ML20235A956
| ML20235A956 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 12/09/1988 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| CON-#189-8182, REF-10CFR9.7 2.206, NUDOCS 8812150172 | |
| Download: ML20235A956 (348) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION bs 4 wom= c h FEB;91989""2
Title:
m awn x f1EETING WITH PUBLIC 0FFICIALS HAVING RESPONS $1LIFFf5h i
EMERGENCY PLANNING FOR PILGRIM NUCLEAR POWER o IAJJp e I
1 Location: ONE WHITE FLINT NORTH, ROCKVILLE, MARYLAND Date: FRIDAY, DECEMBER 9, 1988 Pages: . 1-185 l
1 OR'GINA'_
1 Ann Riley & Associates -
q Court Reporters 1625 i Street, N.W., Suite 921 ,3 Washington, 'D.C. 20006 71
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i 5 DISCLAIMER 6
- 7 This is an unofficial transcript of!a meeting 8 of the United States Nuclear Regulatory Commission held i
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9 on in.the Commission's office at One '
10 White Flint North, Rockville, Maryland. Thefmeetingwas 11 ,
open to'public attendance and observation. This transcript 12 has not been r.eviewed,-co.rrected, or edited,!and it may
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l'3 contain inaccuracies.
14 .The transcript is intended solely for general 15 informational purposes. As provided by 10 CFR 9.103, it is 16 not part of the formal or informal record of-decision of the 17 matters discussed. Expressions of opinion in this transcript 18 do not necessarily reflect final determination or beliefs.
19 No pleading or other paper.may be filed with.the Commission 20 in any proceeding as the result of, or addressed to, any 21 statement or argument contained herein, except as the
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22 Commission may authorize.
23 24 25
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1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 ***
l 4' MEETING WITH PUBLIC OFFICIALS HAVING RESPONSIBILITY FOR
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EMERGENCY PLANNING FOR PILGRIM NUCLEAR POWER PLANT 6 ***
7 PUBLIC MEETING 8 ***
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Nuclear Regulatory Commission i 10 One White Flint North
- 11 Rockville, Maryland 12 .
' 13 ,
," . FRIDAY, DECEM'BER 9,.1988 14 ,
15 The Commission met in open session, pursuant to 16 notice, at 2:00 P.M., the Honorable LANDO W. ZECH, Chairman of 17 the Commission, presiding. -
18 COMMISSIONERS PRESENT:
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- LANDO W. ZECH, Chairman of the Commission 20 THOMAS M. RCBERTS, Member of the commission 21 JAMES R. CURTISS,. Member of the Commission 22 KENNETH CARR, Member of the Commission ,
23 KENNETH ROGERS, Member of the Commission 24 25 4
___.__________..__._m. _ _ _ _ _
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1 STAFF AND PRESENTERS SEATED AT THE COMMISSION TABLE:
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'. 2 S. CHILK P. AGNES 3 W. PARLER B. HAUSNER' 4 A. THOMPSON D. QUAID 5 D. HADFIELD V. STELLO 6' M. FEHLOW B. LAZARUS 7 ,' P. DOWD T. MURLEY 8 C. O'NEIL -
W. RUSSELL 9 H. COPELLO R. BELLAMY 10 R. REED D. MCDONALD 11 D. McGONAGLE T. BARLOW
, 12 C. NOYES -
A. WAITKUS-ARNOLD
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3 1 PRO-CEEDINGS
. 2 (2:00 P.M.]
- 3. CHAIRMAN ZECH: Good afternoon, ladies an'd gentlemen..
4 The Pilgrim Nuclear Power Station in Plymouth, Massachusetts, 5: was given a Nuclear Regulatory Commission operating license in 6 September, 1972, and was in commercial operation until it was 7' shut down by Boston Edison Company on April 12, 1986, due to a 8 series of equipment problems. The Nuclear Regulatory 9 Commission Region I, subsequently issued'a Confirmatory Action 10 Letter' confirming Boston Edison Company's intent to keep the 11 plant shut down until certain equipment and management 12 deficiencies had been corrected.
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Since,that time,.' the plant has remaine,d shut 'down as .
14 . corrective actions were undertaken. In August of 1987, the 15 Federal Emergency Management Agency, or FEMA, withdrew it 16 finding.of adequacy with respect to Massachusetts' planning for 17 radiological emergency response around Pilgrim, based on the 18 identification of six issues which called into question the 19 adequacy of state and local emergency response planning.
20 On October 14, 1988, the Commission was briefed on 21 the readiness of the Pilgrim Station to resume operation, by 22 officials of the Boston Edison Company, the NRC staff, and _
23 several members of Congress the and Lt. Governor of 24 Massachusetts, includ'ng i the status of each of the six FEMA 25 issues. Subsequent to the October 14th meeting, staff
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-1 rcprc3cntativos mat'with civil dafonr,o directors and other 2 local officials in the seven emergency planning zones an'd 3 reception centers -- communities.around Pilgrim.
4 These meetings were' held to enable the NRC to obtain 5 first-hand information on the status of the loce.1 emergency 6 plans and procedures, and to hear the concerns of local l i
7 officials. The results of these meetings were made available 8 to t he Commission. Today we will hear from local officials 9
concerning the ' status of off-site emergency preparedness at 10 -Pilgrim, including the readiness and ability of local officials 11- to execute existing emergency plans.
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12 Following these presentations, we will hear again
' 13 from state'officialN.' Finally, we will' hear from'the NRC staff -
14 with an update for the Commission concerning the readiness of 15 the Pilgrim facility to return to power operation. This should 16 include briefing of the Commission on the staff papers 17 submitted November the 15th to the Commission, summarizing the 18 status of off-site emergency. preparedness. That paper is 19 available for review in the NRC public document room.
20 I request that the staff closely monitor the 21 presentations today, and inform the Commission if any new facts 22 are presented that would have an effect on the staff's previous _
" 23 . conclusions regarding off-site emergency planning at Pilgrim.
24 , This is the only business which is before the Commission this 25 afternoon, and the scheduled witnesses who have been notificd l
5 1 _ Era tho cnly onOO who will ba hoard from todcy.
2 This agenda is required conduct of this meeting. If 3 anyone other than the scheduled witnesses has something to 4 contribute to the Commission's consideration of this matter, 5 they are requested to do so in writing to the Secretary of the 6 Commission at the earliest opportunity. Today's meeting is for 7 information only. There is no vote scheduled today. The 8 Commission will require some time in order to reflect on what 9 is heard today, before authorizing the NRC staff to act on the 10 Boston Edison's request to restart the Pilgrim Plant.
11 Do any of my fellow Commissioners have any opening 12 comments to make before we begin? Commissioner Roberts?
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- COMMISSIONER ROBERTS: .This is a very important 14 matter, and it"has my full and undivided attention, but we have 15 a full and ambitious list of people to hear from. The meeting i
16 is scheduled to end at 4:00. I suspect it will run over. I 17 must leave at 5:00 for a family committment.- I will read the 18 transcript of any portion of the meeting that I miss. '
19 My leaving does not indicate any lack of interest in 20 this matter. Thank you.
21 CK1IRMAN ZECH: Commissioner Carr?
22 COMMISSIONER CARR: Yes. As you've heard in August _
23 of 1987, FEMA withdrew its finding of adequacy with respect to Massachusetts' planning for radiological emergency response
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24 25 around Pilgrim. That withdrawal was based on the 4
6 1- identification of six issues which: called into question the 2 adequacy of state and local emergency response planning. 1[n 3 order for FEMA to again issue a finding of adequacy, it'is 4 necessary that the Commonwealth, working in cooperation with 5 the local governments, the appropriate federal agencies and the 6 Boston Edison Company, resolve those six issues. .
7 The commission understands that substantial progress
'8 has been made in that regard. At the Commission meeting today, 9 I hope to hear.from Commonwealth.and the local governments 10 about their progress in the last year and four months. I' , for 11 one, am particularly interested in hearing what has been-12 achieved and what remains to be accomplished. . I believe that 13 theischedule and plans for completion of any remaining' task's 14 are of particular interest to the Commission.
15 Although the Commission is particularly interested in 16 resolution of the six FEMA issues, we are aware that there are 17 state and local emergency planning concerns that go beyond the 18 federal planning requirements and the six FEMA issues. Whether 19' the Commonwealth and local governments desire to expend their 20 resources on emergency planning beyond the baseline of federal 21 requirements.s, is a matter of their judgment. ,
I 22 However, it must be recognized that notwithstanding _)
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23 the desire'to do more, the Commission is guided the principle 24 of ad' equate, not absolute assurance of public safety. The 25 plans must help achieve reasonable protective measures, but
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.7 1 they need not be perfect,_nor can there be the perfect plan.
2 our regulations recognize that emergency planning'is 3- dynamic. process,_ and that gaps or deficiencies may arise in 4 emergency. plans or preparedness. But our regulations do not 5 require the shutdown or continued suspension of operation for 6 every planning deficiency or.open item. That is why I believe' ,
7' it is particularly important for.the local communities ~to put 8 the issues yet to be resolved in the greater context of their 9 existing capability and committment to emergency response.
10 With that, I look forward to hearing the progress 11 mede by these responsible governments to resolving the 12 , emergency planning issues for Pilgrim. ,
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13 CHAIRMAN ZECH: ,
Thank you very much.' Are there any 14 other comments?
15- (No response.]
16 CHAIRMAN ZECH: If not, I would like to welcome each 17 of the Massachusetts officials who have come here today to 18 present information to us on this important matter. Ms.
19 Thompson, who is the Chairman of the Board of Selectmen of 20 Plymouth, Massachusucts, is our first speaker. Ms. Thompson, 21 welcome. You may proceed.
22 MS. THOMPSON: Thank you. Also attending this _
23 earing from Plymouth, is our Civil Defense Director, Douglas 24 Hadfield and Mrs. Marie Fehlow representing the Nuclear Matters 25 Advisory Committee, and also one of your speakers later, and e
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11 Ann Waitkus-Arnold;who is the Chairman of the Plymouth Handicap 2 Commission, but is speaking in another context this afternoon.
3 The to,wn of Plymouth welcomes this opportunity to 4 speak directly to the Commissioners in the scheduled meeting.
5 I have been told that it is the first time in the history of 6 the NRC that local officials have had such an invitation. If' ,
7 that's true, I applaud your decision that permits the voice of .
8 the people to come through. As the spokesman for historic
, 9 people, I thank you.
10 It's our feeling that this hearing should have 11 happ.ned'long ago, and it should have' happened in the area of 12 greatest concern.in the emergency planning zone itself.
our.
13 - New' England traditions of governaent make.that a reasonable 14 expectation for us. It's the responsibility of the Plymouth 15 Board of Selectmen to develop, to approve and to implement all-16 emergency planning, whether it be for the natural disasters 17 such as storms to which we a're a constant companion, or whether 18 it is for radiological response to an accident at the Plymouth 19 Nuclear Power Station.
20 Emergency planning is part of our public safety 21 responsibilities that we take an oath to uphold. These are 22 serious commitments to protect the life and the property of the .
23 citizens of Plymouth. The Plymouth Board of Selectmen is 24 composed of five persons elected to the highest executive body 25 of the town. The statement that you are hearing today is O
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1 ' unanimously approved by'those five.
2 That particular Board has a wealth of experience to 3 bring to bear in the area of civil defense. 'Three of us are
- 4 veterans of active military service. George Butters is-a 5 retired officer of fire fighters. David Malaguti is in the 6 construction trades. Bruce Arons is a businessman. George 7 Cameron is a fire and arson specialist. Albert Thompson has 8 had civil defense experience and large evacuation experience.
9 Our's is hard-working Board, well equipped for a 10 rational approach to emergency planning. In addition, we now 11 have Douglas Hadfield, trained Civil Defense Director full-12 time, who served the town for eight years ih a volunteer
'. capacity, and was hi, red.in January of 1988 -- this year -- as a
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13 14 full-time' Civil Defense Director. The 1985 radiological 15 emergency plan for the town, to which you referred when you 16 spoke about FEMA, was about one half inch thick.
17 It as an eleven by eight notebook. Our present draft 18 plans and procedures now fill seven, two and one half inch 19 binders, and there are many more that are still to come. Yes, 20 we have made and we are making genuine progress in our effort 21 to plan for radiological emergency. For us, it is a l i
22 prioritized, continuing task, especially in the face of ,
j 23 repeated statements made by individuals, that the NRC is going 24 to restart the Pilgrim Nuclear Power Station, and that that is 25 imminent.
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i 10 1 I cannot express too strongly that while Plymouth has 2 come a long way in the planning process, we still'have a long
.3 way to go. We have a heavy sense that we're not' prepared at 4 this time to respond effectively to a radiological accident of 5 major proportions. Our's is not just a matter of facing 6 multiple regulations. Our's is a moral responsibility to be .
7 prepared to assist our citizens -- Lil of them -- under 8 conditions of tensions and fear.
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9 There are several factors that make planning in'the 10 town of Plymouth a complex and a difficult process. In terms 11 of area,-we are the largest town in Massachusetts -- 103 square 12 miles.' We have a coastline on Massachusetts.s Bay which is 17
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- miles long. That means we have no hope.of' egress for about 180-14 degrees. One, our year 'round population is 45,000 and 15 growing. We have grown by one and one half times since Pilgrim.
16 Nuclear Power Station opened in 1972, and we are-the fastest i
17 growing community in all of southeast Massachusetts. l 18 In the warmer seasons of summer and spring and fall, 19 an additional 20,000 residents who own or rent in our town, 20 join us'for long periods of time, and because we are one of the 21 nation's historical treasures, we receive over 1 million other
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22 transient visitors. Because of that great geographical spread ,
23 of l'03 square miles, we find five distinct groupings of village 24 centers, according to what call our comprehensive plan.
25 Incidentally, our center of population in that 17
11-lL. Dilco along th3 coast, is in South Plymouth, which is close to 2 the nuclear power station. South Plymouth is our fastest 3 growing area, exacerbating the' updating of the'whole process.
4 At the moment, South Plymouth is served by one very small fire -
5 station. The police station, the town hall, and the civil 4
6 defense headquarters are 12 road miles away from South-
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7 Plymouth.
8 The Manomet Section of Plymouth surrounds the' Pilgrim 9 Nuc, lear Power Station and is also one of our fastest growing 10 areas with numerous subdivisions planned, and with several 11 popular beaches. I must tell you that in the past year, this 12 portion of the year, we have already issued over 800. permits
. 13 for new homes in the town of Plymouth. - ,
14 The road network around Plymouth is deficient for our* -
15 normal needs. Since Route 3-A is the countrys oldest road, 16 . winding its way through the business center of a string of 17 towns leading to Boston, the expressway, Route 3, which 18 parallels 3-A to the West, is the main Boston to Cape Cod l
19 Highway. ,
20 Route 44 is the main East-West route out of Plymouth 21 to Providence and New York. It's a meandering, overloaded 22 antique with dangerous intersections at Route 3, which are _
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23 currently the worst traffic accident scenes in the entire town.
24 That's all a matter of record.
25 All three major evacuation routes are but two lane f
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-l' and suffer gridlock during normal rush hours, during the summer 2 visitor" influx and during storms. 'Our police and fire chiefs 3 have serious concerns about response time, given the conditions 4 of our roads under normal conditions, let alone under disaster 5 conditions.
6 Our eleven schools are scattered all through our j 7 large area to serve our various centers of population. We have i 8 one of the largest school-age populations in the state. We i 9 have over 8,000 students and 1,000 staff members. The task of 10 evacuation is tremendous when we consider that six schools are ,
11 with five miles of the Pilgrim Nuclear Power Station, and the i
12 Manomet Elementary School.is only 2.3 miles from the plant. ,
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The entire emergency planning zona.has exactly one 14 hospital. a in Plymouth, and it is 3.5 Is the Jordan Hospit'l 15 miles from the Pilgrim Nuclear Power Station. It has only one 16 decontamination room, dedicated first to serving workers of the 17 plant itself, and only secondarily, the citizens of the Town of 18 Plymouth. -
19 The adminstration of the hospital has had such 20 difficulty in its planning, it has not yet been able to pass to 21 our Civil Defense Director, an approved first draft to 22 planning. To give you some idea of the scope of our plans, we ,
23 must" consider nine summer camps, sixteen pre-school daycare 24 cunters, eight nursing homes, six elderly congregate housing 25 projects, the large Plymouth County Jail and House of
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13 11 Correction,-a Massachusetts' Correctional', Institution, a: vast'
-2 state park of 15,000 acres, included within.that-are twelve l
- 3. lakes, whose daily camping and recreational. visitors reach many 4 thousands at various times.
.5 I hope you have some idea ofLthe complexity of our-6 _
preparations for radiological response. I'm sure you want to 7 kn'ow most the'present status of our emergency planning. To 8 encapsule in one statement;-we have come a long way, and we 9 have a long way to go. . We are. proceeding with'all speed 10 commensurate with effective planning.
11 our. channel of progression begins with the work of 12 our' Civil. Defense Director, Hadfield, which town department or
- r 13' private agency. Once the departm'ent has a plan it believes'it ~ '
14 can operate, the_ department head signs off. The draft then 15 moves to the. Radiological Emergency Response Planning Committee 16 for review. That Committee includes a Selectman as Chairman, 17 the Civil Defense Director, the Police and Fire Chiefs, 18 representatives of the Department of Public Works, the School 19 Department, Public Health, as well as three at-large citizens.
20 The Committee reviews all plans, and when satisfied, 21 passes the draft to the Board of Selectmen which studies and 22 moves toward approval. Obviously, anywhere along that line of ,
23 evaluation, the draft could be returned for additions and 24 changes. The aforementioned channel is a good vehicle for 25 arriving at prudent decisions.
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L1. However, there still remains the never-ending: task 2 for periodic updating, as is the case in all strategic 3 planning. At the moment, Plymouth has an incomplete, untested 4 draft.of plans. The task of public education has barel,y begun.
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The slim, general draft has had only a technical review by the 6 Federal Emergency Management Agency ~.
7 That review was almost a useless generic matching L 8 -against NUREG-0645. All five EPZ towns received exactly the 9 same generic report -- hardly reassuring, since the 10 circumstances of our planning are quite different. I must also 11 'tell you that Plymouth got somebody else's plan in that same 12 packet -- not even our own plan, and had to ask.for the return 13 of.our own plan. _
14 We are in the process of writi,ng implementing 15 procedures which, of course, are the responsibilities and 16 necessary actions for each department. We require 90 17 implementing procedures. The Selectmen have approved 34 in 18 concept. None of those IP's have been forwarded to the State 19 Civil Defense Agency. j 20 Now, here is the heart of the difficulty. Key 21 portions of the implementing procedures are still being 22 . developed. Police, fire, schools, hospital, handicapped ,
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23 populations and Saquish, an isolated beach peninsula, are in
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24 various draft stages. These absolutely essentially aspects of 25 our emergency plans are incomplete or in a preliminary form.
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. 15 1 To summarize, we are working assiduously, but our radiological 2 planning is far from being complete, and therefore is not 3 approved at the local level; has had no higher review; and is 4 un. tested.
5 Anyone who believes dur town is ready for restart of 6 Pilgrim Nuclear Power Station, has not really examined our 7 ability to respond to nuclear emergency. The unanimous
,8 position of the' Board of Selectmen is that Pilgrim Nuclear 9 P,ower Station ought not be pe:mitted to restart, until they are 10 effective radiological emergency response plans in place, which 11 have been approved and tested.
12 The Board took this position based,on sound 13 reasoning. First; the Plymouth Nuclear Power Station has had
'14 many years of troubled history, reflected by numerous NRC 15 fines, poor self evaluation and maintenance and management 16 problems.
17 Two; radiological control continues to earn only a 3, 18 the lowest numerical category of the SALP report. Three; the-19 mounting levels of radioactive spent fuel rods and other highly 20 contaminated debris in the on-site pool is a community concern.
21 Four; in the two and one half years the Pilgrim 22 Nuclear Power Station has been off-line, there have been a ,
23 large number of recent key appointments of personnel without 24 any operational experience at Plymouth Nuclear Power Station, 25 and some of those with little boiler water reactors.
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, .16 e I 1 Next, Plymouth has'had a full-time' Civil Defense !
2 Director for one year only, his appointment.having been made in a 3 January of this' year. A year of, concentrated effort has not j l
4- been.long enough to produce all the town needs in radiological ?
5 planning or preparation'of our emergency operations center, or-
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6 marshalling _of'the volunteers -- to mention only some of his 7-responsibilities.
8 Next, no present drafts of plans or operating 9 procedures have ever been approved by FEMA.- No present drafts 10 have ever been tested, and basic training in our departments 11 and agencies is incomplete, and in some of them has not even 12 begun. There are surely continuing problems of communication-13 between Boston Edison and.the Town of Plymout'h. I'm h' ope'ful 14 that this brief outline, rooted firmly'in the' collective wisdom 15 of our staff, has given you insights into our p, preparedness.
16 We have not dragged our feet. We have not pbrmitted 17 the size of the problem to stop us; neither have we indulged in 18 . irrational and illogical fears. But we do maintain that the 19 Commission has not had an accurate picture of our situation 20 until today. That, we believe, is the result of an 21 administrative process that never dealt equitably with the
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22 pe,ople who knew best and had the planning responsibility. ,
23 I recall with some bitterness and frustration, 24 sitting through a meeting which gave Boston Edison four hours 25 of testimony time, and gave the Town of Plymouth two minutes,
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. 17 1 and those two minutes in the closing hours just before 2 adjournment. But that has been the usual tenor -- long days of f 3 technical review, with perfunctory attention to the public and 4 little attention to emergency planning.
5 There has never been,' to our knowledge, an NRC 6 meeting in Plymouth which was devoted to emergency Plymouth, .
7 yet thousands of hours went into the technical reviews of the 8 -
Pilgrim Nuclear. Power Stations, and several public meetings 9 were held by technical NRC staff. We consider that a sad ratio 10 of concern. The only NRC hearing on emergency planning was 11 held here in Rockville on October the 14th of this year.
12 To the consternation of Plymouth, we were not even 13 invited to testify. Our'CivilDefenseDirect.or,who 14 nevertheless journeyed to your meeting', was not permitted to 15 speak. Yet, Boston Edison had been invitec' co give 1 and this 16 is your quote - " current understanding," -- close quote -- of 17 the status of radiological emergency planning in the EPZ towns.
18 What did you expect? An objective and a dispassionate view I 19 from a utility that had been off-line for two and one half 1 20 years, and was petitioning to go back on line, and had expended 2
21 millions of dollars?
22 Why was Boston Edison supposed to be a better source ,
23 of information than those of us who had the responsibility for 24 developing'and operating the emergency plans. Credibility is 25 indeed stretched by such a process. As you know, the Town of O
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~ l~ Plymouth challenged the accuracy of much of the factual. .
2- testimony presented at'your October 14 meeting -- particularly 3 pages76-103 in the transcript.
4 Perhaps,even more importantly, we question the 5 underlying assumptions and conclusion. They deny the reality.
6 as;we know it. After the October 14, 1988 meeting, two NRC .
7 staffers visited the Plymouth Emergency Operations Cer:ier in 8 the Plymouth Memorial Building. In the past three years, they 9 have been the only NRC staffers in the planning area, whd ever 10 visited our EOC or ever consulted with us.
11 Even those two staffers did not have time to thumb 12 through any of draft plans., Not a volume from our three-foot ,
13 shelf was opened. 'We find those circumstances extraordinary in j 14 the.f. ace of our vulnerability to disaster. In these fifteen 15 minutes, I've tried to bring you the truth of what exists in 16 Plymouth.
17 I have not, because of limits of time, been able to 18 give you much beyond the general picture. I've not even been 19 able to deal with the threat of radiological accident to l'and 20 and property, currently assessed at $2 billion in Plymouth 21 alone. I sincerely hope, however, I have conveyed to you the 22 unanimous position of the Plymouth Board of Selectmen -- the _
23 Pilgrim Nuclear Power Station ought not be permitted to restart 24 until there are effective radiological emergency response plans 25 which have been approved and tested.
19 1 Our's is a solemn responsibility to protect and 2 uphold the public safety. We are not prepared, nor ready to do 3 that in the event of serious emergency at the Pilgrim Nuclear 4' Power Station. Essentially, emergency planning decides who 5 will deal with the disaster and how they will operate. It 6 also, by its tib'eframe, may decide who will live and who will ,
7 die.
8 These are not merely pieces of paper developed 9 according regulations. They are blueprints for survival. At-10 this critical moment in the history of a troubled Pilgrim with 11 a capital "P," all the other 45,000 small pilgrims with'a.small l 12 "p," the citizens of our precious historic town, are not protected by compl'eted or approved or tested emergency plans.
'13 14 Let the record show clearly that those of us sworn to uphold 15 the public safety of the Town of Plymouth, have so advised the ,
16 Nuclear Regulatory Commissioners.
I 17 If, in the face of our arguments, y6u decide to 18 restart the Pilgrim Nuc'. ear Power Station before we are' ready 19 to protect our own citizens, then you must understand that you 20 have overridden the judgment of the traditional local authority 21 in the public safety area. If that happens, it will be you who 22 will be held accountable. ,
1 23 Your's is a awesome responsibility. Thank you so 24 much for this opportunity.
25 CHAIRMAN ZECH: Thank you very much, Ms. Thompson.
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1- Questions from my fel. low commissioners? Commissioner Roberts? l 2- COMMISSIONER ROBERTS: No.
- 1 3 CHAIRMAN ZECH: Commissioner Carr? '
4 COMMISSIONER CARR: I have some questions. Please, 5 you said your road network had gridlock under normal 6 conditions. How do you define gridlock and when does it occur ,,
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7 and how long does it last?
8 MS. THOMPSON: Yes, gridlock is, of course, when 9 traffic comes to a halt because there is --
10 COMMISSIONER CARR: Stopped or slowed down?
11 MS. THCMPSON: Stopped really. Gridlock ia stop as
. 12 far as I am concerned. Slow moving -- it's that very often, of 13 course, given our conditions. How long? ,
5 14 Sometimes it is a matter of ten minutes; sometimes 15 it's a matte,r of one hour, depending on what the conditions on 16 the road ~are. Even snow, you see, blows across the road, and 17 we have great difficulty. The expressway is our best.
.18 COMMISSIONER CARR: But it's not 7-9:00 in the 19 morning, and 3-5:00 in the afternoon?
20 MS. THOMPSON: Yes, it could be. In the summertime 21 particularly, everyone who is traveling toward Boston or Cape 22 cod, or course, tunes in and gets the news there. You see, we _
23 also are face'd with only two bridges over Cape Cod, and that 24 - stops us in going in that direction, and that highway leads in 25 that direction, as well as to Boston -- highly traveled, and in
i 21 1 the summertime, more than the road can take.
2 COMMISSIONER CARR: You'va hired your Civil Defense 3 Director, and you say he's only been there a year, but he was a 4 volunteer for a number of years before?
5 MS. THOMPSON: Yes, he was. ,
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6 COMMISSIONER CARR: How many what we call full-time .
7 equivalents -- how many assistants does he have?
8 MS. THOMPSON: None. Am I correct Mr. Hadfield?
9 MR. HADFIELD: (Nods head affirmatively.]
10 COMMISSIONER CARR: What kind of a budget does he 11 have? -
,12 , MS. THOMPSON:
'Mr. Hadfield, would you perhaps answer
[ i3 that one, please? -
14 MR. HADFIELD: The budget for the Town of Plymouth 15 now is approximately $3,000. -
16 COMMISSIONER CARR: For your part of it.
17 MR. HA.DFIELD: For the operation of the department, 18 which there is a request in for more for this year. -
19 COMMISSIONER CARR: You mentioned that you had had 20 continuous poor communications with Boston Electric. Would you 21 amplify that a little bit? Have they not been helpful?
22 MS. THOMPSON: Oh, yes, I said we had continuing poor _
23 -- not continuous.
24 COMMISSIONER CARR: Well, kind of discuss continuing 25 poor, so I understand what that means.
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1 MS. THOMPSON:- Surely. I'm an old English teacher, )1 2 so you will have to forgive me.
3 (Laughter.) )
4 MS. THOMPSON: I'm looking at a file which is in 5 front of me. "A year ago, for example, almost to the day --
6 November, a year ago in November, there was at the plant, a q
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7 series of nine incidents over the weekend, to the point where 8 the vice president, perhaps angry of dissatisfied with what had 9 happened in terms of maintenance and those problems over the 10 week and -- they were not reportable to the NRC, please
. I 11 understand that -- dismissed hundreds of employees. They 1 12 streamed out of the gates, with which, of course, anybody
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13 living near immediately began.tx) call everybody in town. ,
14 "What'shappebing? Has there been an accident?"
I 15 They were streaming out. I want you to know that 16 nobody at the Town Hall was informed. The Civil Defense 17 Director was not informed. The first time that the town was 18 called was 4:00 p.m. in the afternoon, and I was called at I '
19 6:00. When I was called at that point -- no, I'm sorry. I'm i
20 looking at a later -- let me get that.
21 I was called at 3:00 p.m. in the afternoon. It took 22 me three hours to get what the facts were. I had to talk with _
'l 23 Mr. Byrd, the Senior Vice President. I had to talk with Mrs.
l l
24 Johnson in the Nuclear Information Office. I talked with Mr. )
l 25 Bought who was happily down at the plant at that particular l
l
. .I
o 23
- 1. ' time, in order to get all the facts of the case. Meanwhile, i
- 2 the community was calling everybody, wondering what'had 3 happened.
i
.4 We did not.have the information either. After that, 5- we wrote a letter to Mr. Byrd and we said, please do something
'6 about this. You've been there for fifteen years. You.ought to j 7 be able to tell us -- even the non-reportable ones that you 8 think may cause concern, consternation, misinformation -- all 9 of that.
10 He promised to do that, and said, we will inform you 11 directly. I'm looking at his letter of December 17, 1987, and 12 here it is last month, in November of 1988, there was some
~
i3 spiilage o'f 2,00'O gallons o'5 water with an attendant flow of..
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14 low level radioactive water to an adjacent parkin'g lot. Guess 15 what? They called the Civil Defense Director in the morning at i
16 11:00. That was fine. !
17 Now, he knew what the procedure was, so his
. 18 presumption was that the Town Hall had been called. It had 19 not. His presumption was that the Chairman of the Board of l 20 Selectmen had been called. They had not. Our Executive 4
21 Secretary was not called until 4:00 p.m. that afternoon. I was 22 called at 6:00 p.m. that night. Meanwhile, a press release _
23 had been issued by Boston Edison. We had the same scenario all 24 over again.
25 Should I take my two children and get out of town?
O J
24 1- 'Is there some, danger? Misinformation, consternation, and the 2 Selectmen and the Executive Secretary feeling totally 3 uninformed, and I muut say, at a time like that, it's awful to 4 feel so dumb in your own town, and not to know what has -
5 happened. .
6 Again, your letter has gone, and we said, please, .
7 even when it is not an unusual event, we once again ask to be 8 informed in a timely manner, and certainly before the issuance 9 of a press release to the media. We have instructed our Civil 10 Defense' Director as to how to proceed in this matter, but we'll 11 look forward to a resolution of the communication problem. ,
12 That's where we are, and that was last month.
13 .'C O,M M I S S I O N E R C A R RI: understand'that. I think we 14 ought to let the rec'ord show that Mr. Byrd hasn't been there 15 .for fourteen years -- fifteen years. The plant has maybe, but 16 he's just been there a while. Fight?
17 MS. THOMPSON: Well, there sure have been other men 18 who were responsible and in charge.
19 COMMISSIONER CARR: You mentioned -- I think my pre-20 note said that your emergency plans were all in draft form, but 21 I thought you ,said the hospital didn't have a draft plan?
22 MS. THOMPSON: It doesn't even,have a preliminary, ,
23 but you understand that we have -- the Civil Defense Director 24 has drafted something to assist them, and hopes that they will 25 look at it, make their emendations and then come through with i
25 1 something that they can accept.
2 COMMISSIONER CARR: . So there is a draft plan for the l 3 hospital; it's just they haven't approved it; is that accurate?
4 MS. THOMPSON: They haven't processed it.
5 COMMISSIONER CARR: You mentioned that FEMA had only 6 given it a technical review.. What other kinds of reviews 7 should they get?
8 MS. THOMPSON: Actually, in the past --
9 COMMISSIONER CARR: I don't understand.
10 MS. THOMPSON: -- they approved it; did they not, Mr.
11 Hadfield.
12 COMMISSIONER CARR: I guess I don't un,derstand what a 13 technical rev.iew' is.
- 14 MS. THOMPSON: Sure. All right. Mr. Hadfield?
15 MR. HADFIELD: Our understanding of a technical 16 review is that they will look at this, go through it and decide 17 whether this follows what they feel is good procedure. But the 18 only thing that they have had, is the draft plan, and they 19 describe it in NUREG 0654, not the implementing procedures.
20 They have seen none of the implementing procedures.
21 COMMISSIONER CARR: But they were satisfied with the 22 draft plan -- ,
23 MR. HADFIELD: They had problems --
24 COMMISSIONER CARR: -- from a technical standpoint. I 25 MR. HADFIELD: From an technical standpoint, they had .
I
-7_----__--_-_____---_ , ,
26 l, problems with even the original draft plan, and that draft
- plan j 2- is not in draft 7, which they have not seen the' draft 7 of. i 3 COMMISSIONER CARR: In your implementing' procedures, 4: does the' state have a responsibility in those procedures?
5 MR. HADFIELD: Yes, they do. .
6 COMMISSIONER CARR: In addition to the locals?
-l 7 MR. HADFIELD: Yes, they do. ,-
8 COMMISSIONER CARR: Are they aware of their i
,- 9 responsibility?
10 MR. HADFIELD: Y.es, they are.
11 COMMISSIONER CARR: Also, it # s been mentioned a-12 Master Draft Plan. What's that?
13 .
MS. THOMPSON: No, I think perhaps you~are. confusing 14 the comprehensive planning of our community -- the growth plan 15 of our community with civil defense plans. 1 16 COMMISSIONER CARR: So there is no -- that's a term 17 that -- ;.
18 MS. THOMPSON: No, that's the plan we use for 19 comprehensive planning growth. ;
l 20 COMMISSIONER CARR: Are your training plans working? .
21' MR. HADFIELD:. The ones that have been undertaken so 22 far are being accepted, fairly well. The problem is that they ,
23 are not even half completed, and some departments have not even 24 started their's yet.
25 COMMISSIONER CARR: But some training is ongoing?
4
28 e
1 have two to three days notice that you don't even open the 2- schools if you know there's a hurricane coming. So, you don't 3: even have that situation at that point. 7
.4- COMMISSIONER CARR: To what timeframe do you feel 5- constrained to plan this one under?
6 MR. HADFIELD: We have'to make planning on a short- .
7 term - - ,
8 COMMISSIONER CARR: Two hours? Six hours? Two days.
9 MR. HADFIELD: The possibility of two to six hours 10 possibly.
11 COMMISSIONER CARR: I don't have any other questions.
12 CHAIRMAN ZECH: Thank you very much. Commissioner
. i 13 -Rogers? -
14 COMMISSIONER ROGERS: Just to try to get a little 15 . understanding of your level of effort, did you say your budget ,
16 is -- the civil defense budget is $3,0007 17 MR. HADFIELD: At the moment.
18 . COMMISSIONER ROGERS: That's without. salaries?
'19 MR. HADFIELD: That's correct, that's without 20 salaries.
21 COMMISSIONER ROGERS: Well, what would it be with .
22 salaries -- without ,-- if there's only one salary, you don't ,
23 have to tell me.
24 (Laughter.)
25 MR. HADFIELD: That and a 25-hour a week clerk.
27 3 MR. HADFIELD:. Yes, it is.
2 COMMISSIONER CARR: Why isn't the training -- the 3 other departments; why haven't they started, I guess is the 4 question?
5 MR. HADFIELD: Well, one of the departments, for 6 instance, is the school department which just started training ,
7 this past Monday. The Elementary School Departments -- it's 8 two separate school departments in the Town of Plymouth. One 9 is a regional which takes in the intermediate' school and.the 10 high schools, and the other is an elementary school system, and 11 it's under two separate :ommittees..
12 The Elementary Committee decided to start, training 13 , without accepta,nce o'f the-plan,' knowing that the training was .
14 based on the plan, but realizing that there were probably 15 problems that would come up in the training; and there have
. 16 been problems found in the training..
17 COMMISSIONER CARR: But as you said, you've lived 18 with hurricanes and natural disasters for years, so you 19 obviously had some plans to evacuate schools in those cases.
20 MR. HADFIELD: That is an entirely different type of 21 situation. You are not under the threat of the timeframe, and 22 you are not -- in a hurricane situation -- _
23 COMMISSIONER CARR: What timeframe are you working 24 under?
25 HR. KAGFIELD: In a hurricane situation, you usually
29 1 MS. THOMPSON: Part-time cl erk '-- that's all we: have.
~2 COMMISSIO!!ER ROGERS: You have a part-time clerk, and 3 you're full-time?
4 MR. HADFIELD: Yes.
5 COMMISSIONER ROGERS: What is the town's total public d
6 safety budget?
7 MS. THOMPSON: I'm sorry, I didn't bring those 8 figures.
9 , COMMISSIONER ROGERS: Well, roughly?
10 MS. THOMPSON: I don't really want to say, because I 11 don't know. I'd have to add three departments together, and 12 offhand, I don't know what those are.
. 13 . M CO'MISSTONER ROGERS: What's the town's total budget
^
14 without the school system?
15 MS. THOMPSON: $52 million. ,
16 COMMISSIONER ROGERS: $52 without the school system?
17 MS. THOMPSON: Oh, without the school system -- no, 18 I'd have to cut that down by,.well, the school takes 19 approximately 53 percent of that or a little more than 53 20 percent of that at the moment, and.it is rising.
21 COMMISSIONER ROGERS: Is your emergency planning 22 essentially an effort of volunteers? ,
23 MS. THOMPSON: Yes. ,
24 COMMISSIONER ROGERS: Is that how it's carried out?
25 MR. HADFIELD: It has been in the past, and the l
1
i 30 1 department is run with myself, the part-time secretary and 2 volunteers. i 3 COMMISSIONER CARR: I assume the utility provides j 4 same help to.you?
5 MR. HADFIELD: We would hope that they would' 6 COMMISSIONER CARR: But they haven't?
7 MS. THOMPSON: They do.
8 MR. HADFIELD: Financial help, yes. Yes, they have -
9 -
10 MS. THOMPSON: And equipment.
11 MR. HADFIELD: Yes, planners as well.
12 ~
COMMISSIONER ROGERS: Are they all part of this -- is 13 thiis part of this $3,000 budggt? ,'
14 MR. HADFIELD: No.
15 COMMISSIONER ROGERS: Or is that something in
~
16 addition?
17 MR. HADFIELD: That's in addition.
18 COMMISSIONER ROGERS: Isn't it important to try to 19 make clear what the total expenditure is of your planning 20 efforts, so that we have some -- when you say $3,000 for your 21 total civil defense effort, then if there's more, it would be 22 nice to know how much more there is that's going into that. ,
23 That seems like that's a very low level of effort for something 24 that you're so concerned about.
25 MS. THOMPSON: Mr. Rogers, the Town of Plymouth has l
31 1 never considered the resources of Boston Edison as part of 2 their budget, and I would tell you that even in the case of.the 3 planners, we have cautioned Mr. Hadfield again and again -- all 4 assistance possible from all quarters, of course. That makes 5 sense,-but no planner from Boston Edison or anybody else is 6 going to come in and put a plan on the table that they dreamed .
7 up and developed, because it is we who must live with that.
-8 That'is only a starting point. It's only one of our.
9 resources. Mr. Hadfield knows he's in trouble if he ever 10 presents to any department, that which came out of somebody 11 else's head, because he is the expert in-civil defense in 12 Plymouth,,and we expect him to utilize the resources, but to
>- 13' come'out with a plan which is, uni'quely our's which.has a chance 14 of work'ing. {
15 We haya never considered, while we take help frem'all 16 quarters -- the state, from Boston Edison -- grateful to get 17 it. On the other hand, we have to do our own particular work 18 on it, and it would not be acceptable to our police chief or to .
19 our fire chief or to anybody else to accept somebody else's 20 dreamed-up plan. Sometimes those people don't even have any 21 practical experiences'in the planning area. They're doing it 22 from textbooks, and that's not acceptable. We have to do it ,
23 from experience as well as from the textbook.
24 COMMISSIONER ROGERS: Thank you.
.25 CHAIRMAN ZECH: Commissioner Curtiss?
l i
_ _ _ _ _ _ _ _ _ _ _ _ . . _ _ . _ _ _ . _ _ . . I
. 32
- 1 ,
C' COMMISSIONER CURTISs: Just a' quick couple of' I 2L questions. What is the status of your implementing procedures
'3 for the fire and the police?
4 MR. HADFIELD: They have gone before the RERP.
5 . Committee. They.are to go before the Board of Selectmen.
6 COMMISSIONER CURTISS: Are they pending now before .
7 the Board of. Selectmen?
- 8 MR. HADFIELD: They vill - .they are.not pending at 9 this moment before the Board of Selectmen, no, but they will-10 be.
11 COMMISSIONER CURTISS: What'is the status of the IPs 12 for the schools?. .
13.' ,
MR., HADFIELP: The 'sc hools has not even gone to the
.14 RERP. Committee yet, because it has not been approved by.the 15 School Committees.
16 COMMISSIONER CURTISS: Implementing procedures, 17 though, have been drafted for all three of those?
18 MR. HADFIELD: Yes.
19 COMMISSIONER CURTISS: What is your judgment as the 20 civil Defense Director, of the adequacy of those procedures?
21 MR. HADFIELD: I have to go along with what the 22 department head has felt is his opinion that he can live with ,
1 -
23 these particular procedures that we've worked on together.
24 COMMISSIONER CURTISS: Ms. Thompson, do you have any 25 views on whether a full scale exercise of your procedure's is
l 33
.1' necessary before you all will be c,omfortable with emergency 2 preparedness? .
3 MS. THOMPSON: Certainly that~would be the highest 4 level of being comfortable. Actually,'it could be tested in 5 many ways, but at the moment,-we really have no kind of testing 6 that's been applied. .
7 COMMISSIONER CURTISS: One final question -- what is t
I 8 the schedule that you have in place or anticipate for the i
9 completion of your effort? '
10 MS. THOMPSON: Well, I can only answer that by saying
- 11. how many months did you think the plant was going to be off-12 line, or did you have to evaluate work and look again, and 13 again, and again? The plans will,be done when.they have moved 14 through that careful process, and we have approved them and-15 ,
believe them to be effective. Anything el'se would be an 16- artificial goal towards which you push people without the 17 necessary thought process.
18 CHAIRMAN ZECH: I presume the Town of Plymouth has 19 been involved in previous emergency exercises and drills in the f 20 past since the plant has been operating since 1972? You have 21 been involved in those exercises?
22 MS. THOMPSON: Yes, we have. _
23 bHAIRMANZECH: How would you characterize the tests 24 that have already been conducted in the past?
25 MS. THOMPSON: The English teacher gives them a C ,
i
,-34 1:. sometimes D+.
2' COMMISSIONER CARR: That's a passing gradet
~3 MS. THOMPSON: In the area of public safety,_you like
'4 that? 'I don't like those chances. -
5 CHAIRMAN ZECH: But you have participated?
6 MS. THOMPSON: Yes. D 7,
- CHAIRMAN ZECH: They have been --
8 MS. THOMPSON: They were not very realistic to my way 9 of thinking. I've been in command post exercises; you've been-10 in many, and some of the rest of you. They were not.very 11 . realistic. They were bubbly,-upbeat kinds of things --
12 ,
frankly, I thought mostly public relations.
13 ,
CHAIRMAN ZECH: .Do you think that what _ hais tiaken 14 place here in the recent year or so; would you characterize the 15 ability for emergency planning as improved over what it was i-16
- the past?
17 MS. THOMPSON: Certainly.
18 CHAIRMAN ZECH: You say you've come a long way, and 19 you have a long way to go, and we appreciate that, but I would 3
20 hope that you would continue to put ferth the effort that you 21 obviously indicate, Ms. Thompson, you are putting forth to 22 co,ntinue to improve and to continue to try to make those plans ,
23 as good as you can for your community. I'm sure that's what 24 you want to do. 1 25 MS. THOMPSON: Of course.
1
)
n- . J
.+. , ,
,_ 35 n
1 CHAIRMAN ZECH: Also,.I know we've talked about this 2 before'and you brought it up to, about handling other types'of 3 non-nuclear emergencies in your area, and I for one know that 4 you have a reputation for being quite good at that. Could you 5 .tell us'perhaps, and maybe Mr.'Hadfield would be better to tell 6 us about your handling of non-nuclear _ emergencies . I'm ,
7 thinking about the policemen, the firemen and so forth -- 1 8 hurricanes, the floods perhaps some other heavy accident in the 9 area of some kind.
10- What do you think is your community's ability to 11 handle those kinds of accidents?
i
~
12 .MR. HADFIELD: I think we're in pretty decent shape !
13 in that kind of thing, because it's something that we.can plan 14 on in advance knowledge if there is so'mething like that coming' ,
15 and we've done it in the'past. We've had very good cooperation 16 between the police, the fire, the schools for opening shelters 17 and things like that. I think in that respect, we are in 18 pretty decent shape, for something of that nature. But you're 19 not talking on the same vein as a nuclear problem.
20 CHAIRMAN ZECH: All right. Thank you very much. Any ,
21 other questions from my fellow Commissioners before we proceed?
.22 ,
(No response.) , _
23 CHAIRMAN ZECH: Ms. Thompson and your colleagues, we 24 thank you very much for being with us today. We appreciate 25 your being with us.
1 4
L
36 i
l' MS. THOMPSON: Commissioner Zech, we're so grateful.
2 that you permitted us to be here. Thank you so much.
3 CHAIRMAN ZECH: Thank you again.
4 COMMISSIONER ROGERS: We wish that everyone who 5 appeared here would be as articulate as you.
6 MS. THOMPSON: Thank you. .
7 CHAIRMAN ZECH: We call Patricia Dowd, please, who is 8 the Chairman of the Board of Selectmen of Duxbury, 9 Massachusetts. Ms. Dowd, welcome, and you may proceed. .
10 MS. DOWD: Good afternoon. I have with me today, Mr.
11 Carl O'Neil, our Civil Defense Director.
12 Chairman Zech, and members of the commission, I 1'3 ' appreciate the opportunity .to speak today on behalf of my 14 colleagues on the Board of Selectmen and the residdnts of .
15 Duxbury. This is the first time any member of my Board or for 16 that matter, any public official from Duxbury has been invited 17 to provided information on the status of emergency planning in 18 our town.
19 In the testimony given on October 14th, there was 20 clearly an implication that NRC staffers enjoyed a close 21 working relationship with local selectmen and appointed 22 planning officials. Unfortunately, that has not been the case _
23 with the Town of Duxbury. Dr. B911amy did visit our EOC after 24 the September hearing in Plymouth, in order to assess the i
25 radiation protection' factor in the building.
i 37' 11 ,
We are still waiting for.a written opinion on that 2 issue. In: addition, two NRC staffers met with our Civil 3 Defense Director cnt October 26th, 12 days after your hearing, 4' in order to discuss the ctatus of our planning efforts. I do 5 not consider this a fair amount of interface with local 6 officials. .
7 We also have come a long way. Considerable' progress i
8 has been made in upgrading our plans and procedures, however, 9 we ace continually frustrated when that progress is repeatedly' 10 misrepresented as an indication that those plans and procedures 11 .could be implemented in the case of an accident. Gentlemen, 12 draft plans and draft procedures which are not reviewed,
- ~
~
13 , . r,evised and approved cannot be implemented.
14 As selectmen, we not only recognize that emergency 15 plannin'g is our responsibility -- one we share with the 16 Commonwealth of Massachusetts -- but we take this 17 responsibility seriously. If, after presenting an accurate 18 analysis of our planning status and restating our position that 19 the Pilgrim Nuclear Power Station should not restart until 20 plans and procedures are approved and tested, you decide in 21 favor of restart, the responsibility will have to be your's in 22 the event of an accident. -
s 23 The emergency response planning process in Duxbury:
1 24 as our confidence in Boston Edison diminished and the risks at 25 the plant became evident, Duxbury took a good look at the l
38 1 emergency 1 response plan and recognized that~it,could never-be 2 implemented in its current form. We withdrew our approval of 3 that plan, as did FEMA in 1987.
4 Duxbury appointed the Radiological Emergency Response-5 Plan Study Committee to work with department manage'- to 6 develop a viable, workable plan. In the past two years, these ,
7 officials and volunteers have expended and exorbitant' amount of 8 time to accomplish that task. Duxbury's draft plan, excluding 9 implementing procedures, was forwarded to the Commonwealth and 10 subsequently to FEMA for technical review only. l 4
11- There is a four-stage peocess in the development and 12 approval of our' implementing procedures, or IPs. First, the
~
dra'ftsarer.eceivedksyBostonEdisonandr'evisedbythe,"
~
13 14 appropriate manager. Second, the revised drafts are. reviewed 15 by all the managers and revised as many time as necesshry.
l At this stage, the school procedures are also .
17 reviewed, revised and ultimately approved by our school 18 committee. Three, the IPs are reviewed by the RERP Study ,
19 Committee. At this stage, information on supplemental I 20 resources needs to be available. Recommendations are made by )
21 that Committee to the selectmen. )
)
22 Four, the Board of Selectmen review all segments of ,
23 the plan and~either approve or request additional revisions.
24 , There are 38 implementing procedures for Duxbury. of these, 35 25 have been developed and are currently in the second stage of l
39 1 the process. Four of the 35 have undergone review, but still
. 2 have unanswered questions. The school procedures are under 3 review, but have not'yet been presented to the school 4 committee.
~
5 The RERP Study Committee has not completed their ,
6 review of any of the procedures, and in fact, has not received 7 most of thcm. Nont of the IPs have been submitted to the Board I
8 or Selectmen for review and approval. This progression takes a i
9 considerable amount of time, but it is t'he core of the planning ~ l 10 process, and must be accomplished in order to achieve our goal 11 of developing a viable plan.
12 Although none of the procedures have moved through 13 all 'four phases, this process is , approximate.y.15-20 percent-14 complete in total. The implementing proced'ures, contrary to 15 the testimony given on October 14th by Dr. Bellamy, have not 16 been for, warded to the Commonwealth or to FEMA. Introductory 17 training has begun in the areas of radiation, dosimetry and 18 decontamination only.
19 Training cannot begin on those IPs unique to Duxbury 20 until the IPs are revised.- Completion is estimated at one half 21 of one percent by our Civil Defense Director. Duxbury does not i
22 have a designated, approved reception center. If we were l r
- l' 23 forced to implement a plan at this time, we would be I 24 implementing a plan absent its most critical component - a 25 destination point for the evacuating public.
40 ,
1L The center currently under consideration by the state 2 is not equipped at this time, and is unacceptable to Duxbury.
3 Unique characteristics.of Duxbury which present obstacles in 4 obstacles in emergency planning: Duxbury has approximately-150 5 miles of public roads. Outside of limited access, Route 3, and 6 state routes 14 and 3-A, local streets are rural, narrow, ,
7 curved, and are not designed to accommodate traffic generation 8 of anywhere near evacuation capacity.-
9 Duxbury Beach, inclusive of Gurnet and Saguish, is a 10 seven-mile barrier spit from which exiting traffic is limited 11 to Gurnet road and the Powder Point Bridge. No viable, 12' manageable system of moving an estimated,9,000 person from this-13 facility exists. Procedures. uniquely suited to this resource, ,
14 and its limited access,are central to a credible emergency 15 response plan. Development of these procedures is incomplete, 16 if not in its infancy at this time.
