ML20205N988

Discusses Quotes Taken from Transcript of 881014 NRC Meeting in Rockville,Md Re Emergency Planning

ML20205N988
Person / Time
Site:	Pilgrim
Issue date:	10/31/1988
From:	Thompson A PLYMOUTH, MA
To:	NRC
References
NUDOCS 8811070189
Download: ML20205N988 (9)

Text

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i TOWN OF PLYMOUTH OFFICE OF SELECTh1EN THE SELECTMEN 11 Lincoln Street

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GEORGE W. CAhf ERON 0A witithi R. cRimx Nm uth. Massachusetts 02360 3$n 'n$lNsoN h Chairman EXEClmVE SECRETARY (508)747-1620 fe-3%J October 31, 1988 Nuclear Regulatory Commission Washington, D.C. 20555 Gentlemen:

The transcript of the October 14, 1988 meeting of the NRC ,

held in Rockville, Maryland, has been received and reviewed by the Plymouth Civil Defense Director and the Chairman of the Board of Selectmen.

Quotes taken from pages 76 - 103 in reference to emergency planning are compared with the facts as we know them.

Today Mr. William Lazarus of Region I and Miss Rosemary Hogan of NRR, both in the NRC emergency planning area, met with Mr.

Douglas Hadfield, Plymouth Civil Defense Director, and Mrs.

Alba Thompson, Chairman of the Board of Selectmen. The informal meeting was held in the Emergency Operations Center of our town. Some of our concerns were passed to them. It is the first time any emergency planners of the NRC have over met with or listened to Plymouth officials with a view to gathering some specific information. They did not, of course, have a chance to study our draft plans and procedures.

We trust we have been able to convey to you our substantial doubts about testimony presented that we know to be inaccurate or incomplete as it relates to Plymouth.

We request, again, that the Commissioners themselves speak directly to us. Please contact our Executive Secretary, William Griffin, 508-747-1620. We shall make ourselves available either here in Plymouth or at a location convenient to the Commissioners.

We appreciated meeting with Mr. Lazarus and Ms. Hogan, but it is not a substitute for speaking directly to the Commissioners. No member of our Board of Selectmen nor our 8811070109 0H1031 DR ADOCK O g

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Civil Defense Director has ever been accorded this courtesy.

It is our feeling that in view of our location, entirely within the EPZ, and our geographical. spread of 103 square miles, and a population of 45,000 citizens, as well as our hands-on knowledge of and responsibility for radiological emergency planning, that our request to be heard by the  :

Commissioners is firmly _ based on your need to know and our need to be heard.

Very truly yours, i

, BOARD OF SELECTMEN ub.YftA,fto c l Alba C. Thompsdn ,

Chairman -

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. cc Governor Michael Dukakis Senator Edward Kennedy Senator John Kerry Congressman Gerry Studds  ;

) State Representative Peter Forman  !

State Senator Edward Kirby i

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o Comparison, Quotes from the Transcript of NRC meeting on October 14, 1988, "Discussion /Possible Vote on Pilgrim Restart." (pp.76-103 only) Rockville, Maryland, October 25, 1988 (Transcript Quote-- first; Plymouth Civil Defense / Selectmen's Comment follows)

"The Situation at Pilgrim is not unique" p. 76 line 16 The past history at pilgrim (See SALP reports, fines) and the ,

difficulties of roadway net make planning for Plymouth unique. In any case, every emergency plan is unique to the locality bearing in mind particular geographic, meteorological, demographic conditions among others.

...The staff believes that we have sufficient information to come to our own conclusions concerning the significance of '

the outstanding issues, pending completion of the FEMA process." p. 78 That is not possible without a study of Plymouth's plans at this point (October 14, 1988). No NRC emergency planning staffer has ever consulted with the Civil Defense Director or

a Selectman in the past three years. Not a one has ever visited a Plymouth official for the purpose of being informed

on emergency planning. Plymouth with a population of 45,000 is entirely in the EPZ. It is the largest town in Massachusetts in terms of area (130 square miles).

l "The last full exercise was in 1985. We have issued an ,

exemption to the regulation requiring full participation '

exercise every two years." p. 78 3mergency planning reauires testing to determine weaknesses ,

i and deficiencies, Present drafts have never been tested.

