ML20045D909

Ack Receipt of 930526 Petition Submitted on Behalf of We the People,Inc of Us.Petition Requests Immediate Action to Delay Scheduled Startup of Plant

ML20045D909
Person / Time
Site:	Pilgrim
Issue date:	06/22/1993
From:	Murley T Office of Nuclear Reactor Regulation
To:	Hadley E HADLEY, E.C.
Shared Package
ML20045D910	List: ML20045D909 ML20045D911
References
NUDOCS 9306300204
Download: ML20045D909 (6)

Text

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NUCLEAR REGULATORY COMMISSION

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WASHINGTON. O,C. 205S5-0001 June 22, 1993 Docket No. 50-293 Ernest C. Hadley 414 Main Street P.O. Box 3121 Wareham, MA 02571

Dear Mr. Hadley:

This letter is to acknowledge receipt of a Petition dated May 26, 1993, submitted by you on behalf of We the People, Inc., of the United States-(Petitioner) to the Executive Director for Operations of the U.S. Nuclear Regulatory Commission (NRC) pursuant to 10'CFR 2.206. The Petition has been referred to my Office for praparation of a response.

The Petition requests immediate action by the NRC to delay the scheduled-startup of the Pilgrim Nuclear Station. operated by the Boston. Edison Company (Licensee), or, in the alternative, to order its immediate shutdown if the.

Pilgrim Station is permitted to start up before the Petition can be acted on.

The Petitioner requests that the Pilgrim Nuclear Station not be' permitted to operate until the Licensee completes hardware: modifications designed.to.

eliminate errors in reactor water level measurement. The Petitioner contends that the system in place at the Pilgrim facility does not adequately measure the water level of the reactor vessel and-thus constitutes!an unacceptable risk to the health and safety of the public. The Petitioner alleges that the NRC staff informed the public in February'1993 that the NRC had based its-determination that continued operation of boiling water reactors (BWRs), such as the Pilgrim facility, did not pose-a safety threat'on generic studies performed by the Boiling Water Reactor hiners Group' (BWROG). These studies showed that water level errors would be measured in inches and would be self-correcting'within a short period of time. The Petitioner alleges that these assurances were given despite the fact that on January 21, 1993, Washington Nuclear 2 (WNP-2) reported a'significant event in which a water level error of.

more than I hour in duration was observed.

It is further alleged-that this error was significantly larger than those previously observed.

Additionally, the Petitioner alleges that it requested information.from the NRC used by the Pilgrim Licensee to make its operability determination for the water level measurement-system as required by the Technical Specifications for the Pilgrim facility. Because the NRC failed to provide this information, the Petitioner concludes that such'information either does not exist or would not withstand independent scrutiny.

Finally, the Petitioner refers to' a meeting ~of the #1visory Committee on Reactors Safeguards (ACRS) held on.May 12, 1993,.which included the BWROG.

It is the Petitioner's understanding that during a closed session of that'

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meeting, the BWROG.and the NRC staff-confirmed that water measurement errors 9306300204 93nggy gDR ADOCK 05000293 W ') L('

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Ernest C. Hadley 2'-

June 22, 1993

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-could be on the order of 27 feet and/that neither the:.BWROG nor the'NRC:staffi

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any longer believe:the error will correct itself with,the' passagelof time.

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'On May 2761993,imembers of my staff contacted you byLtelephone to inform:you?

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that the NRC: staff had considered the;information' presented in:theLPetition and that it'had determinedinot to grant >the immediate-relief: sought.L SYouLwere>

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further. informed that you;would-receive a: written response'.documentingithe'NRC:

-j staff's freasons for this decision.: tThose reasons:are set'out below.E q

q With regard to your request:for immediate action, the NRCLs'aff has considered s t

l the BWROG ' test 1 data, the event at WNP-2 of January 21', J1993,f the: actions:

already implemented by the Licensee in response to Generic lettern(GL):9?-04>..

and the: actions requested by. Bulletin.93-03. The NRC staff has: concluded thatL continued, operati on of ' the: Pilgrim Hucl ear Pl ant r i s : acceptabl e; 1

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LInAugust1992,LtheNRCstaff1ssuedGL92-04' requesting;that/ licensees 1submiti l

a= schedule for long-term corrective action that may; include hardware -.

1 modifications-and that:licenseesitake;certain short-term actions to address:

_ 1 concerns about errors'in level indication related to. rapid:depressurization,

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'On' December /2,~1992, the NRC: staff; agreed to extend the deadline:for the*

submission of plans-for:long-term actionsito ' July:1993. ?The; Pilgrim Licensee.

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implemented the short-term actions, 'which;were verified by;an NRC' inspection.

To assist in resolution.of the water leveltissue, on: ugust 12;11992, the BWROG initiated'a program,7 that included testingUto assess.the' potential, errors in water level. instrumentation that could:resultL from rapid '..