17 Specifics relating to the beach issues will be 18 presented later with the state's testimony. Thirty-three 19 percent of the population of Duxbury consists of 0-18 year 1
20 olds, with approximately 3,100 students enrolled in the public 21 schools. Busing capability.available through the town of 22 Duxbury permits relocation of only one third of the school .
b .
23 population at any one time.
24
- Contrary to testimony given on October 14th, it is 25 currently impossible to transport all students in a single O
41 1 trip. The availability of information on supplemental bus 2 resources is, at best, sketchy. We have been able'to identify 3- only one. carrier for the town of Duxbury for 12 buses, and that 4 carrier is stationed in the Worcester area, seventy miles away 5- from our town.
6 Additionally, there are three pre-school daycare 7 facilities of significant size, and numerous smaller programs 8 at scattered site locations. Procedures adequate'to ensure the 9 safe transit of this under-18 population sector are not 10 finalized. They year 'round population is approximately 14,000 11 in a community characterized as " bedroom," that is, with an 12 Adult workforce that is predominantly commuter.
'3 1
Jm estimated 65 pircent of the town's workforce .
14 commutes daily to urban employment centers within one to two 15 hours of Duxbury. Adequacy of plans to manage relocation of a 16 dispersed workforce during peak period commute times, for 1
17 conditions akin to peak periods that would arise from workers 18 attempting to unite and move families during an event, is 19 unknown at this time. Planning response of a dispersed rather 20 than concentrated workforce calls for different transportation 21 management strategies not yet assembled and reviewed.
22 Municipal resources are limited. The Town of Duxbury r
I 23 has devoted maximum poisible staff and volunteer service hours )
i 24 to emergency response plan development. The Fire Chief serves )
{
25 as our Civil Defense Director, and all public safety personnel l
l 1
L 42
)
b 1 carry ERP responsibilities as ancillary to their daily .
2 workloads. BECO has,provided emergency operations center and'
. 4 1
3 equipment, but training in equipment use, such as the telephone 4 communication system, is inadequate to make the facility 5 functional at'this time.
6- Town department heads meet weekly with Boston Edison l l
L 7 planners to devote time to ERP development. To suggest that a 8 plan is complete or procedures are at an implementation stage, 9 is woefully premature.
10 Identified needs by the town to complete the planning 11 process: 'information made available is often erroneous er 12 'ncomplete, i and frequently, the requested information is not -
u 13 available at all. Information needs.are: supplemental' bus.'
14 services for transport of school and/or sp'ecial needs O
15 populations; identify the transportation service providers, the 16 number of buses to be available; assurances of driver j 17 commitments; allocation of total bus resources for contaminated 18 areas; identification of a viable and acceptable reception 19 center; identification of special needs population, as well as 20 resources to supplement municipal staffing.
21 Resources needed to' even consider implementation of a 22 plan for Duxbury are: documented guarantees of additional ,
a 23 emergency manpower from State Police, Coast Guard, National
^
24 Guard and other support agencies; completed training modules in 25 all procedures for all applicable municipal officials and 0
6 s
j
. 43 1 employees; suitable training, demonstrations and tests of all 2 EOC equipment and other components.of the evacuation process, 3 including not only the communications system, but TDD 4 provisions for the hearing. impaired; auxiliary: power for town i
5 buildings used.for shelters and for the EOC.
6 I am here today to ask for time -- time to complete b 7 procedures development in accordance with our four-phase 8 process; to complete training. programs that are the only 9 guarantee of making implementation of a written plan a proximal 10 goal; to-demonstrate the effectiveness of plans and procedures 11 through a program of field testing exercises.
12 We do not believe that testing in ano,ther region is 13 ' sufficient,..and there have no,t b,een demonstr'tions'of a bus and ambulance drivers for Duxbury, at least not in conjunction with' l 14 15 our planning officials. To permit. municipal managers'to' carry 16 our ERP responsibilities without~doing so at the expense of 17 other public safety functions. To witness consistent evidence 18 of plant management improvements, safety provisions and good 19 faith efforts on the part of BECO that are long overdue to the 20 communities in the emergency response zone.
21 The water spill incident a couple of weeks back, 22- certainly did not. strengthen our confidence in Edison, when I ,
23 received phone calls personally for residents, before our civil 24 Defense Director was notified that a newsworthy event had taken 25 place. I was surprised a faw minutes ago to hear that Plymouth
________.___m__ _ . . _ _ _ _ . - . . _ . _
44 1 received notice at 11:00. Our Civil Defense Director was not 4
2 called until 4:00 in the afternoon.
3 The Duxbury Board of Selectmen are officially opposed 4 to the restart of the Pilgrim Nuclear Po'wer Station until 5 radiological emergency response plans, including procedures, 6 training and resources are approved and tested. Regardless of .
7 your decision on restart, Duxbury officials and volunteers will .
8 continue to work with Boston Edison to reach our goal of 9 producing a plan which will provide for the health and safety 10 of our residents.
11 As a matter of fact, we have recently accelerated 12 these efforts. .I am here today to ask that you give us 13 s'ufficient timd to protect those whose lives will be most 14 affected-if Pilgrim is al' lowed to restart at this time. .Thank 15 you.
16 CHAIRMAN ZECH: Thank you very much, Ms. Dowd.
17 Questions from my fellow Commissioners? Commissioner Roberts?
18 COMMISSIONER ROBERTS: No.
19 CHAIRMAN ZECH: Commissioner Carr?
20 COMMISSIONER CARR: Is your interpretation of a 21 technical review only,.the same as Plymouth's 22 MS. DOWD: Yes, it is, but Mr. O'Neil might like to _
23 answer that.
24 MR. O'NEIL: Yes, I agree with that Plymouth 25 interpretation of it.
i 45-
- :p lL, COMMISSIONER CARR: Even though'your plans for-2 implementing procedures-are only.in draft form, if something 3: happened, would you attempt to'use them?
4 MR. O'NEIL:- At this time, we are in the position 5 that we couldn't use any plans that haven't even been tested.
6 COMMISSIONER CARR: You wouldn't make the attempt to .
7 use them? .
\
8 MR. O'NEIL: We'd use any plans we had available.
9 COMMISSIONER CARR: You would?
10 MS. DOWD: May I give you an example?
11' COMMISSIONER CARR: Sure.
~
12 . .MS. DOWD: The Board of Selectmen received'a draft of 13 the procedures for.the Board of, Selectmen, and the Board of
- 14. Selectmen, you know, are the operating officials in our town.
15 Those procedures were -- did not apply to the situation in our 16 ' town at all. They did not recognize the fact that we have a 17 town manager who is or would be in private industry, a chief 18 executive officer. He was not even mentioned. '
19 They didn't apply at all. Our Board, my Board, could 20 not follow those procedures if something happened tomorrow.
21 We'd have to use our common sense.
22 MS. DOWD: 2That's semantics. I mean, was there ,
23 enough guidance there that you knew what to do?
24 MS. DOWD: In those procedures? No, we sent them 25 back. My common sense would be a better judge to me of what to
F. .
46 1L do than:that procedure.
2 COMMISSIONER CARR: I'll buy that answer.
3 MS. DOWD: Okay.
4 COMMISSIONER CARR: Do the players that drafted these 5 plans have a part -- did they have a part in their drafting --
,6 the people who are going to execute the plans; did they help ,
7 draft them?
8 MR. O'NEIL: Certain ones did, yes -- not all of 9 them. However, all thd players had an opportunity to rev'iew
- 10. them, yes.
. l 11 MS. DOWD: But that's Phase I and II in that process, j I
12 you know, so that -- ,
~,
13 . . COMMISSIONER CARR: I understand.: You mentioned that' .
14 only 35'of 38 of the implementing procedures -- are the three 15 missing ones the school procedures?
. 16 MS. DOWD: No, they are not.
17 COMMISSIONER CARR: What are the three missing ones? i
}
J 18 MS. DOWD: The school procedures are in the second )
19 phase of the process, but not through that phase yet, and have 20 not gone to the School Committee. The three that are not done l 1
21 are the -- the Board of Selectmen sent their's back, as I 22 explained earlier. The Town Manager -- ,
23 MR. O'NEIL: Town Manager and Public Information I 24 Officer.
25 COMMISSIONER CARR:. Does the state have a major part i
l
47 cl. to play in your implementing procedures?.
'2 MS. DOWD: Most. definitely.
3 COMMISSIONER CARR: 'How is your training plan 4 working?
3 5 MS. DOWD:- Well, as I explained, we've only had an 6 introduction to training. So far, the training has only been - ,
7 - right now the ongoing training is in the area of introduction 8 to radiation, dosimetry and decontamination. So, there has not
'9 been' training in any of the individual implementing procedure l 10 areas.
. 11 COMMISSIONER CARR: When do you expect to. start that?
.i
^
12 MR. O'NEIL: The training that Mrs. Dowd'is speaking 13 -
of has'been done by the introduction to ' radiation, introduction- '
14 to emergency response and dosimetry and emergency workers'in .
15 the town. The school hasn't even started that yet. The other 16 implementing procedure training will be starting in the near 17 future.
18 COMMISSIONER CARR: Like this month? Next month?
19 MR. O'NEIL: Hopefuily it will start before the end 20 of this month.
21 COMMISSIONER CARR: Okay, in your reception center 22 problem, when do you expect to designate a reception center? ,
23 Who designates it? ,
24 MS. DOWD: The state has the Wellesley Center under 25 consideration right now. Duxbury has taken an official
, 48-
>-- 1 position'that that's unacceptable.to us. I don't know whether )
2 our position'--
'3 COMMISSIONER CARR: Why is that unacceptable _to 4 .Duxbury?
5 MS. DOWD: Carl, you could probably answer that 6- better. -
7 MR. O'NEIL: The feeling that'the Town of Duxbury has 8' is, it is a considerable distance, and where it has been in the 9 feasibility stage, we will need answers that will assure us 10 that the population of the Town of.Duxbury can be 11 satisfactorily transported.that distance to the safe reception 12 'cg5ter, before it would be a viable site.
- o .
. 13 MS. DOWD:- Most' of .our reservations conce'rn 14 transportation. ,
l 15 COMMISSIONER CARR: On the Duxbury Beach area, what 16 are your current regulations for access to that beach?
17 MS. DOWD: What are our regulations? J 18 COMMISSIONER CARR: Yes, do you keep -- do you have 19 to get permits to go to the beach?
20 MS. DOWD: Oh, yes.
21 COMMISSIONER CARR: How many permits do you --
22 MS. DOWD: We have sticker permits. -
23 COMMISSIONER CARR: How many permits do you issue?
24 MS. DOWD: There were in excess of 3,000 issued last 25 year, last' summer. In addition to that, there are two l I
i
49 1: residential areas at the end of that beach.
2 COMMISSIONER CARR: A permit is for how many people?
3 MS. DOWD: Excuse me?
4 COMMISSIONER CARR: How many people is a permit?
5 MS. DOWD: A permit is per car.
- 6. MR. O'NEIL: In addition to that, the Gurnet/Saquish .
7 area is Plymouth, and Duxbury has no control over how many 8- permits are issued out that way. l 9 MS. DOWD: In addition to the stickers that we issue 10 to. residents, there is also a section of that beach that is for 11 the public.
' 12 ' . COMMISSIONER CARR: How much parking is there?
13
- MR. O'NEIL:. Around ,2,000 cars. -
14 COMMISSIONER CARR: I guess that I don't understand 15 your school' bus problem, saying you can only handle a thir'd of 16 the kids at any time. What time does the first bus leave for 17 school and what time does school start?
18 MS. DOWD: We transport all of our school age i
19 population in three trips, so that the high schoolers start 20 first at 6:50 in the morning. Intermediate school, I don't 21 -
know the exact times. The elementary schools go around 9:00, 1
22 so that we have a group of buses that do three complete trips. ,
23 COMMISSIONER CARR: Sometime between 6:50 and --
l
- 24 MS..DOWD: 9:00.
25 COMMISSIONER CARR: -- 9:00, they get them all to i l
)
50 .
l' school? *
- 2. MS. DOWD: Yes.
3 - COMMISSIONER-CARR: Okay, I understand that. You 4- said you.had predominantly commuters going out at peak hours --
5 , about 9,000 or so of your 14,000. How long does it takaLthem 6 -to get in'and out? What's the peak hour traffic?'
7- MS. DOWD: Sometimes it takes -- my husband works in 8 town. Sometimes it takes him an hour and a half to get to-9 Boston, which-is 30 miles away. .That's the same. route we would 10 have to evacuate by.
- 11 COMMISSIONER CARR: But he wouldn't have to go that 12- far?
13, -
MS . .- DOWD :
Excuse'mh*
.14 . .
COMMISSIONER CARR: Most of that is in Boston or 15 getting out of Duxbury?
16 MS. DOWD: No, a lot of it now is getting out of 17 Duxbury. There is one major access road out of our area, and 18 it's Route 3. It's a two-lane highway.
19 COMMISSIONER CARR: What is your budget?
20 MR. O'NEIL: The budget -- the town budget is --
21 COMMISSIONER CARR: I just mean for civil defense or 22 whatever your -- ,
23 MR. O'NEIL: Civil defense is $420 prorated by the 24 town.
25 MS. DOWD: May I explain that, please?
G
- S1 1 COMMISSIONER CARR: Please. j
~
2 MS. DOWD: Carl is our Fire Chief, and as Fire Chief, 3 he is spending a great deal of his time on civil defense, but 4 his salary is paid out of the fire budget. The other 5 department managers who work with Carl are the Town Manager, 6 the Police Chief, the School Superintendent, the DPW Director.
7 Their salaries are paid out of those individual budgets.
8 We do have monies from Edison..They did contribute 9 toward the building of the EOC center and the equipment. In 10 addition to that, we have funds to hire some consulting people 11 to help with civil defense, and we're in the process of looking 12 to hire someone. But other than our department managers, all 13 of our civil defense work is done by ' volunteers.
- ~
14 COMMISSIONER CARR: So, what do you predict that you ;
15 will have to spend out of the town's budg'et to get where you 16 want to go?
17 MS. DOWD: Well, we haven't broken it down to civil 18 defense, because we present our budget as --
19 COMMISSIONER CARR: However --
20 MS. DOWD: I really don't know at this time, but I'd 21 be glad to figure it out and send it to you, if you'd like.
22 COMMISSIONER CARR: I'd appreciate that. You've got ,
23 to get somewher's, and I just wondered. You say that Boston 24 Electric is helping you solve the problems?
25 MS. DOWD: Yes, they are.
,52 1 COMMISSIONER CARR: Is the state also helping?
- 2. MS. DOWD: 'Yes, the state has been working with'the c
3- civil defense. 2 4 COMMISSIONER CARR: Are you meeting weekly with the 5- state?
6 .MR. O'NEIL:- Yes,'the local officials are meeting 7 ,
weekly with'the state.
8 COMMISSIONER CARR: Has that accomplished a lot?
9- MR. O'NEIL: Yes, it has.
10 COMMISSIONER CARR: Have you taken a look at short-
, 11 -cutting your four-step procedure to maybe speed it up?
12 MS. DOWD: I don't think that's possible, but I will
. . ~ ~
[13 ' say that right now we are'in an accele'ated r mode. ,Our training 14 has begun, and we.think that will move a lot faster than it has 15 in the past. Now that we have the procedures in hand and have 16 started revising them, we think that will move faster.
17 I don't think there's a short-cut to that four-step ;
i 18 process at all. To do so would be to take a plan that we feel ;
19 would be inferior.
20 COMMISSION"" Cr 3: One of the things you asked for 21 was time to permit your municipal managers to carry out ERP 22 responsibilities without doing so at the expense of other ,
23 public safety functions. I understand that now better since 24 you say that there are the Fire Chief and all those other kinds
- j. 25 of, so it's a collateral duty with them?
.j
= ._ . _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ _
53 l' MS. DOWD: That's right. Right now, our Fire' Chief
~ '
2 spends a. good deal of'his weekly time on civil defense.
. 3. ,
COMMISSIONER CARR: As far as you can tell, you've
~4 got'your priorities right then?
5 MS. DOWD: Excuse me?'
6 COMMISSIONER CARR: You have your priorities right as ,
7 far as you can tell us, as attacking this problem?
8- MS. DOWD: Oh, I think so. We're certainly working 9 very hard on it.
10 COMMISSIONER CARR: . I was curious. I noticed that 11 one of things that you needed was a LORAN navigation radio.
12 What do you plan to do with that? .
13 MR. O'NEIL: That was requested by,the Harbor Master.
'14 He already has one. In that area, the' Harbor'gets very foggy.
15 COMMISSIONER CARR: Everybody needs two. I 16 understand that.
17 MR. O'NEIL: There are a lot of people out there in 18 t,he fog, too.
19 COMMISSIONER CARR:- You say that the Gurnet/Saguish 20 area is not one of your problems? That's somebody else's 21 problem? ,
22 ,
MS. DOWD: Saquish -- the Saquish area, even though ,
23 it's at the and of Duxbury Beach, belongs to Plymouth.
24 COMMISSIONER CARR: I guess I was curious about the 25 four-wheel drive vehicle. You have a police four-wheel drive 6
54 l' -vehicle,'I would assume?
2: MS. DOWD: 'We do, but we have_always serviced the 3 Saquish area -- out of a moral obligation more than anything 4 else. But our Police Chief has stated, and I thihk he is 5 correct; they're out on a spit, and.for us to take careaof 6 those people before our own residents in case of an event, 7 would be unacceptable to the Town of Duxbury.
8 You know, we certainly are going to take care of
, 9 Duxbury residents first. .
10 COMMISSIONER CARR: I understand. I was led to 11 believe your estimate of completing your readiness was February E How does that look to you today?
12 89.
. 13 , MR. O'NEIL: *Do yo.u want to answer that or do you ,
14- want me to answer that?
9 15 MS. DOWD: The February -- my Board of Selectmen:
16 decided that we needed to set up some sort of'a schedule in 17 order to be able to judge our progress and to get where we're 18 going.
19 COMMISSIONER CARR: I commend that. -
20 MS. DOWD: We asked Carl to come up with a schedule. I 21 The February 15th date is a date for everything to come to the 22 Board of Selectmen for their review. _
L 23 COMMISSIONER CARR: What step is that in your four-24 step process?
25 MS. DOWD: Fourth.
~ "
55 1, COMMISSIONER CARR: That's the fourth step?
2 MS.- DOWD: Th,at's the fourth step. We set that-
'3 schedule, realizing that a lot of what we have to prepare; we 4 need to wait on the state for a lot of that. It was better 5 having a date and a goal, even if that date has to be moved.
6 COMMISSIONER CARR:. I understand. Does that look.
-I 7 still good to you?
8' . MR. O'NEIL: I think it.would be very optimistic to 9 expect to attain that goal by February'15th.
10 COMMISSIONER CARR: What if I doubled your budget to 11 $840?
12' [ Laughter.] .
I ,-don't believe that sould do it.
13 .
MR. O'NEIL: .
.14 . COMMISSIONER CARR: That's all the questions I've .
'15 got.
'16 CHAIRMAN ZECH: Commissioner Rogers?
17 COMMISSIONER ROGERS: Just again to try to get some 18 idea of'what forces are actually going into this, what are the 19 dollars available for consultants? You mentioned that there is 20 some money available for consultants. Roughly, what is that?
21 MR. O'NEIL: From Boston Edison?
22 COMMISSIONER ROGERS: I don't care where it comes ,
23 ,
from.
24 MS. DOWD: $47,000.
25 COMMISSIONER ROGERS: How much?
56 1 MR. O'NEIL: $47,000 for ad'ministrative and technical 2 support, and they also financially assist in the training.
3 COMMISSIONER ROGERS: That's underway now?
4 MR. O'NEIL: Yes.
5 COMMISSIONER ROGERS: You're using those funds at 6 that level?
7 MR. b'NEIL: Yes.
8 MS. DOWD: For the training -- we haven't hired a 9 planning consultant yet, We're in the process of looking for 10 one.
11 CHAIRMAN ZECH: That's money from Boston Edison; did.
12 I un3c.rstand that?
The training is additional td.the
~
13 MR.,O(NEIL: Yes.
14 $47,000.
15 CHAIRMAN ZECH: Thank you. Commissioner Rogers?
16 COMMISSIONER ROGERS: What's your total town budget.
17 did you say?
18 MS. DOWD: About $23 million. May I add too, in 19 Massachusetts, we operate under the constraints of Proposition 20 two-and-a-half. The Town of Duxbury has reached its taxing
~
21 capacity. We have reached our levy limit, and might possibly 22 be looking at an override situation next year. That's part of ,
23 our problem. "We simply are not allowed --
24 , COMMISSIONER CARR: 'rou're not allowed to grow?
25 MS. DOWD: No, we simply are not allowed to raise, O
57 1- you know, aus much taxes as we need to run our town. -
2^ COMMISSIONER CARR: You better talk to Plymouth.
3 They are growing fast.
4 (Laughter.)
O 6 L 5 CHAIRMAN ZECH: Commissioner Curtiss? ,
6 COMMISSIONER CURTISS: Just two quick questions on ,
7 what Mr. Carr raised. The February 15th date; I had understood.
8 that to be the date by which you could complete all: the 9 procedures, and at the same time,.have a drill of the plan 10 undertaken. Is that still the target, and does the fourth step 11 that you envision, come before or after the dril,1?
12 .
MS. DOWD: I don't think we'll be finished by
[ .13 pobruary 1,5th. No, I think that.those proce'dures will ,
~
14 probably come to our Board around the middle of February --
15 possibly the middle of March.
16 -
COMMISSIONER CURTISS: Does the drill take place 17 before or after they come to you?
18 MR. O'NEIL: In that projection, the Town Managers, 19 the department heads, wanted to have some moderate exercises to 20 then adjust the implementing procedures prior to forwarding 21 them to the selectmen. We feel that it's a key issue to at 22 least do some initial exercises with it to find how acceptable _
23 they're going to be, before we even attempt to-forward them to 24 the selectmen.
25 COMMISSIONER CURTISS: Have you resolved the dispute
58 1 over early dismissai of' school children?
2 MR. O'NEIL: No. -
l 3 COMMISSIONER CURTISS: Is that a dispute that you can 4 resolve, or does the state have to resolve that?
~
5 MR. O'NEIL: I believe that will be up to the School ,
(
6 Committee. '
7 .
MS. DOWD: Fell, it will probably be up to the School 8 Committee, but keep in mind that the Board of Selectmen are the 9 ones who ultimately have to approve the whole plan.,
l 10 COMMISSIONER CURTISS: I understood. ;
11 MS. DOWD: I have a feeling that if.the School-12 Committee did not resolve that issue, then the Board of .
13 Selectman will.
^ '
14- COMMISSI7NER CURTISS: You have the final authority 15 to do that then?
16 MS. DOWD: Yes.
17 COMMISSIONER CURTISS: Thank you.
18 CHAIRMAN ZECH: You've been involved, I presume, in 19 Duxbury, and other officials.of Duxbury, in previous emergency 20 exercises regarding the Pilgrim Plant since it's been operating 21 since 1972. Could you characterize your views as to how th'ose 22 exercises have gone, and perhaps the status -- you think _
o .
23 whether the efforts you have made have improved or not 24
- improved? Could you give us your own characterization, please?-
25 MS. DOWD: I was not a member of the Board of
59 l' Selectmen.when those exercises were carried on. Carl might )
. I 2 want to add to what I have to say. I understand -- it is'my 3 understanding that those exercises were successful, but they 4 were exercises that were done on a plan that FEMA withdrew 5 approval of in 1987.
6 The plan clearly had deficiencies. There have not ,
7 been exercises on this current plan that we are working on, 8 which is a much improved plan.
9 CHAIRMAN ZECH: Thank you. I know that Duxbury, like 10 Plymouth, also has a history of competence in handling non-11 nuclear type emergencies. Perhaps you could tell us -- maybe 12 .
Mr. ,0'Neil would be-the proper one to tell us how you do handle
~
13 the hurricanes and the. flood possibilities.or other emergencies 14 in your territory. .
15 MR. O'NEIL: Certainly. In the past, we've handled 16 hurricanes and some severe winter storms without serious 17 consequence. We've been able to handle them very well. We, in 18 Duxbury, don't have an extreme area of low level flooding 19 during hurricanes, so that we have never been involved with any 20 major evacuation. That's what we are concerned with in this 21 particular situation.
22 CHAIRMAN ZECH: Thank you very much. Any other ,
23 questions from my fellow Commissioners?
24 (No response.]
25 CHAIRMAN ZECH: All right. Ms. Dowd, Mr. O'Neil; we m_______. _ _ _ . _ _ _ _ . .
60
.-- l . t1[ankyouverymuchforbeingwithustoday,'andforyour; 2 ' contribution-to this meeting.
3 MS. DOWD: Thank you. We appreciate the opportunity 4' to let you know'where we are in. planning.
5 CHAI'RMAN ZECH: Thank you very much. Next, we'll 6 call.Ms. Helen Copello, Administrative Assistant to the Deputy ,
7 Director of Civil Defense in Carver, Massachusetts. Ms.
8 Copello, did I pronounce that correctly?
9 MS. COPELLO: Yes. .
10 CHAIRMAN ZECH: Thank you. Good afternoon, 11- l gentlemen. Thank you very much for inviting our town to 12 participate. I'm sorry that Mr. Vezilli couldn't be here, who-13 was our Director, but because of a scheduling mixup, h'e has 14 told you.that I would'make his speech for him.' .
'15 CHAIRMAN ZECH: Give him our respects and tell him 16 thank you for allowing you to come.
17 MS. COPELLO: Thank you. In January of this year, 18 the Carver RERP, Radiological Emergency Response Plan,,was 19 submitted to the state Civil Defense and FEMA for initial, 20 informal technical review.
21 Comments received by the state and by FEMA have been 22 incorporated into the plan. We have 42 implementing procedures .
23 that include town agencies and private facilities. These
'24 private facilities are nursing homes, daycares'and camps.
25 Our sheltering program has twelve facilities that S
.. b
e .
" 61
- 11 have been identified and agreed to, and have-tone alert radios 2- and sheltering kits in place.. We havs four public and eight 3 private sheltering areas with a capability of housing our town 4 population.
5 On. October 12th of this-year, we submitted our plans, 6 procedures and sheltering procedures to Civil Defense and FEMA .
7 for another informal technical review. Our emergency operation 8 center is essentially, complete. We have some equipment that is, 9 still.on order and approximately 83 percent of our emergency 10 response personnel for the town have some form of training.
11 We hope to have all.our personnel completely trained 12 ,in the first quarter of next' year. Although.our communication with Bo' sten. Edison and our response capability'has greatly 13 - -
14- improved over the last is months, we'have no way of knowing 15 whether'or not the RERP and implementing procedures will be 16 accomplished until we test our capabilities in announced and 17 unannounced drills, and a full scale exercise has been tested.
s 18 That's all, gentlemen. I will try to answer your 19 questions if you have any.
20 CHAIRMAN ZECH: All right, thank you very much. We 21 appreciate that. Commissioner Rogers -- Commissioner Roberts, 22 I'm sorry. ,
a 23 COMMISSIONER ROBERTS: No.
24 CHAIRMAN ZECH: Commissioner Carr?
25 COMMISSIONER CARR: You seem to have done much better t
62 1 in Carver than others we've heard asout today. How do you 2 account for that? Have you got more effort and more FTE's, 3 more budget, more help?
4 MS. COPELLO: No, we just have a small town -- a lot l l
5 smaller than the re,st of them. Our population is only l'0,000.
I 6 COMMISSIONER CARR: It's'not that much smaller. You 7 still have to put out the same amount of paper, I would assume?
I 8 MS. COPELLO: More than likely. l a 9 COMMISSIONER CARR: There would seem.to be some ,
10 problem in your town of setting up the Decon facility. Would 11 you expand on that a little bit for me?'
12 MS. COPELLO: Well, the Fire Department,is not 13' wi'llingi ot do the decontami'natic'n, so we are trying to put 14 together. volunteers to do our decontamination. We also have an 15 area lined up to do decontamination, but it will not even be 16 started till after the first of the year.
l 17 What we are doing is taking a building that .au part i 18 of the DPW&L. When they move out of there, they're going to 19 revamp it to a decontamination area.
20 COMMISSIONER CARR: Have you got any insurmountable !
21 problem there, or is it just a matter of time?
l 22 MS. COPELLO: Well, if everything goes, they hope to ,
23 have them out of their position sometime in February, which 24 means it can get started. But it's also getting volunteers to 25 come in and help us.
E P
3 1
} 63 a
l' COMMISSIONER CARR: I don't want to neglect your 7
L 2 budget. How much is your budget? I 3~ MS. COPELLO: The town budget for civil defense that 4 is voted on by tho' people is $1,000. -
5 COMMISSIONER CARR: Thank you. l i
1 6 CHAIRMAN ZECH: Commissioner Rogers?
I 7 COMMISSIONER ROGERS: Out of what is your total L 8 budget -- town budget? l 9 MS. COPELLO: The town budget is $11 million.
10 COMMISSIONER ROGERS: Thank you.
11, MS. COPELLO: That's including school also.
12 CHAIRMAN ZECH: Commissions.r Curtiss?,
13 , COMMISSIONER CURTISS: No. '
14 CHAIRMAN ZECH: Well, I don't know, Ms. Copello, if 15 you've had the experience to know, but perhaps you do know that 16 your town has been involved in these exercises before. Could 17 you chara1terize how those exercises have gone in the past?
18 MS. COPELLO: I was not in civil defense at the time i
19 the exercises were. From what I have gathered from people who 20 have been involved, they were satisfactory, but I couldn't 21 answer you better then that.
22 CHAIRMAN Z.ECH: All right, fine. All right, thank ,
23 you very much. Are there any other questions from my fellow 24 Commissioners?
25 (No response.]
w-_.----_.-__-__. _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ . . _ _ ,
f 64 11 CHAIRMAN ZECH: Ms. Cepello, thank you very much for 2 being with-us today. We appreciate your appearance.
3 MS. COPELLO: Thank you.
4 CHAIRMAN ZECH: Next, we'll call on Mr. Robert Reed,
'S the Town Administrator of Kingston. ,
6 Welcome, Mr. Reed, P.nd you may proceed. ,
7 MR. REED: Thank you very much. Good afternoon. My 8 name is Robert Reed and I am the Town Administrator of i
9 .Kingston, Massachusetts. I'm here to offer brief remarks.on 10 behalf of the selectmen, the civil defense officials and 11 citizens of the town of Kingston.
12 . Kingston is a town immediately to the North of
~. 13 , Plymouth,.the. town in'which Pilgrim Nuclear Power Station is ,
14 located. Kingston has a population of approximately 8,000, 15 and, for the purposes of planning, is included in its entirety
. 16 within the Pilgrim 10-mile Emergency Planning Zone.
17 Because of the plant's past performance, and the 18 proximity of Kingston to the site, the restart of Pilgrim 19 Nuclear Station is a matter of great concern to the people of 20 Kingston. Last November 8th, the majority of the citizens of 21 Kingston who voted supported a statewide referendum questions l
22 which called for no further generation of power by commercial _ i I
23 nuclear plants in the Commonwealth, by means of which would l 24 result in the production of nuclear waste'.
25 At a speci.1 town meeting in May of 1987, the town L _ _ _ ___ -_- .
__ _ _ . _ - - = - _ _ _ _ _ _ _ _ . _ __ _ _ _ _ _ _ _ _ -
65 li voted to request the Governor and Attorney General of-2 Massachusetts to take whatever legal action appropriate to 3 delay the restart.of Pilgrim Nuclear Station until.the 4 Massachusetts Department of Public Health completed a study of 5 the cancer incidence in the towns of Plymouth, Kingston, 6 Duxbury, Marshfield and Scituate. ,
7 Finally, the Kingston Board of Selectmen recorded' 8' their official position on restart. They are opposed to the 9 restart of Pilgrim Station until an approved and tested 10 radiological emergency response plan is in place.
11 In July of 1987, the planning process was begun on 12 the Kingston radiological emergency response plan,.and since
. 13 that process'was fnitiated, the, plan.itself and implementing 14 procedures for it are considerably better than they used to be.
15 Town officials have put in countless hours of planning, 16 training and procedure development.
17 Agency heads,. private shelter owners, school 18 officials and volunteers all dedicated a great deal of effort 19 towards completing a draft version of the response' plan and 20 detailed implementing procedures consisting of 70-75 checklists 21 and the shelter implementation program. All of these documents 22 were submitted to the state civil Defense Agency and the ,
23 Federal Euergency Management Agency for technical review on 1
24 October 12, 1988.
25 We are await'.ng feedback from these agencies as to
)
I: 66 1 the appropriateness of format and content of the documents.
2 However, it must be noted that these plans procedures have been 3 approved by th town in concept only, and there remain some 4 planning, procedure and resources problems which must be 5 addressed before formal approval can be considered.
6 For instance, there is the policy of the Kingsten ,
7 Elementary School Committee to dismiss students early when 8 there is a snow emergency. The Committee wishes to follow the 9 same procedure in a radiological emergency, but the policy is 10 at odds with the draft implementing procedures for schools, 11 which instead calls for bringing in buses and conducting a 12 precautionary transfer of school children to host schools 13 . '~ outside the area. .
14 . The School Committee's wishes are also at odds with 15 the recommendation of state and utility planners. Discussions 16 to resolve this issue are underway, but no agreement has yet 17 been reached. In addition, the implementing procedure for )
18 Kingston's regional high school is still under review by that 19 School Committee, which includes representatives from three 20 non-emergency planning zone towns.
1 j
21 The school itself contains students from outside the !
22 Emergency Planning Zone, and specific provisions for the _
23 parents of those children have not yet been outlined. There is 24 also a concern for the special needs population of Kingston, 25 and what special measures would be taken for their safety. As I'
67 l' yet,' identification of the special needs' population.is:
- 2. incomplete.
3 The Kingston P'olice Chief objects to some premises as 4 set forth'in the traffic management procedures. He feels 5 strongly:that no one should be permitted'to enter the town, 6 once an evacuation is ordered. His objections conflict with
~
7 the current evacuation time estimate which-states that the 8 borders of the town are not to be controlled for two hours so
'9 that residents may get in and out to adjust for their own 10 evacuation needs.
11 The Police Chief feels that this strips him.of 12 maximum. control of the town and this is another example of
, . 13 procedure in need of attention.
Recent'ly, work has' begun.in '
14 the construction of a large shopping mall in southeast
~
15 Kingston, expected to be completed in 1989. The company 16 developing the mall has propt Hui and is initiating work on the 17 upgrading of five different traffic intersections to handle the l 18 anticipated increase in traffic near the site of the mall.
19 An item like this raises some concern about our i 20 radiological emergency response plan. If ' construction needs to
~
21 be done all along our r'oads and intersections reconfigure in 22 order to service an influx of drivers out on a shopping spree, ,
23 how can we assume the current roads are sufficient and safe
. 24 enough to handle the v'olume and type of traffic expected during 25 a nuclear evacuation? I W
4
68- ,
l 1 o The mall is not only the largest project proposed for
-2 Kingston,.already a rapidly growing area, and traffic-3 congestion'is expecteg1 to increase each year. A resource 4 concern closely aligned with traffic management, is that 5 ,
additional coordination is required among-the Kingston' Police 6 Department,,the State Police and County Sheriff's-office. _
l 7 There is a question as to whether the town police 8 force can manage to staff all'of the traffic and access control 9 points assigned to them. Our Police Chief says that there's 10 not enough cruisers to man all the traffic and access control 11 points. School officials are concerned as to whether a 12 sufficient' number of bus drivers will' respond'to evacuate the 13 school children. ,
14 Recruitment is still needed in order"to staff all the 15 civil defense positions at least two deep to ensure 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 16 coverage. We are still in need of an alternate civil defense 17 director to take over when the designated director has done a 18- 12-hour shift. l 19 The planning process has also uncovered some 20 equipment needs such as functional emergency operations center, 21 traffic and access control equipment, and communications i
22 equipment. This equipment is vitally needed in order for the ,
l 23 town to protect its citizens. '{
)
24 Although the utility has provided a great deal of 25 this equipment, it is not all in place. Other equipment issues
y L -
69 g 11' still unresolved includ$e the fact.that only two telephone! lines
- 2 exist into the Kingston Elementary _ School, the Regional High ,
-3 School or the School Administration Building.
4 . The telephone system at our emergency operations 5 center is not fully operable at this point either. We need 6 pagers for all key people if we want to feel confident we can ,
l l
7- notify them at any time. We still need public address' systems !
)
.8 for police and fire vehicles, traffic control barricades, cones.
9 and decontamination kits. ,
10 In addition, it is believed that the number _of 11 shelters for transients is-insufficient. All these equipment 4
12 and facilities needs illustrate the overwhelming expectations l 1 :- .
- - , , . l ,
13 placed on a' municipality's limited resources.
14 Perhaps the most single most important element in the l 15 Emergency Response Plan is training. In many' departments, the' 16 training remains incomplete, or has not yet hagun. The Police, 17 .re and Highway Departments are not yet fully training. No i i
l 18 training sessions have been held for the one hundred plus 19 teachers and staff at the Regional High School.
20 At training session.was held at the Elementary 21 School, but there was only very light attendance. Our Civil 22 Defense Director is not comfortable that a staff yet exists ,
23 which is suffic'iently trained to coordinate the Emergency 24 Operations Center. There are dozens of nursing home, daycare, 25 camp and civil defense staff yet to train.
I
- - - _ . , _ _ . - - - - _ . - . . _ , . . . _ - _ _ _ _ _ _ _ __n.-_.------._ _---_._- - - - - . _ - - - - _ _ - - _ . - - _ _ _= -_ _ _ . _ _ _ . _ _ - _ . - - . _ _. . _ _ --. _ - - _ - - _ . . - ~ , - - . -- _ ~ _- ~
.- 1 I /r :
70 11 Many of'these people-are not yet aware that:they 12 would have roles to play in an emergency response plan, and' 3 only training can rectify.that situation. We recognize that 4 training is an ongoing process'and will never be complete, but ]
5 our concerns are related to training on the implementing 6 procedures.
7 ,
Some people have not been fully ~ informed of their 8 duties within these procedures, and'we have no estimates of 9 when the initial training sessions will be complete. Without 10 this basic type of training, we have little confidence in our 11 emergency response plan. Finally, and in agreement with the 12 surrounding towns, the selectman insist on participating and l
~ l 13 judging a full test.of the. plan and progadures. f 14 We'd like to'see a simulated example of an emergency 15 at Pilgrim Station. We would like to see many facets of the 16 plan demonstrated,. notifications, communications equipment 17 tests, state participation, facility operation and a few buses 18 running pickup routes and precautionary transfer routes. Only 19 after a successful test of the plan and implementing 20 procedures, will we feel public safety is well served.
21 One might use the analogy of a football play draw on 22 a blackboard, j but never run in practice. We have all the x's ,
23 and o's, but we have no idea how the team will work together.
l l
24 We do know, however, the team works well together in the 1
25 planning process, because throughout the process, Kingston town
.___.._.__________________.m_ _ _ _ _ _ . _ . _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ __ _ _
_- _ - ____ _ -_- _ _ - _ _ _ _ = _ = _ _ .
71
- j. ,
1~ officials and many citizens have worksd diligently on the 2 emergency-response plan.
.3 They've offered their time on it, not in the 4 expectation that it would prevent injury or loss of-life, nor 5 that it would guarantee the safety of everyone in Kingston, but 6 in the beli2f that having a well thought out emergency plan is 7 far better than having no plan at all. They have been largely f 8 engaged in an act of faith during this process,.and as such, 9 have cooperated with all parties to the best of.their ability, 10 but without benefit of the knowledge that the plan really 11 works. -
12 We Vo believe that the state of'Kingston's emergency 13 ' preparedness has been increased by the level of planning that 14 has been accomplished through the efforts of town offi.cials.
15 However, we feel that the is' sues discussed here regarding the 16 implementing procedures must be addressed; training must be 17 completed; equipment must be put in place, and a full scale o
18 exercise must be conducted. ;
19 We believe that an exercise will be the most .
l 20 realist'ic manner in which a determination can be made as to the 21 readiness of the Radiological Emergency Respons's Plan.
22 In view of those sentiments, the Board of Selectmen ,
23 of the Town of Kingston believes that the Pilgrim Nuclear Power 24 Station sho'uld not be aliowed to restart until an' exercise has )
l 25 been conducted.
4
- --_-__-___--__-_____.o
i 72 l' On' behalf.of the town of'Kingston", I'would like to I
. 0 2 thank you for this' opportunity to express the town's view on ]
3 'the status,of' radiological emergency preparedness for the town. l u
4 Thank you.
5 CHAIRMAN ZECH: Thank you very.much. Questions from 6 my colleagues. Commissioner Roberts?
7 COMMISSIONER ROBERTS: No. )
8 CHAIRMAN ZECH: Commissioner Carr?
. 9 COMMISSIONER CARR: You say that you have no major 10 problems that training couldn't solve, and it seems that most 11 of what you have left is a matter of training and cooperation.
12 What is your budget for Civil Defense, taking care of this 13' problem? -
14 MR. REED: Our budgets also -- the civil' defense is 15 quite small,. It's.in the area of four to five hundred dollars.
16 We have received quite a bit of assistance from the utility.
17 We have a grant for a Civil Defense Planner. We received a 18 great deal of equipment for our Emergency Operation Center, and 19 the construction of that center. And I don't see how we, in 20 any way, would have been able to amass the resources that they 21 have put into Kingston. But we're still far away from --
22 COMMISSIONER CARR: So you don't have anybody right .
23 now in charge of Civil Defense? ,
24 MR. REED: We have a Civil Defense Director, but he's 25 only part-time.
4 73 1 COMMISSIONER CARR: And he's part-time? Is'he a 2 volunteer -- -
'3- FGt. REED: Yes. Largely.
4' COMMISSIONER CARR: -- or is it a collateral duty to 5 him? ,
6 MR. REED: Yes.
7 COMMISSIONER CARR: I was curious, when you said you 8 don't know when you can get your training done. How can you 9 operate without an estimate of some time frame you want to get 10 your training done in? You don't know how many trainers to get 11 or how many people you've got to train?
12 MR. REED: Well, I think we have an idea of how many
~
'13 we have to train, but I think the overall scheduling still 14 hasn't been completed. .
15 COMMISSIONER CARR: My curiosity is aroused as to why 16 -- what have you got left to do, or who -- who is responsible 17 for doing that, I guess? As a town administrator, is that 18 part of your responsibility?
19
- MR. REED: I would say that's largely the 20 responsibility of our civil Defense staff.
21 COMMISSIONER CARR: I have no-further questions. ;
22 CHAIRMAN ZECH: Commissioner Rogers? ,
23 COMMISSIONER ROGERS: What is your process for 24 approval of your plans, your int'ernal process within the town 25 structure itself? How many steps do you have in that? How G
9
74 1- .does-that. proceed?' ,
2' MR. REED: Well, my understanding, and this is, you ]
3 know, my understanding. Admittedly, I think, perhaps, for 4- accuracies sake, you may.be better off, or your staff may be
{
5 better off contacting our Civil Defense people. '
6 But the plans are reviewed with the various ,
i 7 department heads, are people responsible for implementing the 8- -various procedures.- And they are signed off before they are 9 submitted to the Board of Selectmen for further review.
10 COMMISSIONER ROGERS: What is your town budget, your 11 total town budget?
12 MR. REED: Without schools, approximately $6 million.
13' COMMISSIONER ROGERS: Without schools. With schoo.ls, 14 just on the same basis as the other towns have told us?
1,5 MR. REED: Yes. Probably about $11 million.
16 COMMISSIONER ROGERS: Thank you. .
17 CHAIRMAN ZECH: Mr. Curtis?
18 COMMISSIONER CURTIS: No, thank you.
1 L '19 CHAIRMAN ZECH: Perhaps, Mr. Reed, you could 20 , characterize how the previous exercises that have been 21 conducted regarding a Pilgrim's Emergency Planning in your area 22 -- could you characterize how those exercises have been viewed? _
23 MR.' REED: Previous exercises, I don't believe I 24 could. I've been in Kingston about a year. I've --
25 CHAIRMAN ZECH:. You're not able to do that.
I'
751
'l MR.HREED: I1wouldn't ha:ard a guess on that.
2' CHAIRMAN ZECH: All right. Certainly.
- 3. But from what you tell us, it'looks-like more 4' training and a little more time'i.s necessary. Is that-5' essentially *what you're telling us?
6 MR. REED: Well, I think,'right now, the emphasis 7 would be on training and also on an exercise. That has been 8 the emphasis with our Civil Defense' Director and also'with the-9 Board of Selectmen.- And that will give us a prospective on.our .
10 plan and'how well it works.
11 . CHAIRMAN ZECH: All right. Thank you very much. Any 12 other questions? .
~
. . 13 ,
~ (No resp'onse.] ,' '
14 , CHAIRMAN ZECH: All right. Thank 'you very much, Mr.
15 Reed, for being with us today.
16 , MR. REED: Thank you.
17 COMMISSIONER ZECH: We appreciate your appearance.
18 Mr. Daniel Mcdonald, Vice Chairman of the Board of 19 Selectmen of Marshfield, please. Mr. Mcdonald, welcome. You 20 may proceed.
21 'R. MCDONALD:
M Thank you, gentlemen. I'd like to 22 introduce our Civil Defense Director, Mr. Dan McGonagle. ~
l l 23 Commission members, as the Town of Marshfield's 24 representative from the Board of Selectmen, I'd like to thank 25 you for this opportunity to familiarize you with the status of
-- a _ . - _ ._ - - - _ .
-76
' 1 '. our emergency' planning.. The emergency planning 'for Marshfield 2 has been a long, arduous, and incomplete process.
3 Our Emergency Response Committee has wor'ed k prudently.
4- with Boston Edison personnel and our many.public service groups 5 to develop the Emergency Response Plan that suits the'needs of 6; our community in the event of an accident at the Pilgrim 7 Nuclear Power. Station, 8 Throughout that developmental process, the Board of 9 Se!.ectmen.has actively reviewed the plan with comments on a-
.10 number of occasions. On August 8, 1988, the Board unanimously 11 took action on the current status of the Marshfield Plan,;snd-12 in a letter to our Emergency Response Committee Chairman, Mr.
' 13 'McGonagle, the Board
- clearly and in no u certain terms' stated -
14 its position relative to the evolving nature of the plan.
15 I would like to read into the record the contents of 16 that letter of August 8, 1988, which is atta;hed to my 17 statement.
18
Dear Mr. McGonagle,
19 The Marshfield Board of Selectmen has revised the 20 -draft document titled " Town of Marshfield Radiological 21 Emergency Response Plan for the Pilgrim Nuclear Power Station."
22 We have offered suggestions and have agreed to forward the plan ,
23 -
for further review and comment to Massachusetts Civil Defense 24 , Agency and F.E.M.A. It must be clearly understood that the 25 Marshfield Board of Selectmen has not approved or endorsed the
. 77 li plan, and ve still have major reservations regarding its 2 viability. Realizing that neither the Board of Selectmen nor 3 any other official in town is adequately trained to skillfully 4 evaluate all the merits ar.d deficiencies of this proposal, we 5 feel the time has come for M.C.D.A. and F.E.M.A. to have' direct 6 professional input.
7 13de issues of greatest concern to the Marshfield 8 Board of Selectmen are as follows:
9 1. The adequacy of evacuation to Wellesley as opposed to 10 Weymouth Air Base or University of Massachusetts in Dorchester
> 11 ' or other more appropriate sites.
11 2. Concerns relative to actual traffic flow in a worst 13 .cas'e' scenario during evacuati6n.
14 ,
- 3. Although the. plan is specific concerning the I 15 Governor Winslow School (within the 10 mile zone), we believe 16 general chaos would occur.at other schools as well as with l
17 parents rushing to pick up children.
18 4. We need greater clarification of the ongoing 19 training timetable and agenda with more attention given to 20 inevitable personnel changes.
'21 5. We have serious doubts regarding the willingness of 22 local unions and other employee union groups to remain at their ,
'23 posts and to cooperate during the evacuation.
24 Under no'circumst'ances can this Board approve this 25 document in good conscience unless and until a written letter
~ 0
78 1 of agreement is received from involved employee groups 2 accepting their roles in the evacuation process and their 3 ' expressed willingness to perform cur in the alternative, 4 personnel being provided by B.E.C.O.. Additionally, any 5 approval by this Board would require a concurrent endorsement 6 by our yet-to-be-hired " Emergency Response Consultant."
7 Although we agree that the current plan demonstrates a good 8 effort by B.E.C.0., we feel any support for it would be 9 premature at this time.
10 We ask that you forward this draft to the appropriate 11 state and federal officials for their constructive analysis.
'12 It's signed Richard E. Levin, Chairman; John 13 MacMahon; and Daniel F. Mcdonald. '
14 The Town of Marshfield has, in every capacity, acted 15 in good faith to address the needs of our community in the 16 event of an emergency at Pilgrim. It was distressing to have 17 read the transcript of the September 29, 1988 " Review of the 18 Proposed Restart of the Pilgrim Nuclear Power Station Meeting 19 held in Plymouth, Mass.," at which time, in his discussion of 20 the plans to date, Mr. Ronald Bellamy can be quoted as saying:
21 "First the Town of Harshfield. The draft t 22 implementing procedures, a shelter implementation program and a ,
23 cost reference of the F.E.M.A.-identified deficiencies with 24 sections of the plans and procedures that address resolution l
25 have been approved by the Selectmen . . .
l f
79 1 It'is important at this time, commission members, and-2 with all due respect for Mr. Bellamy, to set the record-
- 3. straight. Our position on the status of our plan'can be no 4 more succinctly stated than to re-quote our August 8 concerns.
5 And I quote: "It must be clearly understood that the 6 Marshfield Board of Selectmen.has not approved or endorsed the ,
7 plan, and we still have major reservations regarding its 8 viability. Realizing that neither the Board of Sel'ectmen nor 9 any other official in town is adequately trained to skillfully 10 evaluate all the merits and deficiencies of this proposal, we 11 feel the time has come for M.C.D.A and F.E.M.A. to have' direct 12 professional input." .
13 Mr.,Cha,irman, it must be notegl.that'w'e in the' Town.of 14 Marshfield have put our best efforts forward to address the 15 needs of our community for an incident of unknown magnitude and 16 of which there is little understanding or consensus.
17 The position of our Board has been that of cautious 18 diligence. We are deeply concerned that there are remaining 19 major structural concerns within the EPZ as to the procedures 20 necessary to ensure the safety of our school children, 21 waterfront user groups, and the disproportionate number of
-22 elderly that have made this zone their home. _
23 Furthermore, as Selectmen representing the entire 24 town, I feel it is ludicrous to entertain the notion that the 25 90 percent of the Town of Marshfield that reside or do business
)
80 1 outside'the-EPZ and that have not been addressed in our plan 2 will not react to the deluge of media response to an accident 3 'at the Pilgrim Nuc, lear Power Station.
4 We therefore must join our Stat:e Department of.Public 5 Safety in calling for protective actions, and,I quote, "on a 6 ' hole w town basis." This will provide a conservative margin of 7 safety, and it will avoid confusion regarding which parts of .
