ML20205J353
| ML20205J353 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 10/05/1988 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML20205J349 | List: |
| References | |
| CON-#189-8170 2.206, NUDOCS 8810310374 | |
| Download: ML20205J353 (107) | |
Text
{{#Wiki_filter:_ _ _. e l ., , V g-I U.S. NUCLEAR. REGULATORY COMMISSION ! SeconT&I l l- !
,In the Matter oft ,
OPEN MEETING WITN BOSTON EDISON ) COMPANY: PILGRIM NUCLEAR POWER ) Docket do. 50-293 l STATION ) l l I i ) [ 1 Wednesday, f October 5, 1988 t i Nuclear Regulatory Commission ! 11555 Rockville Pike i Room 2FM2 Rockville, Maryland l The above-entitled matter came on for hearing, pursuant to notice, at 1:08 p.m. j r I i APPEARANCES: f i Moderator: f DANIEL G. MCDONALD l Senior Project Manager f Project Directorate I-3 i I Division of Reactor Projiacts I/II
Participants:
TOM MURLEY Office of Nuclear Reactor Regulation R.G. BIRD Boston Edison WILLIAM T. RUSSELL Nuclear Regulatory Commission f Region I i Heritage Reporting Corporation (202) 628-4888 ggio3kf2?A8853){g3 -
r a 2 ( APPEARANCES,(CONT.) ! RONALD VARLEY l Boston Edison j l SAMUEL J. COLLINS NRC Region I i EDWARD HOWARD Boston Edison . t R.A. LEDGETT { Boston Edison ; WILLIAM D. TRAVERS Nuclear Regulatory Comunission ! Office of Nuclear Reactor Regulation j RONALD R. BELLAMY i Nuclear Regulatory Convaission j
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B l 3 1 PBQCEEQINQS 2 1:08 p.m. 3 MR. MCDONALD: Good afternoon. My name is Daniel 4 Mcdonald. I'm with the Office of Nuclear Reactor 5 Regulation. I'm the project manager lor Pilgrim Facility. l 6 The purpose of this meeting today is to provide Boston l 7 Edison to give the status on the readiness for restart for j 8 the Pilgrim Nuclear Power Station. 9 I have provided copies of the meeting minutes on 10 the back of the table, and also handouts from Boston Edison ! 11 for their presentation. 12 Would you turn that on please? On the chart is l 13 the agenda for the meeting. 14 (A' copy of the maeting aganda t 15 was marked for identification , 16 as Attachment 1.) 17 The meeting is being tr.'.nscribed and I request 18 that the speakers identify themselves prior to their 19 discussions and that people asking questions or responding 20 please also identify themselves before speaking, in order to 21 get an accurate transcript. 22 We are trying to have the transcript available 23 within a day or two after the meeting. The transcripts will 24 be in the public document rooms and our local public 25 document rooms and the libraries in the vicinity of Heritage Reporting Corporation (202) 628-4888 h
s , 1 4 i 4 l i 1 Plymouth. i i 2 As noted on the notice of the meeting, this is an i 3 open meeting to the public in accordance with the Commission j 4 policy. People are to attend and observe the meeting, and j 5 as indicated on the agenda, we have allocated time for a ; 6 repress .ative of the commonwealth of Massachusetts to ! 7 provide comments. 8 I would like at this time if the representative ! i 9 from the Commonwealth stand and introduce himself, please. ; .I ! ] 10 MR. AGNES: My name is Peter Agnes. I'm the !
! 11 Assistant Secretary for Public Safety. !
i i 12 MR. MCDONALD: Thank you, Mr. Agnes. Before we 13 proceed, I would like the members of the staff and the l l 14 representatives of Boston Eifison to plosse go around the l I 15 table and introduce themselves. 16 MR. MURLEY: I'm Tom Murley, Director of Nuclear f
.I Reactor Regulation. l j 17 ;
2
) 18 MR. RUSSELL: Bill Russell, Regional l l 19 Administrator, Region I NRC. (
20 MR. COLLINS: Sam Collins, Deputy Director, 21 Region I NRC. , I 22 MR. BELLAMY: Ron Bellamy. I'm chief of the i i 23 facilities radiological safety and safeguard, Region I. i 3 24 MR. BOGER: Bruce Boger. I'm the assistant 1 J 25 director for Region I Reactors, with NRR.
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f d t j Heritage Reporting Corporation " j (202) 628-4888 l i i , L
U 5 , 1 MR. HIGHFILL: Ken Highfill, Safety Director, 2 Pilgrim Station. 3 MR. VARLEY: Ron Varley, Emergency Preparedness 4 Department manager. 5 MR. LEDGETTI I'm Ron Ledgett, Director of Special 6 Projects, Boston Edison. J 7 MR. BIRD: Ralph Bird, Sr., Vice President 8 Nuclear, Boston Edison Company. 9 MR. GRAZIO: I'm Bob Grazio, Manager of Regulatory
- 10 Section, Boston Edinon Company.
11 MR. MCDONALD: Thank you very much. I'd like to 12 make one other point. An attendance sheet is being passed 13 around. If you'd please sign it, and at this time I would l 14 like to turn it'over to Dr. Murley to make some opening l i 15 remarks. l 16 MR. MURLEY: Thanks Dan. We are in the process, 17 the staff of the NRC, of formulating our recommendations to 18 the Commission on whether and under what conditions Pilgrim [ i 19 could be allowed to resume operations. 30 We have in hand Boston Edison Company's request to 21 restart the plant. The region has completed an extensive 82 readiness inspection at the uite, and I expect to get the 33 region's recommendations soon. There have been a number of 34 public meetings, most recently last Thursday in Plymouth, 35 Massachusetts. lleritage Reporting Corporation (202) 628-4888 ,
6 1 Over the past several months we have received the 2 views of the Commonwealth of Massachusetts, of local town 3 officials, and of Cong:*essional representatives, and today ; i 4 we will also hear again from Peter Agnes, who we invited to 5 come and join us today. ll 6 The purpose of today's meeting is to hear an 7 integrated assessment by the Boston Edison Company of the 8 readiness to resume operations at the Pilgrim station. In - 9 particular, we would like to hear about the readiness of the i 10 organization at the site, of the plant's status itself, of 11 their power ascension plans, and of the progr-as that's been ; i 12 made on emergency planning improvements. ; 13 With those, then I'll turn it over to Boston 14 Edison. ; 15 MR. BIRD: Good afternoon. I will be covering the ( 16 first several items on the agenda, and then Ron Varley will 17 follow me to discuss the emergency preparedness area. [ l 18 We're here today to tell you why we believe that l 19 we are ready to restart the Pilgrim Nut: lear Power Station, f 20 and what I'm going to cover today will be similar to what I 21 expect to cover next week at our meeting with the ! 22 Commissioners. , 23 Our management team is in place. I believe that l 24 in terms of structure, experience and overall ability, it l 25 compares favorably with any other utility. The competence l I t l Heritage Reporting Corporation l (202) 628-4888 [ 1 l L (
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^
TOWN OF PLYMOUTH
, g - . OmCE OF SCt ECTMEN yh,,. -
THE SELECTMEN "M* "d%S 11 uncoln Stmet ALBA C. THOMPSON Chamno n
, gygc m Plymouth.. Massachusetts 02360 yy,D F{
to Ct/TWE SECRETARY (508)747 1620 . i October 4, 1988 l l i l Nuclear Regu3atory Commission i j Washington, D.C. 20555 ; 1 ' Gentlemen: i l The Plymout.h Board of Selectmen is astonished to learn that the Nuclear Regulatory Commission has requested Boston Edison I to appear in Washington on October 5, 1988 to discuss off- ; site emergency preparedness and to provide a written ' description of Boston Edison's "current understanding of the state of the off-site ptogram and the status of the issues ; ra.ised in FEMA's August, 1987 "Self-Initiated Response." ! Why is the "current understanding
- of a utility seeking restart of the Pilgrim Nuclear Power Station a valid basis .
for judgement? Since the utility is not responsible for - l off-site preparedness and the Town of Plymouth 13, why was [ the Town not invited to testify at the October 5, 1988 ! meeting? ! We repeat here the findings of FEMA's Region I, August 22, ! 1988 in a letter responding to Charles V. Barry, Secretary, j Executive office of Public Sefety* Commonwealth of ! Massachusetts concerning radiolc ial off-site emergency ! planning and preparedness for Pilgrim and quoted to this : Board by TEMA, Washington, D.C. in its letter to us under
. date of September 9, 1988: *
. . . reviews indicate that l there has hg.tD Egg prooress R&5121D imorovina ed uparadina j local clans. Overall, however. Ahg plans _ remain incemolete, i lagg specific det: ails in certain areas, Ed A2 AQ1 include [
recuired imolem6.stino orocedures.* (emphasis added). I L It should be clear to your Commission from the above as to the truth of the status of off-site radiological planning in f this and other communities in the EP2. f This Board knows the truth far better than any utility which ! wi11, without doubt, seek to put the best face on a dangerou,s ) situation. That you should ask it and not a town official to ! tell you the present status of the Town of Plymouth's ; emergency planning is to lose' credibility, f I I
I Nuclear Regulatory Commission i October 4, 1988 Page 2 ; We thoroughly question the validity of this course of action l and deny that you can arrive at the truth of areas under our ; jurisdiction by asking for "current understandings" from Boston Edison. Indeed, we are astonished that you at old do so while I ignoring our own officials' "curri at u; 'tratandings." We refer to our civil defense directs,- chairman of our Radiological Emergency Response Plu.a4. J Committee, and to our selectmen who are responsible for writing, implementing, : testin(, and approving our planw. l i We invite your esponse, but more particularly we urge you to .. 2 consult with Plymouth's Board of Selectmen and our Civil Defense Director, and our heads of departments if you are truly interested in the states of emergency planning in this ! community. Any other course avoids the facts. That surely
, cannot be your purpose. ,
Very truly yours BOARD OF SELECTMEN ! h(w \d %bW Alba C. Thompson y ; Chairman t ACT/1t i I I i r i ; i . l
.i
a e - COMMENTS OF J. DOUGLAS HADFIELD, CD DIRECTOR, TO NRC AT HEARING ON OCTOBER 5, 1988 AT ROCKVILLE, MARYLAND I am here today not to discuss any of the safety or management issues related to restart. My main concern is Emergency Planning. Plymouth's Emergency Plans are not done. If the NRC is not going to consider Emergency Plans an important part of their decision to restart, then why have we spent more than a year working on these plans? I have a big problem with comments I have heard & read that, "plans in progress will be considered sufficient for restart." With that philosophy, I can write the word "plan" on a piece of paper, and that would be a plan in progress. Plymouth has come a long way in the last year. We now have a 7th draft of an Emergency Plan. We have Implementing Procedures for a lot of the separate segments of the plan. The point-I would like to make very clear is that: the plan and procedures that we have are only ' approved in concept." The meaning behind this is that; this is the best we can come up with at this time, working individually with each procedure. The only way we can determine the workability of this plan is with a full scale drill to find tne problems we nave possioly created that must be fixed. Defore a full scale drill can be done, the training should be at least half completed in each department requiring emergency rasponse. This has not been done. I have no intention of going before my board of Selectmen with a statement that the plan and procedures will work until and unless someone can give me positive assurance that the personnel to implement these procedures will be available. Procedures are a piece of paper until someone is there to do the work. My cnly concern is for the safety and well being of the people of the Town of Plymouth. I say the people and I mean all the people; not only the able-bodied, but the special-needs people that are dependent on us for assistance. Special needs people do not just include physical or mental handicapps, but also includes school children from daycare to high school. On September 27, I had a meeting with the Joint Sch.ool Committees that represent the Town of Plymouth's school population. At that meeting, the committee took a e
I S no cetion atanco* on thair proceduros. This monns that no training can ba dona for cchool parsonnol. The committee has a number of problems with the procedure. Some of the proble7s are major. A decision was made to hold a public hearing to get input from parents and staff. This meeting has not been scheduled as yet. When
.you consider the student enrollment of 8168 students and a staff of 1148, that is a large number of important people to be left out of the plan. The students of our schools are the future of this country, and I have a big problem with not having anything in place to secure their welfare.
Our special needs procedures are in draft form to direct us in notifying handicapped citizens. That statement alone is very misleading. The procedure is ready; however, we do not have the most important thing we need to implement it. This is, an up-to-date list of the people to notify. Another point I would like to mention is our radiological detection equipment. We do not have enough equipment available to do all the tasks that have been identified. However, that is not my main concern as Boston Edison has already agreed to purchase and supply the additional equipment to the State for distribution. FEMA has a directive that states they will reimburse the State for calibration of this equipment on a 4 year change over cycle. FEMA also has said they do not feel 4 years is sufficient for EPZ communities. Where does that leave ' the EPZ communities? The 60 kits we presently have were changed 15 months ago. I feel that with the possibility of a restart of Pilgrim, our equipment should be changed out before that takes place and on a yearly basis thereafter. It is not Plymouth's intention to stop work on our planning process. The safety and well-being of the people of Plymouth is dependent on us. I say us because though the NRC does not have direct responsibi1 Tty for their safety; any decisions will have a direct bearing on the people that do have that responsibility. I say again, as I have said before many times, Pilgrim should not be allowed to restart until a tested and approved emergency plan is in place for Plymouth. Thank you for the time to bring these important problems to your attention. 9
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' 7 TOWN OF PLYMOUTH
,g, 3 omcs or
- # sELEcrMEN THE SELECTMEN 1i Uncoln Street =4"#sARs o
'MLLIAM R cRITTIN ALBA C. THOMPSON Chairman
- r5ymouth. Massachusetts 02360 o
- c (EctmVE SECRETARY ]g[f (508)747 1620 September 27, 1988 Nuclear Regulatory Commission Washington, D.C. 20555 Gentlemen:
We, the Plymouth Board of Selectmen, have tried in every way to apprise you of the fact that this community does not have an approved nor tested radiologigal response plan in being. We have_ repeatedly advised you that the Pilgrim Nuclear Power Station ought not be permitted to restart until the citizens of this town a major are protected by a response plan in the event of accident. We have many timec tectified, witnessed, and written to this effect. The Nuclear Regulatory Commission, its staff, the Federal Emergency Management Agency, the Reactor Safeguards , Committee, informed ofand ourthe Commonwealth of Massachusetts are well position. The Board of Selectmen of the 45,000 inhabitants of the historic town of Plymouth, all of whom live within ten miles of the Pilgrim Nuclear Plant, now reiterate our position that until an approved radiological response plan is in place, the plant ought not be given permission to restart. Not once in the past three years has any official of the NRC nor of FEMA visited this community to monitor the conditions of our readiness to respond to nuclear emergency or to official.with our Civil Defense Director or any elected consult completed bYet 20,000 hours of inspection have been recently of concern,y the NRC at Pilgrim. This is a deplorable ratio particularly since we have been told at public hearings that planning thetoNRC prior would indeed consider emergency restart. 9 4 ' 4 0 4
Nucloor R0gulatory Commission' September 27, 1988 j Page 2 t-We who.have' sworn to uphold the public safety and who know all the technical evaluations do not outwei to consider the public health and safety. Let it be known hold it accountable in this matter.that the full weight
, and we of de Very truly yours, BOARD OF SELECTMEN Alba C. Thompso'n Chairman ACT/lt .
