ML20054H855
| ML20054H855 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 06/02/1982 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Studds G HOUSE OF REP., FOREIGN AFFAIRS |
| Shared Package | |
| ML20054H856 | List: |
| References | |
| NUDOCS 8206250086 | |
| Download: ML20054H855 (8) | |
Text
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WN 2 1982
% -M l
The Honorable Gerry E. Studds l
United States House of Representatives
/
l Washington, DC 20515
Dear Congressman Studds:
'Thank you for your May 3,1982 letter to Chairman Palladino regarding concerns about the Pilgrim facility in Plymouth, Massachusetts. As you are aware, the Attorney General of the Commonwealth of Massachusetts has requested an adjudi-catory hearing on the Order issued to the Boston Edison Company regarding the license for the Pilgrim facility.
Since that request is currently pending before the Comission for a determination of whether a hearing should be granted, exparte rules preclude Chairman Palladino from commenting on this matter at this time; therefore, your request has been referred to me for a response.
Let me assure you that the NRC' shares your desire to assure the safety of all-residents of Massachusetts. We understand the concern of those who live in the local area around the Pilgrim Station.
It is for such reason that.the NRC Regional Administrator and senior members ofi bis staff have established a close contact with the Plymouth Board of Selectmen, and furnish them with periodic reports. As you have also noted, the NRC staff participated at the request of the Selectmen in a town meeting. ~The nature and conduct of the meeting was established by the Selectmen and it appears that some of the residents' positions were not adopted by the NRC staff.
With respect to the assignment of inspectors to the Pilgrim facility on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis, we have taken steps to augment our inspection program. However, we do not believe that assignment of resident inspectors to maintain continuous 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> coverage is the best approach to provide the levels of inspection required to assure adequate protection of the public health and safety. As Chairman Palladino noted at the December 14, 1981 hearings before a subcommittee of the Comittee on Government Operations, the NRC has reviewed its policy regarding resident inspectors. Specifically, NRC inspection coverage at a nuclear power ' plant is best achieved through an appropriate mix of region-based inspectors and resident inspectors. The region-based inspectors result in a proper balance by providing additional support and coverage, specialized technical expertise and a continuing fresh look at licensee performance.
Based on this approach the NRC priority is to assign at least one resident inspector to each construction', pre-operational and operating reactor site.
Based on past licensee performance and recognizing the availability of ade-quately trained personnel, we do in some cases assign a second resident inspector to selected sites where there is only one reactor.. The Pilgrim station currently has two resident inspectors assigned. The resident inspectors are normally on site during the day when the most maintenance, 8206250006 820602'
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'r testing, and other activities are carried out in the plant.
In addition, these two inspectors stagger their work hours during intense maintenance and testing activities to assure NRC observation of these activities during the off-shifts and weekend shifts.
It is our objective to conduct about 20 percent of the inspection effort outside nomal plant working hours. To supplement the resident inspector program at Pilgrim, routine inspections are being conducted by inspection specialists from the NRC Region I Office. We believe this arrangement provides the most effective use of resources and provides reasonable assurance that the plant is being operated consistent with NRC regulations.
With respect to the petition from the Attorney General's Office, the NRC staff has opposed the Attorney General's request for_a hearing, because Boston Edison Company has consented to the restrictions imposed by the Director of the Office of Inspection and Enforcement's Order Modifying License and the Attorney General does not contest the imposition of the order. Thus, in the staff's view, a hearing on the order is unnecessary, because all are agreed that Boston Edison Company should comply with the order. The NRC Order requires steps be taken to improve plant safety.
NRC resources have been augmented at the Pilgrim facility to conduct in-depth inspections which are designed to evaluate the licensee's compliance with the order and to assess the effectiveness of the corrective actions.
Furthermore, meetings are being scheduled with senior utility managers to discuss and review their progress in improving performance. Consequently, if a hearing were held in this
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instance, although not required by law, the NRC technical resources in the i
Regional Office would need to be redirected to the hearing process. The holding of a hearing would result in an expenditure of somewhat limited Comission resources. Although the Staff has taken this position, the Comissioners will determine independently whether the Attorney General's.
request for a hearing should be granted.
