ML20237J527
| ML20237J527 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 08/21/1987 |
| From: | Murley T Office of Nuclear Reactor Regulation |
| To: | MASSACHUSETTS, COMMONWEALTH OF |
| Shared Package | |
| ML20237J494 | List: |
| References | |
| CON-#487-5055 2.206, DD-87-14, NUDOCS 8708260206 | |
| Download: ML20237J527 (46) | |
Text
.O e DD-87-14 UNITED STATES OF AMERICA-NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Or. Thomas E. Murley, Director In the Matter of )
L Docket No. 50-293 BOSTON EDISON COMPANY )
(Pilgrim Nuclear Power Station) ) (10 C.F.R. 62.206)
INTERIM DIRECTOR'S DECISION UNDER 10 C.F.R. 4 2.206 INTRODUCTION On July 15, 1986, Massachusetts State Senator William B. Golden and others (Petitioners) filed with the Nuclear Regulatory Commission a Petition requesting that the Director require Boston Edison Company (BECo, the licensee) l 1
to show cause why the Pilgrim Nuclear Powcr Station should not remain closed i
or have its operating license suspended by NRC until the licensee demonstrates that the issues raised by the Petitioners'have been resolved. The Petitioners also requested that NRC require the licensee to submit a feasibility study related to certain structural modifications and that the NRC schedule a public hearing to address the issues raised by the Petitioners. i The Petitioners assert as grounds for their request (1) numerous s
deficiencies in the licensee's management, (2) inadequacies in the existing
.q radiological emergency response plan, and (3) inherent deficiencies in the
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s facility's containment structure. The Petitioners assert that "the deficiencies cut a broad swath across the spectrum of safety requirements" and that, in the l aggregate, these deficiencies compromise the reliability of the most important safety systems in the plant. Further, the Petitioners assert that the licensee and the NRC have failed to resolve these safety issues. )
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On August 12, 1986, James M. Taylor, then Director of the Office of ;
J Inspection and Enforcement, acknowledged receipt of the Petition. He informed ,
the Petitioners that the Petition would be treated under 10 CFR 2.206 of the >
Commission's regulations and that a formal decision would be issued within a reasonable time. Notice of receipt of the petition was published in the Federal Register (51 FR 29728).
On December 19, 1986, Mr. Taylor provided further response to the I Petitioners in a letter to Senator Golden. He' stated it would be more meaningful to formally respond to the Petition after (1) the licensee has had an opportunity to address the issues outlined in.the Petition and (2) the NRC '1 has had an opportunity to review the licensee's actions. He also stated (1) that the Pilgrim Station will not be permitted to restart until the NRC determines that there is reasonable assurance that the public health and safety will be protected and (2) that the staff will consider the manage-ment, emergency planning, and containment issues raised by the Petition.
i Dr. Thomas E. Murley, then Regional Administrator of NRC Region I, sent J additional letters regarding the Petition to Senator Golden.on February 20, and April 1, 1987 The February 20 letter acknowledged that a meeting with the Petitioners had been delayed because the NRC first wanted to have available the licensee's report documenting why the licensee believes the Pilgrim Station can be restarted. The April 1 letter was in response to the Petitioners' letter of February 25, 1987, regarding a meeting between NRC and the Petitioners.
Dr. Murley's April 1 letter provided clarification regarding the proposed meeting with Petitioners; it also noted that the plant has remained shut down
a and that considerable changes had occurred, and continue to occur, in the.
Substantive areas outlined in the Petition.
On August 5,1987, Massachusetts Public Interest Research Group (MASSPIRG) submitted " Health Surveillance of the Pilgrim Area" as an addendum to the Petition. This report provides results of the Massachusetts Department of Public Health (MDPH) study to determine whether there is excess risk of l certain adverse health outcomes among residents in the communities surrounding l the Pilgrim Station. The data revealed no disturbing trends in either the patterns of cancer mortality or in the expression of low birthrate and infant mortality, but indicated higher than expected incidence of leukemit. As l
stated in the MDPH study, radiation monitoring records did not suggest any significant levels of radiation that could have potentially exposed the residents in the communities surrounding the Pilgrim Station. The report was l
l the result of a descriptive, first step epidemiological study which acknowledged major gaps in understanding the relationship, if any, between the occurrence of leukemia and the Pilgrim Station. Consequently, no further consideration of this report by the NRC is merited at this time.
For the reasons discussed below, Petitioners' request insofar as it relates to the emergency preparedness and containment issues is denied. A final decision with respect to the management issues is deferred. However, to the extent Petitioners are reouesting that Pilgrim remain shut down until the NRC is satisfied that management and emergency preparedness issues are dealt with to the Commission's satisfaction, the Petition is granted.
Petitioners also request that "the NRC, prior to making a decision pursuant to issuing an operating license suspension, schedule a comprehensive public hearing to address the issues raised by the Petitioners herein" (Petitionat391. In response to that reouest, the NRC staff has agreed to
meet with Senator Golden and other petitioners to discuss the issues raised in )
i the Petition as well as the overall status of NRC regulatory activities at Pilgrim when the licensee has completed those actions necessary for restart of )
the plant.
I In addition, the Commission intends to hold a public meeting to be briefed by the Staff on the readiness of P_ilgrim to resume operations before allowing restart. The filing of a 2.206 Petition, however, does not require the NRC to hold formal evidentiary hearings with respect to issues raised by the Petition. Illinois v. U.S. Nuclear Reculatory Conmission, 591 F.2d 12 j 14 (7th Cir.1979); Porter County Chapter of the Izaak Walton League of America, Inc. v. Nuclear Regulatory Commission, 606 F.2d 1363 (D.C. Cir.
1979); Wells Eddleman, et al. v. Nuclear Reculatory Commission, No. 87-1018, slip op. at 5 (4th Cir. August 10,1987); Lorion v. Nuclear Regulatory Commission, 785 F.2d 1038 (D.C. Cir. 1986). See also Florida Power & Licht Co. v. Lorion, et al. , 740 U.S. 729 (1985).
BACKGROUND The NRC staff found the overall performance at the Pilgrim Station acceptable during the assessment period covered by the Systematic Assessment i
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i of Licensee Performance (SALP No. 85-99). 1/ There was sufficient concern, )
however, about the facility's performance that Region I conducted a special in-depth Diagnostic Team inspection from February 18 to March 7,1986 l (InspectionReportNo. 50-293/86-06, issued April 2,:1986). The team found that improvements were inhibited by (1) incomplete _ staffing, particularly operatcrs and key mid-level supervisory personnel; (2) a prevailing (but incorrect) view in the organization that the improvements made to date had )
corrected the problems; (3) reluctance, on the part of the licensee's management, to acknowledge some problems identified by the NRC; and (4) the licensee's dependence on third parties to identify problems rather than implementing an effective program for self-identification of weaknesses.
Nonetheless, in a letter from Region I to the licensee dated May 23, 1986, the Diagnostic Team inspection results confirmed the SALP Board conclusions for SALP No. 85-99. In that letter, Region I restated its belief that i
"... performance in the operation of the facility was found acceptable although l some areas vere only minimally acceptable."
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--1/ This Decision refers to two SALPs. The first iG identified as SALP '
No. 85-99 and relates to the licensee's performance during the period October 1, 1984 - October 31, 1985. The report of this SALP was initially issued by Region I on February 18, 1986. It was the subject of further correspondence dated May 23, 1986, between Region I and BECo. The second SALP is identified as SALP No. 86-99 and relates to the licensee's performance during the period November 1,1985 -
January 31, 1987. The report of this SALP was initially issued April 8, 1987 It was issued as a final report on June 17, 1987
On April 1?,1986, the licensee shut down the Pilgrim Station because of equipment problems and operational difficulties. The NRC Regional Administrator acknowledged this shutdown in Confirmatory Action Letter (CAL) l 86-10, which was issued that same date. On July 25, 1986, the licensee stated that the facility would remain shut down for the completion of various modifications and for refueling. In an August 27, 1986, letter to Mr. J. Lydon of BECo, Dr. Murley stated that, although the licensee's actions in response to CAL 66-10 appeared to be thorough, additional issues had been identified that had to be resolved before restart of the facility. j
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These issues included certain technical issues (overdue surveillance, I malfunction of recirculation pump motor generator field breakers, seismic qualification of emergency diesel operator differential relays, and completion of Appendix R modifications) and programmatic matters (the l licensee's action plan for improvements, the role of the licensee's safety l review committees, and the readiness of the plant and corporate staffs to support restart). Further, Dr. Murley stated in the same letter, "In light 1
of the number and scope of the outstanding issues, I am not prepared to approve restart of the Pilgrim facility until you provide a written report l that documents BECo's formal assessment of the readiness for restart ope ra ti on. "
At this time, the Pilgrim Station remains shut down. The staff recently issued SALP Report No. 86-99 (April 8,1987). Although this report identifies a number of perfonnance problems (as did the previous SALP report),
the staff believes the licensee is beginning to effectively deal with these
e problems and is making progress toward improving their performance. For ex-ample, changes have been made to the radiological controlc program, decon-tamination is in progress, fire protection modifications are being completed, i
and various surveillance, maintenance, and modification issues are being resolved. Offsite emergency planning issues have been evaluated by the
-l Federal Emergency Management Agency (FEMA). These are reported in a FEMA i l
report entitled, "Self-Initiated Review and Interim Finding for the Pilgrim Nuclear Power Station," dated August 4,1987 The licensee has stated that the facility is not expected to be ready for restart before the end of September 1987.
NRC has asked the licensee to submit a readiness assessment report at least 45 days before the planned restart of the plant. On July 30, 1987, the licensee submitted a report entitled " Pilgrim Nuclear Power Station Restart Plan." This Plan describes a portion of the programs, plans and actions considered necessary by BECo management for safe and reliable restart and operation of Pilgrim. Portions of the Plan will be updated six weeks before BEco's proposed restart and final results will be submitted three weeks before the proposed restart. The Plan is currently under staff review.
A specific discussion of each of the three areas addressed in the '
Petition follows.
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DISCUSSION A. Management i The Petitioners allege numerous deficiencies in the licensee's management.
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The Petition essentially states that (1) competent management is critical to ensure the safe operation of any nuclear power facility; (2) the licensee's
-1 management of the Pilgrim Station is. deficient; and (3) long-standing management deficiencies at Pilgrim Station have not been corrected. !
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As a basis for their Petition, the Petitioners have provided an extensive list of management deficiencies that have been documented in NRC inspection and SALP reports. The areas of concern include: plant operations, radiological
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controls, onsite emergency preparedness, maintenance and modifications, surveillance testing, security and safeguards, refueling and oJtage management, licensing activities and fire protection. The basic documonts relied on by the Petitioners were SALP Report No. 85-99, issued February 18, 1986, and the Special NRC Diagnostic Team Inspection Report issued on April 2,1986. In j addition, the Petitioners referred to the 1982 Civil Penalty and Order modifying the Pilgrim license, and to news accounts of statements by Commissioner James Asselstine to the effect that Pilgrim is one of the worst run and least safe plants in the nation.
At the time the Petition was filed, the NRC felt the licensee had not successfully deelt with the problems that were ioentified in (1) the enforce- '
ment actions taken in 1982, as evidenced by SAlp No. 85-99, and (2) the
1 Diagnostic Team inspection findings. Although the licensee had instituted )
programs intended to improve management and had made progress at certain times and in specific areas (such as in engineering and technical support), the :x
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letter transmitting SALP No. 85-99 expressed NRC's concern about the licensee's I apparent " inability to improve performance, or sustain improved performance once achieved."
Several management changes have taken place in the licensee's organiza-tion since early 1986. The station manager was replaced on May 1,1986, and {!
was replaced again on February 1,1987 'On July 1, 1986, the Senior Vice )
l President-Nuclear was transferred. At that time, the Chief Operating.0fficer . t assumed the responsibilities of the Senior Vice President-Nuclear, which he .
held until February 20, 1987, when the current. Senior Vice President-Nuclear (Ralph G. Bird) assumed the responsibilities of this position. On March 26, 1987, the Chief Operating Officer and the Executive Vice President / Chief Financial Officer announced their intent to retire within the next year. On April 10,1987, the Vice President for Nuclear Operations resigned; his responsibilities are being managed by the Senior Vice President-Nuclear, and .
l a replacement has not been hired at this date. '
The NRC has monitored management issues at Pilgrim Station since SALP '
No. 85-99 and the Diagnostic Team inspection. The most recent SALP evaluation, SALP No. 86-99, issued April 8,1987, states: "The lack of a clear
f organizational structure, recurring management changes, and chronic staffing -
vacancies delayed the establishment of a stable licensee mantgement team at the plant and inhibited progress during the assessment period."
Starting with CAL 86-10, issued April 12, 1986, the NRC has taken steps to ensure the Pilgrim Station will not restart until adequate corrective actions have been taken. On July 30, 1986, Dr. Murley, at a meeting with the licensee, informed the licensee that, even when the technical issues set I forth in CAL 86-10 were resolved, he would not approve restart of the plant until the managenent issues discussed in SALP No. 85-99 also were resolved. '
In addition, on A; gust 27, 1986, in a letter to the licensee, Dr. Murley stated that restart of the Pilgrim Station would not be approved until the ;
I licensee formally documented and NRC reviewed (1) an assessment of the i licensee's readiness for plant restart and (2) a restart program and schedule including well-defined hold-points at discrete milestones.
The NRC agrees with the Petitioners that significant management defi-ciencies have existed at Pilgrim Station. The NRC is continuing to observe and i
evaluate the licensee's performance through ongoing inspections, bimonthly-management meetings with the licensee, and the SALP process. The NRC will conduct an independent team review of the licensee's actions in response to the SALP findings and the findings of the Diagnostic Team inspection of February-March 1986. The NRC will evaluate the Pilgrim Restart Plan and other information to determine whether the issues raised by the Petitioners, including management issues, have been adequately resolved, m__________.____.--_--_m.-_-_.____._-____-____--__--_m.m_ _.____.__. .-. _ - _ . _ - _ _ _ _ _ _ _ . _ . _ _ . . - . _
F Because the Pilgrim Station is currently shut down and will not be allowed
- restart until authorized to do so by the NRC, there is no additional safety assurance to be gained by granting Petitioners' request.
Thus, the management deficiencies at the Pilgrim Station do not warrant a Show Cause Order for the facility to remain closed or have its operating license suspended.
A final Director's Decision regarding management issues cannot be rendered until the management deficiencies have been suitably addressed by the licensea and the staff completes its assessment. This portion of the Petition will therefore be addressed in a subsequent final decision.
B. Radiological Emergency Response Plan The Petitioners allege inadequacies in the existing Radiological Emergency Response Plan (RERP) for the Pilgrim Station. The Petitioners essentially state that there are deficiencies in (1) the RERP, (2) the procedures for providing advance information to the public, (3) the systems for notification 1
of the public during an accident, (4) the evacuation plar.s, (5) available medical facilities, (6) the size of the emergency planning zone, and (7) the coordination and prioritization of the RERP.
The emergency response plans for Pilgrim Station were submitted in response to the NRC requirements that resulted from the issuance of a revised emergency preparedness rule on August 19, 1980 (45F]!55402). After the
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revised rule was issued, FEMA reviewed the State and local response plans for the Pilgrim site and evaluated the March 3,1982 joint full-participation exercise. On the basis of this review and evaluation, FEMA's Region I office issued interim findings in a report entitled, " Joint State and 1.ocal l
Radiological Emergency Response Capabilities for the Pilgrim Power Station, Plymouth, Massachusetts," dated September 29, 1982. In this report, FEMA concluded that the Massachusetts State and local emergency plans and preparedness for coping with the offsite effects of radiological emergencies that may occur at the Pilgrim Station were adequate to protect the public.
With regard to the onsite portion of the March 3, 1982 exercise, the NRC determined that the emergency response actions taken by the licensee were adequate to protect the health and safety of the public. Since that time, the licensee has participated in additional emergency preparedness exercises where nsite and offsite response capabilities were demonstrated and evaluated by the i NRC and FEMA. The most recent full-participation exercise was conducted on ,
September 5,1985. A remedial exercise, held on October 29, 1985, demonstrated ;
that four deficiencies identified during the September exercise had been corrected. As a result, FEMA Region I concluded that there was reasonable assurance that appropriate offsite action can be taken in the event of a radiological emergency to adequately protect the public health and safety.
The relevant portions of the Petition relating to emergency preparedness were transmitted to the FEMA staff on August 4,1986, and the !
NRC requested on August 11, 1986, that FEMA review offsite emergency planning
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and preparedness issues raised in the Petition. On December 22, 1986, the Secretary of Public Safety of the Commonwealth of Massachusetts sent FEMA a copy of the Office of Public Safety report entitled, " Report to the Governor on Emergency Preparedness for an Accident at the Pilgrim Nuclear Power Station "
dated December 1986., The Secretary of Public Safety also asked FEMA Region I to review a report entitled, " Evaluation of Offsite Emergency Preparedness in the Area Surrounding the Pilgrim Nuclear Power Station," dated January 1987, which was prepared for the licensee by the Impell Corporation.
On January 14, 1987, FEMA informed the NRC that the requests for a review of these repcrts might delay the completion of the FEMA evaluation of the issues raised in the Petition. In a memorandum to NRC dated March 31, 1987, FEMA stated that it was also conducting a self-initiated review of the overall state of emergency preparedness at Pilgrim Station. FEMA said that it would prepare a consolidated evaluation that would address the Petition issues, the report submitted by the Office of Public Safety, the Impell report, FEMA's self-initiated review, and other relevant available information. FEMA committed to make the production of their evaluation report a priority task. By memorandum dated April 29, 1987, the NRC provided FEMA with a copy of a report prepared by the Town of Plymouth Nuclear Committee entitled, " Report to the Selectmen on the Plymouth Radiological Emergency Response Plan," dated March 1987, and asked FEMA to include this report in the ongoing review.
On June 4,1987, BECo prepared reports regarding Evacuation Time Estimates and Beach Population Sheltering, Mobility Impaired, and Special
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Facilities. One June 12, 1987, BECo prepared a report regarding a Northern Reception Center. NRC forwarded these reports to FEMA on July 1, 1987.
On August 6,1987, FEMA forwarded their August report entitled, "Self-Initiated Review and Interim Finding for the Pilgrim Nuclear Power l Station, Plymouth, MA," to the NRC. This report included FEMA's July 29, l 1987, analysis of the issues raised in the subject petition entitled,
" Analysis of Emergency Preparedness Issues at Pilgrim Nuclear Power Station Raised in a Petition to the NRC Dated July 15, 1986." In their analysis FEMA individually addressed each of the seven issues in offsite emergency planning I
raised in the subject Petition and one-by-one found that the information in the Petition did not sustain the Petitioners' contentions when compared to the record at the time the Petition was reviewed. For convenience, FEMA's detailed analysis is provided as Attachment A to this Director's Decision. On the basis that FEMA's analysis of the Petition's specific issues did not sustain the contentions, this portion of Petitioners' request is denied. This denial notwithstanding, the Commission acknowledges that FEMA agrees with the l '
i general thrust of some of the conclusions of the Petition for reasons cited in l FEMA's Self-Initiated Review and Interim Finding dated August 4,1987 Based on this latter report, FEMA has concluded that offsite radiological emergency l planning and preparedness for Massachusetts are inadequate to protect the l
public health and safety in the event of an accident at the Pilgrim Nuclear Power Station. The issues that FEMA identified as a basis for this conclusion were:
- 1. Lack of evacuation plans for public and private schools and daycare centers.
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- 2. Lack of a reception center for people evacuating to the north. .!
- 3. Lack of identifiable public shelters for the beach population.
- 4. Inadequate planning for the evacuation of the special needs population.
- 5. Inadequate planning for the evacuation of the transportation dependent .l 1
population. i
- 6. Overall lack of progress in planning and apparent diminution in emergency i
preparedness.
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l In summary, while this portion of Petitioners' request is denied, the emergency planning issues identified by FEMA are a matter of serious concern. The detennination whether to restart the Pilgrim plant will involve, in necessary part, consideration of the resolution of emergency planning issues identified by FEMA.
C. Containment Structure The Petitioners allege thet there are numerous deficiencies in the General ,
l Electric (GE) Company Mark I containment structure. The Petitioners assert that ;
I the GE Mark I presssure-suppression system employed by the Pilgrim reactor 4 contains inherent design flaws that raise questions about its ability to with-stand accidents. Generally, the concerns relate to (1) design issues raised by Dr. S. H. Hanauer in the early 1970s, (2) the Chernobyl accident, and (3) the capability of the Pilgrim containment to withstand severe accidents. These are addressed below. However, before discussing the adequacy of the Pilgrim con-tainment it would be useful to describe the design philosophy and licensing requirements, which are the basis for reactor containments in the United States.
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- 1. BACKGROUND 1 l
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Containment structures are an integral part of the US reactor designs in -
that they form one part of a structured tiered approach to public safety known as defense in depth. Concisely put, defense in depth is the process imple- ,
mented by the AEC (later NRC) to ensure that multiple levels of assurance and safety exist to minimize risk to the public from nuclear plant operation.
l A primary level of assurance are those activities to ensure that the plant 1 is designed and constructed to high ouality standards. Guidance on plant desion j l
is provided in the Code of Federal Regulations and specified in the General j Design Criteria (GDC). Specific information is provided in the NPC's Standard Review Plan (SRP) which details acceptable methods for complying with the -
requirements established in the GDC.
Early in the development of commercial nuclear power it was recognized that these complex systems could not be expected to be immune from various failures and malfunctions, regardless of the quality of design, construction, and operation.
l Therefore, a further level of defense was established in that the plants were ]
required to be designed for successfully coping with various equipment failures, transients and postulated accidents. The scenarios for postulated accidents, I to which all plants are designed to adequately respond, are known as design basis accidents and are detailed in the NRC's Standard Review Plan, which is used to evaluate the design of each nuclear power plant prior to the granting of a construction permit or operating license. I Design basis accidents were chosen to represent a wide spectrum of plant problems, some of which were expected to be experienced in the plant lifetime (such as failure of power systems), as well as events considered to be quite infrequent (such as major ruptures of piping systems).
Details of these design basis accidents are found in Chapter 15 of the NRC Standard Review Plan, which also identifies acceptable plant protection standards for each postulated plant accident. The requirements and capabilities of plant safety systems necessary to prevent these design basis accidents from leading to unacceptable radiological releases are specifically identified. Guidelines for judging the acceptability of the analytical results in response to these hypothetical scenarios are specified in NRC regulations. The plan % Jesign guidance required as a result of this approach results in the incorporation of multiple and backup safety systems which will protect the reactor during the postulated failures of these various protection devices.
Notwithstanding the above, additional margins are required in the plant design to protect the public even in the event of very unlikely accidents.
The reactor containment provides an additional level of safety. Design basis accidents for containment reflect a number of arbitrary accident sequences developed from postulated events. For example, the containment structural design is based upon the effects of a concurrent earthquake and a rupture of major reactor coolant system piping. Concurrently, in order to assess the effectiveness of leaktightness, the safety systems are presumed to not be effective in cooling the reactor core resulting in the release of fission products from the reactor core. Although the design basis accidents discussed above are allowed to result in some failed fuel (lest than one percent), they do not result in core damage. For the containment design, some independent failures of the protection systems are assumed to occur simultaneously with the occurrence of the accident they are intended to cont.rol. While the purpose of other safety systems is to shut down the reactor fission process and provide
emergency cooling water to the reactor core, the containment has a required function of providing an essentially leaktight barrier to " bottle up" any radioactive material released to the containment through any rupture or break in the reactor coolant system. Given the release of the radioactive material 1
and cooling water, the containment is required to retain this material and prevent significant releases to the e'nvironment. Consequently, the assessment of containment design adequacy assumes the postulated release of fission products to the containment irrespective of the performance of the core cooling f safety systems.