ec Congrecsman G. Studds Senator J. Kerry - Senator E. Kennedy State Representative P. FormanSecretary Barry, MA Departm State Senator E. Kirby FEMA
. Plymouth Civil Defense Director 4
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1 and effectiveness of our team has been recognized in the 2 integrated assessment team inspection report, and in the 3 letter report from the Advisory Committee on Reactor 4 Safeguards to the Commission. 5 All of the key positions section headed above are 6 filled by Boston Edison employees. All maintenance 7 supervisory positions have been filled by Edison employees. 8 The few remaining vacancies are filled by qualified 9 contractors, and we're ahead of schedule in filling the 10 remaining positions, and we have not compromised our 11 standards in that process. 12 The NRC's integrated assessment team inspection, 13 the IATI, confirmed the conclusion of our own self-14 assessment, that with the completion of specific items, the' 15 Pilgrim plant is physically ready for safe and reliable , 16 restart and continued operation. 17 Eight of the restart items in the restart plan , 18 remain open. Five of the items determined to be necessary 19 for restart by our management oversight assessment team and 20 our restart readiness self-assessment remain open. Three of 21 the NRC open items required for restart remain open, and one 22 of the commitments that we committed to complete before 23 restart as the result of the IATI remains open. We expect 24 all of those items to be closed by the 14th of October. 25 Virtually accessible areas, 90 percent of the Heritage Reporting Corporation (202) 628-4888 S 9 4 4 4
. 8 1 process buildings, are radiologically clean, and we 1,ntend 2 to keep them clean. -
3 We have expended considerable resources to improve 4 material condition of the plant, and we intend to keep it in 5 good shape. Since the completion of the last SALP period, 6 and the completion of NRC maintenance' inspection 8817, we 7 have made a number of maintenance improvements that have 8 proven to be effective. 9 We implemented a revised work process which 10 includes planning checklists and we trained 546 people, ! 11 including our managers and myself, on its use. We issued a 12 greatly improved maintenance manual. We have a copy of it 13 here if you'd care to look at it. 14 We implemented detail travelers for our work 15 packages whicn improved work performance, and made audits 16 easier. We procedurized the supervisory review to ensure 17 thorough maintesiance close-out, and we assigned operations 18 and systems engineering to have the lead in prioritizing-19 work to be done. , 20 We have added a deputy maintenance section manager 21 to the organization, and we filled the position with an 22 individual who has ,30 years of broad experience in this 23 field. We've expanded the maintenance organization by 24 transferring personnel from other areas and at the same 25 time, we have improved the supervisor to craft ratio. Ileritage' Reporting. Corporation (202) 628-4888 O e e
g 1 All maintenance supervisory positions are now 2 filled with Boston Edison employees who have attended 3 supervisory training before assuming their responsibilities, 4 and duties that in the past prevented supervisors from 5 getting out in the field have been reassigned. 6 We've improved the organization's ability to 7 integrate radiological and operational considerations by 8 assigning health, physics and senior reactor operator 9 qualified people to assist in maintenance planning. 10 Our recent assessment of the new work control 11 process showed both the value of the process and its 12 acceptance by the work force. While we improved our 13 maintenance work control process, we also continued to 14 reduce the maintenance backlog. The number of open power 15 block maintenance requests, which we referred to as MRs, has 16 been reduced to about 250 as of today, which is considerably 17 lens than our most recent goal of 400 open power block MRs, 18 which by the way is well below the industry average also, 19 and this equates to about a three week backlog of work. 20 New work is reviewed and prioritized at the 21 beginning of each work day by a committee chaired by the 22 chief operating engineer. This committee includes 23 representatives of systems engineering, maintenance, 24 construction management, planning and outage management and 25 fire' protection. Heritage Reporting Corporation (202) 628-4888 e e t g h
10 1 The work items are categorized to one of five work 2 priority categories. Those priorities range from priority 3 1, which is work that's urgently required to correct a 4 limiting condition of operation or personnel safety hazard, 5 down to 5, which is very minor fill-in type of work. 6 In addition emergency work items are processed 7 separately in accordance with the following restrictions; 8 the Priority E or Emergency item, Priority E category may be 9 assigned only by the nuclear watch engineer or the chief 10 operating engineer, and can only be used when 11 troubleshooting, investigation or repair must commence 12 immediately, and it can only be used for work directly or 13 indirectly needed to assure public or employee health and 14 safety, and we use that priority very rarely. The average 15 is about one a month or so. . 16 The number of MRs at Pilgrim station that are 17 required for restart has been reduced to 84, as we have 18 completed our preparations for power ascension, and we 19 expect these open restart work items to be completed by 20 October 14th. 21 The increased emphasis on radiological issues 22 throughout the organization, and expanded training, are 23 showing clear, measurable improvements. Last spring we met 24 our goal to have 90 percent of the process buildings 25 radiologically clean. We have made the changes in lieritage Reporting Corporation (202) 628-4888 9
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," 11 1 attitudes, training, and work practices required to maintain ~
2 that level of cleanlinees, and this has become a source of 3 pride to the organization. 4 The goal for total radiation exposure for this 5 year has been set at 390 man rem, which is 20 percent better 6 than the industry boiling water reactor average and less 7 than the 1990 INPO industry goal. We're pursuing that goal 8 aggressively and we're on track to meet it. 9 There has been a sustained improvement in the 10 number of radiological currents reports issued, despite 11 lowering the th'reshold for reporting three times, and we've 12 also had success in reducing the backlog of open RORs. All l 13 long-term open items were closed of March 1988 and they're l l l 14 .now running ac routinely'less than 2n percant of our 1 15 historica; sverage. . l 16 The plant manager, Roy Anderson, who has those 17 groups with the greatest range of activities in the process 18 buildings reporting to him, now chairs the ALARA committee, 19 and we have begun a source term reduction project under Ed 20 Wagner, who has extensive experience in this area. 21 Substantial further reduction of radiation 32 exposure will be achieved through the use of a new 23 interactive video disc tour program which will be completed 34 by mid-December of this year. This program will consist of 25 over 65,000 photographs of plant spaces, systems and Heritage Reporting Corporation (262) 628-4888
12 1 equipment on a video disc controlled by a personal computer. 2 The program will be used by radiological, 3 maintenance, p1'anning and outage, training, engineering, 4 systems, public informat,on, operations and quality 5 assurance. As an example of the benefit that we expect, 6 during a current outage, about 15 percent of the 7 radiological expoFure was used in reviewing work areas for 8 interferences, locating inspection areas and getting 9 familiar with the work area. Using this new program, we 10 expect to sa a large portion of that radiation exposure 11 because people won't need to go into the plant. 12 Even though the last SALP rating for radiological 13 protection was a 3, the improving trend was noted and many 14 accomplishments were cited. Tho IATI report and our rectart 15 assessment readiness report have confirmed that we have , 16 built on our progress and that the improvements have 17 continued. 18 MR. MURLEY: Does this 90 percent, is that the 19 floor space in the reactor building that you're talking 20 about? 21 MR. BIRD: Correct. 22 MR. MURLEY: And does that includo each of the 23 corner rooms? 24 MR. BIRD: Yes, they are all clean. 25 MR. MURLEY: One of the -- as I recall, one of the Heritage Reporting Corporation (202) 628-4888 3 4 5
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. 13 1 recurring problems was the running, kind of a running 2- disagreement between the operations staff and the 3 radiological staff. They didn't seem to have kind of a 4 mutual respect. What have you done to solve that problem?
5 MR. BIRD: First, we established the standard that l 6 there will be cooperation and mutual respect fnr the other 7 person's job, and the other person's viewpoints are 8 essential in a'high class organization. We have put 9 operators into the maint'enance side to help with planning, t 10 and radiological people to help with the maintenance work 11 planning. 12 We have the health physics technicians on shift 13 work, so that there's health physics coverage when it's 14 n'eeded on the back shitts, and my personal discussions with : 15 the watch engineers who set the tone for the way the other 16 operators deal with people outside the operat..ons 17 organization, as well as by all managers down through the 18 organization, have been a factor. l 19 We, of course, have had new managers in each of 20 those areas who work very well together, and they set the 21 example and the tone for their subordinates in the operation ; 22 and the subordinates are responding very well in my. opinion. I 23 Would you like to elaborate Ken? 34 MR. HIGHFILL: I thirk that pretty well covers it. 25 . We basically have established that radiological controls is Heritage Reporting Corporation (202) 628-4888 9 a
14 1 everybody's business, and not just HP. And I think tnat has 2 changed the attitude considerably. 3 MR. DIRD: Good point, and there are some other 4 steps that I've taken. I hold periodic all hands meetings, 5 and I discuss the issues which go across the ent' ire 6 organization, where it's part of everybody's job, such as 7 procedure, compliance, updating the procedures to be sure
- 8 they're accurate, and radiological controls, and each week 9 at my staff meeting I have an agenda for me to discuss 10 specifically radiological controls issues which have come up 11 during the preceding week, and to reinforce this view that 12 radiological controls, like security, and like fire 13 protection in particular, require everyone in the entire 14 organization to support them and understand them, because we 15 cannot have one section of the organization acting as a -
16 policeman or imposing standards on the rest. 17 It's got to be uniform standards understood across 18 the entire organization. I think the results in all of 19 those areas, in recent months, are a good indication of the 20 effectiveness. 21 MR. RUSSELL: Let me give you a flavor for what I 32 saw on Wednesday of last week, in going through a number of , 23 these places on site. What a remarkable change from the 24 situation of a year ago. I think that Ken and I went 35 through three, four rooms -- four? We were able to get into lieritage Reporting Corporation
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. 15 1 all of the areas, including poking our heads in the clean up 2 bunk rooms, which were whole PCs the last time I was there 3 before.
4 There's been a very substantial improvement. 5 Operators can now get to all of the equipment. The 6 contamination you're seeing is typically on the head plates 7 of the rotating machinery. Floor spaces are clean; you can 8 get up to the machinery, observe it and' inspect for leaks, 9 and the entire tour was conducted in street clothes. We 10 didn't have to suit up or cross step of f pads at any time, 11 and the inspection route was planned by the senior resident.- 12 It was not a pre-staged planned room for the inspection. We 13 chose where we wanted to go during the time we were there, 14 and there's been a major improvement in both radiological 15 controls and cleanup. 16 We also had a significant meeting with the company 17 on Monday of this week to address the long-term commitments 18 to continuing improvement in radiological controls. And the 19 two things that were most impressive were the resource 20 commitments and where on the company the relative priority 21 list'of some of the long-term improvements to improve 22 radiological control. 23 I would expect, if those trends continue, then we 24 would clearly be looking at an improved SALP category over 25 the next period. The principal reason that we kept it at a Heritage Reporting Corporation (202) 628-4888 f e .
16 1 3 is that we have been bitten before by projecting what 2 might occur. We need to see sustained performance over a 3 period of time, and had not seen that. 4 The second area that was of concern was the 5 message getting down to the working level within the 6 radiological controls organization as to what are the 7 policies and procedures, and the interfaces with other 8 organizations, and that has also improved sirc:e the SALP and 9 the IATI report. 10 MR. MURLEY: One time we had them under order. 11 Are they still under order? 12 MR. RUSSELL: Th9 order has been lifted. 13 MR. MURLEY: Closed out. 14 MP. BIRD! That was lifted last December, as I 15 recall. , 16 MR. MCDONALD: Let me make one more comment, 17 please. Would the speakers identify themselves for our 4 18 reporter? It's going to make it easier for the transcript. 19 MR. MURLEY: Are you talking to me, Dan? 20 MR. MCDONALD: Certainly, but Ken and Bill, and 21 anybody who speaks, so we do have an accurate record. Thank r 32 you. I 23 MR. BIRD: Moving on to the programs that we hava l l 34 in place to maintain the improvements that we've made in the 35 last few months, the success of our rigorous self-assessment Heritage Reporting Corporation (202) 628-4J88
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- 17 1 was confirmed by the smal.1 number of new items found by NPO 2 or by the IATI. And we're absolutely determined to avoid 3 complacency or backsliding in any area. We have made a 4 commitment to extensive programs to institutionalize ,
i 5 continued progress toward rising standards of excellence, 6 Today I 11 mention only a few of those which are in areas l 7 that are key to safe and reliable operation, or which have 8 been a concern to Boston Edison or the NRC in the past. 9 Our commitment to retain the best talent and to ; 4. 10 develop our employees to be among the best in the industry 11 will continue. Because of the clearly demonstrated 12 benefits, we will maintain the program of self-assessment 13 under the management oversight and assessment team which I
! 14 chair. The lessons learned from self-assessment during the ,
d i 15 power ascension program will be incorporated into our -{ 16 permanent programs. >
- 17 The radiological action plan and the material j 18 condition improvement action plan are the most comprehensive 19 programs resulting from our self. assessments, and have shown 4 i 20 their importance to the organization. However, since we '
I 21' have covered those in past discussions, today I'd like to
- i 22 highlight a few of the others, which, although they're i
23 narrower in scope, combine to be an important part of the l 24 basis for continued progress. , 25 The engineering was a strength in my original , l Heritage Reporting Corporation (202) 628-4888 ; 4 , i - - I i, - l
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18 1 assessment of the nuclear organization, and engineering and 2 technical support has been given the highest possible SALP 3 rating ever since the NRC began evaluating this as a 4 separate category. 5 The. safety enhancement program is an Boston Edison 6 initiative which emphasizes prevention of core damage 7 accidents. The program, which includes equipment 8 modifications and revised emergency operating procedures, 9 has placed Pilgrim at the forefront of the technology. 10 Past criticism of operations was based -- 11 Yes? 12 MR. WESSMAN: Can I interrupt? 13 Dick Wessman from NRR. 14 Can you summarize for us where you are on the 15 direct torus vent installation of the valves on that, and . 16 also can you summarize where you are as far as heading to 17 neet the station blackout rule that was recently 1,8 promulgated? 19 MR. BIRD: Okay. I will start, and Ed Houard will 20 add in if there's anything to add. 21 The direct torus vont installation is proceeding. 22 It will not be placed in service until we have received some 23 feedback from you on review of the installation. But we 24 expect it will be placed in service rather quickly. 25 The station blackout, as you know, we've installed Heritage Reporting Corporation (202) 628-4888 G S
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0 19 1 a third diesel generator as part of the safety enhcncement 2 program, and I'm not sure if we've completed our review 3 against the station blackout rule, but we believe we 4 essentially meet it. Ed, would you elaborate on that? 5 MR. HOWARD: We haven't completed -- , 6 I'm Ed Howard, vice president of nuclear 7 engineering for Boston Edison. 8 We have not completed review of our station 9 blackout improvements against the rule at this time. We 10 have probably gone beyond the requirements, the rules, from 11 our general sense of things. We both have an extended DC 12 battery capability as well as the third backup diesel. 13 MR. WESSMAN: Thank you. Our review of your torus 14 matched up -- occontially completo, and I expect that we'll 15 issue that result to you within the week. , 16 MR. BIRD: Good. Thank you. 17 MR. HOWARD: Just a supplement. The only actions 18 we have remaining to be able to make the system operational 19 are the revision of one satellite procedure, the emergency 20 operating procedures are -- handle the direct torus vent as al they would any venting situation. And the satellite 22 procedure just prescribes the specific mechanical actions 33 for the uso of the direct torus vent. 24 And then following the procedure revision, 25 operator training. Heritage Reporting CorporaP.lon (202) 628-4888 e O
20 1 MR. MURLEY: Do I understand the Rev. 4 is in 2 place and your ope,rators are trained on them, and that is 3 what you have in effect at this time? 4 MR. BIRD: Yes, that's correct. 5 MR. MURLEY: Okay. 6 MR. BIRD: To continue in the subject of 7 operational readiness, past criticism of operations was 8 based on the fact that we had too few licensed operators 9 that worked too much overtime. The competence of the 10 operators was not in question. We have tripled the number l 11 of licensed operators, and we will be able to staff a six-
?