8 the community need to react.
, 9 Mr. Chairman, there are other issues on the periphery 10 of the Pilgrim debate that are also of deep concern to the 11 citizens of Marshfield when discussions of re-start occur.
12 Some of these are well documented as major deficiencies in the 13 - operation of this facility. We in Marshfield have little 14 technical expertise to assess the management capability of 15 Boston Edison, the reported high cancer incidence in the five-16 town region, or the reported high risk of failure associated 17 with GE Mark I contaminants like Pilgrim.
18 Mr. Chairman, you and your Commission hold the 19 legislative duty and responsibility to act prudently and 20 responsibly to ensure the uncompromised public health and 21 safety of our citizens as a vital component of re-start 22 considerations. .
23 Finally, Mr. Chairman, at this time we must support 24 the overwhelming call from our congressional delegations of 25 Senators Kerry, Kennedy, Congressman Studds, Governor Dukakis, e
81 l' the Massachusetts Department of Public Safety, the l 2 Massachusetts Civil Defense Agency, and local officials for a 3 full-scale exercise of off-site plans. ,
. 76- ,
A plan that doesn't work is not a plan. .
5 Thank you for your sincere concern for the residents 6 of the Town of Marshfield.
7 CHAIRMAN ZECH: Thank you very much. Commissioner 8 Roberts?
9 COMMISSIONER ROBERTS: No.
10 CHAIRMAN ZECH: Commissioner Carr?
. 11 COMMISSIONER CARR: Yes. Have you hired -- that 12 ietter was dated August 8. Have you hired your Emergency 13 ,R'esponse Consultant yet?
14 MR. MCDONALD: No, we h' ave not.
15 COMMISSIONER CARR: What happens to be the problem 16 there?
17 MR. MCDONALD: We had no place to put him. Our EOC 18 Center was under construction -- not even under construction at 19 the time, and we expect completion within the next 60 days. In 20 November, we advertised for both an Administrative Assistant as 21 well as a Consultant to review the plan. We, as a matter of O
22 fact, on the way down,, reviewed the resumes of both today, and ,
l 23 we hope to have someone on board by the first of the year, or 24 as soon as the EOC Center is available.
25 COMMISSIONER CARR: Let's say for discussion that he
'N .
82
-1. comes on by the first of'the year, and on 1 February he 2- . approves your plans, does that reassure you -- the Board of 3 Selectmen --
4 MR. MCDONALD: Well, ultimately, the Board of
$ Selectmen will approve the plan. We certainly look forward --
6 COMMISSIONER CARR: But you said you're waiting on
- ~
7 him.
8 MR. MCDONALD: We look forward to professional input.
9 We don't feel qualified to assess what the needs are of an.
10' emergency at Pilgrim.
J 11' COMMISSIONER CARR: Well, it appears to me that 12 you've taken the problem as one to be solved, and that training 13 ,is a majc(' obstacle left in.your, town as well.
, 14 MR. MCDONALD: Th'at's right.
15 COMMISSIONER CARR: I realize the Board hasn't
, 16 approved the plan, and you feel you're inadequate to make the 17 skillful evaluation. With respect to your statement that a 18 plan that doesn't work is not a plan, I would only quote you 1
19 Webster, which says that a plan is a method of action or 20 procedure.. He goes on to say that a plan refers to any method
'21 of thinking out acts and purposes beforehand, which you seem to i
22 have done. I think we would all agree that any plan is better ,
23 than no plan usually.
24 Would you use what you have in case of an emergency 25 at Pilgrim?
_ _ _ _ _ _ _ _ _ _ _ _ i a
83 1 MR. MCDONALD: Of courco.
2 COMMISSIONER CARR: Are you having weekly meeting 3 with the states?
4 MR. McGONAGLE: We have meetings on Thursday.
5 Meetings are conducted in Area 2.
6 COMMISSIONER CARR: In your town, or --
7 MR. McGONAGLE: No, it's in -- within the area.
8 Approximately 25 to 30 miles away.
.9 ,
COMMISSIONER CARR: So it rotates, or is it always 10 the same place?
11 MRs McGONAGLE: Basically, it's in the same location.
12 MR. MCDONALD: Our attendance at the meetings has not 13 been -- has not been known to be, great. Mr. McGonagle, as our 14 Civil Defense Director, is a full-time worker and a volunteer 15 for the town. And we look forward to these two positions'that 16 Boston Edison has made money available to us for.
17 COMMISSIONER CARR: Would you classify state and 18 Boston Electric's aid as helpful?
19 MR. McGONAGLE: Yes.
20 COMMISSIOh7ER CARR: Absolutely necessary?
21 MR. McGONAGLE: Yes.
l 22 COMMISSIONER CARR: Okay. I might make a comment on
- 23 your comment about responsibility, as well as Duxbury's and 24 Plymouth's, also. Even if you all approved all those and 25 blessed them, you couldn't relieve us of our responsibility.
I 84 1
1 So I-feel that very strongly, no matter what. That's all I l 2 have.
3 CHAIRMAN ZECH: I think we all do. Commissioner l'
l 4 Rogers?
l 5 COMMISSIONER ROGERS: Yeah. What is your. Civil 6 Defense Budget, and what's your town budget?
7 MR. MCDONALD: Our Civil Defense budget is $2,000, 8 It includes salaries. And town budget is approximately $30 9 million.
10 COMMISSIONER ROGERS: Thank you.
11 CHAIRMAN ZECH: Commissioner Curtis?
12 . COMMISSIONER CURTISS: What's your total population? ,
' ~ '
13 MR. MCDONALD: Twenty -- approaching 25/000.
14 COMMISSIONER CURTISS: ' What share of that is within 15 the ten mile EPZ? -
16 MR. MCDONALD: Approximately ten percent and we have 17 a build-out analysis of approximately double that figure.
18 CHAIRMAN ZECH: Mr. Mcdonald, could you characterize 19 the past emergency drills that you had and emergency exercises 20 you have had regarding the Pilgrim emergency plan in the past.
21 MR. MCDONALD: In regards to Pilgrim?
22 CHAIRMAN ZECH: Yes. ,
23 MR. MCDONALD: Mr. McGonagle, do you want to answer 24 that?
25 CHAIRMAN ZECH: Either one of you.
e W
'85 1 MR. McGONAGLE:. In comparison, ovar the-past 18 2 years, my experience has been, we've been very successful in 3 handling various emergency type situations. However, I feel 4 necessary to point out, dealing with an incident at Pilgrim 5 would.tNa quite different than what we've experienced in the 6 past.
7 For example, in'the blizzard of '78, Hurricane 8 Gloria, we had a lot of people come forward to help us out.
9 They did participate. We were grateful for that. But I don't 10 strongly feel that we would have those types of people come 11 forward in.the event of a nuclear --
- 12. . CHAIRMAN ZECH: But is the past, exercises have been
~ '
., 13 . conducted in the Pilgrim' Plant. In the'past, emergency .
14 planning exercises have been conducted. Has the Town of 15 Marshfield participated in those exercises?
16 MR. McGONAGLE: Yes, sir, they have.
17 CHAIRMAN'ZECH: And how would you characterize those 18 exercises?
19 MR. McGONAGLE: Good.
20 CHAIRMAN ZECH: Okay. Thank you. Any other 21 questions?
22 . COMMISSIONER CARR: Yes. I might add one comment ,
23 with respect to your last one there about helping in a time of 24 emergency. I refer yod to the major fire they had in the 25 Springfield in the chlorine production facility, which you i
I
86 .
1 Dight rcvicw that. And thsy ecamrd tu gat a lot'of help, no .
1 2 matter that it was a hazardous situation. So, it might 3 reassure you what people do in the case of a real emergency.
4 MR. MCDONALD: We have a problem already standing in 5 that at the time of this August 8 meeting, our Department of 6 Public Works attended and issued a statement that said that j 7 they would have no part of any part of an incident at Pilgrim.
8 COMMISSIONER CARR: Is that a town department or a 9 state department?
10 MR. MCDONALD: It's a town department.
11 COMMISSIONER CARR: Do you have control over that?
12 MR. MCDONALD: Within reason.
13 I think the other. point that's'important'to make is 14 that we have not gone through any. training as of yet, and we're 15 waiting for the training modules to be approved by the state.
16 And it's my understanding that they haven't been submitted to 17 the state by Boston Edison. And at that point, I think when we 18 get into the training we'll have a better idea of the types of 19 problems we'll hhve with other -- other groups that are part of I
20 the plan. 'We've seen some resistance in other communities, as 21 well as in town, relative to schools.
22 COMMISSIONER CARR: But it's your responsibility, as ,
23 well as Boston Edison, to get those training modules forward, I
24 isn't it? l 25 MR. MCDONALD: We're ready for them, and they're l
I l
y
.. 87 1: aware-of'that.- .
-2 COMMISSIONER CARR: But if they didn't give them'to 3 you, you'd still have to prepare them?
4 ,
MR. MCDONALD: I believe they do the preparation of
~
5 the training. i 6 COMMISSIONER CARR: Thank you.
7 CHEIRMAN ZECH: I believe Ms. Thompson said that she. )
8 believed that they've come a long way in Plymouth, and they --
9 but they really still have a'long way to go. Would you' agree i
10 that -- and you've told us you have a way to go. We recognize ;
11 that. Would you agree, though, that you have improved your 12 plan over the ' plan you had in the past?
' ~ ~ ' '
13 .
kR. McGO'NAGLE: Yes, sir.
14 CHAIRMAN ZECH: It has been improved?- .
15 MR. MCDONALD: The problem that we're concerned with 16 is the problem of the split zone in town. The evacuation area 17 is in the furthest corner to the evacuation route. So we're 18 concerned that, as I suggest, in the event of an incident, and 19 the deluge <>f media that will take place, there is -- it's just 20 inconceivable to think that the rest of the town will stay put.
21 CHAIRMAN ZECH: All right.
22 MR. MCDONALD: That creates a whole host of problems ,
23 that are not addressed in the plan.
24 CHAIRMAN.ZECH: All right. Anything else? Thank you 25 very much. We appreciate you being with us today. Thank you,
88 e
1 gentlemen.
2 MR. MCDONALD: Thank you.
3 CHAIRMAN ZECH: We will?ask Mr. Tom Barlow, the Clerk ,
4 of the Board of Selectmen of Bourne,'and Mr. Charles Noyes, the 5 Civil Defense Director. Welcome, gentlemen. You may proceed, 6 Mr. Barlow.
7 . MR. BARLOW: I'd like to thank you for the 8 opportunity to speak today. The town of Bourne -- Bourne is j 9 located in Southeastern Massachusetts. It's bordered on the 10 north by Plymouth, east by Sandwich, south by Falmouth, west by 11 Wareham.' It's approximately 55 miles south of Boston. It's 12 year-round population is 15,365; summer populations wells to 13 35,000. ;
i 14 I'd like to bring your attention to,the area within 15 ten miles radius'of Pilgrim Power Plant. I have a map attached 16 in this handout. It's that aerial photography done by the l 17 County of Barnstable. It shows ten-mile radius to the Pilgrim 18 Plant, going down to*20 miles outside. The town of Bourne is 19 within that ten-mile radius. It's presently eight residences, l 20 both seasonal and year-around. In the upper right-hand corner, 21 --
22 , CHAIRMAN ZECH: Excuse me. How many? ,
23 MR. BARLOW: It's eight.
24 CHAIRMAN ZECH: Eight.
25 MR. BARLOW: There is construction under way for a
- e. .
. 89 !
s I 1, 77-units complex within ten miles of the radius. There,are 2 future plans for a condominium -- more condominium units in ;
-3~
that specific area. We don't know how many at this_ point.
4 Traffic concerns. The Sagamore'and the Bourne' 5 Bridge, built in'1935, provide the only means for,the public to 6 travel from the Cape to Boston or to other points. Cape Cod ~ ,
7 has a year-round population of 170,600, and a summer population 8 of just over 500,000.- Average daily vehicle traffic across the 9 Sagamore and Bourne Bridges is 64,442.
10 In the event of an incident requiring the evacuation 11 surrounding the Pilgrim Station, the Town of Bourne is not
-12 '
aware of any traffic management plans for this area.
~13 Currently, on holiday, weekends, the. traffic.back-up .
14 - and this is not only holiday' weekends) it's almost every 15 weekend during the summertime -- there's a back-up of five to 16 ten miles from the Bridges.
17 The Town of Bourne requests emergency planning zone 18 designation. There are several pages here in the handout i
19 designating those particular correspondents. I just want to 20 highlight them. ;
21 CHAIRMAN ZECH: Thank you.
22 MR. BARI4W: On March 6, 1987, Massachusetts Civil ,
23 Defense Agency offers the Town of Bourne to be designated EPZ 24 community. 'May 14, 1987, Bourne requests informational meeting 1
25 with Mass. Civil Defense officials regarding the EPZ ]
6
- - _ - _ - _ _ _ _ _ _ - _ _ _ _ - _ _ - - _ - _ _ _ _ _ = _ _ _ - - _ -___ ._ _ - - - - - -__ _ - _ _ - _ - - - - - - . - _ -
90 1 designation. May 28, 1987, Mass. Civil' Defense acknowledges receipt of the Town of Bourne's request for EPZ designation.
~
2 3 June 22, 1987, Bourne received notification that the 4 Governor's office had approved Bourne's request tolseek i
'5 inclusion in the EPZ. August 24, 1987, the Board of Selectmen 6 formally request for inclusion in the Pilgrim EPZ. December 9, 7 1988,.the Bourne Board of Selectmen request that the Nuclear 8 Regulatory Commission include Bourne in the Pilgrim EPZ.
- 9 Present public safety concerns. Presently, Bourne is 10 not notified of incidents at the Pilgrim Station. There was an 11 incident approximately two weeks ago. No.one was notified in 12 the Town of Bourne. I called after.the incident was given to 13' - dhe general press, and'I was-told that they would not be 14 notified in the future.
15
- Bourne does not have an opportunity to develop 16 emergency plans due to a lack of knowledge of any existing 17 plans. Possibility of panic among citizens and confusion among 18 local officials.due to a lack of planning.
19 Th's Town of Bourne's request. The request by the' 20 Town of Bourne to be included in. the Pilgrim Station Emergency 21 Planning Zone is made not to condemn or endorse the Pilgrim
~
22 Power Plant, but rather that Bourne and its residents be _
23 adequately prepared for an emergency at Pilgrim's Station.
24 Any questions would be handled by Mr. Noyes. He's 25 the Civil Defense Director.
l L 11 CHAIRMAN.ZECH: Thank you very much. We-appreciate 2 your being with us today. Commissioner Roberts?
)
3 COMMISSIONER ROBERTS: No. i 4 CHAIRMAN ZECH: Commissioner Carr?
5 COMMISSIONER CARR: On the bridge back-up, I a.ssume u 6 that's on Fridays and off on Sundays that that four to five .
]
7 mile back-up is? I 8 MR. NOYES: That's when the general problem with the 9 back-up.is, yes.
10 COMMISSIONER CARR: To and from the beach on 11 weekends?
12 , MR. NOYES: Uh-huh. .
13 COMMISSIONER CARR: Is there a back-up everyday?
14 MR. NOYES: Not everyday. There's a traffic slow 15 down during the morning commute to Boston and then the evening 16 return from Boston.
17' COMMISSIONER CARR: In reading your report -- your 18 requent of 27 August to be designated an Emergency Planning 19 Zone' community, I couldn't help but focus on the paragraph 20 discussing resources, financial and equipment, which would be 21 provided to your community by virtue of this. Do you not now 1
22 have an alert notification system and a method of public .
23 . warning in the event of a natural cr non-nuclear disaster?
24 MR. NOYES: The only warning system in the Town of 25 Bourne is the fire whistles for the fire department.
92 1- COMMISSIONER CARR: Do you have any emergency plans?
2 MR. NOYES: We have a comprehan'sive emergency l 3 management plan ' for the town, yes.-
L 4 COMMISSIONER CARR: Do you train for emergencies?
I 5 MR. NOYES: There have been service' training, both in 6 the police and the' fire departments, yes.. i 7 COMMISSIONER CARR: And it appears to me, when the 8 state said in their 6 March of '87 letter that Boston Electric 9 Company is expected to support the cost of any alert 10 notification and communications equipment which the town must 11 acquire to fulfill its obligations to implement the emergency _
-12 plan, your interest heightened considerably. Is that s fair 13 statement? ,
14 MR. NOYES: Well, we -- well, we did, after that, the 15 information was.first supplied to us by the state, we asked 16 what Bourne's requirement and commitment would be, what cost'
- 17- would be incurred by the Town of Bourne, and what costs would 1 18 be recovered by the town from whatever agencies might be --
19 _ COMMISSIONER CARR: But it's a good deal to be I 20 classified -- from a civil defense standpoint, it's a good deal 21 to be classified in EPZ. You get a lot of good gear.
22 MR. NOYES: Well, the main concern is, why should not -
23 those 200 -- a' approximately 200-plus people who live within the 24 -
ten-mile zone, just because they live in Bourne, not have the 25 same protection those ten-mile people in Plymouth be offered?
93 l 1 And that was our main concern.
2 COMMISSIONER CARR: Your request seemed to hinge at 3 first on early notification, from what I've heard from 4 Plymouth. Being in the EPZ doesn't necessarily mean you're 5 going to get early notification.
6 MR. NOYES: Apparently not.
7 COMMISSIONER CARR: But, if -- have you asked Boston 0
8 Electric to add you to just their notification list without ;
9 putting you in the EPZ?
10 MR. NOYES: I specifically asked them that, and they 11 told me no.
12 . COMMISSIONER CARR: That's all.I have.
. 13 CHAIRMAN ZECH: Commissioner Rogers?
- 14. ,
COMMISSIONER ROGERS: Just what's your Civil Defense 15 budget and your town budget?
16
- MR. NOYES: It's a little over $6,000.
17 COMMISSIONER ROGERS: Civil Defense?
18 MR. NOYES: Correct.
19 COMMISSIONER ROGERS: And your town budget?
20 MR. NOYES: Eighteen million.
21 COMMISSIONER ROGERS: Eighteen million?
22 MR. NOYES: Uh-huh. -
l 23 COMMISSIONER ROGERS: Thank you.
24 CHAIRMAN ZECH: Commissioner Curtiss?
25 COMMISSIONER CURTISS: No.
l
i i
94 , i 1 CHAIRMAN ZECH': Any other questions, fellow-2' commissioners? ,
3 (No response.]
4 CHAIRMAN ZECH: All right. Thank you very much for j 5 being with us today. We appreciate your coming.
6 MR. NOYES: Thank you.
7 CHAIRMAN ZECH: We will ask Ms. Ann Waitkus-Arnold, 8 who is the Chairwoman of the Disabled Persons Advisory Group on 9 Nuclear Evacuation, Massachusetts Office of Handicapped 10 Affairs. Ms. Waitkus-Arnold, am I pronouncing that correct?
11 MS. WAITKUS-ARNOLD: Yes, you are.
12 CHAIRMAN ZECH: Thank you very much for being with us-13 today, and you may proceed. ,
.14 MS. WAITKUS-ARNOLD: Thank you. Good afternoon and 15 thank you for inviting me to speak here'today.
16 As Chairwoman for the Disabled Persons Advisory Group 17 on Nuclear Evacuation, I have been intimately involved in 18 emergency planning procedures for all nuclear plants affecting 19 the one million disabled people in Massachusetts, including 20 Pilgrim 1, Yankee Rowe of Vermont, Yankee and Seabrook Station.
21 The Massachusetts Office of Handicapped Affairs 22 initiated the first meeting with officials from Boston Edison .
23 several years ago about emergency planning for people who 24 cannot evacuate on their own, and we have pursued this issue in 25 the intervening time by forming a Working Group on Disability 4
95 1 Issues and Emergency Planning in the event of an accident at 2 the Pilgrim Power' Station. We have' suggested a proposal be 3 commissioned for a Comprehensive Project to' determine emergency.
4' planning needs for people who~ require assistance.
5 The current status of planning for elderly and 6 disabled; people and others with special needs is grossly ,
7 inadequate. The Evacuation Time Estimates, developed'by Boston 8- Edison, are completely inadequate. Boston Edison has used 9 these figures as if they were correct over the strong 10 opposition from the office of Handicapped Affairs. , i 11 We feel BECO is acting in bad faith. The research 12 ,
methods for this document were seriously flawed, thus the 13 figures from Boston Edison arrived at are invalid. For 14 example, BECO alleges that.approximately one percent of the 15 population is disabled,'when the latest Harris Polls for the 16 United States Disabilities Census'shows actual figures of 17 17 percent, many of whor. would need assistanca in an emergency.
18 We also know that the fastest growing population in 19 this country are people over 65, the majority of whom have 20 disabilities. They are not included in this poll. Thus, 21 Boston Edison's reassurances cannot be relied upon.
22 The addition of thousands of people in th'e Pilgrim _
23 EPZ needing special arrangements and care could throw the 24 entire evacuation plans into disarray. Therefore, Edison's i 25 erroneous figures for the special needs population actually
m ,
!96 l' would invalidate all of the ETE results which are used as a 2
basis for any planning that is being proposed.
i 3 Attempts'to have this population self-identify also 4 have not worked. Full page ads in several, local newspapers 5 have only elicited ten responses. This extremely low response 6 is no< surprise to this Agency; historically,.the self- -
7 identification process for this target population has not 8 worked.
9 The legal definition of a disabled person is any 10 person who has an impairment that limits one or more major 11 activities of daily liv,ing. This includes people who have 12 problems with walking, talking, seeing, hearing, breathing, or 13 , thinking. This definition' encompasses people with 14 developmental disabilities, medically fragile persons, elderly 15 persons, people with mental illness, persons with sensory or
- 16. physical limitations, temporarily disabled persons, and'the 17 transitory population -- disabled people who leave their place 18 of residence for school, sheltered employment or adult care, 1
19 and travel in and out of the EPZ for these services. i 1
20 We presume that other special needs populations,
?
21 including the. schools, nursing homes, hospitals, and group' 22 homes will be planned for separately. -
23 The Comprehensive Survey goals deserve particular ,
". 24 attention. The task of this project goes far beyond the 25 development of rough estimates of numbers of people with L
97 11 disabling conditions in'the area who might-need accessible
~
2 transportation only. The challenge is much.more complex than 3 this.
. 4' . We must develop an area profile showing the.known and 5 probable' distribution of disabled people at several specific 6 times reflecting working and'non-working hours-and' weekends. -
7 We must determine how the evacuation of the general population 8 will effect people who need special assistance.
9 We must develop current standards for people who may 10 be at too great a risk to evacuate, including evaluating the 11 attendant risks of remaining behind. These people could
. 12 include 1) hospitalized inf' ants, children and adulty,, nursing home 13 patients, and people onelife support systems at home. T$ey 14 could be anyone of us unfortunate enough to be hospitalized for' 15 a serious condition during a radiological emergency.
16 Who will stay behind with these people?- There must .
17 be agreements made with people who are willing to remain behind 18 and provide care for those who can't be moved. These-workers l 19 would have to be provided with specialized training for dealing 20 with a radiological accident, and the risk of having to take 21 potassium iodide along with their patients.
- 22. The most critical facet of this plan is the -
23 , requirement for functional skills assessment for the ;
i 24 communities involved in terms of supervision and assistance.
25 In order for proper planning to happen, this assessment must be
- - - - - _ _. . _ _ _ _ _ _ _ __ _--_.--._-._------_-.__w_-.__--_-- - -._-____-__._-_ - _- - _ _
q 98
'1 conducted in relation to residence and location in the~ ,
'2 community, and must provide for. transitory. populations, 3 What levels of assistance'will people need.to safely l.
4 evacuate?
5 , ,
Also, the plan must address people.with low incidence 6 disabilities. These people, such a person who may be a 7 quadriplegic, would require continuous, very, specialized .
8 planning _and care to survive, even in a sheltered situation.
, 9 Their living situation and formal support requirements must be '!
i 10 assessed,:as well as their general environment, including daily 11 ' activities in correlation with the general evacuation process.
.12 '
Throughout the process of this prop,osal's
'13- development, Boston Edison agreed to pay for this project. ,
14 However, several months after its completion, they reneged on
- 15. .their agreement. -They have failed to act in good faith, once 16' again, and we are left facing a potentially dangerous situation 17 with no factual data. Valid' planning is not possible in such 18' an informational vacuum.
19 There must be an honest evaluation of the feasibility 20 of actually evacuating and caring for all of the men, women and 21 children in the EPZ who co: uprise the spec'ial needs population.
22 As you know the population in Plymouth has almost tripled sines -
23 Pilgriu Station went on line 16 years ago, and the two lane
(
24 evacuation routes are often bumper to bumper, even in normal 25 situations. Evacuation routes are overburdened during normal
. 99.
l 1- use, but especially in the summer months.
~
l 1
i 2 As presently planned, evacuation activities of the 3 general population will make it impossible to. evacuate the I
4 sizable numbers of people with special needs. Slipshod 5 preparations proposed by Boston Edison with the NRC's apparent 6 agreement are highlighted by the recent statement by NRC 7 officials that ".present planning is sufficient for re-start."
8 Sufficient for whom? Since there is no planning.for i
9 the special needs population, and this clearly discriminates 10 against that population, and is, thus, a violation of the 11 , Massachusetts Constitution Amendment 114. This law guarantees. I 1
, , 12 equal protection for people with disabi'lities in Massachusetts.
13 There are also questions as to'whether this discriminatory ;
1 14 behavior violates federal laws. .
15 What is required is the guarantee that citizens of i
16 Massachusetts with special needs have an equal opportunity to j 17 leave an crea around a nuclear plant during a radiological 18 accident.
19 It is illogical and duplicitous to go on low power, 20 the only object of which is to go to full power, without any 21 viable plan for evacuating the population. It is our position 22 that Pilgrim Station should remain closed until and unless safe -
23 evacuation plans can be made for all people, not just some j
! 24 people.
25 CHAIRMAF ZECH: Thank you very much. Commissioner
100 1 Roberts?
2 COMMISSIONER ROBERTS: No.
3 CHAIRMAN ZECH: Commissioner Carr?
l
-4 COMMISSIONER CARR: Yes. You know this is not a new q l
5 problem brought on by nuclear power plants.' How does the state J l
6 and.you cope with this problem in other areas? -
l 7 MS. WAITKUS-ARNOLD:. I haven't worked with ,the state 8 on other areas-besides planning for nuclear emergencies. This ,
, i 9 is what I work on; I don't work on other types of emergencies ]
10 for the state. 1
)
11 COMMISSIONER CARR: Well, --
12 ,' MS. WAITKUS-ARNOLD: We became inIvolved when, five years ago,.I found that people'with special'needs 'really 13 14 weren't included in planning. ,
15 COMMISSIONER CARR: But you mean by that, you don't 16 look at other types of emergencies where they have evacuated 1
17 people'in handicapped positions and see how that works, and see 18 if that's something you can apply?
- 19. MS. MAITKUS-ARNOLD: Right -- no. Right now, I'm 20 looking at evacuations for a nuclear disaster, which, of 21 course, would be much different than' planning for other types .
1 22 of emergency. .
23 COMMISSIONER CARR: Well, let's take the Springfield i 24 fire. Seventy-thousand people, over a number of days, in and 25 out. Obviously, they had to move handicapped people. Did you
d
- 101
- 1. look at that?
- - . l 2 MS. WAITKUS-ARNOLD
- I haven't looked at'that 1
3' personally. )
1
'4 COMMISSIONER CARR: I recommend you do that.
5 MS. WAITKUS-ARNOLD: Well, I also recommend that
~
6 people with special'needs be included in planning for nuclear. l 7 emergencies.
8 COMMISSIONER CARR: I acknowledge that. !
l 9 MS. WAITKUS-ARNOLD: Do you?
10 COMMISSIONER CARR: But do you know how they -- you 11 say that one of the problems is they won't self-id'entify. How 12 are you going to solve that? -
n ,
13 MS. WAITKUS-ARNOLD: .That's historically. .
14 . COMMISSIONER CARR: How are you going to solve that?
15 MS. WAITKUS-ARNOLD: By the survey, I was just 16 talking to you about for the past five minutes, ten minutes. I 17 have a copy of that I'd like to submit to you.
18 COMMISSIONER CARR: Do you know how they did that in 19 the Springfield fire? They did it by calling 911.
20 MS. WAITKUS-ARNOLD: We're talking about 94,000 21 people here, with one million tourists.
22 COMMISSIONER CARR: Oh, I'm n'ot talking about 94,000 23 --
4 24 MS. WAITKUS-ARNOLD: You're talking about the 25 Springfield fire.
102- .I 1 COMMISSIONER CARR: -- that need-this special
. . 1 2- assistance,.I think.
3 MS. WAITKUS-ARNOLD: I'm talking about. Pilgrim 4 Station, Mr. Carr.
S COMMISSIONER CARR: Thank you. I'll save the rest of 6J them for the state, since it's not your problem. .
7 MS. WAITKUS-ARNOLD: It's.not my -- it's the state's.
8 CHAIRMAN ZECH: Commissioner Rogers? ,
9 COMMISSIONER ROGERS: I have'no questions.
10 CHAIRMAN ZECH: Commissioner Curtiss?
11 COMMISSIONER CURTISS: No.
~*
12 , CHAIRMAN ZECH: No, I don't have any questions, but I
. 13 agree that it probab,1y would be valuable'to'look at how 14 handicapped. people are evacuated in other emergencies.
-15 But I just want to thank you very much, Ms. Waitkus-16 Arnold, for your appearance here today, but also for what 17 you're doing for handicapped people. I hope that you're making i
18 -- you're certainly showing an important leadership role in the 19 area you're specializing in, in nuclear, but I want to thank ,
20 you for what you're doing for all handicapped people, because I 21 think'you're doing that also.
22 Any other questions, my fellow commissioners? -
23 COMMISSIONER CARR: He didn't ask you if you had a f 24 question.
25 MS. WAITKUS-ARNOLD: No, I don't have any questions.
. 103 1 CHAIRMAN ZECH: All right. Thank you very much for 2 being with us today.
3 MS. WAITKUS-ARNOLD: I would also hope that you 4 gentlemen would have the same concern for people with special 5 needs that I do, and to ensure that they're included in 6 planning before you give a license to start a nuclear power -
7 plant.
8 . CHA'IRMAN ZECH: Thank you very m'uch. We appreciate 9 your being with us today very much.
10 We are calling Mr. Peter Agnes, Assistant Secretary 11 of the office of Public Safety, Commonwealth of Massachusetts.
12 Mr. Agnes? Mr. Agnes, welcome. You may proceed. .
13 MR. AGNES: Thank you, Mr. Chairman. Good afternoon, 14 -
Commissioner'rs. .
15 on my right is Mr. Jeffrey Hausner of the N,uclear 16 Safety Emergency Preparedness Unit within the Civil Defense 17 Agency of the Commonwealth of Massachusetts, and to my left is 18 Mr. David Quaid, who is a resident of the Saquish/Gurnet area l
19 of Plymouth.. And during my presentation, which I will 20 abbreviate as far as I can to give you an opportunity to ask 21 some questions, Mr. Quaid will speak for a few moments about 22 some slides which he's prepared to show you some of the! -
23 specific concerns we have about that particular part of the 24 EPZ.
I 25 The Massachusetts Secretary of Public Safety is 9
.i 104 f 1 pleased that the opportunity to address the Commission on the 2 status of off-site preparedness for an accident at the Pilgrim 3 Nuclear Power Station. As others have said to you today, the 4 meeting, we think,.is long overdue.
5 Those here today should bear in mind that it was the
~
6 Commonwealth of Massachusetts, and not the Nuclear Regulatory 7 Commission, and not the Federal Emergency Management Agency, 8 which first drew attention to the issues we are here today to 9 discuss.
10 It was a result of Governor Dukakis' initiative that 11 -
we produced the first. comprehensive report analyzing emergency
. 12 preparedness for an accident at.Pilgrimfs Station.in December ,
l'3
- of.1986. That'200?page report was the first to document that 14 emergency planning in the Pilgrim area was woefully inadequate.
15 It is interesting to us that nearly two years after 16 that report was issued, we have yet to receive any formal 17 response to its conclusions from the NRC.
18 In the summer of 1987, the Commonwealth sponsored the 19 first of many open public meetings at which citizens and local 20 government officials were invited to discuss emergency 21 preparedness and their safety. The Commonwealth has held 21
, 22 public forums in the intervening months. Also, the staff of l
23 our Nuclear Safety Emergency Preparedness Program has held 77
' 24 weekly working meetings with EPZ Public Safety Officials, and 25 attended more than 180 meetings of local boards and committees a
105 ,
i
- 1. regarding emergency preparedness.
2 While the'~ staff may tell you that they have held
- 3. meeting after meeting with EPZ residence, let the record show 14 that up until today, the Commission has not once hosted a l'
5 single public meeting to hear from local and state officials on 6 off-site emergency preparedness for the Pilgrim EPZ. Given the 7 serious nature of the subject, we think this is a deplorable 8 record for a federal regulatory body whose specific charge is 9 protection of public health and safety.
10 on two occasions, the NRC has addressed off-site 11 preparedness. In a meeting here on october 6, local officials 12 . had hoped,to inform you of their concerns but were denied the ,
13 opportunities:to' speak. And o'n. October 14, the're was another 14 . meeting held here in which the staff of this Commission 15 discussed preparedness with you, in,which the licensee 16 discussed emergency preparedness, but where we were' forcibly 17 denied the opportunity to rebut blatant misrepresentations by 18 your staff. !
19 In fact, on October 14th, your own staff stated that 20 they had met with public officials of EPZ communities to 21 discuss the status of planning. This statement is clearly no 22 true. -
23 A series of meetings was held by your staff with EPZ f 24 and host communities between October 25 and November 2nd of 25 this year, and these have been documented.in a series of
[ . 106
'*'1 ,
undated memoranda from Mr. Lazarus to Mr. Russell. j 2 Shortly thereafter, I met with representatives of 3 several EPZ communities, and it was the unanimous sense of the 4 EPE towns that the Lazarus memoranda did not accurately reflect 4
5 the number and, severity of unresolved planning items. Some of I
6 that concern was expressed to you earlier today.
7 '
Let me say that the Commonwealth of Massachusetts is 8 not opposed categorically to the operation of Pilgrim Nuclear ]
9 Power Station. However, we will not support the re-start of 10 the Station until we are satisfied that a plan exists which 11 satisfies every requirement of NUREG-0654, and other regulatory 12 criteria. Nor can we' support re-start until we are,certain ,
~
~
L. 13 that public safety can be protected in the event of a nuclear 14 accident, as demonstrated in a full-scale graded exercise of 15 those plans. Further, we do not believe that~ Pilgrim should be 16 authorized to re-start until the licensee demonstrates its 17 ability to operate the facility in a responsible and safe 18 manner.
19 At this moment, we lack confidence in all of these 20 regards.
21 I deeply regret that the Federal Emergency Management 22 Agency, the one federal agency exclusively charged tb deal with 23 emergency preparedness, has not participated in any of our
[ 24 planning activities. In a meeting I held with FEMA Regional 25 Director Henry Vickers in October of 1987, he promised that a
~
o' 107 1 member of his staff would be delegated to work with the 2 Commonwealth and local governments in emergency planning. No 3 such action was ever taken.
4 As recently as November 18th of this year, I wrote to 5 FEMA National Director Julius Beckton -- a copy of the 6 correspondence is attached to my testimony -- asking whether 7 Pilgrim was the only nuclear power station in the country for 8 which FE104 has withdrawn interim approval of emergency plans, 9 and for which every state and local authority has expressed its 10 lack of confidence in emergency preparedness.
11 To date, we have received no response to this simple
,12 inquiry. '
FEMA has.been invited to join every meet'ing held at
~
13 -
14 which emergency planning was discussed, including our weekly 15 working group meetings. But they have chosen not to accept our 16 invitations. In fact, FEMA failed to send a representative to 17 the meeting that took place between myself and Mr. Lazarus on 18 October 22nd of this year, at which we gave the NRC a 19 comprehensive review of the status of off-site planning.
20 On October 13th of this year, the day before your 21 Commission meeting, we received a letter from Mr. Vickers in 22 .which he said, "Before we fully respond to your September 2nd 23 and September 29 of 1988 letters, we would like an opportunity
[ 24 to carefully study and review the report to the Governor."
25 I ask today, on December 9th, how long does it take
108 1 FEMA, your sister agency with which the NRC has a letter of 2 agreement concerning assessment of off-site emergency 3 preparedness, to respond to important requests for information
,4 and analysis?
5 I'd like to touch briefly on ten specific areas with 6 which we are concerned regarding off-site emergency -
7 preparedness. Let me say, however, as an aside, in response to 8 an earlier queistion about the hope that you would hear about 9 the great progress that has been made to date in amargenc'y 3
10 planning, that I don't believe it's my responsibility to come 11 here to Rockville from Massachusetts to tell you about that 12- progress. *
'13 ' We documented, in our report of October, 1988, as we *'
14 .had i'n earlier reports, very comprehensively, the progress and 15 deficiencies in off-site planning. ,
16 As we find ourceives on the eve of what may be a 17 decision to re-start the Pilgrim Nuclear Power Plant, I think 18 it's incumbent upon us to use these precious few minutes to 19 talk about the problems that still remain with off-site 20 planning. And there are essentially ten areas where we would j 21 like to briefly touch upon.
22 ,,
In the area of training, you may wish to note that -
23 although there has been considerable training of emergency
' 24 personnel and workers, that training is approximately two-25 thirds left uncomplete, or incomplete, rather. And this is
109 1 across the EPZ and the reception center communities. F 2 You have also heard each of the towns talk about the 3
implementing procedures that are s6 critical to the emergency 4 plan. As part of this testimony, I have presented to you today 5 .a status report on the development of implementing procedures 6 by each community. ,
7 Let me make clear that we have not yet received a set 8 of implementing procedures which have been approved by local 9 officia'Is from any of the five EPZ towns or the two host 10 communities. Five of the towns have forwarded draft procedures 11 ,
to us, and we have sent these and other planning documents to
'12 FE'A'for M informal technica1 review more than two months ago.
E.. ,
?.3 ,
Out of the more than 300 procedures under-14 consideration by the seven communities, only about 190 have 15 .been approved in concept by local officials. Two communities 16 do not feel sufficiently comfortable yet with the procedures 17 they have developed to even have submitted them to us and FEMA IS in draft form.
19 Let me also say, briefly, with respect to the matter 20 of expenditures and budgets, although the communities that you 21 have heard from have had relatively modest civil defense
~
22 budgets, the record should indicate that vast sums of money 23 - have been spent by both the licensee and the Commonwealth over 24 the past two-and-a-half years in an effort to address these 25 concerns. While I don't wish to speak for the licensee, I do i
110 1 wish to say that it mu'st be in excess of a million dollars that 2 the licensee has spent in this regard, and we applaud that 3 effort that they have made.
4 The state, thanks to an initiative by the Governor, 5 has an appropriation this fiscal year of almost $500,000
~
6 exclusively for off-site emergency planning, which supports a 7 staff and provides us with the means for engaging consultants 8 and working with local governments.
9 So that, although the local communities have 10 relatively modest budgets, they have committed enormous 11 ,
resources in terms of time; the licensee has spent a great deal
~
12 of money, and the state has spent a considerable amount of
~ ~
13 money and is' continuing to do so. -
14 Now, in addition to concerns about implementing 15 procedures, we are also concerned, as. Ms. Waitkus just 16 reported, about the needs of those people in the EPZ with 17 various kinds of disabilities. And while progress has been 18 made, despite the best efforts of state and licensee officials, 19 we have yet to undertake the comprehensive survey of people 20 within the Emergency Planning Zone with special needs who 21 require exceptional assistance during an emergency.
22 This survey is intended to identify who those people 23 are in an effort to supplement the outreach that each of the
{ 24 communities in the state has done.
25 I should also add, briefly, that the planning process
i 1114 1 1 'that some.of you asked. questions about is very much a product
\ *_ .
2 of state and local governments, and one that the licensee has 3' bought into and endorsed for the past two-and-a-half years.
4 -
The process was intended to produce the very best.
5 possible plan,. starting at the local level, so that the 6 painstaking procedures that were described to'you for local ,
7 department head working with state and licensee officials to 8 first approve-in concept, to submit to the Selectmen, to submit 9 to the state, and to submit to the federal regulatory agency 10 such as FEMA, was well thought out with the licensee, and 11 seine. thing that the licansee concurred in and has been 12' supportive.of for the past two years...S'o that while l't has' ,
'I- li3 taken a. great deal of ti5:e, it is one that all parties 14' ' concerned believed would produce the best possible plan.
15 In addition to those two concerns, implementing 16 procedures and special needs, off-site communications is 17 critical.
I 18 State and local officials have worked diligently with 19 the licenses to install a new off-site notification system.
20 Nonetheless, as of this moment, training has not been completed 21 for all personnel who must operate the system, and the system
~
22 has not been subjected to a full test.
23 Note that in November of 1987, the last time that an
( 24 unusual event was declared at Pilgrim Station, not all 25 officials were notified within 15 minutes. Therefore, I have O
112 l' no basis to say today that we are capable even'of noting'all';
~
2 off-site authorities of an acci' dent, as required by federal 3 regulations.
P 4 We',re also very much concerned, as you've heard 5 today, about traffic management throughout the EPZ and to the 6 reception centers. The last section of the evacuation time 7 .esti' mate and traffic management analysis, commissioned by 8 Boston Edison, was not received until late in October of'this 9 year.
10 The ETE and traffic management plan are enormously 11 complex, and in the space of two months', we have not yet'been 12 , able to assess,the pdequacy of these very important documents.
I'should also add, as'an aside', that we have engage'd 13 14 an outside consultant to help us in this effort and will 15 continue to work with that consultant and local officials and 16 the licensee on traffic management for all of the EPZ towns, 17 and the many community through which traffic must pass on its 18 way to reception facilities.
19 In speaking with local officials from each community 20 prior to developing our October 1988 report, we also learned 21 that communities generally feel that they do not have adequate 22 personnel identified to fulfill all emergency functions o,
23 detailed in their draft plans.
/ -
-; 24 We will not certify that plans are adequate until it 25 has been demonstrated that all local as well as state response
. 113.
1 agencies can fill their emergency personnel rosters., This 2 issue is one that perhaps will not be resolved until we have 3 had that graded full-scale exercise.
4 We remain concerned that we do not have reception 5 centers that are capable of providing all required services to 6 evacuees, including radiological monitoring and 7 decontamination. The state and the licensee are actively-8 engaged in a process under which the necessary capital 9 improvements will be made to the designated state institutions 10 which will serve as reception centers.
11 Nonetheless, these improvements have not been 1.2 completed, and we cannot state today'that we can provide even 2
13 radiological nonitoring to evacuees in a timely m,anner.. .
14 Perhaps our most vulnerable population are our 15 children of school age. While significant progress has been 16 made in drafting better plans for their care, we have a 17 distance to go in providing training to the teachers and other 18 school personnel responsible for protecting children in the 19 avant of a nuclear accident. Moreover, not all EPZ towns have 20 enunciated a clear policy on early closine of schools, and, 21 whether children will be kept together or dismissed.
22 Again as an aside, the school teachers, principals, 23 and administrators are probably the last group of local.
24 officials who have been -- who we, and the licensee, and other 25 local government officials have worked with on the development i
. (
_ _ _ _ - _ - - _ - _ _ _ _ _ _=
)
114 1 of implementing procedures, simply because attention ~was first s
2 . given to primary responders such as police, fire, and public 3 works. So the school populations, both administrative and 4 teaching, are groups that'are large, diverse, and groups with 5 which a great deal more work needs to be done. <
6 FEMA has re-assessed its policy on shelter as a 7 protective action, and now claims that it is unnecessary as an 8 element of emergency response planning. We believe this is an 9 unwise decision given the range of accident scenarios 10 postulated for nuclear facilities.
11 We are requiring.that each EPZ town have a shelter 12' utilization plan to provide the maximum protection to resident .
13 and transien't populations, including people at beaches and 14 other Sacreation areas. Although there have been good faith 15 efforts, again, by the licensee and local governments, we have 16 not yet received draft shelter utilization plans from two of 17 the EPZ communities, and thus cannot assess the adequacy of the 18 energency response system until these are received.
19 At this point, I would invite Mr. David Quaid to 20 present some photographs of }he EPZ area in which he owns a 21 home, the Saquish/Gurnet section of the town of Plymouth. This 22 is a remote area just three miles from Pilgrim's Station, which, '
23 lies at the end of a three-mile peninsula, served by a road i 24 which is difficult to traverse under the best conditions when 25 it is passable, only in four-wheel-drive vehicles, and
115 1 virtually impassible in' bad weather and'during. peak tides. A 2 number of people such as Mr. Quaid own winterized homes'there, 3' and reside in Saquish fulltime or part-time.
4 Since a picture is often worth a thousand words, let 5 me ask,-with your permission, Mr. Quaid to briefly comment on 6 some of the slides. Mr. Quaid? -
7 CHAIRMAN ZECH: Certainly, Mr. Quaid. Welcome, and 8 you may proceed. -
9 MR. QUAID: Thank you very kindly.
10 CHAIRMAN ZECH: certainly.
11 MR. QUAID: First slide, please. This'is a U.S.
12 nautical map of the area. As you can see, it's.a barrier beach 13 shaped'like a fish hook. At the top .
at,the'very top,. yod'can 14 see the long, wooden bridge. That's the straight l'ine at the 15 very top. That's north. At the right-hand bottom is Gurnet 16 Point, which is just a shade over three miles from Pilgrim 1.
17 That distance is four-and-a-half miles from the bridge to the 18 Gurnet Point light. And then to your left, and sloping down 19 toward the center, is Saquish Beach and Saquish Head.
20 Next slide, please. This, the little triangle there, 21 shows the angle of view of a series of aerial photographs that 22 were accomplished on July 3rd of 1988 in order to demonstrate -
)
23 some of the problems with evacuation in this area.
( 24 The -- oh, I will preceed up the beach to the --
25 what's called the Public Beach,'and show you the various 4
. I
. 116 I situations-of concern to the people of Gurnet/Saquish,.andsof -
J 'i .
2 Duxbury.
3 fNext si'ide, please. And this is the angle. "That is 4 Gurnet Point there. There's about 40 residents there, seven or 5 eight all-year-round residents, and,;of course, all those area .
- 6. homes are occupied full-time in the summer. .
7 As you can see at the upper part of the picture.that' 8 white building at the top with the arrow' pointing to it is 9 Pilgrim 1, and that is just over three miles down wind. And 10 this is very important. From the end of April through October,-
11 this' area is down wind of Pilgrim 1, the times of greatest 12 beach population. .
.T .
13 ' ' Next siide, please. Now we progress further north up 14 the beach.
15 Could I have the next slide. This shows -- this is 16 typical of the road. It's a little hard to see, but there are-17 cables along either side. Anyone evacuating from this area 18 must stick to the road. You cannot, it's impossible to drive a 19 car through these heavy steel cables.- And that situation 20 continues for four-and-a-half miles down to the bridge.
21 Next slide. This is the area called High Pines, 22 which is halfway down the beach. Next slide. And as you can
~
23 see, the four-wheel-drive vehicles, on a very, very celd day.
t QJ 24 Later you'll see that, in the parking lots, that they're less 25 than 50 percent utilized, and normally, there'd be twice the
9 117.
e
~
1- number of vehicles at this point.
2 'Next slide. This is just a little further north, i 3 and, as you can see,Jit says, "One of two exits fro'm beach in 4 four miles." Those are the only two crossovers,.as they're
. 5 called locally, in four miles,.and in time of evacuation, it -
6 would be very, very difficult to get the hundreds'of four- -
7 wheel-drive vehicles out of those -- especially at high tide, 8 out of those crossovers, which are very soft sand. I've been 9 stuck there many times, and I've lived there a long time. '
10 Next slide. Now we're a little further down the 11 beach, toward the Public Beach. Next slide. And as you'can 12 see, it's just endless four-wheel-drive. vehicles. And as.I
~
I 13 'said, on'a warm day, you would actually have to drive between 14 two lines of four-wheel-drive vehicles to navigate ,that area of 15 the beach.
16 Next slide. This is the area of the -- what's called 17 the Town Beach. And, as you can see, the long bridges in the 18 middle of the scene.
19 Next slide. This is the Town Beach, and you can see 20 that the parking lots are just -- less than 50 percent 21 utilized, but you do get an idea of the number of people that 22 utilize this area. o -
23 Next slide. This now shows, contiguous to what's
./ 24 called the Town Beach, is what's called the Public Beach. And 25 there are somewhere between 2,00 and 2,500 parking spaces in
_ - ~ . _ - - - - . . . . - - _ _
118 1 this area.
2 Next slide. And this the Public Beach with the -- it 3- shows the number of people utilizing it, plus the bath house 4 and the parking spaces. But when -- on times of heavy use, 5 which is every weekend, the marked parking spaces are quickly 6 used up, and then they park just about anywhere they can.
7 These are estimates of beach population. Well, let's 8 say -- let's just use 2500 as a figure. With 2500 parking 9 spaces, nobody comes to a place like this by themselves. "Let's 10 conservatively say that's 5000 people at that point.
11 The Gurnet/Saquish area, conservatively speaking, is 12 somewho're between 3500 and 400,0 people'using it, and the four 13 ' and a half miles from the ridg4 to the Gurnet, you have ,
14 probably another 3000 people using it, so that would be -- five 15 and three is eight -- that's 12,000.
16 And then Al Siemano, who is the oversight Safety 17 Supervisor for Boston Edison stated at an Emergency Response 18 Study Committee meeting that BECO had also made an overflight 19 1987 -- their estimate was 16,000 people. He did not state 20 whether Plymouth beaches were also included in this figure.
21 Next slide, please.
22 (Slide.] -
23 All right, now we're out at Saquish. The angle is
( 24 from just off Saquish Head along Saquish Beach.
25 Next slide.
. 119 1 [ Slide.)- .
2 This is July 3rd, and there were between the estimate 3 by professional security people -- were that there were between 4 400 and 500,four-wheel drive vehicles had gone past that 5 checkpoint, and they estimated that there were 3500 people
, 6 there on that cold day.-
7 Now if you look beyond, you'll see there's many, many 8 houses and cottages in that area. Contrary to testimony of
^
9 October 14th, people do overnight on these beaches. There are 10 some 300 cottages and all-year-round homes with entire families 11 ,in residenes from May until late September.
12 CHAIRMAN ZECH: Excuse me. What day was that,you -
13 were referring to again? .
14 MR. QUAID: July 3, 1988.
15 CHAIRMAN ZECH: July 3, 1988.
16 MR. QUAID: -1988. A very cold day, I must say.
17 CHAIRMAN ZECH: Thank you.
18 COMMISSIONER CARR: That was Fourth of July weekend.
19 MR. QUAID: Yes, it was. It was the Fourth of July 20 wee,kend.
21 CHAIRMAN ZECH: Thank you very much.
~
22 MR. QUAID: Next slide.
23 (Slide.]
I 24 This shows now the angle of greatest concern by 25 people of that area for evacuation.
120
' l. 4 Next slide. '
. j 2 (Slide.]
3 Now this is the angle. Now you see it shows Gurnet l
4 Point to-the right, and then there's an A figure and an angle I 5 pointing to a road arara. Then there's a B figure- and a C.
l 6 The A area is totally inundated during high course 7 tides.
i
- 8. Next slide.
9 (Slide.]