'depressurization events; In" February'and Marchloffl993~ the.NRC? staff-visited, y

the Electric-Power;Research-' Institute (EPRI) test' facility in Charlotte,1 North Carolina, where the BWROGsreference leg de-gas. tests were conducted,Ltot observeLthe reference leg'de-gas-tests and to discuss the technical details of.-

the testing program with the BWROG. The NRC staff also conducted (a1 quality-H assurance-inspection at Continuum. Dynamics Inc.J(CDI), in Princeton,,New..

y Jersey on May 4 and SL 1993J ' CDI performed the ' testing; for the' BWROG.at: th'e C

EPRI test facilityn During this inspection,>the NRC staff collected. raw 4 test.

data from the reference 1 eg'de-gas test. This raw' testrdatatis:the; basis of 1

t the:27-foot value =that-was discussed at the! ACRS meeting-on'May 12L 1993.c It should be noted that the. magnitude"of the 27-foot error:isinot directly;

applicableito thel Pilgrim. plant, because. the magnitude

of any error is: plant l specific, but is: demonstrative'of the significant effects.of this phenomenon.

The NRC' staff hasTconsidered this data relative toethe actions requested.inJ i

GL 92-04 and concluded that the effectiveness'of the-shortuterm' actions-implemented ~ by the. Pilgrim-LicenseeLin' response;to~ GL 92-04iis not changed;by-1 o

'these; test results. This is:because the actions of GL;92-04 were based on thef 1

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assumptions that maximum theoretical calculated errors could ' occur, andithatt 4

'significant! errors would not occur: untill depressurization-below ~450 psig, and.

4 the test. data did'not invalidate either of these -two assumptions.

i The NRC staff has also. evaluated the significance of~ the event that' occurred I

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'at WNP-2 on~ January 21,:1993. ~ This; event demonstrated that level. errors' can~

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Ernest C. Hadley June 22, 1993 occur even during slow depressurization. The NRC staff issued NRC Information Notice 93-27 on April 8,1993, to alert licensees to this event. The NRC staff also requested the BWROG to perform a generic evaluation of level indication errors during normal reactor pressure vessel depressurization.

The BWROG submitted a report on May 20, 1993, discussing the effect of level errors on automatic safety system response and operator actions during transients and accidents initiated from reduced pressure conditions of plant CooldoWn.

Following its review of this report, the NRC staff issued NRC Bulletin 93-03 on May 28, 1993. This bulletin requested each BWR licensee to implement short-term compensatory actions within 15 days to address concerns related to errors during slow depressurization.

During the 15 days until the Pilgrim Licensee implemented the requested short-term actions, it was not likely that gases would build up to a high concentration in the reference legs; therefore, it was not likely that significant errors in the-level instrumentation would result.

This is because gas buildup is a relatively slow process, and following a restart after a cold shutdown, as occurred at Pilgrim, the gas concentration in the reference legs is low because the reference legs have been depressurized. The NRC staff has concluded that continued operation of the Pilgrim Nuclear Power Plant is acceptable, with adequate compensatory measures as requested by Bulletin 93-03 and with the actions already completed by Boston Edison in response to GL 92-04, until a permanent hardware modification is made.

Accordingly, your request for immediate action is denied.

In accordance with 10 CFR 2.206, the NRC will take action with regard to.the specific issues raised in your Petition within a reasonable time.

For your information, I have enclosed a copy of the Notice that is being filed with the Office of the Federal Register for publication.

Sincerely, DMgi'nal signed by Domas I. Earley Thomas E. Murley, Director Office of Nuclear Reactor Regulation

Enclosure:

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L Ernest C. Hadley' June 2'2, 1993 occur.even during slow depressurization.,The'NRC staff issued NRC-Information Notice 93-27 on April 8,1993,.to alert licensees to1this' event. The NRC-d staff also requested the BWROG to perform _a genericievaluation of level indication errors during normal reactor pressure > vessel depressurization. The

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BWROG submitted'a report on May 20,.1993,ndiscussing the 'effect of level' L

errors on automatic safety. system response 4and; operator _ actions.during<

transients and. accidents initiated from reduced pressurefconditions ofl plant:

- cooldown..