12 shift rotation near the end of the power ascension and test i 13 program. 14 To insure that we continue to have plency of 15 operators, classes leading to licenses for new reactor . 16 operators and senior reactor operators will begin in , 17 January, 1989. The fact that no operator has left the job l 18 this year is an indicator of improved morale, but we intend 19 to have enough operators in the pipeline so that in the 20 future some operators can move to other jobs without 21 adversely affecting the operation. 22 New and improved procedures help the operators to ( 23 do their jobs. Formal comrnunications and uniforms add *,s 24 the professional atmosphere. And our new state-of-the-art, 25 plant-specific simulator has greatly improved training. All Heritage Reporting Corporation (202) 628-4888 9 9
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21 I watch standers have been trained on the emergency operating 2 procedures, provision 4, BWRS group guidelines, and use of 3 the simulator has allowed the operators to perform casualty 4 drills that validate the emergency operating procedures as 5 well as the drills that validate other emergency operating 6 procedures. 7 The establishment of the systems engineering 8 division was a major step toward improving plant 9 reliability. Each major system new has an owner. Their 10 programs iniclude routine walkdowns of major plant systems, 11 to identify and correct problems before failures occur; and < 12 routine trending of key system operating parameters for 13 early identification of equipment that's deg,rading. The 14 systema enginewt. provide in-depth, root cause 4.. lvses of 15 plant events and equipment failure, and technical support of . 16 maintenance activities to ensure that repairs are effective. 17 I think that among the more important steps to 18 insure future success are those that prepare people to move 19 up and to take on added responsibilities. This is a path 20 that starts with recruiting the best possible person for 21 every job and then providing training and opportunity for 22 advancement. And I feel a very strong personal 23 responsibility for recruiting, training and de'voloping our 24 people. 25 We have a first rate group in Boston Edison's Heritage Reporting Corporation (202) 628-4883 4
22 J 1 nuclear organization, and we will have the programs that 2 they need to succeed. Among those are a college degree 3 - that will be available to operators and other 4 ps , for enhancing professionalism, for personal 5 fulfillment, and for future advancement; Career development 6 and planning for key management personnel; more initial 7 training and more continuing development training for i 8 managers; and an improved performance appraisal system.
! 9 Mov'ing now to the powers ascension and test 10 program, we worked very hard to be ready to restart Pilgrim, l
11 but restart is not the end of the process, but is the 1 12 beginning of a careful and deliberate power ascension and
! 13 test program, which has been reviewed and approved by the i 14 HRC staff. Tliw cuiitpony ha apgraded plant ayatema. We've A5 expanded and improved the nuclear organization, and we've .
3 16 assisted the Commonwealth of Massachusetts and the local
. 17 towns to improvo off-site emergoncy plans. We're taking the 1
18 same careful, methodical approach to the power ascension and 19 test program. 1 l 20 There are five NRC approval points in the power i 21 ascension program start-up, five percent, 25 percent, 50, 22 and 15 percent power. At each level, operator training and f 33 related assessments will be conducted. Boston Edison will
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24 have an extra senior operator on each shift. An experienced 1 25 senior management oversight team will provide additional j 1 1 lieritage Reporting Corporation i l (202) 628-4888 ; t i ! 1
23 i i supervision at key points, particularly any tests, other 2 dynamic operation of the plant, and the changes in power , 3 level in particular will be monitored very closely by this { 4 nanagement team. 5 And ascenslon from one power level to another will 6 require approval by both the Boston Edison management and by l 7 the NRC staff. 8 The program is scheduled for about four months, 9 and will confirm the readiness of the personnel and the ! 10 plant for continued safe and reliable operation. : i 11 MR. MURLEY: Question. . 12 MR. BIRD: Yes. 13 MR. MURLEY: The extra SRO, that is on all shifts? ' 11 MR. BIRD: That'9 corract. , 15 MR. MURLEY: What is his function? .i 16 MR. BIRD: He will be an assistant to the watch t c 17 engineer. Primarily he will be out in the spaces, l 18 overseeing and supervising the non-licensed operators. He 19 will also be available for other assignments made by the 30 watch engineer. And he will be -- we intend that he will be l 21 a qualified watch engineer. 22 MR. MURLEY: The watch engineer is your term for . 23 the senior personnel in charge? ! 24 MR. BIRD: He's the top watch, right. l 25 MR. MURLEY: So that's gives you three SRos per t Heritage Reporting Corporation (202) 628-4888 . i k
24 ; 1 shift? 2 MR. BIRD: Correct. Plus the management oversight l 3 people, plus peer evaluators, many of whom also hold l
, 4 operating licenses or have held licenses in the past. Peer 5 evaluators will have no duties other than to assess what's j 6 going on and report to the manager that I put in charge of 7 that operation. That will be an independent check of what's !
i 8 going on. [ 9 MR. MURLEY: This management team -- I didn't 10 understand them to be on each shift. 11 MR. BIRD: Not continuously, for the entire four I 12 months, but when there are evolutions going on, I expect i 13 that we will have a senior manager on shift, in addition to t 14 all of the other oversight. f l 15 But because we're going to be operating in steady- .' i j 16 state plateaus for a while between the hole points, during l 17 those steady-state operations, assuming that things proceed ] 18 as we expect them to, we will take off at least the senior j 19 management oversight team and see that the normal line ! 20 operation in performing as it should. [ l 21 MR. MURLEY: Okay. ' 22 MR. RUSSELL: This is Bill Russell. i 23 Part of that concept of having that enhanced 5 24 oversight revert back to what would be a normal operation 31 25 load when.they're at steady state is to provide an 1 i Heritage Reporting Corporation l (202) 628-4888 , i i i t
o , 25 1 opportunity for NRC to evaluate performance of the plant at 2 reduced power levels over a period of time, such that when 3 we complete the program, we have coniidence that not only is 4 the management oversight activity sufficient to control 5 those evolutions associated with start-up, but the routine 6 aperation that's then in place is also satisfactory. 7 So the plateaus are intentionally rather long to 8 assess the ability of the crew to conduct such things as 9 surveillance testing, routine operations, and to complete 10 the needed power operations above 20 percent power for those 11 licenses which are conditioned to cold operation. So it is 12 quite a lengthy plateau at each step. I believe the 25 13 , percent plateau is probably the longest, and at the end of 14 the 25 percent power plateau, there are some special testa 15 in evolution. . 16 During the periods of time the power is 17 increasing, or the periods of time where there are these 18 special tests or other evolution, NRC will also be in round-19 the-clock coverage during those evolutions. We will ther. go 20 to a more norma >. mode of monitoring, unannounced inspection, 21 back shift, et cetera, during the steady-state plateau 22 periods at low power, to evaluate routine operations. 23 So the two programs have been coordinated from the 24 standpoint of our resources, what inspections we need to 35 conduct over what periods of time, and te are specifically Heritage Reporting Corporation (202) 628-4888
e - O 26 1 looking for a conclusion from the company's management team l i 2 that's there on two points. One, they would feel t 3 comfortable and are ready to stand down and allow the normal r 4 crew to operate steady state. And secondly, that they are 5 prepared to propose operation at the next plateau. So we 6 are going to be looking for those two statements from the f 1 7 company, and then of course, our assessment will be to 8 evaluate that readiness independently. 4 9 MR. MURLEY: How many of your licensed operators 10 have actually operated a commercial plant before? 11 MR. BIRDt Those who will be operating during the 12 power ascension program for shifts, I think that the answer 13 will be, all. Can you help me on that, Ron? 14 Mh. LEDGETT: Well, there are eight fully 15 qualified reactor operators. . 16 This is Ron Ledgett, director of special programs. 17 MR. BIRD: Two per shift. 18 MR. LEDGETT: Two per shift, which is the 19 requirement for four shifts. 20 MR. BIRD: And the watch engineers, their 21 supervisors also have operated Pilgrim. 22 MR. LEDGETT: That's right. 23 MR. BIRD: We don't see the new people wu'vu 24 brought in and gone through license training have cold 35 licenses, but they are not qualified to operate until we've Heritage Reporting Corporation (202) 628-4888
27 1 got, I think, 20. days at power operation. 2 MR. MURLEY: That was the thrust of my question. 3 You do have an enough for a full shift complement? 4 MR. BIRD: Full shift, plus the extra watch 6 5 engineer on each shift, yes. And we've elected to go to 6 four shifts for the power ascension and test program 7 specifically so we could provide the extra supervisory 8 talent on each shift. We'll be in a position to go into six 9 shifts sometime near the end of the power ascension program, 10 depending on how satisfied we with the new operators and 11 their performance.in the. teams. 12 MR. RUSSELL: Let me clarify the earlier issue 13 that started this out. It was the number of licensed t 14 reactor operators, not senior operators. They have more 15 than a sufficient number of expcrienced senior operators.
. f 16 In this case, they have sufficient reactor operators for the i
17 four-shift rotation, and as they've had time and operation 18 above 20 percent power, the license condition on the new - r 19 operators that have been licensed since the shutdown would l t 20 be lifted, and then they would move into a six-shift 21 rotation. ! r 32 Whether that occurs during the 50 percent plateau, ! 23 or 75 percent, the expectation is that it would occur prior l f 34 to the completion of the power ascension program, such that } l 35 the NRC would bo in a position to evaluate the transition 7 Heritage Reporting Corporation { (202) 628-4888 . j l
28 i i from a four-shift operation to a five-shift or a six-shift ! 2 operation. 3 MR. BIRD: Yes. Now we, by taking senior reactor 4 operators and putting them down on reactor operator watches, ; 5 we could have manned more than four shift. I think we could ; 6 probably have manned six, if we wanted to, but I felt that 7 this is a better way to go. It's more conservative, and it ' t 8 gives us more strength on each shift. And it leaves people 9 manning their normal watches, puts the best talent where l 10 they have the most experience. l 11 MR. RUSSELL: Okay. I 12 MR. BIRD: To conclude, the work and the testing 13 required to be done, we expect will be complete by October 14 14. Based on the results of the restart plan and our I l 15 restart readiness self-assessment, we conclude that tha ,! t i 16 necessary conditions for a restart, set for in confirma:ory ! ! F j 17 action letter 86-10, and the supplement to that letter, will i t ; l 18 have been satisfied, and that Pilgrim will be ready to f i j 19 proceed into the pilot program. ! I j 20 Morale in the organization is high. It shows in ! al many ways and has been noted by all of our recent visitors. ). 32 We are working to a nuclear ethic that is common to the ! 23 management team. You ccn see it in the professionalism of f i 34 the operators and the dedication of the employees at overy l l l l 35 level. i l J t j Heritage Reporting Corporation i (202) 628-4888 r I i r _ _ _ _ _ _ _ _ _ _ . _ . _ _ , _ . e
29 1 And we ar'e committed to making it easier for . 2 people to do the right thing, and they are responding. 3 Therefore, on behalf of Boston Edison, we intend to request l 4 an affirmative vote from the Commission on restart, on ; 5 October 14. ! 6 I will be followed now, if you have no other ; 7 questions for me, by Rob Varley, who will give you some data [ 8 on where the emergency planning process stands. h l 9 MR. RUSSELL: Tom, I do have some questions on I l 10 management and technical issues. We believe that these are l 11 resolved, but these are, from a historical perspective. l 12 Some were touched on in the presentation, but I'd like to, ! 13 for the record, get the company's response to each of the 14 four issues identified back in 1986 time fromw, facturc [ 15 which were contributing to the inability to reach . 16 resolution. 17 The four problems identified were, first, 18 incomplete staffing, in particular reactor operators and key 19 mid-level supervisory personnel. ' believe that Mr. Bird 30 has addressed that in the presentation, but I would like to 21 get the company view on the record with respect to that , 22 particular issue. 33 MR. BIRD: We have increased the number of 34 licensed reactor operators if you count the cold licenses, 35 the people that have passed the NRC licensing requirements, Heritage ' Reporting Corporation (202) 628-4888
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30 1 we have increased that number from eight in 1987 to about 22 2 now. We intend to hold that number. Twenty-two og 23. , 3 Does that answer that particular concern? 4 MR. RUSSELL: Yes. 5 The second issue was -- and this is coming out of
- 6 the SALP review and the management me'eting that led up to 7 the supplement to the confirmation of action letter -- the 8 second point is that the prevailing view in the organization 9 was that the improvements made to date had corrected the 10 problem.
11 M R_. B I RD s., None of us here believe that the 12 process of improvement, or the quest for excellence is ever I . !. 13 finished. Since I've been with the company, we have even il 14 written into tne corpordte, Boston Edison corporate l 15 objectives, a commitment to rising standards of excellence. ' l I i 16 Obviously we completely support that commitment in. , l 17 the nucioar organization. It is reflected in the i j 18 improvements that we've made to date and in our commitment 1
- 19 to continuing improvements, our self-assessment process. t 1
1 20 And it's part of our long-term plan. It's a conscious [ a j 21 decision and thought process we've gone through on our i 1 1 22 budgeting, for both this year and for next year and on out ! l i j 23 into the future, to insure that we put tne money into the } : i 24 budget, into the areas that will produce the rising ; l 25 standards of excellence in each area that's important to i l' Heritage Reporting Corporation : l (202) 628-4888 . l 1' l 4 ! i o . . _ .
G - 31 1 operation of a nuclear power plant. 2 MR. RUSSELL: And the third point was a reluctance 3 by management to acknowledge problems identified by NRC. 4 MR. BIRD: This will be a subjective answer, but I 5 don't think that you see a reluctance to respond to NRC 6 concerns, nor do I think you see any defensiveness in us. 7 You are really in quite a good position to judge that. I 8 have my views. I don't think that show fits anymore, if it 9 ever did. 10 MR. RUSSELL: And the final point was a dependence 11 on third parties to identify problems rather than - 12 implementing effective programs for identification of 13 weaknesses. , 14 MR. BIRD: There are avveral indicature I can 15' point to there. First, our determination to drastically . 16 reduce our reliance on contractors and consultants, which is 17 reflected in the increased Boston Edison staffing, the 18 increase in the number of top management people, top-quality 19 management people, the reduction of the span of control for 20 the managers, and our own self-assessment process, again,. as 21 a good example. 22 MR. RUSSELL: The reason I wanted to review those 33 'again, because the gentleman sitting here by my side was a 24 principal author of those four points, and while I had 25 provided input to him, I thought it would be best to hear it Heritage Reporting Corporation
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c 32 1 from the company, since you're the one that has to implemerit 2 the programs to make those thiny be lasting corrections. 3 MR. BIRD: Anyone in the Boston Edison group that 4 would like to add anything? 5 If there are no other questions, I'll turn the 6 floor over to Ron Varley. 7 (A copy of Mr. Dird's 9 presentation slides was marked
) for identification as l') Attachment 2.)
