ML20049H750
| ML20049H750 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 02/26/1982 |
| From: | Howard J BOSTON EDISON CO. |
| To: | Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| 82-45, 82-64, NUDOCS 8203030506 | |
| Download: ML20049H750 (4) | |
Text
BOSTON EDISON CO M PANY BOD BOYLSTON STREE' BOSTON. MASSACHUSETTS O2199 E
8
.J. EDWARD HOWARD V84E Pine 9*0Eps?
BECo. Ltr. #82-64
'O VPNE Ltr. #82-45 e
Mr. Richard C. DeYoung RECSVfD
'I Di rector L
i Office of Inspection & Enforcement ofAR 03 79826'-
( 8maateww Yw U.S. Nuclear Regulatory Commission Washingt
, D. C.
20555
'D License No. DPR-35
/
6 O
Document No. 50-293
References:
(A) Letter, Richard C. DeYoung to William D. Harrington dated February 12, 1982 (B) Letter, J. Edward Howard to Ronald C. Haynes dated January 21, 1982 (C) Letter Ronald C. Haynes to J. Edward Howard dated February 12, 1982
Dear Sir:
This letter is in response to your letter dated February 12, 1982, concerning apparent failure on the part of Boston Edison Company to meet the February 1, 1982, deadline for completion of installation and initial testing of the prompt public notification system for the Pilgrim Nuclear Power Station, Unit 1, and the Notice of Violation referenced.in and enclosed with that ~1etter.
Paragraph 2 of the Notice of Violation requires that Boston Edison submit to the Office of Inspection and Enforcement a written statement or explanation in reply, including (1) admission or denial of the alleged violation; (2) the reasons for the (alleged) violation; and (3) the date when full compliance was achieved. Our response to this Notice of Violation is submitted as Attachment A to this letter pursuant to the terms of the Notice and Section 2.205 of the NRC's " Rules of Practice", Part 2, Title 10, Code of Federal Regulations.
Attachment B to this response consists of copies of the correspondence cited as Reference B) and Reference C) to this letter.
Reference C) indicates that gg co o Boston Edison's request for an extension of the February 1,1982 imolementation date remains under consideration by the Office of Nuclear Reactor : Regulation.
@8 Reference B) is a copy of the letter requesting an extension, and detailing the am reasons for anticipated failure to meet the February 1,1982 implementation date.
O
,o Inasmuch, as stated in Reference C, Boston Edison's request for an extension of g
the February 1,1982 implementation date remains under consideration by the NRR, oc and since, as stated in the attached Response to Notice of Violation, the Company o<
has, as of this date, completed installation nd initial testing of the system it 8e is respectfully requested that the NRC refrain from issuing any Notice of Proposed Q$
Imposition of Civil Penalties in this matter.
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80% TON EDISDN COMPANY Mr. Richard C. DeYoung February 26, 1982 Page 2 Should you have any further comments or questions concerning this response, please do not hesitate to call or write us.
Very truly yours,
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Commonwealth of Massachusetts)
County of Suffolk
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Then personally appeared before me J. Edward Howard, who, being duly sworn, did state that he is Vice President - Nuclear Engineering of Boston Edison Company, the applicant herein, and that he is duly authorized to execute and file the submittal contained herein in the name and on behalf of Boston Edison Company and that the statements in said submittal are true to the best of his knowledge and belief.
~ fly Commission expires: Odddeof f/gg w
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NotargPublic 4
cc: Mr. Ronald C. Haynes Attachments:
(A) Response to Notice of Violation (B) ' Correspondence between J. Edward Howard, Boston Edison Co' pany, and Ronald C. Haynes, m
Director, NRC Region I
ATTACHMENT A Response to Notice of Violation Boston Edison Company Docket No. 50-293 License No. DPR-35 Pursuant to Section 2.201 of the NRC's " Rules of Practice" Part 2, Title 10, Code of Federal Regulations, Boston Edison Company hereby provides its response to the " Notice of Violation" dated February 12, 1982, issued in the above captioned *
't.
The item of non-compliance contained in the Notice of Violation is set forth first, followed by Boston Edison Company's response.
Item As a result of information submitted by the licensee, the following violation, categorized in accordance with the Interim Enforcement Policy (45 FR 66754, October 7,1980), was identified:
10 CFR 50.54(s) and Appendix E to 10 CFR Part 50 (46 FR 63032, December 30, 1981) require each nuclear power reactor licensee, by February 1,1982, to demonstrate that administrative and physical means have been established for alerting and providing prompt instructions to the public within the plume exposure pathway emergency palnning zone.
