IR 05000293/1981037
| ML20154D935 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 03/10/1982 |
| From: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Jamarl Cummings, Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE), NRC OFFICE OF INSPECTOR & AUDITOR (OIA) |
| Shared Package | |
| ML20150E217 | List: |
| References | |
| FOIA-88-198 NUDOCS 8809160173 | |
| Download: ML20154D935 (208) | |
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i y e 'o,, ) UNITED STATES *b '# # e 8, ' o NUC'. EAR REGULATORY COMMISSION 431 PARK A ENUE
\+, # xiNo oP PRUSSIA, PENNSYLVANIA iM06 j
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....+,o EAR 101982 MENORANDUM FOR: Richard C. DeYoung Director, Office of InspectioV
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and Enforcement James M. Cuimmings, Director Office of Inspector and Auditor
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' FROM: Ronald C. Haynes, Regional Administrator, RI -
, SUBJECT: INVESTIGATION REP 0Tti 50-293/81-37; 10 CFR 50.44 - MATERIAL FALSE STATEMENT INCIDENT
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l The subject investigation report is scheduled for issuance on March 18, 1982. From the evidence developed during this investigation, we ;onclude that the incident does not appear to involve deliberateness , on the part of the Boston Edison Compan" nor its employees. Rather, the incident resulted from a lack of effective management of consuni-cations to the NRC.
As discussed, an advance copy of this report is forwardsd for your review. I plan to issue the report on March 18i please advise if you believe issuance is inappr@riate, c.K onald C. Haynes Regional .administ tor
Enclosure:
As stated J
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Docket No. 50-293 Boston Edison Company M/C Nuclear ATTN: Mr. F. President 800 Boylston Street Boston, Massachusetts 02199
Dear Mr. Staszesky:
By letter dated January 18, 1982 you were informed of the Notice of Violation and Proposed Imposition of Civil Penalties regarding the failure of Pilgrim Nuclear Power Station (PNPS) to comply with the requirements of 10 CFR 50.44 (Standards for Combustible Gas Control System in Light Water Cooled Power Reactors). In this letter we stated that an investigation was ongoing into the circumstances surrounding certain asoects related to this matter.
This investigation, conducted by Mr. R. Keith Christopher of the NRC Region I Office, has been completed. The purpose of the investigation was to determine the circumstances surrounding the material false statement contained in the
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BECo letter to the NAC dated October 19, 1979 regarding compliance with 10 CFR 50.44 and to determine why the NRC was not promptly notified of the information subsequently developed by the BEco staff which identified that some of the requirements of 10-CFR 50.44 had not been met.
Areas examined during this investigation are described in the NRC Region I Investigation Report which is enclosed with this letter. Within these areas l the investigation consisted of selective examinatiens of procedures and documents relevant to this issue, interviews of both present and former BEco employees, and the obtaining of sworn statements.
Based on our review of the facts, information, and sworn :tatements obtained during this investigation, we found that this evidence indicates that the false statement was not deliberately made and that the contrary information subsequently developed by the BEco staff was not intentionally withheld from the NRC. Rather, these items resulted from a lack of effectise management of BEco communications and notifications to the NRC. This findina does not mitigate the seriousness of this incident nor lessen our concern about the problems in the PNPS management and control of NRC regulated activities which were previously addressed in the Notice of Violatin and Proposec Imposition of Civil Penalties dates January 18, 1982. The inrormation develoned as a result of this investigation provided further insight into these p oblems.
While a specific response to this investigation report is not requirad, we expect that the information contained in this report will be examined and l considered when implementing the corrective actions you are taking in response I to the Order Modifying License Effective Immediately dated January 18, '982, 1
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Report No. 50-293/81-37
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Docket No. 50-293 , License No. DPR-35 Priority -- Category C Licensee: Boston Edison Company , 800 Boylston Street Boston, Massac,hytetts 02199 i Facility Name: P1) rim Nuclear Power Station Investigation At: Plymouth, Massachusetts; Boston, Massachusetts; Atlanta, , Georgia; New Orleans, Louisiana; Phoenix, Arizona
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Investigation Conducted: November 24,1981-January 7,1982 Investigator: Pin +})'l~&DJ }w 1/3/12 R. Keith Christopher, estigator date' igned 1 Approved By: / 4/4A J F Robert T. Carlson Director, Enforcement date/ signed and Investigation Staff Investigation Summary: Investication from November 24, 1981-January 7, 1982 (Report No. 50-293/81-37) i Areas Investigated: The investigation was conducted to determine the I circumstances surrounding the licensee's submittal of a letter to the NRC
dated October 19, 1979 which containsd an apparent material falso statement regarding the status of the Pilgria Nuclear Power Station's compliance with the requirements of 10 CFR 50.44, and to further determine if the licensee l intentionally withheld from the NRC information diveloped subsequent to its October 19, 1979 submittal indicating the Pilgrim Nuclear Power ) Station was in noncompliance with the requirements of 10 CFR 50.44.
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SUMMARY This investigation was initiated to determine the circumstances surrounding ' ' the submittal of a letter from the licensee to the Nuclear Regulatory Commission's Office of Nuclear Reactor Regulation (NRR) dated October 19, 1979 which contained an apparent material false statement pertaining to the
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status of the Pilgrin Nuclear Power Station (PNPS) compliance with the i
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requirements of 10 CFR 50.44, "Standards for Combustible Gas Control System , in Light Water Cooled Power Reactors." In this letter, the licensee stated it had conducted an analysis demonstrating that compliance with 10 CFR * :
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50.44 requirements had been met with existing plant equipment. This equipment
, ' consists of an existing standby gas treatment system and the drywell and '
torus purge and vent lines. Exhaust from both the torus and drywell is i routed to the main stack via the standby gas treatment system, and nitrogen ' makeup is supplied via the purge lines. This arrangement serves to control hydrogen concentrations by a bleed and feed method. Interviews of present and former licensee corporate and plant personnel (including the author of the letter) determined that no formal analysis had actually been conducted to support the statement of compliance made in the October 19, 1979 letter
, to NRR. The conclusion was apparently based on a purge analysis only in which the maximum offsite doses were estimated and compared with the dose guidelines of 10 CFR 100 but did not consider the requirements of 10 CFR 50, Appendix A, General Design Criteria 41, 42 and 43 as required by 10 CFR 50.44. Further, it was determined that following an October 30, 1979 request from NRR for the analysis referenced in the October 19, 1979 letter, an evaluation was prepared of PNPS compliance with 10 CFR 50.44. This
evaluation indicated PNPS was in noncompliance with 10 CFR 50.44 because a
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recent reactor habitability study had indicated that credit could not be taken for operator actions to satisfy the single failure and loss of power design criteria of General Design Criterion 41. This evaluation of PNPS
compliance was prepared by the licensee's Nuclear Engineering Department (NED) and was formally transmitted to the licensee's Nuclear Operations Department (N00) by internal memorandum on March 28, 1980. The NRC was not notified of the contents of this evaluation until May,1981 following an NRR telephone request asking the licensee to respond to the MRC letter of October 30, 1979 which originally requested the analysis. It should also , be noted that Ameneent 35 to the FNPS Final Safety Analysis Report (FSAR), ' dated January 28,1974, had already assumed for design purposes that the reactor building would be inaccessible for 45 days af ter a design basis loss of coolant accident (LOCA). Amendment 35 was submitted to the NRC as i a result of the regulatory staff's review of the FSAR appiteation and i subsequent conclusion that a combustible gas control system was required ! for the Pilgrim station. ;
\ ! Interviews of NED personnel determined that the analysis had been reviewed i i and approved by the NED Fluid Systems Division Supervisor and the NED 1
Manager prior to being transmitted to the N00. The NED personnel interviewed I i said it was their understanding that th'is evaluation had been submitted to i the NRC by the N00 Licensing Division. Interviews of N00 personnel responsible I i l l l I i l L - - _ _ - _ --- - - -_ l
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for responding to the NRC request for the analysis stated their position to be that the evaluation, as received by N00, was inadequate to support a statement of either compliance or noncompliance with 10 CFR 50.44. While the individuals interviewed denied intentionally misleading the NRC regarding ' the status of PNPS compliance with 10 CFR 50.44, they were unable to explain what happened to the evaluation after it was formally transmitted to N00 on March 28, 1980 or why these perceived inadequacies in the evaluation were i not resolved and the results reported to the NRC per its request of October : 30, 1979. All of the individuals interviewed regarding the reportability I of the results of the evaluation stated that, in retrospect, it was their ; opinion that the evaluation and its conclusions should have been reported to the NRC to identify a potential item of noncompliance. The licensee's ; ) management personnel opined that the occurrence was an oversight caused by i a lack of management control over the processing of HRC correspondence and i requirements and not an intentional attempt to mislead the NRC regarding the status of PNPS compliance with 10 CFR 50.44.
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g II. PURPOSE OF INVESTIGATION The purpose of this investigation was to determine the circumstances turrounding the Itcensee's submittal of a letter to the NRC dated October 19 2 1979 which contained an apparent material fals? statement regardf sg th,,. status of Pilgrim Nuclear Power Station's compliance w'th the requiresents of 10 CFR 50.44, and to further determine if the 'tcensee intensionally withheld from the NRC information developed subsiqant to its October 19, 1979 submittal indicating PNPS was in noncompliance with 10 "4: SP 44
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. l i III. BACKGROUNO l On August 25, 1971 the Atomic Energy Commission's Division of Reactor i Licensing (DRL) published the report of its Safety Evaluation (SER) of the ! application by BEco for a license to operate the Pilgrim Nuclear Power j Station (PNPS). Section 4.1.2 of the SER entitled "Containment Atmosphere Control" concluded that the licensee should provide a hydrogen control I system in addition to the purging system proposed by the licensee to maintain the concentrations of combustible gases below flammability limits. In response to this requirement, the licensee submitted, on January 28, 1974, Amendment 35 to its Final Safety Analysis Report proposing installation.of , the containment atmosphere dilution (CAD) system as a method to provide 1 redundant means of nitrogen supply to the containment. In Section !!!, l l "Design Basis", of. this amen i j would not be accessible for95 $nent, days itafter is assumed that the design the LOCA, basis reactorand building that
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the CAD and nitrogen makeup s!/ stems and their associated instruments / controls
. would be designed to allow remote operation from the main control room. l l However, by letter dated June 13, 1974 to the AEC's Ofrectorate of Licensing i the licensee advised that it had suspended work on the CAD system as described l
- in Amendment 35 pending issuance of the revision to Regulatory Guide 1.7, j
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"Control of Combustible Gas Concentrations in Containment Following a Loss- 1 of-Coolant Accident", then under consideration by the AEC, following which the proposed CAD system would be reevaluated and modified as appropriate. ,
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In September 1976 Regulatory Guide 1.7, Revision 1, was issued for coseent t and Revision 2 was issued in final status in November 1978. On October 27, . 1978,10 CFR 50.44 was published and became effective on November 27, 1978. ! 10 CFR 50.44 required that a means be established for control of hydrogen gas that may be generated following a loss of coolant accident. Additionally, ! all BWR/PWR power reactors fueled with cylindrical zircaloy clad oxide l pellets were to have the capability to (1) measure hydrogen in the containment, !
(2) insure a mixed atmosphere, and (3) control combustible gas concentrations.
For facilities in which the notice of hearing on the application for a ; construction permit was published before December 22, 1968 (as is the case ' for PNPS), a purging system is an acceptable means provided it could be l , shown that the combined radiation dose at the low population zone outer i boundary met the dose guidelines of 10 CFR 100 and it could be shown that ]
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- the purging system was designed to conform to the general requirements of 10 CFR 50, Appendix A, General Design Criteria 41, 42, and 43.
By letter dated March 14, 1979, the Itcensee was reminded that Regulatory Guide 1.7, Revision 2, was issued in final status in November 1978 and was requested to subelt within 60 days a schedule for installation and testing
. of the CAO System, the work on which had been suspended in 1974 untti j Regulatory Guide 1.7 was issued. In a response dated June 6, 1979, the licensee advised that it no longer intended to install the CAD system and 1 stated its intent to retain the inert containment atmosphere while a system that incorporated hydrogen recombination was evaluated. Furthermore,
) the licensee advised that a summary description of the proposed system and t prop,osed schedule of implementation would be submitted by September 15, i 1979.
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In a letter to NRR dated October 19, 1979, BEco confirmed the CAD system would not be installed, requested deletion of Amendment 35, and further stated that based on analysis, PNPS met the requirements of 10 CFR 50.44 with existing equipment.
By letter dated October 30, 1979, NRR requested the Itcensee to submit within sixty days the analysis referenced in the October 19, 1979 letter which demonstrated conformance with 10 CFR 50.44. This request was not responded to until June 15, 1981 when the licensee provided an evaluation dated March 28, 1980. This evaluation was stated to be the documented basis for the Itcensee's letter of October 19, 1979. However, none of the documentation submitted demonstrated'that an analysis had been performed prior to the October 19, 1979 letter to support the conclusions contained in that letter. The evaluation of March 28, 1980 stated that all 10 CFR
- 50.44 requirements were not met with existing equipment in that, as a result of a .TMI-related reactor habitability study, it was determined that local operator action could not be credited to satisfy the single failure and loss of power criteria of 10 CFR 50, Appendix A, GDC 41. On June 16, 1981, the 1;censee submitted Licensee Event Report No. 81-021/01X-0 formally notifying the NRC of PNPS noncompliance with 10 CFR 50.44.
Subsequently, the licensee conducted from June 15, 1981 to July 16, 1981 an internal investigation regarding this incident. This licensee investigation did not reveal any wilfull intent to not comply with 10 CFR 50.44 or to not i report the noncompliance with this regulation after it was identified. ~ The investigation identified inadequate management controls over the work management systems, inadequate multidisciplinary reviews within the nuclear organization associated with the respo'nse to 10 CFR 50.44 and various other management related deficiencies that contributed to the failure to comply with 10 CFR 50.44
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g IV. DETAILS This portion of the report is prepared in two parts (Section A and Section B) to report independently on two aspects of the investigation. Section A addresses the results of the investigation into the circumstances surrounding the licensee's submittal of the letter dated October 19, 1979 (BEco letter No. 79-207) which contained an apparent material false statement to the effect that PNPS met the requirements of 10 CFR 50.44 with existing plant equipment.
Section B addresses the results of the investigation to determine if the licensee intentionally withheld from the NRC an evaluation dated March 28, 1980 that concluded that PNPS was in noncompliance with 10 CFR 50.44.
A. EVENTS LEADING TO SUBMITTAL OF BECO LETTER NO. 79-207 0F OCTOBER 19 1979 1. Sequence of Correspondence Concerning 10 CFR 50.44 a. In response to the AEC Regulatory staff concerns raised over hydrogen generation in the containment following a loss of coolant accident and discussed in the FNPS Safety Evaluation
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Report, the licensee submitted Amendment 35 to the PNPS FSAR on January 28, 1974 proposing installation of the containment atmosphere dilution (CAD) system as a method to provide redundant nitrogen supply to the containment. The system was to be designed to assure control of combustible gas concentrations by maintaining oxygen concentrations below 5%. b. On June 13, 1974, the licensee advised that work on the CAD system as described in Amendment 35 was being suspended until Regulatory Guide 1.7, which would delineate methods of control acceptable to the NRC, was finalized.
c. In September 1976, Regulatory Guide 1.7, Revision 1, was issued for comment.
d. In November 1978, Regulatory Guide 1.7, Revision 2, was issued in final status, e. On November 27, 1978, 10 CFR 50.44, "Standards for Combustible Gas Control Systems in Light Water Cooled Power Reactors," became ef fective, f. On March 14, 1979, the Nuclear Regulatory Commission's Office of Nuclear Reactor Regulation (,NRR) issued a letter to Mr. G. Carl Andognini, Manager, Nuclear Operations Department, BEco, which reminded the licensee that Regulatory Guide 1.7 was in final status are requested the licensee to submit within 60 days a schedule for installation of a
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' previously committed to CAD system in order to meet the requirements thht PNPS have a hydrogen control system.
. g. On June 6,1979, the licensee responded by letter to this ; request stating "Our current plans do not call for the i installation of a CAD system. We intend to retain the 1 present inerted, contairment atmosphere requirements, and we !
. are evaluating a system that incorporates hydrogen recombination capb111ty.... We will submit a summary description of our proposed system and our proposed schedule of implementation by September 15, 1979." ,
h. On October 19, 1979, the licensee, over the signature of Mr.
' Paul McGuire, PNPS Plant Manager, submitted to NRR BEco letter No. 79-207 which cot:f reed that the CAD system would not be installed and requested that Amendment 35 to the PNPS I FSAR be deleted from the docket. This document also stated
the following with respect to 10 CFR 30.44:
, "To determine what changes are currently required for l '
l post LOCA containmee combustible gas control, we have l
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evaluated the present statt .a design with respect to 10 : l CFR 50.44. Based upon our < M ysis, we comply with 10 i CFR 50.44 with existing equi,mt."
, INVESTIMTOR'S NOTE: This letter was signed by Mr. Paul l McGuire, PNPS Plant Manager, in the absence of Mr. G. Carl Andognini, BEco Nuclear Operations Superintendent. l 2. Interview of Author of the BECo Letter No. 79-207 dated October 19. 1979 l Mf. Howard Steinan, Senior Chemical Engineer, SEco, was interviewed I on December 3,1981 by the reporting investigator. In a sworn
, statement, Stetaan acAnowledged preparing BEco letter Fo. 79-207 i
- of October 19,1979 while assigned to the Nuclear Engineering i Department and also acknowleged that at the time of the submission .
of the letter to tht NRC there was no formal analysis done to i ' support the stateselt of compliance. He explained that the i
statement was made cased on a limited inforval analysis in which l I offsite dose assestments were compared to doso guidelines of 10 ! l CFR 100 and that the practicalities 9f reactor butiding accessibility i 1 and operator habitability were not considered. Also, he said ' i that at that stee ce was not aware that Amendment 35 assumed the ' i reactor building would not be a:cessible af ter a design basis !
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loss of coolant accident. Steinen denied that there was any ' ) intent on his part to mislead the NRC regarding the status of PHPS compliance with 10 CFR 50.44, and stated that at the time he l 3 ! prepared the letter he believed the station was in compliance '
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with 10 CFR 50.44 based on the informal analysis he had done. !
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! Steinan also stated that if he had done a proper analysis at the time he would have realized the plant was not in compliance, and r
' said he would have stated as much at the time. Steinan said that the draft of the October 19, 1979 letter was reviewed by his in final !
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supervisor form, from the (Mr.
Nuclear Wayne Merritt) Department Engineering and was then forwarded,(Stephen Manager l 1 Rosen) to the Nuclear Operations Depa*tment. Steinan said he was !
! not queried by anyone from the BEco staff either from N00 or NED i l . regarding the contents of the October 19, 1979 letter and its ;
J statement of compliance with 10 CFR 50.44. The sworn statement l ] of Mr. Steinan is appended to this report as Exhibit (1). . I l I 3. Interview of Mr. Wayne Merritt. Former Fluid $ygtens Division i a Supervisor. NED I ! 1 Mr. Merritt was interviewed by the reporting investigator on j December 8,1981. He confirmed that during the time period in l
- question he was the supervisor of Mr. Howard Steinan in the Fluid !
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$> stem Division of the BEco Nuclear Engineering Department, j ! Merritt also noted at this time that he is no ' onger employed by - ! the licensee. Merritt said he reviewed Steinan's draft of the j '
October 19, 1979 letter. He said that at the time the primary , 2 criterion for the statement of compliance was the acceptable results of the offsite dose rate assessments per 10 CFR 100 rather than a , a point by point analysis of compliance with 10 CFR 50.44 requirements. '
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Merritt acknowledged that this analysis w6s inadequate and did not consider operator habitability in reference to satisfying the i single failure and loss of power criteria of 10 CFR 50, Appendix ; ! A, GOC 41. Merritt recalled that at the time he was confused as i j to what direction the combustible gas issue was going in light of .
the TMI esperience and he felt that the post TMI standards would : i be such more stringent than the present 10 CFR 50.44 requirements. I Hirritt concluded that he did not, nor did he believe that anyone l i involved in the preparation and review of the October 19, 1979 . 1 letter, intend to decahe the NRC with respect to the status of ' ! PNP $ compliance with 10 CFR 50.44. The sworn statement'of Mr.
I Merritt is appended to this report as Exhibit (2).
I l 4. Interview of Mr. Stephen Rosen. Former Nuclear Eneineerine Deoartment ! i Manacar ! i Mr. Rosen was interviewed on December 15, 1981 by the reporting ! investigater. Rosen advised he is currently the Director of j Analysis for the Institute of Nuclear Power Operattens (!NPO) but
- l that during the time period in question he was Manager of the NED for Boston Edison Company. In a sworn statement, Rosen said he i did not recall reviewing an analysis or documentation to support j the statement of compliance Twith 10 CFR 50.44 in the October 19,
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1979 letter to NRR. Rosen said normally he would not have reviewed 1~ l documentation of this nature unless specifically requested to do l
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, so. He said that since he did not review or request the analysis, I he was not aware of the fact that an analysis to support the I i statement of compliance in the October 19 letter was not formally l
- documented nor was he aware of what the conclusion of compliance was based on. Rosen said he.spproved the letter and its transmittal [
to the NGO based on the "great sheet review" for NRC correspondenct
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i which indicated that Mr. Wayne Merritt had already approved the l document and its contents. Rosen denied that there was any l
intent on the part of NED personnel to mislaad the NRC with , i respect to the status of compliance with 10 CFR 50.44 at PNPS, L i and conjectured that an inadequate "green sheet review" by both ! j NED and N00 personnel contributed to the incident. The sworn' i statement of Mr. Rosen is appended to this report as Exhibit (3). . j
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INVESTIGATOR'S NOTE: The d green sheet review" refefred to by Mr. i l Rosen is a sign off process (per N00 Procedure 6.03, Control of i NRC Correspondonce) that is utilized to insure that all the
. cognizant sanagers review important correspondence before it is i
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1 5. Interview of Nuclear Operations Department Personnel involved In I j - Green Sheet Review of BEco Letter lo. 79-207 _of October - 19. 1979 i a. Mr. James Keyes. Senior Licensino Enaineer. N00, was interviewed :
on December 9, 1981 by the reporting investigator. He said I - his responsibility with respect to the document was to
,' insure that the letter as drafted by NEO was in proper j format and to insure that the green sheet review was carried l out within the N00. He said he accepted as fact that the NED l , had an analysis to support the statenant of compliance in i i
the letter of October 19, 1979 and did not question what ; type of analysis was done or what the basis was for the ! conclusion that PNPS was in compliance with 10 CFR 50.44. .
! The sworn statement of Mr. Keyes is appended to this report l asExhibit(4). ! ! b. Mr_. Edward Ziemianski, Management Services Group I.eader was 1 interviewed by the reporting investigator on December 2, .
i 1941. Zionianski advised that during the time period in l
! question he held the position of Plant Support Group Leader !
I and as such was involved in the activities pertaining to the i l issue of compliance with 10 CFR 50.44 including the Licensee's ' i letter No. 79-207 of October 19, 1979. With respect to that l
! letter, Ziemianski said he would not have questioned whether I j or not the analysis referred to in the letter actually l existed, nor would he have attempted to determine the details I ) of such an analysis that led to the conclusion of compliance (
l with 10 CFR 50.44. He said his sign off on the green sheet i review would primarily have been based on the fact that the
! analysis was already approved by the NED Manager (Stephen }
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Rosen). Ziemi.anski said that after reviewing the letter he , would provide i'c to the Licensing Division of N00 for development into a formal letter for signature prior to it being sent to ~ the NRC. Ziemianski concluded that he did not believe there was any inten i.o mislead the NRC regarding compliance with ' 10 CFR 50.44, and attributed the incident to an inadequate , management review of the letter prior to submittal to the ' NRC in addition to confusion as to what would actually be , required to meet the requirements of combustible gas control I in light of the TMI experience. The sworn statement of Mr.