... The NRC staff has continuously monitored the status of emergency preparedness." p. 79 No one ever sat down with Plymouth Civil Defense Director or a Selectman or tested our draft plans for the past three '

years.

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"FEMA in its report, withdrew its interim finding .,f. adequacy for off site emergency; preparedness and concluded that there was no longer adequate assurance that public health and safety could be protected" p. 79 That report was issued August 1987. There is Dg FEMA approved emergency plan at this time for Plymouth. FEMA's statement remains correct (October 1988), and the Plymouth Board of Selectmen also says "There ir, no adequate assurance that public health and safety could ce protected with the state of present emergency planning."

"Considerable progress toward resolution of the issues pertaining to the schools ... is evidenced by the drafts that have been prepared." p. 80 Not True. There are no implementing procedures for Plymouth Schools. Both school committees held a public hearing on October 25, 1988 to solicit input and have much work ahead of them.

"In order to assess progress, the NRC staff has reviewed local plans and procedures, discussed the issues with local town emergency planning officials ..." p. 80 NRC staff has never reviewed local plans with town emergency planning officials. Neither could our procedures have been reviewed since they have never left Plymouth, and no NRC staffer has ever asked to see them. There are at present (October 26, 1988) 34 approved from a total of 90 to be completed.

"We have attended numerous public meetings in the area ..."

p. 80 Not one public meeting in Plymouth has been devoted to emergency planning. The only NRC Commission meeting on emergency planning was held on October 5, 1988, in Rockville, Maryland. Our Civil Defense Director was present but wan not permitted to speak. Boston Edison was invited to give its "current understanding" of Plymouth's planning - no Plymouth officials who are responsible for planning, implementing, or approving plans were invited to testify. Plymouth protested this in a letter to commissioners dated October 4, 1988.

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"We have toured the area ... with special emphasis on the beaches" p. 80 When? Not with our Police or Fire Chief. Not with our Civil Defense Director. Not with a Selectman.

Subsequent testimony indicates a lack of knowledge of the number and difficulties of our beaches. There seems to be a confusion of Saquish and Plymouth Beach. Saguish is a highly isolated peninsula with a small year round population.

Plymouth Beach is a three mile peninsula which attracts thousands in the summer. There are other Plymouth beaches which NRC doesn't seem to know about (Priscilla, Manomet, White Horse, etc.)

"We have toured the area with special emphasis on ... the local emergency operating centers." p. 80 When? No NRC emergency planning staff has ever visited Plymouth's EOC. The only NRC staff that ever paid a visit to the EOC was the Reactor Safeguards Subcommittee (September l 1988 hearing) during its lunch break when meeting in the same  ;

building. The EOC was under renovation at the time and much '

equipment was missing.

"There are five procedures for two EPZ communities for Plymouth and Ducksberry that although prepared, have not yet been approved by the local officials for forwarding to the Commonwealth for Technical review." p. 82 Incorrect. Selectmen had, as of the date of the testimony, approved 34 implementing procedures. Since we shall have 90 l

total procedures, we have still a great deal of work to be I

accomplished. None of the 34 locally approved IP's have been forwarded to anyone at any level.

l l "These limited demonstrations provide the staff with the basis to conclude that significant progress has been made in improving the emergency plans and procedures" p. 82

{ We are unaware of any "demonstrations" in Plymouth of training of bus and ambulance drivers from companies providing transportation for school and daycare centers, l special needs population, and Transportation-dependent persons.

To conclude "pianificant progress" has been made on "limited" demonstrations (of which Plymouth is unaware) is not logical.

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"This first slide shows the status for resolution of the school children concern ..." p. 85 There has been no resolution on school children concern.

