ML20235T775

Responds to 880527 & 0707 Ltrs Re Offsite Radiological Emergency Planning & Preparedness for Facility.Fema Encourages Development of Comprehensive Schedule for Completion of Emergency Plans for Facility

ML20235T775
Person / Time
Site:	Pilgrim
Issue date:	08/22/1988
From:	Vickers H Federal Emergency Management Agency
To:	Barry C MASSACHUSETTS, COMMONWEALTH OF
References
CON-#189-8165 2.206, NUDOCS 8903080468
Download: ML20235T775 (4)

Text

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PRDD. & UTIL FAC.5m

. . Federal Emergency Management Agency

, Region I J.W. McCormack Post Office and Court House e .* Boston, Massachusetts 02109 hIb August 2 198 gn ' Wj Charles V. Barry, Secretary  %

Executive Office of Public Safety d pocnrTrD Ccanonwealth of Massachusetts Che Ashburton Place i gB;919899h  %

Boston, Massachusetts 02108 C~

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)N o ThisisinresponsetoyourlettersofMay27andJuly7,1988,c$1[q[r[ni - [f-site radiological emergency planning and preparednen for the Pilgrim Nuclear Ibwer Plant. The efforts of the Canmonwealth of Massachusetts and the local connunities to upgrade plans and preparedness around Pilgrim are recognized and appreciated by the Federal Dnergency Management Agency (FDIA). Informal technical assistance reviews of the draft local radiological emergency response plans for Plynouth, Carver, and Kingston, Massachusetts and of the Reception Center Plan for Taunton, Massachusetts were canpleted by FD4A and the results were forwarded to Mr. Robert Boulay, Massachusetts Onergency Management Director, on March 30, 1988. The results of the informal technical assistance reviews of the Bridgewater Reception Center Plan. and the Duxbury Radiological Bnergency Response Plan were forwarded to Mr. Boulay on Aug.ust 3,19.88, and August 8, ,

1988,.respectively. . Informal technical assistance plan reviews have now been '

cmpleted for all of the Pilgrim emergency planning zone' (EPZ) communities

• except for Marshfield. The Marshfield plan and the plan for a third reception i

center have not yet been sutxnitted for review.  !

! 1he reviews indicate that there has been sane progress made in improving and upgradiry the local plans. Overall, however, the plans remain incomplete, lack specific details in certain areas, and do not include required implementing procedures. In addition to these issues in the local plans that must be ad-dressed, the status of the Massachusetts Civil Defense Agency Area II Plan and the Caamonwealth of Massachusetts Plan must be clarified. The Area II Plan is now obsolete in many respects and needs upgradina and republishing. By our records, the July 1981 edition of the Coninonwealth Plan remains the effective version, since the 1984 revised edition was never implemented. Since the Commonwealth and Area II Plans both contain elements that affect and are critical to the local plans and their implementation, a full formal technical review of offsite planning for Pilgrim cannot be completed by FEMA until revised commonwealth and Area II Plans are submitted alorg with ccmplete supporting local plans. As indicated in our letters to Mr. Boulay, full implementing procedures, Iatters of Agreement, revised Public information Brochures, and training modules must also be sutxnitted for a full, formal technical review.

We encourage you to continue pursuiry your goal of de'veloping the best possible emergency plans for protecting the public health and safety in the vicinity of the Pilgrim Nuclear Power Plant. We can also appreciate the intricacies of the process and interaction among the State and local jurisdictions and the licensee that is required to develop such plans. We are again requesting, however, that you provide a schedule or milestones indicating when the overall offsite planning 8903080468 880822 PDR ADDCK 05000293 PDR

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process for Pilgrim will be cmpleted and when revised plans will be submitted to FEMA for formal review. We do not believe that this action would be arbitrary or that it would imply that considerations other than public safety are paramount.