While design basis accidents are used to determine the adequacy of plant ,
systems' design and performance, a set of additional' assumptions is imposed to l
further presume that these systems will not work as designed. The containment
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design basis reflects a combination of parameters incorporating several desion basis accidents for structural considerations coupled with an assumed release !
of radioactive material to containment for assessing leaktightness.
In summary, the original design purpose of the reactor containment was to protect against postulated radioactive releases from hypothetical reactor accidents up to and including major ruptures of reactor coolant piping, where such events resulted in some degree of core damage. These hypothetical events- l postulated a release of fission products from the reactor core to the reactor coolant system and subsequently into the containment through the pipe break.
This was considered one of the less likely, but possible accidents and provided a straightforward means of providing additional margins for containment design.
One must also consider the concept of severe nuclear accidents and how they fit within the framework of protection from design basis accidents. 2_/
For the last several years, as part of the NRC's efforts to continually evaluate and increase power plant safety, we have been studying the likelihood and consequences of extremely low probability incidents with attendant higher estimates of core damage and higher radiological releases from the core. - This a
class of accidents is beyond the existing design basis and is k'nown generally as severe accidents. This was first done comprehensively by the Reactor Safety-Study (WASH 1400), which is known as a probabilistic risk assessment (PRA). The type of accidents studied in this evaluation are bDsically those where multiple l
backup safety systems fail, eventually resulting in damage to the nuclear fuel '
and considerable releases of radioactive material outside of the reactor cooling system. Depending on other failures and containment behavior, significant 1 radiological releases into the environment could conceivably occur. Implicit in these scenarios is the development of a better' understanding of containment -
1 performance and its failure mechanisms.
More detailed PRA studies have been conducted since the publication of WASH 1400 to better understand the probability of these unlikely events and also to better predict the magnitude of potential radiological releases into the environment, given a containment failure and attendant consequences.
Considerable work has also focused on the behavior of reactor containments fol- i lowing a severe accident where molten reactor fuel could potentially melt through the reactor vessel. Results of such studies have generally confirmed
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2/ Severe accidents are defined as those "in which substantial damage is done to the reactor core, whether or not there are serious offsite consequences." This definition is extracted from the." Policy Statement on Severe Reactor Accidents Regarding Future Designs and Existing Plants,"
50 Fed. Rea. 32138, August 8, 1985.
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the very low likelihood of such accidents and relatively low risk to the public even if such very low probability accidents were to occur. While not originally l designed to protect against some of the severe accidents, reactor containments 1
provide considerable benefit from their ability to reduce radiological releases i to the public from such accidents. For example, the results of research work indicate that the actual pressure retaining capability of most containments is well above their original design pressures. Studies also indicate that the massive i containment structures may provide considerable retention of radioactive material j even if they were to fail following a core melt event. As discussed in Section C.4, there exists considerable uncertainty regarding a Mark I containinent's behavior during a core melt accident. A recent study judged the probability of some form of containment failure, assuming a core melt had occurred, to be between 10 and 90 percent. E Due to the very complex processes involved in a severe reactor accident, exact predictions of accident consequences are difficult. Considerable research 1 isunderway to give us additional information in this area. Results from such studies allow us to focus our attention in areas where improvements can be made l
to provide increased levels of safety from these very unlikely events. The purpose of these projects is to conduct hypothetical "what if" studies, to understand ways public risk from nuclear operations can be justifiably reduced.
Even though we strive to reduce public risk further, results of our studies indicate that risk from these severe accidents are very low and do not warrant E The Reactor Risk Reference Document - Draft (NUREG-1150).
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immediate actions. More information on the adequacy of the Pilgrim containment l
and its adequacy with respect to severe reactor accidents is provided in Section j l C.4
- For background information purposes, a brief description of the Pilgrim l
l Mark I Containment Design is provided in Attachment B. A discussion of the l
l historical problems and the specific three assertions regarding deficiencies in the Mark I design is provided below. Section C.2 will address the Hanauer 1 1
issues, Section C 3 will address the Chernobyl issues and Section C.4 will l provide additional information on the Pilgrim containment's acceptability from, a perspective of severe accident risk.
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- 2. Hanauer Issues l The Petitioners have expressed concerns that are based on memoranda i written before 1978 by the staff of the Atomic Energy Commission (AEC) and the .
1 NRC (which succeeded the AEC in 1975). These concerns relate to the ability of the Mark I containment to respond adequately to its original design function (i.e., deal with a large loss of coolant accident). The key document cited is a memorandum written by Dr. S. H. Hanauer on September 20, 1972. This document raised seven concerns, all of which centered on the viability of the pressure-suppression containment concept. Portions of four of those concerns have been either directly or indirectly quoted in the Petition; they relate to steam- l i
bypass susceptibility, valve reliability, lack of adequate testing, and j volume limitations causing overcrowding.
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1 When Dr. Hanauer's seven concerns were raised, the staff evaluated ' i each of them to determine whether adequate safety margins were being maintained on existing plants. Subsequently, the NRC staff concluded that Dr. Hanauer's concerns had been properly considered, and documented its findings in NUREG-0474, "A Technical Update on Pressure Suppression Type Containments in Use in U.S. Light Water Reactor Nuclear Power Plants," issued in July 1978.
Enclosure A to NUREG-0474 summarizes NRC staff actions related to each of the seven concerns identified in Dr. Hanauer's memorandum of September 20, 1972. For convenience, a copy of that enclosure is provided as Attachment C to this response. E&ch statement of concern was followed by a response that reflected the NRC evaluation. In each case, the response showed that the NRC no longer considered the concern an unresolved safety issue.
It should be noted that while the concern reflected the views of Dr. Hanauer in September 1972, the NRC response reflected the status of the issue in July 1978. Moreover, by June 1978, Dr. Hanauer had changed his !
opinion regarding his 1972 concerns, as reflected in a memorandum dated June 20, 1978 in which he stated: "Thus while we may yearn for the greater simplicity ,
of ' dry' containments, the problems of both ' dry' and pressure suppression con-tainments are solvable, in my opinion, and the design safe, therefore licensable" (NUREG-0474).
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s Our review of the Petition issues 'that are based on correspondence dated 1978 or earlier indicates that-all of these issues have been addressed in j- NUREG-0474 Although various changes have occurred since then, the fundamental 1
safety conclusions stated in NUREG-0474 are. essentially unchanged. The most )
notable of the changes has been the NRC. position related to inerting the con-tainment. O Since NUREG-0474 was issued, the regulations relating to this issue (10 CFR 50.44, " Standards for Combustible Gas Control System in Light 1
Water Cooled pnwer Reactors"1 have been revised to require all Mark I cnd II J containments to be inerted. The response to Dr. Hanauer's concern (see Item B 4 of Attachment C to this response) indicates that mort Mark I containments were already inerted. Pilgrim was inerted at the time NUREG-0474 was published; however, the reason for inerting was restricted to Design Basis Accident (D8A) considerations. With the issuance of the revised 10 CFR 50.44, the Comission required all Mark I and II containments to be inerted to accommodate the de-graded core accident. Therefore, although the revision did not cause anv j immediate change to the Pilgrim plant operation, the change did alter the basic j NRC requirements in this area. A review of this and other changes made since NUREG-0474 was issued indicates that, in no case, have the changes altered the fundamental staff conclusions concerning safety contained in NUREG-0474.
The Petition references statements from NUREG-0474 that relate to differences between expected experimental results and actual test results.
T/ An inerted containment is one in which oxygen is replaced by enough nitrogen to preclude combustion.
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The Petitioners state that surprises repeatedly occurred during the course of the various, then-ongoing, test programs. The statements extracted from I i
NUREG-0474 were made during 1978 when many of these test programs were in their l
early stages. )
These test programs were initiated by utilities owning Mark I plants as part of a program in response to NRC letters that were transmitted in February and April 1975 to all utilities owning BWR facilities with Mark I design containments (including the licensee). The letters requested that the owners quantify the hydrodynamic and safety-relief valve-(SRV) discharge loads and assess the effect of these loads on the containment. (These.loadshadnot been considered during the licensing of the individual plants because these loads (including pool swell) were identified in the period 1972 through 1974 as part of the review of the large-scale testing of the Mark III containment system 1
design.)
1' As a result of these letters from the NRC and recognizing that the evaluation effort would be very similar for all Mark I BWR plants, the utilities (including the licensee) formed an ad hoc Mark I Owners Group. The objectives of this Owners Group were to determine the magnitude and significance of these
'Jynamic loads as quickly as possible and to identify actions to resolve any outstanding safety concerns. A series of generic test programs was created to accomplish these objectives.
Since NUREG-0474 was issued in July 1978, the generic test programs related to the Mark I containment design and the NRC assessment of the tests have been completed. The staff evaluation of the generic tests programs was reported in NUREG-0661, " Mark I Containment Long Term Program Safety Evaluation l
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Report," issued in July 1980. NUREG-0661 describes and presents staff con-clusions regarding the generic techniques for the definition of suppression pool hydrodynamic loads in a Mark I system and the related structural acceptance criteria. As part of the acceptance criteria, the staff required a plant-specific analysis. I The licensee performed a plant-specific analysis on the Pilgrim Station. The licensee submitted the Plant Unioue Analysis Report (PUAR) of the l
l Suppression Chamber - Mark I Containment Long-Term Program (TR-5310-1) on l
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l October 27, 1982, and the PVAR of the Torus Attached Piping - Mark I Contain- l ment Long Term Program (TR-5310-2) on October 26, 1983. On the basis of this analysis, the licensee proposed design changes to restore the intended safety I margins. (The intended margin in this context simply means that the structural margin that was computed without consideration of the hydrodyn6mic and SRV loads would remain unchanged when the loads are included and the modifications completed. ) The staff reviewed these changes and approved them in a Safety Evaluation Report issued January 30, 1985. The modifications have been imple-mented and the licensee has demonstrated that the Pilgrim containment is capable of accorrmodating design-basis accidents with adequate margin.
The Petition refers to another concern which can be considered as related to Dr. Hanauer's concerns. The concern focused on the safety dis-advantages of pressure-suppression containments. This issue is related to the possibility of steam bypassing the suppression pool in BWR pressure-suppression containments, and was designated as Generic Issue 61, "SRV Line Break Inside the Wet Well Airspace of Mark I and II Containments." An evaluation of this issue 1
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was recently completed, and the results were presented in NUREG/CR-4594,
" Estimated Safety Significance of Generic Issue 61," which was issued in 1
June 1986.
l On the basis of these results, the staff concluded that no new requirements were justified and, on the basis of an overall risk assessment, no further study of this safety issue was warranted.
In summary, the Petitioners have asserted that the pressure-suppression containment design is flawed from the perspective of its original design function and they have questioned the viability of this containment type.
We have shown that many of their specific concerns, and in particular those issues raised by Dr. Hanauer, were previously and satisfactorily addressed in NUREG-0474 and in various generic issues programs. For those concerns identi-fied since NUREG-0474 was issued, generic programs were conducted to determine the magnitude of the design loads under investigation and the licensee, based on the program results, implemented design changes at Pilgrim to reestablish acceptable structural design margins. Consequently, these concerns are resolved.
- 3. Chernobyl Accident The Petitioners express concern regarding the threat of a Chernobyl-type event at the Pilgrim Station as part of an overall reference to severe accidents.
Immediately upon learning of the event at the Chernobyl plant in the Soviet Union, the NRC fonned a task force to thoroughly evaluate the accident
to learn as much as possible about its causes, course, and consequences. The results of this effort were published in NUREG-1250, " Report on the Accident at the Chernobyl Nuclear Power Station." NUREG-1250 was prepared collaboratively by the NRC, other United States Government agencies, and other groups.
Within the next few weeks, the NRC plants to issue for public comment a report entitled, " Implications of the Accident at Chernobyl for Safety Regulation of Commercial Nuclear Power Plants in the United States," NUREG-1251 (August 1987).
The facts of the Chernobyl accident relied on for this report are drewn from NUREG-1250 and its sources. NUREG-1251 present; an assessment of the implications, with respect to a number of U.S. reactor safety regulatory issues. The issues selected for evaluation were those associated with significant factors which led l 1
to or exacerbated the consequences of the Chernobyl accident. Issues covered are in the areas of administrative controls and operational practice, design, l containment, emergency planning, and severe accident phenomena.
Notwithstanding important design differences between the Chernobyl l reactor and U.S. commercial rectors, the findings from these reports add to our 1
understanding of some of the phenomena that may be involved in a severe nuclear accident and provide some additional insights useful in guiding our severe accident programs. The findings and assessments provide us with conclusions regarding the vulnerability of plants such as Pilgrim to a Chernobyl-type event.
The Chernobyl accident was initiated by serious operator violations of safety procedures. However, the ensuing reactor damage resulted from basic design f eatures o# the RMBK 1000 reactor which are specifically prohibited
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in US reactors. The RMBK reactor :lesign does not use large steel reactor. '
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pressure vessels with water as a moderat$r, such as are employed in the US s designs. Rather, the RMBK utilizes a graphite moderated pressure tube . concept.
For some conditions or modes of operation this design has an undesirable. a characteristic known as a positive void coefficient. s%
A positive void coefficient means that, for. reactor incidents where rapid.
power increases vaporize cooling water in the pressure tubes, a further power increase is incited. This is known as negative control' stability, sad occurred ,
so quickly at Chernobyl that the operetors or safety systems had no opportunity l to respond and an explosion resulted. In violation of operating procedures, .some.
i 1 q safety systems had also been deactivated. The RMBK design also possesses a slow acting safety control rod system, which further contributed to the event.
As nuclear power was being developed in the United States, the importance
')
of control stability and specifically negative void and negative power co-efficients were recognized. The nuclear cores of US reactors are 3 specifically designed to prevent the power instability which caused the Chernobyl accident, and also include fast acting safety control rod systems. Fully complying with dese design criteria, Pilgrim responds to an increase in voiding by a power reduction due to the inherent physics of its design. Additionally, it is worth noting that the accident at Chernobyl was exacerbated by the graphite fire which resulted. Since Pilgrim does not utilize graphite in its design, the concerns I associated with a graphite fire are not applicable. Also of note is the fact that the reactor at Chernobyl is surrounded by a confinennnt structure as opposed to a containment, as in Pilgrim. The differences in design relate to the basis 1
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of the pressure retaining capability of the two structures. 'The Pilgrim reactor I con'tainment would be expected to withstand an internal pressure resulting from 1
an energy. release many times the energy release that the Chernobyl reactor co1finement could (by design and'in fact) withstand. .!
As discussed above, the steam explosion in the reactor core, wh'ich ruptured l the reactor core and surrounding building, was caused by a nuclear physics design vulnerability specifically prevented by the Pilgrim design. Due to that !
i and other factors discussed above, we find that the contentions of the Petitioners j i
regarding Chernobyl are without merit.
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- 4. Capability of the Pilgrim Containment to Withstand Severe Accidents The Petitioners raised concerns regarding the possibility that'the Pilgrim containment might fail in the event of a severe accident. The 1 Petitioners assert that there is a tendency to underestimate the probability of various types of accidents; they cite, among other things, the recent accident at Chernobyl (see previous section). The Petitioners also conclude that there is a high probability that Pilgrim's Mark I containment structure will not stand various severe accident scenarios.
As discussed at the initial introduction to this section (C.1), the NRC !
views probabilistic risk assessment as a structured method for investigating J the likelihood and consequences of reactor accidents considered to have a very low frequency of occurrence. The perceived inability of the Pilgrim s
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containment to survive a severe accident was identified by the Petitioners as a design flaw.
The evaluation of severe accident vulnerability involves three ' distinct evaluations. First, the probability of an accident involving core damage.
Second, the likelihood of containment failure and third, an assessment of the radiological consequences and public doses resulting from the accident. All.
three issues must be considered in making a determination on the magnitude of severe accident risk and what actions should prudently be taken to reduce those risks.
The studies which have been conducted emphasize that the results inherently possess large uncertainties. The draft results of NUREG 1150 present the most recent program, whose intent is to accurately reflect the severe accident risk at a number of US nuclear power plants, and also to properly reflect the areas of uncertainty. This study included an evaluation for Peach Bottom, a plant quite similar to Pilgrim in reactor design and containment. The study pre-sented the estimated mean frequency of core damage to be approximately one chsnce in 100,000 per yebr of operation. Another comprehensive risk study conducted for the Limerick plant estimated a mean core damage probability of 1 in 10,000.
These results are consistent with NRC's belief that core melt accidents are.
very unlikely. Draft NUREG 1150 also investigated the probability of early containment failure following a core melt. This study concluded that our ability to accurately predict the response of a Mark I containment was limited l
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1 for situations where it was subjected to the harsh temperature and pressure i i
conditions following a core melt accident. As stated earlier, the report indicated that tortaiment failure probability (for these extremely unlikely 1
I events) could likely range from 10 to 90 percent. l l
These uncertainties are currently the subject of research efforts to l better predict the behavior of containments during severe accidents, so that a .
1 more complete risk perspective can be assembled for guiding our regulatory activities. However, it is important that these uncertainties be properly ;
1 characterized. They are not identified deficiencies in the BWR Mark I con-
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tainments, which have been demonstrated to satisfy their design performance requirements (see Hanauer Issues, Sec. C.2). Rather, these uncertainties are areas which guide our research investigations, whose goals are to provide improved understanding of very unlikely risk situations at nuclear power ]
facilities. Results from these studies (including high containment failure probabilities) also allow us to calculate public risk estimates assuming that one element of the three which go into a risk assessment (containment failure) is less favorable.
l Even allowing the large uncertainties which result in a high upper value l l
for containment failure, the NUREG 1150 study estimated that the probability I of a large reactor accident that results in 1 or more early fatalities ranged from I in one million to 1 in one billion. Given a severe accident, the prob-abilities of very high radiation exposure and the distances over which they would occur were also estimated to be reasonably small. The risk levels for Pilgrim would of course depend on its actual core melt probability, containment
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behavior, the local demography, and could vary somewhat from the results presented {
in NUREG 1150. The results of this and related studies do, however, support our 1
overall conclusion of low severe accident risk at the Pilgrim utility. One con- l tributing factor is the issue mentioned in Section C.1, that the massive reactor containment structures may retain considerable radioactive material following a core melt even if its pressure boundary is failed. In this regard, containment failures include cracks or other phenomena that result in loss of pressure i
integrity that can result in leaks but should not be viewed solely as catastrophic failure of the containment structure. Plateout and deposition of material within containments, even though there may be leakage, also increase the tim available to implement effective evacuation activities. ,
l While we believe that severe accident risks are low at operating nuclear i plants, our goal is to pursue additional activities to achieve even lower levels of public risk. To assure that our risk conclusions are applicable to all operating units, a number of programs are going forward to assess severe accident likelihood and consequences. These programs include plant specific l
studies to determine any severe accident vulnerabilities, both from the per-spective of accident frequencies and from containment performance following a core melt. Any problems will be dealt with if identified. This program is known as the individual plant examination (IPE) program which is expected to commence later this year. These and related programs will be conducted to provide further assessments of severe accidents on a plant specific basis, so )
that appropriately low risk levels can be maintained.
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On July 25, 1986, the licensee announced that it is voluntarily considering implementation of certain modifications to enhance the Pilgrim i Station containment capabilities. In an April 30, 1987 letter from S. Varga j to R. Bird, NRC asked the licensee to provide details of the modifications and i
procedural changes. We have received the licensee's response dated July 8, l 1987 and.it is currently under review. The NRC does not view any of these modifications as necessary before the plant restarts. The NRC staff will ,
I review these modifications to ensure that th y do represent overall safety.
improvements and that they have no overall adverse safety impact on existing ,
1 systems.
The Petitioners also reouested that the NRC require the licensee to submit a feasibility study on all possible structural modifications before NRC approves specific modification proposals. At the present time, neither the licensee, nor the staff, nor the Petitioners have identified any structural modifications j to the Pilgrim containment that would be warranted by severe accident considerations. Therefore, this reouest for a feasibility study is denied.
The Petitioners' assertions with respect-to inherent design flaws in the pressure-suppression system utilized at the Pilgrim plant have been addressed above. The licensee has implemented modifications to re-establish Pilgrim's intended containment design margins (see the discussion on the Pilgrim PUAR).
Evaluations of the Mark I containment with respect to severe accidents are continuing through (1) the implementation of the Commission Policy Statement on Severe Accidents, (2) the NRC staff and industry dialogue to improve j containment severe accident perfortnance for all BWRs, and (3) the licensee's voluntary initiative.
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1 As indicated in the discussion on the Mark I containment, the Petitoners have not presented sufficient evidence to indicate that .the Pilgrim Station .
should not operate while risk-reduction improvements are being considered.
That is, there is not sufficient evidence of either design flaws at Pilgrim or
.y high risk to warrant a Show Cause Order for the plant to remain closed or to suspend the operating license. Therefore, this portion of Petitoners' request is denied.
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1 CONCLUSION -
l The NRC has required, and will continue to require, that the Pilgrim facility remain shut down until the management and emergency preparedness issues are dealt with to the satisfaction of the NRC.
For the reasons discussed above, a decision cannot be made at this time regarding the management issues. This portion of the Petition will be addressed in a subsequent response.
For the .easons discussed above, the. information identified by the i
Petition does not warrant the initiation of the requested proceedings in '
regard to the radiological emergency response plan.- Based on the FEMA evaluation of the emergency preparedness issues raised by the Petitioners, the Petitioners' request for action pursuant to 10 CFR 2.206 on this issue is denied. However, in view of FEMA's interim finding that Massachusetts offsite i i
radiological emergency planning and preparedness are inadequate to protect the i public health and safety, the Commission will. consider, among other issues, i 1
corrective actions regarding emergency planning issues identified by FEMA before permitting the restart of the Pilgrim Plant.
For the reasons discussed above, the information identified by the l
Petition does not warrant the initiation of the requested proceedings in regard i
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to the containment issues. Accordingly, the Petitioners' reouest for action pursuant to 10 CFR 2.206 on this issue is denied.
As provided in 10 CFR 6 2.206(c), a copy of this Decision will be -
- filed with the Secretary for the Commission's review.
FOR THE NUCLEAR REGULATORY COMMISSION p,; e F .
Thomas E. Murley, Dire <ct~or ~
Office of Nuclear Reactor Regulation Attachments:
A. FEMA Analysis of Petition's Contentions B. Mark I Containment Design .
4 C. Sumary of Staff Actions Related I to Hanauer Issues Dated at Sethesda, Maryland ,
this 21st day of Aug.1987.
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l ATTACHMENT A gh *" w e l
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I ANALYSIS OF EMERGENCY PREPAREDNESS ISSUES AT PILGRlM NUCLEAR POWER STATION RAISED IN A PETITION TO THE NRC UATED JULY 15, 1986
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JULY 29,1987 1
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FEDERAL EMERGENCY MANAGEMENT AGENCY JOHN W. McCORMACK POST OFFICE AND COURTHOUSE 02109-4595 ff/4Lf$ Md5b BOSTON, MASSACHUSETTS SI(f-
TABLE OF CONTENTS EGL 1-3 SECTION 1 - INTRODUCTION..........................
3-4 SECT 10N 11 - SUMMAR1..............................
