ML20151D099
| ML20151D099 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 05/11/1988 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| References | |
| NUDOCS 8807220358 | |
| Download: ML20151D099 (354) | |
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1 PUBLIC MEETING TO DISCUSS COMMENTS 2 RECEIVED ON THE PILGRIM RESTART PLAN 3 WEDNESDAY, MAY 11, 1988 - 7:05 P.M. 4 MEMORIAL HALL, COURT STREET 5 PLYMOUTH, MASSACHUSETTS 6 7 PARTICIPANTS: Samuel J. ColJins 8 Jay M. Gutierre: 9 Ronald Bellamy 10 Bruce A. Boger II
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2 1 I N D E X 2 SUBJECT PAGE 3 S. Collins - Opening Remarks S 4 J. Gutierrez - Public Participation Restart Process 8 5 . R. Bellamy - Radiological Monitoring / 6 Emergency Preparedness 24 7 S. Boger - Containment / Safety Enhancement Program 46 8 S. Collins - Management /NRC Assessment 9 Process 64 10 Public Comments 76 11 Closing Remarks 197 12 L- 13 14 15 16 17 18 19 . 20 21 22 23 24
y, 3 1 P R O C E E D I N G S. 2 THE CHAIRMAN. Good evening, ladies 3 and gentlemen. Thank you for coming out on a 4 rainy night when the Celtics are playing. We 5 appreciate your interest. First, I want to thank 6 you for coming. 7 Let me introduce myself and other members 8 of the panel here tonight representing the Nuclear 9 Regulatc1 Oc* mission. I am Samuel Collins, the 10 Deputy trector, Division of Reactor Projects'. II - Legion 1, and Chairman of the Pilgrim Restart 12 Assessment Panel. Additionally we have Jay i L- 13 Gutierrez, Regional Counsel for Region 1: Dr. 14 Ronald Bellamy, Chief of the Emergency 15 Preparedness and Radiological Protection Branch, 16 Region 1, and also a member of the Pilgrim Restart 17 Assessment Panel. In addition, we have Mr. Bruce 18 Boger who is the Assistant Director for Region 1 19 Reactors, Office of Nuclear Reactor Regulation and 20 the Co-Chairman of the NRC Restart Assessment 21 Panel. 22 I would like to begin tonight by,briefly 23 reviewing the purpose and format of this meeting. 24 NRC Confirmatory Action Letter 86-10, which
Pr , 4 i 1 was issued following BECO's decision te shutdown 2 Pilgrim, required BECO to submit a restar* 3 readiness assessment, a restart program and a 4 schedule before startup from the current outage. 5 Additionally, the confirmatory Action Letter 86-10 ; i 6 stated that the NRC decision on restart would be 7 based in part on the review of these documents. , I 8 In response to these Confirmatory Action Letter 9 requirements and as a part .o f the over411 review 10 of Boston Edison Company's proposal for plant 11 restart activities, the NRC has conducted a review 12 of the Pilgrim Nuclear Power Station Restart Plan 13 which describes the programs, plans and actions 14 considered necessary by BECO management for 15 restart and continued operation of the Pilgrim 16 Nuclear Power Station. The review has been 17 coordinated by an NRC assessment panel comprised 18 of managers from NRC Region 1 and NRC
- 1) headquarters. This panel coordinates and providen 20 direction to all NRC revimo activities associated 21 with Pilgrim.
22 In order to provide for public 23 participation in the plan review process, copies g 24 of the Pilgrim Restart Plan w=re placed in the l [
_c. - _ - y/ G l. 1 local Public Document Room, Plymouth Public l 2 Library, and public libraries at Duxbury, Carver. 3 Kingstoa, Marshfield, Plympton and Hareham. 4 On February 18, 1988, a public mreting was 5 held here in Plymouth for the purpose of providing 6 the opportunity for interested public and 7 officials to participate and provide comments on 8 the Restart Plan. Additionally, the NRC 9 acknowledged that written or mailed in comments 10 against the plan wou*d be accepted. At that time. 11 the NRC committed to consider those comments 12 received for enhancing its review and inspection 13 activities and to hold another public meeting in
- 14 the area to present the disposition of those 15 comments received on tne Restart Plan.
16 Following the February 18th meeting, a 17 public record was provided in the form of the 18 meeting transcript, and copies of those comments 19 .eceived by mail. These were placed in those l ) 20 public libraries to which the Restart Plan had 21 previously been sent. 22 Our purpose l ere tonight is to provide 23 feedback to the public on the comments that were 24 received on the Boston P.dison Company's corrective g
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'Ii 1 action plan. This meeting is not to reach a l l'
2 decision on Pilgrim restart, but to explain the ; f 3 process being utilized by the NRC. : 4 In order to coordinate the NRC review of l 5 the Restart Plan and the receipt of public 6 comments, a multi-disciplined task force was 7 formed. A total of seventy-one different 8 individuals or parties have press. ted comments in 9 response to the NRC request, and the number of I 10 comments receiv'ed totals approximately two hundred
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11 forty. The NRC review of the plan in concert wita 12 the public comments resulted in our requesting i U- 13 BECO to respond to specific questions or to 14 clarify the plan. Those letters and replies are 15 provided tonight for your information as an 16 attachment to the meeting handout which is 17 available in the back of the room. 18 The NRC review is complete, and those l 19 comments received have been evaluat7d by the NRC 20 staff in its assessment of the Pilgrim Restart 21 Plan. Generally, the majority of comments t l 22 received fall into four broad areas: The first f 23 area are issues dealing with public particip.ation 1 24 in the Pilgrim restart assessment process, such as ( l l l
7 - 1 requests for hearings, the Confirmatory Action 2 Letter and opportunities for public input. The 3 second area is environmental monitoring and 4 emergency p2eparedness, such as offsite 5 monitoring, NIH cancer study, the emergency plan 6 review process and the status of NRC actions. The 7 third broad area is containment and the Safety i i 8 2nhancement Program known as SEP. This includes j 9 areas such as the Mark 1 containment design, the 10 defense-in-depth concept and the status of the il safety enhancement program including the direct 12 torus vent. The fourth area is management and NRC iL-13 assessment process issues, such as the criteria 14 for management effectiveness, recent site events 15 and the NRC process to evaluate BECO readiness to 10 support plant restart. 17 Meeting handout Attachment 2 provided 18 tonight is a summary listing of public comments 19 received by the NRC, where they are located in the 20 transcript of the February 18, 1988, public 21 meeting and where the NRC response to the issue 22 will be contained. Responses to which a written 23 reply is provided are available tonight as Hand-24 , out Attachmant 3. Other public comments have been (
8 1 included into the four categories previously 2 mentioned and will be responded to Mithin the P r e s e nt At 'i c n5 j 3 context of the preper *!cn* given tonight. A 4 report of this public meeting will be issued and , 5 containing all meeting handouts +e a transcript of { 6 the meeting presentation. This meeting report 7 will be provided to the area public libraries 8 previously provided the plan and the February 18, 9 1988, meeting report. 10 Following presentations listed on the 11 agenda which is also contained in your handout and 12 as timo allows, we well accept public comments on L- 13 the restart plan review process. A sign-up list 14 will be provided at the back table for those who i 15 wish to speak. 16 I will serve as meeting moderator tonight. 1 17 I would like to thank you in advance for your l 18 cooperation and courtesy, so we may hear the 19 speakers and respect the views of all. Thank you 20 for your attention. 21 I would like to introduce the first 22 speaker, Mr. Jay Gutierrez, the Regjonal Counsel 23 'or the Region 1 Office. 24 MR. JAY GUTIERREZ: Thank you, Sam. i
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9 1 I'm pleased to be here tonight to respond l 2 to the comments that the NRC received after the
? February 18th meeting relative to the issue of l
4 public participation on the issue of whether or ' 5 not the Pilgrim facility should be permitted to F restart. A summary of the comments that the NRC 7 received during the February 18 meeting is 8 provided in the back as a handout as indicated by 6 9 Mr. Collins. My presentation will similarly be 10 part of the hearing transcript tonight. Alth'ough 11 the NRC invited the public to comment on the 22 Boston Edison Restart Plan and the purpose of I 13 tonight's meeting is to address the public 24 comments on that plan, I think it's fair to say 15 that many of the public comments went to the issue 26 of the public' desire to hold an adjudicatory 17 hearings. And the thinking of the or the theme in 18 those comments indicated that from the perception 19 of the public they think it's unfair for a restart 20 decision to be made without an adjudicatory 21 hearing. Therefore, the NRC thought it was e 22 appropriata tonight to lay out, explain. what 1 23 process we will be using relative to deciding 24 whether or not to permit Pilgrim to restart and (
10 I 1 why we think the process provides ample ) l 2 opportunity for public input. l l 3 Before I get to the substance of my talk, ! 4 let me stress two procedural points. The first 5 point in reviewing the numerous public comments 6 seems clear that the premise of the public's 7 concern for an adjudicatory hearing is that 8 without such a hearing the public will be shut out 9 of the process. I want to explore that premise in NRC's 10 depth tonight because it's the NO"': position that 11 there are ample opportunities for input from the 12 public without an adjudicatory hearing. The NRC 13 recognizes the intense public interest in the 14 Plymouth area relative to the Pilgrim issue and as 15 a result of this interest has opened up the 16 decision-making process in a number of ways. The 17 second preliminary point I want to make is that f 18 although the public input is encouraged by the 19 NRC, the public on the other hand must recognize 20 that by law the decision of whether or not to 21 permit Pilgrim to restart and whether or not 1 22 Pilgrim can restart in a manner so as to protect 1 l l 23 the radiological health and safety of the public l 2# in the final analysis is a decision for the NRC. ( l
i 81 1 Let me turn now to the public comments that 2 were received during the February 18 meeting 3 relative to a formal adjudicatory hearing. These 4 comments took many forms. Some of you requested a 5 show cause proceeding. Others of you requested an 6 evidentiary hearing. Still others referenced 7 Section 2.206 of the Commission regulations. What 8 seems clear to me after reviewing the numerous 9 comments is there's a great deal of confusion with 10 respect to certain issues. Those issues are what 11 precisely is involved in the formal adjudicatory 12 hearing. When is a member of the public entitled i L- 13 to an adjudicatory hearing? Why has the NRC thus 14 far decided not to hold such a hearing? What 15 rights does 2.206 within the Commission's 16 regulations afford the public? And what process 17 today is the NRC utilizing to assure public input 18 into the decision-making process? l ! 19 In an effort to clear up some of these 20 issues, I'm going to address three basic areas. 21 The first area will be what constitutes an 22 adjudicatory hearing. I'm going to spend a lot of 23- time, about a third of the talk, because I think 24 what's driving a lot of the public's desire for an (
12 1 adjudicatory hearing as, as I said, is the premise 2 that without that you don't have input into the 3 process. If I do nothing else tonight, what I 4 hope to do is destroy that myth. because I think it 5 is just that, and that is a myth. 6 The second issue I'm going to spend some i ' 7 time on is what constitutes a 2.206 petition and l 8 how does that petition fit into the.overall NRC 9 process with respect to inspection and 10 enforcement. Ahd, lastly, I'm going to spend some 11 time explaining the process that the NRC is using 12 with respect to a decision-making process in 13 deciding whether or not to permit the restart of 14 Pilgrim and assuring ample opportunity for the 15 public input. Let me say this last issue Mr. 16 Collins is also going to expand upon. 17 So let's start with what is this la adjudicatory hearing that almost fifty percent of 19 the public requested as a result of the February 20 18 meeting. A formal adjudicatory hearing is a 21 trial type hr ving. It's'where specJric parties 22 who have be. ..mitted to a fora
- eeding 23 after demonstrating certain legal inscrests and 24 standing have an opportunity to present evidence
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13 l 1 to the judge. Typically evidence is presented to 2 this judge through a lawyer and, in the case of 3 the NRC, is presented to a board known as the 4 Atomic Safety and Licensing Board. 5 It is important to note that members of the 6 general public such as yourself are not free to 7 participate in formal adjudicatory hearings 8 without meeting the many burdens and obligationc 9 placed on parties to those hearings by the 10 numerouc regulations that govern formal 11 adjudicatory hearings. A member of the public who 12 wishes to participate in a formal adjudicatory i L- 13 hearing in the NRC must set forth in a petition 14 for leave to intervene his interest in the 15 proceeding and demonstrate how his interest may be 16 affected by the contemplated a'c t i o n . He must set 17 forth the nature of his interest, the nature and 18 extent of how that interest may be affected in the 19 contemplated action and the effect of any NRC 20 order on his interest. Mo.reover, if a member of 21 the public wants to become part of the formal 22 adjudicatory process, he must file what are called 23 4ntentienc/ contentions. What contentions are are 24 essentially factual assertions that if the member g
14 1 of the public becomes a party he has an 2 opportunity to prove those factual assertions 3 which would argue one way or another in terms of 4 having a board decide what should occur. The 5 scope of the formal hearing is limited to the 6 proposed action. 7 If this all sounds complex, it is. More 8 simply put, the public is constrained to address 9 admitted contentions in a formal adjudicatory 10 hearing. The pu'blic is n o t. free to either state 11 or have considered whatever other issues may be of 12 concern to it. f. L- 13 Once contentions are admitted and the 14 discovery process and other pre-hearing activity 15 occurs, a hearing is held. Again, that hearing is 16 very formal and procedura11 zed. Parties to the 17 hearings are required to submit direct testimony 18 in writing. They have to serve that testimony on 19 all other parties to the proceeding, and attorn,eys i l 20 typically conduct the cross-examination and direct l l 21 examination of witnesses. Non-lawyers may 22 participate in questioning of witnesses under very 23 narrow, defined situations. Members of the g 24 general public, however, such as yourselves, are l l t . .- ._. ._. .- - . _ - - - - _ _ _ _ ..
10 1 not permitted to participate in the hearing. 2 There are what are known as limited appearance 3 statements, but the important thing to note with 4 respect to limited appearance statements is that 5 the public can stand up and talk at a mike like we 6 have before us tonight, but that statement cannot 7 by NRC rules form the basis for the decision from 8 the judge. The judge is constrained to decide the 9 case based on the evidence provided in the record 10 and the written submittals of the parties. 11 Now you may at this point be asking, well, 12 at what time in the process is a member of the L- 13 public afforded a right to a formal adjudicatory 14 hearing. There are certain well defined times 15 during the NRC process when a member of the public 16 is given an opportunity for a formal adjudicatory l 17 hearing. The two principal opportunities is the l 18 time initial construction is contemplated, that's ! 19 known as the construction permit hearing, and the ( the d e c i si on , l 20 time initial previelen for the authority to
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\ 21 operate is being contemplated. Those are called 22 operating license hearings. But in addition and 23 more importantly to people in this room relative 24 to Pilgrim, once a plant has a license to operate,
86 1 each time an amendment or change to that license 2 is requested from the .icensee to the NRC an 3 individual has certain hearing rights. At that 4 time the licensee is required to provide the 5 license amendment request to the state and must 6 siellarly put that license amendment request in 7 the public document room. The NRC in turn issues 8 a notice of receipt of that request, and members 9 of the public are given an opportunity for formal 10 hearing. II Let me summarize my first point. The 12 adjudicatory proceedings typically occur when the 13 NRC is either considering initial license issuance 14 or change to an existing license. The process is 15 cumbsrsome and rarely takes -- I'm sorry -- 16 typically takes one to two years an. at times has 17 taken several years. It is this type of hearing 18 request that many of you asked for in the context 19 of the February 18th meeting. Finally, numerous 20 Commonwealth officials have requested such an 21 evidentiary hearing be initiated as part of the 22 NRC enforcement process under the provisions of 23 what we call 10 CFR 2.206. Therefore, I next want 24 to turn to axplain that process to you a little
87 1 bit, so that you can understand it and also l 2 understand where the 2.206 process fits into the 3 NRC inspection and enforcement program. 4 After receiving a license an NRC licensee 5 such as Pilgrim remains subject to continuing NRC 6 review and oversight under the NRC Inspection and 7 Enforcement Program. This program is aimed at 8 ensuring continued protection of the public health 9 and safety through compliance with the license and 10 the federal regulations. The NRC by reason of the 11 Atomic Energy Act has a wide range of enforcement 12 actions open to themselves to use against L- 13 licensees. Typical enforcement options are 14 Confirmatory Action Letters, notices of 15 violations, civil penalties and orders to either 16 suspend, modify or revoke a license. 17 For the most part, enforcement action by 18 its very nature is NRC initiated. There is a 19 mechanism, however, for citizens attempting to get 20 the NRC to initiate enforcement action. That's 21 what the 2.206 process is. It's a vehicle whe'reby 22 a member of the public can ask the MRC to initiate 23- enforcement action. Now a 2.206 petition must de 24 more than simply cite an enforcement action they l 1 r
18 1 request the NRC to take. They must set forth 2 facts which constitute the basis.for the action. 3 Now the gist of the petitions flied in the Pilgrim 4 case so far by the various officials of the 5 Commonwealth is that the NRC should initiate the 6 show cause order for formal adjudicatory hearings 7 relative to Boston Edison management, emergency 8 preparedness and containment issues at Pilgrim. 9 The basis for these petitions was information 10 already known to the NRC and for the most part 11 taken from NRO documents. 12 Upon receipt of the 2.206 petition, the NRC 13 is faced with a decision. If they find merit to 14 the request for enforcement action, they can take 15 the request for enforcement action or select any 16 other enforcement action that in the judgment of 17 the NRC is deemed appropriate. One such option 18 and the action requested by various officials 19 within the Commonwealth is ordering the licensee 20 under Section 2.202 of our regulctions to show 21 cause why a proceeding should not be instituted to 22 modify, suspend or revoke Pilgrim's license. The 23 licensee and any other person who can demonstrate 24 an interest in the proceeding then has an g
19 1 entitlement to a hearing, and it would be 2 essentially the type of hearing that I have 3 described previously in terms of a formal 4 adjudicatory hearing. 5 On the other hand, the NRC may determine 6 that no show cause hearing or other enforcement 7 action is warranted. If that's the case, under 8 its regulations it must notify the person who 9 submitted the petition of that decision and in 10 writing provide a written basis for the NRC's 11 decision. Now this has occurred in part relative 12 to Senator Golden's request, and the NRC decision 6 L- 13 is still pending with respect to the request by 14 Governor Dukakis and Attorney General Shannon. 15 Governor Dukakis and Attorney General Shannon, 16 however, have been informed that thus far the NRC 17 w311 not issue an immediately effective order 18 against Pilgrim suspending all activity that could 19 possibly lead to restart. 20 Let me summarize th.e essential points in 21 this phase of the talk. With respect to 2. 206 22 petitions, the filing of a 2-206 petition does not 23 require by law the NRC to hold an adjudicatory 24 hearing. The NRC is free to use other enforcement
20 1 tools in response to issues raised in the 2.206 l 1 2 petition. In the case of the two 2.206 petitions i 3 currently pending before the NRC relative to 4 Pilgrim, the NRC has taken the position that 5 although many of the issues identified by the 6 petitioners are valid and, indeed, are the very 7 same issues which the NRC is addressing in 8 deciding whether or not to permit restart of 9 Pilgrim, the facts so far developed do not warrant
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10 issuance of an enforcement order since the 11 facility is already voluntarily shutdown, the 12 necessary corrective actions have been voluntarily 13 initiated by the licensee, the NRC has initiated 14 -- has issued a confirmatory Action Letter. The 15 licensee is addressing the issues that have been 16 raised as a basis for the petitions, and Pilgrim 17 will not be permitted to restart by the NRC until 18 the identified issues are addressed to the 19 satisfaction of the NRC. 20 Now against this rather formal presentation 21 of the process of a formal' adjudicatory hearing, 22 2.206 petition, let me now get to the specific 23 process that the NRC is using in the case of 24 Pilgrim and describe the' process utilized to {
28 1 assure public input into the Pilgrim restart 2 decision. This process will be more fully 3 developed by Mr. Collins in his talk. 4 I think the first point to be made and the 5 point that seems to escape those who insist upon 6 an adjudicatory hearing is that the NRC will 7 consider any safety issue that a member of the 8 public brings to its attention. You don't need to 9 wait for a meeting like tonight or a meeting like 10 February 18th to raise an issue with the NRC .- We 11 have resident inspectors in the area, we have a 12 regional office in King of Prussia, and we have a L- 13 continued presence at Pilgrim. It should be 14 considered the public's responsibility to bring _ 15 any safety issues that they have to the attention 16 of the NRC, regardless of the ultimate disposition 17 of whether or not you're going to have a formal 18 adjudicatory hearing. 19 What has been done to date in the process? 20 The staff and local officials within Massachusetts 21 have had many discussions related to Pilgrim.* 22 This dialogue has included at least three public 23 meetings with the Plymouth Board of Selectmen as g 24 well as a meeting with the Plymouth Chamber of
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I 82 1
; 1 Commerce, the Duxbury Board of Seleetmen, the ,
1 2 Massachusetts Joint Commission on Energy, the 3 Massachusetts Legislative Committee on the 4 Investigation and Study of Pilgrim Station, the 5 Town of Plymouth Advisory Committee on Nuclear 6 Matters and other groups. The NRC participated in 7 a public meeting sponsored by the Duxbury Board of 8 Selectmen on the Pilgrim situation. More to the 9 issue of today, a meeting was held on February 18 10 to receive public comments on the Boston Edison 11 Restart Plan, and the people to my left, the 12 members of the panel that will follow me, are t L-- 13 prepared to address the specific comments made. 14 As the NRC proceeds with its deliberations 15 regarding whether or not to authcrize the restart 16 of Pilgrim, additional public meeting will be held 17 regardless of the issue of the resolution of 18 whether or not formal adjudicatory hearings will 19 be held. These meeting will provide opportunity 20 for public input, of equal importance is that any 21 time the NRC and Boston Edison meet, these 22 meetings are also open for public observation in 23 accordance with the NRC's open meeting policy, and g 24 4 the NRC is receptive to comments after the meeting s
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23 I by members of the public. Mr. Collins will 2 outline key meetings planned in his presentation. 3 Other meetings beyond those outlined by Mr. 4 Collins will be held as circumstances warrant. 5 In conclusion, let me emphasize certain 6 points. Formal adjudicatory hearings are net the 7 only way for public input into the NRC's decision-8 making process and they are a burdensome way for 9 people to participate in them. The NRC is not 10 required to hold such hearings in response to
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11 requests to take enforcement action under 2.206. 12 Despite that, the NRC staff elected to open the i L- 13 NRC deliberative process on whether or not to 14 permit restart of Pilgrim to the public out of the 15 recognition that there is intense public interest 10 in this issue. The NRC has opened that process by 17 seeking public comments at key times in the 18 process such as on February 18th after the company 19 supplied their Restart Plan and also by having an 20 open meeting policy to permit public attendance at 21 meetings between the NRC and BECO. 22 I want to thank you very much for your 23 attention to my presentation. At this time I 24 would like to introduce Dr. Ronald Bellamy who is g
24
, 1 the Chief of the Emergency Preparedness and Radio-2 Icgical Protection Branch at NRC, , Region 1, who 3 will address public comments on emergency I
4 preparedness and radiological monitoring of 5 Pilgrim. 6 i DR. RONALD BELLAMY: Thank you. I 7 will address two distinct areas in my remarks in 8 response to the comments received during the 9 February 18, 1988, meeting. These areas are 10 emergency preparedness and environmental 11 monitoring. I will address the emergency 12 preparedness issues first. 13 Before addressing the specific concerns 14 that were raised in the February meeting, I would 15 like to provide the regulatory framework for 16 emergency preparedness. The NRC has recognized i 17 the importance of emergency preparedness in 18 protecting the health and safety of the public and l 19 has over the past several years implemented 20 specific regulations and regulatory guidance. I 21 Significant inter-agency cooperation, specifically l 22 with the Federal Emergency Management Agency, has 23 resulted in definitive criteria being published. l 24 I want to be sure that you are aware of these l
20 1 regulations and criteria and how the NRC will use 2 this published guidance in restart deliberations 3 for the Pilgrim Station. 4 Title 10 of the Code of Federal Regulations 5 contains Appendix E entitled "Caergency Planning 6 and Preparedness for Production and Utilization 7 Facilities." This appendix establishes minimum 8 requirements for emergency plans for use in 9 sttaining an acceptable state of emergency lo preparedness. Specific reference is made to a 11 document developed jointly by the NRC and the 12 Federal Emergency Management Agency known as I '- 13 NUREG-0654 entitled "Criteria for Preparation and 14 Evaluation of Radiological Emergency Response 15 Plans and Preparedness in Support of Nuclear Power 16 Plants." I have copy of that document here with 17 me, if anybody would like to see it after the 18 meeting. 19 The planning standards in NUREG-0654, as 20 specifically referenced in the regulations, are 21 required to be addressed in the emergency plans. 22 These sixteen planning standards are: Assignment 23 of responsibility, onsite emergency organization, 24 emergency response support and resources, the {
26 1 emergency classification system, notification 2 methods and procedures, emergency communications, 3 public education and information, emergency 4 facilities and equipment, accident assessment, 5 protective response, radiological exposure 6 control, medical and public health support, 7 recovery and reentry planning and post-accident 8 operations, exercises and drills, radiological 9 emergency response training; and, finally, 10 responsibility for the planning effort: 11 development, periodic review and distribution of 12 emergency plans, t L- 13 It is important to realize that the goal of 14 emergency preparedness is to prepare onsite and 15 offsite personnel and the public for a variety of 16 ways of dealing with nuclear emergencies. It is 17 necessary to be prepared for a range of protective 18 actions. It is not appropriate to develop 19 specific plans for every conceivable accident, .but 20 to address a spectrum of accidents to give 21 forethought to the actions required, angtokeep 22 in mind the overall ob.jectives of providing 23 emergency plans, procedures and training to g 24 achieve dose savings for a spectrum of accidents.
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27 1 Another specific part of the 10 CFR Part 50 2 is ::: 1 : entitled "Emergency Plans," and f 3 this is 10 CFR 50.47. This regulation identities 4 the NRC as the regulatory authority that is 5 required to make a finding on emergeacy 6 preparedness prior to the issuance of an operating 7 license for a nuclear power reactor. Th? required 8 finding is that, and I quote, "There is reasonable 9 assurance that adequate protective measures can lo and will be taken in the event of a radiologi' cal 11 emergency." The NRC, however, does not obtain 12 information to make this conclualon in a vacuum. I 13 We consider first the review of the Federal 14 Emergency Management Agency and that agency's 15 findings as to whether state and local plans are 16 adequate; second, whether there's reasonable 17 assurance they can be implemented; and, third, the j 18 NRC assessment as to whether the applicant's 19 onsite emergency plans are adequate and whether 20 they can be implemented. The ultimate decision as 21 to whether the state of emergency preparedness is 22 adequate to protect public health and eafety rests 23 with the Nuclear Regulatory Commission. 24 At the public meeting held February 18, ( l
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28 1 1 1988, there was a concern with the NRC review 2 process and its basis for emergency review 3 preparedness. I have general addressed generally 4 the criteria for this review. One specific 5 concern dealt with the emergency action levels. 6 NUREG-0654 specifies these emergency action levels 7 in increasing level of significance and required 8 actions as, first, notification of unusual event; 9 second, alert; third, site area emergency; and, 10 four, genera] emergency. A gradation is provided 11 to assure fuller response preparations for more 12 serious indicators. 13 To give you e better understanding of these 14 classes, for notification of unusual event, the 15 lowest of the event classifications, unusual 16 events are in process or have occurred which 17 indicate a potential degradation of the level of 18 safety of the plant. No releases of radioactive 19 material requiring offsite reponse or monitoring l 20 are expected unless further degradation of safety 21 systems occurs. , 22 Personnel are brought to a state of I 23 readiness, prepared for any further response, g P4 Relative 1) minor events cause the declaration of
m 29 1 an unusual event, such as the transportation of a 2 contaminated injured individual from the site to 3 an offsite hospital, or reactor coolant 4 temperatures or pressure outside expected values. 5 For an alert, events are in process or have 6 occurred which involve an actual or potential 7 substantial degradation of the level of safety of 8 the plant. Any releases are expected to be 9 limited to small fractions of the EPA protective 10 action guidelines. This second stage emergency 11 action level would be declared, for example, if 12 hurricane winds occurred near the site or k- 13 radiological effluents have ten times greater than 14 allowable instantaneous limits. 15 For a site area emergency, the events are 16 in process or have occurred which involve actual 17 or likely major failures of systems or equipment 18 needed for protection of the public. Any releases 19 are not expected to exceed EPA action guidelines 20 except near the site boundary. A steam line break 21 outside containment, without being isolated, o'r 22 severe damage to shutdown equipment from missiles 23 or explosions are examples of site area g 24 emergencies.
30 ' 1 For a general emergency, events are in 0 process or have occurred which involve actual or 3 imminent substantial core degradation or melting ; 4 with potential for loss of containment integrity. 5 Releases can be reasonably expected to exceed EPA 6 protective action guidelines offsite for more than 7 the immediate site area. A general emergency 8 would be declared if a loss of offsite power 9 occurs plus failure of reactor shutdown systems, lo or effluent monitor detect significant radiation 11 levels at the site boundary during actual 12 meteorological conditions. L_ 13 Boston Edison is required to and has beon 14 conducting training on how various plant events 15 lead to the declaration of these emergency action 16 levels. The Nuclear Regulatory Commission will 17 inspect this area and ensure that plant operation 18 can appropriately categorize plant events. 19 A second specific concern raised during 20 your public meeting dealt with alert and 21 notification of the public. Appendix E referenced 22 earlier states that public emergency preparedness 23 planning information shall be given to the public 24 within the ten alle emergency planning zone on an (
38 l 1 arnual basis. This information shall include ) 2 methods and times required for public notification l 3 and the protective actions planned if an accident 4 occurred, general information as 's o the nature and 5 effects of radiation and a l i s t i n. of local 6 broadcast stations that will be used for 7 dissemination of information during an emergency. 8 We are aware that this information has not been 9 distributed for the Pilgrim Station for 1987 or 10 for 1988 and that the Commonwealth of 11 Massachusetts has determined that it is not 12 appropriate to distribute emergency preparedness t L -- 13 information until changes to the appropriate 14 emergency plans are completed. The Nuclear 15 Regttlatory Commission will verify this public 16 i information is available prior to restart of the 17 silgrim Station. l l 18 Additionally, a prompt public notification 19 system shall have a design objective of being 20 capable of essentially completing the initial i 21 notification of the public within the ten mile i 22 emergency planning zone within about fifteen 23 minutes. The use of this notification capability l g 24 will range from immediate notification of the l i
32 1 public within fifteen minutes of the time that 4 2 state and local officials are notified that a . 3 situation exists requiring emergency action to the 4 more likely events where there is substantial time 5 available for the state and local governmental 6 officie.Is to make a judgment whether or not to 7 activate the public notification system. Where 8 there is a decision to activate the notification 9 system, the state and local officials will
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10 determine whether to act.vate the entire 11 notification system simultaneously or in a 12 graduated or staged manner. 13 The responsibility for activating such a 14 public notification system shall remain with the 15 appropriate state and local governmental 16 authorities. NUREG-0654 indicates that the design 17 cbjective discussud above provides reasonable 18 assurance that early notification can be 19 provided. Periodic testing of sirens identifies 20 deficiencies in the system and specific localities 21 where improvements are necessary and required. l 22 Emergency plans are documents that are l 23 constantly undergoing changes and revision. The 24 offsite emergency preparedness plans for Pilgrim l [ i I
33 1 Station were subnitted by the Massachusetto civil 2 Defense Agency to FEMA in 1981. Numerous drills 3 and full-scale exercises were held as required 4 with the appropriate state and local 5 participation. However, due to deficiencies 6 identified during these drills and exercises and a 7 lack of progress by off-site organizations. both 8 state and local communities, in correction of 9 long-standing plan deficiencies, the Federal 10 Emergency Management Agency conducted a 11 self-initiated review of Pilgrim and published and 12 their report un August 4, 1987. This FEMA review
'-- 13 included the report issued by the Massachusetts 14 Secretary of Public Safety, Mr. Charles Barry, in 15 December, 1086, 16 FEMA identified six issues. These are lack 17 of evacuation plans for some public and private 18 schools and day care centers, lack of a reception 19 center for people evacurted to the north, lack of 20 identifiable public shelters for the beach 21 population, inadequate planning for the special I
22 needs population, inadequate planning for the l 23 evacuation of the transportation dependent 24 population, an overall lack of process in planning { l
34 4 1 and an apparent diminution of emergency 2 preparedness. report I 3 The NRC transmitted the and g these findings 4 to the Boston Edison Company in Boston in August, 5 1987, encouraging Boston Edison to work with and 6 support the Commonwealth of Massachusetts and 7 local organizations to correct these 8 deficiencies. We are aware of some of the work to 9 date in improving the o f f s i .t e emergency 10 preparedness programss at Pilgrim and correcting 11 the emergency planning deficiencies identified by 12 the Federal Emergency Managemens Agency. We are 13 aware that drafts of the local emergency plans 14 have been completed, and these plans have been 15 forwarded by the Commonwealth of Massachusetts to 16 FEMA for a technical review. This initial 17 technical review has been completed, and FEMA has 18 happene. transmitted comments back to the l 19 Commonwealth identifying areas where further work 20 is required. We are aware that the draft 21 Massachusetts Civil Defense Agency Area II Plan is 22 essentially complete and is being reviewed by the 23 Commonwealth, and the' draft of the commonwealth 24 plan for Pilgrim is nearing completion. [
30 1 iRC has stated at several public meetings 2 that it will not permit the Pilgrim facility to 3 resume operation until corrective action 4 satisfactory to NRC have been taken to address the 5 emergency planning deficiencies identified by the 6 Fede2al Emergency Management Agency. The NRC will 7 give special attention tc the schools and day care 8 centers as well as for special needs and 9 transport-dependent populations in the plume 10 exposure pathway ten mile emergency planning 11 zone. Before allowing Pilgrim to restart, the NRC 12 will require some demonstration that critical b-- 13 aspects of the emergency plan can be adequately 14 implemented. 15 The NRC may authorize restart with some 16 planning issues not fully resolved. As long as 17 the NRC can still make a finding that there is 18 reasonable assurance that the public health and 19 safety can be protected. In reaching this 20 decision, the NRC will examine each planning 21 deficiency and weigh the significance of the 22 deficiency, the nature of any compensatory actions 23 and the progress being made by the Commonwealth, g 24 local g o v e. nments and the licensee, Boston Edison,
36 r 1 toward correction of the deficiency. I j 2 Emergency planning is a dynamic process at i 3 operating nuclear plant sites in the United 4 states. In practice, we expact that emergency
- 5 response plans will be revised and improved on a 6 continual basis. Deficiencies identified during 7 the ongoing review process and in biennial 8 exercises of each of these sites are assessed for 9 significance and the regulations p e r.a l t that 10 plants may be allowed to operate while the II deficiencies are being corrected. Given the 12 progress to date at Pilgrim, it is premature at 13 this time to attempt to determine which, if any, 14 deficiencies may remain when restart decisions are 15 to be made.
16 In conclusion, the NRC is aware of the 17 identified deficiencies is offsite emergency 18 planning around Pilgrim and the corrective actions 19 underway. The NRC will not permit Pilgrim to 20 resume operation until corrective action 21 satisractory to the NRC hsve been taken to address 22 these emergency planning deficiencies. 23 I will turn now to environmental 24 monitoring. The environmental monitoring concerns { a
37 I l l 1 raised during the February 18, 1988, meeting j 2 include onsite and offsite monitoring, technical 3 specification sampling requirements, the 4 responsibilities of Boston Edison in contrast to 5 those of the NRC, differences in shellfish versus 6 finfish activity and numerous comments about the 7 results of cancer studies performed around the 8 Pilgrim Station. I will address each of these 9 areas, but it is first important to set the stage 10 for radiological environmental monitoring and 11 effluent monitoring. 12 Radiological environmental monitoring and t L- 13 effluent monitoring at Pilgrim is important both 14 for normal operations as well as in the event of 15 postulated events. During normal operations 16 environmental monitoring verifies the 17 effectiveness of in-plant measures for controlling 18 the release of radioactive materials and makes 19 sure that the levels of radioactive materials in 20 the environment do not exc.eed regulatory 21 requirements and are as low as reasonably ! 22 achievable. For postulated events it allows the l l 23 an additional means for estimating doses to 24 members of the general public. {
38
)
1 There are specific regulatory bases for i 2 requiring this environmental monitoring and ' 3 effluent monitoring. Regulations are contained in 4 General Design Criteria 64 of Appendix A of 10 CFR 5 Part 50 and Section IV.B of Appendix I of 10 CFR 6 Part 50 that note in part, "The licensee shall 7 establish an appropriate surveillance and 8 monitoring program to: Provide data on quantities 9 of radioactive material released in liquid and 10 gaseous effluent's: provide data on measurable 11 levels of radiation and radioactive materials in 12 the environment to evaluate the relationship 13 between quantities of radioactive material 14 released in effluents and resultant radiation 35 doses to individuals from principal pathwafs of 16 exposure." 17 The requirements of the licensee'a 18 operational radiological environmental monitoring 19 program are specified in the radiological effluent 20 technical specifications that are issued with the 21 operating license for the nuclear power plant. 22 These technical specifications for Pilgrim were 23 significantly revised and upgraded in August of 24 1985. More detal.19d information is contained in {
39 1 the offsite dose calculation manual which is 2 referenced in the plant)'s technical 3 specifications. The technical specifications also 4 require that the licensee submit an annual report 5 and a special report within thirty days if 6 predetermined levels of radioactivity are 7 exceeded. To assure the precision and accuracy of 8 the measurements of radionuclides in the 9 environmental samples, licensees are required to 10 participate in an interlaboratory comparison il program. 12 The results of 2?CO's radiological
'-- 13 environmental programs and effluent monitoring 14 programs are reported to the NRC in Region 1. The 15 environmental monitoring results are reported 16 annually and effluent monitoring results are 17 reported semi-annually.
18 The program at the Pilgrim Station includes 19 specific criteria on the exposure pathway analyzed 20 or sampled, including radiolodines and 21 particulates in air, sampled at eleven stations by 22 continous air sampling analyzed weekly; direct 23 radiation; surface water, sampled at three 24 locations continuously or weekly; ground water; {
40 6 1 drinking water; sediment from the shoreline,
-2 sampled at six stations semiannually; milk, 3 sampled at two stations semimonthly; shellfish, 4 sampled at five locations quarterly; algae, 5 sampled at four locations quarterly; lobster, 6 sampled at four locations quarterly; fish, sampled 7 at thirteen locations quarterly; cranberries, 8 sampled at three locations at harvest; vegetation, 9 sampled at seven locations at harvest; and, 10 finally, beef, sampled at two locations semi-11 annually.
12 During 1987 doses from these sources were f '- 13 small fractions of regulctory limits. 14 NRC Region I conducts inspection activities 15 relating to environmental areas. Approximately 16 once per year the licensee's effluent 17 radioanalytical laboratory programs are 18 inspected. The last inspection at Pilgrim in this 19 area was conducted in October of 1987 and showed 20 that Boston Edison was conducting an adequate 21 program. The scope of these inspections 22 encompasses organization, procedures, records, 23 quality control, laboratory facilities and 24 confirmatory measurements. NEC conducts this {
4a
. 1 confirmatory inspection with the use of a mobile 2 laboratory. Effluent stream samples are split 3 with the licensee and analyzed in their laboratory 4 and in the NRC mobile laboratory. A high level of 5 quality control is maintained with traceability to 6 the National Bureau of Standards. Split sample 7 results are intercompared and applied to an 8 agreement / disagreement criteria. The purpose of 9 this type of inspection is to ensure that 10 1dcensees are making valid radiological 11 measurements. We have committed to bringing the 12 mobile van to the Pilgrim Station within three '-- 13 months of any restart.
14 The second type of inspection that is done, 15 again usually on an annual basis, is in the area 16 of radwaste effluent controls. During this 17 inspection, operation procedures, records and 18 calibration of effluent moniters are reviewed with 19 particular emphasis on the latter. In addition, 20 the licensee's offsite dose calculation manuals l 21 are reviewed for changes, and records are reviewed j 22 for adequacy of implementation. Example ODCM 23 calculations are made and tested against 24 regulatory and technical specification 4
j 42 1 requirements. This area was last inspected at l l 2 Pilgrim in April of 1988, just last month, and l 3 showed Boston Edison is conducting an adequate , 4 program in this area. 5 Also in the environmental area, inspection 6 of the licensee's environmental monitoring program 7 is conducted generally once every two years. It 8 involves the environmental laboratories and 9 equipment, procedures, organization, records and 10 general program implementation. Licensee 11 monitoring results are intercompared with 12 confirmatory results from the NRC programs as well k- 13 as estimates and descriptions presented in the 14 environmental statements for the facility. This 15 inspection at Pilgrim was last performed in 16 October of 1987 abd show Boston Edison to be 17 conducting an adequate program in this area. 18 In addition to the monitoring that was 19 performed by Boston Edison under their technical to specification requirements, NRC provides 1 21 independent confirmatory environmental monitoring 22 by means of two programs. First, environmental 23 sampling and analysis are performed by 24 participating states under contract t^ the NRC. (
I l 43 1 Second, direct radiation measurements are made by 2 the NRC's thermo-luminescent dosimetry, TLD for 3 short, network. This network is operated out of 4 the NRC Region 1 Office. 5 The purpose of state contracts program for 6 environmental confirmatory monitoring is to
- 7. conduct independent measurements in the area of 8 nuclear facilities to evaluate the quality of the 9 licensee's environmental radioactivity and 10 radiation measurements. These measurements 11 duplicate as closely as possible certain parts of 12 the licensee's environmental monitoring efforts,
'- 13 but are made completely independent of the 14 licensee's program. The results of the state i
15 contract program are used by the NRC and the l 16 states in verifying the capability of the licensee 17 to measure radioactivity in environmental media. l 18 The state contracts program is viewed as a 19 cooperative effort between the state and the NRC. 20 Participation by a state is completely voluntary. l l l 21 The Commonwealth of Massachusetts is a participant l 22 in this plan and performs both sample collection 23 and analyses for intercomparison of results, i 24 The NRC environmental TLD program was { { n- \
44 I i 1 established in 1979 after the Three Mile Island 2 accident. Approximately fifty dosimeters are 3 exchanged quarterly around each of seventy-one 4 power reactor sites and several production 5 facilities in the United States. At the Pilgrim 6 Station forty-nine dosimeters are exchanged 7 quarterly, located within ten miles of the plant. 8 The NRC's direct radiation monitoring program i s 9 operated by the NRC in order to provide continous 10 measurement of ambient radiation levels around 11 nuclear facilities, primarily power reactors. It 12 has a two-fold purpoce. First, it is a e '- 13 confirmatory program for the purpose of assuring 14 that licensees operate their effluent monitoring 15 and control systems in a manner consistent with 16 regulatory requirements; and, second, it is 17 intended to provide information regarding 18 environmental doses in the event of a nuclear 19 power reactor accident. Detailed results of the 20 program are published quarterly as NUREG-0837. 21 An issue raised at the February 18, 1988, 22 meeting concerned cancer studies around the 23 Plymouth area. The NRC staff has reviewed the
, 24 epidemiological study entitled "Health
>-+u,--
40 i surveillance of the Plymouth Area," which was s' 2 performed in February, 1987, by the Massachusetts 3 Department of Health. The study reports detecting 4 2n increased incidence of leukemia cases in five 5 towns in the vicinity of the Pilgrim Nuclear Power 6 Plant. Because many other factors other than the 7 Pilgrim Plant could cause this increase, the 8 authors of the study state that the cause of the 9 increased incidence has not been determined. The 10 NRC agrees with the author' statement. 11 The effects of radiation on living systems 12 have been studied for decades by individual L_ 13 scientists as well as by select committecc who are 14 formed to objectively and indopendently assess the 15 risks from radiation. These studies were 16 considered in the development of the public health 17 and safety limits on tho part of the Pilgrim Plant 18 as well to other nuclear power plants. Those 19 studies have not detected a statistically 20 significant increase in cancer for doses and dose i. 21 rates normally encountered in the vicinity of a 22 nuclear power plants. In fact, variations in 23 natural radiation backround in different 24 geographical locations are much greater than ( l
46 1 increases in radiation levels around nuclear power 2 plants due to the operation of these plants, and 3 there is no significant correlation in cancer 4 rates due to such variation in natural backround 5 radiation. 6 We are also aware of the National 7 Institutes of Health's involvement in studying the 8 adverse effects of low-level lonizing radiation. 9 We support the need to further define the effects 10 of this phenomenon, but we believe it will be I 11 several years before the results of these studies 12 will be available. We look forward to L- 13 incorporating these results in the body of data 14 already available on this subject. 15 Thus, the NRC staff has found that on the 16 basis of the substantial data available in the 17 area of health effects from exposure to radiation 16 there is no statistically significant increase in 19 cancer around nuclear power plants. It is not not 20 appropriate to delay starting the Pilgrim Plant l 21 pending completion of further study to' determine 22 if there is a link between certain types of cancer 23 and commercial nuclear power operation. ( 24 Another issue raised at the February l
. . _ _ . . =- , _ , . - . . . , , - _ _ __ . . - . , - - _ . - _ _ _ . ._-. .
47 l I meeting by several members of the public concerned 2 the impact of radioactive releases from Pilgrim 3 Station on shellfish and finfish. Small but 4 measurable amounts of radioactive material have 5 been measured in the marine biota. Studies and 6 measurements of this possible radioactive material 7 in marine biota are required by the Pilgrim 8 Station technical specifications and are 9 implemented by the licensee's radiological 10 enviromental monitoring program. As previously 11 discussed, these programs are inspected in detail 12 by the NRC and the results are regularly reported 13 to the NRC. The most recent analysis of the 14 release of radioactive material from Pilgrim show 15 the potential health effects to be of 16 insignificant consequence. 17 The radioactive material is most prevalent 18 in shellfish due to the feeding mechanism of the 19 shellfish. These biota feed by filtering 20 particulate material from.large voJumes of water, 21 and particulate isotopes are generally the 22 detected contaminant. In addition, shellfish tend 23 to remain fixed in location compared to finfish. 24 Finfish tend to be migratory in nature, and, being ( 1
l i 48 I 1 mobile, they do not normally reside near the f 2 discharge canal long enough to accumulate 3 measurable amounts of radioactivity. Thus, there i 4 is the perception that shellfish accumulate 5 radioactive material in preference so finfish. 6 In either case, any dose commitment to an 7 individual consuming quantities of shellfish would 8 be negligible compared to the doses. received by 9 memberc of the public from natural and man-made 10 sources of radioactivity. 11 In conclusion, first, Boston Edison is 12 required to maintain an extensive environmental
'~ 13 and effluent monitoring program. NRC inspections, 14 continuing inspections, have shown these programs 15 to be acceptable. Secondly, there is no basis to 16 conclude that there are any statistically 17 significant increases in cancer for doses and dose i
18 rates normally encountered around nuclear power 19 plants. 20 Thank you for listening to my remarks. Mr. 21 Bruce Boger is the next speaker. . - 22 MR. BRUCE BOGER: I'm pleased to be 23 here today to respond to the comments received l 24 during the February 18, 1988, public meetings ( l l l l
+ - - -
49 8 1 regarding the Pilgrim Mark 1 containment and 2 Boston Edison Company's Safety Enhancement 3 Program. A summary of the comments that we 4 received are provided as handouts tonight. My , 5 presentation will be included in the transcript as 6 a part of the meeting report documenting this 7 public meeting. 8 Before I respond to the specific comments 9 received on the Pilgrim Restart Plan I would like 10 to provide some of the backround information on 11 the licensing process used by the Nuclear 12 Regulatory Commission during the initial licensing (
'- 13 and subsequent modification of a facility, 14 the"Defense-In-Depth" concept for the safety of 15 nuclear power plants, and the NRC monitoring 16 process after licensing. This backround 17 information may be helpful in understanding NRC 18 octivities related to Mark I containments.
19 With respect to the licensing process, the 20 regulations which govern the licensing f nuclear 21 power plants are contained in Part 50 of Title 10
..g 22 of the Code of Federal Regulations. This is also 23 known as 10 CFR 50. Those regulations are 24 supplemented by various industry codes, standards
(
00 f 1 and guidance documents. These are referred to as 2 Regulatory Guides, Standard Technical 3 Specifications, Standard Review Plan. An 4 applicant for a facility license prepares a 5 document called a Final Safety Analysis Report 6 which identifies plant features and the codes and 7 standards used in its design and construction. 8 The Nhc staff reviews the Finel Safety Analysis 9 Report against the regulations which are in effect 30 at the time of I'icensing. The results of the NRC 11 staff's review are documented in a Safety 12 Evaluation Report. These documents, the Final i 13 Safety Analysis Report and the Safety Evaluation 14 Report, in part constitute what is termed the 15 licensing basis for the issuance of a facility 16 operating license. Furthermore, each license 17 issued for operation of a nuclear power plant 18 incorporates technical specifications which set 19 forth the safety and environmental limits impos.ed 20 on that facility which must be met in order for 21 the facility to operats in accordance with its 22 licensing basis. For Pilgrim these licensing 23 documents are ave 11able in the Local Public
; 24 Document Room located in the Plymouth Public
- . - - . . . _ - - - . . - - . . - . - ~ . - -- - --
52 l
. 1 Library.
2 Subsequent to obtaining a license, the 3 facilities must upgrade or chenge their initial 4 design and operating procedures as a result of 5 operating experience. Such change would require 6 prior approval from the NRC if the proposed change 7 is a change in the technical specifications or 8 constitutes an unreviewed safety question. In 9 part, a proposed change constitutes an unreviewed 10 safoty question if it, che, increases the 11 probability or consequences of an accident 12 analyzed in the Final Safety Analysis Report, i 13 creates the possibility of a new type of accident, 14 or reduces the margin of safety as defined in the 15 basis for any technical specification. 16 Other changes and enhancements can be made 17 l by the licensee if no technical specifications are 18 required and a determination is made by the 19 licensee that no unreviewed safety question 20 results from the change. This a allowed by the [ V-l 21 regulations and is referred to as a 5 0 .~5 9 change
- F t?