Following its review 'of this report,cthejNRC staffiissued NRC BulletinL93-03:

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on May 28, 1993. L This bulletin requestedLeach BWR licensee' to: implement t short-term compensatory actions within 15: days to ~ address concerns related.to--

errors 'during1 slow depressurization. '

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During the'15 days until the-Pilgrim Licensee-implemented th'e requested lshort-term actions, it was not:likely that gases would build up~toLa hight.'

concentration.in the1 reference legs; therefore, itiwas not likely.thatL -

Lsignificant errors in the <1 eve 1Linstrumentation'would' result. Thisiis because, gas buildup is ~ a relatively' slow processh and following airestart.after aDcold shutdown, as occurred.at Pilgrim, theLgas concentration.in;thef reference legs <

-is low.because the reference legs:have been depressurized, -The! NRC; staff hasi concluded that contin _ued operation of the Pilgrim Nuclear? Power, Plant?is) acceptable,L with adequate compensatory measures asirequested by Bulletin 93-03 and with the actions already. completed: by Boston: Edison in. response to?

GL 92-04, until'a--permanent hardware,modificationiis made>

Accordingly,'your request-for immediate; action is denied.:iIn1accordance with:

10 CFR 2.206, the NRC will take action with regard to the: specific; issues:

raised in;your Petition within a reasonable ~ time.

For 'your information','I-have~ enclosed a' copy of. the Notice thatLis being' filed with the: 0ffice of the Federal Register for publication.

' Sincerely,

g[

Thomas E.- Murley, Director -

0ffice of Nuclear Reactor: Regulation-Enclosure ~:

Federal-Register Notice cc w/enclosureO See'next page s

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j Pilgrim Nuclear Power Station cc:

l Mr. Edward S. Kraft,-

Mr. H.-Vernon 0heim~

Vice President of Nuclear Manager, Reg. Affairs Dept.

Operations & Station Director.

-Pilgrim' Nuclear-PowereStation Pilgrim NucleariPower. Station RFD #11 Rocky Hill. Road _

RFD #1 Rocky Hill Road

Plymouth, Massachusetts 02360 Plymouth, Massachusetts 02360

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.Mr.' David F.'Taranti.no i'

Resident-Inspector Nuclear:Information Manager U. S. Nuclear Regulatory Commission-

- Pilgrim l Nuclear Power Station-i Pilgrim Nuclear Power Station.

RFD:#1-Rocky Hill Road

-i Post Office: Box 867-Plymouth': Massachusetts: 02360 '

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Plymouth, Massachusetts 02360 lMr. Thomas Rapone; _ _..

Chairman, Board.of Selectmen Secretary ~of Public Safety _-

11 Lincoln Street Executive Office. of Public, Safety.

Plymouth, Massachusetts 02360

.One Ashburton Place.

' Boston, Massachusetts :02108T Office of the Commissioner

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Massachusetts Department of Mr. David:Rodham,' Dire'ctor Environmental Protection 1

Massachusetts; Emergency Management L One Winter: Street-~

Agency- __

Boston, Massachusetts 02108-T400, Worcester Road P.O." Box 1496:

Office of the Attorney Generals

.Framingham,. Massachusetts.01701-0317, j

One Ashburton Place

. Attn:1--James Muckerheide t 20th' Floor.

Boston, Massachusetts 02108:

- Chairmen,. Citi:' ens Urging:

Responsible" Energy: '

.Mr. Robert M. Hallisey, Director-

P. 0.< Box 2621 Radiation-Control Program-Duxbury,LMassachusetts 02331' Massachusetts Department of Public Health Citiiens at' Risk" 305 South Street- -

P.'O.? Box-3803? -

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Boston, Massachusetts- 02130 Plymouth,' MassachusettsD 02361 Regional Administrator, RegionLI' W.LS.(Stowe,, Esquire-l U. S. Nuclear Regulatory Commission Boston ~ Edison. Company 475 Allendale Road-800 Boylston' St.,: 36th Floorf >

King of Prussia, Pennsylvania 19406-

Boston,~ Massachusetts'102199; Mr.. Paul J. Hamilton Mr. E.: Thomas:Boulette,'Ph.D-d Licensing Division Manager-

Senior Vice President'-': Nuclear D

Boston Edison CompanyL Boston; Edison Company:

~ 25 Braintree Hill Park,

- l Pilgrim Nuclear Power Station Braintree,-Massachusetts '02184-

.RFD #1 Rocky; Hill Road >

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Plymouth, Massachusetts 1 02360 x

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' Pilgrim 2.206 Acknowledgement Letter Date June 22. 1993 DISTRIBUTION:-

Docket? File: 50-293;;(w/ incoming ' letter)?

NRC/ Local PDRs (w/ incoming: letter)

ED0#0008947 J. Taylor.

J. Sniezek H. Thompson-J. Blaha T. Martin, RI J.'Lieberman, OE

- B. Hayes, 0E D. Williams,'0IG

- T. - Murley/F.Miraglia

- J..Partlow S..Varga J. Calvo'.

^

W.' Butler' S.- Little R. Eaton-OPA OCA:

NRR Mail _ Room.(ED0#0008947)

PDI-3 Reading

- J.: Goldberg, 0GC

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- J.. Li nvill e, '. RI

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