10 This now shows the angle that we shot, the high 11 , course tide of September 26th, which was only an 11-4 tide.
j 12 _.
Real high course tides are 11-9 to 12 foot, and it was a dead e . .
13 calm day. On a storm force day or a wind. force day, the depth 14 is considerably more.
15 Next slide.
i 16 (Slide.]
17 As.you can see, it's a flat calm day. This is the 18 road that's inundated. You can see the reflection of the 4-19 foot ruler I put in to give an idea of the -- and the birds --
20 give an idea of the depth. It came to just an inch short of 21 two feet on an 11-4 tide on a flat calm day. And that's very
~
22 unusual.
23 COMMISSIONER CARR: Did it last two hours?
f '
1 24 MR. QUAID: No, no. This was at high tide.
25 COMMISSIONER CARR: So --
_ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ . . _ _ _ _ . _ _ . _ _ _ _ _ _ _ _ _ _._ _ _ o
(
121 1 MR. QUAID: Oh, how last -- oh., I can give you that.
2 The Lazarus report says two to three days per month.
3 COMMISSIONER CARR: No, no. I mean --
4 MR. QUAID: Oh, oh --
5 COMMISSIONER CARR: -- it lasts --
6 MR. QUAID: Oh, it lasts a minimum of two'and a half .
7 hours to three hours, yes.
8 , COMMISSIONER CARR: Okay.
9 MR. QUAID: But now that you mention that, the
.10 Lazarus. report said two to three days. It's actually three to 11 four days. I sent to'Mr. Chilk a tide calendar, and it showed 12 .that most high course tides are four' days, and that's a matter ,
'I[ 13 of record.
14 Next slide.
15 (Slide.]
16 Okay. Now this is the B and C area of that previous 17 photograph. To the right is_what we call the back road. The ,
18 back road is a goat trail. It's underwater. It is just a l
19 single lane, a sand trap is what it is, and it's underwater at l
20 high course tides. That's to the right.
21 To the left is the only access and agress for 3500 22 people in the event of difficulty. And as you see, the road ,
23 goes up there. You can't even s'ee someone coming the other
~
-( 24 way. It takes the greatest of courtesy to handle that over a 25 weekend with cars constantly meeting in the middle. Someone A_ ___ _ - _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
. 122 1 has to back~up.
2 Next slide. r 3 [ Slide.]
4 This shows on September 26th, about a half-hour after 5 the -- the 27th -- after the previous high course tide, the 6 shot you ,saw previously. This is the angle along what's called 7 the curved beach toward Saquish Head.
8 Next slide.
9 '[ Slide.]
10 And this is on a flat calm day, and this is the only 11 evacuation route for 3500 people under those conditions. And 12 that's it. '. . i. ,
~
13' If'you hav .any questions, I'd be happy to a'nswer 14 them. .
15 CHAIRMAN ZECH: Thank you very much. We appreciate 16 it.
17 Any questions from my fellow Commissioners?
18 COMMISSIONER CARR: Are we through completely or --
19 CHAIRMAN ZECH: I don't know. No.
20 MR. AGNES: I have a few brief additional --
21 COMMISSIONER CARR: I'll wait.
, 22 MR. AGNES: Thank you. ,
23 CHAIRMAN ZECH: Mr. Agnes, you may proceed.
24 MR. AGNES: Those were ten specific emergency 25 planning issues or concernu that the Commonwealth brings to you I
l 123
!1 today.
2 In addition to that, I.want to comment briefly on an 3 issue that arose during one of the earlier presentations from.
4 the town of Bourne, which is to.make clear what the 5 commonwealth's position is.
6 We have accepted the request an interest shown by the -
7 town of Bourne and have designated Bourne as part of the
-8 emergency planning zone under state law and have sent the 9 necessary' requests to FEMA and to the NRC for appropriate s..
10 recognition of Bourne, as well as Wareham and Plimpton, which 11 are" contiguous towns, and both of which technically have some
~
12 of their town within ten miles -- to the regulatory agencies
'- 13 f.or acknowledgement of those three towns under federal law as 14 ,
being part of the EPZ. There has been no further action taken 15 by FEMA or the NRC, to our knowledge, and we have indicated to 16 the town of Bourne that we will make every effort consistent :
17 with our obligation to first address' concerns of the 18 communit!.es which have traditionally been part of the EPZ to 19 work with them on emergency planning, and we would certainly 20 hope that the commission wculd acknowledge that decision made 21 by the commonwealth of Massachusetts as well. ;
i 22 Now in addition to the smergency planning concerns -
23 that I just outlined, part of the presentation, written l
,i 24 presentation, todsy deals with some concerns we have regarding 25 management and personnel matters, which I won't take tibe to
L -
. 124 i
- 1 discuss in detail, other than to note briefly that we have done 2 an analysis of so-called 50.72(c) event reports received from
> \
3 the licensee over the past year, simply to ascertain'whether l 4 any pattern emerges from an examination of this material, and )
1 5 as the material indicates, there does seem to be a much higher
. 6 percentage of what we have characterized as personnel or human 7 error in connection with those reports for Boston Edison 8 Company and Pilgrim Station than there does appear to be for 9 Rowe or Vernon, which are operating nuclear power plants as !
10 opposed to, as you know, the Pilgrim nuclear power plant.
11 We draw no specific conclusions from that, but simply '
, 12 bring it to your attention as an , issue that we, hope your staff 4
13 perhaps will look into~as well and which may reflect on the 14 training or the management of the licensee's operation.
15 Many of the people who have spoken before me today 16 have talked about the need for a test of the plants. We have !
1 17 been saying for as long as we have been discussing emergency 18 planning issues that there is a need for a full-scale, graded 19 exercise at Pilgria Station. The last exercise took place in 20 September of 1985, and we think that with all of the 21 development that has been done, that the present emergency 22 preparedness situation resembles that of a new licensee. -l 23 For this reason alone, Pilgrim Station should not be r
24 permitted to restart until a successful full-scale exercise of 25 all plants, facilities, and personnel has been held, which <
l L - i
125 1 demonstrates that all FEMA exercise objectives can be met.
2 Your staff alleges that the Commonwealth, having held 3 exercises for other nuclear power plants, has given evidence of 4- sound preparedness to respond to an accident,at Pilgrim. We , j I
5 think this argument is patently absurd.
6 An emergency exercise for one site indicates ,
7 absolutely nothing about emergency response capabilities in 8 other EPZs. The~ Massachusetts response system is designed such 9 .that first responsibility for public safety resides with local 10 authorities, and having been no demonstration of local P
11 capabilities in the Pilgrim EPZ communities for more than three
~
12 years, the need for an exercise shculd be apparent.
13 Moreover, Dr. Murley has asserted on previous 14 occasions ~that plans for a response to an accident at Pilgrim 15 Station are better than ever. I simply cannot imagine how such 16 a statement can be made in the absence of a meaningful test of 17 the plants. Exercises that may have been held for previous 18 emergency plans at Pilgrim Station simply have no bearing on an 19 analysis of present-day plans, because, as you have heard in 20 such great detail today, we are dealing with an entirely new I
.3 21 set of procedures in plants, some of which are not evenj i
22 , complete. . .
23 In our judgment, it would be irresponsible for the t 24 Commissioners to authorize the restart of Pilgrim Station until 25 the following conditions are met:
- 127 1 mainland.
.2 COMMISSION $R CARR: You're a self-sufficient, sealed-1 3 up community?
g 4 NR. QUAID: . Yes, yes.
5 COMMISSIONER CARR: So as I understood your
! 6 description of the evacuation, were you saying it was 7 impossible or just hard?
8 MR. QUAID: No. I would say -- I would say.
9 impossible.if you're discussing the situation as it exists.
10 Let's say that road that's inundated is elevated; that's one 11 thing out of the way.
12 If you doubletrack the road from the beach, that's '
13 -
fixed. - -
14 COMMISSIONER CARR: Is it a private road or a state 15 road?
16 MR. QUAID: These roads are sort of private. It's a 17 mixed up situation. It's owned by the town of Plymouth, but I 18 believe the roads are owned by the conservation -- see,;the 19 whole Duxbury Beach is a -- what do you call it -- is a 20 conservation area.
~
21 COMMISSIONER CARR: ou're not going to build a road 22 there, then. ,- l 23 MR. QUAID: Well, I think 'fiit becomes a. situation !
[ 24 of improving roads that exist, I think if it's a situation of 25 public safety, I really believe that a weight can be applied
_ ___ a_L_________ _ _ _ _ _ _ . _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ . - - _ . _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _______.__._______._________._.._m__ .___ . . . _ _ . . _ . _ _ _
128 1 for that. I just don't believe that any responsible person- .
1
~
2 would deny that. i 3 COMMISSIONER CARR: From that bridge south, how many 4 year-round residents are there? Is that south or --
5 MR. QUAID:. Yes., that's exactly right. They're only- !
6 at, Gurney Point at this point. They're at Gurnet Point. And 7 there are --
8 COMMISSIONER CARR: You said eight families?
9 MR. QUAID: There's eight families, seven or eight.
10 I think one -- there's some coming in, and one is moving out.
11 COMMISSIONER CARR: 32 people. Are they working? Do
. 12 they go back and forth. everyday?
t' ' '
13 MR. QUAID: Oh, yes. Some people --
' 14 COMMISSIONER CARR: They only have to go back and 15 forth at low tides?
16 MR. QUAID: They have to live by the tides. I've 17 spent many a two and a half hour, you know, working late at is night, sleeping in the car --
19 COMMISSIONER CARR: Like waiting for a ferry.
20 MR. QUAID: Precisely.
21 COMMISSIONER CARR: I understand. !
22 MR. QUAID: Until the tide receded.
23 -
COMMISSIONER CARR: And how would you say -- the peak f
~
24 summer load was 12,000; is that what you said -- below that 25 bridge?
129 1- MR. QUAID: 'I would say - no. I would say it's 2 12,000,-- and this is -- I'd say it's very conservative, but I
~
3 want to be conservative. I'd say 12,000 including all of 4 Saquish Beach, Gurnet, all the way down the four and a half 5 mile of town beach and including the public beach, which is 6 really an enormous number of people. There's at least 5000, 7 8000 on a summer --
8 COMMISSIONER CARR: Okay. And is the season like 9 most New England, July 4th to Labor Day?
10 MR. QUAID: No, not when you're talking about the 11 1 people. The people open up -- as soon as the weather gets 12 good, people open up their places. The water is f. rigid li,ke --
N,, .
13 . COMMISSIONER CARR: . Memorial Day to Labor Day?
~4 P3t. QUAID: Before' Memorial -- Memorial-Day to Labor 15 Day, yes, but actually give it --
16 COMMISSIONER CARR: Let me get a round number.
17 MR. QUAID: Give it a month before and a month after.-
18 Truthfully, truthfully.
19 COMMISSIONER CARR: Okay. I understand that.
20 ,
Now, Mr. Agnes, how do you define " technical review?"
21 Do you kind of agree with the local communities on what a
~
22 technical review consists of? . .
23 ,
MR. AGNES: Yes, Commissioner. Our understanding of r .
3 24 a technical review is that it is an informal review. It is 25 based on the materials submitted. There is generally no
130 1" discussion or analysis or meeting between the parties before g 2 the --
3 COMMISSIONER CARR: It says it meets the requirements 4 as laid.down in some piece of paper.
5 MR. AGNES: Generally, yes.
6 COMMISSIONER CARR: Okay. As far as meetings go, do 7 you remember a meeting with me in your place?'
8 -MR. AGNES: I remember your stopping by, 9 Commissioner, yes.
10 COMMISSIONER CARR: You.had a good opportunity to lay 11 .it all.on the table.
.. 12 ' . ,
MR'.'AGNES: At that moment, I, don't. recall exactly-
.: ~ . . .
13 when that was. It was quite awhile ago,.I believe, and --
14 COMMISSIONER CARR: I've only been here two years 15 plus.
16 MR. AGNES: It was not the kind of meeting, I think, 17 that we've been looking for until today, in the sense that.
I 18 there was not an opportunity to have presented material from 19 local officials.
. I 20 COMMISSIONER CARR: I was there. You knew I was j i
21 coming, and I was there for an hour and a half at your leisure. I
~
- 22 I didn't have any time schedule. ;
23 MR..AGNES: Well, it certainly was a meeting,
/
$ 24 Commissioner, but when you consider the numerous meetings --
25 COMMISSIONER CARR: Okay. I just thought we ought to 0
131 1 get the record to look right.
2 MR. AGNES: And I don't believe it was an official 3 meeting that this commission would consider to have any impact 4 on the regulatory process either.
5 COMMISSIONER CARR: I'm just saying I was available 6 if you wanted to lay it before me.
7 The notice of an unusual event you referred to, I 8 think you ought to correct the record, your testimony says 9 November '87. You meant November '88?
10 MR. AGNES: No, Commissioner.
11 COMMISSIONER CARR: Oh, so it's been over a year ago
, ,12 that they didn't notify you? ,
13 mrv AGNES: No. The point of the testimony was, at -
14 that time the notification was not able to be made within the 15 fifteen minutes.
16 COMMISSIONER CARR: That's over a year ago?
17 MR. AGNES: Yes.
18 COMMISSIONER CARR: Well, is it getting better?
19 MR. AGNES: Well, I indicated that there were still 20 some outstanding concerns about the communications system. It 21 certainly has'gotten better, because one of the devices!that 22 had been proposed as a replacement for the old communications -
o .
23 system itself has been found to be inadequate and superseded by 24 a new system. That new system, however, has not been fully 25 tested.
132 1 COMMISSIONER CARR: Okay. According to our records, 2 at a FEMA meeting in. Boston on 14 August '87, attended by you 3 and Mr. Lovering and Mr. Hausner, you stated that you had been 4 instructed by the' Governor to develop the best possible plans 5 without delay, and-you discussed a schedule that would complete 6 all' activities by 12/31/87. ,
7 To what do you attribute your inability to accomplish 8 .that? Was it inadequate effort, inadequate skill, inadequate 9 followup, inadequate resources, people, money? Would you give 10 me a little discussion on how you didn't meet your goal?
11 MR. AGNES: ,I have never placed a date for the, f 12 completion of emergency planning, and I would take issue with
~
13 whatever' report your comment is based on. I categorically 14 would deny that I ever said that.
15 COMMISSIONER CARR: Hmm? You agree with that? He )
(
16 didn't give a date?
17 MR. HAUSNER: That's right.
18 COMMISSIONER CARR: Why would the people that were 19 there imply that, I wonder?
20 MR. HAUSNER: I have no idea.
21 MR. AGNES: Why would the people who presented' 22 material to you on Octo,ber 14th misrepresent the facts? I
- 23. don't know, Commissioner. ; i
- I 4 24 COMMISSIONER CARR: Well, what is your date? !Do you I 25 have one?
133 1 MR. AGNES: I have not done that, Commissioner, for 2
the same reason, I think, that the Commission has learned that 3 when dates have been applied to the restart.of this plant, at 4 least to my knowledge, several times they have not been met, 5 because there are simply events that are beyond the control of 6 any one individual or agency with regard to the successful -
7 completion of that project.
8 I indicated to you that our planning process involves 9 local government, state government, and the licensee. The 10 licensee fully supported that process in the early part of 1987 11 and has been party to it ever since, and that process calls for 12 development at the local level, submission to the state,.
submission to FEMA, and'it's simply taking a'long' time, because 13
'14 it's a very complicated task.
15 COMMISSIONER CARR: You've been notified by FEMA, 16 since 1981 of deficiencies in your planning.
17 MR. AGNES: After exercises, yes.
18 COMMISSIONER CARR: How much money have you spent 19 since '81 in correcting those?
20 MR. AGNES: Well, before the last fiscal year, the l .)
j 21 figure would be difficult, because it would be based on sums l
22 from several different departments that were not specifically -
23 appropriated for nuclear emergency planning, but I could say
( 24 that it would involve the Civil Defense Agency, the Department 25 of Public Safety, the Department of Public Health, the
- 134 1 Executive Office'of Public Safety. All of those agencies would 2 have contributed to the planning process and the correction of 3 deficiencies, and, of course, local government.
4 Since the fiscal --
5 COMMI$SIONER CARR: Have you got a ballpark figure 6 since '81? ,
7 MR. AGNES: It's into the hundreds of thousande of 8 dollars.
9 COMMISSIONER CARR: How many people?
10 MR. AGNES: Well, there are eight or nine people 11 , dedicated full-time in the Civil Defense. Agency for emergency
, 12 planning for nuclear power plants at the moment.'.There are s
13 people, as you hatard, in'all the local communities, some of 14 whom are volunteers and some of whom are from different 15 depa'rtments, who are dedicated full-time or part-time. There 16 are probably six or eight other people in state government'who 17 are spending considerable amounts of their time on this issue.
18 So upwards of 30 or 40 state and local people spend most of 19 their time, I would estimate, on nuclear emergency planning 20 issues, as well as a substantial number of people that the 21 licensee has made available for this purpose.
22 And as we said, the number of meetings which are 23 documented in the attachment to our testimony is extraordinary.
( s 24 COMMISSIONER CARR: Well, that's why I was asking, if 25 those meetings were still going on.
__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ __ __ __ a
135
. 1 Would you classify those as productive? ,
2 -
MR. AGNES: I think they have been. . I have attended 3 them periodically, not every single week, but they have' 4 provided an opportunity, as some of the selectmen said,'for the 5 local Civil Defense Directors to put their stamps on draft 6 material that might have come from several different places, -
7 before it gets submitted to. local government, provided an 8 opportunity for the licensee to exchange views with local and 9 state officials, and provided an opportunity for local 10 officials to share with each other experiences.in their own 11 communities that might benefit each other. So I think they 12 have been useful.
13 COMMISSIONER CARR: 'Y6u're familiar with the six 14 deficiencies that FEMA identified?
15 MR. AGNES: Yes.
16 COMMISSIONER CARR: In ' .r opinion, are any of those 17 completed?
18 MR. AGNES: I think one of the deficiencies had to do 19 with the general nature of the State's resolve, if you will, in 20 emergency planning, and I would hope from what you've heard in 21 the material that we've submitted that there is no question but 22 that the State is working as hard as it can with local 23 government.
!' 24 In the other areas, I would say that there remain in 25 each one of those areas some unresolved issues.
i
1 1)6 1 COMMISSIONER CARR:. Of the remaining five, which one
'2 is going to be the toughest?
3 MR. AGNES: I don't think I could say that, 4 Commissioner.
5 COMMISSIONER ,CARRt Okay.
6 MR. AGNES: I would add, though, when you say."the 7 remaining five,'" we might characterize them somewhat 8 differently, but I would hope you would include in that list 9 the need for an exercise, which.is not specifically listed, I 10 don't believe.
11 COMMISSIONER CARR: I'm talking about the ones they 12 listed. .- , ,
13 MR. AGNES:. Well, that was one of the other. concerns-14 that we had, and I appreciate the judgment on restart is a
, 15 judgment that you have to make. It's not a judgment that state 16 or local government has to make. But again, we have, in good 17 faith, given you three very lengthy reports in which we.have 18 expressed our views, and we would hope, as you consider FEMA's 19 concerns, that you would also take ours at least into 20 consideration.
l 21 COMMISSIONER CARR: Okay. The city of Taunton has 22 stated that its reception center could handle more than 20 -
23 percent of the EPZ population. Does your office agree with a
- 24 that?
25 MR. AGNES: Well, " handle" is a word that I think e
l
.i 137 1 requires some'further definition. If you mean that more than
. i.
2- 20 percent. of the population could --
3' COMMISSIONER CARR: Well, let's rephrase. Whatever a 4 reception center is supposed to do. Could they take more than 5 20 percent of the EPZ population.
6 MR. AGNES: Well, whether you use the word "taxe" or 7 " handle," my point is simply this. When you talk about either 8 of those two terms, do you mean simply be able to process 9 people through the reception center in the sense that people 10 can park their car there?
11 COMMISSIONER CARR: x Well, what does the State e'pect
- 12. the reception center to.do? ,
13
. 'MR'. AGNES: We1.1, we expect that radiolog'ical .
14 monitoring and decontamination has to take place there. We 15 expect that people who might require a change of. clothing be
- 16 provided with a change of clothing and a facility to take a 17 shower. People have to at least be given an opportunity to be 18 referred to --
19 COMMISSIONER CARR: Okay. I understand that.l 20 'MR. AGNES: Quite a number of those details.
1 i
21 COMMISSIONER CARR: Can they handle 20 percent?
l 22 MR. AGNES: I'm not certain of that. -
23 COMMISSIONER CARR: If a non-nuclear accident similar I 24 to Springfield's fire occurred in the Area 2 tomorrow, could 25 MCDA handle it?
b 1
l
138 1 MR. AGNES: Again, we try to handle anything that we 2 have to, because our responsibility is to the health and safety 3 of citizens. But I should first say that with' regard to the 4 Springfield incident, with which I am quite familiar, the 5 people who were evacuated were approximately 25,000 to 30,000, 6 not 70,000. The incident occurred over the course of several 7 days, giving local officials, who did an outstanding job by the 8 way, an opportunity to evacuate people in a relatively 9' efficient and. orderly manner, and the spill, although of rather 10 vast proportions, nevertheless was in many respects brought to 11 the upper atmosphere and did not have some of the dangerous 12 effects that we might,otherwise experien.ce. '
13 ,
Also MCDA is not a first-response agency, and that's 14 an important point. MCDA is an agency that coordinates the 15 response.
16 COMMISSIONER CARR: Yes. I didn't get the impression 17 that you all were the prime actors in that. But the planning, 18 I would say, was in an embryonic state for that emergency.
19 MR. AGNES: Quite to the contrary. The city of 20 Springfield has one of the most sophisticated, comprehensive 21 emergency response plans.
22 COMMISSIONER CARP- Even better now. -
23 MR. AGNES: I think so, yes, thanks to a great deal 24 of work by the city and MCDA. But they will tell you -- at 25 ,least the emergency personnel have told me -- that but for the
139 1 SARA Title III program, for example, and the work that they 2 have done, we might have had a very different result there.
3 COMMISSIONER CARR: Is there any hazardous 4 . substances-producing, using storing area -- are there any of 5 those in Area 2? .
6 MR. AGNES: Yes.
7 COMMISSIONER CARR: And do you have those plans, 8 then, in SARA III for 2?
9 MR. AGNES: I can't say for certain that'each of the 10 EPZ communities in the Plymouth area have them, but I think 11 that they do.
12 COMMISSIONER CARR': And are you coordinating -- does
. 13 MERC -- it'looks like the same people are involved in MERC that 14 are involved in radiological planning, so you're taking 15 advantage of each other's --
16 MR. AGNES: It's the same agency. Two separate 17 units.
18 COMMISSIONER CARR: So if the plans are available in 19 one area, I assume they would be available to be used in the 20 other situation.
. 21 MR. AGNES: The plans would obviously be available.
~
22 As you know, the planning basis is somewhat different.
23 COMMISSIONER CARR: Somewhat different, yes.
2 24 While we're on that, who is responsible for taking 25 care of these disadvantaged that we were talking about awhile
140 I
1~ ago. It's not her responsibili.ty;-it's a state responsibility?
2 MR. AGNES: I th, ink it's a state responsibility with 3 the licensee's support. And I say that.for.two reasons.
4 First, the federal regulatory guidance suggests that 5 the licensee should support the State's efforts, and the j 6 licensee in this case has been supportive. ,
1 l 7 And secondly, the licensee has essentially, as I 8 said, bought into our planning process, and we have been 9- working for two and a half years in part on trying to solve 10- this problem of persons with special needs.
11 Now we have made advances, but the issue of the 12 survey has been a stumbling block, and 1t is important to us ,
13 because it is -- it will be the first time, to myl knowledge, ,
14, that a scientific survey will have been done to try to identify 15 who the people are who may have a disability and need help in 16 an evacuation. We depend on people to self-identify to some 17 extent. We depend upon local officials to know the people in 18 their community to some extent. But you never know for 19 certain how many people with disabilities you may have in your 20 community who may need assistance.
21 COMMISSIONER CARR: Will next year's census-taking 22 take care of that? -
23 MR. AGNES: I can't answer that. I'd be guided by
[
^
24 Ms. Waitkus on that question.
25 COMMISSIONER CARR: Never mind. One more question 9
141
.l. for.you. ,
2 MR. AGNES: Yes, sir. ;
. 3, COMMISSIONER CARR: I noticed The Globe article.that l
'4 was done on you recently says'that --
5 CHAIRMAN.ZECH: You can ask Ms. Waitkus, if you'd- ,
6 like to. .
7 COMMISSIONER CARR: I gave her a --
8 CHAIRMAN ZECH: Would you mind taking the. microphone, 9 please, Mr. Waitkus, right there?.
10 COMMISSIONER CARR: Your survey that you're writing, 11 I was curious if we're going to run a census next year, I was 12 wondering, does the census record whether or not the people in .
l3 the homes are -- ,
14 MS. WAITKUS-ARNOLD: First I'd like to say that I
, 15 really resent your term " disadvantaged" when it comes to people 16 who are elderly and disabled.
17 COMMISSIONER CARR: Well, whatever.
18 MS. WAITKUS-ARNOLD: It's not "whatever." It's a 19 serious term to use.
20 COMMISSIONER CARR: I'm elderly.
21 MS. WAITKUS-ARNOLD: Then you must be disadvantaged, 22 in your mind, huh? 2 ,
23 COMMISSIONER CARR: You can see that.
f i 24 MS. WAITKUS-ARNOLD: I don't feel disadvantaged.
25 This survey, you can never find all people who need e
142 1 assistance. You can get rough estimates. Say we know the 17 2 percent,,and we're going to have to plan to have transportation 3 and expert individuals trained, who have expertise in issues
'4 for maybe 15 or 14 percent of the population.
5 COMMISSIONER CARR: No. My question was --
6 , MS. WAITKUS-ARNOLD: What were you saying?
7 COMMISSIONER CARR: In the census that's taken next 8 year, do you know if that will provide these data?
9 MS. WAITKUS-ARNOLD: Not the census, no. A survey 10 like this might, a comprehensive survey. The census will not, 11 no.
12 ,,
COMMISSIONER *CARR: ,
Will not? ,
13 MS. WAITKUS-AENOLD: No, absolutely not-.
14 CHAIRMAN ZECH: Thank you. ,
15 COMMISSIONER CARR: Thank you.
16 Back to The Globe article. I notice that it says, 17 you say getting involved in controversies makes life exciting 18 for.you. Doe solving problems make it equally exciting?
l 19 MR. AGNES: It is, Commissioner, when you can solve 20 the problem. And when you can't solve the problem, it's 21 sometimes frustrating.
Okay.
22 COMMISSIONER CARR: That's all I've got.
23 CHAIRMAN ZECH: Commissioner Rogers?
[ 24 COMMISSIONER ROGERS: Well, we've all been here a 25 long time, and I don't want to prolong this unduly. But what l
143 1 is your view towards the question of whether the individual 2 towns are availing themselves of consultants that could help to 3 assist them in organizing their efforts in ways that might lead 4 to a little more rapid conclusion?
5 Obviously there's a lot of dedicated volunteer 6 efforts that are being contributed.to these problems in each 7 town, and I'm sure people are working very hard and spending an 8 enormous amount of time. But are they trying to reinvent the 9 wheel here with respect to emergency planning?
10 There is some expertise that undoubtedly exists and 11 that can be brought to bear and shared. What is the State's 12 position with respect to what you can do to try to assist, to.
13 make the process streamlined a little bit better and make sure 14 that people ar.e not unduly debating issues that somehow or 15 other really have been settled on a professional basis long 16 ago?
17 MR. AGNES: In my opinion, Commissioner, 100 more 18 consultants would not speed the process up, but, in fact, 19 retard it. There has been no lack of assistance from outside 20 sources during the last two and a half years of emergency 21 planning.
~
22 The licensee has made an enormous outlay of
- 23 expenditures for emergency planning consultants. The State
" 24 has had staff full-time working with local governments.
25 But what I think you heard today, what I hope you l
i
_.__..___.__._..__1...__________.__________
144 l' heard 1today, waslthe unrelenting desire and responsibility felt
. 2 by loca} communities to put their own stamp.of approval and 3 mark on this planning material, or else it doesn't rapresent 4 their plan, that'they feel that their people can implement, but 5 it represents.something out of a book. When the emergency 6 occurs, the consultants aren't going to be there. The fire 7 chief, the' police chief, the public works director--- those are 8 the peop'le who are going to get a call at 2:00 o' clock in'the 9 morning, and those are the people who have to understand the 10 plan, and it has to be one that fits with the community.
11 So it is a cumbersome process. It is time-consuming.
12 But I'think all of the partiss have worked.just as hard'as they 13 possibly can, and it's. simply not complete.- '
14 CHAIRMAN ZECH: Commissioner Curtiss? -
15 COMMISSIONER CURTISS: Yes. I guess I have a number 16 of questions here. I want to clean up one that Commissioner l
17 Carr ra# sed, first of all.
.18 When was the Springfield incident?
19 MR. AGNES: Oh, I think it was in June of this year.
20 COMMISSIONER CURTISS: You mentioned in the 7
21 discussion that the work.that the State had undertaken unde,r
~
22 the community right-to-know provisions, which became effective I
23 July 1st of '88, contributed substantially to your ability to ,
- 24 undertake the evacuation in the Springfield incident.
25 Is there something that might give you a leg up on i
s
+ ,
. 145 l 1 what you're doing here in the nuclear area?
2 MR. AGNES: I don',t think that the emerge.ncy planning 3 part of the SARA Title III program is particularly relevant to i l
4 the problem that we are facing here, because the problem is, in 5 part, that the planning process simply has not been completed, 6 not that people don't understand what it is they're supposed to '
7 do, just that it hasn't been completed, and secondly that we 8 feel that it is so complex, that to give you any assurance that 9 - we think the plans can be implemented, we think there ought to 10 be a full-scale exercise.
11 So the fact that you might have three other kinds of 12 comprehensive emergency plans sitting side-by-side in your
, 13 community is not going to help you resolve those two issuds.
14 ,
COMMISSIONER CURTISS: Have you exercised a plan ,
15 under the SARA legislation for your chemical plants?
16 MR. AGNES: Springfield did.
17 COMMISSIONER CURTISS: Has the whole state?
18 MR. AGNES: No.
19 COMMISSIONER CURTISS: Okay. Let me shift gears for 20 a minute.
21 I'm a little bit confused about your statement on 22 page 3 of the tastimony where you indicate that you will not 23 support the restart of the Pilgrim Station until the ,
r 2
24 requirements of NUREG-0654 and all other regulatory criteria 25 are satisfied.
146 1- What are those "other regulatory criteria" that you 2 would' urge us to consider?
3 MR. AGNES: Well,,,one that comes to mind obviously is
'4- -the requirement of the biennial exercise, which I' Understand
- 5 there is an exemption which extends to the end of this, calendar
~
6 year. .
7 There is also a requirement for emergency planning 8 information, which we're working with the licensee _to produce 9* .and distribute to people in the EPZ.
10 COMMISSIONER CURTISS: Are they all federal criteria, 11 or are there --
. 12 MR. AGNES:
Yes. My point was to indicate that we
.13 obviously a're insisting tht all of the applicable federal 14 criteria be met,.and as you know --
15 COMMISSIONER CURTISS: I understand that.
16 MR. AGNES: -- there is a certain amount of guidance 17 material that is published by FEMA in connection with NUREG-18 0654i which we're constantly reviewing.
19 COMMISSIONER CURTISS: Are there requirements'beyond 20 the federal criteria that need to be met here, or is it.just 21 the federal requirements that we should be looking at?
22 MR. AGNES: Well, we ceWainly would hope you might -
23 agree with some of the proposals that we have advanced in our l( 24 three previous reports regarding health and safety issues.
25 We're not expecting you as federal regulators to be bound by
- i 147 1 things we might recommend that should be done, such as improved 2 monitoring systems, computer-linked between the plant and the 3- state, for example, such as they have in Illinois, or 4 enhancements of that sort.
5 We certainly have recommended them to you in the 6 past, as I know others have, and we would recommend them to you -
7 in the future. But we're here today to simply point out to you 8 that we don't think the applicable federal regulatory 9 requirements have been met.
10 COMMISSIONER CURTISS: Well, let me discuss two of 11 them, because one you mentioned in your testimony, and that'c 12 the adequacy of shelter as a protective action.
- 13. If We address that. issue to FEMA's satisfaction, 14 would that resolve that issue,.in your judgment?
15 MR. AGNES: First of all, as you might have gleaned 16 from some correspondence between FEMA and the State, I don't 17 understand the FEMA position, and I don't know, for example, if 18 the NRC has adopted the FEMA position on sheltering. All I 19 know is that FEMA has apparently changed its view on 20 sheltering. I don't quite understand exactly what their view 21 is today.
22 So I can't answer that question. -
23 COMMISSIONER CURTISS: Well, if we can clarify what 24 their view is, and if their view is, in fact,'that the 25 sheltering for huge populations is not necessary to meet the
148
-1 -federal criteria, would that address --
2 MR.- PARLER: Mr. Chairman?
3 CHAIRMAN ZECH: Yes.
1 4 , ,
MR.-PARLER: The issue in general that's being 5 discussed might be a contested issue in other proceedings. I 6 apologize for interrupting, but --
7 COMMISSIONER CURTISS: All right. I'll move on to my' 8 next example, then.
9 If we were satisfied that the state of emergency
+
10 preparedness within the 10-mile emergency planning zone was 11 sufficient to protect the public health and safety, does that
,j, ,12 ,
discharge our responsibility, or.in your judgment, would we ,
13 -
need to' find that emergan'cy preparedness.'is sufficient beyond 14 ,
' 10 miles in order to meet that finding?
15 MR. AGNES: Well the emergency planning zone, 16 according to the guidance, as I understand it, is supposed to 17 be approximately ten miles. We have indicated, for example, 18 and we will try to supply you with the additional 19 correspondence.that may go beyond what the town of Bourne has 20 given you, that we think that the towns of Bourne, Plimpton, 21 and Wareham ought to be included in the EPZ, as well as the 22 rest of the town of Marshfield, Marshfield having only about 10 23 percent cf its population in the EPZ.
(. .
1 24 Now that is a decision which we've made as a state.
25 We've gone as far as we can. We've notified FEMA, and we've
1 1
r' ~ '149 l
l 1 notified the NRC. I don't know what the position of the NRC is l~
l
.2 frankly, because we've never been given any* official response.
3 ',00MMISSIONER CURTISS: Do you have a state law on the 4 size of the EPZ?
5 MR. AGNES: Yes.
6 COMMISSIONER CUPTISS: And what is that?
7 MR. AGNES: It indicates that there is an authority 8 within state governmenc to designate so-called nuclear power 9 plant areas, I believe, for planning purposes, and we have done 10 as much as we can under that authority to indicate that we 11 consider those communities to be part'of nuclear power plant
,, 12 plannidg areas. -
- r .
13 ' COMMISSIONER CURTISS: How far is Ba'rnstable fro'm the 14 plant? ,
15 MR. AGNES: It's further south than Bourne. I can't 16 tell you exactly what the distance is. The Cape, as you know, 17 curves, and so the actual distance as the crow flies might be 18 closer than some areas that by car are closer.
19 COMMISSIONER CURTISS: I have one final question. In 20 your statement at a number of points, you alluded to the lack 21 of gus,ince and response from FEMA, and in particular seemed to 22 suggest an interest on the'part of the State to get FEMA more 23 actively involved in assisting you to , carry out the two
-f 24 respective emergency planning responsibilities.
25 In late August of this year, they asked you to
150 1 provide a schedule of milestones for1when you intended to carry 2 out the various responsibilities that you have, on the basis of 3 their judgment that that would enhance the ability to complete 4 the actions.
5 Is that something that you just disagree with them 6 about, that setting milestones and schedules, as they have 7 suggested, wouls not contribute to moving forward?
8 MR. AcNLS: Well, we said in our response, and we've 9 said before, that milestones in the sense of objectives are 10 patently obvious. We want the very best possible plans. We've 11 been following NUREG-0654 and the federal guidance as best we 12 can. But dales by which things are going to be completed, in 13 our judgment, place artificial constraints that could' seriously 14 impact on public safety, as some of the earlier speakers have 15 said, by creating pressures that people may feel to do things 16 by a certain deadline, when they may not be ready to do them 17 by. '
18 And'I would simply say that I hope you would respect 19 the decision of state and local governments with respect to 20 milestones, just as you respect a decision of your own staff i 21 with respect to technical issues, that they are resolved when 1
22 they are resolved. -i 23 COMMISSIONER CURTISS: Thank you.
t
- 24 CHAIRMAN ZECH: I know that Massachusetts has 25 participated in the past on previous exercises at the Pilgrim i
Y
151 1- plant.
2 Are you familiar with those, Mr. Agnes, and if you 3 are, could you give us perhaps your views of the results of 4 those exercises? ,
5 MR. AGNES: I'm not familiar from havi,ng personally 6 participated, but in our first report, which we did for the !
7 Governor in December of '86 and which we provided to the 8 Commission, we documented the history of those previous 9 exercises, and in each case with* regard to the pre-1986 10 emergency plans, there were exercises; deficiencies were noted; 11 in some cases, remedial exercises were held to correct those; 12 and FEMA awarded the interim finding of adequacy or approval, .
13 which, as you know, of course, was withdrawn in 1987.
14 CHAIRMAN ZECH: Did you or the State participate in 15 making any recommendations or concerns regarding those 16 deficiencies in those exercises; do you recall?
17 MR. AGNES: In the pre-1986?
18 CHAIRMAN ZECH: Previous, yes.
19 MR. AGNES: Yes, the St'te a did, I believe. ,
1 20 CHAIRMAN ZECH: Yes. And as far as those i
21 deficiencies are concerned, those are the ones that, of course, 22 we're aware of and are being addressed. -
)
23 Could you give your views on how those are being
- l. 24 addressed at the moment, those deficiencies specifically? )
l 25 MR. AGNES: Well, when we issued our report in
)
)
152 f i
- 1. December of '86,.what we attempted to do was to compile-all of 2 the outstanding items that we considered'to be deficiencies 3 .previously identified or deficiencies.that.we had identified, 4 and that has been the basis of the planning effort since that 5 time.
6 CHAIRMAN ZECH: I understand. .And then as you -
7 pointed out, you're not satisfied at this stage with the 8- training and with the emergency plans as they stand.
9 Could you -- do you think that even though you're not 10 satisfied, have they been improved over the past plans that 11 were in effect when the plant has been operating before?
e.
12 MR. AGNES: Well, tihere is a se.nse, I think, in which 13 you can say yes, that you,can'make a udgment thit because of' 14 the effort and the consideration of factors which were not 15 considered in the past, that there has been an' improvement.
16 But you can never really make that judgment with the 17 kind of confidence, I think, we all want to have before>we 18 ' confront an accident without having had an exercise and a test. i 19 CHAIRMAN ZECH: I agree. Just because they've 20 improved doesn't mean that they're necessarily adequate. But 21 the point is that we had a plan before. There were exercises 22 done on it. There were deficiencies. We've addressed the -
23 deficiencies. We've put these on the table. And apparently
'[ 24 from what we've heard from others, too, it would appear, as you 25 state too, I believe, that there have been improvements made in
[ 193 1- that plan that we've been using for a number years.
2 I guess the other thing I'd appreciate your views on 3 is, again I recognize that the State of Massachusetts and the 4 New England area in its entirety ha,s a reputation for being ,
5 able to handle other casualties than the nuclear casualties,
~ '
6 and it has over the past.
7 Could you give us, in your role as a state. official, 8 your view as regards the capability of your state and others in 9 the area to handle natural disasters, excluding the nuclear r
10 disaster? .
11 MR. AGNES: I think with respect to the common range 12 -
of natural disasters - snowstorms, floods, hurricanes -- , ;
13 experienced'public safety official's will alw'ays tell you '
, 14 , f' rankly that they're scared to death of having to confront'such 15 a disaster, because no two are alike.
16 At the same time, I think'we have some of the very 17' best officials at the state and local level, who have been-18 through a great deal, who are competent, who are well-trained.
19 But I.think the very best people will frankly tell you that no 20 one is confident that you're going to make it through the next 21 so-called disaster, just because you may have survi,ved the last 22 one .,
23 CHAIRMAN ZECH: Well, of course, it's the same thing 24 that we're involved with all the time. You can't have any 25 guarantees, but you want to make the best judgment you possibly
.. 154 4
1~ can, so that, as we say, " reasonable assurance" is provided 2 that adequate protection would be there, and that, of course,'
3 is what we both want, I think, Mr. Agnes.
4 .Are there any other questions from my colleagues?
5
~
COMM,ISSIONER CARR: I need two things. When did the 6 State ask NRC and FEMA for expansion of EPZ to '
7 Bourne /Wareham/Plimpton? I don't have that in my file.
8 MR. AGNES: It would be approximately in the 9 summer / fall of 1987, I think. The correspondence'that you have 10 from the town of Bourne --
11 COMMISSIONER CARR: Well, that shows they didn't ask 12 you until late '87.
- E" ..i 13 . MR. AGNES: ,
Well, I think my recollection is that 14 ther~e is some correspondence that starts in the spring, and it 15 goes through August, and I think we had meetings in that period 16 with NRC.
I 17 COMMISSIONER CARR: But your letter has come to us, l
18 you think? -
19 MR. AGNES: Oh , yes . - We'll produce that, if you 20 don't have it in your file.
21 COMMISSIONER CARR: Okay. And I need to correct the
~
22 record on the Springfield fire. It happened at 10:13 on June -
23 17th of this year. They evacuated 30,000 people that afternoon f 24 out a mile and a half. They let some of them back in Saturday 25 morning. Then they had to re-evacuate about 50,000 four miles
t . ...
155 1- the next day,'and then -- so it.was oser a three-day period,.
2 they moved 70,000 people in and out and around. So that will 3 make the record a little more agreeable with --
4 MR. AGNES:. Well, our estimates were 25,000 to 11
.)
5 30,000, but those are judgment matters, and I respect your --
6 COMMISSIONER CARR: Well, that's out of the mayor's 7 office.
8 CHAIRMAN ZECH: All right. Thank you very much, Mr.
9 Agnes. We appreciate you and your colleagues being with us 10 today.
11 MR. AGNES: Thank you.
12 CHAIRMAN ZECH: And I would suggest, 11' there's no
', 13 objection, we take a fifteen-minute , recess ri,ght now, and we'll 14 come back again in fifteen minutes, 5:40.
15 [hlriefrecess.)
16 CHAIRMAN ZECH: Good afternoon, ladies and gentlemen.
17 We will continue this afternoon's meeting with a 18 presentation by'the Staff.
19 Mr. Stallo, you may proceed.
20 MR. STELID: Thank you, Mr. Chairman.
21 I will make a very few brief points to begin with and 22 turn very quickly to Bill Russell, and we'll try to -- I know 23 the Commission must be tired by now -- to go through the points r
24 that we think are important, based on what you've heard.
25 But the most important one, I think, we need to start
l 156 1 with is, first you've heard an awful lot now for the last i
2 several hours on emergency planning, and that is an important )
l 3 issue, I agree and concur, but I must remind the commission
]
l 4 that the reason that this plant was shut down was because of ]
1 l
5 its poor performance, both from the equipment point of view as 6 well as performance of people in management.
7 So we want to at least spend a few moments to talk 8 about those issues and summarize the status of the plant in 9~ that regard, and then we will get into the emergency planning l
10 issues, and then finally we'll tell the commission where I l I
11 think we come out, based on what we've heard and our 12 understanding of where we are today at the end.
o * .
13 So with that brief introduction, l'et me ask Bill to 14 give you a summary of the overall sta.tus of the plant.
15 CHAIRMAN ZECH: Thank y'u o very much. Mr. Russell, 16 you may proceed.
17 MR. RUSSELL: Let me start out by first saying that is the technical issues which were identified in the Confirmation 19 of Action Letter 86-10, which was the original basis for the 20 shutdown, have been corrected, and to the extent that they can 21 be tested in a shutdown plant, we are satisfied that they have 22 been resolved. ,,
23 We supplemented that confirmation of Action Letter to
/
24 require in addition a formal assessment of the readiness of the 25 plant for operation and a formal restart plan by the licensee,
157
~
1- including a' power ascension plan. That required NRC review and' 2 approval.
3 At the last meeting, I reviewed the status of our t
4 review of their readiness for operation and did briefly. discuss 5 the power ascension program. I thought,it would be useful to 6 describe what that program is and the fact that it would'be, in 7 another supplement to the Confirmation of Action Letter, 8- Supplement 2, which I would. issue subject obviously to 9 Commission approval.
10 The testing program would involve a four-to-six-month 11 period of close monitoring by the Staff. There would be ,
12 periods of time that would have around-the-clock coverage. . I.t 13 -
ha's built in to it a number.of hold points, the first one being 14 initial criticality, and then 5 percent, 25 percent, 50 15 percent, 75 percent, and then 100 percent. Now 'the 100 percent 16 hold point would be the point at which we would reduce from the 17 augmented inspection coverage back to more normal inspection
'18 coverage.
19 There is a formal review and recommendation against 20 established criteria for each hold point, and that review is
?
21 done by a joint review by NRR and Region I senior managers
~
22 through the Restart Assessment Panel, and they will provide a 23 report to me, which then I will use as the basis for making a
-( 24 judgment.
25 The Restart Panel, in addition to looking at both
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I
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1:
158
-1 technical issues and managemen't performance, has been-receiving 2 periodic reports on the status of emergency preparedness from 3 Dr. Bellamy and'others. That status would also be available. j 4 Since the october 14th Commission meeting, I'd like l 5 to review the status of the facility. At that time, I 6 indicated it would be a few days until the facility would be -
7 physically ready for restr.rt. However, on the.14th, that 8 pfternoon during the Commission meeting, an NRC inspector 9 identified concerns with some anchor bolts that were for large i
10 structural supports for piping at the point where the piping 11 enters the drywell.
These anchor bolts were tack welded.. When the ta.ek
~
12 *
. . c 13 welds were removed and the~ anchor bolts tested, i$wasfound 14 that two were not properly installed.
15 CHAIRMAN ZECH: Two of how many?
16 MR.-RUSSELL: There were ten large supports. I don't -l 17 know the exact number.of anchor bolts, but it would be many, in 18 the few hundreds.
19, CHAIRMAN ZECH: Did you check them all?
l 20 MR. RUSSELL: There was an extensive program of i 21 testing other anchor bolts, looking for others. There were 22 others that were found, but with a 95 percent confidenceslevel, -
)
23 which is identical to that used in the I&E bulletin. They were f 24 found to be satisfactory, and they were operable -- that is, 25 with factors of safety of 2. The supports would still
159 1 function, even though there were some loose anchor bolts in the 2 supports, so that while the issues were pursued, we did 3 conclude that they were operable. We documented this in an 4 inspection report, provided th's inspection report in an update 5 memorandum to the Commission on November the 29th.,
6 There are some remaining final calculations that the -
7 Staff is treating on a routine basis that will be closed out in 8 an inspection report, but the effort has now been completed by 9 the licensee.
10 There was earlier in the testimony mention of a spill .
1 11 which occurred on the 16th of November. It was essentially an 12 activity in the truck bay at the facility. D. mineralized -
i 13 water was,being added to a vessel that had contamination in it.
14 It was thought that the filling process had been terminated and 15 was secured. It was not adequately secured. The scene was 16 left by the contractor involved in the activity. There was an 17 overflow. It did progress outside of the truck bay into the 18 parking lot area, up to the fence of the protected area.
19 We have reviewed the short-term actions taken by the 20 licensee, which have included cleanup of the area and 21 termination of those types of activities and the longer-term 22 plans for some physical design modifications in the area, and 23 we are satisfied with the administrative controls that they r
5 24 have imposed, such that that would not reoccur.
25 There was no contamination off the protected area of 4
160 l' 'the facility', and there were samples in the environment that 2 were done both by the Massachusetts Department of Health, as 3 well as the licensee, and those all showed negative results.
4 The licensee is currently maintaining what I would 5 characterize as a two to three-day rolling schedule of 6 surveillance activity and some corrective maintenance. The .
7 licensee's objective is to complete those things now, so that-8 there will be a longer period of time potentially of operation 9 for known work. There clearly is going to be other activity 10 that comes up, and it may be necessary for'a shutdown, as I 11 have previously described. The plant has not operated for some 12 two and a half years. It has not been up to temperature and
.13 pressure, a'nd we expect that the low-power period _of operation, 14 up to 5 percent, could take four to six weeks to complete and 15 may, in fact, require a shutdown prior to the scheduled 16 shutdown from outside the control room.
17 Overall, we feel that the technical and the 18 management issues which were the basis for the shutdown have 19' been resolved and that the facility is ready for restart. We 20 reaffirmed that conclusion in our November 29th memorandum.
21 CHAIRMAN ZECH: Thank you very much.
22 Dr. Murley, are you -- ' -
23 MR. MURLEY: Yes. Thank you, Mr. Chairman.
( 24
- CHAIRMAN ZECH: Proceed.
25 MR. MURLEY: In order to develop fully the Staff's I
1 l
161 1 conclusions.and recommendations,-I'will repeat br'iefly some of 2 the background from'the october 14th meeting.
3 Regarding the recent history,of emergency 4 preparedness at Pilgrim, in June 1981 the initial plans were l
5 submitted to FEMA by the commonwealth of Massachusetts. They 6 were reviewed, revised, and resubmitted in October 1981. . .
7 In March 1982, the first full-scale exercise was held 8 at Pilgrim. Several deficiencies were noted by FEMA, and in 9 September of 1982, FEMA issued an interim finding that the 10 state and local response was adequate.
11 ,
In June of 1983, the second full-scale exercise was
, 12 held. I was the Regional Administrator in Region I at the
. , 13 time, and I persorially observed that exercise with the FEMA "
14 Regional Director. I saw the -- started out observing the
.15 exercise in f.he control room. I moved to the technical support 16 center, to the emergency operations facility, which at that l
17 time was a series of trailers adjacent to the site, and I then 18 observed the local activities in Plymouth at, I believe it was 19 the armory. .
)
20 There it was clear that the resources and the 21 communications facilities were in place. I was impressed, as a l
22 matter of fact. And I recall the state official at that time - .l 23 came in by helicopter from Boston to the emergency operations j 24 facility. I observed the local civil defense, the local 25 police, the local coast Guard liaison, and as I said, their I
i
s-162 i liaison'with their state civil defense facility in Framingham.
~
2 From that exercise in June of '83, FEMA issued a
-3 finding of adequacy, although here again there were several-4 deficiencies noted. , ,
5 I did not observe evacuations. We do not'in our 6 exercises require evacuations to be done as a rule. We mainly 7 look at facilities and at personnel and communications 8 equipment and that sort of thing in an emergency.
9 As-I mentioned,-many of those things I-did personally 10 observe in June of 1983.
11 In August of 1984, there was a drill, which is sort I
.12 of a partial exercise, at which FEMA made a finding of
- e p
13 adequacy, and they found one defi'ciency at,that time.
14 In 1985, FEMA wrot's to Massachusetts,and told'the 15 Commonwealth that there were several planning problems l 16 unresolved, and they stressed that the Commonwealth was not 17 making progress in corrective actions toward those
,18 deficiencies. ,
19 InSeptemberof1985,therewasyetanotherfbil-20 scale exercise' in which four deficiencies were observed.
21 There was a remedial exercise the following month, 22 October of 1985, that' corrected the deficiencies, after which 23 there was a FEMA finding of state and local response adequacy.
