ML20235A947

Provides Most Recent Status of Resolution of Offsite Emergency Preparedness Deficiencies in Commonwealth of Ma & Local Plans for Plant EPZ

ML20235A947
Person / Time
Site:	Pilgrim
Issue date:	09/09/1988
From:	Lazarus W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
CON-#189-8167 2.206, NUDOCS 8811210055
Download: ML20235A947 (25)

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V h h h ~~ N.M DOCKET NUMBER g ,

PROD. & UTIL FAC...m. - 2_

b MEMORANDUM FOR:

September 9, 1988 William Russell, Regional Administrator o

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l FROM:

THRU:

William Lazarus, Chief, EPS bn StewartIfellamy, Chief,FRSSB (k

d sNISh FEB -91999Y l Ebneter, Director, DRSS cf SEC # x

SUBJECT:

STATUS OF 0FFSITE EMERGENCY PREPAREDNESS AT PILGRIM The purpose of this memorandum is to provide you with the most recent .

status of resolution of off-site-emergency preparedness deficiencies in the Commonwealth of Massachusetts and local plans for the Pilgrim Emergency Planning Zone EPZ These deficiencies were identified in a Self-Initiated Review performe(d by). FEMA Region I and are summarized below:

1. Lack of evacuation plans for public and private schools and day-care I centers. -

2. Lack of a reception center for people evacuating to the north.

3. Lack of identifiable shelters for the beach population.

4. Inadequate planning for the evacuation of the special needs population.

.- 5. Inadequate planning for the evacuation of the transportation dependent

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. population.

6. Overall lack of progress in planning and apparent diminuation in emergency preparedness.

Deficiency No. 3, regarding the lack of shelters for the beach po)ulation has been removed as a concern by FEMA due to the position taken that soth sheltering and evacuation do not have to be demonstrated as feasible for all segments of the population in order to demonstrate a " range of protective actions". A shelter survey has also been completed by the licensee, which apparently demonstrates adequate shelter ca3acity. Deficiency No. 6 is general in nature and will largely be resolved by t1e progress made on the other specific issues. That leaves the 3 deficiencies regarding evacuation planning for the school children, special needs population, and transportation dependent population and the one deficiency regarding the lack of a northern reception center.

Considerable progress has been made in drafting plans and procedures for the EPZ and host communities to correct these deficiencies, and the present ,

status is as noted below:

FEMA, in conjunction with the primary RAC members has reviewed and commented on the draft plans for Plymouth, Kingston, Carver, Duxbury,

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Taunton and Bridgewater. Comments from the RAC, as well as additional comments from MCDA, have been incorporated in the plans and procedures drafted for these towns as well as Marshfield.

1. Marshfield - the Plan, Implementing Procedures (IP's),' Shelter Implementation Program and SIR cross reference have been approved by the selectmen and forwarded to MCDA. l

2. Taunton - the Plan Implementing Procedures and SIR cross reference and corrective action plan have been forwarded to MCDA.

3. Duxbury - all documents are complete except for three IP's. These are in draft form and.are to the planning committee for review. ,

4. Plymouth - all documents are complete except for three IP's. These are in draft form and are to the planning committee for review.

5. Kingston - all documents are complete and ready to be forwarded to MCDA.

6. Carver - all documents are complete except for one IP. All documents should be forwarded to MCDA by September, 1988.

7. Bridgewater - all documents are complete except for one IP. All -

document,s should be forwarded to MCDA by September, 1988. .

Although .not specifically identified as deficient in the FEMA Report,  !'

renovations are being conducted at the town Emergency Operations Centers.

with those in Plymouth, Kingston, Bridgewater Carver and Taunton complete.

andtheoneinDuxburyap3roximately90% complete. Renovation of the last one

- Marshfield began Septemaer,1988, and should be complete in about two months.

A northern reception. center has been tentatively identified by the Commonwealth in the town of Wellesley, however the decision to locate the center there will not be made until completion of a feasibility study. The schedule for the completion of the feasibility study is not known. Planned renovations of the remaining two reception centers in Taunton and Bridgewater not yet started, but again these reception centers have not been identified by FEMA as inadequate. The lack of the third reception center may also be resolved by demonstration that the present two centers are adequate for the population and the development of evacuation planning for the two centers rather than three.

