ML20153H038
| ML20153H038 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 08/26/1988 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1690, NUDOCS 8809090070 | |
| Download: ML20153H038 (306) | |
Text
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~ UNITED STATES O NUCLEAR REGULATORY COMMISSION
! In the Matter of: MEETING OF THE AD HOC ) SUBCOMMITTEE ON PILGRIM ) l RESTART ) l i
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I 1 ! I ! Pages: 1 through 232 Place: Plymouth, Massachusetts Dato: August 26, 1988 mu..........==================================="""="".....c HERITAGE REPORTING CORPORATION omnem 1424 L Street N.W., suite 606 0 w . o.c. = (202) 628 4888 sso909007o it.os ._ PDR ACRS PD: j T-1690
i PUBLIC NOTICE BY THE () 2 UNITED STATES NUCLEAR REGULATORY CCKMISSION'S 3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS , 4 5 i 6 l 7 The contents of this stenographic transcript of the ! 8 proceedings of the United States Nuclear Regulatory 9 Commission's Advisory Committee on Reactor Safeguards (ACRS), 10 as reported herein, is an uncorrected record of the discussions 11 recorded at the meeting held on the above date. 12 No member of the ACRS Staff and no participant at 13 thin meeting accepts any responsibility for errors os
~ , 14 inaccuracies of statement or data contained in this transcript. ;
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g UNITED TATES NUCLEAR REGULATORY COMMISSION
^ 2 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
( 3 O k- 4 In the Matter of: )
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5 MEETING OF Tile AD !!OC ) SUBCOMMITTEE ON PILGRIM ) 6 RESTART )
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7 Friday, 8 August 26, 1988 9 Memorial !!all 10 83 Court Street Plymouth, Massachusetts 11 The above-entitled matter came on for hearing, 12 pursuant to notice, at 8:00 a.m. [') U 13 A'.RS MEMBERS PRESENT : 14 DR. WILLIAM KERR g3 Professor of Nuclear Eng.neer and Director of the Office of Energy Research, University 16 of Michigan, Ann Arbor, Michigan M1 . CllARLES J. WYLIE, retired Chief Engineer, 17 Electrical Division, Duke Power Company, Charlotte, North Carolina 18 g, DR. JAMES C. CARROLL ya ACRS COGNIZANT STAFF l' EMBER:
;g PAUL BOEHNERT 22 NRC STAFF PRESENTER:
SA'!UEL COLI3 INS 33 t 24
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2 g NRC STAFF PRESENT: ALLEN R. BLOUGli ( 2 LAWRENCE DOERTLEIN 3 BRUCE BOGER DANIEL Mc DONALD (s 4 RICl!ARD WESSMAN 3 BOSTON EDISON COMPANY PRESENTERS: 6 RALPli BIRD KEN !!IGHFILL 7 RON VARLEY ED llOWARD 8
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2 DR. KERR: The meeting will come to order. 3 This is a meeting of the Advisory Committee on t' (-)s 4 Reactor Safeguards and Ad lloc Subcommittee on the Pilgrim s Restart. 6 My name is Kerr. I am Subcommittee Chairman. 7 Other members of the ACRS who are in attendance today are 8 Mr. Carroll and Mr. Wylie. 9 Our purpose in the meeting is to review the proposed n) restart of the Pilgrim Nuclear Power Plant. 3 Mr. Paul Boehnert is the ACRS staff member for the 12 meeting. () 13 Rules for participation in todays meeting were 34 announced as part of the notics of the meeting published in 15 the August 19, 1988 Federal Register. 16 A transcript of the meeting is being kept and will 17 be made available as stated in the Federal Register Notice. I is I ask that each person who speaks identify himself 19 or herself and use a microphone.
- o We will proceed with the meeting. I call on Mr.
21 Sam Collins from the NRC. Mr. Collins. MR. COLLINS: Good morning. Can everyone hear? 22 , ( I I thank you for the opportunity to speak to the 23 j ACRS Subcommittee this morning. I would like to acknowledge 24 l that the ACRS is an independent body that reports to the () 25
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- Commission.
2 I think that this part of the process lends v 3 creditability to the staff's efforts in regards to the 0) u 4 review of the Pilgrim restart activities to date. y I am on Slide 2. The handouts that are available 6 in the back of the room are a copy of the slides that I will 7 be using this morning. They are available for the use of the a participants and'the observers and I will refer to 9 the slido numbers as I go through the presentation. 10 The first part of my presentation this morning is gg Section II of the Agenda. The Agenda is structured such 12 that the staff will present the issues and concerns which Preceded and led to the shut down of the Pilgrim Station in
]G b 13 34 April of 1986. The secondpresentation will be by the 15 licensee, Boston Edison. Boston Edison will speak to the 16 issues and how the issues have been addressed by the licensee 17 The third presentation will be from the staff. It is currently 18 scheduled to be in the afternoon and that presentation will contain the verification activities that have been performed 39
- o by the staff.
2: The slides I have contain quite a significant ,nount 22 of information. I do not intend to read the slides at this L] I time. The slides have been provided to the ACRS for review 23 l and I will over view the slides, hight light the areas of 24 , O >> I"i"*'t""e""d"'e' S """" ' 9" "'t "" """" "ver ert"'*- p Heritoge Reporting Corporation g --
i 5 I I would like to introduce the staff that is here p
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2l today who is available to participato in the meeting. 3 I am Samuel Collins, Deputy Director, Division of O b' 4 Reactor Projects. I am also the Chairman of the Pilgrim Re-5 start Assessment Panel and I was the Team Manager for the 6 Integrated Assessment Tcam Inspection. 7 We have with us, Randy Blough. Randy is the Sectior , 8 Chief of the Division of Reactor Projects in Region I. Randy 9 is a member of the Restart Assessment Panel and was the Team 10 Leader for the Integrated Assessment Team Inspection. il Next is Larry Doortlein. Larry Doortlein is the 12 Project Engineer. lie works for Randy Blough, in the Division h 13 of Reactor Projects in Region I and was a member of the Inte-34 grated Assessment Team Inspection. 15 We have Mr. Bruce Boger. Mr. Boger is the Assistant 16 Director for Region I Reactors in the Office of Nuclear 17 Reactor Regulations, in Rockville. Bruce is the Co-Chairman is of the Restart Assessment Panel. 19 To Bruce's right, we have Mr. Dan Mc Donald, the 20 licensing Project Manager for the Pilgrim Station. !!e is 21 also a member of of the Pilgrim Restart Assessment Panel, 22 I Also in attendance, we have Mr. Dick Wessman, who in c I 23 the Project Director for NRR. 24 r We have the Senior Resident, Mr. Clay Warren at 25 the back table and we have the Resident, Jeff Lyash. Fl; Heritage Reporting Corporation cm> m j
l 6 g I would like to acknowledge that in the past two and 2 a half years, there has, along with a significant turn over O in the staff at BECO, there has boon a turnover in the staff 3 O b 4 at the NRC and the number of the individuals who are here 5 today do not have the benefit of experience that goes back 6 preceding to 1986. 7 The two individuals who have probably the most 3 depth would probably be Larry Doortlein and Jeff Lyash as 9 far as continuity. I tend to think that that brings some 10 independence into the project as far as the people being yg able to assess the activities without having over sight of 12 them during the period of the problems. I am now on Slide 4. I would like to set the stage I)
- v. 13 14 for the presentation. The purpose of the presentation this 15 morning is to provide background and perspective on the 16 historical issues in Pilgrim Station.