In fact, we have found schedules and milestones to be useful~for planning purposes I and for monitoring progress at other sites and we believe that the Commonwealth, the local jurisdictions, and the licensee could better organize the planning effort and would find that producing a schedule would help facilitate the process. i In your letter you questioned whether the plans that are ultimately developed will i provide reasonable assurance that adequate protective measures "can and will" be i raken to protect the public. You also requested that FEMA provide you with a state-ment of the criteria FEMA intends to employ in making a determination of reasonable assurance associated with a review of the plans for Pilgrim. FENA continues to use 44 CFR 350 as the basis for its reasonable assurance finding. If the intent of l

FEMA's regulation 44 CFR 350 and the planning standards and related evaluation cri- I teria contained in NUREG-0654/ FEMA-REF1, Revision 1, are met, based on the pro-fessional judgment of FEMA and other Federal reviewers, then we are able to make l the determination that emergency plans adequately protect the public health and '

safety by providing reasonable assurance that appropriate protective measures can be taken offsite in the event of a radiological emergency. As a point of clari-fication, 44 CFR 350 does not require a FEMA reasonable assurance determination that protedive measures "will" be taken, only that they "can" be taken. I In regard to your discussion of planning options and dose savings, the overall. ,

objective of any radiological emergercy response plan related to a nuclear powe'r  ;

plant is to assure reasonable and feasible dose savings for a spect; rum of radio-logical accidents that could produce offsite deses in excess of Protective Action Guides (PAG's). A PAG is defined as a projected absorbed dose to individuals in the general population which acts as a trigger point to warrant protective action. A PAG under no circumstances implies an acceptable dose. The Nuclear Regulatory Cammission (NRC) confirmed the above position in a ruling on July 24, 1986, and stated that emergency planning requirements do not require that ,

an adequate plan achieve a pre-set minimum radiation dose-savings or a minimum evacuation time for the plume exposure (10-mile) EPZ in the event of a serious accident (Long Island Lighting Co (Shoreham Nuclear Power Station, Unit 1) 24 NRC 22 (CLI-86-13, 1986). The protective actions taken after a nuclear incident are intended to minimize the radiation exposure of the general public resulting frcm the incident, and thus achieve dose savings in ecmparison to actions taken on an ad hoc basis without emergency plannirg. Even the best emergency plans and preparedness cannot assure that radiation exposure will not occur for the worst case accidents.

In your letter you raised 'the issue of the bet h population in the vicinity of Pilgrim and questioned whether FEMA continues to stand by the results of the Self-Initiated Review and Interim Finding. There are several factors that will be considered by FEMA in reviewing the revised Pilgrim plans regarding the beach population and other special populations within the EPZi One factor involves Planning Standard J in NUREG-0654/FENA-REP-1, Revision 1, which requires that a " range of protective actions" be considered in developing offsite radiological emergency response plans. As part of the Pilgrim plan revision process, FEMA expects offsite officials to develop protective action options, based on site-specific characteristics and local. capabilities, and to provide the technical

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I rationale for whatever protective action option or options are selected and adopted as the most appropriate planning approach for the site. It is FEMA's position that a "rarge of protective actions" could be satisfied by evacuation alone.

Also, in the Self-Initiated Review and Interim Finding FDM stated, based on certain factors, that protective a.ctions for the beach population "may well be adequate cur-rantly and, if not, readily correctable." It may be, based on the relatively low numbers of people who may be without shelter, that nearby buildings could be iden-tified to offset the difference,. It is our expectation that once this option is fully explored, an adequate sheltering plan for the transient beach population ,

can be developed. However, if this is not the case, to require sheltering for the transient beach population as a condition of a finding of reasonable assurance is

' inconsistent with the precept that emergency planning requirements do not require that an adequate plan achieve a pre-set minimum radiation dose savings or a minimum evacuation time. E is approach is being applied to all EPZ's nationwide. Rus, our response to your question as to whether or not we stand behind our finding is twofold:

1) we continue to believe that an adequate sheltering plan for the transient beach population can be developed for the limited circumstances where sheltering would be the preferred protective action; and 2) that this issue, in and of itself, would not support a negative finding for the aforementioned legal and policy reasons and for the technical reasons stated below.