The ETE study was completed and the report was distributed to the local town planners and MCDA on Au Copies will be forwarded to NRC the week of September 11, 1988. gust 26, 1988.

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.i The Commonwealth has not yet found a satisfactory method tio ensure that the special needs population has been identified. MCDA will be conducting a

, detailed special needs population survey in the near future.

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i The plans and procedures are in what the licensee considers to be i sufficiently final form that training is being conducted in accordance with a l training )rogram approved by the Commonwealth. In preparation for reviewing I training )eing conducted for off-site response personnel at Pilgrim, Mr.

Conklin and I attended a meeting on August 22, 1988 at the Massachusetts Civil .

Defense Agency (MCDA). This meeting was at our request, with the purpose of briefin the Commonwealth of Massachusetts on our of off- ite response personnel that had commenced. plans to observe A secondary the training purpose was to i determine from the Commonwealth the' status of the plan and procedure revisions which were in {

deficiencies. progress to correct the FEMA Region I Self-Initiated Review i l

Commonwealth of Massachusetts attendees included:

Peter Agnes, Undersecretary, Department of Public Safety Robert Boula , Director MCDA Jeffery (Buz Hausner, Manager, Nuclear Safety Engineering Preparedness Pro ram TomMattkews,(NSEPP),MCDA Emer y Response Planner, Department of Public Health Al.Slaney,Regionage anner, MCDA '

The meeting had been disc'ussed and coordinated with FEMA' Region I and an agreement reached with that office for them to send a representative to attend  ;

the meeting, however, the individual who had planned to attend was prevented <

from doing so shortly before the meeting by direction from FEMA headquarte,rs.

An outline of discussion points prepared by Mr. Agnes is attached. A  !

summary of the principle points of discussion presented by Mr. Agnes is as follows.

Massachusetts considers the plans reviously reviewed and evaluated by FEMA in the Self-Initiated Review to be inoperative, and that the 31ans and procedures currently in SIR)'raft represent a total re-write and may

)e fundamentally different from the previous versions. They do not know if these plans are adequate and will not be in a position to-make that determination until they have been completed and tested in a full-scale )

exercise. He reiterated that it remains to be seen whether an adequate plan can be developed that will protect the health and safety of the J public in the Pilgrim emergency planning zone.

All those present concurred that the licensee has demonst' rated commitment and support for the planning effort.

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The Commonwealth is currently soli . ting input on the current status of emergency planning, and plans. to issue an updated status report in mid September, 1988. ,

MCDA has conducted weekly meetings with the locals on planning issues 'and status. Currentl and city of Taunton (host city) have.y, the town of completely Marshfield finished their (risk town) plans, dures and aroce support.ing documents and have forwarded them to MC)A with a request to have FEMA review them. All other towns' plans and procedures are essentially complete, and should be submitted to MCDA in the immediate future.

MCDA summarized their refusal to submit the completed documents to FEMA as a result of FEMA's non-responsiveness to their letters regarding FEMA's position on sheltering of the beach po3ulation in the Pilgrim EPZ. (At an

. unplanned contact with Mr. Agnes at: tie Plymouth Sheraton on August 24, 1988, Mr. Agnes was asked if he would now forward the completed documents to FEMA for review as they had received FEMA's reply on August 23, 1988. l Mr. Agnes replied that he didn't know since he hadn't had time to '

carefully review FEMA's letter.)

Wellseley has been designated as the third Reception Center. It is approximately 35 miles from the EPZ. A feasibility study is currently being conducted to determine if it will serve the purpose. This study should be . completed by the' end of September. After the' study the Commonwealth will undertake capital improvements and procedure development.

MCDA is waiting for the revised ETE to make determinations of beach evacuations and possible other population pocket areas.

MCDA hasn't agreed on a method to identify the special needs populations.

l.etters of Agreement are essentially in place, however MCDA believes that they need to further strengthen this area..

MCDA is still considering an expanded EPZ with the priorities on Marshfield beaches, Duxbury and Carver, and the Cape. They expressed a desire to perform Protective Actions on a town wide basis.

The training program has been approved by MCDA. Approximately 6000 individuals have been identified for training. To date approximately 25%

of the 6000 have been contacted with approximately 15% completed.

The public information program is essentially complete except for some rework on the facts of radiation section.