In your letter you also correctly noted that the NRC staff in a report issued last August rated the Pilgrim plant below average in several areas and that the report noted that major organization and personnel changes were made in response to NRC's concern. The evaluation period considered in the report covered January 1980 through December 1980, and the changes referred to were l
made in September 1980.
Such changes alone are not viewed in isolation. The proper implementation of policies and directives requires an organization, procedures, adequate staffing and a management comitment, to list a few items. Based on the NRC staff observations since the 1980 reorganization, we found it necessary to take extraordinary measures.
In addition to the fine issued to Boston Edison Company on January 19, 1982, the NRC also imposed an Order which required that the licensee develop a management improvement plan designed to correct many of the long term managerial deficiencies identified at Pilgrim. The NRC staff is coriducting reviews at predetermined intervals (every 6 weeks) and, is also meeting with licensee management to discuss progress and to assess plan effectiveness. Consequently, we believe that the NRC is taking appropriate and aggressive steps to both follow very closely licensee operations at the Pilgrim facility and monitor progress of the plan OFFICE) conu4me>
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- o 4 to improve management controls related to those aspects of the plant which have a bearing on public health and safety, and the environment.
l If I or my staff can be of any further assistance, please do not hesitate to contact me.
l Sincerely, I
(Signed) William J.Dirckr William J. Dircks Executive Director for Operations Distribution:
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Rep, cacutat4ve Gerry E. Studds S Imet.4t
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Washington, DC 20515 cu ~
Dear Re entative Studds:
Thank you for your May 3,1982 letter to Chairman Palladino regarding concerns about the Pilgrim facility in Plymouth, Massachusetts. As you are aware, the Attorney General of the Commonwealth of Massachusetts has requested an adjudi-catory hearing on the Order issued to the Boston Edison Company (begot. regarding [
the license for the Pilgrim facility.
Since that request is currently pending before the Comission for a determination of whether a hearing should be granted, ex/parter rules preclude Chairman Palladino from commenting on this matter at this time; therefore, your request has been referred to me for a response.
Let me assure you that the NRC shares your desire to assure the safety of all residents of Massachusetts. We understand the concern of those who live in the local area around the Pilgrim Station.
It is for such reason that the NRC Regional Administrator and senior members of his staff have established a close contact with the Plymouth Board of Selectmen, and furnish them with periodic reports. As you have also noted, the NRC staff participated at the request of the Selectmen in a town meeting. The nature and conduct of the meeting was established by the Selectmen and it appears that some of the l
residents' positions were not adopted by the NRC staff.
With respect to the assignment of inspectors to the Pilgrim facility on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis, we have taken steps to augment our inspection program. However, we do not believe that assignment of resident inspectors to maintain continuous 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> coverage is the best approach to provide the levels of inspection required to assure adequate protection of the public health and safety. As Chairman Palladino noted at the December 14, 1981 hearings before a subcommittee of the Committee ~on Government Operations, the NRC has reviewed its policy regarding resident inspectors.
Specifically, NRC inspection coverage at a nuclear power plint is best achieved through an appropriate mix of region-based inspectors and resident inspectors. The region-based inspectors result in a proper balance by providing additional support and coverage, specialized technical expertise and a continuing fresh look at licensee performance.
Based en this approach the NRC priority is to assign at least one resident inspector to each construction, pre-operational and operating reactor site.
Ba:;ed on past licensee performance and recognizing the availability of ade-quately trained personnel, we do in some cases assign a second resident inspector to selected sites where there is only one reactor.
The Pilgrim station currently has two resident inspectors assigned. The resident inspectors are normally on site during the day when the most maintenance,
_2_
testing, and other activities are carried out in the plant.
In addition, these two inspectors stagger their work hours during intense maintenance and testing activities to assure NRC observation of these activities during the off-shifts and weekend shifts.
It is our objective to conduct about 20 percent of the inspection effort outside normal plant working hours. To supplement the resident inspector program at Pilgrim, routine inspections are being conducted by inspection specialists from the NRC Region I Office. We believe this arrangement provides the most effective use of resources and provides reasonable assurance that the plant is being operated consistent with NRC regulations.