5-49 SECT ION 111 - FEMA AN ALYS IS . . . . . . . . . . . . . . . . . . . . . . .
APPENDICES:
1 ANALYSIS REPORT OF_ EMERGENCY PREPAREDNESS ISSUES AT PILGRIM NUCLEAR POWER STATION RAISED BY THE MASSACHUSETTS PuBLIC INTEREST GROUP (NASSPlHG)
FEMA, NOVEMBER 6, 1983 2 ANALYSIS REPORT ON ISSUES RELATED TO THE PILGRIM LVACUATION IIME ESTIMATE FOR PILGRIM NUCLEAR POWER STATION, PLYMOUTH, MASSACHUSETTS, FEMA, MAY 1, 1984
'i 3 MASSACHUSETTS CIVIL DEFENSE AGENCY (MCDA) ANALYSIS !
TO THE MASSACHUSETTS PuBLIC' INTEREST RESEARCH 6ROUP (MASSPIRG) REPORT " BLUEPRINT FOR CHAOS 11", JULY 20, 1983 4 1986 EMERGENCY PUBLIC INFORMATION (EPI) BROCHURE FOR PILGRIM EPZ 5 BOSTON EDISON'S RESPONSE ON THE PETITION DATED OCTOBER 29, 1986 6 COMMONWEALTH OF MASSACHUSETTS PottCY ON DISTRIBUTION l 0F POTASSIUM 10DIDE (KI) 7 SEPTEMBER 5, 1986 FEMA LETTER TO COMMONWEALTH OF MASSACHUSETTS REQUESTING ITS VIEWS CONCERNING THE ALLEGATIONS IN THE PETITION; AND'!NDICATING THAT FEMA WAS UNDERTAKING A SELF-! NIT!ATED REVIEW OF THE ABILITY OF THE STATE TO PROTECT THE PUBLIC IN THE EVENT OF AN ACCIDENT AT PILGRIM
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1 INTRODUCTION ON wuLY 13, 193b, MASSACHUSETTS 3TATi 3ENATOR UOLDEN, ,
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3 TATE REPRESENTATIVES HYNES AND -!LDT, THE i' MASSACHUSETTS l DUBLIC INTEREST KESEARCH 6ROUP (MASSPIRG), THE PLYMOUTH !
COUNTY NUCLEAR INFORMATION COMMITTEE, INC. (PCNIC), THE PLYMOUTH ALLIANCE AND ATTORNEYS JO ANN SHOTWELL AND JAMES SHANNON FILED A PETITION wlTH THE NUCLEAR REGULATORY COM-MISSION (NRC). THIS PETITION REQU6STED THAT THE NRC ISSUE AN ORDER TO THE BOSTON ED! SON COMPANY, 1
...TO SHOW CAUSE AS TO WHY THE PILGR!M I NUCLEAR 99WER 3TATION ("C ILSRIM") SHOULD NOT REMAIN CLOSED AND/OR HAVE ITS OPERATING LICENSE SUSPENDED BY THE NHL UNLESS AND UNTIL THAT TIME AT WHICH THE LICENSEE DEMON" STRATES CONCLUS!VELY TO THE NRC AND THE PUBLIC: (1) THAT ITS MANAGEMENT IS NO LONGER HAMPERED BY THE DEFICIENCIES NOTED BY THE l PETITIONERS; (2) THAT THE KAD10 LOGICAL EMER- i GENCY KESPONSE PLAN FULLY COMPLIES WITH 10 CFk s50 47 AND 10 LFR 560 57, IS GIVEN HIGH .
ORGANIZATIONAL PRIORITY AND SUFFICIENT FUNDING l BY THE LICENSEE, THE FEDERAL EMERGENCY MANAGE- ]
MENT AGENfY (FtMA), THE MASSACHUSETTS CivlL DEFENSE AGENCY (MCUA) AND LOCAL GOVERNMENTS; AND ( 3) THAT THE INHERENT DESIGN FLAWS ,
NOTED BY THE PETITIONERS WHICH RENDER PILGRIM l l's CONTAINMENT STRUCTURE EXTREMELY VULNERABLE l IN MOST ACCIDENT SCENARIOS HAVE BEEN OVERCOME j
TO THE EXTENT THAT THE PUBLIC HEALTH AND SAFETY WILL BE ASSURED. l ON AUGUST 11, 1986, NRC FORWARDED A COPY OF THE PETITION TO FEMA FOR INFORMATION AND INITIAL REVIEW. IHEN, ON. l OCTOBER 15, 1986, NRC FORMALLY REQUESTED THAT FEMA EVALUATE THE OFF-SITE EMERGENCY PLANNING AND PREPAREDNESS ISSUES RAISED IN THE PETITION. IHIS IS A REPORT OF THAT EVALUA-1 T10N. {
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IHE PETITION IDENTIFIED SEVEN ALLEGED DEFICIENCIES IN EMER-GENCY PLANNING (LISTED AS NUMBERS 14 THROUGH 20 IN THE PETI-T!ON) AS FOLLOWS:
14 DEFICIENCIES IN THE HADl0 LOGICAL EMERGENCY RESPONSE PLAN (KLKP) 15 DEFICIENCIES IN ADVANCE {NFORMATION 16e DEFICIENCIES IN NOTIFICATION UURING AN ACCIDENT 17 DEFICIENCIES IN EVACUATION PLANS 18 DEFICIENCIES IN fled! CAL FACILITIES 19 THE EMERGENCY PLANNING ZONE IS TOO SMALL 20 LACK OF COORDINATION AND PRIORITIZATION OF THE RERP UN SEPTEMBER 5, 1986, FEMA SENT A LETTER (SEE APPENDIX 7) l TO K0BERT BOULAY, DIRECTOR, MASSACHUSETTS CIVIL DEFENSE l
l AGENCY WITH A COPY TO BOSTON EDISON REQUESTING THElR VIEWS l CONCERNING THE ALLEGATIONS IN THE PETITION AND FURTHER l
DEVELOPMENT OF PROCEDURES FOR CORRECTING ANY PLAN DEFICIENCIES WHICH MAY EXIST. FLNA ALSO SENT A LETTER TO SENATOR 60LDEN REQUESTING A TRANSCRIPT OR DETAILED NOTES OF A JUNE 18, 1986 MEETING AT THE STATE HOUSE CONCERN!NG THE EMERGENCY RESPONSE PLANS FOR THE P!LGRIM PLUME EXPOSURE EMERGENCY PLANNING ZONE, WHICH WOULD HELP US IN OUR REVIEW OF THE PETITION. l 1
IHE BOSTON EDISON COMPANY PROVIDED INFORMATION USED IN RE- j VIEWING THIS PETITION. BOSTON EDISON'S WRITTEN RESPONSE IS ATTACHED AS APPENDIX 5 THE STATE INDICATED THAT IT HAD NO l
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COMMENTS ON THE PETITION. WE UNDERSTAND:THAT.NO~ TRANSCRIPT WAS MADE OF THE MEETING AT THE STATE HOUSE, AND FEMA sAS, THEREFORE, RELIED ON ITS OWN NOTES AND RECOLLECTIONS OF THE MEETING.
IHE ANALYSIS OF THESE ISSUES WAS PREPARED BY FEMA REGION I WITH THE ASSISTANCE OF THE ARGONNE NATIONAL LABORATORY, BASED UPON-ORAL INPUT FROM MASSACHUSETTS'CONCERNING THE CONTENTS OF THE PETITION; PREVIOUS WRITTEN AND ORAL INPUT FROM MASSACHUSETTS CONCERNING THE ISSUES COVERED BY THE PETITION; RESPONSES PREPAR-
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ED BY PLMA TO A PREVIOUS NASSPlKb PETITION; FLhA REVIEWS OF -
THE MASSACHUSETTS RERP; AND OF EXERCISE REPORTS FOR THE EXERCISE OF THE RADIOLOGICAL EMERGENCY RESPONSE PLANS FOR THE PILGRIM-NUCLEAR POWER STATION IN 1982, 1983, AND 1985 ON DECEMBER 30, 1986, FEMA WAS PROVIDED A COPY OF A REPORT CONCERNING THE. MASSA-CHUSETTS PLANS TO PROTECT THE PUBLIC IN THE PILGRIM EPZ~. THE REPORT WAS PREPARED BY THE SECRETARY OF PUBLIC SAFETY AND ENDOR-SED BY MASSACHUSETTS GOVERNOR DUKAKIS (HEREINAFTER CALLED THE BARRY REPORT). IHE BARRY REPORT AND ALL OTHER RELEVANT FACTORS, INCLUDING INPUT FROM PUBLIC MEETINGS IN BOSTON, DUXBURY, AND PLYMOUTH, A MEETING WITH A REPRESENTATIVE 0F THE PLYMOUTH COUNTY 1
NUCLEAR INFORMATION COMMITTEE, INC., AS WELL AS ADDITIONAL ANAL-YSIS BY FEhA STAFF AND CONSULTANTS HAS BEEN SEPARATELY ANALYZED AS PART OF THE ATTACHED REVIEW OF THE MASSACHUSETTS' RAD 10 LOGICAL PLANS FOR PILGRIM WHICH FEMA INITIATED PORSUANT TO 44 CFR 350 I
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SUMMARY
IHE DETAILED ANALYS!$ OF ISSUES RAISED IN THE JULY 15, 1986 PETITION IS PRESENTED IN SECTION ((l. 10ST JF THE lSSUES 0
, RAISED IN THE 1986 PET! TION ARE ESSENTIALLY IDENTICAL ISSUES RAISED IN A PETITION SUBMITTED TO THE NRC IN 1983 8Y MASSPIRG, AND TO ISSUES PREVIOUSLY EXAMINED BY NRC AND FEMA.
BASED ON A PREVIOUS ANALYSIS BY F'MA, t THE NKC DENIED THE 1
1983 MASSPIRG PETITION ON FEBRUARY 27, 1984 FEMA REVIEdED THIS NEW PETITION IN LIGHT OF THE STATE OF THE RECORD AT THE TIME OF ITS SUBMITTAL AND [NFORMATION AVAILABLE i TO EEMA AS OF 'l0VEMBER, 1986 UUR REV!EW WAS LARGELY COMPLETED BY UECEMBER 20, 1986 FEMA DEALT WITH LATER INFORMATION INCLUD-ING FEMA STAFF ANALYSIS OF PUBLIC AND INTERAGENCY MEETINGS, AND THE BARRY. REPORT, IN ITS SELF-!N!TIATED REVIEW. IT SHOULD BE l
NOTED, HOWEVER, THAT, WHILE FEMA'S ANALYSIS OF THE SEVEN AL- {
LEGED DEFICIENCIES IN OFF-SITE EMERGENCY PLANNING INDICATES THAT THE INFORMATION IN THE PETITION DID NOT SUSTAIN THE CON-TENTIONS BASED ON THE STATE OF THE RECORD AT THE TIME THE l
PETITION WAS REVIEWED, FEMA AGREES WITH THE GENERAL THRUST l UF SOME OF THE CONCLUSIONS OF THE PETITION FOR THE REASONS CITED IN ITS SELF-[NITIATED REVIEW AND [NTERIM FINDING DATED 1 JULY 29, 1987 I
IHE FEDERAL EMERGENCY MANAGEMENT AGENCY WILL CONTINUE TO !
REVIEW AND ANALYZE THE STATUS OF EMERGENCY PLANNING IN THE VICINITY OF ALL NUCLEAR POWER PLANTS, INCLUDING PILGRIM, TO INSURE THAT A CORRECT ANALYSIS OF OFF-SITE EMERGENCY PLANNING ]
IS PRESENTED TO THE NUCLEAR REGULATORY COMMISSION.
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k 5-Ill. AN A LYS IS I
FEMA HAS ADDRESSED EACH OF THE SEVEN ISSUES IN OFF-SITE ,
EMERGENCY PLANNING RAISED IN THIS PETITION BELOW.
14/ DEFICIENCIES IN THE RADIOLOGICAL EMERGENCY RESPONSE PL ,
(HERP) $
PETITIONERS: }
l SERIOUS DEFICIENCIES EXIST IN THE RERP FOR P!LGRIM, WARRANT-ING SUSPENSION OF 00STON LD! SON'S OPERATING THELICENSE COMBINEDBY THE NRC. THE DEFICIENCIES ARE OUTLINED BELOW. l EFFECT OF THESE DEFICIENCIES IS TO ABROGATE THE " REASONABLE .
ASSURANCE THAT ADEQUATE PROTECTIVE MEASURES CAN AND WILL BE /
TAKEN IN THE EVENT OF A RADIOLOGICAL EMERGENCY," THE STAND-ARD SET BY 10 CFR 550 47 (A)(1).
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FEMA:
FEMA HAS PROVIDED RESPONSES TO EACH OF THE PETITIONER'S ALLE- !
I GATIONS. THESE RESPONSES ARE GIVEN BELOW. !
q 15,/ DEFICIENCIES IN ADVANCE lNFORMATION A) PETITIONERS: }
IHE ONLY METHOD BEING USED FOR ADVANCE PUBLIC EDUCATION IN THE PILGRIM EMERGENCY PLANNING LONE (LPZ) IS THE DISTRIBU-TlON OF PAMPHLETS BY MAIL. A MASSPlkG TELEPHONE SURVEY CON-i
)
DUCTED IN 1983 REVEALED SERIOUS INADEQUACIES IN'THE DISTRIBU-T10N, RETENTION, AND UNDERSTANDING OF THE PAMPHLETS BY AREA RESIDENTS. NO IMPROVEMENTS IN THE ADVANCE INFORMATION PROCE-DURES HAVE BEEN CARRIED OUT SINCE 1985 FEMA- 1 IHIS ISSUE WAS RAISED PREVIOUSLY IN THE PETITION OF THE MASS-ACHUSETTS PUBLIC INTEREST RESEARCH GROUP'FOR EMERGENCY AND REMEDIAL ACTION FILED BY MASSPIRG WITH THE NRC ON JULY 20, 1983 NO SUBSTANTIVE NEW ISSUES ARE RAISED BY THE CURRENT PETITION. IN RESPONSE TO THE 1983 PETITION (APPENDIX 1)
FEMA STATED:
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IWO PAMPHLETS ENTITLED " EMERGENCY-PUBLIC lNcoo-MATION"-AND " NUCLEAR ENERGY QUESTIONS'AND ANSWERS" l I
WERE MAILED TO ALL RESIDENTS lN THE LPI IN bEPTEMBER 1981 AND SEPTEMBER 1982 IN ADDITION, THE PAMPHLETS dERE DISTRIBUTED TO COMMERCIALLESTABLISHMENTS'AND PUBLIC BUILDINGS IN THE EPl, INCLUDING HOTELS
- 9VER 120,000 0F BOTH BROCHURES HAVE BEEN. DISTRIBUTED IN AN AREA 0F APPROXIMATELY 55,000 POPULATION:AND_20,000 i HOUSEHOLDS. POSTERS DEPICTING EMERGENCY: !NFORMATION- l HAVE BEEN DISPLAYED IN THE EPZ SINCE OCTOBER 1982 i MASSPIRG'S INFORMATION WAS DERIVED FROM A: POLL THAT THEY CONDUCTED OF SOME OF THESE RESIDENTS IN THE' AREA. !
WHEN ASKED IF THEY HAVE RECE!VED EPl BROCHURES, A SUB- I STANTIAL 70% RESPONDED THAT THEY REMEMBERED RECEIVlNG THEM.
MASSP.lRG ALSO REPORTS THAT 9% OF THOSE POLLED SAID THEY WOULD TUNE TO AN Eb8 RADIO STATION AS A FIRST REACTION TO HEARING THE SIRENS, AND AN ADDITIONAL 19%- ,
WOULD TUNE TO RADIO OR IV, BOTH OF WHICH ARE REASON- l ABLE AND APPROPRIATE RESPONSES. MASSPlkG D!D NOT ASK _ )
WHAT PEOPLE WOULD DO UPON SOME REFLECTION AS'THE SIRENS I
CONTINUED TO SOUND. f EACH SIREN HAS A PUBLIC ADDRESS CAPABILITY AND CAN BE USED TO BROADCAST SPECIFIC ~! INSTRUCTIONS TO THE PUBLIC,. ,
INCLUDING TRANSIENTS, IN AN EMERGENCY AND THIS SHOULD 1 BE CONSIDERED TO BE PART OF THE PUBLIC EDUCATION EFFORT.
LOCAL AND STATE PUBLIC SAFETY VEHICLES ALSO ARE EQUIPPED:
WlTH PA CAPABILITY. MESSAGES WILL BE BROADCAST OVER THESE PUBLIC ADDRESS SYSTEMS TO TUNE TO THE EBS STATION FOR INFORMATION. IHIS SHOULD BE SUFFICIENT TO A!D RESI-DENTS AND TRANSIENTS IN AN EMERGENCY.
FEMA DETERM!NED IN 1983 THAT THE PETITION DID NOT INDICATE 1
THAT THE COMMONWEALTH WAS UNABLE TO PROTECT THE HEALTH AND )
SAFETY OF THE PUBLIC. IHE MASSPIRG PETITION WAS DENIED BY THE NRC,1N THE "lNTERIM DIRECTOR'S DECISION UNDER 10 CFR 2 206", FEBRUARY 27, 1984 HOWEVER, SINCE THAT T!ME THE COMMONWEALTH HAS TAKEN ADDITIONAL STEPS TO ENHANCE ITS PUBLIC ;
INFORMATION PROGRAM.
ACCORDING TO INFORMATION PROVIDED BY MCDA AND THE BOSTON
-__-______-_______a
I l . .
I 7-EDISON COMPANY, THE ANNUAL PUBLIC EDUCATION BROCHURE ENTI-TLED " EMERGENCY PUBLIC INFORMATION: WHAT TO 00 IN CASE OF' 1 AN EMERGENCY AT PILGRIM NUCLEAR POWER STATION" (APPENDIX WAS MAILED TO RESIDENTS, HOTELS AND MOTELS, AND PUBLIC BUILD-l INGS IN THE PLUME EXPOSURE EMERGENCY PLANNING ZONE (hPI l
AUGUST 1986 (SEE APPENDIX 5). BROCHURES WERE ALSO MAILED l TO RESIDENTS IN 1985 THE 1986 BROCHURE !$ IN COMPLIANCE l WITH THE GUIDANCE PROVIDED IN NUREG-Ubb4, FEMA-KEP-1, KEV 1, "lRITERIA FOR PREPARATION AND LVALUATION OF KAD10 LOGICAL LMERGENCY HESPONSE PLANS AND PREPAREDNESS IN SUPPORT OF:
NUCLEAR F0WER FLANTS." IHE CURRENT BRUCHURE CONTA!NS THE FOLLOWING INFORMATION:
- EDUCATIONAL INFORMATION ON RADIATION)
- DESIGNATION OF RADIO STATIONS FOR EMERGENCY PUBLIC INFORMATION)
SHELTERING, RESPIRATORY PROTECTIVE MEASURES (1.E.,
PROTECTION, EVACUATION ROUTES, AND RECEPTION CENTERS);
AND A RETURN POSTCARD AND INSTRUCTIONS FOR PERSONS WITH SPECIAL NEEDS SO THAT ARRANGEMENTS CAN BE MADE TO PROVIDE APPROPRIATE TRANSPORTATION IN THE EVENT OF AN EVACUATION.
FEMA SPONSORED A STATISTICALLY VAllD SURVEY AFTER THE SEPTEM-BER 29, 1986 TEST OF THE PILGRIM PUBLIC ALERT AND NOTIFICA-TION SYSTEM. IHE SURVEY INDICATED THAT 72 8% OF THE PEOPLE REMEMBER RECEIVING THE PUBLIC INFORMATION BROCHURE.
FEMA, THEREFORE, CONCLUDES THAT THE PETITION DOES NOT PROVIDE INFORMATION WHICH SUSTAINS THE CONTENTIONS.
F m B) PETITIONERS:
IHE CURRENT (SEPTEMBER 1985) PAMPHLETS CON'iAIN NO INFORMA-T10N REGARDING PUBLIC TRANSPORTATION FOR PURPOSES OF EVACUA-T10N, DESPITE THE FACT THAT THE RADIOLOGICAL EMERGENCY $E-SPONSE PLAN (RERP) FOR THE IOWN OF PLYMOUTH PROVIDES FOR THIRTEEN " STAGING AREAS" WHERE PERSONS WITHOUT TRANSPORT-ATION WILL BE DIRECTED FOR "POSSIBLE" PUBLIC TRANSPORT.
FEMA:
IHIS ISSUE WAS RAISED PREVIOUSLY IN THE " PETITION OF THE MASS-ACHUSETTS PUBLIC INTEREST RESEARCH 6ROUP FOR bMERGENCY AND REMEDIAL ACTION" FILED BY MASSPlKb WITH THE NKC ON JULY 20, 1983 NO SUBSTANTIVE NEW ISSUES ARE RAISED IN THE CURRENT
! PETITION.
IHE COMMONWEALTH STATED IN ITS RESPONSE TO THE 1985 PETITION:
(APPENDIX 3)
LOCAL PLANS UTILIZE LISTINGS OF POST OFFICES, FIRE l
HOUSES, SCHOOLS AND OTHER WELL KNOWN, RECOGNIZABLE SITES FOR ' STAGING AREAS.' ALTHOUGH LOCAL RESIDENTS '
ARE WELL AWARE OF THESE SITES, WE ARE STUDYING THE l USE OF MAPS AND MAY INCLUDE THEM IN FUTURE PUBLICA-T!ONS.
l FEMA STATED IN ITS RESPONSE TO THE 1983 PETITION: (APPENDIX 1)
PUBLiC TRANSPORTATION - IHE LACK OF PROVISIONS IN THE PLANS FOR TRANSPORTATION OF THOSE WHO MAY NOT HAVE ACCESS TO CAR $ WAS PREVIOUSLY NOTED AS A DE-FICIENCY AND THE STATE IS REVISING THE PLANS ACCORD-INGLY. NO REQUESTS FOR SPECIAL TRANSPORTATION HAVE, '
TO DATE, BEEN REGISTERED WITH PLYMOUTH CIVIL DEFENSE, '
ALTHOUGH SUCH INFORMATION HAS BEEN SOLICITED.
IHE 1986 PUBLIC INFORMATION BROCHURES DIRECT PERSONS IN NEED OF TRANSPORTATION OR OTHER SPECIAL HELP TO RETURN THE I
POSTCARD FOUND IN THE BROCHURE TO MCDA AREA 11 HEADQUARTERS OR TO CALL THEIR TOWN HALL OR CIVIL DEFENSE OFFICE AS SOON AS POSSIBLE TO ARRANGE FOR ASS! STANCE BEFORE AN EMERGENCY.
- _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ - _ _ _ - _ . .__ .u
-g-
{F PEOPLE NEED ASSISTANCE DURING AN EMERGENCY, THEY ARE TO THE LOCAL PLANS SPECIFY CALL THE LOCAL CIVIL DEFENSE OFFICE.
THAT CONTRACTOR SCHOOL BUSES MAY BE USED TO MOVE THO
[F NEEDED, ADDITIONAL BUSES l PERSONAL MEANS OF TRANSPORTATION.
(OR OTHER MEANS OF MASS TRANSPORT) WILL BE REQUESTED THR HEAD-THE MASSACHUSETTS CIVIL DEFENSE AGENCY (MCDA) AREA QUARTERS. THE COMMONWEALTH OF dlASSACHUSETTS HAS IDENTIFIED IN ITS bTATE C
LAN A VAST NUMBER OF STATE CONTROLLED RES.0VRCES AVA!LABLE lN THE EVENT OF AN ACCIDENT AT PILGRIM.