17 These issues have to be put in the proper context. 18 They took place in 1986 and preceding and the issues carry 19 through to the early part of--or the latter part of 1986 and 20 carly part of 1987, 21 It is important to not that they are historical, 22 that they have been the subject of on going DECO corrective . 23 actions and verification activities by the staf f and response 24 to the issues by BECO and verification by the NRC will be 25 addressed in subsequent presentstions. I Heritage Reporting Corporation
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- The IATI Inspection, which the exit was on Wednes-f- 2 day of this week, provides the most recent input on verifica-(v) 3 tion activities. That information, as well as the informatior
() 4 that is contained in the most recent SALP document, which war 5 just issued in July of 1988, will be presented in this after-6 noons presentation. 7 For the purposes of background, I am now on Slide s 5, this contains some detailed information on the Pilgrim 9 l Station. It is actually a handout that is made available to io the Commissioners when they come to the site for a visit. 1: It contains the license dates as we.1.1 as the power levais 12 and the responsible individuals from the NRC who have dealt , with the Pilgrim Project. (~
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) 13 i4 This is a rather busy slide. For those of you who 15 have the handout in front of you, we're on Slide 6. This is 16 the Issues Milestonc Chart. This is a part of the milestone 17 schedule that is used by the Restart Assessment Panel to 18 track the activities in conjunction with Pilgrim restart.
39 The significant milestones, to get to the main topig 20 of the agenda which is Historial Issues and Concerns, start 21 with the order to modify the license and radiological control s 22 in 1984. 23 The SALP document which is the Cycle 6 document, k 24 I which covers the period of October 1984 to '85, docu?.ented a i I number of concerns which existed at the site. That SALP 4 ([) 25 Heritage Reporting Corporation i m u. I
8 i Report was forwarded to the licensee and NRC, Region I ( 2 performed a diagnostic team inspection to confirm the SALP 3 l and to try to determine the root cause of those issues, that i i- 4 , is this inspection right here, in the early part of 1986. 5 The benefits of that inspection, this is Inspection 6 l 86-06, were included in the cover letter of the SALP document 7 which was forwarded to the licensee. 8l To continue, the plant shutdown occurred on April 0 9 ll llth, 1986. We'll get into the details of that shutdown in H 10 h a la ter slidc. The confirmatory action latter, 86-10, was l 11 i issued in April of 1986. The technical issues which resulted I { in the confirmatory action letter was the subject o'. an Aug-12 , 13 mented Special Safety Team Inspection, which was sent to the 14 site at the time of the shutdown. That special inspection, is 86-17 details the licensee's response to three main technical 16 I areas which is leakage into the LhR system frcm the main 17 j.hl coolant system. The failure of the MSIV outboards to reopen ll il 18 ;} in the spurious Loop 1 PCS isolation. h 19 h In July of 1986, licensco determined to continue b 20 the shutdown for technical reasons. At that point in time, 21 l a decision was made by the licensee to inspect the ware rings b g 22 ji on the EllR pumps in response to a similar issue at Prsch L)J l Bottom that extended the outage and they determined to go 23 4 , Number 7 at that time, 24 j into refueling outv-p (o) 2s [ The NRC issued a supplement to the original H Heritone Reporting Corporation
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9 confirmatory action letter in August of 1986, the details
, 1 2 of which are in a slide to come. That greatly expanded V
3 4 the NRC issues which were required to be addressed by BECO I (f 4 prior to restart. 5 In November of 1986, a management meeting was held 6 l to discuss the status of the outage and the status of corrective 1 7 actions in response to the confirmatory action letters at 8 Management Meeting 86-41. That report contains, as an 9 attachment, a consolidated list of the issues and their lo reference for the use by BECO to insure that the issues were It addressed prior to restart. 12 Following that period in time, there were a number I 13 of issues which came into play that the NRC is taking under 14 l advisement in conjunction with restart which did not relate 15 to the original shutdown at the plant in April of 19S(z. That i 16 inclodes the emergency preparedness issue. Tb', Massachusetts j l7 Report on the status of the emergency neeparedness that was . h 18 [ issued in December of 1986. That report subsequently was d 39 ] supplemented by feria who perfor.ned a self initiated review of the status of emergency preparedness in relation to 20 l 4 21 l! Pilgrim. That report was issued in August of 1987. The d e 22 h NRC forwarded that report to the licensee, Boston Edison h
!sws) n 23 1 for appropriate response.
24 d SALP Cycle 7 was a.1,so performed. That report was
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() e 25 ll issued in June of 1987 The period ended in January of 1987. u He Itage Reporting Corporation [ a m m m. J
10 g I'll get into the details of the SALP Report in a later slido, but that report indicated, at that time, that there were con-('}
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2 3 tinuing issues at the station that needed to be addressed (m, (-) 4 prior to restart.. 5 The 2.206 Petition which was issued in October of 6 1987, that petition indicates 3 issues that are outstanding 7 in the petitions mind and asked for an adjudicatory hearing, s The issues are emergency preparedness, Mock I containment 9 and the adequacy of management. in While the plant was shut down, there was a loss 11 of vf! -ite power vent in November of 1987 that was responded 12 to by an Augmented Inspection Team from the NRC. In subsc-quent--boyond the slide, there is an additional 2.206 {'} t 33
-) 34 petition that was filed by the Attorney General and the l 13 Governor and that petition also deals with emergency pro-16 Paredness, Mock I containment adequacy and management issues 17 at the site, la That is a brief overview, in a historical perspec-19 I tive of the issues that led to and have transpired since the 20 shutdown. There is a supplenent to this which will be pre-21 sented in the second half of the presentation that updates 22 ; these milestones following the 1987--November 1987 period, f You really break these down into two separate group s.