With respect to the petition frpm the Attorney General's Office, the NRC staff has opposed the Attorney General's request for a hearing, because Boston Edison Company has consented to the restrictions imposed by the Director of N N
office of Inspection and Enforcement's Order Modifying License and the Attorney General does not contest the imposition of the order. Thus, in the staff's K
view, a hearing on the order is unnecessary, because all are agreed that Boston Edison Company should comply with the order. The NRC Order requires steps be taken to improve plant safety.
NRC resources have been augmented at the Pilgrim facility to conduct in-depth inspections which are designed to evaluate the licensee's compliance with the order and tc assess the effectiveness of the corrective actions.
Furthermore, meetings are being scheduled with senior utility managers to discuss and review their progress in improving performance.
Consequently, if a hearing were held in this instance, although not required by law, the NRC technical resources in the Regional Office would need to be redirected to the hearing process. The holding of a hearing would result in an expenditure of somewhat limited Commission resources. Although the Staff has taken this position, the Commissioners will determine independently whether the Attorney General's request for a hearing should be granted.
In your letter you also correctly noted that the NRC staff in a report issued last August rated the Pilgrim plant below average in several areas and that the report noted that major organization and personnel changes were made in response to NRCiconcern. The evaluation period considered in the report v
covered January 1980 through December 1980, and the changes referred to were P
made in September 1980.
Such changes alone are not viewed in isolation. The l
proper implementation of policies and directives requires an organization, procedures, a dquate staffing and a management commitment, to list a few items.
Based on the NRC staff observations since the 1980 reorganization, we found it necessary to take extraordinary measures.
In addition to the fine e issued to Boston Edison Company on January 19, 1982, the NRC also imposed orr p
Order which required that the licensee develop a management improvement plan designed to correct many of the long term managerial deficiencies identified at Pilgrim. The NRC staff is conducting reviews at predetermined intervals (every 6 weeks) and, is also meeting with licensee management to discuss progress and to assess plan effectiveness. Consequently, we believe that the NRC is taking appropriate and aggressive steps to both follow very closely licensee operations at the Pilgrim facility and monitor progress of the plan to improve management controls related to those aspects of the plant which have a bearing on public health and safety, and the environment.
.- - - +
. If _I or my staff can be of any further assistance, please do not hesitate to contact me.
Sincerely, h
William J. Qkks Executive Director for Operations
. Distribution:
W. Dircks, ED0 K. ' Cornell, E00 T. Rehm, EDO V. Stello, EDO H. Denton, NRR R. DeYoung, IE G. Cunningham, ELD L. Underwood,11PA R. Haynes, RI R. Starostecki, RI EDO #11872 SECY 0492-PDR LPDR Docket No. 50-293 Region I Docket Room OCf RI:DE&TP RI:DE&TP RI:DE&TP RI:DRA RI:RA EHr 6bo Oc6 Elsasser/cgl Brunner Starostecki-Allan-Haynes Dircks 5/27/82 k
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DESCRIPTION )] LETTE R.OMEMo O REPORT.O OTHER SPECIAL INSTRUCTIONS OR REMARKS Concerns ever issues relattag to the PRIORITT operetten of testen Edison's.Pfigria I.
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EXECUTIVE DIRECTOR FOR OPERATIONS DO NOT REMOVE TI//S CUP /
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PRINCIPAL CORRESPONDENCE CONTROL
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Logging Date 5/10/82 i
i NRC SECRETARIAT TO:
O Commi.sioner oate XXG Enec. DirJOper.
Gen. Counsel Con 3. Liaison solicitor O Public Affairs O secretary inspector & Auditor O Poiiev ev.iu. ion Rep Gerry Studds incom;,
From:
Palladino 5/3/82 7.
n concerns over issues ret,a, ting to the operation s q,c,.
of, Boston Edison's Pilgrim I stat i
1 XX Prepare reply for signature of:
Mhairman L
.And.I,own hk Commissioner D soo. oC. co. sot. PA. SECY, I A, PE O sint-e m miite Date due R9tnu: May 26 h Return original of incoming with respome 1
O For direct repiv-Exparte per OGC For appropriate action Rec'd OM. EDO oa te.........-.43.l.b.,
For information Tinn.. d i. e.........,.
. Remarks:
RF. OCA tn acte,agcket For the Commission:
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- Send three (3) copies of reply to Secy Correspondence and Records Branch -
M 9C FORM s2A ACTION SLIP (s.or) r