22 as defined in the regulations of 10 CFR 50.-59. 23 These changes are reported to the NRC and are 24 routinely inspected usually following {
32 ! 1 implementation. 2 As a result of NRC activities associated 3 with research and development and monitoring of 4 nuclear power plant experience, changes to the 5 NRC's regulations occur. Some of these changes 6 are intended for future nuclear facilities and, 7 therefore, are not imposea on current facility 8 licensees. However, if the NRC determines that 9 substantial additional protection for public 10 health and safety is provided by upgraded 11 requirements, then these requirements are imposed 12 on licensees. This is referred to es backfitting '- 13 newer requirements on a previously licensed 14 facility and is governed by the regulations in 10 15 CFR 50.109. Some examples of backfitting at 16 Pilgrim are revised emergency operating 17 procedures, increased staffing, upgraded training, 18 safety system upgrades, added instrumentation, and 19 Appendix R fire protection requirements. . 20 Now I would like to discuss the defense-in-21 depth concept. The NRC has incorporated the 22 defense-in-depth philosophy in the design and 23 operation of the reactor facility to reduce the 24 likelihood of individual equipment, component or {
53 1 human errors that could result in the loss of a 2 safety system or a safety function. This is i 3 accomplished during the design process by 4 redundancy and diversity within each safety 5 system. 4 6 An example of the defense-in-depth is the 7 number of physical barriers which are designed to 8 prevent the release of significant offsite levels 9 of radiation. Reactor plant design provides for 4 10 the initia] physical barrier being the fuel 4 11 cladding, the second barrier being the reactor 12 vessel, and the third barrier being the i
'- 13 containment. In turn, each of these barriers is 14 protected by redundant and/or diverse systers to 15 provide reasonable assurance their individual 16 integrity is maintained.
17 In addition to the design features of the 18 defense-in-depth concept, operational controls are 19 established which include technical specifications 20 that identify requirements on equipment operation 21 and system operating parameters, operating 22 procedures to keep the plant within normal bounds 23 and emergency operating procedures to cover 24 situations outside the normal bounds, training and (
54 1 licersing of the operating staff on technical i I 2 specifications and procedures, i n c'l u d i n g training 3 on a plant specific simulator, and the licensee's 4 quality assurance and quality control programs ! i' 5 related to construction, operation and maintenance 6 of plant equipment and systems. g ., 1 7 To assure that licensed facilities maintain 8 and operate their structures, systems and l 9 components in accordance with the regulations, i lo standards and procedures they were approved by, i 11 the NRC has an extensive inspection and 12 enforcement program. Pilgrim Station has three L_ 13 full-time resident inspectors on site. In 14 addition, announced and unannounced inspections 15 are performed by specialists from NRC headquarters 16 and the regional office 7 augment the residents' 17 daily inspection activities. All inspection-18 activities are documented in inspection reports 19 and are available in the Local Public Document 20 Room. The purpose of the NRC inspection and 21 enforcement program is to promote and protect the 22 radiological health and safety of the public by 23 ensuring compliance with the NRC requirements, , 24 obtaining prompt corrective actions, deterring
55 e 1 future violations and encouraging the improvement 2 in licensee performance. 3 Thus far I have provided a brief overview 4 of how the NRC staff has and is continuing to 5 address concerns related to the Mark 1 containment 6 and assessing the plant-specific modifications to 7 the Pilgrim Mark containment implemented as part 8 of the Boston Edison Safety Enhancement Program. 9 In a nuclear power plant the principal 10 sources of protection of public health and safety 11 are provided by the defense-in-depth concept of 12 proper design, conciruction and operation. The ) i
'- 13 initial licensing of the power plant requires that 14 the ability to withstand certain types of 15 accidents, which are thus known as design basis 16 accidents, be included as a design requirement.
17 Design basis accidents represent a wide spectrum 18 of plant problems, some of which might be expected 19 to occur in the lifetime of a plant, such as loss 20 of electrical power supplies, and others which are 21 considered to be very unlikely, for instance, 22 major ruptures of piping systems. These design 23 basis accidents are included in facility's Final ( 24 Safety Analysis Report. Every commercial nuclear
56 i i i' i power plant licensed in the United States must 2 have a protective containment around the reactor, 3 usually made of steel or steel-reinforced 4 concrete, that is designed to contain radioactive 5 material which might be released from the reactor 6 during a design basis accident. All containments, 7 including the Mark i design at Pilgrim, must 8 include acceptable structural design margin to 9 withstand these design basis accidents in 10 conjunction with the simultaneous occurrence of an 11 earthquake. 12 In 1972 Dr. S. H. Hanauer of the Atomic f ' '- 13 Energy Commission raised seven concerns relating 14 to the Mark 1 containment's ability to respond to 15 a large loss of coolant accident which is one of 16 the design basis accidents. The NRC staff 17 performed a review which considered Dr. Manauer's 18 concerns and documented its findings in NUREG-19 0474 which was issued in July of 1978. Enclosure 20 A to NUREG-0474 summarizes the NRC staff's actions 21 relating to each of Dr. Hanauer's concerns. As a 22 result, the staff required modifications for all ' 23 Mark 1 containments, including Pilgrim, to ensure t 24 design margins for design basis accidents are \ a -, - . - . - - _ - . _ .
07 1 maintained. 2 Issues related to the Mark I containment 3 design were also raised in an interna] 1975 4 General Electric Company study referred to as the 5 Reed Report. This internal study was a product 6 improvement report by the corporation that 7 designed the Mark 1 containment. This report 8 identified areas in plant design, including the 5 containments, where design improvements could be 10 mado. Members of the NRC staff reviewed the 11 document in 1976 and determined that it did not 12 raise any significant new safety issues. The NRC
'- 13 staff has since re-evaluated the Reed Report from 14 a 1987 perspective and documented the results in 15 NUREG-1285 which was issued in July of 1987. The 16 results of the re-evaluation supported the staff's 17 initial findings and concluded that, one, there 18 are no issues raised in the Reed Report that 19 support the need to curtail the operation of any 20 General Electric boiling water reactor such as 21 Pilgrim; two, there are no new safety issues 22 raised in the Reed Report of which the staff was 23 unaware; and, three, although certkin issues
( 24 addressed by the Reed Report are still being
I 58 !. I studied by the industry, there is no basis for l 1 2 suspending licensing and operation of General 3 Electric boiling water reactor plants while these 4 i s sv 4 *- 5, r e being resolved. 5 As a result of the TMI accident, the NRC 6 staff has been studying accidents which go beyond 7 design basis accidents and are referred to as : 8 severe accidents. The Commission has concluded 9 that existing plants pose no undue risk to the 10 public health and safety and has concluded that 11 immediate action on generic rulemaking or other 12 regulatory changes to plants as a result of severe 13 accident risk was not required. The details of 14 this position are in the Commission's Policy 15 Statement on Severe Reactor Accidents Regarding 16 . Future Designs and Existing Plants, August 8, I 17 1985. 18 The 1975 Reactor Safety Study which is also 19 known as WASH-1400 or the Rasmussen Report in , 20 recognition of MIT professor who coord3nated the l 21 study, and the most recent comprehensive study l 22 entitled "The Reactor Risk Reference Document," , 23 which in also known as NUREG-1150, genera 31y
; 24 confirmed the very low likelihood of severe l
I
09 1 accidents and consequently the relatively low risk 2 to the public even if suct. ach very low 3 prcbability accidents were to occur. 4 Nevertheless, the Commission has several ongoing 6 programs to evaluate probabilistic risk 6 assessments to provide a more detailed assessment 7 of possible severe accident scenarios. 8 NUREG-1150 also investigated the likelihood 9 of early failure of the Mark 1 containment 10 following the very low probability of a core 11 melt. The report n o +. e d that conditional 12 containment failure probability could range from
'- 13 ten to ninety percentfor . ?s e s e extremely unlikely 14 events. The large uncertainties related to the 15 response of the containments during a postulated 16 severe accident are subject of NRC and industry 17 research. The goals of the research effort are to 18 provide an improved understanding of severe 19 accidents. While the NRC believes that severe 20 accident risks are acceptably low at operating 21 nuclear power plants, including Pilgrim, the staff 22 is re-evaluating the Mark I containment 23 performance on a priority basis. The staff
( 24 expects to make recommendation to the Commission
60 1 by late this summer. Any Mark 1 improvements , 2 indicated as beneficial by these studies will be 3 imposed on Pilgrim and other Mark i facilities in 4 accordance with the backfitting policy. 5 Several Mark i modifications have been 6 considered by the NRC and the industry which are 7 intended to improve plant performance in the event 8 of a severe accident. Boston Edison has performed 9 an evaluation and completed a number of these 10 modifications at Pilgrim as part of its Safety 11 Enhancement Program. The NRC staff reviewed these 12 modifications in August of 1987 and concluded that I L-13 eight modificetions were appropriate for 14 implementation. These changes include containment 15 spray nozzle modifications, the installation of a 16 third emergency diesel generator, modifications to 17 fire protection systems and features to respond to 18 anticipated transient without ceram. These 19 modifications are in line with the NRC goals to , 20 enhance containment perfcrmance under severe 21 accident conditions. These modifications are not 22 a requirement for restart of Pilgrim and have been 23 1rplemented by Boston Edison company in accordance i 24 +1'd the issues of 10 CFR 50.59.
i 62 I Questions have been raised by NRC staff 2 regarding the Direct Torus Vent modification being 3 considered by Boston Edison. The Direct Torus 4 Vent would provide a hardened path from the 5 containment torus structure to the plant stack and 6 would be used to relieve containment pressure in 7 certain postulated severe accident situations, ; 8 During staff review of this proposed modification 9 a number of questions were asked of Boston Edison 10 regarding the design and use of the Direct Torus il Vent. These questions must be resolved before 12 this system is placed into service.
'- In conjunction with the efforts to review 13 14 and enhance the containment performance the NRC 15 staff is also reviewing procedures used by the 16 operating staffs in response to postulated i
17 accidents. Theae procedures are referred to 18 Emergency Operating Procedures. Since Boston 19 Edison upgraded the Emergency Operating Procedures 20 at Pilgrim, .he staff recently performed a team 21 inspection to review Emergency Operating 22 Procedures development methodology, upgraded the 23 Emergency Operating Procedures content and the i , 24 associated operator training on the use of the l l i l
I 62 1 upgraded Emergency Operating Procedures. The 2 results of this inspection indicate that the 3 procedures for developing Emergency Operating 4 Procedures, 'e h e upgraded Emergency Operating 5 Procedures content and the associated operator 6 training are acceptable. 7 To summarize, the purpose of this 8 discussion has been to provide the regulatory 9 approach used to address the comments received on 10 Mark I containments durit.g the previous pubalc 11 meetings on February 18. In summary, all Mark i 12 containments, including Pilgrim, have been t i 13 demonstrated to satisfy their design requirements 14 with acceptable structural design margins. Dr. 15 Hanauer's concerns relating to design basis 16 accidents have been resolved and the GE Reed 17 Report did not raise any new significant issues. 18 The assertion that the NRC denied the 2.206 19 petition hearing request filed by State Senator. 20 Golden and others because if a policy issue, such 21 as the Mark 1, was brought into focus it would , 22 affect other plants besides Pilgrim is incorrect. 23 As indicated in the Interim Director's Decision on ( 24 the 2.206 petition dated August 21, 1987, the
-w - --,.,m- - , , - -__
63 I petitioners had not presented sufficient evidence 2 to indicate that the Pilgrim Station should not 3 operate while risk-reduction improvements were 4 being considered. That is, there is not 5 sufficient eviderce provided of either design ~ 6 flaws at Pilgrim or high risk to warrant a show 7 cause order for the plant to remain closed or to 8 suspend the operating license. 9 Boston Edison Company has completed a 20 number of modifications as part of their Safe'ty 11 Enhancement Program which are in line with NRC 22 gn* , to enhance containment performance. The 13 upgraded Emergency Operating Procedures for the 14 Pilgrim Station have been reviewed and found to be 15 satisfactory. A final decision on the use of the 16 Direct Torus Vent is pending resolution of the NRC 17 staff's concerns. However, as previously stated, 18 the completion of the Safety Enhancement Program, 19 including the Direct Torus Vent, are not a 20 requirement for restart of Pilgrim. 21 Finally, those present who would like more 22 detailed information on Mark i containment should 23 review the Interim Director's Decision responding ( 24 to the 2.206 petition of State Senator Golden and
64 1 others. Attached to the document is Enclosure A 2 to NUREG-0474 which summarizes the NRC's actions 3 relating to Dr. Hanauer's concerns. The Interim 4 Director's Decision, inspection reports, NUREGs 5 and other documents I have referenced in this 6 presentation are available at the Local Public 7 Document R o o'm located in Plymouth Public Library. , 8 That concludes my presentation and thank you for 9 listening. 10 The next speaker will be Sam Collins. 11 MR. SAMUEL COLLINS: In the context 12 of my presentation I will respond to the comments L_ received during the February 18 public meeting 13 14 regarding management and the NRC asseasment 15 process as these two areas relate to the restart 16 2eviews at Pilgrim. A summary of the comments 17 received in these areas has been provided tonicht 18 as a handout. My presentation will be incl ded in 19 the transcript as a part of the meeting report . 20 documenting this public meeting. 21 In the NRC's view the past problems at 22 Pilgrim have been well defined. The NRC 23 Confirmatory Action Letter, our reports on routine 24 inspections and the systematic assessment of
60 1 licensee performance reports, known as SALP, have 2 all defined weaknesses that must be corrected 3 before a decision on restarts can be made. The 4 solutione proposed to correct those weaknesses 5 must demonstrate that Boston Edison Company is 6 fully capable of operating Pilgrim within the 7 confines of the Commission's safety requirements 8 before any commission decision can be made to 9 allow restart of the facility. 10 It is important to recognize that it is the il responsibility of Boston Edison, not the NRC, to 12 formulate and impicment programs that address the 13 weaknesses that have been identified at the 14 plant. In particular, Boston Edison must 15 demonstrate that it has provided strengthened line 16 management to ensure safe operation of the 17 facility, strong independent oversight of 18 operating activities to ensure that problems are 19 quickly identified and efficiently corrected and 20 an operating environment that fosters safe, 21 professional operation of the facility. 22 When Pilgrim was voluntarily shut down by 23 BECO, the NRC confirmed by Confirmatory Letter { 24 86-10 that certain actions were required before
I I 66 1 the plant would be permitted to restart. The BECO 2 Restart Plan is a blueprint for the needed changes 3 and fulfillment of the goals of this plan are the 4 restart criteria by which the NRC will evaluate 5 the restart readiness. The NRC staff will 6 determine the effectiveness of the restart plan's 7 implementation and whether it is having the 8 desired effect in correcting the problems that 9 have been identified at Pilgrim. Underlying the 10 problems that Pilgrim in the past has been an 11 unstable, unsupportive management structure from 12 the corporate level to the site line management. L_ 13 BECO has a responsibility to address this problem, 14 and it has been a significant challenge. As a 15 result of BECO's actions, the NRC must have 16 confidence, based on direct observation of 17 licensee performance at every level in the l 18 organization, that management and supervision both 19 at the corporate offfee and at the facility are to committed to and require high standards of 21 professional performance f' r om its employees. In i 22 order to accomplish this, the NRC needs to review 23 and evaluate the potential and actual I ' 24 effectiveness of licensee management. l l l l
67 1 Management effectiveness is a concept that-2 does not easily lend itself to a straight-forward 3 definition. However, there are certain traits 4 that are typically evident in effective management 5 organizations. Some of these traits are: 6 First, structurally the organization 7 is established to bring to bear appropriate 8 management attention and focus on the various 9 mission areas of the organization. For a nuclear lo power plant these are&c anclude operations, 11 maintenance, surveillance, engineering, 12 radiological controls, security, emergency 13 preparedness and licensing. 14 Secondly, management positions are 15 filled with qualified personnel. Turnover in 16 these positions is controlled such that management 17 development and succession plans can be 18 implemented without resulting in signifAcant 19 degradation in performance. 20 Thirdly, management policies are 21 clearly stated and widely understood within the 22 organization. Policies and procedures are 23 satisfactorily implemented and rarely violated. , t 24 Fourth, management information
~~
68
?
1 systems exist that can provide adequate records 2 .and trends of organization performance and can 3 serve as a credible basis for management 4 decisions. 5 F i f t' h , decision making is at the S level in the organization that ensures an adequate 7 management review. 8 Sixth, prior planning and appropriate 9 assignment of priorities are evident within the 10 organization. 11 Seventh, corporate and site 12 management involvement in site activities are L_ 13 evident. Management reviews are timely, thorough 14 and technically sound. 15 Lastly, corrective actions to 16 identify problems are timely and typically 17 targeted toward the root causes of those 18 problems. 19 The NRC has many tools that serve as . 20 guidelines for the review and evaluation of the 21 potential and actual effectiveness of licensee 22 management. Some of these are: 23 First, the standard review plan i 24 Section 13.1.1 called Management and Technical
69 1 Support Organization. This is used to define the 2 criteria for new licensees construction. 3 Secondly, the American National 4 Standard and ANS Standard 3.1 which is Selection, 5 Qualification and Training of Nuclear Power Plant 6 Personnel. 7 Thirdly, NUREG/CR-4125 which is 8 Guidelines and Workbook for the Assessment of 9 Organizations and Administration of Utilities 10 Seeking Operating Licenses for a Nuclear Power 11 Plant. 12 Fourth, the systematic assessment of L_ 13 licensee performance known as SALP. The SALP 14 evaluation criteria includes specific management 15 involvement in all areas evaluated areas. The 16 performance category ratings are on a 17 three-category scale. 18 Fifth, the Performance Indicators, 19 called PI, Program which provides an objective 20 view of specific aspects of operational 21 performance. This is trending performed by in 22 NRC. o* t While management effective is not directly i l 23 evaluated the trends and changes in the i 24 performance indicators are evaluated for
70 1 indications of management performance. 2 Sixth, management review meetings 3 with corporate and plant management to follow up 4 on the results of the inspection program. 5 Seventh, NRC senior management 6 meeting are conducted on a six-month basis within 7 the NRC to evaluate available information relevant ; 8 to individual plant performance and identify 9 significant changes and t h e.i r potential cauces. 10 Augmented or additional NRC actions are developed 11 with those licensees with a poor or degrading 12 performance in order to ensure timely corrective i 13 action. 14 Eighth, NRC diagnostic evaluations 15 and other studies. For example, NUREG 1275. WOREG doc uments 16 There are numerous nee regulatione available on 17 that topic. rc it k,Nt 18 Ninth, reecter-team inspections, 19 either headquarters or regionally based, in . 20 response to site events. 21 Last, for selected plants the staff 22 has requested written self-evaluations be 23 performed as a measure of management's ability to ( 24 self-criticize, such as Beaver Valley 2 Plant,
71 1 Nine Mile, River Bend, Pilgrim and Peach Bottom, ;
)
2 The NRC has and will continue to review 3 these types of management guidelines during our 4 continued reviews at Pilgrim. Some of the 5 examples: A complete SALP will be performed prior 6 to any restart decision assessing the period from 7 February, 1987, to May, 1988. 8 Frequent management meetings S 9 including BECO senior m e.n a g e m e n t meeting,have been l 10 conducted throughout the shutdown. 11 NRC senior management meetings have 12 identified Pilgrim as a high priority plant 4 L_ 13 warranting3 requiring careful monitoring and close l 14 agency oversight. 15 The use of augmented NRC inspections, 16 including team inspections, to evaluate BECO's 17 licensee corrective action programs and assess 18 their implementation effectiveness, such as the l a 19 diKgnostic or evaluative team inspection, and l l 20 special team inspection called AIT. Both of those 21 were performed immediately following the plant l 22 shutdown in 1986. A recently completed' 23 maintenance inspection was done at the site. A l TATI 24 planned assessment team inspection, called f. ! T I ,
72 Wi!k 1 'culd also be conducted following BECO's restart 2 readiness inspection. - 3 The conduct of reactive team i 4 inspections to assess BECO's response to site 5 events have also.been conducted such as the 6 inspection that was performed as a result of the 7 loss of offsite power at the site. 8 Sixth, BECO was requested in 9 Confirmatory Action Letter 86-10 to conduct a 10 formal assessment of readiness for restart 11 operation. To date, they are continuing to , 12 conduct that self-assessment. I t. addition, they L_ 13 are presently undergoing a review by the Institute 14 of Nuclear Power Operations. 15 Seventh, ongeing inspection reviews 16 including recent site events are conducted by the 17 NRC office of Region 1 which provide input to the 18 effectiveness of management actions and contribute 19 to the overall assessment conducted as part of the 20 systematic assessment of licensee-performance. 21 Let me overview the NRC assessment process 22 being used to evaluate Pilgrim restart readiness. 23 The handout package provided tonight contains an ( 24 attachment as the last page which shows the
73 1 projected overall milestones within the NRC 2 assessment process. This table is for planning 3 purposes only and does not contain all the support 4 activities associated with each milestone. And in 5 many cases depicts goals that may or may not be 6 accomplished within the process. As you can see, 7 the NRC process contains many sub-elements, each 8 providing an input to the overall assessment of 9 the BECO corrective actions program. The dates 10 which are contained in the boxes are dates which 11 have been achieved. 12 Let mc point out a few specifics on this L_ 13 table. Generally you will note there is no firm 14 schedule in regards to the restart assessment or 15 decision. That restart assessment or decision 16 will follow BECO's determination they are ready to 17 restart the plant. We will not perform our 18 restart assessment reviews until that time. 19 Additionally you will note that several NRC 20 management reviews are in process. The Regional 21 Administrator has visited the site for a review 22 and public meeting participation. The Director of 23 NRR has conducted a site revjew. The Regional ( 24 Administrator, I should say, will participate in a
74 1 public meeting. The Director of NRR will also 2 participate in a public meeting. The Executive 3 Director of Operations or the EDO has committed to 4 perform a site review. NRC Commissioners have 5 been involved. Site reviews were recently 6 conducted by three of the five NRC Commissioners. 7 A total of four of the tive Commissioners have 8 visited the site. 9 BECO's decision on plant readiness is a IATI l A i 10 prelude to the NRC inspection for the 21TT. 11 statement is required bv the Senior Vice-President 12 that the self-assessment and their independent L_ 13 reviews support plant restart readiness. 24 Incomplete or additional actions which have been 15 identified as a result of the BECO self-assessment 16 cr the INPO review, for example, must be 17 identified, understood and scheduled for 18 resolution. The IATI 4444, on which is the fourth line of the 19 A 20 block, will be composed of twenty-four hour A 21 observation of site operations and activities. He 22 are using experienced inspectors. A majority of 23 those are site senior inspectors at other sites in i 24 the northeast. Mr. Randy Blough who is here 1
70 i 1 1 tonight will be the team leader and I will be the j 2 senior manager of that team. We have extended an 3 invitation to the Commonwealth to provide an 4 observer to that inspection. 5 That inspection process is expected to take 6 approximately three weeks. We will compare the 7 results of our assessment with BECO's assessment 8 and pursue any differences as a measure of the 9 BECO process effectiveness and the ability of 10 their management to perform self-assessments. 11 Additionally, we have committed to hold a 12 public meeting on the results of that inspection 13 following a report being issued. Ultimately, 14 after the staff has reached a position based upon 15 careful review of the licensee's readiness to it operate, the Commission will be briefed by the 17 staff at a public meeting. Based on that briefing 18 and the information provided from the assessment 19 and issues previouslygmentioned, the NRC 20 Commissioners will make a decision with respect to 21 the restart of Pilgrim. l 22 That concludes my presentation. I would 23 like to provide the opportunity for public i ( 24 comments. If we could have the cards brought up, e
w 76 I will moderate the comments, and the 1 please. 2 panel will attempt to answer the comments that we 3 are capable of. It's important to note this panel 4 is prepared tonight to address the issues in 5 conjunction with plant restart and its assessment, , 6 and any issues that fall outside of that area will j 7 be acknowledged. If we need to commit to provide 8 a response to the individual's, we will do that. , 9 The first individual is Mr. Peter 10 Forman, State Representative, Plymouth. 11 MR. PETER FORMAN: Can I assume that 12 the questions and answers and public comments will L_ 13 go beyond nine o' clock if people have more? THE 14 CHAIRMAN: That's correct. 15 MR. FORMAN: A word, first of all, 16 before the questions about the presentations 17 tonight. I think we all appreciate your coming 18 here, I must say that I'm somewhat disappointed in 19 the presentations I have heard. I've gotten a - 20 pretty good lesson on the NRC regulations, but 21 with few exceptions most of the concerns that were 22 raised in the earlier hearings and have been 23 raised in other hearings we are being told ( 24 tonight, if we simply check the rules and-rate regu\afion
77 1 books, our fears and concerns will be put to rest 2 and that is a fundamental assumption that the regu l ah' ens 3 ret:: will be correct and will be properly adhered 4 to. We hope some of the other questions and 5 answers that other people may have at other 6 meetings, we might be able to flush out some of 7 those concerns and you might be able to challenge 8 some of the bases of some those other than quoting 9 the regulations to us. 10 Wculd you prefer that I give ask you 3 11 questions one a time to the specific presenter or 12 would you like all the questions at once? L_ 13 THE CHAIRMAN: I will decide who 14 answers. I don't know how much you have planned. 15 We will take them one at a time and I will direct 16 you-17 MR. FORMAN: Five or six. On the 18 issue of public input in the adjudicatory hearings 19 and show cause hearings, I think there is a 20 concern about the different levels at which public 21 and official issues will be addressed. Clearly, a 22 show cause or adjudicatory hearing is not a proper 23 forum for large public protests or for a lot of I 24 general public statements about not wanting the
78 l l , i plant to be reopened, but, like, the hearings such 2 as this and even the ones we have had up at the 3 State House with the legislative panel are not 4 exactly appropriate forums for legal challenges to 5 Boston Edison or the NRC performance. 6 I think just to suggest that because you cc 7 have been, quote, a**essible, and we have had very l 8 frequent meetings in Massachusetts on the issue, 9 but to suggest that because. staff members have 10 been holding many meetings and attending many 11 hearings that, therefore, all the public and 12 official concerns are being addressed is i 13 inadequate. There are, I think, other forums at 14 which legal challenges or official statements from 15 state officials and local officials would be 16 better heard than meetings such as this. 17 My question is what kind of input do these 18 meetings actually have and influence they have on 19 the five Commissioners. The decision to reopen 20 the plant will be made by the five Commissioners. 21 I assume it takes a majority vote. Is that 22 correct? 23 THE CHAIRMAN: That's correct. 24 MR. FORMAN: For restart. A majority
79 1 being three out of five, we ve already had two 2 Commissioners down who have been given a tour of 3 the plant. They have come out and all but raised 4 their hands in favor of restart. I'm wondering 5 what kind of input we have had, what kind of 6 impact the public meetings have had on the 7 Commissioners. Are they hearing these concerns 8 and do they really take ther into account when 9 they simply come down, tour the plant and come lo out, hold a press conference and say it looks good 11 to them. 12 THE CHAIRMAN: Let me address the 13 last part of the question first. We had two 14 Commissioners here recently, and both 35 15 Commissioners have come out g WW> a result of 16 interviews in the press, the press statements have 17 concluded that the Commissioners, I guess, if I 18 can paraphrase, indicate there doesn't appear to 19 be any examples based on what they saw which at 20 this time that would be an impediment to restart. 21 I think it's important to qualify those 22 statements. i 23 The Commissioners receive just that. They 24 received a tour of the facility, they received a { l
80 l
. I briefing by the NRC resident inspectors. I was at 2 both of those. They received a briefing also by 3 BECO. And their statements are meant to indicate 4 that based on the level of review they have 5 performed they have provided their impreccions 6 based on the need for the press to have those 7 types of things.
8 The process, as I indicated earlier, is set E 9 forth such that the staff comes to a decision 10 before the Commissioners. The Commission 11 purportedly base their decisions on their staff's 12 to include a restart assessment report wh!.ch would f L- 13 include the types of issues that the public are 14 here for tonight. I think it's incorrect to say 15 that we have not addressed the comments. We have 16 addressed the comments. 17 Were you here for the opening statement? 18 MR. FORMAN: Yes. 19 THE CHAIRMAN: The opening statement 20 indicated in the package that addresses where the 21 comments are provided, and we have gone through a 22 very painstaking review of those comments end : 23 grert nu=ber to ensure many of thea are 24 addressed. However, many cf them are very broad {
88 1 comments. What we are attempting to do tonight is 2 to provide backround knowledge, references that 3 can be used in the future by referencing the 4 transcript which will be made publicly available 5 to get to the type of information that those 6 questions seem to be based on. We understand it's 7 a highly technical presentation because it's a 8 highly technical field. The questions.
-t h e st 9 un f ortunately, for the sake o f 4he people, seem to l 10 be focused toward the rules and regulations, and la so the answers were focused towards that.
22 MR. FORMAN: I would like to have a L 13 follow up on the public input. At most meetings 14 that we had here or in Boston there have baen 25 repeated requests that the NRC Commissioners come 26 down for meeting or hearing with the public. That 17 cs far has not been granted. At least two of them 18 have come, toured the plant. What does it take to 19 get them to come to some sort of public forum 20 where they can hear citizens' and officials' 21 concerns and not just tour the plant? < 22 THE CHAIRMAN: It takes direct 23 expression to the Commission. Have you got a 24 letter to the Commission requesting that? (
82 1 MR. FORMAN: We have have been told 2 the staff is filtering information and giving it 3 to the Commission. I would think with all the 4 meetings that the staff would go back and say, "We 5 are sick and tired of being bludgeoned to death at 6 the meetings. Why don't you go down and take it 7 for a while?" If that's all it takes, that's 8 fine, we w111 write a letter and invite them to 9 number of forums up here.
.0 THE CHAIRMAN: The position you just 11 referred to is not my position. I'm not sick and 12 tired of coming here and receiving comments and '- 13 giving forth answers. That is basically what 14 we're here for. The Commission performs a very 15 different function. The Commission is just that.
16 It's a voting body which votes predominantly based 17 on the recommendations of the staff and the 18 information that is put forth to them both by the 19 ' staff and the licensees. I would recommend if you 20 desire the commission to come to this area, that 21 you exprecs that directly to them. They have done 22 that in only one instance in the past, and that 23 has been in conjunction with the Three Mile Island 24 restart. {
,,,.y -. -, _ _ _ . , - .,.. . , - _ , ,. . , _ _ _ _ _ ,
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83 4. l 1 MR. FORMAN: I will be glad to do j 2 that, on the issue of emargency preparedness, the 3 statement was made that the NRC will decide 4 whether or not the plans are adequate. That, of 5 course, presumes that is with FEMA, consultation 6 of state and local consultation. The question is 7 where would the NRC decision on the adequacy of 8 emergency plans follow the state decision on 9 whether the plans are adequate or not? 20 THE CHAIRMAN: I think Dr. Bellamy 11 can answer that. 12 DR. BELLAMY: I'm not sure exactly L_ 13 what you mean by the state decision on the 14 emergency plans. The Commonwealth has forwarded 15 the draft local plans to FEMA for a technica3 16 review. 17 MR. FORMAN: Let me clarify. The 18 Governor says in his view or the selectmen in the 19 communities in their view find that the emergency l 20 plans are not adequate. Would you accede to that 21 finding and move the same way? l 22 DR. BELLAMY: I think you would have 23 to take a look at exactly what the plans indicated l 24 were to be done to protect the plan, who was going { l l i 1 - - . - - . - -- . . . - . - . - , . . _ . - . - . - . _ - - . -
i 84 1 l i i to take those actions and were those people 2 prepared to take those protective actions. There 3 is a significant amount of training going on now 4 as we speak in'the area around Plymouth Station. 5 And when Boston Edison comes to the NRC and says 6 we think we are ready to restart, once we go 7 through the significant team inspection that Mr. 8 Cellins indicated, we will assess whether we think 9 those plans can be implemented. 10 MR. FORMAN: If I may, the only 11 people that can implement emergency plene would be 12 police and other state and in some cases county
'- 13 officials. Wouldn't you then have to rely on 14 their determination as to whether or not they wers 15 prepared or able to implement the plans?
16 THE CHAIRMAN: I think we are not 17 really prepared to debate the specific aspects, 18 but I think we are comfortable in saying if there 19 is a locality or a state entity which has come to 20 a conclusion, we would be made aware of that and 21 we would review the basis of that conclusion and 22 take that into consideration. 23 MR. FORMAN: Obviously, I was making 24 the question because I know the answer from ( r r- .
85 1 previous meetings. The NRC I think is comfortable 2 in not going along with a state or local 3 determination on the adequacy of the plan. To me, 4 that's just one of two things. Either you assume 5 that the decision by the state and local officials 6 is based purely on politics or you assume that you 7 have better knowledge and expertise in the area of 8 emergency planning and their ability to implement 9 that. I don't know if you want to answer which 10 one is the case, whether it's A or S. 11 THE CHAIRMAN: If your expressing the 12 question and answer, I'll let that stand. 13 However, it's your answe.r. 14 MR. FORMAN: That's a good response, 15 and I think you know what my response to that 16 would be. 17 The health monitoring issue. The NRC 18 comments that I heard tonight argued that from the 19 many years of studies you have not been able to 20 find any conclusive link to health problems, 21 higher cancer rates, around nuclear plants in 22 relation to those plants. However, there have 23 been some studies that do show reason for serious 24 concern and questions. In this area you do have [
86 8 1 some studies which I don't think are all 2 conclusive on the cancer rates. I am told there 3 are studies of plants in England that suggest a 4 stronger tie between cancer rates and nuclear 5 plants on the coast. I was wondering if you are 6 prepared to refute those things. Obviously you 7 are not prepared tonight, but at some point are 8 you prepared to refute those studies? 9 DR. BELLAMY: I would like to address 10 it now. I'm very familiar with that studies that 11 were done in England. You will find the results 12 of those studies show that there is a less cancer
'- 13 rate around nuclear power plants in England than 14 there would be if those plants were not there.
15 MR. FORMAN: Thank you. That's at 16 least a direct challenge to those studies. I 17 think that's useful. I think it would be useful 18 at some other time to have a fuller meeting on 19 that issue, which brings as to my last question, 20 and that is on the containment issue itself and 21 the Mark 1. . 22 Agaan, I heard some presentation on the 23 Mark 1 issue, but it really didn't answer some of ( 24 the questions that had bsen raised by NRC , W m w-- ,p. , -w-- - - - , - -
~ .
87 1 officials in the past, and that is the-likelihood 2 of failure by Mark 1 and the fundamental t' . a w s in 3 that. Are you prepared at some point to directly 4 refute the suggestion that there is a ninety 5 percent likelihood off a breach if there were a 6 core melt or are ycu going to wait for some 7 study? Clearly, the NRC must be taking those 8 concerns seriously. They would not be engaged in 9 to the long extent they are. 10 I'm curious as to what that study is g'oing 11 to recommend. We heard figures there is a 12 possibility of anywhere from ten to ninety percent , f 13 breach in the event of a core melt. Does the NRC 14 have a goal, a percentage goal, that would be 15 acceptable breach failure level if there were a 16 core melt? Is ten percent considered acceptab.le? 17 Is twenty percent considered accoptable and will 18 the summer report be able to identify what the 19 percentage likelihood is in the breach? , 20 THE CHAIRMAN: I think I'll let Mr. 21 Gutierrez answer that. I think before that i~t 22 it's important to note we have not, I think I l 23 heard you say, contradicted NRC documentation. I ( 24 think it was acknowledged in Mr. Boger's l I 1
88 ' 1 presentation that the probability of severe 2 accidents resulting in the potential containment 3 rupture was from ten to ninety percent. That was 4 put in the context within the study itself. So 4 5 that information does exist within the NRC 6 research study which is one of the opinions that 7 the available to overall accident policy and 8 review. 9 MR. FORMAN: I believe that was the 10 NRC statement. I believe -- I may be ' incorrect -- 11 that NRC officials who since left the agency have 12 made projections on the their own which would be b- 13 outside the NRC documents. 14 THE CHAIRMAN: Can you be more 15 specific in who and where and what they are? Asselstlne 16 FLOOR: Jim H 201 tine. Commissioner 17 (% e l st'in t. _ezeitine 18 THE CHAIRMAN: Can you give me the 19 ' specific issue you're referring to? I understand Asselstine 20 Commissioner H:: ltir.: has many views. Most of l 21 them are common knowledge. 22 FLOOR: It was Denton. 23 THE CHAIRMAN: I understand the 24 names. I'm trying to get the issue. {
89 1 FLOOR: Mr. Denton's charges were not 2 put in an official document, but' a U.S. and NRC 3 official who without a formal NRC report suggested 4 it was a ninety percent breach failure. 5 THE CHAIRMAN: I think you will find 6 he was referencing the study which was completed 7 by research, but if you can bring me the specifics 8 of that statement I will be glad to respond to 9 that. 10 MR. FORMAN: If you can get to the 11 question that I had. Is there a percentage breach 12 failure rate that you find acceptable and will the 13 summer report be able to pinpoint with any 14 accuracy better than ten to ninety percent ot the 15 likelihood failure of a breach? 16 MR. BOGER: Any time you have a range 17 of possibilities of ten to ninety percent, that 18 shows there's a lot of uncertainty in that 1 l 19 decision, and that's why we are doing a lot of l l l 20 studies. You can't say it's at the ninety percent i 21 or the ten percent end. Even when you dook at the 22 ten to ninety percent, that doesn't constitute i 23 t o t a .1 containment failure. It may be any breach 24 failure. It may be a big failure in containment. { l
. . _ . . . _ _ ~ . _ _ _ _ _ _ . . _ _ _ _.
1 90 1 So even within the range of ten to ninety percent 2 we're talking about a range of failures. 3 When the Commission assesses the risk to 4 the public they have to consider not only the risk 5 of the failure, probability of failure 6 containment, but they also have to consider the 7 probability of the accident that leads to such a 8 failure. Right now the probability of the 9 accident that leads to such a containment failure 10 is very low probability. We also have to consider 11 that the nature of the failure, even when the 12 containment fails, that it provides some
'- 13 protection beyond that. You also have to consider s
14 the environmental conditions and tomography of the 15 area, 16 So it's all on a big, encompassing 17 decision. It's not just one part. So I can't say 18 there's a twenty-five or fifty percent number that 19 we would would be willing to live with in the 20 severe accident realm with respect to containment 21 failure. 22 MR. FORMAN: Do you expect the summer ' 23 study to try to narrow that down more? 24 MR. BOGER: I think the study that {
91 ( 1 will come out is looking at potential 2 modifications to the Mark 1 containment that may 3 reduce that risk. I don't think that the study -- 4 the purpose of the study is to come out with a 5 precise number, the one that is due at the end of 6 the summer. 7 THE CHAIRMAN: There are overall hormally 8 safety goals and objectives which are, published in 9 -wermally the Commission's policies towards 10 analysis of events that encompass those goals and Th at 11 objectives statement. 44e4 &her policy which is in l 12 the publjc document;th:t itself had some figures l L_ 13 which references acceptable level of risk. 14 MR. FORMAN: One closing comment to 15 get back to the emergency preparedness to answer 16 my own questions since you accorded me the 17 opportunity. Should the state or the towns in the 18 EPZ determine that the plan is not adequate and 19 the NRC rules otherwise, I would have to argue 20 that that decision is based on the NRC's opinion l ! 21 they know best and that they will be able to l l 22 predict exactly what the state or communities are 23 able to do. ( 24 I'm not always the biggest cheerleader for 1 i
92 1 our state agencies, including the Department of l 2 Public Safety, but it really is the height of l 3 irresponsibility federal agencies to come in and 4 determine what state and local capacity is, what 5 our capabilities'are and then rule that, 6 regard 3eso of what we find in the emergency 7 planning, that we will otherwise be able to carry 8 it out. We are the ones who would have to be 9 doing it and not you as NRC staffers. That 10 troubles me. But it's absolutely absurd to think 11 that the NRC is going to come down or FEMA, for 12 that matter, and rule that, contrary to what those
'- 13 local and state officials say they can do, that we 14 will be able to do differently because you say so 15 based on your regulatory interpretation or your 16 findings in other states with nuclear plants.
17 That's very troubicsome. 18 So I think that issue is going to end up in 19 court because I have no doubt that the state wo,n't l 20 approve the plans and the NRC will ultimately try 21 to overrule the state so Me are going'to be left 22 with a court deciding this. I'm not sure the 23 judge is in the greatest position to rule on ( 24 aither adequacy of the emergency preparedness. I l l
93 1 think you make a great mistake is not offering 2 some assurance that you will follow, mimic what 3 the state officials rule on emergency planning i 4 because you are not going to be the ones here 5 directing traffic. 6 THE CHAIRMAN: I acknowledge that 7 comment. I think it's unfortunate that you have 8 come to a pre-determined conclusion which you have 9 just expressed and also have determined what the 10 NRC's response to that will be. I think t h a t s 11 totally conjecture. I think it's probably 32 inappropriate for you to do that. We will have to L_ 13 wait and see. Our role is to assess what actually 14 happens. I would hope that the state and the 15 state representatives will make a determination 16 when the time is right. 17 MR. FORMAN: I will be glad to 18 apologize for my predisposition to determine to 19 the two C o mmi s s i o r.e r s that came down and toured i 20 the plant and determined they were ready for l 21 restart before the plant hearings. e 22 FLOOR: Can I make a statement? l 23 THE CHAIRMAN: Yes. ( 24 MR. RICHARD FAY: I'm Dick Fay from
94 1 the NRC. The gentleman's comments about emergency 2 planning, in February, 1987, there was a public 3 meeting in which, among the participants were 4 Senator Kennedy, Senator Kerry, but the principal 5 one ' Governor Dukakis. Now insofar as the 6 state's role is concerned, there are twenty-seven 7 states that are agreement states. Why doesn't 8 Massachusetts become an agreement state? 9 FLOOR: What does that mean? 10 THE CHAIRMAN: I would like to 11 indicate, I guess, for the record that the 12 statements that the Commissioners --
'- 13 FLOCR: Would you repeat the 14 statement?
15 THE CHAIRMAN: I'll have it read 16 back. 17 That the statement that the Commissioners 18 made was based solely on the technical review of 19 the plant and they did not take into consideration l 20 emergency preparedness aspects. They were not 21 briefed on the emergency preparedness other than 22 being introduced to the individual and to BECO's 23 perception of the status of those. And the 24 Commission itself has said that, as Mr. Bellamy {
95 i 1 indicated in his testimony, that the emergency 2 preparedness issue still needs to be addressed. 3 I have Alba Thompson, please. 4 FLOOR: Could you repeat what was l 5 said -- 6 THE CHAIRMAN: For the sake of 7 timeliness, if we can proceed to the next 8 speaker. 9 FLOOR: I hear other people asking 10 for the same thing. 11 THE CHAIRMAN: I would suggest that 12 Mr. Fay, if you would make yourself available in t
'- 13 the back of the room, perhaps, you could explain 14 your statement to the individuals.
15 MS. ALBA THOMPSON: I'm Alba 16 Thumpson. I'm Chairman of the Plymouth Board of l 17 Selectmen. I want to start by saying I personally l I let.ture l 18 do not appreciate the 1:::en that our State 19 Representative just got from you, Mr. Collins, and 20 I consider it discourteous. (Applause) i l 23 Now returning to the matter at hand, and I l 22 referring to the Regional Counsel's statement 23 which had to do with the adjudicatory hearing, 24 it's aJmost a first for me to hear a lawyer attack ( l i
! i 96 l > 1 an adjudicatory hearing. I understand that the 2 NRC is not required to give an adjudicatory 3 hearing. However, it is the wish of this state 4 and many of the citizens of the state, and while 5 you posed all the problems, we may be dumb, but we 6 are too dumb to use the adjudicatory hearing. So 7 I would say that inspite of the fact that there 8 are difficulties in it, if in his wisdom the 9 Governor of this state and many others have asked 10 for it, inspite of its difficulties and since it 11 is indeed an expression of the people of this 12 state, it ought to be granted. '- 13 For Speaker Number 2 who was Dr. Bellamy 14 who spoke of FEMA and of the basic question as you 15 posed, it I believe it was, are state and local 16 plans adequate, referring to emergency plans. And 17 you spoke of a technical review being made by l
18 FEMA. That is a review of drafts not approved at 19 the local level or by the state. Not a final 20 plan. You spoke about the draft plan of the i 21 Commonwealth as nearing completion. That is not 22 true and cannot be true because the Town of l 23 Plymouth does not have a plan which has been l 24 approved by the Selectmen and is a long away from ( l
97 8 1 having one, so how can the state have given you
, ~2 that impression when it does not have 11 from 3 Plymouth and I do not think from neighboring 4 communities, an approved draft, let alone a final 5 copy. We have just done two implementing 6 procedures. I think we have seventy-eight to go.
7 That's a long way from being an approved plan 8 nearing completion. So if you are speaking about 9 the public health and the safety can be protected, 10 those were your words, I'm here to tell you 1.n the 11 Town of Plymouth at this stage of our game they 12 cannot be protected. I assume you will uphold L_ 13 both of those characteristics. 14 Also, in reference to the cancer studies, 15 there is no evidence on either side of that. It 16 is indeed premature befc.re the National Institutes 17 of Health had made a definitive study to indicate 16 that in the rather astounding statement that 19 around some of the nuclear plants in Great Britain 20 that there is less cancer.than in other places.
- d 21 That's a rather unscientific statement. .g; (I would 22 suggest that something is being killed. You'd i
23 better find out what. l l 24 The Mark I containment referred to by [ _. -- - _ _ - . . __ _ _ , _ . . ~ , , . . _ . . . . . _ _ _ _ . . - _ . - - _ . -
98 4 i 1 Speaker Number 3, there was that dichotomy or at 2 least a strange kind of juxtaposition when you 3 spoke of the fact that the Reed Report did not 4 -raise any new issues not known to the NRC and then 5 you immediately s' aid it is still being studied. 6 If it raised no new issues, why are you still 7 studying it after all of these years? After all, 8 it dates back to 1975, somewhere in there. 9 For management, in my statement to you made 10 in February, one of my comments was, and I presume 11 you meant to answer it tonight, but I find no 22 answer to it, I spoke about overload on the t 13 Vice-president - Nuclear. There were so many 14 people reporting to him as though somehow or other 15 in some marvelous form he could be responsible for 16 this complete turn around. I said is there 17 overload on the Vice-president. I didn't hear 18 that being answered. 19 I also spoke to the fact that there was. 20 tremendous restructuring of organization and many, 21 many men appointed to new top positions. I 22 pointed to the fact that not any'of them have ever 23 operated Pilgrim. They have not been in any ( 24 operational phase. What does this mean in terms
~ 99 l l I ( 1 of restart when all of this personnel who have 1 2 been here at a time of shutdown now become 3 operational? ' 4 The statements of the two NRC 5 Commissioners, as our State Representative, Mr. 6 Forman indicated, were very disturbing, if they 7 were correctly reflected in the press. In the ; I 8 Army we always had a fine phrase. We said, "If it , 9 doesn't move, eat it." But the Navy also says, 10 "If it doesn't move, paint it." And that P11' grim Il plant has a lot of white paint. But I want to 12 tell you, as you must know, that cleanliness is L~ 13 not next to godliness in a nuclear plant at all. 14 There's something far more effective here that has 15 to be studied. 16 I wish I could tell you -- I know you are 17 men of good will and I know it must be a drain on 18 you to come so often here. I wish the people of 19 this community could feel that somehow or another l 20 the concerns we raise, both technical and r . 21 emotional, are reflected to the commissioners.
- t. . ,
22 I'm afraid the filtering process is such that we 23 do not feel any confidence that the five NRC l ( 24 Commissioners really know what our concerns are. l t l 1
100 i i I wish I could say to you I am glad that you came, 2 I'm glad you made comments and that you are here. 3 It has been a long, long road and, once again, all 4 of the people here have to place their trust in 5 the NRC, and the past history is one that does not 6 lead us to confidence. 7 You must be particularly careful, as Mr. 6 Forman again pointed out, that you do not 9 substitute the decision of those who are sitting 30 anywhere, either in King of Prussia or Washington, 11 for the local and state authorities who have to 12 make it work in the event there's an incident or L- 13 accident at the Pilgrim Nuclear Station. We are l 14 in the best position to know what we can do and t 15 what we can't do, and we have the authority by law
- 16 in the public safety area to order things to be l
17 done and you do not. So we are, indeed, headed l 18 for a donnybrook, and we hope that the courts will 19 be merciful on us all. (Applause) . 20 THE CHAIRMAN: The next speaker is 21 Senator Kirby. 22 SENATOR KIRBY: Good evening. I 23 would like to join those who -- I think all the ( 24 speakers have -- have commended you for coming l I
101 ) i 1 here tonight and addressing the concerns that have 2 been raised. Knowing that you are all 3 professional people, lawyers and engineers, 4 particularly I think most of the engineering, I 5 think it's understandable why it is that your 6 comments are not going to be Oscar winners. I 7 don't know of any engineers who can express 8 themselves in a very cogent way that is easily 9 understood. Perhaps, that's a course that should 10 be offered at MIT, Northeastern and some of the 11 other engineering universities. 12 But I would like to distinguish myself from L_ 13 those who say that the NRC is necessarily in bed 14 with the nuclear industry. I know that the NRC 15 has been critical in the past of Boston Edison 16 Company, has assessed some of the highest fines 17 that have ever been assessed by the agency on 18 Boston Edison Company, and I think that ought to 19 be taken into consideration by those who are 20 concerned about the'sincerety of the NRC, 21 concerned about the effectiveness of the public as 22 a regulatory agency. I think it's terribly 23 unfortunate when public officials say things such ( 24 as that the NRC is in bed with the nuclear I
l 1 102 ' 1 industry. It's not going to advance the cause of 2 reaching the truth that has been sought around l 3 here for a couple of years, and I believe that in ' 4 many, many instances public statements have been 5 made which have had the offect of chasing the 6 rabbits rather than Jo11owing the real issues that 7 have been presented and can-be found in this 8 situation. 9 Just for an example, I would like to point 10 out that about a year ago there were hearings at 11 the State House, and cancer figures were brought 12 from the Cancer Registry for a period up to 1985 13 which indicated an increace in leukemia for adult 14 males in five towns near this plant. That 15 increase has been described. In fact, the overall 16 number of figures involved have been described, 17 and I think without any challenge, as being 18 statistically insignificant. That is to say, it's 19 impossible to tell from that number of cases 20 whether or not there is a real causative factor at 21 work bringing about that increase in leukemia ~for 22 adult males. 23 Last week Dr. Protrow-Stith, the i 24 Commissioner of Public Health for the Commonwealth
203 1 of Massachusetts, stated these figures to 1985, 2 the latest figures available from the Cancer 3 Registry. As a result of her statements that some 4 seventy plus percent of males, more than would be 5 expected, had leukemia in the five-tnwn region 6 there weres headlines in the newspaper indicating, 7 and that was in both the dailies that are i 8 published in the region, indicating that new 9 figures indicated further e.vidence of leukemia 10 having been found near the Pilgrim Plant, causing 11 people to be extremely worried, more people to 12 conclude that this issue had been determined and L_ 13 that, perhaps, that Pilgrim should never open 14 again because of the leukemia question. 15 But, in fact, those updated figures 16 actually decreased the amount of increased numbers 17 of leukemia cases. In other words, there were 18 fewer cases in 1985 than there had been in the 19 years up to 1985, including 1984. I think that's 20 just one example of how di.fficult it is for people 21 to communicate adequately about this subject. 22 There have been people talking past each 23 other here for two years. Some have gotten up, ( 24 such as people who come from the western part of
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104 1 1 the state, advocating we no longer have any 2 generation of nuclear waste in the Commonwealth of 3 Massachusetts, people who have a referendum on the 4 ballot. They came to hearings in the past, 5 hearings in this' town, and have cade statements 6 which were artfully arranged to have a maximum 7 negative effect. 8 I say that it's time for people to make 9 greater effort to understand each other, a greater lo effort to unders'tand one of the real issues here. 11 We have to get beyond the point where someone can 12 write an article which says that the public has 13 been misled concerning the containment of the 14 Chernobyl Plant which did blow up, and we know the 15 results of that tragedy. Nevertholess, the 16 distinction between that kind of plant and the 17 Pilgrim Plant have been glossed over in the press 18 and ignored by a good many people to the point 19 where someone recently, as I indicated a moment 20 ago, wrote an article that indicated, that said, 21 that the Chernobyl Plant did have a containment 22 similar to the ones which exist in this country 23 wher, in fact, every engineer that studied that ( 24 situstion, every expert or every amateur who has
+
100 1 1 gone to Russia and the other plants at Chernobyl, 2 have found there was no containment whatsoever 3 similar to that which is present in every nuclear 4 facility providing commercial generation of power 5 in this country.. That's the kind of 6 misunderstanding that we've got to deal with. 7 Now I think it's incumbent upon NRC to make 8 a greater effort to communicate more effectively. 9 The gentlemen tonight have spoken at length. You 10 have spoken from prepared notes. But, frankly, $t 11 was all very difficult to follow. If one attempts 12 to read the various things which are put out, the L- 13 varioue SALP reports, the incident reports, the i 14 weekly reports, all of the reports that are issued l 15 by the Nuclear Regulatory Commission, it is a very 16 difficult process, very hard for anyone to 17 conclude anything from, and that's reflected, as I 18 say, in what has happened here tonight. I think l 1 19 that you do need some kind of source in explaining 20 what you're getting at. l l 21 For instance, I still have a que tion 9 .4 22 concerning the containment. Every time you 23 gentlemen speak and engineers speak about the ( 24 containment problem, you talk about the design
106
- 1 basis, yet nobody has explained yet what the 2 design basis means, nobody has commented on the 3 adequacy of the design basis. Nobody has 4 indicated whether or not there may be difficulties 5 which are really possible, risks which are 6 substantial which are beyond the design phases and 7 which, therefore, have not been answered in the 8 design of the plant. It may well be none of those 9 things exist, but this kind of thing has never 10 been addressed by anybody I have heard as an 11 expert describing this situation and describing 12 the Pilgrim Nuclear Facility.