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At the conclusion of the meeting, Mr. Agnes indicated that he was very ,

disappointed in the fact that FEMA has been very unresponsive in reviewing the progress that has been made in correcting the deficiencies identified. We indicated that FEMA was involved, as he knew, in the informal technical review of the plans and procedures which had been forwarded to them, and that we had  :

expected their presence at the August 22nd meeting.

j After the meeting had adjourned we requested and were provided copies of l the Marshfield and Taunton plans and procedures to review in preparation for evaluating the training that was being conducted over the next two days. l b(These ut had notplans and been procedures forwarded had been to FEMA submitted to MCDA by the respective towns, for review.)

On August 23 and 24, 1988 Mr. Craig Conklin, Ms. Rosemary Hogan, and I met with the licensee and his contractor who is conducting the training of i transportation providers. We reviewed the scope of the training program, the individual lesson modules that were to be used in the training that was to be conducted on those two days, and witnessed the training of bus drivers from two companies that would be providing transportation to school children, or transportation dependent, or special needs population. Findings are noted below.

Training program development is ongoing. Essentially, as draft procedures are complete, a training plan is developed, including contacts, lesson

, pla'ns and hands-on training. This' program is then approved by MCDA prior .

to actual training beginning. ,

Training has been conducted for many organizations most notably th'e general overview training. Specific trainin l includingthatfortransportationproviders.gisalsobeingconducted Several bus and ambulance companies have been contacted and training has begun. Scheduling is continuing and will be an ongoing process for probably the rest of the year.

The training is quite detailed and in fact included the actual running of bus / ambulance routes by various drivers. Formal classroom training is conducted, followed by hands-on training. On August 23 and 24, 1988 we observed training of drivers for two bus companies which would be used for i school children or transportation dependent individuals. The training

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included demonstration of the drivers use of the materials developed and provided to assist them in accurately running their routes. These materials are deemed to be adequate to allow the drivers to complete their assigned routes without difficulty. Training also included hands-on dosimetry use and oral questions regarding their roles. The drivers are receiving high quality training and demonstrated a high retention level from previous classroom training, c

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NW W liam J r Chief. Emergency Preparedness Section

Attachment:

As-stated cc: S. Collins l- C. Conklin i F. Congel, NRR W. Travers, NRR R. Hogan, NRR J. Dolan, FEMA I l.

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I e OFF-SITE EMERGENCY PLANNING FOR PILGRIM NUCLEAR POWER STATION

.. e DISCUSSION POINTS August 22, 1988 j I. Development of a whole new emergency preparedness and l response program for Pilgrim Nuclear Power Station vs.

revisions to the 1985 plans l

II. Status of development of Emergency Response Plans and Programs

a. Establishment of Nuclear Safety Emergepey l b.

Preparedness Local planning process - ,,gr,Ad/

Program - jF g N M%# es,,b .;

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c. Status of local plans #6#2 > 2. c_ -A" "

'd. Status of implementing procedures l

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III. Status of FEMA "Self Initiated Review" findings .]

. a. Evacuation of Schools - i

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b. Third, Northern Reception : Center - /44/I 247 3 Q s c. Protection of Beach Popu}ations --

Shelter d.

Utilization Plans [h)

Emergency Preparedness for Special Needs Populations

e. Overall Lack of' Progress in Planning and Apparent Diminution in Emergency Preparedness  ;

l IV. Other areas of concern being addressed through the planning process

a. Agreementa to assure the availability of buses, ,

ambulances, and chairvans for transport dependant populations

b. Improved " prompt notification" system

c. Training for all emergency workers 1

V. Public Health emergency preparedness issues

a. Accident assessment *' M w w ^-- *

b. Off-site monitoring of radiological releases-

c. Plans and facilities for ca e of inj'ury'd-contaminated individuals -'

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d. Plans for di al of radioactive waste from ,

decontamination of emergency workers and eq ment, and the general public M - L'O % M k I

e. Plans for reentry into contaminated areas M a~- N

f. Plans for control of the food chain in the 50 mile. M"'"- '

ingestion pathway , f continued... 4 Attachment

VI. Other Issues

a. Revised Evacuation Time Eatinate

b. Special Needs Population Survey L c. Revised Emergency Public Information Brochure

d. Installation of enhanced prompt notification system

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