Contrary to the above, by letter dated January 21, 1982 the licensee notified the NRC that it would not be able to demonstrate by February 1, 1982 that administrative and physical means had been established for alerting and promptly providing public instruction within the plume exposure pathway emergency planning zone for the Pilgrim Nuclear Power Station, Unit 1.
This is a Severity Level III violation (Supplement 1).
Response
The NRC office of Nuclear Reactor Regulation is currently considering Boston Edison Company's request for an extension of the February 1,1982 implementation date for Prompt Public Notification Systems in the area of the Pilgrim Nuclear Power Station. For the reasons stated in Boston Edison Company's letter of January 21, 1982 requesting such extension, Boston Edison Company submits that such extension should be granted and in such case there would be no violation.
In the event there is a determination by NRR that Boston Edison Company's request is denied, Boston Edison Company admits failure to meet the February 1,1982 deadli ne.
The reasons for Boston Edison Company's failure to complete installation and initial testing of the prompt public notification system were circumstances beyond the immediate control-of Boston Edison Company. These reasons included
- 1) delays in the issuance of permits for utility pole sites by local authorities; and 2) delays in meeting established delivery schedules by equipment contractors.
Boston Edison Company has dept the NRC fully informed of the progress of instal-lation.
Installation and initial testing of the prompt public notification system has been completed as of February 26, 1982. Boston Edison Company will imediately under-take actions to correct any deficiencies identified as a result of initial testing.
The Company accordingly believes that full compliance with the applicable provisions of 10 CFR 50.54(s)(2) and Appendix E of 10 CFR Part 50 has been achieved as of 1
February 26, 1982.
ATTACHMENT B to BECo. Ltr. #82 VPNE Ltr. #82-45 I
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a BOSTON EDISON C O M PANY B00 BOYLsTON STRECT EOsicN. MAssacHuscTTs 02199 J. EDWARD HOWARD aus6 san January 21, 1982 VP-N #82-26 Mr. Ronald C. Haynes Director, Region I U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pennsylvania 19406 License No. DPR-35 Docket No. 50-293
Dear Mr. Haynes:
The purpose of this letter is to request extension of the February 1, 1982 implementation date for prompt public notification systems in the Pilgrim Nuclear Power Station area.
It now appears that the prompt public notification system for the Pilgrim area will be fully Install.ed and tested on or before April 15, 1982. We believe that an extension tnrough that date is warranted for several reasons, which are enumerated and discussed below.
(1) The Time Required for Implementation Varies Widely by Site, and Depends Upon Characteristics of the EPZ The Pilgrim EPZ combines a number of characteristics which have demanded a complex and time consuming approach to full system implementation. Tha topography and demography of the EPZ has required a carefully designed system involving 91 sirens. The political compositier. of the EPZ has demanded continuous and diligent attention to the desires and needs of five local governments, each of which had developed and implemented plans to accomplish public notification using existing capabilities in December,1979.
The intent of the Commission in establishing a deadline for implementation clearly was to ensure all due speed and diligence in meeting its requirements. We believe that Boston Edison has taken all possible actions toward early implementation which are consistent with sound system design and emergency preparedness practice.
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sosvo9 EoiroN CoMMNY Mr. Ronald C. Haynes January 21, 1982 The extension of the deadline to February 1, 1982, may have permitted full implementation of less comprehensive systems, or systems in less politically demanding environments. System complexity, political considerations, and equipment delivery delays beyond the control of Boston Edison have made it impossible to meet the February 1, 1982 date despite demonstrable e
diligence on the part of the licensee.
(2) Prompt Notification System Completion is on a Reasonably Firm Timetable, Progress is Demonstrable, and Remaining Problems are Being Resolved Our recent letter to you (BECo Letter #82-5, January 7,1982) reviewed the status of Boston Edison's efforts to fully implement the prompt notification system for the Pilgrim site, and noted that equipment delivery delays and a failure by the Board of Selectmen in one of five EPZ communities to act upon Boston Edison's permit requests are the principal problems still t,eing faced. Progress over the past week appears to have been steady, and our anticipated implementation completion date of April 15, 1982, appears reasonably achievable. Sub-stantial portions of the system, including all units within a five-mile radius of the site, could very well be in place and tested considerably earlier than April 15. Areas where progress continues are summarized below.