13 I would like to say to you that, yes, the 14 Commissioners have to examine everything at the 15 plant, they have to make a determination whether 16 management is now ready to operate the plant in a 17 trustworthy fashion, but that cannot be the end of 18 the examination of the situation. I believe that 19 before reopening the plant we have to give full, 20 response plans. 21 I have to fault the commonuealth of 22 Hassachusetts in its efforts in this direction. I 23 believe there has been insufficient effort put in ( 24 by the administration to see to it that sufficient
107 ( 1 funds are appropriated so that the civil Defense l 2 Agency which has been given this responsibility by ; i 3 the Commonwealth can really do their job. There 1 4 has been insufficient effort on the part of the 5 administration and the leadership of the general 6 court to see to it that the cost of all of this is 7 assessed on the utilities, as it should be. 8 I believe the state should have in place a 9 much better radioactivity monitoring system, 10 giving constant readings and automatically 11 recording them so that from moment to moment you 12 know what emanates from the plant. Not that I L- 13 know there has been a great deal of harmful 14 radiation emanated, although there may have been. 15 But, nevertheless, the public deserves and 16 requires being assured that there have not been 17 and there will not be in the future. I believe 18 also that the cost of all that, too, should be 19 assessed on the utility. - 20 To go back to my own backround as a lawyer, j 21 some thirty years ago as a young lawyer starting 1 22 out I represented a pig farmer who was concerned 23 because his particular facility was under attack 24 after people had moved in. This pig farm was ( l l
108 l l (- 1 there first. But, you know, the law in 2 Massachusetts is very good on the, subject. It I 3 indicate = that if you have a pig farm and your 4 neighbor moves in, that even though your pig farm 5 was there first, if your farm is a nuisance to 6 these new neighbors, it has to go. In fact, that 7 happened in this very town of Plymouth where the 8 County of Plymouth had to its facility at the 9 County House of Correction and which was shut down 10 by the County Commissioners during my term as a 11 member of that body because new development had 12 moved in beside the pig farm, and it was a 13 nuisance to the new neighbor. 14 I would say on the other side that a l 15 nuclear generating facility, while it may have 16 some of the characteristics of a nuisance to the l 17 neighbors is something a little higher in th 18 order of need. But we have a need for the power l 19 that could be generated by Pilgrim, but the Town l 20 of Plymouth has a need for its tax base to be 1 21 maintained. And for those reasons we have to'make 22 a comparison of the pig farm very carefully. It 23 isn't as though we could get pork somewhere else. 24 There are really serious needs for generating (
i 109 d 1 capacity. I think it's your responsibility and 2 that of the Nuclear Regulatory Commission to see 3 to ~i t that, if that can be provided safely, that 4 it is done and this is made clear +o the public in . 5 a way that the public can accept. 6 There will always be those in the public 7 who have a complete prejudice against nuclear 8 generating facilities and who want to see all of l 9 them in the nation shut down. I don't think you 10 have to satisfy those people. But there is a 11 large group of people in the population who are l 12 willing to listen, who are very concerned about i 13 the things I have mentioned, the tax base of this ( 14 town and the need for the power, so that our 15 economy can continue to grow in this region and 16 will share in that, if we continue to make 17 multi-billion dollar investments which we then 18 shut down and throw away because it has a harmful , 19 regional effect on the regional economy. 20 But those people are willing to be 21 persuaded, and I tell you it's part of your 22 responsibility to get it across to the public much 23 more fully. It's also part of the responsibility 24 of the Boston Edison Company to do the same ( i I
110 l I ( i thing. I fault them as well as the Nuclear 2 hegulatory Commission for failure to make that l 3 point. 4 I really think that pretty much covers what 5 I want to say. I'm sure there are other things 6 that I will think about that I want to say to the 7 Commission. But I do think we should make a 8 greater effort. I don't think you ahould leave it 9 at j ust providing a transcript of the remarks that 10 you have given of your prepared remarks tonight. 11 You ought to make a very strong effort to say 12 things or put points across in ways that are not i
'- 13 bureaucratic, that are not going to leave people 14 wondering what you meant, such as the statement 15 that was made here by Mr. Fay, one in '.hich he 16 probably had a very strong point, whatever it was, 17 but he's talking the kind of jargen that the 28 people have never heard before. Whatever the 19 point was that he had to make was completely lost 20 on people here. Much of what you have said has 21 been lost.
22 Lastly, I would like to say, and I know 23 Peter Forman needs no defense, and I realize 1 24 anyone can get their anger up a little bit and l
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228 i 1 overreact. Certainly, that happened here ! l 2 tonight. It's unfortunate when it does happen. I j i 3 think that each of you has to look at your own j 4 soul to determine whether you are preparing and 5 delivering prope.r statements. But I think, too, 6 that the people listening to you ought to make as 7 great an effort as they can to understand what it l 8 is that you are trying to say because there is 9 something to be lost here. This plant may not 10 open. Many of us have made a very strong c a s'e and j 11 taken a strong position that it should not open if 12 the plans for emergency response are not carried i L- 13 out. If that isn't done, the plant will not open, 14 in my view, and there will be something lost. 15 I think great effort has to be put in by 16 everybody involved in this issue. Setting aside 17 those that have already made up their minds as 18 anti-nuclear advocates, those who want to overlook 19 the other ecological harms that come from other 20 kinds of generating plants. 21 I think I'll just close by saying that 22 there is great risk to our ecology, not only from 23 radiation, but also from the great building ( 24 amounts of carbon dioxide that continually go into m.
182 ( 1 our atmosphere from fossil generating plants or 2 anything else that burns anything. It's not only 3 carbon dioxide, but mutants such.as nitrous oxide 4 and acid rain which comes from burning sulfur. 5 But the biggest threat in the long_run that comes 6 from fossil generated plants is carbon dioxide 7 that is accelerating the buildup, the greenhouse 8 buildup which is causing, according to authorities 9 at Woods Hole, a rise in the sea level in this 10 decade of one inch. Every ten years an inch more 11 of water covers the entire surface of the face of 12 the earth which are vast, which are some t
'- 13 three-quarters of the surface of our planet, and 14 that has tremendous in it implications for 15 everybody.
16 So we can't say let's go back to burning 17 coal, let's burn nice clean natural gas. We can't 18 simply say that nuclear energy is the only 19 bogeyman involved in the field of generating .
- 20 power. It's your responsibility, just as it is 21 mine, to see to it that the public understands the 22 entire range of issues which face us when we 23 consider this question of generating facilities in
( 24 our neighborhood. I don't think the answers are
113 1 there that are clearly laid out as yet. Maybe 2 they're not even available as yet. It's your job 3 to make them ele ?, if you can. (Applause) 4 THE CHAIRMAN: The next speaker is 5 David Quaid. 6 MR. DAVID L. QUAID: My remarks 7 really address Mr. Bellamy, but I would like to 8 read -- the last time I was hare a read from a 9 letter that I wrote to the Chairman, Mr. Zack. I 20 got a reply from Thomas Murley, and one of the 11 questions I asked him about was the evacuation of 12 the beaches in the area down wind of the plant L_ 13 during the summer months. The reply to that was 14 in September, 1986, because of the information 15 received from local officials, Commonwealth of 16 Massachusetts and other interested parties, FEMA 17 began to self-initiate review of -- 18 THE CHAIRMAN: Sir, could you slow 19 down for the Stenographer 7 Instead of reading. 20 that, if you want to give us a copy. . 21 MR. QUAID: I'm interested that 22 people hear the discussion, 23 On August 6, 1987, FEMA gave NRC a report ( 24 on its findings, The report listed six specific
114 1 1 areas of concern in Massachusetts, emergency l 2 planning for Pilgrim ten-mile Emergency Planning 3 Zone. These areas of concern include the lack of 4 adequate information concerning the evacuation 5 measures for beach population. FEMA requested the 6 following additional information from the 7 Commonwealth. One, updated geographical 8 description of the beach area; two,. detailed 9 analysis of the beach population, including the 10 number of permanent and temporary residents and 11 the number of day visitors together with a 12 geographical dispersement; three, an updated E 13 estimate for length of time it will take to 14 evacuate the beach population; four, a liet of 15 suitable buildings available for sheltering the 16 beach population at each beach, including the 17 capacity of these buildings and distance of each 18 beach. l 19 I provided Mr. Bellamy with the very l I 20 accurate facts that 5,268 vehicle permits were 21 issued by the Town of Duxbury for that area. 'That 22 there are twenty-five hundred parking areas at 23 what is call the public beach just north of the 24 conservation area, and recently I is discovered ( ( - 1
315 i i that there are four thousand more permits issued 2 by Marshfield and the towns further north. 3 obviously, people don't come, you know, one in 4 each aucomobile, so right there you're discussing 5 at least ten thousand people on a good summer 6 weekend on a very small area of, I would say, 7 seven miles of beach. In addition, there are at 8 Icast four hundred vehicles that are not accounted 9 for. 10 On March loth -- I was very grateful 11 because my only purpose was in a way to show the. 12 NRC the true problem they're facing because they i l I L~ ! 13 said there is no problem and you can shelter all 14 those people. I think I showed to Dr. Bellamy l 15 that in four and a half miles of beach there is 1 16 not a single building or a tree and there are only 1 17 three narrow crossovers, soft sand, to evacuate 18 that beach population. After the ride I'm s.re 19 Dr. Bellamy will be interested to know they ran a 20 grader over the beach. I t.' s a much nicer drive. 21 What I would be really interested in, Dr. l 22 Bellamy, is, first of all, has FEMA come up with a l 23 revaluation -- has FEMA come up with an evacuation a 24 plan for that area? It's very serio a. ?. - . - _. . . . -
226 1 DR. BELLAMY: First of all, let me
- 2 say, yes, that was an excellent tour of that beach 3 that day, and I did appreciate you giving me an 4 exceIIent first hand feeling for the difficulties 5 that there exist'in emergency planning from the 6 Duxbury Beach, no question about it. I think you 7 mischaracterized the situation when you asked the 8 question has FEMA come up with a plan for 9 evacuation. It's not FEMA's responsibility to do 10 that. It's not the NRC's responsibility to do
. 11 that, you have heard two public officials tell 12 you they are responsible for the emergency
'- 13 preparedness in that area. The Commonwealth of 14 Massachusetts and the local municipalities are the 15 people responsible for generating the emergency 16 plans in that area. Those are the people that you 17 should take these concerns to.
16 MR. QUAID: I have already. In fact, 19 I brought the representative of the State Civil 20 Defense organization, and.I brought out a member 21 of the Public Safety Commission after I' brought
+
22 you out. But there is also, and this also 23 reinforces what you say, something else. Thomas 24 Butridge concluded with this. He says, "Let me {
117
? I assure you that the NRC will not permit the j il 2 Pilgrim Plant to resume operatic.9 until we 3 determine that Pilgrim can be operated safely and 4 that the health and safety of the public can be 5 protected. The determination of whether to 6 restart the Pilgrim Plant will involve 7 consideration of each of the emergency planning 8 issues identified by FEMA. The quality of offsite 9 emergency preparedness will depend heavily on how 10 well the Common ~ wealth of Massachusetts is a b 1'e to 11 correct the deficiencies noted in the FEMA 12 report." Thank you very much. (Applause).
N 13 THE CHAIRMAN: Thank you, sir. 14 The next speaker is James Petros. 15 MR. JAMES PETROS: I have been in 16 Plymouth since 1974 or so. I have worked as an 17 electrical engineer in industry. I want to echo 18 some of the feelings of past speakers in that, 19 while I understood most'of the jargon and material 20 presented here, I was kind of bludgeoned to death 21 by it at one point. I couldn't even keep track of 22 my notes, and certainly once I go home and I try 23 to think back as to what the presentations were, ( 2 <4 unless I can get a copy of the material or maybe
118
! I an audiotape, I'm not going to be able to really 2 make much sense of that because I can't remember 3 that much material, in particular the constant 4 referrals to paragraph numbers and line numbers 5 and so on. I was just overcome with them.
6 I have also taught -- I'm handicapped, and 7 I have also taught and continue to teach children 8 with special needs. I sit on the Commission on 9 Handicapped Affairs. About two years ago I was 10 definitely for the production of power through the il nuclear process. I couldn't even speak for 12 myself. It s's e m s to me that when Senator Kirby L_ 13 referred to other forms of energy being dangerous 14 and causing problems, I think that if you look at 15 the nuclear industry, the potential here is going 16 from producing megawatts to a mega disaster. 17 Therefore, the concerns I think are certainly 18 legitimate, regardless of the information' a person 19 may have or the ability to understand the . 20 technical aspects of it. 21 I have several concerns. That is, I have 12 heard assurance by the board and several people 23 that the plant : ill not go on line unless the ( 24 Commission was assured -- NRC was a9sured that
119 l 4 1 preparedness was all set and evacuation plans were , 2 ready to go and imp 1'aented. I wonder, because, 3 as Mrs. Thompson said, I think there has been a 4 lot of talk that, yes, this is ready, that's 5 ready, and when we look deeply into it we see very 6 little is written, and, in particular, the special 7 plans necessary in order to implement the 8 evacuation of the people with special needs. Here 9 the magnitude is such that many people with 10 special needs require a one-to-one persten 11 breakdown in many cases, one e va c u a t i c, n person 12 necessary for every one special needs person to be L L_ 13 evacuated. 14 I have concerns about training of preparing 15 these people who will be in charge for preparing 16 the evacuation. What's to prevent this 17 professional from saying, the heck with this, I'm 18 going home and getting my family out first and 19 then I'll worry about somebody living over there 20 to get them into a car or get them oui. . I have a 21 lot of concerns even about the non-special needs l l 22 population. I'm sure the planning has taken place l 23 and routing traffic through the town and to the ( 24 evacuation araas. l t _ . ._ --
180 1 1 Personally, I don't think it's_ practical, 2 that it can be practical to do this. There are 3 two concerns also. I think one is this. One is 4 emergency planning. The other concern is what are 5 the chances of something happening that will 6 require this emergency planning. The point 7 becomes moot if there never is an unusual event at 8 Pilgrim in terms of emergency planning. 9 I have thought as I Was sitting here, and I 20 ask for your patience because I wasn't given that il much time to prepare, so my comments will be kind 12 of off the cuff. When Three Mile Island had an f
'- 13 unusual occurrence, did they comply with aal the 14 NRC requirements", Were they in compliance with 15 all issues that NRC required? Were they in 16 compliance with the regulations? Were they in 17 compliance with all the safety features? Or was 18 there some problem here?
19 THE CHAIRMAN: That is when the to accident happened? 21 MR. PETROS: Just prior to'tne l 22 accident. Were they in compliance? , 23 THE CHAIRMAN: They were in
^
i lY ( 24 compliancey3 4He appears when we read the accident l 1
126 , i l 8 1 report that they might have had a system disabled. 2 MR. PETROS: Generally, they were in 3 compliance, and yet we didn't have this disaste* I I i 4 that now can be put down to human error, who j 5 really knows. But we go there, you have all this 6 assurance and listen to what you have done to 7 prepare and what you allow NRC to approve, and yet t 8 the human factor is there. That's one of the 9 emergency aspects of this, and I think that's 10 where the problem is. It is going to be really l 6 11 unable to provide the appropriate evacuation 12 procedures for those people who are not fully I 13 capable of getting out them. I think it's a major 4 portion of Plymouth. So it is my concern. 15 The other aspect is in the past there have 16 been unusual incidents throughout the country and 17 a lot of sites, and they failed to really inform 18 the Commissioners and the appropriate officials in 19 a timely manner this occurred. And I don't have 70 any knowledge at this part'icular time of punitive 21 action taken with respect to tnese plants, even 22 though there were not serious incidents of losses 23 that should have informed the NRC and so on and. ( 24 I think the NRC has failed to follow through in
822 1 1 making sure that this does not occur. 2 I have a sense that should the incident j 3 occur -- In the past few weeks we heard of an 4 incident that occur at Pilgrim which are not of a 5 serious nature, a'nd we know Pilgrim is down, but 6 you hear about somebody pushing s wrong button and 7 starting a pump that is not appropriate, getting a 8 false indication of something because an 9 inappropriate process was used. Training comes 10 in, but you s t i l'1 have a human factor. 11 And again my concern is and my other 12 concern is that there appears to be the perception
'- 13 by a great number of the population, not only in 14 Plymouth, but I think throughout the country, that 15 the NRC tends to favor the nuclear industry. I 16 don't know why they would think this, but this is 17 also my concern, and it's just something that, 18 perhaps, you know, we think of. This is why, 19 perhaps, we have so many people who are against 20 nuclear power.
, 21 In any case, if there had been no incidents 22 in our past history of accidents occurring, and 23 some serious, there is potential for greater ( 24 spread of fire and a melt down. And several years
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l 123 1 ago, like in the southwest where a fire was t 2 started inadvertently and caused all kinds of 3 damage, we hear very little about it. We could 4 find it, but how many of us have time to go to the I 5 libraries and p l .e k out the books? How many of us 6 have time to spend a day looking through those 7 rules and regulations to see exactly what's . 8 happening? 9 That's pretty much what I wanted to say. I 10 did ask the question. I think that Three Mile la Island kind of stands out and says to us, well, in 12 spite of all the planning and in spite of all the L- 13 implementation and safeguards and all that, the 14 chances are there. We used to get numbera like 15 the chances of anything happening are a million to 16 one, something of this nature. I think it has 17 been proven wrong. In most cases it may not be 18 mechanical failure; it may be human failure. I 19 think that there's more of a chance that we have a 20 failure, so we really have to take seriously the l 21 idea that something will eventually happen. We 22 know the plant is very old. And in spite of all 23 of the additions and improvements that have been i 24 made to it, I have some question as to whether it l
124 I 1 would be in operation at this point for its 2 safety. 3 Just one other quick issue. That the 4 storage of increasing radioactive material on site 5 and the method that is used to store it and so 6 on. Obviously, these rods that are highly 7 radioactive are put in a pool. They have already 8 had to go down once and repair the pool. I think 9 that's an increasing danger. Even after the plant 10 shut down, you're going to have a section in la Plymouth that is just not going -- It's just goiag 12 to very rapid waste. I think it's interesting
'- 13 that the insurance companies refuse to really sell 14 insurance for protection against any kind of 15 nuclear incident. I think they know the name of 16 the game and know this is really quite 17 significant.
18 So these remarks, I hope that maybe I have 19 helped speaking about it. Thank you very much.. 20 (Applause), t 11 DR. B$LLAMY: Sir, I would like to 22 address a couple of your concerns, if I could, or 23 try to at least. First off, as Dr. Murley's i 24 letter to Mr. Quaid stated, and I hope you've got
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1 1
1 225 i 6 1 out of my remarks earlier there is no question 2 that the Federal Emergency Management Agency has 3 Identifiad the special needs population and the 4 transportation as an asea requiring improvement, 5 we share that concern. One of the things that I 6 committed that the NRC was going to do was to 7 assure that there was some demonstration that the 8 mobility preparedness in a special needs 9 population could be adequately protected beforp we 10 would allow this p l a r. t to restart. 11 MR. PETROS: Can I make a comment? 12 DR. BELLAMY: Be my guest. L_ 13 MR. PETROS: My comments with respect 14 to this is not very great, and the decisions that 15 the Commissioners make are based upon supposedly
.26 the information they are given. In any case, we 17 all perceive facts in many ways, and I think 18 decisions that are made many times that I have 19 seen in the past are very subjective, and what-20 would be fine to one Commissioner may not be fine 21 to somebody else. The Governor, I think, 22 recognizes this and simply refuses to go through 23 with the charade that it is possible to really I 24 provide a realistic and practical working plan for
r-b 126 1 the special needs people and, in fact, most people 2 in this state because he spent more attention with 3 seabrook which is not in this state, but certainly 4 close by. 5 In fact, one of the items that tends to 6 give me a little less confidence than maybe I
? would have is the fact that in the conflict 8 between our Governor in this state and the NRC, 9 and at that time there was a twenty-mile radius, 10 the NRC simply said, well, we will thin it down to 11 ten miles and, therefore, this issue becomes less 12 important. This is to me, at least, political 13 rather than based on hard fact and science. These 14 are things that create the ability to really have 15 a loss of confidence in the Commission. We see a 16 lot of political decisions made this way. A 17 person will say, well, this is fine. Where, in 16 fact, you know Mrs. Thompson can show you facts 19 that's it's not fine, can make statements. I have 20 heard all of the reports. I still will ask 21 questions because I just don't remember the full 22 segment.
23 DR. BELLAMY: The other thing I would i 24 like to point out is that there have been a large
227 i i number of times in this country where emergency 2 plans have been implemented for natural disasters 3 including fi"es, chemical releases and explosions, 4 and there have been tens of thousands of people 5 evacuated, including special needs and mobility 6 impaired people, in a very timely manner with no 7 injuries or affliction. So it is a fact that 8 there can be generated adequate emergency plans to 9 protect all facets of the public. 10 MR. PETROS: That may be true for 11 part of the case. The other factor is that should 32 there be an occurence of radiation release, this 9 L_ 13 is kind of ongoing, and there may be no effects 14 for a long time, but -- We are still seeing some 15 significant effects of Chernobyl of people who 16 have gotten out. It will be many years before we 17 will know, if we can ever know, the full effects 18 of that disaster. I'm not saying that could 19 happen here. Maybe it could. That, indeed, I l 20 agree with you. 21 But these are our concerns. They are not 22 based on scientific matters. They're based on 23 information that's available to the average guy. ( 24 I read a lot on it, and, just truthfully, my l l
828
' 1 personal feeling is that politics intrude into 2 these areas. Maybe not specifically with the 3 people sitting in front of me, but where it 4 counts, and that most of these decisions are 5 tainted with a 1 1't t l e bit of political tainting.
6 That's really what I'm worried about. 7 THE CHAIRMAN: There are two points I e would like to make. One is that the information 9 will be available to the public library 10 transcripts. I think that was your first comment, 11 that you felt you needed the notes, and that will 12 be available for you. The other is your mention 13 of a number of instances where reporting of events 14 did not take place and the Commission was not Do 15 aware. 44 you have any specifics, l~ 16 MR. PETROS: Research requires time, 17 but we hear not that it hadn't been raported, but 18 reported long after. Well, I can remember one in 19 Seabrook where it got jammed. It's an incident, 20 regardless of how innocent or how safe. 21 THE CHAIRMAN: You do understand 22 there are various official levels of reporting. 23 Not every instance or event is -- ( 24 MR. PETROS: I understand that. But
189 ( 1 this is the impression or the perception, that s 2 this has occurred and nothing has been done. In 3 fact, at Three Mile Island I think there was a 4 very critical time before sufficient warning was 5 given. That was the basis of my comment. 6 THE CHAIRMAN: Thank you. 7 State Senator William Golden has asked to 8 address the panel. 9 SENATOR WILLIAM GOLDEN: Thank you 10 very much, Mr. ' Collins. My name is William 11 Golden, State Senator. I represent the Norfolk / 12 Plymouth District in Massachusetts which consists L_ 13 of the towns of Weymouth, Hingham, Hull, Cohasset, 14 Scituate, Marshfield and Duxbury. 15 In trying to decipher what it was that I 16 wanted to convey to you tonight, I thought about 17 the reams of material that we have as elected 18 officials gone through in a very intensive two-19 year period of trying to educate ourselves on the 20 problems that we are confronted with in regard to 21 the Pilgrim Nuclear Power Station, including the 22 range of our responsibilities with regard to that 23 restart. Bay secondly I concluded that it would ( 24 do no good to go through with you in any itemized l
*30 1 n: gced to go through "ith you in eny itemixed 2 fashion either of those issues or to call into 3 question your comments tonight, either written or 4 oral comments. That is beceuse it is apparent te 5 me that we disagree on many of these issues. It C doesn't mean that I'm right. It doesn't mean that 7 you're right. But the disagreement through the 8 past few years has become painfully clear. These 9 sessions are a series of opportunities for us te lo express concerns and for officials of the NRC to
- make statements that I don't find particu:arly 12 responsive to those concerns or particularly L_ 13 en11ghtening with regard to the dispute that 24 exists between our concerns and those concerns 15 expressed by Boston Edison.
26 What I'm here to say tonight is simply 17 this. That disputes throughout the NRC and the 18 country are nothing new. An aroused and 19 enlightened citizenry has often traised questions 20 about the efficacy of their government and has 21 voiced concerns in which government officials have 22 responded with positions of disagreement, with 23 responses that the citizenry did not find 24 particularly enlightening.
=
'832 I What seems to be new here is the continued 2 refusal of the NRC to give us as elected officials 3 and its citizens concerned about the restart of 4 Pilgrim a meaningful forum in which we can address 5 these concerns and attempt to resolve factual and 6 legal disputes that we have raised with regard to 7 the restart of Pilgrim. In fact, an earlier 8 speaker suggested that many people have voiced the 9 opinion that the NRC cannot be trusted as an 10 objective, fair agency that is going to meet the 11 public trust that has been entrusted through the 12 Atomic Energy Act. The speaker said that many u_ 13 people have alleged that the NRC is in bed with 14 the nuclear industry.
15 I think that is the root of the problem 16 tonight. It's not the fact that we dispute facts , 17 of law or that we have a disagreement on that. 18 It's a fact that you as Nuclear Regulatory 19 Commission officials are no longer trusted by us 20 as state and local officials to give us a fair and 21 objective consideration of these questions of' 22 fact, nor do we feel that you have earned the 23 right for us to invest our trust in you as a fair 24 and neutral arbiter of these disputes.
832 1 I am one of those officials, and I'm not 2 ashamed or abashed to state it, to have concluded 3 that this NRC, not you as staff, because I think 4 you as staff have a different role that you play. 5 It's a restricted role. It's a role that 6 empJoyees play for management in many different 7 contexts. But your managers, your Commissioners, 8 I feel are in bed with the nuclear industry in l 9 this country. I will say it again. I believe the 10 NRC is in bed with the nuclear industry and that 11 this charade that we are going through tonight is 12 one example, just one example of many, that has t 13 proven and corroborated to us that not only are we 14 in disagreement, but we have no basis upon which 15 to trust you as officials representing us to be 16 neutral, impartial or
- sir.
17 think the key to this conclusion is that la apparently you as officials do not feel that your is positions that you about to take or have taken in 20 the past are positions, or the positions of Boston 21 Edison Company, that can withstand the public-22 scrutiny that would come from a 2.206 petition, 23 from an effort through an adjudicatory hearing to 24 determine what is fact and what is fancy, what is
133 1 legally correct and what is a mistake of law. I 2 regret that. I think it's a tragic position in 3 which this country finds itself. 4 I think you as employees of the NRC, to the 5 extent you carry out this sham and support it, are 6 doing more to destroy the future of nuclear 7 technology in this country than the clam Shell 8 Alliance or any anti-nuclear group. Because what 9 you're doing is you're proving to the American 10 people tonight, as you have on many other 11 occasions, that the NRC cannot regulate the 12 nuclear industry. You cannot distinguish between b_ 13 a plant that is well managed and one that isn't. 14 You cannot distinguish a physical plant that is 15 safe and one that is not, you cannot distinguish 16 a plant that is safely located and one that is 17 not. And because of that, because of your 18 unwillingness and inability to make that 19 distinction, we as elected officials no longer 20 trust you. It's a sad issue to make. 21 I don't think I can say anything more on 22 the issue here because not only are we in dispute, 23 but I think that you come to this proceeding 24 biased and prejudiced against rational reasoning
l 134 l i l I l i i factual inquiry. I think to the extent that you , i 2 foJ1ow the lead of your commissioners you as 3 public employees, and I say this with regret, but l l 4 I think you as public employees betray the public 5 trust. , 6 I have served at every level of ; 7 government. I have worked at the federal level, 8 state level, county level and local level. I have 9 seen people that in good faith disagree and in 10 good faith disagree violently. I have seen people 11 that intentionally don't pursue the public trust, 12 and in other instances I have seen people such as t L_ 13 yourself who are trying to be good employees 14 tonight and do your job when you're following the 15 Commission that has made it very, very clear to 16 any objective observer is going to get this plant 17 up and going, regardless of the significant 18 problems that it has encountered in its operation 19 and continues to encounter in its management and 20 its physical plant and in its emergency 21 preparedness plan. 22 I call again today, and I don't understand 23 that any explanation has been given as to why 24 there is not going to be an adjudicatory hearing.
239 1 You have not ruled on the' Governor's or the 2 Attorney General's request for adjudicatory 3 hearing, although it has been many months since 4 that request was filed. You have not denied the 5 entire extent of the petition that I have filed o r. 6 behalf of fifty state legislators in July of 7 1986. You have only denied two sections of that 8 three-part request. Those two sections now are 9 before the Circuit Court of Appeals, and I stand 10 as one of the petitioners who appealed that 11 denial. I personally am outraged and 12 disappointed. [_ 13 It's really out of a rage of love for this 14 country and its democratic institutions that I 15 stand before you anf. really express my sadness and 16 disappointment in you as public officials and the 17 Commissioners that you represent in not providing 18 what is clearly the intention of the Congress to 19 allow full opportunity for local and state 20 officials to participate, even though, as you have 21 announced today in your earlier comment, we are 22 the officials that are responsible for the safety 23 of these people. 24 Cne of you, I'm not sure who it was,
136 I
, 1 indicated earlier that you can't be asked to 2 provide the emergency preparedness plans for the I 3 people of this area because that's not your 4 responsibility, you directed that attention to 5 the state and local officials. You have given 6 that responsibility to us, but you don't provide 7 the reciprocal opportunity to have a fair and 8 objective hearing about the concerns that we have 9 encountered in trying to meet that responsibility.
10 That's unfair. It's against the intent of the 11 law, and again I think it's a grave and sad breach 12 of the public trust. Thank you. (Applause) L__ 13 THE CHAIRMAN: Let me try to respond 14 to that. I think Mr. Gutierrez probably has some 15 thoughts also. There are a couple of points I 16 would like to make. I presume you had the benefit 17 of the presentations tonight. 18 SENATOR GOLDEN: I listened to most 19 of it on the radio. I did have to speak at 20 another engagement, but thanks to NATD and the 21 miracles of radio, I had a chance to listen. 22 THE CHAIRMAN: Additionally, I think 23 it's a misconception to say that we are following 24 the direct Commission guidance. We are not. I am i 1 1
837 1 the Chairman of this Restart Assessment Panel, and 2 these processes are coordinated by Mr. Boger who 3 is the senior representative from headquarters and 4 myself. I have not received one word of guidance 5 from the Commissioners since I have been on this 6 project which is last fall. 7 SENATOR GOLDEN: Can I ask you very ; I 8 basically? We have talked about this. You have 9 said in that statement you are an independent 10 agent, in effect. 11 THE CHAIRMAN: No. I didn't say 12 that. [__ 13 SLNATOR GOLDEN: You said you 14 received no guidance. 15 THE CHAIRMAN: I said I have received 16 no direct guidance from the Commissioners. I have 17 indicated that this plant is being coordinated by 18 a Restart Assessment Panel. I'm chairman of that ! 19 panel and that process is -- 1 i 20 SENATOR GOLDEN: You have independent j 21 opinion and ability to direct that process? l 22 THE CHAIRMAN: I am the individual 23 who is able to speak for the agency policy, yes. 24 SENATOR GOLDEN: If you're able to
238 , I speak for policy, could you tell me personally, i r. 2 your own judgment, not the judgment of the l
. I 3 Commissioners, your own judgment, whether or not 4 you feel we should have a full and complete 5 adjudicatory hearing, and, if so, if you feel we 6 should, why we haven't had it? If you feel we I
7 should have it, why shouldn't we as local ! 8 officials have that opportunity as set forth in 9 the Atomic Energy Act? 10 THE CHAIRMAN: I can't speak for 11 them. That's not my -- That area is directed 12 toward a different part of the agency, not to be L 13 confused with the technical aspects of the 14 restart. If our reviews and our functions happen 15 to bear on the technical basis for that type of 16 adjudicatory or legal decision, then that's my 17 input. 18 SENATOR GOLDEN: Couldn't you take a 19 position with your commissioners that to complete 20 your job, which you say is your responsibility, 21 and I assume you will take full responsibility for 22 the completeness of that job, that job cannot be 23 completed without the benefit of a full 24 adjudicatory hearing where both sides of these i s
139 1 issues are presented in depth, with l 2 cross-examination, with presentation of 3 documentation, with witnesses? And can't you take 4 that position as an individual that you can't do 5 your job without that kind of information? Could 6 you answer that, please? 7 THE CHAIRMAN: I guess that process 8 -- there is a process technically -- 9 (Several voices talking at the same time.) 10 SENATOR GOLDEN: You haven't got it. 11 That's my point, you have to take responsibility 12 for the failure to give us that opportunity, even '_ 13 if it's not specifically within your bailiwick. 14 THE CHAIRMAN: I think that's an 15 extrapolation of your point. That doesn't really 16 bear on -- 17 SENATOR GOLDEN: Let me interject. 18 MR. GUTIERREZ: I think it's unfair 19 to Mr. Collins. He's not the NRC official making 20 the decision with respect to 2.206. 21 SENATOR GOLDEN: He just said he is. 22 MR. GUTIERREZ: He is the official in 23 charge of making recommendations to the Director 24 of Nuclear Regulations who ultimately makes that
240 1 1 decision. Let me make a more basic point. The 2 more basic point is that the purpose of tonight's 3 meeting, as stated time and time again, was not to 4 debate the merits of the 2.206 petition that has 5 been formally ans.wered by the NRC and, as Senator 6 Golden says, appealed to the First Circuit. The 7 purpose of tonight's meeting was to hear the NRC 8 explain a response to pubide comments on the 9 Boston Edison Restart Plan. 10 Senator Golden, you as a State Senator and 11 a member of this audience tonight, had an 12 opportunity to file a lengthy document, if you [, 13 wanted to, on what you thought the Boston Edison 14 Rectart Plan meant. Other state officials have 15 done it in other proceedings in other states. The 26 purpose of tonight was not to conduct an attack on 17 the members of the Nuclear Regulatory Commission 18 whc appear today. 19 I have been on this Commission for eight 20 yearss I can tell you in eight years I have met 21 technical people such as the panel before you who fu h kiC 22 are people of good will who are publich officials
- pu blit 23 like yourself. And for a fellow pub 11
- h official 24 to stano up in a forum like this and to confront l
t- ___ _ ._ _
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848 l 1 issues of trustworthiness I find irresponsible on (: 2 your par . (Applause) 3 SENATOR GOLDEN: Mr. Gutierrez, first 4 you have defined a purpose for this hearing. That 5 is not our purpose. You have said that the NRC 6 has rejected our 2.205 petition. You are 7 inaccurate. As an attorney I feel that is i l 8 irresponsible. There has -- j 9 MR. GUTIERREZ: I'm sorry. I did not 10 say that. I said the purpose of this hearing.is 11 not to discuss the 2.206 petition. Do you dispute 12 that, sir? (Gutierrez and Golden talking at the same time.) [_ 13 14 SENATOR GOLDEN: If you can get to 15 one point at a time, the transcript will reflect 16 what was said. 17 MR. GUTIERREZ: You said the purpose l 18 of the meeting is to discuss the 2.206 petition. l 19 That's not the purpose of this meeting. 20 SENATOR GOLDEN: I'm not going to 21 confuse the Stenographer by trying to talk over 22 you, but I will make the point again that you just 23 said that the NRC has acted on the 2.206 24 petition. You are wrong. You are inaccurate and l -, .___.
142 1 you are a lawyer. You are working for the NRO. 2 That is part of our problem. The NRC has totally 3 failed to respond to the Attorney General of this 4 Commonwealth and the Governor of this Commonwealth 5 in this petition. There has been no response and 6 there -- 7 MR. GUTIERREZ: There has been a 8 response. 9 SENATOR GOLDEN: There has not been 4 10 an action on that petition. Il MR. GUTIERREZ: There has not been a 12 total response, but there has been a response in [_ 13 part, as there has not been a total response to 14 the petition you filed. 15 SENATOR GOLDEN: That's correct. The 16 action has not oven taken. If notifying 17 petitioners that their petition has been -- notice 18 of receipt of the petition has been put in the 19 federal register is responsiveness, it's not the 20 kind of responsive we are looking for. Again, t 21 think that's irresponsible on your part. The 22 purpose tonight of the NRC was to create a public 23 forum to give the illusion that these people had 24 meaningful participation in this process. My i
843 9 1 purpose in being'here is to respond to that by 2 calling it a sham, that there is an opportunity in 3 the law made by "s.igress that local and state 4 officials do have e -p*ortunity to give ! 5 meaningful participa+2 .. The NRC has chosen not 6 do it, you as members of the NRC have chosen not 7 recommend to the NRC. 8 And, Mr. Collins, I just asked you, dces he 9 have the right to say that he does not have 10 sufficient i nforration because there has been no 11 2.206 petition that he could recommend to the NRC 12 Commissioners that there be a 2.206 hearing. And, g_ 13 if he has that right and has not exercised it, ! 14 find that irresponsible, and that's why I'm here 10 tonight. 16 THE CHAIRMAN: We acknowledge your B 17 comments. Thank you. 18 SENATOR GOLDEN: If there was 19 something else you were going to say. 20 THE C H A IRM All : I don't think it would 21 be helpful. 22 SENATOR GOLDEN: One more response to 23 Mr. Gutierrez. You suggested we'could have filed 24 a lengthy response. I suppose we could al.so have I
, , . _ - - - , , , , , . m -
y
144 I i taken ten, twenty feet of documents and gone down i l 2 to the ocean down here and thrown them in the 3 ocean. And the real perception many, many people 4 in this state today because of the reaction of ; I 5 this NRC Commission during the eight yearn you ! 6 have served on it, I feel that the value of 7 submitting those materials to you tonight would be 8 abou' as valuable as taking them down to Plymouth 9 Bay and throwing them in the bay. That's why : 10 haven't submdtted them, and that's why the 11 Attornev General und the Governor have boycotted 12 these proceedings, because they don't have any
' Thank you L_ 13 trust in any value in participating.
14 very much. (Applause). 15 THE CHAIRMAN: Miss Ann Arnold. 16 MS. ANN ARNOLD: That's a hard act to 17 follow. My name is Ann Arnold. Tonigh* I'm i 18 speaking as a special needs coordinator for We The 19 People. I'm also the chairman of the State 20 Standards on Nuclear Evacuation for the State 21 Office of Pandicapped Affairs, and we represent 22 one million disabled people in Massachusetts. 23 I had a lot of statements and questions to 24 make tonight, but it seems almost useless. I have I
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l l _ -
245 1 heard the whole planning process is flawed because 2 there are no requirements to plan for an accident 3 greater than a class 9 accident which would 4 include a core melt? Is that true? 5 THE CHAIRMAN: That's correct. 6 MS. ARNOLD: So for the most 7 catastrophic accident we could have there are no 8 plans. That is true? 9 THE CHAIRMAN: Could you make that 10 statement again? 11 MS. ARNOLD: I have been told there 12 are no requirements to plan for an accident L 13 greater than a Class 9 accident that would include 14 a core melt. Son of a gun. 15 DR. BELLAMY: I think the answer to 16 yor question is no, that the core melt scenario 17 is considered a Class 9 accident, and Class S 18 accidents are ennsidered part of the emergency 19 planning process. 20 MS. ARNOLD: So your emergency l 21 planning process is to license a plan including i 22 planning for a core melt accident. 23 THE CHAIRMAN: You're l l A[elease? l . 24 driving towards a release. What you need is a
q 146 a d 1 release to have the offsite consequences I think 2 you'"e trying to get to. 3 MS. ARNOLD: What about worst case a 4 scenarios? A breach. Do plans for licensing need 5 to have evacuation plans that would allow the 6 public to safely evacuate during a breach? During 7 a fast-breaking accident? 8 THE CHAIRMAN: If I'm not mistaken. I 9 believe we deal with that in terms of releases. 20 Releasa can be from a planned release as a result 11 of -- 12 MS. ARNOLD: Unplanned release or a [_ 13 breach. 24 DR. BELLAMY: If your que.' tion is is 15 that one of the scenarios that is considered in 26 the spectrum of accidents, the answer is yes. 17 MS. ARNOLD: A breach of 18 containment? 19 DR. BELLAMY: That's the same answer 20 that I gave this audience in this forum on 21 February 18, 1988. 22 MS. ARNOLD: So our evacuation plans 23 are supposed to protect us. 24 DR. BELLAMY: Emergency plans.
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I 147 ; I 1 MS. ARNOLD: Emergency plans are e 2 supposed to protect the Town of Plymouth and the 3 South Shore against a. fast-breaking ecident, that 4 is true, for licensing purposes? 5 DR. BELLAMY: one of the rtatements 6 made earlior, and I'll read it again. It is 7 'mportant to realize that the goal of emergency 8 preparedness is to prepare onsite and offsite 9 personnel and the public for a variety of ways of 10 dealing with nuclear emergencies. It's not 11 appropriate to develop specific plans for every 12 conceivable accident, but to address a spectrum of 13 accidents, to keep in mind the overall objective (__ 14 of providing emergency plans, procedures and 15 training to achieve dose savings for a spectrum of 16 accidents. 17 MS. ARNOLD: What does that mean? 18 DR. BELLAMY: That means that for a 19 specific accident that you could postulate today 20 there may or may not be a specific emergency plan 21 in place which says this is what you do when that T 22 happens. The purpose of emergency propiredness is 23 to prepare people, all affected people, including 24 yourself, including the Board of Selectmen, (
a48 1 including the local municipalities officials, 2 including the Commonwealth officials, including 3 the Regulatory Commission, including the Feceral 4 Emergency Management. Agency, on how do we make 5 those decisions during the course of a developing 6 accident at a nuclear power plant, take into 7 acccunt all of the information that you have at a 8 certain time and what is the best decision that 9 the Commonwealth could make to achieve the 10 greatest dose savings? That's the purpose of the 11 emergency preparedness. It is not to try to 12 achieve a zero dose. It is to achieve the g 13 greatest dose savings. 14 MS. ARNOLD: It's my understanding 16 that really isn't up to the Commonwealth, 16 Licensing is up to you. You have licensed plants 17 all across the country with no plans for people 18 with special needs. How long do you plan to l 19 continue doing that? 20 DR. BELLAMY: I can't address that. l 21 MS. ARNOLD: I'm telling you. The 22 Rowe Plant, Vermont Yankee. Our plans are worse 23 in Seabrook for people with special needs. 24 DR. BELLAMY: I don't think it's
i 149 I worth getting into a comparison of plants to other 2 plants. The Yankee Rowe Plant was fully tested. 3 off hours, unannounced, two weeks ago. 4 MS. ARNOLD: I have gone over the 5 Rowe plants for the State of Massachusetts. Any 6 plans for special needs around the Rowe area are a 7 joke, and I have a feeling that you have done this 8 nationwide and you have discriminated blatantly 9 across this nation with people with special needs, 10 never mind people who are able bodied. I would 11 like to know why you think you can get away with 12 this. I think people are going to get fed up at
'_ 13 some point.
1 g 14 THE CHAIRMAN: Was that 3discrepancy, i 15 was that called up in the Yankee Rowe Plant by the 26 state? 17 MS. ARNOLD: No. 18 DR. BELLAMY: The answer is no. 19 THE CHAIRMAN: Do you know the 20 reason? 21 MS. ARNOLD: You licensed the plant. 22 There were no real plans at that time and before l 23 then to provide emergency plans for people with 24 special needs, but this plant was licensed. Why? ( 1
250 1 THE CHAIRMAN: I believe at the time 2 this plant was licensed emergency prepared was 3 different than it is now. 4 MS. ARNOLD: Not in 1985. This plant 5 was licensed all three years until its voluntary 6 shutdown. How can you allow plants to be licensed 7- and running without plans that include all 8 segments of the population? 9 THE CHAIRMAN: I think you're doing 10 what you need to do. I am not sure anyone has 11 brought that issue to -- 12 MS. ARNOLD: Don't be ridiculous. { 13 How many times have I met with you people in the 14 past four years? I have been talking to you about 15 deafness. This plant still doesn't have an alert 16 system for our detf population. The present 17 regulations, you are supposed to oversee them. 18 Deaf per mle have no way of knowing when alarms go 19 off. Why can't you do your job? I just don't 20 understand. 21 DR. BELLAMY: The issue you are , 22 raising and the concerns we will evaluate prior to l 23 making a restart decision, but we are not the 24 people responsible for correcting those (
153 1 deficiencies, t 2 MS. ARNOLD: You are the people 3 responsible for the final licensing of the plant. 4 At a meeting of the Department of Public Safety, 5 and Mr. Collins was there, and we taped the 6 meeting, Mr. Collins said to me, "Well, Ann, we 7 can go two ways. We can listen to FEMA, an 8 advisory group, or go the other way, do not listen 9 to FEMA, put the plant on line and presume that 10 the state will take their responsibility and make 11 an evacuation plan for y o u .. " 12 THE CHAIRMAN: No. If you have a 13 tape, I would like to see it. {_ 14 MS. ARNOLD: I wi]; send it to you.
