ML20236F292
| ML20236F292 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 10/26/1987 |
| From: | Varley R BOSTON EDISON CO. |
| To: | Boulau R MASSACHUSETTS, COMMONWEALTH OF |
| References | |
| EPC87-764, NUDOCS 8711020083 | |
| Download: ML20236F292 (17) | |
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, Emergency Operations Facihty Obery Heights Plymouth, Massachusetts 02360 (L
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! October 26;.1987 EPC87-764 Mr. Robert J. Boulay Director ,. .
Civil Defense Agency and Office of Emergency Preparedness Commonwealth of Massachusetts 400 Worcester / Road P.O.' Box 1496 Framingham, MA 01701-0317
Dear Mr. Boulay:
By )|letter dated September 18, 1987]] you forwarded to Mr. Bird a memorandum prepared by your staff which identifies a number of concerns regarding the ~1 August 1987 Stone & Webster Engineering Corporation " Study to Identify Potential Shelters.in the EPZ Coastal Region of the Pilgrim Nuclear Power Station." Enclosed is.a memorandum that provides Boston Edison Company's comments on those concerns and identifies how they have been or are being resolved.
-The memorandum which you transmitted states that the " principal concern is that we must be able to put data in the hands of local officials which are sufficient for the development of shelter utilization plans for all areas of all five communities within the Pilgrim EPZ." Boston Edison is committed to developing, with the Commonwealth's and the local governments' assistance, appropriate plans to assure that the public in the EPZ has access to sufficient shelters in the event of an accident at. Pilgrim Nuclear Power l Station. Thus, we are concerned that the memorandum forwarded with your l September 18 letter misperceives the limited scope and purpose of the August, 1987 Stone & Webster study.
That study was not intended to identify actual, usable shelters or to assess ,
the capability or suitability of specific structures to serve as shelters. i Instead, its purpose was to survey and develop a list of public structures within close proximity to the public beaches that might potentially serve as shelters for the beach population in the event of an emergency at Pilgrim.
Thus, the study was only a first step in the process of planning for sheltering-the population in the EPZ.
M 8711020083 871026' PDR ADOCK 05000293 F PDR /
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l 5- EPC87-764 - s Page'2 i LIn_ September, Boston Edison also commissioned Stone & Hebster to expand upon
- their August study in< order to identify ootential public shelters near parks, campgrounds and recreational areas in the EPZ and to provide information regarding representative protection factors for structures in the EPZ. That study, as. well is only an initial step in .the~ planning process. .l In the near future, planners will begin to visit the various' structures identified by Stone & Hebster, in order to explain the purpose of a shelters' use to the owners or-managers of these structures,.to determine the' owners' or managers' willingness to make their space available,"and then to survey the j
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space in' order to. determine suitability for sheltering purposes. Ultimately -
letters.of agreement, as~necessary, will be obtained to formalize these arrangements. Boston- Edison is confident that this process will result in the l identification of suitable, available shelter capacity in the.EPZ.
Moreover, it is' important to stress that plans are.being prepared to' provide for precautionary clearing of the beaches and recreational areas at the'
" Alert" level. Thus, the likelihood of large numbers of _ persons in those locations needing shelter is greatly reduced.
,The-August 1987 Stone & Webster study'and the expanded study now being conducted should be viewed in the context of the overall effort to assure sufficient shelter capacity in the event of an accident at Pilgrim. -I; hope' that you will find the enclosed memorandum.useful. If you have any questions, please feel _ free to call myself or Albert Samano of my staff at (617) 747-8544.
Sincerely,-
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Ronald A h arivy Staff Assistant to Senior V.P. - Nuclear 1
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cc: Mr. Peter Agnes Assistant Secretary-of Public Safety The Commonwealth of Massachusetts Executive Office of Public Safety One Ashburton Place Room 2133 Boston, MA 02108 Mr. John Lovering Deputy Director 1 MCDA 400 Worcester Road Framingham, MA 01701 i
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'Mr. Jeffrey B. Hausner MCDA L 1400 Worcester Road' Framingham, MA 01701-1 Mr.. Arthur DeCoursey ,
Chairman - Board of Selectmen Town' Hall, Main Street
- Carver, MA' 02330 l
'Mr. David Vogler Chairman - Board of Selectmen Town Hall, 878 Tremont Street.