{ 24 Six months later, as we know, in April 1986, the 25 plant was shut down, and later on in that year, in December of 4
i j \
L_------__-_---__--_---- - - - - - J
D .
163 ,
1 l
1 1986, Secretary Berry sent a report to NRC and FEMA that .
2 described the problems that the Commonwealth of Massachusetts 3 saw with emergency planning at the site.
4 In August of 1987, FEMA issued the report to NRC of 5 their findings from their self-initiated review. In that i
6 report, they highlighted six major deficiencies that they .
7 found. They found that the offsite emergency preparedness ;
8 generally had deteriorated, and they could no longer make the 9 finding that state and local plans were adequate.
~
10 .Here it's important to emphasize --
11 CHAIRMAN ZECH: Excuse me. Would you say that 12 again.? What was the principal reason for making that finding l
13 again?
14 MR. MURLEY; There were six major deficiencies.
15 overall, there was a general finding that the emergency 16 preparedness was inadequate, and they could not longer make the 17 finding that state and local plans were adequate.
18 CHAIRMAN ZECH: Overall; is that what you're saying?
19 MR. MURLEY: Yes.
20 CHAIRMAN ZECH: All right.
21 MR. MURLEY: And here, I think it's important,to 22 emphasize -- s -
L 23 CHAIRMAN ZECH: Because of those six specific-I y . i 9 24 findings?
25 MR. MURLEY: Yes, yes.
164 1 CHAIRMAN ZECH: Okay. In other words, the totality 2 of the six of them? Is that what was meant?
3 MR. MURLEY: That is what led FEMA to conclude --
4 CHAIRMAN ZECH: All right. You may proceed. >
i 5 MR. NURLEY:
It's important to recognize that the six 6 deficiencies that FEMA found were all in the area of planning. .
7 They were not deficiencies in execution during the exercise',
8 for example.
9 The plant was already shutdown at that time, of 10 course, and we concluded that there was no need to take any 11 enforcement action. Boston Edison, we knew, had been working
- 12. with the state.and local officials to improve the plans, and we 13 could see at that: time -- and this was in August of 1987 - .
14 that improvements were.being made. In fact, Boston Edison 15 testified recently on October 14th that.they have spent now $10 16 million on improvements to the plans and facilities in the 17 emer'gency planning zone, and they intend to spend about SS 18 million more, according to their testimony.
19 Nonetheless, there is more work that needs to be done 20 before we can receive a finding of adequacy from FEMA. There 21 must be complete plans and procedures developed by the towns.
22 The state must submit the final plans to FEMA. FEMA must .
. 23 review and approve the plans and schedule an exercise. The 1" 24 exercise must be conducted, and any deficiencies must be i
l M 25 corrected. And finally, FEMA must issue to the NRC a formal
m 165 1 ' report of a finding of adequacy.
2 We estimate that it would take about six months after
'3- Massachusetts submits the final plans before we could_ receive ;
1 4 the final FEMA finding. .
5 our regulations do not require perfection in u- 6 emergancy plar.ning. In fact, it is not possible to guarantee ,
1 7 that amargency planning actions will protect all the people in 8 the emergency planning zone near a nuclear plant under all 9 accident corditions and in all weather conditions. Our ;
10 regulations recognize this reality, and they.only-require.a 11 reasonable'a'asurance finding that adequate protective actions
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12 can and will be taken in the event of a radiological emergency.
.; ~ . . .
- ! 13 We recognize that' emergency pl'anning is a dynamic 14 process', that perfection is'not attainable, that deficiencies 15 will occur from time to time, and that deficiencies can be 15 corrected while the plant is operating.
17 Ron Bellamy will summarize the improvements that have 18 been made in the plans and NRC observations of these 19 improvements.
20 CHAIRMAN ZECH: All right, you may proceed.
21 MR. STELLO: If the Chairman would excuse me, before 22 Mr. Bellamy starts, we have attempted tos try to -- and Mr. ,
o .
23 Ballamy will -- identify Jose things that were discussed with
(
24 you tuis afternoon that we have a comment on, and those will be 25 incorporated directly in Mr. Bellamy's part that he covers.
166 1 CHAIRMAN ZECH: All right. Thank you very much. You 2 may proceed.
3 MR. BELLAMY: Thank you, sir.
4 Although emergency preparedness was not an issue for 5 the Pilgrim Plant shutdown in April 1986, FEMA began their j 6' self. initiated review in September of 1986. The FEMA self- ,
7 initiated review was issued in August 198i, and identified six 8 specific planning issues.
9 Staff committed at the d'ctober 14, 1988 Commisslon -
10 meeting to continue to assess the progress being made to fully 11 resolve the FEMA-identified issues in offsite emergency 12 preparedness. -
~2 13 ' Subsequent to that meeting, some local of"ic'ials f
14 requested meetings with the NRC Staff to review information L5 regarding emergency plans, implementing procedures, facilities 16 and resources. TheExecutive.birectorofOperationsandother Douglas Hatfield, the Plymouth Civil 17 senior staff, called Mr 18 Defense Director, at his request on October 21, 1988, and 19 offered to have Staff members meet with him.
20 The Staff subsequently met with him and the remaining 21 six Civil Defense Directora between October 25th and November i
s 22 2nd, 1988. Discussions were held in the offices of the Civil _
4 23 Defense Directors and included tours of the emergency operating ,
I
-[ 24 centers for the five towns within the 10-mile EPZ and the two l 25 reception communities. 1
}
1 .
167 e
1 -
In two cases, selectmen were involved in these 2 discussions, and.that was Mrs. Thompson of Plymouth and Mr.
3 Mazzilli of Carver. And the representative of the 4 Massachusetts Civil Defensa Agency was present for the majority 5 of these discussions.
4 6 In addition, the Staff toured the Duxbury, Gurnet and ,
7 Saquish Beaches, with the head of the Duxbury Department of 8 Land and Natural Resources.
9 All the discussions with the local officials were 10 forthright and cordial. As a result of these meetings, a 11 review of correspondence since the October 14 meeting and Staff 13 , inspections, additional information regarding the status of 13 emergency preparedness was reviewed. The status of emergency 14 plans, implementing procedures and other supporting documents 15 for the five towns within the 10-mile EPZ and the two reception 16 communities, is consistent with the status presented by the 17 Staff on October 14, 19'88.
18 The emergency plan,. implementing procedures, and 19 shelter implementation program from Marshfield, Carver and 20 Kingston have been submittsd to the Massachusetts Civil Defense 21 Agency and forwarded to FEMA for a technical review.
22 The emerguncysplan and implementing procedures for _
23 Taunton and Bridgewater have been submitted to MCDA and
(
t 24 forwarded to FEMA for a technical review.
25 Since the shelter implementation programs are for the
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168 1
EPZ communities only, this program was not' applicable to 2 Taunton and Bridgewater.
3 The emergency plan for the Massachusetts Civil 4 Defense Agency has been submitted to MCDA and forwarded to FEMA 5 for a technical review.
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6- The emergency plan for Duxbury and Plymouth has been ,
]
7 submitted to MCDA and forwarded to FEMA for technical review. '
8 For Plymouth and Duxbury, the procedures are not 9 complete. All procedures in Plymouth have been drafted,.and 10 all except for three -- and these are for the Saquish/Gurnet 11 area -- monitoring and decontamination and the procedure for 12 Jordan Hospital'havs received department head approval.
, 13 For Jordan Hospital,'EPZ residents would not.be
. 14 treated and decontaminated there. This would be done at 15 facilities outside the emergency planning zone.
16 34 of the Plymouth procedures have received selectmen 17 approval, including the generic shelter manager procedure. The 18 33 individual shelter procedures which have been developed are l 19 modeled after the shelter manager procedure, and it is our 20 understanding that they do not require individual approval.
21 Of the remaining procedures, 20 have received the 22 Civil Defense Directors' and the Radiological Emergency -
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23 Response Planning Committee's approvals, and are awaiting I' 24 selectmen review and approval.
25 Four procedures --special needs officer procedure, as
169 li well as the three procedures that are awaiting department head
'2'- ' .
approval, have yet to be approved by the RERP Committee.
3 For Duxbury, all 38 procedures have been drafted, and n
4 all except for three -- and these are the procedure for the 5 selectmen, the town manager, and the public information officer 6 -- have been reviewed by the department head and are in various 7 stages of review by the RERP committee and the selectmen.
8 This information was provided by the respective Civil 9 Defense Directors during the meetings with the Staff. Minutes 10 of these meetings were documented, and sent to each Civil 11 Defense Director, who agreed that the minutes factually and ,
12 accurately represented the discussions. .
- 13 -
With respect to schools, the emergency plans identify 14 all th's schools, they assign responsibilities for notification, 15 transportation resources, and protection of the children for I
16 the five towns in the 10-mile EPZ.
Implementing procedures have been drafted for all 17 18 schools and approved at the department head level.
19 Subsequently the school superintendent for Marshfield has 20 indicated his dissatisfaction with this plan.
21 Several school committees have yet to approve the 22 procedures. The primary concern, as you have heard earlier, is _
23 the philosophy on how and when school children would be
( 24 evacuated. Some school administrators would idke to see the {
i
- 1 25 children sent home at an alert. This is in conflict with the l l
__om. __ _ . _ _ _ _ _ _ _ _ . _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ . _ _ _ _ _ _ _ - _ _ _ . _ _ _ _ . . _ _ . _ . _
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170 1 Commonwealth and local Civil Defense Director's position, as l '
2 well as the police desire, which is to prevent traffic from 3 reentering the towns once an evacuation is ordered.
4 If the children are sent home at an alert, then the 5 children will be at home, and if traffic cannot reenter the EPZ 6 after an evacuation is ordered, parents would not be able to l
l 7 'get hoine to pick up their children. ,
8 Conversely, if the school children are evacuated at 9 an alert, and a subsequent evacuation of the general public is 10 ordered, parents would be able to be reunited with their 11 children, who would already be outside the EPZ. The plans as 12 -
drafted call for the staging of transportation at an alert, and t
13' 'an evacuation of'the school children &t'a' site area emergency.
14 During the meetings with the Civil Defense Directors, 15 most did indicate that they would have the majority of people 16 necessary to implement the plans. But several of the towns are 17 short of volunteers to complete their staffing plans, primarily 18 for the second shift and non-technical positions.
19 Many of the positions that the local towns would 20 staff are not key positions, such as messengers and extra 21 communicators. The Staff believes that the plans could be 22 implemented with the existing resources. _
23 The Staff has obtained an update of the status of the I 24 offsite facilities, particularly the local EOCs. The Staff has 25 toured all of the local EOCs since the October 14, 1988
171 1 meeting.- Based on these tours, but primarily based on the 1 .- .
2 input from the civil Defense Directors, the status of the EOCs 3 is that the EOCS for Plymouth, Carver and Taunton are 4 functional.
5 The EOC for Kingston is ne'arly functional, with 6 telephone call routing problems noted and being corrected. ,
7 This EOC could be used in an emergency with' minimal difficulty.
8 The EOC for Duxbury is also nearly functional, with 9 selected communication equipment installation to be completed.
10 This EOC could be used in an emergency with minimal difficulty.
11 The EOC for the reception community of Bridgewater 12 has been renovated and communications equipment is being The pr'avious EOC, loc'at.ed in the,same building, 13 installed. ,
14 could be used by installing some. additional telephones.
15 The new EOC is better equipped than the old one and 16 could be used in an emergency with mi,nimal difficulty.
17 The EOC for Marshfield is considerably behind the 18 other EOCs, but is expected to be completed this month. The 19 old EOC is still functional and could be used in an emergency.
20 It should be noted that the condition of the old EOCs i 21 was not identified by FEMA as being a concern, and the new EOCs 22 are a significant improvement. ,
23 With respect to the notification system, significant
' 24 improvements have been made in the ability of Boston Edison to 25 notify the Commonwealth and local towns of an event. The
172 -
e 1 previous system relied on notification to the' state police 2 dispatcher in Middleboro, Massachusetts, and subsequent 3 relaying of information to the local towns.' The new digital 4- notification network has been installed and is bparational.
5 This system automatically rings down to the 6 Commonwealth, each local warning point, which is the police or .
7 fire department, which is manned 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, or to the 8 local EOCs; except, as I have indicated, for the Marshfield 9 EOC. And it also rings in the state police when the phone is' 10 picked up in the control room.
11 Additional capabilities at these facilities include 12 hard copy facsi, mile transmission, capabilities.
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13 During follow-up inspections, the Staff has obtained 14 specific information and an update with respect to .
15 transportation needs and providers. The form and content of i
16 the letters of agreement are now approved by the Commonwealth.
l 17 The letters of agreement address such issues as physical needs, 18 such as the number of buses and ambulances, mobilization times, 19 and driver resources.
20 To date, letters of agreement have been executed for 21 34 of the 3'5 transportation providers. These letters of 22 agreement represent transportation resources in excess of the ,
23 planned needs.
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- 24 -As an example, 954 buses have been committed in the l
25 letters of agreement that have been signed, whereas 407 are )
. i l
l
-l 173
- 1 'needed for plan implementation.
2 Similarly, resources are in excess for-the vans, the 3 lift vans, the ambulances, bus drivers, and the emergency 4 medical teams. l
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5 Training of these providers is continuing. 521 of 6 the bus van drivers and 131 ambulance drivers have received ,
7 training to-date. The Staff has audited several of the 8' training sessions for these transportation providers. The 9 training includes classroom training on radiation safety,.
10 dosimetry, basic emergency preparedness, and specific l
11 procedural assignments, and was subsequently.followed by ,the 12 : actual driving of designated transportation routas. ,
13 ' Based on this review, the staff concludes that E. ,
. 14 adequate training is being provided to the transportation 15 providers. Training for these transportation providers is 16 scheduled for completion by January 31, 1989.
17 The level of training in the performance of emergency 18 responders was not identified as being deficient by FEMA.
19 However, most Civil Defense Directors indicated that training 20 does remain a concern. A total of 530 lesson plans are 21 required. 148 have been forwarded to the Commonwealth; 379 are 22 in various stages of review; and three have yet to be .
23 developed.
24 To date, the Commonwealth has approved 14 lesson
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I 25 plans, with two lesson plans having been approved since July
174 1 1988.
2 A maximb of 5800 individuals, needing approximately 3 25,000 manhours of training, have been identified. of these, 4 2569 individuals have received 7811 hours0.0904 days <br />2.17 hours <br />0.0129 weeks <br />0.00297 months <br /> of classroom training 5 pertaining to utilizing the approved lesson plans.
6 Generally each individual receives training ,
7 consisting of three hours of introductory and overview 8 training, in basic emergency preparedness, radiation safety and d
9 -
dosimetry, and one hour specific training on implementing 10 procedures.
11 ,
of the training conducted to date,. approximately 80 12 ,
percent has been the introductory and overview training.
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1 13 Staff review of the implementing procedures subinitted 14 to FEMA -- submitted ,to MCDA and subsequently'y to FEMA -- shows 15 that they have been developed by position, and a simplified 16 checklist format with significant detail in the use of these 17 implementing procedures would be straightforward. With the few 18 exceptions previously noted for Plymouth and Duxbury, they have 19 been developed in concert with, extensively reviewed, and 20 approved by the department heads.
~21 The Staff believes that the department heads 22 responsible for implementing these procedures during an -
23 emergency.are familiar with the content of these documents, and
( 24 can be expected to direct their staffs during an emergency.
I 25 Although the training is not scheduled to be completed until J
1
.175 5 1 March 31, 1989, the Staff concludes that the emergency plans 2 can be implemented, so that adequate protection of public 3 health and safety is assured. .
4 For the special needs population, the Staff believes l
. 5 that the responsibilities for identifying, notifying and 6 carrying out protective actions have been adequately 7 incorporated into the applicable town emergency plans.and .
~8 implementing procedures.
9 The Civil Defense Directors have indicated to us that 10 each town has a special needs list, which was supplemented by 11 soliciting input from residents by newspaper advertisements.. ,
12 The Commonwealth and Boston Edison are working out detail 3 to
- 13 conduct an'additio'al'special n needs populat' ion survey.
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14 - Additionally', the public information brochure, which ,
15 will go to all EPZ residents, has provisions for allowing 16 special needs residents to identify themselves to town 17 officials. Although the Civil Defense Directors are not 18 convinced that all those with special needs have been 19 ' identified, they did not indicate that they thought there was a 20 significant unidentified special needs population in their 21 town'. These lists are confidential, and some individuals are 22 reluctant to be so identified. .
23 Nonetheless, the plans prov'ide that an individual can f 24 call the Civil Defense Office during an emergency and arrange 25 for transportation. Identification of the special needs
- ~ . . . - . . . . . . - - - . - . - . - - . . - - - - - - _ _ - - - _ _ . - - - -
176
'l- population, based on input from the Civil Defense Directors, is 2 a total of 686 individuals in the emergency planning zone. And 3 I do have that broken down by town.
4 This total number compares favorably to the expected 5 number of special needs population for the EPZ, which is 647 6 . individuals, based on an EPZ population of 70,274, and a total ,
7 expected percentage of impaired individuals of 0.92 percent.
8 These numbers are from the~ evacuation time estimate
- 9 which NRC and FEMA have reviewed, and the percentage is from 10 annex and of the local hazardous material planning guide, which
.. 11 has been supplied by-the Commonwealth to all towns.
~
12' - While the Staff recognizes that identification of 13 special needs population must occur on a continui g bas,is,'.
14 thes,e numbers indicate that the Commonwealth and EPZ towns are 15 taking positive steps to identify this segment of the 16 population.
17 An issue that the Staff has continued to review in 18 detail is the emergency planning, specifically the evacuation 19 concerns for the Saquish/Gurnet area and the Duxbury Beach 20 south of Powder Point Bridge.
21 The Saquish/Gurnet area is only accessible from the l 22 Duxbury Beach, but Saquish is jurisdictionally part of .
1 23 Plymouth, and the Saquish Association is actively working with 24 Plymouth officials to complete their implementing procedure.
25 The town of Duxbury, particularly the Department of
- 1 177 1 Land and Natural Resources, has the necessary resources to
~
2 effect an evacuation.of this area, and.this department head 3 believes a peak population for this area is 4000,'with 3000
- 4. being typical. - .
5 The head of the Duxbury Department of Land and j l
6 Natural Resources has stated that access is. limited from the*
7 Powder Point Bridge south to'500 vehicles, and is strictly-8 enforced.
i 9 Access to the Saquish/Gurnet area is limited to the 10 residents and summer population is less than 700. There are 11 very few year-round re,sidents.
12 The area of the road between Saquish and Gurnet has 13 iieen identified as impassable due to periodic high tides for-I 14 perhaps two hours during consecutive high tides for two days 1 i
15 each month, and this is during a full moon.
16 During these high tides, the roadbed floods to a 17 depth of one to two feet for approximately a 100 yard length of 18 the road. This should not present a serious impediment to most i 19 four-wheel drive vehicles, and in any event, the Staff and the 20 head of the Duxbury Department of Land and Natural Resources 21 believe that'the area would be passable on foot, and people i
22 could be picked up by vehicles on the Gurnet side, if ,
i 23 evacuation was necessary, f 24 The Staff has returned to this area twice since the 25 October 14, 1988 meeting, and our conclusions.are based upon O
e
178 l' direct observation of'the area and information provided by the 2 Duxbury head _of the Department of Lands and Natural Resources.
3 Finally, the Staff is aware that the public 4' information brochure has not been issued since September 1986.
5 An interim brochure was issued in December 1987. TheLlanguage in the upcoming public information brochure has been approved 6' .
. 7 by the Commonwealth. The brochure is being finalized, and is 8 on schedule to be distributed in December 1988.
9 And just this week, a siren test was conducted for 10 the emergency planning zone on the afternoon of December 7, 11 1988. Of the 97 sirens, 95 operated properly.
12 To conclude, the Staff has continue *d to review the
(- ' 13 progress toward resolution of the planning deficiencies identified by FEMk in their self-initiated review.
~
. 14 The 15 finalization of plans.and procedures and ongoing training of ,
16 transportation providers for the protection of school children 17 and transportation-dependent population continues to indicate 18 that offsite response plans include measures to protect these 19 groups.
20 Based on Staff meetings with Civil Defense Directors 21 and the head of the Duxbury' Department of Land and Natural 22 Resources, and on continuing Staff inspection activities, the -
23 Staff concludes that the planning deficiencies identified by 24 FEMA are r'esolved in the emergency plans, and that progress has !
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25 continued since October 14, 1988 to improve the status of
___._______._..____.______m___m.___ _
'179 1 emergency preparedness at the Pilgrim Station.
2 CHAIRMAN'ZECH: All right, thank you very much.
3 MR. MURLEY: .There are two regulatory matters pending 4 on Pilgrim. The first is October 15th, 1987, Governor Dukakis 5 and Attorney Genera 1 Shannon filed a petition pursuant to l
6 Section 2.206 of the Commission's regulations. The enforcement l
7 action sought by the petitioners included maintaining. Pilgrim's 8 shutdown pending the conduct of an adjudicatory hearing,' and 9 the development and certification by the Governor of adequate 10 emergency plans.
11 . Principal concerns raised by the petitioners included 12 , the adequacy'o'f the facility itself, management issues, and 13 emergency preparedness.
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- 14 I have. issued two interim responses to the 15 petitioners, on May 27th and October 6th, 1988. Petitioners' 16 request for NRC action has been denied, insofar as it relates 17 to the facility and to the management issues.
18 We are preparing a response to the petitioners 19 regarding emergency preparedness. Our assessment is 20 considering the current status and progress of emergency 21 preparedness.
i 22 second regulatory matter is that the last f,ull -
23 participation exercise at Pilgrim was conducted on September
- f 24 5th, 1985. Appendix E to 10 CFR Part 50 requires each licensee 25 to exercise with offsite authorities, such that the state and
- :180 1 local government emergency plans for each operating reactor
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2 site are exercised biennially, with full partial participation 3 by state and local governments in the emergency planning zone.
4 In late 1987, Boston Edison Company requested a 5 schedular exemption for the biennial exercise which should have 6 been conducted in 1987. This request was based on a 1 7 determination that the ongoing efforts by the Commonwealth and 8 local governments to improve emergency preparedness in the Pilgrim EPZ precluded their participation in an exercise in
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9 10 1987. This exemption, which expired on June 30th, 1988, was 11 extended in response to the licensee's request by a second ,
12 exemption, until the'and of 1988. ,,
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' 13 Bostbn Edi,sen. Company has, on December 8th,, jus't 14 yesterday, submitted a request to the NRC for a further -
15 extension of the schedular exemption to the requirements of 10 15 CFR 50, Appendix E.
17 In summary, then, our ' findings with regard to 18 emergency preparedness at Pilgrim are the following:
19 Based on the three previous successful exercises at 20 Pilgrim over the years, we believe the infrastructure to handle 21 emergency preparedness is still largely?in place. Most of the 22 local individuals who would take part in emergency actions, ,
23 Civil Defense authorities, police authorities, school !
[ 24 authorities, have been working closely with Boston Edison 25 Company in developing the revised plans.
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181-l' Therefore, we believe it is logical to conclude that 2 those individuals can and would implement the revised plans, even though the plans may be in draft, and even though there 3
4 has not been a full scale exercise with the revised plans.
i 5 The six planning deficiencies identified by FEMA, the l
5 NRC Staff has reviewed improvements'in the plans, and observed ,
7 some demonstrations of these improvements, and we have 8 concluded that the planning deficiencies have been resolved.
9 Our reviews and observations indicate that the 10 current status of emergency planning at Pilgrim is in fact
. 11 superior to that which existed and was considered acceptable 12 during the earlier period when the plant was operating. '
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13 In reaching thi's judgment, we have considered the .
14 emergency planning issues that were z'aised to us by emergency -
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15 planning officials in meetings with the NRC Staff, and some of 16 these issues have been repeated for the Commission here today.
l 17 Based on successful exercises at Yankee Rowe and 18 vermont Yankee within the past year, we believe that the 19 Commonwealth of Massachusetts has demonstrated the capability 20 to ranage an emergency at the state level. 1 21 Based on the findings above, then, we- bel 3. eve that there is reasonable assurance, even considering the lack of a I 22 .
23 recent exercise, that adequate protective actions csn and wi11
[ 24 be taken in the event of a radiological emergency at the 25 Pilgrim Plant.
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182 1 'Furthermore, wa expect that'the status of emergency preparedness will continue to improve in the coming weeks and 2
3 months.as Massachusetts and local officials continue to improve the plans in preparation for a full scale exercise.-
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5 MR. STELLO: Mr. Chairman, along with the conclusion 6 that Dr. Murley has provided you with in regard to emergency .
7 planning, I think_the Staff would like to reiterate two other 8 conclusions that I think are very important, relating to the 9 +
original reason the plant was shut down.
10 First is that it is our view that the physical state 11 of the plant, especially in light of the sig,nificant safety 12 improvements that.h, ave been made over the past couple of years
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13 - , these improvements, I might add,.are improvements that
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14 similar plants have not made. Pilgrim is. clearly leading in 15 this regard. But that leads us to believe that this plant is 16 now safer than the plant was when it was licensed.
17 Two,'the plant management team that is now on site, 18 in our view, is the best management team that wa have seen up 19 at Pilgrim, and we think it has all of the ingredients to be a 20 very successful team to run thet plant.
21 A couple more pointa that I think also ought to bear i 22 before I finally give you cur conclusion, and that's -- you've ,
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, 23 already heard that there is a very controlled and carefully 24 thought out start-up program which weuld probably span four to 25 six months, depending on the kinds of problems that they may i s
. 183 1 run into as they start up the plant, and since this plant has 2 been down for some time, I expect that they will have such 3.. problems to deal with as they start up.
4 Finally, the Staff intends to, as Bill has already 5 mentioned, augment very carefully the plant start-up. Our
- 6 oversight would be quite intense, including round-the-clock
. 7 coverage for all of the significant evolutions.
8 We would prepare reports at each of these hold points !
9 that Bill mentioned, giving our view of the status of the 10 plant, how well they have done, and Bill would normally prepare 11 these reports before the Staff would authorize the licensee to And if the Commission, wished, 12 move up to the next power level.
1, 13 , we'c'ould include at that point any report on the progress of 14 emergency planning consistent with those reports, and would 15 intend to provide those to the Commission.
16 The Staff, therefore, recommends to the Commission 17 that it authorize the Staff to go forward with this carefully 18 thought out start-up program. And that ends our presentation, 19 Mr. Chairman.
20 CHAIRMAN ZECH: Thank you very much.
21 Commissioner carr?
22 COMMISSIONER CARR: No. _
23 CHAIRMAN ZECH: Commissioner"Rogets?
I" 24 COMMISSIONER ROGERS: No. .
s 25 CHAIRMAN ZECH: Commissioner Curtiss? ,
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184 1 COMMISSIONER CURTISS: No.
2 CHAIRMAN,ZECH: All right. Well, let'me'just,say 3 thank you very much to the Staff. I would especially like to 4 thank each of those individuals that came from Massachusetts, 5 representing the local communities, and representing the State 6 of Massachusetts. They have come here today to present us with .
7 their views and with the current information that they have 8 available regarding the status of emergency preparedness.
9 These views of these officials will be carefully considered by 10 the commission, and'the views of the Staff will be considered 11 along with those views, as we attempt to come to a decision 12 regarding the restart of the Pilgrim facility.
,' 13 'The Comm.is'sion will not autho'rize restart.of'the 14 Pilgrim facility unle'ss we are satisfied that the reactor can 15 be operated safely, and that the health and safety of the 16 citizens living in the vicinity of the plant will be adequately 17 protected. That is our responsibility, and that is what we 18 will be attempting to decide.
19 I believe the question really remaining before the 20 Commission with respect to the Pilgrim restart is whether or 21 not we have reasonable azzurance that the emergency plans that 22 presently exist can be executed to protect the public in the -
23 unlikely event of an accident with offsite consequences at s' 24 Pilgrim. This is what the commission will be attempting to 25 decide.
185 1 As I stated earlier this afternoon, there will be no.
2- vote taken today.- I would ask my fellow commissioners to L _3 reflect carefully on what we have heard today, and with that, I 4 will ask my fellow commissioners if they have any additional 5 comments to make before we conclude our meeting.
6 If not, thank you very much to all of you. We stand 7- adjourned.
8 [Whereupon, at 6:30 p.m., the proceedings were 9 -adjourned.)
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CERTIFICATE OF TRANSCRIBER -
This is to certify that the attached events of a meeting of the U.S. Nuclear Regulatory Commission entitled:
TITLE OF MEETING: !1EETING WITH PUBLIC 0FFICIALS HAVIt!G RESPONSIBILITY FOR E!1ERGENCY PLANNING FOR PILGRIf1 NUCLEAR POWER PLACE OF MEETING: Washington, D.C. P L /. ilT
- FRIDAY, DECEf1BER 9, 1988 DATE OF MEETING:
i were transcribed by me. I further certify that said transcription is accurate and complete, to the best of my ability, and that the transcript is a true and accurate record of the foregoing events. ,
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Ann Riley & Associates, Ltd.
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12/9/88 SCHEDtilING NOTES TITLE: MEET!!JG WITH PUBLIC OFFICIALS HAVING RESPONSIBILITY FOR EMERGENCY PLANNING FOR PILGRIM NUCLEAR POWER PLANT SCHEDULED: 2:00 P.M., FRIDAY, DECEMBER 9, 1988 (OPEN) l CURATION: APPROX 2 HR$
PARTIC1 PANTS: Pustre OrrterAts
- ALBA THOMPSON, CHAIRMAN 15. MINS ,
BOARD OF SELECTMEN, PLYMOUTH *
- DOUGLAS HADFIELD, CIVIL DF.FENSE DIRECTOR
- GEORGE CAMERON, SELECTMAN'
- PATRICIA DOWD, CHAIRMAN 10 MINS
- BOARD OF SELECTMEN, DUXBURY
- CARL O'NEIL, CIVIL DEFENSE DIRECTOR
- HELEtt M. COPELLO 10 MINS ADMll!!$TRATIVE ASS!$ TANT /
DEPUTY DIRECTOR OF CIVIL DEFENSE, CARVER
- ROBERT T. REED 10 MINS TOWN ADMINISTRATOR, KINGSTON
,, - DANI'EL. MCDONALD, VICE CHAIRMAN 1.0 MINS
" - BOARD OF SELECTMEN, MARSHFIELD '
- DANIEL MCGONAGLE, CIVIL DEFENSE DIRECTOR
. - TOM BARLOW, CLERK- 10 MINS
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BOARD CF SELECTMEN, BOURNE
- CHARLES N0YES, CIVIL DEFENSE DIRECTOR
- ANN WAITKUS-ARNOLD, CHAIRWOMAN 10 MINS DISABLED PERSON'S ADVISORY GROUP DN NJCLEAR EVACUATION M/sSACHUSETTS OFFICE OF HANDICAPPED AFFAIRS l
- PtTER AGNES, ASSISTANT SECRETARY 10 MINS 1 OPJICE OF PusLIC SAFETY CO M NWEALTH OF MASSACHUSETTS !
- Ros!At J. BOULAY, DIRECTOR
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MASSA (NU$dTTS CIVIL DEFENSE AGENCY
- JOHN L. LOVERING, DEPUTY DIRECTOS MASSACHUSETTS CIV!L DEFENSE AGENCY ;
- BUZZ HAUStiER, DIPECTOR NUCLEAR SArETY EMERGENCY TRE9AREDNESS PROGRAM
- DAV!D OL' AID l
NR,[ 20 MINS
- VICTOR STELLO
- TOM MURLEY
- WILLIAM RUSSELL l'
- RONALD BELLAMY
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TESTIMONY' ALBA C. THOMPSON, CHAIRMAN PLYMOUTH BOARD OF SELECTMEN NUCLEAR REGULATORY COMMISSION ROCKVILLE, MARYLAND DECEMBER 9, 1988 I am Alba Thompson, Chairman of the Plymouth Board of Selectmen.
Also attending this hearing is Selectman George Cameron, .
Civil Defense Director Douglas Hadfield, and Marie Fehlow representing the Nuclear Matters Advisory Committee.
The Town of Plymouth welcomes this opportunity'to speak ,
directly to the Commissioners in a scheduled meeting. I have been told it is the first time in the history of the NRC that local officials have had such an invitation. If that is true, I applaud your decision that permits the voice of the people to be heard, and as the spokesman for historic Plymouth, I thank you. It is our feeling that this hearing should have, happened a long time ago and that it should have happened in the emergency planning area itself where the
. people most affected live. Our New England traditions of government.made that a reasonable expectation.
It is t'he responsib.ility of the Plimouth Board of Sel'ectmen to develop, implement, and approve emergency planning whether it be for natural disasters such as storms or radiological response (RERP) to an accident at the Pilgrim Nuclear Power Station (PNPS) . Emergency planning is a part of our public safety responsibilities that we take an oath to uphold.
These are serious commitments to protect the life and property of our citizens.
The Plymouth Board of Selectmen is composed of five persons elected to the highest executive body of the town. It has a wealth of personal experience to bring to bear in the area of civil defense. Three of us are veterans of active military service. George Butters is a retired officer of fire fighters. David Malaguti is in the construction trades.
Bruce Arons is a businessman. George Cameron is a fire and arson specialist. Alba Thompson has had experience in civil defense and large evacuations.
Ours is a hardworking Board, well equipped for a rational approach to emergency pisnning. In addition, it now has a ,
full-t'ime, trained Civil Defense ~ Director, Mr. Douglas Hadfield, who served the town for eight years as a vclunteer and was hired in January 1988 as a full-time Civil Defense Director.
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The'1985 radiological emergency plan for the Town was about a one-half inch thick 11x8 notebook. Our present draft plans and procedures now fill.seven 2 1/2 inch binders and there is more that must still come.
Yes, we have made and are making genuine progress in our effort to plan for radiological emergency. For us that is a prioritized, continuing task, especially in the face of repeated statements from NRC staff that re-start of the Pilgrim Nuclear Power Station is imminent' .
I cannot express too strongly that while Plymouth has come a long way in the. planning process, we have still a long way to .
go. We have aiheavy sense that we are not prepared at this time to respond effectively to a radiological accident of major proportions. Ours is not just a matter of facing multiple regulations; ours is a moral responsibility'to be
. prepared to assist our citizens - all of them under conditions of tension and fear.
I would now bring your attention to the map our Civil Defense Director has pinned up. There are several factors that make planning in Plymouth a complex and difficult process. In terms of area, we are the largest, town in Massachusetts, 103 square miles. . We have a coastline on Massachusetts Bay which
.is-17 miles long. That means we have no hope of egress (by sea) for almost 180 degrees.. Our year-round popula. tion is.
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45,000 an'd growing. We~have' grown by,2004 since the' Pilgrim,' !
Nuclear Power Station opened in 1972, and we are the fastest '
developing community in southeastern Massachusetts. In the warmer seasons of spring, summer', and' fall, an additional 20,000 residents join us. And because Plymouth is one of the nation's historical treasures, we receive over one million transient visitors every year.
Because of the great geographical spread of 103 square miles, we find five distinct groupings of population in what our comprehensive plan calls " village centers." Incidentally, ,
our center of population is in south Plymouth which is close l to Pilg;im Nuclear Power Station. South Plymouth is our l fastest growing residential district exacerbating the up - ;
dating of the planning process. At the moment South Plymouth i is served by one small fire station. The police station, the l Town Hall, and the Civil Defense headquarters are 12 road miles away.
i The Manomet section of Plymouth surrounds the Pilgrim Nuclear l l
Power Station and is also growing fast with numerous subdivisions and several popular beaches. The road network -
around Plymouth la deficient for our normal needs since Route -
3A is the country's oldest road, winding its way through the business centers of a string of towns leading to Boston. The expressway, Route 3, which parallels 3A to the west, is the main Boston to Cape Cod highway. Route 44 is the main 2
east / west route out of; Plymouth to Providence and New York. l It is'a' meandering, over-loaded antique with dangerous intersections at Route 3, which are currently the worst i traffic accident scenes in the entire town.
All three major evacuations routes are but two'-lane and .
suffer grid-lock during normal rush hours, during the summer visitor influx, and during our New England storms'. Our police and fire chiefs have serious concerns about response time given the conditions of our roads under normal conditions, let alone under , disaster conditions.
Our eleven schools are scattered throughout.our large area to -
serve the,various centers of population. We have We one of the have over i
1 largest school age populations in our state.
8,000 students and an educational staff of over 1,000. The task of. evacuation is tremendous, especially when one considers that six schools are within five miles of the Pilgrim Nuclear Power Station and the Manomet Elementary school is only 2.3 miles from the plant. ]
The entire EPZ has one major hospital. It is the Jordan Hospital of Plymouth which is 3 1/2 miles from the Pilgrim.
Nuclear Power Station. 'It has only one decontamination room d'edicated first to serving workers of the-Pilgrim-Nuclear i Power Station and only secondarily.the general citizenry of Plymouth. The admi'nis-tration. of the' hospital has not yet .
been able to pass approved. first draft plans to our Civil }
Defense Director.
To give you some idea of the scope of our plans, we must consider 9 summer camps, 16 pre-school day care centers, 8 nursing homes, 6 elderly congregate housing projects, the large Plymouth County Jail and House of Correction, a .
Massachusetts correctional institution, and a vast state park of 15,000 acres and 12 lakes whose daily camping and recreational visitors reach many thousands at various times.
I hope you have some idea of the complexity of our preparations for radiological response. '
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But I am sure you want most to know the present status of our 5 emergency plans. To encapsule in one statement - we have come a long way and we have a long way to go. ,
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We are proceeding with all speed commensurate.with effective planning. Our channel of progression begins with the work of
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our Civil Defense Director Hadfield with each town department or private agency. Once the department has a draft plan it The believes it can operate, the department head signs off. -
draft then moves to the Radiological Emergency Response Planning Committee for review. That committee includes a Selectman as chairman, the Civil Defense Director, the Police and Fire Chiefs, representatives of the Department of Public Works, School Department, Public Health, as well as three 3
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at-large citizens. The Committee reviews all. plans and, when satisfied, passes the draft-to the B'oard of Selectmen which
. studies and-moves toward approval. Obviously, anywhere along that.line of evaluation, the draft could be returned for additions and changes.
That aforementioned channel is a good vehicle for arriving at prudent decisions. However, there still remains a never-ending task for periodic up-dating, as is the case in all strategic planning.
At the moment, Plymouth has incomplete, untested, draft '
plans. The task of.public education has barely begun.
The slim general draft has had only a technical review by the Federal Emergency Management Agency (FEMA). The review was almost a useless " generic" matching against NUREG 0645. All ,
five EFZ towns received exactly the same " generic" report, hardly reassuring since our circumstances for planning vary considerably.
We are'in the process of writing implementing procedures (IP's) which, of course, are the specifics of responsibility and necessary actions for each department. We require 90 IP's. The selectmen have approved 34 in concept. No.pe of the IP's have been forwarded to the State Civil Defense
' Agency.
Key portions of the implementing procedures are still being developed. Police, Fire, Schools, Hospital, Handicapped Populations, and Saquish (a beach peninsula) are in various draft states. These absolutely essential aspects of our.
. emergency plans are incomplete or in a preliminary form. To summarize, we are working assiduously, but our radiological planning is far from being complete and therefore is not approved at the local level, has had no higher review, and is untested. Anyone who believes cur town is ready for re-start of Pilgrim Nuclear Power Station has not really examined our j ability to respor.d to nuclear emergency. The unanimous position of the Board of Selectmen is:
The Pilgrim Nuclear Power Station ought not be permitted to restart until there are effective, radiological emergency response plans in place which have been approved and tested.
The Board took this position based on sound reasoning:
- a. The Pilgrim Nuclear Power Station has had years of ,
troubled history reflected by numerous NRC fines, poor SALP evaluations, and management and maintenance problems.
- b. Radiological control continues to earn only a 3, the lowest numerical category of a SALP report.
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- c. The mounting levels of radioactive spent fuel rods and other highly contaminated debris in the on-site pool is a community concern.
- d. In the 2 1/2 years the Pilgrim Nuclear Power Station has been off-line, there have been a large number of recent, key appointments of personnel without any operational experience at the Pilgrim Nuclear Power Station.
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- e. Plymouth has had a full-time Civil Defense Director for one year only, his appointment having been made in January )
1988. A year of; concentrated effort has not been long enough to produce all the town needs in radiological planning, preparation of an emergency operations center, and marshalling of volunteers, to mention only some responsibilities.
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-f. No present drafts of plans or operating procedures have ever been approved by FEMA.
- g. No present drafts have ever been tested.
- h. Basic training is incomplete in most departments and has not even begun in others.
- 1. Ther'e are continuing problems o'f communication between Boston Edison and the Town of Plymouth.
I am hopeful that this brief outline rooted firmly in the collective wisdom of our staff has given you insights into our preparedness. We have not dragged our feet. We have not permitted the size of the problem to defeat us. Neither have we indulged in irrational and illogical fears. But we do maintain that the Commission has not had an accurate picture of our situation until today. That, we believe, is a result of an administrative process that never dealt equitably with the people who knew best and had the planning responsibility.
I recall with some bitterness and frustration one public meeting that gave Boston Edison 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of testimony time and gave the Town of Plymouth two minutes, and that came in the late afternoon just prior to adjournment. But that has been the usual tenor - long days of technical review with perfunctory attention to the public and little attention to emergency planning.
There has never been, to our knowledge, an NRC meeting in ~
Plymouth which var devoted to emergency planning, yet .
thousands of hours went into technical reviews of Pilgrim Nuclear Power Station and several public meetings were held by technical NRC staff. That is a sad ratio of concern.
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l The only NRC hearing on emergency planning was held here in
-Rockville on October 14, 1988.. To the' consternation of l Plymouth, we'were not even invited to testify. Our Civil Defense Director, who nevertheless journeyed to thr,t meeting, was not pernitted to speak., Yet Boston Edison had been invited to give its " current understanding" of the. status of radiological emergency planning in the EPZ towns.- What did-you expect -an objective and dispassionate view from a utility that was petitioning to go back on line after a 2 1/2 year hiatus and an expenditure of many millions of dollars?
Why was Boston Edison supposed to be a better source of information than we who have the responsibility for i developing and operating the emergency plans? Credibility is* *
- 1 indeed stretched by such a process.
As you know, the Town of Plymouth challenged the accuracy of much of the factual testimony presented at the October 14 NRC meeting, particularly pages 76 to 103 in the transcript.
Perhaps even more importantly we question the underlying assumptions and conclusions. They deny the reality as we know it.
After the October 14, 1988 two NRC staffers (Lazarus and Hogan) visited the Plymouth Emergency Operations Center (EOC) in the Plymouth Memorial Building. In the past three years they have been the only NRC staffers in the planning area who ever visited.our*EOC or ever consulted with us. Even those
/ .two. staffer.s didLnot have time to thumb.through"any of.our draft plans. Not a volume from our three foot' shelf was opened.
. . We find these circumstances extraordinary in the face of our vulnerability during radiological disaster.
In these 15 minutes, I have tried to bring to you the truth of what exists in Plymouth. I l' ave not, because of limits o'f
- time, been able to give you mneh Reyond the general picture.
I have not even been able to deal with the threat of radiological accident to lar.d and property, currently assessed at two billion dollars in Plymouth alone.
I. sincerely hope, however, I have conveyed to you the unanimous position of the Plymouth Board of Selectmen "The Pilgrim Nuclear Power Station ought not be permitted to restart until there are effective, radiological emergency response plans in place which have been approved and tested."
Ours is a' solemn responsibility to protect and uphold the public safety. We are not prepared or ready to do that in the event of serious emergency at the Pilgrim Nuclear Power -
Station. .
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l Essentially emergency planning decides who will deal with the L disaster and how they will operate. It also, by its time L frame, may decide who will live and who will die. These are not merely pieces of paper developed according to regulations. They are a blueprints for survival.
At this critical moment in the history of a troubled Pilgrim, all the other 45,000 pilgrims, the citizens of our precious historic town, are not protected by completed, or approved, or tested emergency plans. ,
Let the record show clearly that those of us, sworn to uphold
,the public safety of the Town of Plymouth, have so advised '
the Nuclear Regulatory Commissioners.
If, in the face of our arguments, you decide to re-start the Pilgrim Nuclear Power Station before we are ready to protect our ora citizens, then you must understand that you have over-ridden the judgement of'the traditional loca1 authority in the public safety area.
If that happens, it will be you who will be held accountable.
Yours is an awesome responsibility. ,
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SYMOPSIS, TESTIMONY OF ALBA C. THOMPSON, CHAIRMAN PLYMOUTE BOARD OF SELECTMEN w
NUCLEAR REGULATORY COMMISSION, ROCKVILLE, MARYLAND-DECEMBER 9, 1988
- 1. Preliminary remarka -
2.
Difficulties 31 emer-enev =lannine in Pivreuth
- a. Geography:
103 square miles, 17 miles of coastlinet largest town in area in Massachusetts
- b. Demographys 45,000 population year-round; 20,000 additional summer visitors per year; residents; 5 " village"one million transient-centers
- c. Road Networks main evacuation routes 3A, 3,. 44 subject to grid-lock under normal.conditionst all are
, two lane roads
- d. One hospital in the entire EPE: Jordan Hospital in !
Plymouth is 31/2 miles from Pilgrim Nuclear Power Station
- e. Schools: School age population of 8,000 and staff of 1,000 in eleven scattered schools f.
Full time Civil Defense Director has only been at work since January 1988
- g. 9 summer camps 16 preschool daycare centers; 8 nursing homesp,6 elderly congregate housing units; 1 Plymouth County jails 1 Massachusetts Correctional Instituter 1 Massachusetts state park
- h. Entire community is in the emergency ' planning zone
- 3. Presene m 31 Radioloalcal Emereency 11.ans -
- a. All 'in draft, untested form *
- b. Progression: Department Heads - RERP Committee -
Selectmen - state Civil Defense - FEMA
- c. General draft plan has had only technical FEMA review e
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Cestimony of. Alba C. Thompson, Rockville, Maryland 12/9/88
- d. :=plementing procedures:
- 22 needed; 24 approved locally in concert only; a have been forwarded to the State civil Defense
- e. Key' portions of master draft plan still in development stages: police, fire, schools, hospitalt handicapped population
- 4. Position ,gi Board ,gf Selecte3n g g m vears
- a. The Pilgrim Nuclear Power Station ought not be permitted to restart until there are effective, radiological emergency response plans in place which have been approved and tested.
- b. Reasons for offi'cial position (1) Years of troubled history of' Plymouth Nuclear Power Station (fines, SALP findings, management and maintenance problems, communications)
(2) Continuing poor SALP evaluation in some areas (3) Continuing poor communications between Boston Edison / Town of Plymouth H (4) Large number of recent key appointments at Boston Edison Company of personnel without any operating experience at Pilgrim Nuclear Power Station (5) Plymouth has only had a full time Civil Defense Director less than one year (6) No present drafts of plans or operating procedures have ever been approved by FEMA (7) No present drafts have ever bee.n tested (8) Basic training is incomplete in most departments and has not even begun in others -
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- 5. Closine Remarks G
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STATEMENT OF PATRICIA A. DOWD .
DUX3URY BOARD OF SELECTMIN NUCLEAR REGULATORY COMMISSION, ROCKVILLE, MARYLAND DECEMBER 9, 1988
- 1. Openinc' Remarks
- 2. Emercency Restonse Plannine Process:
A. Recognition of deficiencies in plan which led to withdrawal of approval by FEMA and the Town of Duxbury.
B. Establishment of the Radiological Emergency
- Response Plan Study Committee (RERP) and regular Civil Defense and Department Managers meetings.
C. There is a four-phase process in the development and approval of Implementing Procedures (IPs): draft, revised draft (includes School Committee reviev),
review by the RERP Study Committee, review and approval by the Board of Selectmen.
N'P're.sentstatusofDuxbu.ry'sPlan .
- 1. The draft plan (general' plan excluding Implementing Procedures) was forwarded to FEMA for technical review only. ,
- 2. Implementing Procedures (IPs) are in draft form only. They have not been approved by Department Managers school procedures do not have School Committee approval; IPs have not been reviewed by the RERP Study Committee.
- 3. The Board of Selectman has not reviewed or approved the IPs.
- 4. The IPs, contrary to testimony given at the NRC hearing on Oct. 14, 1988, have not been forwarded to the Commonwealth or to FEMA.
- 5. Introductory training has begun on radiation, dosimetry and decontamination. Completion is estimated at 1/2 of 1% by our Civil Defense ~~
Director.
- 6. Duxbury's Plan is lacking its most critical components a designated reception center.
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Testimony of Patricia _A. Dowd, Rockville, Maryland 12-9-88
- 3. Unicus charaeceristics of Duxbury which eresent obstacles in Emeroency Picnninc.
A. Road networks there is limited access to Rtas. 3, 3A and 14. Local streets are rural and not designed to accommodate traffic of evacuation capacity. , .
B. Duxbury Beach is a seven-mile barrier beach from which exiting traffic is limited to Gurnet Rd. and the Powder Point Bridge. This beach hosts residents, tourists and daily visitors. Problems associated with this area have not been resolved.
C. The school population consists of 3100 students of which three-fourths are concentrated in a " campus complex" four miles from the Rte.14/ Rte.3 interchange.
Busing capability available through the Town of Duxbury permits relocation of only one-third of the school population at any one time. Additionally, there are three pre-school / day care facilities of significant size and numerous sea 11er programs at scattered locations.
D. The year-round population is approximately 14,000 vith an adult-workforce that is predominantly, commuter. Planning' response for a' dispersed rather than concentrated workforce calls for management strategies not yet assembled and reviewed.
E. Municipal resources are limited. The Town of Duxbury has devoted maximum possible staff and volunteer service hours to Emergency Response Plan development.
- 4. Identified Needs by the Town to domelete Plannine Process A. Information is often erroneous or incomplete and frequently the requested information is not available
- 1. Supplemental bus services identification of transportation providers, number of buses available, driver commitments, allocation of bus resources for j
" contaminated" area.
- 2. Identification of a viable and acceptable
- reception center. '
- 3. Identification'n' of special needs population as l well as personne1 resources to supplement municipsi ,
staffingo 4
0 _ _ _ _ _ ______._____1* _____ w
Testimony of Patricia A. Dowd, Rockville, Maryland 12-9-88 B.. Resources:
- 1. Documented guarantees of additional emergency l manpower from State Police, Coast Guard, National Guard, other support agencies.
- 2. Completed training modules in all procedures for all applicable municipal officials and employees. .
- 3. Suitable training, demonstrations and tests of all EOC equipment, including not only the communication system but TDD provisions for the hearing-impaired.
- 4. Auxiliary power for town buildings used as shelters and for the EOC. -
C. Times
- 1. To complete procedures developed with our four-phase process. .
- 2. To complete training programs that are the only
- guarantee of making implementation of vritten pians an .
approximal goal.
'3.Todemonstrabatheeffectivenesso'f.plansand -
procedures through a program of field testing exercises.
- 4. To permit municipal managers to carry out ERP responsibilities without doing so at the expense of other public safety functions.
- 5. To witness consistent evidence of plant management improvements, safety provisions and good f aith eff orts on the part of BECO that are long overdue to the communities in the Emergency Response Zone.
- 5. Official Position of the Duwbury Board of Selectmen The Duxbury Board of Selectmen are officisily opposed to the restart of the Pilgrim Nuclear Power Station until radiological emergency response plans, including procedures, training and resources, are approved and tested. _
- 6. Cicaina Remarks .
