ML20245A683

Forwards GE Studds Transmitting Town of Plymouth Committee on Nuclear Matters Rept Re Emergency Response Plan for Plant,For Ongoing Review of Offsite Emergency Preparedness Issues,Per 870331 Memo

ML20245A683
Person / Time
Site:	Pilgrim
Issue date:	04/29/1987
From:	Congel F Office of Nuclear Reactor Regulation
To:	Krimm R Federal Emergency Management Agency
References
CON-#487-5052 2.206, NUDOCS 8705060340
Download: ML20245A683 (1)

Text

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• r MEMORANDUM FOR: Richard W. Krim DOCKETEr-Assistant Associate Director USNFC

( Office of Natural and Technological Hazards Programs Federal Emergency Management Agen@J IR -5 P7:43 FROM: Frank J. Congel, Director trricf 0F E. u a T v -

Division of Radiation ProtectionDOCKEhNG 4 $[pygj' and Emergency Preparedness BRANCE Office of Nuclear Reactor Regulation

SUBJECT:

OFFSITE EMERGENCY PLANNING AT PILGRIM ,

The enclosed letter from Congressman Gerry E. Studds of Massachusetts provides a report by the Town of Plymouth Comittee on Nuclear Matters concern-i ing the emergency response plan for the Pilgrim nuclear power plant. Since FEMA has the lead responsibility for the evaluation of offsite plans and as the report addresses issues of offsite preparedness, I am transmitting Congressman Studds' letter and the report to you in connection with your ongoing review of offsite emergency preparedness issues at Pilgrim, as described in your memo-(~ randum of March 31, 1987 regarding the Pilgrim 2.206 petition. A copy of the report was previously provided to your staff.

Original signed by:

Frank J. Congel . Director Division of Radiation Protection

, and Emergency Preparedness Office of Nuclear Reactor Regulation

Enclosure:

Ltr. from Congressman Gerry E. Studds dtd. 4/7/87 CONTACT: C. Richard Van Niel, NRR 492-4535 Distribution:

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April 7, 1987

Dear chairman Zech:

I am writing today to bring to your attention a report prepared by the Town of Plymouth Committee on Nuclear Matters on the emergency response plan for use in the event of a severe accident at the Pilgrim nuclear power station. I hope that this summary of the plan's deficiencies and practical suggested improvements will be helpful as the Commission considers the pending petition requesting that the commission order the Boston Edison Company to show cause why the Pilgrir facility should not remain closed until the company demonstrates that certain issues, including emergency response issues, have been resolved.

I would also appreciate being informed of the status of the Commission's consideration of this petition.

Thank you for your attention to this matter.

With kind regards.

Since ely/)

,: [E l l !/

Gerry . Stu ds Lando W. Zech, Jr.

Chairman }

United States Nuclear Regulatory Commission 1717 B Street, NW l Washington, DC 20555 l

l Enclosure k '

i TOWN OF PLYMOUTH COMMITTEE ON NUCLEAR MATTERS t

6 REPORT TO THE SELECTMEN ON THE PLYMOUTH RADIOLOGICAL EMERGENCY RESPONSE PLAN i

l March, 1987 g G ,k C rk f 12-((g 0 - ' 7 " i' Af

s p r THE COMMITTEE ON NUCLEAR MATTERS MEMBERS:

Grace M. Healy, Chair Charles W. Adey, Vice-Chair Ann Waitkus Arnold r Theodore L. Bosen j, Marie P. Fehlow &

Kenneth T. Holmes Kathleen M. Leslie Anthony V. Lonardo John P. Rooney James W. Ryan Howard E. Shetterly SUBCOMMITTEE MEMBERS:

Ann Waitkus Arnold Kenneth T. Holmes J

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i TOWN OF PLYMOUTH THE RADIOLOGICAL EMERGENCY RESPONSE PLAN INTRODUCTION As one of its tasks, the Committee on Nuclear Matters assumed respon-sibility for a review of the Plymouth Radiological Emergency Response Plan (RERP). The following is the result of research undertaken by the sub-committee, and of the deliberations of the entire committee.

In order to det ermine Plan adequacy and f eas ibility , informat ion was sought from many sources. Subcommittee members reviewed written materials:

other Emergency Response Plans (ERP); Federal Emergency Management Agency (FEMA) Regulations; rr. ports on the adequacy of various RERP's; testimony of public interest groups, and one available section of Secretary Barry's report. Subcommittee members also contacted, in person and by telephone, representatives from: (1) Local, Regional and State Civil Def ense Of fices, (2) FEMA, (3) various Town offices; (4) State Of fice of Handicapped Af f airs; and (5) Boston Edison.