- 15 THE CHAIRMAN
- I think the question l
( 16 that was posed to me at that meeting was does the 17 NRC have to abide by the state, and the response 18 to that was, as Mr. Bellamy's testimony indicates, 19 no, final responsibility rests with the NRC. 20 MS. ARNOLD: Exactly. That's my l 21 point. You don't have to take anyone's advice. 22 You told me you don't even have to take FEMA's 23 advice. They're an advisory group. It's up to 24 you whether you want to take their advice or not. l l i l l 1
852 1 You can open this plant without taking their ( 2 advice, without workable evacuation plans as we 3 have had since this plant has been opened. 4 THE CHAIRMAN: I think it was Mr. 5 Bellamy's statement -- 6 MS. ARNOLD: It was your statement. 7 DR. BELLAMY: Let me clarify one 8 thing. I guess I take exception to the 9 implication tnat anybody else's finding, whether lo that be the finding of the Federal Emergenc*/ 11 Management Agency, whether that be the finding of 12 the Plymouth Board of Selectmen, whether that be [_ 13 the finding of the State Senator for this area, 14 that we are not going to serious 1r consider them 15 when we do our review. 16 I personally agonized over findings that l 17 these people give me. You may not believe that, i 18 and I'm sure that Senator Golden does not believe 19 that, but that's a fact. I personally agonized 20 over the comments that are made that say this 21 emergency plan is not workable and that there are 22 not adequate protective measures to move the l 23 transportation dependent and special needs 24 population. I spend many hours agonizing over are I f 1
153 1 there other common saving factors that, say, in i 2 the overall scheme is the state of emergency 3 preparedness around this plant or any other plant 4 in Regian 1 adequate in my technical opinion to 5 protect the public health and safety. But it's 6 not accurate to say that the NRC lgnores, does not 7 consider any of those findings. I know you 8 didn't say that, but I want to say that to set it 9 straight for the record. 10 MS. ARNOLD: I guess I'm saying this 11 is not the only plant where people have been left , 12 out. I have seen many other plants and plan to l 13 see plants nationwide. I'm sure this is the case 14 nationwide. There is a nationwide problem of 15 discrimination. I don't think you gentlemen are 16 doing your job. People are left out in every 17 plan, but you license the plants anyway. I mean, 18 you have no conscience? 19 DR. BELLAMy: Let me try to 20 paraphrase. I'm not sure where you're headed. 21 That if the point you're trying to make is that we 22 have decided, we as a body, that the 23 transportation dependent and the special needs 24 population do not need to be considered in k
154 1 emergency preparedness process, I will tell you 1 2 that is flat wrong. If that's the point, I will 3 tell you we consider those people as well as every 4 other segmen't of the population when we make our 5 determination of reasonable assurance. 6 MS. ARNOLD: While you license the 7 plants. Were the others excluded? Because you 8 have done that and you will probably do that. 9 THE CHAIRMAN: Ann, what I was going 10 to respond to, ! believe that the process you are 11 using for this case is the appropriate process. 12 You bring the issue to the state. The state [ 13 decides on how to go with the plan on that issue. 14 If it becomes a contention during the plans as 15 being inadequately responded to, a valid issue, 16 something, as Ron mentioned we, we assess during 17 the process. Have we done that at other sites? I 18 don't know. If you would give me a specific 19 reference of a site, we can go back and look and 20 give you the reasons why. We are willing to to 21 I that. 22 MS. ARNOLD: I've done this for four 23 years, for myself, recommendations to the state 24 what we should do to really provide for our (
b55 1 elderly and our special needs and young children. 2 Obviously, nothing has come of it, and I really 3 doubt anything will come out of it with the NRC, 4 to be honest with you. 5 THE CHAIRMAN: I think that Ron's 6 statement is some demonstration that -- 7 MS. ARNOLD: I'm not saying to Mr. 8 Bellamy in particular because I know Mr. Bellamy. 9 It seems like we are just faced once again with 20 having to participate in the same kind of dog and 11 pony show meeting that gives us the illusion the 12 public really has some say in their talent. We 13 really have nothing to say. It seems to me the {_ 24 state has nothing to say. It seems to me the NRC 15 makes the final licensing deciuion, whether we 26 think our plan works or not, whether we think our 17 plants are safe or not, whether our legislators l 18 file petitions or not. You make the final 19 decision. ! 20 It seems to me no one in this country 21 really has anything to say about your rules, your i 22 regulations, which you enforce yourselves, but 23 yourselves. It seems almost a waste of time to go 24 through this year after year. I just don't see 1 l l l t
836 l i i 1 hcw we are getting anyplace. Our legislators j
}
2 can't get anyplace with you. How,do you expect , 3 the people to? Why do you let us think or let 4 people think that we might make a difference 5 because we don't make a difference. ; 6 THE CHAIRMAN: I think you can come 7 to whichever conclusion rau think is appropriate 8 as far as the effectiveness and purpose of these 9 meetings, but we -- 10 MS. ARNOLD: Is there any plant in 11 this country where they have evacuation plans that 12 have a final approval, not an interim approval? L 13 DR. BELLAMY: The answer is I wish 14 you would characterize it as emergency plans, and 15 the answer is yes. 16 MS. ARNOLD: Which plants are they? 17 I would like to see a copy. 18 DR. BELLAMY: There's a plant just 19 south of here. And all of the plants in the State 20 of Connecticut have full, final, signed, 21 certified, sealed and delivered approval. - 22 MS. ARNOLD: I would like to request 23 to see a copy of the plans. 24 DR. BELLAMY: I would say have your (
257 '. I 1 state officials contact the Commonwealth -- the 1 2 Connecticut officials. But let me also volunteer 3 to fou please let me know if you have any 4 difficulty in getting those plans. Let me know, 5 and I will assist you. 6 MS. ARNOLD: Thank you, Mr. Bellamy. 7 THE CHAIRMAN: Mr. Stephen Comley. 8 MR. STEPHEN COMLEY: I'm Steve 9 Comley. I'll give you a little of my backround. 10 My family has been in the nursing home profession 11 for over forty years. We have always tried to 12 represent our elders the way we feel they should [_ 13 be, and that includes safety. That's really what 14 got me interested in it from the very beginning in 15 regards to nuclear power. I want to make it 16 perfectly clear I was never against nuclear power, 17 but I feel that I have, like anything I try and 18 do, I try to act very responsible. 19 I think one of the things that I try to do 20 is I spent twenty-five weeks in Washington, met Asselsdi ne 21 with Mr. .9 ; ; c i t i r.a who commented and said we are l 22 going to have a nuclear accident in this country 23 that can happen any day because of the way our 24 plants are being run and the way they have been i
138
-1 constructed. And that kept me pretty interested.
1 2 From there, I have been talking to people inside 3 the NRC, very high level, confidentially, and have 4 some found some things that are very disturbing to 5 me. 6 One is that there is no question 7 whatsoever, and I wish Mr. Kirby was still here 8 because I have a report that I would like very 9 much for him to read and any other responsible 10 elected official. That is, that I don't know if 11 you're familiar with this, but I would like you to 12 answer the question. The question I have is I L 13 have a report here that's entitled Special Report 14 Office of Special Investigation from the United 15 States General Accounting Office and was sent to 16 Honorable Zack, Jr., April 22, 1988. 17 Do you have a copy of that? Are you 18 familiar with that report? Have you read it? 19 Well, to summarize, it really confirms a 20 lot of things people inside the NRC have told me. 21 That has Mr. Hayes, who happens to be the Director 22 of Office Investigations -- I'm sure you're aware 23 of that. He has stated in comments before that 24 Mr. Stello as well as Mr. Roberts has interfered (
i 809 1 1 with investigations that they have tried to make I
?
2 on a number of plants. This certainly shows that 3 and confirms that, and I'm sure this puts you 4 fellows in a very embarrassing position at times, 5 too, because, you know, I sympathize with you. I 6 really think and I know there are good people in 7 the NRC. I know there are. But I also know that 8 there are people that certainly are corrupt, that 9 are not representing the people. They are lo representing t h.e industry. 11 you have all read and seen enough of it to 12 certainly question it in your own minds. That [_ 13 makes it very, very difficult for people like you, 14 and I don't know, you know, but I have to really 15 make a conclusion from what you have been saying 16 here today. That is that you work very hard. And 17 when you do work very hard and when the top men, 18 so-called, like Mr. Stello, like Mr. Roberts, 19 certainly puts on suspect the trust that we are 20 supposed to have in the Commission, I think you 21 have to agree with that. 22 I want to leave a copy of the report with 23 you, but after reading it I have confirmed that 24 the NRC agency is corrupt. There's no question in (
860 1 my mind whatsoever. That's my personnel opinion. 2 This was given to me. And, seriously, this order ; 3 says, "Further release of this document may not be 4 in the best interest of the government for reasons 5 stated in." Now I s.spect it's not in the best 6 benefit of public relations as far as the NRC are 7 concerned, but I do think it's in the best 8 Interest of the public to really know and 9 scrutinize what is in this report. I think they 10 have a right to know. I'm going to leave you a 11 copy, and anyone that is interested in Plymouth or 22 anyone else, it's going to be available in the We
'[_ 13 The People office.
14 THE CHAIRMAN: Excuse me. Wait just 15 a minute. 16 MR. GUTIERREZ: You have offered to 17 give us a copy. I would like to see a copy. 28 THE CHAIRMAN: That is a GAO report? 19 Why don't you go ahead? Mr. Gutierrez will be i . 20 looking at it. 21 MR. COMLEY: When you first started 22 the opening of the meeting I guess we all somewhat 23 got a description in a led lesson. I do think 24 that law lesson should be returned)and maybe that (
161
-( 1 same speech should be given to Mr. Stello, Mr.
2 Roberts and Mr. Zack. Because the bottom line on 3 a lot of things that have been going on for a good 4 many years is at the very least irresponsibility. 5 All of us have got to live in a society that obeys 6 the law. 7 Now this here, this lodine kit, talk about 8 respect again, this is Victor Stello, and, for 9 those of you who don't know, he's the Executive 10 Director on the overall operation of the NRC. He 11 replied to a letter finally pertaining to the 12 special needs individuals, and this is what he 13 says. "For the few individual patients where in 14 the judgment of medical experts prompt evacuation 15 is non-advisable, we believe that shelter is an 16 appropriate protection measure until they can be 17 safely relocated. In some cases, depending on the 18 accident scenario and risk _ factors, it may be 19 appropriate to administer potassium iodine." . 20 That's this. It's to be administered by 21 somebody at a nursing home, hospital, in a home, 22 who is willing to volunteer to do this i n c. 23 nuclear disaster. 1 24 Now I ask you, and I suspect that all of (
262 l 1 you have families or relatives or whatever, you 2 all know people who are incapacitated. I want to 3 ask you, and I ask in my letter further, I think 4 you noticed her daughter over here, do you think 5 -- 6 I would really like him to listen. I think 7 it's very important, but I'll wait until he gets 8 through. 9 THE CHAIRMAN. I'm-sorry. 10 MR. COMLEY: What I wanted to say, if 11 each one of you had a relative or a friend, do you 12 think that's appropriate? Can you respect Mr. I L- 13 Stello's opinion and do you agree with it? We 14 have a right to know that. And I want to say 35 this. I have noticed since we have throughout the 16 hearings I have been to Washington, and the people 17 I have t a .' k e d to inside the NRC, that I get the 18 impression that we are in a wartime because we all 19 know that sometimes our government during war 20 makes people expendable and they accept it. I 21 want you to know that we don't accept that here in 22 America or anyone else. And do you want to know 23 why? It's because in America we are supposed to 24 follow the law. This is against the law because [
863 . l l l 1 it's dit:crimination. 7 hat's agrinst the law. l l 2 That's what a lot of us feel. You've got a stone l 3 wall here because we are not going to accept this 4 because if the NRC -- if Mr. Stello is willing to , 5 administer this to people who need us the most, we 6 think, but they happen to be a lot stronger than 7 we are, he's sadly mistaken. We aren't accepting 8 it. I want to know whether you think this is 9 humane. 10 DR. BELLAMY: z ou asked about 11 thirteen or fourteen questions there. But I will 12 give it my best shot. The answer to some of your f b- 13 questions. I will give you very specific yes or 14 no answers. To the answer to the question of do I 15 support Mr. Stello in this, the answer is yes, I 16 do. To the question do I agree with Mr. Stello, 17 the answer is. yes, I do. 18 The purpose of emergency preparedness, as I 19 have said at least three times tonight, is to 20 achieve the greatest possi.ble dose savings. And 21 there are some accidents where the greatest 22 possible dose savings will be administered by 23 administering to certain people this potassium thyroid 24 iodine which blocks the 'incudibl-) so you will {
164 1 not ingest radioactive lodine instead of trying to 2 transport them through a plume of radioactive 3 material where they may achieve a greater dose. 4 That is a decision that will be made by your state 5 and local officials during that accident. That is 6 not inhumane and it is not discrimination. It's 7 trying to protect these people and every other 8 selected population group to the best of 9 everybody's ability. I maintain it is not 10 discrimination. 1: MR. COMLEy: I disagree with you, 12 sir, but I think we have to go back again. We are
- 13 not wartime here. The NRC really decides whether 14 we continue on with nuclear power in this 15 country. Do you think that's right, sir, given 16 that nuclear power is uneconomical, it's 17 unreliable and it's unsafe and you don't have a 18 solution to the nuclear waste? Yet you, and 19 you're excluding our government officials now --
20 When I say the NRC, you know, you are paid by 21 them, so you have to accept that much. -And I 22 think that it's very -- I ask you a question. If 23 your daughter or your son or relative, do you feel 24 that you're at the point where we need this kind {
160 l 1 1 of unacceptable power in this country that you're
-{
2 going to accept something like that and shouldn't 3 the people, the bottom line, should not the people 4 have the opportunity in America to decide whether 5 they want to continue on with nuclear power or de 6 you think that should remain in a dictatorship 7 role with the NRC? Don't you really believe that 8 we shou 3d have a say? (Applause) 9 MR. GUTIERREZ: Let me eddress that 10 because I think many people feel that the NRC can 11 decide as a matter of policy whether or not we 12 should proceed with a nuclear program in this 13 country. The fact is that under the Atomic Energy 14 Act of 1954 the United States Congress, elected 15 officials, decided that electrical production by 16 nuclear power and peaceful use of nuclear material 17 was in the overall benefit of this country. That 18 was a decision by your elected officials.
- 19 In recognizing there was a risk associated 20 with it, they created an independent regulatory 21 body at that time, the Atomic Energy Commission noW l 22 known as the NRC, not charged with rethinking 23 their decision, but rather charged with given the l
l g 24 fact this is out there, given the fact this Act l l l L
166 I 1 authorizes people to use it, you, the NRC, use it 2 in a safe manner. It's not a dictatorship. 3 I think if the overall public sentiment was 4 sufficiently strong, the appropriate remedy is 5 modification of the Atomic Energy Act through 6 legislation. 7 MR. COMLEY: I'm asking you as fellow 8 citizens, do you feel the American people should 9 have a right to decide whether we continue on with 10 nuclear power, given Three Mile Island and the 11 developed ten-mile radius because of it, not 12 before, and given Chernobyl where it affected our I L- 13 cows in Vermont? And it can happen. Mr. A ssel ti n'n e 14 -F. :citinc seems to think it can. Don't you feel l 15 that the American people deserve the right to 16 decide this issue? l 17 THE CHAIRMAN: I think the answer to l 18 that is yes. I think it has just been expressed 19 the way to do that is through the elected . 20 officials who control the laws. We are an ( j 21 enforcement agency. Our agency is predicated on 22 -- I think a lot of the discussion tonight has 23 been risk oriented. We are a risk-oriented l 24 society. Going out the door and getting in 3 Or g l i
*67
. 1 is what you have determined to be an acceptable 2 risk. Whatever the case may be, we live with 3 that, our laws which are promulgated by the 4 Commission are based on that acceptable risk 5 concept. That exists because of the national 6 policy, energy policy, to include nuclear energy
~
7 technology. The proper way to change that is to 8 change the policy. 9 MR. COMLEY: But you feel that the 10 people have a right to decide this issue and maybe 11 they can do it by pushing Congress and everyone 12 else that way? Is what you're saying? You feel I k- 13 you have that right? 14 THE CHAIRMAN: I don't think there is 15 any doubt in anyone's mind that the people have 16 the right to elect officials who represent their 17 views. 18 MR. COMLEY: Given the way that the 19 NRC have handled elect officials out to New , 20 Hampshire regarding Seabrook and the way they're 21 going to start doing the same +1ng in Mr. s 22 Dukakis' own state, it certainly puts a. question 23 whether you pay attention to him. So, I mean, I g 24 think you have to give that much.
1 168 -( 1 I guess this is more or less -- I guess 2 it's directed to everybody and especially Governor 3 Dukakis. I feel that he certainly has exercised 4 his authority very well as far as it goes in the 5 Seabrook, and I think he has given a lot of 6 dedication. But given him being front runner and 7 our elective process as we have been talking 8 about. I would like to personally request that he 9 come here to the Town of Plymouth himself. 20 We have heard from Mr. Shannon and we have 11 heard from Mr. Kennedy and we have heard from Mr. 12 Kerry. I think that it is Mr. Dukakis' 13 responsibility and his duty for his voice to be 14 heard and his presence to be felt here in 15 Plymouth. Also, if he feels that the Seabrook 16 Nuclear Power Plant cannot be evacuated safely, he 17 has to believe that Plymouth cannot be evacuated 18 safely or any other plant in the United States 19 given Chernobyl. I think it's time that he make 20 this a national issue, not a local issue, even 21 though there are some people that think lt.'s not 22 politically safe at this time. But it's very 23 important that he do that for us and for our 24 future generations.
869
, 1 The last thing I want to say is this. I !;
2 want you -- I would like very much for you to go 3 back and tell the NRC where you were. This is the 4 mother city of America and this is where America , 5 was founded, and we don't have anyplace to go. 6 But I'll tell you here we are here to send a 7 message to all of America because we want the cay 8 in whether we continue on with nuclear power, and 9 we are going to begin here in Plymouth because we 10 owe it to the rect of the people just like the 11 Governor owes across the United States to start 12 telling what he has found out, not wait until he t k- 13 gets in or if he gets in as president. He needs 14 to do it now. We all need to do it now. Not so 15 much for us. For our future generations and for 16 the hope of other natio'ns. This is ludicrous, 17 it's ridiculous, and we all know it. 18 We are responsible people here. We have 19 worked very hard. We have looked into it. We've 20 gotten the facts. It's time for you to stand up 21 for what you want to do right because, if you 22 can't see what's going on, you've got to be blind l 23 and deaf because we have seen it and I have l 24 experienced it and we all have. you may be
870 i i 1 getting tired of what I'm saying, but I'll tell 2 you I'm tired of you not representing the NRC. 3 And I'm saying there's a lot of people that I know 4 that are working to try and expose the agency for 5 what it is. It's time that you joined them S because, if you don't join them, you're on the 7 other side, and there's no room for you because 8 there no fences on this issue, None at all. 9 They're worthless. Either you're for'it or 20 against it, 21 I'll tell you the people of Plymouth tre 12 against it, and we are going to send that message
- 23 across the United States, and you tell them back 24 there that that's what they're up against here.
25 They have a stone wall, and we aren't moving. 16 It's our kids. That's what it's about. (Applause) l 17 you tell that to Mr. Stello and ask him to start l l 18 joining us, too. 19 THE CHAIRMAN: I think you will find 20 that the state was asked to participate in the 21 meeting and declined. My understanding >1s that I 22 the Governor was invited and didn't show. 23 Mr. David Vogler, please. 24 MR. DAVID VOGLER: Good evening. My l I l
171 4 1 name is David Vogler, member of the Board of 2 Selectmen in Duxbury. I realjze the hour is 3 late. I would like to go back. 4 I have a question for Dr. Bellamy that goes 5 back to his presentation around two hours ago. I 6 got the clear impression when you were reviewing 7 the emergency preparedness that FEMA somehow in 8 the final stages of reviewing draft plans 9 i,ubmitted by the state end by the local 10 communities that corrective measures were b e l'n g 1 teken. But oince I am a member of the Board of 22 Selectmen, the Board of Selectmen in Duxbury has t l-- 13 not submitted any approved draft emergency 14 response plan. And as Selectwoman Thompson 15 pointed out, the Plymouth Board of Selectmen has 16 not approved an emergency response plan. My 17 , question is what is it that FEMA is looking at in 18 the2 technical review? 19 DR. BELLAMY: I think it may be a 29 problem with semantics between draft and informal 21 and approved. I did not say at any tiac t ~t t 22 there were any approved plcias submitted to the 23 Commonwealth of Massachusettes or the Federal 24 Emergency Management Agency. I did not imply with { m
178 ( 1 you or Mrs. Thompson or any other Board of 2 Selectmen or the Commonwealth of Massachusetts I 3 ria v e approved any plans and sent those to FEMA. 4 You are aware of a draft plan from the 5 Commonwealth of Massachusette. The Commonwealth 6 of Massachusetts chose to send them to the Federal 7 Emergency Management Agency asking them for a 8 technical review. That technical review has been 9 completed. And that review pointed out 10 deficiencies in those plans, significant holes in 11 those plans. I'm saying the plans were not 12 complete. Those comments have been given back to L- 13 FEMA and the Commonwealth of Massachusetts or I 14 those comments have gotten from FEMA to the 15 Commonwealth of Massachusetts. 16 MR. V0GLER: The draft plan that FEMA 17 is reviewing are the ones that were submitted by 18 Boston Edison. Is that correct? 19 OR. BELLAMY: No. . 20 MR. VOGLER: They were not submitted 21 by the local communities, so who is it-{ hat 22 aubmitted these draft plans? 23 DR. BELLAMY: I think that you will 24 need to check with the Commonwealth of
l 873 i 1 Massachusetts and ask them where they got those 2 plans. 3 MR. VOGLER: Do you know where they 4 got the plans, since this is your area? 5 DR. BELLAMY: It's my understanding 6 those plans were given to the Commonwealth by the 7 local municipalities. And if I'm incorrect, I'll 8 stand up and say I was incorrect. I was not 9 involved in that process. 10 MR. VOGLER: I think it's very 11 important that you know of the origin of these 12 plans, and we would appreciate it being checked to 13 see where those plans came from since two of the 14 five communities indicate they did not submit the 15 plans. 16 DR. BELLAMY: It's immaterial to me. ( 17 I think if you have a concern as to those plans, l 18 you need to go to the Commonwealth of 19 Massachusetts and ask them where did you get those l 20 plans and why did you submit them to FEMA when 21 FEMA has those plans and asks for a technical l 22 review, that the technical review was done and 23 those comments were gone back to the Commonwealth 24 of Massachusetts. {
z 274
. 1 THE CHAIRMAN: We can coordinate 2 that, sir. -
3 MR. V0GLER: I would appreciate a 4 response. (Applause) 5 THE CHAIRMAN: Sure. 6 Is Miss O'Brien still in the audience? 7 MS. KATE O'BRIEN: I.am, but I'll 8 defer. It was c. similar question. 9 THE CHAIRMAN: Same question? Okay. 10 Mr. Frank Beard? I can read the question. 31 It's a gcod question. Would the NRC license a new 12 BWR Mark 1 reactor under present safety 13 standards? BOGEA 14 MR. 0 " T I 4 e e 6 4-: He approved such a 15 pressure supression type of containment at the 16 Hope Creek Plant in New Jersey just a few years 17 ago. So the Mark 1 containment design meets la today's standards. 19 T!!E CEAIRMAN: Mr. Gray Aluisy. 20 There is no quest. ion attached. 21 Mr. Gerald Hayes. < 22 MR. GERALD HAYES: Am I the last 23 one? 24 THE CHAIRMAN: Yes. It w a a n ' +.
170 l 1 intentional. 2 MR. HAYES: Maybe having been a part 3 of this planning process for the past year and a 4 half or so I can try to explain where the plans 5 that are now in the possession of FEMA have come 6 from. You have to understand the planning process 7 as it goes on in this area. The state, first of 8 all. has relegated all authority for preparing the 9 plans to Boston Edison. Communities have done 10 much the same thing. The plans have been prepared 11 in parts, s. mall sections at a time. They have 12 been passed on to the department heads for review ff 13 and comments. They have then been signed off by 14 the department heads, turned over to the state and 15 been submitted to FEMA for a technical review. 16 THE CHAIRMAN: These are draft 17 plans? 18 MR. HAYES: These are the draft 19 plans. We were told by the state that this was 20 going to be going to our benefit because this wey 21 here FEMA could pick up any shortcomings in the 22 plan, refer them back to us se we could correct 23 them, and also it would make it easier for FEMA to 24 review the plans piece by piece than review them { I
876
~
t 1 all together. 2 There is one flaw in this process because 3 each section refers to other sections of the plan, 4 as far as duties and responsibilities go. So I 5 really cannot understand how anybody can do a 6 technical review on a plan by looking at one 7 section today and another section that refers to 8 it two weeks later and then another section a 9 month after that. you know, after having been 10 preparing plans'for nuc2aar power plants for some 11 dwelve years, it doesn't seem to make any sense to 12 me.
- 13 Edison has generated an atmosphere around 14 this plant of fear and intimidation. They will 15 remove anybody from the planning process that does 16 not agree with them one hundred percent, anybody 17 that questions their methodology, their planning 18 procers or anything else. This became quite 19 apparent about two months ago at a meeting at 20 Edison at the county farm when Mr. Ron Barley said 21 Edison would not tolerate anybody who was opposed to 22 to *5eir planning process and that person would be 23 1 vved from the process. I'm here to tell you 24 tonight I am no longer a part of that process
{
l i 277 l 1 i 1 ( 1 because I had been removed just as Mr. Barley 2 threatened. 3 The outcome of this is -- I want to point 4 out to you there is an atmosphere of intimidation 5 that is being used by Boston Edison in this 6 planning process. I have in my hand -- I have 7 permission to read it from the author who is Mr. 8 Pierce, David Pierce, who is the former Civil 9 Defense Director for the Town of Carver. Mr. 10 Pierce feels much like I do, that Edison is 12 controlling the process too much, nobody is paying 12 an awful lot of attention and things are just 13 going the way Edison wants them. They have 14 reneged on agreements for equipment that they have 15 made with the communities, not written agreements, 16 cut verbal agreements. They have decided they 17 will tell us what we need to protect the people of 18 the town. We will not tell them. As a result of 19 this, Mr. Pierce submitted this letter to the 20 Board of Selectmen on the 26th of April, 1988. 21 "To the Board of Selectmen, Town Hall, 22 Carver, Mass., from David Pierce, Box 253, Carver, 23 Massachusetts.
Subject:
Resignation of Civil 24 Defense Directorship.
278
- - 1 "I have enjoyed being involved in public 2 safety for the Town of carver these past few years 3 as your Director of Emergency Preparedness, but :
4 feel I can no longer perform this task. I hav'e 5 experienced difficulty in choosing my own staff of 6 qualified personnel as per statute Chapter 639 of 7 the Acts of 1950." That's the Massachusetts Civil 8 Defense Act. "And thus I am not able to guarantee 9 the effectiveness of the staff in any given lo emergency. 11 "The reason I made this statement is 12 because Boston Edison doesn't want anybody in the L- 13 process who doesn't agree with them 14 wholeheartedly. This is in particular regard to 15 the emergency plans for an accident at Pilgrim 16 Power Plan in Manomet. While a major accident is 17 unlikely at the plant, the possibility does exist, 18 especially as it has had serious problems in the 19 past and is still closed by order of the NRC. I 20 call your attention that in today's edition of the 21 Boston Globe" -- This is April 26 --
"Pilgrim is 22 still listed as the second worst run plant in the 23 United States.
24 "The plans for emergency response currently
879
- 1 under development were done by Boston Edison 2 themselves. This is like allowing the fox to 3 build the chicken coop. I have found myself 4 objecting less and less to the pressure to get the 5 plans done, and this is a disservice to the town.
6 I have become too overwhelmed by the buying of 7 Carver by Boston Edison. I disagree with the 8 concept that the proposed plans will do what they 9 purport to do. The current situation, even with 10 the new emergency operation center, will not allow 11 the mission of the protection of the citizens of 12 the Carver. With my best educated estimate, I N 13 have over ten years of civil defense service and 14 over twenty years in nuclear physics studies, the 15 plan would only protect seventy percent of the 16 c3tizens of Carver at best. This could be 17 dramatically lessened if a rapidly growing 18 incident occurred. 19 "I am, therefore, withdrawing all of my , 20 previous approvaJs of the BECO plan and resigning 21 my post as civiJ Defense Director. I cannot be 22 objective in any dealings with Boston Edison as my 23 requests to BECO for the town have constantly been 24 disapproval of the plans especially in the field {
180 1 of communication. In the past I have publicly 2 stoted many times that the various systems that 3 Boston Edison provided to the towns would not 4 work, systems such as the"minitor" which is the 5 old prieavy notification system which consisted of 6 a series of pages and beacon, by the way, which is 7 the new primary notification system, and they did 8 not work, and B o s t e .7 Edison is now trying 9 something, namely, dedicated telephone lines 10 directly to all the communities involved. 11 Hopefully, practice will make perfect, but I 12 cannot rely on that. L- 13 "The moral, let alone the legal, 14 responsibilities of the position of Civil Defense 15 Director require anyone in that position to 16 constantly put the town first. I have failed that 17 by giving into my better judgment and allowing 18 Boston Edison to run the proCram and, in fact, l 19 make Carver a company town. The current plan is l 20 not the plan of the Town of carver, but Boston 21 Fdison's plan for the Town of carver. I cannot l I 22 accept and will not accept the responsibility for 23 this. I c a n r.o t fight city hall, but I can say 24 that in my opinion the plan will not work as l l L
181 { 1 designed and will not protect the citizens of 2 Carver to the extent they deserve. This is 3 especially true for the sick, handicapped, elderly 4 and the very young. I cannot in good conscience 5 recommend the plan to the town or the state. 6 Neither can I continue to beat my head against the 7 wall or, more exactly, against Boston Edison's 8 monolithic organization. 9 "It has been my pleasure to serve you, but 10 the time has come to say good bye. I hereby 11 tender by resignation as Civil Defense Director 12 effective May 10. 1988." (Applause) 13 There is a feeling among people in the 14 planning process, e ctiod many of whom I have known 15 for ten to dwelve years, that now that Boston 16 Edison is providing money to pay some of the 17 salaries they are afraid to speak out, afraid they 18 will wind up on the outside looking in like some 19 of us have. It is imperative that you gentlemen 20 know this plan is not being written by the 21 communities. It has been written by Boston 22 Edison. .I t is being forced on the communities. 23 It's being approved by people in the communities 24 who do not have that much of a background on {
182 ( 1 emergency preparedness, who really do not 2 understand what this involves. Edison has decided 3 they will have a plan come hell or high water, and 4 nobody better get in the way. :I want you 5 gentlemen to consider this as you review these 6 plans. 7 You heard the Selectman from the Town of 8 Duxbury tell you his Board has never approved any 9 plcns to be sent up to FEMA. *i o u heard the 10 Chairman of our Board of Selectmen from the Town II of Plymouth tell you the same thing. Yet the 12 plans exist and they are there and thoy are being 13 reviewed. Our local governments don't even agree 14 with them. Can't you gentlemen see what Boston 15 Edison is doing in this area? 16 I stood before the full Commission in New 17 York City in 1981, and I asked them at that time 18 to provide us with the equipment necessary to de 19 what was necessary to protect the people around l l 20 Pilgrim Station. I got the same stock answer l : 21 every time I asked the question. I asked $,h e 9. 22 question at least twelve times in the course of 23 the weekend. They said they would use their 24 licensing authority to make sure what had to be l l
=
183
. I done would be done. This is some six or seven 2 years ago. They have never made good on that 3 promise.
4 I'm sure you four gentlemen here, some of 5 you I know person, ally, I'm sure you know your own 6 intention. I'm sure you're very sincere about 7 what you're trying to do. I don't see a problem 8 with you gentlemen. I see the problem with the 9 five people that sit on the top, the people who ' 10 change the rules to fit the scenario, the peo'ple 11 who have said we don't need approved plans for 22 Scabrook, the people that have said we don't need 13 an effective outdoor warning system for Seabrook. 14 And I'm very much afraid that because of the 15 pressure that the industry can bring to bear 16 through lobbying efforts that we may wind up with 17 the same situation in this town. We've got to 18 play by the same rules. 19 Ann Arnold asked you about a worst case 20 sc'enario accident. It had always been my l 21 understanding and from reading NUREG 6054 that we b
- 22 were to try and keep win EPA guidelines as far as
! 23 exposures for people. We don't talk about dose i 24 savings. We t.alk about limiting people's exposure ( i 1
1 264
; 1 to less than one rem. And there is not a plant 2 that can be built that can effectively guarantee 3 that to the entire population around Pilgrim 4 Station in a worst case scenario, you gentlemen 5 know it and I know it.
6 So please, Dr. Bellamy, don't play with 7 word games, don't tell us what we are talking 8 about dose savings. Let's talk about what EPA 9 says we should plan for, and that's one rem. 10 Thank you, g e r.t l e m a n . (Applause) 11 THE CHAIRMAN: I apologize to Dr. 12 Muirhead and Mary Ott. Their cards got mixed up. L_ 13 1 over1ooked them. 14 Miss Ott, would you like to go neat? 15 MS. MARY OTT: Good evening. My name 16 is Mary Ott, Co-Chairman of Duxbury Citizens 17 Urging Responsible Energy. 18 The last time I appeared before you our i 19 organization was committed to keeping the Pilgrim , ! 20 Nucient Power Station shut down until we could be l 21 assured that it could be managed safely. We havo 22 recently concluded that there are no longer any l 23 assurances, and we call upon the NRC to order g 24 rejection of the license of this poorly designed, l
Se5
# 1 mi.smanaged facility.
2 In denying the adjudicatory hearing 3 requested by citizens and state officials of the 4 Commonwealth, the Nuclear Regulatory Commission 5 has placed yet another obstacle between people who 6 would seek the truth and the Boston Edison 7 Company. This meeting tonight and the one before 8 it on February 28 make a mockery of the democratic 9 process. They are as cosmetic as many of the 20 changes now in place in Pilgrim. 11 Within the past two weeks two of the five 12 NRC Commissioners have toured Pilgrim and reduced F. k- 13 serious safety concerns regarding plant operation 14 to a public relations game. On April 22nd 15 Commissioner Kenneth Carr said, "I don't see any 26 problems right now. I don't see any show - 17 stoppers." 18 On May 8 Mr. Rogere, the newly appointed 19 Commissioner who was on the board of directors of 20 a utility that owns three nuclear power plants and 21 was reported to have Jnterests in two utilities in 22 Pennsylvania said, "I don't see any serious 23 questions about running the plant. There are no 24 serious questions about the integrity of the
186
- I containment. He said the turbine room is very 2 impressive, returnished, sparkling, white, neatly 3 arranged and cleaned."
4 And I ask you, how does one arrange 5 turbines neatly? Is white paint the answer to 6 Pilgrim's problem? Have these Commissioners seen 7 the NRC outstanding item list which Senator Golden 8 obtained under the Freedom of Information Act? It 9 documented ninety-nine or one hundred items 10 unresolved, fifty-one of which must be resolved 11 before restart, and many of them dating to 1984, 12 1985 and 1986. Have they read their own reports
- 13 indicating a high risk of failure associated with 14 the GE Mark I containment? Management stability 15 has been promised. Do they know eight key 16 management people have left Pilgrim in the past 17 year, and that includes the plant manager hired in 18 December who along with many of the others 19 resigned for personal reasons?
20 The NRC readiness team has yet to perform 21 three weeks of extensive scrutiny on Pilgrim 22 changes. Do they realize there are no evacuation 23 plans in place to protect thousands of people 24 within the ten-mile radius of Pilgrim? Such {
==
887 ( i comment is totally inappropriate at this time and 2 serves to convince those who question your 3 intelligence that who you really are protecting is 4 not the people, but the Boston Edison Company. We 5 do not want to be subjected to the risk involved 6 in giving Boston Edison one more chance to resolve 7 their management problems. 8 A nuclear power plant is not the place for 9 prolonged on-the-job training. At some point the 10 NRC has to say enough is es.o u g h . It is a matter 11 of time before there will be a serious accident 12 here in Plymouth, and it will be little solace for h all of us that the NRC has documented problems at 13 14 Pilgrim over sixteen years. We ask you to move 15 the question. Thank you. (Applause). 16 T!!E CHAIRMAN: I can answer one of 17 those questions. That is the assessment team 18 inspection will be input to the Commission and 19 will be part of the final ass 23sment report along 20 with the SALP documents and the overall summary. 21 So they will have that report for consideration. 22 Dr. Muirhead. 23 DR. DONALD MUIRHEAD, JR.: It is 24 late. I'll try to be extremely brief. Four [
~
^
286 ( 1 comments. I heard from the second speaker tonight 2 when you were talking about whether it's ten 3 percent or ninety percent risk ;f a melt down anc 4 breach of containment. I'm not sure that any of 5 us really care about arguing or wondering whether 6 there's going to be a study done, whether it's 7 going to be ten or ninety percent. If it's one 8 percent or two percent or five percent. I think 9 you should know it'e too much for us. And this lo risk that we a r e' supposed to be +aking that '. 11 believe you blamed on Congress, I think that's 12 partially true. Way back when when people didn't 13 know about much this and this was the new peace 34 and so forth, we all agree and many of us feel 15 there was a big mistake made, but to continue a 16 mistake I think is uncon=clonable. 17 Secondly, Dr. Bellamy, you have obviously 18 hit upon one of my, I won't say, favorite topics 19 by any means, but, as you know, at least one I'm 20 very interested in. And I see tonight which I did 21 learn one thing that the NNC has f e r.n ,1 1 y cott out 22 and summarily said that there is absolutely ro 23 cancer risk here and this will certainly not be a 24 determinant as to whether the plant opens. You
' 1 189 l )
I i ,
< l
( 1 mentioned you had read a good deal on this. I 2 hope you continue to read and not just plow these 3 figures in as they come out into what you said you 4 have already collected. 5 I would submit, number one, that if, 6 ind sed, there is a potential problem that many 7 studies point to, this may, in fact be worth 8 while to consider. I wonder if you have seen one 9 of the latest studies from the British Medical lo Journal of about a month ago. I will briefly' 11 recount it. It shows in small fig"res, perhaps 12 minute, in :he town of Sulford, the plant there, b_ 13 they looked at two cohorts of school aged 14 children. Do you know the study? 15 DR. BELLAMY: Yes. 16 DR. MUIRHEAD: Then you know what 'm 17 going to say. I will be interested in your brief If comment about it. The first cohort, the mothers 3 lived around the plant, they were pregnant around 20 . the plant and they bore these children and they e 12 went to school. The other cohort, the mothers
- v-
't 2 lived elsewhere, bore their children elsewhere and
;3 came to the sulford plant. I can't recount how 24 many yearsof school, but simply a long time during
{ J
190 1 the school age. Whether it's seventh or eighth l 2 grade or tenth grade, I can't tell you. But, in 3 any event, when they came out, happily they came 4 out with a small number of cases of leukemia. 5 There were only five, but all five cases of 6 leukemia, I think most people can guess, perhaps, 7 where they all came from, came from the cohort of 8 the mothers who were pregnant around the plant and 9 bore their children there. 10 Another statement which I couldn't find in 11 my question, Sam, which I brought to you and had 12 raised again tonight. In the worst case scenario, 13 and you remember that we talked about the fact 14 that I didn't feel you were planning on worst case 15 scenario which to me and to everyone else is the 16 melt down, and we have heard some statistics on 17 that possibility and particularly in this plant 18 and then a breach. And by a breach I mean a blow 19 out, a partial, a roof blow out, whatnot. I don *t 20 mean a controlled release such as they were 21 attempting to put in the plant there that you
< r 22 stopped.
23 And with that and in your own NRC 24 regulations that I believe you are looking at {
298 ( 1 right now it speaks about the fact that a plume 2 can travel ten miles in half an hour. And just 3 exactly how anybody can plan for evacuation I'm 4 not sure. 5 The last one that comes up on this has to 6 do with shelters. We have all heard what the 7 change in FEMA was abruptly and most of us know 8 why, I think, they summarily threw shelters out. 9 So if, indeed, shelters are thrown out, I would 10 like to ask that question are shelters in or out? II Are they in vogue or are they not? If they're 12 out, if a plume can travel ten miles in half an L 13 hour, what do we do? Thank you. (Applause). 14 DR. BELLAMY: Let me just try to 15 briefly comment on two of the points. First of 16 all, I have to agree that in some cases with the 17 studies that are done we are probably not dealing 18 with enough cases or numbers to prove a point one 19 way or the other. I think that's also the case . 20 with the report that the Commonwealth of 21 Massachusetts has recently issued. If you take a 22 look at those numbers. 23 DR. MUIRHEAD: Don't~ you agree with 24 me because I'm saying those five numbero are very {
892 ( 1 important because -- 2 DR. BELLAMY: Okay, then I do not 3 agree. I think in most cases we do not have 4 enough statistics to prove a point one way or the 5 other. 6 you didn't mention it, but I'm assuming 7 you're talking about the change in FEMA's position 8 with respect to the necessity or lack of necessity 9 for sheltering the beach population out of 10 Seabrook Nuclear Power Plant. It's my 11 understanding that change in position, and I de 12 not agree that we all know the reason for that L_ 13 change, is not a generic change, that that 14 position specifically appIles only to the Seabrook 15 Station, and that sheltering is a protective 16 action that will still be considered as one of the i l 17 saecessary protective actions in the emergency plan 18 process. I'm not prepared tonight to address i 19 anything as regards Seabrook Station. I will 20 not. 21 THE CHAIRMAN: Is Miss Patricia D'owd 22 still in the roon? I 23 George Cameron. f 24 MR. GEORGE CAMERON: I sat here , l
193 1 ( 1 earlier, and I was already to get up and start 2 hollering and ranting and raving. Other people 3 did that before me. I heard the first speaker get 4 up and tell us about the adjudicatory hearings and 5 why they wouldn't be held, why the public would 6 have such a problem, you know, I think what 7 you're doing is you're hiding behind a set of i 8 rules and regulations that were made up, in my 9 opinion, to insulate you from the public, lo something '; h a t you can get behind. II We've got two United States Senators. 12 We've got the Governor of the State of X 13 Massachusetts. We've got state senators, 14 selectmen, Attorney General. Everybody is asking 15 for these adjudicatory hearings. Why don't you 16 put all this paper work aside and say here, we 17 will give it to you. The people in this town have 16 voted almost two to one on a referendum question i 19 dealing with nuclear waste which would, in effect, 20 shut down Pilgrim 1. 21 I don't see how the NRC which, ikmy v f 22 opinion, are no more than political puppets -- l 23 Let's face it, if Michael Dukakis did it tomorrow, l 24 there would be a new NRC. I don't think you can { l
A94
- 1 deny that. Why not just come out and build faith =
2 in the people and give them the adjudicatory 3 hearing? I don't care if they take two years. I 4 don't think anybody else cares if it takes two 5 years, as long as we get through. 6 Somebody else got up and started talking 7 about this is where it all started. We don't want 8 it to be the place where it all ended. They're 9 building one hundred fifty thousand housing units 10 in Russia for people who can never go back to
~
q 11 their towns. I don't want to see it here., I 12 worked two jobs full time all my life to maintain L_ 13 a family and a home. And if something happens 14 here, there's a chance I might not be able to come 35 back to it, and tfhat are we going to get back out 16 of it? They tell you your insurance company isn't 17 going to pay you. Edison is only liable for 18 twenty-five or thirty cents on a dollar. That is 19 what I get out of my life's work along with heart 20 problems because of it? There are other people 21 doing the same thing 22 This gentleman talked about agonizing. We 23 agonize here. Who are we going to leave behind? 24 I know and you people know some are going to be ( I
195 ( 1 left behind. There's no way you can do it. 2 Common sense. You don't have to be a scientist or 3 an engineer or a doctor. Common sense tells you 4 you're not going to get everybody out. If the 5 people don't want it, why does the NRC insist on 6 107 That's what you're doing. You're insisting
? on it. You're arbitrarily willing to throw out 8 this or that report saying it's irrelevant. You 9 accept what you want and you throw out what you 10 don't want. That's where you're losing faith'with 11 people.
12 Why can't you come up with these hearings? 13 Why not just put everything aside and say, look, 14 let's show the people we are sincere and honest, 15 give them what they want. And when the end 16 results come out, you can say, well, you haven't 17 proven your case or maybe you can say you have 18 proven your case, we were wrong. I don't know how 19 you can go home and look at your families and 20 friends and say, well, we did a real good job 21 today. I don't think you'have done a go'od job. n 22 I came to this town because the power plant 23 was here in 1972. I used to think the people 24 running around with signs were a bunch of nuts, ( i l I
196 ( 1 But they're not. If you look at the problems this 2 country has had with PBC and Vietnam, asbestos, 3 black rights, if it wasn't for the people doing 4 the protesting and telling the government, we 5 would still be in the dark ages. Maybe it's time 6 that we realize that there isn't any room for 7 nuclear power. 8 I know that's how you fellows make your 9 living, you make your living because there are 10 nuclear power plants cround and you're part of the 11 Nuclear Regulatory Commission. If you've got all 12 those degrees, you can find something else. I '- 13 You're not going to starve. I think you should 14 stand up and say let's give the people what they 15 want. Give us the hearings we are asking for. At 16 least be able to stand up and look in the mirror 17 and look yourself in the face and say I did the 18 right thing. Give us those hearings, please. 19 (Applause) . 20 THE CHAIRMAN: That concludes our 21 signed up speakers for tonight. We thank you for w 22 your attention and for your participation. This 23 meeting was intended to be responsive to your 24 comments and provide a transcript reference for (
197 ( 1 your use in the continuing reviews to be performed 2 here at the Pilgrim Station. 3 The presentations were quite technical, I 4 think as a recult of the information that was 5 requested by the public comments. We had made 6 ourselves available to the local groups to talk 7 one on one informally, and that hasn't been taken 8 advantage of, and that offer still exists. I 9 appreciate your tolerance and hope we have 10 encouraged in some measure your continued 11 participation. Thank you. 12 (Whereupon, at 11:25 p.m., the 13 hearing was adjourned.) 14 15 16 17 18 19 20 21 22 23 24
s ne aratt pian nas guaranteed that adauste Duses , will arrive. The bus provider says 1142 buses for the 3,uclear Reporto. Erz a,e schuuied i ,anici, ate. Do , u beue,e : thb? Has Carey Bus Co. entered contracts with either Boston Edhon Co. or the Comm:nwealth of Massachusetts to provide buses for a nuclear ' Askm. 5o the Impossible thebuses? Willthesedriversoncetheyleave ( be aUowed to reenter it and take care of their own The superintendent of schools has perhapuome of famuses? In case of a delay in traffic and stronger the most complex responsibilities in the draft plan. " measures are enacted, will the bus driver or school He is theoretically responsible for protection and personnel distribute potassium iodide? Will either be transportation of school age children away from pro- required to take it themselves? If so, gho will ad. bable danger. According to the Town of Duxbury minister it? Radiological Emergency Response Plan for Pilgrim Nuclear Power Station (Revision 2. Oct. 30,1987 The draft plan has no provhions for any of the draft), the following are his responsibuh s: above people who could be acutely ul with radiation sickness. What provisions have you made for addi School Department donal assistance if needed? Where will it come from? (a) Notifies and implements protective actions for Who will eninleser before evacuation? potassiumiodideifitis re the school population. ' (b) Coordinates transport of the school and the
, Magic Dragon Day Care Center. Bree Mile Island never reached an alert classifica.
(c) Provides facilities to support transportation tion. Wul you evacuate the chudren at an earlier assistance.
. stage? Certain nuclear incidents can escalate to ao l (d) Provides shelter for transient populations, alert level in less than 30 minutes. What do you have .
-}n place that is ready to be utihzed for thb lastanc i
i .. Children at schools and camps wul receive special consideration during an emergency at PNPS. At the Wul parents be allowed to phk up their children? l Wul students who drive be allowed to leave without alert classific4 tion level, buses will park in front of I the EPZ schools and camps in preparation for a - parental consent? Wul perents that attempt to pick , precautionary transfer of children to the Bridgewater up their childica be allowed to ride the buses? If so, ' Reception Center. how many additional buses will be necessary? Will An adequate number of buses will be provided to children be released to neighbors, relatives, etc. If the transport the children in a single trip. In the event of parents have not been contacted for permission? I a rapidly escalating incident in which immediate pro. tective action is required, provisions have been mada. Your responsibuides include providing shelter for for the protection of children at schools and camps, transient population. Do you have the necessary staff I { The school superintendent in the EOC will notify to do thh task? If the school children are evacuated who will stay behind with these peopic? Will school school principah and administrators (public, non. children have a priority over transient populations or public nursery and day care) of the emergency and will everyone be moved Iogether? Wul you need addi-protective action ra==*='l=. Principah and tional buses? If so, approximately how many are administrators will nodfy their staff. avaliabis? Is the town involved in daten= tina shelters if a precautionary transfer occurs or evacuation
- with adequate protection? Are these' shelters using becomes necessary, students and school staff wul be formulas based on dose reduction rates? Who is transported by bus to the Transfer Recepdon Center, dat !='In! th: shelters? Boston Edison? State?
Town? Since the shelters are part of your respon. School staff wiu ressala with stadents mats parea. sibuities, do you have some input into them? Are you tal p6chup is poespleted. responsible for supplies, stocks and maintenance? Wtu there be nr.sks avanabic? If you are not respon. The following questions are submitted to alble, who is? When do you czpect the shelters mil be Superintar*nt' Donald Kennedy: ready? Does the town have insurance for them? Are you, partially covered? It has been stated that school staff wGl reusala with children until pickup'is an=plaad. What does this Who wiH direct the traffic at the school? If it is the mean? Wul all teachers be required to stay with their crossing classrooms? Will teamers be aBowed to go to their training?Do guards, they havehave they that contracts completed the to require them ne own families or will they stay with sheltered chudront direct traffic? Do you have ve clothing for I . Waucaley has been stated to be the new roospdon thsen? If they decitas to pate, what sharnatives center. Will teachers travel there with the chudren? Is do you havet
# t it in the contracts of the teachers to perform these duties? Have you poued the teachers to see if they According to the plan, you have some respon.
wMd fulful these obligationst is there an espected sibeltise for camps and nursery schools. What h thh salary increase because of these obligations? If so .f9yt Do fou feel that they att ustely who vrill pay it? Duabury? The Boston Edison Co.i provided for? Are their evacuation plans own responsibuity or are thew yours? Are these schools I l De town is negodating con'racts for tralains of ano camps covered "- - with @c town's insurance? school staff. Do you require that rJI teachers, bus ,^ ' ( drivers, crossing guard, secretarial be8p, and custo-dians pardcipate? Wut certification of this tralalas
', guarantee dWr cocspletion of duties? Will staff who take the and then subsequently decline to stay with the en be liable or otherwise accoun.
table? Does the present plan depend heavily on school staff 7 '
~ . - . - - ...
I I The plan has lated a school superintendent, where will you be dur' a nuclear emergency? Do your ! responsibilides with the close of school? Are you ' responsible for providing for after school activines? Transient parta6ee? If not, who is responsible for the after school acdvides when'large numbers of children are left for lessons, CCD, sport saraes, etc.? Who is responsible for the transient populadon in private lessons, such as ballet, swim, gymnasdes? Do parents contact you in such cases duras an emergen-cy? . You have been reviewing the plan for alc20st 2 years. Are you satisfied with the progress? How many of the above questions have been presendy answered? Do you feel that .those answers satisfy your obligadons? Will you take stronger action ifit is required so that we may have a workable plan before . Pilgrun I start up? ' As the superintendent of schools for Duxbur/, do i you think that we can develo plan? Do we have one now?p a workable evacuation How close is it to com-pledon? ( I - e I a 1 O l l l
i Questi:ns for the Board of Selectmen ( . The primary responsibility for the emergency . response plan lies with the telectmen. The following is a list of their obij gations under the new Duabury Draft (Section 11.A 4)
- a. Direcu the overall control of emergency response,
- b. Basures 24-hour sulting of emergency respones.
- c. Approves pubbe information statessents.
- d. Declares a state of emergency.
- e. Ensures im '"%
mended protective a;ction. of the recom-
- f. Oversees recovery and re-entry activities.
- 3. Itegular review and approval of emergency s the following questions to the chairman of the board of hmen, Patrida Dowd:
- 1. Are you aware that the Boston Edison is the main author of the current draft of emergency response plans? What new evidence has arisen that gives you the confidence ta allow them to provide plans that are better than the ones they previously authorod? And what are the improve-menu over re}ccted plans?
- 2. Are you satisfied with Ad Hoe Plasalag which is currently being classifwd as the Gov.
ernors State of Emergency?
- 3. Last year the Town of Dumbury sold over 5,000 beach stickers for the 1937 34 season. It is already =sahmhd fact that there is no
( shelterlag est there. Do you latend to costlaue selling beach stickers or are you 30-lag to limit the access to Dumbury Beach to the new r-==dastaa of 300 vehicles?