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PATRICIA A. DOWD, CHAIRMAN DUXB_URY BOARD OF SELECTMEN Statement on the Status of Emergency Planning
)1 for the Pilgrim Nuclear ?over Plant. *
'k December 9, 1988 g
I appreciate the opportunity.to speak today on behalf.of my colleagues on the Board of Selectmen and the residents of
~Duxbury. This is the first time any member of my board or for thai matter, any public official'from Duxbury has been invited to provide information on.the status of Emergency Planning in-our town. In the testimony given on October 14th, there.vas clearly an implication that NRC staffers enjoyed a close working relationship.vit.h local Selectmen and appointed planning officials. Unfortunately, that has not been the case
, with the Town of Duxbury. Dr. Bellamy did visit our EOC after the September hearing in Plymouth in order to assess the radiation protection factor in the building. We are still waiting for a written opinion on that issue. In addition, two NRC staffers met with our Civil Defense Director on October 26th[ 12 days after your hearing, in order to discuss the status of our planning efforts. I assume this is what is referred to as a fair amount of interface with local officials.
Considerable progress has been made in up-grading our plans and procedures. However, we are continually frustrated when that progress is repeatedly misrepresented as an e
2 .
indication that those plans and procedures could be implemented in the case of an accident. Gentlemen, draft plans i
and draft procedures, which are not reviewed, revised and approved cannot be implemented.
As Selectmen we not only recognize that Emergency Planning is our responsibility, one we share with the Commonwealth of Massachusetts, but we take this responsibility ~
seriously. If, after presenting an accuarate analysis of our planning status and restating our position that the Pilgrim Nuclear Power Station should not restart until plans and procedures are approved and tested, you decide in favor of restart, the responsibility vill be yours in the event of an accident.
Emergency R'esponse P1anning Process'in'Duxbury:
,}
As our confidence in Bost'on Edison dimin'ished and'the '
risks of the Plant became evident, Duxbury took a good lock at the Emergency Response Plan and recognized that it could never-be implemented in its current form. We withdrev our approval as did FEMA in 1987. Duxbury appointed the Radiological Emergency Response Plan Study Committee to work with Department Managers to develop a viable, workable Plan. In the past two years, these officials and volunteers have
,expended an exorbitant amount of time to accomplish that task.
Duxbury's Draft Plan, excluding Implementing Procedures ,
j was forwarded to the Commonwealth and subsequently to FEMA for ~
technical review only.
There is a four-stage process in the development and approval of Implementing Procedures (IPs):
3
- 3. Drafts are received from Boston Edison and revised by the appropriate Manager.
- 2. The revised drafts are reviewed by all the Managers and rev'ised es many times as necessary. At this stage, the school procedures are also reviewed, revised and ultimately approved by the School Committee.
4
- 3. IPs.are reviewed by the RERP Study Committee. At this stage information on supplemental resources needs to be available. Recommendations are made to the Selectmen.
- 4. The Board of Selectmen review al'1 segments of the plan and either approve or request additional revisions.
There are 38 IPs for Duxbur'y. Of these, 35 have been developed and are currently in the second stage of the proc,ess. FoWr of the 35'have undergone review but'still have unanswered questions. Th'e school procedures are'under review but*have not yet been presented to the School Committee. The RERP Study Committee has not completed their review of any of
, the procedures and in fact, has not received most of them.
None of the IPs have been submitted to the Board of Selectmen for review and approval.
This progression takes a considerable amount of time but it is the core of the plan.and must be accomplished in order to achieve our goal of developing a viable plan. Although '
none of the procedures have moved through all 4 phases, this l process is approximately 15-20% complete in total.
The Implementing Procedures, contrary.to the testimony given on October 14th by Dr. Bellamy, have not been forwarded to the Commonwealth or to FEMA.
4 Introductory training has begun in the areas of radiation, dosimetry and decontamination only. Training cannot begin on those IPs unique to Duxbury until the'IPs are revised. Completion is_ estimated at 1/2 of 1% by our Civil Defense Director. !
, Duxbury does not ts # a designated, approved reception center. If've'were forced to implement a plan at this time, we would be implementing a plan absent its most critical component: a destination point for the evacuating public. The center currently under consideration by the State is not equiped at this time and is unacceptable to Duxbury.
Unique Characteristics of Duxbury which present obstacles in
' Emergency Plannings, ,
Duxbury,h'as approximately 150 miles of public roads'.
Outside of limited access Rte.3 and State'Rtes.14 & 3A, local '
streets are rural-narrow, curved-and are not designed-to accommodate traffic generation of anywhere near evacuation capacity.
Duxbury Beach (. inclusive of Gurnet and Saquish) is a seven mile barrier spit from which exiting traffic is limited to Gurnet Rd. and the Powder Point Bridge. No viable, manageable system of moving an estimated 9,000 persons from this facility exists. Procedure's uniquely suited to this 1 resource and its limited access are central to a credible
. . 1 emergency response plan. Development of these procedures is incomplete if not in its infancy at this time. ' I l
Thirty-three percent of the population of Duxbury
. 5 concists of 0-18-yoar-olds, with approximately 3100 studanto-enrolled in the public schools. Busing capability available through the Town of Duxbury permits ~ relocation of only one-third of the school population at any one time. Contrary to testimony given on october 14th, it is currently impossible to transp' ort all students in a single trip. The availability of information on supplemental bus resources is, at best, sketchy. We have been able to identify only one carrier for Duxbury for 12 buses and the carrier is stationed in the Worcester area, 70 miles away.
Additionally, there are three pre-school / day care facilities of significant size and numerous smaller ' programs at se ttered-site locations. Procedures adequate to ensure the safe transit of"this under-18 population sector are not l
+
finalize,d.
The year round population is approximately 14,000 in a
. community characterized as " bedroom"--that is, with an adult workforce that is predominantly commuter. An estimated 65% of the Town's workforce commutes daily to urban employment j s
centers within one to two hours of Duxbury. Adequacy of plans I to manage relocation of a dispersed workforce during l
\
peak-pericd commute times, or conditions akin to peak-period !
J that would arise from workers attempting to unite and move families during an event, is unknown at this time. Planning response of a dispersed rather than concentrated workforce -
calls for different transportation management strategies not yet assembled and reviewed.
1
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6 Municipal rocources are limited. The Town of Duxbury has devoted maximum possible staff and volunteer service hours to Emergency Response Plan development. The Fire Chief serves as Civil Defense Director, and all public safety personnel carry ERP responsibilities as ancillary to their daily workloads.
BECO has,provided emergency operations center and equipment, but training in equipment use (i.e. telephone communications -
system) is inadequate to make the facility functional. Town department heads meet weekly with Edison planners to devote time to ERP development; to suggest that a plan is complete or procedures are at an implementation stage is voefully premature.
Identified Needs by the Town to Complete the Planning Process" n
Information'made available is often erroneous or, incomplete and frequently the requested information is not available at all. Information needs are:
- Supplemental bus service for transport of school and/or special needs populations: identify transportation service providers, number of buses to be available, assurances of i
driver commitments, allocation of total bus resources for
" contaminated" areas. .
- Identification of a viable and acceptable reception center.
- Identif'A4 tion of special needs population as well as resources to supplement municipal staffing. ~
l Resources ~'needed to even consider implementation of a plan for Duxbury are:
L_ _ - - _ _ _ _ _ _ _ _ . . . _ - - __
7
- Documented guarantees of additional emergency manpower from State Police, Coast Guard, National Guard, other support agencies.
- Completed training modules in all procedures for all applicable municipal officials and employees.
- Suitable training, demonstrations and tests of all EOC equipment and other components of the evacuation process, ,
including not only the communications sy' stem but TDD provisions for the hearing-impaired.
- Auxiliary power for town buildings used as shelters and for the EOC.
I am here today to ask for time, time :
- To complete procedures development in accordance with
~
our four-phase process, .
- To comp 1ste trai'ning programs. that are the only '
guarantee of making implementation of written plan an approximal goal, .
- To demonstrate the effectiveness of plans and procedures through a program of fi~ eld testing exercises. We do not believe that testing in another region is sufficient and there has not been demonstrations of bus and ambulance drivers for Duxbury.
- To permit municipal managers to carry out ERp responsibilities without doing so at the expense of other ;
~
public saf,ety functions, I
- To witness consistent evidence of plant management improvements, safety provisions and good-faith efforts on the l
5 8
part of BECO that are long overdue to the communities in the Emergency Response Zone. The water spill incident a couple of weeks back certainly did not strengthen our confidence in Edison when I received phone calls from residents before the Civil Defense Director was notified that a. newsworthy event
, had taken place.
Official Position of the Board of Selectmen: '
The Duxbury Board of Selectmen are officially opposed to the restart of the Pilgrim Nuclear Power Station until radiological emergency response plans, including procedures, training and resources, are approved and tested.
Regardless of your decision on restart, Duxbury officials and v"olunteers will continue to work with Boston .
' Edison to reach our goa1 of producing a plan which will provide for the health and safety of'our residents. As a
, matter of fact, we have recently accelerated our efforts. I am here today to ask that you give us sufficient time to protect those whose lives will be most affected if Pilgrim is allowed to restart. ATTHg ftp;E.
g e e
wm CL,e G! M Carver Massachusetts 02330 '
Teleonone 666 2561 .
l December 2, 1988 i
l i
l
- 4. l.1ndo W. Ztch, Jr.
\
Chairman ,
i U. S. Nucleu Reculatoru Comunion
~
Washington, D.C. 20555' pur Mt. itch Thank you for de invitation'to participate in de Conni44 ion mast-ing regading' t.hs Pilgrim Nur1*** 'Penst Station. Ths following is 1 brief (summary Program RERP) foroft.he thsTown
+'=*"iofof. de Radiologist Encagsney Rupones Carva.
1 Emucencu Runon4e Plans (RERPl ==d innlamentina Proc *d"*u (194) l The Carvu RERP was submitted to MCOA and FEM for an initia informst technicat Alvino in January af t.kis ysar. Mc0A and fen subssqusnt- -
ly ptovided connent.4 tAat have been incorporated into the plan. i 1&*=nting proceduu (TP's) was deusloped win input paavided by variou town agueiu and 044 vat.L fariflflu such u nauing homu, daycu t ed=+=*2 and camp 4. In all 4r IP'4 wut developed and revicatd by town ag==efu and psivata far!!!*!*4.
A Shn>ter6ctI l ~M 11e and p44vatet*=>*=*!an ba>>d1--e Program been 'dantified ha4 baan deu and agasad
, g,o es }->+=*s ilth tons alut *= din' = "** kits in place.
Co==r+a-f appaaval of plan 4 and pesanda==+ ha4 6ssa given by de variou agenciu in the tant in order for et plana, ptocadstu and ik=>+=t p4ogram to be ia">t**d to McDA and' FEE for an informs 4
'**k=1*=1 Asvl,un.
Mtet- copiu of the Carvu RERP, !=p/ mating Procadnasa and Shd##E *-
ing I-'-=>+=*!an Prog 4mm st.ong with 4ap-a t!== documsate ws44 Aub-alt. tad to MCDA for FEMA on detabu It,1988.
Ik. Lo.ndo W. :ech. Jr., Chairman .Pags 2 U. S. Nuc.Lur Regalstory Comnudon Dusmber 2,1988 Final acuoval of the RERP and imcLamentino Proceduu by the town of Cavu wiLL not be accomplished until ah auciss hu besn con-
. ducted.
. Facidties a.nd Eauiomtnts i
i The Emugency Opuations Cutu is usenti-Hy complets. Sont squip-ment is s dLL on ordu.
Trsinino:
Appodmately 83 percent of emergency resconss pusannel in t.he town of Cavu have receiw.d some form of trarnino. We unset to havs aLL personnel complatoQ' trained in t.hs first qhartu of 'ntxt ytu.
Summaru:
Our response caeability has greatly impoved ovu t.hs Zut 13 months.
Although a r preenduss, fcu ittu un ou ++- 41=
sn livs (ann bsgan training and andou ans.g, to' tutwsourhsus usftsd'nno
- =rhH1tlu ounud and unannounesd) d*1He and A full-scals *****i".
i Sincast),
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e
,--2
^& _
~ Frans R. Matuus '.
t'k-i>===
- Board of Salutasn i i Civil Defass Director em e
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1 gh T ~~
TOWN OF KINGSTON, MASSACHUSETTS lJIfice of' ,
- ' THE SELECTMEN town house 23 GREEN STREET
!!'iNONE M17) 585 4445 KINGSToN, MA 0:3.'4 TESTIMONY OF ROBERT T. REED Town Administrator, Kingston, Massachusetts i
NUCLEAR REGULATORY COMMISSION, ROCKVILLE, MARYLAND December 9, 1988 .
Good afternoon:
M'y name is Robert. Reed and I am the Town Administ,rator,of Kingston,' Massachusetts. I am"here to offer brief remarks on behalf of the Selectmen, Civil Defense officials and citizens of the Town of Kingston.
Kingston is the town immediately to the. north of Plymouth, the town in which Pilgrim Nuclear Power Station is located.
Kingston has a population of approximately 8,000 and, for purposes of planning, is included in its entirety within the Pilgrim ten-mile Emergency Planning Zone.
Because of the plant's, performance record in the past, and the -
proximity of Kingston to the site, the restart of Pilgrim Nuclear Station is a matter of great concern to the people of Kingston.
'2 i?
L Last;"ovember 8,-a majority of the citizens of~Kingston who l
m Voted' supported.a statewide referendum question which called for no.further generation of. electric power by commercial nuclear plants in the. Commonwealth by means which result in the production of nuclear waste.
At'a.special Town Meeting in May of 1987, the town voted to' '
request the' Governor and. Attorney General of Massachusetts to '
take whatever legal action appropriate to delay'the restart of Pilgrim Nuclear Station until the Massachusetts Department of Public Health completed'a study of the' cancer incidence in the towns cf_. Plymouth, Kingston, Duxbury, Marshfield'and Scituate.
, Finally, the.Kingston; Board.of Selectmen, record.ed their official position on,restar,t: they are opposed to the restart' .
of^ Pilgrim Station until an approved and tested Radiological Emergency Response Plan is in place.
History In July of 1987, the planning process was begun on the Kingston Radiological Emergency Response Plan and since that process was initiated, the plan itself and implementing procedures for it are considerably better than they used t'o be. Town officials have put in countless hours of planning, training and procedure development. Agency heads, private shelter owners, school ~
officials and volunteers all dedicated a great deal of effort toward completing a draft version of the response plan,
3 detailed implementing pr'ocedures, consisting of 70-75 checklists, and a shelter implementation program. .All of these documents were submitted to the State Civil Defense Agency and the Federal Emergency Management Agency for technical review on October 12, 1988. We are awaiting feedback from those agencies as to the appropriateness of format and content of the documents. However, it must be noted that these plans and procedures have been approved by the town "in concept" only, i and there remain some planning, procedure and resources problems which must be addressed before formal approval can be considered.
Implementing Procedures ,
For instance, it is the policy of the Kingston Elementary School Committee to dismiss st'udents early when there is a snow emergency. The committee wishes to follow the same procedure in ,
a radiological emergency, but the policy is at odds with the draft implementing procedure for schools, which instead calls for bringing in buses and conducting a " precautionary transfer" of schoolchildren to host schools outside the nrea. The school committee's wishes also are at odds with the recommendations of State and utility planners. Discussions to resolve this issue are underway, but no agreement has yet been reached. In ,
addition, the implementing procedure for Kingston's regional l
high school.is stil'1 under review by that school committee, which includes representatives from three non-Emergency planning Zone towns. The school itself contains students from
4
~
L outside-the Emergency Planning Zone, and specific provisions
) -
for the parents of those children have not yet been outlined. -
There is also a conce'rn for the special needs population of Kingston and.what sp,ecial measures would be taken for their ,
safety. As yet, identification of the special needs population is incomplete. -
Traffic Management The Kingston Police Chief objects to some premises set forth in the traffic management procedures. He feels strongly that no .
one should be permitted to enter the town once an evacuation is ordered. His objections conflict with the current Evacuation Time Estimate, which states.that the borders of the town are not to be cohtrolled for two hours so that residents may get in ~
and out to adjust.for their own evacuation needs. The police chief feels this strips him of maximum control of the town,,and is another example of a procedure in need of attention.
Recently, work has begun on the construction of a large shopping mall in southeast Kingston expected to be completed in 1989. The company developing the mall has proposed and is initiating work on the upgrading of five different traffic intersections to handle the an'ticipated increase in traffic near the site of the mall. An item like this one raises some concern about our radiological emergency response plan: if construction needs to be done along our roads and intersections reconfigure in order to service an influx of drivers out on a e
5 l shopping spree, how can we assume the current roads _are l sufficient and safe enough to handle the volume and type of l traffic expected during a nuclear evacuation? The mall is not
_the only large project proposed for Kingston, already a rapidly growing area, and traffic congestion is anticipated to increase each year.
Personnel A resource concern closely aligned with traffic management is that additional coordination is required among the Kingston Police Department, the State Police and the County Sheriff's office: there is a question as to whether the town police force can manage to staff all the traffic and access control points as' s igned 'to theb'. Our police chief siys there is.not_enough '
1 cruisers to man all the traffi"c and access control points.
School, officials are concerned whether a sufficient number of bus drivers will respond to evacuate the school children.
Recruitment is still needed in order to staff all the civil i
defense positions at least two deep to ensure 24-hour coverage. l We are still in need of an alternate Civil Defense Director to 1
take over when the designated director has done a 12-hour l l
shift. I o ,
t e i
6 Ecuipment and Facilities c The planning process has also uncovered some equipment needs, l such as a functional Emergency Operations Center, traffic and access control equipment, and communications equipment. This equipment is vitally ne'eded in order for the town to protect its citizens. Although the utility has provided a great deal of this. equipment, it is not a'11 in place. Other equipment issues still unresolved include the fact that only two telephone lines ex'ist into the Kingston Eiementary School, the regional high school or the school administration building. The telephone system at our Emergency Operations Center is not fully operable at ,this point, either. We need pagers fer all our key people if we want to' feel'confid,ent that we can notify.them.at any time.
We still n'eed public address systems for police and fire vehicles, traffic control barricades and cones,. decontamination kits. In addition, it is believed that the number of shelters for transients is insufficient.
All these equipment Lnd facilities needs illustrate the overwhelming expectations placed on a municipality's limited resources.
I Training
~
Perhaps the single most important element in the emergency response plan is training, and in many departments the training remains incomplete or has not yet begun. The police, fire and highway departments are not yet fully trained. ,
No training
O 7
sessions have been held for the 100-plus teachers and staff at the regional high school; a training session was held at the elementary school, but there was very light attendance. Our Civil Defense Director is not comfortable that a staff yet exists which is sufficiently trained to coordinate the Emergency Operations Center. There are dozens of nursing home, day care, camp and civil defense staff yet to train. Many of these people are not yet aware that they would have roles to play in an eme'rgency response plan, and only training can rectify that situation.
We recognize that training is an ongoing process, and will never be complete, but our concerns are related to training on
'the implement $ng procedures. Some' people have not deen fully informed of their duties within those procedures, and we have no estimates of when the . initial training sessions will be complete. Without this basic type of training, we can have little confidence in our emergency response plan.
A Test of the ' Plan Finally, and in agreement with the sentiments of the l
surrounding towns, the Selectmen insist on participating in and judging a full test of the plan and procedures. We would like to see a' simulated example.of an emergency at Pilgrim Station.
We would,like to see many facets of the plan demonstrated:
l roster notifications, communications equipment tests, state d
j L. ,
8 participation, facility operation and a few buses running .
pickup routes and precautionary transfer routes. Only after a successful test of the plan and implementing procedures will we ,
feel public. safety is well served. One.might use the analogy of a football play drawn on a blackboard but never run in practice: we may have the X's and O's, but we have no idea how the team will work together.
Conclusion We do know, however, the team works well together in the planning process because throughout the process Kingston town officials and many citizens have' worked diligently on the ,
emergency respo'nse program. They have offered their time on it not in the expectation that it would prevent injury or loss of life, nor that it could guarantee the safety of everyone in Kingston, but in the belief that having a well-thought-out emergency plan is far better than having no plan at all. They have been largely engaged in an Act of Faith during this process, and as such, have cooperated with all parties to the best of their abilities, but without benefit of the knowledge that the plan really works. We do believe that the state of Kingston's emergency preparedness has been increased by the level of planning that hac been accomplished through the -
efforts of town officials. However, we feel that the issues discussed here regarding the implementing procedures must be addressed, training must be completed, equipment must be put in l
l
_ _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ _ _ _ . _ _ _ _ _ _ - . . _ _ _ _ . - - . - - - - - . - _ _ - - - - - - - ~ - - - - - - - - - - - - - - - - - - - - - - - - '
.e place and a full-scale exercise must be conducted.'We believe that an exercise wirl be the most realistic manner in which a-determination can be made as to..the readiness of the radiological emergency response program. In view of those sentiments, the Board of Selectmen of the Town of Kingston believes that the Pilgrim Nuclear Power Station should not be
. allowed to restart until an exercise has been conducted.,
On behalf of the Town of Kingston, I would like to thank you for this opportunity to express the town's views on the status of radiological emergency _ preparedness in the town.
I Thank you.
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TOWN OF MARSHFIELD l 870 MORAINE STREET
-g - 4,,, f. uansecto. uAssac>.useTTs oaoeo 617 8 37 5141 .
December 6, 1988 .
United States Nuclear Regulatory Commission WashinEton, D. C. 20555 l Commission Members: .
As the Town of Marshfield's representative from the Board of Seleotmen, I would like to thank you for this opportunity to familiarize you with the status -
of our emergency planning. The process of emergency planning for Marshfield has been a long, arduous and incomplete process. Our Emergency- Response Committee has worked prudently with Boston Edison personnel andl our many public service groups to develop an Emergency Response Plan that suits the needs of our community in the event of an sooident at the Pilgrin puolear Power Station.
Throughout that developasntal process, the Board of Seleotmen has actively reviewed the plan with comments on a number of ooossions. On August 8, 1988, the Board unanimously took action on the ourrent status of the Marshfield Plan, and in' a letter to ont Emergency Response' Committee Chairman, Deniel A. NoGons- -
gle, ,the Board' clearly and in no uncertain' terms stated its position relative ,to the. evolving nature of the plan. -
{
I would like to read into the record the contents of that letter of August 8, 1988, which is attaohed to my statement.
!Atter!
The Town of Marshfield has, in every capacity, acted in good faith to address ,
the needs of our community in the event of an emergency at Pilgria. It was diz- l tressing to have read the transcript of the September 29, 1988, ' Review of 4 Proposed Restart of the Pilgria Nuclear Power Plant Meeting held in Plymouth, Mass.", at which time in his discussion of the plans to date, Mr. Ronald Bellamy can be quoted as sayings "First the Tom of Maraktield. The draft implementing procedures, a shelter implementation program and a cost reference of the FENA- identified deficianoles with sections of the plans and procedures that address resolution have been approved by the Seleotama....'
It is important at this time, Commission members, and with all due respeet for Mr. Bellamy to set the record straight. Our position on the status of our plan can be no more succinctly stated that to re-quote our August 8th oonoornas -
"It must be clearly understood that the Marshfield Deard of Seleotaan has NOT approved or endorsed the plan, and we still have anjor reservations regarding its viability. Asalizing that neither the Board of Seleotmen nor any other official in Town is adequately trained to skillfully evaluate all the merits and deficien-oies of this proposal, we feel the time has come for the M.C.D.A. and F.E.M.A. to have direct professional input.'
_________._____..._.__-._.m_ ___-_ _
t~nited States Nuclear Reguintory Commission December 6, '988 Pass 2 Mr. Chairman, it'aust be noted that we in the Town of Marshfield have put our best efforts forward to address the needs of our community for an incident of unknown magnitude and of which there is little understanding or consensus. The position of our Board has been that of cautious diligence. We are deeply concer-ned that there are remaining major structural concerns within the EPZ as to the procedures necessary to ensure the safety of our school children, waterfront user groups and' the disproportionate number of elderly thst have made this zone their home. -
Furthermore, as Selectaan representing the entire town, I feel it is ludi-orous to entertain the notion that that the 905 of the Town of Marshfield that reside or do business outside the EPZ and that have not been addressed in our plan will not react to the deluge of media response to an sooident at the Pilgrim Nuclear Power Station. We, therefore, must join our State Department of Publio Safety in calling for protective actions "on a whole town basis". This will pro-vide a conservative margin of safety, and it will avoid contasion regarding vnich parts of the community need to act.
Mr. Chairman, there are other issues on the periphery of the Pilgria debate that are also of deep concern to many df the citizens of Marshfield when discus-sions of re-start occur. Some of these are well documented.as major deficiencies in the operation of this facility. We in Marshfield have little technical exper-time to assess the management capability of Boston Edison, the reported high cancer incidence in the five-town region or the reported.high risk of failure associated with the GE Mark I conf,ainments like Pilgria. ,
Mr. Chairman, you and your commission hold the legislated duty and 'responsi-bility to act prudently and responsibly to ensure the uncomproatsed public health and safety of our citizens as a v, ital component of re-start considerations.
Finally, Mr. Chairman, at this time we must support the overwhelming call from our congressional delegations of Senators Kennedy and Kerry, Congressman Studds, Governor Dukakis, the Massachusetts Department of Public Safety, the Has-sachusetts Civil Defense Agency and local officials for a full-scale exercise of off-site plans.
A plan that doesn't work is not a plan! -
4 Thank you for your s1N*re concern for the res3 dents of Marshfield.
Sincerely, l
w 5 m --
Daniel P. MoDonald -
Yios Chairman -
Board of Selectaan Marshfield, Massachusetts DTM:1 ene.
c g7 TOWN OF MANSHF1 ELD m o e . . .rr rw- a,,f f , ; wasmuks.ma===-serru omesa -
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7
. . . . . en ess stas ,* *
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August 8, 1988 Mr. Denial A. McGonagle, Chairnan Emergency Response Committaa 107 Stagecoach Drive Marshfield, MA 02050
Dear Mr. McGonagle:
The Marshfield Board of Selecensa has reviewed the draft document titled " Town of Marshfield Radiological Emergency Itasponse Plan for Pilgrim Nuclear Power Station".
We have affarad suggestions and have agreed to forward tha plan for further review and con:=ent to the Massachusetts Civil Defanse Agency and F.E.M.A. It must be clearly understood that the Marshfield Board'of Selaerman has not approved or endorsed the plan, and we still have major reservations regarding its viability.
Realizing that neither. the Board of Selectmen nor any other official in town is adequately trained to skill. fully evaluate all the maries and deficiencies of this proposal, we feel the time has come for the M.C.D.A. and F.E.M.A. to have direct professional input. -
The issues of greatest concern to the Marshfield Board of Selectman are as follows:
- 1. Adequacy of ' evacuation to sallesley an opposed to Weymouth Air. Base or University.of' Massachusetts in Dorchestar or other more appropriate sitas.
- 2. Concerns relative to actual traffic flow in a worst case scenario during evacuation. 3
. 3. Alt! ough the plan is specific concerning the Governor Winslow School-(w' thin the 10 mile zona), we believe general. chaos could occur at the 3
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of> r schools as well,with parents rushing to pic.k up childran.
4.
We need greatar clarification of the ongoing ' training cinacabla and ;
agenda with more accantion given to inevitable personnel changes.- .
- 5. We have serious doubts regarding the willingness of local unions and I other amployes groups to remain at their posts and to cooperata during -
the evacuation. .
Under no circumstances can this Board approva this document in good conscience unles.
and until a written letter of agressant is received from involved employee groups accepting their colas in the evacuation process and their expressed wNa-assa to perform or in the alternative, personnel being providad by B.E.C.O. Additionally, any approval by this Board would require a concurrent endorsement by our yet-to-be-hired "Emargency Rasponse Consultant". Although va agree that the current plan demonstrates a good faith affort by B.E.C.O., we faal any support for it would be pr nature at this time. - -
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We ask that, ycu forward this draft co the appropriate stata and federal agencias for i their constructive analysis.
Very ly yours, Ricnara E. Levin f /b - %
_a o n'F. MacMahon N Daniel T. Mcdonald Chairman m
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OFFICE OF CIVIL DEFENSE BOURNE, MASSACHUSETTS The town of Bourne is located in southeastern Massachusetts, approximately 55 miles from Boston. It is comprised of 26,200 acres of land and 300 acres of fresh water. It has a year round population of 15,365 and a summer population of 35,900 based on 1985 censuses. Bourne is bordered on the north by the town of Plymouth, the east by Sandwich, the south by Falmouth, and the west by Wareham. Bourne has a 32 member police department and a 39 member fire department. The town center is located approximately 14 miles from Boston Edison's Pilgrim Station. One public school is located within the 12 mile radius, and three others within 15 miles.
A small portion of Bourne located at the northeast corner of town lies within the 10 mile radius of Pilgrim. Presently there are eight existing homes and construction has begun on a 77 unit housing development within this 10 mile radius.
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. Bourne has the distinction-of having the Sagamore and Bourne Bridges. These two highway' bridges, built in 1935, provide.the only mieans for the general public to travel to and from Cape Cod.
According to figures provided by the Cape Cod Planning and Economic Development Commission, Cape Cod has a year round l population of 170,600 and a summer population of 500,000 (1986 Census figures). On the average day, the Sagamore and Bourne Bridges carry a total of 64,442 vehicles to and from Cape Cod.
In May 1987, the Town of Bourne requested through the Massachusetts Civil Defense Agency that the town be designated as I part of the EPZ for Pilgrim. The request was made not to condemn or endorse the Pilgrim plant, but rather that Bourne and it's residents would be adequately prepared for an emergency at Pilgrim. Without being included in the EPZ Bourne would not receive any advance notification of an emergency at Pilgrim, and would therefor be severely hampered in providing services necessary to keep vehicular traffic moving and preventing panic, whether warranted or not, for the residents of Bourne.
In conclusion, Bourne requests to be included in Pilgrims EPZ for two reasons; first that our residents that live within the 10 mile radius receive the same consideration and planning as ,
residents of other towns within the 10 mile radius; and secondly l so that the town might better prepare for the traffic problems that will occur in the event of an emergency at Pilgrim Station.
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TOWN OF BOURNE
.- BOURNE IS LOCATED IN SOUTHEASTERN MASSACHUSETTS
- BORDERED ON NORTH BY PLYMOUTH, EAST BY ,
- SANDWICH, SOUTH BY FALMOUTH, WEST BY -
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WAREHAM APPROXIMATELY 55 MILES SOUTH OF BOSTON
- YEAR ROUND POPULATION 15,365, SUMMER 35,000 e
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A AREA WITHIN 10 MILE RADIUS OF PILGRIM PLANT
- PRESENTLY EIGHT RESIDENCES', BOTH SEASONAL AhD YEAR ROUND.
. - CONSTRUCTION UNDERWAY FOR' ..
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SEVENTY7 SEVEN UNIT COMPLEX WITHIN 10 -
MILE RADIUS. ..
i TRAFFIC CONCERNS
- THE SAGAMORE AND BOURNE BRIDGES, BUILT IN 1935, PROVIDE THE ONLY MEANS FOR
. THE PUBLIC TO TRAVEL TO AND FROM CAPE .
COD. CAPE COD.HAS A YEAR ROUND POPULATION OF 170,600 AND A' SUMMER -
POPULATION OF JUST OVE'R 500,000. -
AVERAGE DAILY VEHICULAR TRAFFIC.ACROSS THE SAGAMORE AND BOURNE BRIDGES IS 64,442.
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IN THE EVENT OF AN INCIDENT REQUIRING THE EVACUATION SURROUNDING THE PILGRIM STATION, THE TOWN OF BOURNE IS NOT AWARE OF ANY TRAFFIC MANAGEMENT PLANS.
- CURRENTLY-ON HOLIDAY WEEKENDS, THE TRAFFIC BACKUP IS 5-10 MILES. FROM THE BRIDGES.
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TOWN OF BOURNE REQUEST FOR E P Z DESIGNATION
- MhRCH 6, 1987 MASSACHUSETTS civil DEFENSE AGENCY OFFERS TOWN OF BOURNE
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OPPORTU,NITY TO BE DESIGNATED EPZ COMMUNITY. - - -
- MAY If4,1987 BOURNE REQUESTS INFORMATIONAL MEETING WITH MASS. CIVIL DEFENSE OFFICIALS REGARDING EPZ DESIGNATION.
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- MAY 28, 1987 MASS. CIVIL DEFENSE ACKNOWLEDGES RECEIPT OF TOWN OF BOURNE REQUEST FOR EPZ DESIGNATION.-
- JUNE 22, 1987 BOURNE RECEIVED NOTIFICATION THAT THE GOVERNOR'S '
OFflCE HAS APPROVED' BOURNE'S R'EQllEST .
TO SEEK INCLUS10R IN EPZ.
- AUGUST 24, 1987 BOARD OF SEELCTMEN FORWARD FORMAL REQUEST FOR INCLUSION IN PILGRIM EPZ.
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- DECEMBER 9, 1988 BOURNE BOARD OF SELECTMEN REQUEST THAT THE NUCLEAR
. REGULATORY COMMISSION INCLUDE BOURNE
.IN PILGRIM EPZ.
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PRESENT PUBLIC SAFETY CONCERNS PRESENTLY BOURNE IS NOT NOTIFIED OF INCIDENTS AT PILGRIM STATION.
BOURNE DOES NOT HAVE OPPORTUNITY TO ,
DEVELOP EMERGENCY PLANS'DUE TO A LACK 0F KNOWLEDGE OF ANY EXISTING PLANS. .
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POSSIBILITY OF PA,NIC AMONG CITIZENS AND CONFUSION AMONG LOCAL.0FFICIALS DUE TO A LACK OF PLANNING.
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l ' TOWN OF BOURNE REQUEST THE REQUEST BY THE TOWN OF BOURNE TO BE INCLUDED IN THE PILGRIM STATION EMERGENCY PLANNING ZONE IS MADE NOT TO e
CONDEMN OR ENDORSE THE. PILGRIM POWER PLANT, BUT RATHER TAAT BOURNE ' AND ITS RESIDENTS BE ADEQUATELY PREPARED FOR AN EMERGENCY AT PILGRIM STATION.
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.# R8h, g THE COMMONWEALTH OF MASSACHUSETTS EXECUTIVE DEPARTMENT
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. osancron MICHAEL 5. DuMAnts .,
savoinoa March 6, 1987 .
\COM i Mr. Robert W. Parady,' Chairman i j
Bourne Board of Selectmen Bourne Town Hall C[ ;tgROUT 5TO , ?
24 Perry Avenue Buzzards Bay, MA 02532 INiilAlp l
Dear Mr. Mr. Parady:
As the Director of Massachusetts Civil D I have fense the Agency andto responsibility Office of Emergency Preparedness, designate communities which will be included in the Emergency
- Planning, Zone (EPZ) for a nuclear power station. ,
in the document "NUREG Guidance from the federal, governmentSection 13-2b of the 0654" as well as Chapter 33 Appendix, indicate that the EPZ Massachusetts General Laws (attached) should consistSince of allacommunities small portion within of Bourne ten lies miles of a ten within nuclear power plant.
' miles of Pilgrim Station, I- want to offer you the opportunity.to be designated an EPZ community.
If designated an EPZ community, this agency will assist you, the Bourne Civil Defense Director, and other concerned officials with development of local plans for response to an accident at The Boston Edison Company is expected to Pilgrim Station. notification, and communications support the costs of any alert, !
equipment which the town must acquire to fulfill its obligations to implement the emergency plan. .
It should be noted that Secretary theofthe Public SafetyonCharles Governor Safety at V.
1986 report Barry in his December, Pilgrim Station made the finding that present emerg it remains to be determined if plans are not adequate and thatadequate plans to respond to an accid be developed. This offer does not constitute acknowledgement nor would your agreement to
,that adequate plans can be developed,you feel adequate plans are possible.
. Join the EPZ indicate that l
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. o I want to advise you that the Executive Office of Public Safety is working with the state legislature to reach a concensus position on expanding the areas for which nuclear power plant emergency plans are prepared. However, it is possible that legislation will be enacted which expands the EPZ and I will advise you of any action on this matter.
If you will contact me at your earliest convenience, I will be happy to meet with you to discuss this offer'at length.
Sincerely,
- i ert J. Boulpy
, Director i
RJB/kam cc: Secretary 'of Public Safety Charles V. Barry Assistant Secretary Peter W. Agnes Boston Edison Company Bourne Civil Defense Director
. 'Mr. Edward A. Thomas, Federal Emergency Management Agency Members of the Legislative Commission to St'udy Pflgrim -
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TOWN OF BOURNE Y A BOARD OF SELECTMEN
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. Perry Avenue
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BUZZARDS BAY. MA 0253 c:2 -
TEL. 759 4486 ROBERT W. PARADY. CliAIRMAN MARIE J. OLIVA Mav.14, 1987
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JAMES CIVILINSKI I
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Mr. Robert J. Boulay Director Massachusetts Civil Defense Agency 400 Worcester Road !
P.O. Box 1496 Framingham, MA 01701-0317 -
Dear Mr. Boulay:
We are writing to reconfirm our position regarding the possibility of the Town of Bourne being included in the Emergency Planning Zone (E. P . Z ..) for the Pilgrim Power Plant.
As per our earlier conversations, we have expressed an interest to join, but would like to reschedule a meeting that was previous cancelled by you so that we may make a firm decision and learn more about the E.P.Z.
We would also like to go on record that because we have shown interest in the Emergency Planning Zone it does not constitute an endorsement to reopen the Pilgrim Power Plant.
We will patiently wait to hear from you.
Very truly yours, BOA F SE*ZCTMEM
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Kos(e . . Part y ' f Marle J. Oliva.
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O >h G ames Civ111nsu JC/njs cc: Charles Noyes
- Bourne Civil Defense Director -
Fire Chief Martin Jordan Police Chief Dennis Mannix
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THE COMMONWEALTH OF MASSACHUSETTS # 4-EXECUTIVE DEPARTMENT f ;1 h
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MICHAEL S. DUKAKIS . Rd8ERT J. Bouw
- 'aa , .May 28,.1987 o'a'cma Mr. Robert W. Parady, Chairman Y29 Bourne Board of Selectmen i, . t.
Bourne Town Hall ,
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1 24 Perry Avenue .._ __ u
' Buzzards Bay, MA 02532 i
Dear Mr. Parady:
In a letter to you dated March 26, 1987, I offered the town of Bourne the opportunity. to be designated aR2 Emergency Planning Zone (EPZ) community for Pilgrim Nuclear Power Station.
I have. received your. indication of interest in this designation.
.and I am gratified by your cooperation.
At present, this agency is consulting with federal authori-
- ties on this matter, consistent with their. regulations. Just as soon as this-consultation.proces's is complete, I will consider making a formal designation of Bourne as part of the Pilgrim EPZ. I will keep you informed of all issues relating to this matter. ,
If you have any questions or observations regarding this designation, please contact my Deputy Director, John Lovering, Program Manager for. Pilgrim Planning, at 875-1381.
Thank you for your patience, I look forward to working with you to see that the public safety needs of your community are 4 fulfilled.
Sin urely, ,
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Robrt .. oulay Director RJB/kam cc: Assistant Secretary Peter W. Agnes, Jr. .
Deputy.' Director John Lovering Mr. Charles Noys, Civil Defense Director of Bourne Area II Director Thomas P. Rodger, MCDA/0EP
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June 22, 1987 h
- _ s TO: Board of Selectmen .
FROM: Charles K. Noye, CD Director
SUBJECT:
Pilgrim Emergency Planning Zone
'At approx 0930 hrs date, I received a telephone call from a Mr.
Al Slanney, Area 2 Headquarters, MA Civil Defense. Mr. Slanney re-layed a message from his office that Governor Dukakis had approved the To,wn of Bourne's request for inclusion in the Pilgrim Emergency Planning Zone. This inclusion is conditional pending consultation with the Federal Emergency Management Agency (FEMA) and the Nuclear Regulatory Agency (NRC).
- CLL_\LRy Charles K. Noyes, Director Bourne Civil Defense es.
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nos RT Aov. cu4 au4.x Buzzards, Bay assachuszets 02532 Augus,t 24, 1987 l
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Mr. Robert J. Boulay Director Massachusetts Civil Defense Agency 400 Worcester Road P.O. Box 1496 Framingham, MA 01701-0317
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Dear Mr. Boulay:
l As you are aware, a portion of the town of Bourne lies within the 10-mile Emergency Planning Zone (EPZ) of the Pilgrim Nuclear Power Station located in Plymouth, MA. On Tuesday, Auguct 11, 1987, the members of the Board of Selectmen, 'the towri's Civil D'efense Direct.or and Police and -
. Fire Chiefs were briefed by membe,rs of your staff, Mr.
. Lovering and Mr. Slaney relative to Public Safety issues .
involved and to questions that we had concerning this matter.'
consequently, please. consider this communication as an official request to have the entire town of Bourne, or at least that portion of the town located north of the Cape Cod Canal, as part of the officially designated Emergency Planning Zone. This request is made pursuant to the following' Legal Authority and Federal Regulatory Guidance.
- 1. Massachusetts General Laws, Chapter 33 Appendix Secti:n 13 enc Section 13-2B.
- 2. Criteria for Preparation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants (NUREG 0654) issued in 1980 l by the Nuclear Regulatory Commission and the l F.ederal Emergency Management Agency.
We also request that you petition the Nuclear Management Regulatory Commission and the Federal Agency to concur in our *cquest to be so offici Emergency' ally l
designated.
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1 August;24, 1987 Paga_2 In cddition, it is also important for us to ascertain from you and/or officials at the appropriate level and/or levels.of government, the following: who would be responsible.for providing this community with the resources (financial-equipment) which relate to:
- 1. - Emergency Plan development and maintenance.
- 2. Equipment relating to an alert notification and
, public warning systems for key. town officials and the population in general.
- 3. Emergency Operations Center enhancements (Command Channe.1 Communications).
4.. First responder training (annual) for the towns' -
public and private sector personnel who would be involved.
- 5. Costs incurred relative to Annual Exercise involvement.-
All cf the above programs, we understand, would be an integral part of the EPZ designation requirements.
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We are sure you realize, Director Boulay, that as Selectmen we are vitally concerned with the Public Safety ;
issues related to this program and respectfully request an expeditious answer to this communication.
. Finally, we take.the opportunity.to again. emphasize.
that'this official request to be designat,ed an Eme gency .
' Planning Zond community'does not in any way cons tute an endorsement to reopen the Pilgrim Nuclear Power Plant located in Plymouth,. Massachusetts.
Very truly yours, BO OF S C.
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flo . . Paracyr,- Y
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- bJaqys enA (uuD2xd 1 Civ111nsx1 njs cc: Charles V. Barry, Secretary E.O.P.S. (Att: Peter Agnes)
Boston Edison Co., Att: Ralph Bird, V.P. Nuclear Operations Charles K. Moyes, Bourne Civil Defense Director 9
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l OUTLINE TESTIMONY OF ANN WAITKUS.. ARNOLD MASSACHUSETTS OFFICE OF HANDICAPPED AFFAIRS NUCLEAR REGULATORY COMMISSION, ROCKVILLE, MARYLAND DECEMBER 9, 1988 PILGRIM I STATION-RADIOLOGICAL EMERGENCY R -
- 1. Preliminary Remarks
- 2. Present S':stJs of Rad 2cloatcal Emercancy Plans for Pecole wi<: 1 Jissaill ?' es
- 3. Pronosed comprehensive Protect by McHA
- a. Goals ,and Objectives
. . b. Special Implications .
- c. Feasibility Aspect 4
- 4. Position of the office of Handicsoned Affairi
- 5. Clostna Remarks D
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- TESTIMONY OF -
ANN WAITKUS-ARNOLD DISABLED PERSONS ADVISORY GROUP ON NUCLEAR EVACUATION THE COMMONWEALTH OF MASSACHUSETTS OFFICE OF HANDICAPPED AFFAIRS NUCLEAR REGULATORY COMMISSION, ROCKVILLE, MARYLAND - .
DECEMBER 9, 1988 -
' Good afternoon, Mr. Chairman.Thank you for inviting me to speak here today. As Chairwoman for the Disabled persons Advisory Group on Nuclear Evacuation, L have been intimately involved in emergency planning procedures for all nuclear plants affecting the one million disabled people in Massachusetts.
The Massachusetts Office of Handicapped Affairs initiated the first meetings with officials from Boston Edison several years ago about Emergency. Planning for people who cannot evacuate on their own, an'd we have pursued this issue in the intervening ' time by formi.ng a Working Group on Disabilit'y-
- Issues and Emergency.Pl'anning in the event of an, accident at the Pilgrim. Nuclear Power Station. We have suggested a proposal be commissioned for a Comprehensive Project t o' determine Emergency Planning needs for people who require assistance.
The current status of planning for elderly and disabled people and others with special needs is grossly inadequate.
The Evacuation Time Estimate figures, developed by Boston Edison, are completely inaccurate. Boston Edison has used thes figures as if they were correct over the strong opposition from the Of fice of Handicapped Affairs. We feel Beco is acting in bad faith. The research methods for this document ' were seriously flawed, thus the figures Beco arrived
- at are invalid. For example, Beco alleges that approximately is of the, population is disabled, when t'he latest Harris polls for the U.S. Disability Census show actual figures of 17%, most of whom.would need assistance in an emergency. We also know that the fastest growing population in this country are peopde over 65, the majority of whom have disabilities.
Thus, Beco's reassurances cannot be relied on. The addition of thousands more people in the pilgrim EPZ needing special arrangements and care could throw the entire Evacuation Plans into disarray, therefore, Beco's erroneous figures for the Special Needs Population actually, invalidate all of the ETE results which are used as a basis for any planning thatvis being proposed. Attempts to have this population self-identify also have not worked. Full page ads in severdi local newspapers have only alicited 10 responses. This extremely low response is na surprise to this Agency;
f historically, the self-identification process for this target population has never worked.
The legal definition of a-disabled person is- any person who has an impairment that limits one or more major activities of daily living. This includes people who have
' problems with-walking, talking, seeing, hearing, breathing, or thinking. This definition encompasses people with developmental disabilities, medically fragile persons, :
elderly persons, persons with mental illness, persons with sensory or physical limitations, temporarily disabled '
persons, and the transitory population-disabled individuals who leave their place of residence for school, sheltered employment or adult care, and travel in and out of the EpZ for these services. We presume that other.special needs populations-schools, nursing homes, hospitals and group homes i will be planned for separately.
l The Comprehensive survey goals deserve particular i attention. The task of this project goes far beyond the l development of rough estimates of_ numbers of people with '
disabling conditions in the area who might need accessible transportation. The challenge is much more complex. We must to develop an area profile showing the known and probable distribution of disabled < people at several specific times
. reflecting working and non-working hours and, wee'kends; we' must determine how the evacuation of t.he general population '
will effect evacuating / people wiio need special assistance; we must develop current standards for people who may'be at too great a risk to evacuate, including evaluating the attendent risks of remaining behind - these people could include hospitalized infants, children and adults, nursing home patients, and people on life support systems at home. They could be any one of us unfortunate enough to be hospitalized for a serious condition during a radiological emergency. Who will stay behind with these people? There must'be agreements made with people' who are willing to remain behind and provide
. care- for those who can't be moved. These workers would have to be provided with specialized training for dealing with a radiological accident and the risk of having to take
- Potassium lodide along with their patients.
The most critical facet of the plan is the requirement for a Functional Skills Assessment for the communities involved in termg of supervision and assistance. In order for proper planning to occur, this assessment must be conducted in relation to residence and location in the community, and must provide for transitory populations. What levels of assistance will people need to safely evacuate? Also, the plan must address people with low incidence disabilities.
i I These people, suchas a person who is a quadriplegic,wayfd require continuous very specialized planning and care gp survive, even in a sheltering situation. Their living situation and formal support requirements must be assessed, as well as their general environment including
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t daily activities-in correlation with the general evacuation
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process. Throughout the process of this proposal's development. Seco agreed to pay for the project.. However, several months after its completion, Beco reneged on their
, agreement. They have. failed to act in good faith, once l again, and we are left facing a potentially dangerous i situation with no factual data. Valid planning is not-possible in such an information vacuum.
There must.be an honest evaluation of the feasibility of actually evacuating and caring for all of the men, women and children in this EPZ who comprise the Special Needs population. As you know, the population in Plymouth has almost tripled since Pilgrim Station went on liner 16 years
'ago , .and the two lane evacuation routes are often bumper to I
- bumper traffic, even in normal situations. Evacuation routes are over burdened during normal.use, but especially in summertime. As presently planned, evacuation activities of ,
the general population'will make it impossible to evacuate
- the sizeable numbers of people with special needs. Slipshod preparations proposed by Beco with the NRC's apparent agreement, are highlighted by recent statements that "present ,
planning is sufficlent for re-start" . Since there is no -
planning for the special..needs/ population, this clearly -
i discriminates against that population,. and is, thus, a l
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violation of the Massachusetts Constitution Amendment 114.
. This law guarantees equal protection for people with disabilities in Massachusetts.. There are also questions as to whether this discriminatory behavior violates federal law.
What is required is' the guarantee that citizens of Massachusetts with special needs have an equal opportunity to leave an area around a nuclear power plant during a radiological accident.
- It is illogical and duplicitous to go to low power,'the only object of which is to go to full power, without.any viable plan for evacuating the population. It is our position that Pilgrim Station should remain closed until and unless safe evacuation plans can be made for all people.
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% - Voice & TDD FOR IMMEDIATE RELEASE CONTACT: LORRAINE GREIFF DECEMBER 4, 1987 617-727-7400 PRESS RELEASE ANN WAITKUS-ARNOLD APPOINTED CHAIRWOMAN OF DISABLED PERSONS ADVISORY GROUP ON NUCLEAR EVACUATION ANN WAITKUS-ARNOLD OF PLYMOUTH WAS RECENTLY APPOINTED BY THE '
MASSACHUSETTS OFFICE OF HANDICAPPED AFFAIRS TO BE CHAIRWOMAN -
OF THE DISABLED PERSONS ADVISORY GROUP ON NUCLEAR EVALUATION.
THE PURPOSE OF THE ADVISORY COMMITTEE IS TO MAKE RECOMMENDATIONS ^ !
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TO THE STATE-WIDE TASK FORCE ON CIVIL DEFENSE TO INSURE INCLUSION IN EVACUATION PLANNING FOR PEOPLE WHO ARE ELDERLY AND/OR DISABLED IN ALL AREAS OF THE STATE NEAR NUCLEAR POWER STATIONS. ,
THE ADVISORY GROUP CONSISTS Ob' ADVOCATES WHO ARE DISABLED FROM THROUGHOUT THE. STATE. IT HAS. MET WITH BOSTON EDISON, YANKEE ATOMIC, AND THE MASSACHUSETTS CIVIL DEFENSE AGENCY.
IT IS EXPECTED TO RECOMMEND THE HIRING OF A PROFESSIONAL CONSULTANT TO RESEARCH THE DEMOGRAPHICS OF PEOPLE WITH DISABILITIES NEAR NUCLEAR POWER PLANTS; TO DETERMINE THEIR NEEDS IN THE EVENT OF AN EMERGENCY; TO DETERMIME WHICH PEOPLE IF ANY, CANNOT BE EVACUATED; AND TO DETERMINE THE ATTENDENT RISKS IN REMAINING.WHERE THEY ARE.