Duxbury, MA' 02332 Mr. Joseph-Costa-Chairman - Board of Selectmen iTown Hall,'23 Green Street..
Kingston,-MA. 02364 q
w .Mr.-Richard Levin .
Chairman - Board of. Selectmen ,
Town Hall, 870 Moraine Street'
.e Marshfield, MA 02050 Mr. David Malaguti Chairman - Board of Selectmen Town Hall, 11 Lincoln Sti 't Plymouth, MA .02360-Mr. David Canepa Chairman - Board of Selectmen Town Hall' .
Bridgewater, MA - 02324 Mr. David Pierce Civil Defense Director 4 P.O. Box 253 Carver, MA 02330 Fire Chief Carl O'Neil Civil Defense Director P.O. Box 1153 Fire Department Headquarters Duxbury, MA 02331-1153 Mr. Robert A. Mulliken Civil Defense Director Town House Green Street Kingston, MA 02364 C___---.___:__.__.___.__m. -
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- 'Page 4 Mr.. Daniel McGonagle.
Civil Defense Director-i= 107' Stagecoach Drive ,!
Marshfield, MA. 02050 Mr. J. Douglas Hadfield Civil Defense Director Memorial Hall' 83 Court Street
-Plymouth, MAz 02360 Mr. Donald E. : Ford -
Civil Defense Director-88 Rowayne Park Bridgewater, MA 02324 Mr. Robert C. Spearin Civil Defense Director-
-15 Summer Street-
'Taun. ton. MA 02780 LMr. Steven'N!IVargaiDirector? ,
Division of Reactor Projects,- I/II Office-of Nuclear Reactor Regulation 4 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. R.H. Hessman, Project Manager Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, MD 20814
- Wessman - NRC-U.S. Nuclear Regulatory Commission Region 1 - 631 Park Avenue King of Prussia, PA 19406 Senior NRC Resident Inspector l Pilgrim Nuclear Power Station Rocky Hill Road- ,
Plymouth, MA 02360 l
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MEMORANDUM Re: Boston Edison Company Comments on September 11, 1987 MCDA Memorandum Regarding August', 1987 Stone & Webster Engineering Corporation Shelter Study Date: October 26, 1987 !
Introduction By )|letter dated September 18, 1987]], Mr. Robert J. Boulay, Director, Massachusetts Civil Defense Agency and Office of Emergency Preparedness (MCDA) i transmitted to Boston Edison Company a memorandum prepared by his staff expressing several concerns regarding the August, 1987 Stone & Hebster 4
Engineering Corporation " Study to Identify Potential Shelters in the ,EPZ Coastal Region of the Pilgrim Nuclear Power Station." The purpose of this memorandum is to provide Boston Edison's comments on those concerns and to identify how they have been or are being addressed.
Before addressing each of the specific concerns, however, it is important to set forth the regulatory requirements and guidelines which govern the development of plans to provide sheltering arrangements for the public in the EPZ, and to clarify the intended scope and purpose of the August, 1987 Shelter Study.
II. Acolicable Reaulatory Requirements and Guidelines Nuclear Regulatory Commission (NRC) and Federal Emergency Management Agency (FEMA) regulations (10 CFR 50.47(b)(10) and 44 CFR 350.5(a)(10) 1 l
x respectively) require that'"[a] range of protective actions" be developed for -
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the plume exposure pathway emergency planning zone (EPZ). The applicable j i
NRC/ FEMA guidance, NUREG-0654, FEMA - REP-1, Rev.1 " Criteria for. Preparation and Evaluation of Radiological Emergency Response Plans and. Preparedness in >
Support of' Nuclear Power Plants" (NUREG-0654)' Evaluation Criterion J.10.m states that emergency plans should include:
The bases for the choice of recommended protective actions from the plume exposure pathway during emergency conditions. This shall include expected local protection afforded in residential units or other shelter for direct and inhalation' exposure....
. Footnote omitted.