- 4. If there is an essergency at Pilgrim I, -
their plans calls fos your presence. Do you in-tend to be at 'the funergency response center? If not, who wal your designated replacement . be?
- 6. In the case of a Pilgrim I auclear emer.
the statement "something is better than
" is misleading. It haplies that there is protection for our town when the reality is that there is really nothing in place. Du you feel that a plan that has the Boston Edhon Com as the author is written with the boot latereau of the of Duxbury?
- 7. The r'a=-weakh of Massachusetts has spent mahoes of our tax do8ars on the pro-taction of 4 hiassachusetts communities. How sauch of our tos. dollar is being spent on the protection of the citianas of the South Shore?
- 4. If you decide thses is no plan, you can-not sign coe. What is the town's next stspt
- 9. Do you plan to sign 6 plan that has Welisley as the renapelan oester?
- 10. Are you og to dessand an ajudicatory hearing on ' I before restart?
(
, , , , - _ . ~ , _ , ,,.__,_y.,.-,,,- ,- --_,w__ , . ,,, , - . - . .
What About t.he ( Handicapped? , According to the Duxbury Radlological Emcigen-cy Resp.,nse Plan, Special Populatiors "require assistar:e in taking protective action. 'fhis special popula' ion cresists of transportation dependent per-sons, mobility impaired persons in recreational areas, workets for .nsjor, employers and persons in special facilities. The ..r propnate officer in the EOC will coordinate the p.xective raponse for their res lye special popu' rios group." s new draft plan han very limhed reference to any people.who are handicapped. At present the main decisions are being left up to an adyssory group from the Office of Handicapped Affairs. This group will make recommendations that may or may not be put into effect by the Commonwealth. The draft plan makes reference to a health officer: Who are responsible for Duabury? What are their-qualifications regarding the assistance of the han-dicapped? How far along in the planning process are they with regards to the special needs of the han-dicapped? Who in Duxbury is the liaison to the of. fice of Handicapped Affairs? Who in an official capacity attended the Fpecial Needs Hearing on March 28 in Plymouth? What issues of particular im - portance were brought out at that beanng? Were they or the health officer offer.ded that littic or no participation from the Boston Edison Co. and from the State Civil Defense was evident at the hearing? Was any testimony submhted for the town of Dua-( bury? Can the Clipper get a cooy of it? Has the town of Duabury W,satified the nusaber and residences of all tw;s who will need special
- - *==ce in the event of My emergency? Can people *
' ' contact someone in d s event thi they need help when a nuclear emergency esists? If so, who is the e contact? If a person would like to be added to that list who does he (she) e ontact)?
Boston Edison has ande the offer to fund TDD's (Telecommunicaiton Devices for the Deaf) over a year ago. How many of the TDD's have been given to people within the town of Duabury? Without a TDD how will a deaf person be notified of an acci dent at PNPS7 Who as the contact person for the TDD's? Regarding perseas with disabilities, who will be evacuaterl? Will people wkh special aseds be given a priority over the pomeral ion? Will they be forced to wait unts: the populationle enoved? - ( Will there be people will ne left behied? Who will snake this determlaatioef Assuming that all populations will eventually be provided for, who will %. provide the necessary care for the special populations b3"V that are awaiting help? If shelterin ^g is deemed to tm V $ e ' necessary, are the sheeters for ' ;;:Iaccessible or will there be individuals present to assist them? If so will these people be presset 3 all shelters or a eclect few with the other volunteers? Who ' t'ro-vide the necessary tralains for these maalasaan? Who will be legally responsible for them? Will they bc medically trained and able to dupense enedications (. correctly? Will medication be stored at all shelters? Who is legally responsible for providing an
' escrgency response plan for the handicapped y'*past
With only 8% cf Marshfic:d accounted fer within the emergency planning zone. How do you propose t) contain the other 92% plus the ballooned summe population in order tht the town of Duxbury ma> nave direct egress thr.msh routes 139 and route 3At Please take into account the rough estimate of the ( aumber of beach stickers sold by the towns of Dux. bury, Marshfield, and the Scituate portion of
- Humarock Beach with its only land access through
.Marshfield.
Duxbury 5,142 stickers Marshfield 4,688 stickers What makes you think the le of Marshfiell will sit idly by and allow the tion of Duxbur) to pass 11. 47 Waat plans do you have for Dux. bury and the swollen number of vehicles that are try. ing to peas through Duxbury to get to a decontamina. don center? Do you feel that the manpower you cut-rently have and the pro}essad lacreases you plan to have will be sufficient? How many officers do you plar, to leave behind in Duxbury to protect the town against looters in the event that evacuation frozo the power plant might be only a short term measure? - Long term measure? Gas for vehicles is of primsty concern in order to keep the flow of traffic moving. What provisions - have you made for gas to be available in Duxbury for cars sind buses that may not have large enough t'anks to sustain an adequate supply for a lengthy walt? Tbc present bus provider survey and the Com-monwealth of Massachusens have an estimated 1,142 buses available within a 30 mile radius of the plant. ( What provisions do you have that will allow these buses direct access to the W*t tion of Duxbury? What plans have yor for this populauon if the traffic flow is so heavy that the . buses may not arrive? What provisions are there for gas, etc., for these buses once they arrive? How do , you plan to get to the dependent population? Will the buses travel the congested ways and streets of Dux. - bury or will the dependent tion get to the buses th-wives? Who is in the dependent population? Do you have infctmation schedules for them or will they 'be expected to call you at the Emergency Operation Center on one of the 27 telephone lines 7 o .
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1 5 LL L$ L. P IA 38 Dumbury alpper, wedsender, Ayrs as,7sse '
- 2. The ca 5. When do you a full and adequate QueSilOBS f0F the dividuais mtergency we .reresponsenot fammar plan wim -ar. 4 in-emage eyresponsepMSvenacinh draft has dang.
sheher officer, transportation officer, public infor- that you nowdirecto,, have been civii d.fe.se thinausade Pa.,unaware o, f, do,you, as Ovil Defense Director =ation orrice, e.d ,adioiogicai ofn.er. Have 6e ateve individuals beep ===ad? If so,
,,o,,o,c, 5ithout a locaDy approved plan? You spend many ubo are tky? Do they work for Duxbury? State? Do hours weekly devoted to planning, what has been ac-The Ov5 Defense Director has the overaB respan. complished? How many hours do you devote to plan-sibility for ^ ' - for a nuclear tisey work for Boston Fdlean? Who bears the legal b;-- Power Statica. In the Babilities for thems? Are they under contract to per. nies? Do you feel the addmonal amount for a con-emergency at sukant of $47,000 wiR help? What qualifications are case of Duxbury, our civH defense director is Fire form service for the town? Are there back up trained Individuals la case they refuse to cooperate? you looking for la this individual? Who wiu deter-Chief Carl O'Neu. 3. Recently the town decided to e *-r contracts udne the suitability of the individual? Town or Since Chief O'Ne5 has the dual r*=raadbuities of with Boston Edison for an updated emergency Edison? ,
both the emergency response plan and the fire 6. How saany people have special needs in town? department, his duties are numerous. (O'Neu is also response center worth approximately $370,000, amt for consuking contracts to help you. How many of Do you have provisions for them? How many special on the emergency respoose study consadttee. meets needs students are in the DIS 7 Who is responsible for with 3 department heads every Tuesday resorde' s the the deficiencies previously noted in the plan will be satisfied by the EOC7 Do you think Duxbury has them? plan, has weekly meetings with the $ tate regarding been negligent in its past responsibilities toward 7. What are the gusHfications of the individuals civE defense for the Pilgrina station and bra sanny dispensing potassnan iodide? Will they be doctors 7 nuclear ymy - _^_ =7 Why, when given a wish list aseetlass with Boston Fd3*a= ) Dux .has last suerser, were none of the items, that are under Will um iodide be given to school personnel? allocated a Ettle over 5300 for civE defense la cur. Ben 7 Ocssing guards? Harbor master staff? rent budget. negotiation, ce k7 Who devised the list of items necessary for nuclear emergency? Du. bury? Boston Palire===7 DPU workers? Firemen? Selan===7 The foDowing questicos are subunitted to Cider 3. What does "Megate the damage" mean7 In a O'NeH: Edison? . 4 The police department is scheduled to receive worst case sceneno, what are the, projected death
- 1. Given the important . 74 you have rates for a town Duxbury4 size witma the EPZ7 In-under this plan, do you think tiet you have sufficieng approximately 365,000. Recent runors have cir- Jury rs'e7 How many people could be exposed to a staff to accomplisit the meesseery ansks? Many of culated that k is a great deal more. How usuch is the police department going to receive from Boston potentiaRy lethal dose of radiation? ,
these duties must be orsned simsele-ty, such 9. Is there an emergency response avaDable if the as the activation of sirens and findlas the select. Edison? containment fans to hold at Pilgrim 17 Is the present l What is the total figure that you expect Duxbury to men, etc. Do you have d=Esf=8mm named to assist you? plan based on the fashy assumption that the contain-If you are act here, who is responsible for perform. receive? Do feel thet the amount is sufficient to ment wiB always hold? If the contaanment fails, in Protect the of Duxbury? What problems has las these duties? Are a5 departament heads accoun- the worst case scenario, what are the estimated death Duxbury encounte ed that has led Boston Edison to rate? Injury rste? How many people in Duxbury table to that lodivkhmalf is that indivkheehs fansnier offer our town substantiaUy more than the other wkh the essergency remporise plan as you are? Do you could be exposed to potentially lethal radiation? towns in the esmergency preparedness zone? have a back up for that individual 7 8 l ' l . 1 l i
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1 1 l hxW CMpper, Wednesday. Apes 2s. 39as ! 10. You signed the past plan in 1935. What im- ed at the Pilgrim I station? Eas tier this year there was j provements have been made to k to make k more a fire at the Pilgrim. What did you have at that I workable? Wha
- is your fechng on the recent decon- time? Would it have work Maam has been online emminnelan centerthat is to be located in Wellesley? for 17 years: Emergency response pleas have been re-Do you feel this is a reasonable option? Why? If not. quired for the past a years. Why is there so anuch left I what do you intend to do about k7 Do you intend to to do with regards to planning 7 If somethina had l sign a plan that has Wellesley as a reception center? happened in 1934, would the pise have worked?
- If you do not, when do you intend to let the Com- What changes new are in place to see that the cur-
- , ,. anonweakh know? cat draft is any.betterl.
! II. Since last December. Imow many times has the 15. As civil defense director, do you feel there are
- essergency response comunittee spet? What is the occasions that Pilgrun I has operated unsafely and 1 <
prissary purpose of this committee? Do you continue we could have used a plan? Do you think there is a to their efforts? Do you support the recom- likelihood that Duxbury will ever need a nuclear s of the comunittee regarding sheltering? cmcrgency plan in place 7 i 'Ihis commhtee has repeatedly asked Boston Edison j for information regarding long-term evacuation. j FAlman has not cooperated. Do you intend to push the matters further7 Do you intend to see if long- ! terna evacuatian is included in the plan? Do you in-i tend to see if there are means in place should the
. workers and volunteers become acutely 91 with radia-tion sickness?
j 12. Do you think the present draft plan is a good ' l one? Does the esnergency response study committee think so? What is their response to the Phase I draft? , , Are they satisfied with k?' s
- 13. Who is legally responsible and liable for the j plan? Will this be established in writing befose the -
l town signs it? Do you think the C2overnor's State of l Es.gf is sufficient for the planning process? Do i you subscribe to ad hoc planning? What do you in-tend to see in place before you sign off on the plan?
- 14. How many times have unusual events been call-1 1
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1 v OPENING REMARKS FOR SAMUEL J. COLLINS NRC PUBLIC MEETING TO RESPOND TO COMMENTS ON PILGRIM NUCLEAR POWER STATION RESTART PLAN MAY 11, 1988 THANK YOU FOR COMING, LET ME INTRODUCE MYSELF AND OTHER MEMBERS OF ' HE PANEL HERE TONIGHT REPRESENTING THE NUCLEAR REGULATORY COMMISSION: I AM SAMUEL J. COLLINS, DEPUTY DIRECTOR, DIVISION OF REACTOR PROJECTS, REGION I AND CHAIRMAN OF THE NRC PILGRIM RESTART ASSESSMENT PANEL ADDITIONALLY, WE HAVE JAY M. GUTIERREZ, REGIONAL COUNSEL, REGION I DR. RONALD R. BELLAMY, CHIEF, EMERGENCY PREPAREDNESS AND RADIOLOGICAL PROTECTION BRANCH REGION I, AND MEMBER OF THE NRC PILGRIM RESTART ASSESSMENT PANEL BRUCE A. B0GER, ASSISTANT DIRECTOR FOR REGION I REACTORS, OFFICE OF NUCLEAR REACTOR REGULATION AND CO-CHAIRMAN OF THE NRC PILGRIM RESTART ASSESSMENT PANEL, AND (OTHERSASNEEDED) l I WOULD LIKE TO BEGIN BY BRIEFLY REVIEWING THF PURPOSE AND FORMAT OF THIS MEETING. l (
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s Opening Remarks - Pilgrim Hearing 2 NRC CONFIRMATORY ACTION LETTER 86-10, DATED AUGUST 27, 1986, WHICH WAS ISSUED FOLLOWING BECO'S DECISION TO SHU!DOWN PILGRIM, REQUIRED BECO TO SUBMIT A RESTART READINESS ASSESSMENT, A RESTART PROGRAM AND A SCHEDULE BEFORE STARTUP FROM THE CURRENT OUTAGE. ADDITIONALLY, CAL 86-10, STATED THAT THE NRC DECISION ON RESTART WOULD BE BASED IN PART ON THE REVIEW 0F THESE DOCUMENTS. IN RESPONSE TO THESE CAL REQUIREW.Nf3 M0 AS A PART OF THE OVERALL REVIEW OF BOSTON EDISON COMPANY'S PROPOSAL FOR PLANT RESTART ACTIVITIES, THE NRC HAS CONDUCTED A REVIEW OF THE PILGRIM NUCLEAR POWER STATION RESTART PLAN WHICH DESCRIBES THE PROGRAMS, PLANS AND ACTIONS CON 3]DERED NECESSARY BY BECO MANAGEMENT FOR RESTART AND CONTINUED OPERATION OF THE PILGRIM NUCLEAR POWER STATION. THE REVIEW HAS BEEN COORDINATED BY AN NRC ASSESSMENT PANEL COMPRISED OF MANAGERS FROM NRC
, REGION I AND NRC HEADQUARTERS. THIS PANEL C0 ORDINATES AND PROVIDES DIRECTION TO ALL NRC REVIEW ACTIVITIES ASSOCIATED WITH PILGRIM.
-- IN ORDER TO PROVIDE FOR PUBLIC PARTICIPATION IN THE PLAN REVIEW PROCESS, COPIES OF THE PILGRIM RESTART PLAN WERE P uCED IN THE LOCAL PUBLIC DOCUMENT ROOM (PLYMOUTH PUBLIC LIBRARY) AND PUBLIC LIBRARIES AT DUXBURY, CARVER, KINGSTON, MARSHFIELD, PLYMPTON AND WAREHAM. i ON FEBRUARY 18, 1988, A PUBLIC MEETING WAS 4 ELD "5RE IN PLYMOUTH FOR THE PURPOSE OF PROVIDING THE OPPORTUNITY FOR IN15RESTEU PUBLIC AND OFFICIALS TO PARTICIPATE AND PROVIDE COMMENTS ON THE RESTART PMN. ADDITIONALLY, THE NRC ACKNCWLEDGED THAT WRITTEN OR MAILED IN COMENTS AGAINST THE PLAN WOULD BE ACCEPTED. AT THAT TIME, THE NRC COMITTED TO CONSIDER THOSE COMMENTS RECEIVED FOR ENHANCING ITS REVIEW AND INSPECTION ACTIVITIES, AND TO HOLD ANOTHER PUBLIC MEETING IN THE AREA TO PRESENT THE DISPOSITION OF THOSE COMMENTS RECEIVED ON THE RESTART PLAN.
FOLLOWING THE FEBRUARY 18, 1988 MEETING, A PUBLI RECORD WAS oROVIDED IN THE FORM OF THE MEETING TRANSCRIPT, AND COPIES OF THOSE COMMENTS RECEIVED BY MAIL. THESE WERE PLACED IN THOSE PUBLIC LIBRARIES TO WHICH THE RESTART P UN HAD PREVIOUSLY BEEN SENT.
s Opening Remarks - oilgrim Hearing 3 6 OUR PURPOSE HERE TONIGHT IS TO PROVIDE FEEDBACK TO THE PUBLIC ON THE COMMENTS THAT WERE RECEIVED ON THE BOSTON EDIS0N COMPANY'S CORRECTIVE ACTION PLAN. THIS MEETING IS NOT TO REACH A CECISION ON PILGRIM RESTART, BUT TO EXPLAIN THE PROCESS BEING UTILIZED BY THE NRC. IN ORDER TO C0 ORDINATE THE NRC REVIEW OF THE RESTAi<T PLAN AND THE RECEIPT OF PUBLIC COMMENTS, A MULTI-DISCIPLINED TASK FORCE WAS FORMED. ATOTAL$F 71 DIFFERENT INDIVIOUALS OR PARTIES PRESENTED COMENTS IN RESPONSE TO THE HC 'lEQUEST AND THE NUMBER OF COMMENTS TOTAL APPR0XIMATELY 240. THE NRC REVIEW 0F THE PLAN IN CONCERT WITH THE PUBLIC COMMENTS RESULTED IN OUR REQUESTING BECO TO RESPOND TO SPECIFIC QUCSTIONS, OR TO CLARIFY THE PLAN - THOSE LETTERS AND REPLIES ARE PROVIDED TONIGHT FOR YOUR INf0RKS. TION AS AN ATTACHMENT TO THE MEETING HANDOUT. THE NRC REVIEW IS COMPLETE AND THOSE COMMENTS PREVIOUSLY RECEIVED HAVE BEEN EVALUATED BY THE NRC STAFF IN ITS ASSESSMENT OF THC PILGRIM RESTART PLAN. GENERALLY, THE MAJCRITY OF COMMENTS RECEIVED FALL INTO 4 BROAD AREAS:
+ 1. ISSUES DEALING WITH PUBLIC PARTICI_PATION IN THE PILGRIM RESTART ASSESSMENT PROCESS - SUCH AS REQUESTS FOR HEARINGS, THE CONFIRMATORY ACTION LETTER AND OPPORTUNITIES FOR PUBLIC INPUT
+ 2. ENVIRONMENTAL MONITORING AND EMERGENCY PREPARE 0 NESS -
SUCH AS OFFSITE MONITORING, NIH CANCER STUDY, THE EMERGENCY PLAN REVIEW PROCESS AND STATUS OF NRC ACTIONS
*3.C(NTAINMENTANDSAFETYENHANCEMENTPROGRAM(SEP)-SUCHASTHEMARKI CON 1?tNMENT DESIGN, THE DEFENSE-IN-DEPTH CONCEPT AND THE STATUS OF THE SAFETY ENHANCEMENT PROGRAM INCLUDING THE DIRECT TORUS VENT (DTV),AND
+ 4. MANAGEMENT AND NRC ASSESSMENT PROCESS ISSUES - SUCH AS CRITERIA FOR MANAGEMENT EFFECTIVENESS, RECENT SITE EVENTS AND THE NRC PROCESS TO EVAlbATE BECO READINESS TO SUPPORT PLANT RESTART
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V , Opening Remarks - Pilgrin Hearing 4 MEETING HAND 0UT ATTACHMENT 2 PROVIDED TONIGHT IS A
SUMMARY
LISTING OF THE PUBLIC COMMENTS RECEIVED BY THE NRC, WHERE THEY ARE LOCATED IN THE TRANSCRIPT OF THE FEBRUARY 18, 1988 PUBLIC MEETING AND WHERE THE NRC RESPONSE TO THE ISSUE WILL BE CONTAINED. RESPONSES TO WHICH A WRITTEN REPLY IS PROVIDED ARE AVAILABLE TONIGHT AS HAND 0UT ATTACHMENT 3. OTHER PUBLIC CORMENTS HAVE BEEN INCLUDED INTO THE 4 CATEGORIES PREVIOUSLY MENTIONED AND WILL BE RESPONDED TO WITHIN THE CONTEXT OF THE PRESENTMION GIVEN TONIGHT. A REPORT OF THIS PUBLIC MEETING WILL BE ISSUED CONTAINING ALL MEETING HANDOUTS AND A TRANSCRIPT OF THE MEETING PRESENTATIONS. THIS MEETING REPORT WILL BE PROVIDED TO THE AREA PUBLIC LIBRARIES PREVIOUSLY PROVIDED THE PLAN AND THE FEBRUARY 18, 1988 MEETING REPORT.
-- FOLLOWING PRESENTATIONS LISTED ON THE AGENDA AND AS TIME ALLOWS, WE WILL ACCEPT PUBLIC COMMENTS ON THE RESTART PLAN REVIEW PROCESS. A SIGNUP LIST WILL BE PROVIDED AT THE BACK TABLE FOR THOSE WHO WANT TO SPEAK.
I WILL SERVE AS MEETING MODERATOR TONIGHT. I WOULD LIKE TO THANK YOU IN ADVANCE FOR YOUR COOPERATION AND COURTESY SO THAT WE MAY HEAR THE SPEAKERS AND RESPECT THE VIEWS OF ALL.
-- THANK YOU FOR YOUR ATTENTION, I WOULO LIKE TO INTRODUCE THE FIRST SPEAKER, JAY GUTIERREZ, THE REGIONAL COUNSEL FOR THE NRC REGION I 0FFICE.
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s S I LIST OF HANDOUTS
- i. .
- 1. AGENDA
- 2.
SUMMARY
OF COMMENTS RECEIVE 0 ON PILGRIM NUCLEAR POWER STATION RESTART PLAN
- 3. LETTERS / REPLY TO BECO RE: PLAN COMMENTS I
! 4. WRITTEN RESPONSE TO PUBLIC COMMENTS
- 5. NRC LETTER TO BECO RE: RESTART PLAN P
- 6. NRC ASSESSMENT PROCESS MILESTONES l
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.L , 30' o RESPONSE TO C0KMENTS REGARDING ASSESSMENT OF PILGRIM KANAGEMENT AND THE NRC ASSESSMENT PROCESS COMMENTS RECEIVE 0 OURING THE PILGRIM RESTART PROGRAM PUBLIC MEETING PLYMOUTH, MASSACHUSLTTS - FEBRUARY 18, 1988 SAMUEL J. COLLINS, DEPUTY DIRECTOR DIVISION OF REACTOR PROJECTS REGION I Plymouth, Massachusetts May 11, 1988 t.
1 I IN THE CONTEXT OF MY PRESENTATION, I WILL RESPOND TO THE COMMENTS RECEIVED OURING THE FEBRUARY 18 PUBLIC MEETING REGARDING MANAGEMENT AND THE NRC j ASSESSMENT PROCESS AS THESE TWO AREAS RELATE TO THE RESTART REVIEWS OF PILGRIM NUCLEAR POWER STATION. A
SUMMARY
OF THE COMMENTS RECEIVED IN THESE AREAS HAS BEEN PROVIDED TONIGHT AS A HANDOUT. MY PRESENTATION WILL BE INCLUDED IN THE TRANSCRIPT AS A PART OF THE MEETING REPORT DOCUMENTING THIS PUBLIC MEETING. IN THE NRC'S VIEW, THE PAST PROBLEMS AT PILGRIM HAVE BEEN WELL DEFINED. THE NRC CONFIRMATORY ACTION LETTER, OUR REPORTS ON ROUTINE INSPECTIONS AND THE SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE REPORTS (KNOWN AS SALP) HAVE ALL DEFINED WEAKNESSES THAT MUST BE CORRECTED BEFORE A DECISION ON RESTART CAN BE MADE. THE SOLUTIONS PROPOSED TO CORRECT THOSE WEAKNESSES MUST DEMONSTRATE THAT BOSTON EDIS0N COMPANf IS FULLY CAPABLE OF OPERATING PILGRIM WITHIN THE CONFINES OF THE COMMISSION'S SAFETY REQUIREMENTS BEFORE ANY COMMISSION DECISION CAN BE MADE TO ALLOW RESTART OF THE FACILITY. IT IS IMPORTANT TO RECOGNIZE THAT IT IS THE RESPONSIBILITY OF BOSTON EDISON, NOT THE NRC, TO FORMULATE AND IMPLEMENT PROGRAMS THAT ADDRESS THE WEAKNESSES THAT HAVE BEEN IDENTIFIED AT THE PLANT. IN PARTICULAR, BOSTON EDISON MUST DEMONSTRATE THAT IT HAS PROVIDED STRENGTHENED LINE MANAGEMENT TO ENSURE SAFE OPERATION OF THE FACILITY, STRONG INDEPENDENT OVERSIGHT OF OPERATING ACTIVITIES TO ENSURE THAT PROBLEMS ARE QUICKLY IDENTIFIED AND EFFECTIVELY CORRECTED, AND AN OPERATING ENVIRONMENT THAT FOSTERS SAFE, PROFESSIONAL OPERATION OF THE FACILITY. WHEN PILGRIM WAS VOLUNTARILY SHUT DOWN BY BECO, THE NRC CONFIRMED BY CAL B6-10 THAT CERTAIN ACTIONS WERE REQUIRED BEFORE THE PLANT WOULD BE PERMITTED TO RESTART, THE BECO RESTART PLAN IS THE BLUEPRINT FOR THE NEEDED CHANGES, AND t L
)4 2 FULFILLMENT OF THE G0ALS OF THIS PLAN ARE THE RESTART CRITERIA BY WHICH THE NRC WILL EVALUATE RESTART READINESS. THE NRC STAFF WILL DETERMINE THE EFFECTIVENESS OF THE RESTART PLAN'S IMPLENENTATION AND WHETHER IT 13 HAVING THE DESIRED EFFECT IN CORRECTING THE PROBLEM 5 THAT HAVE BEEN IDENTIFIED AT PILGRIM. UNDERLYING THE PROBLEMS AT PILGRIM IN THE PAST HAS B5EN AN UNSTABLE, UNSUPPORTIVE MANAGEMENT STRUCTURE FROM THE CORPORATE LEVEL TO SITE LINE MANAGEMENT. BECO HAS THE RESPONSIBILITY TO ADDRESS THIS PROBLEM AND IT HAS BEEN A SIGNIFICANT CHALLENGE. AS A RESULT OF BECO'S ACTIONS, THE NRC MUST HAVE CONFIDENCE, BASED ON DIRECT OBSERVATION OF LICENSEE PERFORMANCE AT EVERY LEVEL OF THE ORGANIZATION. THAT MANAGEMENT AND SUPERVISION BOTH AT THE CORPORATE OFFICE AND AT THE FACILITY ARE COMMITTED TO, AND REQUIRE, HIGH STANDARDS OF PROFESSIONAL PERFORMANCE FROM ITS EMPLOYEES. IN ORDER TO ACCOMPLISH THIS, THE HRC NEtDS TO REVIEW AND EVALUATE THE POTENTIAL AND ACTUAL EFFECTIVENESS OF LICENSEE MANAGEMENT. MANAGEMENT EFFECTIVENESS IS A CONCEPT THAT DOES NOT EASILY LEND ITSELF TO STRAIGHT-FORWARD DEFINITION. HOWEVER, THERE ARE CERTAIN TRAITS THAT ARE TYPICALLY EVIDENT IN EFFECTIVE MANAGEMENT ORGANIZATIONS. SOME OF THESE TRAITS ARE:
- 1. STRUCTURALLY, THE ORGANIZATION IS ESTABLISHED TO BRING TO BEAR APPROPRIATE MANAGEMENT ATTENTION AND FOCUd ON THE VARIOUS MISSION AREAS OF THE ORGANIZATION, FOR A NUCLEAR POWER PLANT, THESE AREAS INCLUDE OPERATIONS, MAINTENANCE, SURVEILLANCE, ENGINEERING, RADIOLOGICAL CONTROLS, SECURITY, EMERGENCY PLANNING, AND LICENSING.
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- 2. MANAGEMENT POSITIONS ARE FILLED WITH QUALIFIED PERSONNEL. TURNOVER IN THESE POSITIONS IS CONTROLLED SUCH THAT MANAGEMENT DEVELOPMENT AND SUCCESSION PLANS CAN BE IMPLEMENTED WITHOUT RESULTING IN SIGNIFICANT DEGRADATION IN PERFORMANCE.
- 3. MANAGEMENT POLICIES ARE CLEARLY STATED AND WIDELY UNDERSTOOD WITHIN THE ORGANIZATION. POLICIES AND PROCEDURES ARE SATISFACTORILY IMPLEMENTED AND RARELY VIOLATED.
- 4. MANAGEMENT INFORMATION SYSTEMS EXIST THAT CAN PROVIDE ADEQUATE RECORDS AND TRENDS OF ORGANIZATION PERFORMANCE, AND CAN SERVE AS A CREDIBLE BASIS FOR MANAGEMENT DECISIONS.
- 5. DECISIGNMAKING IS AT THE LEVEL IN THE ORGANIZATION THAT ENSURES AN ADEQUATE MANAGEMENT REVIEW.
- 6. PRIOR PLANNING AND APPROPRIATE ASSIGNMENT OF PRIORITIES ARE EVIDENT WITHIN THE ORGANIZATION.
- 7. CORPORATE AND SITE MANAGEMENT INVOLVEMENT IN SITE ACTIVITIES ARE EVIDENT. MANAGEMENT REVIEWS ARE TIMELY, THOROUGH, AND TECHNICALLY SOUND.
- 8. CORRECTIVE ACTIONS TO IDENTIFIED PROBLEMS ARE TIMELY AND TYPICALLY TARGETED TOWARD THE ROOT CAUSES OF THOSE PROBLEMS.
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4 THE NRC HAS MANY TOOLS THAT SERVE AS GUIDELINES FOR THE REVIEW AND EVALUATION OF THE POTENTIAL AND ACTUAL EFFECTIVENESS OF LICENSEE MANAGEMENT, SOME OF THESE ARE:
- 1. THE STANDARD REVIEW PLAN SECTION 13.1.1., MANAGEMENT AND TECHNICAL SUPPORT ORGANIZATION.
- 2. ANSI /ANS STANDARD 3.1, "SELECTION QUALIFICATION AND TRAINING 0F NUCLEAR POWER PLANT PERSONNEL."
- 3. NUREG/CR-4125,"GUIDELINES AND WORKBOOK FOR ASSESSMENT OF ORGANIZATION AND ADMINISTRATION OF UTILITIES SEEKING OPERATING LICENSES FOR A NUCLEAR POWER PLANT."
, 4. THE SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP). THE SALP EVALUATION CRITERIA INCLUDES SPECIFIC MANAGEMENT INVOLVEMENT IN , EVALUATED AREAS. THE PERFORMANCE CATEGORY RATINGS ARE ON A THREE-CATEGORY SCALE.
- 5. THE PERFORMANCE INDICATORS (PI) PROGRAM WHICH PROVIDES AN OBJECTIVE VIEW OF SPECIFIC ASPECTS OF OPERATIONAL PERFORMANCE. WHILE MANAGEMENT EFFECTIVENESS IS NOT EVALUATED, TRENDS AND CHANGES IN THE PIs CAN BE INDICATIVE OF MANAGEMENT PERFORMANCE.
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- 6. MANAGEMENT REVIEW MEETINGS WITH CORPORATE AND PLANT MANAGEMENT TO FOLLOW-UP ON THE RESULTS OF THE INSPECTION PROGRAM.
- 7. NRC SENIOR MANAGEMENT itEETINGS ON A SIX-MONTH BASIS TO EVALUATE AVAILABLE INFORMATION RELEVANT TO INDIVIDUAL FLANT PERFORMANCE AND IDENTIFY SIGNIFICANT CHANGES AND THEIR POTENTIAL CAUSES. AUGMENTED NRC ACTIONS ARE DEVELOPED FOR THOSE LICENSEES WITH POOR OR DEGRADING PERFORMANCE IN ORDER TO ENSURE TIMELY CORRECTIVE ACTION.
- 8. NRC DIAGNOSTIC EVALUATIONS AND OTHER STUDIES, FOR EXAMPLE, NUREG-1275.
- 9. REACTIVE TEAM INSPECTIONS EITHER HEADQUARTERS OR REGIONALLY BASED.
- 10. FOR SELECTED PLANTS THE STAFF HAS REQUESTED WRITTEN SELF-EVALUATIONS, E.G., BEAVER VALLEY 2, NINE MILE 2, RIVER BEND, PILGRIM AND PEACH BOTTOM.
THE NRC HAS AND VILL CONTINUE TO USE THESE TYPES OF MANAGEMENT ASSESSMENT GUIDELINES DURING OUR CONTINUING REVIEWS AT PILGRIM FOR EXAMPLE:
- 1. A COMPLETE SALP WILL BE PERFORMED PRIOR TO ANY RESTART DECISION ASSESSING THE PERIOD OF FEBRUARY 1987 TO MAY 1988.
- 2. FREQUENT MANAGEMENT MEETINGS INCLUDING BECO SENIOR MANAGEMENT HAVE BEEN CONDUCTED THROUGHOUT THE SHUT DOWN.
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- 3. NRC SENIOR MANAGEMENT MEETINGS HAVE IDENTIFIED PILGRIM AS A HIGH PRIORITY PLANT WARRANTING CAREP L MONITORING AND CLOSE AGENCY OVERSIGHT.
- 4. THE USE OF AUGMENTED NRC INSPECTIONS, INCLUDING TEAM INSPECTIONS, TO EVALUATE LICENSEE CORRECTIVE ACTION PROGRAMS AND ASSESS THEIR IMPLEMENTATION EFFECTIVENESS, SUCH AS THE DIAGNOSTIC TEAM INSPECTION AND SPECIAL TEAM INSPECTION (AIT) FOLLOWING PLANT SHUT DOWN, A RECENTLY COMPLETED MAINTENANCE TEAM INSPECTION AND THE PLANNED ASSESSMENT TEAM INSPECTION (AITI) TO BE,PERFORMEND FOLLOWING BECO'S RESTART READINESS DECISION.
- 5. THE CONDUCT OF REACTIVE TEAM INSPECTIONS TO ASSESS BECO RESPONSE TO SITE EVENTS SUCH AS THE LOSS OF OFF SITE POWER EVENT.
- 6. BECO WAS REQUESTED IN CAL 86-10 TO CONDUCT A FORMAL ASSESSMENT OF READINESS FOR RESTART OPERATION. TO DATE THEY ARE CONDUCTING A SELF-ASSESSMENT AND ARE PRESENTLY UNDERGOING A REVIEW BY THE INSTITUTE OF NUCLEAR POWER OPERATION (INPO).
- 7. ONGOING INSPECTION REVIEWS INCLUDING RECENT SITE EVENTS WHICH PROVIDE INPUT TO THE CFFECTIVENESS OF MANAGEMENT ACTIONS- AND CONTRIBUTE TO THE OVERALL ASSESSMENT OF SALP,
7 LET ME OVERVIEW THE NRC ASSESSMENT PROCESS BEING USED TO EVALUATE PILGRIM RESTART READINESS. THE HANDOUT PACKAGE PROVIDED CONTAINS AN ATTACHMENT AS THE LAST PAGE WHICH SHOWS THE PROJECTED OVERALL MILESTONES WITHIN THE NRC ASSESSMENT PROCESS, THIS TABLE IS FOR PLANNING PURPOSES ONLY AND DOES NOT CONTAIN ALL THE SUPPORT ACTIVITIES ASSOCIATED WITH EACH MILESTONE. AS YOU CAN SEE, THE NRC PROCESS CONTAINS MANY SUB-ELEMENTS EACH PROVIDING AN INPUT TO THE OV2RALL ASSESSMENT OF BECO CORRECTIVE ACTIONS AND THEIR EFFECTIVENESS. (REVIEW MILESTONES) . (ATTACHMENT 4) ULTIMATELY, AFTER THE STAFF HAS REACHED A POSITION BASED ON A CAREFUL REVIEW 0F THE LICENSEE'S READINESS TO OPERATE, THE COMMISSION WILL BE BRIEFE0 BY Thi STAFF AT A PUBLIC MEETING. BASED ON THAT BRIEFING AND THE INFORMATION PROVIDE 1 FROM THE ASSESSMENT INITIATIVES PREVIOUSLY MENTIONEO, THE NRC COMMISSIONERS WILL MAKE A DECISION WITH RESPECT TO THE RESTART OF PILGRIM. COMMENT PERIOD { I
LAL b l*J Diagnos. CAL 86 ' RFO-7 NRC Ltr Rgs ; SALP 80put SALP NRC SEP Ltr Restart nectart 85-99 Team 10 AIT Start Meeting 86-99 Assess From Plan Iama. PLT Scr Assess 86-41 Plan BEco Rev. 0 l : l l l " g g/g- I4/12/86l I 7/86 i 18/27/86] R1/24/8d g-l
/ l7/8/87l l7/8/87l P/30/87l FEMA '5tP Ltr EP Ltr 5tco 9 PWP. Asc Restart 51te Bu.o EP Re- w/8ECo Prg Self Int to to Plan Work LOOP Muc Re-Rev .SECO BECo sponse Submit Rev. 1 Stop AIT align l :- l 2 l :
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MILESTONE NOTES 2
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24 HOUR OBSERVATION OF SITE OPERATIONS /ACTIVITES USING EXPERIENCED INSPECTORS, AN NRC SUPERVISOR AND SENIOR MANAGER - COPHONWEALTH OBSERVER ALLOWED INSPECTION PROCESS APPROXIMATELY 3 WEEKS WILL COMPARE RESULTS WITH BECO ASSESSMENTS AND PERSUE ANY O!FFERENCES AS MEASURE OF BECO PROCESS EFFECTIVENESS AND MANAGEMENT SELF ASSESSMENT CAPABILITY HOLD PUBLIC MEETING ON RESULTS FOLLOWING THE REPORT BEING ISSUED. r
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MILESTONE NOTES GENERALLY YOU WILL NOTE THAT: THERE IS NO FIRM SCHEDULE IN REGARDS TO RESTART ASSESSMENT OR DECISION SEVERAL NRC MANAGEMENT REVIEWS PLANNED OR IN PROGRESS REGIONAL ADMINISTRATOR, SITE REVIEW AND PUBLIC MEETING PARTICIPATION 4 DIRECTOR OF NRR, SITE REVIEW AND PUBLIC MEETING PARTICIPATION DEPUTY EXECUTIVE DIRECTOR FOR OPERATIONS SITE REVIEW PLANNED COMMISSION INVOLVEMENT: SITE REVIEWS RECENTLY CONDUCTED BY 3 0F 5 COMMISSIONERS 4 0F 5 COMMISSIONERS HAVE VISITED SITE BECO DECISION ON PLANT READINESS IS PRELUDE TO NRC INSPECTION STATEMENT BY SR. VP THAT SELF ASSESSMENT AND THEIR INDEPENDENT REVIEWS SUPPORT RESTART READINESS INCOMPLETE OR ADDITIONAL ACTIONS HAVE BEEN IDENTIFIED - ARE UNDERSTOOD AND SCHEDULCD FOR RESOLUTION . i X,
SUMMARY
ASSESSMENT OF PILGRIM MANAGEMENT AND NRC ASSESSMENT PROCESS COMMENTS FROM FEBRUARY 18, 1988 MEETINGS The commenters are identified numerically and in general, arranged in order of the afternoon session (oral and written), the evening session (oral and written), and those received by mail. The page numbers refer to either the location of the specific comment in the transcript (most cases) or the start of , the commenter's presentation. Commenter Page Number Number Comment
- 1. 12 1. Wants Show Cause Hearing to address:
- Management Issues
- Offsite Emergency Prep: redness
- Containment Concerns 16 3. Restars Plan does not address recent management concerns such as contaminated dirt ,
plie, fire, and LOOP.
- 2. W 4. The Restart Plan and mee+.ing 1- transcript should be placed in Manomet Branch of the Plymouth Public Library. [
- 4. 23 Opinion - Pro Restart I
- 5. 25 Opinion - Pro Restart !
Commenter Page Number Number Comment
- 8. 38 & 1. Management, due to large W staff changes, is untested in the operational phase of Pilgrim.
38 & 2. Has restructuring resulted in W overload of VP-Nuclear?
- 9. 43 & 1. Have management changes prepared W BECo for improved performance?
43 & 2. Increase NRC monitoring after ' W startup. 10, 50 1. The highest NRC officials should , make the Restart decision based upon application of the highest standards of excellence. 51 2. NRC should be extremely alert during any beginning phases of operation.
- 10. 4. NRC has to make greater 54 effort to explain decisions so that the public can ,
understand them.
- 11. 56 Opinion - Pro Restart
- 12. 57 Opinion - Pro Restart l
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Commenter Page Number Number Comment
- 13. 60 2. Management problems resolved prior to Restart.
- 14. 62 Opinion - Pro Restart
- 18. 75 & 1. Wants Adjudicatory Hearing to W address:
- Management issues
- Evacuation planning
- Containment problems 76 & 2. Recent (Nov 87) plant events W indicate it's unsafe to Restart.
- 19. 79 4. Commissioners should make on-site visits to assess health and safety problems.
79 5. Wants opportunity to appear before Commission prior to Restart.
- 20. 9 1. Phrases in Plan indicate organization and operation in enormous transition.
Which actions have been taken? Which are critical to safe plant operation?
- - - - . . , - r- n , , , --- - - g-a ,, -- w --n. e --
Commenter Page Number Number Comment
- 20. 10 2. Management Effectiveness:
(Continued)
- Where are the clearly specified criteria for judging?
- Where is the performance evaluation process defined?
10
- Who besides BECo top management is actually assessing and evaluating operation?
- Who will do it during the Power Ascension Program?
10 3. What are the NRC evaluators qualifications and experience? Will NRC be present throughout
.the Power Ascension process?
Will NRC management performance evaluation guidelines be available onsite?
' 1 1
i l Commenter Page I Number Number Comment i
- 20. 11 4. Requests NRC presence onsite (Continued) through entire process.
(00tage, Power Ascension?)
- 21. 12 & Wants Adjudicatory Hearing to W address:
- Management Issues
- Reactor Safety Issues
- Emergency Planning Issues
- 22. 16 2. Comments due 10 days after invitation.
17 3. Want hearings on:
- Management Issues
- Emergency Response Issues 17 4. Public meeting (2/18) falls in traditional vacation week.
M 5. Additional time needed to review Appendix 11. 23, 2. Meeting held during school vacation week. l { t T~ . ~
.m__, . ~ . - . . , - - . - , , . , _ _ - - - , . . ._ _- -
s I Commenter Page j Number Number Comments
- 24. 22 1. NRC has yet to demonstrate an attitude of understanding fears and concerns of residents.
- 25. 22 & W Opinion - Pro Restart (Technical).
- 26. 27 Opinion - Pro Restart.
- 27. 28 Opinion - Pro Restart.
- 28. 29 Opinion - Pro Restart.
29, 30 & W Opinion - Pro Restart. 32 2. New management has turned around the plant.
- 31. 42 1. Wants Adjudicatory Hearing for:
- Management Issues
- Evacuation Plan Issues
- Containment Issues
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Commenter Page . Number Number Comments
- 31. 41 ' cent plant events reinforce of poor management
- 32. 46 & W 1. erotests meeting forum:
- held during vacation week
- only 10 days notice to review Plan a discoureges public participation by limiting comments to Restart Plan.
- 33. 49 1. Wants Adjudicatory Hearing to address:
- Containment Issues
- Evacuation Time Estimates
- Management Problems W 2. Corporate mission, as stated in the Restart Plan, indicates safety is second to continued Pilgrim operation.
W 3. Restart Pisn provides no criteria by which performance will be measured. W 4. There is no sense of what an cppropriate level of performance is to be for a given task.
Commenter Page Number Number Comments
- 33. W 5. Restart Plan calls for greater (Continued) accountability for results, the focus of which sends the ressage that the bottom line is output not as much how its achieved (e.g., safety values).
W 6. Plan calls for anticipating and planning for routine work and improvements. It should anticipate and plan for the non-routine, since it's the unusual or infrequent event that can cause harm. W 7. It is unclear who is going to assess whose performance and how, who will identify, report to whom and correct problems. f W 8. Restart Plan states that supervisors will be directed to understand the contents of the Plan and will direct the next line of authority to do likewise. How can anyone be directed to understand? 1 l l l l
l Commenter Page Number Number, Comment
- 33. W 9. Infusion of navy-style manage-(Continued) ment is apparent throughout the Plan. How will an authoritative paternalistic style of management work with the civilians who have been doing well?
W 10. The reporting str0cture (navy style, hierarchical authority structure) is usually not responsive to complex unexpected events. W 11. Reorganization concentrates
.too much decision making at the Senior VP Nuclear position.
W 14. Does the fact the new Operations Manager is a former NRC inspector bias the NRC in evaluating operational readiness? W 15. Does anyone in the NRC have a basis of management expertise from which to evaluate organizational capability beyond immediate functional levels?
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Commenter Page Number Number Comment
- 36. 58 2. Plan subject to revision, therefore very little can be accomplished'at this scage of restart prscess'.
58 3. Tne public has no way of knowing how their testimony will be dispositioned. 59 4. Future final meeting is planned to be held in Washington which is net. conducive to puolic participation. 59 5. NRC has not indicated what its criteria or outstanding items are upon which to basing the restart decision and what sort of public participation is planned with regard to such a list.
- 37. ,, 61 Opinion - Pro Restart.
Opinion - Pro Restart.
- 40. 67
- 41. 74 Opinion - Plant should restart for economic reasons.
r' h
Commenter Page Number Number Comment
- 46. 95 4. The location of and preparation time for Restart Plan public review was inadequate.
- 48. 104 2. Failure to notify proper authorities of the unusual event (fire) casts doubts on the company's integrity. ,
- 3. Public meeting was publicity campaign cn the part of NRC and BECo.
- 49. 113 Opinion - Pro Restart.
- 51. M Opinion - Pro Restart.
- 52. M Opinion - Pro Restart.
- 54. M 1. Wants adjudicatory hearing to l
l resolve: I
- Management Issues
- Emergency Preparedness Issues
- Reactor Safety Issues M 4. Will the NRC issue a full report
! on the events of November 7 and 8, 1987, including an assessment of their causes and suggested remedial actions? l l
Commenter Page Number Number Comment
- 55. M 1. Critical of NRC for being lax with BECo.
- 56. M 1. Opposed to restart considering continuing problems involving contaminated dirt pile, fire, and LOOP.
- 57. M Opinion - Pro Restart.
- 58. M Opinion - Pro Restart.
- 59. M Against restart in light of past continuing problems such as contaminated dirt pile.
- 62. M Opinion - Opposed to Restart.
- 63. H Requests Show Cause Hearing.
- 64. M Opinion - Opposed to Restart.
- 65. M Opinion - Pro Restart l
l l 67. M Opinion - Pro Restart. l
- 68. M Opinion - Pro Restart.
i M 1. Cites various examples of management / policy improvements, l.
Commenter Page . Number Number Comments
- 68. M 3. Cites several modifications to (Continued) improve reactor / plant quality /
safety.
- 69. M Opinion - Opposed to Restart.
- 70. H Wants Adjudicatory Hearing to address:
- Management Issues
- Emergency Response Plans
- Reactor Safety Concerns
- 71. M Opinion - opposed to restart with references to management and evacuation plan problems.
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ATTACHMENT 2 4 COMMENT BREAKOOWN h r.
ATTACHMENT 3 REFERENCES
- 1. LETTER OF APRIL 7,1988, L.W. ZECH, JR. TO THE HONORABLE WILLIAM DONALD SCHAEFER.