1 Ziemianski is appended to this report as Exhibit (5). - c. Mr. Paul J. McGuire, former Plant Manager. PNPS was interviewed
- by the rt. porting investigator on December 16, f931. McGuire adyised that he is no longer employed by the Boston Edison
! Company but confirmed he was the Plant Manager at PNPS j during tha time period in question. In a sworn statement, ;
l Mr. McGuire said he signed BECo letter No. 79-207 of October i
- 19, 1979 documenting compliance with 10 CFR 50.44 in the
- absence of Mr. Carl Andognini, the Manager of Nuclear Operations.
) . McGuire said that at the time he signed the letter he was
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not aware of the basis for the analysis referred to in this letter and was not aware that PNPS was actually in noncompliance l with 10 CFR 50.44. McGuire said that at that time he wasn't ' 4 specifically aware of what 10 CFR 50.44 was, but signed the letter based on the fact that the green sheet review indicated 1
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previous acceptance of the document by the NED Manager, the l Plant Support Group Leader, and the Licensing Engineer.
McGuire concluded that, with respect to the preparation of )
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this letter, he had no reason to believe there was any intent to willfully mislead the NRC regarding the status of
.apliance with 10 CFR 50.44. The sworn statement of Mr.
'<Guire is appended to this report as Exhibit (6).
6. Interviews of Additional Present and Former BEco Management Personnel . Pertaining to_ the Circumstances leading to the Submittal of BECO Letter No. 79-207 of October 19. 1979 l a. Mr. John Fulton. Senior L.icensino Ennineve. N00, was interviewed j on December 1, 1981 by the reporting investigator. In a
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sworn statement, Fulton said he was not directly involved in j a review of the October 19, 1979 letter untti subsequent to its submission to the NRC and was not aware of what the
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basis was for the statement that PNP 5 was in compliance with I 10 CFR 50.44. He said his subsequent inquiries determined that there was no formal analysis conducted to document l compliance with 10 CFR 50.44 prior to the submittal of the
! October 19, 1979 letter to NRR. Fulton said he made this i determination as a result of discussions with the aut'or of i
the letter (Howard stetaan). Fulton also opined that I l i j l l I I
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operator accessibility to the reactor building to satisfy the single failure and loss of power criteria of GDC 41 was not considered in the October 19, 1979 letter. Fultpn said , that prior to its transmittal to N00, both Wayne Merritt
- (Supervisor of Fluid Systems) and Stephen Rosen (NED Manager)
should have reviewed the analysis for acceptability. The sworn statement of Mr. Fulton is appended to this report as r
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Exhibit (7). i b. Individual A, who requested confidentiality, was interviewed by the reporting investigator on December 8,1981. With,
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' respect to the October 19, 1979 letter, Individual A said he i had ao direct involvement in the preparation of that letter; ; j however, an offsite dose calculation was done under his ' j direction during this time frarse to substantiate thu following ! a containment venting, PNPS3 woJ1d remain within the dose guidelines of 10 CFR 100. Individual A opined that tnis was
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i i the "analysis" referred to in the October 19, 1979 letter to i NRR. He concluded that prior to the submittal of the ' October 19, 1979 letter he was not requested to provide any ! further information or analysis data with respect to 10 CFR i - 50.44 and further opined that he had no reason to believe I that anyone intended to mislead the NRC with respect to 10
' : CFR 50.44 compliance. The sworn statement of Individual A is appended to this report as Exhibit (8). i c. Mr. G. Carl Andegnini, fortner Superintendet. Nuclear Operations !
Department was interviewed on December 17, 1981 by the reporting investigator. Prior to beginning the interview,
'
Andognint requested that his sworn statement regarding this issue be withheld from the public record.
' Andognini stated he was absent from work during the time in which the October 19, 1979 letter was being reviewad for i
'
transmittal to the NRC. However, he stated that had he seen the letter and read its content he would not have questioned
l the analysis referred to in the letter or its conclusion of compliance with 10 CFR 50.44. Andognini said he would have checked the green sheet for the other management reviews and had he seen the concurrence of the NED management on this review sheet he would have signatured his approval based on
his reliance of the prior approvs1 of the NED Manager.
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Andognini stated that he was not aware that PNPS was not in coepitance with 10 CFR 50.44 nor did he have any reason to
believe that the letter of October 19, 1979 was intended to deceive the NRC regarding the actual status of compliance i 1 with 10 CFR 50.44 at the time it was submitted. A sworn a
/ 1 statement was obtained from Mr. Andognini but is being l
withheld from this report per his request.
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g i d. Mr. J. Edward Howard. Vice President - Nuclear was interviewed on December 3, 1981 and on January 7, 1982 by the reporting investigator. In a sworn statement, Howard said that at the ' time BEco letter No. 79-207 was submitted to the NRC stating . PNPS compliance with 10 CFR 50.44 he was not personally aware of the basis for the statement of compliance and did ! not* know what analysis was done to reach that conclusion. - 1 He said he was not involved in any discussions or review , I processes involving the issue of 10 CFR 50.44 compliance. L
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Howard said that through subsequent inquiries he has determined l that there was no formal analysis as indicated in the letter !
- of October 19, 1979 that would justify the statement of i compliance with 10 CFR 50.44. Howard coassented that this c j was a situation which in his mind was completely unacceptable. l Howard opined that the problem arose on this requirement !
>
because of difficulties in trying to distinguish between the 10 CFR 50.44 criteria and the post TNI requirements which
! were believed to ultimately require a strit.ter standard than that previously permitted by 10 CFR 50.44. Howard said that il he did not believe anyone knowledgeable of the October 19, ,
i 1979 letter intended to mislead the NRC as to the actual
*
status of compliance with 10 CFR 50.44, and concluded that an inadequate management review of the October 19, 1979 letter permitted this document to be transmitted to the NRC.
The sworn statement of Mr. Howard is appended to this report as Exhibit (9).
. 7. Document and procedure Review a. Regulatory Guide 1.7. Revision 2., provides an analysis of i hydrogen evolution following a postulated loss of coolant J accident. This analysis also provides parameter values for 3 assessing the radiological source term. This source term is 4 based on the fission product distribution model values i
..ated in the Regulatory Guide and these are consistent with
, the values stated in 10 CFR 100.11.
> ' b. Amendment 35 was submitted to the NRC on January 28, 1974 to I supplement and amend the PNPS Final Safety Analysis R6 port { (FSAR). This amendment (which the licensee requested be j deleted from their docket in the October 19, 1979 letter) 1 provides a description of the means and controls to be d provided by PNP 5 to limit combustible gas concentration in the containment following a design basis loss of coolant accident. It was noted that Section !!!, "DE5!GN BASIS." of , this document states the following:
j "For design purposes it is assumed that the reactor
- building will not be accessible immediately after the j
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postulated design basis LOCA but will be accessible 45 days later with a postulated dose rate of 760 mR/hr whole body and 10 R/hr thyroid."
"The CAD and Nitrogen Makeup Systems and their associated instruments will allow remote operation, calibration and test from the main control room." - i c. During reviews of various BEco office memoranda related to 10 CFR 50.44, an interoffice memorandum dated October 17, 1979 was found that was addressed to the author cf the . October 19, 1979 letter (H. Steinan). This memorandum contains an analysis entitled "Reactor Building Maintenance following a Design Basis Accident" that states "The only complete dose rate study for the reactor building is for airborne activity.
Based on this dosage, access to the Reactor Buildina prior
-
l to 30 days for maintenance is lioT7easible." This memorandum
'
Is Upended to this report as ERibit (10). 1
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INVESTIGATOR'S NOTE: The author of the October 19, 1979 letter (Howard Steiman) was questioned as to whether this information was a factor in his conclusion as to compliance with 10 CFR 50.44. Steiman stated his original determination of compliance was based on taking credit for local operator
'
action and the information contained in these two documents (Amendment 35 and the memo of October 17,1979) was not
,
considered. Steinan dio not recall the specific purpose for l his receipt of the memorandum of October 17, 1979 but conjectured l tt was in reference to a study he was conducting regarding post accident sampling.
' ! d. Nuclear Operations Denartment Procedure No. 6.03. Control of NRC Correspondence, establishas qcthods for the control of cr.rrespondence between the Nuclear Operations Department
(N00) and the Nuclear Regulatory Cosnission regarding the
! licensee's operational nuclear power plant. Table 6.03-A in ! I that procedure establishes review responsibilities of submittals i to the NRC as follows: ,
(1) Nuclear Operations Manager *
Reviw for - interface with other activities, operations parsonnel coenitments, policy considerations and cost / ; benefit.
(2) Muclear Engineerina Manager
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Review for - factual content, engineering acceptability.
engineering personnel commitments, interface with other activities, cost / benefit. Performs and/or reviews safety evaluations. ;
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! (3) Station Manaaer and Station Organization l Review for - factual content, effect on station operations, i station personnel cosuiitment, interface with other ! ;. activities. j (4) Plant Support Group Leade_t , >
l Review for plant support group personnel commitments, ! interface with other activities, factual content, ! I i proper review and followup assignment. '
;
a .
! (5) Licensino Encineer l i
I 1 Review for - interface with other activities, schedules, ' I regulatory requirements, followup responsibility. f (6) Vice president - Nuclear l Review for - company policy, cost / benefit, organizational ! commitment. j ) , B. EVENTS SUBSE0 VENT TO THE SU8MITTAL OF BEco LETTER NO. 79-207 l l I , OF OCTOBER 19. 1979 i . j 1. Secuence of Cornspondence Concernina 10 CFR 50.44 j a. In response to the licensee's letter of October 19, 1979, I whenin the licensee documented compliance with 10 CR 50.44 with existing equipment, the Division of Operating Reactors, WRR, requested by letter dated October 30, 1979 that the licensee submit within 60. days an analysis of the existing
- equipment which demonstrated conformanes with 10 CR 50.44. !
J The analysis was to include sufficient dotati to enable NRR I to evaluate compliance with respect to 10 CR 50 Appendix A,
.
Criteria 41, 42, and 43.
b. The licensee's formal response to this request was received , via IEte letter No. 81-127 dated June 15, 1981. Enclosure A i , to this letter contained an evaluation of pnp 5 compitance I
'
with 10 CFR 50.44 - This evalustion, da'mf March 28, 1980, was stated by the licensee to be the evaluation which documented I the basis for the October 19, 1979 letter. Enclosure B to i the June 15, 1981 letter contained what the licensee described j as "...the detailed evaluation of said compliance performed I subsequent to discussions with you and members of your staff l to nspond to your letter of October 30, 1979. The results l of this recently performed evaluation demonsv, rate that though rapid access for brief periods of time is possible, the calculated upper limit dose rates may preclude personnel ! i r
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access for the extended periods of time protected as necessary ! to perform equipment maintenance to assure the single failure
- criterton is satisfied." The licensee further advised in ;
d this document that "the system modifications which would i have resulted from this awanness were in fact developed and ;
- installed during the 1980 refueling outage as a nsult of i the lessons learned from TMI." c
! 1 '
The introduction to the licensee evaluation of 10 CR 50.44 i
'
dated March 28, 1980 states: l
'
l "Compliance with 10 CFR 50.44 depends on maintaining ,
- combustible gas control while meeting the dose !
requirements of 10 CR 100 for post accident . i cases, and meeting General Design Criterion (GOC) 41, GDC 42, and GOC 43." , l I
! This evaluation further states: l l "This analysis is the basis for the conclusion in l *
Refennce (a) that P11 grin meets 10 CR 50.44 with existing equipment. Subsequently, it was found i that one of the assumptions in Reference (a) was l l' incorrect. It was assumed that local operator l
, action could be used for satisfying single failun and loss of power design critera. A recent Reactor l 1 Building habitability study, a nsult of the TMI ;
j Lessons Learned implementation efforts, has demonstrated i j that the Reactor Suilding may be inaccessible i j after an accident. The Reactor Su11 ding area dose i i rates may be too high to permit personnel entry, 1 Secause timely operator access for local action cannot be guaranteed, all 10 CR 50.44 nquinments are not met with existing equipment."
. I This evaluation was fot n .11 transmitted to the Nuclear Operations Department Manager via NED memorandum 80-404 dated March 28, 1980 over the signature of the NED Manager (Stephen Rosen). This menerandum indicated that the analysis was previously provided to the N00 on February 22, 1980. The NED memorandum 80-404)is appended to this report as Exhibit (11)(. > IWESTIGATOR'S NOTE: "Reference (a)" in the above paragraphs rePers to Itcensee letter No. 79-207 of October 19, 1979.
2. Interview of Author of Licensee 10 CFR 50.44 Evaluation dated
Farch 28.1980 -- { I l I l l \ l
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Mr. Howard Steiman, Senior Chemical Engineer, said that after the BECo Licensing Division received the request for the analysis to ' support compliance with 10 CFR 50.44, he was assigned by his .
! supervisor (Wayne Merritt) to prepare a formal analysis to demonstrate !
, compliance with 10 CFR 50.44. Steinan said that in this analysis t ' h6 reached the conclusion that PNPS was not in complianew with 10 !
- CFR 50.44. Steiman said he based his conclusion on the results !
' of a recent reactor building habitability study which was performed as a result of the TMI Lessont, Learned effort. According to !
' .
Stetaan, the study concluded that because of high area dose rates
'
in the reactor building, local operator action could noc be . .
. credited for satisfying the single failure and loss of power i i design criteria of 10 CFR 50, Appendix A, GDC 41. - :
Steiman said he prepared several "rough drafts" of this evaluation , ! which were distributed to both NED and NOD personnel for review I and comment. He said his first draft was distributed for review in the early part of November 1979. He also stated that the ' final version of this evaluation, which was approved by his
,
supervisor and the NED Manager prior to being formally transmitted I
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to N00, reiterated his conclusion that PNPS was not in compliance l with 10 CFR 50.44. Steiman said he received no further questions : on the evaluation after it was transmitted to the N00. He also ! said that he was not a party to any discussions regarding the l necessity of reporting noncompliance with 10 CFR 30.44 to the l NRC. He concluded that he did not believe there was an attempt to withold this information from the NRC as auch as there was an issue to formulate a valid and correct analysis prior to making 1 a decision as to whether or not PNPS was in compliance with 10
CFR 50.44. Mr. Steiman's sworn statement is appended to this j report.as Exhibit (1).
1 3. Interviews of present and Former NED Personnel Involved in preparation of 10 CFR 50.44 Evaluation dated March 28. 1980 j ' a. Mr. Wayne Merritt, former Supervisor. Fluid Systems Division, said that af ter receipt of the NRC request for the 10 CFR ~ 50.44 analysis in support of BEco letter No. 79-207 of October 19, 1979, ha assigned Mr. Steinan the task of preparing a formal analysis to support the October 19, 1979 letter. ~ Merritt said Steinan initially assumed credit for operator
,
action to satisfy the single failure and loss of power i criteria of 10 CFR 50 Appendix A GDC 41 but as a result i of the TMI related reactor building habitability study he ! learned that the reactor building would be inaccessible l because of high dose rates. Merritt also said it was his , recollection that Mr. Ziemianski (Plant Support Group Leader),
N00, had informed Steinan that Amendment 35 to the FSAR had l alresdy made this assumption even without the TMI dose rate i ) information. Therefore, the conclusion was reached within ' } NED that PNPS was not in compliance with 10 CFR 50 44 J l I '
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According to Merritt, the conclusions of this evaluation were initially reported to the N00 on February 22, 1980 and that same evaluation was formally transmitted to the N00 Manager on March 28, 1980 over the signature of the NED Manager (Stephen Rosen).
, Merritt also stated that at the time of the transmittal to N00, both he and Mr. Rosen concurred with Steiman's conclusion regardir; l the status of compliance with 10 CFR 50.44. He.also stated that 1 when the evaluation was transmitted to NOD over Mr. Rosen's 1 signature on March 28, 1980, he (Merritt) assumed that this l analysis was to be forwarded to the NRC. According to Marritt, '
'after the evaluation was sent to N00, he received no fur,ther l comments or questions on the evaluation and assumed that it was acceptable. Merritt concluded by stating that he was not aware of l any discussion that occurred within either the NED or the N00 regarding the issue of reporting noncompliance, and that the responsibility for reporting noncompliance rested with the Licensir@
Division within N00. Mr. Merritt's sworn statement is appended to this report as Exhibit (2).
b. Mr. Stephen Rosen, former Nuclear Engineerina De partment Manager 1 said that as the NED Manager he approved the 10 CR 50.44 evaluation
-
that was transmitted to N00 on March 28, 1980, and that at the , time this evaluation was transmitted, it was his expectation that l the analysis would be forwrded to the NRC by the N00 Licensing ! Division. Rosen said he recalled no discussions taking place 1 with N00 regarding the validity of the evaluation done by Steiman, and said he was not a party to any discussions in which the l subject of reportability of noncompliance with 10 CFR 50.44 was 1 ] discussed. ! , Rosen said that, as noted in the transmittal memorandum dated I . March 28,1980, he was of the opinion that the evaluation's l conclusions were reportable to the NRC. He also clarified that,
per BEco policy, communications with the NRC were the responsibility , of the Licensing Division of the N00. Rosen concluded that to ! the best of his knowledge there was no request from the N00 for uy further review of the conclusions reached in the 10 CFR 50.44
evaluation after it was transmitted to the N00 on March 28, 1980 i over his signature. Mr. Rosen's sworn statement is appended to , this repor t as Exhibit (3).
c. Individual A stated that the reactor building habitability study referred to in the 10 CFR 50.44 evaluation prepared by Mr. Steinan , was conducted under his direction pursuant to the requirements of l NUAEG-0578, Section 2.1.6b (Design Review of Plant Shielding of
!
i Spaces for Post Accident Operations). Individual A said the purpose of this analysis was to determine areas in which shielding
,
modifications would be required to enhance operator accessibility
! to plant systems after an accident. Individual A said he first j became aware during the latter part of 1979 that 10 CFR 50.44 ,
i
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i compliance relied on taking credit for local operator action, and i that this created a conflict with the results of the reactor
- building habitability study.
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Individual A recalled that at the time, he reviewed Steinan's evaluation of 10 CFR 50.44 at the request of the NED Manager, and ' was in agreement with the conclusion stated in that evaluation l l that indicated operator access may not be available to satisfy l the single failure and loss of power criteria of 10 CFR 50, l l
, Appendix A, GOC 41. According to Individual A, modifications as f
- recommended in the habitability. study were implemented a,t the ;
direction of the N00 and NED Managers. Individual A also said i~t t was his understanding that when the 10 CFR 50.44 evaluation was i j transmitted to N00 on March 28, 1980, it was comnleted and accepted
! by the Nuclear Operations Department and it was his assumption l
,
I that this evaluation would be submitted to the NRC by the N00 l
!
Licensing Division. Individual A concluded that he did not l believe there was any intent on anyone's part to withhold or j provide false information to the NRC regarding the status of ! compliance with 10 CFR 50.44 for the purpose of benefiting Boston Edison Company. However, he could provide no logical explanation '
; -
as to why this evaluation and its identification of apparent , . noncompliance was not reported to the NRC. Individual A's sworn ! I statement is appended to this report as Exhibit (8).
) 4. Review of BEco Shieldino Review Report (Reactor Buildina Habitability , Study) l l This shielding review was prepared and completed in January 1980 as i part of the reactor building habitability study conducted in response to the requirements of Section 2.1.6b of the NRC's NUREG-0578, "TMI-2 Lessons learned Task Force Status Report and Short-Tera Reconseendations."
, This review was directed towards identifying the locations of vitai j areas and equipment in spaces around systems that may, as a result of j aa accident, contain highly radioactive materials. The objective of
; this review was to determine areas where personnel occupancy might may ! be unduly limited and safety equipment unduly degraded by the radiation j fields during post accident operation of these systems.
l Section 3 of the licensee's report, entitled "Plant Accessibility and ! Recommended Modifications", reached the following conclusion with i respect to reactor building accessibility: l 'A review of personnel accessibility to the reactor buildin , indicates that entry to most areas will be practically prec uded j for the first 30 days following the postulated accident due to j high radiation fields. Maintenance during this time period on plant systems necessary for cold shutdown would be severly limited under present conditions... ] l i i
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...In the event of a postulated single failure, operator action ;
to position certain valves will be necessary to vent the primary l l containment to atmosphere vis the standby gas treatment system in order to maintain the analyzed combustible gas concentration
- inside containment to less than explosive levels. Due to high radiation levels in the vicinity of these valves, modifications .
'
I of the valves and the control systees should be made to obviate i the requirement for operator accessibility." l
'
! The conclusions of this report suggested that the area radiation { assesseents.resulting from this review be utilized in develop.ing post accident procedures and appropriate modifications.
{ a
; INVESTIGATOR'S NOTE: According to internal BEco correspondence i l examined by this investigator, this analysis was provided to the Vice President-Nuclear on January 1, 1980 and to the Nuclear Operations !
Department Manager on January 2,1980, both over the signature of the . NED Manager, j ] 5. Interviews of Present and Former Licensee Personnel Regarding Review of l 10 CFR 50.44 Evaluation of March 28. 1980 I a. Mr. John Fulton. Senior Licensine Engineer, said that after he i received the October 30, 1979 letter from the NRC requesting the ; i analysis to support compliance with 10 CFR 50.44, he contacted ' i ' Howard Stetaan of the NED to obtain the analysis. Fulton said * that at the time he was told by Steinan that there was no formal analysis done and no written documentation to support the statement of compliance in the October 19, 1979 letter. Fulton said that, { at that time, he initiated action by requesting NED to provide an i analysis that would respond to the NRC request. He said a draft l of this evaluation was disseminated within N00 and NED for comment l in early November 1979. According to Fulton, this draft was i returned to NED in order to have N00 comments incorporated in the evalwtion prior to its submittal to the NRC. Fulton stated that l while it was clear in the March 28, 1980 evaluation that the NED l position was that PNPS was not in compliance with 10 CFR 50.44,
- he, and to his recollection Mr. Zientanski (Plant Support Group Leader) and Mr. Andognini (Nuclear Operations Department Manager),
did not believe the analysis was sufficient to prove or disprove whether or not PNPS was in compliance with 10 CFR 50.44. Fulton said he did not recall spectf tcally sending this analysts back to NED for additional work but felt it must have been sent back in 1 erder to get their additional comments incorporated into the i evaluation. However, in subsequent interview, Fulton acknowl-
) edged that it did not appear that the analysis was returned to NED after it was transmitted to N00 on March 28, 1980.
, ' Fulton denied that there was a conscious management decision to < not report the noncompliance with 10 CFR 50.44 to the NRC, and i
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i said he did not recognize the necessity to report the questionable , i status of compliance with 10 CFR 50.44 until he reviewed what he '
- considered to be an adequate analysis to nsolve the question of i whether PNPS was or was not in noncompliance. Fulton said he j
- felt the analysis to comply with the NRC October 30, 1979 letter ,
i should have been done without the benefit of the information l f obtained as a result of the TMI studies. Fulton had no explanation : I for why this 10 CFR 50.44 issue was not nsolved or as to why the j i ' evaluation was never forwarded to the NRC, He acknowledged, in i retrospect, that the evaluation of 10 CFR 50.44 should have baen ; reported to the NRC. He also said that while the licensing grcup ! l had the nsponsibility for assigning outstanding cornsp6ndent.e & to responsible groups, they (Licensing Division) had no autherity 1 to insure timely responses. Further, he opined that the cause of 4 ! this incident was contributed to by.the fact that the licensee l i lacked a tracking mechanism to monitor the status of open items ; I with the NRC to insure timely followup of outstanding items. Mr. ' l Fulton's sworn statement is appended to this report as Exhibit } (7).
s
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j b. Nr. James Keyes. Senier Licensina Enaineer, said the NED analysis i
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provided to N00 on March 28, 1980 was the first documented corre- l
! spondence completed by NED on this subject. He said prior drafts
! of this analysis were questioned by the N00 because they brought i into consideration a habitability study performed after the i October 19,1979 letter. Keyes stated his opinion that the !