11 MR. MURLEY: Okay. Is that next on our agenda? 12 MR. MCDO!1ALD: Yes. , 13 MR. VARLEY: Good afternoon. My name is Ron 14 Varley, and I am the mancgor of Oc: ten Edi:en': cmcrgency 15 preparedness department. . 16 As I understand it, we have been asked by the 17 staff to describe our current state of knowledge in two 18 areas. First, the overall status of the off-site emergency 19 preparedness program around Pilgrim station. And second, 20 the status of~the issues identified by the federal emergency al management agency in its August 1987 self-initiated review. 22 Bef ore proceeding in providing the information 33 requested.tur the staff, I'd like to make one important 24 point. We believe that the significant prog'ress that has 25 been achieved to date in improving the .off-site program is lloritage Reporting Corporation (202) 628-4888
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O 33 1 due, in some measure, to our recognition that the program 2 belongs to the Commonwealth and the towns, and that our 3 legitimate role is to provide assistance to them. 4 Accordingly, I want to stress that the views presented today 5 are those of Boston Edison, and that I am not speaking on 6 behalf of either the Commonwealth or the towns. 7 As I will discuss in some detail, great deal of 8 progress has been made in upgrading the status of off-site 9 emergency preparedness around Pilgrim Station. The quality 10 of those improvements under way has been explicitly 11 recognized by FEMA.
- 3. I'd like to begin by citing the basic improvements 13 to the off-site emergency, response program achieved to date.
14 These include, among other things, enhanced' draft plans, new 15 implenienting procedures, implementation of a new training 16 program, a revised and updated evacuation time estimate, and 17 numerous forms of technical and financial assistance that's 18 being provided by Boston Edison. A fuller account of these 19 improvements is contained in our written response to the 20 NRC's information request . 31 Boston Edison has been engaged in a comprehensive 32 program of assistance to the commonwealth and local 23 governments. Since the summer of 1987, a team of between 20 24 and 30 Boston Edison employees and professional emergency 35 planning consultants has been working on a dey-to-day basis Heritago Reporting Corporat!.on
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34 1 with local and Commonwealth officials. Boston Edison has 2 spent about $10 mi). lion in its assistance efforts since 3 August of 1987 and expects to spend an additional $5 million - 4 in 1988. 5 Drafts of revised emergency. response plans for all 6 seven towns and for MCDA area 2 have been pi ,parad. Local 7 civil defense directors and other responsible town officials i 8 have been intimately involved in their preparation. As of 9 last evening, five of the seven towns have forwarded revised 10 draft emergency plans, full sets of draft, detailed , 11 implementing proceuures, and draft shelter implementation ; 12 programs to the Commonwealth for their review and for ; 13 forwarding to FEMA for a second round of informal technical 14 reviews. Late last month the Commonwealth also submitted a , I 15 draft of their area 2 plane for FEMA informal technical 16 review as well. 17 FEMA's first round of informai reviews resulted in 18 requests for various corrections and additional information j 19 to be provided on the town's draft plans and looked to the ! i 20 submission of implementing procedures as well. They ilso l 21 indicated in theit first review that they believed that some ! outstanding improvements were being made in the program. 32 33 FEMA's specific comments have been incorporated into the new . 34 revisions of the towns' draft plans that are being i 25 submitted. l I Heritage Reporting Corporation (202) 628-4888
35 1 in addition to the plans themselves, hundreds of 2 detailed draft implementing procedures for responsible 3 officials and emergency workers have been prepared. 4 Facility-specific draft procedures have been developed for 5 each school, licensed day-care center, nursing home, or 6 other special facility in the EPZ. 7 The dratt implementing procedures contain detailed 8 checklists of actions to be taken by the responsible persons 9 under each of the possible emergency classifications. The 10 checklists contain, in the procedures, carefully prioritized 11 actions and specify individual responsibilities. 12 Development of the draft implementing procedures in our 1 13 opinion represents a significant accomplishment. They 14 provide detailed, structured cuidance, and are integrated 15 with the Commonwealth's response program. These new 9 16 procedures will greatly assist the towns in performing 17 effectively in the event of an emergency. 18 An entirely new training program is another 19 important element of the efforts to upgrade the off-site 20 emergency preparedness program. Over 500 specific lesson 31 plans have been prepared. These tretning materials are
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32 designed to assist emergency response personnel in better 23 understanding the specific tasks and the responsibilities 34 set forth in the detailed implementing procedures. 25 Almost all of the lesson plans have been prepared, lieritage Reporting Corporation
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'I and training of emergency response personne1 by 2 . Commonwealth-certified instructors is wel?. under way.
For 3 example, as of last week, approximately 500 bus drivers have 4 received full classroom training. 5 In additional to traditional classroom training, 6 an additional tool has been developed that will further 7 enhance the training effort. That tool is the 8 implementation of hands-on training for bus, van and 9 ambulance drivers. The hands-on training supplements the 10 standard classroom training, enable participants to actively 11 perform various key tasks associated with the protection of 12 several population of special concern within the EPZ. Those 13 populations are school and day-care centers, the special 14 nands. population and paranns who are transportation 15 dependent. , 16 To date, eight hands-on training sessions have 17 been conducted, and another eight session have been 18 scheduled through mid-October. 19 In addivion to our efforts to assist in the 30 enhancement of plans, procedures, and training, Bostdn 21 Edison has undertaken a number of other significant 22 initiatives. We commissioned the development of an updated, 23 state-of-the-art set of evacuation time estimates by a 34 nationall'y recognized authority. The final evacuation time 25 estimate incorporates reviews by Commonwealth and local Heritage Reporting Corporation (202) 628-4888 i
y - _ _ _ _ , - - - _ - _ i 37 . 1 officials, as well as by police departments and other , 2 agencies that would be involved in traffic management 3 activities within the EPZ in the even of an emergency at . 4 Pilgrim. We will soon provide a separate document that l ] 5 contained traffic management plans for the reception c nter
- 6 communities and the communities bstween the EPZ ar.d t 7 reception center communities.
l 8 Boston Edison has also funded and directed the ' i 9 renovation of emergency operation centers in all five EPZ : 10 towns and the two reception center communities. EOC i 11 renovations have been completed in Taunton, Kingston and ! 12 Plymouth. Only non-operational items remain to be completed f
't 4 .13 in Carver and Bridgewater. The Duxbury EOC construction 11 offert ch'ould be completed shortly, and the Marshville-EOC 4 >
,l 15 construction effort is scheduled for completion by the end l
i 16 of 1988. , I d
. 17 Boston Edi..n is providing over two and a half 1
18 million dollars to renovate and equip these EOCs. ! i ] 19 MR. MURLEY: Is that included in your ten million j . 20 dollar estimate? 21 , MR. VARLEY: Yes. I 22 MR. MURLEY: So did I understand that your ten f 23 million dollar estimate is what you've expended to date, or i i 24 what you expect to expend in total. : 1 I j 25 MR. VARLEY: Fifteen million in total by the time j i t i I Heritage Reporting Corporation .f j (202) 628-4888 i i i i l
6,) e 38 1 we're through in 1989. 2.5 million of that is set aside for _2 EOCs and the equipping of the EOCs. - 3 MR. MURLEY: Thank you s : 4 MR. VARLEY: Finally, Boston Edison has entered 5 into agreements to fund a full-time civil defense staff 6 position in each of'the seven towns for the operating life J
- 7 of Pilgrim. ;
8 Also, comprehensive grant agreements entered into 9 with each of,the towns provide, among other things, for- [ i i 10 additional material assistance such as purchasing of ;
- 11 comununications and traf fic control equipment.
12 Boston Edison is also compensating emergency 13 workers for their time spent in classroom' training. f u ; J 14 ~Th0 actions wtAch I have just summarized represent j i ] 15 a brief overviaw of the overall offort we have undertaken to ; 1 t 16 assist in the up1rading of the off-site emergency response , l 17 program. I'd now like to turn to the actions taken to l 18 address the specific issues identified by FEMA in its self-19 initiated review. Again, a more detailed discussion is { 20 presented in our written submission to the NRC's request for j 21 information. f 22 FEMA's self-initiated review outlines six areas of ! 23 major concern. The first of those criticized the lack of l
&4 evacuation plans fo: public ind private schools and day-care
.! t 25 centers. In response to that concern, the draft local plans l h j i i
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y ------ ---- ------ . - 39 1 now contain lists which identify the public schools, private 2 schools, and licensed day-care centers in the EPZ. These 3 listing are also contained in the relevant draft 4 implementing procedures so that they're readily available to 5 emergency response officials. 6 Specific draft implementing procedures now provide 7 detailed direction and guidance to the responsible emergency 8 response personnel in carrying out their action. Draft
- 9 facility-specific procedures have been developed for each 10 schcol and licensed day-care center. Moreov9r, while we 11 have estimated that 313 buses and 26 vans may be needed to l 12 transport the maximum school and day-care conter population,
- 13 transportation providers representing over 1100 buses and
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14 147 vans have documented their willingness to assist. 15 The second issue raised by FEMA in it self-16 initiated review was the lack of a reception center for 17 people evacuating to the north. At the time that the SIR 18 was issued, the existing off-site program utilized the 1 19 Taunton State Hospital and Bridgewater State College as t 20 reception centens for persons evacuating from the EPZ. The 21 Hanover Mall had been designated as a third reception center 22 but was no longer'evailable for that purpose at the timo of 23 the completion of FEMA's review. 24 In December of last year, we completed and 25 transmitted to the NRC a report which assessed the Heritage Reporting Corporation (202) 628-4888 6
40 1 capability of Taunton and Bridgewater facilities to monitor 2 the population for contaminat on in the Pilgrim EPZ in 3 accordance with all federal guidance. The primary purpose 4 of that analysis was to determine whether the objective of 5 the foderal guidance could be achieved using two rather than 6 three reception centers. The analysis summarized in the 7 report concluded that Taunton and Bridgewater facilities, 8 with appropriate improvements and equipment procurement, 9 would have the capability for monitoring the requisite 10 number of people evacuating from the EP3. 11 While there have since been minor changes in some 12 of the logistics, the conclusion of the analysis remains 13 valid. Facility improvements and equipment procurement will l4 be undertaken as soon as arrangements with the Commonwealth 15 are concluded. , 16 The third issue raised by FEMA was the lack of 17 identifiable shelters for beach population. In response to 18 this issue, a comprehensive shelter implementation program 19 that far exceeds applicable regulatory requirements has been 20 developed at Pilgrlm. The program will insure that persons on the beaches and at other major outdoor recreational areas l 21 22 as well have access to adequate shelter in the event of an 23 emergency. 24 In order to insure that adequate sheltering l 25 capacity existed, local officials, assisted by Boston ! Heritage Reporting Corporation (202) 628-4888 I 1
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41 ; 1 Edison, met over the course of the last year with building 2 management in each of the towns to identify available 3 shelter capacity. Individual buildings were determined to 4 be readily accessible before they were designated as public 5 shelters. Structures were selected that were near the beach 6 and recreational areas. Each was visually inspected to 7 insure its accessibility and to develop specific floor 8 plans. 9 During these visits, the purpose of the specific 10 shelter programs was explained to building management, and 11 they were asked if they would be willing to participate in 12 the program. Once the structures were determined to be 13 accessible, suitable and available, Boston Edison entered 14 into agreement with private building owners to formalize , 15 agreements for their use or obtain municipal authorization 16 for buildings owned by the towns. ! 17 FEMA's fourth concern was inadequate planning -- 18 MR. MURLEY: Question. 19 MR. VARLEY: Yes. , 20 MR. MURLEY: I need to understand you language 21 there. Do you have such agreements, did you say? 22 MR. VARLEY: Yes, with every private building . 23 that's been identified as a shelter, we have an agreement 24 with the Lsilding owner that he will make that shelter , 25 available for access to the public. And, in fact, he has IIeritage Reporting Corporation (202) 628-4888
. 42 1 been trained on what his role is; he has procedures that he 2 identlfles and uses during sheltering.
3 For those building that were owned by the towns, 4 we have what we call municipal agreements, that the town 5 agrees that, yes, they would make it available for that 6 purpose. 7 MR. MURLEY: Okay. 8 MR. VARLEY: FEMA's fourth concern was inadequate 9 planning for evacuation in the special needs population. An 10 improved program is being developed to provide for the 11 protection of the special needs population. The program 12 includes the development of a detailed draft procedure 13 governing the maintenance and upgrading of the towns' 14 special needs listings. It also includes a system for civil 15 defense officials to verify the needs of individuals 16 identified on the special needs list, as well as to allow j 17 individuals to self-identify during the emergency. 18 Moreover, transportation providers controlling a 19 sufficient number of vehicles to evacuate special needs' 30 persons in an emergency, have documented their willingness I 31 to assist. To further strengthen the program, we are 32 concluding an agreement with the Commonwealth to initiate a 1 23 study of the special needs population within the EPZ. 34 FEMA's fifth concern was inadequate planning for 35 evacuation of transportation dependent persons. Detailed l Heritage Reporting Corporation (202) 628-4888 e '
c 43 t
- 1. draft plans and procedures to 1rotect this segment of~the 2 population have also been developed. Draft local plans i-3 provide for the dispatch of buses to specific bus routes in 4 the EPZ for pickup of persons requiring transportation 5 assistance.