- 2. NRC MEMORANDUM OF FEBRUARY 1, 1988, F.P. GILLESPIE TO J. M. TAYLOR,
SUBJECT:
STUDY GROUP II RECOMMENDATIONS e,- .m-, ,,,w.-,- -, .,7 %.~ g , .r ,--,--.,--,-,,,,,__y.-r1--,..- -g-c .;---, , wn - ,. - - - , - -+---re-- - wy e
t t RESPONSE TO COMMENTS REGARDING PUBLIC PARTICIPATION IN THE REST'.RT ASSESSMENT PROCESS RECEIVED OURING THE FEBRUARY 18, 1988 PUBLIC MEETING ON THE PILGRIM RESTART PROGRAM JAY M. GUTIERREZ REGIONAL COUNSEL USNRC, REGION I Plymouth, Massachusetts May 11, 1988 l
l l l I. INTRODUCTION AND OVERVIEW I AM PLEASED TO BE HERE TODAY TO RESPOND TO THE COMENTS RECEIVED DURING THE FEBRUARY 18 PUBLIC MEETING REGARDING PUBLIC PARTICIPATION ON THE ISSUE 0F WHETHER OR NOT TO AUTHORIZE RESTART OF PILGRIM. A SUMARY OF THE COMENTS RECEIVED BY THE NRC HAS BEEN PROVIDED AS HANDOUTS TONIGHT. MY PRESENTATION WILL BE INCLUDED IN THE TRANSCRIPT AS A PART OF THE MEETING REPORT DOCUMENTING THIS PUBLIC MEETING. ALTHOUGH THE NRC INVITED THE PUtiLIC TO COMMENT ON THE BOSTON EDISON COMPANY'S CORRECTIVE ACTION PLAN ENTITLED "PILGRIM NUCLEAR POWER STATION RESTART PLAN," AND THE PURPOSE OF TONIGHT'S HEETING IS TO RESPOND TO PUBLIC COMMENTS ON THAT PLAN, THE GIST OF MANY OF THE PUBLIC COMMENTS RECEIVED WERE THAT THE NRC SHOULD HOLD FORMAL ADJUDICATOR't HEARINGS PRIOR TO REACHING A DECISION ON PILGRIM RESTART, THERE WAS AN UNDERLYING THEME TO THE COMMENTS THAT TME NRC'S DECISION THUS FAR NOT TO HAVE FORMAL HEARINGS WAS FUNDAMENTALLY UNFAIR. THEREFORE, THE NRC THOUGHT IT WAS APPROPRIATE TO SPEND SOME TIME TONIGHT EXPLAINING THE PROCESS IT HAS UTILIZED IN SOLICITING PUBLIC INPUT INTO THE PILGRIM RESTART DECISION AND WHY WE THINK THAT PROCESS PROVIDES AMPLE OPPORTUNITY FOR PUBLIC PARTICIPATION. l LET IIE STRESS AT THE BEGINNING OF MY TALK 2 POINTS: FIRST THAT IT APPFARS THE l PREMISE OF THE PUBLICS CONCEM FOR AN ADJUDICATORY HEARING IS THAT WITHOUT SUCH A HEARIWG THE PUBLIC WILL BE SHUT OUT OF THE PROCESS. THIS IS NOT l 1 l
2 CORRECT. THE NRC RECOGNIZES THE INTENSE PUBLIC INTEREST IN THE PILGRIM ISSUE AND AS A RESULT OF THAT INTEREST HAS OPENED UP THE DECISION MAKING PROCESS IN RECOGNITION OF THIS PUBLIC INTEREST. SECOND, ALTHOUGH PUBLIC INPUT IS ENCOURAGED BY THE NRC, YOU ALL MUST REALIZE THAT BY LAW THE DECISION WHETHER OR NOT PILGRIM CAN OPERATE IN A MANNER SO AS TO PROTECT THE RADIOLOGICAL HEALTH AND SAFETY OF THE PUBLIC IS THE NRC'5 DECISION. HAVING MADE THESE 2 POINTS LET ME TURN TO THE PUBLIC COMMENTS MADE DURING THE FEBRUARY 18 MEETING REQUESTING A HEARING. THESE COMMENTS TOOK h/NY FORMS: SOME PERSONS REQUESTED A SHOW CAUSE PROCEEDING, OTHERS AN EVIDENTIARY HEARING, STILL OTHERS REFERENCED 2.206 0F THE NRC'S REGULATIONS. WHAT SEEMS CLEAR IS THAT THERE IS A GREAT DEAL OF CONFUSION RELATIVE TO WHAT IS INVOLVED IN A FORMAL HEARING, WHEN SOMEONE IS ENTITLED TO ONE, WHY THE NRC HAS THUS FAR NOT INITIATED SUCH A HEARING, WHAT RIGHTS 10 CFR 2.206 DOES AND DOES NOT AFFORD THE PUBLIC, AND WHAT PROCESS IS BEING UTILIZED AT PILGRIM TO ASSURE PUBLIC INPUT IS RECEIVED AND CONSIDERED. IN AN EFFORT TO CLEAR UP SOME OF THAT CONFUSION, LET ME ADDRESS: (1) WHAT CONSTITUTES A FORMAL ADJUDICATION AND WHAT OPPORTUNITIES EXIST FOR SUCH HEARINGS; (2) WHAT IS A REQUEST FOR ENFORCEMENT ACTIONS UNDER 2.206 AND HOW DOES IT RELATE TO THE OVERALL NRC INSPECTION AND ENFORCEMENT PROGRAM; AND (3)
3 THE PROCESS THAT IS BEING UTILIZED TO ASSURE PUBLIC PARTICIPATION IN THE NRC RESTART ASSESSMENT PROCESS RELATED TO PILGRIM. II. WHAT CONSTITUTES A FORMAL ADJUDICATION AND WHAT OPPORTUNITIES EXIST FOR SUCH HEARINGS A FORMAL ADJUDICATORY HEARING IS A TRIAL-TYPE HEARING WHERE SPECIFIC PARTIES, WHO HAVE BEEN ADMITTED TO THE PROCEEDING AFTER DEMONSTRATING A CERTAIN LEGAL INTEREST AND STANDING IN A CASE, PRESENT EVIDENCE ON ADMITTED CONTENTIONS. TRIAL-TYPE HEARINGS ARE THOSE PROCEEDINGS WHERE PARTIES, TYPICALLY THROUGH THEIR LAWYERS, PRESENT EVIDENCE TO A JUDGE OR, IN THE CASE OF THE NRC, TO THE ATOMIC SAFETY AND LICENSING BOARD (THE ASLB). IT IS IMPORTANT TO NOTE THAT MEMBERS OF THE GENERAL PUBLIC ARE NOT FREE TO PARTICIPATE IN FORMAL ADJUDICATIONS WITHOUT MEETING MANY OBLIGATIONS PLACED UPON THEM BY THE NUMEROUS RULES THAT GOVERN SUCH PROCEEDINGS. A HEMBER OF THE PUBLIC WHO WISHES TO INTERVENE IN A FORMAL ADJUDICATORY HEARING MUST FIRST SET FORTH, IN A PETITION FOR LEAVE TO INTERVENE, HIS INTEREST IN THE PROCEEDING AND DEMONSTRATE HOW THAT INTEREST MAY BE AFFECTED BY NRC ACTION. THE PETITION MUST SET FORTH (1) THE NATURE OF THE PETITIONER'S RIGHT UNDER THE ATOMIC ENERGY ACT TO BE MADE A PARTY TO THE PROCEEDING, (2) THE NATURE AND EXTENT OF THE INTEREST THAT MAY BE AFFECTED BY THE PROCEEDING, AND (3) THE EFFECT OF ANY ORDER WHICH KAY BE ENTERED IN THE PROCEEDING ON THE PETITIONER'S INTEREST. MORE0VER, THE PETITIONER TO INTERVENE MUST FILE A SUPPLEMENT TO HIS PETITION CONTAINING HIS CONTENTION (S) AND THE BASIS FOR THOSE CONTENTIONS. CONTENTIONS ARE FACTUAL
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4 ASSERTIONS WHICH, IF PROVEN, WOULD ARGUE IN FAVOR OF CERTAIN ACTIONS BY THE HEARING BOARD. THE SCOPE OF THE FORMAL HEARING IS LIMITED TO THE PROPOSED ACTION FOR WHICH THE HEARING WAS ESTABLISHED. IF THIS SOUNDS COMPLEX - IT IS, MORE SIMPLY PUT - THE PUBLIC IS CONSTRAINED TO ADDRESS THE ADMITTED CONTE'NTIONS AND IS NOT FREE TO EITHER STATE OR HAVE CONSIDERED WHATEVER OTHER ISSUES MAY BE OF CONCERN. ONCE CONTENTIONS ARE ADMITTED AND DISCOVERY AND OTHER PRE-HEARING ACTIVITY HAS OCCURRED, A HEARING IS HELD. THE PARTIES TO THE HEARING ARE REQUIRED TO SUBMIT DIRECT TESTIMONY IN WRITTEN FORM AND SERVE COPIES OF SUCH PREPARED WRITTEN TESTIMONY ON ALL PARTIES. ATTORNEYS TYPICALL( CONDUCT DIRECT OR CROSS-EXAMINATION ON BEHALF OF A PARTY. UNDER CERTAIN LIMITED CONDITIONS NON-LAWYERS MAY PARTICIPATE IN THE QUESTIONING. MEMBERS OF THE GENERAL PUBLIC, NOT ADMITTED AS PARTIES, ARE NOT FREE TO PARTICIPATE IN SUCH HEARINGS. AT TIMES, AND AT THE DISCRETION OF THE ASLB, THE GENERAL PUBLIC IS PERMITTED TO MAKE LIMITED APPEARANCE STATEMENTS, BUT THESE STATEMENTS ARE NOT EVIDENCE IN THE ADJUDICATION AND CANNOT BE USED AS A BASIS FOR A DECISION IN THE CASE. THE TRANSCRIPT OF TESTIMONY AND THE EXHIBITS, TOGETHER WITH ALL OF THE PAPERS AND REQUESTS FILED IN A PROCEEDING, CONSTITUTE THE RECORD FOR THE DECISION. THERE ARE CERTAIN WELL DEFINED ACTIONS DURING THE NRC PROCESS WHEN A MEMBER OF THE PUBLIC IS GIVEN AN OPPORTUNITY FOR A FORMAL ADJUDICATORY HEARING. THE TWO I PRINCIPAL OPPORTUNITIES FOR A HEARING IN THE PAST RELATIVE TO PILGRIM HAVE BEEN l
5 PRIOR TO AN NRC DECISION TO PERMIT PLANT CONSTRUCTION (A CONSTRUCTION PERMIT HEARING) AND PRIOR TO INITIAL OPERATION (OPERATING LICENSE HEARING). IN j ADDITION, AND MORE IMPORTANTLY IN THE CASE OF PILGRIM, ONCE A PLANT HAS A LICENSE TO OPERATE ITS FACILITY, EACH TIME AN AMENDHENT OR CHANGE TO THAT LICENSE IS SOUGHT, AN INDIVIDUAL HAS CERTAIN HEARING RIGHTS. AT THE TIME A LICENSEE REQUESIS AN AMENDMENT, IT MUST NOTIFY THE STATE IN WHICH ITS FACILITY IS LOCATED OF ITS REQUEST BY PROVIDING THE STATE WITH A COPY OF ITS APPLICA-TION. THE LICENSE AMENDMENT REQUEST IS ALSO NOTICED FOR PUBLIC INFORMATION IN THE FEDERAL REGISTER AND PLACED IN THE LOCAL PUBLIC DOCUMENT ROOM. THE STAFF THEN MUST MAKE A DECISION WHETHER OR NOT TO ISSUE THE LICENSE AMENDMENT BEFORE OR AFTER AN OPPORTUNITY FOR A FORMAL ADJUDICATION; BUT IN ANY EVENT AN OPPOR-TUNITY FOR A FORMAL ADJUDICATION IS PROVIDED. THE SCOPE OF THE HEARING IS LIMITED TO THE SUBJECT OF THE LICENSE AMENDMENT. TO SUMMARIZE: THE AB0VE OUTLINED PROCESS TYoICALLY OCCURS WHEN THE NRC IS CONSIDERING EITHER THE ISSUANCE OF AN INITIAL LICENSE, OR A CHANGE TO AN EXISTING LICENSE; THE PROCESS RARELY TAKES LESS THAN ONE TO TWO YEARS AND IN A FEW CASES HAS EXTENDED OVER SEVERAL YEARS; AND IT IS THIS TYPE OF HEARING THAT VARIOUS PUBLIC COMMENTERS REQUESTED IN RESPONSE TO THE NRC'S REQUEST FOR COMMENTS ON THE BOSTON EDISON RESTART PLAN. FINALLY, NUMEROUS COMMONWEALTH OFFICIALS HAVE REQUESTED SUCH AN ADJUDICATORY HEARING BE INITIATED AS PART OF A REQUEST FOR ENFORCEMENT ACTION UNDER THE PROVISIONS OF 10 CFR 2.206 AND THEREFORE THAT PROCESS ALSO WARRANTS SOME EXPLANATION.
6 III. WHAT IS A 2.206 PETITION AND HOW IS IT RELATED TO NRC ENFORCEMENT ACTION AFTER RECEIVING A LICENSE, AN NRC LICENSEE SUCH AS PILGRIM REMAINS SUBJECT TO CONTINUING NRC REVIEW AND OVERSIGHT UNDER THE NRC'S INSPECTION AND ENFORCEMENT PROGRAM. THIS PROGRAM IS AIMED AT ENSURING CONTINUED PROTECTION OF THE PUBLIC HEALTH AND SAFETY THROUGH COMPLIANCE WITH THE COMMISSION'S REQUIREMENTS. THE NRC HAS A WIDE RANGE OF ENFORCEMENT REMEDIES WITH WHICH TO ACCOMPLISH THIS GOAL. ENFORCEMENT ACTIONS AVAILABLE TO THE NRC INCLUDE CONFIRMATORY ACTION LETTERS DOCUMENTING iHE NRC'S UNDERSTANDING OF LICENSEE INITIATED ACTION, NOTICES OF VIOLATION, CIVIL PENALTIES, AND ORDERS MODIFYING, SUSPENDING, OR REV0 KING LICENSES. A MORE DETAILED EXPLANATION OF NRC'S ENFORCEMENT PROGRAM CAN BE FOUND IN THE NRC POLICY STATEMENT ON ENFORCEMENT, 10 C.F.R. PART 2, APP. C. FOR THE MOST PART, ENFORCEMENT ACTION IS INITIATED BY THE NRC. HOWEVER, THERE IS AN AVENUE FOR THE PUBLIC TO INITIATE NRC ENFORCEMENT ACTION, THAT IS A 2.206 PETITION. A 2.206 PETITION MUST SPECIFY NOT ONLY THE RELIEF OR ENFORCE-MENT ACTION REQUESTED, BUT ALSO "... SET FORTH THE FACTS THAT CONSTITUTE THE BASIS FOR SUCH REQUEST." THE GIST OF THE PETITIONS FILED IN PILGRIM BY VARIOUS OFFICIALS OJ THE COMMONWEALTH IS THAT THE NRC SHOULD INITIATE BY A SHOW CAUSE ORDER FORilAL ADJUDICATORY HEARINGS RELATIVE TO THE MANAGEMENT, EMERGENCY PREPAREDNESS AND CONTAINMENT ISSUES AT PILGRIM. THE BASIS FOR THESE PETITIOMS WAS INFORMATION ALREADY KNOWN TO THE NRC AND FOR THE MOST PART TAKEN FROM NRC DOCUMENTS.
7 IF THE DIRECTOR OF THE REVIEWING OFFICE OF THE NRC FINDS MERIT IN THE REQUEST FOR ENFORCEMENT ACTION, HE OR SHE MAY SELECT THE APPROPRIATE ACTION TO TAKE FROM THE WIDE RANGE OF ENFORCEMENT OPTIONS IDENTIFIED AB0VE. ONE SUCH OPTION, i AND THE ACTION REQUESTED BY VARIOUS OFFICIALS WITHIN THE COMMONWEALTH, IS ORDERING THE LICENSEE UNDER 10 C.F.R. 2.20 TO SHOW CAUSE WHY THE NRC SHOULD NOT "INSTITUTE A PROCEEDING TO MODIFY, SU5 PEND, OR REV0KE A LICENSE OR FOR SUCH OTHER ACTION AS MAY BE PROPER." IF GRANTED, A 2.202 ORDER CHIEFLY LISTS THE ALLEGED REGULATORY VIOLATIONS OR OTHER FACTS THAT ARE GROUNDS FOR THE PROPOSED ENFORCEMENT ACTION, INFORMS THE LICENSEE THAT IT MU3T FILE AN ANSWER TO THE ALLEGATIONS, AND INFORMS THE LICENSEE THAT IT MAY REQUEST A HEARING ON THE ALLEGATIONS. UNDER CERTAIN CIRCUMSTANCES, THE ENFORCEMENT ACTION MAY BE TAKEN IMMEDIATELY. IF, ON THE OTHER HAND, THE DIRECTOR DETERMINES THAT NO SHOW CAUSE PROCEEDING OR OTHER ENFORCEMENT ACTION IS WARRANTED, HE MUST NOTIFY THE PERSON WHO SUBMITTED THE 2.206 REQUEST OF THAT DECISION IN WRITING, AND PROVIDE A WRITTEN STATEMENT OF REASONS FOR THAT DECISION. THIS HAS OCCURRED, IN PART, RELATIVE TO SENATOR GOLDEN'S REQUEST AND THE DIRECTOR'S DECISION IS STILL PENDING RELATIVE TO THE PETITION OF GOVERNOR DUKAKIS AND ATTORNEY GENERAL SHANNON. GOVERNOR DUKAKIS AND ATTORNEY GENERAL SHANNON HAVE BEEN NOTIFIED, HOWEVER, THAT THUS FAR THE NRC WILL NOT ISSUE AN IMMEDIATELY EFFECTIVE ORDER AGAINST PILGRIM SUSPENDING ALL ACTIVITY LEADING TO RESTART. TO SUMMARIZE: THE FILING OF A 2.206 PETITION DOES NOT FEQUIRE THE NRC TO HOLD FORMAL EVIDENTIARY HEARINGS, AND THE NRC IS FREE TO U3E 0THFR ENFORCEMENT TOOLS
1
- 1 8
IN RESPONSE TO THE ISSUES RAISED IN A 2.206 PETITION. IN THE CASE OF THE TWO PETITIONS CURRENTLY PENDING RELATIVE TO PILGRIM, THE NRC HAS TAKEN THE POSITION THAT ALTHOUGH MANY OF THE ISSUES SET FORTH IN THE PETITIONS ARE VALID, AND ARE THE VERY SAME ISSUES THAT THE NRC IS ADDRESSING IN DECIDING WHETHER OR NOT TO PERMIT RESTART, THE FACTS S0 FAR DEVELOPED 00 NOT WARRANT ISSUANCE OF AN ORDER ESTABLISHING A SHOW CAUSE PROCEEDING SINCE THE FACILITY IS ALREADY VOLUNTARILY SHUTDOWN, THE NECESSARY CORRECTIVE ACTIONS ARE BEING VOLUNTARILY IMPLEMENTED BY THE LICENSEE, A CONFIRMATORY ACTION LETTER HAS BEEN ISSUED BY THE NRC, THE LICENSEE IS ADDRESSING THE ISSUES RAISED AS A BASIS FOR THE PETITIONS AND PILGRIM WILL NOT BE PERMITTED TO RESTART BY THE NRC UNTIL THE IDENTIFIED. ISSUES ARE ADDRESSED TO THE SATISFACTION OF THE NRC. IV. PROCESS BEING UTILIZED AT PILGRIM TO ASSURE PUBLIC INPUT IS RECEIVED AND CONSIDERED AGAINST THIS BACKGROUND OF REQUESTS FOR FORMAL ADJUDICATORY PROCEEDINGS, LET ME BRIEFLY DESCRIBE THE PROCESS CHOSEN TO ASSURE PUBLIC INPUT INTO THE PILGRIM RESTART DECISION. THIS PROCESS WILL BE MORE FULLY EXPLAINED BY MR. COLLINS IN HIS PRESENTATION. THE NRC IS FULLY AWARE OF PUBLIC CONCERN REGARDING THE RESTART OF THE PILGRIM FACILITY AND HAS GCNE TO UNUSUAL LENGTHS TO ASSURE BROAD PUBLIC PARTICIPATION IN THE RESTART DECISION. THE NRC WILL CONSIDER ANY SAFETY ISSUE BROUGHT TO ITS ATTENTION BY A MEMBER OF THE PUBLIC. THERE IS NO NEED TO WAIT FOR MEETINGS SUCH AS TONIGHT TO COME TO THE NRC IF YOU HAVE A SAFETY ISSUE RELATIVE TO PILGRIM. IT SHOULD BE CONSIDERED THE PUBLIC'S AND THE COMMONWEALTH OF HASSACHUSETTS' RESPONSIBILITY TO BRING TO THE NRC ISSUES IT BELIEVES TO BE SAFETY SIGNIFICANT REGARDLESS OF PENDING REQUESTS FOR FORMAL HEARINGS.
9 THE NRC STAFF AND LOCAL OFFICIALS IN MASSACHUSETTS HAVE HAL MANY DISCUSSIONS 1 RELATED TO PILGRIM. THIS DIALOGUE HAS INCLUDED AT ICAST THREE PUBLIC MEETINGS l WITH THE PLYMOUTH BOARD OF SELECTMEN, AS WELL A5 MEETINGS WITH THE PLYMOUTH CHAMBER OF COMMERCE, THE DUXBURY BOARD OF SC'ECTMEN, THE MASSACHUSETTS JOINT COMMITTEE ON ENERGY, THE MASSACHUSETTS LEGISLATIVE COMMITTEE ON THE INVESTIGATION AND STUDY OF THE PILGRIM STATION, THE TOWN OF PLYMOUTH ADVISORY COMMITTEE ON NUCLEAR MATTERS, AND OTHERS. THE NRC STAFF PARTICIPATED IN A PUBLIC FORUM SPONSORED BY THE DUXBURY BOARD OF SELECTMEN ON THE PILGRIM SITUATION AT THE DUXBURY HIGH SCHOOL ON OCTOBER 29, 1987. HORE TO THE ISSUE OF TODAY, A MEETING WAS HELD ON FEBRUARY 18, 1988 TO RECEIVE PUBLIC COMMENTS ON THE BOSTON EDISON RESTART PLAN 03D THE PANEL MENBERS THAT FOLLOW HE WILL ADDRESS SPECIFIC PUBLIC COMMENTS MADE AT THAT MEETING. REPRESENTATIVES FROM SOME OF THE AB0VE GROUPS ALSO HAVE PARTICIJATED IN NRC REGION I MANAGEMENT MEETINGS DEALING WITH THE PILGRIM FACILITY, INCLUDING THE SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP) MEETING HELD ON MAY 7, 1987. ON OCTOBER 8, 1987, THE NRC MET WITH REPRESENTATIVES OF THE COMMONWEALTH OF MASSACHUSETTS IN OUR REGION I 0FFICE. THIS MEETING, WHICH WAS OPEN TO THE PUBLIC, WAS HELD TO DISCUSS AGENDA ITEMS PROPOSED BY THE COM40NWEALTH, INCLUDING EMERGENCY PREPAREDNESS ISSUES, THE STATUS OF VARIOUS NRC TECHNICAL REVIEWS, AND INSPECTION ACTIVITIES EXPECTED IN THE NEXT FEW MONTHS.
1 10 AS THE NRC PROCEEDS WITH DELIBERATIONS REGARDING WHETHER 0R NOT TO AUTHORIZE RESTART OF THE PILGRIM REACTOR, ADDITIONAL PUBLIC MEETINGS WILL BE HELD REGARDLESS OF THE RESOLUTION OF THE EVIDENTIARY HEARINGS THAT HAVE BEEN REQUESTED. THESE MEETINGS WILL PROVIDE OPPORTUNITY FOR PUBLIC COMENT. OF EQUAL IMPORTANCE IS THAT WHEN THE NRC MEETS WITH BOSTON EDISON, TPESE MEETINGS ARE ALSO OPEN TO PUBLIC OBSERVATION IN ACCORDANCE WITH THE NRC'S OPEN MEETING POLICY, AND THE NRC STAFF IS RECEPTIVE TO CO MENTS AFTER THE MEETINGS BY MEMBERS OF THE PUBLIC WHO ATTEND. MR. COLLINS WILL OUTLINE KEY MEETINGS PLANNED IN HIS PRESENTATION. OTHER PUBLIC MEETINGS BEYOND THOSE DISCUSSED BY MR. COLLINS, WILL BE HELD AS CIRCUMSTANCES WARRANT. THESE MEETINGS WILL BE ANNOUNCED PURSUANT TO NRC STAFF POLICY ON OPEN MEETINGS. IN CONCLUSION, LET ME EMPHASIZE;
- 1. FORMAL ADJUDICATORY HEARINGS ARE NOT THE ONLY WAY FOR PUBLIC INPUT INTO THE NRC'S DECISION MAKING PROCESS, AND PLACE HEAVY BURDENS ON ADMITTED PARTIES;
- 2. THE NRC IS NOT REQUIRED TO HOLD SUCH HEARINGS IN RESPONSE TO REQUESTS l
l TO TAKE ENFORCEMENT ACTION UNDER 2.206;
- 3. THE STAFF ELECTFD TO OPEN THE NRC DELIBERATION PROCESS ON WHETHER OR NOT TO PERMIT RESTART OF PILGRIM TO THE PUBLIC, OUT OF RECOGNITION OF l THE INTENSE PUBLIC INTEREST IN THIS ISSUE; 1
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- 4. THE NRC HAS OPENED THE PROCESS BY SEEKING PUBLIC COMMENTS AT KEY TIMES IN THE PROCESS AND HAVING AN OPEN POLICY TO PERMIT PUBLIC ATTENDANCE AT MEETINGS BETWEEN THE NRC AND BECO.
THANK YOU FOR YOUR ATTENTION, AT THIS TIME I WOULD LIKE TO INTRODUCE DR. RONALD BELLAMY, CHIEF OF THE EMERGENCY PREPAREDNESS AND RADIOLOGICAL PROTECTION BRANCH AT NRC, REGION I, WHO WILL ADDRESS PUBLIC CO M ENTS ON EMERGENCY PREPAREDNESS AND RADIOLOGICAL MONITORING.
l THANK YOU. I WILL ADDRESS 2 DISTINCT AREAS IN MY REMARKS AND RESPONSE TO THE COMMENTS RECEIVED DURING THE FEBRUARY 18, 1988 MEETING. THESE AREAS ARE EMERGENCY PREPAREDNESS AND ENVIRONMENTAL MONITORING. I WILL ADDRESS EMERGENCY PREPAREDNESS FIRST. EMERGENCY PREPAREDNESS RONALD R. BELLAMY, CHIEF FACILITIES RADIOLOGICAL SAFETY AND SAFEGUARDS BRANCH U. S. NUCLEAR REGULATORY COMMISSION MAY 11, 1988 BEFORE ADDRESSING SPECIFIC CONCERNS RAISED AT THE FEBRUARY MEETING, I'D LIKE TO PROVIDE THE REGULATORY FRAMEWORK FOR EMERGENCY PREPAREDNESS. THE NRC HAS RECOGNIZED THE IMPORTANCE OF EMERGENCY PREPAREDNESS IN PROTECTING THE HEALTH AND SAFETY OF THE PUBLIC AND HAS, OVER THE PAST SEVERAL YEARS, IMPLEMENTED SPECIFIC REGULATIONS AND REGULATORY GUIDANCE. SIGNIFICANT INTER-AGENCY C00PERATION, SPECIFICALLY WITH THE FEDERAL EMERGENCY MANAGEMENT AGENCY, HAS RESULTED IN DEFINITIVE CRITERIA BEING PUBLISHED. I WANT TO ENSURE THAT YOU ARE AWARE OF THESE REGULATIONS AND CRITERIA, AND HOW THE NRC WILL USE THIS PUBLISHED GUIDANCE IN RESTART DELIBERATIONS FOR THE PILGRIM STATION. TITLE 10 0F THE CODE OF FEDERAL REGULATIONS CONTAINS APPENDIX E, ENTITLED "EMERGENCY PLANNING AND PREPAREDNESS FOR PRODUCTION AND UTILIZATION FACILITIES." THIS APPENDIX ESTABLISHES MINIMUM REQUIREMENTS FOR EMERGENCY PLANS FOR USE IN ATTAINING AN ACCEPTABLE STATE OF EMERGENCY PREPAREDNESS. SPECIFIC REFERENCE IS MADE TO A DOCUMENT DEVELOPED JOINTLY BY THE NRC AND FEDERAL EMERGENCY MANAGEMENT AGENCY, KNOWN AS NUREG-0654, "CRITERIA FOR PREPARATION AND EVALUATION OF RADIOLOGICAL EMERGENCY RESPONSE PLANS AND i J
r. 2 PREPAREDNESS IN SUPPORT OF NUCLEAR POWER PLANTS." THE PLANNING STANDARDS IN NUREG-0654, AS SPECIFICALLY REFERENCED IN THE REGULATIONS, ARE REQUIRED TO BE ADDRESSED IN THE EMERGENCY PLANS. THESE 16 PLANNING STANDARDS ARE: A. ASSIGNMENT OF RESPONSIBILITY (ORGANIZATION CONTROL)
- 3. ONSITE EMERGENCY ORGANIZATION C. EMERGENCY RESPONSE SUPPORT Ato RESOURCES D. EMERGENCY CLASSIFICATION SYSTEM E. NOTIFICATION METHODS AND PROCEDURES F. EMERGENCY COMMUNICATIONS G. PUBLIC EDUCATION AND INFORMATION H. EMERGENCY FACILITY AND EQUIPMENT I. ACCIDENT ASSESSMENT J. PROTECTIVE RESPONSE
3 K. RADIOLOGICAL EXPOSURE CONTROL L. MEDICAL AND PUBLIC HEALTH SUPPORT M. RECOVERY AND REENTRY PLANNING AND POST-ACCIDENT OPERATIONS N. EXERCISES AND DRILLS
- 0. RADIOLOGICAL EMERGENCY RESPONSE TRAINING; AND FINALLY P. RESPONSIBILITY FOR THE PLANNING EFFORT: DEVELOPMENT, PERIODIC REVIEW AND DISTRIBUTION OF EMERGENCY PLANS IT IS IMPORTANT TO REALIZE THAT THE G0AL OF EMERGENCY PREPAREDNESS IS TO PREPARE ONSITE AND OFFSITE PERSONNEL, AND THE PUBLIC, FOR A VARIETY OF WAYS OF DEALING WITH NUCLEAR EMERGENCIES. IT IS NECESSARY TO BE PREPARED FOR A RANGE OF PROTECTIVF. ACTIONS. IT IS NOT APPROPRIATE TO DEVELOP SPECIFIC PLANS FOR EVERY CONCEIVABLE ACCIDENT, BUT TO ADDRESS A SPECTRUM 0F ACCIDENTS, TO GIVE FORETHOUGHT TO THE ACTIONS REQUIRED, AND TO KEEP IN MIND THE OVERALL OBJECTIVE OF PROVIDING EMERGENCY PLANS, PROCEDURES, AND TRAINING TO ACHIEVE DOSE SAVINGS FOR A SPECTRUM 0F ACCIDENTS.
AN0fHER SPECIFIC PART OF 10 CFR PART 50 IS ENTITLED "EMERGENCY PLANS," AND THIS IS 10 CFR 50.47. THIS REGULATION IDENTIFIES THE NRC AS THE REGULATORY AUTHORITY THAT IS REQUIRED TO MAKE A FINDING ON EMERGENCY PREPAREDNESS PRIOR l l TO THE ISSUANCE OF AN OPERATING LICENSE FOR A NUCLEAR POWER REACTOR. THE
4 REQUIRED FINDING IS THAT "THERE IS REASONABLE ASSURANCE THAT ADEQUATE l PROTECTIVE MEASURES CAN AND WILL BE TAKEN IN THE EVENT OF-.A RADIOLOGICAL EMERGENCY." THE NRC, HOWEVER, DOES NOT OBTAIN INFORMATION TO MAKE THIS CONCLUSION IN A VACUUM. WE CONSIDER, FIRST, THE REVIEW 0F FEDERAL EMERGENCY MANAGEMENT AGENCY, AND THAT AGENCY'S FINDINGS AS TO WHETHER STATE AND LOCAL PLANS ARE ADEQUATE, SECOND, WHETHER THERE IS A REASONABLE ASSURANCE THAT THEY CAN BE IMPLEMENTED, AND TdIRD, THE NRC ASSESEENT AS TO WHETHER THE APPLICANT'S ONSITE EMERGENCY PLANS ARE ADEQUATE AND WHETHER THEY CAN BE IMPLEMENTED. THE ULTIMATE DECISION AS TO WHETHER THE STATE OF EMERGENCY PREPAREDNESS IS ADEQUATE TO PROTECT PUBLIC HEALTH AND SAFETY RESTS WITH THE NRC. AT THE PUBLIC MEETING HELD FEBRUARY 18, 1988, THERE WAS A CONCERN WITH THE NRC REVIEW PROCESS, AND ITS BASES, FOR EMERGENCY PREPAREDNESS. I HAVE ADDRESSED GENERALLY THE CRITERIA FOR THIS REVIEW. ONE SPECIFIC CONCERN DEALT WITH THE ENERGENCY ACTION ' EVELS. NUREG-06S4 SPECIFIES THESE EMERGENCY ACTION LEVELS IN INCREASING LEVEL 0F SIGNIFICANCY AND REQUIRED ACTIONS, AS
- 1. NOTIFICATION OF UNUSUAL EVENT
- 2. ALERT
- 3. SITE AREA EMERGENCY
- 4. GENERAL EMERGENCY A GRADATION IS PROVIDED TO ASSURE FULLER RESPONSE PREPARATIONS FOR MORE SERIOUS INDICATORS.
i
S TO GIVE YOU A BETTER UNDERSTANDING OF THESE CLASSES:
- 1. FOR A NOTIFICATION OF UNUSUAL EVENT THE LOWEST OF THE EVENT CLASSIFICATION, UNUSUAL EVENTS ARE IN PROCESS OR HAVE OCCURRED WHICH INDICATE A POTENTIAL DEGRADATION OF THE LEVEL OF SAFETY OF THE PLANT.
NO RELEASES OF RADI0 ACTIVE MATERIAL REQUIRING OFFSITE RESPONSE OR MONITORING ARE EXPECTED UNLESS FURTHER DEGRADATION OF SAFETY SYSTEMS OCCURS. PERSONNEL ARE BROUGHT TO A STATE OF READINESS, PREPARED FOR ANY FURTHER RESPONSE. RELATIVELY MINOR EVENTS CAUSE THE DECLARATION OF AN UNUSUAL EVENT, SUCH AS THE TRANSPORTATION OF A CONTAMINATED INJURED INDIVIDUAL FROM THE SITE TO AN OFFSITE HOSPITAL, OR REACTOR COOLANT TEMPERATURES OR PRESSURE OUTSIDE EXPECTED VALUES.
- 2. FOR AN ALERT, EVENTS ARE IN PROCESS OR HAVE OCCURRED WHICH INVOLVE i AN ACTUAL OR POTENTIAL SUBSTANTIAL DEGRADATION OF THE LEVEL OF SAFETY OF THE PLANT. ANY RELEASES ARC IXPECTED TO BE LIfilTED TO SMALL FRACTIONS OF THE EPA PROTECTIVE ACTION GUIDELINES. THIS SECOND STAGE EMERGENCY ACTION LEVEL WOULD BE DECLARED IF HURRICANE l
WINDS WERE PRESENT NEAR THE SITE, OR RADIOLOGICAL EFFLUENTS WERE 10 TIMES GREATER THAN ALLOWABLE INSTA"TANE0VS LIMITS. 1 I l l
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- 3. FOR A SITE AREA EMERGENCY, EVENTS ARE IN PROCESS OR HAVE OCCURRED WHICH INVOLVE ACTUAL OR LIKELY MAJOR FAILURES OF SYSTEMS OR EQUIPMENT NEEDED FOR PROTECTION OF THE PUBLIC. ANY RELEASES ARE NOT EXPECTED TO EXCEED EPA PROTECTIVE ACTION GUIDELINES EXCEPT NEAR THE SITE BOUNDARY. A STEAM LINE BREAK OUTSIDE CONTAINMENT, WITHOUT BEING ISOLATED, OR SEVERE DAMAGE TO SAFE SHUTDOWN EQUIPMENT FROM MISSILES OR EXPLOSIONS ARE EXAMPLES OF SITE AREA EMERGENCIES.
- 4. FOR A GENERAL EMERGENCY, EVENTS ARE IN PROCESS OR HAVE OCCURRED WHICH INVOLVE ACTUAL OR IMMINENT SUBSTANTIAL CORE DEGRADATION OR MELTING WITH POTENTIAL FOR LOSS OF CONTAINMENT INTEGRITY. RELEASES CAN BE REASONABLY EXPECTED TO EXCEED EPA PROTECTIVE ACTION GUIDELINES OFFSITE FOR MORE THAN THE IMMEDIATE SITE AREA. A GENERAL EMERGENCY WOULD BE DECLARED IF A LOSS OF 0FFSITE POWER OCCURS PLUS FAILURE OF REACTOR SHUTDOWN SYSTEMS, OR EFFLUENT MONITOR DETECT SIGNIFICANT RADIATION LEVELS AT THE SITE BOUNDARY UNDER ACTUAL METEOROLOGICAL CONDITIONS. .
BOSTON EDISON IS REQUIRED TO, AND HAS BEEN CCNDUCTING TRAINING, ON HOW VARIOUS PLANT EVENTS LEAD TO THE DECLARATION OF THESE EMERGENCY ACTION LEVELS. THE NRC WILL INSPECT THIS AREA, AND ENSURE THAT PLANT OPERATION CAN APPROPRIATELY CATEGORIZE PLANT EVENTS. A SECOND SPECIFIC CONCERN RAISED DURING THE EARLIER PUBLIC MEETING DEALT WITH ALERT AND NOTIFICATION OF THE PUBLIC. APPENDIX E, REFERENCED EARLIER, STATES THAT PUBLIC EMERGENCY PREPAREDNESS PLANNING INFORMATION SHALL BE GIVEN TO THE s _ - . _ _ _ __ _ __ , ___ __
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PUBLIC WITHIN THE 10 MILE ON AN ANNUAL BASIS. THIS INFORMATION SHALL INCLUDE METHODS AND TIMES REQUIRED FOR PUBLIC NOTIFICATION AND THE PROTECTIVE ACTIONS PLANNED IF AN ACCIDENT OCCURS, GENERAL INFORMATION AS TO THE NATURE AND EFFECTS OF RADIATION, AND A LISTING OF LOCAL BROADCAST STATIONS THAT WILL BE USED FOR DISSEMINATION OF INFORMATION DURING AN EMERGENCY. WE ARE AWARE THAT THIS INFORMATION HAS NOT BEEN DISTRIBUTED FOR THE PILGRIM STATION FOR 1987 OR DURING 1988, AND THAT THE COMMONWEALTH OF MASSACHUSETTS HAS DETERMINED IT IS NOT APPROPRIATE TO DISTRIBUTE EMERGENCY PREPAREDNESS INFORMATION UNTIL CHANGES TO THE APPROPRIATE EMERGENCY PLANS ARE COMPLETED. THE NRC WILL VERIFY THAT THIS PUBLIC INFORMATION IS AVAILABLE PRIOR TO RESTART OF THE PILGRIM STATION. ADDITIONALLY, A PROMPT PUBLIC NOTIFICATION SYSTEM SHALL HAVE A DESIGN OBJECTIVE OF BEING CAPABLE OF ESSF.NTIALLY COMPLETING THE INITIAL NOTIFICATION OF THE PUBLIC WITHIN THE 10 MILE EPZ HITHIN ABOUT 15 MINUTES. THE USE OF THIS NOTIFICATION CAPABILITY WILL RANGE FROM IMMEDIATE NOTIFICATION OF THE PUBLIC (WITHIN 15 MINUTES OF THE TIME THAT STATF AND LOCAL 0FFICIALS ARE NOTIFIED THAT A SI1UATION EXISTS REQUIRING URGENT ACTION) TO THE MORE LIKELY EVEN'S WHERE THERE IS SUBSTANTIAL TIME AVAILABLE FOR THE STATE AND LOCAL GOVERNMENTAL OFFICIALS TO MAKE A JUDGEMENT WHETHER OR NOT TO ACTIVATE THE PUBLIC NOTIFICATION SYSTEM. WHERE THERE IS A DECISION TO ACTIVATE THE NOTIFICATION SYSTEM, 1BE STATE AND LOCAL OFFICIALS WILL DETERMINE WHETHER TO ACTIVATE THE ENTIRE NOTIFICATION l SYSTEM SIMULTANEOUSLY OR IN A GRADUATED OR STAGED MANNER. THE RESPONSIBILITY FOR ACTIVATING SUCH A PUBLIC NOTIFICATION SYSTEM SHALL REMAIN WITH THE APPROPRIATE GOVERNMENTAL AUTHORITIES. NUREG-0654 INDICATES THAT THE DESIGN
8 OBJECTIVE DISCUSSED ABOVE REASONABLE ASSURANCE THAT EARLY NOTIFICATION CAN BE PROVIDED. PERIODIC TESTING OF SIRENS IDENTIFIES DEFICIENCIES IN THE SYSTEM, AND LOCALITIES WHERE IMPROVEMENTS ARE NECESSARY. EMERGENCY Pl.ANS ARE DOCUMENTS THAT ARE CONSTANTLY UNDERGOING CHANGES AND REVISION. THE OFFSITE EMERGENCY PREPAREDNESS PL ANS FOR PILGRIM STATION WERE SUBMITTED BY THE MASSACHUSETTS CIVIL DEFENSE AGENCY TO FEMA IN 1981. NUMEROUS DRILLS AND FULL-SCALE EXERCISES WERE HELD AS REQUIRED, WITH APPROPRIATE STATE AND LOCAL PARTICIPATION. HOWEVER, DUE TO DEFICIENCIES IDENTIFIED DURING THESE DRILLSANDEXERCISES,ANDALACKOFPROGRESSBYOFF-SITEORGANIZATIONS(STATE AND LOCAL COMMUNITIES) IN CORRECTION OF LONG-STANDING PLAN DEFICIENCIES, FEDERAL EMERGENCY KANAGEMENT AGENCY CONDUCTED A SELF-INITIATED REVIEW 0F PILGRIM, AND PUBLISHED THEIR REPORT ON AUGUST 4, 1987. FEMA REVIEW INCLUDED THE REPORT ISSUCD BY MASSACHUSETTS SECRETARY OF PUBLIC SAFETY, CHARLES BARRY, IN DECEMBER 1986. FEMA IDENTIFIED SIX ISSUES. THESE ARE LACK OF EVACUATION PLANS FOR SOME PUBLIC AND PRIVATE SCHOOLS AND DAY CARE CENTERS. LACK OF A RECEPTION CENTER FOR PEOPLE EVACUATING TO THE NORTH. LACK OF IDENTIFIABLE PUBLIC SHELTERS FOR THE BEACH POPULATION. INADEQUATE PLANNING FOR SPECIAL NEEDS POPULATION.
4 9 INADEQUATE PLANNING FOR THE EVACUATION OF THE TRANSPORTATION DEPENDENT POPULATION. OVERALL LACK OF PROGRESS IN PLANNING AND APPARENT DIMINUTION OF EMERGENCY PREPAREDNESS. THE NRC TRANSMITTED THE REPORT AND THESE FINDINGS TO THE BOSTON EDISON COMPANY IN AUGUST 1987 ENC 0URAGING BOSTON EDIS0N TO WORK WITH, AND SUPPORT, THE COMMONWEALTH OF MASSACHUSETTS AND LOCAL ORGANIZATIONS TO CORRECT THE DEFICIENCIES. WE ARE AWARI 0F SOME OF THE WORK TO DATE ?N IMPROVING THE OFFSITE EMERGENCY PREPAREDNESS PROGRAMS AT PILGRIM AND CORRECTING THE EMERGENCY PLANNING DEFICIENCIES IDENTIFIED BY FEDEPAL EMERGENCY MANAGEMENT AGENCY. WE ARE AWARE THAT DRAFTS OF THE LOCAL EMERGiNCY PLANS HAVE BEEN COMPLETED AND THAT THESE PLANS HAVE BEEN FORWARDED BY THE COMMONWEALTH TO FEDERAL EMERGENCY MANAGEMENT AGENCY FOR TECHNICAL REVIEW. THIS INITIAL TECHNICAL REVIEW HAS BEEN COMPLETED, AND FEDERAL EMERGENCY MANAGEMENT AGENCY HAS TRANSMITTED COMMENTS BACK TO THE COMMONWEALTH, IDENTIFYING AREAS WHERE FURTHER WORK IS REQUIRED. WE ARE AWARE THAT THE DRAFT MASSACHUSETTS CIVIL DEFENSE AGENCY AREA II PLAN IS ESSENTIALLY COMPLETE AND IS BEING REVIEWED BY THE COMMONWEALTH, AND THE DRAFT OF THE C0 m0NWEALTH PLAN FOR PILGRIM IS NEARING COMPLETION. NRC HAS STATED AT SEVERAL PUBLIC MEETINGS THAT IT WILL NOT PERMIT THE PILGRIM FACILITY TO RESUME OPERATION UNTIL CORRECTIVE ACTION SATISFACTORY TO NRC HAVI. BEEN TAKEN TO ADDRESS THE EMERGENCY PLANNING DEFICIENCIES IDENTIFIED BY
1 10 FEDERAL EMERGENCY MANAGEMENT AGENCY. THE NRC WILL GIVE SPECIAL ATTENTION TO THE SCHOOLS AND DAY-CARE CENTERS, AS WELL AS FOR SPECIAL NEEDS AND TRANSPORT-DEPENDENT POPULATIONS IN THE PLUME EXPOSURE PATHWAY EPZ. BEFORE ALLOWING PILGRIM TO RESTART, THE NRC WILL REQUIRE SOME DEMONSTRATION 1 HAT CRITICAL ASPECTS OF THE EMERGENCY PLAN CAN BE ADEQUATELY IMPLEMENTED. THE NRC MAY AUTHORIZE RESTART WITH SOME PLANNING ISSUES NOT FULLY RESOLVED, AS LONG AS THE NRC CAN STILL MAKE A FINDING THAT THERE IS REASONABLE ASSURANCE THAT THE PUBLIC HEALTH AND SAFETY CAN BE PROTECTED. IN REACHING THIS DECISION, THE NRC WILL EXAMINE EACH PLANNING DEFICIENCY AND WEIGH THE SIGNIFICANCE OF THE DEFICIENCY, THE NATURE OF ANY COMPENSATORY ACTIONS, AND THE PROGRESS BEING MADE BY THE COMMONWEALTH, LOCAL GOVERNMENTS AND THE LICENSEE TOWARD CORRECTION OF THE DEFICIENCY. EMERGENCY PLANNING IS A DYNAMIC PROCESS AT OPERATING NUCLEAR PLANT SITES IN THE UNITED STATES. IN PRACTICE, WE EXPECT THAT EMERGENCY RESPONSE PLANS WILL BE REVISED AND IMPROVED ON A CONTINUAL BASIS. DEFICIENCIES IDENTIFIED DURING THE ONG0ING REVIEW PROCESS AND IN BIENNIAL EXERCISES AT EACH OF THESE SITES ARE ASSESSED FOR SIGNIFICANCE AND THE REGULATION PERMIT THAT PLANTS MAY BE ALLOWED TO OPERATE WHILE THE DEFICIENCIES ARE BEING CORRECTED. GIVEN THE PROGRESS TO DATE AT PILGRIM, IT IS PREMATURE AT THIS TIME TO ATTEMPT TO DETERMINE WHICH, IF ANY, DEFICIENCIES MAY REMAIN WHEN RESTART DECISIONS ARE TO BE MADE. IN CONCLUSION, THE NRC IS AWARE OF THE IDENTIFIED DEFICIENCIES IS OFFSITE EMERGENCY PLANNING AROUND PILGRIM, AND THE CORRECTIVE ACTION UNDERWAY. THE NRC WILL NOT PERMIT PILGRIM TO RESUME OPERATIONS UNTIL CORRECTIVE ACTION SATISFAC-TORY TO THE NRC HAS BEEN TAKEN TO ADDRESS THESE EMERGENCY PLANNING DEFICIENCIES.
I WILL TURN NOW TO ENVIRONMENTAL MONITORING RONALD R. BELLAMY, CHIEF FACILITIES RADIOLOGICAL SAFETY AND SAFEGUARDS BRANCH U. S. NUCLEAR REGULATORY CO>NISSION MAY 11, 1988 THE ENVIRONMENTAL MONITORING CONCERNS RAISED DURIN'G THE FEBRUARY 18, 1988, MEETING INCLUDED ONSITE AND OFFSITE MONITORING TECHNICAL SPECIFICATION SAMPLING REQUIREMENTS, THE RESPONSIBILITIES OF BOSTON EDISON IN CONTRAST TO THOSE OF THE NRC, DIFFERENCES IN SHELLFISH VERSUS FINFISH ACTIVITY, AND NUMEROUS COMMENTS ABOUT THE RESULTS OF CANCERS STUDIES PERFORMED AROUND THE PILGRIM STATION. I WILL ADDRESS EACH OF THESE AREAS, BUT IT IS FIRST IMPORTANT TO SET THE STAGE FOR RADIOLOGICAL ENVIRONMENTAL MONITORING AND EFFLUENT MONITORING. RADIOLOGICAL ENVIRONMENTAL MONITORING AND EFFLUENT MONITORING AT PILGRIM IS IMPORTANT BOTH FOR NORMAL OPERATIONS, AS WELL AS IN THE EVENT OF POSTULATED j EVENTS. DURING NORMAL OPERATIONS, ENVIRONMENTAL MONITORING VERIFIES THE EFFECTIVENESS OF IN-PLANT MEASURES FOR CONTROLLING THE RELEASE OF RADI0 ACTIVE MATERIALS, AND MAKES SURE THAT THE LEVELS OF RADI0 ACTIVE MATERIALS IN THE ENVIRONMENT 00 NOT EXCEED REGULATORY REQUIREMENTS AND ARE "AS LOW AS REASONABLY l ACHIEVABLE". FOR PS0TULATED EVENTS, IT ALLOWS AN ADDITIONAL MEANS FOR ESTIMATING DOSES TO EMBERS OF THE GENERAL PUBLIC.
2 THERE ARE SPECIFIC REGULATORY BASES FOR REQUIRING THIS ENVIRONMENTAL MON AND EFFLUENT MONITORING. REGULATIONS ARE CONTAINED IN GENERAL DESIGN CRITEf:IA 64 0F APPENDIX A 0F TITLE 10 0F THE CODE OF FEDERAL REGULATIONS PART 50 AND SECTION IV.B 0F APPENDIX I 0F 10 CFR 50 THAT NOTE (IN PART): "THE LICENSEE SHALL ESTABLISH AN APPROPRIATE SURVEILLANCE AND MONITORING PROGRAM TO: PROV DATA ON QUANTITIES OF RADI0 ACTIVE MATERIAL RELEASED IN LIQUID AND GASEOUS EFFLUENTS...; PROVIDE DATA ON MEASURABLE LEVELS OF RADIATION AND RADI0 ACTIVE MATERIALS IN THE ENVIRONMENT TO EVALUATE THE RELATIONSHIP BETWEEN QUANTIT RA0;0 ACTIVE MATERIAL RELEASED IN EFFLUENTS AND RESULTANT RADIATION DOSES TO INDIVIDUALS FROM PRINCIPAL PATHWAYS OF EXPOSURE; ..." THE REQUIREMENTS OF THE LICENSEE'S OPERATIONAL RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM ARE SPECIFIED IN THE RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS THAT ARE ISSUED WITH THE OPERATING LICENSE FOR THE NUCLEAR POWER PLANT. THESE TECHNICAL SPECIFICATIONS FOR PILGRIM WERE SIGNIFICANTLY REVISED AND UPGRADED IN AUGUST 1985. MORE DETAILED INFORMATION IS CONTAINED IN THE OFFSITE DOSE CALCULATION MANUAL WHICH IS REFERENCED IN THE PLANT'S TECHNICAL SPECIFICATIONS. THE TECHNICAL SPECIFICATIONS ALSO P2 QUIRE THAT THE LICENSEE SUBMIT: (1) AN ANNUAL REPORT; AND (2) A SPECIAL REPORT WITHIN 30 DAYS IF PRFDETERMINED LEVELS OF RADI0 ACTIVITY ARE EXCEEDED. TO ASSURE THE PRECISION AND ACCURACY OF THE MEASUREMENTS OF RADIONUCLIDES IN THE ENVIRONMENTAL SAMPLES, LICENSEES ARE REQUIRED TO PARTICIPATE IN AN INTERLABORATORY COMPARISON PRDGRAM. THE RESULTS OF BECO'S RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAMS AND EFFLUENT MONITORING PROGRAHS ARE REPORTED TO REGION I. THE ENVIRONMENTAL
3 MONITORING RESULTS ARE REPORTED ANNUALLY AND EFFLUENT MONITCRING RESULTS ARE REPORTED SEMI-ANNUALLY. THE PROGRAM AT THE PILGRIM STATION INCLULES SPECIFIC CRITERIA ON THE EXPOSURE PATHWAY ANALYZED OR SAMPLED, INCLUDING: RADIOI0 DINES AND PARTICULATES IN AIR, SAMPLED AT 11 STATIONS BY CONTINUOUS AIR SAMPLING ANALYZED WEEKLY DIRECT RADIATION SURFACE WATER, SAMPLED AT 3 LOCATIONS CONTINUOUSLY OR WEEKLY GROUND WATER DRINKING WATER l SEDIMENT FROM SHORELINE, SAMPLED AT 6 STATIONS SEMIANNUALLY MILK, SAMPLED AT 2 STATIONS SEMIMONTHLY, i SHELLFISH, SAMPLED AT 5 LOCATIONS QUARTERLY ALGAE, SAMPLED AT 4 LOCATIONS QUARTERLY
- 4 LOBSTER, SAMPLES AT 4 LOCATION 3 QUARTERLY FISH, SAMPLED AT 13 LOCATIONS QUARTERLY CRANBERRIES, SAMPLED AT 3 LOCATIONS AT HARVEST VEGETATION, SAMPLED AT 7 LOCATIONS AT HARVEST AND FINALLY BEEF, SAMPLED AT 2 LOCATIONS SEMIANNUALLY DURING 1987, DOSES FROM THESE SOURCES WERE SMALL FRACTIONS OF REGULATORY LIMITS.