'
October 19,1979 letter needed to be c1csed out before introducing l new information into the analysis. Keyes said that, to his knowledge, there was never any consideration given to an issue of l nporting noncompliance with 10 CFR 50.44. Keyes said he could l' only conjecture that this issue was not perceived as an immediately
' reportable iten because it was not actually being pursued by the , NRC, nor were there any immediate safety considerations due to ; the plant being in an outage (January 5-May 19,1980). Also, ! modifications to bring PNP $ into compliance were in progress and I were scheduled for completion prior to startup. Keyes did state ; that transmittal of the analysis from NED to N00 on March 28, ! 1940 was at the Managers' level because that version was considered t to be the final accepted version of the ans'ysis. Mr. Keyes' l sworn statement is appended to this report as Exhibit (4). l C. Nr. Esheerd Zientanski. Enseement Services Grous Leacer said that at the time he us the P' ant 5upport Group .eader anc was involved r in the review d 1.0 CFR 50.44. He said he first learned that ! there was ne formal analysis conducted to support the October 19, 1979 letter after the NRC request of October 30, 1979 was received.
Zieelanski recalled that the N00 Department (via the Licensing . Division) requested the NED to prepare an analysis that would ' support BEco's statement of compliance in the Octobar 19, 1979 l 1etter. He said that, to the best of his recollection, several
i l
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- drafts of the evaluation were prepared by Steiman and were commented on by himself and possibly the N00 Manager (Andognini). Ziemianski
, said there was general agreement within N00 that the evaluation i was inadequate and did not support either compliance or non-compliance with 10 CFR 50.44, and was thus sent back to NED in order to have their comments and questions addressed in the evaluation.
! Ziemianski said t femal evaluation document was transmitted to i NED under an NED memorandum dated March 28, 1980. He maintained ' I
that, in his opinion, the evaluation was still inadequat,e to ! support a statement of compliance or noncompliance with 10 CFR ; ! 50.44. He also explained that the information ootained from the l }
. reactor building habitability study regarding operator ac ess
! was, in his opinion, not partinent to this evaluation in that j Amendment 35 to the FSAR had already made that assumption.
. l ' Ziemianski said that because they (the Nuclear Operations Depart-ment) did not think the analysis was adequate it was not forwarded
: to NRR to respond to the October 30, 1979 request. He said there j was no formal mechanism by which the acalysis would have been j ' *
returned to NED for further work and stated that, in retrospect, ; it did not appear that the analysis had evar been returned to NED l for resolution. . l j Ziemianski said that he could not explain why NRR was never , notified of the status of 10 CFR 50.44, and said he did not ! l recall having discussions with anyone in NED or N00 regarding the ! I necessity of informing the NRC of the potential noncompliance i 1 with 10 CFR 50.44 He denied that there was any intent to withhold i this infonnation from the NRC for any reason. Ziemianski attributed l the failure to report noncompliance with 10 CFR 50.44 to a lack ! t of a systematic process to formally assess the reportability of , engineering or analytical issues or of issues discovered by the ofisite engineering offices. Mr. Ziemianski's initial sworn i i l statement is appended to this report as Exhibit (5).
i ' ] In a second sworn statement submitted by Ziemianski (Exhibit 12 ,
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pertains) he advised that to the best of his recollection he did l I not have any detailed discussions with the Nuclear Operations I ) Department Manager relative to the status of compliance with 10 ' ] CFR 50.44 regarding the evaluation in question. He explained that while the memorandum transmitting this evaluation was addressed l to the N00 Manager, he most probably forwarded the evaluation to i
him (Ziemianski) for action without actually examining or analyzing its contents. He said that while he did not feel he was in a position to make an absolute decision as to the acceptability of i the evaluation, he had input into the document and to all documents , of this nature. He reiterated his opinion that the evaluation i was inadequate to submit to the NRC.
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d. Mr. G. Carl Andognini, formnr Superintendent. Nuclear Operations Department said he did not recall ever seeing the memorandum dated March 28, 1980 that transmitted the NED evaluation of 10 CFR 50.44 to N00 nor did he recall seeing the evaluation or being maae aware of its contents. He also said he recalled not having any discussions with anyone regarding the status of compliance with 10 CFR 50.44 or of the need to report noncompliance with the regulation as a result of this evaluation. Andognini said a ) coordinator acted for him on most documents requiring action or ) signature on his part and most documents of this type were screened prior to his receiving them for signature. He said the Plant ! Support Group Leader (Ziemianski) fulfilled this role.
Andognini stated that based on his current review of the evaluation in question he could not understand why no action was taken to i report the potential noncompliance. He said if there was a i question of adequacy relative to the evaluation it should have - i been brought to his attention so he could resolve the issue
through discussions with the NED Manager. Andognini did note that, according to his personnel records, he was absent from his i duties from March 27, 1980 through the first week of April 1980 and that Mr. Ziemianski would have reviewed his mail and would have taken whatever actions he deemed necessary for him.
Andognini concluded that this outstanding item (NRC Request October 30,1979) should have been identified as still open on i the computer printouts that tracked outstanding items with the BEco system; however, he conjectured that this system did not ! , ' provide for independent audit of the items that would have assured identifying this item in a much more expeditious fashion. As was l stated earlier in this report, Mr. Andognini's sworn statement is i being withheld from this report por his request.
l e. Mr. J. Edward Howard. Vice President - Nucidar provided a sworn j ' statement on January 7,1982 in which he acknowledged that he was on distribution for the NED evaluation dated March 28, 1979, but "' stated he had no recollection of reviewing that evaluation or of i being made aware of the fact that PNPS was potentially in non- , . compliance with 10 CFR 50.44. He said he is routinely placed on i i distribution for these types of documents but said his review is ! I norsally limited to insuring that the document had the appropriate
) distribution and review control. Regarding this evaluation, {
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Howard stated "Had I read this analysis, I still do not feel that it would have triggered a concern on my part relative to non-compliance with 10. CFR 50.44 because in my mind 50.44 set a less than adequate standard than would be required after the TMI-2
accident and both standards were referenced in the analysis." He also said that based on his current review of the NED evaluation, l it was now his opinion that this document and its conclusions i should have been forwarded to the NRC regardless of whether or not there was BECO staff agreement on the eva'.uation.
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- Howard concluded that while he could not cite a specific reason i or excuse for the noncompliance not being reported to the NRC, he
- did not, nor did he believe that anyone in the Nuclear Operations
! Department of BECo intended to withhold the information from NRR '
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! for the purpose of continuing power generation at PNPS or for any / l other reason, either financial or personnel. Mr. Howard's sworn d t i statement is appended to thjs report as Exhibit (9). 1 i i i i f. Mr. Paul McGuire, former Plant Manager PNP $ when interviewed i 1 said that in reference to the March 25, 1950 evaluation done by ! 1 the NED he was not informed or communicated with on this. natter : l and was not aware that PNPS was in noncompliance with 10 CFR . i a 50.44. McGuire opined that the Plant Support Group who apparently l 1 reviewed the evaluation did not, in his mind, have the technical i l ability to make a decistou as to the adequacy of the evaluation 1 and that a detemination of reportability should h6ve been made i by the plant Operating Review Committee (ORC). McGuire further ! i opined that a lack of communication between the plant and NED was ! l the cause of this incident. He explained that the Plant Support !
; Group screened everything from the NED to determine if the plant ;
, should or should not be informed or consulted with on certain i
information. McGuire concluded that while he did not believe the 1
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information regarding noncompliance with 10 CFR 50.44 was willfully , '
! withheld from the NRC he believed that management lacked the appropriate control to assure adequate flow of information from !
the NRC. Mr. McGuire's sworn statement is appended to this report as Exhibit (6), j l g. Mr. Alton Morist. Manager. Nuclear Operation Support Grous, was I 1 interviewed on December 2,1981 by tie report' ng investigator.
! Morist said he recalled having no involvement in either the BEco ' letter of October 19, 1979 or in any followup to the NRC request ' l
of October 30, 1979 for the BEco analysis that supported the October 19, 1979 letter. He said he had no knowledge as to what the rationale was for not reporting the apparent nonccmpliance with 10 CFR 50.44 as identified in the March 28, 1980 analysis.
He denied possessing any information that indicated there was any.
i intent to withhold the status of compliance with 10 CFR 50.44 i from the NRC. Mortsi said his:only direct involvement in the j issue of compliance with 10 CFR 50.44 occurred in June of 1981 j when the noncompliance was identified and the NRC formally nottfted l by LER. Mr. Mortst's sworn statement is appended to this report i as Exhibit (13).
6. Review of BEco Docueents Relatina to NED Analvsis dated March 28, 1980 A review of BEco files containing correspondence related to M CFR 50.44 indicated that a 10 CFR 50.44 evaluation was receive in the BEco Nuclear Records Center on December 12, 1979. This tyd uation l also documented that "PNPS does not meet the loss of power and redundancy ] i
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criteria with )xisting equipment with consideration of ;:ost accident doses. Modifications will be performed to insure loss of power opera-bility and redu,dancy." The basis of this statement on the copy of
- the evaluation located in the Nuclear Records Center was contained in
' an apparent draft cover memorandum to the evaluation which stated that, as a result of post accident shielding and accessibility stuotes,
- modifications.would be needed to respond to NUREG-0578 concerns, and also indicated that these design modifications would assure compliance with 10 CFR 50.44 i
The proposed changes discussed in the document included a design i change to the containment venting system to provide single fa'ilure i , protection independent of operator access to the vent valves, i INVESTIGATOP'S NOTC; A cover sheet to the memoranous and 10 CFR 50.44 evaluation in the Nuclear Records Center indicated that this particular draft was received by the Office of the Vice President, Nuclear on , October 22, 1979 and by the Nuclear Operations Department on October !
: 31, 1979. } ! A draft of the 10 CFR 50.44 evaluation was reviewed by the investi- !
i gator. It indicated the evaluation was provided to N00 and to the NED l l Manager on January 10, 1980. This draft was marked and edited for , coment by various personnel from N00 and NED. Of relevance in this / i',,
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draft was a coment concerning the results of the TMI containment l habitability study as it related to 10 CFR 50, Appendix A, GDC 41 ) criteria. The comment, made by the Plant Support Group Leader (E.
- Ziemianski), indicated that, in his vptnion, the information obtained 1 from the habitability study was not relevant to the analysis. According 1 to notes on this draft evaluation, it was returned to NED sometime
subsequent to January 10, 1980. Regarding the status of this draft
! evaluation, coments attributed to Mr. Ziemianski on this draft were l quoted as follows, "We find that this analysis is stiil not in a condition which we feel is acceptacle to N00 and the NRC."
l 7. Oy, rational Status of PNPS
1 Free October 1,1979 to January 5,1980, the PNPS was operated at l power for 97 days out of a possible 97 days. From January 5, 1980 to i May 19, 1980, the PHPS was in a major refueling and plant modifict. tion outage and was returned to power on May 21, 1980.
j INVESTIGATOR'S NOTE: In November 1980, the Electric Licht and Power j Macartne, a news sagazine of electric utility management and technology
, named BECo the outstanding electrical utility based on the strength of
its financial and operational performance of 1979. PNPS was cited in l l this award for its 83% capacity factor of PNPS during 1979.
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27 l i i ! , ! 8. Additional Inouiry Relative to BECO Compliance With 10 CFR 50.44 l
i Between May 14, 1979 and June 1, 1979, NRC Region I inspectors conducted l an unannounced inspection at PNPS to assure that certain factors ! contributingeport to the ir.cident at TMI did not exist at PNPS (refer to ' Inspection 50-293//9-09 fordetails).
i ' As a result of this inspection, three items of noncompliance were l
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identified relating to procedures specifying valve position, procedures l 1 specifying valve locking, and valves being documented locked in the l l wrong position. Of concern was the finding that the drywell nitrogen ! i makeup valves that were required to be locked open were actually l j locked closed. ;
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1 The licensee responded to the items of noncompliance in this report on 1 October 21, 1979 via BEco letter No. 79-192. In the licensee's responu { i to two of the items of noncompliance (identified as Items A and C in ; j the response) which did not address the status of the nitrogen makeup ! I valves specifically, the 11censeo stated "Appendix A (valve list) of I
- all 2.2 procedumt will be checked against da 9110$ and each will be i i updated as ne%ssary. At the present time all safety systems have
} been chected and we'are in compliance in this area. All systems will ! i be checked and we will be in full compliance by June 1,1980."
I I Regarding the nitrogen makeup valves being locked in the closed t I position (required open) the Itcensee was cited against 10 CFR 50, i j Appendix B, Criterion XIV, "Inspection, Test and Operating Status." ' 1 In the Itcensee response (Item B of the response) to the noncompliance, ! l the licensee did not address a verification of the actual and/or ! j correct position of the valves. Their response to this item of non- l compliance stated: '
"The two NPO's invohed in these two incidents were admonished to be more careful in the future when filling out survatilances to assure that anything under surveillance that is not as stated sust be flagged on the surveillance shewt and brought to the attention of the Watch Engineer. We are presently in compliance
{ in this area."
) INVESTIGATOR'S NOTE: The nitrogen makeup valves in questten are part i of the nitronen purge vent systen required to be in compliance with 10 ' ! CFR 50.44. "he following interviews were conducted in an attempt to l determine what the licensee had actually done to verify the actual
position of the valves prior to preparing their response to the above j identified itees of noncompliance.
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1 9. Intervious of Licensee Personnel Involved in the Response. to NRC Inspection Report No. 50-293/79-09 ' a. Mr. Edward Cobb Principal Engineer. Operations, was interviend by the reporting investigator on January 6, 1982. Cobb confirmed that the valves referenced in Inspection Report No. 50-293/79-09 were the l" manually operated nitrogen block valves. He advised a thatthePipingandInstrumentationDiagram(P&ID) originally indicated thtt these nitrogen valves should be in the open positier, while the plant was running but that due to excessive nitrogen , leakage in the containment, an Operating Review Cosmittee approved
- change to the 2.2 Procedures modified the valve position *to ,
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closed. He said that a memorandum should have been submitted to i update the P&ID following the procedure , change; however, to his
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knowledge, P&ID updates were running as much as 3 years behind i the actual changes in the plant. l Cobb advised that to the best of his recollection he provided the !
, majority of the input to BEco letter No. 79-192 which responded
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to the NRC Inspection Report and items of noncompliance. He said that, as he could recall, there was no actual walkdown on any of
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the valves using either the P& ids or the valve list to the 2.2 , procedures. He said the P& ids were compared against the valve Itst for the emergency core cooling system prior to the response i being submitted and that the long term intent was to check all of ' i the P&ID's against the valve Itst (including the nitrogen valves) to insure that they were in compliance. Cobb said if a dis- i
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- crepancy was found during these reconciliations between the P&ID's and the valve list, a determination would have boon made !
as to how the plant was actually running and either the F&IO or i 3 the valve list would be changed to conform to the plant operating i conditions.
' l l With respect to BEco's response to the 10 CFR 50. Appendix B.
I' Criterion XIV citation, Cobb said there was no verification of the position of the nitrogen makeup valves at the time of the response because these valves were not considered to be safety related. Cobb said that, in his mind, the citation called for t riprimanding the plant operators who did not accurately verify , l the valve list with the actual valve positten and for insuring ! that all operating personnel wre reinstructed on the requirements of the surveillances. Cobb said the valve position of the nitrogen
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sakeup valves in question would have been verified by' June 1 . { 1960 as stated in the BEco response. l I I b. Mr. Dervced Hughs. Jr., Sr. Nuclear Training Specialist was i l in;erviewed on January 6,1982 by the reporting investigator. ;
! Hups stated that to his recollection the nitrogen makeup valves ' , (sanval l" valves) were placed in the closed position because the
{ nitrogen leakage into the containment from the various plant
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I leakoffs negated the need to have the nitrogen valves open for makeup. For this reason, the operating procedure (2.2.70) was changed in April,1979 to close the valves to conform with the ! actual operating condition of the plant.
, i Hughs recalled that as a result of the items of noncompliance in " j IE Inspection Report No. 50-293/79-09 he was assigned to check '
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the P&ID's against the procedures and valve checklist. With 6 respect to the manual nitrogen makeup valves he recalled determining that the P&!O showed the valves in the locked open position,while i the valve checklist showed the valves locked closed. Hughs said i he submitted a design change notice to the P&ID to reflect the i change of the valve positions during operation from open to
closed. Hughs recalled that, as per the response to NRC Inspection ;
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Report No. 50-293/79-09, he was under a deadline of June 1,1980 ; to complete the P&ID and procedure. reconctitation. Hughs said , ! that this task did not include an actual walkdown of the valves unless there was a specific question about a valve position, j A walkdown such as this was not conducted on the nitrogen makeup valves in question. ' j
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c. James Keyes. Sr. Licensino Ennineer. N00, was interviewed on ; I i Ta'nuary 7,1982 by the report < ng investigator regarding the
licenset s response to the items of noncompliance identified in NRC Inspection Report No. 50-293/79-09. With regard to the Item i B response by the licensee, Keyes said he reviewed the draft i response prepared at the plant and that he added the last sentence which stated "We are presently in compliance in this area." He i said this statement was added to indicate that corrective action had been taken with respect to insuring that the operators conducting j surveillances had been properly instructed in the correct procedures l . of doing the surveillances, and was not meant to imply that any , valve position verifications had been conducted. Keyes said it was his ir.terpretation of Iten B that the citation pertained to
{ the tagging procedures and not to valve positions. Keyes concluded
; that since these valves were not considered safety related, the verification of valve position would be completed by June 1,1980 l during the review of all non-safety related systees as stated in
, the response to the itees of non-compliance, i
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V. STATUS OF INVESTIGATION The status of this investigation is closed.
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, . 31 YI, EXHIBITS 1. $ worn statement of Howard Steinan - 12/3/81 I 2. Sworn statement of Wayne Merritt - 12/4/81 .
3. Sworn statement of Stephen Rosen - 12/15/81 ] ,
j 4 $ worn statement of James Keyes - 12/9/81 * , t ! 5. $ worn statement of Edward Ziemianski - 12/2/81
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6. $ worn statement of Paul M:Cutre - 12/16/41 i 7. Sworn statement of John Fulton - 12/1/81 e 8. $ worn statement of Individual A - 12/4/81 ,
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i 9. $ worn statement of J. Edward Howard - 1/7/82 1
: 10. BEco Reactor Building analysis dated 10/17/79 1 .
j 11. NED Memorandum No. 80-404 - 3/28/80 12. Second sworn statement of Edward Ziemianski - 1/6/82
13. Sworn statement of Alton Morisi - 12/2/81 ' 1 ; ) .
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. UNITED STATES NUCLEAR REGULATORY C0pWI55!0N 0FFICE OF INSPECTION AND ENFORCEM NT REGION ! Page 1 of $ Place: loston, Massachusetts Date December 3,1931 DRAFT STATEMENT I, Haward Steiman, hereby make the following voluntary statement to Mr. Keith Christopher, who has identified himself to me as an Investigator with the U. 5.
Nuclear Regulatory Connission. ! make this statement freely with no threats or promises of reward having been made to me. Investigator Christopher is preparing this statement for me at ey request.
As background infomation, I am in the position of Senior Chemical Engineer with
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the Boston Edison Company. I transferred frer, the Nuclear Engineering Division to the Fossil Generation Division in July 1980in order to take a supervisory position.
The 10/19/79 letter frun BEco to the NRC states that based on our analysis we comply with 10 CFR 50.44 with existing plant equipment. At the time of the submission of this letter, there was no femal analysis done to support this s tatament. The infomal analysis was based on an offsite dose assessment. This analysis was incomplete because it did not consider the practicalities of reactor l butiding habitability. The contents of Amendment 35 including reactor building habitability were not considered in this analysis. Amendment 35 to sy knowledge was not prepared to satisfy 10 CFR 50.44 requirements. This assessment that was done was designed to find out if it was possible to use a purge system for combustible gas control at Pilgrim I. The result sed that we could use the purge system with the existing LPZ at that time. l EXHIBIT 1
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l After BECo received the NRC's March 14,1979 letter requesting a schedule for l CAD installation, I was assign 6d by my supervisor, Wayne Merritt, to look at , ' what type of system to install. We, as an organization. (Nuclear Operations , ' and Engineering) started to look at options such as hydrogen CAD and air CAD, ! ' however, no fonnal installation plans were made. During this time the TM! f accident occurred and at this point, it was my opinion that an oxygen control j
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system was more appropriate than a hydrogen control system for cadustible' gas ! control at Pilgrim tecause it was a BWR.
i At this time, I took the lead in exploring other options su:h as, hydrogen ; reccznbination with an inerted primary containment atuosphere. During the spring
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and suertr of 1979, representativas of Engineering and Operations met to try and select a suitable systee. The first meeting resulted in the opinion that the best option was an inerted containment with hydrogen 're:ombination. There was later j a second meeting in which the more senior mer6ers of the Operations Department j l
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were present and no consesus could be reached on combustible gas control. To my recollection, this meeting occurred during 'the time frame that the NRC was sent i 1 1 I a letter dated 6/6/79 that stated that BECO was studying the various options. , I I i
. At the time of these settings, the 50.44 issue as related to compliance, was l not a concern as such u dat the TH! retrofits would require. In my opinion, the organization felt that the 50.44 requirements would be incorporated into the i '
post TMI requirements. This is my opinion because 50.44 would have allowed a j deinerted containment and that no longer saaned appropriate. What I am saying, is i that the 50.44 requirement allowed a less than 11 core average metal-water I reaction and this assgtion did not appe'r a to be born out by the TN! accident.
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f At this time, the 50.44 requirements were not getting much attention becuuse I was handling the TMI modifications 'and was spread pretty thin. As a result, the analysis for the 10/19/79 letter doceenting compliance with 50.44 was both informal and incomplete. At the direction of g supervisor, (Wayne Merritt), I wrote the origins 1 draft of the 10/19/79 letter. As I recall, this letter was tmnsmitted for coerent to Nuclear Operations (Steve Rosen to C. Andognini), in the sunser of 1979. Prior to this transmittal, the letter was reviewed by g supervisor. In the 10/19/79 letter, I requested that Amendment 35 be dropped I because I felt the post TN! requirements would dictate new requirements for combustible gas control. I do not know how the Operations Departmeht reviewed this document as I received no additional questions from them prior to fonnal i i
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submittal of the letter on October 19, 1979.
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After BEco received the NRC request for the 10/19/79 analysis. I was assigned l by Wayne Herritt to prepare an fonnal analysis that would demonstrate copliance
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with 50.44. At the time ! submitted the draft of 10/19/79 I believed that the
I station was in compliance with 50.44. This belief was based only on the limited l analysis I had done en the offsita dose assessments that was prepared by the Systems l Safety Analysis Group. If I had done a proper and complete formal analysis, I < would have realized we were not in compliance and would not have written the I . letter stating that we were in compliance.
On the analysis that I was formally requested to prepare, I was assisted by
Mr. Jim Ashkas of the Systems Safety Analysis Group. I prepared the initial handwritten draft nself sometire in late 1979. To the best of n knowledge, this ] ! J
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Page 4 of 5 l was circulated within the Engir.eering Department only for review. There were l ; at least two more drafts that were written by gself and Jim Ashkar. These we'e circulated through the Operations Departrent for cossent. I received comments, mostly in the form of questions on the draft. After meetings to resolve the
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questions, the last draft was fonnally submitted to Operations under Office Memo 1 80-404 to Carl Andognini on 3/28/80. I am not aware of any subsequent action
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> I on this doctment.