In severe accident sequences, the total dose potential is emprised of several cm-ponents. These are the direct exposure frm imersion in the plume, cloud-shine fran a plume overhead, exposure fran inhalation of the plume, and ground-shine frm -

deposited radionuclides. We exact relationship among the various cmponents will vary with time and distance frm the point of release. In severe accident sequences, however, the ground-shine component is moct likely to be the major contributor to total dose if no protective actions are taken. In thoce cases, if the dose reduction strategy is sheltering first, followed by an evacuation after plume passage, the total dose reduction would not be as great as that for the immediate evacuation strategy.

In an immediate evacuation, to move the population relatively short distances in a cross-wind direction would greatly decrease or eliminate exposure. Even moving the population dpwnwind relatively short distances would decrease the dose rate by a factor of 3 or 4. . He sheltering part of the strategy reduces dose primarily frm the plume imersion and inhalation component. It is generally accepted, depending on the quality of the shelter, that the effectiveness of a shelter to reduce the in-halation exposure degrades af ter two hours. At sme point, sheltered individuals would have to be relocated. Ibring this evacuation after plume passage, individuals previously sheltered would still receive the ground-shine dose, potentially the major cmponent. W erefore, sheltering followed by evacuation is likely to be a less l effective means of achieving dose reduction than evacuation alone, particularly for ,

severe accident sequences.

Generally, the closer an area is to the point of release of radiation the greater the potential dose savings that can be achieved by early evacuation. By implementa-tion of the immediate evacuation strategy, dose reductions greater than those to be derived frm a " shelter first-evacuate later" concept can be obtained by movement l of the population relatively short distances, even in the extremely unlikely case in which the plume track and the evacuation routes coincide.

In addition to the factors outlined.above, the NRC Staff has advised FD4A that its interpretation of NRC emergency planning regulations is that the regulations e

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do not require that sheltering be provided for all accidents, at all times, and at  ;

all locations within the plume exposure pathway EPZ. Stated differently, the NRC j Staff views the regulations as not requiring that there be a range of protective l actions that includes both sheltering and evacuation options, for all accidents, l at all times, and at all locations within the EPZ. NRC has also advised FDM that  ;

its regulations are not contravened by the absence of shelter in the case of the I beach population.

In consideration of FD%'s interpretation that " range of protective actions" could be satisfied by evacuation alone, the potentially greater dose savings frcm an im-mediate evacuation versus sheltering strategy, and the NRC's interpretation of its -

regulations, the lack of sheltering for a special segment of the population will not, by itself, necessarily be cause for a negative reasonable' assurance finding.

These standards were applied to reviewing planning for the beach population in the Seabrook case and are being applied to all reviews nationwide. l Mr. Richard Krimm's recollection of the quotation in your letter is that the state-ments wre made in the context of shelterirg as a preplanncd, chosen protective action and referred to sheltering for the permanent population. We expect the Ccmnonwealth of Massachusetts and local jurisdictions to consider a range of protective action options and to technically justify those options that are selected as the Pilgrim plans are revised and upgraded. In selected instances, sheltering may be a logical I and appropriate approach. I I,would ljke to reiterate, as stated earlier, that FD M encQurages the deve,lopment of a comprehensive schedule for completion of the emergency plans for Pilgrim and that this process is not " arbitrary," nor does it imply "that considerations other

• than public safety (are) paramount." If the schedule, once developed, needs to be g adjusted subsequently in order to improve the plans, FD% could accamodate such 1 modifications.

Once again, additional technical assistance frcm FD% will be readily available to l you should you desire it in ccrnpleting the Pilgrim planning effort. If you need '

any additional information, please contact me at 223-9540 in Boston.

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