"THIS ADVISORY GROUP IS A CRITICAL FIRST STEP IN THE STATEWIDE EFFORT TO DEAL WITH EMERGENCY EVACUATION PROCEDURES FOR ALL PEOPLE," ACCORDING TO JIM GLEICH, DIRECTOR OF THE MASSACHUSETTS OFFICE OF HANDICAPPED AFFAIRS.
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STATEMENT OF l' ASSISTANT SECRETARY PETER W. AGNES, JR.
IN BEHALF OF MASSACHUSETTS EXECUTIVE OFFICE OF.PUBLIC SAFETY SECRETARY CHARLES V. BARRY BEFORE THE ,
UNITED STATES NUCLEAR REGULATORY COMMISSION !
I Rockville, Maryland '
December 9, 1988 i
GOOD AFTERNOON CHAIRMAN ZECH AND COMMISSIONERS. THE MASSACHUSETTS' SECRETARY OF PUBLIC SAFETY IS PLEASED AT THE OPPORTUNITY TO ADDRESS THE COMMISSION ON THE STATUS OF OFF-SITE PREPAREDNESS FOR AN ACCI$ENT AT. PILGRIM NUCLEAR POWER STATION.
THIS MEETING IS LONG OVER-DUE. THOSE HERE TODAY SHOULD BEAR IN MIND THAY IT WAS THE COMMONWEASTM OF MASSACHUSETTS'-- NOT ,
THE NUCLEAR RREGULATORY COMMISSION AND NOT THE FEDERAL EMERGENCY MANAGEMENT AGENCY -- WHICH FIRST DREW ATTENTION TO THE ISSUES WE ARE GATHERED TO DISCUSS. AS A RESULT OF GOVERNOR DUKAKIS' INITIATIVE, WE PRODUCED THE FIRST COMPREHENSIVE REPORT ANALYSING EMERGENCY PREPAREDNESS FOR AN ACCIDENT AT PILGRIM STATION IN DECEMBER OF 1986. THAT 200 PAGE REPORT WAS THE FIRST TO DOCUMENT
. THAT EMERGENCY PLANNING IN THE PILGRIM AREA WAS WOEFULLY INADEQUATE. IT IS INTERESTING TO US THAT NEARLY TWO YEARS AFTER i THAT REPORT WAS ISSUED, WE HAVE YET TO RECEIVE ANY FORMAL RESPONSE TO ITS CONCLUSIONS FROM THE NRC. IN AUGUST OF 1987,
FINDINGS OF OUR REPORT AND' WITHDREW INTERIM APPROVAL OF PILGRIM EMERGENCY PLANS. FEMA HAS YET TO RESTORE ITS APPROVAL.
DECEMBER 9, 1988 PETER W. AGNES, JR.
IN THE SUMMER OF 1987, THE-COMMONWEALTH SPONSORED THE FIRST OF MANY OPEN PUBLIC MEETINGS AT WHICH CITIZENS AND LOCAL OFFICI,ALS WERE INVITED TO DISCUSS EMERGENCY PREPAREDNESS AND THEI'R SAFETY. THE COMMONWEALTH HAS HELD TWENTY-ONE PUBLIC FORUMS IN THE INTERVENING MONTHS. ALSO, STAFF OF OUR NUCLEAR SAFETY EMERGENCY PREPAREDNESS PROGRAM HAS HELD 77 WEEKLY WORKING MEETINGS WITH EP2 PUBLIC SAFETY OFFICIALS AND ATTENDED MORE THAN 180 MEETINGS OF LOCAL BOARDS AND COMMITTEES REGARDING EMERGENCY PREPAREDNESS. IN JANUARY OF 1988, SENATOR KENNEDY HELD HEARINGS IN THE EPZ TO SEEK PUBLIC TESTIMONY ON EMERGENCY PREPAREDNESS.
WHILE THE NRC STAFF WILL TELL YOU THAT THEY HAVE HELD MEETING AFTER MEETING WITH EP2 RESIDENTS, LET THE RECORD SHOW THAT UP UNTIL TODAY,.THE COMMISSION HAS NOT ONCE HOSTED'A SINGLE PUBLIC ,
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MEETING TO HEAR FROM LOCAL AND STATE OFFICIALS ON OFF-SITE GIVEN THE SERIOUS EMERGENCY PREPAREDNESS FOR THE PILGRIM EP2.
NATURE OF THE SUBJECT, I THINK THAT THIS IS A DEPLORABLE RECORD FOR A FEDERAL REGULATORY BODY WHOSE SPECIFIC CHARGE IS PROTECTION OF PUBLIC HEALTH AND SAFETY.
ON TWO OCCASIONS, THE NRC HAS ADDRESSED OFF-SITE IN A MEETING HERE, ON OCTOBER 6, LOCAL EMERGENCY PREPAREDNESS.
OFFICIALS OF EP2 COMMUNITIES HAD HOPED TO INFORM YOU OF THEIR
.) ON OCTOBER 14 CONCERNS BUT WERE DENIED THE OPPORTUNITY TO SPEAK.
ANOTHER MEETING WAS HELD IN WHICH THE NRC STAFF DISCUSSED EMERGENCY PREPAREDNESS WITH THE COMMISSIONERS AND WHERE WE WERE I
FORCIBLY DENIED THE OPPORTUNITY TO REBUT BLATANT IN FACT, ON OCTOBER 14 YOUR OWN ,
I MISREPRESENTATIONS BY THE S1AFF. f l
e
PETER W. AGNES, JR. DECEMBER 9, 1988 STAFF STATED THAT THEY.HAD MET WITH PUBLIC OFFICIALS OF EPZ COMMUNITIES TO DISCUSS THE STATUS OF PLANNING, A STATEMENT WHICH WAS CLEARLY NOT TRUE. A SERIES OF MEETINGS WAS HELD BY YOUR STAFF WITH EPZ AND HOST COMMUNITIES BETWEEN OCTOBER 25 AND NOVEMBER 2, 1988, WHICH HAS BEEN DOCUMENTED IN A SERIES OF .
UNDATED MEMORANDA FROM MR. WILLIAN LAZARUS TO MR. WILLIAM T.
RUSSELL. SHORTLY THEREAFTER, I MET WITH REPRESENTATIVES OF SEVERAL EPZ COMMUNITIES AND IT WAS THE UNANIMOUS SENSE OF THE TOWNS REPRESENTED THAT THE LAZARUS MEMORANDA DID NOT ACURATELY REFLECT THE NUMBER AND SEVERITY OF UNRESOLVED PLANNING ITEMS.
TODAY YOU WILL HEAR SEVERAL LOCAL OFFICIALS EXPAND ON THESE VERY
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ISSUE 3.
LETMESAYATTHEOUTSETTHATTHECOMMONWEALTHQh MASSACHUSETTS IS NOT OPPOSED CATEGORICALLY TO THE' OPERATION OF PILGRIM NUCLEAR POWER STATION. HOWEVER, WE WILL NOT SUPPORT THE RESTART OF PILGRIM STATION UNTIL WE ARE SATISFIED THAT A PLAN EXISTS WHICH SATISFIES EVERY REQUIREMENT OF NUREG 0654 AND ALL OTHER REGULATORY CRITERIA. NOR CAN WE SUPPORT RESTART UNTIL WE ARE CERTAIN THAT PUBLIC SAFETY CAN BE PROTECTED IN THE EVENT OF A
- NUCLEAR ACCIDENT AS DEMONSTARTED IN A FULL-SCALE, GRADED EXERCISE OF THOSE EMERGENCY PLANS. FURTHER, WE DO NOT BELIEVE THAT PILGRIM SHOULD BE AUTHORISED TO RESTART UNTIL BOSTON EDISON DEMONSTRATES ITS ABILITY TO OPERATE THE FACILITY IN A RESPONSIBLE AND SAFE MANNER. AT THIS MOME'NT WE LACK CONFIDENCE IN ALL OF THESE REGARDS..
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PETER W. AGNES, JR. DECEMBER ~9, 1988 TODAY YOU WILL HEAR FROM LOCAL OFFICIALS SERVING TOWNS IN a
THE PILGRIM EMERGENCY PLANNING 2ONE ABOUT THE STATUS OF EMERGENCY PREPAREDNESS IN THEIR OWN COMMUNITIES. THESE ARE INDIVIDUALS WHO ARE CHARGED WITH THE RESPONSIBILITY OF PROTECTING THE HEALTH, SAFETY, AND PROPERTY OF THE CITIZENS THEY ARE ELECTED AND APPOINTED TO SERVE. YOU SHOULD LISTEN CAREFULLY TO WHAT THEY HAVE TO TELL YOU, BECAUSE IT IS THESE LOCAL OFFICIALS -- NOT THE NUCLE /' REGULATORY COMMISSION -- WHO MUST REACT PROMPTLY AND EFFECTIVELY SHOULD THERE EVER BE AN ACCIDENT AT PILGRIM NUCLEAR POWER STATION. EACH COMMUNITY HAS TOILED IN GOOD FAITH TO PRODUCC THE BEST POSSIBLE PLAN AND PROGRAM FOR EMERGENCY RESPONSE
. BUT TO DATE NOT ONE COMMUNITY HAS EXPRESSED SUFFICIENT CONFIDENCE IN THEIR PLAN TO ENDORSE IT FOR THE PURPOSE OF HOLDING AN EMERGENCY EXERCISE.
I DEEPLY REGRET THAT THE FEDERAL EMERGENCY MANAGEMENT AGENCY -- THE ONE FEDERAL AU4MCRITY EXCLUSIVELY CHARGED TO DEAL WITH EMERGENCY PREPAREDNESS -- HAS NOT PARTICIPATED IN ANY OF OUR PLANNING ACTIVITIES. IN A MEETING I HELD WITH FEMA REGIONAL DIRECTOR HENRY VICKERS IN OCTOBER, 1987, MR. VICKERS PROMISED THAT A MEMBER OF HIS STAFF WOULD BE DELEGATED TO WORK WITH THE COMMONWEALTH AND LOCAL GOVERNMENTS IN EMERGENCY PLANNIG. NO SUCH ACTION WAS E.VER TAKEN. ON NOVEMBER 18, 1988, I WROTE TO FEMA NATIONAL DIRECTOR JULIUS BECTON ASKING WHETHER PILGRIM IS THE ONLY NUCLEAR POWER STATION IN THE COUNTRY FOR WHICH FEMA HAS WITHDRAWN INTERIM APPROVAL OF EMERGENCY PLANS AND FOR WHICH EVERY STATE AND LOCAL AUTHORITY 1:AS EXPRESSED ITS LACK OF CONFIDENCE IN 4
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l PETER W. AGNES, JR. DECEMBER 9, 1988 l
EMERGENCY PREPAREDNESS. TO DATE WE HAVE RECEIVED NO RESPONEE TO THIS SIMPLE INOUIRY.
- 7MA HAS BEEN INVITED TO JOIN EVERY MEETING HELD AT WHICH !
EMERGENCY PLANNING WAS DISCUSS'ED, INCLUDING OUR WEEXLY EP2 WORKING dROUP MEETINGS, BUT THEY HAVE CHOSEN NOT TO ACCEPT OUR INVITATIONS. IN FACT FEMA FAILED TO SEND A REPRESENTATIVE TO A MEETING BETWEEN MYSELF AND MR. WILLIAM LAZARUS OF THE NRC'S REIONAL OFFICE ON AUGUST 22, 1980, AT WHICH WE GAVE A COMPREHENSIVE REVIEW OF THE STATUS OF OFF-SITE PLANNING. ON OCTOBER 13, 1988, WE RECEIVED A LETTER FROM MR. VICKERS IN WHICH HE STATES THAT "BEFORE WE FULLY RESPOND TO YOUR SEPTEMBER 2 AND 29, 1988, LETTERS, WE WOULD LIKE AN OPPORTUNITY TO CAREFULLY STUDY AND REVIEW THE REPORT TO THE GOVERNOR..." I ASK TODAY, ON DECEMBER 9, HOW LONG DOES IT TAKE FEMA -- YOUR SISTER AGENCY WITH WHICH THE NRC HAS A LETTER OF AGREEMENT CONCERNING ASSESSMENT OF OFF-SITE EMERGENCY PREPAREDNESS -- TO RESPOND TO IMPORTANT REQUESTS FOR INFORMATION AND ANALYSES 7 MOREOVER, IF THERE IS ONE REPRESENTATIVE HERE TODAY FROM THE FEDERAL EMERENCY MANAGEMENT AGENCY, I ASK THAT YOU ACKNOWLEDGE YOUR PRESENCE AND STATE YOUR l -
CONCERNS FOR EMERGENCY PREPAREDNESS AT PILGRIM STATION.
AS YOU, THE NUCLEAR REGULATORY COMMISSION, SITS POISED TO AUTHORIZE RESTART OF PILGRIM STATION, I WOULD LIKE YOU TO EXPLAIN TO THE ASSEMBLED PUBLIC OFFICIALS HOW YOU CAN IN ALL CONSCIENCE IGNORE THE FACT THAT FEMA HAS WITHDRAWN AND NEVER RESTORED ITS APPROVAL OF THE , PILGRIM EMCPGENCY PLANS. THE COMMONWEALTH OF MASSACHUSETTS AND EVERY COGNISANT LOCAL GOVERNMENT IS HERE TO
PETER W. AGNES, JR. DECEMBER 9, 1988 TELL YOU THAT WE DO NOT AT PRESENT HAVE ADEOUATE EMERGENCY PLANS.
I ASK, JdST HOW DO YOU THE COMMISSIONERS JUSTIFY RESTARTING PILGRIM STATION WHEN EVERY SINGLE CONCERNED PUBLIC OFFICIAL --
FEDERAL, STATE, AND LOCAL -- OTHER THAN THE NRC MAINTAINS THAT EMERGENCY PREPAREDNESS FOR AN ACCIDENT AT PILGRIM STATION IS NET ADEOUATE7 THE SECRETARY OF PUBLIC SAFETY HAS SENT THE GOVERNOR THREE REPORTS ON SAFETY AT PILGRIM, IN DECEMBER OF 1986, DECEMBER OF 1987, AND OCTOBER OF 1988, ALL OF WHICH HAVE BEEN MADE
, AVAILABLE TO THE COMMISSIONERS. EACH OF THESE REPORTS HAS DISCUSSED IN DETAIL THE SERIOUS DEFICIENCIES WE HAVE FOUND IN OFF-SITE EMERGENCY PREPAREDNESS, AND I WANT TO TAKE A MOMENT TO REVIEW'A NUMBER OF ITEMS FROM THE SECRETARY'S' OCTOBER, 1988 -
REPORT'WHICH REMAIN TO BE RESOLVED.
EMERGENCY PLANNING DEFICIENCIES PERHAPS THE MOST IMPORTANT PENDING ITEM IS IMPLEMENTING PROCEDURES FOR EACH COMMUNINITY'S EMERGENCY RESPONSE PLAN. THESE PROCEDURES HELP DETERMINE THAT NO ELEMENT OF EMERGENCY RESPONSE IS LEFT TO AD HOC ACTION AND THAT ALL ACTIVITIES ARE SUPPORTED BY ACTUAL OPERATIONAL CAPABILITIES. I HAVE FCA YOU TODAY A STATUS REPORT ON THE DEVELOPMENT OF IMPLEMENTING PROCEDURES BY EACH COMMUNITY. HOWEVER, LET ME NOTE THAT WE HAVE NOT RECEIVED A SET l
OF IMPLEMENTING PROCEDURES WHICH HAVE BEEN APPROVED BY LOCAL )
t OFFICIALS FROM ANY OF THE FIVE EP2 OR TWO HOST COMMUNITIES. FIVE OF THE TOWNS HAVE FORWARDED DRAFT PROCEDURES TO US AND WE HAVE
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PETER W. AGNES, JR. DECEMBER 9, 1988 SENT THESE AND OTHER PLANNING DOCUMENTS TO FEMA FOR " INFORMAL TECHNICAL REVIEW" MORE THAN TWO MONTHS AGO. OUT OF MORE THAN 300 PROCEDURES UNDER CONSIDERATION BY THE SEVEN COMMUNITIES, ONLY 190 HAVE BEEN APPORVED IN CONCEPT BY LOCAL ELECTED OFFICIALS. TWO EP2 COMMUNITIES DO NOT FEEL SUFFICIENTLY COMFORTABLE YET WITH THE PROCEDURES THEY HAVE DEVELOPED TO EVEN HAVE SUBMITTED THEM TO US AND FEMA IN DRAFT FORM.
l l DESPITE THE BEST EFFORTS OF STATE AND LICENSEE OFFICIALS, WE HAVE YET TO UNDERTAKE A COMPREHENSIVE SURVEY OF PEOPLE WITHIN THE EMERGENCY PLANNING ZONE WITH SPECIAL NEEDS REQUIRING EXCEPTIONAL ASSISTANCE DURING AN EMERGENCY. A REPRESENTATIVE OF THE MASSACHUSETTS OFFICE OF HANDICAPPED AFFAIRS IS WITH US TDAY ,
TO ADDRESS YOU ON THE SPECIFIC ISSUES RELATING TO PEOPLE WITH SPECIAL NEEDS. -
OFF-SITE COMMUNICATIONS IN THE EVENT OF AN ACCIDENT AT P.ILGRIM STATION IS VITAL TO EFFECTIVE EMERGENCY RESPONSE. STATE AND LOCAL OFFICIALS HAVE WORKED DILIGENTLY WITH THE LICENSEE TO ,
INSTALL A NEW OFF-SITE NOTIFICATION SYSTEM. NONETHELESS, AS OF
.THIS MOMENT TRAINING HAS NOT BEEN COMPLETED FOR ALL PERSONNEL WHO
. MUST OPERATE THIS SYSTEM AND THE SYSTEM HAS NOT BEEN SUBJECTED TO I
A FULL TEST. NOTE THAT IN NOVEMBER, 1987, THE LAST TIME THAT AN UNUSUAL EVENT WAS DECLARED AT PILGRIM, NOT ALL OFFICIALS WERE NOTIFIED WITHIN FIFTEEN MINUTES. THEREFORE, I HAVE NO BASIS TO i
SAY THAT WE ARE CAPABLE EVEN.OF NOTIFYING ALL OFF-SITE AUTHORITIES OF AN ACCIDENT AT PILGRIM STATION, AS REQUIRED BY I FEDERAL REGULATIONS.
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DECEMBER 9, 1988 PETER W. AGNES, JR.
THE LAST SECTION OF THE EVACUATIOON TIME ESTIMATE AND TRAFFIC MANAGEMENT ANALYSIS COMMISSIONED BY BOSTON EDISON WAS NOT RECEIVED UNTIL LATE IN OCTOBER OF THIS YEAR. THE ETE AND TRAFFIC MANAGEMENT PLAN ARE ENORMOUSLY COMPLEX AND IN THE SPACE OF TWO l
MONTHS, WE HAVE NOT YET BEEN ABLE TO ASSESS THE ADEQUACY OF THE VERY IMPORTANT RECOMMENDATIONS THEY CONTAIN. THIS IS ESPECIALLY CRUCIAL WHERE TRAFFIC
- MANAGEMENT ACTIONS MUST BE IMPLEMENTED.BY LOCAL LAW ENFORCEMENT PERSONNEL FROM AS MANY AS 40 COMMUNITIES i
l THROUGH WHICH TRAFFIC COULD PASS ON THE WAY TO RECEPTION ,
l FACILITIES. FURTHER, TRAINING FOR MANY OF THESE LOCAL LAW ENFORCEMENT PERSONNEL HAb NOT EVEN BEEN INITIATED.
IN SPEAKING WITH LOCAL OFFICIALS FROM EACH COMMUNITY PRIOR TO DEVELOPING OUR. OCTOBER, 1988 REPORT, I LEARNED THAT THE
' COMMUNITIES' GENERALLY FEEL THAT THEY DO NOT HAVE ADEQUATE PERSONNEL IDENTIFIED TO FULFILL ALL EMERGENCY FUNCTIONS DETAILED -
IN THEIR DRAFT PLANS. WE WILL NOT CERTIFY THAT PLANS ARE ADEQUATE UNTIL IT HAS BEEN DEMONSTRATED THAT ALL LOCAL AS WELL AS STATE RESPONSE AGENCIES CAN FILL THEIR EMERGENCY PERSONNEL l ROSTERS.
- WE REMAIN CONCERNED THAT WE DO NOT HAVE RECEPTION CENTERS THAT ARE CAPABLE OF PROVIDING ALL REQUIRED SERVICES TO EVACUEES, INCLUDING RADIOLOGICAL MONITORING AND DECONTAMINATION, THE STATE AND THE LICENSEE ARE ACTIVELY ENGAGED IN A PROCESS UNDER WHICH THE NECESSARY CAPITAL IMPROVEMENTS WILL BE MADE TO THE DESIGNATEp f STATE INSTITUTIONS WHICH WILL SERVE AS RECEPTION CENTERS.
NONETHELESS, THESE IMPROVEMENTS HAVE NOT BEEN COMPLETED AND WE l
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1 PETER W. AGNES, JR. DECFMBER 9, 1988 )
CANNOT SAY THAT WE CAN PROVIDE EVEN RADIOLOGICAL MONITORING TO EVACUEES IN A TIMELY MANNER. ,
PERHAPS OUR MOST VULNERABLE POPULATION IS CHILDREN OF SCHOOL AGE. WHILE S.GNIFICANT PROGRESS HAS BEEN MADE IN DRAFTING BETTER PLANS FOR THEIR CARE, WE HAVE A DISTANCE TO GO IN
'PROVIDING TRAINING TO THE TEACHERS AND OTHER SCHOOL FSRSONNEL RESPONSIBLE FOR PROTECTING CHILDREN IN THE EVENT OF A NUCLEAR ACCIDENT MOREOVER, NOT ALL EPZ TOWNS HAVE ENUNCIATED A CLEAR POLICY ON EARLY CLOSING OF SCHOOLS AND WHETHER CHILDREN WILL BE HEPT TOGETHER OR DISMISSED.
THE FEDERAL EMERGENCY MANAGEMENT AGENCY HAS REASSESSED ITS POLICY ON SHELTER AS A PROTECTIVE ACTION, AND NOW CLAIMS THAT IT IS' UNNECESSARY'AS AN. ELEMENT OF EMERGENCY RESPONSE PLANNING.
WE BELIEVE THAT THIS IS A VERY UNWISE DECISION GIVEN THE RANGE OF ACCIDENT SCENARIOS POSTULATED FOR NUCLEAR FACILITIES. WE ARE -
REQUIRING THAT EACH EP2 TOWN HAVE A SHELTER UTILIZATION PLAN TO PROVIDE PROTECTION TO THE MAXIMUM RESIDENT AND TRANSIENT POPULATION, INCLUDING PEOPLE AT BEACHES AND OTHER RECREATION AREAS. IN SPITE OF THEIR GOOD FAITH EFFORTS, WE HAVE NOT RECdIVED DRAFT SHELTER UTILIZATION PLANS FROM TWO EPZ COMMUNITIES, AND WE CANNOT ASSESS THE ADEQUACY OF THE EMERGENCY RESPONSE SYSTEM UNTIL ALL SHELTER PLANS HAVE BEEN REVIEWED.
I HAVE INVITED MR. DAVID QUAID TO PRESENT SOME PHOTOGRAPHS OF THE EP2 AREA IN WHICH HE OWNS A HOME, THE SAOUISH NECK SECTION OF THE TOWN OF PLYMOUTH. THIS REMOTE AREA IS JUST THREE MILES FROM PILGRIM STATION. SAOUISH LIES AT THE END OF A
'l PETER W. AGNES, JR. DECEMBER 9, 1988 i'
THREE MILE PENINSULA SERVED BY A ROAD WHICH IS DIFFICULT TO TRAVERSE UNDER THE BEST CONDITIONS WHEN IT IS PASSABLE ONLY IN FOUR WHEEL DRIVE VEHICLES, AND VIRTUALLY IMPASSABLE IN BAD WEATHER AND DURING PEAK TIDES. A NUMBER OF PEOPLE SUCH AS MR.
QUAIL OWN WINTERIZED HOMES AND RESIDE IN SAQUISH FULL-TIME OR PART-TIME YEAR AROUND. THE SUMMER POPULATION CAN SWELL TO MORE THAN 4,000. WHETHER THE RECOMMENDED PROTECTIVE ACTION IS SHELTER IN PLACE OR EVACUATION, THE SAQUISH AREA IS THE PORTION OF THE EP2 IN WHICH WE WOULD HAVE THE GREATEST DIFFICULTY PROTECTING RESIDENTS AND VISITORS, REGARDLESS OF WEATHER, TIDES, OR THE TIME OF DAY OR YEAR. AS OF THIS MOMENT WE SIMPLY HAVE NOT CONCLUDED ARRANGEMENTS FOR PROTECTION OF THE SAQUISH POPULATION.
'THESE ARE JUST BRIEF DISCUSSIONS OF SOME OF THE VERY
' SERIOUS EMERGENCY RESPONSE' PROGRAM DEFICIENCIES WHICH PERSIST TODAY. I URGE THAT YOU READ CAREFULLY SECRETARY BARRY'S OCTOBER, 1988 REPORT TO THE GOVERNOR WHICH ELABORATES ON THESE AND OTHER UNRESOLVED EMERGENCY PLANNING ISSUES. I BELIEVE THAT ANY OBJECTIVE ANALYSIS OF THE STATUS OF EMERGENCY PLANNING IN THE PILGRIM EP2 LEADS TO THE INEVITABLE CONCLUSION THAT THE BEST AND
. CONCERTED EFFORTS OF STATE GOVERNMENT, LOCAL GOVERNMENT, AND THE LICENSEE HAVE NOT YET PRODUCED THE BEST POSSIBLE EMERGENCY RESPONSE PLANS FOR THE PILGRIM EP2. l MANAGEMENT AND PERSONNEL ERROR CONCERNS .
IN ADDITION TO THE FACT THAT EMERGENCY PLAN 5 FOR RESPONSE TO AN ACCIDENT AT PILGRIM ARE INCOMPLETE, WE REMAIN CONCERNED
- PETER W. AGNES, JR. DECEMBER
- 9, 1983 OVER BOSTON EDISON'S OBVIOUS DIFFICULTY IN MANAGING. PILGRIM I f
j STATION. THIS MANAGEMENT FAILURE IS_ AMPLY DEMONSTRATED BY PILGRIM STATION'S CONTINUING PLAGUE OF SERIOUS PERSONNEL ERRORS.
THE MASSACHUSETTS CIVIL DEFEPSE AGENCY a..J OFFICE OF EMERGENCY PREPAREDNESS RECEIVES COPIES OF ALL 50.72(C) REPORTS MADE TO THE NRC BY PILGRIM STATION, YANKEE STATION, AND VERMONT YANKEE STATION. AN ANALYSIS OF THESE REPORTS FOR THE PAST TWELVE MONTHS IS QUITE REVEALING. '
i FROM OCTOBER, 1987, THROUGH NOVEMBER, 1988, YANKEE STATION FILED ONLY TWO 50.72(C) REPORTS, AND FOR THE SAME PERIOD, VERMONT YANKEE FILED 41 REPORTS. PILGRIM STATION FILED THIRTY-EIGHT 50.72(C) REPORTS, IN SPITE OF THE FACT THAT PILGRIM
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IS IN COLD SHUTDOWN WHILE' YANKEE AND'VERNOMT YANKEE HAVE BEEN IN FULL OPERATION. FURTHER, BOTH YANKEE INCIDENTS WERE THE RESULT OF MECHANICAL FAILURE WHILE 30 VERMONT YANKEE REPORTS -- 73x --
WERE THE RESULT OF MECHANICAL FAILURE AND ONLY 8 -- 204 -- WERE THE RESULT OF VERMONT YANKEE PERSONNEL ERROR. ON TH'E OTHER HAND, AT PILGRIM STATION, 23 -- 604 -- OF THE 50.72(C) EVENTS WERE THE RESULT OF PERSONNEL ERROR. THUS, ON A PERCENTAGE BASIS, PILGRIM
- STATION HAS THREE TIMES THE RATE OF PERSONNEL ERRORS RESULTING IN REPORTABLE EVENTS THAN VERMONT YANKEE, EVEN THOUGH THEY ARE THE SAME GE MARK 1 CONFIGURATION AND EVEN THOUGH VERMONT YANKEE IS IN FULL OPERATION AND PILGRIM STATION IS IN COLD SHUTDOWN. OUR ANALYSIS DOES NOT INCLUDE AN INCIDENT WHICH OCCURRED ON NOVEMBER
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30, 1988 IN WHICH PILGRIM WORKERS ALOWED MORE THAN 2000 GALLONS OF CONTAMINATED WATER TO BE SPILLED WITH MORE THAN 100 GALLONS
e PETER W. AGNES, JR. DECEMBER 9, 1988 l
ESCAPING TO THE ENVIRONMENT ON-SITE.
THIS D'OES NOT SPEAK WELL AT ALL OF BOSTON EDISON'S ABILITY TO MANAGE'ITS PERSONNEL'S OPERATION OF PILGRIM STATION.
WE CONSIDER THIS CONSTANT STREAM OF PERSONNEL ERRORS -- SOME OF WHICH ARE VERY SERIOUS, INDEED -- TO BE EVIDENCE OF INADEQUATE MANAGEMENT, ESPECIALLY WHEN CONSIDERED IN LIGHT OF THE MEDIOCRE l
TO POOR SCORES WHICH PILGRIM RECEIVED IN THEIR LAST SALP REPORT.
WE HAVE BEEN TREATED TO A NEVER ENDING HOSANNAH ABOUT HOW MANAGEMENT OF PILGRIM HAS BEEN TURNED AROUND, YET THE PERPONDERANCE EVIDENCE OTHER THAN THE RESUMES OF THE NEW MANAGEMENT TEAM WOULD INDICATE OTHERWISE. WE DO NOT BELIEVE THAT i I
PIL, GRIM STATION SHOULD BE PERMITTED TO RESTART UNTIL DOCUMENTARY
\
EVIDENCE HAS'BEEN PRODUCED, SUCH AS A SALP REPORT WITH j l
SIGNIFICANTLY IMPROVED GRADES, THAT NUCLEAR MANAGEMENT AT PILGRIM
)
STATION HAS GENUINELY IMPROVED.
1 NEED FOR A GRADED EXERCISE SECRETARY BARRY'S OCTOBER, 1988 REPORT TO THE GOVERNOR DISCUSSES THE DEGREE TO WHICH PILGRIM AREA EMERGENCY RESPONSE
. PLANS, FACILITIES AND PERSONNEL ARE NEW. WE BELIEVE THAT SO MANY VAST CHANGES AND ENHANCEMENTS HAVE BEEN MADE TO EMERGENCY RESPONSE PLANS AND CAPABILITIES SINCE THE LAST EXERCISE WAS HELD )
l IN SEPTEMBER OF 1985 THAT THE PRESENT EMERGENCY PREPAREDNESS 4 SITUATION RESEMBLIS THAT OF A NEW LICENSE. FOR THIS REASON ALONE, PILGRIM STATION SHOULD NOT BE PERMITTED TO RESTART UNTIL A )
l SUCCESFULL FULL-SCALE EXERCISE OF ALL PLANS, FACILITIES, AND I
1
PETER W. AGNES, JR. DECEMBER 9, 1988 PERSONNEL HAS BEEN HELD WHICH DEMONSTRATES ALL FEMA EXERCISE OBJECTIVES.
THE NRC STAFF ALLEGES THAT THE COMMONWEALTH OF MASSACHUSETTS' HAVING HELD EXERCISES FOR OTHER NUCLEAR POWER PLANT EP2'S IS EVIDENCE OF SOUND PREPAREDNESS TO RESPOND TO AN ACCIDENT AT PILGRIM. THIS ARGUMENT IS PATENTLY ABSURD. AN '
EMERGENCY EXERCISE FOR ONE SITE INDICATES ABSOLUTELY NOTHING ABOUT EMERGENCY RESPONSE CAPABILITIES IN OTHER EP2'S. THE MASSACHUSETTS RESPONSE SYSTEM IS DESIGNED SUCH THAT FIRST RESPONSIBILITY FOR PUBLIC SAFETY RESIDES WITH LOCAL AUTHORITIES, AND THERE HAS BEEN NO DEMONSTRATION OF LOCAL CAPABILITIES IN THE PILGRIM EP2 COMMUNITIES FOR MORE THAN THREE YEARS. DR. MURLEY OF
,THE NRC MOREOVER HAS ASSERTED THAT PLANS FOR RESPONSE TO AN.
ACCIDENT AT PILGRIM STATION ARE BETTER THAN EVER. I SIMPLY CANNOT IMAGINE HOW SUCH A STATEMENT CAN BE MADE IN THE ABSENCE OF 4
A MEANINGFUL TEST OF THE PLANS.
IT IS THE POSITION OF THE COMMONWEALTH THAT A FULL-SCALE GRADED EXERCISE MUST PRECEED ANY MOTION TO RESTART PILGRIM ,
l I
STATION, BUT THAT AN EXERCISE SHOULD NOT BE HELD UNTIL WE HAVE PLANS TO TEST WHICH HAVE BEEN APPROVED BY ELECTED OFFICIALS IN EACH EP2 AND HOST COMMUNITY. THE FACT IS THAT, TO DATE, NOT ONE OF THE SEVEN EP2 AND HOST COMMUNITIES HAS INDICATED TO ME THAT THEIR PLANS ARE SUFFICIENTLY COMPLETE THAT THEY SHOULD BE SUBJECTED TO A FULL-SCALE EXERCISE.
PETER W. AGNES, JR. DECEMBER 9, 1998 CONCLUSIONS _
, LET ME REITERATE THAT THE COMMONWEALTH OF MASSACHUSETTS IS ,
NOT OPPOSED CATEGORICALLY TO THE OPERATION OF PILGRIM NUCLEAR POWER STATION. HOWEVER, WE CONSIDER OUR RESPONSIBILITY TO PROTECT PUBLIC SAFETY TO BE A SOLEMN OBLIGATION, AND i SIMPLY CANNOT TELL YOU'TODAY THAT EMERGENCY PREPAREDNESS HAS REACHED THE POINT WHERE I CAN ASSURE THE PEOPLE I SERVE -- AND YOU THE COMMISSIONERS -- THAT PUBLIC SAFETY CAN BE ADEQUATELY PROTECTED SHOULD THERE BE AN ACCIDENT AT PILGRIM NUCLEAR POWER STATION.
THE AGENCIES OF THE COMMONWEALTH OF MASSACHUSETTS AND THE PILGRIM EP2 AND HOST COMMUNITIES HAVE EXPENDED AN ENORMOUS EFFORT TOWARDS DEVELOPING THE BEST POSSIBLE EMERGENCY RESPONSE SYSTEM,
- AND WE APE GRATEFUL FOR BOSTON EDISON'S SUPPORT FOR OUR EFFORTS.
WE ARE ALL PROUD -- I BELIEVE' JUSTIFIABLY PROUD -- OF THE PROGRESS WE HAVE MADE IN EMERGENCY PREPAREDNESS, BUT LET ME SAY ONCE AGAIN THAT PROGRESS DOES NOT SAVE LIVES.
WE ARE DOING EVERYTHING WITHIN OUR ABILITIES TO DEVELOP ADEQUATE EMERGENCY RESPONSE PLANS, AND WE INSIST THAT THE NUCLEAR REGULATORY COMMISSION DOES EVERYTHING WITHIN ITS POWER TO ASSURE
- THAT PILGRIM STATION IS OPERATED SAFELi.
IT WOULD BE IRRESPONSIBLE FOR THE NUCLEAR REGULATORY COMMISSIONERS TO AUTHORIZE THE RESTART OF PILGRIM NUCLEAR POWER STATION UNTIL THE FOLLOWING CONDITIONS ARE MET:
- 1. THAT EACH EMERGENCY PLANNING ZONE AND HOST COMMUNITY HAS IN l PLACE AN EMERGENCY PLAN WHICH MEETS ALL REGULATORY REQUIREMENTS AND WHICH HAS THE FAITH AND ENDORSEMENT OF LOCAL
PETER W. AGNES, JR. DECEMBER 9, 1933 1
OFFICIALS,
- 2. THERE HAS BEEN A SUCCESFUL FULL-SCALE, GRADED EXERCISE OF ALL EMERGENCY PLANS, FACILITIES, AND PERSONNEL FOR THE PILGRIM 1
AREA, AND
- 3. COMPELLING DOCUMENTARY EVIDENCE IS PRODUCED THAT BOSTON l 1
i EDISON CAN MANAGE PILGRIM STATION IN A SAFE AND RESPONSIBLE l MANNER.
THANK YOU. I WILL BE HAPPY TO RESPOND TO ANY QUESTIONS I
OR OBSERVATIONS YOU HAY WISH TO OFFER.
O S
e ,
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. T~, Federal Emergency Management Agency g Region I J.W. McCormack 1%t Omce and Court House
. . Boston, Massachuse 409
'\
ac ,: ,
OCT 13 Lo f( ' '-
5' g g(sd Charles V. Barry, Secretary Executive Office of Public Safety J Connonwealth of Massachusetts .
One Ashburton Place Boston, liassachusetts 02108
Dear Mr. Barry:
This is an interim response to your letter of September 6,1988, and September 29, 1938, in which you responded to my August 22, 1988, letter concerning radiological emergency planning and preparedness for the Pilgrim Nuclear Power Plant. Your letters did not arrive in our office until Saptember 16, 1988 and October 7, 1988, respectively.
Subsequent to receiving your' September 6,1988, letter, Mr. Robert '
J. Boulay,. Director, Massachusetts Civil Defense Agency and office of Bnergency Preparedness, submitted copies of the initial Draft Radiological Bnergency Response Plan for the Town of Marshfield,
- ~ Massachusetts; copies of a revision to the Draft Radiological .
- anergency Response Plan *for the City of Taunt'on, Massachusetts;
- copies of a revision to'the Deaft Radiological anergency Ra'sponse Plan for 'Ibwn of Bridgewater, Massachusetts,and copies of the
- MCDA Area II Draft Radiological anergency Hosponse Plan for review.
In addition, we just recently received a draft copy of the latest canprehensive report to Governor Dukakis on radiological emergency planning and preparedness at the Pilgrim Nuclear Power Plant.
letters, Before we fully respond to your September 6 and 29, 1988, we would like an opportunity to carefully study and review the report to the Governor and the latest draft planning doctaments that have been submitted for review. . Hopefully the comprehensive report to Governor Dukakis will address the exact status of the Pilgrim
- planning effort and include projected canpletion dates or milestones for canpleting the planning not yet scocuplished.
Please contact me at 223-9540 in Boston if you have any questions.
Sincerely,
' Henry G. Vickers Regional Director
ADx 8 /)M40AM6t%Y f e/ d.JCZC MJh$$
$2:ocs/he h ibeof $ ldh $l$
0e $1llusfon $ dice Michael S. Dukakis
- '" $oJlon,e b JJaadaJClb OS/'0S ,
charles v. Beny W
November 18, 1988 Mr. Julius W. Becton, Jr., Director Federal Emergency Management Agency 500 C. Street / Southwest Washington, D.C. 20472
Dear Mr. Becton:
I am writing in an effort to clarify a matter we have brought to the attention of the NRC staff with regard to emergency planning for the Pilgrim Nuclear Power Plant.
I have enclosed an excerpt from a transcript of a meeting with NRC Staff, including Dr. Thomas Murley, Director of N.R.R., in Rockville, Maryland on October 5, 1988 (Transcript
'pp. 84-92). On page 89, Dr. Murley observed that'with respect-to offsite emergency planning, " Pilgrim is not a particularly difficult site. In fact, it does not even make the' top ten difficult sites in the United States in terms of emergency planning." Later in the proceeding, Assistant Secretary Peter Agnes asked whether there was any other licensed commercial nuclear power plant in the nation where the state had declared offsite emergency plans inadequate and where FEMA too had -
withdrawn interim approval of such plans (Transcript pp. 90).
Dr. Murley responded by claiming that Mr. Agnes was mistaken (transcript p. 90).
This issue also was brought up by several of the speakere at the full NRC Commission meeting in Rockville, Maryland on October 14, 1988. I have enclosed a complete copy of that transcript for your review.
My question is can you identify a fully licensed and operating commercial nuclear power plant in the United States where state and local government have declared offsite emergency response plans to be inadequate, and where FEMA has declared that "offsite radiological emergency response planning
- and preparedness are inadequate to protect the public health
- and safety in the event of an accident" and also doclared that its previous interim finding of adequacy "no longer applies,"
as FEMA did in the case of Pilgrim? See enclosed memorandum of Richard W. Krimm dated 8/6/87.
Julius W. Becton, Jr.
November 18, 1988
- Page Two-We also would appreciate it if you could tell us whether FEMA has-a timetable for reevaluating its interim finding of August, 1987 regarding Pilgrim? ,
Sincerely,
., Charles V. Barry Secretary of Public Safety CVB/cas l l
i 4
4 4
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September 6, 1988 f l
1
. I l
q Mr. Henry G. Vickers, Regional Administrator-Federal Emergency Management Agency Region I Office and Court House 442 J.W. McCormack Post ,
j Boston, MA 02109
Dear Mr. Vickers:
22, 1988,-in I am in receipt of your letter dated August 1988, about the response to my letters of May 27 and July 7,in reviewing Radiological evaluation criteria employed by F.I.M. A.
" Emergency Response Plans for Pilgrim Station.
Your observation that' there is a great. deal of work to be done t
...q to complete the development of. these plans, pri'er to an I am currently assessmen in the
.j
' regarding their adequacy, is correct.
process of preparing a comprehensive reportatfor the Govern Pilg:im aspects of emergency preparedness for an accident Station._ My report will spell out in detail the statusand ofwhat the issues- ref e: red to in your letter, as well as others, re state and local government. l 1
'* In response to your reque'st for a work plan and afor specificatic Pilgrim
._of deadlines.for. comp 1.eting we have work ontime said' offsite andplanning again. "he is Station, I repeat whatalong with local governments and the, licensee, 1966 Commonwealth, following a planning process established after our December, had been It is unfortunate that F.I.M.A.
report to the Governor. ,
unable to attend any of the numerous planning sessions and severa:
the Commonwealth has hosted over the past I conferences that
! years.
that even if a complete <
~'
It is our strong conviction, however,the applicable federal a standard has plan appears to meet be made unless and until it
- determination of adequacy cannot such a requirement been tested by a full scale offsite exercise.
i t d is particula:1y appropriate a revision to an ea:11e: plan, butthis and necessary in ra:hca with new plan would constitute a completely new plan,notbased upon a new approach,eme rgency pers procedures designed for a large number of new schooled under an entirely new ::aining r e g i .e n.. ,
t .
~
1 Henry G . "ictte r s
,.., Septemoer 6, 1988
) Page Two I
1
'The Commonwealth believes strongly that Pilgrim should not be pe'rmitted to restart without.an approved effsite plan that has
' withstood the rigors of a full scale, grade.i exercise. There isthe great concern among local residents and of ficials, which we at '
state-level share, regarding the lack of reasonaole assurance that the public health. and saf ety can be protected in We,.therefore the absence of urge a i completed, tested and approved emergency plan.
F.I.M.A.
to withhold any restoration"of interim approval to of f site i plans until the new Pilgrim plans have been. finally completed and approved by local and state government and tested by a full scale, graded exercise.
To date, neither N.R.C. Region I Administrator William Russel nor N.R.R. Director Dr. Thomas Murley have been willing to state with precision what in their opinion must be demonstrated to the offsite emergency reso,1ve the N.R.C.'s concerns about preparedness problems. For example, they have not stated whether approved plans and imp'lementing procedures (particularly for the special needs populations), the emergency worker tr,aining program, letters of, agreement, three fully ecuipped and operational reception centers, the procur.ement o(. radiological monitoring and
) communications equipment, a new EPI publication, and transportatier.. but
~ resources all must be in place bef ore restart or whether some, 'Neither not all, of the' above must be demonstrated before restart.
have Regional Administrator Russell nor Director Murley stated whether a graded, full scale exercise must take place before ,
restart.
Instead, we have been advised by N.R.C. staff that these are <
Since we matters for F.E.M.A. to address in the first instance.
is scheduled to take up the matte are advised that the full N.R.C.
- of the Pilgrim restart on October 14, 1988, we believe it is time for F.I.M.A. and the N,R.C. staff to provide us with answers to these questions.
I look forward to a prompt response.
Sir eTely, t JUy .
Charles V. Barry
> Secretary of Public Safety Cv3/cas cc: Dr. Thomas Murley, Director, N.R.R.
Mr. William T. Russell,. Region I Admi nis t r a t o r
e e e -- - .. m c .. s..nm .:a - - - - - - - - - - - - - - - - - - - - -
. ;2----- ---- - -
WQBBINE_QBQU2_!:iEEIIU2 From: March 17, 1987 To: December 8, 1987 Total Meetings Held - 77 (See attached attendance reports)
EEECI& _dEEIINES , .
Total meekings Held (See attached attendance reports) dEEIINEE_QISEB_IB98.WQBBINE_98QUE 1
Total Meatings Held - 148 (See attached attendance reports) e 0.'8 g 1
l
- - _ - _ _m...______-.
120Z_:_ dss 11can_e11medag_cateC_iban_WrChics_Gesus:
March 31, 1987 -
Kingston RERP Committee meeting at Kingston.
April 1, 1987 -
Taunton RERP Committee meeting at Taunton.
April 6, 1987 - -
Kingston RERP Committee meeting at Kingston.
April 7, 1987 -
Bourne Selectmen regarding expansion of EPI.
April 13, 1987 -
Kingston RERP Committee meeting.
April 13, 1987 -
Plympton Selectmen's meeting regarding EPZ expansion. -
April 14, 1997 -
Plymouth County end civil Defense Director regarding ETE at Plymouth.
April 16, 1987 -
Taunton Red Cross at Taunton.
April 1E, 1957 -
Marmnfield RERP at Marshfield.
April C1, 1987 -
Duxbury RERP Committ=o === ting at Dunbury.
April 27, 1987 -
MDPW meeting regarding RERP. .
April 28, 1987 -
Wareham Civ.il Defense Director regard.ing expansion of EPZ.
April 29, 1987 -
Bridgewater RERP Committee meeting at Bridgewater.
May 5, 1057 -
Carv=r Superintendent of Schools regarding RERP at Carver.
May 8, 1987 -
Carver Superintancent of Schools regarding RERP at Carver.
May IC, 1007 -
Plymouth RERP Committee meeting at olymouth.
May 15, 1987 - Red Cross RERP Committee meeting at Brockton.
May 20, 1987 - BridDewater RERP Committee meeting at Erid g= wet er.
May 21, 1987 - Marshfield RERP Committee meeting at Marshfield. o May 25, 1987 -
Kingston RERP Committee meeting at KingcLon.
May 27, 19S7 -
NRC, GALP at Plymouth.
May 29, 1987 -
Kingston Selectmen's meeting regarding RERP.
e
4 i
e 1302_:_Utt11DEE_a11RDERG_21 HEC _1bGD WGCB1LE_9."ggge: (cont.) Page 2-June 11,- 1987 -
Plympton HERP meeting regarding expansion of 4 EPZ.
l
\
sube us, 15mi -
cP1 mewtang an Waymouth. f JunG 23, 1987 -
Handicapped Afinirm mw ting in Plymouth.
July 2, 1987 -
MCDA training officer regarding RERP training. ,
o July 7, 1987 -
Plymouth RERP Committee meeting at Plymouth Town Hall.
July 9, 19S7 -
Ouwtury RCDP Csmmitt== ==ct ir.g at Du:: bury.
July 13, 1987 -
Weymouth Selectmen's meeting regarding reception center to north.
July 1 'i , 1927 -
NnO and MCOA mesting r=garding =n=cn=ien of EPZ.
July I'2, 1987 -
Plymouth RERP Committee meeting at Plymouth
. for all EPZ and host eiv11 defense directors.
July 28, 1987 -
'MCDA RERP. meet'ing with MCDA at Framingham.
July 28, 1987 -
Carver Selectmen 5s meeting regarding RERP at Carver.
.Tipy pm, 3ma7 - Caev r Civil ner n . nir rtne e.gmeding RERD at Carver. -
August 5, 1987 - Kingston Civil Defense Director regarding RERP at Kingston.
August 10, 1987 -
Bridgewater Civil Defense Director regarding RERP.
. August 11, 1987 -
Bourne Selectmen, Police, Fire, Civil Defense Director regarding RERP.
August 12, 1987 - Plymouth RERP at Plymouth, i
August 13, 1987 -
Marshfield RERP at Marshfield. !
a August 25, 1987 -
Carver Selectmen and Civil Defense Dirs: tor regarding RERP.
August 21, 1007 -
Duxeury Sels=t=sn's m==tir.g r=ge.rting RERP.
)
1 o
\
126Z_:_det11cun_e11Qndad_21btC_1bsn_WsChion_ECrust ( ==nt . ) Pace 3 September 1, 1987 -
Kingston 5electmen's meeting regarding RERP.
1 September 2, 1987 -
Plymouth RERP meeting at Plymouth.
l September 8, 1987 -
Attended training meeting at EOF, l
September 8, 1997 -
Bridgewater Selectmen's meet ing regarding RERP.
Captember 10, 1987 -
Bridgww Lwr
- RERP Committas masting at Bridgewater.
Captember 14, 1987 -
Plymouth RERP Committss meeting et Plymouth.
September 15, 1987 -
7aunton Council meeting on RERP.
E=pt==b=P 16, 1987 - *---"*d id RERP Ccemitt== m== ting at Marshfield.
September 21, 1987 -
Taunton RERP Committee meeting at Taunton.
September 23, 1987 -
Dridgewater RERP Committee meeting at Bridgewater.
Emptemb.sr 22, 1987 - -
Carvsr Handicapps5 mas [ing with Civil" "
Defense Director.
September 22, 1987 -
Marshfield RERP Committee meeting mL Marshfield.
September 28, 1987 -
Carver RERP Committee meeting at Carver.
September 20, 1987 -
Plymouth RERP Committee meeting at Plymouth.
October 5, 1987 -
Carver RERP Committee meeting at Wareham.
October 7, 1987 -
Bridgewater RERP Committee meeting at Bridgewater.
C=tober 12, 1957 -
MCDA training officer regarding training program.
October 20, 1987 -
MCDA trasning meeting at Framingham.
Cctober 31, 1937 -
Kingshan RCRP CammilLww mwotit)Q ;t Ming:t;n.
October 21, 1987 -
Plymouth RERP Committee masting at Plym=uth.
not oh.-r .24, icA7 -
F i d gewa t a.- RERO Committes meeting at Brid:eweter.
October 29, 1987 -
C-Med meeting in Hanson regarding ambulances.
m .
1282_:_ den 110ss_srienced_etba:_ibco_Wechics_Ec29si (cont.) page 4 October 29, 1987 -
EPI meetinD at Bridgewater. -
November 2, 1987 -
Bridgewater RERP.
9electmen's Maeting regarcireg November 9, 1987 -
Dridgewater RERP Committee meeting at Bridgewater.
N=vomb=r 13, 1007 .
- 144 maating on RCnp at .?ramingitam.
December 7, 19B7 -
Transportation meeting in preparation for visits to the bus companies.
D = = =r.ib a r S . 1987 -
Training meeting at Plymouth ECO.
Decameer v. Ivut -
Marsnrield RERP at Marshfield.
December 10, 1987 -
Kingston training at ECC.