23 ; 24 l There are issues which deal with the shutdown and then there l are broader issues that came in following the shutdown. The (]) 25 d h lj Heritage Reporting Corporation i => m .= h
11 I shutdown issues are those which are those which are dealt 2 with in the SSFI Inspection, the Safety Systems Functional w/ 3 Inspection, the SALP documents, the Diagnosite Team Inspec-O (_) 4 tion, the shutdown itself and the confirmatory action letter 5 and the augmented inspection team which responded to that. 6 The broader issues are the emergency preparedness 7 issues, and the 2.206 petitions, the status of which will be 8 presented this afternoon, s 9 We're now on Slide 7. Slide 7 depicts the 10 systematic assessment of licensee performance results prior 11 to the April 1986 shutdown. 12 What is notable here is the historical inability 13 to maintain level of performance in some critical areas. You (' } m- 14 notice in the operations area, there are a number of swings is between Category 2 and Category 3 performance. Radiological 16 Controls the same. Surveillance is the same only the 17 swing is to a Category 1 to a Category 2. Maintenance 18 seems fairly straight forward. Emergency Preparedness there is 19 a dScline as the result of a major drill and the observations 20 of the major drill in 1984. f 21 You see, there are some aspects of this slide which 22 l are curious and I will explain it, the definition of im-23 proving change in the SALP process throughout the period. 24 l Improving, if you notice in Cycle 5, there is an 1 () 25 k"
"i" for improving after the Category 1, for example, in Heritage Reporting Corporation
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12 i Maintenance. At that point in time, if a plant changed (-)
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2 categories they were either improving or declining. In the 3 later SALPS which we will get into a little bit this after-s' 4 noon, declining and improving were refined to mean that they 5 j had to be improving or declining at the end of the assessment 6 period as an indicator that if that continued into the next 7 perioi, the performance would be expected to change one way 4 8P or the other. I' 9 It was predictive, simply put, whereas the past i 10 definition was confirmatory, it had already happened, i 11 The functional areas had also changed throughout 12 l the SALP assessment cycles. You notice there are some 13 blanks in the table. That is the result of further refine-
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h i ment of the categories for assessment. 15 Assurance of Quality and. Quality Assurance picks l 16 up again on the next slide which I will get into this after-l i 17 l noon with the more recent assessments. 1 I l \ ! 18 i For the benefit of those who are here, the Systemat Lc 19 l Assessment of LiConsee Performance is normally performed I ; I h 20 ! every 12 to 15 months is a subjective assessment of licensee J performance. It takes into consideration inspection activi-21 ) 1
< 22 ties and review activities that have been performed at the
,l 23 q site during that period. It is not based on enforcement 24 solely, it is not based on plant performance solely. It is
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) 25 L targeted towards management performance and management y
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13 i i effectiveness towards safe implementation of of the programs. p v 2 This slide will be updated with the latest SALPS in 3 this afternoons presentation. O V 4 I am now on slide 8. We're dealing now with the 5 program issues leading to the April 1986 shutdown. Generally 6 these issues were acknowledged in a systematic assessment of 7 Licensee Performance Report which is Reference 2 here. That 8 report indicated that there was a history of poor performance t L 9f at the site and that there wre so.no fundamental issues at L r 10 the site that needed to be corrected prior to those historica) 11 issues being able to be addressed effectively. I 12 We then performed, as the milestone chart indicated, {} 13 a diagnostic team in spection at the site to try to understand 14 better why the SALP results were the way they were and to
!? ! confirm the assessment performed by NRC.
16 Those results were depicted in the SALP itself 17 which is the second SALP, the management meeting SALP--let me I 18 go back a meeting. I'm probably confusing people. I 19 There are two SALPS that are issued in each cycle. I i 20 ' There is a board report and a management report. The board i l L 21 report is issued to the licensee. It is taken under cdvise-22 ment by the licensee. We hold a management meeting to discuss t
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the initial report. The licensee formally responds to that ! i i We take that response under censideration and issue 24 c report. 25 a final document, j
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ll [ 14 1 I i In the case of the SALP issued in 1986, between che 2 h period of time when the draft--or when the board SALP rather (^'J)
'_ G 3h was issued and the final SALP was issued, we did perform the ^w ;
d c ' e K 4 j diagnostic team inspection to try to understand better what a
$ the issues vere that were presented into the GALP.
F 6 j Those issues are depicted here in the first four 0 7h notes and those issues were contained in the SALP !!anagement n 1 8 j Koport which was forwarded back to the licensee. 9 Issues of significance, I thaink, at that time, they c n) h were perceived to be accured and I think, based on the in-1 11 h formation we have to date, they were accurate, h 12 h These issues are the subject of on going reviews t 13 by the MRC. They are part of the standard reviews to assess b 14 hL restart readiness of the plant and they are the rajor focus 15 [ of !!anagement "ceting Peport 86-41 which was held in the fall r 16 L of 1986 to review the status of the licensee's actions and l 17 i the status of the actions with Confirmatory Action Letter la b 86-10. o 19 : Nov leading up to the details of the 1986 shutdown, 20 l I am on Slido Number 9, this slide is lifted out of the 21 J SALP 86-99. It is a graphic precentation of the plants 73 22 operating perf~ nance starting in November and ending with the O 23 shutdown in April. The blanks in the line are plant shutdowns. The 24 shutdowns which we will detail in significance are the two (o) 25 Heritogo Reporting Corporation a u.
15 I that took place in April '86, specifically April 4th and Apri O 2 l lith. J l 3 The subject of those shutdowns are contained on the U 4 next 3 slidos which are also taken out of the SALP document 5 , which indicate the reasons for the shutdown and the root causc 6 l of the shutdown. 7 I'll go through the first two rather quickly. I 8 Starting in January, there are a number of plant shutdowns, I 9 primarily based on secondary plant problems. There are also [ 4 10 a number of mechanical problems which led up to the April 198( 11 j shutdown which the NRC was tracking. 12 These issues in and of themselves are indicatore 13 f of poor performance and perhaps, in some cases, maintenance i 14 l problems and attention to detail issues, but they are not I 15 4 precursors of the April 4th and April 12th shutdowns. I 16 Now, on Slide 12, I would like to focus on the k 17 April lith, 1986 shutdown. This is the shutdown which i resulted f rom Elin leakage--leakage into the EllR system is [ d 19 [ rather, low pressure system, from the reactor coolant system. 0 20 ji In conjunction with that leakage, the plant isolated their N 21 h containment line with two valves. It was a conservative call , d
,o 22 h as interpretation of Tech Specs which resi.lted in an Action (tj ) i i
;) 9 Statement to shut the plant down and, of course, in a plant 24 4 shutdown, they received a spurious containment isolation c,
() 25 signal which resulted in the mainstream isolation valves l I Heritage Reporting Corporation o mm I
16 going closed. Subsequent to that they had an inability to q 2 reopen the outboard mainsteam isolation valves. I'll get into
,) ' l 3 1 the details of that event here in just a monent.