1 The basic purpose of planning for sheltering the public in the EPZ is to pr' ovide an alternative to evacuation where such action will result in greater
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dose savings than'if the public were evacuated. Sheltering would be ,
appropriate, for example, where evacuation would expose the public to a radioactive plume and where, therefore, a greater measure of protection would
'be afforded by recommending that persons seek shelter for the relatively short period of time until the plume passes.
It is not necessary to identify or secure the availability of specific-shelters for the entire population in the EPZ. As an NRC Staff witness in Commonwealth Edison Co. (Byron Nuclear Power Station, Units 1 and 2),
LBP-84-2, 19 NRC 36, 269 (1984) testified and the Licensing Board quoted:
Essentially, sheltering is a protective action consisting of doing the best you can with what you have. We are not talking about ensuring that everyone has a basement, or lives in a fallout. shelter., What we are talking about is closing the doors and windows, going inside, turning off the ventilation system (or for most houses the furnace fan), and staying away from any outside openings if possible. Having a basement-would be ideal, but it.-certainly isn't a requirement for licensing that i' all homes have basements and be made of brick. Also, this criterion does no_t mean that a house-to-house canvas or survey must be conducted to determine how many have basements, how many are made of brick, and ;
how many are office buildings, etc. (Emphasis in original).
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Similarly,:in Lona-Island Liahtina Co.'(Shoreham Nuclear Power Station),
LBP-85-12, 21 NRC 644, 774 (1985), the Atomic Safety and-Licensing Board considered a contention' that, among other things, transients at beaches and-outdoor recreation' areas would have "no access to shelter and that LILC0 must identify shelters for transients." According to'the' Board, FEMA's witness testified that NUREG-0654 "does not require that such shelters be -
' identified." The Board went on to state that it " agrees with FEMA, and further finds that... the_ transient population will be able to move quickly.to seek shelter in a nearby-building, return home, or return to their-local lodgings. Id. at 775.
In Philadelphia Electric Co. (Limerick Generating Station, Units 1 and 2),-LBP-85-14, 21 NRC 1219, 1303 (1985), the Licensing Board stated:
There.is no provision... which requires an individualized evaluation of buildings to determine their adequacy for sheltering.... . If the
[ responsible state agency] were to undertake such evaluations, its ability to make protective action recommendations would not be enhanced because the individual protective value of a building has no. bearing on the decision to shelter or' evacuate. Protective action recommendations are based upon the dose projection for the entire population rather than the. occupants of any particular building. Evaluation of the protection afforded by structures within the EPZ will not make those buildings more suitable for sheltering or affect the choice of a sheltering option.
The Atomic Safety and Licensing Appeal Board in Carolina Power and Licht 1 (Shearon Harris Nuclear Power Plant), ALAB-843, 24 NRC 200, 207 (1986),
quoting an earlier Licensing Board decision (LBP-85-49), discussed the purpose ,
of NUREG-0654 Evaluation Criterion J.10.m:
[T]he purpose of the requirement that sheltering effectiveness in the EPZ be assessed... is to allow planners to make informed, but relatively gross, judgments about sheltering in the EPZ as a whole, or large segments of the EPZ, wherever people happen to be at the time. Its purpose is nat to assist decisionmakers in deciding whether to move i people, e.g., from wood buildings to brick buildings, seeking to j 3 l l
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..a 1 0 -l l maximize sheltering projections. Thus, what the decisionmakers need is- f a manageable set of reasonable estimates, not.a finely tuned:and l
detailed mass of data. (Emphasis added).
Thus, whatiis needed ar'e reasonable estimates of the shielding factors afforded by.the types of structures typical in the EPZ and not an exhaustive' analysis of the' shielding capability of specific structures. Egg ga.,
Shearon Harris,'ALAB-843. 24 NRC.at 207;~ Byron, LBP-84-2, 19 NRC at 270-71.
In the Sh'oreham' decision cited above (LBP-85-12, 21 NRC 644, 772 j s(1985)),. the Licensing Board _ also considered a contention that:
- A substantial number of- people who might be advised tol shelter will be unable.to do'so because many structure > in the Shoreham plume EPZ are constructed of wood and lack basements.
