency Executive Department 1
The Commonwealth of Massachusetts 400 Worcester Road P.O. Box 1496 Framingham, Massachusetts 01701-0317 t
Dear Mr. Hausner As requusted in your letter of September 28, 1987, I have reviewed the testimonies of Avishai Ceder and Thomas J. Adler regarding the Seabrook Station evacuation tispe estimates (ETEs) to see if they have any bearing on your consideration of the I'llgrim Station ETEs.
Dr. Ceder focuses specifically on tt.e behavioral assumptions
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and parameters of the 1-DYNEV traf fic simulation model, and i
concludes that the model can not provide realistic ETEs within a 4
reasonable degrer (i 10%) of accuracy.
Furthermore, he believes l
that the model is likely to produce ETEs which err on the low side.
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Dr. Adler concen cates on the input data to the simulation model, an.1 concludes that the ETEs were underestimated, especially for the eummer scenarios, and that the complete set of ETEs should be redone.
Each cite a number of reasons for believing that the ETEs j
were underestimated.
First, there are Seabrook-specific ones.
4 One of them relates to the estimation of evacuation traf fic from i
l the beach area.
Dr. Adler testifies that the ETEs for summer-l l.
Weekend scenarios should reflect the times required to evacuate beaches which are at 100% of capacity, not at 2/3 capacity (as wan l
j done by K1,D Associates, having observed 2/3 capacity to be typical j
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of actual use).
This and other Seabrook-specific issues will not j
be commented on here.
l Escond, there are also a number of technical assumptions which may not be agreed upon among all people in the profession.
One of these assumptions is the saturation dischaege headway for l
intersections.
Dr. Ceder recommended 2.7 secondf,/ vehicle, based on an observation of 80 vehicles (R. J.
Salter, Highway Traffic a
Analysis and Design, Addison Wesley,1974), while KLD used 2.4
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4,.. m.y em,
I Mh. Buna Hausnor Novctber 19, 1987 I
i seconds / vehicle, taking the high end of the range f rom a low of 2.1 to a high of 2.4 documented in the Highway capacity Manual (Transportation Research Board, 1985).
No attempt will be made here to resolve differing views about these technical assumptions.
However, there are some major issues raised in the testimony which have direct bearing on your consideration of the Pilgrim ETEs, and which are addressed here.
Simulation of Normal Behavior The Seabrook ETEa are the result of simulation of normal travel behavior.
Effects of potential abnormal or unstable travel behavior in highly congested and stressful situations were not I
taken into account.
Dr. Ceder points out that only one driver needs to behave in an unstable uanner to create a significant disturbance for a long I
line of vehicles (e.g., a single impatient vehicle occupying part l
of an intersection and thereby reducing intersection capacity i
significantly for the cross-flowing traffic).
I Dr. Ceder also points out that more traffic accidents are likely to occur during an evacuation, because the traffic safety circumstances during the evacuation process are, in his view, analogous to the circumstances which commonly exist during roadway construction / maintenance work, and that traffic incidents such as vehicle breakdowns due to overheated engines, empty gas tanks, or mechanical failures are very likely to occur during the evac-uation.
Dr. Ceder concludes that these traffic accidents and traffic inctients will cause additional delays for the evacuating traffic.
Dr. Adler goes one step further and raisen the question of whether people will stay with or abandon their cars if circumstan-ces make auto travel considerably slower than walking.
It is likely that at least some of the events descrit-d above would occur during an evacuation.
However, there are no empirical data to quantify the probability of their occurrence and the severity of their impacts.
Therefore, a "what-if" analysis is appropriate.
It is suggested that KLC Associatus develop Pilgrim ETEs for a range of reductions in roadway capacity for a selected scenario.
Trips from Work to Home The return-ho$e-from-work trips by employees who reside in the Evacuation Planning Zone (EPZ) were not included i'n the trip assignment / simulation models for the ETEs.
The effects of these trips were implicitly considered by assuming that the capacity of two-way road section will be red 1ced to a level corresponding to a 904/10% split of evacuating vs. returning traffic.
Dr. Adler
Mi. Busa Hau:nor Nov0cber 19, 1987 4
suggests that these work-to-home trips should be explicitly modeled.
As you may recall, this topic is discussed in my september 6, 1987, memorandum to Dr. Michael D.
Meyer of the MDPW.
It is recommended that a sensitivity analysis be performed by including thesa trips in the trip assignment / simulation process for one of Scen rios 3 through 7, to determine the effect of these i
trips on the ETEs.
4 Apparent Errors l
Dr. Adler points out two apparent errors in the modeling pro-
{
cess.
One error is in the calculation of the capacity of freeway l
ramps under con ested flow conditions (service volume at level of service F).
Wh le the documentation says that the volume at level f
l of service F is assumed to be 85% of the volume at level of ser-i vice E, the actual volume used is approximat'aly 94% of the v'olume f
I at level of service E.
It is suggested that a sensitivity analy-l sis be performed by running the model with carrected capacities for a scenario, and that the ETEs for all scenarios be mtnually f
adjusted according to the findings of that sensitivity analysis, A second error relates to the interpolation method.
The I-DYNEV t.odel produces the number of vehicles that have passed j
through a given area (e.g., the edge of the EPZ) at half-hour l
j intervals.
An adjustment procedure is necessary to determine j
when, during the last 30-minute interval, the area actually l
l cleared.
KLD Associates performed the interpolation for all l
exiting roads combined instead of interpolating individual roads separately and choosing the maximum value.
As a result, the ETE computations are biased on the low si Je by as much as 25 minutes.
The Pilgrim ETEs should be corrected.
The correction work does not requ. ire running the model.
Concluding Remarks The recommendations made here are focused on (a) correcting I
apparent errors, (b) refining the modeling process where the model may have been over-steplified, and (c) per forming limi ted what-if analyses for uncerteenties during the evacuation.
l It is sugger,ed that any time and effort available beyond the above recommendations would be best utilized w.....,
- er in refining the Pilgrim traffic-management plan.
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Sincerely, N
~
Yong B. Chang i
Technical Director cc:
Dr. Michael D.
Meyer, MDPW Matthew currie, MDPW I
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