g C 4 That had a procursor on April 4th. The NRC did 5 review the event of April 4th and determined that the. 6 actions at that time, taken by the licensee, were determined 7 to be acceptable. Following the recurrent issue on the lith a of April, the NRC issued an confirmatory action letter to 9 provide for Boston Edison to maintain the plant in a condition 10 that was acceptable for the NRC to conduct the special inspec- - 31 tion which followed. 12 DR. KERR Excuse me, Mr. Collins. You said, 13 after the April 4th shutdown, the NRC reviewed the actions 34 taken and found them to be, what was the word you used? 15 ; MR. COLLINS: Acceptable. 16 DR. KERR All right, thank ywu. 17 MR. COLLINS: I would like to over view the l is confirmatory action letter for a moment and then I will get I i, into the results of the special inspection which was conducted 20 I following the shutdown. 21 This slide is continued on Slide 14 in just a mo. mon t 22 i and will contain all the items contained in the confirmatory O 23 1 i action letter. The lead in indicates that on April lith, the l ' 24 shutdown was required by technical specifications. While 25 shutting down an unplanned SCRM' occurred due to the spurious i f ll Heritage Reporting Corporation 1] <m, m m. j l
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- primary containment group on isolation. All 8 MSIVs closed.
{ l (~l 2 l The outboard main steam isolation valves could not be reopened .
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3 The NRC issued confirmatory action letter 86-10. l1 (~T h (_) 4 j! As a result of these recurring events, they maintained the N
$ l plant in a shutdown condition until the NRC could review in 6 detail the causes of the events and the licenscos corrective 7 action in response.
i a The specific actions contained in confirmatory 9 I action letter 86-10 of April required tht the plant be main-g) i tained in a condition to provide for NRC review of the event, i c is ij basically froze the plant conditions at that time, h 12 1 Also required that Boston Edison provide a written f 13 response to the NRC prior to restart, evaluating the three I y ) items which, at that time, were ir.dicators of technical issue 2 leading to and resulting in the shutdown, 15 l h 16 Ui Doston Edison decided on July of 1986 to remain shut l 37 down to go into refueling outage Number 7 At that point in I 18 time, the confirmatory action letter 86-10 was updated. That I l 39 g was August of 1987. It was supplemented to include other h 20 [ hardware issues and also SALP related performance issues, h 21 The update to CAL 80-10 contained the requirement
,- 22 to resolve specific technical issues which were broader than k) ~
the original CAL. It required a formal assessment of their 23 [ 24 , readiness to rentart. It required a formal restart program and schedule be subnitted to the Nnc and, again, it required (m) m-25 [y Heritogo Reporting Corporation n (HO m me L
i 18 that the assessment and the r9 start plan be submitted for NRC
/^i 2 review and approval.
j t 3l To get into some of the details of the plant shut-
) 4 down. The R!lR valvo leakage was contained in Loop B. There 5
was manual icolation valve involved, a check valve involved, I, 6 4 h two motor operated valves, a pressure switch, a flow switch, d, 7! another manual valve--excuse me, another motor operated l valve, a check valve and then the pump. g 9 At that time the check valve was the boundary go between the high pressure system and the low pressure system.
- lj They were receiving--they, the licensee BECO, was receiving 12 ,
Ri!R high pressure alarms. That alarm normally alarms at, I b believe, 400 pounds. That alarm was received on April 10th 13 !' l 34 h and April lith. 4 isj 'i shtequen t to the shutdown, licensee tested the ValV03 'ad indicat.ed tnere was approximately half i of a GPM 16 I b 37 N leal: into the aystem which was being trapped into the system 0 is f by a tight check valve immediately up stream of the Pl!R i 19 y B pump. There is a relief valve on the line. The relief h Their analysis and the tne NRC review
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. h valve never lifted.
0 h confirmed that there was no potential damage to the plant, n
;; j1 Modifica+. ions were performed subsequent to that 7-() ~
E h event which included the ability to drain the line, the 23 U 24 y addition of a pressure switch and overhaul of the valves, q no potential damage done 1 ()- 25 L DR. KERR: When you say, ! Heritage Reporiino Corporoflon l im m I
19
'l I to the line, I"m not sure I understand what "potential damage' o 2 is.
A 3 MR. COLLINS: No damage. (v 4 DR. KERR: No damage?
$ MR. COLLINS: No damage.
6 DR. KERR Thank you. 7 MR. CARROLL: What is the design pressure rating of 8 the Ri!R system as a whole condition? 9 MR. COLLINS: If I recall and maybe I can be 10 corrected by the staff, it's approximately 450 pounds. 11 What was happening at this time was they were 1 , 12 receiving Ri!R valve leakage, to the R!!R valve leakage, fl 13 two of the motor operated valves were subsequently closed. l-x 14 Those were determined by the licentee to be primary contain-15 ment isolation valves. They were also indicated to be leaking 16 by as a result of the recurring pressure alarms, therefore 17 ,l they determined that they had a problem with primary contain-l 18 j ment isolation valve integrity and they chose to invoke the 19 action statement which required that the plant be shut down to in that condition. The subsequent team inspection to the shutdown 21 l h 22 p indicated that-- 23 DR. KERR Let me see if I understand. There was [f I 24 h leakage in the check valve and also in the motor operated i 1 2s valves? O Heritage Reporting Corporation j j =
20 g MR. COLLINS: Yes. There are a series of valves. 2 DR. KERRt Yes. t } 3 MR. COLLINS: Motor operated valves and check (qj 4 valves. One of the check valveu which is the check valve 5 immediately preceding the pump which is on the end of the 6 piping train was a very tight valvo. Normally, any leakage 7 into the system would be passed through the system and into a the torras. This end check valve being tight enough, it did 9 not pass that leakage into the torras, tended to trap that 10 leaking in betweer the valves, il The motor operated valves, there are two. One was 12 f closed, to provide for a boundary, the leakage continued, a l O w 13 subsequent valve was closed to provide for a boundary, the 34 leakage still continued. The licensco then determined since is they weren't abic to quantify the leakage, they were still 1 Il 16 i receiving the alarm, although the relief valve was not lifting 37 at that time, so they weren't at the relief valve set point, i is , They determined that they had an unknown amount of t I ' 19 ( leakage by the containment isolation valves. They determined
- o I that they were then inoperable and the license requires that 23 they shut down in that condition and that's what they did. (
22 l DR. KERRt Thank you. O 23 q1 MR. COLLINS: During the course of the shutdown, 24 they received an unexpected Group 1 isolation. They cite the c
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1 21 g in a plant SCRAM. Following a plant SCRAM, once the SCPRt wat 3 lj reset, the outboard MSIVs were unable to be reopened. That LJ i 3] took away the normal cool down path to the main condensor, g
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4 [ If I remember correctly, at that time, they put !! PSI into the o e l test mode and used !! PSI as a cool down method for the plant, 5 h F 6 which is acceptable.