NRC REGION I CONDUCTS INSPECTION ACTIVITIES RELATING TO ENVIRONMENTAL AREAS. APPROXIMATELY ONCE PER YEAR THE LICENSEE'S EFFLUENT RADI0 ANALYTICAL LABORATORY PROGRAMS ARE INSPECTED. THE LAST INSPECTION AT PILGRIM IN THIS AREA WAS t CONDUCTED IN OCTOBER, 1987, AND SHOWED BECO TO BE CONDUCTING AN ADEQUATE PROGRAM. THE SCOPE OF THESE INSPECTIONS ENCOMPASSES ORGANIZATION, PROCEDURES, RECORDS, QUALITY CONTROL, LABORATORY FACILITIES AND CONFIRMATORY MEASUREMENTS. i NRC CONDUCTS THIS CONFIRMATORY INSPECTION WITH THE USE OF A HOBILE LABORATORY. l ErFLUENT STREAM SAMPLES ARE SPLIT WITH THE LICENSEE AND ANALYZED IN THEIR l LABORATORY AND IN THE NRC HOBILE LABORATORY. A HIGH LEVEL OF QUALITY CONTROL IS MAINTAINED WITH TRACEABILITY TO THE NATIONAL BUREAU OF. STANDARDS. SPLIT l SAMPLE RESULTS ARE INTERCOMPARED AND APPLIED TO AN AGREEMENT / DISAGREEMENT , CRITERIA. THE PURPOSE OF THIS TYPE OF INSPECTION IS TO ASSURE THAT LICENSEfi-
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ARE MAKING VALID RADI0 ANALYTICAL MEASUREMENTS. WE HAVE COMMITTED TO BRINGING THE MOBILE VAN TO THE PILGRIM STATION WITHIN THREE MONTHS OF ANY RESTART. A SECOND TYPE OF INSPECTION THAT 15 DONE, AGAIN USUALLY ON AN ANNUAL BASIS, IS IN THE AREA 0F RADWASTE OPERATIONS AND EFFLUENT CONTROLS. DURING THIS INSPECTION, OPERATION PROCEDURES, RECORDS, AND CALIBRATIONS OF EFFLUENT MONITORS ARE REVIEWED, WITH PARTICULAR EMPHASIS ON THE LATTER. IN ADDITION, LICENSEE'SOFFSITEDOSECALCULATIONMANUALS(ODCM)AREREVIEWEDFORCHANGES, AND RECORDS ARE REVIEWED FOR ADEQUACY OF IMPLEMENTATION. EXAMPLE ODCM CALCULATIONS ARE MADE AND TF3TED AGAINST REGULATORY AND TECHNICAL 7,PECIFICATION REQUIREMENTS. THIS AREA WAS LAST INSPECTED AT PILGRIM IN APRIL, 1988, AND SHOWED BECO TO BE CONDUCTING AH ADEQUATE PROGRAM. ALSO IN THE ENVIRONMENTAL AREA, INSPECTION OF THE LICENSEE'S ENVIRONMENTAL MONITORING PROGRAM IS CONDUCTED, GENERALLY ONCE EVERY TWO YEARS, AND INVOLVES THE ENVIRONMENTAL LABORATORIES AND EQUIPMENT, PROCEDURES, ORGANIZATION, RECORDS AND GENERAL PROGRAM IMPLEMENTATION. LICENSEE MONITORING RESULTS l ARE INTERCOMPAREP WITH CONFIL:'ATORY RESULTS FROM THE NRC PROGRAMS AS WELL AS ESTIMATES AND DESCRIPTIONS PRESENTED IN THE ENVIRONMENTAL STATEMENTS FOR THE FACILITY. THIS INSPECTION AT PILGRIM WAS LAST PERFORMED IN OCTOBER, 1987 AND-SHDWED GECO TO BE CONDUCTING AN ADEQUATE PROGRAM. IF ADDITION TO THE MONITORING THAT IS PERFORMED BY BECO UNDER THEIR TECHNICAL SPECIFICATION REQUIREMENTS, NRC PROVIDES INDEPENDENT CONFIRMATORY ENVIRONMENTAL
6 MONITORING BY MEANS OF TWO PROGRAMS, FIRST, ENVIRONMENT /.' SAMPLING AND ANALYSES ARE PERFORMED BY PARTICIPATING STATES UNDER CONTRACT TO NRC; AND SECOND, DIRECT RADIATION MEASUREMENTS ARE MADE DY THE NRC THERMO-LUMINESCENT DOSIMETRY (TLD) NETWORK,OPERATEDOUTOFTHEREGIONI0FFICE. THE PURPOSE OF THE STATE CONTRACTS PROGRAM FOR ENVIRONMENTAL CONFIRMATORY MONITORING IS TO CONDUCT INDE9ENDENT MEASUREMENTS IN THE ENVIRONS OF NUCLEAR FACILITIES TO EVALUATE THF QUALITY OF THE LICENSEE'S ENVIRONMENTAL RADI0 ACTIVITY AND RADIATION MEASUREMENTS. THESE MEASUREMENTS DUPLICATE AS CLOSELY AS POSSIBLE CERTAIN PARTS OF THE LICENSEE'S ENVIRONMENTAL MONITORING EFFDDTS, BUT ARE MADE INDEPENDEhi UF LICENSEE PROGRAMS. THE RESULTS 3F THE oTATE CONTRACT PROGRAM APE U$ED BY NRC AND THE STATES IN VERIFYING THE CAPABILITY OF THE LICENSEE TO MEASURE RADI0 ACTIVITY It. ENVIRONMENTAL MEDIA. THE STATE CONTRACTS PROGRAM IS VIEWED AS A COOPERATIVE EFFORT BETWEEN THE STATE AND THE NRC. PARTICIPATION BY A STATE IS VOLUNTARY. THE COMMOMWEALTH OF MASSACHUSETTS IS A PARTICIPANT IN THIS PLAN, AND PERFORMS BOTH SAMPLE COLLECTION AND ANALYSES FOR COMPARISON OF RESULTS. THE NRC ENVIRONMENTAL TLD PROGRAM WAS ESTABLISHED !N 1979 AFTER THE THREE MILE ISLAND ACCIDENT. APPROXIMATELY 50 DOSIMETERS ARE EXCHANGED QUARTERLY AROUND EACH OF 71 POWER REACTOR SITES AND SEVERAL PRODUCTION FACILITIES. AT THE PILGRIM STATION, 49 DOSIMETERS ARE EXCHANGED QUARTERLY, LOCATED WITHIN 10 MILES OF THE PLANT. THE NRC'S DIRECT RADIATION MONITORING PROGRAM IS OPERATED BY THE NRC IN ORDER TO PROVIDE CONTINUOUS HEASUREMENT OF AMBIENT RADIATION LEVELS AROUND NUCLEAR FACILITIES, PRIMARILY POWER REACTORS. IT HAS A TWO-FOLD
' 7 4 PURPOSE. FIRST, IT IS A CONFIRMATORY PP0 GRAM FOR THE PURPOSE OF ASSURING THAT LICENSEES OPERATE THEIR EFFLUENT MONITORING AND CONTROL SYSTEMS IN A MANNER CONSISTENT WITH REGULATORY REQUIREMENTS; AND SECOND IT IS INTENDED TO PROVIDE INFORMATION REGARDING ENVIRONMENTAL DOSES IN THE EVENT OF A NUCLEAR POWER REACTOR ACCIDENT. DETAILED RESULTS OF THE PRDGRAM ARE PUBLISHED QUARTERLY AS NUREG-0837. AN ISSUE RAISED AT THE FEBRUARY 18, 1988, HEETING CONCERNED CANCER STUDIOS AROUND THE PLYMOUTH AREA.^ THE NRC STAFF HAS REVIEWED THE EPIDEMIOLOGICAL STUDY ENTITLED, "HEALTH SURVEILLANCE OF THE PLYMOUTH AREA." WHICH WAS PERFORMED FEBRUARY,1987 BY TilE MASSACHUSETTS DEPARTMENT OF HEALTH. THE STUDY REPORTS DETECTING AN INCREASED INCIDENCE OF LEUKEMIA CASES IN FIVE TOWNS IN THE VICINITY OF THE PILGRIM NUCLEAR POWER PLANT. BECAUSE MANY FACTORS OTHER THAN THE PILGRIM PLANT COULD CAUSE THIS INCREASE THE AUTHORS OF THE STUDY STATE THAT THE CAUSE OF THE INCREASED INCIDENCE HAS NOT BEEN DETERMINED. THE NRC AGREES WITH THE AUTHORS' STATEMENT. THE EFFECTS OF RADIATION ON LIVING SYSTEMS HAVE BEEN STUDIED FOR DECADES BY INDIVIDUAL SCIENTISTS AS WELL AS BY SELECT COMMITTEES THAT HAVE BEEN FORMED TO OBJECTIVELY AND INDEPENDENTLY ASSESS THE RISKS FRDM RADIATION. THESE STUDIES WERE CONSIDERED IN THE DEVELOPMENT OF THE PUBLIC HEALTH AND SAFETY LIMITS THAT APPLY TO THE PILGRIM PLANT, AS WELL AS TO OTHER NUCLEAR POWER PLANTS. THE STUDIES HAVE NOT DETECTED A STATISTICALLY SIGNIFICANT INCREASE IN CANCER FOR DOSES AND DOSE RATES NORMALLY ENCOUNTERED IN THE VICINITY OF NUCLEAR POWER PLANTS. IN FACT, VARIATIONS IN NATURAL RADIATION BACKGROUND IN DIFFERENT
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8 GEOGRAPHICAL LOCATIONS IS MUCH GREATER THAN INCREASES IN RADIATION LEVELS AROUND NUCLEAR POWER PLANTS DUE TO THE OPERATION OF THESE PLANTS, AND THERE IS NO SIGNIFICANT CORRELATION IN CANCER RATES DUE TO SUCH VARIATION IN NATURAL BACKGROUND RADIATION. WE ARE ALSO AWARE OF THE NATIONAL INSTITUTES OF HEALTH'S INVOLVEMENT IN STUDYING THE ADVERSE EFFECTS OF LOW-LEVEL IONIZING RADIATION. WE SUPPORT THE NEED TO FURTHER DEFINE THE EFFECTS OF THIS PHENOMENON, BUT WE BELIEVE IT WILL BE SEVERAL YEARS BEFORE THE RESULTS OF THESE STUDIES WILL BE AVAILABLE. WE LOOK FORWARD TO INCORPORATING THOSE RESULTS INTO THE BODY OF DATA ALREADY AVAILABLE ON THIS SUBJECT. THUS THE STAFF HAS FOUND THAT ON THE BASIS OF THE SUBSTANTIAL DATA AVAILABLE IN THE AREA 0F HEALTH EFFECTS FROM EXPOSURE TO RADIATION THERE IS NO STATISTICALLY SIGNIFICANT INCREASE IN CANCER AROUND NUCLEAR POWER PLANTS. IT IS NOT APPROPRIATE TO DELAY RESTARTING THE PILGRIM PLANT PENDING COMPLETION OF FURTHER STUDY TO DETERMINE IF THERE IS A LINK BETWEEN CERTAIN TYPES OF CANCER AND COMMERCIAL NUCLEAR POWER GENERATION. ANOTHER ISSUE RAISED AT THE FEBRUARY MFETING BY SEVERAL MEMBERS OF THE PUBLIC CONCERNED THE IMPACT OF RADI0 ACTIVE RELEASES FROM PILGRIM STATION ON SHELLFISH AND FINFISH. SMALL BUT MEASURABLE COUNTS OF RADI0 ACTIVE MATERIAL HAVE BEEN MEASURED IN MARINE BIOTA. STUDIES AND MEASUREMENTS OF THIS POSSIBLE RADIOACTIVE MATERIAL IN MARINE BIOTA ARE REQUIRED BY THE PILGRIM STATION
9 i TECHNICAL SPECIFICATIONS AND ARE IMPLEMENTED BY THE LICENSEE'S RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM. AS PREVIOUSLY DISCUSSED, THESE PROGRAMS ARE INSPECTED IN DETAIL BY THE NRC AND THE RESULTS ARE REGULARLY REPORTED TO THE NRC. THE MOST RECENT ANALYSIS OF THE RELEASES OF RADI0 ACTIVE MATERIAL FROM PILGRIM SHOW THE POTENTIAL HEALTH EFFECTS TO BE OF INSIGNIFICANT CONSEQUENCE. THE RADI0 ACTIVE MATERIAL IS MOST PREVALENT IN SHELLFISH DUE TO THE FEEDING MECHANISM 0F THE SHELLFISH. THESE BIOTA FEED BY FILTERING PARTICULATE MATERIAL FROM LARGE VOLUMES OF WATER, AND PARTICULATE ISOTOPES ARE GENERALLY THE DETECTED CONTAMINANT. IN ADDITION, SHELLFISH TEND TO REMAIN FIXED IN LOCATION AS COMPARED TO FINFISH. FINFISH TEND TO BE HIGRATORY IN NATURE, AND BEING MOBILE THEY DO NOT NORMA'.LY RESIDE NEAR THE DISCHARGE CANAL LONG ENDUGH TO ACCUMULATE MEASURABLE AMOUNTS OF RADI0 ACTIVITY. THUS, THERE IS THE PERCEPTION THAT SHELLFISH ACCUMULATE RADIOACTIVE MATERIAL IN PREFERENCE TO FINFISH. IN EITHER CASE, ANY DOSE COMMITMENT TO AN INDIVIDUAL CONSUMING QUANTITIES OF SHELLFISH WDULD BE NEGLIGIBLE COMPARED TO THE DOSES RECEIVED BY MEMBERS OF THE PUBLIC FROM NATURAL AND MAN-MADE SOURCES OF RADI0 ACTIVITY. IN CONCLUSION, FIRST, BOSTON EDISON IS REQUIRED TO MAINTAIN EXTENSIVE ENVIRONMENTAL AND EFFLUENT MONITORING PROGRAMS. NRC INSPECTIONS HAVE SHOWN l
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THESE PROGRAMS TO BE ACCEPTABLE. AND SECOND, THERE IS NO BASIS TO CONCLUDE THAT THERE ARE ANY STATISTICALLY SIGNIFICANT INCREASES IN CANCER FOR DOSES AND DOSE RATES NORMALLY ENCOUNTERED AROUND NUCLEAR POWER PLANTS. THANK YOU FOR LISTENING TO MY REMARKS. MR. BRUCE BOGER IS THE NEXT SPEAKER, 1
c. A. t Response to Comments Regarding The Pilgrim Containment And Safety Enhancement Program (SEP) l Comments Received During the > Pilgrim Restart Program Pubite Meetings Plymouth, Massachusetts, February 18, 1988 r. t
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Bruce A, Boger4 , Assistar.t Director P Region I Reactors Divisions of Reac'.or Projects I/II i i L r 4 Plymouth, Massachusetts t May 11, 1988 , r
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o . I am pleaseu to be here today to respond to the comments received during the February 18, 1988 public meetings regarding the Pilgrim Mark I (MK-I) containment and Boston Edison Company's (BECo) Safety Enhancement Program (SEP). A summary of the comments that we received are provided as handouts tonight. My presentation will be included in the transcript as a part of the meeting report documenting this public meeting. Before I respond to the specific comments received on the Pilgrim Restart Plan, I would like to provide some background information on the licent%; ;;rocess used by the Nuclear Regulatory Commission (NRC) during the initial licensing and subsequent modification of a facility, the "Defense-In-Depth" concept for safety of nuclear power plants, and the NRC monitoring process after licensing. This background information may be helpful in understanding NRC activities related to MK-I containments. Licensing proeg i The regulations which govern the licensing of nuclear power plants ar: contained in part 50 of Title 10 of the Code of Federal Regulations (10 CFR 50). These regulations are supplemented by various industry codes, standards and guidance documents (i.e. Regulatory Guides, Standard Technical Specifications,
$tandard Review Plan, etc.). An applicant for a facility licerse prepares a document called a Final Safety Analysis Report (FSAR) which ',dentifies plant features and the codes and standards used in its design and construction. The NRC staff reviews the FSAR against the regulations which are in effect at the time of licensing. The results of the NRC staff's review are documented in a Safety Evaluation Report (SER). These documents, the FSAR and SER, in part constitute what is termed the "licensing basis" for the issuance of a facility operating license. Furthermore, each license issued for operation of a
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nuclear power plant incorporates technical specifications which set forth the safety and environmental limits imposed on that facility which must be met in order for the facility to operate in accordance with its licensing basis. For Pilgrim these licensing documents are available in the Local Public Document Room located in the Plymduth Public Library. Subsequent to obtaining a license, facilities must upgrade or change their initial design and operating procedures as a result of operating experience. Such changes require prior approval from the NRC if the proposed change involves a change in the technical specifications or an unreviewed safety question. In part, a proposed change constitutes an unreviewed safety question if it: (1) increases the probability or consequences of an e u dent analyzed in the FSAR, (2) creates the possibility of a new type of accidant, or (3) reduces the margin of safety as defined in the b4 sis for any technical specification. Other changes or enhancements can be made by the licensee il no technical specifications are changed and a determination is made by the licensee that no unreviewed safety question results from the change. This is allowed by the regulations and is referred to as a "50.59 change" as defined in the regulations (10 CFR 50.59). These changes are reported to the NRC and are routinely i inspected, usually following implementation. As a result of NRC activities associated with research and development, and the monitoring of nuclear power plant experience, changes to the NRC's regulations and guidance occur. Some of these changes are intended.for future nuclear facilities and therefore are not imposed on current facility licensees. However, i
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.i if the NRC determines that substantial additional protection for public health and safety is provided by the upgraded requirements, then these requirements are imposed on licensees. This is referred to ar "backfitting" newer requirements on a previously licensed facility and 17 governed by the I regulations in 10 CFR 50.109. Some examples of backfitt'ng at Pilgrim are revised emergency operating procedures, increased staf,ing, upgraded trainina safety system upgrades, added instrumentation, and Appendix R fire protection requirements.
1 I Defense-in-Depth Concept
- The NRC has incorporated the defense-in-depth philosophy in the design and i operation of reactor facilities to reduce the likelihood of individual equipment, component or human errors that could result in the loss of a safety system or a safety function. This is accomplished during the design process by redundancy and-diversity within key safety systems and functions. An example of defense 1..-
depth is the number of physical barriers which are designed to prevent the release of significant offsite levels of radiation. Reactor plant design provides for the initial physical barrier being the fuel cladding, the second ; barrier being the reactor vessel and the third barrier being the containment. In turn, each of these barriers is protected by redundant and/or diverse systems to provide reasonable assurance their individual integrity is maintained. In addition to the design features of the defense-in-depth concept, operational controls are established which include: (1) technical specifications that identify requirements on equipment operation and system operating parameters, (2) operating procedures to keep the plant within normal bounds and emergency operating procedures to cover situations outside normal bounds, (3) training
4 4' and licensing of the operating staff on technical specifications and procedures, including training on a plant-specific simulator, and 4) the licensee's quality assurance and quality control programs related to construction, operation and maintenance of plant equipment and systems. NRC Monitoring Process To assure that licensed facilities maintain and operate their structures, systems and components in accordance with the regulations, standards and procedures they were approved by, the NRC has an extensive inspection and enforcement program. The Pilgrim Station has three full-time resident inspectors on site. In addition, announced and unannounced inspections are performed by specialists from NRC Headquarters and the Region to augment theresidents'dailyinspectionacti41 ties. All inspection activities are documented in inspection reports and provided to the LPDR. The purpose of the NRC inspection and enforcement program is to promote and protect the radiological health and safety of the public by ensuring compitance with NRC requirements, obtaining prompt corrective actions, deterring fu ure violations, and encouraging improvement in licensee performance. Public Comments on the Pilgrim Restart Plan Thus far I have provided a brief overview on how the NRC staff has, and is continuing to address concerns relating to the MK-I containment and assessing the plant-specific modifications to the Ptigrim MK-I containment implemented as part of the BEco SEP.
5-In a nuclear power plant, the principal sources of protection of public health and safety are provided through defense-in-depth of proper design, construction, and operation. The initial licensing of the power plant requires that the ability to withstand certain kinds of accidents, which are thus known as "design basis accidents" be included as a design requirement. Design basis accidents t (DBAs) represent a wide spectrum of plant problems, some which might be expected to occur in the lifetime of a plant (e.g. a failure of its electrical power systems), and others which are considered to be very unlikely (e.g. major ruptures
.of piping systems). These DBAs are identified in the FSAR. Every conmercial nuclear power plant licensed in the United States must have a protective containment around the reactor, usually made of steel or steel-reinforced -
concrete, that is designed to contain radioactive material which might be released from the reactor during a postulated DBA. All containments, including the MK-I design at Pilgrim, must inc!,ude acceptable structural design margin to withstand these DBAs in conjunctien with the simultaneous occurrence of an earthquake. In the 1972 timeframe, Dr. S. H. Hanauer of the Atomic Energy Commission raised seven concerns relating to the MK-I containments' ability to respond to a large loss of coolant accident, which is one of the DBAs. The NRC staff performed a review which considered Dr. Hanauer's concerns and documented its findings in NUREG-0474, "A Technical Update on Pressure Suppression Type Containments in Use in U.S. Light Water Reactor Nuclear Power Plants," issued in July 1978. Enclosure A to NUREG-0474 summarizes the NRC staff's actions I
f r relating to each of Dr. Hanauer's concerns. As a result, the staf f required modifications for all MK-I containments, including Pilgrim, to ensure design
- margins for DBAs are maintained.
Issues.related to the NK-I containment design were also raised in an internal 1 1975 General Electric Company (GE) study-referred to as the "Reed Report." This internal study was a product improvement report by the corporation that designed-the MK-I containment. This report identified areas in plant. design, including containments, where design improvements could be made. Members of the NRC staff reviewed the document .in 1976 and determined that it did not raise any significant new safety issues. The NRC staff has since re-evaluated the Reed Report from a 1987 perspective and documented the results in NUREG-1285, "NRC i Staff Evaluation of the General Electric Company Nuclear Reactor Safety Study I (Reed P,eport)" issued in July 1987. The results of the re-evaluation supported the staff's initial findings and concluded that (1) there are no issues raised ! i in the Reed Report that support a need to curtail the operation of any GE boiling i t water reactor (BWR) such as Pilgrim; (2) there are no new safety issues raised a in the Reed Report of which the staff was unaware; and (3) although certain issues addressed by the Reed Report are still being studied by the NRC and the industry, there is no basis for suspending licensing and operation of GE BWR l plants while these issues are being resolved. . , As a result of the TMI accident, the NRC staff has been studying accidents ! l which go beyond DBAs and are referred to as severe accidents. t l
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F L;. ! I The Commission has concluded that existing plants pose no undue risk to public health and safety and has concluded that immediate action on generic rulemaking or other regulat: f -hanges to plants as a result of severe
- accident risk was not required. The details of this position are in the Commission's "Policy Statement on Severe Reactor Accidents Regarding Future Designs and Existing Plants," 50 Federal Register 32138, August 8,1985. ,
The 1975 Reactor Safety Study (WASH-1400), or the Rasmussen Report in recognition of the MIT professor who coordinated the study, and the most recent comprehensive study entitled "The Reactor Risk Reference Document" (NUREG-1150) generally confirmed the very low likelihood of severe accidents and consequently the relatively low risk to the public even if such very low probability accidents were to occur. Nevertheless, the Commission has several ongoing programs to evaluate probabilistic risk assessments to provide a more detailed assessment of possible severe accident scenarios. NUREG-1150 also investigated the likelihood of early failure of the MK-I containment following the very low probability of a core melt. The report noted that conditional containment failure probability could range from 10 to 90 percent for these extremely unlikely events. The large uncertainties relating to the response of the containments during a postulated severe accident are subject of NRC and industry research. The goals of the research effort are to provide an improved understanding of severe accidents. While the NRC believes that severe accident risks are acceptably low at operating nuclear power plants, including Ptigrim, the staff is re-evaluating MK-I containment performance on a priority basis. The staff expects to make
y: - recommendations to the Commission late this summer. Any MK-I improvements indicated as beneficial by these studies will be imposed upon Pilgrim and other MK-I facilities in accordance with the backfitting policy. Several MK-I modifications have been considtred by NRC and the industry which are intended to improve plant performance ',n the event of a severe accident. BECo has performed an evaluation and completed a number of these modifications at Pilgrim as part of its SEP. The NRC staff reviewed these modifications in August 1987 and concluded that eight of the modifications were appropriate for implementation. These changes include containment spray nozzle modifications, the installation of a third emergency diesel generator, modifications to fire protection systems, and features to respond to an anticipated transient without scram. These modifications are in line with NRC goals to enhance containment performance under severe , accident conditions. These modifications are not a requirement for the restart of Pilgrim and have been implemented by BEco in accordance with the provisions of 10 CFR 50.59. Questions have been raised by the NRC staff regarding the Direct Torus Vent (DTV) modification being considered by BECo. The DTV would provide a hardened path from the containment torus structure to the plant stack and would be used to relieve containment pressure in certain postulated severe accident situations. During staff review of this proposed modification a number of questions were asked of BECo regarding the design and use of the OTV. These questions must be resolved before this system is placed into service.
O 9 In conjunction with the efforts to review and enhance containment performance, the NRC staff is also reviewing the procedures used by operating staffs in response to postulated accidents. These procedures are referred to as emergency operating procedures (EOPs). Since B.ECo upgraded the E0Ps at Pilgrim, the staff recently performed a team inspection to review E0P development methodology, upgraded E0P c'ontent and the associated operator training on the use of the upgraded E0Ps. The results of the inspection indicate that the procedures for developing E0Ps, the upgraded E0P content, and the associated operator training are acceptable. Summary - The purpose of this discussion has 'oeen to provide the regulatory approach used to address the comments received on MK-I containments during the previous public meetings on February 18. In summary 4 all MK-I containments, including Pilgrim, have been demonstrated to satisfy their design requirements with acceptable structural design margins. Dr. Hanauer's concerns relating to DBAs have been resolved and the GE Reed Report did not raise any significant new safety issues. The essertion that the NRC denied the 2.206 petition hearing request filed by State Senator Golden and others because if a policy issue, such as the MK-I, was brought into focus it would affect other plants besides Pilgrim, is incorrect. As indicated in the Interim Director's Decision on the 2.206 petition, dated August 21, 1997, the Petitioners had not presented sufficient evidence to indicate that the Pilgrim Station should not operate while risk-reduction improvements are being considered. That it, there is not sufficient evidence provided of either design flaws at Pilgrim or high risk to warrant a Show Cause Order for the plant to remain closed or to suspend the operating license.
BECo has completed a number of modifications as part of their SEP which are in line with NRC goals to enhance containment performance. The upgraded E0Ps for the Pilgrim Station have been reviewed and found to be satisfactory. A final decision on use of the DTV is pending resolution of the NRC staff's questions. However, as previously stated, completion of the SEP including the DTV are not a requirement for the restart'of Pilgrim. Finally, those present who would like more detailed information on the MK-I conta ent should review the Interim Director's Decision responding to the 2.206 petition of State Senator Golden and others. Attached to the document is Enclosure A to NUREG-0474 which summarizes the NRC's actions relating to Dr. Hanauer's concerns. The Interim Director's Decision, inspection reports, HUREGs and other documents I've referenced in this presentation are available at the Local Public Document Room log,ated in the Plymouth Public Library.
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ATTACHMENT REFERENCES
- 1. All inspection reports relating to the Pilgrim Nuclear Power Station.
- 2. NUREG-0474, "A Technical Update on Pressure Suppression Type Containments in Use in U. S. Light Water Reactor Nuclear Power Plants," July 1978.
- 3. NUREG-1285, "NRC Staf, Evaluation of the General Electric Company Nuclear Reactor Study (Reed Report)," July 1987.
- 4. Policy Statement on Severe Reactor Accidents Regarding Future Designs and Existing Plants," 50 Federal Register 32138, August 8,1985.
- 5. WASH-1400 (NUREG-75/014) "Reactor Safety Study: An Assessment of Accident Risks in U. S. Commercial Nuclear Power Plants," October 1975.
- 6. NUREG-1150, Reactor Risk Reference Document, Oraf t for Comment, February 1987.
- 7. Interim Director's Decisica, 2.206 filed by State Senator William B. Golden and Others, August 21, 1987.
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CLOSING REMARKS FOR SAMUEL J. COLLINS NRC PUBLIC MEETING TO RESPOND TO COMMENTS ON PILGRIM NUCLEAR POWER STATION RESTART PLAN MAY 11, 1988 THANK YOU FOR YOUR ATTENTION AND PARTICIPAYION IN THE NRC ASSESSMENT OF THE PILGRIM STATION RESTART PLAN. THIS MEETING WAS INTENDED TO BE RESPONSIVE TO YGUR COMMENTS AND PROVIDE A TRANSCRIPT REFERENCE FOR YOUR USE IN THE CONTINUING REVIEWS TO BE PERFORMED AS PART OF THE hRC REVIEW PROCESS. THE PRESENTATIONS WERE QUITE TECHNICAL AS A RESULT OF THE INFORMATION REQUESTED BY THE PUBLIC COMMENTS. I APPRECIATE YOUR TOLERANCE AND HOPE WE HAVE ENC 0URAGED YOUR CONTINUED PARTICIPATION. THANK YOU. GOOD EVENING. i l 1
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NRC PUBLIC MEETING PLYMOUTH, MASSACHUSETTS MAY 11, 1988 The purpose of tonight's meeting is to provide feedback on the public comments received or. the Boston Edison Company's Pilgrim Restart Plan. A summary of all comments received is provided in this handout. The feed-
.back on these comments is presented in two forms. The majority of the comments received fell into four (4) categories (public participation, Emergency Preparedness, management and containment) and will be responded te through a transcribed oral presentation. For those specific comments whicn did not fit into the broad categories, a written response is attached. A report of the meeting will be issued containing the meeting transcript and handouts.
Also attached to this handout for information, are the letters to and from Boston Edison Company on the results of NRC review of the Restart Plan and the NRC assessment process milestones. Attachments:
- 1. Agenda
- 2. Summary of Comments Received on Pilgrim Nuclear Power Station Restart Plan
- 3. _ Written Response to Public Comments
- 4. Letters / Reply to Boston Edison Company Re: Plan Comments
- 5. NRC Letter to Boston Edison Company Re: Restart Plan
- 6. NRC Assessment Process Milestores a' d
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'o ATTACHMENT 1 AGENDA May 11, 1988 Public Meeting to Discuss Comments Received on the Pilgrim Restart Plan Location: Memorial Hall, Court Street, Plymouth, MA Date/ Time: May 11, 1988 -
7:00 - 9:00 p.m.
Participants:
Samuel J. Collins, Deputy Director, Division of Reactor P ojects, Region I Jay M. Gutierrez, Regional Counsel, Region I Ronald R. Bellamy, Chief, Emergency Preparednes: and Radiological Protection Branch, Region I Bruce A. Bogar, Assistant Director for Region I Reactors, Office of Nuclear Reactor Regulation 7:00 - 7:15 p.m. Opening Remarks / Introduction of Speakers S. Collins Purpose of Meeting 7:15 - 7:35 p.m. Public Participation Restart Process J. Gutierrez 7:35 - 7:55 p.m. Radiological Monitoring / Emergency Preparedness R. Bellamy 7:55 - 8:15 p.m. Containment / Safety Enhancement Program B. Boger [ 8:15 - 8:35 p.m. Management /NRC Assestment Process S. Collins' 8:35 - 9:00 p.m. Public Comments NRC Panel 9:00 p.m. Closing Remarks S. Collins
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ATTACHMENT 2. Summary of Comments Received on the. Pilgrim Nuclear Power Station Restart Plan This attachment provides a summary of all comments received during the February 18, 1988 public meeting or by mail concerning the Pilgrim Restart Plan. The Attachment also indicates how and where (i.e., oral transcript or written response) the NRC intends to address / respond to these comments. The following key identifies the asconse location: PP-T - Public Participation Presentation - Transcript EP-T - Emergency Preparedness / Radiological Monitoring Presen-tation - Tr nscript CONT-T - Containment Presentation - Transcript MGT-T - Panagement Presentation - Transcript W - Written Response in Handout
.n
. s i
Summary of Comments - The following list summarizes the comments received during the February 18, 1988 public meetings and by mail during the announced comment period. For cross-reference, the commenters are identified numerically a'nd in general, arranged in order of the afternoon session (oral and written), the evening session (oral t ind written (W)), and. t....e received by mail (M). The page numbers refer to either the location of the specific comment in the transcript (most cases) or the start of the commenter's presentation. Commenter Page Response Number Number Comment Location
- 1. 12 1. Wants Show Cause Hecring to PP-T address:
Management Issues Offsite Emergency Preparedness Containment Concerns 14 2. NRC does not allow public PP-T participation in that only one 2.206 Petition was granted out of hundreds filed 16 3. Restart Plan does not address MGT-T recent management concerns such as :ontamintted dirt pile, fire, and LOOP.
a Attachment 2 - Summary of Comments 2 Commenter Page Response Number Number Comment Location
- 2. 17 1. Wants Adjudicatory Hearing. DP-T 17 2. Problems with containment CONT-T need to be dealt with before Restart.
17 3. Wants a proven (tested), EP-T workable Evacuation Plan in place prior to Restart. W 4. The Restart Plan and meeting PP-T transcript should be placed in Manomet Branch of the Plymouth Public Library. W 5. Pilgrim power is not necessary. W
- 3. 20 1. Actual water level in BWR is W not known.
22 2. Current valve position W monitoring is inadequate.
- 4. 23 Opinion - Pro Restart -
- 5. 25 Opinion - Pro Restart -
- 6. 27 & Allegation of potential over- W W exposure incident.
Attachment Summary of Comments 3 Commenter Page Response Number Number Comment Location
- 7. 33 1. It appears that the reactor is W inherently unsafe if a situation occurred which puts stress on the reactor.
34 2. Wants a tested, workable EP-T evacuation plan prior to Restart. 34 & 3. Wants concern over elevated EP-T M cancer rates resolved prior to Restart. M d. Can Pilgrim's Containment CONT-T withstand the stress of a moderate to severe accident?
- 8. 38 & l. Management, due to large MGT-T W staff changes, is untested in the operational phase of Pilgrim.
38 & 2. Has restructuring resulted in MGT-T W overload of VP-Nuclear? 39 & 3. There is no effective emerg- EP-T W ency plan and specifically there are problems of overloaded evacuation routes and shelters for transient population. 41 & 4. Wants Adjudicatory Hearing. PP-T W
- 1 Attachment 2 - Summary of Comments 4 N
Commenter Page Response Number Number Comment Location
- 9. 43 & 1. Have management changes prepared MGT-T W BECo for improved performance?
43 & 2. Increase NRC monitoring after MGT-T W startup. 44 & 3. NRC must evaluate containment CONT-T W improvements. 45 & 4. Acceptable evacuation plans EP-T W should be developed as rapidly as possible, but not prereq. for Restart.
- 10. 50 1. The highest NRC officials should PP-T make the Restart decision based upon application of the highest standards of excellence.
51 2. NRC should be extremely alert MGT-T during any beginning phases of operation. 51 3. Restart should not be allowed EP-T unless adequate emergency response plans are in place.
. Attachment 2 - Summary of Comments 5 Commenter Page Response Number Number Comment Location
- 10. 54 4. NRC has to make greater MGT-T (Continued) effort to explain decisions so that the public can understand them.
55 5. Adequacy of containment must CONT-T be resolved prior to Restart.
- 11. 56 Opinion - Pro Restart -
- 12. 57 Opinion - Pro Restart -
- 13. 60 1. Repairs and modifict.tions CONT-T (including SEP) completed prior to Restart.
60 2. Management problems resolved MGT-T prior to Restart. 61 3. Upgraded system for monitoring EP-T radioactive emissions from plant be installed and checked regularly by NRC and State (prior to Restart). 61 4. A workable evacuation plan EP-T be completed prior to Restart.
+
Attachment 2 - Summary of Comments 6 Commenter Page Response Number Number Comment Location
- 13. 61 5. The health impact studies on EP-T (Continued) the communities need to be completed prior to Restart.
61 6. A permanent repository for W spent fuel rods needs to be established prior to Restart. 61 7. All other alternatives for W energy production have been fully exhausted prior to restr.rt.
- 14. 62 Opinion - Pro Restart. -
15, 70 Migratory species of fish feed on EP-T radioactive substances from Pilgrim.
- 16. 72 Requests Show Cause Hearing. PP-T
- 17. 74 Who pays for the cost of 'W relocation after an accident?
- 18. 75 & 1. Wants Adjudicatory Hearing to PP-T W address:
- Management issues
- Evacuation planning
- Containment problems I _
I Attachment 2 - Summary of Comments 7
)
Commenter Page
~
Response
Number' -Number Comment Locatien
- 18. 76 & 2. Recent (Nov 87) plant events MGT-T (Continued) W indicate it's unsafe to Restart.
- 19. 78 & W 1. Wants Adjudicatory Hearing. PP-T 78 & 2. Resolve question on link EP-T W between cancer and nuclear power prior to Restart.
78 3. Evacuation Plan approved by EP-T FEMA prior to Restart. 79 4. Commissioners should r.ake MGT-T. on-site visits to assess health and safety problems. 79 5. Wants opportunity to appear MGT-T before Commission prior to Restart.
- 20. 9 1. Phrases in Plan indicate MGT-T organization and operation in enormous transition.
Which actions have been taken? Which are critical to safe plant operation?
a -. Attachment 2 -. Summary of Comments 8 Commenter Page Response Number Number Comment Location
- 20. 10 2. Management Effectiveness:
(Continued)
- Where are the clearly MGT-T specified criteria for judging?
Where is the performance MGT-T evaluation process defined? 10
- Who besides BECo top MGT-T management is actually assessing and evaluating operation?
- Who will do it during MGT-T the Power Ascension Program?
10 3. What are the NRC evaluators MGT-T qualifications and experience? Will NRC be present throughout MGT-T the Power Ascension process? Will NRC management performance MGT-T evaluation guidelines be available onsite?
e
-. Attachment 2 - Summary of Comments 9 Commenter Page Response Number Number Comment location f .
- 20. 11- 4. Requests NRC presence onsite MGT-T (Continued) through entire process.
(Outage, Power Ascension?)
- 21. 12 & Wants Adjudicatory Hearing to PP-T W address:
- Management Issues
- Reactor Safety Issues Emergency Planning Issues
- 22. 15 1. Restart Plan is time -
dependent, does not reflect where the process is. Specifically: M + Appendix 2, What is the W negative float for each of the activities not yetcompIOtd~d? M
- Appendix 3, firJre sh$uld W be 6 shifts of licensed operators prior to Restart.
M + Appendix 4, All positiocs W in the Radiological Section should b? filled prior to Restar"
Attachment 2 - Summary of Comments 10 Commenter Page Response Number Number Comment Location
- 22. 15 (Continued)
(Continued) M
- Appendix 5, The PEI W reports should be updated.
M
- Appendix 6, khat's the W status of the 11 Open Items in the MCIAP?
M
- Appendix 7, What is the W status of the RAP Items?
M
- Appendix 8, What is the W status of CAL 86-10?
M
- Appendix 9, With respect W to Meeting 86-41, what's tho status of security, fire brigade and Appendix R?
16 2. Comments due 10 days after MGT-T invitation. 17 3. Want hearings on: PP-T
- Management Issues
- Emergency Response Issues
. Attachment 2 - Summary of Comments 11 Commenter Page . Response Number Number Comment Location
- 22. 17 4. Public meeting (2/18) falls in MGT-T (Continued). traditional vacation week.
M 5. Additional time needed to MGT-T review Appendix 11.
- 23. 19 1. Wants Adjudicatory Hearing. PP-T
- 2. Meeting held during school MGT-T vacation week.
- 24. 22 1. NRC has yet to demonstrate an MGT-T attitude of understanding fears and concerns of residents.
69 .. Will the NRC allow reste"t EP-T without being satisfied that evacuation availabilities are adequate?
- 25. 22 & W Opinion - Pro Restart (Technical). -
23 1. Health and environmental effects EP-T of operating nuclear plant tre negligible. 23 2. Emergency Planning is only a EP-T supplement of engineering safeguards built into the plant. 24 3. Evacuation is possible. EP-T
l i
. Attachment 2 - Summary of Comments 12 Commenter Page Response l
Number Number Comment- Location
- 26. 27 Opinion - Pro Restart. -
- 27. 28 Opinion - Pro Restart. -
- 28. 29 Opinien - Pro Restart. -
- 29. 30 & W Opinion - Pro Restart. -
31 1. Health records do r.ot support EP-T claims of cancer problems. 32 2. New management has turned MGT-T around the plant. 32 3. Pilgrim energy is needed. W 78 4. Opinion - If cancer registry EP-T data is flawed, the state government did not do the job it was supposed to.
- 30. 34 & W 1. Disagrees with BECo letter EP-T that there is a sufficient sheltering capacity for the beach population.
36 2. High tide makes evacuation EP-T of Duxbury beach impossible. 37 & W 3. Roads are inadequate for EP-T evacuation of area.
Attachment 2 - Summary of Comments 13 Commenter Page Response Number Number Comment Lacation
- 31. 42 1. Wants Adjudicatory Hearing PP-T for:
- Management Issues Evacuation Plan Issues Containment Issues 41 2. Recent plant events reinforce MGT-T views of poor management 73 3. Considering the emergency EP-T planning scenarios, does the spectrum of accidents include a breach of containment?
- 32. 46 & W 1. Protests meeting forum: MGT-T
- held during vacation week
- only 10 days notice to review Plan discourages public participation by limiting comments to Restart Plan.
- 2. Wants evidentiary hearing for: PP-T
- Containment Issues
- Offsite Emergency Planning Issues Health Issues
. Attachment 2 - Summary of Comments 14 Commenter Page Response Number Number Comment Location 33 49 1. Wants Adjudicatory Hearing to PP-T adoress:
Containment Issues Evacuation Time Estimates
- Management Problems W 2. Corporate mission, as stated MGT-T in the Restart Plan, indicates safety is second to continued Pilgrim operation.
W 3. Restart Plan provides no MGT-T criteria by which performance will be measured. W 4. There is no sense of what an MGT-T appropriate level of performance is to be for a given task. W 5. Restart Plan calls for greater MGT-T accountability for results, the focus of which sends the message that the bottom line is output not as much how its achieved (e.g., safety values).
T 1 l .
. Attachment 2 - Summary of Comments 15 Commenter Page Response Number Number Comment- Location 33(Continued) W 6. Plan calls for anticipating and MGT-T planning for routine work and . improvements. It should anticipate and plan for the non-routine, since it's the unusual or infrequent event that can cause harm.
W 7. It is unclear who is going to MGT-T assess whose performance and how, who will identify, report to whom and correct problems. W 8. Restart Plan states that MGT-T supervisors will be directed to understand the contents of the Plan and will direct the next line of authority to co likewise. How can anyone be directed to understand? W 9. Infusion of navy-style manage- MGT-T ment is apparent throughout the Plan. How will an authoritative paternalistic style of management work with the civilians who have been doing well?
Attachment 2 - Summary of Comments -16 Condnenter Page Response Number Number Comment location 33 (Continued) W 10.- The reporting structure (navy MGT-T style, hierarchical authority structure) is urvally not responsive to. complex unexpected events.
, W 11. Reorganization concentrates MGT-T too much decision mating at the Senior VP Nuclear position.
W 12. How does t'.e shift of W responsibility for radiological e control to the individual supervisors affect the necessary attitude change of radiological workers? W 13. Will the new radiation train- W ing overcome the past indoc-trination that said the "stuff" is harmless? W 14. Does the fact the new MGT-T Operations Manager is a former NRC inspector bias the NRC in evaluating operational readiness?
. } . Attachment 2 - Summary of Corrments 17 Commenter Page Response Number Number Conment Location 33 (Continued) W 15. Does anyone in the NRC have a MGT-T basis of management expertise from which to evaluate organizational capability beyond immediate functional levels?
W 16. Isn't the reasen why the NRC CONT-T denied the 2.206 Petition Hearing request because if policy issues such as Mark I containment design were ~ brought into focus, it would affect other plants besides
. Pilgrim?
i
- 34. 51 Requests hearing to address PP-T energency response plans.
- 35. 53 Several things throughout the W plant are jury rigged.
- 35. .58 1. Very few citizens.have the PP-T time or expertise to go through the Restart Plan which therefore limits public participation.
. Attachment 2 - Summary of Comments 18 Commenter Page Response Number Number Comment Location 36 (Continued) 58 2. Plan subject to revision, MGT-T therefore very little can be accomplished at this stage of restart process. 58 3. The public has no way of MGT-T knowing how their testimony will be dispositioned. 59 4. Future final meeting is MGT-T planned to be held in Washington which is not conducive to public participation. 59 5. NRC has not indicated what MGT-T its criteria or outstanding items are upon which to basing the restart decision and what sort of public participation is planned with regard to such a list. 37, 61 Opinion - Pro Restart. -
- 38. 62 1. Opinion - Against restart EP-T (worried about environmer.t).
76 2. Worried about evacuation for EP-T handicap.
~
. . Attachment 2 - Summary of Comments 19 Commenter. Page . Response Number Number Comment Location
- 39. 65 1. Emergency Plan needs to be EP-T revised and tested prior to restart.
65 2. The radiation monitoring EP-T (offsite?) is flawed with a lack of (State?) onsite monitoring system. 67 3. Disagrees that there's no EP-T link between cancer rate and radiation exposure. 66 4. State's cancer registry EP-T data is flawed.
- 40. 67 Opinion - Pro Restart. -
- 41. 74 Opinion - Plant should restart for -
economic reasons.
- 42. 78 Evacuation of any kind would not EP-T be effectively handled due to human element.
- 43. 81 1. Fundamental question of CONT-T integrity of the containment has not been adequately addressed by the NRC.
. Attachment 2'- Summary of Comments 20 Commenter Page Response Number Number Comment Location 43 (Continued) 81 2. Wants adjudicatory hearings PP-T (favorable response to 2.206 Petitions). W 3. Recommendations of the Joint Special Committee Investigating Pilgrim: Creation of a Commonwealth - Division of Nuclear Facilities Safety
- Endorsement of compre- W hensive load management and conservation programs ,
Prioritize Massachusetts W based electrical generating facilities
- Department of Public W Utilities to establish a five year supply plan without reliance on Pilgrim
- Attachment 2 - Summary of Comments 21 Commenter Page Response Number Number Comment location 43 (Continued) W
- Review of SALP and recommedcd measures to correct serious functional deficiencies (and eliminate any Category 3's) such as management involve-ment, training, maintenance backlog, staffing vacancies and modification completion in the areas of:
Radiological Protection, W Surveillance, Fire pro-tection, Security and Safeg~uards, Atsurance of Quality, Plant Equipment, General Management concerns and Standby Gas Treatment : System Reactor Containment CONT-T - Decommissioning Plan W Improved Emergency Preparedness EP-T Plan
~
Attachment 2 - Summary of Comments 22
- Commenter Page Response Number Number Comment Location
- 44. .87 Homeowner insurance policy has V clause that excludes any damage from nuclear hazard. Some way needs to be found to enable homeowner to insure against this hazard.
- 45. 88 1. Sirens and speakers are EP-T unintelligible during tests.
89 2. Emergency planning; concerned EP-T over school, hospital and nursing home evacuation and inadequate road systen.
- 46. 92 1. Hanauer memo or report CONT-T (1971) stated that none of the Mark I containment plants should be allowed to go into operation. This report wac suppressed by the Commission.
93 2. State health survey statistics EP-T are incomplete. L 1
- - , _ - , m . -- , - . , . _ , _ , _ . , . , . _ . , . _ . . . - _ . _ _ , , , , _ -, , , _ _ . _ , , . . _ _ _ _ - _ . - ~ _ . .
-4
- Attachment 2 - Summary of Comments 23 Commenter Page Response Number Number Comment Location 46(Continued)94 3. Spent fuel pool reracking and W consolidation cause danger.of an explosion.
95 4. The location of an preparation MGT-T time for Restart Plan public review was inadequate.
- 47. 99 1. Emergency Planning: EP-T 99
- Evacuation plan is terrible 99
- Roads are inadequate 100
- Hospitals not capable of treating radiation victims 101 2. Wants formal hearing. PP-T
- 48. 103 1 Emergency planning is EP-T s inadequate for restart, in particular, the evacuation time estimates and shelter survey.
104 2. Failure to notify proper MGT-T authorities of the unusual event (fire) casts doubts on the company's integrity. I
s
. Attachment 2 - Summary of Comments 24 Commenter Page Response Number Number Comment- Location 48 (Continued) 104 3. Public meeting was publicity MGT-T campaign on the part of NRC and BEco.
- 49. 113 Opinion - Pro Restart. -
5C. W General concern with:
- 1. Evacuation of Cape Cod. EP-T
- 2. Property value after an W accident.
- 3. Embrittlement and corrosion W problems resulting in high repair / replacement costs.
- 4. Nuclear waste. W
- 51. M Opinion - Pro Restart. -
- 52. H Opinion - Pro Restart. -
- 53. M Opposed to restart until all local EP-T emergency preparedness measures are in place, fully tested and ready for implementation.
1
--+3 - .