SUMMARY

CONCLUSIONS AND RECOMMENDATIONS r

There are deficiencies in the Plymouth RERP. Moreover, these deficiencies are serious enough, in the Committee's judgment, to precluAe

"... reasonable assurance that adequate protective measures can and will be taken (by the Town and State) in the event of a Radiological Emergency."

There is reason to believe that as things stand now, the Selectmen cannot fulfill their legal respons ib ilit y , particularly during a Radiological Emergency, ".... to provide for the health and safety of persons and their property ...."

The Plymouth RERP is a " paper" plan, essent.ially untested relative to mobilization of some of the essential personnel. As long as it is untested, difficult questions can remain unanswered and difficult decisions can be avoided. This is a situation unacceptable to the members of the committee.

Thus, we respectfully urge Selectmen to assign tasks and t imelines to appropriate personnel and/or offices to ensure accomplishment of the following:

A. Comprehensive revision of the Plymouth RERP.

1. Correction of outdated information.

2. Elimination of specific deficiencies noted below.

3. Complete specification of implementation procedures.

4. Specification of procedures for ongoing updating and coordination with local, area, and state plans.

l B. Appointment of a full-time Civil Defense Director, with staff as needed, with adequate interim headquarters, and with long-term plans for location in one of the new Town buildings.

C. Development of funds for emergency preparedness from federal, state and utility sources. (Appointment of liaison for same.)

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. D. Full Town participation in a comprehensive drill prior to Pilgrim's -i coming back on-line. (While actual citizen evacuation may not be feasible, full participation must at least include all responsible personnel being in-j place and carrying out assigned tasks.) Coordination of agencies, their services and lines of responsibility - local, state, federal levels must be tested.

l The Commit tee further recommends that all deficiencies be remedied and all recommendations be implemented prior to reactor start-up.

There .was one dissenting opinion expressed concerning the above. The objection relates to making total task accomplishreat a condition for reactor start-up' when longer time may be required for some tasks. The dissenting.

opinion does not represent disagreement on deficiencies or recommendations, but on timelines. In all cases there is agreement on need and urgency for action.

!iPECIFIC DEFICIENCIES AND RECOMMENDATIONS Following are specific deficiencies found by the Committee on Nuclear Matters and some recommended corrective measures; they have been grouped in ,

eight categories: ( A) Advance Information, (B) Notification and Communication  !

Systems, (C) Evacuation Routes , (D) Evacuation Time Estimates, (E) Transpo[t of Dependent Populations, (F) Reception Centers and Public Shelters, (Q) _

Medical Facilities, and (H) Radioprotective Drugs.

A. ADVANCE INFORMATION DEFICIENCIES:

1. Inadequate public information in Emergency Preparedness Zone (EPZ).

2. Lack of mult i-lingual info rmat ion (Italian, Portuguese, Spanish, Japanese).

3. Inadequate distribution of Emergency Preparedness Info rmat ion (EPI) brochures.

4. No information for people without access to transportation.

5. No information about staging areas (pick-up points).

6. Tourist and transient information inadequat e or non-existent .

7. No educational effort outside the Town of Plymouth.

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ADVANCE INFORMATION (Continued)

RECOMMENDATIONS:

1. Implement a comprehensive, ongoing public educat ional program through news ads, cable TV programs, radio public service announcements, and informational packets included in utility bills. Include an outreach program for non-English speaking people in these activities.

2. Develop emergency info rmat ion posters (multi-lingual), with maps explaining:

- Protective Actions - Location of Public Transportation

- Evacuation Routes - Local Radio Station of EBS

- Location of Public Shelters - Staging Area Locations

3. Post Emergency Information Posters in public locations:

Hotels, motels, restaurants, gas stations, phone booths, recreation facilities, tourist sites, inf o rmat ional centers, theaters, airports, bus stations, trolley cars, and all public buildings.

4. Develop survey to identify special populations: ,

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a. Non-English speaking people. ,

b. Transport dependent groups:

- 15% of Plymouth households have no car;

- 50% of households have one car, but one half of workers have jobs outside of Plymouth.

c. Special needs people:

- Federal regulations require not ification of "all segments of society."

- Deaf and hard-of-hearing people must be identified beforehand so they can be alerted by appropriate meann.

5. Distribute updated pamphlets semi-annually to:

- General public and all recommended locations in #3 above.

- Multi-lingual pamphlets should be available in the same places.