Equipment has begun to arrive at Plymouth, and Boston Edison is receiving repeated assurances from Federal Signal Corporation that revised schedules can be met or approximated.
If this is the case, equipment for all sitas rithin five miles should be on hand before February 1, and the balance of equipment should be delivered during installation of initial shipments.
A hearing for site permits has been scheduled before the Duxbury Board of Selectmen for January 25, 1982; Boston Edison and Town Counsel have agreed on all outstanding issues, and, as a result of Boston Edison initiatives, key Town depart:nent heads have indicated that they will support Boston Edison's request.
Al1 arrangements _ for siren installation, control unit installation, installation of central activation equipment, and wiring of units by the local utility are in place.
Progress is steady in securing permits (seven outstanding, outside of the Town of Duxbury, whichinvolves17 sites).
..w EDISDN COMPANY Mr. Ronald C. Haynes January 21, 1982 i
Boston Edison has made arrangements to install and test control equipment, has been working with local governments in developing activation procedures, and is arranging for training of Fire / Police Dispatch personnel.
(3) Adequate Interim Compensating Actions have been Taken, and Additional Compensating Actions are being Taken Promptly i
In a letter to Mr. Boyce H. Grier (BECo letter t81-174, July 21, 1981) Boston Edison described the many compensating actions that were being taken to assure an adequate state of emergency preparedness pending implementation of the prompt notification system. The material below reviews, updates, and expands that description.
Emergency Action Levels have been extensively revised, emergency procedures have been improved, and considerable training and facility improvement has taken place.
This activity should, collectively, assure that the decision to notify off-site authorities is made in the shortest possible time.
At the request of state authorities, and following consultation with members of the NRC Emergency Appraisal Team, a new system for prompt notification of local governments was adopted.
Boston Edison has purchased tone-voice encoder / transmitters for utilization by the State Police for simultaneous notification of 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> warning points in each of eight communities to assist in the rapid marshalling of local officials. Primary and backup communication with both the State Police and State Civii Defense has been improved. Full implementation of these measures awaits equipment delivery, currently, scheduled for no later than January 31,1982.
The procedural means to recont.end prompt protective action to local authorities directly or through the State Police have been established.
Such actions can now be initiated more readily if state Health and Civil Defense officials i
J are unavailable.
Prewritten emergency public information messages have been developed and reviewed by the Region I RAC Committee.
' Boston Edison received a request from the Massachusetts Civil Defense Agency on January 12, 1982, to assist in improving the state's Emergency Broadcast System through i
Co
.?N EDl20N COMPANY Mr. Ronald C. Haynes January 21, 1982 purchase of RPU equipment (transmitter / received and associated antennas) at the State E0C and at Radio Station WROR in Boston.
This request was immediately approved, and plans for procurement and installation are underway. These actions will reduce the I
time needed to take effective protective action through rapid and effective emergency public information.
A new Emergency Public Information Brochure was developed, and
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has been mailed to each addressee in the Pilgrim EPZ, and otherwise broadly distributed.
In Place Rapid liotification capabilities have been revised.
updated and improved.
Boston Edison has aided this effort through the provision of continuous consultant support to the state and its localities since May,1981. Mth the help of this support, existing systens for alerting the public, using sirens, fire horns and mobile alert capabilities a
have been strengthened. These systems will be maintained upon full implementation of the full prompt alert system, both as backup and for validation that protective actions recommendations are followed.
Additional Equipnent fieeds exist at both the state and local level to assure a very high level of emergency preparedness.
Boston Edison had invited local governments and key state agencies to identify such needs, and has made a commitment to meet them to the extent that they are supportable under e,
liUREG-0654 criteria, and consistent with local and state V
plans and sound emergency preparedness practices.
Boston Edison has supported the development and delivery of emergency operations and radiological protection training in each of the communities in the PEZ, as well as designated reception communities. This training will help to improve notification times en an interim basis, and to improve the effectiveness of protective response, both before and following implementation of prompt alert capabilities.
(4) Boston Edisen has Demonstrated Diligence in Attempting to Meet the Prompt Public f?otification Capability Requirement Boston Edison has been intensively involved in ' defining, designing, developing and procuring the components of the prompt public g
notification system since shortly after publication of fiUREG 0610 in September,1979.