~
Attachment 2 - Summary of Comments 25 4 Commenter Page -
Response
_ Number Number Comment Location
- 54. M 1. -Wants adjudicatory hearir.g to PP-T resolve:
- Management Issues
- Emergency Preparedness Issues
- Reactor Safety Issues M 2. What action will be taken W against BECo for the two security breaches in August 1987.
M 3. What are the results of the' W NRC's review of the overtime allegations? M 4. Will the ilRC issue a full MGT-T report on the events of November 7 and 8, 1987, including an assessment of their causes and suggested remedthi actions? l M 5. Has the NRC reconsidered W its procedures for site inspections so that there will be unannounced inspections every twenty-four hour period? l [ ..
g Attachment 2 Summary of Comments 26 Commenter Page Response Number' Number Comment Location 54(Continued)_M 6. What role, if any, will the W ,
.NRC play in the implementation of the LOOP AIT recommendations?
M 7. When will the NRC make a CONT-T final decision regarding the installation of the Direct Torus Vent?
- 55. M 1. Critical of NRC for being MGT-T lax with BEco.
M 2. Opposed to restart without EP-T a workable evacuation plan.
- 56. M 1. Opposed to restart considering MGT-T continuing problems involving contaminated dirt pile, fire, and LOOP.
M 3. Opposed to restart for EP-T emergency preparedness issues including lack of plans, inadequate roads and lack of shelters.
- 57. M Opinion - Pro P,estart. -
4
. Attachment 2 - Summary of Comments 27 Commenter Page Response Number Number Comment location
- 58. M Opinion - Pro Restart. -
- 59. M Against restart in light of past MGT-T.
continuing problems such as contaminated dirt pile.
- 60. M Opposed to restart because of:
Incidence of cancer near the EP-T plant.
- Inadequate road system for EP-T evacuation.
No way to dispose of spent -W fuel.
- 61. M Generally positive noting -
improvements in plant management and communications with EPZ towns, however, much still to be done in EP-T the areas of evacuation and training of local civil defense personnel.
- 62. M Opinion - Opposed to Restart. -
- 63. M Requests Show Cause Hearing. PP-T
Attachment 2 - Summary of Comments 28 Comme.ter Page Response
-Numbe- Number Comment Location
- 64. M Opinion - Opposed to Restart. -
- 65. M Opinion - Pro Restart -
M 1. Pilgrims containment is CONT-T-diffferent from Chernobyl M 2. Excess cancer cases, if EP-T: observed around Plymouth, could not be attributed to radiation. M 3. Evacuation is possible around EP-T Pilgrim.
- 66. M Sirens and speakers unintelligible EP-T during tests.
- 67. M Opinion - Pro Restart. -
- 68. M Opinion - Pro Restart, ,
M 1. Cites various examples of MGT-T management / policy improvements. M 2. Cites improvements in EP-T Emergency Planning Procedures / facilities.
\
.; . Attachment 2 - Summary of Comments 29 Commenter Page Response Number Number Comment Location v
68 (Continued) M 3. Cites several modifications to - improve reactor / plant quality / safety.
- 69. M Opinion - Opposed to Restart. -
l
- 70. M Wants Adjudicatory Hearing'to PP-T address:
i a Management Issues
- Emergency Response Plans
- Reactor Safety Concerns
- 71. M Op nion - opposed to restart with MGT-T references to management and EP-T evacuation plan problems. !
E
ATTACHMENT 3 WRITTEN RESPONSE TO pVBLIC COMMENTS I. Comment (s): 17 74 Who pays for the cost of relocation after an accident? 44 87 Homeowner insurance policy has clause that excludes any damage from nuclear hazard. Some way needs'to be found to enable homeowr.ar to insure against this hazaro. 50 W General concern with property value after an accident. Answer: Virtually all property and liability insurance policies issued in the United States, except the ones issued by the nuclear insurance pools, exclude nuclear damage. The exclusion means that claims for damage to a policyholder's dwelling, automobile or other property by radiation or con-tamination from a nuclear facility would not be collectible under that policyholder's own insurance policies. Thus, if a property owner suffered damage to his property because of a nuclear accident, the compensation would come from nuclear liability insurance or government indemnity as provided under Price-Anderson. While the Price-Anderson Act does not pro-hibit private insurers from offering this type of insurance, the standard fire and property policies have contained the exclusion since 1959. The l insurers consider that property damage caused by a nuclear accident would be covered by nuclear liability insurance provided under the Price-Anderson Act and that coverage for the same property should be excluded from the conventional homeowner's policy to avoid duplication of coverage. l I i l u
Attachment 3 - Written Response to 2 Public Comments The Price-Anderson Act, which became law on September 2,1957, as part of the Atomic Energy Act of 1954, was enacted by Congress to meet two basic objective:: (1) To c.1sure that adequate funds would be available to satisfy liability claims of members of the public in the unlikely event of a very low probability catastrophic nuclear accident; and, (2) To remove the deterrent to private svtar participation in the use of nuclear power presented by the threat of potentially large lia-bility claims if such an accident were to occur.
- Price-Anderson provides a system to pay funds for claims by members of the public for personnel injury and property damage resulting from a nuclear accident.
Principal obstacles to a claimant's recovery for injuries or damages under the Price-Anderson Act could be the traditional legal defenses against liability available to the defendant, such as the claimant's conduct, failure to prove the defendants negligence, actions that are the fault of persor s indemnified, or charitable or governmental immunity. Congress attempted to remove these obstacles in 1966 by amending Price-Anderson to introduce the concepts of extraordinary nuclear occurrence (ENO) and waiver-of-defenses. "Extraordinary nuclear occurrence" is defined as an offsite dispersal of nuclear materials in amounts causing radiation levels that NRC determines to be substantial and that NRC determines has resulted, or will probably > esult in substantial damages to persons or to property of fsite. When NRC determines that a nuclear incident is an ENO, then the waiver-of-defenses provisions of' the insurance pelicies and in-demnity agreements making up the Price-Anderson system are activated, re-sulting in an essentially "no fault" recovery scheme. Claimants would
?
, Attachment 3 - Written Response to 3
!' Public Comcents then need only show (1) personal injury or damage, (2) monetary amount of loss,'and (3) a verifiable link between the loss and the radioactive mate-rial released. Claimants would not need to establish the fault of any party in order to pursue their claims.
For more information, obtain a copy of NUREG/8R-0079 from the Office of State Programs, United States Nuclear Regulatory Commission, Washington, D.C. 20555 (301) 492-7000. I l L
Attachment 3 - Written Response to 4 Public Comments II. Comment (s): 13 61 A permanent repository for spent fuel rods needs to be established prior to restart. 50 W General concern with nuclear waste. 60 M No way to dispose of spent fuel. Answer: The Nuclear Regulatory Commission initiated a rulemaking proceeding on October 25, 1979 to assess generically the degree of assurance that radio-active waste can be safely disposed of, to determine when such disposal or off-site storage will be available, and to determine whether radioactive wastes can be safely stored on-site past the expiration of existing facility licenses until off-site disposal or storage is available. This proceeding became known as the "Waste Confidence Rulemaking." The Commission's decision is summarized in the following findings: (1) The Commission found reasonable assurance that safe disposal of high level radioactive waste and spent fuel in a mined geologic repository is technically feasible. (2) The Commission found reasonable assurance that one or more mined geologic repositories for commercial high-level radioactive waste and spent fuel will be available by the years 2007-08, and that suffi-ciert repository capacity will be available within 30 years beyond expiration of any reactor operating license to dispose of existing commercial high-level radioactive waste and spent fuel originating in such reactor and generated up to that time.
Attachment 3 - Written Response to 5 Public Comments (3) The Commission found reasonable assurance that high-level radioactive waste and spent fuel will be managed in a safe manner until suffi-cient repository capacity is available to assure the safe disposal of ~ all high-level radioactive waste and spent fuel. (4) The Commission found reasonable assurance that, if necessary, spent fuel generated in any reactor can be stored safely and without sig-nificant environmental impact for at least 30 years beyond the expir-ation of that reactor's operating license at that reactor's spent fuel storage basin, or at either on-site or off-site independent spent fuel storage installations. (5) The Commission found reasonable assurance that safe independent on-site . or of f-site spent fuel storage will be made available if such storage capacity is needed. In keeping with its commitment to issue a rule providing procedures for considering environmental effects of extended on-site storage of spent fuel in licensing proceedings, the Commission issued changes to 10 CFR Parts 50 and 51. In adopting ch:nges to 10 CFR 50.54, the Commission established procedures to confirm that there will be adequate lead time for whatever actions may be needed at individual reactor sites to assure that the management of spent fuel following the expiration of the reactor operating license will be accomplished in a safe and environmentally acceptable manner. Accordingly, no discussion of any environmental impact of spent fuel storage for the period following expiration of the license or amendment applied for, is required in connection with the issuance or amendment of an operating license for a nuclear reactor. For a more extensive discussion of these rulemakings, see the Federal Register Notice (49 FR 34658 - August 31,1984). I
u: . Attachment 3 - Written Response to 6 Public Comments III. Comment: 3 20 Actual water level in BWR is not known. Answer: Reactor vessel -level is determined by differential-pressure devices. Con-densing chambers connected to the steam space in the reactor vessel are used as the reference-leg. Pressure taps at different levels in the water space of the reactor vessel are used as variable leg sensing taps for narrow and wide range instruments. The differential pressure method of measuring vessel water level senses the weight of fluid above the lower instrument tap and is calibrated in terms of water at a predetermined density. Therefore, its reading is a collapsed liquid level measurement (the equivalent level of single phase liquid), ine reading is thus a representative of the mass of water above the sensing tap rather than an indication of the actual fluid surface, which will be higher than indi-cated if steam is present in the reactor water. A more extensive discussion of the response of a generic reactor vessel level detection system to transients can be found in Section 2.17, "Vessel Level Detection" of Appendix A to NUREG-0626, "Generic Evaluation of Feed-water Transients and Small Break Loss-of-Coolant Accidents in GE-Oesigned Operating Plants and Near-Term Operating License Applications," January, 1980.
~ Attachment 3.- Written Respon~se to 7 Public Comments IV. Comment (s):
2 W Pilgrim power is not necessary. 13 61 All other alternatives for energy production have been fully exhausted prior to restart.
-29 32 Pilgrim energy is needed.
43 W Endorsement of comprehensive load management and con-servation programs. 43 -W Prioritize Massachusetts based electrical generating facilities. 43 W Department of Public Utilities to establish a five-year supply plan without reliance on Pilgrim. Answer: The only known requirements to address the comments given above are con-tained in the Commission requirements for environmental reports found in 10 CFR Part 51. Following the granting of an operating license, the Commission does not evaluate the need for power or use of. alternate energy sources in making decisions related to operating license for a specific nuclear plant.
' We do recognize, however, that these issues may be presented and argued in rate cases to the local public utility commissions.
--- . ~ , . _ , - - . - - -
,-- - - . ,- ,.-- ,r-.,_ --1 --.____v., _,,e--. , . - , , . -----m, - . - . . - -
.; I Attachment 3 - Written Response to 8 Public Comments V. Comment: ,.
54 M Has the NRC reconsidered its procedures for site inspections so that there will be unannounced inspec-tions every twenty-fvur hour period? Answer: At this time, the NRC does not require unannounced inspections every twenty-four hour period. It is our goal that resident inspectors spend their normal work week at the site with about 20 percent of this time on
- backshift and/or weekend coverage. These backshif t and weekend inspec-tions are generally random and unannounced. Additional inspections are conducted by NRC specialists and focused team inspections.
To manage finite NRC inspector resources, including maintaining the flexi-bility to respond to events at any site, the inspection program is de-signed to critically examine, on a planned sampling basis, the implementa-tion of the licensee's controls for adequacy in protecting the public. It is emphasized that NRC inspectors are not on-site to duplicate or substi-tute for a licensee's management controls established as a part of its quality verification system. Further, NRC has imposed sufficient eveit reporting requirements on licensees to assure an appropriate level of at-tention can be brought to bear on any facility in response to significant events. We believe the current system of routine and random unannounced backshift inspection provides the most effective use of inspector resources to sup-port the NRC's mission and to assure the public's health and safety are protected. 4
. Attachment 3 - Written Response to. 9 Public Comments VI. Comment (s):
54' M What action will be taken against Boston Edison Company (BECo) for the two security breaches in-August 1987? 54 M What are the results of- the NRC's review of the over-time allegations? Answer: NRC's initial review of the security breaches and overtime allegations are documented in Inspection Report Nos. 50-293/87-30 and 50-293/88-07 respec-tively. Final NRC action is pending ongoing reviews; however, the licen-see's corrective action programs to maintain security barriers and effec-tively control overtime are restart ' issues and will be reviewed for ade-
.quacy prior to any restart decision.
f
Attachmant 3 - Written Response to 10 Public Comments VII. Comment: 54 M What role, if any, will the NRC play in the implemen-tation of the loss of Offsite Power (LOOP) Augmented Inspection Team (AIT) recommendations? Answer: In response to the LOOP at Pilgrim on November 12, 1987, an NRC AIT was dispatched to the site to determine - the - sequence, the causes and the safety significance of the event. The team's findings are documerted in Inspection Report No. 50-293/87-53. The report also contains severa1 ~ recommendations for BECo to consider in order to improve the stations ability to respond to future similar events. All of the recommendations were added to the NRC's open items list for tracking and subsequent re-view. In addition, four of the recommendations (the third emergency diesel generator, the backup instrument air supply, the additional-instru-ments to analyze switchyard transients, and determination of the cause of the blown fuses in the analog trip system) were made restart issues and will be completed and inspected by the NRC for adequacy prior to any decision on restart.
e
. Attachment 3 - Written Response to 11-Public Cemments VIII Comment:
7 33 "It appears that the reactor is inherently unsafe if a situation occurred which put stress on the reactor." Answer: All reactor designs are reviewed to determine whether a reactor can with-stand, 'with extra margin, a number of design oasis transients 'and acci-dents. These transients and accidents are identified in the staffs' Standard Review Plan. If the staff should determine that any reactor could not withstand any of the design basis transients or accidents, the staff would require either plant modifications to assure the safety of the reactor or terminate reactor operations. Presently, the staff is not aware of any design flaws such that the Pilgrim reactor would not be able to withstand any of its design basis transients or accidents. .The Mark I containment issue will be further discussed in the meeting transcript.
' Attachment 3 Written: Response to 12 Public Comments IX. Comment:
46 4 Spent fuel reracking and consolidation causes danger of an explosion. Answer:
-At this moment, there is not an application before the staff to expand the spent fuel storage capacity at the Pilgrim plant. Further, there is no known phenomenon resulting from reracking or consolidation that would create an explosion, as suggested. During the course of its review of--
spent fuel reracking amendments, the staff evaluates design basis trans-ients and accidents including loss of cooling water and fuel handling accidents to assure that all licensing criteria are satisfied. The oppor-tunity for public hearing on the modification is also provided. Most recently, the staff is also evaluating accidents in the spent fuel . pool which would be considered beyond the plant design basis. Most notably is the structural failure of the spent fuel pool leading to a subsequent zirconium cladding fire (see NUREG/CR-4982). These design basis events are being studied generically as Generic Issue 82. If d6termined neces-sary, the resolution of Generic Issue 82 u:uld result in recommendations for improvements at all operating reactors. 1
Attachment.3 - Written Response to 13 Public Comments X. Comment 43 W It is unclear what happens to the plant and storage of radioactive waste when the plant is permanently closed. The questions of the cost involved decommis-sioning, the impact on Plymouth taxes, waste storage, security, and dismantling or "sealing" of the reactor building are of great concern to area residents. The NRC, the State and Boston Edison should develop decom-missioning plans, well before a scheduled closing, to answer these and other questions. Answer: 10 CFR 50.54(bb) requires that no later than five years before the expira-tion of the reactor operating license, licensees of operating nuclear power reactors shall submit written notification to the Commission for its review and preliminary approval of the program by which the licensee in-tends to manage and provide funding for the management of all irradiated fuel at the reactnr upon expiration of the reactor operating license until title to the irradiated fuel and possession of the fuel is transferred to the Secretary of Energy for its ultimate disposal in a repository. Final Commission review will be undertaken as part of any proceeding for con-tinued licensing under Part 50 or Part 72. The licensee.must demonstrate to NRC that the elected actions will be consistent with NRC requirements for licensed possession of irradiated nuclear fuel and that the actions will be implemented on a timely basis. The issue of spent tuel repositories was previously discussed in Comment Il response.
E
. Attachment 3 - Written Response to' 14 t Public Comments XI. Comme _nt: .
3 22 Current valve stem position monitoring is- inadequate. Answer: The staff position or philosophy has been that it is ntore important to monitor the variables associated with the process stream (i.e. , water,
. steam, etc.) rather than concentrate on the accuracy of a given valve position. Staff reviews routinely emphasize the use of flow rate, temper-ature and pressure' instrumentation in order to provide a reasonable means to gauge required safety system performance. Once obtained, the process stream variables can be compared to the design basis values. Plant oper-ators can then make an assessment whether the systems are operating within the plant design basis envelope.
Attachment 3 - Written Response to 15 Public Comments XII. Comment: 6 27 & W Allegation of potential radiation overexposure incident. Answer: Previously, on four separate occasions (twice in 1980, 1982.and 1986), the NRC reviewed all documentation supplied by the ir.dividual involved as well as the licenses's exposure records. On each occasion, the NRC concluded that the individual did not receive an exposure in excess of regulatory limits while employed at Pilgrim. In each case, letters were sent to the individual informing him of the results of the NRC reviews. In addition, the issue of whether his exposure at Pilgrim caused any physical ailment was the subject of a three day jury trial in Massachusetts Supervisor Court in 1982 and resulted in a jury verdict in favor of Boston Edison Company.
}
. Attachment 3 - Written Response to 16 Public Comments XIII Comment (s):
33 W How does the shift of responsibility for radiological control to the individual supervisors affect the necessary attitude change of radiological workers? 33 W Will the new radiation training overcome the past indoctrination that said the "stuff" is harmless? Answer: The NRC is not aware of the training problems noted by the commenter. The NRC routinely (approximately annually) reviews the. radiation worker train-ing program for adequacy and documents the findings in publicly available inspection reports. While the NRC is not endorsing the shift of responsibility for radiologi-cal control to the individual supervisors as the solution to BEco's past problems, we note it is not uncommon for supervisors to be responsible for worker safety whether it's industrial or radiological safety. Nor-mally, radiological organizations provide the policies, procedures, and oversight of the radiv!ogical control program. In placing the responsi-bility for performance on supervisors and workers, they can be held accountable for their actions. Nonetheless, the NRC will expect demonstrated improvement in worker atti-tudes and practices, and will evaluate the effectiveness of radiation worker training, prior to restart.
- Attachment 3 - Written Response to 17 Public Comments XIV. Comment:
50 W General concern with embrittlement and corrosion problems resulting in high repair / replacement costs. Answer: The NRC currently has programs that require licensees to identify and monitor the condition of reactor system components vulnerable to either intergranular stress corrosion cracking (IGSCC) or embrittlement. These programs are required to assure that any degradation of components is detected and evaluated. If necessary, plant modifications may be required to assure that operation of the plant will be within the previously approved design envelope. While NRC recognizes that repair / replacement ll costs for some components may be substantial, NRC's primary emphasis and concern is to assure necessary plant modifications restore the plant con-dition to the original design basis so that operation of the plant does not endanger the health and safety of the public. i r$ .
4 ' Attachment 3 - Written Response to 18 Public Comments XV. Comments: 22 M Appendix 2 - What is the negative float for each of the activities not yet completed? 22 M Appendix 5 - The Performance Excellence Indicator (PEI) reports should be updated. Answer: The NRC agrees with the comment on updating the PEI reports and has ! requested Boston Edison Company to formally transmit these reports to the NRC. These will subsequently be placed in the local Public Document Room (LPOR) for public review. In addition, Boston Edison Company will provide an updated PEI report with its Self-Assessment Report / Update of the Restart Plan which will also be placed in the Lp0R. , With respect to Appendix 2. "The Target Schedule", at this time all major work is essentially complete and there does not appear to be a neej or useful purpose for updating this Appendix. s 6
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Attachment 3 - Written Response to 19 Public Commento XVI. Comment (s): 1 22 15 Restart Plan is time dependent, does not reflect where the process is. Specifically: M
- Appendix 3 - There should be 6 shifts of licensed operators prior to Restart. ,
M
- Appendix 4 - All positions in the Radiological Section should be filled prior to Restart.
M
- Appendix 6 - What's the status of the 11 Open Items in the MCIAP?
M + Appendix 7 - What is the status of the RAP Items? M + Appendix 8 - What is the status of the Confirma-tory Action Letter (CAL) 86-107 i M
- Appendix 9 -
With respect to Meeting 86-41, what's the status of security, fire brigade and Appendix R? 35 53 Several things throughout the plant are jury rigged. ' 43 W Review of SALP and recommended measures to correct serious functional deficiencies (and eliminate any Category 3's) such as management involvement, train- " ing, maintenance backlog, staffing vacancies and modification completion in the areas of: Radiological Protection; Surveillance; Fire Protection; Security and Saf aguards; Assurance of Quality; Plant Equipment; , General Management concerns and Standby Gas Treatment . System. t
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. i Attachment 3 - Written Respon:a to 20 Public Comments Answer: .
The 1RC agrees with many of the comments and recommendations noted above ; by commenters 22 'and 43. The majority of these issues have been pre-viously identified by the NRC and are well documented in Inspection Reports, Systematic Assessment of Licensee Performance (SALP) Reports, and < generic documents such as NRC Bulletins and Information Notices. Simi-lacly, the majority of these issues have been identified as restart items and have been or will be inspected by the NRC to verify adequacy, 'This includes issues such as: the Standby Gas Treatment System single failure concerns; the staffing vacancies; the Appendix R modifications; the main-tenance backlog; and the effectiveness / adequacy of the radiological and security programs. i Finally, it should be noted that the NRC plans to perform a full Y.LP, and conduct a Integrated Assessment Team Inspection to evaluate the 9ffective- i-ness of licensee corrective action programs and the readiness of the plant ; equipment and personnel to resume power operation, prior to making any decision on restart. i I f I
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. . ATTACHMENT 4
#1 BOSTON EDtSON Ngtim Nucleat %r 5' ate Rocky HJI Road Mymouth, Massachusetts 02360 Ralph G. Bird Smot We Present - Nuclear j BECo Ltr. #88 079 U.S. Nuclear Regulatory Comission Attn: Document Control Desk Hashington, D.C. 20555 Docket No. 50-293 License No. OPR-35
Dear Sir:
This letter is submitted in response to the NRC Staff questions transmitted by NRC letter dated March 18, 1988 regarding the Pilgrim Nuclear Power Station Restart Plan . Attachment I contains a restatement of the NR'C question followed imediately by the Boston Edison response. Please contact me directly if there are any questions regarding this letter. PJH/bl Attachment . cc: Mr. William Russell Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Sr. Resident Inspector - Pilgrim Station Standard BEco distribution
?
ATTACHMENT 1 l BECO Resoonse to NRC Review of Piloria Rectart. flan - NRC Ouestion 1 Volume 1 Chapter 2 of the Restart Plan needs to be updated to reflect the recent organizational and personnel changes. SECO Rfsoonse it.e recent organizational and personnel changes within the nuclear organization of cotton tdist.O Company will be described in a chapter on organizational and parsonnel cht.nges in the Final Report of Management Self-Assessment of Reediness to Restart. This report, which documents the results of the self-assessment, is a companion document to the Restart Plan and the Power Ascension Program. According to the current schedule, the self-assessment report will be issued in mid-May,1988. NRC Ouestion 2 Under the new organization, how will the functions attributed to the Planning and Restart Group as defined in Volume 1. Chapters 2 and 3 be accomplished? For example, the Nork Planning and EsU. mating Branch provided each section with a full time planner designed to enable the section to improve planning and scheduling of its own work and coordinate and integrate its %K plans and schedules with those of other sections ano discip:1nes. BECO Resnonse-Although the new Organization no longer has a group entitled "Planning , and Restart Group", the functions attributed to that group have been I retained, primarily tr. the Planning and Outage Management Department. For axample, there remains a full time planner (s) from the Planning and l Outage Management Department assigned to each Department to enable each Department to improve planning and scheduling of its own work and I coordinate and integrate its work plans and schedules with those of other sections and disciplines. The Materials Management Section was re-organized under the Plant Support Department. In addition, each day at 0600 hrs, and 1500 hrs. coordination meetings are held to facilitate support services (e.g.: Health Physics, Building services) for the day and to integrate the work which has been i planned. Page 1 of 9
. NRC Ouestion 3 There are no action itens in the appendices to schedule, indicate status, or track the program discussed in Volume 1 Chapter 4, of-transferring fire protection surveillance currently performed by plant operators to the Fire Protection Group.
BEC0 Resoonse The transition of responsibility for the performance of fire protection surveillances from the plant operators to the Fire Protection Group is scheduled after plant start-up outside the context of the Restart Plan. The plan which currently indicates the schedule and status and tracks this program is the Nuclear Fire Protection Group Long Term i Plan. This issue is tracked as item number seven in this plan. The purpose in scheduling the transition after plant start-up is to ensure an orderly turn-over, undisturbed by start-up pressures. In addition, fire protection personnel have focused existing resources on commitments which have been scheduled to be accomplished prior to plant restart. ' The current schedule for transferring the responsibility for performing fire protection surveillances to the Fire Protection Group is December, 1988. NRC Ouestion 4 There is no discussion in the Restart Plan on the adequacy or < effectiveness of High Radiation Area control. RECO Resoonse Effectiveness in the control of High Radiation Areas was identified as an area of concern by review of Radiological Occurrence Report (ROR) trends as described in the Radiological Action Plan (Action 02-603-02). Action was taken to restrict the handling of Locked High Radiation Area keys to Radiation Protection personnel for all work activities except non-routine plant operations. A process of , continuous access point monitorinq and double verification of door closure upon final exit has been 'nitiated. A directive from the Stat M Director to all site personnel has reemphasized the importani.e of individual responsibility and outlined the disciplinary policy for future vic,1ctions. Since implementation of these controls, the number of ROR's related to control of High Radiation Areas for the subsequent three months dropped by 90% compared to the previous three month period. Effectiveness of control has been achieved. Close attention to this trend indicator will continue as described in the Radiologics1 Action Plan. Page 2 of 9 l l
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NRC Ouestion 5 1
- There are no action items assigned or di.'.ession of trending performance and/or measuring effectiveness of the completed action items in Appendix 10, Issue 02-009, "Improve the radiological performance of Pilgrim Station personnel."
BECO Resoonse l Improvement of the radiological performance of Pilgrim Station ! personnel is addressed in a continuing fashion by and comprehensively addressed within the Radiological Action Plan (RAP). This plan was prepared as a result of self-assessments at the completion of the prior 1 Radiological Improvement Program effort. The status of RAP actions are ; contained in Tab 7 to the Restart Plan, Volume 2, Rev.1. NRC Ouestion 6
)
How do the work stoppage during the week of November 9,1987; the Loss of Offsite Power Augmented Inspection Team findings; and, the recent numerous Engineered Safeguards Feature actuations relate to the Haterial Condition Improvement Action Plan (MCIAP) as discussed in Volume 1, Chapter 47 Has BECo evaluated whether any changes to the MCIAP or other programs are necessary because of these events? BECO Resoonse The first portion of this question pertains to how recent events relate to the Material Condition Improvement Action Plan. As part of the investigations of the events leading to the work stoppage of November 9,1987 and of the Loss of Offsite Power (LOOP) BEco determined that common threads existed. The common threads involved: (1) planning, and (2) supervision of the activities of station personnel. Many of the investigations following specific Engineered Safety Features (ESF) actuations have resulted in the identification of these same common threads. Many of these recent events relate to the programmatic improvements of the long tern MCIAP actions. The actions related to improvement of the l planning and supervision of activities are in progress and are I scheduled to complete over the next several months. The existing MCIAP issues and long term actions that will assist management in preventing or minimizing the occurrence of similar events are:
- The bng ters organizational and staffing improvements outlined in the actions of issue 03-001.
- The performance standards improvements of issue 03-005.
l
- The supervisory development policy of issue 03-011.
l i Page 3 of 9 l
o The managezent feedback and MR scheduling improvements identified in issue 03-012 and improvements to the MR process outlined in issue 03-013.
- The maintenance planning improvements of issues 03-016 and 019.
- The work assignment improvements of 03-020.
- Development of an automated maintenance data base in accordance with issue 03-027.
- Preventive maintenance improvements of 03-028.
The second portion of question number 6 pertains to whether Boston Edison has evaluated the need to change the MCIAP or other programs because of these events. BECo has evaluated whether changes to the MCIAP or other programs are necessary. The results of those evaluations are summarized as follows: a) A Hork Stoppage "action plan" was developed using a data base file siellar to ths HCIAP and actions are in progress or complete. b) The results of the BECo LOOP investigation and the AIT findings were incorporated into the Restart Plan Appendix 10 listing and the required actions are in progress or cc.aplete. c) To date no required changes to the MCIAP in the above discussed areas have been identified, but reports of critiques and other problem identification processes are reviewed to identify possible programmatic items requiring MCIAP issue or action development. NRC Ouestion 7 Appendix 10, Issue 03-940-01 on th, valuation of procedures for receiving vendor supplied information and providing recommendations to correct identified problem areas has a due date of restart plus 240 days. This allestone appears excessive for the indicated action. What is the status of improving control of vendor supplied information? BECO Response The Appendix 10 Action Iten 03-940-01 encompasses all vendor technical information. BECo has a vendor technical information control program which is implemented by several groups and has been inspected by the NRC and audited by our QA Department with favorable results. The i elements of the vendor technical information program include the l Operating Experience Review Program, which provides centralized control for vendor technical information generated by INPO and our NSSS supplier (General Electric Company), the Regulatory Affairs and Programs Division's control of information generated by the NRC regarding plant equipment supplied by vendors, and vendor information , from other sources which line organizations evaluate via existing i processes. Page 4 of 9
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The industry he.s endeavored for several years to develep recommendations for integrated vendar technical information control. :
, The approach we plan to use will cepitalize on the industry's '
) progress. He intend to consider key elements of the NUTAC (Nucle'ar Utility Task Action Comittee) Vendor Equipment Technical Information J Program (VETIP) INPO 84-010 dated March 1984. The result will be a centralized approach to implement a VETIP at BECo. , The schedule for Appendix 10 Action Item 03-940-01 was developed i considering the fact that the programs / processes listed above provided
; adequate interim assurance that vendor information has been sufficiently implemented to support plant operation.
i i Accordingly, our schedule of restart plus 240 days was based on the magnitude of the effort to fully implement an integrated VETIP, recognizing the competing priorities to support plant restart and considering the need to accomplish this effort with our own personnel. l
- NRC Ouestion 8
! Appendix 10, Issue 03-905-08 discusses an evaluation of the motor ' operated valve failure analysis reports for adequacy. What followup
- actions and schedule will be developed from this evaluation?
1 i BECO Resoonse 1 The effectiveness evaluation of the MOV Program comenced in March 1988 upon the completion of the associated outage work activities. This review is scheduled to conclude June 17, 1988. The recomendations and improvement findings will be incorporated into the MOV Preventive Maintenance Program for RFO-8. Should significant follow-up actions result from the effectiveness evaluation, a modified response to this question will be provided including both the recomended follow-up actions and schedule for implementation. NRC Ouestion 9 , Why is the schedule for Maintenance Group performance trending system, Appendix 10, Issue 03-906-02, tied to restart? What is the current status of this system? BECO Response This item should have been categorized as a CONTINUING item as defined in Appendix 10. The Maintenance Group Performance Trending System has been implemented as a management tool to focus awareness on the performance indicators, and is published on a weekly basis. Action item 03-906-02 was closed on 02/08/88, after repeated monthly evaluations of continued effectiveness. Page 5 of 9
1
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NRC OuesttgrLig l While a few Jpecific procedure updates appear as action '+ ems and the legibility of drawings is discussed in Appendix 10, Issue 06-003,*how will BECa er.sure all procedures and drawings have been reviewed for adequacy and updated (if necessary) prior to restart? BECO Response This question has two major elements. The first element relates to procedural adequacy and the second element relates to drawing adequacy. The BECo Response addresses each element separately. P acedure Adeauacy j The processes in place at the PNPS to ensure procedure adequacy for plant restart are (1) the procedure validation process, (2) the two year review process required by ANSI '418.7-1976 and (3) the recent , administrative requirement that drawing changes be appropriately tied l to the procedure change process. Procedures are also reviewed for adequacy prior to implementation. Qu Una Adeauacy Drawing adequacy for the safe operation of PNPS is ensured by, (1) Engineering procedures requiring design drawings to be updated to reflect design changes, (2) the records management system identifying for retrieval the current official revision cf all drawings, and any outstanding design change modifications not yet incorporated, and (3) walkdowns of plant systems which have been performed to ensure drawings used on a daily basis by plant operations personnel are current and adequate. Desian Chance Drawina Undate NED procedures require that drawing changes be issued through the Plant Design Change (PDC) process. Af ter modification implementation, these drawings are updated to reflect the as-built design change and issued as an official "E" revision. Additionally, the PDC lists drawings
.ffected by the change (but not needed for modification implementation)
;o that these may also be updated and re-issued.
The PDC drawing update effort is prioritized so that drawings which may be used on a daily basis by plant operatiens personr.e1 are updated first. These so-callad "Priority" drawings xst be issued as an official "E" revision prior to operational turnover of the system. Non-priority drawings are updated to reflect as-built design changes after system turnover. System Walkdowns for Drawina Validation At the time these drawing update requirements were formally introduced (1984), it was recognized that previous design changes may not have been fully incorporated on official "E" revisions of drawings. The effort to confira drawing adequacy included walkdowns of certain Priority drawings used most frequently by operations and maintenance personnel (e.g. P&ID's). The walkdowns resulted in the identification and correction of drawing discrepancies on these drawings. Page 6 of 9
In addition, a specific procedure was developed to 5,rovide for a systematic review of all design changes from initial plant startup through refueling outage #6. Approximately 13,000 drawings have been revised under this program. Records Manaaement A system user has access to a complete picture of the current design status of any plant structure, system, or component by use of the Document Control Centers managed by the Records Management Division. Summary In sunnary, Boston Edison has undertaken a comprehensive series of , measures (e.g., design change drawing update, records management and l
. the corrective action program) which provide continuous controls to ensure drawing adequacy.
NRC Ouestion 11 Th e e is no action item or discussion in Volume 1 or Volume 2, Appendix 10, !! sui 07-001 of scheduling and tracking the technical training of BECo security personnel. This appears necessary to ensure the new hires can be fully utilized and, in the interin, assigned duties and responsibilities commensurate with their training and qualifications, jLECO Resoonse The Nuclear Security Section has developed a training program for security management outside the context of the Restart P'an. The program was designed specifically for the Security Shift Supervisors. However, other BECo and contractor security supervisory personnel also attend the training. This training covers the following subjects: PNPS Security, Plan Safeguards Contigency Plan Security Force Training and Qualification Plan Implementing Procedures (for the three plans) Safeguards Event Report (10 CFR 73.71) Protection of Safeguards Information (10 CFR 73.21) Duties and Responsibilities of the Contract Security Force Supervisory Training (cossnensurate with their Outy Positions) The completion date for training all current Security Shift Supervisors is scheduled for April 29, 1988. The new Adelnistrative Compliance and Technical positions were filled with individuals who were already qualified and experienced in their respective positions. Additionally, the more recent hires to fill the Security Shift Supervisor positions ali have a nuclear security backgrounf. Existing security supervisory personnel are qualified for the positions they fill. Page 7 of 9 l l .
NRC Ouestion 12 Mith respect to Appendix 10, Issue 07-002-11, what is the new completion schedule for the access control modifications? - BECO Resoonte The planned access control modifications at the Main Access Point which include installation of x-ray equipment for package searches and full . length turnstiles for added protection are scheduled for completion by 1 September 30, 1908. NRC Ouestion 13 There is no action item or discussion in Volume 1 or Volume 2, Appendix 10, Issue 10-002, of a training plan for management and technical new hires. BECO Resoonse Boston Edison is in the process of restructuring and expanding its supervisory and management training programs outside the context of the Restart plan. The new structure includes four component programs: New Exempt Orientation New Supervisor Crientation Management-Supervision Initial Management-Supervision Continuing : New management employees are required to participate in New Exempt ' < Orientation, normally within the first three months of their l employment. The content of this program includes, but is not limited to the following topics: Nuclear Organization Safety Administration Fire Protection Plan Records Management Housekeeping Policy Nuclear Regulatory Affairs Conduct of Operations Quality Assurance & Corrective Action Radiological Protection /ALARA Planning and Scheduling This program is instructed by the subject matter experts and is designed to give the staff sufficient skill and knowledge to permit them to function efficiently. They are also given the name of a contact person in each area should they require assistance. New supervisors will also participate in the New Supervisor Orientation l program and Management-Supervision Initial training. The format of the l New Supervisor Orientation program is the same as the New Exempt l Orientation program. Management-Supervision Initial is a formal program to teach basic - supervisory skills. Pt.gc 8 of 9
. -Manage:;ent-Supervision Continuing is offered to all managers and supervisors en an "as-needed" basis. Identification of the different prograss is accomplished normally through the use of a needs assessment form which Nuclear Training circulatts to coincide with the comparty's anr.aal developmental reviews. The results of the assessment are analyzed and an annual plan establishei based upon the frequency of l response and perceived need. On the technical side, we have an INPO-accredited program entitled , Technical Training for Staff and Managers. This program is coordinated l by the Technical Training Section and is targeted for a wide variety of l technical personnel. In addition to initial training, there is a program of continuing training that ranges in length from 8 to 20 hours per year. NRC Ouestion 14 The NRC disagrees with the change made in Appendix 11. Page 19, and has concluded lesson plans are necessary for the EAL training. (Based on our February 22 teleconference, we believe BECO concurs with our position). BECO Resoonse Lesson plans for training on the new EAL's are currently being , prepared. This training will be conducted during Session VIII i currently scheduled for May 2, 1988 of the Licensed Operator , Requalification Training (LORT) Program. NRC Ouestion 15 Appendix 2, "Level I RFO-7 Schedule" and Appendix 5 "Performance Excellence Indicators" need to be periodically updated and distributed to interested parties. BECO Response Various indicators, including the Performance Excellence Indicators, and others now useful to management are updated weekly. These various indicators are widely distributed and displayed on site bulletin boards. The status of these performance indicators will be included in the Final Report of Management Self-Assessment of Readiness to Restart which will be provided to the NRC and interested parties. Page 9 of 9
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=
g j somwsuscw Pilgnm Nuclear PoMer staten Rocky Hdl Road Plymouth, Massachusetts 02360 Ralph G. Bird May 6, 1988 Senor V<e Presdent - Nuclear BECo letter # 88-076 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mashington, D.C. 20555 Docket No. 50-293 License No. OPR-35
Dear Sir:
This letter provides additional information regarding the Pilgrim Nuclear Power Station Restart Plan requested by Mr. R. Blough during a telephone conversation with Mr. R. Ledgett on May 4, 1988. The current status of the "Performance Excellence Indicators" is provided as Attachment 1. The "Final Report of Management Self-Assessment of Readiness to Restart", scheduled for submittal by May 16, 1988, will also include a current status of the "Performance Excellence Indicators". The current organization chart is provided as Attachment 2. A discussion of the changes since the Restart Plan was issued, including how the functions of the Planning and Restart Organization responsibilities are accomplished in the current organization will be provided in the "Final Report l i of Management Self-Assessment of Readiness to Restart". Please contact me directly if there are any questions regarding this letter. 1: . nk_ - R.G. rd i CS/bl Attachments cc: Mr. Hilliam Russell Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Sr. Resident Inspector - Pilgrim Station f fj f M L S b
Attachment 1 PILGRIM NUCLEAR POWER STATION i,3,a IP Elilif Ulf! M la M C E E !B (C E Il11 E M C E U M l0 0 (C fB Vl0 lB S ( STATUS AS OF MAY 2.1988 )
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[ D j e NUCLEAR RE L M0lONI R COMMISSION
- 475 ALLEN 7 ALE DIAD KING oF PMuSSIA, PENNSYLVANIA 194o8 MAR 18 B88 Docket No. 50-293 Boston Edison Co.npany ATTN: Mr. Ralph G. Bird Senior Vice President - Nuclear 800 Boylston Street Boston, Massachusetts 02199 Gentlemen:
This refers to the NRC staff review of the Pilgrim Nuclear Power Station Restart Plan. Overall, we found the Restart Plan to be basically sound and determined that the programs and plans described within appear to address the previously iden-tified management and hardware deficiencies. Nonetheless, several concerns and questions were identified during our review. These concerns and questions are identified in Enclosure 1 and were discussed with Mr. R. Ledgett and other members of your staff by Mr. L. Doerflein onsite on February 19,1988, and by Messrs. A. R. Blough and L. Doerflein during a subsequent telephone conversa-tion on February 22, 1988. You are requested to respond to these concerns and questions indicating your existing programs, procedures, and/or planned actions to resolve each item. Please provide a written response within 30 davs of receipt of this letter. The staff is also reviewing oral and written comments received from the public as a result of our February 18, 1988 public meeting and associated request for written comments. As our review progresses, further infer:ction or actions may be reouested from you. The response directed by this latter is not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511. Should you have any questions concerning this letter, please contact Mr. A. Randy Blough at 215-337-5146. Sincerely, ' r a . , Deputy Director Division of Reactor Projects 3 532+#t3
N
#e' k UNITED STATES NUCLEAR REGULATORY COMMISSION D FIEGION 1
't 9 478 ALLEN! ALE CAD
, KING oF PRUSSIA, PENN8YLVANIA 194o8 MAR 181988 Docket No. 50-293 Boston Edison Comp'any ATTN: Mr. Ralph G. Bird Senior Vice President - Nuclear 800 Boylston Street Boston, Massachusetts 02199 Gentlemen:
This refers to the NRC staff review of the Pilgrim Nuclear Power Station Restart Plan. Overall, we found the Restart Plan to be basically sound and determined that the programs and plans described within appear to address the previously iden-tified management and hardware deficiencies. Nonetheless, several concerns and questions were identified during our review. These concerns and questions are identified in Enclosure 1 and were discussed with Mr. R. Ledgett and other members of your staff by Mr. L. Doerflein onsite on February 19, 1988, and by Messrs. A. R. Blough and L. Doerflein during a subsequent telephone conversa-tion on February 22, 1988. You are requested to respond to these concerns and questions indicating your existing programs, procedures, and/or planned actions to resolve each item. Please provide a written response within 30 days of receipt of this letter. The staff is also reviewing oral and written comments received from the public as a result of our February 18, 1988 public meeting and associated request.for written comments. As our review progresses, further infer :: tion or actions may be reouested from you. The response directed by this letter is not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511. Should you have any questions concerning this letter, please contact Mr. A. Randy Blough at 215-337-5146. Sincerely,
.a . o , Deputy Director Division of Reactor Projects i
f) 3c b
Boston Edison Co2pany 2
Enclosure:
As stated cc w/ enc 1: R. Bar-ett, Nuclear Operations Manager B. McIntyre, Chairman, Department of Public Utilities Chairman, Plymouth Board of Selectmen Plymouth Civil Defense Director J. Keyes, Boston Edison Regulatory Affairs and Programs E. Robinson, Nuclear Information Manager R. Swanson, Nuclear Engineering Department Manager The Honorable Edward J. Markey The Hc'orable Edward P. Kirby The Honoiable Peter V. Forman S. Pollard, Secretary of Energy Resources P. Agnes, Assistant Secretary of Public Safety, Commonwealth of Massachusetts R. Shimshak, MASSPIRG Public Document Room (POR) local Public Document Room (LPOR) Nuclear Safety Information Center (NSIC) NRC Resident Inspector Commonwealth of Massachusetts (2) i l
1 I 1 l l ENCLOSURE 1 NRC Concerns and Questions on the Ptigrim Restart Plan
- 1. Volume 1, Chapter 2 of the Restart Plan needs to be updated to reflect the recent organizational and personnel changes.
- 2. Under the new organization, how will the functions attributed to the Planing and Restart Group as defined in Volume 1 Chapters 2 and 3 be accomplished? For example, the Work Planning and Estimating Branch pro-vided each section with a full time. planner designed to enable the section to improve planning and scheduling of its own work and coordinate and integrate its work plans and schedules with those of other sections and disciplines.
- 3. There are no action items in the appendices to schedule, indicate status, or track the program discussed in Volume 1, Chapter 4, of transferring fire protection surveillance currently performed by plant operators to the Fire Protection Group.
- 4. There is no discussion in the Restart Plan on the adequacy or effective-ness of High Radiation Area control.
- 5. There are no action items assigned or discussion of trending performance and/or measuring effectiveness of the completed action items in Appendix 10, Issue 02-009, "Improve the radiological performance of Pilgrim Station personnel."
- 6. How do the work stoppage during the week of November 9,1987; the Loss of Offsite Power Augmented Inspection Team findings; and, the recent numerous Engineered Safeguards Feature actuations relate to the Material Condition Improvement Action Plan (MCIAP) as discussed in Volume 1, Chapter 4? Has BEco evaluated whether any changes to the MCIAP or other programs are necessary because of these events?
- 7. Appendix 10, Issue 03-940-01 on the evaluation of procedures for receiving vendor supplied information and providing recommendations to correct iden-tified problem areas has a due date of restart plus 240 days. This mile-stone appears excessive for the indicated action. What is the status of improving control of vendor supplied information?
- 8. Appendix 10, Issue 03-905-08 discusses an evaluation of the motor operated
. valve failure analysis reports for adequacy. What followup actions and schedule will be developed from this evaluation?
. _ ~ _ _ _ _ . __ _ _ ________ _ _ . _ _ . . _ _ _ _ _ _ _ . __ . - . _ _ . . _
- Enclosure 1 2
- 9. Why is the schedule for Maintenance Group performance trending system, Appendix 10, Issue 03-906-02, tied to restart? What is the current status of this system? -
- 10. While a f e ,c specific procedure update: appear as action items and the legibility of drawings is discussed in Appendix 10, Issue 06-003, how will BEco ensure all procedures and drawings have been reviewed for adequacy and updated (if necessary) prior to restart?-
- 11. There is no action item or discussion in Volume 1 or Volume 2, Appendix 10, Issue 07-001, of scheduling and tracking the technical training of BEco security personnel. This appears necestery to ensure the new hires can be fully utilized and, in the interim, assigned duties and responsibilities commensurate with their training and qualifications.
- 12. With respect to Appendix 10, Issue 07-002-11, what is the new completion schedule for the access control modifications?
- 13. There is no action item or discussion in Volume 1 or Volume 2, Appendix 10, Issue 10-002, of a training plan for management and technical new hires.
- 14. The NRC disagrees with the change made in Appendix 11, Page 19, and has concluded lesson plans are necessary for the EAL training. (Based on our
~
February 22 teleconference, we believe BEco concurs with our position),
- 15. Appendix 2, "Level I RFO-7 Schedule" and Appendix 5, "Performance Excellence Indicators" need to be periodically updated and distributed to interested parties.
l l 1
j d#'% UNITED 8TATES ATTACHt;ENT 5 g NUCLEAR REGULATORY COMMISSION l g ,j REGION I l
* 't ' 475 ALLENDALE ROAD l T* KING oF PRUS$f A, PENNSYLVANIA 19408 MAY 061988 1
Docket No. 50-293 Boston Edison Company ATTN: Mr. Ralph G. Bird Senior Vice President - Nuclear 800 Boylston Street Boston, Massachusetts 02199 Gentlemen: This letter refers to the NRC staff review of the Pilgrim Nuclear Power Station Restart Plan, as submitted by Boston Edison Company (BECo) in letters dated July 30, 1987, October 27, 1987 and December 30, 1987. The NRC staff has completed its review of the plan, as well as your April 14 and May 6,1988 responses to the NRC's March 18, 1988 request for additional information. Com-ments received from the public and from elected officials were considered dur-ing the staff review. The NRC staff has concluded that the Plan, as clarified by your April 14 and May 6,1988 letters, provides a suitable framework for responding to the NRC's request for a self evaluation of restart readiness as described in our August 27, 1986 update of Confirmatory Action Letter (CAL) 86-10. Having now acknowledged the viability of the Plan at clarified by your two supplementary letters, the NRC staff will form a conclusion on the effective-ness of its implementation at a later date. The NRC staff's process in this regard will involve, in part, review of Boston Edison Company's anticipated "Final Report of Management Self-Assessment of Readiness to Restart," review of the anticipated final update of the Restart Plan including implementation, and evaluation of results of various ongoing and planned NRC inspection and review activities. l Please note that, in another matter related to CAL 86-10, NRC staff review of your proposed Power Ascension Program is ongoing. Your cooperation in these matters is appreciated. Sincerely, { l I a e . n.o ins, Deputy Director Division of Reactor Projects i l l i cm i c en i n o l q 0 4 > & u f Ly l
Boston Edison Company 2 cc: K. Highfill, Station Director R. Anderson, Nuclear Operations Manager B. McIntyre, Chairman, Department of Public Utilities J. Keyes, Boston Edison Regulatory Affairs and Programs E. Robinson, Nuclear Information Manager R. Swanson, Nuclear Engineering Department Manager The Honorable Edward J. Markey The Honorable Edward P. Kirby The Honorable Peter V. Forman-P. Agnes, Assistant Secretary of Public Safety, Commonwealth o'f Massachusetts Chairman, Plymouth Board of Selectmen Chairman, Ouxbury Board of Selectmen Plymouth Civil Defense Director S. Pollard, Secretary of Energy Resources R. Shimshak, MASSPIRG Public Document Room (POR) local Public Document Room (LPDR) Nuclear Safety Information Center (NSIC) ' NRC Resident Inspector Commonwealth of Massachusetts (2)
t.AL 86-10 SALP Diagnos CAL 86- RFO-7 NRC Ltr Rqs; Physt SEP Ltr R start " ' SALP NRC 85-99 Team 10 AIT Stcrt Restart Assess From Plan A55'55 Meetin9 86-99 Inso. PLT Scr 86-41 Plan BECo Rev. 0 l : l : g gg6- 14/12/861 l 7/86 l 18/27/861 (11/24/8d g-: l 7/8/87 l 17/8/87l l7/30/87 l FEMA SEP Ltr EP Ltr BECO 9 PWR Asc Restart Site StCo Self In EP Re- w/BEco Prg t to to Plan Work LOOP Nuc Re-Rev BEco , BECo sponse Submit Rev. 1 Stop AIT align l : l :
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