6 And finally, FEMA's sixth concern pointed out the 7 overall lack of progress in planning achieved as of August 8 of last year. Whatever the status of emergency preparedness I 9 was at that time, significant progress has been achieved 10 since FEMA's report was issued. 11 We believe that the current situation is markedly 12 different from the circumstances when the SIR was issued. I 13 And I'd like to conclude by saying that the program in 14 improving the state of off-site emergency preparedness has 15 been achieved to date as a result of a product of a 16 cooperative effort between off-site officials and Boston 17 Edison. We are firmly committed to continuing to assist the 18 Commonwealth and the towns in improving their off-site 19 emergency preparedness program. , 30 That's the end of my statement. 31 MR. TRAVERS: Now that FEMA -- 32 I'm Bill Travers, by the way. 23 Now that FEMA has taken a position that sheltering 24 per se is not required, does BECO still intend to continue 25 with the sheltering program? Heritage Reporting Corporation (202) 6?8-4888 e B 3 e_- 3
. 44 1 MR. VARLEY: Yes. We believe that we want to have
, 2 - sheltering as a viable part of our emergency preparedness 3 program, and we believe we have a very good shelter programs 4 that more than meets all of the requirements and is a very 5 viable part of our decision-making process. 6 MR. BELLAMY: Ron, this is Ron B'ellamy. 7 You talked a little bit about the school children, 8 and you used the term documentation. Is that -- are you 9 using documentation to be synonymous with letters of 10 agreement with the school buses and the school bus drivers? 11 MR. VARLEY: We currently have letter of agreement 12 that were signed by the bus companies. At the time, it was 13 envisioned that the state vould also enter into that letter 14 of agreement. Further discussions with the. state have ! 15 indicated that rather than have a letter of agreement of i 16 that nature, what they are looking for is a letter from the i 17 bus company that explicitly states their understanding of 18 their role during a response. And we are formulating those i 19 letters to go back to the bus company, so that they will 20 send a letter to the state, indicating their knowledge of ! 21 their involvement and to the extent that they will be ! r 22 involved. ! 23 MR. BELLAMY: So you believe that the f 24 documentation is there, and the Commonwealth has indicated i 25 that they would like a letter directly from the bus
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1 companics, and that's what you're working on? 2 MR. VARLEY: Yes. 3 MR. RUSSELL: Bill Russell, Region F. 4 One of the issues that came up last Thursday night 5 was raised by an emergency planner from Duxbury, raising a 6 concern about the shelter effectiveness of the Duxbury 7 emergency operations center, the view being that if they 8 were in the process of conducting an evacuation, the people 9 that were staying behind to handle that evacuation activity J 10 would not be sheltered. Could you provide some background > I 11 as to the decision-making process that resulted in a wood-12 frame structure for that EOC, as compared to a hardened 13 facility? 14 MR. VARLEY: Sure. All of the town EOCs are 15 essentially either in existing buildings or buildings that 16 were added on in the facility that the town chose as being 17 their place for a command and control and decision-making 18 point. Those facilities are designed for decision-makers to 19 come together to make decisions and to implement protective O. 0 actions for their towns. They have in their draft al procedures provisions that, in the case of Duxbury, should 22 the decision be made.for Duxbury to evacuate, that once all 33 of the people from Duxbury are evacuated, then.their EOC is 34 also evacuated, and the shift to an alternate location to l 35 continue to carry out their responsibilities. Heritage Reporting . Corporation ; (202) 628-4880 ' O e l
. 46 1 None of the town programs are envisioned that 2 their EOCs continue to function after the town has been 3 evacuated, but they reassemble outside of the town, and 4 continue to make -- decision-making for that town outside of 5 the town boundaries.
6 MR. BELLAMY: J'ust one more question. Ron 7 Bellamy. 8 You talked about training bus drivers, emergency 9 workers, et cetera. Can you give us a sense of the schedule 10 that you're on for completing the training for workers? ) 11 MR. VARLEY: We currently have about 30 percent of t 12 the training done, and we would envision that as we continue - 13 into the fall and winter months, we should be somewhere - 14 around 80 to 100 percer.t trained' by the end of the year. 15 Again, a lot of that scheduling is dictated by 16 when the towns complete procedures, and when they are 17 willing to make their people available to be trained on 18 those procedures. i 19 MR. MURLEY: Tom Murley. [ 30 I have a series of questions. l l al Nhat actual observations have you made of these 32 training exercises to have confidence that the bus drivers 23 know where to go, that you have a complete list of the . 24 people, that the phones will work, that someone will answer ! i 35 them, and so forth? Have you actually, during these j Heritage Reporting Corporation (202) 628-4888 l
t . , i l , 47 l 1 training exercises, observed that these activities are r 2 taking place. , ! 3 MR. VARLEY: Well,'the hands-on training sessions : 1 t 4 are designed to be the next step in the process. After they : l i 5 get through with the classroom tr'aining, then we want to ! ! l take them out in the field and determine whether what we ! 6 7 have trained them in the classroom has been effective. l l t 8 So it starts out in the bus company when drivers j t 9 assemble and they go through getting the dosimotry packets, l 10 they get their directions to whatever particular location l 11 they will go to in the EPZ, and then they get in the bus and P 12 they drive. Now not all 30 or 40 of them drive a bus, and 13 the others ride in the bus, and the follow along on their , t 14 maps to verify that, in fact, yes, I can use this map, and 15 that the map is a good reflection, j 16 During that bus trip, then, we have instructors j 17 that ride on the buses that quiz them about, how would you [ t 18 read your dosimetry, do you understand what exposure levels ! 19 mean certain actions as you carry out your responsibilities. 20 Once they get to their destination, they're then quizzed on, l 21 what would you do at this destination, who do you meet with, l 22 who.do you talk to, who do you take direction from. ! I
. 23 They than go from whatever destination they were l 24 set to arrive at in the EP: to what other destination they j i
35 would arrive at, such as a reception center. They again use Heritage Reporting Corporation (202)'628-4888 ; I l
. j e
L . , . 48 l 1 maps and follow along with the maps and follow along with 2 the maps to determino if the can use maps and how effective 3 that is. That's the type of hande-on. training we're 4 providing right now. 5 MR. MURLEY: Has there been some of that training? 6 MR. VARLEY: Yes, we have done eight sessions of l 7 that so far, and we are scheduled to do another eight 8 through the middle of October. 9 MR. MURJ.EY: What plan do you contemplate using if 10 the Commission were to grant approval to start up? 11 MR. VARLEY: That question would probably best be 12 asked of the Commonwealth. 13 MR. MURLEY: No, you've got to make some phone 14 : ells, yourself. You've got a lot of alerting to do. 15 MR. VARLEY: Certainly, and we have a program in 16 place where we notify the towns. We have revised our 17 emergency planning program that became effective on October 18 1, and that program interfaces with the draft ptogram that 19 has'been developed in the towns? l 20 MR. MURLEY: Okay. ) 1 21 Is this essentially the same plan that existed 22 from your point of view, making the cause and so forth, that 23 existed for several years? 24 MR. VARLEY: The station's emergency plan? Is it 25 the same as what existed before? Heritage Reporting Corporation (202) 628-4888
49 l 1 MR. MURLEY: Yes. , i 2 4m. VARLEY: No, we have revised our on-site 3 program and' enhanced'it to reflect a lot of the new l 1 ,
- 4 philosophies that are being reflected in the draft town j
5 programs. 6 MR. MURLEY: Have we observed any of this? ) 7 MR. RUSSELL: We've had an on-site exercise in ) 8 December of -- '867 '87.
- 9 MR. BELLAMY
- That exercise was conducted in [
d ! i 10 Dacomber of 1987. We did observe it. l 3 11 MR. RUSSELL: We have also had observers that have i 12 observed the training of the bus drivers and the ambulance
! i j 13 drivers, and we're prepared to address that from the staff d
[ r . 14 viewpoint when appropriate. l, 15 MR. MURLEY: Okay. (' 16 MR. VARLEY: Thank you. i BoeJ 17 MR. MCDONALD: I believe that finishes the ( 18 presentation for Boston Edison. 4 19 , Mr. Agnes, if you would like to come to the podium i
- r j 80 and provide your comments. !
j !
- 81 KR. AGNES: Good afternoon, Dr. Murley, members of j- 22 the NRC staff and representatives from Boston Edison Company f i
j 33 from the Commonwealth, from local cities and towns and j l } 1 84 others. [ l ! l 25 My name is Peter W. Agnes, Jr. I am the assistant j j {
. Heritage Reporting Corporation !
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50 1 secretary of public safety for the Commonwealth of 2 Massachusetts. I am here today representing Governor 3 Dukakis and the people of the Commonwealth of Massachusetts. 4 And before I begin, I would just like to acknowledge some of 5 the other people who are here who came down with me, who 6 came down on their own today to listen to this proceeding. ; 7 Mr. John Judge from the Governor's office is here. Mr. 8 George Dean from the Attorney General's office in 9 Massachusetts is here. Two individuals from the Nuclear 10 Safety Emergency Planning Program in Massachusetts are here, 11 John Sovring, the deputy director of the agency, ano Buzz
, 12 Hausner, who is the director of that program.
13 We also have two local officials from the Pilgrim ( 14 EPZ here. Mr. Doug Hadfield, who is the civil defense 15 director at Plymouth, and Mr. Carl O'Neill, who is both the 16 fire chief and the civil defense director in Duxabury, both 17 of whom, incidentally, had planned to offer sorae remarks, if , 18 possible, and I would certainly urge the members of the NRC ] 19 to afford them that opportunity. [ l 30 And I notice there are at least two residents from l
, i l 31 the area, and I apologize if there are others and I haven't i
32 noticed, but I notice Mary Dinan and Kate O'Brien from the 33 . Pilgrim EPZ are there. 34 I am not here today in the capacity that I'm
- 35 usually appearing in throughout my professional career as a ,
l t Heritage Reporting Corporation (202) 628-4888 4 l 1 t
51 1 attorney. I'.m not here as an adversary. I'm not here as a 2 participant. I am speaking here on behalf of the 3 Commonwealth of Massachusetts as a public safety official 4 concerned exclusively about the health and safety of both 5 the residents of the Pilgrim EPZ, personal who may travel in 6 and out of that area to work or for recreation, and for all 7 the other people in the commonwealth. 8 Emergency planning is the responsibility of the 9 Commonwealth of Massachusetts. That is something that we 10 have acknowledged time and again, and have never tried to ! 1 11 shift responsibility to anyone else. Yet, it seems to me 12 from both the proceeding here today and from other 13 proceedings in which the NRC has sponsored, that the NRC 14 seems to be more interested in the views of the licensee 15 with respect to emergency planning offsite than it is in tha , 16 views of the Commonwealth of Massachusetts or local t A7 officials or residents. 18 It seems to me that the commonwealth is here today j 19 to be heard only after you have heard the views of the ; 20 licensee, and frankly, only after you have once again spent a considerable amount of time listening to both the views of l al [ 32 Boston Edison and of your staff with respect to technical ; I 33 issues. i 34 Now, in the last month or so, I have attended 35 numerous meetings where technical issues have been the focus t i I lioritage Reporting Corporation 1 (202) 628-4888 , l i
52 1 of the meeting, the exclusive subject, or at least the 2 dominant subject of' a meeting. That includes the exit 3 interview for the most recent SALP report, the IATI, exit 4 interview meeting, the subcommittee meeting for the ACRS j 5 that was' held in Plymouth, the meeting that Mr. Russell held [ 6 in Plymouth last week, but there has never been a meeting in 7 Plymouth, certainly not in the last year that I'm aware of, 8 where the NRC has gone to the area and asked the i 9 commonwealth and local cities and towns to come and talk 10 about emergency planning. 3 l 11 And it seems that again we are here today only at l 12 the very end of a meeting that has otherwise been given over I a l 13 to technical issues. In a meeting that, frankly, most !
! 14 people simply can't attend. There are many people in the
[ [ 15 Pilgrim EPZ, there are many local officials who have ,
?
j 16 religiously, if you will, attsnded planning sessions week in j 17 and week out for the past year who have attended those l 1 18 meetings in r.he spirit of trying to work with the licensee j ]' r I 19 and the commonwealth to develop the very best possible plan, j i 30 who have legitimate concerns and who would like an ; I al opportunity to be hearo, but who simply can't come to l
- 32 Rofkville, Maryland, to 6.~oress their opinions.
I d 23 So while I will try to speak on their behalf, I l 34 cannot and I don't think the NRC in good conscious can f 1 j 35 expect one representative of the commonwealth to convey i l ! ) Heritage Reporting Corporation ! (202) 628-4888 , j l i i
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, 53 I their concerns.
2 For that reason, the Commonwealth of Massachusetts 3 is hosting a meeting in Plymouth or Duxsbury, I should say, 4 tomorrow evening that we will transcribe and that we will 5 deliver to the NRC Commission in advance of their meeting on 6 October 14th, so that there will be at least one public 7 meeting where the public and local officials have a real 8 opportunity to express their views on these issues. 9 And as I said a few moments ago, it seems to me l 10 that there has been a decided emphasis placed on the 11 resolution of technical issues of the past year, but not the 12 same degree of emphasize by the NRC staff on the resolution 13 of emergency planning issues. 14 I have heard time and again representatives of the 15 NRC indicate the thousands and thousands of hours that have 16 been spent either on site at the Pilgrim Nuclear Power Plant 17 or in meetings with the licensee in order to identify and 18 resolve these hundreds of technical issues which we have 19 been confronted with ever the past several years since the 80 facility shut down in April of 1986. 21 But I dare share that there has been a fraction of 32 that time spent, in my judgment,.by the NRC vith respect to 33 offsite emergency planning issues. And I havs 'ieard in 24 several instances here today references to the so-called 35 self-initiated review that was done by FEMA in August of Heritage Reporting Corporation (202) 628-4808
54 1 1987, which has been discussed, as I said, several times. 2 We met with FEMA in the fall of 1987, after that 3 review was prepared. We discussed the issues. We told the 4 regional administrator of FEMA, Mr. Vickers, very clearly 5 what we planned to do, what the process was that we intended 6 to follow, and we were told by Mr. V;ckers how carefully 7 FEMA intended to monitor that process and how interested 8 they were. - 9 Well, the fact of the matter is that since that ! l 10 meeting I have nc c seen any evidence of any interest on the j 11 part of FEMA. We assume they have reviewed material when ! I 12 it's been sent to them. They have not bothered to come to i 13 any one of the hundreds of planning meetings that have been i 14 held by the commonwealth, by local cities and towns in that 15 interval. And when the NRC expressed some interest in
! 16 meeting with us in August, I believe it was, of this year to A7 talk about emergency planning, and FEMA was invited to 18 attend, they chose for whatever reason not to attend.
t 19 So it's very disturbing to me in tsrms of the 30 process that's being followed with regard to offsite I 31 emergency planning issues to hear time and again references l 32 to the FEMA self-initiated review and emphasis or, the' 33 concerns that FEMA had when in fact I have seen no l ! 24 indication that FEM.; has the slightest interest in the 25 efforts being made by the licensee or the commonwealth to s Heritage Reporting Corporation . 1 (202) 620-4888 I
55 1 resolve these concerns nor any interest in participating in 2 the process that we have established for dealing with some 3 of these issues. And I think in view of the role which FEMA , 4 is supposed to play in this area, that that is very, very 5 disturbing. 6 How in addition to cone?rns about the process, I 7 also have concerns about the standard that apparently the L 8 Commission will employ, and perhaps that you, Dr. Murley, 9 will employ to evaluate offsite emergency planning. There i lu are some very objective criteria that havn been employed by ; i 11 the restart reviuw group in Region I, and by other members 12 of the NRC, to deal with some of the technical issues. And i i 13 it seems that there is always a very objective measure of ! 14 whether a technical issue is a problem or is not a problem, - 15 whether it is open or whether it is closed, and what the i
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16 status of it is at any given moment. 17 And yet I have a very difficult time understanding i 10 what that objective measure is in the case of emergency l l 19 planning. 30 One thing, however, that I am quite certain of is ! 21 that when human life is at stake, that progress is no f 32 substitute for inadequate offsite emergency plan that meets , 33 all the applicable criteria. And what strikes me as rather 24 ironic 'in 1988, as wo sit here and talk about emergency ! 35 planning, is that talk of progress and focusing on draft ; i lieritage Reporting Corporation ! (202) 620-4888 l [ __ .
t 56 1 material sounds to me a lot like a return to the old Atomic l 2 Energy Commission standard of 1956, I believe, with respect 3 to emergency planning onsite that looked for "a description 4 of proposals" in the event of an accident that . night cause a t ]- 5 radiological hazard. 6 I thought we had come a long way from the day when , 7 we were concerned about what proposals the licensee or a 8 state might have put forth to deal with an offsite release 9 in the case of an accident at a commercial nuclear power l 1 10 plant, and that we indeed were operating in a much different 11 post-Three Mile Island accident environment where much, much ( 12 more than that was required. 13 This is not a case of whether the glass is half l L 4 j 14 empty or half full. That's for othar paople to judga. But 15 what I can say and what I think is beyond dispute is that l 16 there is not today in existence an adequate offsite 17 emergency response plan, a tested emergency response i i 18 organization that I believe provides reasonable assurances ] 19 that the public health and safety would be protected in the 30 event of an accident, and that is the only thing that I am [ 31 concerned about. [ Now, we have provided you with a report that we I 32 23 released in draft form last --I think earlier -- last week, ; 24 I should say, or earlier this week, which will detail many 25 of the issues that Mr. Varley spoke about and some broader ( )' \, ] lieritage Reporting Corporation i (202) 628-4888 : i J i 1 .