PREDETERMINED STAGING AREAS FOR BUSES WILL BE ACT!VATED SITES SPECIFIED BY THE DIRECTOR OF CIVIL DEFENSE (CD) A SITUATION REQUIRES. PLYMOUTH HAS IDENTIFIED 13 STAGING AREAS WHERE THOSE PEOPLE IN NEED OF TRANSPORTATION WOULD G IF AN EVACUATION WERE TO OBTAIN PUBLIC TRANSPORTATION. i j
ORDERED, PEOPLE WOULD BE ADVISED TO STAY TUNED TO RADIO AND IHE PLYMOUTH IV FOR INFORMATION REGARDING THE EVACUATION.
Civ!L DEFENSE DIRECTOR IS RESPONSIBLE FOR COORDINATING W!
MCDA AREA II HEADQUARTERS TO ASSURE THAT INFORMATION REG IN NEED OF TRANSPORTA-ING THE ARRANGEMENTS FOR THOSE PEOPLE TION ARE CONTAINED IN EBS MESSAGES.
FEMA, THEREFORE, CONCLUDES THAT THE PETITION DOES NOT PRO-VIDE INFORMATION WHICH SUSTAINS THE CONTENTION.
l l
(
i 10 -
C) PETITIONERS:
THE ADVANCE INFORMATION SYSTEM FOR TOURISTSFOR AND OTHER NO EXAMPLE, TRANSIENTS IS INADE00 ATE OR NONEXISTENT.
SIGNS HAVE BEEN POSTED TO PROVIDE APPROPRIATE INFORMAil0N FOR TRANS!ENTS, A MEASURE SUGGESTED BY THE NKL IN 10 lbK j PART 50, APPENDlX E. [V.O.2 FEMA: I IHIS ISSUE WAS RAISED PREVIOUSLY IN THE " PETITION OF THE l MASSACHUSETTS PuBLIC INTEREST RESEARCH 6ROUP FOR EMERGENCY
> AND REMEDIAL ACTION" FILED BY MASSPIRG WITH THE NRC ON Jy,y 20, 1983 NO SUBSTANTIVE NEW ISSUES ARE RAISED IN THE CURRENT PETITION. 1 IHE COMMONWEALTH STATED IN ITS RESPONSE TO THE 1983 PETITION:
(APPEND!x 3)
POSTERS HAVE BEEN DISTRIBUTED, AND ARE AVAILABLE THROUGHOUT THE tPL. lHE LPI PAMPHLETS INCLUDE RE-MOVABLE EMERGENCY PUBLIC INFORMATION STICKERS AND HAVE ALSO BEEN DISTRIBUTED (SEE ENCLOSED). IHE SIREN SYSTEM INSTALLED THROUGHOUT THE EPl IS EQUIPPED WITH PUBLIC ADDRESS CAPABILITY WHICH WOULD BE USED TG PROVIDE TRANSIENTS WITH EMERGENCY INFORMATION. LOCAL AND STATE PUBLIC SAFETY VEHICLES ARE ALSO EQUIPPED l WITH PA CAPABILITY.
FEMA'S RESPONSE TO THE 1983 PETITION (APPENDIX 1) STATED:
IWO PAMPHLETS ENTITLED " EMERGENCY PuBLIC INFORMATION" AND " NUCLEAR ENERGY OUESTIONS AND ANSWERS" WERE MAILED TO ALL RESIDENTS IN THE EPZ IN SEPTEMBER 1981 AND SEP-TEMBER 1982 IN ADDITION, THE PAMPHLETS WERE DISTRIB-UTED TO COMMERCIAL ESTABLISHMENTS AND PUBLIC BUILDINGS IN THE EPZ, INCLUDING HOTELS. OvER 120,000 0F BOTH BROCHURES HAVE BEEN DISTRIBUTED IN AN AREA 0F APPROX-IMATELY 55,000 POPULATION AND 20,000 HOUSEHOLDS.
POSTERS DEPICTING EMERGENCY INFORMATION HAVE BEEN DIS-PLAYED IN THE EPl SINCE OCTOBER 1982 ACCORDING TO INFORMATION PRESENTED TO FEMA BY BOSTON LDISON, 9
__________2 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ - _ - _ _ _ _ _ _ _ _
o e i
11 -
WHO DISTRIBUTE Tmi BROCHURES F O R ' T H E I'l A S S A C H U S E T T S _ 'L I V I L DEFENSE AGENCY, dMERGENCY PUBLIC INFORMATION BROCHURES dERE RECENTLY DISTRIBUTED TO HOTELS AND MOTELS, LIBRARIES, AND TOWN.0FFICES IN THE AREA, AND PLACARDS WERE POSTED.AT VARIOUS LOCATIONS THROUGHOUT THE LPl (SEE LETTER FROM BOSTON EDISON, DATED OCTOBER 29, 198b, APPENDIX 5). !
i FEMA, THEREFORE, CONCLUDES THAT THE PETITION DOES NOT PROVIDE INFORMATION WHICH SUSTAINS THE CONTENTION.
l I D) PETITIONERS: j 1
IHE INADEQUATE ADVANCE INFORMATION SYSTEM VIOLATES 10 CFR 550 47 (B)(7); 10 CFR PART 50, APPENDIX E. IV U.2, AND EVALUATION CRITERIA G.1, G.2 AND P. 10 0F NUREG-0654 FEMA:
FEMA HAS RESPONDED TO THIS ISSUE IN ITEMS A, B, AND C ABOVE.
Ib/ DEFICIENCIES IN NOTIFICATION UURING AN ACCIDENT A) PETITIONERS:
IHE WARNING S!REN SYSTEM AND BACK-UP SYSTEMS ARE INADE-QUATE TO ESSENTIALLY COMPLETE THE INITIAL NOTIFICATION OF THE PUBLIC WITHIN THE PLUME EXPOSURE PATHWAY OF THE EMER-GENCY PLANNING LONE (LFl) WITHIN FIFTEEN MINUTES, AS REQUIRED BY 10 CFR PART 50, APPENDIX E., IV. D.3 FOR EXAMPLE, THE SIREN SYSTEM HAS BEEN PLAGUED WITH FALSE ALARMS. RATHER THAN CORRECT THIS PROBLEM, THE RESPONSE HAS BEEN TO Dl'JONNECT THE SIREN SYSTEM DURING ELECTRICAL STORMS.
1
.. , . 1 12 - )
i FthA:
~f IHIS ISSUE WAS RAISED PREVIOUSLY IN THE " PETITION OF THE j$
MASSACHUSETTS PUBLIC INTEREST KESEARCH GROUP FOR EMERGENCY k
AND REMEDIAL' ACTION" F.lLED BY MASSPIRG WITH THE-NRC ON l l
JULY 20, 1983 NO NEW SUBSTANTIVE ISSUES ARE RAISED IN THE. i CURRENT PETITION.
4 WHILE THE ALERT AND NOT!FICATION SYSTEM-EXPERIENCED. FALSE !
ALARMS FOR SOME TIME AFTER ITS INSTALLATION, BOSTON EDISON 'I EXAMINED THE PROBLEM AND MADE IMPROVEMENTS IN THE SYSTEM.
FEMA'S REVIEW OF THE SIREN TEST RESULTS, THE ALERT AND NOTIF- b r
ICATION SYSTEM DESIGN AND OPERATIONAL RECORDS PROVIDED BY BOSTON 'tDISON COMPANY INDICATES THAT THIS PROBLEM DOES NOT NOW EXIST. (ALSO SEE APPENDIX 5, PAGE 8, ET.. SEQ.)
l FthA, THEREFORE, CONCLUDES THAT THE PETITION DOES NOT PROVIDE INFORMATION WHICH SUSTAINS THE CONTENTION.
B) PETITIONERS:
IHE SIRENS ARE INAUDIBLE OR BARELY AUDIBLE WITH!N LARGE AREAS OF THE EPZ (REPORT ON THE PILGRIM NUCLEAR POWER STATION SIREN IEST, JUNE 19, 1982, FEMA, JANUARY 1985, P.6).
FURTHERMORE, F REGULATIONS REQUIRE NOTIFICATION OF OF THE POPULATION (CRITERIA J 10.C, E.6; "ALL SEGMENTS,EDERAL 10 CFR PART 50, APPEND!x E, IV. D.3).
l FEMA: l
. IHIS ISSUE WAS RAISED PREVIOUSLY IN THE " PETITION OF THE MASSACHUSETTS PuBLIC INTEREST RESEARCH GROUP FOR EMERGENCY f
AND REMEDIAL ACTION" FILED BY MASSPIRG WITH THE NRC ON JULY 20, 1983 NO SUBSTANTIVE NEW ISSUES ARE RAISED IN'THE CURRENT PETITION.
1
13 - u 1
FEMA STATED IN ITS RESPONSE TO THE 1983 PETITION (APPENDIX 'l) 4 MASSPIRG SEEMS TO HAVE 'ilSUNDERSTCOD THE REPORT ON THE " PILGRIM NUCLEAR POWER STATION S!REN KESPONSE 'l EXERCISE FOR THE PILGRIM NUCLEAR POWER STATION, MARCH 3, 1982." THE FIXED SIREN SYSTEM WAS DESIGNED l
TO BE USED IN CONJUNCTION WITH OTHER METHODS OF NOTIFICATION SUCH AS MOBILE NOTIFYING'TEAMG,. TONE H
ALERT RADIOS, AND THE ESS. FEMA IS CURRENTLY DE- '
VELOPING STANDARDS FOR MEASURING THE EFFECTIVENESS 0F FIXED SIRENS. HOW EVE R , THE 1982 SIREN TEST ,
DEMONSTRATED AN IMPRESSIVE ABILITY TO. NOTIFY THE PUBLIC USING SIRENS ALONE* IN OUR OPINION, THE j l
TEST ALSO DEMONSTRATED A CONTINUING.NEED FOR THE OTHER FORMS OF PUBLIC NOTIFICATION THAT ARE PRES
- ENTLY INCLUDED IN THE PLANS.
FEMA'S REPORT ON THE PILGRIM NUCLEAR POWER STATION SIREN f IEST DID NOT STATE THAT THE SIRENS WERE INAUDIBLE OR BARELY AUDIBLE WITHIN LARGE AREAS OF THE EPl. PAGE 6 0F THE REPORT, WHICH THE THE PETITIONERS REFERENCE, DISCUSSES WHERE. FEMA OBSERVERS WERE LOCATED DURING THE TEST. FEMA STATED ELSEWHERE j IN THE REPORT THAT WE CHOSE TO LOCATE THE 18 OBSERVERS IN THOSE FEW AREAS WHERE SIREN OUTPUTS WOULD BE THE WEAKEST.
IHEREFORE, WE CONCLUDED THAT THE OBSERVERS' REPORTS SHOULD NOT BE TAKEN AS AN INDICATION OF WIDESPREAD PROBLEMS. .lT IS WORTH NOTING THAT FEMA SPONSORED A TELEPHONE SURVEY IMMEDIATELY FOLLOWING A SEPTEMBER 29, 1986 TEST OF THE PILGRIM ALERT AND NOTIFICATION SYSTEM WHICH INDICATED THAT 88 2% OF THE PEOPLE WERE DIRECTLY ALERTED BY THE SIRENS ON THE DAY OF THE TEST.
FthA, THEREFORE, CCNCLUDES THAT THE PETITION DOES NOT PRO- ,
VIDE INFORMATION WHICH SUSTAINS THE CONTENTION.
14 -
C) PETITIONERS:
IHE DEFICIENT SIREN SYSTEM WOULD FAIL 1TO WARN THE HEARING IMPAIREC; TESTlMONY AT THE JUNE 18, 198b HEARING ON THE P!LGRIM KERP BEFORE MASSACHUSETTS LEGISLATORS PROVIDED NO EVIDENCE OF THE EXISTENCE OF AN ALTERNATE PLAN FOR NOTIFI-CATION OF THIS SEGMENT OF THE POPULATION, A DIRECT vlOLA-T10N OF THIS STATUTORY MANDATE.
FEMA:
IHis ISSUE WAS RAISED PREVIOUSLY IN THE " PETITION OF THE MASSACHUSETTS PUBLIC INTEREST GROUP FOR EMERGENCY AND REME-DIAL ACTION" FILED BY MASSPIRG WITH THE NRC ON JULY 20, 1983 NO SUBSTANTIVE NEW ISSUES WERE RAISED IN THE CURRENT PETITION.
IN ITS RESPONSE TO THE 1983 MASSPIRG' PETITION (APPENDtx'3),
THE COMMONWEALTH OF MASSACHUSETTS STATED:
MCDA AND BOSTON EDISON HAVE WORKED'WITH THE MASSA-CHUSETTS UFFICE FOR THE UEAF (MUD) AND THE DEAF LOM-MUNITY CENTER IN FRAMINGHAM, MA IN ORDER TO ADDRESS THIS PROBLEM. BOSTON EDISON OFFERED TO EQUIP HOUSE-HOLDS OF DEAF PEOPLE LIVING ALONE IN THE EPl WITH TELE-TYPEWRITER DEVICES FOR THEIR TELEPHONE. THIS DEVICE IS WIDELY ACCEPTED AS ADEQUATE COMMUNICATIONS FOR SERVING A DEAF PERSON DURING AN EMERGENCY. NEWS-LETTERS FOR THE DEAF CARRIED NOTIFICATION OF THIS PROGRAM. NO SUCH HOUSEHOLDS HAVE BEEN IDENTIFIED IN THE P!LGRIM EPZ.
FEMA STATED IN ITS NOVEMBER 3, 1983 ANALYSIS OF.THE 1983 MASSPIRG PETITION (APPENDIX 1).
THE COMMONWEALTH OF MASSACHUSETTS AND BOSTON EDISON HAVE WORKED WITH THE MASSACHUSETTS OFFICE'0F THE DEAF, THE COUNCIL OF ELDER AFFAIRS AND THE DEAF COMMUNITY CENTER IN FRAMINGHAM IN AN ATTEMPT TO IDENTIFY DEAF RESIDENTS WITHIN THE EPZ. THEY HAVE ALSO ATTEMPTED TO NOTIFY DEAF PEOPLE WITHIN THE EPZ THROUGH NEWSLETTERS ABOUT EFFORTS TO PROVIDE
l 15 -
1 DEAF RESIDENTS OF THE EPZ WITH TELETYPEWRITER.(TTY) I DEv!CES. NO SUCH HOUSEHOLD 3 HAVE BEEN IDENTIFIED BY THESE EFFORTS. IHIS M A'. BE BECAUSE MOST INDIVID-UALS WITH SPECIAL NEEDS LIVE WITH SOMEONE.AND CAN RELY ON OTHER MEMBERS OF THE HOUSEHOLD IN TIMES OF EMERGENCY. ALSO, DEAF PEOPLE AND OTHER. INDIVIDUALS WITH SPECIAL NEEDS TEND TO CONGREGATE IN URBANIZED AREAS WHERE THEY CAN RECEIVE SERVICES READILY AND THE PILGRIM EPZ IS NOT URBANIZED. .
1' CONFIDENTIAL LISTS IDENTIFYING THE DEAF ARE BELIEVED TO EXIST. IN A MEETING ON AUGUST 19,'1983 wlTH MASSPIRG, THE MASSACHUSETTS SECRETARY OF PUBLIC' -1 i
SAFETY AGREED TO DO RESEARCH ON EXISTING LAWS TO SEE 1F THIS INFORMATION COULD LEGALLY.BE MADE AVAIL-ABLE TO THE MCUA FOR PLANNING PURPOSES. THE COMMON-WEALTH AND UTILITY HAVE ASSURED FthM THAT THEY WILL CONTINUE THEIR OUTREACH AND WILL PROVIDE TTY DEVICES TO ANY PROFOUNDLY DEAF PERSON IN THE LPI WHO REQUESTS ONE.
i InE EFFORT TO IDENTIFY HEARING IMPAIRED PEOPLE WHO MAY REQUIRE TTY DEVICES CONTINUES THROUGH ANNUAL EMERGENCY PUBLIC INFOR-MATION (EPI) BROCHURES MAILED TO ALL HOMES WsTHIN THE 10-MILE EPZ. AS NOTED EARLIER, THESE BROCHURES CONTAIN A POSTCARD TO BE USED BY SPECIAL NEEDS INDIVIDUALS APPRIS!NG LOCAL OFFICIALS OF THE INDIVIDUAL 5 SPECIAL NEED. dOSTON EDISON RECENTLY SENT A LETTER TO THE MASSACHUSETTS COMMISSION POR UEAF AND HARD OF HEARING TO REQUEST THEIR AlD IN IDENTIFYING INDIVIDUALS LIVING IN THE PILGR!M EPZ, WHO MAY NEED TTY i
DEVICES (SEE BOSTON EDISON LETTER - APPENDIX b).
MCUA AND BOSTON EDISON INFORMED US THAT AS OF OCTOBER 1986, i NO HOUSEHOLDS CONTAINING A DEAF PERSON HAVE BEEN IDENTIFIED.
l i
15 - .l l
1 i
FEMA, THEREFORE, CONCLUDES THAT THE PETITION DOES NOT 290-VIDE NFORMATION WHICH SUSTAINS THE CONTENTION..
D) PETITIONERS: 1 j
[N TESTIMONY BEFORE MASSACHUSETTS 3 TATE LEG I S L A T O R S ON '
l JUNE 18, 1986, EDWARD A. IHOMAS, d! VISION CHIEF, NATURAL
' & TECHNOLOGICAL HAZARDS, FEMA, STATED THAT BOSTON EDISON HAD FAILED REPEATEDLY TO DELIVER TO PtMA NECESSARY TECH-MR. IHOMAS' NICAL SPECIFICATIONS ON THE SIREN' SYSTEM.
ADDED THAT THESE DELAYS BY'bbCO HAVE FORCED' REPEATED POSTPONEMENTS 0F THE FULL
- SCALE SYSTEM TEST REQUIRED BY-FEMA.
FEhA:
nHILE BOSTON EDISON DID NOT SUBMIT THE NECESSARY TECHNICAL INFORMATION WHEN SCHEDULED, THE COMMONWEALTH OF MASSACHUSETTS-FORWARDED TO FEMA THE " FEMA-43 REPORT, Pust!C ALERT AND NOTIFICATION 3YSTEM FOR THE PILGRIM NUCLEAR POWER STATION" ON JUNE 20, 1985 ADDITIONAL INFORMATION WAS REQUESTED AND PROVIDED TO FEMA BY 80STON EDISON ON JUNE 23, 1986 THE I
l ADDITIONAL INFORMATION WAS ANALYZED AND FOUND TO'BE IN SUFFICIENT COMPLIANCE WITH THE REQUIREMENTS OF FEMA-43 TO ENABLE FEMA TO CONDUCT A TEST OF THE PILGRIM 31REN SYSTEM ON bEPTEMBER 29, 1986 THIS TEST INDICATED THAT 88 2% OF ,
THE PEOPLE WERE DIRECTLY ALERTED BY THE SIRENS ON THE DAY ,
OF THE TEST.
FEMA, THEREFORE, CONCLUDES THAT THE PETITION DOES NOT PROVIDE INFORMATION WHICH SUSTAINS THE CONTENTION.
I l'
A 17 - 1 17/ DEFit!?NCIES IN EVACUATION PLANS A) PETITIONERS: ,
INE EVACUATION TIME. ESTIMATES FOR THE PILGRIM EP2 ARE
- y UNREALISTICALLY LOWS IHEY FAIL TO TAKE INTO ACCOUNT m:0 THE PROBABIL]TY OF SOME PANIC, TRAFFIC DISORDER, TRAFFIC OBSTACLES OUTSIDE.THE EPZ AND THE FACT THAT THOUSANDS OF ; o PEOPLE OUTSIDE: DESIGNATED EVACUATION ZONES WILL ALSO EVACUATE. ACCORBlNG TO TESTIMONY BEFORE MASSACHUSETTS LEGISLATORS ON JUNE zl3,1986, BY EDWARD A. THOMAS,-OlVISION CHIEF, NATURAL'& IECN0 LOGICAL HAZARDS, FEMAerTHE " REASONABLE ASSURANCE" ADEQUACY OF THE CURRENT PLAN l$ SASED ON THE ASSUMPTION THAT COMMUNITIES OUTSIDE OF THE TEN MILE L?l HAVE DEVELOPED PLANS TO AUGMENT EVA WHEN ASKED, ?tR. LUBERING,{UATIONANDSHELTERING SICl DEPUTY DIRECTOR!
EFFORTS.
0F THE ' MASSACHUSETTS LIVIL UEFENSE nGENCY ( FlL U A )#, STATED URTHER-THAT HE MAD NO EVIDENCE THAT SUCH PLANS EXIST.
MORC. EVACUAT13N TIME EST! MATES ARE NOT PROV'!DED FOR.
VARIOUS ADVERSE dEATHER SCENARIOS.
FEMA:
l IHE CURRENT EVACUATION TIME ESTIMATES ARE BASED ON A'SEPTEM-BER, 1980, STUDY CONDUCTED.BY HMM ASSOCIATES, INC% 4HICH WAS u
l'
]
UPDATED IN AUGUST, 1981 IHERE WERE ALSO SUPPLEMENTAL STUDIES ADDRESSING TRAFFIC CONGESTION PROBLEMS OUTSIDE OF THE'EPZ IN THE VICINITY OF BUZZARDS 3AY AND THE SAGAMORE 3 RIDGE.'AND PRO-JECTING THE IMPACT OF FUTURE POPULATION GROWTH.
IHESE STUDIES WERE EXTENSlVELY REVIEWED BY THE NRC AND FEMA AS PREV!OUSLY BOSTON EDISON HAS RECENTLY CONTRACTED 0 MENTIONED IN THIS REPORT.
TO UPDATE THE EVACUATION TIME ESTIMATE FOR THE PILGRIM NUCLEAR POWER STAY 10W. IHE PETITIONERS RAISE FIVE SEPARATE ISSUES WITH RESPECT TO EVACUATION WHICH WE HAVE ADDRESSED BELOW:
A) WANIC -
PANIC, AS ACCEPTED BY MOST DISASTER RESEARCH PROFESSIONALS, WAS DEFINED BY ENRICO L. QUARANTELLI TO MEAN PEOPLE RUNNING FROM AN ASSUMED THREAT OF DANGER, NOT Jb T A q.
4 . d '
18 -
HEIGHTENED SENSE OF ANX1ETY 1. PANIC ALSO CONNOTES.A SUDDEN .
OVERWHELMING FEAR THAT P R O D L ,3 HYSTERICAL'3R IRRATIONAL BEHAVIOR THAT CAN SPREAD-QUICKLY THROUGH A GROUP 0F' PEOPLE.
RESEARCH BASED ON ACTUAL DISASTERS-HAS REVEALED THAT THE SPECTER OF WILD OR 1RRAT10NAL FLIGHT IN THE' FACE OF GREAT PEOPLE WILL THREAT OR DANGER IS NOT BORNE OUT IN'REAL'ITY.