December 10, 1987 -
Transportation meeting regarding bus providers.
December 14, 1987 -
Notification meeting at MCDA.
December"16, 198 Transportation with bus providers.
December 18, 1987 -
Transportation with bus p'eviders.
r December 22, 1987 -
ETE meeting with State Police.
I 1
1 e
1 l
1 l
I h
_______._____y _ _ _ _ _ _ _
)
l k
issa_:_enntinss_atianseg_cibsr_ nec_wscalen_sceus: Page C January 5, 1988 Met with three transportation providers.
- January 8, 1988 -
ETE meeting with Edaville Railroad. I January 6 1968 -
Plymouth RERP Committom rnanting at Alymouth.
January 7, 1988 -
Taunten RERP Committ== === ting at Taunton. i January 7, 1988 -
Met with Brewster Ambulance regarding transportation.
January 12, 1988 -
Carver Civil Defense Director regarding training at Carver.
January 13, 1988 -
Marshfield RERD Committee meeting at' Marshfield.
January 20, 1988 -
Carver training meeting at Area II.
January CO, 1980 -
Marshfield training meeting at Marshfield.
January 22, 1983 -
Plyn)cubh County, braining maating at Plymouth.
January 27, 1988 -
Coast Guard coordination meeting at , Plymouth.
Febru'ary 1, 1988 -
Red Cross meeting at Framingham.
February 2, 1988 -
Cerver RERP meetire with Edeville Rail'oed.
- Penruary 2, 1986 - 1 carver nelectman's meeting regarcing Henv.
February 2, 1988 -
Plymouth MCI RCRP meeting.
February 8, 1988 -
Attended RERP meeting Area II plan.
February 10, 1988 -
Taunton State Hospital regarding RERP reception center.
February li, 19G8 -
Bridgewater State College regarding RERP recept ion center.
Fabruary 11, 1003 -
MOPW regarding staging areas.
February 24, 1988 -
Plymouth RERP Committee meeting at Plymouth.
February 29, 1988 -
BridDewater Executive Secretary regarding RERP.
March 1, 1988 -
Plymouth Civil Defense Director regarding training for RERP.
March 9, 19AA -
no w nn, y appo Neara4+4== cn==+4mg et nu - t,ury .
_ _ m _ -- ,_ m ~,_ u _oq p peg- ,
y 1200 0 U :1102%_fl1E022n_210E0.Ibst_d' gnhing_QC2ME: (: ant.) Page 6 March 14, 1988 -
Marshfield RERP Committee and Board of-health at Marshfield.
maren 16, 1988 -
RERP meeting in Framingham.
March 23, 198E -
Plymouth RERP Committaa meeting et Olymouth.
March 24, 1988 -
ETE meeting at Plymouth.
March 28, 1988 -
Handicapped Affairs meeting in Plymouth.
March 31, 1988 -
Wellesley DPW regarding third reception center.
March 31, 1988 -
Notification meeting at Framingham.
April E, 1988 -
Bridgewater training meeting regarding RERP. i May 12, 1988 -
MOPW regarding Eagainor w staging area.
May 16, 1988 MDPW District 7 regarding " Park and Ride" staging area.
May 23, 1988 - ~
. Myles Standish State Forest ' training meeting regarding RERP.
June 1, 1988 Wellesley DPW regarding facility.
June 7, 1988 -
Plymouth RERA.
County C-Med committee regarding i June 10, 1988 -
MDMH training meeting at Framingham.
June 15, 1988 -
Plymouth RERP Committee meeting at Plymoutn.
July 8, 1988 -
MDDW
- m 4 mi rc meet ing at Plymouth.
July 27, 1988 -
.. MDPW District ~7 Micdleboro RERP training. '
August 9, 1988 -
Kingston RERP at Kingston.
August 10, 1988 -
Rod Cross regarding RERP at Framingham.
August 24, 1988 -
NSEPP Bridgewater meeting with Iccal communities and Peter A D n***
Augu=t 21*, 198S -
Duxbury Man's Club, BECo, CURE.
' Sect ember 15, 1988 -
Dunbury RERD Cemmittaa and pates- A g ne n.
September 19, 1988 -
KinDaten Gehool Committee, Civs1 batense Dir=ctm" Taveres, Deputy Direeter Weecworth.
_ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ - - - - - - - - - - - - - - - - - ~ ~ -
_ _ _ _ - - --~ ~ ~ p.?
i l
13aa_:_destions_eticrdrd_ iber_ibs0_WIChirs_2:222: teent.) Pag: 7 September 27, 1988 -
Plymouth - Local anc regional school
. ==mmitt===.
September 28,. 1988- -
Duxbury school. I October 1, 1988 -
Kingston EOC open house.
- Uctober 4, 1988 -
Plymouth - Local and regional school committees,. Civil Defense Director Hadfield. -
Cetober 8, 1988 -
Duxbury, Peter Agnes, CURE, Plymoutn, Marshfield, Cape Cod, MDPH, MCDA, MA Asst.
Attorney General.
October 15, 1000 -
Plymouth ECC opan huuww.
Cetober 24 1988 -
olymnoth arkan1 =h= 1 & ar; =e8nei committees, DECO. MCDA, Plymouth Civil Defense Director.
October 25, 1988 -
Plymouth school committees (elementary and regional)'for vote.
August, 00, 1938._ -
M, C. me.whing an equipment at. Area II. .
. August 31, 1988 -
Kingston RERP Committee meeting at' Kingston.
August 31, 1988 -
Marshfield RERP Committee meeting et I Marshfield.
September 1, 1988 -
Carver RERP Committee meeting at Carver.
September 15, 1988 -
Duxbury RERP Committee meeting at Duxbury.
Septwmbwr 21, 1588 -
Marshfield RERP Committee meeting at Marshfinid.
Geptember ES, 1988 -
Plymouth RERP Committom meeting et Plymouth.
October 8, 1988 -
Duxbury and EPZ Superintendent of Schools at Duxbury.
O=tober 25, 19ES -
NRC visit to Ouxbury, Taunton, Kingston.
October 27, 1988 -
NRC visit to Carver.
October 31, 1988 -
Plymouth Deuth High School, joint school committee meeting regarding RERP. !
November 2, 1988 -
NRC visit to Bridgewater.
Nav=mber A, 1990 -
Cemst Guard training meeting rusceding RERS.
l
'12EE_:_TREEj.DEE,#ttDDGEG_otb.t" tbsn,WO y.ir2 Ercu 1 (eent.) Pa;;e S November 10, 1988 -
.D1ymouth RERD Committas siisating et Plymvulh.
November 17, 13G5 -
Duxoury Gehool Committee meeting regarding RERP.
November 17, 1988 "
Duxeury schools, PTA, Civil Defense Director, Principais, Superintendent.
l November.22, 1988 -
Diymouth Civil Defen== Dies = tor Hadfield and regi.enal scheci officials.
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12S2_ _9EEE1A1_C.!EEilD22 121 CEC 10AD i:!2Ci!1DE_EC29g Page ~,
Wilu_sil_EEI_nDs b221_EEGUNDiiiEE_GCEEEDI)
April 10, 13G7 - Offico of Handicapped Affairs and local office regarding curvey.
April 14, 1987 --
MCDA, Plymouth County and CDDs from each of the 7 communities rcegarding ETE.
April 22, 1987 - Meeting for all CDDn with MCDA in Plymouth.
June 29, 1987 - Handicapped Affai'rs meeting in Plymouth.
June 29, 1987 - EPI meeting in Plymouth.
~- Office of Handicapped Affairs at Plymouth July 16, 1987 -
regarding RERP.
July 22, 1987 - All CDD and Staff with Secretary Barry, Secretary Pollard and MCDA at Plymouth Town Hall regarding RERP . .
October 29, 1987 - Duxbury High School, State, Local, Federal meeting regarding RERP. Called for by Selectmen in Duxbury.
November 6, 198,7 - Special-Working Group'meetinD.with Mr..
A g n= r. , E=1=ctmen, Eenst = r=, Re;:res ent r.t ives ,
and CDDs regarding progress report.
Decs=mbar 3, 167 -
Wandiempped Affairs menting in Plymouth.
December is, 1987 -
Harbor Master, Coast Guard and Civil Defense Director coordination rnesting.
S 0
0
12SS_ ..Esasial 5ke11Las_f.stbrC_ibac_W2:liina Q 2 LIE Pena 10 wiib c11_EEI_Ect_f.2E1_IstCuniiica_2rEEEL1)
January 7, 1908 - Senate Hearinor, held in Plymouth by Senator Kennedy.
J ar'eu er y 12, 1958 -
Handicapped Affairs meeting at Secretary of Public Safety's of fice, Seaton. ,
May 11, 1988 -
NRC rnest irig in Plymouth.
June 16, 1988 -
Public Safety meeting, Plymouth Town Hall with Peter Agnes.
August 4, 1988 -
Public Safety meeting at Plymouth Town Hall regarding participation in the augmented team inspection, 3:30 meeting, public officials. .
August 4, 1988 -
Puolic Safety meeting at Plymouth Town Hall f or- general public.
August 25, 1988 -
NRC meeting, Sheridan Hotel, Plymouth.
F.ugust 00, 1000 NTIO Out c. rarait t aa rasating at Mataw ini Hall,
, Plymouth with P. Agnes, BECo, MA Citizens
. for Scfe Energy. .
September 29, 1988 * -
Plymouth - NRC Region 1 (W. Russell), Peter Agnes, Kingston, Duxbury, CURE.
October 6, 1988 -
Duxuby - School Superintendent, MCDA, D un b ury-r*1 ymo ut n , Mat-=n f i = 14, Eilv=r Leh=
Schools.
6
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4
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GQBBMD11Y: PLYMOUTH Date entered: 12-02-68 RERP 10-30-87 Rev. 6 Received 10-30-87 Cross Reference Rev. Received Corrective Action Response Iaalementins_Ernsedursei__ Hens _fsrustdsd_ts_ HEE 6_as_sf_12:92:AA.
RERP Part IE He. 1Hess1Ests Eressdure_I111e Draft _He. Italsesnted 01 (1) Board of Selectmen J, M 02 (1) Civil Defense Agency C, E,F,H,J 03 (2) 10-12-88 Police Department 7 E, J 04 (2) Fire Department E, J, X 05 (1) 02-17-88 Public Works Department 2 J 06 (2) ,
School Department _.
.J 07 (1) Board of Health- J i l
08 (1) Radiologiesi Officer X 09 (1) Transportation Officer J j 10 (1) 03-10-88 Shelter Officer 0 J 11 (1) Harbor Master J 12 Council on Aging J
=13 (2) Emergency Medical Servicae J, L
~
=13 (1) 02-17-88 Communications Officer o
- Duplicate Numbers (1) RACES (2)(4) Special Needa Officer (2) Dept. Mental Retardation (2) Mass. Dept. Mental Health (3) Health Officer *
(2)(5) ENMDS l
21 (1) Public Information G l
PLYMOUTH Italementins_Ernandursa:
RERP Part 12_Ne- 1Hets1 Gate Eresadura_Illie DEsit_He- Italemented 22 Monitoring and Decontamination J, X 23 Handling Contaminated Injured L Persons 24 (2) 01-14-88 Massage Control i H 25 Siren Activation E 26 Training , O 27- Drilla and Exercises N 28 Program Maintenance P 30 09-14-88 Teleconsunications' Devices i for the Deaf 41 (1) Tiny Town Child Care ' J 42 (1) Jack and Jill J
43 (1) Xinder College J 44 (1) Busy Bee Nursery and J Day Care ;
1 45 (1) Xidsport, Inc. J 46 (1) Seven Hilla Nursery School J 47 (1) Methodist Nursery School J 48 (1) Cooperative Child Care J 49 First Baptist Church J 50 (1) Zion Christian Pre-School J 51 Little People's Place J 52 (1) 01-27-84 Happy Day Nursery, Inc. O J 53 (1) Xinder Haus Nursery J .
1 l
~
PLYMOUTH Imaissantins_Etesadutsa:
RERP Part IE_Es- IHetalEmin Ernsadurs_Iltle Desit_Es. Italaasntad 54 (3) Pilgrim Manor Child Cara J 55 (1) 01-29-88 New Testament Christian J School .
56
- 57 (1) Pinewood School of Montessori J 58 (2) South Shore Industries J 59 (2)(4)(5) Jordan Hospital J 60 (1) Mayflower House J 61 (1) Pilgrim Manor J 62 (1) Beverly Manor J 63 (1) Newfield House. J 64 (1) Plymouth Nursing Home J'
65 (1) Chilton House J
- 6 (1) High Point J 67 (1) Plymouth Day Habilitation J 64 Rainbow J 69 (2) Cachalot Scout Reservation J 70 (2) Camp Clark J 71 (2) Camp Massascit J 72 ,;(2) Camp Squanto J 73 (2) 04-14-84 Camp Child 1 J 74 (2) YAD > J C
I .
l FL'YMOUTH I
Imelsaantins_Ersendursa:
RERP Part IE No. 1Hets1 Data Ernesdure_Iltis Qrmit_He. Imalsannted l 75 Pinewood Camp -
J 76 (2) Camp Rournedale J 77 ,
(2) Baird Center J .
78 (
,2) Wind in the Pines J 79 Plymouth Jail J 80 (1) 03-10-88 Shelter Manager 0 (1) New Testament (1) Pilgrim Manor Day Care (2)(3) Plymouth Discovery Center (2)(3) Saquish HQIE3! As of 12-02-88 .
(1) Approve'd "ir} conce'pf." by Selectmen. .
(2) Awaiting a'pproval "in eencept" by Sal'actmen.
(3) Approved by RERP Committee.
(4) Awaiting approval by RERP Committee.
(5) Awaiting approval by agency head.
kammen_Elsna:
Hea Iltle Ests 3-1P Intro to the EOP 07-26-88 3-2P Communications Officer 03-16-88 3-3P RACES / ARES 04-29-88 3-4P Overview of Message Control ,,05-01-88 l
3-5P Board of Selectaan 04-29-88 e
, , q l
PLYMOUTH
\ .
Het Iltis Date 3-8P Radiological officer 04-29-88
\
3-7P
- Special Needa 04-29-48 I 5-1P Intro to Police Dept. 07-21-88 5-2P Police Servicae os'ficer 10-25-88 l
5-3P Shift commander 10-23-48 5-4P Petrol Supervisor 10-25-88 5-57 Police Dispatcher 10-25-88 5-6P Eco Security officer 10-25-88 Se77 Security Officer Memorial Hall 10-25-88 i 5-SP EOC Initial Monitor- 10-25-88 5-9P Police EOC Radio Operator 10-25-88 -
6-1P Intro to Civil Defense 05,-16-88 6-2P Civil Defense Director 06-16-88 6-3P Operationa officer 05-16-84 7-1P Intro to DPW 09-20-88 7-27, Public Worka officer & Highway 09-20-84 Supervisor 7-3P Route Alerting 09-20-88 7-4P Deatmatry Coordinator 09-20-84 8-1P Harbor Master 10-28-88 9-1P Overview of EMS 08-01-88 12-6P Intro to Transportation 07-22-88 12-7P Transportation Officer 07-15-84 12-9P Staging Area Managers 07-15-88 4
PLYMOUTH l
Het Title Dans 12-9P ,
Tran'apertation Dosimetry 07-14-88
, Coordinator ]
12-10P Vehicle Dispatcher 07-15-88
, 19-1P Intro to Board of Health 07-06-88 21-1P Shelter Cff1cor 03-16-44 4
E e
F M
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m GesBWn11g: DUXBURY Date entered: 12-02-88 RERL 5-07-85 Rev. 1 Received 5-07-45 Imelssentins_Ernanduran:
As of 12-02-48 the Civil Defense Director reports that they have a total of 38 IP's on hand.
Three of these, Selectmen, Town Manager and Public Affairs, are under development. ,
All of the others are complete and have been reviewed by the respective i department heads. DPW and Harbor Master need drastic changes. f RERP Cosaittee members have 35 IP's in their possession and are currently reviewing on an individual haaia, =
i l
The RERP Committee has not met formally to review and forward the IP*a to the Selectaan.
Leamen_Elsna:
Hai Iltle Date U
11-1D Duxbury Introduction t'o School 08-01-88 Procedure 11-2D Superintendent and Staff 04-29-88 11-3D Duxbury School Principala 03-28-88 11-4D Maintenance Staff 03-29-88 19-1D Overview of Board of Health 10-06-88
..y
l .
GGEEuD1123 CARVER Dato entered: 10-18-C4 RERP 6-24-88 Rev. 4 Raceived 6-24-88 _
Cross Reference 10-03-88 Rev. O Received 10-03-88 C rrective Action Response 10-03-88 Received 10-03-88 Italementins_Erssedurent RERP Part.
IE_Hs- _Qate. Erssedurs_Iitin Dratt_Ha. Innlenented 01 06-30-88 Board of Selectmen 'l J, M 02 08-15-88 Civil Defense Agency 2 C, F, H, J 03 10-07-88 Police Department 3 E, J 04 09-21-88 Fire Department 4 E, J, X 05 10-07-88 Public Works Department 2 J 06 07-14-88 School. Department 0 J 07 06-27-88 Board of Health 2 J
- 08 ,08-18-88 R, radiological Officer 4 X 09 08-19-88 Transportation officer
- 2 J 10 08-15-88 Shelter Officer 3 J 11 08-19-88 Emergency Medical Services 2 J, L 12 06-24-88 Council on Aging 1 J 13 06-22-88 Communications Officer i E, F 14 01-18-88 RACES 1 F
, 15/20 open 21 06-28-88 Public Information 3 G 22 08-08-84 Monitoring and 2 J, X Decontamination 23 07-28-88 Carver School District 0 J Transportation Provider 24 10-06-88 Message Control 2 H
. . l CAAVER RERP Part 12_No. _ Data. Erasedura_I111a DEsit_Hg. Imaissanted ;
, 25 Siren Activation E 26 Training 0 27 Drilla and Exercises N 28 Program Maintenance P -
29 Special Needa Program 4 J Maintenance 30 09-14-88 Telecommunicatichs Devices i for the Deaf 41 Cranberry Crossing Nursery J and Day Care 42 Web of Life Day Care J 43 Captain pal Preschool J 44 Kids' Count J.
45 Camp Clear J l
. i 46 Hilltop Nursing Home J l 47 Betty's Place J 48 Reach Group Home J 49 Eday111e Railroad J 50 04-27-88 Shelter Manager 2 J )
{
. 51 04-27-88 Atwood House 2 J 52 04-27-88 Benjamin Ellis School 2 J 53 04-27-88 Carver High School 2 J l l
, 54 04-27-88 Governor John Carver 2 J l School Bldg. A l
l I
CARVER RERP Part IE_He. _ Data. Ernsadurs_Iltin Draft _No. Inninannted 55 .
04-27-88 Governor John Carver 2 J j School Bldg. B
~ '
56 04-27-88 Camp clear 2 J 57 04-27-88 Pinewood Way 2 J 58 04-27-88 Crane Brook Tea Room 2 J 59 04-27-88 Faith Baptist Church 2 J 60 Open 1
61 04-27-88 VFW Post #7421 2 J 62 04-27-88 United Methodist Church 2 J 63 04-27-88 Christian Unity Hall 2 J 64 04-27-88 Cranberryville Tenting 2 J.
. and Trailer Park - .
Esseen_Elson: '
Het Iltle Date 3 Emergency Operations Center 11-01-88 4-1C Introduction to Fire Department 06-10-88 4-2C Fire EOC Rap & CFD Duty Officer 06-15-88 4-3C Fire Dispatcher 06-14-88 4-4C Siren Spotting & Route Alerting 06-14-88 4-5C Fire Dept. Deaimetry Coordinator 06-14-88 4-6R Emergency Workar Monitoring & 11-02-84 Decontamination
- 6-1C Civil Defense Dir&ctor 10-25-88 l
____,,-,,--,,---,-,s_mm, _,
l CARVER l
l Est IA11e Dans 9-1C Introduction to Emergency 02-09-84 Medical Services 9-2C Emergency Care During an Incident 02-24-88 ,
l st PNPS '
9-3C EMS ECC Rep 03-31-88 .
9-4C EMS Duty Officer /Desimetry 03-30-88 Coordinator '
11-1C Introduction to School Procedure 07-22-88 11-2C Superintendent & Staff 03-28-88 l
11-3C Principals 03-28-88 l 11-4C Maintenance Staff 03-28-88
'19-2C Council on Aging 05-16-88
~
.21-1C , Shelter Officer 07-15-88
. 21-2C ,
Shelter Manager ,
~
04-29-88 8
l I
l j
i
.,_____-._m____ m -----
f l
G98Eun81gv XINGSTON Date antered: 10-17-S8 RERP 10-04-88' Rev. 5 Received 10-12-88 Cross Reference 10-04-88 Rev. O Received 10-12-88 Corrective Action Response 10-04-88 Received 10-12-88 Chelter Implementation Program 9-30-88 Innlementins.Erasedurras -
RERP Part IE_He. Esta. Eresadurs~.IltIn Qcatt_Ha. Insiemented 01 09-27-88 Board of Selectman 4 J, M I
02 09-30-88 Civil Defense Agency 3 C, F, H, J 03 09-30-88 Police Department 3 E, J 04 09-29-88 Fire Department / Emergency 3 E,J,X,L Medical Services 05 09-26-88 Highway Department 3 J "
School' Depart'ent 06 09-22-88
' ~
m 2 J
~
07 09-30-48 Health E00 Representative 3 J 08 09-23-88 Radiological Officer 3 X 09 09-26-88 Transportation Officer 4 J 10 10-04-88 Shelter Officer 4 J 11 09-20-88 Harbor Master 3 J 12 09-20-88 Special Needa Officer 3 J 13 09-20-88 Communications Officer 3 F 14 05-31-88 RACES 2 F 15/20 .
Open 21 09-20-88 Public Information 3 G 22 09-20-88 Monitoring and 3 J, X Decontamination 9
XINGSTON i
RERP Part
.;2_Ho. ,_Qats_ 2resegura_Iltis
- Gragt_He. Ianlamented l 1
23 .
Open 24 06-03-88 Message Control 2 H 26 Training O 27 Drilla and Exerciaea N 28 Program Maintenance P
, 29 06-07-88 Special Needs Maintenance 2 -J 30 09-14-88 Telecommunications Devices 1 J for the Deaf 31 Open 41 06-06-88 Sacred' Heart Schoola 1 J
, 42 09-21-88 Growth Unlimited Preachool 3 J 43/44/45 Open ,
46 09-22-88 Camp Mishannock 2 J 47 09-23-88 Camp Norma Soy Scouta 2 J 48 09-26-88 Evanswood Retirement 2 J 49 09-30-88 Meadowerest Apartmenta 2 J 50 09-30-48 Proviencial Residence 3 J
]
1 51 09-30-88 Blueberry' Hill Rest Home 2 J l
. 52 09-30-44 Margaret W. Carter Veta 2 J Home 53 09-30-88 Shelter Manager 3 J 55 09-30-44 Sacred Heart klementary 3 J School ,
56 09-30-88 Sacred Heart High School 3 J
___ _ ___ ~ ___ _ _ _ _m.
XINGSTON
' RERp part IE_Es. _Qalm_ Erasseura_Iltis Dratt_Ho. Italemented 57 09-30-88 Step and Shop plaza 3 J 58 '
09-30-88
- Xingston Elementary 3 J School -
108 09-30-88 Cordage park Company 3 J.
Esseen_Elsna:
Het Iltlu Date 3-1X Introduction to Emergency 10-17-88 operations Center 3-2X Communications Officer 10-17-88 3-3X RACES 10-17-84 3-4X ' Message Control 10-17-88 Board'of" Selectmen
~
3-5X. 10-17-88 3-6X Radic1ogical Officer- 10-17-88 3-7X Special Needs 10-17-88 4-2X Xingston Fire EOC 04-29-88 Representative 1
5-2X Xingston polies EOC Rep c5-17-88 I 6-2X Civil Defense Director 06-02-88 1
G-3X ECC operationa Officer 06-02-84 l 7-2X Xingston Highway EOC Rep 05-16-84 8-1X Harbor Master 07-21-88
)
11-2X
- Xingston School Departnant 03-30-88 Superintendent and Staff 19-1X Board of Health ^04-29-84 20-6 public Information Assistant 08-01-88
. :. ~. . - :: .... .: -- : .. ::.. - :.- - : 2.ro :
G9BEuG11X: MARSHFIELD Data entered: 10-18-88 RERP 7-11-84 'Rev. 5 Received 4-12-88 Cross Reference 7-28-86 Rev. O Received 8-12-88 Corrective Action Response Rev. Received '
Innistentins_Ernsadurset -
RERP Part
. I2_He. _ Data. Eressdurs.I111e Ermit_He- Innissanind-01 ,07-13-88 Board of Selectmen 2 J, M 02 07-21-88 Civil Defense Agetacy 2 0, F, H, J 03 07-20-88 Police Department 2 E, F 04 07-26-88 Fire Department 3 E,J,K 05 07-25-88 Public Works Department 2 J, L !
06 07-14-88 School Department 0, J 07 , Health Department J 08 07-22-87 Radio 1#gical Officer 2 K, J 09 07 25-88 Transportation Officer 2 J 10 04-27-88 Shelter officer 2 J 11 07-20-88 Harbor Master 2 J 12 07-20-88 Special Needa 2 J 13 07-19-88 Communications Officer 3 F, K 14/20 Open 21 03-10-88 Public Information 2 G 22 07-25-88 Monitoring and 2 J, K Decontamination 23 07-22-88 Emergency Medical Services 2 24 07-22-88 Message Control 3 H
7 c a c 3c oc o e m- v res e -
_w v--------------------- ,
MARSHFIELD RERP Part IE_No. Gate. EressduEs_I111s Ersit_He. Iseltaansed 25 Siren Activation E 26 Training O 27 Drills and Exerciaes
. N 28 Program Maintenance e
P 29 06-13-88 Special Needs Maintenance 2 J 30 09-14-84 Telecommunications Devices i for the Deaf 31 Open 41' 04-27-84 Gov. Winslow Elementary 2 J School.
- 42 04-27-88 Brant Rock Union Chapel 2 J 43' ' 04-27-88 J Saint Anna by' the See 2 'J 44 04-27-88 Our Lady of Assumption 2 J Lassen_Elana Het Iltle Esta 2-5M 11-04-88 Intro to DNN Network 1
'l 4
0 4
e
ow e m - -e e x . ce . ee, - r,s r ene . g o
.GenaunitE:' 3RIDGEWATER Date' entered: 10-17-88 RERP 8-18-88 Rev. 4 Received 9-27-88 Cross Reference 8-26-88 Rev. O Received 9-27-88 Corrective Action Response 9-21-88 Iaalsasonins Ereesdurant RERP Part IE_He. _Qate. Erneedura_Iltis , Qtsit_He. Inglemensed. .
i 01 ,
03-23-88 Board of Selectmen 3 J, M l
02 08-08-88 Civil Defense Agency 3 C, F, H, J 03 06-14-88 Police Department 3 E, J -
04 .06-27-88 Fire Department . 3 E, J, K 05 06-09-88 Highway Department 3 J .
06 06-06-88 School Department 3 J
~
07 01-88 Board of Health
. 3 J -
08 02-16-48 ' '
Radiological'l Officer 3 N -
09 02-16-88 Communications officer 3 E, F 10 05-08-88 American Red Cross 3 J 11 02-16-88 RACES ,
3 F 12 02-16-88 Animal Control Officer 3 J 13 09-08-84 Bridgewater State College 1 J 17 03-21-88 ECC Reception Center 3 J Transportation Officer
. :21 02-23-88 Public Information 3 G 22 03-09-88 Monitoring and 3 J, X Decontamination ,
23 02-04-88 Emergency Medical Services 3 L 24 12-23-87 Message Control 3 H i
..........--...m. . - - . . _
Oi '55 ;;;;5 '5EFF-PF.:~3E A E: ~E -1905 : ;;
.E BRIDGEWATER RERP Part IE_He. _Qata_ Eressdurs.I111e Ermit_No. Inninannand 25 04-14-88 Reception Center Medical 3 J Support 26 Training O 27 Drilla and Exercises N -
28 Program Maintenance P knaasn_Elsnat .
Esa Iltle Esis l 6-1B , Civil Defense 07-18-88 l 1
7- Bridgewater Highway Dept. 06-13-88
,'11-1B .Bridgewater School Dept. 08-01-28
- 19B . Board of Health' . 1'1 .1 9 - 8 8 4
6 9
__ -__ _ _ ~ - - _ _ _
m GREBWD11Z: TAUNTON- Date entered: 10-18-88 RERP 7-28-84 Rev. 5 Received 7-28-88 l Cross Reference Rev. Received Corrective Action Response Rev. Received 3malsmentina_Erassdursa:
RERP Part 12.He. IEsis1Qsta Brassdurs_Iltas Ermit_He. Imminannted 01 04-29-88 Mayor / City Council 3 02 05-02-88 Civil Defense Director 3 03 04-30-88 Police Department 3 04 04-28-88 Fire Department 3 l 1
05 03-29-88 Department of Public Works 3
06 04-27-88 Schoci Department 3 I 07 03-29-88 Board of Hadith --
3 i
08 04-28-88 Radiological of[icer 3 09 03-16-88 Communications Officer 3 10 03-11-88 American Red Cross 3 11 03-16-88 RACES 3 12 03-16-44 Animal Control Officer 3 13 04-27-88 City of Taunton Reception 3 Center
. 17 04-27-88 Transportation Officer 3 18 03-16-88 Hospital Representative 3 21 02-26-88 Public Information 3 22 03-10-88 Monitoring and 3 Decontamination .
23 04-28-88 Emergency Medical Services 3
TAUNTON RERP Part 12.50 1HetalData Ecsendurs_Iltle Drsit_He- Isalssented !
24 01-05-88 Message Control 3 25 02-02-88 Reception Center Medical 3 Support 26 Training '
27 Drilla and Exercises 28 Program Maintenance .
Lassen.21 sus:
Het 'Iltis Ents 3-17 Intro 'to ECC 09-22-88 3-27 Communications Officer ~09-22-88 3-3T RACES 04-01-88 3-47 Overview of Massage Control 05-06-88 3-57 Mayor 09-22-88 3-67 Radiological Officer 09-23-88 3-7T Hospital EOC Representative 05-06-88 4-17 Intro to Fire Department 06-10-88 4-27 Fire Chief & Fire /EOC 09-19-88 Representative 4-37 Fire Dispatcher 9-14-88 4-47 Dosimetry Coordinator 9-19-88 5-17 Intro to Police Department 06-15-88 5-2T Police Chief 05-01-88
, 5-3T police EOC Official 05-01-88 .
l L__._________._._________-__. _
TAUNTON Het I111e Dats l 5-4T Police Dispatcher 05-01-88 6-17 Intro to Civil Defense 05-16-88 6-2T Civil Defense Director , 05-25-88 7-17 Overview of DpW ,09-26-88 9-17 Intro to EMS 05-01-88 9-27 Medical Director 05-01-88 9-37 EMS Desimetry Coordinator 05-01-88 9-47 Senior Ambulance Technician 05-01-88 10-1T Intro to Reception Center 08-04-88 10-27 Taunton ECC Representative 04-12-88 10-37 Taunton. Reception Center Manager 09-21-88 10-57 Overview'of Taunton Reception' 09-21-88 -
Center Medical Support -
12-1T Intro to Transportation 05-02-88 12-2T ECC Reception Center Transports- 09-22-88 tion Officer 12-3T Staging Area Teams 09-22-88 19-17 Overview of Board of Health 03-14-88 23-1T Overview of Animal Control Officer 09-21-8E
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, December 7, 1988 Duxbury Board of Selectmen 1 bun Hall .
Duxbury, MA .02332 ..
Gentlemen:. .
We would like to ask the Duxbury Board of Selectmen for clarification of the IL.w 1, -1983, meno to William Russell of the Nuclear Regulatory Canaission.
This letter is a brief synopsis of the ccanents made by Fire Chief Carl O'Neil, who was acting as Civil Defense Director for the town. The meeting took place i'
on October 26, 1988.. Representatives of the NRC and the State were present.
Chief O'Neil was allowed to make changes on anything he disagreed with in the context of the mano,.
We are concerned,~ as citizens of Duxbury end as msnbers of the Bnergency Response Study'Comnittee, with not only the content of this meno, but also with the tone.
We fear, as;past dealings have documented, that any misleading infortration could
- be misinterpreted and lead to further confusion and delays.with the planning pm-cess. We ask you to instruct Carl O'Neil to clarify any misconceptions in writing to the NRC. 'We feel that, in light of the December 9 meeting in acckvill, MD. ,
time is of the essence. We are asking for clarification on the following points:
Implementing Pmcedures: Ibr the record, our wenittee is currently called theJoergency Response Study nnenittee not RERp. According to our recollec-
- tion, and it can be verified with our last meeting minutes, no procedures have been completely reviewed. At one meeting we briefly went over the pro-cedures for the fire department. At our last meeting we had so many concerns with inaday1=te manpower that we agreed and voted that all procedures were to stay within the committee until we had some sort of carpleted list as to the who, what, and where of these procedures. We are afraid that the rumo could lead one to int-r i.ethat all but three of the procedures were dealt with.
Schools: We do not consider the teacher participation and buses minor. Pbr 1 the past two years we have considered these issues to be of major concern. In (
. light of the June survey of the teachers and the fact that to our knowledge we only have one signed contract for buses these are definitely najor concerns.
The contract for the buses is for twelve buses with a company located 70 miles away in Worcester.
Perso:mel Resources: It is our understanding that there are staff shortages especially in toe DpW and the fire d eartment as indicated in discussion at the December 5 selectmen's meeting. We would like to enphasize that many on our conmittee have a great deal of tmuble relying on volunteers to fill roles.
Training: .Our comnittee was told that we would view the training before it progressed any further. We have reservations about the thalical accuracy of the modules. At our last meeting the assertion was made that medical doctors had not viewed this material.
Duxbury Board of Selectmen 2 Decenber 7,1988 Special Needs Pbpulation: We verified with the Office of Handicapped Affairs the following infomation: , Their office has been trying to get a survey done to identify those with special needs. They have attenpted to make it clear that there is documented proof that people do not respond to ads in the news-i paper. Further, a total of nirie ads have been takan out in the entire EPZ.
We feel that the language in the meno which finds the special needs population evacuation not to be of major concern to be offensive and irresponsible. No
! , amount of noney will protect these people if they are not rawly identified and cared for.
Beaches: We were unaware that evacuation using the powder Ibint Bridge Wd greatly alleviate anything. The population would merge onto t e way streets through the town. We are,also concerned, having seen Mr. Quaid's presentation, with the trite reference to the high tides. In the siznmer conths one is talking about large nunbers of stranded people.
We would appreciate your prompt attention in this natter and look forurd to hearing fzun you.
Sincerely yours, Claire Ibnahue Mary Dinst S
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..... NOV 2 8 GB November 1, 1988 iuww w oureuwv MEMORANDUM FOR: ' William Russell, Regional Administrator amutom smEN
.I THRU: ( R. Bellamy, Chief, Facilities Radiation Safety and A Safeguards Branch, DR$5 10"l^',
3 ih i j, FROM: W. Lazarus, Chief. Emergency Preparedness Section, FRSSB R. Hogan' Emergency Preparedness Specialist, NRR I'
SUBJECT:
MEETING WITH CIVIL DEFENSE OFFICIALS IN THE TOWN 0F Gr81URY -
.T0 DISCUSS THE STATUS OF EMERGENCY PREPAREDNESS ON OCMER 26, t . 1988 i.
BACKGROUND
- A meeting was held in the Duxbury Fire Station on October 26, 1988. The purpose of this meetir.g was to obtain the latest factual infomation regarding the status of emergency plans, implementing procedures, and facilities, directly from the Director of Civil Defense for the town of Duxbury. The Director of Civil Defense was also provided an opportunity to bring any previously unidentified concerns regarding the status of emergency
! preparedness to the attention of the NRC.
ATTENDEES
~
' Carl O'Neill,' Duxbury' Civil Defense Director and Fire Chief Alfred Slaney, Planner, Massachusetts Civil Defense Agency (MCDA)
William J. Lazarus, Chief. Emergency Preparedness Section, NRC Region !
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Rosemary T. Hogan Emergency Preparedness Specialist, Office of NRR
! DISCUSSION I
- Mr. O'Neill presented the following status sunnaries and concerns regarding i
the state of emergency preparedness in the Town of Duxbury.
Imolementina Procedures There are approximately 38 implementing procedures (IPs), none of which have been sent to FEMA for review. All of the IPs, except three, have i
been reviewed by cognizant Department Heads. The three IPs which are
! ,' still under development are: Selectmen; Town Manager; and Public
! ( information Officer. The RERP has reviewed the Fire and Civil Defense IPs and are reviewing the School IP. All IPs will be sent in segments to the Board ti Selo.tmen for their review. Copies of the Plan, IPs, Shelter Implement.6 ion Plan and Evacuation Time Estimate" are available in the E0C.
The following are specific concerns which remain to be resolved.
i Schools: The school comittee does not agree with the school l
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/ procedure as drafted, but is considering early dismissal of school children at the ALERT, rather than have the buses in standby and -
. evacuate the children at a SITE AREA EMERGENCY. There is no sound technical basis for the position and in some cases would require I
three round trips of the school buses. This is contrary to the recommendation of the Civil Defense Director and MCDA who would like to see the procedure remain as it is. There are a few other minor concerns involving role conflict of teachers and the -
guarantee of sufficient buses which remain to be resolved.
Personnel Resources There are a few personnel shortages which need to be filled. The EOC staff does not have a complete second shift complement and the police department needs two additional staff for Gurnet-Saquish route alerting if.necessary. Alf"5ther departments appear to have sufficient staff.
Evacuation Time Estimate The new ETE har neen received, but it has not been thcroughly reviewed.
Eouioment end Fne111 ties The EOC is nearing completion. The facility is expected to be complete-in four weeks when the communication equipment is installed. Some portable radios, a repeater and a LORAN navigation radio should be 4 delivered within a few weeks.
The Board of Selectmen has not approved a reception center community.
Although the current plan provides for evacuation to Bridgewater or Wellesley, the Selectmen are opposed to Wellesley. There are reservations on the use of Bridgewater, as well, because the evacuation routes to that comunity would be blocked delaying evacuation.
The police need a 4 wheel drive vehicle to be used for route alerting of the Gurnet-Saquish Beach area.
- I Trainino -
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Training has just begun, but is progressing very smoothly.
- Barry Reoort Mr. O'Neill thought the Barry report accurately u _ reflected,the concerns
- and the status of emergency preparedness in Duxbury.
p Commission Briefing 6
Mr. O'Neill indicated that the statements made by Senator Kennedy, Representative Studds, and Lt. Governor Murphy reflected the status of 1
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emergency preparedness for the town of Duxbury.
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Ability to Imelement .
The Civil Defense Director does not believe the plan could be I implemented at this time ,ecau No portions of the plan h,) eenave b.se tested. Theso,li.t.tle. training Civil Defense has Director been c has notified the Selectmen that he believes that training, equipment installation, plan and IP development, mini-drills and a town drill could be complete by the middle,of february,1989.
_ . -:. = - ...... - -. - -. - - . .
- Enecial Needs poeulation Identification of the special needs population is slow due to the
' reluctance of that population to highlight their handicaps. Repeated advertisements in the local papers requesting self-identification is continuing. TDDs are available to be delivered to deaf people who request them. Special needs population evacuatio.n was not identified as o a major concern provided resources arranged by the state are actually
- available.
i Beaches l
The Gurnet-Saguish procedure is still'under review by the Gurnet-Saguish l Association.. Concerns are that siren coverage may be inadequate. There i
! is no feedback method to determine if the sirens have actuated and i
Duxbury police do not have sufficient resources to run route alerting as i a back-up for siren failure. Route alerting would take at least 45 4
! minutes to complete. Chief O'Neill indic.aled.that some of the estimates reg ~arding the Gqrnet-Saguish beach area he has seen have been inflated.
fle estimated the number for the Saquish Beach at about 4,000 maximum (2,000 typical) on peak days. The road to this beach-is under water from high tides for a part of 2 days per month.(2 to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />). The water ma.y be waist high in that section.
There are 4,000 to 5,000 people on the Duxbury Beach during the peak part of the season. The Powder Point Bridge has been re-opened and provides a second evacuation route for those evacuating the Duxbury-Gurnet-Saquish beach area. This greatly improves the situation. People are requested to evacuate at the ALERT and the beach is closed.
SUMMARY
The major concerns are getting equipment in place and working, completing the training and drills, and resolving the school evacuation issue, and final approval of procedures and plans. ,
I /V A' Mr. O'Neill was provided an opportunity to_. review this memorandum _ and his(-
coments for clarification have been incorporated.
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osemar 1+ - : "kw EP Spec list, NRR cc: J. Dolan, FEMA Region I
, We The People cf the Ucited Stctes Stop ChernobylHere l
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IMMEDIATE PRESS RELEASE DATE: DECEMBER 9, 1988
SUBJECT:
NRC HEARINGS ON PILGRIN LOCATION: ROCMVILLE, MARYLAND PRESS CONTACT: STEPHEN 8. COMLEY, EXECUTIVE DIRECTOR WE THE PEOPLE, INC.
ROWLEY, MASS.
508-948-7959 We The People is, represented at this NRC hearing even though the agency refuses permission to speak. We The People was formed because many citizens of this country believe the agency is not doing its job, a fact confirmed by individuals within the NRC itself.
"For esample, there are counterfeit, substandard piping materials, electrical components, and fasteners now built into most U.S. nuclear plants from New England to the West Coast including Pilgrim Station," Steve Conley, Esecutive Dir,ector of. We The People.said. "
.The NRC did not publicly *
' notify nuclear plants about this serious safety problem until May 1988. We The People'has a letter from the NRC saying the agency discovered the problem in January 1988, but the agency actually knew earlier than that date. I notified President ,
l Reagan myself in 1987," Conley said.
Such a delay in notification by an agency sandated to insure '
nuclear plant safety is unsettling. Even more disturbing is the NRC's action in lowering safety standards rather than ,
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requiring replacement of substandard materials. We The '
People is asking Congress to investigate this problem.
"There are also problems within the NRC which have a very serious impact on our democracy: the right of the public to
- have a say in nuclear plant decisions affecting their lives and the lives of future generations. The need for I
OVER Box 277 Rowley, MA 01969.(508) 948 7959 50 Coun St., Plymouth, M A 02361,(617) 746 9300 N:tional Press Bids.,14 & F. Sts., N.W., Washington, D.C. 20045 2#3 . d.2 p - gg//
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Offices 5 & 6,3 Pleasant St. Concord, NH 03301. (603) 228-9484
I Congressional action has become even more pressing with the recent Presidential Order on evacuation planning that overrides state and local powers to reject evacuation plans l
which won't work. The issue of nuclear power has become secondary with this action by President Reagan, which cracks the very foundation of American democracy, a government of the people and by the people," Conley said.
l That anti-democratic trend embodied in this hearing where only selected state and local officials are allowed to speak.
"Is this because the public is more likely to be harshly critical of the NRC than are state officials?" Conley asked.
"Given the NRC track record of ignoring all criticism permitting only certain officials to speak is only a public relations ploy," said Conley.
Why has public input been deliberately limited? Does the NRC believe it has nothing to learn or is the agency afraid of what it might learn?
"If the NRC thinks there is nothing more to be learned, then -
decisions about restarting Pilgrim Station _have already been made and this hearing is a sham," Conley commented. "If the NRC is denying public input because it is afraid of what it might hear publicly, then our worst fears about the agency are verified, that it has a much greater commitment to licensing unsafe nuclear plants and maintaining nuclear industry profits than it has in protecting the public,"
Conley concluded.
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DEPARTMENT OF THE ATTORNEY GENERAL- - -
JoMN W. McCOMMACM STATE OFFICE SUfLDING j ONE ASHOURToN PLACE. 8!sToN 02106-1698 l JAMES M $HANNoN
- af70maety otNamat., ,
l December 6, 1988 ,
Stephen B. Comley 1 We the People '
Box 277 . i Rowl'ay, MA ~01969
Dear Mr. Comley:
Thank you for your letter to Attorney General Shannon dated November 30, 1988. I have reviewed the analysis by We the People. In ordwr to complete our review, I would appreciate the original reports footnoted at the end of your analysis. I would also appreciate any additional information you could give me concerning the confidential informants within the NRC.
. I look forward to hearing from you shortly.
Very truly yours, '
s l(
Iterph'en (Jonas Deputy Attorney General Chief, Public Protection Bureau SAJ/BT
. k'E ARE ALSO NOTITYING EVERY U.S. SENATOR, CONGRESSMAN, GOVERNOR (INCLUDING THE " PUSSYCAT") AND k~ri!!E !!OUSE STAFF TO ENDORSE THIS CONGRESSIONAL I
INVESTIGATION.
y UUO UUJ5U Q l cf the United States Stop ChernobylHere 1
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Dear Congressional Representative:
This letter'and the enclosed attachments detail the Nuclear Regulatory Commission's (NRC) failure to protect public hem.lth and safety as is its Congressional mandate. The agency does not enforce its own standards,and regulations for safe nuclear plant construction and operation, nor does it ensure all residents near nuclear plants can be properly evacuated in the face of a nuclear accident.
Enclosure 1, Counterfeit and Substandard Materials (Parts 1 & l 2), analyzes information from sources including recent NRC 4 reports. It shows that most U.S. nuclear plants (from New England to the West Coast) have been built with counterfeit materials which are far below the agency's required standards for nuclear plant safety. These counterfeit materials include electrical components such as circuit breakers, piping materials, flanges, valves, and fasteners such as nuts and bolts. NRC documents show these materials repeatedly failed tests of strength and reliability. The agency did not order the counterfeit parts be replaced even though use of these materials means nuclear plants are much less safe than the agency believed. Instead, the NRC lowered the safety standards for these materials. ,
As recently as a few weeks ago, the NRC raided four more Southern California firms suspected of selling counterfeit electrical components to nuclear power plants (see Enclosure 2, Sworn Affidavit bg U.S. Senior Investigator). With each passing day, the magnitude of the problem becomes more alarming. The NRC is only now beginning to address the problem, not because of its diligence in protecting the public health and safety, but because the problem has become so widespread that the Commission can no longer ignore it.
This is a dangerous situation. The NRC and the nuclear industry have always claimed that even though nuclear
. technology is dangerous, the plants are safe enough because they are built with back up, redundant, safety systems.
However, since materials in the main safety systems as well as in back-up syst}ms are substandard, claims of safety because of redundant systems are invalid.
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Since nuclear plants are less safe than the agency thought, plans for protecting the surrounding population's should be strengthened. Such is not the case. For example, people with special needs have not even been identified within thee ten mile emergency planning zone. Evacuation plans approved by the NRC have no provisions for elderly, deaf, and blind people, and others with special needs. Instead, most of these people will be left behind. This is discrimination against the handicapped, in violation of federal law and the laws of many states. It is morally reprehensible to ignore l Persons who would most need assistance in time of emergency (see E n c 1,o s u r e 3, Related Information, pages 12 & 13, We The People's explanation of the special needs issue).
Special needs people appear to be expendable in the agency's eyes; at some nuclear plants that notion of expendability extends to the entire population. In the case of New Hampshire's Seabrook Station, the agency seriously downgraded required standards and rules for evacuation planning so as to be able to ignore strong evidence the seacoast area north of Boston cannot be evacuated. The Commonwealth of Massachusetts, after extensive study and deliberation, determined that evacuation was impossible. The re'sponse of the, NRC was to label the state as uncooperative. However it
'is not uncooperative for the state to make legi'timate decisions about the welfare of its citizens. This situation resulted in a rule. change that substituted a "best effort" standard for safety sta'ndard'with regards to evacuation planning.
The need for Congressional action has become even more pressing with the recent Presidential order on evacuation planning that overrides state and local powers to reject evacuation plans which won't work. The issue of nuclear power has become secondary with this action by President Reagan, which cracks the very foundation of American democracy, a government of the people and by the people.
These brief examples and the attachments supporting them,
- demonstrate an NRC pattern of allowing operation of nuclear plants at the expense of public safety. When the agency's rules and safety standards, established as the basis for protecting the public, conflict with plant operation, the safety standards are reduced or abolished.
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l The NRC 10 cnoworchio only to Congro30, and to dato, Congroon i hoc not boon ocking corious questions of the NRC. It is l essential the body representing the people of the U.S.
l investigate the agency and take action to ensure the publie l
_ safety, since the agency itself has moved further and further from that responsibility. There are a number of nuclear l plants not yet in operation which have been built with counterfeit materials. Seabrook Station is one of them.
Congress must prevent contamination of any nuclear plant by preventing the issuance of any licenses until all counterfeit materials have been identified and replaced. This will also keep open the option of conversion to much safer energy
, alternatives like gas. Plants already in operation must also be ordered to replace all counterfeit parts.
Until thdn, the people of this country are in danger. As. the i Chernobyl nuclear plant accident shows, even though it was l not the worst-possible accident, radiation knows no boundaries. The industry and the NRC have refused to address the implications of the Chernobyl accident. They can't even properly address the safety of people within the 10 mile radius of nuclear power plants, much less outside that limit.
In August, 1986, 80% of the town of Rowley, Massachusetts, petitioned President Ronald Reagan to conduct an independent investigation of the NRC, (copy enclosed, page 14 of Related Information). To date, there has been no response to Rowley's petition.
Former NRC Commissioner James Asselstine, in an interview August 15, 1986, said nuclear plant accidents in this country are inevitable because of how poorly they are built and operated. The NRC is mandated to regulate the industry so as to prevent such accidents, but it is Congress which must now enforce that mandate. In the absence of Congressional action, the NRC will be allowed to conduct " business as usual." This leads not only to a substantial risk sf a serious nuclear accident, but exacerbates a crisis of public confidence in both the NRC and the Congress and their collective ability to safeguard the public health and safety.
We The People has contact with good people inside the NRC who are willing to come forward and expose the corruption within their agency if a Congressional investigation is granted.
(see NRC quotes, page 11 of Related Information). The consequences of coming forward for these individuals will necessitate reasonable assurances that a full and fair investigation will ensue.
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Wa Tho Pooplo hoc rotoined tho corvicoo of Ernoot Mcdloy, on ottornoy'cxparianced in reproconting whiotlebloworo. Ho to a forcor accociato of tho Gavarncont Accountchility Project in j Washington, D.C. We The People can assist in bringing forward information to expose one of the biggest violations of the public trust that this country has ever witnessed.
The nuclear industry is both wealthy and powerful, but, neither of those factors give it the right to deliberately jeopardire the health and safaty of the American people.
I hope you will soon be able to find the time to meet with me and other members of our staff to further discuss this matter. Please inform me of your response at your earliest possible convenience.
Sincerely, .
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Stephen B. Conley Executive Director , ,
We The People, Inc.
SBC/mk Encs .
Enclosure 1: Counterfeit and Substandard Materials Enclosure 2: Sworn Affidavit bg U.S. Senior Investigator Enclosure 3: Related Information Packets Correspondence including letter given to Presiden't Reagan August 15, 1988 and.O'etober 4, 1988 re'sponse to that-letter from the NRC'pages 2 & 3. The NRC's reply of July 18th .
which stated when they first learned there were counterfeit parts. The NRC stated it was. January 17, 1988, but the i agency actually knew earlier than that date.
\
Documentation of the, enclosed materials is available on request. '
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