57 1 concerns that we have had for several years, and provide you 2 with a very up-to-date status report on it. And I won't 3 take up everyone's time here today to restate everything I 4 that's in that very lengthy report. 5 But I do want you to know that it is our plan to 6 revine that report following the meeting tomorrow night 7 based on the most recent information we expect to receive ; 8 from the many fire chiefs and police chiefs and civil 9 defense officials and school officials and selectmen as well 10 as residents who will be coming to the meeting to testify. 11 And that report will be transmitted to yoa and to ! 12 the commissioners of the NRC early next week along with the 13 transcript of tomorrow night's meeting so that indeed 14 everyone of the details that I spoke of will before you and 15 will be as up to date as humanly possible. 16 But I do want to take this opportunity to briefly ; 17 comment on some of the issues that Mr. Varley commented on 10 and some other issues. Let me first take up those issues 19 that were among the six issues identified by FEMA in the 20 self-initiated review of last year. ] 21 The first was the lack of evacuation plans for 22 public and private schools and day are centers. What you 23 should know is that the school officials in the EPZ, with I 24 whom incidentaliy I am meeting tomorrow, have indicated to l 25 me time and again that they have no confidence that the f t ( i ! Heritage Reporting Corporation l (202) 628-4888 [ 1
s 58 1 draft material ~that they are still looking at is going to 2 suit the needs of their particular communities, or, indeed, 3 whether it's going to carry out the objectives that have 4 been established for implementing procedures for private and 5 public schools. 6 And I think this points out a problem that I'm 7 going to mention several times this afternoon, and that I 8 think you, Dr. Murley, msde reference to earltor. And that 9 is the problem of demonstrating that planning material that 10 has been developed, no matter how much time was spent in 11 developing it, in fact, number one, can be implemented, that 12 the people who you depend upon to implement understand it l 13 and can carry it out, and that it can be implemented in a 1 14 timely manner and successfully.. And that is really the 15 question of an exercise. 16 And I think at the very outset it's important for 17 everyone to understand here today that there has not br.an an 18 exercise, an outside exercise, graded exercise at the 19 pilgrim Nuclear Power Plant for more than three years. And 20 in that time there have been a great number of changes. As 21 many areas in our state and around the country have 22 exper) n:ce'.. there has been growth. Road networks, 23 unfc rtur d.a .y. by and large don't change, and certainly have 24 not in t..is case, although there are more automobiles and 25 more people in the area. Heritage Reporting Corporation (202) 628-4888 4
. 59 1 But even more significantly, there have been 2 numerous changes in the personnel who would be expected to 3 respond in the event of an accident. 4 And finally, we don't yet have all of the planning 5 details, all of the p' ns that these persons would be 6 expected to implement if there was an accident. And, 7 therefore, I think that before one can really speak of 8 progress in any meaningful sense, one has to examine the 9 context in which this discussion has occurred, and there has 10 been no exercise, and I d'on't think that even if planning 11 mate,lal had been com'.leted i in draft form, which it has not, 12 and had been reviewed by state and federal officials, which 13 it has not, that we could with any confidence tell you that 14 we think that it is adequa,te without having experienced and 15 putting it to the test of an exercise. 16 And that has a particularly significant
,7 application when we're talking about public and private 18 schools. We are dealing with some policy issues,'for 19 example, that have not even been resolved yet.
20 One of the proposals that has been made, which 21 m!,ght very well prove to be a suitable one but which has not 22 been resolved, is the question of precautionary transfer of 23 school children at the site area emergency stage. That has 24 had some discussion among licensee representat'ives and 25 public safety officials, but it has not been thoroughly Ileritage Reporting Corporation
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) . 60 1 discussed by school officials, and has not been put before 2 the officials at each of the cities and towns who have to 3 make those kinds of judgments, at least in the first 4 instance before we can make a final judgment, and that is 5 certainly at the center of the development of implementing 6 procedures for the public and private schools and day care 7 centers.
8 Another one of the issues that FEMA identified was 9 the lack of a re>:eption center for people evacuating to the 10 n o r t h.. Now, agcin, to make it clear to everyone, emergency 11 planning is a commonwealth responsibility. And, frankly, I 12 don't care if FEMA is satisfied or the licensee is satisfied 13 with two exiating reception centers. It is the 14 commonwealth's. position that we must have three; that we 15 must find a northern reception center. 16 And I expect by the early part of next week the 17 feasibility study that we have had underway for quite 18 sometime, examining the suitability of locating that third 19 reception center in Wellesley, Massachusetts, at the 20 intersection of Interstate Route 95 and State Road 9, will 21 be available. But I can tell you that if the conclusion is 22 that that is at least a feasible site, that we are looking 23 at least six months of work to develop implementing 24 procedures for that location, and several millions of 25 dollars for capital imorovements that would have to be made Heritage Reporting Corporation (202) 628-4888 _ _ _ -,___ - - , _ . - , . _ . . . _ . _ _ _ _ , . , _ - . _ - m, m .
61 1 to handle things like radiological decontamination, parking 2 problems associated with the management of a reception 3 center, and the improvements that have to be made inside the 4 facility to facilitate the processing of large numbers of 5 people, 6 And v' ' 1 < - we are on the subject of receptions 7 centers, let me say that although FEMA focused on that one i 8 isnue, it is very clear to es, and I think to the licensee, 9 that the existing two reception centers at Taunton, 10 Massachusetts, and at the state hospital that's located 11 there, and in Bridgewater, Massachusetts, at the state 12 college, require capital improvements to be made there as 13 well before we could say with any assurance that they are 14 equipped to carry out the mission of the reception center. 15 And again, this is an area where there certainly 16 has been progress made, and to the credit of the licensee, 17 they have offered to expend the resources that are needed to 18 make those facilities suitable. But that is a process that, 19 too, has a long way to go before it's resolved. 20 And finally, let me add above and beyond the 21 observations in the FEMA self-initiated review, we do not 22 accept, and I k.now I am speaking for the local fire chiefs 23 and police chiefs and civil defense directors and others, 24 the FEMA d.igure that you must be prepared to process 25 approximately 20 percent of the EPZ population, or the EPZ Heritage Reporting Corporation (202) 628-4888 e p 4
y . . 62 1 population at least to be served by that reception center. 2 In either' case, whether it's 20 percent of the 3 total population or 20 percent of the population that that 4 reception center is to be served, we would accept that. I 5 don't accept it not because I have the authoritative figure 6 to give you that'I think it should represent, but I have not 7 seen any authoritative study that compels such a finding. 8 And it is the opinion of, again, state and local public 9 safety officials who have been involved in evacuations of 10 ono kind or another for other situations that that is simply 11 not a reliable figure. 12 And so our assumptions that have gone into 13 planning for the two reception centers in Taunton and 14 - Bridgewater, and that we're going to be planning for the 15 proposed facility at Wellesley, are much more conservative 16 than that. And we think that a much greater number of 17 people would possibly make use of the reception center, and 18 therefore our planning has to be auch that we could 1,9 accommodate that much larger number. 20 The third issue that was in the FEMA self-21 initiated review was lack of identifiable shelters for the 22 beach population. I believe I heard someone here this 23 morning or this afternoon say that, well, sheltering is no 24 longer required according to FEMA. 35 There have been several lengthy correspondences Heritage Reporting Corporation ' (202) 628-4888 f . O
63 1 between the commonwealth and FEMA, and between FEMA and 2 representatives of the United States Congress. I believe 3 Senator Kennedy is one of them. And if that indeed is the 4 position that FEMA now takes that there is no longer a 5 requirement that a demonstration be made that populations 6 can be sheltered in the event of an offsite accident, that 7 will add that to the list of items with which the 8 Commonwealth of Massachusetts seriously takes issue. 9 We certainly would argue that, first of all, that 10 represents a radical departure from positions that FEMA has 11 taken in the past. And we have pointed out in some of our 12 correspondences that those positions were taken in 13 appearances that FEMA made before congressional committees. 14 But more importantly as a practical matter', I know 15 of no other option besides sheltering that is available in 16 the event of a. fast-breaking accident that could pose an 17 offsite consequ6nce. And FEMA has said that time and again. 18 That one of the choices that must be open, one of the 19 protective actions that must be available in that case is 20 some form of sheltering. 21 tiow , again, I am pleased that the licensee has 22 . been supporting this effort along with state and local 23 officials, to develop shelter utilization plans. But you 24 should understand that as of this morning a shelter 25 utilization plan has been forwarded for our review from only Ileritage Reporting Corporation (202) 628-4888 e e
- s 64 1 one of the EPZ communities.
2 So there is, again, a long way te go, at least in 3 terms of reviewing this material, and certainly in terms of 4 approving it, and finally, in terms of validating it by some
~
5 sort of test or exerc Le. And there are some very unique 6 areas of that Pilgrim EPZ which pose very, very difficult 7 problems. 8 There is an area off the coast of Duxsbury which I 9 know the staff of the NRC and the licensee are aware of 10 called the Sequish Gurnett area, which is an area in fact 11 part of which is in Plymouth, part of which is in Duxsbury, 12 which you can only get to from the town of Duxsbury, which 13 is a peninsula off the coast of Duxsbury and only three 14 miles from the plant. And this is an area which has a 15 summertime population which has been estimated to us by 16 people who have lived and worked in the area for m3ny, many 17 years as high as 9,000 people, and a small but nevertheless 18 winter population as well. 19 It is an area that becomes not difficult to pass 20 through, but impossible to pass through at times because of 21 flooding which simply comes over the roads. And even the 22 .best four-wheel drive vehicle has stymied some of the public 23 safety officials and local residents in trying to get in and 24 out of that area. 'And I know that the licensee has had 25 representatives visit the area, and I know that the NRC has Heritage Reporting Corporation (202) 628-4888 e e A
. 65 I had representatives visit the area.
2 But the recommendations in the evaluations that we 3 have received from local officials, which will be included 4 in our final submission to the Commission, is that unless 5 there are substantial improvements in raising the grade of 6 the roads and in doing some other things, you simply can't 7 get in and out of there at times. And I don't think that's 8 very much consolation for the 9,000 odd people who might bee 9 on Sequish at any given point, at a time when it may be 10 necessary to evacuate them. 11 Another one of the areas that FEMA focused on was 12 planning or the lack of planning for the special needs 13 populations. This is an issue that we just spent a great 14 deal of time and perhaps have given the most attention to, 15 because it needed the most attention. We have been working 16 very closely again with the licensee, but also with some 17 specialists.in state government, namely, the State Office of 18 Handicapped Affairs, in order to examine what has happened 19 in the past and what needs to be done for the future. 20 While I am on the point let me add, because again 21 I think there was a question by you, Dr. Murley, related to 22 this. It should be clear to everyone that whatever planning 23 may have gone on at the Pilgrim Nuclear Power Plant in the 24 past, whether it was the 1981 edition of the plans, or the 25 1985 revision of the plans, whatever planning went on prior l Heritage Reporting Corporation (202) 628-4888 e G e 9 4 9 4
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66 1 to the shutdown of the facility in 1986, has absolutely no 2 relevance to the questions that we face here today. 3 The planning process established by the 4 Commonwealth of Massachusetts and implemented in the early . 5 part of 1987, following our lengthy report to the Governor 6 in December of 1986, has gone back to the drawing board to 7 totally revise the offaite emergency response organization-8 at the state and local level, and the offsite emergency 9 response plans. 10 And part of that proc'ess entailed a detailed 11 examination of persons with special needs. One of the 12 controversies over the years has always been how many such 13 persons are there, and many, many monthe was spent working 14 with the Boston Edison Company and with state and local 15 officials in trying to develop an instrument that would 16 permit a scientific survey to be done of persons in the area 17 with special needs to determine just how many people there 18 were. 19 Unfortunately, that survey has not yet commenced, 20 and I'm not going to stand here today and point fingers at 21 one person or another person and try to place blame on who 22 is responsible. That survey hasn't commenced in part 23 because the subject is one that is very complicated, and it 24 has taken a great deal of time for the parties to agree on 25 how to go about doing this survey and, frankly, there have Heritage Reporting Corporation ' (202) 628-4888 O I e
^
67 1 leen disagreements about how much it was going to cost and 2 'iho should do it. And in an effort to resolve those 3 disagreements, additional time was taken. l l 4 But the point is the survey hasn't been done, and 5 I certainly cannot say that I am satisfied, nor do I think 6 local officials will be able to say that they are satisfied 7 that persons with special needs in their communities have 8 been identified until that survey is completed. 9 Now we have made efforts to try to do things on a'n 10 ad hoc basis as a stopgap measure to try to get this pro: css 11 moving forward, including advertisements in local 12 newspapers. But it was the firm belief of local and state 13 officials, and it remains our belief, and the licensee has 14 supported us, that thic survey must be donc, but it hasn't 15 yet been done, and our best estimate is that it should 16 probably commence some time this month, in the month of 17 October. 18 Now another very important issue that has arisen 19 in connection with persons with special needs is the 20 question of how can we provide those persons with the 21 assurances that if they do require assistance, they will be 22 able to communicate with the appropriate offsite officials 23 and make their requests known. And one of the thing's that 24 has been very frustrating as we have tried to work with the 25 licensee and local officials is trying to figure out lieritage Reporting Corporation (202) 628-4888 e
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- 68 1 precisely how many people have asked for the kind of 2 equipment needed to make that communication, TDDs.and other 3 kinds of devices, and how many such devices have b6en 4 provided by the Boston Ediron Company in keeping with its 5 commitment, which it has made on several occasions, to 6 provide such devices to any person who needs them. i 7 And unfortunately, we have been unable to learn 8 from the licensee how many such requests had ever been made 9 and, in turn, how many such devices have been provided. So 10 there are some very specific concerns we have with respect 11 to the special needs population that again cause us 12 unavoidably and unalterably to tell you that reasonable 13 assurances do not exist that the public health and safety 14 could be protected in the event of an accident.