'l OFTEN STAY IN A THREATENING SITUATION RATHER THAN' MOVE OUT' 0F IT. RUSSEL DYNES AND OTHER RESEAR'CHERS 2'HAVE' COMMENTED THAT THERE IS NO REASON TO EXPECT THAT' PEOPLE WOULD REACT-ANY DIFFERENTLY BECAUSE OF A RADlATION THREAT FROM AN EMER-GENCY AT A NUCLEAR POWER PLANT THAN THEY WOULD1TO ANY OTHER~
DISASTER. THEY HAVE ALSO EMPHASIZED THA A KEY TO THE MAN-AGEMENT OF PEOPLE IN DANGER IS THE ABILITY FOR OFFICIALS TO J l
, PROVIDE CLEAR INSTRUCTIONS AND INFORMATION THAT WILL ADDRESS 1 PUBLIC FEARS AND MINIMlZE CURIOSITY THAT COULD ATTRACT ON- >
LOOKERS WHO MIGHT INHIBIT OR INTERFERE WITH MEASURES TAKEN 2
TO PROTECT THE PUBLIC !N DANGER.
l B) TRAFFIC DISORDERS DISASTER RESEARCH LITERATURE HAS.
GENERALLY SHOWN THAT DURING A DISASTER PEOPLE drive SAFELY AND DO NOT EXHIBIT ERRATIC DRIVING BEHAV10R3,4. [s ADDITION, THE COMMONWEALTH OF-MASSACHUSETTS HAS DEMONSTRATED THE ABILITY l
TO DEAL WITH TRAFFIC DISORDERS IN NUMEROUS EXERCISES AND REAL LIFE SITUATIONS.
i I
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C) IRAFFIC OBSTACLES OUTSIDE THE LPl IHIS ISSUE WAS RAISED BY THE NUCLEAR KEGULATORY' COMMISSION AND WAS EXTENSIVELY.RE-VIEWED BY f i h 4 I N 'A REPORT DATED NAY 1, 1984 (APPENDIX 2). l IN BRIEF, OUR MAY 1,'1984 REPORT INDICATES THE TWO AREAS WHICH-MIGHT PRESENT OBSTRUCTIONS TO EVACUATING-TRAFFIC 0UTSIDE OF THE EPZ ARE THE ROUTE 128, ROUTE 3 (SOUTH) INTERCHANGE AND THE SAGAMORE BRIDGE ROTARY. FEMA'S ANALYSIS' INDICATED THAT THE COMMONWEALTH OF MASSACHUSETTS HAS UTILIZED-THE IN-FORMATION DEVELOPED BY BOSTON EDISON AND ISSUES IDENTIFIED BY NRC TO DEVELOP AN ADEQUATE TRAFFIC MANAGEMENT PLAN. IHIS PLAN IS ENTITLED " MASSACHUSETTS STATE POLICE IR00P'U HEAD-QUARTERS, MIDDLEBOROUGH, MASSACHUSETTS, HIGHWAY IRAFFIC CONTROL AND PLAN FOR AN EMERGENCY CONDITION AT PILGRIM l NPS." IHE PLAN CALLS FOR CONTROL OF TRAFFIC AT THE SAGAMORE BRIDGE AND SEVERAL MILES TO THE WEST TO EXPEDITE THE FLOW.0F TRAFFIC OUT OF THE EPl. IRAFFIC FROM CAPE COD WOULD'BE RE-ROUTED TO THE BOURNE BRIDGE. .
J i
IN THE MOST SEVERE CASE MASSACHUSETTS PLANS.TO CLOSE ROUTE i
3 SOUTH AT ITS INTERSECTION WITH ROUTE 128 IN OTHER CASES THEY WILL CLOSE ROUTE 3 SOUTH AT ROUTE 18 WHICH IS 4 MILES SOUTH OF THE 128/3 INTERCHANGE.
D) SHADOW EVACUATION -
IHE MAIN EVACUATION ROUTES OUT OF THE PILGRIM EPZ ARE ROUTE 3 NORTHj ROUTH 3A NORTH; ROUTE 3 S0uTH; ROUTE 3A SOUTHJ ROUTE 6/28 WEST) ROUTE 44 WEST) ROUTE 58 l NORTH; ROUTE 58 SOUTHj ROUTE 108 WEST AND ROUTE 49b WEST.
i
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lHERE ARE' ADDITIONAL SECONDARY ROADS OUT OF THE'CPZ 4HICH WOULD.ALSO BE UTILIZED DURING AN EVACUATION. IHE STATE i l
'l POL' ICE HAVE DEVELOPED A DETAILED TRAFFIC MANAGEMENT PLAN FOR' l
THE PILGRIM EPZ SO AS TO EXPEDITE TRAFFIC MOVEMENTf0VT OF THE EPZ IN THE EVENT OF AN ACCIDENT AT THE PILGRIM ~ NUCLEAR POWER STATION. IHEY WILL BE ASSISTED,BY THE MASSACHUSETTS DEPARTMENT OF PUBLIC WORKS.
' i E) ADVERSE WEATHER
- IHE AUGUST 19, 1981 UPDATE OF THE PIL-1 l
1 3 RIM $VACUATION IIME ESTIMATES PROVIDED AN ESTIMATE FOR AN ADVERSE WEATHER CONDITION WHICH WAS INCLUDED IN THE AREA'l}'
l hlDA PLAN. THE EVACUATION TIME ESTIMATE UPDATE FOR P!LGRIM WHICH IS NOW BEING PERFORMED FOR BOSTON EDISON WILL ADDRESS ADVERSE WEATHER SCENARIOS IN MORE DETAIL.
CONCERNING THE REMARKS ATTRIBUTED TO EDWARD A. IHOMAS, THE THRUST OF SlR. IHOMAS'S COMMENTS WERE THAT: (A) FEMA AND THE COMMONWEALTH OF MASSACHUSETTS SUPPORT THE DEVELOPMENT-0F COMPREHENSIVE PLANS TO DEAL WITH A WIDE VARIETY OF EMER-GENCIES; (B) LOCAL' GOVERNMENTS HAVE THE OPTION OF DETER-MINING WHICH PARTICULAR HAZARDS WILL BE SPECIFICALLY IDEN-TIFIED.IN THEIR PLANSJ-(C) AND THAT LOCAL EMERGENCY PLANS CAN BE AND HAVE BEEN USED TO SUCCESSFULLY PROTECT THE PUBLIC i
FROM HAZARDS NOT SPECIFICALLY RECOGN! ZED IN THE EMERGENCY PLANS. MR. IHOMAS POINTED OUT THREE EXAMPLES OF THE USE r
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l 1
1 21 - )
)
0F EMERGENCY DLANS DESIGNED FOR ONE mAZARD TO PROTECT THE !
1 PUBLIC FROM ANOTHER HAZARD:
A. SUCCESSFUL USE OF CRISIS RELOCATION PLANS TO MOVE APPROXIMATELY 250,000 PEOPLE FROM THE I PATH OF HURRICANE FREDERICK IN 1979 l
- b. bUCCESSFUL USE BY STATE AND LOCAL GOVERN-MENTS OF RADIOLOGICAL EMERGENCY RESPONSE PLANS AND EQUlPMENT TO PROTECT THE PUBLIC IN A SF.CTION OF CONNECTICUT DEVASTATED BY SUDDEN AND CATASTROPHIC FLOODS IN 1982 j C. SUCCESSFUL USE OF LOCAL RADIOLOGICAL EMER-GENCY RESPONSE PLANS AND EQUIPMENT TO PROTECT THE PUBLIC FROM A T0XIC RELEASE OF CHEMICALS FROM A CHEMICAL MANUFACTURER LOCATED NEAR THE WATERFORD NUCLEAR POWER PLANT IN L0ulSIANA.
IHEREFORE, MR. IHOMAS CONCLUDED, THAT IN CONSIDERING WHETHER OR NOT A LARGER EMERGENCY PLANNING 20NE WAS REQUIRED TO PROTECT THE PUBLIC ON LAPE LOD OR IN OTHER AREAS OUTSIDE THE CURRENT EMERGENCY PLANNING CONE FOR P!LGRIM ESTABLISHED j BY THE COMMONWEALTH OF PI A S S A C H U S E T T S , THE LEGISLATURE MAY
- ANT TO CONSIDER FUNDING THE COMPREHENS!VE IMPROVEMENT OF EMERGENCY PLANS FOR THE AREA TO DEAL WITH ALL HAZARDS IN-CLUDING THOSE OF T0XIC CHEMICAL SPILLS, HURRICANES AND FLOODS WHICH EVERYONE AGREES HAVE A MUCH HIGHER PROBABILITY j OF OCCURRING THAN AN ACCIDENT AT A NUCLEAR POWER PLANT.
FEMA, THEREFORE, CONCLUDES THAT THE PETITION DOES NOT PRO-VIDE INFORMATION WHICH SUSTAINS THE CONTENTION.
- 22.-
B) PETITIONERS:
u "IkERE ARE NO WORKABLE PLANS FOR EVACUATING THE PHYSICALLY l DISABLED, NUR$1NG HOME RESIDENTS, SCHOOL CHILDREN, HOSPITAL FATIENTS, CAMPERS, INMATES OF CORRECTIONAL FACILITIES, OR PEOPLE WITHOUT AUTOMOBILES. IN LIGHT OF THE DEFICIENCY NOTED IN C. BELOW (LACK OF CONTRACTUAL AGREEMENTS WITH TRANS-
! PORTATION PROVIDERS), GENERAL STATEMENTS IN THE PLAN TO THE EFFECT THAT THESE GROUPS WILL SOMEHOW BE EVACUATED ARE'MEAN-INGLESS AND UNREALISTIC."
l
- l. FEMA:
IHIS ISSUE WAS RAISED PREVIOUSLY IN THE " PETITION OF THE MASSACHUSETTS PUBLIC INTEREST RESEARCH GROUP FOR LMERGENCY AND KEMEDIAL ACTION" FILED BY MASSPIRG 14!TH THE NRC ON-JULY 20, 1983 NO SUBSTANTIVE NEW ISSUES ARE RAISED IN THE CURRENT PETITION.
FEMA HAS STATED PREVIOUSLY IN ITS NOVEMBER 3, 1983, ANALY-SIS OF THE MASSPIRG PETITION (SEE APPENDIX 1) THAT THE COMMONWEALTH OF MASSACHUSETTS PLANNING FOR SPECIAL NEEDS-POPULATION IS WEAK BUT ACCEPTABLE. MCDA IN ITS RESPONSE TO THE 1983 MASSPIRG PETITION, HAS STATED THAT IN ADDITION TO LOCAL RESOURCES THE SUBSTANTIAL RESOURCES OF THE LOMMON-1 WEALTH WOULD BE BROUGHT TO BEAR SHOULD LOCAL GOVERNMENTS NEED ADDITIONAL ASSISTANCE IN EVACUATING SPECIAL NEEDS POPULATIONS. IHE LOCAL PLANS SPECIFY THAT NURSING HOME RESIDENTS WILL BE EVACUATED BY PRIVATE AUTO, INSTITUTIONAL VAN, FIRE DEPARTMENT AMBULANCES, AND BUSES, IF NECESSARY.
IHE ONLY HOSPITAL LOCATED WITHIN THE lO-MILE EPl IS THE JORDAN HOSPITAL IN PLYMOUTH. IHE PROTECTION FACTOR AFFORDED.
BY THE HOSPITAL BUILDINGS' STRUCTURE AND MATERIALS WILL BE SUFFICIENT TO ALLOW SHELTER-IN-PLACE AS THE APPROPRIATE
23 -
10 WEVER, PROTECTIVE ACTION FOR MANY ACCIDENT SCENARIOS.
- NECESSARY, MOST ;F THE :ATIENTS a0VLD BE EVACUATED EY ORivATE AUTOS OF THE STAFF AND PATIENTS DR BY SUSES COOR-DINATED EY ?LYMOUTH.6IVIL JEFENSE STAFF. INTENSIVE CARE AND ORTHOPEDIC PATIENTS WHO NEED LIFE-SUPPORT SYSTEMS OR SPECIAL CARE IN MOVING WILL BE TRANSPORTED BY AMBULANCES.
IHROUGH RESPONSE CARDS !NCLUDED WITH THE ANNUAL iPl BRO-
"HURES DISTRIBUTED TO ALL HOUSEHOLDS WITHIN THE IU-MILE LE2, PHYSICALLY DISABLED INDIVIDUALS ARE SE!NG l DENT!FIED 50 HAT IPEC: AL ~ TRANSPORTATION NEEDS CAN BE :DENTIFIED IN ADVANCE-AS MENTIONED ABOVE IN RESPONSE TO ISSUE 15(B), THE LOCAL PLANS SPECIFY THAT CONTRACTOR SCHOOL BUSES MAY BE USED TO MOVE THOSE WITHOUT PERSONAL MEANS OF TRANSPORTATION. IHE PLAN PROVIDES THAT, IF THERE IS TIME, SCHOOL CHILDREN WILL BE RETURNED HOME TO EVACUATE dlTH THEIR FAMILIES, UNLESS A DECISION 15 MADE AT THE bTATE OR LOCAL LEVEL, TO EVACUATE IN BUSES.
dVACUATION PLANS FOR INMATES AT CORRECTIONAL FACILITIES ARE DETAILED IN LOCAL PLANS. IHERE ARE ONLY THREE SUCH FACIL-ITIES ALL LOCATED WITHIN THE IOWN OF PLYMOUTH. IHESE ARE THE PLYMOUTH COUNTY HOUSE OF CORRECTION (1984 EST.
PEAK USE 255 INMATES), THE IOWN OF PLYMOUTH JAll (1984 EST. PEAK USE - 22 INMATES), AND THE MASSACHUSETTS COR-RECT 10NAL INSTITUTION (1984 EST. PEAK USE OS INMATES).
~~-- . _ _ - _ _ _ _ _ _ ._.
ACCORDING TO.THE IOWN OF /LYMOUTH nLnP DATED "AY .363, EACH FACILITY HAS ESTABLISHED PROCEDURES FOR SHELTERING 3R EVACUATION OF INMATES AND STAFF.
RECEPTION FOR .! N M A T E S , IN THE EVENT OF AN EVACUATION, WILL ,
BE PROVIDED BY THE MASSACHUSETTS CORRECTIONAL INSTITUTION IN BRIDGEWATER. IRANSPORT WILL BE VIA BUSES AND VANS PRO-'
VIDED BY EACH INSTITUTION, dlTH ADDITIONAL BACK-UP AVAIL-~
ABLE CROM THE NATIONAL 6UARD.
A COMPARISON OF THE ANTICIPATED TRANSPORTATION REQUIREMENTS THAT WOULD BE NECESSARY TO EVACUATE THE TRANSIT DEPENDENT POPULATION (INCLUDING MOBILITY IMPAIRED INDIVIDUALS, NURSING HOME RESIDENTS, HOSPITAL PATIENTS, SCHOOL CHILDREN AND INMATES AT CORRECTIONAL FACILITIES) WITH THE TRANSPORTATION RESOURCES ARTI'CULATED BY THE COMMONWEALTH OF MASSACHUSETTS, (ESPECIALLY, THE VAST $ TATE CONTROLLED RESOURCE OF MBIA BUSES)
DOES NOT SUPPORT THE PETITION $ ALLEGATIONS THAT THE AREA 11 MCDA AND AND STATE RESOURCES ARE 1NADEQUATE TO HANDLE AN EVACUATION.
FEMA, THEREFORE, CONCLUDES THAT THE PETITION DOES NOT PROVIDE INFORMATION SUFFICIENT TO SUSTAIN ITS CONTENTION. ON THE OTHER HAND, FEMA, IN ITS SELF-INITIATED REVIEW-HAS ANALYZED INFORMAT10N OF ITS OWN THAT SPEAKS TO THE ISSUES RAISED.
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C.1) PETITIONERS:
IESTIMONY BY FEMA AND MCDA 0FFICIALS AT THE JUNE 18, 1986 HEARING ON THE PlLGRIM KbRP INDICATED THAT THERE ARE NO CONTRACTUAL AGREEMENTS WITH BUS COMPANIES OR BUS' DRIVERS, AMBULANCE COMPANIES, OR ANY OTHER TRANSPORTATION PROVIDERS FOR THOUSANDS OF PEOPLE WHO CANNOT DRIVE OR MAY. NOT'HAVE AN' AUTOMOBILE.
1 FEMA: 4 IHIS ISSUE WAS RAISED PREVIOUSLY IN~THE " PETITION OF THE MASSACHUSETTS PUBLIC INTEREST RESEARCH GROUP FOR LMERGENCY AND REMEDIAL ACTION" FILED BY MASSPlH6 WITH THE NRC ON ]
I JULY 20, 1983 NO SUBSTANTIVE NEW- ISSUES ARE RAISED IN j
THE CURRENT PETITION. 1 AT THE PRESENT TIME THERE ARE NO WRITTEN AGREEMENTS WITH PRIVATE BUS COMPANIES ALTHOUGH THE STATE HAS BEEN CONSIDER-ING THE NEED FOR THESE AGREEMENTS SINCE JULY 1983, (SEE MCDA RESPONSES TO MASSPIRG PETITION, PAGE 9, APPENDlX 111).
AS STATED IN FEMA'S RESPONSE TO THE 1983 MASSPIRG PETITION' (APPENDIX 1), ARRANGEMENTS HAVE BEEN MADE WITH THE MASSA-CHUSETTS BAY TRANSPORTATION AUTHORITY (MBTA), A, STATE AGENCY THAT, IN AN EMERGENCY, MAY BE DIRECTED.BY THE 60VERNOR TO RESPOND. ACCORDING TO THE COMMONWEALTH OF i MASSACHUSETTS, AN INVENTORY OF PUBLIC TRANSPORTATION RESOURCES IS AVAILABLE ON COMPUTER AND THESE RESOURCES SHOULD BE SUFFICIENT TO PROVIDE TRANSPORTATION TO THOSE WHO NEED IT. [111, SELF-INITIATED REVIEW AND INTERIM FINDING FOR UPDATED INFORMATION).
26 - J C.2) PETITIONERS: {
NO DRIVERS HAVE BEEN TRAINE'D IN FACT, IN THEIR NO DRIVERS SUPPOSED HAVE ROLE IN BEEN INFORMED EVACUATION PLANS.
THAT THEY HAVE A ROLE IN EVACUATION PLANS.
FEMA: i 4
AN EMERGENCY WORKER IS AN INDIVIDUAL WHO HAS AN ESSENTIAL MIS-q SION WITHIN THE PLUME EXPOSURE LPI TO PROTECT THE HEALTH AND SAFETY OF THE PUBLIC WHO COULD BE EXPOSED TO IONIZING RADIATION THE EMERGENCY WORKER MUST BE FROM THE PLUME OR ITS DEPOSITION. 1 TRAINED IN THE BASIC CHARACTERISTICS OF IONIZING RADIATION AND {
IN THIS CONTEXT, BUS DRIVERS AND OTHER ITS HEALTH EFFECTS.
PERSONNEL WHO WILL DRIVE EVACUATION VEHICLES MAY BE EMERGENCY WORKERS AND AS SUCH SHOULD BE TRAINED IN THEIR ROLE DURING AN EMERGENCY. [1E1, FEMA-REP-2 (REV. 1) " GUIDANCE ON OFF-SITE .
1 EMERGENCY RADIATION SYSTEMS", PHASE 1 - AIRBORNE KELEASE,
~
DECEMBER 1985, P. 5-1, AND NUREG-06S4, FEMA REP-1, REV.-1, 11 U. i l
1,2, 4 AND 5.)
IHE MASSACHUSETTS PLANS FOR DEALING WITH AN ACCIDENT AT PILGRIM INDICATE THAT THE PRIMARY MEANS OF EVACUATION FOR THE LPl WILL BE PRIVATE AUTOMOBILES. [. LEE, E 1., IOWN OF PLYMOUTH RADIO-LOGICAL EMERGENCY RESPONSE PLAN, P.7 ET SEo.l. FOR POPULATIONS WHO D D NOT HAVE ACCESS TO PRIVATE AUTOMOBILES, THE PLANS CON-IF EXTRA BUSES ARE TEMPLATE THE USE OF BUSES OR AMBULANCES.
NEEDED FROM OUTSIDE THE EPl, THE TOWNS WOULD CONTACT THE STATE AREA Il CIVIL DEFENSE HEADQUARTERS WHICH WOULD THEN COORDINATE THE PROVISION OF SUCH RESOURCES FROM THE VAST RESOURCES AVAILABLE TO THE COMMONWEALTH OF MASSACHUSETTS ESPECIALLY INCLUDING THE MBTA [lD. AT PP. 24-33).
. o 27 -
FEMA HAS N0 INDICATION THAT APPROPRIATE TRAINING (E.G., IN NOTIFICATION, RAD 10' LOGICAL EXPOSURE CONTROL, AND RADIOLOGICAL ACCIDENTS) HAS BEEN OROVIDED. IHE TOWN OF PLYMOUTH CIVIL DEFENSE U! RECTOR INDICATED AT THE FEMA SPONSORED PUBLIC MEET-ING ON THE PLANS ON JUNE 3, 1982, THAT A TRAINING PROGRAM FOR BUS DRIVERS WAS BEING DEVELOPED FOR DEPLOYMENT IN THE FALL OF 1982 !1EE, TRANSCRIPT OF A PUBLIC MEETING AN THE bTATE KAD10 LOGICAL LMERGENCY KESPONSE PLAN, P. 07}. HOWEVER, WE UNDERSTAND THAT SUCH TRAINING D!D NOT TAKE PLACE, AND IN ANY CASE, TRAINING FOR BUS DRIVERS IN RADIOLOGICAL EXPOSURE CONTROL HAS NOT EVER BEEN PROVIDED TO BUS DRIVERS.
LAC K OF TRAINING FOR DRIVERS OF EVACUATION VEHICLES OR ANY OTHER EMERGENCY WORKER IS A PROBLEM AND IS NOT IN ACCORDANCE WITH FEDERAL GUIDANCE. IHE COMMONWEALTH OF MASSACHUSETTS I 1
PLANS FOR EVACUATING THE PILGRIM EPZ CONTEMPLATE THAT THOSE (
1 BUS DRIVERS FROM OUTSIDE THE LPZ WILL MAKE ONLY ONE RUN INTO THE LPZ, PICK UP PASSENGERS AT A DESIGNATED SITE, AND IMMEDI-l ATELY LEAVE. IN ADDITION, BASED ON OUR OBSERVATIONS OF THE MASSACHUSETTS EXERCISES OF THE PILGRIM PLANS, WE UNDERSTAND THAT THE STATE WILL CAREFULLY CONSIDER THE DOSE CONSEQUENCES l
l TO THE DRIVER AND HIS PASSENGERS, AND THE OPTIMUM TIME FOR THE EVACUATION TRIP SELECTED. [lLE, MASSACHUSETTS MADIOLOG-ICAL EMERGENCY RESPONSE PLAN 55P.A.3, P.B.1, AND P.B 3].
IHE STATE HAS INFORMED US THAT IN THE EVENT THAT A DRIVER l
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.. i 0F AN EVACUATION VEHICLE WAS LIKELY TO BE EXPOSED TO A ;j LARGER' DOSE OF RADIATION THAN THE GENERAL PUBLIC, THE STATJ DECISION-MAKERS COULD USE AS EVACUATION DRIVERS A l l
)
SUBSTANTIAL' POOL OF STATE POLICE AND CIVIL DEFENSE WORKERS- J WHO HAVE BEEN APPROPRIATELY TRAINED IN RADIOLOGICAL EMERGENCY RESPONSE. IHIS TYPE OF PRIMARILY AA H2C RESPONSE )
'l IS NOT DESIRABLE HOWEVER, AND THE COMMONWEALTH'SHOULD IMPROVE [TS PLANS IN THIS AREA. IO ASSIST STATE AND LOCAL j GOVERNMENTS IN IMPROVING THEIR PLANNING IN THE AREA 0F BUS TRANSPORTATION, PARTICULARLY FOR SCHOOL CHILDREN, FEMA i HAS DEVELOPED GUIDANCE MEMORANDUM EV-2, " PROTECTIVE ACTIONS FOR SCHOOL CHILDREN". THIS DOCUMENT WILL ASSIST THE COMMON-I WEALTH IN REFINING PLANS FOR BUS. TRANSPORTATION, AND DRIVER TRAINING. FEMA WILL INSIST THAT IMPROVED PLANS AND TRAINING i
l RELATED TO BUS DRIVERS BE DEVELOPED PRIOR TO, AND TESTED DURING, THE NEXT EXERCISE OF THE PILGRIM RADIOLOGICAL LMERGENCY KESPONSE PLANS.