; The RllR check valves were subsequently inspected 7
(I and were found to be acceptable although they were overhauled, a h f
, l There were some modifications made to the system, f
to lj The main steam isolation valves, there were a gg series of tests that were done on the nain steam isolation [d valves. Those valves are Atwoorl-!' orale 20 inch wide pattern 12 q valv s. They are air operated. They have a 20 inch puppet 13 o 34 [n disc, they normally operate on a 45 degree ar.gle, g3 It was found that the private purret was detached h from the valve stem. ':ormally it's attached by by a set 33 screw and a stake. It was determined that the arsembly was 37 gg j inadequate and at that time there was no torquing requirement for that set screw. The valves were opened up and overhauled 19
;3 and that situation was corrected.
;g L The more complicated aspect of the shutdown is--
MR. CARROLL: b' hat you're describing is the condi- , g\ 23 ti n of one of 4 vales or all four were in that condition? l l
!!R . COLLI!;S: Jeff, is it all four?
3 ,
!!R . LYASil I believe it was.
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! 22 I g MR. COLLINS: That's my recollection. I can go
,^
2 back in in the report and make sure, t 3 DR. KERR: Would you identify yourself for the O . reporter 2 g MR. LYAS!!: My name is Jeff Lyash. The problem-- l l 6 the denign problem was common to all 8 valves, but only four 1 7 displayed the problem. I believe that the pilot puppet had l 1 l g becom disengaged from.the valve stem on all four outboard l 9 valves. l gg MR. COLLINS: That was Jeff Lyash. Jeff is a gg Resident Inspector at Pilgrim Station. 12 The issue of this spurious containment isolation l is a little more complicated. These spurious isolations i l i f)m 13 i J l md 34 tended to happen tthen the mode switch was in a start up or l 15 hot standby with pressure less than 880 pounds which is g normally when you get the low pressure line, gy In the two conditions in which this even occurred la j on April 4th and April lith, on the April 4th event, the SCRAF g was received immediately after receiving the low pressure i
- o q alarm. On the April lith event, it was received approximately b 30 seconds after the low pressure alarm.
- 1 1
1
'2 0 There was some concern after the April 4th event about the SP-1 mode switch. There had been some industry 33 ] i ,
notifications of problems with that modo switch. The GE sill 24 g in 1983 was issued, for example. Boston Edison did inspect 25 [ l [ Heritage Reporting Corporation ! j a.e .=
23 i ih that SP-1 modo switch. They put a mock up together and i 2 did quite an extensive review of the functions of that ('~;~ } y 3 9 switch. It was determined that the switch was acceptable.
, . O kI 4 There was an option to change out the switch with what I
']i 5 h believe was a later model, an SP-9. It was determined that 9
6 the SP-9, because of the extent of the modification, it wasn't d 7 Fl l proven to be necessary and the difference in the feel of P.he l'
- I 8h switch to the operators, that the SP-1 switch would be kept.
l 9 That was reviewed by the NRC and determined to be an acceptable 10 [ action. Following the April llth shutdown, they did do 11 h 0 12 h some testing on the mode switch which was basically simulation h of noad switch action with instrumentation, it was determined (l) 13 34 j that the modo switch was, in fact, operable, f 15 j In response to this first group on isolations, there o 16 j has been a number of actions which have been taken by Boston h 17 4 Edison, including circuitry upgrades, switch verifications h L is g and equipment change outs, but the c.=.use has not been L 39 definitively determined. 20 L There are retests scheduled prior to start up and 21 during the low pressure portions, a power ascension to verify 1 22 the adequacy of those actions. l b.s Are there any questions before I proceed? l 23 l Dh. KEPn h'h a t is the signi;!icance of the last 24 () ' 25 bullet? l t ( Heritogo Reporiing Corporation im m
24 i i MR. COLLINS: This was a determination that was made 2 by the integrated inspection team which came on site April 3 12th following the event. They stayed on site for a period s 4 of approximately 2 weeks to review the sequence that led up , s to the shutdown and the licensees actions following the 6 shutdonw. 7 It was cetermined, as the result of those reviews, a that the approaches to the problem solving were acceptable 9 as contained in the published NRC Inspection Poport. 10 I am now on Slide 15. Previous to this slido, I 11 indicated that the plant shutdown on April lith, we had a 1 12 special inspection team which came to the site to review thos e O S~ 13 p p-events. I went through the results of that special inspection, i t 14 h a confirmatory action letter was issued, of course, at the ti me h of shutdown to provide for the inspection to take place, to 15 j 0 16 [ provide for the review of BECO actions in regards to the 17 ( shutdown. 5 l la h At this timo the y' ant had determined to go into th e ll ' 19 l refueling outage. We had issued the supplen.cnt to the p 20 g confirmatory action letter in August which greatly expanded < l 21 ) the requirements in the original confirmatory action A tter. N 22 h And, now we conducted a management meeting, 86a41 O 23 c [ with Boston Edison to review their status of refueling outage i 24 No. 7 and to review the status of their actions in respense O :$ 0tothec"<tr=>trv=tt"t**er- l lI l p Heritage Reporting Corporation q imw
3 2 25
- 1 , i 1 I s
- 3 As a result of this meeting, the. cover letter for
-9c 2 the meeting report acknowledges that the NRC remains concernec hs .-
at this pot.t in time and again, the tima we're talking here. 3
} 4 is December of 1986. ,
5- The NRC remained concerned about the ability and 6 the rapidity of Boston Edison to effectively address the 7 actions which led to the shutdown and the actions in response a to the confirmatory action letter. 9 We indicated that the technical and the program go issues needed to be reviewed'pr!'r to startup. We provided' a consolidated listing of those issues in Attachment 1. 'At i 12 that point i n time, we indicated that the NRC was looking i for strong ev'idence of progress at Pri1 grim prior to restart, (]) 13 14 that we intended to conduct a SALP prior to reaching a^posi-13 tion regarding the restart of the Pilgrim facility. 16 The purpose of that meeting was to try to sand a 17 strong message to the licensee that he actions to date would determine, although understood, wore determined, in som e a gg l-19 cases, to be inadequate and to provide a consolidated listing i 20 of the issues for their approaches. , 21 During this period of time, we also continuing to ' 22 conduct systematic assessments of licensee performance even O 23 though the plant was shut down. We~ wore using those as another 24 mensure of Boston Edison's response to the iusue preceding th e
% 23 shutdown and the of#cctiveness of their actions during the
(~/ N_ , Heritage Reporting Corporation L im m
, o il 5 + n ?-
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- 26 n, ,
-1 shutdown.' s 7
2 This is SALP 86-99; The assessment period was from 3 11/85 to 1/87'and included lthe period of time l'n'which'the () 4 plantshutdown-addactionsprecedingtheshutdown. '\;, 5 The SALP 4 report, which as I explained earlier, 6 is the initial report provided for the licensee'and was issue ( 7 'in April,.almost.a. year from the time of the shutdown.