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In this document, I stated we werv. not in compliance with 50.44. This opinion was based on a reactor building habitability consideration that was identified ! to me by the Systems Safety and Analysis Group as a result of a reactor building , habitability study. This 3/28/80 document was reviewed and approved by both
- S. Rosen and Wayne Merritt prior to being submitted to Operations. I do not j know if there were further discussions on the analysis between g supervisors l and Operations personnel. '
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! do not know to what extent there were discussione, relative to whether or not the NRC should be notified about the 50.44 question. Io g opinion, the
- Licensing people would have been responsible for notifying the NRC if it was deemed necessary. I did reitarate q position in this document that in g ,
] cpinion we were not in compliance with 50.44 in March 1980. I explained to my supervisors that the initial analysis was incoeplete and therefore incorrect, i
) It is ry opinion that Mr. Merritt and Rosen agrud with ry analysis or they would not have signed off on the transmittal of 3/28/80. I do not believe that there was an wilfull attempt on the part of BEco unagement to withhold infomation !
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or to mislead the NRC regarding the status of 50.44. I believe the issue was to formulate a valid and correct analysis prior to making a decision as to whether or not we were in compliance with 50.44. In g position, I had no l ! responsibility for contact with the NRC and I would have no direct involvement , . ! in any reporting situations to the NRC.
t j I have read the foregoing statement consisting of five typed pages. I have
! made and initialed any necessary corrections and have signed g name in ink in the margin of oach page. This statement is the truth to the best of g knowledge, recollection and belief. I declare under penalty of perjury that the foregoing l is correct and true.
! Original signed by Howard Steiman. 12/3/81. 4:55 p.m.
( ! ) Subscribed and sworn to me before this 3rd day of Decoder,1981, in Boston, Massachusetts, i I ,
Original signed by R. Keith Christopher. 12/3/81. 4:56 p.m. l l l l
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UNITED STATES NUCt. EAR REGULATORY C0m!S$10N l OFFICE OF INSPECTION AMO ENFORCEMENT
- REGION !
Page 1 of 3 Place: Boston, MA
; Date: Decemoer 8,1981 DRAFT STATENENT I Wape J. Merritt, hereby make the fnllowing voluntary statement to R. Keith ! !
Christopher who has identified himself to me as an Investigator with the U. S.
j Nuclear Regulatory Comission. I make this statement freely with no threats l or promises of reward having been made to me. Investigator Christopher is' typing this statement for me at my request.
I am currently employed as an engineer with Chas. T. Main Engineering Corp. I l I teminated Boston Edison Company employment on 11/25/81. My position had l
, ' been Manager - Nuclear Engineering.
i l l My basis for the statements in the 10/19/79 letter was an infonnal, but -
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t documented, analysis done by Mr. Steinan in the Kepner-Tregoe Decision Analysis !
: fonnat. The primary criterion for ecceptable results was the off-site dose ;
i i rate per 10 CFR 100, rather than a point-by-point analysis of compliance to . 10 CFR 50.44. This analysis did not consider habitability as referenced in
! knendrent 35. In retrospect, this was an inadequete analysis because it was not
1 per Appendix B. However, based on this limited analysis, I fe1t we were in
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I compliance with 50.44, l J Following the MRC request for the analysis, I asked Mr. Steisen to fema 11y s I doctanent the analysis to satisfy the NRC request. During the preparation of l j this analysis, he assumed operator action could be credited in meeting th'e single 5 failure criterion because the secondary containment was asstaned to be accessible.
? I j EXHIBIT 2
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Pag'e 2 of 3 At this point he knew that TM! doses would render the containment inaccessiblet but TMI doses were not part of the 50.44 regulation. Therefore he felt he had a valid conclusion. Subsequent to this point, Mr. Ziemianski informed Howie and as that Amendet 35 concluded that the contaiment would be inaccessible (even without TM! doses). This finding invalidated the asamption that op,erator accessibility was valid, and therefore we were not in compliance with 50.44.
This condition of non-compliance was mported to N00 on February 22,1980, as stated in NED memo 80-404, dated 3/28/80. Mr. Rosen and I concurred with Howie's conclusion that ' access....cannot be guaranteed " The N00 attitude was "prove
, to me (N00) conclusively that we are not in compliance.' I felt there was sufficient basis at this time that we were not in compliance with 50.44. I asstened that the 3/28/80 analysis, agned on by N00, would be sent to the NRC to meet the counttment. After my 3/28/80 memo with the analysis, I got no further ccumnants or questions on it frem N00 so I assumed all was acceptable. I do not think they (N00) intentionally withheld information regarding this non-compliance frcan the NRC. At that tire I was not particularly sensitive to the Mporting requirements and ! do not know to what degree N00 discussed reporting this non-coupliance.
I have read the foregoing statement consisting of 2 handwritten pages. I have made and inttiated any necessary cornctions and have signed sy nase in ink in the margin of each pace. This statement is the truth to the best of my knowledge and belief. I declare under penalty of perjury that the foregoing is true and correct.
Original signed by Wayne J. Merritt 12/e/81, 8:00 e.m.
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' ! i , I c j Subscribed and sworn to before me this 8th day of Decem6er 1941, 8:00 P.M., , l Boston, Mass. - f ) . i
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I Oriainal sinned by R. Keith Christopher. 12/8/81. 4 P.M.
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UNITED STATES NUCLEAR REGULATORY C0m!SSION 0FFICE OF INSPECTION AND ENFORCEMENT ,
REGION I
Page 1 of 3 Place: Atlanta, Georgia Date: Decen6er 15,1981 DRAFT STATEMFRT l I, S. L. Rosen, hereby make the following voluntary statement to R. K. Christopher who has identified himelf to me as an Investigator with the U. 5. Nuclear Regulatory Comission. I mke this statement freely with no threats or promises of reward having been made to me. This statement is being typed for me at iny request, i
, As background information, I am currently Director of Analysis for the Institute ;
of Nuclear Power Operations. I joined INP0 on June 1,1980. Prior to that, ! was employed by Boston Edison Company from June 1969 until late May 1980 and was Nuclear Engineering Department Manager when ! left Boston Edison. I l l With respect to the 10/19/79 Boston Edison Company letter to the NRC regarding
' Containment Atmospheric Control System" ! do not meall reviewirg the analysis nferred to in paragraph 2 of the letter and would not normally have reviewed such calculations unless such a review was requutes by anyone involved. 51nce l i ! did not review the analysis, I was not were of its contents or of the fact that it was not femally doctseented. ! relief on the correspondence review sheet !
showing signatures by H. E. Steiman and W. J. Merritt.
With respect to Amenhnt 35 to the FSAR, I do not Mcall any personal involvement in the fonnulation of the paragraph on page 10 referring to reactor butiding access.
From Neverber 1973 untti July 1975, I was assigned to responsibilities on Ptigrim 2 at the Prudential tut 1 ding and therefore was not involved in the fina112ation of the details of Amen &ent 35 in January 1974
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l Page 2 of 3 With respect to the 10/19/79 letter, there was no intent to deceive or mislead i NRC wf th respect to compliance with 10 CFR 50.44. I was in agreement with the j Boston Edison Company NED Analysis transmitted to N00 via NED 80 404 dated 3/28/80
and expected N00 to transmit it to NRC. I left the empluy of Boston Edison l ' l Company in late May 1980 and do not mcall any further actions taken by N00 in the rer'od f between 3/28/80 and the end of May 1980. I don't meall any s'pecific j i discussions with N00 management about the validity of the calculations or !
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! discussions with N00 management relative to 50.44 compliance. I was not a party ,
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to any discussions wherein failure to report as required by MRC regulatory was considered.
! . I j As noted in the 3/28/80 transmittal memo for the analysis I was of the opinion that the content was reportable to NRC. Per Boston Edison Company policy, , licensing coneunications with NRC were the responsibility of the N00. To the best of g knowledge and recollection, there was no femal request by N00 for I . j any additional review by ryself regardin9 the conclusions in the analysis trans-i mitted on 3/28/80. I did not discuss - to the best of g haowledge and re-
- collection the status of Boston Edison Company coepliance with 50.44 after the t
j 3/28/80 memo, i l To some degree, the circumstances at the time (post-TN! sedifications and the . refueling outage workload) may have contributed to the apparent lack of
{ fo11cw.up by Boston Edison Company managernent.
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! have read the foregoing t,tatement consisting of three handwritten / typed pages.
I have made and initialed any necessary corrections and have signed g name in ) ink in the margin of each page. This statement is the truth to the best of my l knowledge and belief. I declare under penalty of perjury that the fomgoing l' is true and correct.
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' Orininal siened by 5. L. Rosen 12/15/81. 4:15 P.M.
subscribed and sworn to before me this 15th day of Decuber,1981, at 4:15 P.M., l in Marietta, Georgia.
l ! Orininal siened by R. Keith Christopher. 12/15/81. 4:15 P.M.
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UNITED STATES NUCLEAR RFGUI.ATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION I
Page 1 of 4 Flace: Baston, MA Date: December 9, 1981
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DRAFT STATEMENT !
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I, James Xeyes, hereby make the following voluntary statement to R. Keith l Christopher who has identified himself to m as an Investigator with the d. S.
Nuclear Regulatory Comnission. I make this statement freely with no threats , l or promises of reward having been made to me. Investigator Christopher is preparing this statement for me 'at my request. ;
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For infonnational purposes I am currently working for Boston Edison Co. as l . I Sr. Lic. Eng. ( 3-1/2 yrs. ). This job encompasses in part the assigning of
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incomin2 NRC correspondence to the various departmental disciplines for resolution.
The October 30, 1979 letter in question was typical of such correspondence and was assigned to NED for closecut. During the closing out of the item it was disc, overed that no "formal" analysis as indicated in the October 19, 1979 ,
(#79-20) was available.
, The analysis mentioned in the October 19, 1979 letter was assumed to be available by the Operations Department. In othe; words when the Engineering Department (Engineer through Manager) signed off con any green sheet, the responsibility for Engineering input was placed on the Engina.ering Department. In turn Operations was responsible for Operations, etc..- My responsibility as EXHIBIT 4 __. -_. -.
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Page 2 of 4 Licensing Engineer for this item was placing the draft Engineering responsa into gramatical form and processing the "green sheet." This means bringing the letter to each individual listed on the sheet and insuring that any coments the individual may have are adequately resolved prior to moving onto l the nort signature.
. I accepted the fact that the Engineering Department had an analysis and was not aware of the basis for that analysis.
The 3/28/80 analysis (NED 80-404) perfonned by NED was the first doctanented
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piece of correspondence completed by NED on this subject. Prior to this several handwritten / draft typed versions were questioned by the Operations l Department because they brought into consideration a habitability study perfonned (perTMI0737)afterourOctober 19,1979 letter (which stated we were in ccanpliance at that time). This letter and statement needed to be closed out, before introducing new infonnation into an analysis.
. At no time was there ever any consideration given as to reporting vs non-reporting a potential item of non-ccepliance. Upon Operations receipt of the 3/28/80 memo there was again no deliberate, conscious effort made in tenns of not
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reporting a non-compliance. In retrospect I can only offer conjecture as to why it was not perceived as an innediate reportable item and offer the following:
- The issue was not being actively pursued by NRR for closecut (due dates had slipped and NRC project manager was not bringing
, to light (as is typically the case for hot items))
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Page 3 of 4
- PNPS was in shutdown refueling mode and therefore no safety i
considerations were inanediate
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- Modifications to bring BECo into compliance were in progress I and were tcheduled for completion prior to startup.
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The level of authority for making a reportability , type decision rested with Mr. G. C. Andognini, Superintendent, N00, however I do not know to what extent Mr. Andognini had been infonned on this issue prior to the 3/28/80 memo.
The 3/28/80 memo ites1f was transmitted at the Managers level because it was considered the final version of the analysis. It did not provide the BECo corrrliance with 50.44 in tenns of our October 19, 1979 letter as requested by , Operations, and as such was difficult to use for a "direct' response to the NRC October 30,1979 letter, but was acceptable in tenns with the then current conpliance with 50.44.
) , I do not recall any discussions or decisions made as to the need to report this to the NRC as an item of non-compliance.
. I have read the foregoing statement consisting of 4 typed pages. I have made and initialed any necessary corrections and have signed by naen in ink in the margin of each page. This statement is the truth to the best of g knowledge
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Pa'ge 4 of 4 and belief. I declare under penalty of perjury that the foregoing is true and correct. Executed on December 9, 1981 at 3:25 p.m.
Original signed by James D. Keyes 12/9/81 3:25 p.m.
Subscribed and sworn to before me this 9th day of December,1981, at 3:2E p.m., Boston, Mass.
. Original signed by R. Keith Christopher 12/9/81 3:25 p.m.
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. . UNITED STATES NUCLEAR REGULATORY COM4ISSION .
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OFFICE OF INSPECTION AND ENFORCEMENT
REGION I
Page 1 of 3 Place: Pilgrim Nuclear Power Station Date: December 2, 1981 DRAFT STATEMENT I, Edward Ziemianski, hereby make the following voluntary statement to Mr. Keith Christopher, who has identified himself to me as an Investigator with the U. S.
Nuclee,r Regulatory Comission. I make this statement freely with no threats or promises of reward having been made to me. Investigator Christopher 1s preparing this statement for me at my request.
As background information, I am currently in the position of Management Services Group Leader for Boston Edison Company. I've been in this position since November
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1980 and prior to that I was the Diant Support Group Leader.
l Since I was promoted to the position of Plant Support Group Leader late in 1979, I was involved in the 50.44 requirements and I believe I would have reviewed the l BEco letter of October 19, 1979. At that time, I would not have questioned whether l or not the analysis as stated in that letter actually existed because the source informc tion for the letter was provided by our NED. I do not,recill in what manner I received this particular source infomation for review, but I often received the source infonnation with a simple cover letter (memorandum) from the Engineerhg Department Manager to the Nuclear Operations Department Manager. I, in turi, would normally have provided that source infonnation to the Licensing Engineer for development of a formal BEco letter.
At the' time, the Nuclear Operations Department received the NRC October 30, 1979 request for the 50.44 analysis, our department (probably J. Fulton) went back to the Engineering Depart: tent in order to obtain the analysis. Through discussict.s with H. Steiran and others, we detemined that there was no femal analysis _ _ _ - - - _ _ _ __ - EXHIBIT 5
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Page 2 of 3 documented per NED procedures that would satisfy the NRC request. My recollection is that the discussions with the Engineering personnel center around the fact that calculations were perfonned which indicated that the dose rates would be less than 10 CFR 100 limits. I felt these calculations were unverified in that they were not fonnally reviewed and documented. I believe we (the Nuclear Operations Department) directed the Engineering Department to prepare an-analysis to support what the BECc said in the October 19, 1979 letter. As I [ ' recall Steiman subsequently produced a draft analysis which was coninented on by myself, J. Fulton, possibly Carl Andognini and others in the Nuclear Fuels Division. We were in general agreement that the analysis was inadequate and did not support either compliance or noncompliance with 50.44. I, and I believe others in N00, made comments on the draft and sent is back to Engineering asking them to incorporate our connents in the analysis and address our questions.
A memorandum dated 3/28/80 fomarded a more formal, typed analysis document to our department from Engineering. However, we still maintained that this document I (the 3/28/80 memo) was totally inadequate to support a statement that we are or are not in compliance with 50.44 I also recall comenting that the Reactor Building habitability study referred to in the March 1980 document was innaterial in that Amendment 35 had c1 ready made this assumption. Because we (the Operations Departmenti felt the analysis was inadequate, it was not fomarded to NRR and was again referred ba:k to Engineering because we believed that our substantive i connents were not adequately, if at all, addressed. While the Operations Department had the final responsibility for responding to the NRC request for the analysis, I can not explain why we did not notify them of the questionable status of the analysis, We believed that the issue would have been readily resolved and a response would have been sent to NRR in the neae future. I do not recall any discussions y :ryone regarding any necessity to infonn the NRC of a potential \ ___________________________. _ _
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Page 3 of 3 noncompliance. I have no reason to believe that a conscious decision was made to withhold a potential noncompliance from the NRC. Our position, as I can best recall, was that the analysis was inadequate to respond either positively or negatively regarding our compliance with 50.44.
During this time period, there was no systematic process to fonnally assess reportability requirements of engineering related, ie, analytical, issues to the NRC regional office particularly if, or when the issue was discovered in the off-site engineering offices. Because of this and the pressures involved in the 1980 outage, I believe we unintentionally failed to adequately followup
. on this issue of reporting the status of the 50.44 analysis. I would restate that there was never any consideration given to the reporting the issue to the NRC Regional Office because the question was not raised. :
I do not believe we had a tracking mechanism to trigger a compliance review of 50.44 or other items of the same time period; this weakness has been identifiedandwe(theBECo}areintheprocessofattemptingtocorrectthis weakness.
I have read the foregoing staternent consisting of three typed pages. I have made and initialed any necessary corrections and have signed my name in ink in the margin of each page. This statement is the truth to the best of :ny knowledge and belief. I declare under penalty of perjury that the foregoing is correct and true. Executed on December 2,1981 at 1845.
Original signed by E. Ziemianski 12/2/81 1845 i l ) Subscribed and sworn to me before this 2nd day of December,1981, at Pilgrim ' Nuclear power Station,
, OH :i a si s 4 c ed b_L ch *i cada a LtL2MLLlM3 !
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UNITED STATES NUCLEAR REGULATORY COM4ISSION OFFICE OF INSPECTION AND Ehf0RCENENT
REGION I
o Page 1 of 3 Place: New Orleans, LA Date: December 16,1981 DRAFT STATEMENT I, Paul J. McGuire, hereby make the following voluntary statement to Keith
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Christopher who has identified himself to me as an Investigator with the U. S.
Nuclear Regulatory Coeuission. I make this statement freely with no threats or promises of reward having been made to me.
I Prior to joining UESC, I was employed Boston Edison Co. as Plant Manager
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at the Pilgrim Nuclear Station up until 8/30/80.
The referenced transmittal, dated 10/19/79(79-207) letter was signed by me for G. C. Andognini who was absent on the day in question, based on the signed off green sheet received frce Engineering. I was not aware of the basis for the analysis nor was I aware that the plant was in ncn-ccepliance with 10 CFR 50.44. I do not believe that it was anyone's intention to misrepresent the facts.
. In reference to the 3/28/80 analysis done by NED, I was not informed nor ccanunicated to on this matter, and I was not aware that the plant was in non-compliance. In g opinion PORC per section 6.0 of the Technical Specifi- ! cation should have reviewed this analysis to determine its reportability. The l EXHIBIT 6
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. Page 2 of 3 Plant Support Group did not have the technical ability to make these decisions.
I do not recall any discussions with the Plant personnel on 'the reportability of the subject analysis, and do not'kna,s the basis of the decision not to report the NED analysis.
In my opinion, the-established comunications between the Plant and NED was the cause of this situation. The Plant Support Group screened everything from NED to determine whether the plant should be inf amed pn certain matters. I feel that enough indirect pressure from upper management to keep the unit on the ! line influenced enough decisions to pemit this situation to occur whether.
. consciously or not. The fact that management did not establish the necessary process to prevent this from happening can be attributed to the cause of this event. The qualifications of the Plant Support Group to disseminate infomation is also at question, again this shows lack of management controls. I do not believe anyone willfully aloud (sic) this situation to occur, but I believe the '
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environment that management established is the cause.
In my opinion, many items were delayed from being done if it was known that other modifications would have to be done in the future. In other words, decision were not made to do things when it appeared that it could delay unit . startup or cause the unit to be shutdown. Based on what I have heard concerning this issue, it is typical of other things that happened while I was employed by BECo.
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Pilge 3 of 3 (I have read the foregoing statement consisting of two handwritten pages which was written by myself as I discussed it content with K. Christopher of the NRC.
, I declare under penalty of perjury that the fomgoing is true to the best of
l my recollection.)
ORIGINAL SIGNED BY PAUL J. MC GUIRE 12/16/81, 9:10 A.M.
l Subscribed and sworn to before me this 16th day of December 1981, 9:10 A.M., New Orleans, LA.
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ORIGINAL SIGNED BY R. KEITH CHRISTOPHER, 12/16/81, 9:10 A.h, i l _ _ _ _ . _ _ _ _ _ _ _ _ . . _ _ _ _ _ . _ _ _ _ _ _ _ , _ _ _ . _ _ , _ _ _ _ _ _ _ _ _ _ _ _ _ . . . _ _ . _ _ . _ . , _ _ _ _ _ _ _ _ _ _ . _ , _ - . _ . _ _ _ . , _ , ~ _ . . . _ _ , _ _ _ . . _ _ . _ _ _ _ - -
. . UNITED STATES NUCLEAR REGULATORY COM4ISSION ,
. OFFICE OF INSPECTION AND ENFORCEMENT
REGION I
Page 1 of 5 Place: Pilgrim Nuclear PS Date: December 1, 1981 DRAFT STATEMENT I, John Fulton, hereby make the following voluntary statement to Mr. Keith Christopher who has identified himself to me as an Investigator with the U. S.
Nuclear Regulatory Comission. I make this statement freely with no threats or promises of reward having been made to me. Investigator Christopher is preparing this statement for me at my request.
As background information, I am currently the Senior Licensing Engineer for the Pilgrim Nuclear Power Station. I joined the Boston Edison Company in 1970 and was subsequently promoted to the above position or October 22, 1979.
Mr. Christopher has asked me to provide the formal analysis upon which the October 19, 1979 letter from BECo to the NRC was fomulated providing the statement that Pilgrim Station was in compliance with 10 CFR 50.44 with existing equipment. Based on rny view, there had not been a fonnal analysis conducted to document the compliance prior to the submittal of the October 19, 1979 letter. After I reviewed the October 30, 1979 letter from the NRC requesting the analysis, I contacted Mr. H. Steiman from our Nuclear Engineering Department and asked him for the analysis. He advised me that there was no fonnal analysis and that the statement was made based on a series of meetings and memos between the Engineering and Operations Department. There was no formal written documentation for this analysis and I did not know what their basis was for stating we were in compliance with 50.44.
EXHIBIT 7 ! l
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Page 2 of 5 It is my opinion that operator habitability as referenced in Amendment 35 was not considered at that time during this analysis. Individuals who should have been involved in this analysis would have included Mr. W. J. Merritt and S. L. Rosen.
Mr. Rosen should have had the formal approval authority for this analysis prior to it being submitted to the Operations Department.
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While I was not familiar with the circumstances surrounding the submission of October 19, 1979, ! initiated action to followup on the NRC October 30,,1979 letter requesting the formal analysis. At that time, Steiman provided us (the Operations Department) with a draf t 50.44 letter that should have been in response to the NRC letter of October 30, 1979. This draft was reviewed by myself, Mr. Carl Andognini and Mr. Ed Ziemanski. This draft copy was re-ceived by us for review in early November,1979 at which time we all made.
coninents on the draft including questions regarding operator habitability as well as other issues. This document was then returned to the Engineering Department in order to incorporate our coments prior to submittal to the NRC.
The written draft dated 3/28/80 was fonnally provided to the Operations Depart-ment on March 31, 1980. This final document was prepared by Mr. Steiman and was reviewed by Mr. Merritt and approved by Mr. Rosen of the Engineering Department. This document which was done at the request of the Operations ' Department (Mr. Andognini) was to fulfill the need of a documented analysis in response to the NRC letter of October 30, 1979. Subsequent to receiving this document, both myself and I believe Mr. Ziemanski and Mr. Andognini re-viewed this document in its final fonn and it was our opinion that the analysis was inadequate to support the statement in the analysis that we could not meet the require ents of 50.44 with existing equipment. While it is clear in the 3/28/!0
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Page 3 of 5 analysis that the Engineering position was that we were not in compliance, I and I believe also Mr. Ziemianski and Mr. Andognini did not believe that the analysis was sufficient to prove or disprove the statement particularly since they had earlier stated in the October 19, 1979 letter that we were in compli'ance.