IN THE MEANTIME, FEMA BELIEVES THAT THE USE OF TRAINED
- STATE POLICE AND CIVIL DEFENSE. WORKERS AS BUS. DRIVERS IS AN ADEQUATE COMPENSATORY MEASURE, AND THEREFORE, THE PETITION DOES'NOT PROVIDE INFORMATION WHICH SUSTAINS THE CONTENTION.
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C.3) PETITIONERS:
FURTHERMORE, THE PROPOSED ROUTE OF SUCH EVACUATION (KOUTE 3 NORTH AND ROUTE 44 WEST) ARE COMPLETELY' INADEQUATE TO EFFEC-T!VELY_ HANDLE.THE ANTICIPATED VOLUME OF TRAFFIC. IHIS.IS PARTICULARLY TRUE DURING THE SUMMER MONTHS DUE TO THE HEAVY VOLUME OF. TOURISTS HEADING TO AND FROM LAPE-COD.
FEMA:-
FEMA THOROUGHLY ANALYZED THIS ISSUE'IN 1984 AT THE REQUEST OF THE NRC, (SEE APPENDIX 2).- WHILE ROUTES 3 AND 44 ARE 1
THE MAJOR ROUTES LEADING OUT OF THE'EPZ,.THERE'ARE MANY OTHER ROADS WHICH CAN BE USED TO LEAVE THE AREA. ALL ROUTES-LEADING INTO THE LPl WILL BE CLOSED TO INCOMING TRAFFIC, ACCORDING TO THE " STATE POLICE h!GHWAY IRAFFIC LONTROL.
AND NOTIFICATION PLAN FOR AN EMERGENCY AT P!LGRIM 1 NPS."
IHE EVACUATION TIME ESTIMATE FOR THE PILGRIM LPl HAS BEEN EXTENSIVELY REVIEWED BY FLMA AND THE NRC-AND FOUND TO BE-ADEQUATE. POSSIBLE BOTTLE NECKS HAVE BEEN IDENTIFIED AND TRAFFIC MANAGEMENT PLANS HAVE BEEN DEVELOPED TO ALLOW EVAC-UATION TO PROCEED AS RAPIDLY AS POSSIBLE. -
i l BOSTON EDISON HAS RECENTLY CONTRACTED T0 UPDATE THE EVACUA-T10N IlME ESTIMATE AND TRAFFIC MANAGEMENT PLAN FOR THE PILGRIM EPZ. (SEE APPENDIX 5, PAGES 11-12).
FEMA, THEREFORE, CONCLUDES THAT THE ISSUES RAISED IN SECTION 17 0F THE PETITION DO NOT PROVIDE INFORMATION SUFFICIENT TO SUSTAIN ITS CONTENTION. UN THE OTHER HAND, FLMA, !N ITS
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SELF-INITIATED REVIEW HAS ANALY2ED INFORMATION THAT SPEAKS j
J TO THE ISSUES RAISED IN 17.C.1 AND 17.C.2 1,8/ ALLEGED DEFICIENCIES IN NEDICAL FACILITIES l
A) PETITION:
VARIOUS NRC AND FEMA REGULATIONS REQUIRE THAT ARRANGEMENTS .
BE MADE FOR MED] CAL SERVICES FOR CONTAMINATED INJURED INDI- '
VIDUALS (10 CFR 55U.47 (B)(12); 10 CFR PART SO, APPENDIX b.
ll.k AND [V. b.7) EVALUATION CRITERIA L 1 AND L.3). IHE PLAN- '
MAKES (NADEQUATE PROVISION FOR TREATMENT OF VICTIMS OF RADIO- -j ACTIVE CONTAMINATION. A MASSPlkb 1983 STUDY.0F THE'TWO- l HOSPITALS LISTED IN THE PLAN IN.EFFECT REVEALED THEY.HAVE A I TOTAL CAPACITY TO TREAT ONLY EIGHT.0R.NINE VICTIMS OF' RADIO-ACTIVE CONTAMINATION. UNE OF THESE (JORDAN HOSPITAL, PLYMOUTH)
IS WITHIN'FOUR MILES OF THE PLANT, SO IT MAY NEED TO BE -i EVACUATED. THE OTHER (MORTON' HOSPITAL, IAUNTON) IN 1983 HAD NO STAFF TRAINED FOR RADIOLOGICAL ACCIDENTS. NO DATA SUGGESTS THE SITUATION HAS MATERIALLY IMPROVED SINCE 1983 FEMA:
l IHIS ISSUE WAS RAISED PREVIOUSLY IN THE " PETITION OF THE MASS- 4 ACHUSETTS PuBLIC INTEREST RESEARCH GROUP FOR EMERGENCY AND'RE- ,
/
MEDIAL ACTION" FILED BY MASSPIRG WITH THE NRC ON JULY 20, 1983 NO SUBSTANTIVE NEW ISSUES ARE RAISED IN THE CURRENT PETITION.
IN ITS RESPONSE TO THE PETITION THE COMMONWEALTH OF MASSACHU-SETTS STATED (APPEND!x 3, JULY 20, 1983):
UNDER NO CIRCUMSTANCES WOULD WE EXPECT LARGE NUMBERS OF CONTAMINATED INDIVIDUALS. IHE NRC 1 THROUGH NUREG-039b MADE IT CLEAR THAT MEDICAL i
REQUIREMENTS RESULTING FROM POWER PLANT ACCIDENTS 1 NEED INVOLVE ONLY LIMITED FACILITIES FOR TREATMENT 0F EXPOSED OR CONTAMINATED INDIVIDUALS. NONETHELESS, '
ALL ACCREDITED MASSACHUSETTS HOSPITALS MUST MAINTAIN A CAPABILITY TO TREAT EXPOSED OR CONTAMINATED INDIVI-DUALS.
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EEMA PREVIOUSLY STATED (APPENDIX 1, NOVEMBER 3, 1983):
IHIS CONCERN HAS BEEN ADDRESSED IN ACCORDANCE WITH NRC'S REQUIREMENTS AS FOLLOWS:
- 1) NUREG-0396 MAKES IT CLEAR THAT MEDICAL REQUIREMENTS RESULTING FROM POWER PLANT ACCIDENTS NEED INVOLVE ONLY I LIMITED FACILITIES FOR TREATMENT OF EXPOSED OR CONTAM- !
INATED INDIVIDUALS. IHIS POSITION IS IN ACCORD WITH I THE NRC COMMISSIONER S MEMORANDUM AND ORDER OF APRIL 4, 1983 (17 NRC 528 (1983), C L1 10 ) WHICH STATES:
\
q NO ADDITIONAL MEDICAL FACILITIES OR CAPABILITIES HOWEVER, l ARE REQUIRED FOR THE GENERAL PUBLIC. ?
FACILITIES WITH WHICH PRIOR ARRANGEMENTS ARE MADE AND THOSE LOCAL OR REGIONAL FACILITIES dHICH HAVE !
THE CAPABILITY TO TREAT CONTAMINATED INJURED INDIVI-DUALS SHOULD BE IDENTIFIED.... EMERGENCY PLANS SHOULD, i
HOWEVER, IDENTIFY THOSE LOCAL OR REGIONAL MEDICAL FACILITIES WHICH HAVE THE CAPABILITIES TO PROVIDE APPROPRIATE MEDICAL TREATMENT FOR RADIATION EXPOSURES NO CONTRACTUAL AGREEMENTS ARE NECESSARY AND NO ADDI-T10NAL HOSPITALS OR OTHER FACILITIES NEED BE CON-STRUCTED.
- 2) WE NOTE THAT ALL ACCREDITED MASSACHUSETTS HOSPITALS ARE REQUIRED BY THE COMMONWEALTH TO MAINTAIN A CAPABILITY TO TREAT EXPOSED OR CONTAMINATED INDIVIDUALS AND EMER-GENCY PERSONNEL ARE ADVISED IN THE HANDLING OF RADI-ATION VICTIMS. IN ADDITION, AS REQUIRED BY NRC REGULA-TIONS, THE UTILITY HAS MADE ARRANGEMENTS WITH JORDAN HOSPITAL IN PLYMOUTH TO PROVIDE ACUTE TREATMENT FOR '
EXPOSED OR CONTAMINATED PERSONNEL. IHIS ABILITY WAS REVIEWED BY THE MAY 1982 EXERCISE OF THE EMERGENCY PLAN AND FOUND ACCEPTABLE.
IHESE ARRANGEMENTS ARE DOCUMENTED ON PAGE 133 AND ANNEX A 0F THE EMERGENCY PLAN FOR THE PILGRIM NUCLEAR POWER STATION. ) l BOSTON EDISON STATED THAT ADDITIONAL HOSPITALS HAVE BEEN i i
IDENTIFIED AND ARRANGEMENTS HAVE BEEN MADE WITH THEM CON-CERNING TREATMENT OF CONTAMINATED INDIVIDUALS OR RADIATION 1 VICTIMS. (APPENDlX 5, PAGE 15).
i
ADDITIONAL RESOURCES ARE AVAILABLE IN OTHER AREAS AND THROUGH-THE FEDERAL RADIOLOGICAL EMERGENCY MESPONSE PLAN.
FEMA, THEREFORE, CONCLUDES THAT THE PETITION DOES NOT DRO-VIDE INFORMATION WHICH SUSTAINS THE CONTENTION.
B) PETITIONERS:
IHE. PLAN FAILS TO PROVIDE FOR THE DISTRIBUTION OF' RADIO-PROTECTIVE DRUGS FOR THE PREVENTION OF THYROID TUMORS TO THE GENERAL PUBLIC OR TO PERSONS IN INST!TUTIONS WHO MAY-NOT BE EVACUATEDi IHE NRC AND FbhA RECOMMEND DISTRIBUTION OF SUCH DRUGS AT LEAST TO SUCH INSTITUT!0NALIZED PERSONS (EVALUATION CRITERIA, J.10.E. AND J.10.F.J).
FEMA:
IHis IS SIMILAR TO AN ISSUE THAT WAS RAISED PREVIOUSLY IN'THE
" PETITION OF THE MASSACHUSETTS PUBLIC INTEREST RESEARCH GROUP FOR EMERGENCY AND REMEDIAL ACTION" FILED BY MASSPIRG WITH THE NRC ON JULY 20, 1983 HOWEVER THE PETITIONER IN THIS CASE MAKES THE ADDITIONAL POINT THAT THERE ARE NO SPECIFIC PROVISIONS.
IN THE MASSACHUSETTS RADIOLOGICAL EMERGENCY PLANS'FOR PROVIDING-RADIO PROTECTIVE DRUGS TO INSTITUTIONALIZED PERSONS AS IS REQUIRED BY FEDERAL GUIDANCE.
l lN ITS RESPONSE TO THE 1983 NASSPIRG PETITION, THF COMMONWEALTH i
0F MASSACHUSETTS STATED (APPEND!x 3):
THE MASSACHUSETTS DEPARTMENT OF PUBLIC HEALTH (MDPH) HAS ADVISED THAT DISTRIBUTION OF POTASSIUM IODIDE IN MASSACHUSETTS WILL BE LIMITED TO EMERG-ENCY WORKERS DURING THE INITIAL PHASE OF AN EMERG" ENCY. IHE MDPH POLICY IS BASED UPON THE DRUG'S '
POTENTIAL ADVERSE SIDE EFFECTS IF DISTRIBUTED TO THE GENERAL POPULATION INDISCRIMINATELY +
FEMA STATED IN ITS RESPONSE TO THE 1983 MASSPIRG PETITION l 1
(APPENDlX 1):
1 !
1 1 l
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.- . -1 IHE COMMONWEALTH OF MASSACHUSETTS HAS CAREFULLY
. REVIEWED THIS ISSUE.AND FORMULATED A POLICY FOR THE ;
DISTRIBUTION OF POTASSIUM IODIDE WHICH IS-THAT IT '
WILL ONLY BE GIVEN T0-EMERGENCY-WORKERS UNDER EX- I TRAORDINARY CIRCUMSTANCES. lF-THERE'WERE A POS-SIBILITY.0F RADIOACTIVE 10 DINES BE!NG. RELEASED, l
THE COMMONWEALTH WOULD EVACUATE THE AREA OR SHELTER THE POPULATION RATHER THAN HAVE THEM TAKE RADIO- ..
PROTECTIVE DRUGS. THIS. POLICY,IS BASED UPON THE COMMONWEALTH'S PERCEPTION OF THE-DRUG S POTENTIAL ADVERSE SIDE EFFECTS IF DISTRIBUTED 1TO-THE GENERAL POPULATION, AND IS CONSISTENT WITH CURRENT FEDERAL POLICY. (SEE APPENDIX b)
IHE COMMONWEALTH'S PLAN FOR THE DISTRIBUTION OF POTASSIUM i IHE bTATE: UIR-10 DINE TO INSTITUT!0NALIZED PEOPLE IS WEAK. .
ECTOR OF THE DEPARTMENT OF PUBLIC H E A L T H', RADIATION CONTROL I
UNIT HAS TOLD US THAT THE CURRENT MASSACHUSETTS POLICY: IS THAT THE COMMISSIONER OF PUBLIC HEALTH WOULD ANALYZE THE i SITUATION AT THE TIME OF THE ACCIDENT TO DETERMINE IF THE ADMIN!STRAT10N OF Kl TO INSTITUT10NALIZED PEOPLE IS WARRANTED.
BECAUSE OF THE COMPARATIVELY FEW INSTITUTIONS IN THE PILGRIM PLUME EXPOSURE EMERGENCY PLANNING ZONE THE DISTRIBUTION OF Kl TO THE INSTITUTIONS COULD BE ACCOMPLISHED ON AN AD HOC' BASIS J IHE USING EXISTING STOCKS MAINTAINED BY NUCLEAR UTILITIES.
COMMONWEALTH S PLAN WOULD BE ENHANCED IF THE POLICY FOR THE 1 ADMINISTRATION OF Kl TO INSTITUT10NALIZED PEOPLE WERE CLEARLY STATED) AND IF PROCEDURES FOR THE DISTRIBUTION OF Kl TO THE INSTITUTIONS WERE MORE FULLY DEVELOPED. l l
FEMA, THEREFORE, CONCLUDES THAT WHILE THE PETITION PolNTS OUT l A WEAKNESS IN THE MASSACHUSETTS PLANS, IT DOES NOT PROVIDE INFORMATION WHICH SUSTAINS THE CONTENTION.
34 -
19/ THE EMERGENCY PLANNING 20NE IS TOO $ MALL A) PETITIONERS:
l IHE ENVIRONMENTAL PROTECTION AGENCY (EPA) RECOMMENDS PRO- -
TECT!vE MEASURES BY THE PUBLIC WHEN RADIATION EXPOSURE IS LIKELY TO EXCEED THE EPA'S " PROTECTIVE ACTION GUIDE" 0F ONE REM (MANUAL OF PROTECTIVE ACTION UUIDE AND PROTEC-TlVE ACTIONS FOR NUCLEAR ACCIDENTS, EPA-520/1-75-001, EPA, 1975). !
i FEMA:
IHE COMMONWEALTH OF MASSACHUSETTS RADIOLOGICAL' EMERGENCY KESPONSE PLAN IS CONSISTENT dlTH PEDERAL PROTECTIVE ACTION 3UIDELINES.
B) PETITIONERS:
NRC REGULATIONS REQUIRE THE EXACT SIZE AND CONFIGURATION OF EACH EPZ TO BE " DETERMINED IN RELATION TO LOCAL RESPONSE NEEDS AND CAPABILITIES AS THEY ARE AFFECTED BY SUCH CONDI-T!ONS AS DEMOGRAPHY, TOPOGRAPHY LAND CHARACTERISTICS, ACCESS ROUTES, AND JURISDICTIONAL B3UNDARIES." GENERALLY, THE NRC PROVIDES, THE PLUME EXPOSURE EFZ SHOULD BE ABOUT TEN MILES IN RADIUS (10 CFR PART 50 47 (C;(2)). BOSTON EDISON COMPANY HAS ADMITTED THAT THE ONLY FACTOR USED TO CREATE THE PILGRIM s EPZ WAS JURISDICTIONAL BOUNDARIES (RESPONSE OF BOSTON EDISON l COMPANY TO COMMONWEALTH OF MA3SACHUSETTS' FIRST SET OF INTER- ,
ROGATORIES ON EMERGENCY PLANN!NG, JULY 20, 1981, P. 21).
FEMA:
IHE REGIONAL ASSISTANCE COMMITTEE, WHICH IS CHAIRED BY FEMA, REVIEWED THE PROPOSED P!LGRIM llVCLEAR POWER STATION PLUME EXPOSURE EMERGENCY PLANNING ZONE AND FOUND IT TO BE ADEQUATE IN SIZE AND THAT IT ADEQUATELY ADDRESSED THE DEMOGRAPHIC, TOP 0 GRAPHIC AND LAND USE CHARACTERISTICS, ACCESS ROUTES, AND JURISDICTIONAL BOUNDARIES.
1 35 -
fHE COMMONWEALTH OF MASSACHUSETTS INDICATED AT THE PLYMOUTH PUBLIC MEETING (JUNE 30, 198b) IT WILL REVIEW THE SIZE OF l THE PILGRIM PLUME EXPOSURE EMERGENCY PLANNING ZONE AS PART ;
0F AN ONGOING EFFORT TO IMPROVE EMERGENCY PLANS AND PREPARED-NESS AROUND NUCLEAR POWER PLANTS.
FEMA CONCLUDES THAT THE PETITION CONTAINS NO EVIDENCE TO SUGGEST THAT THE SIZE OF THE PLUME EXPOSURE EMERGENCY PLAN-l NING ZONE FOR THE PILGRIM NUCLEAR POWER STATION IS TOO SMALL.
C) PETITIONERS:
CAPE COD BEGINS JUST ELEVEN MILES FROM PILGRIM AND 15 CONNECTED TO THE MAINLAND BY ONLY TWO BRIDGES. THERE IS NO EMERGENCY PLANNING FOR CAPE COD, NOR PUBLIC EDUCATION OF PROTECTIVE MEASURES, NOR WARNING SIRENS. HOWEVER, THERE i ARE PLANS TO CLOSE THE CAPE COD BRIDGES TO PREVENT ITS EVAC- j UATION, SO AS TO GIVE PREFERENCE TO EVACUEES WITHIN THE l PLANT'S 10 MILE RADIUS. IHIS IS TOTALLY UNACCEPTABLE TO THE PEOPLE ON THE CAPE, WHO WOULD BE IN THE PATH OF A RAD 10LOGICA. UME IF THE WIND WERE BLOWING TOWARD THE CAPE. I EVEN IF THEY WEP' ALLOWED TO EVACUATE THE CAPE OVER THE CONNECTING BRIDG , THEY WOULD BE DOING S0 IN THE DIRECTION l OF THE PLANT AND THE SOURCE OF THE RADIATION. IHE ISSUE OF l EVACUATING CAPE COD IS EXTREMELY IMPORTANT IN THE LIGHT OF THE CHERNOBYL ACCIDENT, SINCE THERE THE RADI0 ACTIVE PLUME EXTENDED MUCH FURTHER THAN lO-MILES.
FEMA:
IHIS ISSUE WAS RAISED PREVIOUSLY IN THE " PETITION OF THE MASSACHUSETTS PUBLIC INTEREST RESEARCH GROUP FOR EMERGENCY AND REMEDIAL ACTION" FILED BY MASSPIRG WITH THE NRC ON JULY 20, 1983 NO SUBSTANTIVE NEW ISSUES ARE RAISED IN THE CURRENT PETITION.
FEMA STATED IN ITS RESPONSE TO THE 1983 PETITION (APPENDlX 1):
'l l
1 1
i IHE CONCLUSION IN-THE MASSPikb PETITION'THAT'THE SIZE OF THE EMERGENCY ~ PLANNING ZONE SHOULD BE IN-CREASED.TO INCLUDE LAPE LOD AND.0THER. AREAS.1$ BASEDL UPON A REPORT PREPARED FOR THE' MASSACHUSETTS ATTORNEYL GENERAL'S UFFICE. IHIS REPORT WAS' PREPARED.BY hHB IECHNICAL ASSOCIATES AND IS ENTITLED " REVIEW'0F CAL-CULATION OF REACTOR' ACCIDENT. CONSEQUENCES'(CKAL 2)-
RESULTS AND.LloUlD PATHWAYS,1(NUREG-1596) STUDYi
" lM PL I C A T'! O N S FOR EMERGENCY. PLANNING lN THE VICINITY OF-THE PILGRIM NUCLEAR POWER. STATION."
q IHE REPORT CONCLUDES "... PROTECTIVE ACTION I GUIDELINE DOSES MAY BE EXCEEDED,IF THE CURRENT EMERGENCY PLANNING ZONES ARE.USED." IO THE EXTENT THAT THl3 STATEMENT = INDICATES,A NEED~
(
TO INCREASE THE SIZE 0F THELAPPROXIMATELY 10 MILE RADIUS PLUME EXPOSURE-PATHWAY 120NE AT PILGRIM, SUCH A CONCLUSION IS.NOT GENERALLY ACCEPTED BY THE SCIENTIFIC COMMUNITY:AT THIS j
TIME.
IHE SIZE AND CONFIGURATION OF.THE EMERGENCY PLAN-NING LONE FOR PILGRIM IS BASED UPON NUKtG-Obb4 CRITERIA AND APPROVED BY THE REGIONAL ASSISTANCE COMM~ITTEE (RAC). IHE SIZE OF THE'EPL TO'BE USED FOR RADIOLOGICAL EMERGENCY RESPONSE WAS DETERMINED '
BY A JOINT NKC/tPA IASK FORCE STUDY. IHE CONCLU-S!ONS REACHED BY THE TASK FORCE ARE DOCUMENTED IN NUREG-0396, LPA 520/1-78-016 BOTH NUKEb-Ubb4 AND NUREG-0396 RECOGNIZE THAT PA6S MIGHT BE EXCEEDED BEYOND THE TEN MILE PLUME EXPOSURE LPl IN THE. EVENT OF THE WORST POSSIBLE ACCIDENT AND' METEOROLOGICAL CONDITIONS. HOWEVER, A IEN MILE PLUME EXPOSURE i l
tPZ WAS STILL CHOSEN AS A PLANNING BASIS IN NUREG-0654 BECAUSE:
A. PROJECTED DOSES FROM THE TRADITIONAL DESIGN BASl$ ACCIDENTS WOULD NOT EXCEED PAG LEVELS.
OUTSIDE THE ZONE; B. PROJECTED DOSES FROM MOST CORE. MELT. SEQUENCES ,
WOULD NOT EXCEED PAG. LEVELS OUTSIDE'THE ZONEJ l C. FOR THE WORST CORE MELT SEQUENCES, IMMEDIATE LIFE THREATENING DOSES WOULD GENERALLY NOT OCCUR OUTSIDE THE ZONE)
D. DETA! LED PLANNING WITHIN 10 MILES.WOULD PROVIDE A SUBSTANTIAL BASE FOR EXPANSION'0F RESPONSE EFFORTS IN THE EVENT THAT THIS PROVED NECESSARY.