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- B. NOTIFICATION AND COMMUNICATION SYSTEMS DEFICIENCIES:

1. Siren System

a. The siren system is'not equipped to confirm that all sirens have been sounded during an exercise. There are no provisions for-determining which sirens are not working..

b. .Present siren system does not warn hearing-impaired persons. No alternate plan exists to notify this segment of the population.

2. Radio Communications

a. Department of Public Works radio equipment used for Civil Defense is unreliable and inadequate.

b. Present system for notifying local officials is unreliable.

c. Plymouth County . radio network (Sheriff's) is inadequate /

inefficient.

RECOMMENDATIONS:

ALL PROCEDURES FOR NOTIFICATION OF AN ACCIDENT AT PILGRIM I SHOULD BE REVIEWED. l t

1. Investigate the "hard-wire" system or other alternatives that confirm  !

siren activation. Alert officials who will dispatch personnel to areas with defective sirens to activate sirens manually and to warn public from vehicles and loudspeakers.

2. Develop procedures to confirm activation of every siren. Specify numbers of vehicles and personnel required for #1 above.

3. Test sirens weekly on the same day and at the same time.

4. Identify hearing impaired people and install telecommunication devices.

5. Provide closed captioning for the Emergency Broadcasting System.

6. Install tone alert radion in every school bus , transport vehicle, and other vehicle specially licensed to transport children, the elderly, and

' handicapped persons in the Emergency Preparedness Zone.

7. Upgrade Plymouth County Radio network hardware. Test the hardware on a regular basis, f

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C. EVACUATION ROUTES - LIMITED ACCESS AND EGRESS DEFICIENCIES:

1. Proposed routes (Routes 3 and 44) are completely inadequate for ef f ective handling of anticipated volume of traf fic. Traffic is already jammed due to the heavy volume of tourists in the sumn.er months , and during heavy winter storms, or when roads are under construction or repair.

2. Voluntary evacuation (Evacuation Shad v Phenomenon) is not taken into account.

RECOMMENDATIONS:

The following are not remedial; they simply address worsening of the problem.

1. New development along evacuation routes should require an impact study by developers with specifications set by appropriate Town Offices. The study should be reviewed by the Planning Commit tee.

2. Prior to approval of road construction / repair (along evacuation routesf) the appropriate Town Of fice must make an impact assessment anddeve1{p

• alternative routes.

D. EVACUATION TIME ESTIMATES DEFICIENCIES:

1. Present time estimates arc based on outdated information and have major flaws.

2. Evacuation Time Estimates (ETE) is based on several questionable assumptions:

a. It assumes there will be no mass voluntary evacuation not in planned boundaries (shadow-phenomenon) as occurred at Three Mile Island, which could cause major route blockage and back-ups.

b. It assumes that emergency personnel will remain in place and not evacuate with their families.

c. It assumes that cot:munities outside the Ten Mile EPZ have developed adequate plans to augment evacuation and sheltering efforts, although Massachusetts Civil Defense Agency (MCDA) states no such plan exists.

d. It assumes the timely presence of State Police and National Guard.

3. Large discrepancies exist between Boston Edison and the Nuclear Regulatory Con: mission (NRC) ETE's.

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e EVACUATION TIME ESTIMATES (Continued)-

4.. Panic and traffic disorder have not been adequately considered:

a. -Blocking of. cross streets

b. Disregard of traffic signals

c. Driving in left hand lane id.' Abandoned vehicles.

!- e. Driver. confusion

f. Failure of traffic control

g. Accidents These considerations 'plus ineffective traffic control could result

. in more than a 50% reduction in traffic flow, which would mean the

' evacuation time could be more than douLitd.

5. No adequate estimates for time required to evacuate non-car-owning people dependent on public transport.

6. Estimates of the number of vehicles at public beaches is inadequate.

7. Estimates required by federal regulations are lacking.

a. Separate times , for adverse weather - fog, rain, f looding , snow, storms.

b. Day versus night, workday versus weekend, peak transient vers s non-peak transient, and evacuation versus non-evacuation' n adjacent sectors.

c. Separate estimates for "special population groups" on an

" institution by institution" basis (e.g., schools, hospitals, nursing homes , correctional' f acilities).

RECOMM3NDATIONS:

1. The new Bonton Edison Company (BECo) ETE's mu'st:

a. be based on realistic assumptions,

b. include all specific time estimates required by FEMA,

c. take into account mass voluntary evacuation consequences,

d. address previously stated shortcomings. 1 i

2. The new ETE must be completed prior to plant operation.

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3. Documentation should be provided by BECo to assure the ETE's provide a .

workable means to evacuate all residents of the EPZ based on a wide -

range of accident scenarios.