The Board pointed out'that while the dose savings from sheltering "in many
- circumstances are quite small..., inLmost cases a sheltering recommendation 'is
- a last' resort to be taken when no other action will-result in a smaller 4 dose." Accordingly, the Board found that LILCO's' plan' complied with applicable-~ requirements. Citing LILC0's testimony, the Board-stated.that
"[t]he confusion that would result from basing a protective action order on
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the type of structure makes such a plan unworkable. 11, at 774. ,
III. Scoce and Purcose of the Auaust. 1987 Shelter Study '
As the introduction to the August, 1987 Shelter Study states, its purpose was:
to identify notential sheltering capabilities of municipal and commercial buildings for emergency use by the beach / tourist population alo'ng the Massachusetts coastline within the [ Pilgrim EPZ].
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- v. 3 pX August, 1987' Shelter Study at'p.1 (emphasis added). The Study
. separately:listsL" potential'public shelters" in each of the four EPZ towns'with' coastlines (Plymouth, Kingston, Dux' bury and Marshfield)'along.
with their addresses and." approximate area available for potential shelter use." Id. at p.4 No attempt was made to determine the cctual
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availability or suitability of.the identified structures for use as shelters. While " potential short-term public sheltering capacities" are provided, the Study was not intended to provide a definitive'
- quantification of.the available shelter capacity.in the Pilgrim EPZ.
The August, 1987 Shelter Study also included a " sample survey of private residences'near the beaches" and an evaluation of two large special needs' facilities'. -Id. at p.1 The Study was an initial step in the process of planning for shelterin'g the population'in the EPZ'in the event of an emergency at Pilgrim. To date, that process has included:
(1) Determination of the general size and location of the population that might require public sheltering; (2)- Conduct of the August,1987 Shelter Study to identify ootential H
public shelters in or near the beaches; and (3) ' Commissioning of an expanded study by Stone & Webster of ootential 1
shelters in or near parks, campgrounds and other recreational areas 1
in the remainder of the EPZ. This study will also provide information regarding' representative protection factors for structures in the EPZ.
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.s: 3 The following additional steps remain to be accomplished:
(1) Emergency pfanners will, inLthe near future, begin to visit. the
-r various' structures. identified as potential shelters and meet with=
their owners or management in order to identify usable shelter locations. .The planners.will explain the purposes for which the_
particular-structure is proposed for use; determine the owner's~or management's wi.llingness to make their facil.ity available; and if available, survey usable space in order.to determine.its suitability for sheltering purposes taking into account such factors as accessibility (for the general population'and handicapped persons) and apparent environmental or physical hazards; (2) Once available usable shelters are identified, written -letters of.
. agreement would be entered into, as appropriate, .providing, among other things, for' Boston Edison liability for any damages that.
might' occur while such facilities are used as shelters.
Thus, the process underway for establishing sheltering arrangements for -
the' EPZ population goes far beyond the simple identification of potential shelters provided in the August, 1987 Shelter Study.
IV. Boston Edison Company Comments on the Specific Concerns in the Seotember 11. 1987 Memorandum HCDA's memorandum first states that the August,1987 Shelter Study "only covers an area approximately one mile wide along the coast (and that]
shelter capabilities of the entire EPZ must be surveyed and reported." l 6
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Memorandum at p. 1. As described in Section II above, there is no regulatory requirement to identify and survey specific shelter locations in the EPZ.
Nevertheless, in order"to develop the best possible fully implementable shelter plan, Boston Edison commissioned both the August, 1987 Study of potential public shelters near the beaches and the expanded study of specific structures that may serve as cotential shelters near parks, campgrounds and recreational areas in the remainder of the EPZ. The latter study will also provide information regarding representative protection factors for structures in the EPZ.
Since the basic purpose of pre-identifying public facilities (such as municipal and commercial structures) is to provide shelter locations for persons who do not have ready access to resiuences or'other private structures such as persons utilizing parks, beaches or other similar facilities, it is
- appropriate to focus planning efforts on identifying specific shelters within close proximity of such facilities. Residents and most other persons in the EPZ located in or near private and commercial structures would not require additional sheltering. Accordingly, there is no need to survey the shelter capabilities of every structure in the " entire EPZ".