, g The management meeting was held in May and the 't v 9 report itself .was issued in June. We acknowledge that BECO 10 had made significant staf fing and, hardware commitments. at that
, jg time to include performance. The program improvements' wore + 12 begiaaing to have a positive effect. We did note some limited [ 13 improvements. At that time, organizational changes, to date, g4 had clarified responsibilities and accountabilty,-however, many, 15 issues remained. 16 Stability in staf .ng key positions, at that time, 17 continued to be an issue. Staf fi.sg vacancies continue .to be (
! 18 an issue and the slow developing improvements in some pro-i 39 viously identified long-term problem areas.
MR. CARROLL: What does stability in staffing in , 20 kay management positions mean? I 21 I 4 22 MR. CARROLL: Up until that time and preceding that O 23 time, there had been a changeover in some key positions at 24 the site. I guess the most pronounced is the Plant Manager There have been 5 Plant Managers at the site in () 25 position. l Heritage Rwporting Corpordion am -
'i
, '27 1 recent history.- '
,.U:- 2 [ NRC actions in response to those issues were to
. continue the~ augmented.insp~ectio'n program, which I will 3- .
) .,. deecribe this afternoon.
5 DR. KERR: Excuse me. As far as Plant Manager 6 changes, in what period? t 7 MR, COLLINS: Jeff, did that period -' after the t 8 shutdown?
.4 , MR. LYASH: There have been 5 plant mcnagers from , 10 the shutdown to the present time.
DR. KERR: So the concern was no so much about gg 12 stability prior to shutdown but the lack of stability post 13 shutdown? g ,4 MR. COLLINS: Well I think that is an indicator 15 of the stability. There had been issues preceding that ; i ! l 16 as far as changes in the organization, :hanges in corporate ! i
- l'7 stature of the highest individual in the organization at
^
18 the si te, and even previous to the shutdown they had had some 19 instabilities in the Plan Manager's position. 20 DR. KERR: Go ahead. e 21 MR. COLLINS: We have a listing of thosn names in l l 22 transition that we can provide to you, if you want BECO's. t i 23 MR. WYLIE: Let me ask a question. Did these people t ! 24 leave the company voluntarily or were they replaced by Boston j t ! 25 Edison, what was the status of those individuals? (]) i Heritage Reporting Corporotion ; i . <== u.
d.
; 28 3 MR. COLLINS: Those ind viduals were typically 2 replaced by Boston Edidon.
3
/ MR.;WYLIE: They were place somewhere else in the O
< comvanrl' MR. . COLLINS:' Yes, sir.
5 6 MR. WYLIE: Thank you. 7 MR. COLLINS: There*were some limited incidents _where a very senior people left the company, but typically people N 9 tended to move within the company. Some individuals were
-10 brought in_from the outside. - 11 - MR. CARROLL: The next bullett, "Staffing Vacancies 12 is referring to vacancies in lower level jobs like operator h 13 positions and things of that sor t?
14 MR. COLLINS: Yes, sir. Most pronounced vacancies 15 were in the licensed operator ranks, also in the ability just 16 to support the technical areas of maintenance surveillance. 17 Are there any more questions? Is (No response) MR. COLLINS: At ti.is time I would like to get 19 20 into the broader issues. On an earlier slide which was the 21 Milestone Slide, I indicated that there were technical issues 22 leading up to and immediatel, following the shutdown of the
.O 23 Pl ant. No have discussed those.
I ata now into the second area, which is the broader 74 isstes which typtcally follow a piant shutdown, but are being O 23 Heritoge Reporting Corporation
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29/30 g takenunderconsiderationbytheNRCinthereviewofresta$ o 2 activities. ( ) 3 I would like to clarify the slide here and acknow-4 ledge that the_ safety enhancement program which I will dis-3 cuss in a moment is not a: Assue of regulatory or safety 6 concern, but is an issue that is under review. That's why I 7 have it on the slide. I'll discuss that in L moment. 8 In the Emergency Preparedness Area, the on site 9 emergency preparednese has no significant deficiencies. 10 The program is performing well. in The Off Site Emergency Preparedne o issues initiated 12 with a FEMA self-initiated review. During the course of that 13 FEMA review, the Commonwealth of Massachusetts issued a report O ( { O y indicating concerns with the status of emergency preparedness, 15 For the Pilgric site, the FEMA self-initiated 16 review, which was issued in De,: ember of '86, then documented 17 a number of areas, there were 6 that were determined to be jg inadequate in support of an acceptable Emergency Preparedness 39 Plan and they indicated that the plan, as it currently exists 20 i was unable to support a determination of an acceptable level 21 of Emergency Preparedness. 7, 22 That report was forwarded to Boston Edison for 23 response and they are, in fact, working with the state and 24 communities to provide resolution of those issues, thestath 25 of which Boston Edison wt11 address and we will address ({]) i Horitogo Roporting Corporation j imi .a
31/32 " g activities this afternoon. 2 That is an issue which is very visible in the area
.O,- ~
3 and particularly with the local citizens and elected officials .
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4 The Safety' Enhancement Program is a voluntary pro . gram. It is not'a prerequisite for plarit restart, other than 6 it is during mo'difica'tions that some systems art- 'taken out of 7 service. n .. g BECO is implementing several self-fnitiated enhance. . 9" ments to the Pilgrim Mad I containment, in response to a 10 review, an IPE, Individual Plant Examinat!.on, that was done.
- gg These are being implemented utader-10 CFR 50.59. .
12 They do not require changes te the license and the NRC has reviewed.the safety evaluations at our option. It is not a 13 r Q) 34 mandatory review, however, we have determined that the review 15 is appropriate and they have been conducted. 16 Additionally there are some legal and licensing 17 actions which are being worked concurrently with the technica L I i issues. As I mentioned earlier, there have been two 2.206 18 g, petitions submitted requesting that Boston cdison show why 20 the Pilgrim Station s?0uld not remain shut down until certain The petitions request adjudicator ] 21 issues have been resolved. if l 22 hearings to address issues related to management, Mark I O- 21 and Emergency Preparedness. , 24 We'll get into the status of those issues in this {
.js afternoon's presentatio q
Heritage Reporting Corporation l
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.g All licensing actions have been reviewed. There l
,o -2 are three remaining actions that are being worked in conjunc-d tion with plant restart assessment. Those again, will be 3
~O 4 dee 11ed tais efternoon. i ,
5 In summary, to. simplify, there are two blocks of - k 6 issues that,the~ staff is directing in connection with restart 7 activities. 1 g Both $istorical issues,'which existed preceding y 9 the plant shutdown in April of 1986. The technical issues 3, l which led to the shutdown as exhibited by the April 4th 10 gg and April lith plant shutdowns. Those. issues have been 12 looked at by the staff and have been resolved for the start ups. ,{ 13 There are the broader issues which preceded the 34 35 plant shutdown. That includes the Emergency Preparedness j 16 considerations, the 2.206 issues and the on going licensing ! g7 review. , gg We have available, if you so choose, information - 19 whichn is the basis for the summary slides that would , ;o include the organization chart, which depicts the turnovers 21 in management as well as the diagnostic team inspection re- ; 22 port, the augmented inspection report, in response to the >0
- 23 April 12th event and the SALP documents.