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. E. PLANS TO TRANSPORT DEPENDENT POPULATION (People without access to cars, school children and children in day care, hospital and nursing home residents, handicapped persons, campers, persons in correctional institutions.)

DEFICIENC'ES:

1. Numbers of vehicles needed and sources for them have not been analyzed.

2. No contracts or letters of agreement have been signed with MBTA, bus companies, drivers, ambulance companies, and other entities providing public transportation and personnel support for the pisn.

3. There are no particular plans for evacuating handicapped people. This segment of the population has not even been identified.

4 Plans call for individuals to make arrangements with local CD for transportation. Local CD will then contact MCDA Area II for assistance; however, the Area II plan does not contain information on how to procure additional transportation.

5. Schools - There are no separate plans or procedures for each school a9d day care center. Bus companies and drivers have not signed agreemenps to perform during an evacuation. The school plan lacks detailed pro-cedures. Estimated time to mobilize National Guard for schools is three hours, and Guardsmen may not be f amiliar with road network.

RECOMMENDATIONS:

1. Conduct a survey to de t e rmine transportation needs of all people dependent on public transportation in all sectors of EPZ. Provide specific and separate information for summer /non-sucmer, weekday / weekend populations.

2. Document available resources and resource needs, such as transportation contractors, t rained personnel, drivers trained in emergency response procedures, special care personnel and equipment for disabled persons.

3. Obtain written agreements with transportation contractors and drivers.

4 Develop specific, adequate plans to evacuate each dependent group, such as the population in nursing homes, hospitals, schools, camps, residential homes, correctional institutions, day care centers.

5. Provide for special needs population -

physically and mentally handicapped people:

a. Provide notification in advance of special evacuation procedures for disabled people;

b. Plan for delivery of necessary services during an emergency with t ra ined assistance for each handicapped person designated beforehand;

c. Provide beepers, backup personnel for vacation times, special equipment and medications.

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- F. RECEPTION CENTERS AND SHELTERS Bridgewater State College and Taunton State Hospital)

DEFICIENCIES:

1. There are no clearly defined functions for the reception centers and shelters.

2. There are no letters of agreement, or contracts with reception centers.

(Who provides what and who pays?)

3. There are no adequate plans, equipment, supplies or personnel to implement purposes for reception centers. (Such as contamination monitering, decontamination, congregate care, ...)

4. Public shelter locations are not identified.

5. Adequate plans for public shelters are non-existent (personnel, supplies, etc.)

6. Resettlement and/or reentry plans have not been formulated.

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7. The option of sheltering in private homes versus evacuation is nqt addressed. t RECOMMENDATIONS:

1. Define specific and separate functions for public shelters and reception centers.

2, Specify conditions for which sheltering in privete homes might be preferable to evacuation.

3. Conduct survey of potential shelters adequate to accommodate peak summer populations.

4. Identify and contract for an adequate number of reception centers and public shelters to accommodate EPZ population.

5. Provide adequate plans for equipment, supplies and personnel for centers and shelters.

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G. MEDICAL FACILITIES l l

DEFICIENCIES:

1. There are inadequate plans for treating large nuirf> e rs of victims of radiation exposure.

2. The two hospitals listed in the Plan (Jordan and St. Luke's) can treat only a limited number of people with radioactive contamination.  !

i 3- One hospital is within the EPZ and could be simultaneously receiving and evacuat ing patients.

E ~R.DiENDATIONS :

1. Clearly determine response capacity of Jordan and St. Luke's Hospitals.

2. Identify all possible referral hospitals outside EPZ.

3. Document capacity, types of care and provisions available at referral hospitals out side EP' .

4. Obtain signed agreeunts with referral hospitals. r i

5. Develop procedures for transportation of patients outside the EPZ. &

H. RADIOPROTECTIVE DRUCS PRESENT POLICY:

The Massachusetts Department of Public Health does not advise distribu-tion to the general public of Potassium Iodide (KI) as a radioprot ective d rug .

RECOMMENDATION:

That the Department of Public Health provide for the dist ribution of Potassium Iodide or a proven alternative to the general Plymouth population prior to reactor start-up.

In conclusion, the Committee notes, once again, that the deficiencies identified herein and the recommendations made relative to the Plymouth RERP are by no means exhaustive or all-inclusive. Those listed are, however, serious enough that , were they not to be addressed, the selectmen might be unable to "... provide for the health and safety of persons and their property ..." during a radiological emergency. Hence, the Committee respect-fully urges the Selectmen to give immediate attention to the matters con-tained in t'nis report. Even after the current revision of the RERP and the implementation of recommendations, regular monitoring by the Town will be needed so that improvements in the plan may be made as they beccee necessary.

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