While I do not recall specifically, this analysis was returned to the Engineering Department at which time they were asked to rework the analysis and incorporate our coments that were made on the original draft. As ! recall the position as stated by the Engineering Department (Rosen and Merritt) was that even if we were not in complianc,e at that time, we would be in compliance prior to restart , following the TN! modifications to the purge and vent lines implemented during the 1980 refueling outage.
. At the cime that we reviewed this analysis of 3/28/80, there was to the best of my recollection no conscious management decision regarding a need to either report or not report the status of compliance with 50.44 to the NRC. I did not
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recognize a necessity to report this question of compliance ur.til I had received i an adequate analysis to support the statement that we were or were not in compliance. At the time that the 3/28/80 analysis was returned to Engineering, I recall requesting specific infomation from them specifying what the requirements for operator action were. It was our opinion that the Engineering Department should adequately justify their position as stated in the analysis prior to making an NRC notification. I also believe there was further di?cussion between Mr. Andognini and Mr. Rosen on this issue, however, I am not aware of the details of those discussions. The ultimate responsibility as to whether or not I
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I to make a report of this issue to the.NRC rested with Mr. Andognini and ! do not think he felt the engineering analysis suitably justified its position sufficiently to require reporting.
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. Page 4 of 5 < After the analysis was returned to the Engineering Department, no further action took place on this issue until early 1981. At thait time, I had a discussion with Mr. Mark Williams of the NRC at which time we' agreed to close out the still open item. I believe this issue remained open in the system for several reasons:
(1) There did not appear to be any great importance attached to this issue by the
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NRC or BECo at the time; and, (2) We lacked a tracking mechanism within our organization which monitored the status of open items and followup of reg'ulatory requirements, and elevated questionable issues to higher authorities for resolution.
I did not, nor do I have any reason to believe that anyone purposely withheld infonnation from the NRC regarding noncompliance with 50.44
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After the open item was discussed, I sent a memo to Mr. Merritt in the Engine 6 ring Department requesting that they provide us with the 50.44 analysis as we had originally requested. At that time, they prepared the analysis as docunented l
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in the June 15, 1981 letter to the NRC when it was fonnally determined that
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we were not in compliance with 50.44 r
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! do not know how the original 50.44 requirement was handled by the station l at the time it took effect in 1978 and I can not provide direct infonnation as to any other activities that may have occurred regarding this issue prior to my taking the position of Licensing Engineer in late October,1979.
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I have read the foregoing statement consisting of 5 typed pages. I have made and initialed any necessary corrections and have signed my name in ink in the ' margin of each page. This statement is the truth to the best of my knowledge ! and belief. I declare under penalty of perjury that the foregoing is true and j correct. Executed on Decemtrer 1,1981 at 1630.
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* Original signed by John Fulton 12/1/81 1630 Subscribed and sworn to before me this first day of December,1981, at Pilgrim Nuclear Power Station .
Original signed by Keith Christopher 1630 12/1/81
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UNITED STATES NUCLEAR REGULATORY COMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION I
Page 1 of 4 Place: Boston Edison Co.
Date: December 4,1981
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ORAFT STATEMENT
. i I, Individual (A), hereby make the following voluntary statement to R. Keith Christopher who has identified himself to me as an Investigator with the U. S.
Nuclear Regulatory Comission. I make this statement freely with no threats or promises of reward having been made to me. Investigator Christopher is typing this statement for me at iny request.
l Personal infonnation deleted. i
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With respect to the October 19,1979 letter to the NRC I had no direct involve-ment in the preparation of that letter. Analysis done under g direction which l was an offsite dose calculation may be the "analysis' referred to in this letter.
I recall that during this time frame I provided a calculation to H. Steiman at
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his request that was to substantiate the offsite dose assessment following a containment venting. This was to demonstrate capliance with 10 CFR Part 100.
There was a fonnal calculation dens by '
(deleted) and approved by anyself. I was not requested to provide any other analysis regarding the 10 CFR 50.44 l issue at tf.at time.
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Page 2 of 4 l l My Group (deleted) did subsequently initiate a Reactor Building Habitability Study pursuant to NUREG 0578 2.1.6.B. This analyses was to determine any modification required regarding Post Accident Operator inaccessability to required Plant Systems. The conclusion of this study us
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that several plant modifications were recommended including modifications to ' l the containment vent system for cebustible gas control. This study and ' ) reconnendations were forwarded from Steve Rosen to Carl Andognini and the TMI Project. 1 l Around the end of 1979 I first became aware that the 10 CFR 50.44 analysis required operation action and was therefore in conflict with results of the habitability study being completed about that time. I was made aware of this through verbal conversation with H. Steiman. About that time I reviewed Steiman's analysis as Steve Rosen requested for presentation and fonnat. I cormented on the Document to enhance the flow of the report. I do know that , the habitability study referred to in this document was the study done by my ! group in response to NUREG 0578 Item 2.1.6.B. I was in agreenent with the conclusions stated in Steimans evaluation that indicated operator ac. cess may not be available and therefore one of the criteria required to conply with l
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10 CFR 50.44 could not be satisfied. This is consistent with the reccmsnendations made in the habitability study. Therefore appropriate modification as recenenended in the habitability study were iglemented at the direction of both the Operations Superintendent (Andognini) and the Engineering Manager (S. Rosen).
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Page 3 of 4 It was my understanding that based on no further request for input that the 10 CFR 50.44 evaluation dated 3.28.80 was complete and accepted by the Operations Dept. I recall discussions of which I was not a part regarding the clarify of the anal / sis presented. The discussions were at least between the licensing group and the mechanical engineering Group (Merritt). * I was not aware that the conclusions of the habitability study were in question and it was on this basis that modifications required to mest 10 CFR 50.44 were to be made. -
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I assumed the 50.44 evaluation would be submitted to the NRC as requested. I am not aware of the circumstances surrounding its subsequent submittal to the l NRC.
I l l It was apparent throughout the period in question that there was no purposefull l intent on the part of anyone in BEco Management to withhold or provide false statenents regarding compliance with 10 CFR 50.44.
I do not belieYe there Was an understanding on the part of the inYolVed engineers that we were not in compliance with 50.44 at the time of submittal i of the Oct 19,1979 letter to the NRC. I am not aware of any obligations that
were purposely missed with regards to scheduling of analysis, plant modifications
; or submittals to the NRC for the purpose"of benefiting BEco.
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I request that my identity regarding this statenent be withheld from public i disclosure, and request my name not be referenced in subsequent reports.
I have read the foregoing statement consisting of 4 handwritten pages. I ! have mrde and initialed any necessary corrections and have signed my name in I ink in the margin of each page. This statement is the truth to the best'of my knowledge and belief. I declare under penalty of perjury that the foregoing , is true and correct.
Original signed by Individual (A)
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Subscribed and swom to before me on this 12th day of December,1981, at , Boston, Mass.
Original signed by R. Keith Christopher, 12/12/81 l l l
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UNITED STATES NUCLEAR REGULATORY COMi!SSION OFFICE OF INSPECTION AND ENFORCEMENT l REGION I I Page 1 of 6 Place: Boston, Massachusetts Date: January 7,1982 l l DRAFT STATEMENT I, J. Edwani Howard, hareby make the following voluntary statement to R. K.
Christopher who has identified himself to me as an investigator with the.V. S. l Nuclear Regulatory Comission. I make this statement freely with no threats l or promises of reward having been made to me,
,
As background, I currently hold the position of Vice President-Nuclear for Boston '
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Edison Company and was in that position during the timeframe in questions (November 1978 through March 1980).
As I recall, when 50.44 became effective in November 1978 our Nuclear Engineering Department was considering several different options to decide which would best serve Pilgrim Station's need for a combustible gas control system that would meet the requirements of 50.44. Several such considerations were hydrogen
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, recombiner installation and the feasibility of operating without an inert containment.
At the time 50.44 became effective I am now unsure as to what the status of cospliance was with 50.44. During this time period the TMI accident occurred which resulted in the shifting of our resources to following up the new post-THI requirements. In g opinion the 50.44 requirements would now be considered l inadequate and a lesser standard than what wculd ultimately be required. To q knowledge there were no concerns or considerations at that time as to whether l i
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EXHIBIT 9 _
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Page 2 of 6 or not the Station was actually in compliance with 50.44.
' With respect to BECo letter of October 19, 1979 stating that Pilgrim met the requirements of 50.44 with existing equipment, I was not aware of the basis for that statement of compliance and do not know what analysis was done to reach that conclusion. Further, I do not belteve that I was involved in any discussions or decisions relative to the issuance of that letter. I have' subsequently learned that there was no formal analysis as indicated by the letter that would justify
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the statements made in the letter of October 19, 1979. I consider this type of action to be completely unacceptable.
. I believe the problem arose on this requirement because of the difficulties encountered in trying to distinguish between the 50.44 critaria and the post-TMI requirements. I de not know who actually fonnulated the October 19, 1979 letter (at that time) but in iny mind there was obviously an inadequate management review of the document that pemitted it to get to the NRC in that fom.
I was not aware of what events took place to followup the NRC letter of October 30, 1979 requesting our analysis to support our coepliance with 50.44 (at that time).
This correspondence would have been routed to our Licensi.ng Division do wculd assign followup responsibility. In this case it would have gone to our Nuclear Engineering Department for preparation of the response. I do not know why the NRC request was not responded to in a timely manner; it appears that it somehow
"fell through the crack". , ;
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l With respect to the Nuclear Engineering Department analysis of compliance with 50.44 that was transmitted to Nuclear Operations Department on March 28, 1980, it is true that I was on distribution for that doctanent. However, I have no recollection of reviewing that analysis or of being made aware of the fact that we were potentially in non-compliance with 50.44. I as routinely placed on distribution for these type of documents, however, my review at that point is primarily limited to ensuring that the document had the appropriate distribution and review control. Had I read this analysis I still do not feel that it would
have triggered a concern on my part relative to non-compliance with 50.44 i because in my mind 50.44 set a less than adequate standard than what would be
. required after the TNI accident and both standards were referenced in the analysis, r
Based on my current review of the Nuclear Engineering Department analysis, it appears that this document and its conclusions should have been forwarded to the NRC regardless of whether or not there was BEco staff agreement regarding the adequacy of the analysis. I think our Licensing Branch should have submitted I the status of the analysis to the NRC with an explanation that the issue was j still pending a technical resolution.
I cannot cite a specific reason or excuse for why the apparent non-compliance was not reported to the NRC but I did not nor do I believe anyone in the Nuclear Department intentionally withheld from the NRC the fact that Pilgrim Station was in apparent non cogliance with 10 CFR 50.44 in order to assure continued power generation or for any other reason either financial or personal. I believe that l the mistakes made by us on this issue were compounded over confusion as to what I standards were actually going to be required in tenns of 50.44 versus post-TNI modification requirerents. I
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, Rage 4 of 6 Regarding compliance with 50.44. I had no discussion or meeting with anyone on the BEco staff regarding the need to report or not report the status of 50.44 and I was not aware of the fact that the Pilgrim Station was not in cospliance with
,50.44 until June of 1981. ,
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In any opinion, one of the causes of this 50.44 issue was an inadequate process on 1 our part for followup of new NRC regulations and requirements and I believe that the actions taken by n staff were taken in order to detennine what should actually be done to assure compliance rather than any attempt to withhold information from the NRC identifying a potential non-compliance.
< Since beginning n position with this Coapany, I have never experienced any pressure from g upper management to do anything necessary to keep Pilgrim
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Station on line for financial reasons at the expense of operating safety and within regulatory requirements. When I or y operating staff were not satisfied with the nature of plant operation a shutdow would be initiated. These decisions to shutdown were made within y staff and the upper BEco managernent was never advised of a shutdown or consulted with regarding a potential shutdown ) until after we had mado our operating decision. l
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l The award received by BEco in 1979 as the operating Company of the year in no way influenced any operating decision at the plant and did not affect our handling of the 50.44 compliance issue or any decisions regarding necessity to shut the unit down. Our guidelines for plant operations were our existing l l , l ,
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Page 5 of 6 , technical specifications and established regulatory requirementsin comparison with the day-to-day operating parameters being analyzed at the plant. These i specifications and requirements were our only criteria for operating and operating decisions were never affected by financial considerations or any l ' type of corporate management pressure.
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i Cur primary method for assuring that outgoing correspotdence we' o"~ was our "green sheet review process" which required Jerwn ' e' { management review of all outgoing correspondence. 't , F 2 w
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incident that this review process was either not unders... . < at clearly
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defined as to what management review responsibilities were .. are currently ; attempting to strengthen the "green sheet process' through training our personnel I
- in its use and i@ortance, I personally relied on this green sheet review process l
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to satisfy inyself that outgoing correspondence was correct. l
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- In conclusion. I would say that during this time period we were in the midst i
! , of an extended outage involving a large number of modifications as a result of the TMI accident. Our orgar.12ation was oyenthelmed as a result of trying to ! meet the multitude of requirements with a staff that was not established to bandle this increased workload. This caused a shifting of work priorities on
j a daily basis and a continual shifting of personnel to meet thase priorities.
I believe these factors were in large part responsible for our inadequate $ l response to the 50.44 issue.
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Page 6 of 6 I have read the foregoing statement consisting of 3 handwritten / typed pages.
I have made and initialed any necessary corrections and have signed g name in ink in the margin of each page. This statement is the truth to the best of knowledge and belief. I declare under penalty of perjury that the foregoing is true and correct.
! Original signed by J. Edward Howard, 1/7/82, 2:35 p.m. . St6 scribed and sworn to before me this 7th day of January,1982, at 2:35 P.M.
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Original signed by R. Keith Christopher, 1/7/82, 2: 35 P.M.
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'ed CFFICE MEMORANDUM
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To _Ef f M C Preemd by F A/ .Tou <m
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g OFFICE MEMgRANDUM )#
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3/2s/80 R a le w i,y
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S. L. Rosen
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D8 ard Title: PILGRIM STATION UNIT 1 J, w Ashka 's- 10CFR50.44 EVALUATION . At tne request of Mr. J. M. Fulton, we enclose a typed version of the 50.44 evaluation that was Alven to N00 on February 22,'1980. This evaluation incocoorsted NOC cc a nts and was sent to N00 for transmittal to the NRC.
We asswned that the of ficial NED approval would be via the creer* accroval sheet for NRC correspondence.
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Action Recuirect. YES X No Response Required: YES NO X Attacheent .
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EXHIBIT 11 . . - . - . . . - - . Nuclear Operab.ns
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UNITED STATES NUCLEAR REGULATORY COP 94ISSION 0FFICE OF INSPECTION AND ENFORCEMENT
REGION I
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Page 1 of 3 Place: Pilgrim Station
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Date: January 6,1982 DRAFT STATEMENT I Edward Ziemianski, hereby make the following voluntary statement to R. X.
Christopher who has identified himself to me as an Investigator with the U. O.
Nuclear Regulatory Connission. I make this statement freely with no threats or prcnises of reward having been made to me. Investigator Christopher is typing this statement for me at my request. .
I l i With respect to my involvement in tne BECO responses to NRC correspondence i which require Station input such as items of non-compliance I, in my position would act as the focal point at the plant for all requirements submitted to ' the plant by our Licensing Division (J. Fulton). Upon receipt of such
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correspondence, I (through my staff) would nonna11y assign the responsibility ! to the plant Department which is associated with the particular NRC correspondence ! in question. That Dept would be expected to respond to my staff with respect I to corrective actions, and what would be done to ensure ccepliance' and to prer:nt recurrence of the scae situation. Response t % to these Dept. ' assignments are basically set by the NRC deadlines sot for licensee rtsponse.
l Should a Oept, fail to respond in a timely manner, I will if necessary, advise my supervisor (R. Machon) to initiate a response from the Dept. Once this responses have been received by my staff it is reviewed by appropriate Station ' management (DNW & Nm) and then forwarded to our Licensing Branch 'm ca i incorporated into a response to the NRC.
Regarding the BECo NED analysis of 10 CFR 50.44 which was transmitted to N00 by memo on 3.28.80 !, to the best of my recollection did not have any detailed i discussions with C. Andognini, (my supervisor at the time) regarding the adequacy
) of the analysis which in retrospect appeared to place tae plant in non-cceoliance i with 50.44 We nay have discussed some aspects of the issue but not to the extent ( ) .- . ._ _ . _ - - EW! BIT 12
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Pc.ge 2 of 3 that Andognini aver became directly involved in the issue of compliance with
50.44,
ietile the memo and the analysis in question was transmitted to Mr. Andognini. I he most probably fomarded the analysis by initia11ng the upper right corper ; { and forwarded it to me for follow up action without actually examining or e ar,alyzing its contents. I in turn would have forwarded it to Jack Fulton for l the action. At the time I don't feel I was in the position to make the absolute decision as to the acceptability of the analysis but I certainly had
input to the preceding draft and I was able to voice g opinion on its contents.
For the reasons I stated in my previous statement I and I believe J. Fulton ) believed the analysis to be inadequate to support a conclusion as to whether j we were or were not in compliance. In retrospect it appears that infomation < i should have been subettted to the NRC with clarifying infomation stating our i questions as to the adequacy of the analyses and the need to further resolve f '
tete issue. t
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I theitght that we (the Operations Dept.) actually sent the questioned analysis l > back to NED for resolution but at this ti;te it would appear that we did not.
There was no forvel mechanism in place (other than the green sheet sign off i ) for coupleted correspondence) to send the questioned analysis back to NED for resolution and at that time I was overwhelmed with the project dealing with the ' i pipe hangers issue. This situation may have contributed to the 50.44 issue
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I slipping through the crack but in no way was there any intent on g part to withhold the status of 50.44 from the NRC.
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. . . Page 3 of 3 Our handling of the 50.44 issue in late 1979 was in no way related to or
- affected by the fact that BEco was being considered as company of the year largely in part due to the unit availability of Pilgrim Station. neitle it cannot be denied the BEco top mgt desired to be No.1 in generating capacity (per the PAB inspection) this desire in no way influenced our handling of the 50.44 issue.
J With respect to the involvement of the operating connittee (ORC) on the report-ability of 50.44 it is true that the ORC reviews items for consideration as to reportability of potential non-compliance. However, in this case, because of
' frapnentation between corporate and plant staffs this item was apMrently never submitted to the ORC for review. This weakness is being corrected and was also identified by the NRC PAB team.
In conclusion I reiterate that there was no intent on W part or to my knowledge
- anyone elses to intentially withhold this information on 50.44 from the NRC.
I have read the foregoing statement consisting of 4 handwritten pages. I have i l made and in'.tialed any necessary corrections and have signed sqy name in ink in !
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the margin of each page. This statement is the truth to the best of g knowledge ] and belief. I declare under penalty of perjury that the foregoing is true and Correct. ' Original signed by Edward Ziamianski, 1/6/82, 10:05 A.M. I
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Subscribed and sworn to before me this 6th day of January 1982, 10:05 A.M., l ! ) Pilgrim Station.
t j Original signed by R. Keith Christopher, 1/6/82, 10:05 A.M. (
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UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCDiENT
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. l Page 1 of 3 Place: Pilgrim Nuclear Power Station Date: December 2, 1981 DRAFT STATEMENT
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I, Alton Morisi, hereby make the following voluntary statement to Keith Christopher
- who has identified himself to me as an Investigator with the U. S. Nuclear Regulatory Comission. I make this statement freely with no threats or promises l
of reward having been made to me.
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As background infonnation, I am currently in the position of Manager, Nuclear l Operations Support Department for Boston Edison Company. I have been in that position since September 1980. Prior to that, I was the Power and Control 1 Systems Group Leader within the Nuclear Engineering Depaitment.
' , My involvement with (if any) the BECo letter to the NRC dated October 19, 1979 1 l in which it was stated that compliance with 10'CFR 50.44 had been met with existing plant equipment would have been with respect tio electrical design, etc.
I am not familiar with an analysis that was done to support that letter or as to any j rationale or processes involved with this issue at that time. Specifically, I do not recall if operator habitability as referenced in Amndment 35 was considered
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when the October 19, 1979 letter was submitted. l
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l I have no recollection of involvement in the handling and followup to the NRC i letter of October 30, 1979 requesting the BECo analysis in support of its letter
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! of October 19, 1979. I have no recollection as to why this request of the NRC l was not responded to. It is my understanding, that at the time there existed
) within the Nuclear Operations Department, a Licensing group to handle all l l correspondence from the NRC. It is also my understanding that Mr. Andognini
would initially receive NRC correspondence and then would assign the followup EXHIBIT 13 _ _. . -_
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P3ge 2 of 3 to one of his Licensing personnel. It is my understanding that this organization for tracking NRC correspondence did not possess a sophisticated system for tracking work against schedules to meet licensing comitments.
I am not aware of the circumstances surrounding the analysis dated 3/28/80 in j tenns of why it was initiated, who did the analysis, and what further action was
taken on that analysis. I do not recall what the BEco rationale was at that time for not reporting the apparent noncompliance with 50.44 to the NRC as iden- )
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tified in that analysis. I believe the responsibility for making the decision as to whether or not to report the item rested with either Mr. Andognini or Mr.
Rosen. I am not aware of, reor do I have any reason to believe that a management decision was made to intentionally withhold this information from the NRC. It is my opinion that most of the personnel involved in this issue, ie, Mr. Rosen and Mr. Andognini, et al, believed that we were in compliance with b).44 and that j the TM1 modifications that were being installed during the 1980 outage would also meet the requirements of 50.44 Again, I do not know the rationale for the apparent noncompliance that apparently existed between November of 1978 when j ) M.44 went into effect and March 1980 when the TNI modifications were installed. l l . To the best of my recollection, my first direct involvement in the 50.44 issue
! occurred around late May or early June 1981 when I was made aware by my staff
that an analysis was required by the NRC regarding 50.44. The letter I signed ) on 6/15/81 was based on a compilation of information from a variety of sources . to include data provided by H. Steiman that was apparently cunpiled during his initial research of the 50.44 issue that was done prior to the BEco letter of l l October 19, 1979. I signed this letter of June 15, 1981. based on review of the two separate analyses that were attached to this letter. These documents were i
submitted in an effort to provide all information we had on the 50.44 issue.
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PIge 3 of 3 , Based on my limited knowledge of this issue, I have no reason to believe that , the information developed during the analysis dated March,1980, was intentionally withheld from the NRC. I believe the thinking at that time was most probably that the requirements would be met by the TMI modifications prior to startup. i
I have read the foregoing statement consisting of 3 typed pages. I have,made and initialed any necessary corrections and have signed my name in ink in the margin of each page. This statement is the truth to the best of my knowledge and belief. I declare under penalty of perjury that the foregoing i is true and correct. Executed on December 2 at 1:15 p.m.
i I ] Original signed by A. Morisi 12/2/81 1:15 p.m.
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Subscribed and sworn to me before this 2nd day of Decerber,1981, at Pilgrim ,
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i Oriainal signed by K. Christopher 12/2/81 1:15 p.m.' i I
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Historical Sequence of Pilgrim Offsite issues Director of MCOA submitted State RERP (for Pilgrim) to FEMA 6/16/81 with statement that the plan was adequate.
MCDA l FEMA and RAC reviewed and reported on the Mass. RERP. ' 10/81 revised the PERP based upon FEMA's coments.
FEMA and RAC reviewed the revision and reported on weak areas.
9/82 FEMA received no response from the Comonwealth on further ,; revisions.
FEMA held a public meeting. The following issues were raised 6/3/82 by the public: ability to evacuate comunities within the 10 mile EPZ ability to evacuate Cape Cod beyond the 10 mile EPZ Reliability and effectiveness of sirens Trainimo of teachers, school bus drivers and hospital persr.<1 , Public information brochures
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K! policy l Procedures for elderly and special needs persons no date Comonwealth responded to all the above issues by stating the r RERP adh essed these concerns and pledging to work towards further plan improvement.