L 24 Are there any questions at this time? l 25 DR. KERR: Any questions? j I l Heritoge Reporting Corporation im -
+,,
e a -34 I- (No response)
) 2 DR. KERR: Does this' conclude your presentation 0
={~J
- 3 for the moment? '
1 3 _ t xl 4 MR. COLLINS : 'Yes, sir,-t is concludes this aspect. 5 of the presentation. 6 DR. KERR: I have a few; questions'about the SALP
^
7 system, I guess. As I read'both.the staff's. comments and-4
- 8 Boston Edison's comments'on the SALP system, there seems to bo '
9 emphasis:on.the fact that a 3 rating.does not indicate that the-10 plant is unsafe and yet, there appears tc be--in effect, it i 11 appears to me 'that the judgment being made on whether restart . t 12 should be authorized depends fairly-heavily on the staff's i , 13 . evaluation of whether an organization is moving from a 3 to ' .(](}:) ' j 14 a 2 or 2 to a 1. This puzzles me a little because it seems-15 to-me that in a regulatory environment, the staff should i f-16 set requirements which determine safety an'd anything that is I j 17 done beyond that is certainly commendable but is not part } ! j 18 of the regulatory process. < l i !- 19 Can you help me? I mention this not altogether to i j N be critical, but looking to the future, I see a situation ! i 21 which there was some change in the SALP rating over months, i j 22 but were still 2--1, 2 and 2 ratings and a situation in which ! ( r 23 there was not apparently a judgment that the plant should be 3
- 24 shut down until the plant itself was shut down and I'm trying j i
() 25 to judge what may happen in the future if the plant starts j Heritoge Reporting Corporation ; mm ; I f
, 35 1 up. Ilow will the staff make a judgment that things are okay 2 or not.okay.
Presumably not on the basis of'SALP ratings 3 unless the ratings are worse than 3's, b6causefa 3 still indi-4 cates a plant is okay. , s I am(searching.for'the rethod to be used in the 6 future because one sees a attuation here in which there has 7 been a rather;significant change in staffing at both the upper 8 management levels and middle management level. Thdre are a 9 large nuraber of 'new operators. There have bean changes in. 10 the plant and equipment, supposedly improvements. I have no 11 reason to think they are not improvements, but certainly it's 12 a different plant now than it was. 13 What assurance should I look for, as an outside v 14 observor, that one can judge, and the NRC staff can judge, is that things are going okay or not going okay within'the realm 16 of existing regulations? 17 MR. COLLINS: Let me answer that in two parts. I 18 think there are two fundamental questions in there. One is what issue led to the plant shut down? !!ow did we judge that 19 20 the plant was in a condition that needed a response like a 21 CAL? 22 And, the other is: In the advisement of the plant 23 start up, how do we determine to assess acceptable performance both at the start up and following? If I can summarize your 24 O 2> 9"e tio= - i Heritoge Reporting Corporation (see) 6stsees l
y-l 36 g The NRC has maintained that the plant was not O' 2; shut down for violations. of safety requirements. In fact, v= 3 the decision to shut down the plant because the two isolation 4 valves were closed was a conservative interpretation of Tech 5 Specs based on an unknown leakage rate through containment 6 and isolation valves, subsequently determined'to be accept-
- 7. able.
8 , The. plant was shut down be'cause of'the history of 9 performance issues and the three technical issues which occurred 10 on the 4th and i the 12th which, at that point in time, were not gg well understood. 12 Some of those same issues existed on April 4th, and
"*"" '" "S"' '" " "
O ' "**' ""' ""'" '" "* " "" ' **"**" d 34 not to be. 15 The appropriate NRC response at that time was, 16 they issued a CAL to require the plant to shut down until we 17 Performed an independent assessment to determine that Boston gg Edison's actions were, indeed appropriate. 39 MR. CARROLL: You said, required them to shut down. 20 You mean remain shut down? MR. COLLINS: Remnin shut down, yes, sir. The correc t 23 22 words are remain shut down. O 23 At that point in time, there was no intention for 24 this plant to remain shut down for two and a half years. DR. KERR: Well, I don't know whether to feel good 25 Heritage Reporting Corporation om =
37 I about that situation or to feel bad about it. One might
'.) 2 conclude, considering all the changes that have been made 3 since shutdown occurred, that things were in fairly bad ~
4 shape before shutdown occurred and'yet, as you say, the NRC 5 did not step in and say, hay, this plant is not safe, it better
}
4, 6 be shut down until things _get fixed up and this either was 7 because the NRC was reluctant to do so or was unaware of t
~
8 the safety situations or,.indeed, there were no unsafe situa- ! 9 tions or'maybe none of the above. ] 4 10 And'yet, in. retrospect, there just seems to be a 11 concensus that things were certainly not in the best of shape, 12 Does one have to wait, in the future, until some ;
'( 13 serious what, in retrospect, will look like a very serious ,
i 14 situation to develope before one can judge whet her something i I 15 is wrong? l 16 MR. COLLINS: No, I don't think so. I don't think [ 17 we did in this caso either. I think you look at the staff's I { 18 assessment of performance and the purpose of the SALP, to ! 19 complete the answer to your first question. l 20 I agree that category 3, performance, does not ' In fact, that is 21 indicate unacceptable safety performance. 22 very clearly depicted in the SALP NRC manual chapter, 0516. . .O 1 23 In a most recent revision to that chapter, it j 24 clearly indicates that if there is a safety concern with { l ([) 25 licensco performance, that enforcement is the tool that will l j ( Heritoge Reporting Corporation ! mmm t
b 38 e 3 be used to correct that performance and provide for accept-
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2 able performance. , 3 But the SALP is systematic assessment which is () 4 .used to try to understand why the situation' exists as it s does. 6 The Category 3's, although they mean. acceptable . 7 Performance, they are used to forcus both Boston Edison's 8 attention and the licensee's attention--excuse me, and the 9 NRCs attention to that site. i go I,have a slide this afternoon that indicates the ^
- s. ,,
gg amount of inspection' hours put in at"this site from the early l 12 '80 period. You'll see quite a dramatic rise in the inspec-33' tion effort in response'to that initiative. i g4 The plant's performance, although erratic, was 15 determined to be acceptable, but there is other information 16 which wasn't. contained in the slide which indicates that thera 17 were some very severe civil penalties issued prior to the plant 1 l 18 shutdown. 3, We had a number of management mootings with them i l 20 and they made some senior management changes--they had re-21 organized. 22 I think what you're asking me is how much is enough 4 O 23 before the NRC determines that positivo dramatic action needs 4 r 24 to be taken. l () 25 At this point in time, the second shutdown in Heritage Reporting Corporation
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F 39 g April, for the same reasons as the April 4th shutdown was 2 enough. The NRC determined at that point, that we needed ot 3 understand why the plant shut down,'why those issues weren't rv (~/ 4 corrected previously and what they intended to do in thefuttre .