15 And I think the fifth concern that FEMA identified 16 was inadequate planning for evacuation of the transport-17 dependent population, the population that simply is unable 18 on their own to evacuate in the event that is ordered as a 19 protective action. . l 20 Now you, Dr. Murley, earlier asked a question, how 21 do we know, for example, if we have identified X number of l 22 bus companies and X number of bus drivers, that they 23 understand where they would have to go in the event.of an l l 24 accident, that they understand how to follow the different 25 routes that have been predetermined for an evacuation, and Heritage Reporting Corporation (202) 628-4888
s . 69 1 carry out the other responsibilities that are assigned ~to 2 them.
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1 3 Well, the simple answer is we don't know that, and 4 we won't know that until at least af ter t.here has been some 5 exercise, and that is probably the one critical, the.most 6 critical element, or one of two perhaps, that an exercise 7 would help us understand better. Can we in fact deliver the 8 emergency response vehicles that would be required to take 9 care of school children, both public and private, and other 10 people who may need special assistance in the event of an 11 accident with offsite consequences. 12 Now as Mr. Varley indicated, we did indicate 13 earlier in the year that the agreement which had been 14 ' prepared to try to provide assurances that offsite responses 15 would be made in a timely fashion, namely, the bus company 16 letters of agreement, was, in our judgment, inadequato, and 17 it was inadequate for two reasons. 18 It was inadequate because, first, we wanted 19 assurances, we wanted something that we felt provided 20 assurances that people would respond. And we also wanted 21 something that indicated.that there was informod consent on 32 the part of the people who would be expected to drive these 23 buses and vehicles. Did they,really understand what they l 24 would be asked to do. Did they understand that they would 25 be asked perhaps to operate their vehicle during a Heritage Reporting Corporation (202) 628-4888 i l p -- - .~- ,,._,_.__r_._ _ _.m, __. - 9 . _ , . - _ .. _ - . , , , _ , _ , , . , , , . , _ . . . , _ , _ _ ~ - .-_ _ . _ , - - - -
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. 70 1 radiological emergency that could threaten their own, health, 2 or their own safety. -
3 Now I have seen a draft'of such an agreement, a 4 revised agreement, and Mr. Varley and I and Mr. Hausner had 5 a meeting to talk about that agreement, but there have been 6 no such written assurances since the~ time that that material 7 was revised, and this is a matter which the lice.nsee has 8 undertaken to assist the commonwealth with. 9 So while again, in the commonwealth's plan and the 10 commonwealth takes responsibility for offsite planning in 11 this and a number of other areas I will mention in just a 12 moment, the licensee has undertaken to assist the 13 commonwealth. And in this case, the job simply has not been 14 completed. I have not seen any such agreements or letters, 15 whatever characterization one wishes to place, from the bus 16 company drivers that provide those two requisites -- 17 informed consent and assurance that in fact they will 18 deliver the . resources when required. 19 And even if they did exist, it would be my
, 20 position that the only way to demonstrate with some degree 21 of assurance that we can rely on those agreements is to have .
22 an exercise. 23 MR. MURLEY: I would like to explore -- Murley. I 24 would like to explore that question a bit. Are you 25, suggesting that we need almost a contractual detailed Heritage Reporting Corporation (202) 628-4888 4 l
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.. o 71 1 arrangement between who, between the utility and individual 2 bus drivers to make sure that they understand what's 3 expected of them before we in the NRC or anyone else can 4 count on them?
5 MR. AGNES: Well, your guidance, the NUREG-0654 6 guidance, refors to letters of agreement I believe without 7 any other elaboration. But an agreement implies a meeting 8 of the minds between two parties. In this case, the 9 Commonwealth of Massachusetts and the people from the 10 private sector, or the public sector perhaps, who are going 11 to deliver the resources. 12 And as I said, before you can have any such 13 meeting of the minds, we have to see, on the one hand, that 14 there is informed consent, because an agreement isn't worth 15 anything if the persons making the agreement don't 16 understand what they are agreeing to. 17 And, secondly, before we are prepared to be 18 satisfied, we want to see some assurance that the people on 19 the other end are going to deliver. 20 So I think there has to be something approaching 21 that kind of contractual agreement that you roter to but in 22 order to be satisfied. 23 MR. MURLEY: Yes, but there have been bus drivers 24 'in the Plymouth area for years who have participated in 25 these exercises. We have had full-scale exercises in 1982, lievitage Reporting Corporation (202) 628-4888
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. 72 1 1983, and 1985, where things like t,his were demonstrated.
2 So I don't -- I am wondering what it is you think we need 3 beyond what we had then to rely on drivers actually going to 4 be willing to drive during an emergency. E6 5 (Continued on next page.) 6 7 8 9 10 11 12 13 14 15 16 17 18 19 , 20 21 22 23 . 24 25
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73 7-8tG3r1 MR. AGNES: First I would say that the premise of 2 these early tests was faulty, because in looking back at the 3 kinds of agreements that existed, there was no assurance 4 that anyone could from any of those agreements that 5 resources would in fact be made in available during an 6 accident. So an exercise is certainly no test of whether in 7 fact you have an assurance, or it is not a complete test I O should say of whether you have an assurance that a resource . 9 is going to be available. 10 That has to start in the nature of the agreement. 11 And that agreement has to contain an acknowledgement that 12 the' person to deliver the resource understands that it is 13 for evacuation during the radiological emergency. That the 14 heath of the drivers might be impaired.' That the property 15 of the company, namely the vehicles, could be damaged. That 16 has to be something that is acknowledged in the agreement. 17 Secondly, the earlise exercises, I do not think 18 provide sny assurance abouc tha validity of offset emergency 19 response in 1988. We are te.iking about a totally new set of 20 procedures. We are talkinc about probably in most cafes 21 totally new drivers. I do not think that driving a bus is 22 the kind of careet that a person spends years and years at. 23 .I think that there is a tremendous amount of turn-over. You 24 have a transient work force. . 25 And so I do not think that anyone there that Heritage Reporting Corporation (202) 628-4888 I a
. 74 1 participated in an exercise in 1981 or in 1985 i's probably 2 even going to be part of the response organization in 1988.
3 MR. MURLEY: But what I am trying to get at is our 4 regulations allow that there be an agreement so that we know 5 that the resources are available and the people are 6 available, and that there be exercises to test various 7 aspects of it. And we rely on that for findings of adequacy 8 and we have done that for years, and even at Pilgrim we have 9 done it. 10 What I am trying to get at is what is it that you 11 see that is different now. Clearly, there is turnover in 12 bus drivers, and there is turnover in bus companies. But 13 the reliance of agreements similar that we have done in the 14 past and that we do all around the country, I do not quite 15 understand, Peter, what it is that you see different. 16 MR. AGNES: Well, what I said is that there are no 17 agr.eements. There are no agreements that I would call 18 agreements today at all. Now whether there were in the past , 19 or not, I would say is simply irrelevant to the situation 20 today, becauus there are not any today. 21 And secondly, even if there are agreements and 22 when thoro are agreements, I am not going to recommend to ! 23 .the government and nor do I think t, hat any local public 24 safety official would recommend to his superior that there
. 35 are reasonable assurances that public health and safety can
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1 be protected unless I see wha
- that agreement stands for and 2 what it really.means.
3 And the only way that I am going to get some 4 insight into that is to see what the response from those 5 organizations is during an exercise. For example, is there 6 going to be somebody, as'you said, Dr. Murley, on the other 7 end of that telephone at 2:30 some morning when we call up 8 the ABC Bus Company. Or when their telephone call is made, 9 is the ABC Bus Company going to be able to demonstrate with 10 some dispatch an ability to marshall its resources and at ,- 11 least show us that if we needed them to be deployed and l 12 buses to be staged that they would bo there. 13 I do not think that anyone, any responsible public 14 safety official, can make that kind'of a finding or 15 conclusion without that sort of demonstration. And there 16 has not been that demonstration yet. And i think that tnat 17 is a central problem with this issue of us at Emergency 18 Planning. ( 19 flow what I have just covered I think are some of i 20 the five so-called EP issues that were identified in the 21 FEMA report. But I do not want to leave here today without 22 reminding everyone. Mr. Russo11, 23 MR. RUSSELL: Mr. Agnas, I have a question going 24 back to the agreements that wo just talked about. You 25 indicated that there were two deficiencies in the agreements IIeritage Reporting Corporation (202) 628-4888
76 1 that were presented that had been signed. One of the 2 deficiencies was with respect to informed consent. 3 MR. AGNES: They were not signed incidentally. 4 They were signed by the bus companies, but they were never 5 signed by the Commonwealth. 6 MR. RUSSELL: They were signed by the company and 7 by the bus company, but not by the Commonwealth. 8 MR. AGNES: Right. 9 MR. RUSSELL: And you said that the reason that 10 you did not sign those that they did not have two elements. 11 One was informed consent on the part of the providers. And 12 I guess that with re'spect to that that I understand that the 13 training program for the drivers has been approved by the 14 Commonwealth, and that that training includes information on 15 health risks, dosimetry, and how one judges whether you are 16 at risk or not when you are actually implementing the route, 17 and that in fact that training has been observed by the NRC. 18 What I do not understand is what is missing beyond 19 that since the factual material necessary for informed 20 consent is beir.g nrovided and the drivers are part.icipating. 21 MR. AGNES: When the training is completed, it 32 might very well supply that element of informed consent. But 23 you should understand that only 27 percent of the people 34 that require training have be'en trained, and they have only 25 received 19 percent of the training. lioritage Reporting Corporation (202) 628-4888 -
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77 1 MR. RUSSELL: A different issue. I understand the 2 need to complete the training. What I am trying to 3 understand is you were talking in contractual terms. If in 4 fact the training were completed in accordance with the 5 plans approved by the Commonwealth with the agreements that 6 exist now, would it still be necessary to go through this 7 step to modify the agreement that exists, or have you seen 8 enough by way of technical training regarding the health 9 hazards to the providers of the transportation to conclude 10 that that is adequate? 11 MR. AGNES: Well, let me again correct here. When 12 you say the agreement that exists, again no agreement 13 exists. Half of an agreement is not an agreement. 14 MR. RUSStLL: There have been arrangements made by 15 Boston Edison Company with providers of transportation. 16 MR. AGNES: This is the Commonwealth 17 responsibility, Mr. Russell. I appreciate what the licensee 18 has done, but we ere not going to be satisfied until the job 19 is done. I 20 MR. RUSSELL: If your definition is no agreement al exists until you agree, then fine, we agree with that. ; 22 MR. AGNES: Well, it says that no agreement exists ' 33 until there has been a meeting of the minds of the parties 34 to the agreement. 25 MR. RUSSELL: Now I understand what your basis is, Heritage Reporting Corporation (202) 628-4888
. 78 1 that you do not agree, and that therefore there is no 2 agreement.
3 MR. AGNES: I did not say that. I said that we 4 have not yet seen the agreements that we sought. It was the 5 licensee who agreed to go out and solicit it and present it 6 to us. I certainly did not say here or would I say that the 7 Commonwealth would never agree or in principle that the I 8 Commonwealth refuses to agree, but I am not going to agree 9 to something that does not represent informed consent by the 10 other party and that does not constitute the kind of 11 assurance that I think that the people of Massachusetts are 12 entitled to. 13 And in addition, even beyond the training of the 14 bus drivers, does the bus company owner know that his buses . l 15 are going to be rolling out there during an accident and at
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16 some jeopardy, that his property is at risk. And that ths 17 process by which he would secure romuneration for damage to l 18 his property is one that he might not find satisfactory. l 19 That is another issue that I think that the letters cf l 20 agreement get at. 71 MR. RUSSCLL: Okay. I dia done on that issue. 22 MR. AGNES. Okay. Now in conclusion, I wanted to 23 make the point that beyond and above the five issues that I 24 mentioned that were a concern to FEMA when it did this 35 self-initiated review that there have been some other issues Heritage Reporting Corporation (202) 6T8-4888
79 1 that we have been referring to again and again that I hope 2 that you include on your agenda of items for consideration, 3 and that the Commission will consider before they make a 4 decision in this matter. 5 One of the most fundamental and perhaps tha ost 6 fundamental aspects of outside emergency planning is 7 communications. As you heard Mr. Varley say, there is a new 8 alert notification system instituted. This is actually the 9 second new system since the shut-down. Before the report 10 that we issued to the government in December.of 1986 as part 11 of my examination, we went out to the test the outside 12 system and found it totally lacking. 13 As a result of that, an effort was undertsken to 14 develop a new communications system, the so-called BEACONS 15 emergency communications system. That system proved ; 16 officient during the last incidont whero an off-sito '[ 17 communication was required. And tharreforo , we insisted tgon I 18 and the licensee agreed that yet a new system would be . l
, 19 installed. And this is a system where there will be a ;
i ! 20 direct communication trom the plant control room to the :
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] 21 Commonwealth and the loca1' communities by a series of ; l 22 dedicated FAX machines to supplement the voice ! J 23 communications system. l l 24 , That system has not been completed. And emergency 25 procedures have not been written, and there have been no j l Heritage Reporting Corporation i 4 (202) 628-4888 . i i
, 80 1 tests of that system. That is a critical element of 2 off-site emergency preparedness.