There are no implementing procedures yet approved by the two School Committees, let alone the Selectmen.

"The next slide shows the resolution for the beach sheltering $

issues and the concern with mobility impaired" p. 85 There is no resolution for either category. Implementing procedures are not yet completed and therefore they certainly are not yet approved. There is not correct or complete list .

of mobility impaired persons. Such a list is now being I complied but is still very fragmentary. Refer to our Civil 4

Defense Director and our Handicapped Committee.

"Local officials continue to finalize the plans in preparation for a full scale exercise." p. 87 '

Our plans are a long way from a final stage. We have no notification of any full scale exercise to be conducted.

i "I have personally met with some of the local planning '

officials in the Plymouth area." Dr. Bellamy p. 91 With whom? Dr. Bellamy sat on the dais during some public hearings. He never, to our knowledge, met to discuss local emergency planning with Plymouth officials.

"I have toured the Duxbury Beaches" p. 91 But not the Plymouth Beaches? We have 17 miles of coastline t and several beaches.  ;

"I have visited the local emergeacy operating conters ..." p.

91 Plymouth's EOC was completed only last week. We have no knowledge of any visit by Dr. Bellamy to our EOC (Reference l 3 Civil Defense Director).

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Mr. Murley Yes ... What'I said was that we would expect to see progress in improving plans ..." p. 92 This is not~the impression Dr. Murley left citizens during his previous testimony (Kennedy Hearing - January 1988) .

Refer to transcript. He implied a demonstration exercise of such plans would be held before restart. ,

Chairman Zech: But you've (Dr. Bellamy) had a fair amount of interface with local officials."

Dr. Bellamy: Yes, Sir.

Chairman Zech: And they seem to be conversing with you.

.Dr. Bellamy: Pretty much so.

Not true. No one in an official planning capacity is able to recognize Dr. Bellamy. There has been no "interface" except as Dr. Bellamy may have been sitting on a public hearing panel (never devoted entirely to planning). No Selectman has ever had an on-going conversation on planning with Dr.

Bellamy. Neither has the Civil Defense.

"There are approximately 300 as a round number of required ,

l implementing procedures and as I indicated, there are five of i

those procedures that have yet to be sent to the Commonwealth with any type of approval from the local officials." p. 96 Inaccurate as relates to Plymouth. Misleading. Plymouth alone must submit 90 procedures to the Commonwealth. Only 34  :

have been approved by the Selectmen. The core or heart of

! planning - schools, fire, police, hospital - are still in ,

various stages of development. None of these core IP's have  ;

, been approved.  !

Our schools alone have a student population of over 8,000 (8 elementary schools , one intermediate school, and two high schools in 103 square mile area) and a staff of over 1,000.

Planning must be comprehensive, and in this case is difficult.

Jordan Hospital serves all the communities in the EPZ. It is l the only hospital in the EPZ. It's plans are not even in a  :

form to be reviewed by the Civil Defense Director. t i

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. "Commissioner Carr Do they camp overnight on those beaches?

Dr. Bellamy, No, Sir.. They do not." p. 97 Not true. Camping is permitted on Plymouth Beach. Both

! Saquish Beach and Plymouth Beach have some year-round residents. A confusion between Saquish and Plymouth Beach 1 conditions relative to high tide conditions is evident in the testimony.

"Bus drivers know how to drive their buses" p. 98

True, but without letters of agreement, and there are none in Plymouth, there is no guarantee that bus drivers will show up q to evacuate schools, nursing homes, etc.

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Chairman Zech

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... at least I would consider a lot of good working relationship between you and the people that are doing the job in that area; is that correct?"

Mr. Bellamy: Yes, Sir; it is." p. 99 i

j That is not correct. A "working relationship" has not been j established. See previous comments.

"The Commission does indeed have to have the confidence that i

emergency plans could be executed if necessary." (Chairman

! Zech) p. 102 Thank you, from the people of Plymouth. We, too, need to have that confidence as a matter of public safety.

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