_ _ _ _ - _ _ - _ - _ = _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ __ __ __
n_--_ _ . _ - - _ _ _ .
J 37 -
IHE 1 RC MAS 3EEN INVESTIGATING ACCIDENT SOURCE TERMS, ]
PROBABILITIES AND' CONSEQUENCES.0F NUCLEARLREACTOR AC-
.IHE' RESULT OF THE'SE STUDIES, l 0! DENTS FOR SEVERAL YEARS.
WHEN COMPLETE, ARE EXPECTED TO BE USED INf REV! SING NUKtU l 0654 IHE REVISION OF NUKE 6-0634 MAYEINCLUDE'RECONSID '
ERAT 10N OF THE SIZE 0F THE tMERGENCY PLANNING 40NE.
]
NOT NEED SPECIFIC f LAPE COD IS BEYONDTHElu-MILEpPZANDDOES I
HOWEVER, AS NOTED EARLIER l' N q RADIOLOGICAL EMERGENCY PLANS. .
THIS RESPONSE, THE COMMONWEALTH HAS-!NDICATED T0 FEMA-THAT IT WILL REVIEW THE SIZE OF THE PILGRIM PLUME hxPOSURE EMER-l l GENCY PLANNING ZONE AS PART 0F AN ON-GOING EFFORT TO IMPROVE EMERGENCY PLANS AND PREPAREDNESS AROUND NUCLEAR' POWER PLANTS.
SPECIFIC, DETA! LED PLANS DEVELOPED FOR THE-EPZ DO NOT PRECLUDE TAKING APPROPRIATE PROTECTIVE ACTIONS BEYOND THE 10-MILE AREA.
l l IN FACT, THE DETAILED EPZ PLANS BECOME THE BASIS FOR ANY ACTIONS REQUIRED AT GREATER DISTANCES.-
l ACCORDING TO THE MASSACHUSETTS CIVIL DEFENSE AGENCY.COMPRE- .}
I HENSIVE EMERGENCY MANAGEMENT PLANS WHICH ADDRESS-THE USE OF SHELTER AND EVACUATION AS POSSIBLE PROTECTIVE RESPONSE TO EMERGENCIES CURRENTLY EXIST IN MOST COMMUNIT!ES OUTSIDE
! 0F THE PLUME EXPOSURE EMERGENCY PLANNING ZONE.
l \
FEMA HAS JOINED NRC AND THE UEPARTMENT OF bNERGY, LPA AND THE NUCLEAR INDUSTRY IN THE PREPARATION OF A REPORT ON.THE CHERNOBYL ACCIDENT. FEMA ACCEPTED THE RESPONSIBILITY FOR WE THE CHAPTER ON EMERGENCY RESPONSE AND PREPAREDNESS.
VIEW THIS REPORT AS A NECESSARY PREREQUISITE FOR ANY REVIEW
38 -
0F THE U b. KAD10 LOGICAL EMERGENCY PREPAREDNESS PROGRAM.
IT SHOULD IDENTIFY LESSONS FROM THE CHERNOBYL EXPERIENCE THAT CAN BE USED IN REVIEWING:THE V.S.' PROGRAM. AT THIS.
TIME, HOWEVER, WE ARE NOT YET IN A POSITION TO DETERMINE IF THE LESSONS LEARNED AT CHERNOBYL WILL REQUIRE. CHANGES IN THE RADIOLOGICAL EMERGENCY PLANNING.
FEMA, THEREFORE, CONCLUDES THAT THE PETITION DOES NOT PROVIDE INFORMATION WHICH SUSTAINS THE CONTENTION.
D) FETIT10NERS:
DASING HIS CONCLUSION UPON NKC DATA, THE ATTORNEY GENERAL OF MASSACHUSETTS HAS CONCLUDED THAT THE SIZE OF THE PILGRIM l LPl IS INADEQUATE (COMMENTS OF ATTORNEY GENERAL FRANCIS X.
l bELLOTTI KELATIVE TO UFF-SITE EMERGENCY PLANNING FOR THE l P!LGRIM NUCLEAR POWER $TATION, SUBMITTED TO FEMA, AUGUST 1982).
FLMA:
IN RESPONSE TO A JUNE 3, 1982, PUBLIC MEETING ON THE STATE AND LOCAL UFF-SITE RADIOLOGICAL EMERGENCY PLAN, ASSISTANT ATTORNEY 6ENERAL JOANN $HOTWELL OF THE ENVIRONMENTAL PRO-TECTION DIVIS10N OF THE MASSACHUSETTS ATTORNEY GENERAL'S OFFICE REQUESTED BY A LETTER OF JUNE lo, 1982,-THAT THE MEETING RECORD BE LEFT OPEN UNTIL THE END OF JULY SO .THAT HER OFFICE COULD SUBMIT FURTHER COMMENTS. IHE' ATTORNEY GENERAL'S OFFICE RETAINED MHB TECHNICAL ASSOCIATES OF. SAN JOSE, CALIFORNIA, TO REVIEW FOR THEM CERTAIN DOCUMENTS RE-LATED TO OFF-SITE PLANNING AROUND THE PILGRIM NPS. .IHE MHB REPORT WAS TITLED "KEVIEW OF CALCULATION OF REACTOR CON-I
i 1
39 SEQUENCES.lCRAC 2) KESULTS-AND LloulD PATHWAYS (NUREG-li96)
$TUDY: } IMPLICATIONS FOR iMERGENCY CLANNING IN THE 'llCINITY OF THE FILGRIM NUCLEAR POWER STATION". IN A LETTER DATED AUGUST.2b, 1982, FRANCIS 4 DELLOTTI, THE ? MASSACHUSETTS ATTORNEY 6ENERAL (A6) SENT TO FEMA REGION 1, FIFTEEN PAGES OF COMMENTS ADDRESSING FOUR GENERAL ISSUES. UNE OF THESE ISSUES DEALT WITH THE GIIE OF.THE 10-MILE PLUME EXPOSURE d?Z. BASED ON MHb's TECHNICAL ' REVIEW OF THE. REFERENCED
'l4RC DOCUMENTS, IHE MASSACHUSETTS A6 INDICATED THAT'POTEN-TIAL DOSES TO THE POPULATION WOULD' EXCEED THE LEVELS AT WHICH THE EPA PROTECTIVE ACTION GUIDES RECOMMEND EVACUATION, EVEN AT DISTANCES OF 50 MILES DOWNWIND FROM THE PLANT. [HIS SITUATION, THE A6 BELIEVES, WOULD OCCUR DURING AN SSI-1. l WORSE CASE ACCIDENT UNDER CERTAIN WEATHER CONDITIONS THAT RESULT IN MAXIMUM DOSE. IHUS, THE A6 BELIEVES THAT THE CURRENT USE OF THE 10-MILE LPl FOR PILGRIM l$ NOT APPRO-PRIATE, AND THAT THE EPl SHOULD, THEREFORE, BE EXTENDED FURTHER TO INCLUDE ALL OF LAPE LOD.- ,
i IHIS SAME CONCERN WAS RAISED BY MASSPIRG AND WAS REFERRED TO THE NRC FOR THEIR. RESPONSE AS IT WAS IN DIRECT CONFLICT 1 WITH NRC'S REGULATION 10 CFR 50 7 (C) (2). NRC'S RESPONSE TO MASSPIRG IS DISCUSSED ON PAGES 10-14 0F NRC'S " INTERIM DIRECTOR'S DECISION UNDER 10 CFR 2 206 (DOCKET NO. 50-293),"
(FEBRUARY 27, 1984).
l
. s f
40 -
1 IHE RESPONSE STATES THAT IHE PLUME b?Z FOR THE PIL3 RIM-FACILITY ls' BASED UPON huREG-0654 GUIDANCE' CRITERIA.
IHE JOINT NRC/ EPA TASK PORCE THAT DEVELOPED NUKEG-0396 1 CONSIDERED SEVERAL POSS13LE RATIONALES FOR ESTABLISHING THE IHESE INCLUDED RISK, PROBABILITY, COST SIZE OF THE EPZS.
THE EFFECTIVENESS AND AN ACCIDENT CONSEQUENCE SPECTRUM. ,
IASK FORCE CHOSE TO BASE EPl SIZE ON A FULL SPECTRUM C
> _B- ,
ACCIDENTS AND CORRESPONDING CONSEQUENCES TEMPERED BY ABILITY CONSIDERATIONS. (T WAS THE CONSENSUS OF THE IASK FORCE THAT A PLUME iPL OF ABOUT TEN MILES WOULD PROVID,E AN i
ADEQUATE PLANNING BASE BEYOND~WHICH ACTIONS COULD BE TAKEN' !
ON AN A2 EQL BASIS USING THE SAME CONSIDERATIONS THAT WENT IN ITs STATEMENT ON INTO THE INITIAL ACTION DETERMINATIONS.
" PLANNING BASIS FOR EMERGENCY RESPONSE TO' NUCLEAR POWER ACCIDENTS," 44 F D. REG. 61123.(UCT. 23, 1979), THE COMMIS- f
$10N NOTED THAT AN EPZ OF ABOUT 10. MILES IS CONSIDERED LARGE ENOUGH TO PROVIDE A RESPONSE BASE WHICH WOULD SUPPORT ACTlvlTY OUTSIDE THE PLANNING ZONE SHOULD THIS EVER BE NEEDED.
IHE PETITIONER CONTENDS THAT, BASED UPON THE REFERENCED CRAC 2 RESULTS, AN ENLARGEMENT OF THE CURRENT PILGRIM PLUME l EPl IS WARRANTED BECAUSE THE PROJECTED DOSES EXCEED THE E PROTECTIVE ACTION bulDES (PAGS) OUTSIDE THE lu-MILE LPl.
BOTH NUREG-0654 AND NUKEG-0396 RECOGN!ZE, BASED UPON CRAC 2 RESULTS, THAT THE PAGS MIGHT BE EXCEEDED BEYOND THE TEN MILE
I.-
( .
l
~
l 41 -
]
l PLUME EXPOSURE EPl IN THE EVENT OF THE WORST POSSIBLE ACCIDENT l AND " METEOROLOGICAL CONDIT10NS. 90 WEVER, A TEN MILE PLUME f l
EXPOSURE i?l WAS .STILL CHOSEN AS A PLANNING BASIS 1N 1 Nuktb-Ubb4 BECAUSE:
A. DROJECTED DOSES FROM THE TRADITIONAL DESIGN BASIS ACCIDENTS WOULD NOT EXCEED PAb LEVELS OUTSIDE~THE ZONE; 3 PROJECTED DOSES FROM MOST SEVERE FUEL DEGRADATION SEQUENCES WOULD NOT EXCEED PA6 LEVELS OUTSIDE THE ZONEJ 1 C. FOR THE WORSE FUEL-DEGRADATION SEQUENCES, IMMEDIATE 1
LIFE THREATENING DOSES WOULD GENERALLY NOT OCCUR OUT-SIDE THE ZONE; AND f l
1 D. DETAILED PLANNING dlTHIN 10' MILES WOULD-PROVIDE A SUB-STANTIAL BASE FOR EXPANSION OF RESPONSE EFFORTS IN THE f
/
EVENT THAT THIS PROVED NECESSARY.
l
! l l
HENCE, AT THE PRESENT TIME, NRC HAS INDICATED TO FEMA THAT i
l THERE 15 NO BASIS FOR REQ.VIRING THAT A PLUME-EXPOSURE PATH-WAY 't?! SHOULD BE GREATER THAN APPROXIMATELY A lO-MILE RADIUS FROM THE PLANT.
ETNA, THEREFORE, CONCLUDES THAT THE PETITION DOES NOT PROVIDE INFORMATION WHICH SUSTAINS THE CONTENTION.
20/ LACK OF COORDINATION AND PRIORITIZATION OF THE RERP A) PETITIONERS:
IHE NRC SHOULD SUSPEND THE OPERATING LICENSE OF THE PILGRIM-POWER PLANT UNTIL A REALISTIC, DETAILED RERP IS DEVELOPED, SHOWING AN ACTUAL CAPABILITY TO EDUCATE, ALERT, TREAT AND EFFICIENTLY EVACUATE ALL PEOPLE WHO MAY BE AT RISK FROM A CATASTROPHIC ACCIDENT AT'THE. PLANT. FEDERAL, STATE AND.
LOCAL GOVERNMENT AGENCIES, AS WELL AS BOSTON EDISON, HAVE ALL ACCORDED A LOW PRIORITY TO EMERGENCY PLANNING. INSTEAD OF TRYING SERIOUSLY TO DEVISE A PLAN THAT'WILL PROTECT ALL
i 6 I
\
l 0F THE PUBLIC, PLANNERS HAVE SOUGHT TO ACHIEVE ONLY MIN! MUM COMPLIANCE WITH NRC REGULATIONS) AS SECTIONS 13 THROUGH 13' THEY HAVE FAILED _TO DO EVEN 0F THIS. PETITION. DEMONSTRATE, THAT. lHIS INSUFFICIENT COMMITMENT TO PUBLIC PROTECTION IS EVIDENT IN MISSED DEADLINES, SLOW PROCESSING OF PAPER-j WORK, LACK OF ATTENTION TO DETAll AND INADEQUATE BUDGETS AND STAFFING.
IO DATE, FEMA HAS LARGELY ACQUIESCED;IN PLANS THAT Fall TO i DEMONSTRATE A CAPABILITY TO ADEQUATELY RESPOND TO AN ACTUAL f EMERGENCY, AND FEMA'S ACQUIESCENCE HAS BEEN EMULATED BY THE l NRC. WHERE FEMA HAS'CRITIClZED PARTS OF THE PLAN, THE I flASSACHUSETTS civil UEFENSE AGENCY (MCUA) FOR.
HAS NOTzRESPONDED EXAMPLE, AC-IN A TIMELY FASHION TO FENA'S CONCERNS.
CORDING TO'TESilMONY BEFORE MASSACHUSETTS STATE LEGISLATORS ON JUNE 18, 1986, BY EDWARD A. IHOMAS OF'FbhA, THE AGENCY SENT LETTERS OUTLINING PERSISTENT FEMA CONCERNS TO MCUA IN-FEMA RECEIVED NO RESPONSE' UCTOBER, 1985 AND JANUARY, 1986 TO THE JCTOBER LETTER UNTIL JUNE b, 1986 AND FEhA HAD NOT 3 l
YET RECEIVED A RESPONSE TO THE JANUARY LETTER BY THE TIME OF THE HEARING.
l I
FEMA: .)
ON JUNE 16, 1981,- THE DIRECTOR OF THE MASSACHUSETTS Civil
< DEFENSE AGENCY (MCDA) ON BEHALF OF THE G0vERNOR OF THE COMMONWEALTH OF MASSACHUSETTS SUBMITTED THE RADIOLOGICAL EMERGENCY RESPONSE PLANS FOR REVIEW PURSUANT TO 44 CFR 350, AND STATED THAT IN THE OPINION OF MCDA THE PLAN WAS ADEQUATE UN SEPTEMBER 29, TO PROTECT THE PUBLIC HEALTH AND $AFETY.
1982, FEMA ISSUED AN INTERIM FINDING THAT ALTHOUGH THE PLANS WERE NOT PERFECT, "THE INTERIM FINDING OF FEMA IS THAT THE STATE PLAN AND LOCAL PLANS TOGETHER ARE ADEQUATE TO PRO-TECT THE HEALTH AND SAFETY OF THE PUBLIC."b UN MARCH 6, 1985 AND OCTOBER 30, 1985 FEMA INFORMED THE MASSACHUSETTS CIVIL DEFENSE AGENCY BY LETTER THAT BECAUSE OF UNRESOLVED EMERGENCY PLANNING ISSUES RAISED DURING THE RAC REVIEWS OF UCTOBER 1981
r l
43 -
AND SEPTEMBER 1982, AND DURING THE 1h62 AND 1383 EXERCISES aE HAD SUSPENDED PROCESS!NG THEL; AFQUEST FOR A FORMAL APPROVAL '
l PURSUANT TO 44 CFR 350 FthA HAS NOT RESUMED ITS PROCESSING OF THE 350 APPROVAL REQUEST BECAUSE MCDA HAS NOT ADEQUATELY f I
IT SHOULD BE l
ADDRESSED THE ISSUES RAISED IN THE LETTERS.
l f UNDERSTOOD THAT WHILE THE RESOLUTION OF THESE ISSUES WOULD ENHANCE THE MASSACHUSETTS PILGRIM KERP, NEVERTHELESS THE PLANS HAVE BEEN FOUND TO BE ADEQUATE IN THAT THEY MEET THE MINIMUM STANDARD OF FROVIDING A REASONABLE ASSURANCE THAT THE STATE AND LOCAL DLANS ARE ADEQUATE TO PROTECT THE HEALTH f I
AND SAFETY OF THE PUBLIC IN THE P!LGRIM hPl. Ik11, SELF-
{NITIATED dEviEW AND INTERIM FINDING FOR UPDATED INFORMATION.}
LXERCISES OF THE PLANS AND PREPAREDNESS OF STATE AND LOCAL I GOVERNMENTS WITHIN THE PLUME LXPOSURE LMERGENCY PLANNING ZONE FOR THE PILGRIM NUCLEAR POWER STATION.WERE OBSERVED BY FthA ON MARCH 3, 1982; JUNE 29, 1983, AND $EPTEMBER 5, 1985 A REVIEW 0F THE EXERCISES INDICATES THAT THE COMMONWEALTH OF MASSACHUSETTS HAS MOVED PROMPTLY TO CORRECT PLAN OR PERFORM-l j
ANCE PROBLEMS WHICH WOULD INTERFERE wlTH ITS ABILITY TO PROTECT THE PUBLIC IN THE EVENT OF AN ACCIDENT.AT PILGR!M. IHE 1982 AND 1983 EXERCISES DEMONSTRATED THAT A CAPABILITY EXISTED FOR $ TATE AND LOCAL GOVERNMENTS TO PROTECT THE HEALTH AND SAFETY OF THE PUBLIC IN THE EVENT OF AN ACCIDENT AT THE PILGRlM NUCLEAR POWER STATION.
.,: s.
44 -
110W E V E R , FtMA'S OBSERVATION'0F THE EXERCISE CONDUCTED ON bEPTEMBER D, 1985, IDENTIFIED FOUR DEFICIENCIES IN-THE EXER-CISE. FEMA NOW USES THE WORD " DEFICIENCIES"1TO MEAN A'
DEMONSTRATED AND OBSERVED INADEQUACIES THAT WOULD CAUSE FINDING THAT OFF-SITE EMERGENCY PREPAREDNESS WAS NOT ADEQUATE )
l TO PROVIDE REASONABLE ASSURANCE.THAT APPROPRIATE' PROTECTIVE MEASURES CAN BE TAKEN TO PROTECT THE HEALTH AND SAFETY.0F THE PUBLIC LIVING IN THE VICINITY OF A NUCLEAR POWER-FACILITY l IN THE EVENT OF A RADIOLOGICAL EMERGENCY.
UN SEPTEMBEa 20, 1985, FEMA SENT A-LETTER TO'MCDA INFORMING-l THEM OF THE EXISTENCE OF THE FOUR DEFICIENCIES.!DENTIFIED FOR UN UCTOBER THE CARVER EOC AND THE IAUNTON RECEPTION CENTER.
29, 1985, A KEMEDIAL LXERCISE WAS HELD TO DEMONSTRATE CORREC-l l
TION OF THESE DEFICIENCIES. IHE FOUR DEFICIENCIES WERE 1
CORRECTED. (SEE FtMA l DOCUMENT, "KEPORT ON THE KEMEDIAL
'XERCISE t FOR THE PILGRIM NUCLEAR POWER STATION", UCTOBER 29, ,
1985). !
l i IHE COMMONWEALTH OF MASSACHUSETTS RESPONDED PROMPTLY TO THE I DEFICIENCIES IDENTIFIED DURING THE 1985 EXERCISE. AS INDI-CATED ABOVE BOTH BY FEMA AND THE *ETIT10NERS, THE RESPONSE TO ISSUES WHICH WERE NOT CATEGORIZED AS DEFICIENCIES HAS NOT BEEN TIMELY. FOLLOWING THE JUNE 29, 1983 EXERCISE NO DEF1-CIENCIES WERE IDENTIFIED AND THE COMMONWEALTH PROVIDED A i
. _ _ _ -- . _ _ ~ _ _ _ - _ _ _ - _ _ _ _
U$ -
COMMUNITY LEVEL. IHE STATE TH~EN PROVIDED A SCHEDULE OF CORRECTIVE ACTIONS lN A LETTER TO FEMA DATED JUNE 20, 1985, .
FOR ALL STATE AND LOCAL COMMUNITY INADEQUACIES NOTED AT THE 1983 EXERCISE. OEMA OBSERVED, DURING THE 1985 EXERCISE, THAT MANY OF THE PROBLEMS IDENTIFIED IN THE 1982 AND 1983 EXERCISES HAD BEEN CORRECTED, BUT MANY NEW " AREAS REQUIRING CORRECTIVE ACTION" (ARCA) AND FOUR DEFICIENCIES WERE IDENTIFIED.
IHE COMMONWEALTH HAD CORRECTED THE DEFICIENCIES BY OCTOBER 29, 1985 AND cN UCTOBER 50, 1985 PROVIDED FEMA WITH A PLAN OF ACTION WHICH, IT FELT, IF IMPLEMENTED WOULD RESOLVE THE UN . LARCH 5, 13bb FthA
" AREAS REQUIRING CORRECT!/E ACTION"-
SENT THE COMMONWEALTH THE REPORT ON THE SEPTEMBER 5, 1985 EXERCISE. IHE COMMONWEALTH, AS PROVIDED IN FtNA GUIDANCE, WAS TO PROVIDE FthA WITH A SCHEDULE OF CORRECTIVE ACTIONS FOR THE " AREAS REQUIRING CORRECTIVE ACTION" WITHIN 30 DAYS OF THE REPORT'S RECEIPT. ALTHOUGH FEMA HAD NOT RECEIVED A SCHEDULE BY THE TIME THE PETITION WAS FILED, IT D!D NOT FEEL IHE COMMONWEALTH HAS NOT YET, THE SCHEDULE WAS OVERLY LATE.
HOWEVER, SUBMITTED ITS SCHEDULE OF CORRECTIVE ACTIONS. IHIS SUBJECT IS DEALT WITH IN FEMA'S SELF-IN!TIATED REVIEW AT PP 37-44 1
B) PETITIONERS:
ANOTHER EXAMPLE OF THE SERIOUS LACK OF COORDINATION WAS THE FAILURE OF MCDA TO DELIVER TO FthA AN UP-TO-DATE VERSION OF THE STATE EMERGENCY PLAN. ACCORDING TO STATEMENTS 9Y FEMA AND MLUA 0FFICIALS IN THE JUNE 20, 1986 EDITION OF THE PATRIOT LEDGER OF QUINCY, MA, THE PLAN WAS NOT DELIVERED UNTIL 10 MONTHS AFTER IT WAS PREPARED. NLDA COMPLETED THE
. 46 -
UPDATED kLAN IN AUGUST; 1985 BuT Dio NOT DELIVER A COPY 0F IT UNT!L JUNE 25, 1986 FEMA HAD FORMALLY REQUESTED A COPY OF THE PLAN IN UCTOPER, 1985, suT-DID NOT FOLLOW UP ON THAT REQUEST. MCDA'S FAILURE TO RESPOND TO PtMA'S REQUEST AND FEMA'S EVIDENT LACK OF' CONCERN AND UNWILLINGNESS TO DEMAND MORE RESPONSIVE ACTION ARE SYMPTOMATIC OF AN EMERGENCY RESPONSE REGIME THAT IS UNCOORDINATED AND GIVEN LOW PRIORITY BY ITS ATTENDANT PUBLIC AGENCIES.