MCDA's memorandum next states that the August, 1987 Shelter Study "does not separate out those structures which could 'most reasonably' be used as shelters from those where shelter is less appropriate." A " separate list of public buildings and facilities for each town" is recommended along with estimates of " actual usable shelter space and protective factors '. iHemorandum at p. 1.
As discussed in section III above, the August, 1987 Shelter Study did not attempt to identify the "most appropriate" shelters, nor was it intended to do so. Instead, it simply identifies those structures that may potentially 7
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i! be-used as shelters for the' beach population so that planners can examine specific structures in greater detail in order to' identify those that are most
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appropriate for shelter'ing. In that effort, priority will be given to large public buildings.
With respect to the recommendation to develop separate lists of public j shelters for each town including capacity and protective factor information,
'the August,.1987 Shalter Study does list potential shelters and capacity estimates on a town by town basis. -This will also be done for structures in and near other recreational areas being_ identified in the current study. l Procedures will list designated available public shelters for'each town, along with more definitive estimates of usable shelter space. In accordance with l
the regulatory guidance discussed in section II above, individual structures will not be assigned specific protection factors. However, information.
regarding representative protection factors for structures in the EPZ will be-developed.
The next concern expressed in MCDA's Memorandum is that "[m]any of the ,
shelters listed, such as jewelry stores and pharmacies are clearly not suitable for public shelter." Memorandum at p. 1. Again, the August, 1987 Shelter Study was not intended to assess the suitability of specific structures to serve as shelters. Structures which upon further review are l
inappropriate for use as public shelters will be eliminated from consideration by the planners. Commercial and retail facilities frequented by the public will usually be suitable for the short period of time that sheltering may be required. However consideration will be given to particular aspects of the use of the facilities that would.not make them logical or desirable shelters.
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\\ .f The next concern expressed in HCDA's memorandum states: l Regarding protection of the beach population, the survey identifies shelters within a. mile of the coast but does not indicate the distances that beach goers would have to travel to find shelter. In addition, the survey must demonstrate that adequate proximate shelter is available for the total population at the individual beaches. ,
t For instance, Duxbury beach is about seven miles long and the survey i should indicate the distance people at Saquish Head are required to travel to reach adequate shelter. Further, an implementable shelter utilization plan must demonstrate that the nearest shelter would not be ;
full to capacity before the people at the most remote points of the i beaches arrived.
Memorandum at p 2. All of the structures identified in the August, 1987 Shelter Study are located within one mile of one of the public beaches in the EPZ. .Some persons will, of course, be located at greater distances than others, from the point of Beach access and will thus have to travel farther to reach such a shelter. , ,
However, analysis of the beach population distributions shown on aerial ,
photographs shows that people tend to congregate near their parked vehicles.
For example, on Duxbury Beach, approximately 60 percent of the beach l
population is concentrated along the 3/4 mile segment of beach encompassing the two major beach parking areas and on Plymouth beach, approximately 28% of the persons on the beach are located near the parking facilities. These people will have ready access off the beaches.
The aerial photographs also indicate that the remaining persons on Duxbury and Plymouth beaches should have access to a sufficient number of off-road vehicles to permit prompt access off the beaches. Aerial photos of Saquish Neck indicate that access to the area is achieved principally by l
automobile via the road from Duxbury Beach, or by boat, and that persons in l
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the area have access to a vehicle, a boat, or one of approximately 200 l
residences for sheltering.
Beach-goers at th'e other major public beaches (Brant Rock, Green Harbor,
- Gray's Beach, Priscilla Beach, Whitehorse Beach, and Manomet Beach) all have ready access.to adjoining roads where vehicles are parked. Since road access is available along virtually the entire length of these beaches, persons on such beaches will not have to travel long distances to reach public shelters.
I Hith respect to the concern that the " nearest shelter (sh]ould not be l' full to capacity before the people at the most remote points of the beaches arrived," the logical result of this position is that all or virtually all of l the population on a given beach would have to be sheltered in the single l
l " nearest" facility. Memorandum at p.-2. In any event, sufficient sheltering capacity will be provided for all persons on the beaches and a program 1
developed for the peninsular beaches (Duxbury, Plymouth and Saquish Neck) to l
assure that persons seeking public shelter are referred to the closest available shelter.