FEMA issued Interim Finding for Pilgrim.
9/?9/82 f Annual Exercise, FEMA observed 3/5/82 Annual Exercise, FEMA observed j 6/29/83 Annual Exercise, FEMA observed
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9/5/85 Remedial Exercise, FEMA observed
10/29/85 l 8/15/84 Ortil. FEMA observeo 3/85 Status of off site RiRP was* l many planning problems unresolved from 10/81 RAC review J Consonwealth had not responded to 10/82 RAC review
- Comonwealth had not provided FEMA with schedule of l corrective actions for problems identified in 1982 and 1983 exercises FEMA suspended processing of Comonwealth req;est for 44 CFR 3/6/85 350 approval.
Comanwealth sent a schedule to FEM delineating steps to be 6/20/85 taken to correct 1982 and 1983 exercise problems. These revisions were cot delivered to FEMA.
FEMA noted many previous exercise deficiencies were resolved 9/5/85 but identified new problems. l
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Remedial exercise corrected new problems. The Comonwealth has l 10/29/85 not provided FEMA with a schedule of corrective actions, All
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I D i , 10/30/85 FEM again informed the Commonwealth that 44 CFR 350 review was not
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6/86 Comonwealth provided RERP and local plans that were requested in 4 1985.
I 6/6/86 Comonwealth responded to FEM. The reply did not provide a schedule for completion. Review was based upon 1982 GERP and 1985 local plans.
l i 9/5/86 FCM informed MCDA of intent to conduct self initiated review.
) 12/22/86 Comonwealth fowarded copy of Barry Report.
- 8/4/87 FEM Self Initiated Review issued. '
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Status to Date BEco submitted ar Action Plan on 9/17/87. This action plan details the planned assistance for the Commonwealth and local governments, as well as resources and a schedule.for completion. Current status is as follows: Local Plans Orafts complete 11/1/87. Currently in review in the respective towns. Licensee estimates that most will be submitted to MCDA, then FEMA by the end of January 1988.
Local Procedures Drafts approximately 35% complete. They are addressing issues such as buses and sheltering.
MCDA Area 11 Plan Draft complete and in MCOA review. Estimate submittal to FEMA approximately January 1988.
. Commonwealth Plan Draft approximately 75% complete Additionally, BECo, with the concurrence of the Commonwealth, submitted an , exemption request to NRC on the requirements for conducting their Biannual Full Participation Exercise. This exemption was approved, with the stipulation that the exercise be conducted no later than 6/30/87,
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Offsite Dose Rates Estimated Release Rates Estimated Atmospheric Dispersion Time Since Criticality
= Offsite Dose Rates (Rem /hr) -
in affected downwind sectors to the thyroid and whole body
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Projected Offsite Doses . l Offsite Dose Rates , Historic Wind Persistence data (95 percentile) I Data from Technical Support Center on t projected cource of accident or release i j. = Offsite Projected Doses (Rem) i j in affected downwind sectors ! to the th> Told and whole body ; i.; . l,
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, PROTECTINE ACTION RECOMMENDAT10N (From Page 1)
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SHELTER SHROE0 RRERS NNW N NW to NNE R A WNW Q s 8 NE ' P l C W N -
ENE
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REVIELUED BY TIME DATE l (EETC) l
; RPPROUE0 BY TIME ORTE j (EMERGENCY COORD.)
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Protective Action Flow Chart For General Emergency i
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, General
Emergency ' i i l l V J Becommend Setter, I mik reens ! 5 muss devertad sosters
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coctahment DrynD DryveD l N rauwe Yes nomite ye, usait, No ca.th 3,. I w ne:ees, > E 000 >$000 -
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Effluent Pathways , , Main Stack (most probable) ' Elevated release 330 ft (400 ft MSL) . High and normal range monitors
4000 to 24000 SCFW 99% Chanoal filters ' . Flow rate indication i l Reactor Building Vent (less probable)
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Ground level release . 160 ft (con.11dered to be ground level) High and ne rmal range monitors
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25,000 to 700,000 SLTW i No filtration
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Flow rate indication i Turbine Building Roof Exhausters (least probable)
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Ground level release ] 80 ft (considered to be ground level) l l High range monitor 35,000 to 210,000 l No filtration No flow rate indication (number of fans ] running indicate flow rate) t
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Effluent Radiation Monitors
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High Range (all release points) l Ionization chambers
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) K sentgen/ hour 10to 10'R/hr [ Secured to outside of pipe or duct ! or in view of building air volume I Not redundant Can substitute any dose rate measurement ,
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- Normal Range (Main stack and Reactor vent)
Sodium lodide (2 channels) ] Counts per second - 4 . 10:to 10, cps j Offline sampling system
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Meteorological Instrumentation ,
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' 220 foot Meteorological tower j 100 meters from main stack 1 Wind speed and direction at 33 and 220 foot elevation Temperature at 33 foot elevation j Delta temperature 33 foot vs. 220 foot l J, Strip chart recorders in main control room ] Winicomputer inputs for data logging and calculations Dial-up capab!!ity for 15 minute average data
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' , 160 foot Weteorological tower
! 200 meters from reactor building I Wind speed and direction at 33 foot and 160 foot elevation 4 Temperature at 33 foot elevation Delta temperature 33 foot vs.160 foot
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Strip chart recorder in base of tower
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Meteorological Model
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t Straight line Gaussian Dispersion Model ; Concentration factors at ground level l Gamma dose factors based on finite cloud model from l Weteorology and Atomic Energy 1968 i j Considers:
: Topography l Stack height .
Average gamma energy (finite cloud model)
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Seabreeze fumigation potential Mixing lid and reflection i Elevated vs. ground level release modes l Plume transit time
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j Wind speed
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Advantages
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Model is simple to use and understand i Has been implemented on three separate i calculation devices i
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Nomograms ! Desk top calculator (HP-85) l Minicomputer (Nova 3/12) l
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Disadvantages l' ' Plume trajectory is considered as a constant straight line )
Inland trajectory modifications must be manually considered (not automatic) ) i j
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' TABLE 1 , ' BOSTGH EDISON - CCNCENTRATION (X*U/0) (1/M2) 10ROUND LEVEL RELEA?u - DIVIDE RESULTS BY ONE MILLION
.
MILES A B C D E F 0
.325 176.30 004.39 455.11 844.17 1341.50 3062.10' 740S.S0
.05 4h.04 103.08 102.69 376.42 549.98 1135.30 0174.40
.00 6.37 06.44 60.50 1SS.59 05S.3S 445.60 900.21
.75 2.54 10.09 30.67 90.03 157.76 2S7.95 501.43 1.0 1.99 4.95 IS.S0 59.73 107.(:2 210.10 346.22 1.5 1.42 1.93 9.55 33.36 60.65 127.46 206.76
. 0.0 1.09 1.49 5.00 21.36 40.97 06.15 160.37
*
.5 .90 1.23 4.04 15.00 30.27 64.65 13?.97 11.59 50.S0 110.00
*
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..
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*0.73 4.0 .61 .50 1.03 7.60 14.15 37.S9 7+.77 4.5 .56 .72 1.50 6.43 13.04 32.6S 64.4S 0.0 .51 .66 1.05 5.53 12.07 ::S. 71 61.51 7.5 .35 .47 .70 3.23 7.30 10.19 30.33 10.0 .27 .37 .50 0.18 5.10 13.09 OS.S6 15.0 .00 .26 .34 1.00 3.07 S.42 IS 71 00.0 .16 .20 .OS .O! O.21 6.00 13.96
.
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05.0 .13 .17 .23 .60 1.73 4.74 11.16 30.0 .11 .15 .20 .40 1.43 3.91 *.04
. ?S.O .10 .13 .10 .30 1.21 3.30 5.$4 /4 0.0 .00 .12 .16 .33 1.05 0.0S ' 7.07 v -
40.0 ' . 00 .10 .14 .09 03 0.54 6. 3 *:
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BOSTONEDIS0NP!LGRIMSTAT!ON-UNIT'1 RA0!0 LOGICAL EMERGENCY EVALUATION , l
;
CORRELATION BETWEEN PLANT RELEASE RATE 5 AND OFFSITE DOSE RATES , , POST 40CA f3 f i TIME (H,RS. ) IWITH HALOGENS) (W/0HlLOGEN5) h ! 0.0 0.781 0.580 214 0.1 0.719 0.523 219 0.2 0.704 0.484 225 0.5 0.653 0.4 08 241 ; 1.0 0.582 0.341 2.0 266 ! 0.489 0.279 310 5.0 0.338 0.185 401
,
10.0 0.232 0.119 498 ,
.
20.0 0.155 0.0788 640 50.0 0.0887 0.0421 920 100.0 0.0690 0.0335 1150 200.0 0.0693 0.0330 1240 500.0 l
, 0.0861 0.0303 1245 .
1000.0 0.0845 0.0162 1245'
l Q(wC/sec) x f th ; D thyI "P/hr) * U M x O b* I*U/0) ! l Q(9C/sec) x f x (xu/0) ! OI"Ihr) t
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EN TECH ENGINEERING. I A C. ; P103-R1 - Page 24 l
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Boston Edison Company i incorporated 1886 - j . Owns and Operates Three Generating Stations
- e Mystic Station - four units e New Boston - two units
~
. * Pilgrim - one unit - Nuplear ! ! Service Area Consists of 40 Cities and Towns e 600 square miles l o 600.000 customers j e Serving a population of 1.5 million i Employs 4300 People ! !
' __ . _ _ _ . -
- - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
_ _- _. . -
.
l . .
. - .
, l . Pilgrim Nuclear Power Station . l I Located in Plymouth, Massachusetts i
* Fifty mile south of Boston * Situated on 1600 acres l
l
* On Cape Cod Bay
, e Four miles Southeast of Plymouth Center i ) Vital Statistics l , o GE - BWR - 670 megawatts j e Construction commenced in 1967 e Commercial operation began in 1972 - ) e Construction cost S231 million
; !
l l
._
:
!. ,
..
-
Ten Mile Emergency Planning Zone ! -
'
! j Plymouth - Population 39.000 - 103 Sq. Mi.
) Kingston - Popuation 7.852 - 19.32 Sq. Mi.
! Carver - Population 9,723 - 42.97 Sq. Mi.
! l Duxbury - Population 13.689 - 24 Sq. Mi.
. Marshfield - Popu ation 22,700 - 28.5 Sq. Mi.
l Note. Population figures represent entire
--town's population
' , ! i i I \ ,
- _ . - : . . . .
Reorganization of The Emergency i Response Teams: ! Note: NRC recommended reorganization to ensure t l the EO.F. is an outward looking faclity.
! , O.S.C./ T.S.C. E.O.F.
Public Safety Accident Mtigation Environmental NSite Assessment & Command / Control State interface l ! * Emergency Director # Emergency Coordinator 1 . ! * Radiological Emergency * Environmental Emergency l Team Coordinator -- Team Coordinator i
* Emergency Preparedness
! Coordinator
* Relocated Position * Communications Liaison ~ (MCDA-Framingham)
New Position !l
_ __ ___ ______ _ _ ______ - - - _ _ _ ____ __ _- -_
: . . .
!
Control Room '
Operating Cold Simtdown and Refueling
* 2 Licensed Senior Reactor * 1 Licensed Senior Reactor j Operators Operator
* 1 Licensed Reactor Operator
'
i * 2 Licensed Reactor Operators
* 2 Unlicensed Operators * 1 Unlicensed Operator
.
* 1 Shift Technical Advisor * O Shift Technical Advisor i
l . j Notes: * Hgher grade licensed operators may take the place of j lower grade licensed or unlicensed persomel.
i ! e An STA with an SRO may simultaneously serve l as STA and SRO.
! !
i - - - - --
) : i
. a I
,! Technical Support Center l Emergency Director: i TSC Supervisor . i Rad Emergency Team Coordinator Chemical Engineer Reactor Engineer Maintenance Engineer .
. Health Physics Engineer I&C Engineer I
- Shift Technical Advisor Computer Engineer
,
l Operations Engineer Administrative Support I, I ! l l ! _ _ _ _ . _ _ _ _ __________ - ___ .___ --.
_
- :
- . .
! , Operations Support Center
; Emergency Director:
I OSC Supervisor Nuclear Auxilary Operator (s) Electrical Maint. Technician (s) i Chemistry Technician (s) Security Persomel . I & C Technician (s) Tool Management Supervisor
l Rad. Protection Technician (s) Stores Department Supervisor ! Mech. Maint. Technician (s) . i i
l . _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _
- --
.
.
. .
-
l Emergency Director l Responsibilities:
!
l * Direction / coordination of * Provide support to the all onsite operations Watch Engineer i * Classification /re-classification * Ensure adequate protective
! of the event measures are taken for
! * Establish communications pers W
- EOF. - Evaluate advisability
- T.S.C. of re-entry l - O.S.C. * Ensure accurate exposure records are maintained
<
* Conduct briefings --
,
* Determine necessity of site
! evacuation
! Note: The Watch Engineer serves as the Emergency Drector unti i a qualfied Emergency Director assumes responsNty.
. ! ,
- - - . *
I i i T.S.C. Supervisor I Responsibilities: i
,
i e Oversee activation of e Recommend corrective i the T.S.C. action (s)
* Analyze current and * Assist the Emergency projected plant status Director as required
! * Evaluate possible * Conduct periodic solutions briefngs
l i l
) i
;
i
!
i i _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _- - _ - _ - - - _ _ _ _ _ - _ - _ _ - _ _ _ _ - - _ -
. . _ . - . . . . .
O.S.C. Supervisor ! . Responsibilities: l I ! l
! * Oversee activation of e Recommend corrective actions j of the O.S.C.
- Drect O.S.C. persomel in j e Analyze current and emergency support activities
! projected plant status e Conduct periodic briefrigs e Evaluate possble solutions
~
!
1 l !
1 i
! )
__
- - --- --
. -
-
; . .
Emergency Operations Facility
: Emergency Coordinator Emergency Preparedness Coordinator Dir. of Corporate Conm Envirort Emer. Team Coordinator - Corporate Comm. Staff
l - Environ. Assessment Engineers Manpower Coordinator
- Envirort Monitoring Teams - Manpower Coordinator ~s Staff j Communications Coordinator Security Personnel . ' - Communications Staff Administrative Support
i
!
l
-
! ! _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ - - _ _ _ _ _ _
-- -
1 .
; - . .
l l; Emergency Coordinator Responsibilities: ]
i ! * Direction and coordination * Request assistance of al off-site operations * Deployment of off-site j * Activation of the EOE monitoring teams ) e interface with local. State. * Evaluate up-dated information and Federal agencies l . * Conduct periodic briefings !
- Ensure prompt notification - Maintain open communications . . * Mahe protective action
- recommendations
* Provide direction and establish
'
- hdelegaW communications with the
- Recovery Center -
l
i
! ! ! !
- ____ _ . - _ _ _ . .
i l l Recovery Center
Recovery Manager i
:
l Nuclear Engineering Manager Administrative Coordinator
;I Civl Structural Nuclear Management Services , Fluid Systems Department Manager .
Power Systems Qualty Assurance Manager
!
Control Systems Regulatory Affairs & Program. Group l
System & Safety Analysis
; Nuclear Analysis
,
~
.
: ! !
i
!
!
1 I
- _ _ _ _ _ _ _ . - _ ._
- - _ _ _ _
_ _ _ _ _ - - - - -
_ - _ _ _- -. . . e
. .
- Recovery Manager I
! Respons i bilities: i i !- e Oversee activation of the e Conduct periodic briefings i Recovery Center e Establish and maintain ! e Manage the recovery operation communications as required
~
l * Coordinate and support requests e Perform notifications if
- for outside support not yet complete I
l < !
! i I
! - ; :
-___ _______________________ _ ___ - ____ _ - _ _ _ - _ _ _ _ - _ _ . -. _. - _ _ - - _- _ _ _ - - _ -
- _ _ _ -
i . l
- . .
i i Media Center I Public Information Officer , I i l Technical Spokesperson Pubic information Mgr. (cont.)
l Technical Advisor P1 Manpower Coordinator . ! i Public L: formation Manager Buiking Services District Manager Prudential info Central Leader ] j News Representatives P1 Representatives Rurnor Control Rumor Control l l Administrative Support l l-l l
,
i i
! . _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - __ _ _ _ _ _ _ _ _
--
-. -
.
. -
!
Public Information Officer ! Responsibilities: . l l
* Oversee activation of the * Issue press releases Meda Center * Answer questions
* Conduct briefings for Meda e Establish and maintain communi-Center staff cations with Corporate Communi-i l * Conduct briefings for the cations staff at the EOF news meda l
! i i ! ,
. _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ - _ _ _ _ _ _ - - - _ _ _ _ _ _ - - . - _ _ _ _ . - __ _ _ - _ _ _ _ . _ - _ -
_. _ .- _ _ -- . _-
-
I
. .
' initial Notifications To Offsite Agencies
! Showing Primary & Backup Communications Links i
j - - i NRC
'
,I ENS Te W ono 7 i , > s > Mass. % - * *rn T*phme "' ' T* Control Room State Police , 37.78 mHz / 37.78 m Coast Guard , y Rado % Mass. State Police Notifies Te m l *h0PH I e MCDA e s ! * EPZ/ Reception Plymouth
town Police Depts, Police Dept. , j as reW Plymouth Polce Dept. Notifies:
- * Plymouth Civi Defense
! * Other town agencies
- & officials (Selectmen, Fire, Public Works, etc.)
i ' l
I
.- - - - - - - - - - - -
_. - - - . - - . . _ -
. .
- Interfaces Between BECo Emergency Response
!. Facilities & Outside Groups
/ / / / / /
} Federal, State Outside Tech
'
l General Public & Local Gov. Support
/ Age acles / (l>PO.Bechtel,etc.) /
, ! Plymouth Plymouth Braintree I u i / /
- / / /
i i Media Center EOF Recovery Center Boston ! Public hfo Officer j Emergency Coord._) Recovery Ctr. Mgr. / Edson Fac5 ties
=
!' Boston PPP S PPPS r / / / / / . BECo Corp. HO. TSC/OSC Control Room
l C.E.O. / Emergency Dir. / Watch Engineer j i
!
!
"
.
$ _ - __ _ _ _ _ _ _ _ _ _ . _. - _ . . . _ _ _ _ _ _ _ _ _ _ - _ _ _ - - _ _ _ _ _ _ - _ _ _ _ _ _ - _ -
-
- -
-
; .
- Key Emergency Communications Links Between BECo, State & Local Officials I
/ N Governor 1 i
/ %
i State Coord i, Officer l'Sec. PutWic Safety l MSInfa Ff Y , Frnmmntt2m BECo I N / N e N Rep A PH MCDA State
, ~
Agencies . 1 ~ l Coord nator l l heident OPS Dir. I ! ] m a ,e x e A Local Civil i Reps BECo EOF MCDA Area I EOC Defense 1, Pfvmouth y , Bridoewater Directors l ! Emero Coord ! heident OPS Coord ! AEOF Bridgewater ! l To faclitate communications, BECo representatives are located at the state MCDA Hdqtrs. whle
MCDA & AOPH representatives a. :ocated at the EOF.
. !
_ __ -
. , . = .
, Links To The Commonwealth of Massachusetts ! .
/ \/ N/ \/ \
1 EOF MCDA SCO Governor l
!
. i
-
MDPH
!
.
; EOF -
Emergency Operations Facity l MCDA - Massachusetts Civl Defense Agency l SCO - State Coordnating Officer (Sec.of Public Safety) MDPH - Massachusetts Dept. of Public Health i l i ) l
_ _ _ _ _ _ _ _ _ _ _ _
.
.
EOF EMERGENCY CDMMUNICATIONS NETlDDRK
...... .. .............. w m ...... .... .... n:; p. ..... .. .. .........., ..... - * .
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!
- EOF CAPR91L ITY RE0F CRPRGlLiTV
- - . . .
Communications Capability C
" e RADIOS contra Tsc/ eog 3eog 7 main*om Center p,oa,oii ,
Room OSC gate) Center 37.78 mH: } } } } } \ '*S* ,n"* 4 4 4 4 RACES $ h h 45.32/45.36 mHz .g _H .R MCDA W W W
- 461.85/466.85 Offsite Envir Team g g g J/
V Manne Band Rado [
~ 4 4 153.56 mHz ,//
Fre Brigade W / l i
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- -- - . . .
Communications Capability
/
TELEPHONES control Tsc/ #Y Recovery Media EOF AEOF Prudential Room OSC Mw Ntw System - Braintree g tib i Syt.Nm - PtPS g g g g EL'"uT*se', 4 4 4 4 4 4 4 4
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: ua saiance 4 4 4 Auto-Rog sym-m eo 4
; tha12 4 4
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""L' a 4 4 4 # #
* 4 4 ENS h h } ,
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_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ - . _ -- -_. __ _ __ _ _ - - _ _
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_
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' Communicatiens Capability
! Other Communications Equipment
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/ -
Control TSC/ EOF AEOF main Prudential Room OSC Center Center
,
gate) /
;
Pbnt Page System g g ' g
!
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- _ _ _ . . - _ _ - - _ . _ _ _ . _ _ _ _ _ - _ _ _ - . - - _ - - - -____________ - - _ _ ___ _ - - - - -
, - - - - - - -
- - .- _. _- - _ _ _ _ _ _ - _. . _ _ - - _ . ! . . . . ,
Telecommunicatio6;s E
, Internal l
l Commercial Te:ephone Lines ;
* Plymouth
- * Braintree l e Boston l
Plant Data Phones
,
* Control Room
, e TSC/OSC l i
* EOF
{ e Recovery Center i
l
. _ _ . _ - _ - - _ _ _ _ _ . _ _ _ _ . _ - _ _ _ _ - _ _ __ _ . ._ . . .
i I
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Telecommunications i .
! Internal ! ! i Auto. Ring-Down Phones - Corp. Conn.
. l e Links EOF and Media Center Plant Paging System j e Links TSC/OSC Control Room.
l Security i ) ! ! i !
i i
. _ -_ _ - _ _ _ _ _ - . ._ ___ _ -__ ____ - _ _ - _ _ - - _ - _ _ _ - _ _ _ _ _ . -
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- . .
. I Telecommunications i External i Auto. Ring-Down Phones j e From the Control Room to Mass.
l State Police in Middleboro i { e From the EOF to Mass. State Police ! in Middleboro e From the Control Room to the Plymouth ! Police Dept. . j e Links EOF and Media Center i ,
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, - _ _ - - - - - - _ - - _ - - - - . - . _ - . _ _ _ ._ _ _ . - _ _ _ - _ _ _ _ .
_ __. - - - - - _ ___ _ _ _ . __ _ . _ - - _ . ._ -
.-_ -_ _ - -
l I i
- , ;
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, -
Telecommunications - i 3 External l !
) HPN(toNRC)
t i e TSC/OSC ! eEOF ' ! ! ! ENS (to NRC) , , l e Control Room i ! i
* TSC/OSC ,
i l * EOF '
i ! ! l l !
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ __ _ .- - _ _ - - - - - _ _ - - _ _ _ _ _ _ - _ _ _ _
.
- -
l
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l Emergency Response Facilities ! l
* Control Room e Technical Support Center (TSC)
! l e Operations Support Center (OSC) !
* Emergency Operations Facility (EOF)
l ! * Media Center i e Recovery Center
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! ! . I ! !