'3 There is also a concern about the ability of state 4 or local officials to communicate with each other during an 5 emergency response. And in the report that we have provided 6 to you, it is made very clear that in the case of almost 7 every one of the EPZ towns, there are a number of
-8 outstanding equir: ment requests which again the licensee has 9 agreed to honor which have not been completed yet. That is 10 the equipment has not been delivered to many of'the local ,
11 cities and towns and emergency response organizations that t 12 is essential for their communication needs during an 13 accident. So communications is an issue that I hope that 14 you will consider. , [ F 15 Training, I mentioned earlier. Yes, there is T
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16 training that is going on. Yes, t.he commonwealth has 17 approved the content of the training and the overall , j 18 implementation of it. And yes, the licenase has done an , i l 19 admirablo job of supporting it. But we have only begun to l 20 scratch the surfaae, ladies and gentlemen, on this issue. s 21 As I said, only 20 percent of the emergency i I
- 22 personnel that we have identified as requiring training have J I
23 received it, and they have only received 10 percent of the 24 training. So we have a long way to go here. i 25 A document that is very important for local and i Heritaoo Reporting Corporation [ ] (202) 628-4888 1 4 l
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81 1 state officials in developing emergency planning material is 2 the evacuation time estimate which was prepared at the 3 direction of the Boston Edison Company. That evacuation 4 time estimate includes a traffic management plan. But that ; 5 is a document which we looked at over a year ago, reviewed 6 carefully, and communicated back to the licensee and to ; 7 their consultant that it was seriously deficient. l 1 8 A new evacuation time estimate, a revised i i 9 evacuation time estimate, was commissioned, and we received i 10 it only this September, and that is not complete. And the l 11 latest information that I have is that we should receive the i 12 rest of it sometime this month. l 13 But it must be understood that that document is 14 something that state emergency planners and loca.1 emargency 15 planners are required to have and must evaluate in order to ,; 16 pass judgment on traffic management issues, which are of 17 particular concern to local officials who will be staffing 18 traffic management plans and procedures, and who will be i 19 putting their people out on the street by and large, and to [ 20 obviously want to be sure that they have the right number of 21 staff and that the right number of traffic check points have 22 been identified. And one particular concern obviously is 23 traffic control beyond the ten mile EPZ. 24 If we are going forward, as we may, with the* third 25 northern reception center in Wellesley, and if we are going Heritage Reporting Corporation (202) 628-4888 - 4
o 82 1 to have reception centers in Taunton, Massachusetts and 2 Bridgewater, Massachusetts, there are a number of 3 communities outside of the ten mile EPZ that are.in the path 4 of the traffic that will be going to those facilities. Each 5 of those communities has to be involved in and participate 6 in traffic management, or it will be an absolute disaster. 7 And that is the area where the evacuation time 8 estimate that we received in September was very weak. And i 3 that is an area where more work needs to be done. 10 The implementing procedures that are really the i 11 heart and the guts of the emergency plans have been , P 12 developed in draft form, as Mr. Varley said, but I want you i 13 to understand that we have not even seen the implementing 14 procedures from tha towns of Plymouth, Carver, Ducksbury or 15 Kingston, and neither has FEMA seen those implementing 16 procedures. So there is much v. ore work that needs to be 17 done there, at least in terms of reviewing them. 18 And again, I certainly cannot tell you whether.I , 19 think that they are going to pr. ovide the reauonable 20 assurance that your regulations aed federal law requires you 21 to find, because they have not been tested. 22 And again I will close on t. hat very issue, the 23 off-site exercise. Every emergency official at the state or 24 local level that I have talked to in the course of preparing 25 the draft raport which we.have given to you today has said Ileritage Reporting Corporation (202) 628-4888
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. 83 1 to us again and again that these are the people who are not 2 arguing that emergency planning cannot be done. These are 3 not the people who are arguing that the plants should never 4 restart. These are the people that have been involved in 5 public safety all of their life in emergency planning 1 6 activities. l 7 None of them have said to me that they believe 8 that any of the off-site emergency plans or procedures that 9 have been developed to date for the Pilgrim nuclear power 10 plant could be deemed adequate until they have been tested l 11 by an off-site exercise.
12 And if there is one point above all others that I j 13 want to leave you with here today is that I think that it is 1 j 14 unconscionable, putting aside the arguments and - 15 disagreements that we have had over the process that you j 5 16 have followed, and the failure of the NRC to afford the i 17 Commonwealth the kind of adjudicatory that we have beer. 4 18 seeking. Putting all of those issues oside, the one issue ; 19 above and beyond all of the others that I want to impross ; 20 upon you today is that no one in good faith should talk j al' about progress and should talk about plans that are adequato [ 4 22 to support the restart of this plan unless thay have l 1 t 1 23 participated in and satisfactorily passed the test of an i 24 off-site exercise. l 25 And whether there was an off-site exercise in t Heritage Reporting Corporation l { (202) , 628-4888 l l i
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1 Massachusetts for another nuclear power plant sometime 2 earic.er this year or whether there was an off-site exercise 3 in connection with Pilgrim in 1985 and 1981 has absolutely 4 no bearing on whether the emergency procedures for the 5 Pilgrim nuclear power plant could if completed provide that f 6 reasonable assurance that the public health and safety is ; 7 protected, that I think that all of us are obliged to find 8 before restart. 9 MR. MURLEY: Wait a minute. The law gives that 10 finding to the Nuclear Regulatory Commission. We, of I 11 course, will listen to the Commonwealth and we will listen I i 12 to FEMA, we are obliged to. But ultimately, the t i 13 responsibility is quite clear in the law that it is the 14 NRC's responsibility to make that finding. Please do not f 15 confuse that. 16 MR. AGNESt It certainly may be. But it also 17 certair.ly is the fundamental responsibility of every [ 18 governor in this Commonwealth, of every chairman of every i 19 board of selectmen, of every mayor of overy city and town to l
- 20 protect the public health and safety of the reaidents. '
t . 21 And although the NRC may make the final devision j 22 and although the court may say that under the supremacy ' 4 23 clause of the United States Constitution that it is your I 24 decision that is final, do not say to me that it is not the ( i 25 responrlbility of a governor or a chief executive of a city l i Heritage Reporting Corporation
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'do not think that is something that is consistent.
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2 3 MR. MURLEY: I did not say that. I was speaking 4 of the finding that must be made under the Atomic Energy 5 Act. It is reserved exclustvely to the NRC. 6 MR. AGNES: Well, a finding of reasonable 7 assurance is also going to be made by the governor of 8 Massachusetts. And I know that every local official in 9 Massachusetts is expecting us to make that finding as well. 10 And I hope that our two findings are going to concur with 11 each other. 12 With that, I have completed my remarks. And I 13 would only say again as I said at the outset that there are 14 some officials here from local cities and towns who would 15 'like an opportunity to speak if that is possible. And I 16 have some material that they have brought with them fron the 17 Town of Plymouth that I would liku to hand up to you for 18 your review. 19 (The documents referred to, a 20 copy of letters received at 21 the open meeting, were marked
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22 for identification as 23 Attachment 3.) 24 MR. MURLEY: First some comments with regard to 25 your early opening comments. You mentioned that many people i Heritage Reporting Corporation ! , (202) 628-4888
86 1 cannot attend. And that to your knowledge, that there were 2 no meetings in Plymouth on emergency planning. But in fact, , 3 there were at.least in early years. I, myself, attended 4 such meetings. And I alluded to or referred to three l , 5 separate exercises that took place in the past. I was at t 6 one of those and observed it, and it was found to be 4 7 acceptable. 8 MR. AGNES: When was that? 9 MR. MURLEY: 1983. And I mentioned that there was ! 10 one in 1982, 1983 and 1985. Plans were in place, and they 2 11 were observed carefully by us as well as FEMA. And things 12 were allowed to deteriorate over the years. But 13 nonetheless, there have been effective plans in place at 14 Plymouth. , j 15 MR. AGNES: FEMA incidentally, as I think 'that we 1 i 16 all underatand, has withdrawn approval of it. , I 17 MR. MURLEY: They have found some deficiencies, # 18 yes. 19 MR. AGNES: Well, they have withdrawn approval. { 20 They have withdrawn the interim approval that was the ! 21 authority under which those plans supported the operation of 22 the plant, as I understand it. I 23 MR. MURLEY: You mentioned that we pay more 24 attention to technical issues than emergency planning. That 25 is probably true, because the technical issues are generally i i Heritage Reporting Corporation ' (202) 628-4888 ! l 1 P
. . 87 1 touch issues. That was"the reason why the plant was shut 2 down in the first place in 1986. But that is not to say -
3 that we have not spent a large amount of tim.e on emergency 4 planning, because we have. Bill Russell's staff has been up 5 there. They have been observing some of these training 6 exercises for bus drivers and so forth. 7 (Continued on next page.) Cnd7tcs8 9 10 11 12 13 i 14 15 16 17 i
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'podo83 1 I would not like to leave the record as showing 2 that we havo not been paying much attention to emergency 3 planning, because we have. 4 MR. AGNES: But the record should show, and you 5 correct me if 'I am wrong, but in more than a year, this is 6 the first NRC-sponsored meeting where emergency planning has 7 been an official part of the agenda -- off-site emergency 8 planning. 9 MR. MURLEY: That could be within the last year. 10 l'm not aware of any, but there have been many, many 11 meetings on emergency planning where emergency planning in 12 the past has been part et the agenda. 13 PR. LEDGETT That's not accurate in that the NRC 14 has had staff that have met in your facilities in Boston to 15 revi.ew the status of plans and emergency planning, for one. ; 16 And, as you will recall, that was the subject of discussion 17 between the staff as recently as within the last six weeks. 18 , MR. AGNES: The public was not invited to that 19 meeting. 20 MR. COLLINS: We had a public meeting in Duxbury. 21 We had -- 22 MR. AGNES: When was that? 23 MR. COLLINS: Senator Kennedy's October 1987 in 24 Duxbury at Senator Kenned,'s subhearing. FEMA was present at 25 there, Heritage Reporting Corporation (202) 628-4888 e 4 9 g 4
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2 Kennedy. : 3 MR. COLLINS: True. 4 MR. MURLEY: Okay, let me move on. You did . 5 mention also that we seemed to pay more attention to Boston 6 Edison on emergency planning issues than we do to the 7 Commonwealth. Again, that's partly because of our unique ! 8 licensing relationship with . Boston Edison. We have worked t 9 wherever we could with the Commonwealth. In fact, that's 10 why we have invited you here today to hear your views. { 11 Quite frankly, Mr. Agnes, I had hoped tr.st you . t 12 would have spoke more to the positive progress you're . making 13 and what in fact positive steps you are doing. The NRC has 14 a great deal of experience in evaluating emergency plans and . [ t 15 dealing with other states. We have 107 other plants ,l 16 operating in this country that we regulate. They are in 71 17 other sites and there's 33 other states that we deal with. 18 The issues that you bring up are not unique. We 19 deal with them everyday. Pilgrim is not a particularly 20 diffien1t site. In fact, it doesn't even make the top 10 21 difficult.sitas in the United States in terms of emergency 22 planning. And, yet, these other states seem to be able to 23 find a way to deal with these issues and get plans on the 24 street. 25 Now, you have been telling us for two years, now, Heritage Reporting Corporation (202) 628-4888
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, . 90 j l' and I understand we just have another report from Mr. Barry, (
2 from you that details the problems. But my question is we , 3 know the problems, what are you doing.to protect your ; 4 . citizens and when will you be ready for an exercise? i 5 MR. AGNES: Let me first start off by saying when ; t 6 you speak of the numerous other plants around the country l 7 that are operating with emergency plans that you are aware 8 of, name one other plant in this country that is operating 9 where FEMA has withdrawn interim approval for those plants. { 10 That is something that makes Pilgrim, I think, very unique. ; 11 MR. MURLEY: Well, you're just incorrect. TheJe 6 12 are exercises that go on bi-annually now. FEMA frequently l 13 finds Category A deficiencies which are the same kinds of 14 deficiencies that they found at Pilgrim. And those l 15 deficiencies are corrected, either through remedial
.i 16 exercises or through other means. We deal with that every j 17 . day of the week, almost. !
18 MR. AGNES: I know of no other state where FEMA , 19 and the state have bo*a indicated that they do not believe f 20 that the existing emergency plans are adequate for the ! I' 21 operating nuclear. power plant. I just wonder. You 22 indicated -- I think Pilgrim in some respects is unique. f 23 MR. MURLEY: My question is what positive steps , 24 are you taking and when will you be ready for an exercise? 25 MR. AGNES: The steps that we are.taking are well , i Heritage Reporting Corporation . (202) 628-4888 ! i 4
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r~ -------------------~~----------~.---- - 91 I documented in the report that we have given you. And I 2 didn't -- I certainly did not suggest to you nor was it my 3 intention.to suggest that there was not progress being made 4 or that prngress had not been made. 5 But we are facing the restart of the facility. 6 The Commission is scheduled to meet on October 14th. And I 7 came here today not to talk about progress, but to talk 8 about why it shouldn't be restarted on October 14th. It may 9 very well be that at some later date v.his year or next year 10 I would be here supporting the restart of the Pilgrim 11 Nuclear Power Plant. But I am not suppor*.ing it today and I 12 won't be supporting it on October 14th. So, I thought it 13 more important that you understood why we were not 14 supporting the restart than the progress that's been made. 15 Mr. Varley gave you some indication of some areas 16 where there has been progress. And the report that we have 17 prepared I think is a very balanced report. And it does 18 indicate the areas where there has been progress. But that 19 is not the point, I don't think, of the meeting here today, 20 nur is it the~ reason why I came here. Because I don't think 3.1 the plant should restart unless all of these issues have 22 been resolved. 23 Now, you asked me when would *.here be an exercise? 24 I have said time and again to the licensee, "When the 25 emergency planning issues have been concluded, when the Heritage Reporting Corporation (202) 628-4888 e
92 r 1 implementing procedures, when the shelter utilization plans, 2 when the local plans'and the training is concluded, let's 3 have an exercise, if. we get that fa'r." 4 MR. MURLEY: You don't have an estimated date when 5 that would be? 6 MR. AGNES: No. i 7 MR. MURLEY: Okay. I don't have any more I 8 questions. . t 9 MR. MCDONALD: Thank you, Mr. Agnes. I 10 Mr. Bird, do you have any closing comments. i 11 MR. BIRD: Could we maybe just have a short break 12 and see whether we have any comments? l 13 MR. MURLEY: You may want to come back you think? 14 MR. BIRD: Possibly. 15 MR. MCDONALD: Okay, take about a 10 or 15 minute. I
-l 16 MR. MURLEY: 15 minutes.
17 MR. MCDONALD: 15-minute break. 18 (Whereupon, a brief recess was taken.) l i 19 MR. MCDONALD: Mr. Bird, do you have some closing 20 comments? , 21 MR. BIRD: Just very briefly. We think that there [ 22 are some factual statements made by Mr. Agnes that we 23 disagree with. We will review the transcript as well as the i 24 third draft of the Barry report and if we have signifiesnt [ 25 comments, we will submit them in writing to you and to i l i Heritage Reporting Corporation I (202) 628-4888 ,
93 1 Mr. Agnes. I have no other remarks at this time. 2 - MR. MURLEY: Okay. If there is any chance to get 3 them by Friday, that would certainly help. 4 MR. BIRD: Friday of this week? 5 MR. MURLEY: Friday of this week. It depends on 6 who wants to work over the weekend. Otherwise, as soon as 7 you can. But if we don't get them much before the 8 Commission meeting, there is not much we can do. 9 MR. MCDONALD: Dr. Murley, you would like to make 10 some comments? 11 MR. MURLEY: Yes. Thanik you for coming, 12 Mr. Agnes. Thank you. And we are, as I said, developing 13 our recommendations and our views and our position in 14 preparation for the Commission meeting next week. 15 With that, we will close. Thank you very much. 16 (Whereupon, at 3:38 p.m., the hearing was 17 adjourned.) 18 19 20 . 21 22 33 24 35 Heritage Reporting Corporation (202) 628-4888 S 4
6 1 CERTIFICATE 2 3 This is to certify that the attached proceedings before the 4 United States Nuclear Regulatory Commission in the matter 5 of: 6 , Name OPEN MEETING HITH BOSTON EDISON POWER CO.: PILGRIM NUCLEAR POWER STATION 7 8 Docket Number: 50-293 9 Place: Rockville, Maryland 10 Date: October 5, 1988 11 were held as herein appears, and that this is the original 12 transcript thereof for the file of the United States Nuclear 13 Regulatory Commission taken stenographically by me and, 14 thereafter reduced to. typewriting by me or under the 15 direction of the court reporting company, and that the 16 transcript is a true and accurate re:ord of the foregoing 17 proceedings. ,e , 18 /s/ % _N J ~ 8"H 19 (Signature typed) : Mark D. Handy 20 Official Reporter 21 Heritage Reporting Corporation 22 23 24 25 i Heritage Reporting Corporation (202) 628-4888 9 e e - . -. , . , . - - - - - - - - - , a_, -
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