MCDA's next concern is that the " survey must identify adequate shelter which is handicapped accessible." Memorandum at p. 2. Planners visiting L
potential shelters will, of course, evaluate whether such facilities are l accessible to handicapped person. These shelters will be clearly identified in each town's procedures.
MCDA's memorandum next states that the survey "does not distinguish between available space and usable space" and that it "must identify accurately the actual usable shelter space available in each structure."
Memorandum at p. 2. As described above, this information will be developed by planners in the near future.
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The1Memorand'um next states:
l: - Stone and Hebster uses a FEMA nuclear attack value of . ten square feet
.per person to estimate the potential population which can be sheltered.
. Local Civil -Defen'se Officials may wish to' allocate more space -- up to- l twenty square feet'per person -- in their-utilization plans.- The value
. used in the survey' overestimates the potential. capacity in.various
. buildings. .He doubt that 17,000 people can be sheltered at Duxbury High l School. or that 89,700 can be sheltered at the 5 Cordage Park Buildings. l Memorandum at p. 2. While local civil defense directors may wish to allocate more space in their plans, ten square feet per person has been recognized as- l adequate.- and should in fact be adequate - for the relatively_brief period of time for. which shelter is' anticipated to be necessary (particularly when !
compared against the considerably longer periods of sheltering time that would i be required in the event of a nuclear attack). Moreover, as stated earlier, j the' capacity values listed in the survey were not intended to reflect 'actually l i
'available sheltering capacity, but simply the potentially available capacity * .l from which specific usable shelters would be identified. Nevertheless, if sufficient capacity.is available, additional per capita square footage will. be {
allotted. Finally, there is, of course, no intent to shelter.17,000 persons at Duxbury High School or 89,000 persons at the 5 Cordage Park Buildings.
Tha next concern expressed by MCDA is that the survey "must demonstrate I
that public shelters are free from asbestos and other environmental hazards."
Memorandum at p. 2. Public shelters to be designated for use in an emergency will, of course, be drawn from municipal and commercial buildings which are .
used daily by the general public and which are required to comply with state health codes. Given the short duration for which such facilities could be )
1 needed as shelters, it is not necessary to conduct a separate evaluation for potential environmental hazards. Of course, if such hazards are identified during the process of examining specific structures which render a facility unsuitable for use as a shelter, such a facility would not be designated for use.
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-The Hemorandum next states that:
a The report estimates residential " sheltering capability" in individual
. communities'as be. tween 53% and.81%. These. figures indicate that a {
significant number of residents do not have adequate domestic shelter and emphasize the need.for a full study of public_ shelter capacities throughout the entire EPZ.
Further,'even if it.can be established that the' vast majority of- . .
residences offer adequate shelter, local officials must be. prepared to offer public shelter of'a known protective. capability to residents who demand assistance.
Memorandum at pp. 2-3. The August, 1987 Shelter Study identified the percentage of residential structures with shielding capabilities comparable to .!
that provided by typical commercial structures. However, as described in q Section II above, an adequate shelter need not provide protection factors j equivalent to commercial structures.. Residential structures'(whether constructed of brick or wood) are appropriate for providing short term ,
shelters for the public in the EPZ.
Finally, the Memorandum states that the Study:
makes no definitive statement of what constitutes adequate shelter to protect people from the effects of radiological release from Pilgrim , .
Station. This is necessary to determine what facilities are most ;
appropriate,for a local shelter utilization plan and to determine the '
public shelter needs of each community. !
Hemorandum at p. 3. As described in section II above, sheltering is typically selected as a recommended protective action where it will result in greater dose savings than any other action and thus it is not necessary to determine protection factors for specific facilities in developing plans for sheltering. Nevertheless, information regarding representative protection factors'for structures in the EPZ will be developed and the most appropriate shelters availabie_ will be identified and secured in the planning process. i w
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IV. Conclusion.
i When viewed in it's appropriate context, the August, 1987 Shelter Study l 1s a'useful, initia'l step in the planning process. The other steps undertaken to date and planned in the near future will assure that ' appropriate sheltering plans are developed. !
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