. __ . - _ - _ - - . _ _ _ _ - _ _ _ _ - . ._ . . - .- .
i
- . : -
Control Room
1 Purpose:
- e To recognize and classify the event l e To control and maintain safe operations of l the reactor and all supporting systems
) and equipment l Emergency Equipment: i e Terminal to the Nova 3-D computer ' I i e HP-85A programmable calculator e Nomograms j e Emergency Notification System CENS) -- ! e Plant data phone . _ _ _ _ _ _ - _ _ . _ _ _ - _ __ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ - - . . __ -
_ _ _ _ _ _ - _ . _ - _ _ _ _ _ _ . _ - _ _ _ .- _ ___ i
: . .
Technical Support Center ,
- - -
r Purpose:
- in depth diagnostic and corrective action
! assistance to the control room l1 Location: i j e Primary - STA area of new Admin. building ! * Alternate - control room i l ! I ! J i
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Technical Support Center
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l Emergency Equipment: l ; ! ! l e Procedures. Tech Specs., P&lD's. FSAR i
e Slave terminal to p' ant process computer e CRT display (duplicates control
;
j room display) e Closed-circuit television monitor of ! control room l * Radiation survey equipment o ENS extension e Telephones
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Operations Support Center (OSC)
.
. Purpose: l Assembly point for technicians from each plant ! discipline to serve as a manpower resource - for control room and technical support l center personnel
,
l l I Location: j e Primary - S.T.A. area of new Admin. building
* Alternate - control room annex
! , i ! l
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! l . Operations Support Center -
,
i j Emergency Equipment:
'
i ! e Radiation survey equipment ! i e Protective clothing l
- e Scott-air paks
i e Procedures -
l e Speaker box telephone
~ :
! i
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I $
_ _ _ _ - - _ _ _ _ _ - . _ _ __
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l ! j - Emergency Operations Facility (EOF) .
.
l Purpose: Coordination of all involved response organizations l and continuous emergency evaluation including i environmental monitoring and dose assessment Location-l e Primary - Approximately 4 miles N.W. of PNPS
- on the grounds of the Plymouth
' House of Correction on Obery St.
j e Alternate - Area 11 Mass. Civil Defencse Agency
- Headquarters. Bridgewater Ma.
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;
} l l ! _ _ _ - - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - . _ ___________ ____ _ _ __ _ - . _ _ _ _ _ - - - -
- -__ _ -. _ _ _ . _ _ - _ _-_ _ - .- . _ _ _ - .- - . . . .
! Media Center
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E Purpose: i ) Central location for dissemination of information to the media by BECo, Federal, ! State and local personnel
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. Location: i l * Memorial Hall, P.ymouth , l
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Media Center . , i Emergency Equipment
:
l
, !
e BECo Public Information Department ! office space ! * NRC office space
'
> I e Conference rooms i { e Briefing areas l ! ! ! !
! - ! ! ! l
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_m __ -_ _ _ _ _ _ _ _ _ _ _ _ -__ _ _ _ _ . _ . _ _ _ _ _ . _ ___-- __ _.-r-------e- -w w-- -re- w--- --- --w--,---w--_- -w.- - - , - - - - -- --,- - - - _,- ---- -- -- -- - - -- - - --- _ ,- - --_ m _ ____ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ . _ _ ____
. - _ - ___ - _ -_____- . -_ . . . - - _ - . - ' ! . ! . .
I Recovery Center E
Purpose: . l * To assist the onsite emergency organization l as requested during the emergency l response phase
- * To plan and coordinate the recovery of the
- plant from the conditions resulting from the emergency situation Location
{ . l
* Braintree offices I
l 1 - - - - - - - - - - - - - - - - _ - . _ - - _ - - - - - - _ - - - - - _ _ _ _ - - _ - _ _ _ - - - - - - - _ . - - . _ - - __
. _ - - _ _ _ _ _ _ - - _ . _ . - . _ . . . . - - - . . .
O
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Recovery Center
- .
! Emergency Equipment ! ! ! e Offsite dose assessment !
* Radio and telephone communications
' ! e PNPS procedures, drawings, etc.
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E First Aid /Decon Trailer R Statt o Physicians Assistant Location:
* West end of BECo parking area (location of former EOE)
- _ - - _ - - - _ - - - - - ___ _. . _ _ _ _ - _
- __ . . - - _- -. ___ _ _-- _
_
. . . .
Scenario Development .
* Select scenario review team
.
* Review SALP-1 scenarios
* Review six year plan e Select objectives
* Define scope e Develop sequence of events
-
u.._____ _ . _ ___._._ _ _ _ . -__ . _ _. _ _ . __ _ _ ____.__._______m___ w- _-- ___ _ - - __- _ _.-- __ - - -- -- - _ - - _ _ - _ ._ _ _ _
_ - __ ___ -- _-- _. - _ _ _ _ _ _ - _ _ _- - . _. .
. . - .
Scenario Development . l
* Develop evaluation criteria
'
* Complete scenario package i 1. Guidelines I 2. Sequence of events
; 3. Messages l 4. Plant parameters
: 5. Radiological data
; 6. Mini-scenarios
! .
I d
-_
- - - .
_ _ _ . - .-__ _____ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - . -. . . _ . .
- _- -_ .-- - - _ _ - _-__ _ - _ . - _ _ - . _ _ - _ - _ _ __ _ _ . - ; - .
l' l . Exercise Scope .
,
l
* All BECo emergency response facEties
-
Control Room
-
Technical Support Center
-
Operations Support Center l - Emergency Operations Facility
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Media Center
-
Recovery Center l
* Limited state participation
- -
Limited EOF activation
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Limited EOC activation
* Ambulance participation e Hospital participation i
l l
-- - - - - . - . _ - - - -,.----------e- , - - - - - - - , - - - - - - - - - - .__. - - - - - _ - - - - - - - - - _ _ _ _ _ - - _ _ _ _
.. -.- - - - - - _ _ _ - _ - - - . _ _ _.
- .
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! '
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) - Criteria To Be Demonstrated i .
l e Adequacy of new EO.F.
j e Prompt activation of emergency response i facilities during off-hours . { e Timely callout of personnel e Accountability of personnel o Alternate assembly area I , , j e Dispatching of re-entry team j
:
e Rumor control l 0 Interfacility communications ' j o Operability of the P.A.S.S.
i !
l _ _ . - _ _ _ _ _ _
i l
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. _ . - . _ , - _ - - . _ _ _ _ _ . - _ _ _ _ _ ._ ,_
- - _ _ _ _ _ - - - __ -- .- . .
i
i Radiological Emergency Preparedness Plans
! e Demonstrate the adequacy of the Emergency Plan l and Emergency Plan Imp'ementing Procedures
'
both in terms of Management's control of an i emergency situation and the usefuleness of the procedures.
l e Demonstrate the capability to respond to an emergency situation between Midnight and
'
{ 6.00 AM.
'
* Demonstrate the capability to successfuly l
and effectively critique drill activities.
I i i _ _ _ _ _ _ _ _ _ . _ __________ - _ _ _ ____ _ _ _ -___ . . - - -_- __ _ _ __ -_
_ _ _ - - _ _ - __ - _ _ ___ _ -- ._ _ -_-
.- . .
. Notification Procedures j . . l
,
* Demonstrate the ability of BECo emergency
. response personnel to notify offsite agencies
- within fifteen (15) minutes after declaration l of an emergency.
l * Demonstrate the ability to alert, notify j and mobilize Pilgrim /BECo emergency response personnel.
,
l l i
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i i , _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ _ . _ _ _ _ . _ _ _ _ - - - - _ - _ - _ - - - - - - - - - - - - - - ~ ~ , _ . - - - - - - = - - _ - , - - - , - - ___ _ -_ _ _ _ _ _ _ - _ _ _ _ _ _ _ _
.-
. . .
W Emergency Communications 3
* Demonstrate the adequacy of communication links between emergency facilities, teams and offsite agencies.
- Demonstrate the ability to communicate
'
technical information to the State.
- _ -- ---- --- -- - _ _ . -
- - - - - - _ _ - - -
_ _. --_ - _ _ _ _ _ _ _ _ -. . _- .
.- . . .
Public Information . ! * Demonstrate the ability to create press . j releases and provide information to the l media via press briefings and ! media requests.
l e Demonstrate the ability to effectively respond l to technical questions at the Media Center.
! e Demonstrate the capability to respond to rumors ) and exercise effective rumor control.
i i i i
_ _ _ _ _ _ _ _ . _ __ _ __ --. - ._ _
- - _ _ _ - - _ _ . - _ . , _ - _ . _ _ _
. - - - _ - _ _ __- _ - - _ - _ _ . . _- .
e #
! ! Emergency Response Facilities !
l ) * Demonstrate prompt activation of
- emergency response facilities.
'
* Demonstrate functional adequacy of the l emergency response faclities, particuiarly i
! the new EOF.
l e Demonstrate the capability to staff and l maintain a manpower roster for protracted ! operations, ensuring sufficient personnel -- i have been activated and a 24-hour '
- assignment schedule is maintained.
l
l ! ______ _ - _ _ _ - - . _ . - _ - - - - - _ _
, _ . - - - - -
_ -- _ _ _ - - - _ _ _ - _ _ - _ - - - - _ - - _ ! .
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I . N Command and Control i i i l * Demonstrate the ability of key persomel ) to make timely and effective decisions with ! respect to a radiological emergency.
i
i i l
i i
, !__________________- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ - _ - - -
-- _ _ . _ _ _ _ _ _ . _ _ _ . - --_ _.. -__ _____.-._ _ _ _-
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__ --. . - - _ __
: . .
X Accident Assessment E e Demonstrate the ability to assess plant conditions, classify events as they occur and identify projected trends and potential consequences.
- Demonstrate E.e effective assemb'v. dspatch and controi of Envronmental Monitoring Teams.
- Demonstrate the ability to perform dose assessments, determine actual or poten' Jai offsite radiological hazards.
-_ _ __ _ _ _ _ _ _ _ _ _ _ _ - - - _ . - - - . .. _ _- _ _ -
- _ -
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! .
I l . Protective Response . l * Demonstrate the assembly and accountabilty l of all personnel within the Protected Area ! within thirty (30) minutes.
- Demonstrate the methods established to maintain j adequate access control and personnel accoctability l in the TSC/OSC.
i j e Demonstrate the ability to make timely Protective j Action Recommendations (PARS) to Offsite Agencies.
- Demonstrate the ability to evacuate on-site i personnel to the Alternate Assembly Area.
i !
. __-._- _ - - . . . ._.. .._-_._- - -- - - - ._-_ . .
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Radiological Exposure Control .
- * Demonstrate the ability to implement personnel
- dosimetry for emergency response personnel.
! l * Demonstrate the ability to dispatch re-entry i and repair teams in a timely fashion and l maintain doses ALARA.
} l I i i !
.. .- . .
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Emergency Medical Response . k l
* Demonstrate the ability to provide first-aid for a contaminated injured individual.
- * Demonstrate the ability to provide proper j radiological and contamination controls in j the handling of a contaminated injured i individual.
i i i ! ! , .! l
. _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ _
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Re-Entry and Recovery .
l * Demonstrate the activation of the Recovery ! Center to inc'ude the dispatch of personnel to l Pilgrim Nuclear Power Station if requested l by the Emergency Coordinator.
i ! e Demonstrate the capabilities of the Recovery Center to develop recovery plans and l strategies.
-
. i ! !
i
: . -
Utility Emergency Response Organization
. -
? Control Room
i i 'r ' Emergency Technical Operations ! Operations - ; Support a Support Facility (EOF) Center (TSC) Center (OSC) ! ! I j
<
r 'r l Offsite . Officials, NRC l Media i ! l _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - - _ _ _ _ - _ __. -
:
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Town of Plymouth
.
Primary Emergency Response . , i Board of Selectmen f I water Director N/CD Sec e ah M '
, ,r r
,
'
r Chief Chief Dir. Dept.
' Fire Dept. 1 I Poice Dept I of PttAc '
l . i f School Health f Harbor l ' l i I ss Department Director Master
,
;
,
- - - - --- _- _ _ _ _ -
._ _. -- - . .. ! ! -
Emergency Action Levels -
;
i 1. Unusual Event i l e No release of radiation , j * Police Department. Civil Defense Director, and Chairman of Board . of Selectmen notified
- .
! * No Action required i i l i ) . i ! l l I __-_-___ ____ ______ ____ _-______ _ ___ _ _ __ _ - _ _ _ _ - _ __ _ _ ___
. . .
l i
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Emergency Action Levels - ,
i l 2. Alert
-
l * No release outside plant !
* All town officials notified
* Stand-by status .
! I I i l l l
_ . _ - _ . _ - _ - - _ . _ . _ _ _ - _ _ . - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ ___ -_ _ _____- -. - - - _ _ _ _ _ _ - _ - _ _ _ _ - _ _ - - _ _ _ _ _ _ _ _ _ _ - -
.- .-
! . .
. -
) - Emergency Action Levels . l 3. Site Area Emergency
* Potential for release of radiation m
with significant levels within ! plant site only l e All town officials notified I e Activate EOC .
, ! l
- -- - : - - .
i , Emergency Action Levels
I . 4. General Emergency e Potential for release of radiation ! with significant levels beyond site
boundary i e All town officials notified l e Coordinate situation from EOC i I
.
!
4 _ _ _ _ _ - _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ __- _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - - - - _ _ - _ - - - _ _ _
_ -
! .~ .. .
Town of Plymouth l i . UNUSUAL EVENT - ! l ' Boston Edison Co.
Pilgrim NPS
i l
1f f l Plymouth Massachusetts ! Police Dept. , State Police Via Plymouth County Polce Net
,r Civil Defense Director ,r ' r
' Chairman. MCDA Area 11
^ "'
Board of Selectmen Bridgewater incud P outh
! l
i i ____ _ _ _ _ _ _ _ _ _ _ __ _ _ __ _ _ _ __ _ _ __ ____ __ ___ _ _ _ _ _ _ _ _ _ _ _ _ _ __ . _ _ _ _ _ _ _ _ _ _ _ ___1
- : . -
l '
,
Town of Plymouth E ALERT ! Boston Edison Co.
] Pilgrim NPS
l .
,, s
Plymouth Massachusetts Police Dept. State Police Via Plymouth County ' Placed on stand-by Police Net
<r Civi Defense Director ,
r <r Chairman, N MCDA Area il All Local l
'
Board of Selectmen Communities ' Executive Secretary, Bridgewater including Plymouth Board of Selectmen Members, Board of Selectmen Police Department Fire Department Public Works School Department Harbormaster Board of Health Red Cross
_.. _ _ _ ._ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ - - - -
:
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I Town of Plymouth
-
Site Area Emegency & General. Emergency j . l Boston Edison Co.
' Pilgrim NPS
<
r i r Plymouth Massachusetts Police Dept. State Police
' "
Activate / Report to EOC P ico Ne
<r ,
Civl Defense Director ,r ,r Chairman. All Local l Board of Selectmen MCDA Area 11 Communities l
'
Executive Secretary, Bridgewater including Plymouth Board of Selectmen
. '
Members, Board of Selectmen PoEce Department Fire Department Public Works
; School Department Harbormaster Board of Health Red Cross !
l _ _ _ _ _ _ _ _ - _ - _ - _ _ _ _ _ _ - _ _ _ _ _ _ _ - - _ _ - _ _ _ _ _ _ _ __
_ .
. .
_
; . -
l I E Offsite Emergency Response E l
Local j e Plymouth Police Department
* Plymouth Fire Department
) e Jordan Hospital ! State l * Mass. Civil Defense Agency
* Mass Department of Public Health
~
j Federal l e Nuclear Regulatory Commission e Federal Emergency Management Agency l * Department of Energy l
- - - - - - - - - - - - _ - - - - - - - - - - - - - - - . _ - - - . _ - -_ _ _ _ -
- . - .
E Personnel Emergency E
e Onsite emergency medical treatment of an individual with or without personnel i contamination e Offsite emergency treatment of an
- individual without personnel contamination e Cannot have the potential to escalate to a higher class of emergency
- e Does not require a formal declaration of emergency
, l . I
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - _ _ _
_ . .
. e j . .. .
f
-
Personnel Emergency Actions .
a l i ! ! e Medical assistance i
* In ormational notif.ications
, ! l I
i ! l
! l, i
, , . . .
!
.
Unusual Event . l
* Events which indicate a potential degradation of safety of the plant
! * No releases of radicactive material
) e Most EALs associated with exceeding ' technical specifications
!
l i
.
. i L__________________-_________________ _
~
i . j . .
.. -
-
Unusual Event Actions - ! ) i I e Notifications made for informational
! purposes
,
o Mobilize necessary portions of I emergency organizations
i i
4 i
. - _ _ - _ - _ _- _ _ _ __ _ . . - - _- . . - - _ _ . ._ _____ _ ___
_ _ - . - . _ . - -- - _ _ . - - _ . ._ .- _ _. . - _ . _. __ ! l s . . l l
.
Alert -
i ! e Events which involve actual or potential ! substantial degradation of the level of safety of the plant
-
, ) e Possible limited releases to radioactive l materials i i i
! !
i
! _. _ _
_ - -
- : = ..
E Alert Actions E ) * All onsite and offsite emergency organizations placed on standby status
'
! e TSC supervisor and EOF communications coordinator activate their respective facilities , o Shorefront is closed ! e Access to PNPS is controlled l e Control room access is controlled . l
l _ _ _ _ _ -_ _ _ _ _ - _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ .__0
-- _ - -
$ l
.. .
.
, Site Area Emergency I
'
! ) e Events which involve actual or potential i major failures of plant functions needed l for protection of public j e Significant releases may occur
- e No protective action recommendations for l the general public anticipated
! l
l l
. _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___-_
. -
. .
l i R Site Area Emergency Actions E !
! * Full activation of emergency organization
- and all emergency response facilities i
boti onsite and offsite
* Site evacuation to I & S building .
l
)
I
I l l ! l l
. -
- - - - _ - - - . . .
l .. - l
- General Emergency
,
4
* Highest class of emergency i
e Events which involve actual or potential substantial core damage .
- * Significant release may occur
* Protective action recommendations for the i
general public probably warranted
l
i i __ _ - . _ _ ._
. - - -- -
,.
. .
- General Emergency Actions .
-
l * Full activation of emergency response 1 facilities both onsite and offsite i e Site evacuation to ! & S building e immediate recommendations that all members l of the general pubic within a 5-mile radius l be requested to remain indoors
:
l
* Prompt notification system may be activated l
)
!
l
I
- . .
. _ _ - _ _ _ __ __
-. _
!
.. .
i SIRENS ! l Plymouth 58 sirens - 32 rotating
i Marshfield 3 sirens - 1 rotating ! l Carver I 7 sirens - 7 rotating Kingston 9 sirens - 7 rotating , Duxbury.
17 sirens - 15 rotating
- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
_ _ _ _ - _ _ _ _ _ - _ _ _ . -. __ ._. .. _. _ -. .
.
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, ! ! i f
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'
- Initially installed February 1982 i
'
- Manufacturers: Federal Signal l -
electronic sirens
-
Motcsola intrac 2,000's l ) i ! l f i l i
.. -- -. -
- -
. _ -- _ - __ _ _ . - __ _ . . - - - _ _ .
,
-
.,
- Monthly Testing - Yearly Maintenance -
F.E.M.A. Siren Test -
-
September 29,1986 f 88.2 %
\ -
j
.
- -- . . . .
E E Guidelines For Protective Action Recommendations For The General Public
-
E
, !
! ! l '
- _ - _ . . - - - . _ _ _ . - . _ _ _ . _ . _ _ _ _ _ _ _ _ _ _ _ _ ._ _
_ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ . _ ___ _ _ ___ _ _ _ . . _ _ _. . _ _ _ _ _ . _ _ _ _ _ _ _ _
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i
Projected Dose (Rem) to the Recommended Population Actions Comments Whole body 1 No planned protective Previously recommended i j actions. . protective actions Thyroid 5 State may issue an may be reconsidered advisory to seek or terminated.
shelter & await further instructions.
Monitor environmental radiation levels.
. I
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) l ___ _ _ _ - ____ _ _ _ _ -__-_ - - _ -_ _ __ _ _ - - _ - _ - _ _ .
- _ _ . - _ _ _ _ - . - _. _ ______ _ - _ - ___ - _ _ - . . _ __ _____ __ . _ _ _ - - __ '
) -
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- Projected Dose l (Rem)tothe Recommended
I Population Actions Comments
- !
! Whole body Seek shelter as a If constraints exist,
j ( 1 to 5 ) minimum. special consideration ' Thyroid Consider evacuation. should be given ! ( 5 to 25 ) Evacuate unless for evacuation
l constraints make it of children & l impractical. pregnant women.
j Monitor environmental radiation levels.
i . ! Control access.
i ! i i L _ __ _ - . _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ ___- _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
_ _ . .- _ . - - _. - . I *
* * .
i
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i j Projected Dose l (Rem) to the Recommended ! Population Actions Comments j! Whole body Conduct mandatory Seeking shelter would i ! (5 & above) evacuation. be an alternative I j Thyroid Monitor environmental if evacuation were !
(25 & above) radiation levels & not immediately l adjust area for possible.
. mandatory evacuation ] based on these levels.
' Control acce ,s.
I
I I i l l- _ _ _ _
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. - - - _.- - ______ --_ __ - . _ _ _ _ - _ _ _ _ . . - - _
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! I i' These actions are recommended for planning purposes.
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i i Protective action decisions at the time l of the incident must take existing I i , conditions into considerat. ion.
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_ i l _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ - - _ _ - _ - - _ - - - _ - . . . _. - --- -. . - - - - - . _ _ _
--
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1 l l At the time of the incident, officials may
- implement low-impact protective actions l in keeping with the pnnciple of maintaining I radiation exposures as low as reasonably '
, achievable.
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0FFICE MEMORANDUM _98 63034S1 Boston Edison Comp.itny p
* *
/ '
l!% Control Number pep ft ' To: 4. Pedersen From: E. emianski _.
Record Type A4.08 Date: 5/8/86 Dept. Doc NMSS 86-103 None-Safety Related - Subject: pcurityProgramImprovementsStatusRepctt#4 Dist-ibution: J E.T. Graham T. Nicholson P. Hamilton J. Crowder J.A. McEachern M. McBride
. * Atta:hed please find the fourth monthly status report on planned security '
prog am improvements. It is recommended that these reports be forwarded to
,
Mess s Oxsen and Harrington for review and comment.
. Attn: went i
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Dept. Doc. NMSS 86-103 To: A. Pedersen Date: S/8/86 Page 2 Subject: Security Program Improvements Status Report #4 . ATTACHMENT 1
: :
Plan and Schedule of Security Program Imorovement , Increased Management Overslaht - Corporate Security
*
i Plan to establish a Corporate Security Representative to strengthen the interface between site und corporate security personnel. This individual will be respon:'b5; to perform audits in accordance with a structured j audit plan, review program document changes, and maintain state-of-the-art knowledge of security methodologies. This change will be reflected in the Corporate Bulletin Book. ' Original
* Scheduled Current Planned Milestones Ccepletion Status * - Develop job description and approve Feb. 1986 -Com;:le te ! - Commence hiring process for corporate Mar. 1986 -Complete -
security representative
- Corporate Security Representative on Apr. 1986 -Behind Schedule '
board 3 wks. Expected l l, on board 5/18/86 j - Revise Corporate Bulleting Book S-6 to Complete reflect increased involvement of site i security by corporate.
t
*
alan to hire five s5) Boston Edison security supervisors to provide shif t ! t overage of the contract security force.
Original l
'
Scheduled Current
.
Planned Milestones Completion Status
- Develop job description and approve. Jan. 1986 Complete - Commence hiring process for Boston Feb. 1986 Ceeplete i
Edison site security supervisors. Jobs Posted
- First additional Boston Edison site Acr. 1986 Complete i
security supervisor on board.
- umaining Boston Edison site security Jul. 1956 On Schedule
, supervisors on board.
I Self-audits *
'
l
- *
Slan to audit the sectiers of tne security olan on a re;slar basis sucn tra: !