During 1979, Boston Edison had been working closely with Massachusetts officials in expanding and upgrading off-site plans to meet the guidance contained in fiUREG 0306. These
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t'O STO N EDIS O N COMPANY Mr. Ronald C. Ha., es January 21, 1982 plans, which were published in December,1979, included all towns in a ten-mile EP2, and provided for public notification using existing capabilities. During January and February,1980, the Massachusetts Civil Defense Agency (MCDA) began to explore the potential requirements of prompt alert systems with the Federal Emergency Management Agency, and requested FEMA assistance in defining such requirements.
In March, 1980, MCDA officials met with FEMA officials, and agreed to the following:
There was a good deal of uncertainty as to the final form e
proposed prompt alert systems woul'd take; In view of these uncertainties, licensees should be encouraged e
to work closely with the state in defining potential system requirements.
Utilities should be encouraged to undertake independent e
engineering analyses as to what system or combination of systems would meet both system design criteria and the needs of local government; Utilities, contractors, the state and local officials should e
work closely together during design and installation to assure full integration of the system into local emergency preparedness plans and programs.
Boston Edison agreed with these conclusions, and began working with MCDA in May,1980, in draf ting a request for proposals to undertake the required engineering analysis. MCDA assisted Boston Edison in preparation of the RFP, in review of resulting proposals, and in selection of a contractor (Stone & Webster Engineering Corporation) to conduct the analyses. Boston Edison, Stone & Webster and State personnel were in the field, briefing local officials on the proposed analyses, before the final guidelities became generally available in December,1980.
Progre:s throughout 1981 was continuous and satisfying. State and local government has been kept not only fully informed, but fully integrated in the decision-making process.
Both the NRC and FEMA have been kept fully infomed of prcblems and progress throughout the process.
In August,1981, Mr. Robert H. Cunningham of Boston Edison a'ppeared before the Commission during deliberations regarding revision of the prompt notification implementation date, and, as a spokesperson for the industry, enumerated problems faced. When asked by the Commission, Mr. Cunningham stated that Boston Edison's best current i
estimates indicated completion no later than the end of the first quarter of 1982.
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ClD 5TO N EDISDN COMPANY Mr. Ronald C. Haynes January 21, 1982 Despite anticipated problems, it did not become certain until the final hours of 1981, when Federal Signal Corporation notified Boston Edison of an additional equipment delay, that the February 1, 1982 date would be, impossible to meet.
(5) Consideration of Enforcement Action CNuld Await FEMA Evaluation of Prompt Public Notification System Commission Staff have advised Boston Edison that the Comission is considering prompt enforcement action against licensees who fail to meet the February 1, 1982 date.
In the absence of a full evaluation of the effectiveness of a prompt notification system by FEMA, through field surveys or statistical sampling in the EPZ, it would appear that enforcement action is premature.
Boston Edison has been pursuing a course of action since late in 1979 which we believe will result in one of the mor, comprehensive and fully integrated systems in the nation. A less rigurous opproach to the problem and its complexities may well have resulted in a system which could have been implemented earlier, but wou'd have been less likely to fully meet both design criteria and community needs. Boston Edison has and continues to work diligently with state and local officials, and all others involved to assure full implementation at the earliest possible date, and has pursued every available opportunity to assist in completing actions which can help to compensate for the absence of prompt notification capability during its development.
Boston Edison is confident that, in the long run, tha soundness c' this rigorous approach will be evident, and that, under these circumstances, cur request for an extension of the implementation date through April 15, 1982, should be approved.
I will continue to keep you fully informed of the progress in this area.
Sincerely,
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NUCLEAR REGULATORY COMMISslON 8
REGION I
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$31 PARK AVENUE o
KING OF PRUS$1 A, PENNSYLVANI A 1940$
Docket No. 50-293 FEB 13 932 i
Boston Edison Company l
ATTN: Mr. J. Edward Howard J. E. HOWAP" Vice President - Nuclear
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800 Boylston Street Boston, Massachusetts 02199 Gentlemen:
This is in response to your letter dated January 21, 1982 wherein you ask for an extension of the February 1, 1982 implementation date for Prompt Public Notification Systems in the area of the l
Pilgrim Nuclear Power Station.
Your request is one of several being considered by the Office of Nuclear Reactor Regulation and you can expect to hear from them soon.
{
Sincerely, WV U[ >
o a d C. Haynes ional Administrator cc:
W. D. Harrington, Senior Vice President, Nuclear A. V. Morisi, Nuclear Operations Manager - Pilgrim Station Public Document Room (PDR)
Local Public Document Room (LPDR) l Nuclear Safety Infonnation Center (NSIC)
NRC Resident Inspector Commonwealth of Massachusetts (2)
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