FEMA:
IHE BUL' l'F . THE M AS S ACHUS ETTS HERPS FOR'THEs PILGRIM EPl'WHICH FEMA HAS ON FILE ARE CURRENT. IHE LAST MAJOR REVISION TO THE MINOP-3 TATE PLAN WAS IN 1982 AND FEMA HAS THOSE, CHANGES.
FEMA REQUESTED CHANGES TO LOCAL PLANS WERE MADE IN 1985 COP!ES OF THE PLANS ON OCTOBER 30, 1985, AND FEMA RECEIVED-COPIES OF THEM FROM HMM ASSOCIATES'IN A LETTER DATED JUNE 122, 1
1986 IHE COMMONWEALTH SUBSEQUENTLY INFORMED FEMA THAT THE FEMA wouLD 1985 VERS'!ON OF THE LOCAL PLANS WERE CURRENT.
ENCOURAGE ATTEMPTS BY THE COMMONWEALTH 0F MASSACHUSETTS TO l GIVE KADl0 LOGICAL LMERGENCY PREPAREDNESS PLANNING A HIGHER PRIORITY.
l C) PETITIONERS: 1 FURTHER EVIDENCE OF THIS LACK OF COORDINATION AND'PR10RITI-ZATION WAS REVEALED IN MR. IHOMAS' JUNE 18, 1986 TESTIMONY.
MR. IHOMAS STATED THAT BOSTON EDISON HAD FAILED REPEATEDLY TO DELIVER TO FEMA NECESSARY TECHNICAL SPECIFICATIONS ON THE SIRENS THAT WOULD NOTIFY THE PUBLIC OF A RADIOLOGICAL EMERGENCY AT THE P!LGRIM PLANT. MR. IHOMAS STATED THAT THESE DELAYS BY BOSTON EDISON HAVE FORCED REPEATED POSTPON-MENTS OF SYSTEM TESTING. IHUS, THE SYSTEM HAS NEVER BEEN GIVEN THE FULL-SCALE TEST REQUIRED BY FEMA.
FEMA:
AS NOTED IN THE RESPONSE TO ITEM 16 ABOVE, FEMA RECE!VED.THE k
I O
47 .
'S!REN SYSTEM TECHNICAL SPECIFICATIONS ON JUNE 20, 1985, ANDL PERFORMED A DETAILED REVIEWLOF'THE STATE AND LOCAL :ULL-SCALE SIREN TEST ON SEPTEMBER 29, 1986 dESULTS'0F THE i SIREN TEST INDICATED THAT 38 2%_0F THE PEOPLE dERE.DIRECTLY HOWEVER THE ALERTED BY THE SIRENS ON THE DAY OF THE' TEST. .
PETITION DOES NOT DEMONSTRATE THAT THESE DELAYS INTERFERED l
WITH THE COMMONWEALTH $ ABILITY TO PROTECT-THE PUBLIC.
D) PETITIONERS:
IHE EMERGENCY RESPONSE SYSTEM'S LACK OF PRIORITIZATION IS FURTHER DEMONSTRATED BY THE FACT THAT LOCAL ~ CIVIL DEFENSE AGENCIES IN THE COMMUNITIESJW! THIN'THE EMERGENCY PLANNING-e0NE HAVE SERIOUS STAFFING AND BUDGETARY PROBLEMS. 'dOST LOCAL CIVIL DEFENSE DIRECTORS WITHIN'THE EPl-ARE UNPAID OR RECEIVE'ONLY SMALL STIPENDS. MOST'HAVE LITTLE OR NO PAID STAFF. IHE RELIANCE ON VOLUNTEERS,'WHO OFTEN HAVE MINIMAL PROFESSIONAL EXPERIENCE OR TRAINING, REFLECTS THE UNWILLING-NESS OF STATE AND LOCAL GOVERNMENT TO MAKE A GENUINE COMMIT-MENT TO EMERGENCY RESPONSE PLANNING. MAJOREIMPROVEMENTS I N-STAFFING AND BUDGETS OF STATE AND LOCAL-CIVIL DEFENSE BODIES MUST BE IMPLEMENTED BEFORE PUBLIC SAFETY CAN BE' ENSURED.
MORE0VER, LEST THE NECESSARY MEASURES TAKEN CONSTITUTE PUBLIC SUBSIDIZATION OF THE FINANCIAL REQUIREMENTS OF A SAFE NUCLEAR POWER SYSTEM, BOSTON EDISON SHOULD BE REQUIR'ED l TO PROVIDE THE FINANCIAL MEANS FOR THEM.
FEMA:
l FEMA FEELS THAT THIS ALLEGATION IS TOTALLY WITHOUT MERIT BASED UPON PAST HISTORY WITH VOLUNTEER GOVERNMENT IN THE U.S. EACH DAY THOUSANDS OF VOLUNTEERS IN LOCAL GOVERNMENTS PERFORM ADMIRABLY, OFTEN WITH GREAT RISK TO THEIR PERSONAL SAFETY AND WELL-BEING. UNE EXCELLENT EXAMPLE OF.THIS-IS THE DEDICATION AND COMMITMENT DISPLAYED BY VOLUNTEERS WHO PARTIC-IPATE IN RADIOLOGICAL EMERGENCY RESPONSE EXERCISES AND RES*
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POND TO EMERGENCIES IN THE!R COMMUNITIES ON A DAILY BAS!S.
AS NOTED BY PEDERAL EVALUATORS COMMENTS IN EXERCISE REPORTS FOR THE EXERCISES OF THE DAD 10 LOGICAL EMERGENCY kESPONSE PLANS FOR THE ?!L3 RIM NUCLEAR POWER STATION IN 1982, 1983, i AND 1985, THE DEDICATION AND COMMITMENT OF THE VOLUNTEERS HAS BEEN CONSISTENTLY DISPLAYED. THE VOLUNTEERS HAVE IN-CLUDED LOCAL civil DEFENSE DIRECTORS AND STAFF, SELECTMEN, ElRE PERSONNEL, PAla MEDICS, KED CROSS VOLUNTEERS, HACES AMATEUR RADIO OPER4TOAS, THE CIVIL AIR PATROL AND OTHERS.
IHE /0LUNTEERS ARE LNJdLEDGEABLE OF THEIR DUTIES AND CON-SCIENT!OUS IN THE PERFORMANCE OF THESE DUTIES. ALTHOUGH i
VOLUNTEERS RECEIVE LiiTLt OR NO ST! PENDS FOR THEIR SER-VICES, THEY ARE WORKING TO MAKE THE!R COMMUNITIES A SAFER l'
AND BETTER PLACE FOR THEIR FAMILY AND FRIENDS TO LIVE.
MANY VOLUNTEERS HAVE INDICATED TO OUR STAFF THAT THE SAT-ISFACTION OF HELPING PROTECT THE!R COMMUNITY ' AFFORDS THEM FAR GREATER REWARDS AND INCENTIVE THAN ANY MONETARY COMPEN- l SATION COULD PROVIDE.
I FEMA, THEREFORE, CONCLUDES THAT THE ISSUES RAISED IN SEC-TION 20 0F THE PETITION 00 NOT PROVIDE INFORMATION WHICH SUSTAINS THE CONTENTION. ]
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FUDINU_T_E_._S.
1 HANS, JOSEPH N., JR.; S E L L', lHOMAS L., EVACUATION RISKS - AN EVALUATION, ENVIRONMENTAL PROTECTION '
AGENCY, tFA >ZU/.b-/4-UU2, JUNE, 1974 .
'2 IB!DJ'PG 43 I 3 1B1DJ PG 18 .)
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i 4 IREADWELL, MATTIE E., HURRICANE CARLA . SEPTEMBER M ,
l 0 ; DEPARTMENT OF DEFENSE - UFFICE OF l!VIL-UEFENSE, EGION V, DENTON, IEXAS, PG.16 ,
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5 FEMA REGION 1 INTERIM FINDINGS " JOINT STATE ' AND LOCAL I EMERGENCY RESPONSE CAPABILITIES'FOR THE P!L' GRIM NUCLEAR POWER STATION, PLYMOUTH, MASSACHUSETTS, SEPTEMBER 1982" l
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- B Attachment B Mark I Containment Design As discussed in Section C.1 of the Petition, the original design basis of the reactor containment was to provide protection against loss of coolant accidents (LOCAs). This discussion will describe how it fulfills its function- i of protecting against these design basis events.
The design of the Pilgrim containment is referred to as the " Mark I" design, which features a " pressure-suppression" containment (see Figure 1).
A pressure-suppression containment uses a large pool of water to reduce the buildup of steam pressure inside the containment following a LOCA. The steam is condensed by passing it through the pool of water.
The concept of pressure suppression with water was developed by GE for the Humboldt Bay Nuclear Plant during the time period from 1958 to 1962. Since thattine,GEhasdesignedmanyboilingwaterreactor(BWR)plantsandhas developed three distinctively different pressure-suppression containment designs, identified as the Mark I, II, and III designs.
The Mark I containment system consists of (1) a drywell that encloses the reactor vessel, the reactor coolant system, and other branch connections l
of the reactor coolant system; (2) a donut-shaped pressure-suppression chamber (torus) containing a large volume of water; (3) a vent system connecting the drywell to the water space of the torus; (4) containment I isolation valves; (5) containment cooling systems; and (6) other service equipment.
The drywell is a steel pressure vessel supported in concrete with a spherical lower section and a cylindrical upper portion. The pressure suppression chamber is a steel pressure vessel in the shape of a torus, and is
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Containment Isolation FIGUHE Schematic of Reactor Coolant System for BWR - Inside of the 1
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- B located below and encircling the drywell. The suppression chamber is held in i
place by supports that transmit operational, accident, and seismic loads to the reinforced concrete foundation slab of the reactor building. The drywell-to-torus vents are connected to a vent heeder that is located in the airspace of the pressure-suppression chamber. Projecting downward from the vent header are the downcomer pipes, which are nominally 24 inches in diameter and end approximately 3 feet below the water surface of the pool.
l In the event of a LOCA, reactor water and steam would be suddenly released into the drywell atmosphere. This is referred to as a blowdown. As a result of increasing drywell pressure, a mixture of drywell atmosphere, steam, and water would be forced through the vent system into the pool of water that i is stored in the suppression chamber. The steam vapor would condense in the suppression pool, thereby reducing the drywell pressure. Noncondensible gases and fission products would be collected and contained in the air space of the torus. The drywell atmosphere would initially be transferred to the suppression chamber and would pressurize the chamber. At the end of the blowdown, water supplied by emergency core cooling systems (ECCS) would spill l out of the break and rapidly reduce the drywell pressure. The suppression chamber would vent to the drywell through installed vacuum breakers to equalize the pressures between the drywell and suppression chamber. The ECCS would cool the reactor core and transport the heat to the water in the suppression chamber. Cooling systems are available to remove heat from the water in the j suppression chamber, thus allowing for the continuous removal of decay heat l from the primary containment under accident conditions following the initial ;
j deposition of energy to the suppression chamber from the blowdown, t
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- 5 .. n ATTACHMENT C TO RESPONSE TO PETITIONERS C-1 ENCLOSURE A to NUREG-0474 Summary of NRC Staff-Actions Related To The Technical Issues Identified In Dr. Hanauer's Memorandum of Seotember 20, 1972-l A. Concern: '
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"Like all containments the pressure suppression designs are required to include margins in capability. Experiments have been conducted by.
," GE and Westinghouse to establish the. rate of. steam generation that.can be accommodated. The pressure-suppression. pools, ice condenser, etc., j are then sized for the double-ended break steam flow, with margins for 4 unequal distribution of steam to the many modular units of.which the condenser is composed. The rate and distribution margins are probably adequate.
I More difficult to assess is the margin needed when applying the exper-imental data to the reactor design. Recently, we. have reevaluated -
the 10-year old GE test results, and decided on a more conservative interpretation than has been used all these years by GE (and accepted by us). We now believe that the former interpretation was incorrect. ')
using data from tests not applicable to accident conditions.
We are requiring an independent evaluation of the ice condenser design-and its bases to make less probable any comparable misinterpretation of this design."
Responses:
l Since this concern was expressed, add'tional tests, both domestic and foreign, of B and Marviken..{. pressure systems Computer codeshave whichbeen haveconducted, been and are e.g., 4-T, used being PSTF, to predict the contairunent pressure and temperature response of the BWR pressure suppression containment systems have been used to calculate the pressure response for these test facilities. The calculated values when compared to the test results have confimed the adequacy of the computer models. These comparisoris have been made by both the vendor and the NRC.M Consequently, the viability of the pressure suppression concept which a was originally demonstrated by testing perfomed in 1958 through 1962 ,
has been confirmed.
With respect to ice condenser containments, the NRC has developed com- l puter codes which are used to predict the containment's pressure response ;I l
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C -2 during postulated LOCAs. These codes are now being compared to i test data and the preliminary results of such es:parisons are that the adequacy of the current models has been confir9ed. Vendor's codes (Wespnghouse)havebeencomparedtotestsat.dhavebeen confirmed The margins applied for pressure suppression containment design have also been confimed by the additional test data that has become avail-able since 1972. These margins exist both in the basic design of the containment structure and in the analytical models used to predict the containment response. The experimental. data are no longer applied directly to determine the containment design requirements. !
I B. Concern: l
- Since the pressure-suppression containments are smaller than conven-tional " dry" containments, the same amount of hydrogen, formed in a [
postulated accident, would constitute a higher volume or weight percent- i age of the containment atmosphere. Therefore, such hydrogen genera-j tion tends to be a more serious problem in pressure-suppression contain- l I
ments. The small GE designs (both the light-bulb-and-doughnut and the over-under configurations) have to be inerted because the hydrogen l i
assumed (per Safety Guide 7) would immediately fom an explosive mix-l ture. The GE Mod 3 and the Westinghouse ice condenser designs (they have equal volumes) require high-flow circulation and mixing systems l to ensure even dilution of the hydrogen to avoid flammable mixtures in ene or more compartments (see following for an additional serious dis- i advantage of this needed recirculation and its valves). By contrast,-
the dry containments only require recombination or purging starting i weeks af ter the accident."
Resoonse Most Mark I BWR pressure suppression containments are currently required to be inerted as part of the measures for combustible gas (i.e., hydrogen) control following a '
postulated loss-of-coolant accident. This requirement resulted from the staff's assumptions regarding the amount of hydrogen generated and the magnitude of the lower limit of hydrogen flammability. However, in 1974 the Commission ruled that the technical issues related to inerting requirements should be resolved by way of rulemaking. Subsequently, a rulemaking proceeding was initiated which led to the development of a proposed change to the regulations, i.e. ,10 CFR 50.44, " Standards 4f for Combustible Gas Control System in Light Water Cooled Power Reactors."-
The revised assumptions in this proposed rgle and those specified in the Branch Technical Position, CSB 6-2,_/ woule pemit plants to de-inert where it can be demonstrated that the hydrogen concentration
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can be maintained below a combustible mixture. The analyses for Vermont Yankee indicate that most, if not all, plang/s could de-inert using the assterptions in the proposed 10 CFR 50.44-Those facilities with the Mark II pressure-suppression containment system design have not yet been licensed for operation. However, in light of the staff requirements specified in Branch Technical Position, CSB 6.2, we do not expect that inerting will be required for these facilities.
The Mark III BWR containment system and the PWR ice condenser contain-ment system have relatively larger volumes and do not require inerting j for combustible gas control. However, mixing systems are provided to take advantage of the total containment volume for dilution of hydro-gen. In the ice condenser containment design, the primary function of the mixing system is to assure long-term condensation within the ice bed. Staff positions were developed during the course of the review of ]
the first Mark III plant application (i.e., Grand Gulf the minimum design requirements for the and irging systemsg/which set to preclude the potential for excessive steam bypass- j 1
Although the time frame within which combustible gas control must be initiated is much shorter for a pressure suppression containment than for dry containments, it is still long enough to permit manual oper-ation and it occurs well after the initial blowdown transient.
C. Concern:
'All pressure-suppression containments are civided into two.(or more) major volumes, the steam flowing from one to the other through the con-densing water or ice. Any steam that flows from one of these volumes to the other without being condensed is a potential source of unsuppres-sed pressure. Weither the strength nor the leakage rate of the divider (between the volumes) is tested in the currently approved programs for initial or periodic inservice testing. Some effort is now underway to devise a leakage test, but none has so far been accomplished."
Response
With respect to the BWR pressure suppression containment systems, the l 1eakage of steam from the drywell directly to the suppression chamber airspace bypasses the suppression pool and could potentially result in an overpressurization of the containment. The maximum allowable by-pass leakage rate is a function of the size of the pggtulated loss-of-coolant accident. Facility Technical Specification include periMic I
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e r C -4 (approximately every eighteen months) testing requirements to monitor the bypass leakage rate. The tests are performed by pressurizing the drywell to one to two pounds per square inch greater than the suppres- ,
sion chamber and monitoring the rate of pressure decay. The pressure decay rate is then. correlatable to an equivalent bypass leakage area.
This test is conservative since all drywell leakage paths are inherently included in the test results while only a small por-tion of these paths contribute to bypass leakage.
In addition, most BWR operating plants with pressure suppression containments have been operating with a positive pressure differen-tial gtweenMaintaining the drywell and suppression this pressure chamberprovides differential since February a continuous 1976.-
monitor of bypass leakage and a verification of the status of the drywell to suppression chamber vacuum breakers.
With respect to the ice condenser containment design, a substantive amount of bypassing can be tolerated without exceeding design condi-tions. t.nalysis indica feet can be tolerated."g that This bypass is a largeareas of about area when 35 toto50 compared thesquare bypass area which can be tolerated for water pressure-suppression l systems (which varies between about .02 and 1 square feet) and, there-fore, less testing has been required. However, we do require both pre-and post-operational sting to confinn the bypass capability of each ice condenser plant The strength capacity of the "dividier" in the Mark I design is demon-strated by structural analysis of the vent system. The strength capacity of the " divider" floor in the Mark II design will be con-firmed by preoperational testing.
D. Concern:
"Because of limited strength against collapse, the " receiving" volume has to be provided with vacuum relief. In all designs except GE Mod Ill, this function is perfonned by a group of valves. Such a valve stuck open is a large bypass of the condensation scheme; the amount of steam that thus escapes condensation can overpressurize the containment.
Valves do not have a very good reliability record. Recent1,v, five of the vacuum relief valves for the pressure-suppression conti.inment of Quad Cities 2 were found stuck partly open. Moreover, these valves had been modified to include redundant " valve-closed" position indicators and testing devices, because of recent Reg concerns. Th's redundant position indicators were found not to indicatti correctly the particular partly open situation that obtained on the five failed valves. We have only recently begun to pay serious attention to these valves, so pre-T
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1 C-5 vious surveillance programs have not generally included them. The GE 1 Mod 111 design has an elegant water-leg seal that obviates the need for vacuum relief valves."
Response
Yacuum breakers are provided between the drywell and the suppression chamber to allow reverse flow back to the drywell following the ini- ;
tial blowdown transient. These valves are normally closed; however should any of these valves be open at the time of the a:cident, steam bypass could potentially result in an overpressurization of the con-tainment. Since 1972, staff positions were developed which required periodic testing and redundant position indication to. assure that excessive bypass leakage through the vacuum breakers would not occur.Ef Continuous monitoring of these valves is provided by the positive pressure differential between the drywell and suppression chamber.
Additional testing requirements also exist to demonstrate the i capability functions g- these valves to perform their vacuum-relief All of these testing requirements are included in the surveillance requirements contained in the Technical Specifications for each plant.
These testing requirements have also served as a basis for the develop-ment of maintenance programs to correct deficiencies in the valve position indicators. As a result of these independent maintenance programs, failures of the position indicators have been very infre-quent over the past several years.
i E. Concern:
"The high capacity atmosphere recirculation systems provided for hydrogen mixing involve additional valves which, if open at the wrong time, would constitute a serious steam bypass and thus a potential source of containment overpressurization. These valves are large, and must open quickly and reliably when recirculation is needed.
In other engineered safety features, no single valve is relied on for such service, yet redundancy has not been provided even for single failures, open and closed, of these valves. This is a serjous l i
mission, since opening at the wrong time leads to overpressurization, I while failure to open when needed inhibits recirculation."
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Response
This issue relates to the BWR Mark III containment system design.
In 1974, the AEC developed a position in conjunction with the review of the first Mark III BWR (i.e., Grand Gulf) which addresse th concern of large mixing system penetrations in the drywe111/ This e position included the following features:
- 1. Alternate mixing system designs were to be developed to limit the potential for bypass through large drywell penetrations.
- 2. Containment bypass capability'was to be increased to accessiodate single f ailures of the valves in the lines.
As a result of this position each Mark III applicant provided a mixing system design consistent with our position. The designs .
included the following features: small drywell penetrations; re- ]
dundant inlet and exhaust penetrations to assure a recirculation -
path; the use of two valves in series on each line to assure isola- '
tion capability; and an evaluation of the containment capability a odate bypass through an inadvertently open recirculation i
F. Concern: J l
"The smaller size of the pressure-suppression containment, plus the !
l requirement for the primary system to be contained in one of the two-volumes, has led to overcrowding and limitation of access to reactor )
and primary system components for surveillance and in-service testing."
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Response
Although. pressure suppression containment system designs are generally more crowded and less accessible than dry containment system designs, based upon the experience gained through our reviews of the Inservice Inspection and Inservice Testing (ISI/IST) programs whiGh have been submitted by licensees in accordance with the requirements of 10 CFR 50.55.a. only one significant BWR inspection-related accessibility problem has been identified, i.e., the beltline region of the reactor pressure vessel. This inaccessibility is a result of the vessel design, not the containment design.
The beltline region of PWR vessels can be inspected from the inside of the vessel because the core internals can be removed whereas this is not possible for BWRs. Augmented inspection of accessible l
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C -7 areas of BWR reactor pressure vessels and operating limits on reactor pressure and temperature compensate for this inability to perfom ISI.
l With the exception of the above-mentioned area, no other significant i inspection-related accessibility differences between PWR and BWR con-tainments have been identified.
G. Concern:
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" Separate shielding of components has tended to subdivide into compart-ments the volume occupied by the primary system. (Some compartment-tien of dry containment also occurs.) A pipe break in one of these compartments creates a pressure differential; each compartment must be designed to withstand this pressure. A method of testing such
{ designs has not been developed." )
Resoonse:
I The arrangement of structures internal to the containment differ between the Mark I/II containment system design and the Mark III containment design. The Mark I/IIs have fewer compartments than PWR dry containments because there is less need for radiation shielding. The Hark I/IIs are essentially inaccessible during normal plant operations, thereby requiring fewer structures for shielding.
The Mark III design for internal structures is generally comparable l to the PWR dry containment design.
For all designs, both dry and pressure suppression containments, we analyze the pressure response within compartments for postulated pipe breaks to eng/er g'g adequacy of the design pressure differential for compartments
' _ ' There ducted to verify analytical are p'r; going foreign tests being con-methods.l i
NRC and vendor codes are part of this program.
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