- ,e ent,,e pla, ,, add,es,ec e, co,ce,a,e ,e_i1, o_ ea r.
. _ --. __ - - - - - . _ _ _ . _ _ . _ - - --- _
. . .
Dept . Doc. NMSS 86-103 To: A. Pedersen Date: 5/8/86 Page 3 Subject: Security Program Improvements Status Report #4 . Original Scheduled Current Planned Milestones Completion * Status
- Develop corporate level self audit Feb. 1986 Audit program program for the site security plan complete - Review and approve audit program. Apr. 1986 Complete i - Commence first module of audit program Jun. 1986 On Schedule *
. Plan to establish procedures for the existing internal surveillance effort and ! include the scheduling of these surveillances in the Master Surveillance Tracking Program.
*
Original j Scheduled Current , Planned Milestones Completion Status - l .
- Develop procedure to formalize existing Feb. 1986 Complete surveillance programs.
- Approve and issue procedure. Mar. 1986 Complete ) - Revise MSTP to schedule these surveil. Mar. 1936 Complete l tests.
' Corrective Actions System
*
Plan to develop a procedure to standardize the reporting of security deviations i and to initiate tnorough and effac*1ve corrective actions. The procedure will t
!
include a form for reporting deviations and will require a trend analysis of j deviations to identify recurring problems. , ,
' original Scheduled Current Planned Milestones Completion Status l
;
i
- Identify and evaluate requirements of Mar. 1985 Complete (
the corrective action system. ,
]. - Develop and approve procedure, incluc- Jun. 1985 On schedule j ing fora, for reporting deviations.
1 J
- Indoctrination and implementati.on of Jul. 1986
*
process. ,
'
l - Perform first trend analysis of devia- Jan. 1987 ! tions to identify recurring prcDiemt.
l I
- __ _ _ .__ .. _ __-__ - _--_-__.. . . _
*
,
e Dept. Doc. NMSS 86-103
*
To: A. Pedersen Date: S/8/86 Page a Subject: Security Program Improvements Status Repoi t #4 , Regulatory Requirements Analysis i
*
Plan to perform a regulatory requirements analysis of the Modified Amended Security Plan (MASP). Safeguards Contingency Plan, and Training and Qualification (T&Q) Plan vis-a-vis the Code of Federal Regulations. This analysis is to assure that the regulatory requirements are met by existing programs and procedures.
Original . Scheduled Current ' Planned Milestones Completion Status
.,
- Obtain resources to perform analysis Jan. 1986 Complete
.
'
.
-
d
- Determine methodology of performing Feb. 1986 Complete analysts. . - Perform regulatory requirements analysis Oct. 1986 On schedule (interim milestones have been established for this task and are available upon re- , quest).
- Revise Boston Edison program documents Pending results and procedures as required of analysis l Tra'ning ' i
, '
Plan to evaluate the present approach to training such that: i (1) Security force personnel have a greater sense of awareness of the bases ! behind their duties (i.e. why they are here).
I (2) Security force personnel understand the need to initiate aggressive cor-l rective action and to follow-up thoroughly.
l Original Scheduled Current Planned Milestones Completion Status j j - Determine evaluation method Jan. 1986 Complete
) - Perform evaluation. Feb. 1986 Complete
- Issue repor t with evaluation re'sults Mar. 1986 Complete- ! (to (JZ) ,
J
- Revise present accroach to training as Dencing evalu-reauireo. ti:n ess!!s !
. _ . . . .. '
Dept. Occ. NMSS 86-103 To: A, Pedersen Date: 5/8/86 Page 5 Subject: Security Program Improvements Status Report #4 .
4 ATTACHMENT 2 Compensatory Measures on Loss of Security Ceeputer
A recent concern was raised by our Senior NRC Resident Inspector, Dr. M. McBride, regarding establishment of compensatory measures within 10 minutes if the security computer becomes inoperable. The concern is that in 1985, six security event reports have been filed because full compensatory limits were not establishJd within 10 minutes after loss of the security computer.
As stated in our November 27, 1985 letter, Boston Edison has reviewed the
.
situation and implemented the following corrective actions: '
- Reviewed and revised the response methodology allowing security i -
personnel to man the required posts within 10 minutes, i
- Temporarily increased staffing levels as an interim measure to en- .
sure the 10-minute response time can be met.
l
- Provided pre-established compensatory zone assignments on each shif t in the event the cceputer becomes inoperable.
- Trained security force on the revised methodology of response.
- Conducted drills and verified that less than 10-minute response is achieved.
' In addition to the completed actions stated ab "e, the following actions are ) planned: l Original ! ! Scheduled Current ' Planned Milestones Completion Status j - Evaluate the reliability of the security Complete i computer '
- Develop recommendations for computer
Complete j improvemen t s . ' l - Decision on optimal recommendation. Mar. 1986 Complete ( , Spec for computer i i upgrade to be ! l ' starte:1 last Qtr. l
.
1986 (itef. meno I ! AD86-13Y l l
- Implement optimal reccmmencation'.
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' .
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Dept. Doc. NMSS 86-103 To: A. Pedersen Date: 5/8/86 Page 6 Subject: Security Program Improvements Status Report #4 -
'
Plan to proceduralize the process of pre-established compensatory zone assignments. , Original Scheduled Current Dlanned Milestones Completion Status
- Revise existing procedure to formalize Feb. 1986 Complete compensatory zone assignments (Proce-
- , dure 3.10)
- Approve and issue procedure Mar. 1986 Complete .
l
'
Plan to standardize security event reporting.
I
-
Original Scheduled Current - ' PjannedMilestones Completion Status
- Revise and approve procedure to Feb. 1986 Complete standardize requirements of security l ' '
Determine feasibility of revising the Centingency Plan ; i i
Original r Scheduled Current l i Planned Milestones Completion Status i j - Evaluate existing security systems to Feb. 1986 Complete - con- l determine feasittlity of revising the tingency plan not ; ., Contingency Plan to include increased to be revised to l l response time to computer outages, increase response '
- time.
l
- Submit proposed cn4nges to Contingency Plan not to be l , Plan for NRC approval, revisea on this !
subject, !
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OFFICE MEMORANDUM
.
Boston Edison Company
, 986303612 . .
RMG Control Number To: A. Pedersen from: 1emianski Date: 6/16/86 Record Type A4.08 Dept. NHSS 86-107 Non-Safety Related Subject: Security Program Improvements Status Re; ort #5
Distribution: ,
! E.T. Graham T. Nicholson J. Crowder P. Hamilton J.A. McEachern M. McBride Attached please find the fifth monthly status report on planned security program improvements.
It is recommended that these reports be forwarded to Messrs. Ousen and Harrington for review and coment.
Attachment , l
*
The content and scope of this report will be revised next ecnth based on the recent assessment of progress by BECo and the NRC.
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.- Dept. Doc. NMSS 86-107 To: A. Pedersen Date: 6/16/86 I* Subject: Security Program Improvements Status Report #5 Page 2 I
'
!
ATTACHMENT 1 Plan and Schedule of Security Program Imorovement},
Increased Management Oversight - Corporate Security
*
i
Plan to establish a Corporate Security Representative to strengthen the ' interface between site and corporate security personnel. This individual will be responsible to perform audits in accordance with a structured ) audit plan, review program document changes, and maintain state-of-the-art
,
knowledge of security methodologies. This change will be reflected in the l Corporate Bulletin Boca.
Original Schedulec Current Planned Milestones Completion Status
- - Develop job description and approve Feb. 1986 -Complete 4 - Commence hiring process for corporate Mar. 1986 -Complete l security representative
i - Corporate Security Representative on Apr. 1986 -Complete 6/1/86 1, board
- Revise Corporate Bulleting Book B-6 to Complete a
reflect increased involvement of site , ) security by corporate, i 1 * t Plan to hire five (5) Boston Edison security supervisors to provide shif t coverage of the contract security force. l
,
Original i Scheduled Current l Planned Milestones Completion
!
i Status i
'
- - Develop job description and approve. Jan. 1986 Complete
! ! l - Commence hiring process for Boston Feb. 1986 Complete I ) Edison site security supervisors.
- Jobs Posted (
,
!
- First additional Boston Edison site Apr. 1986 Complete j security supervisor on board. '
't
; - Remaining Boston toison site security Jul. 1986 Cn Schedule supervisors on boarc. !
,
(4 on boare, :
, 1 to 90) { 1 , i l Self-Audits
! l
*
,
Plan to audit the sections of the security plan on a regular basis such that \ l i the entire plan is addressed by corperate security one/ year.
i l
<
i - _ _ _ --_ - -- -----
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*
. Dept. Doc. NMSS 86-107
' Te: A. Pedersen Date: 6/16/86 Page 3 Subject: Security Program Improvements Status Report #5
,
L Original Scheduled Current Planned Milesiones Comnletion Statys I
- Develop corporate level self audit Feb. 1986 Audit program program for the site security plan complete
'
- Review and appro'e v audit program. Apr. 1986 Coeplete
- Commence first module of audit program Jun. 1986 On Schedule
"
*
Plan to establish procedures for the existing internal surveillance effort and * include the scheduling of these surveillances in the Master Surveillance Tracking Program.
Original Scheduled Current
! Planned Milestones Completion Status
i
- Develop procedure to formalize existing Feb. 1986 Complete survelliance programs.
,
- Approve and issue procedure. Mar. 1986 Complete
- Revise HSTP to schedule these survell. Mar. 1986 Coeplete
, tests. '
Corrective Actions System '
*
Plan to develop a procedure to standardize the reporting of security deviations
! and to initiate thorough and effective corrective actions. The procedure will include a form for reporting dt.viations and will require a trend analysis of i , deviations to identify recurring problems.
) . i Original ' Scheduled Current j Planned Milestones Completion i Status i l
- Identify and evaluate requirements of Mar. 1986 Complete l
the corrective action system.
- Develop and approve procedure, includ- Jun. 1986 } ing form, for reporting deviations. On schedule ,
- Indoctrination and implementation of Jul. 1986
process.
- Perform first trend analysis of devia. Jan. 1987 tions to identify recurring problems.
1
- - - - _ _ _ - _ _ _ - - - - - - - - _ _ _ _ _ . - . - - _ _ _ - _ _ _ _ _ _ - . _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . _ _ _ - _ _ . . _ _ _ _ _ - - - _ _ _ - _ - _ - . . _ _ -
.. ,
Dept. Doc. NMSS 8(-107 , To: A. Pedersen Date: 6/16/86 Page 4 Su,bj e c t : Security Program Improvements Status Report #5 _ Regulatory Requirements Analysis
*
Plan to perform a regulatory requirements analysis of the Modified Amended Security Plan (MASP). Safeguar:s Contingency Plan, and Training and Qualification (T&Q) Plan vis-a-vis the Code of Federal Regulations. This analysis is to assure that the regulatory requirements are met by existing programs and procedures.
Original Scheduled Current Planned Milestones Completion Status
- Obtain resources to perform analysts Jan. 1986 Complete - Determine methodology of performing Feb. 1986 Complete analysis.
- Perform regulatory requirements analysis Oct. 1986 On schedule (Interim milestones have been estaullshed (2 of 14 modules for this task and are available upon re- complete) Quest).
- Revise Boston Edison program docurrents Pending results and procedures as required of analysis Training i Plan to evaluate the present approach to training such that:
(1) Security forte personnel have a greater sense of awareness of the bases behind their duties (i.e. why they are here). ' (2) Security force personnel understand the need to initiate aggressive cor. i rective action and to follow-up thoroughly.
Original i Scheduled Current l alanned Milestones comotetion Status l
- Determine evaluation trethoc Jan. 1986 Complete l - Perform evaluation. Feb. 1986 Complete - Issue report with evaluation results Har. 1986 Complete (to EJZ) - Revise present approacn to tra;ning as Pending evalu-reagired.
tion results
' . ,
Dept. Doc. NMSS 8?-107
' . To: A. Pedersen Date: 6/16/86 Page 5 Subject: Security Program Improvements Status Report #5 l
ATTACHMENT 2 ' Compensatory Measures on loss of Security Computer
-
, A recent concern was raised by our Senior NRC Resident Inspector, Dr. M. McBride, regarding establishment of coepensatory measures within 10 minutes if the security concater becomes inoperable. The concern is that in 1985, six security event , reports have been filed besause full compensatory limits were not established
' !
- within 10 minutes af ter loss of the security computer.
j * As stated in our November 27, 1985 letter, Boston Edison has reviewed the situation and implemented the following corrective actions:
- Reviewed and revised the response methodology allowing security personnel to man the required posts within 10 minutes.
!
- Temporarily increased staffing levels as an interim measure to en-t sure the 10-minute response time can be met.
I - Provided pre-establisned compensatory zone assignments on each shift in the event the computer becomes inoperable, j - Trained security force on the revised methodology of response.
! - Conducted drills and verified that less than 10-minute response is j achieved.
*
j In addition to the completed actions stated above, the following actions are planned: f ,
'
Original Scheduled Current -
- Planned Milestones Completion Status i
- Evaluate the reliability of the security Complete computer
.
- Develop recommendations for coeputer Complete
' improvemen t s .
- Decision on optimal recoceendation. Mar. 1986 Complete Spec for co puter upgrade to be ; started last qtr.
' 1986 (Ref, memo 4 A086-73), addes to long Term l, Program.
q
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Dept. Doc. NMSS 86-107
.
Te: A. Pedersen Date: 6/16/86 Page 6 , Subject: Security Program Improvements Status Report #5 l
'
. , j ! l
' Plan to procedurallre the process of pre-estabitshed compensatory zone ,
assignments. , Original f J Scheduled Current ! l Planned Mlle). tones Comoletion Status j
'
i
; - Revise existing procedure to formalize Feb.1986 Complete !
coepensatory zone assignments (Proce- ; J dure 3.10) L
- Approve and issue procedure Mar. 1986 Complete f
;
] I, ,
* Plan to standardite security event reporting.
i Original Scheduled Current !
:
j Planned Milestones Coeoletion Status
- Revise and approve procedure to Feb. 1986 Ccmplete (
standardize requirements of security
'
f I
'
Determine feasiblitty of revising the Contingency Plan l i i Original , j Scheduled Current i
;
Planned Milestones Coeoletion Status
-
- - Evaluate entsting security systems to Feb. 1986 Complete - con. I l determine feasiblitty of revising the tingency plan not !
j Contingency Plan to include increased to be revised to [ j response time to computer outages. increase response i
'
{ time.
t ! - Substt proposed changes to Contingency Plan not to be 1 Plan for NRC approval, revised on this 2 subject. . I
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0FFICE MEMORANDUM
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Boston Edison Company *h 486303812 RMG Control Number To:
.
A. Pedersen 9r.om:T. h ,. m E.J. Ziemianski - Date: Record Type A4.08 7/17/86 Dept. Doc NHSS 86-128 Non-Safety Related Subject: Security Program Improvements Status Report #6 Distribution: E.T. Graham T. Nicholson J. Crowder P. Hamilton J.A. McEachern N. McBride R. Swanson Attached please find the sixth monthly status report on planned security program improvements, it li recomended that these reports be forwarded to Messrs. Onsen and Lydon for review and concent.
Attachment
*
The content and scoce of this report will be sucplerented based on the recent assessments of progress and tne June 12 eetting with the NRO.
_
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'l o c u w e ,, ,
ELEASED . I R w
,
ed?2dJ Eh
, *
Dept. Doc. WSS 86-128
'
Te: A. Pedersen Date: 7/10/86 Page 8
- Subject: Security Program Improvements Status Report #6
! -
=
.
[
i ATTACHMENT I
'
i
- Plan and Schedule of Security Program Improvements
, * Increased Management Oversicht - Corporate Security
*
Plan to estab11th a Corporate Security Representative to strengthen the l ) interface between $lte and corporate security personnel. This individual
will be responsible to perform audits in accordance with a structured
'
i audit plan, review program document changes, and maintain *. tate-of-the-art j knowledge of security methodologies. This change will be reflected in the j Corporate Bulletin Book.
j Original i
1, Scheduled Current i , Planned Nilestones
-
Completion Status ! I
- Develt,p job description and approve Feb. 1986 -Complete
i
- Comence hiring process for corporate Har. 1986 -Complete I security representative
- Corporate Security Representative on Apr. 1986 -Complete board i
,
b
! - Revise Corporate Bulleting Bock B-6 to Complete -Complete '
, reflect incressed involve ent of site security by corporate.
'
j Plan to hire five (5) Boston Edison security supervisors to provide shift ; coverage of the contract security force.
t Original ' Scheculed
.
Current Planned M11estones Completion Status (
(
) m Develop job description and approve. Jan. 1986 Complete ! i
! - Coenence hiring process for Boston Feb. 1986 Complete j
Edison site security supervisors. i Jobs Posted
- First additional Boston Edison site Apr. 1986 Complete security sugervisor on toard. ,
'
;
i
- Remaining Boston Edison site security Jul. 1986 On Schedul'
,
Supervisors on boarc. l (4 on board, j
,
I to go) 1
* Se l f- Aut i t s I * t Plan to audit the sections of the secu.ity plan on a regular basis such that j the entire plan 15 addresses by corporate security one/ year. l 1 l I' * Note this itee =111 te delete from the neit recort since i t is cc* lete. f i i
. .
.- _ _ - . - - - - -- - ---
. .
Dept. Doc. NMSS 86-107
'
To: A. Pedersen Date: 7/10/86 Page 3 Subject: Security Program Improvements Status Report #6
.
.
'
Original Scheduled Current Planned Milestones CompleElon Status
j - Develop corporate level self audit Feb. 1986 Audtt program
-
program for the site security plan cceplete t ] .
- Review and approve audit program. Apr. 1986 Cceplete l - Commence first module of audit program Jun. 1986 Complete * * Plan to establish procedures for the entsting internal su.*veillance effort and l include the scheduling of these surveillances in the Master Surveillance i Tracking Program.
Original ' Scheduled Current Planned Milestones Ccepletion Status
! - Develop procedure to formaltre existing Feb. 1986 Complete !
surveillance programs, j - Approve and issue procedure. Mar.1986 Ceeplete l
[ - Revise MSTP to schedule these sarvell. Har. 1986 Ceeplete j tests.
l Cc rective Actions System l ! ! * Plan to develop a procedure to standardize the reporting of security deviations i and to initiate thorough and effective corrective actions. The procedure util ; _ include a form for reporting deviations and will require a trend analysis of l , ceviations to identify recurring problems.
i . Original Scheduled Current j P_lanned Milestones Completion Status i
l J - Identify and evaluate requirerents of Mar. 1986 Complete l l the corrective action system.
{
\
U - Develop and approve procecare, includ- Jun. 1986 Cceple te ! ] ing form, for reporting ceviations.
I - Incorporate into NCP 83A9
'
To be determined
-
by QA i * l - Indoctrination and leplerentation of Jul. 1986 On Schedule
- process.
l - Perform first trend analysis of devia- Jan. 1981
;
tions to identify recurring pro lems.
- l * Note - this iten =111 te deleted from the nest report since it is cce:1ete.
L ---
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:
Dept. Doc. NMSS 86-128
'
To: A. Pedersen Date: 7/10/86 Page 4 Subject; Security Program Improvements Status Report #6
.
Regulato'ry Requirements Analysis - 2 Step Process (1.) Confirm Conpliance (2.) Approach Excellence
* Plan to perform a regulatory requirements analysis of the Modified Amended '
Security Plan (MASP), Safeguards Contingency Plan, and Training and Qualification (T&Q) Plan vis-a-vis the Code of Federal Regulations. This , 4.alysis is to assure that the regulatory requirements are met by existing l programs and procedures.
' l
) Original , Scheduled Current l
, Planned Milestones Completion Status [
l - Obtain resources to perform analysts Jan. 1986 Complete !
,
;
) l
- Determine trethodology of performing Feb. 1986 Complete l
analysis. ! i - Meet with NED to assess progress & j . determine initial scope of mods. To be determined ;
by JAM , !
- - Perform regulatory requirements analysis Oct. 1986 On schedule
: (interim milestones have been established (4 of 14 modules i for this task and are available upon rs- cceplete) l Quest), i I L i
'
- Revise Boston [dison program docurrents Pencing results I and procedures as required of analysis
'
j _ training ; Plan to evaluate the present approach to training such that: l
.
l i (1) Security force personnel have a greater sense of awareness of the bases j ! behind their duties (i.e. why they are here).
I
< (2) Security force personnel. understand the need to initiate aggressive cor- ! rective action and to follow-up thoroughly.
, ) Original i Scheduled Current j Dianned Milestones Coepletion Status l
- Cetermine evaluation method Jan. 1986 Complete ; .
l - Perform evaluation. Fet. 1986 Complete I - !ssue report with evaluation results Par. 1986 Complete l (to EJZ)
- Revise present approach to training as Pe cing evalv- ,
j required, tion results ! I _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . ._ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
_ _ _ _ ________ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -
. - Dept. Doc. NMSS 86-128 To: A. Pedersen Date: 7/10/86 Page 5 *
Subject: Security Prograa Improvements Status Report #6
. '
ATTACHMENT 2 ,
Compensatory Measures on Loss of Security Computer , A recent concern was raised by our Senior NRC Resident Inspector. Dr. M. McBride, l - regarding. establishment of compensatory measures within 10 minutes if thi security " computer becomes inoperable. The concern is that in 1985, sir security event i } reports have been filed. tecause full ccepensatory ilmits were not established I l within 10 minutes af ter loss of the security computer. l
* * As stated in our November 27. 1985 letter, Boston Edison has reviewed the 1 situation and implemented the following corrective actions: !
I
- Reviewed and revised the response methodology allowing security l j personnel to man the required posts within 10 minutes, j , - Temporarily increased staffing levels as an interim measure to en-sure the 10-minute response time can be met.
) - Provided pre-established compensatory zone assignments on each shif t I 4 in the event the computer becomes inoperable.
- Trained security force on the revised methodology of response.
- Conducted dellis and vertfled that less than 10-minute response is j achieved.
I !
' *n addition to the coepleted actions stated above, the following actions are i planned:
) Original l Scheduled Current Planned _ Milestones Completion Status _
- Evaluate the reliability of the security Cceplete !
, , computer I
- Deveico recomendations for computer Complete
, improvewnts. i
.
j - Decision on optimal recce encation. Mar. 19?6 Complete ! 3 Scec for cecouter i ] gegrace to te ! started last atr. l
'
1936 (Ref. me o A086-73). Added !
-
to Long Term i
. Program. Cur- li rently reassess-ing priorities, j
]
- Implement octical recewendation, j i
] ' Note - inis itet to ce deleted from tre neit reccet since it is c:?clete. l l
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j [- Ovpt Doc. NMSS 86-128 i
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TO: A. Pedersen Date: 7/10/86 Page 6 l* Subject: Security Progra3 Improvements Status Report #6
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* * Plan to proceduralize the process of pre-estabitshed compensatory zone assignments.
0-tginal i
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Scheduled Current ,
#1anned Milestones Coepletion Status - Revise existing ' procedure to formalize Feb. 1986 Complete compensatory zone assignments (Proce-dure 3.10) , . Approve snd issue procedure Mar. 1986 Complete i
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* * 81an to standardize security event reporting.
Original Scheduled Current Planned Milestones Completion Status i
- Revise and approve procedure to Feb. 1986 Complete standardize requirements of security t * ' Ottermine feasibliity of revising the Contingency Plan (
Original l Seneduled Current !
:lanned Milestones Cecoletion Status - Evaluate existing security systems to Feb. 1986 Complete - con- ~ determine feastbtitty of revising the tingency plan not '
Contingency Plan to incluce increased to be revised to ; response tire to coeputer outages. Increase response i
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time. ;
- Submit proposed changes to Contingency Plan not to be Plan for NRC approval, revised on this -
subject.
- inote This ites to be deletes from next report since it is complete.
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