, ,5 The SALP document which immediately preceded that, 6 I thinx, hit the target. I think the words that are contained 7 on the slide,which are the subject of.the team inspection, 8 indicated what needed to be done to improve performance.
9 DR. KERR I'mla bit puz'zled as to--you also tell go . me, I think, maybe.I' misunderstand,:but the SALP ratings are 11 not part of regulations and,are not part of any enforcement 12 process. , 13 On the other hand, I read that licenses that have g4 low SALP ratings are expected to improve. 15 MR. COLLINS: That's the second part of your ques-16 tion. I haven't answered that yet. 17 DR. KERR: Okay. I'm trying to separate safety d 18 from SALP and I am having some difficulty doing it because 39 somebody said, if it walks like a dog and barks like a dog 20 and looks like a dog, it must be a dog. 21 The SALP system certainly looks ar.d acts and . 22 barks a bit like an enforcement process, but it isn't? 23 MR. COLLIhS: Correct. 24 DR. KERR: Okay. 4 MR. COLLINS: What we use the SALP for and why it's l (]) 25 Heritoge Reporting Corporoflon ! tm) utasas
-40 referenced in the actions which are necessary to proceed with 2 P l ant restart, is because it's a very effective tool that the w 3 s,taffshas to look.at the ability of licensee management to
( , 4 effectively implement their programs. 5 One part of that is their ability to comply with 6 'the license. That's taken into consideration during the SALP 7 process but it is not a major part of that assessment. 3 DR. KERR: We.it a minute. .You mean the NRC has 9 responsibilities beyond seeing that.a licensee.is complying. 10 with the license,and the NRC regulations? 11 MR. COLLINS: Yes, sir. Our responsibility is as 12 an internal organization, to understand why the plant performs 13 the way it does. U 34 We do that by using the inspection process as the is input of our technical data to look at that raw technical 16 data, to evaluate why it exists as it does and then to perforn, 17 a subjective determination of how the licensees management 18 systems and organization bring those results to bear. 19 It's a historical document that looks back, but it's 20 used to try and determine where our resources, which are 21 limited, should be focused and to send a message to the 22 licensee that, in our judgment, and admittedly it's a subjec-23 tive document and we're very open about that, where there are 24 weaknessos or strengths in the organization exist to help them () 25 focus their resources. Weritoge Reporting Corporation m mmm
t , 41 '
; As an example, we have three resident inspectors-
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/"T 2 at this site as a result of the types of issues that came up V
3' from SALP. ,
\
.(] 4 DR. KERR: Were there 3 resident inspectors before i
5 the shutdown, the '86 shutdown? r I 6 MR. COLLINS: No, sir. We have 3 resident inspectors 4 7 at the Oyster Creek site. We have 3 resident inspectors at 8 Nine Mile Point and'we have 4 resident inspectors at. Peach 9 Bottom and that is the result of a SALP process which focus' , 10 our resources towards those plants which are determined to , 11 need that type of: attention. l 12 DR. KERR: Should I then interpret your comments
-s i 13 to say that you do not believe that the regulations themselves 14 are adequate to determine plant safety?
15 MR. COLLINS: No,,I didn't say that. Compliance 16 with the regulations, including the technical regulations [ 17 insures that on a technical basis the licensee maintains the [ ! i 18 plant within the design limits of it's manufacturoa;. ; 19 construction and operation. That is the basis for safety. , i The second part of our role is to try to understand 1 20
, 21 why that performance is as it indicates, in this case, Boston 22 Edison performance resulted in the plant being shut down and 23 e', confirmatory action letter.
24 The systematic assessment of licensco performance, () 25 I believe, had some very valid issues on why those conditions ! Heritoge Reporting Corporation I l . o i=> m i
42
- , 3 existed. We're using it on.the backside in answer to the 2 second part of your question, as an effective tool', by'th'e 3 staff, to try'and understand the response to the issues by 4' looking at management effectiveness.
3 For example, the plant has been shut down for two 6 and a half years. There is very little license requirements 7 which need to be maintained during that plant shut down, a other than those to maintain some very basic system 3
, operability, to provide for refueling and to maintain minimum 10 levels of staff.
11 If we solely use that as a judgment of licensee 12 performance, we.have very little criteria to judge the O >> ebt t*v or
- ate etent to re tert-O 14 ~ So we use the systematic assessment of licensee 15 performance as en enhancement to try and determino management s 16 involvement to correct those issues.
17 DR. KERR: I'm not trying to make the case that the 18 regulations are adequate to do what needs to be done. I gunsa 19 maybe 'they aren't. I'm trying to find out if, in your view, 20 they are adequate. 21 In my judgment, at th is stage, on the basis of 22 what I see, is that they probably are not adequate, that you 23 need something in addition and the something in addition 24 that is being used in this case is the SALP Reg. O 2. I have difficuter evoidine that conc 1usion. Heritage Reporting Corporation
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43 .T :MR. COLLINS: ~Well, sir, I think we're in a y-2 philosophical' argument about the status of tho. record-- 0 3 DR. KERR: l Unquestionably we're in'a philosophical ih 4 argu:nent one which I personally consider important -because I 3 think we are operating in a milieu in which regulations
, ' exist,.many of them were formulated and'your plants were 7
being constructed and put on line and it would not surprise l 8 me that they are inadequate to deal with plants that have been l 9 in operation a long. i I'm n t sure that they are, but I think we need to 10 gg look at this and not just for this case although I think i 12 this is an important example of what happens in an operation 33 when one he: co depend only on the regulations, i O i4 "a co"'"$' ' ao='* "=aer *==a vour o=e ===e"ta"* 1 15 sir--as proceding your plant shutdown or following a plant s l 16 shutdown?- g7 DR. KERR: Well both. In the first plac6-- i gg MR. COLLINS: I don't agree with you. j-j DR. KERR: I'm not asking you to agroo with me, g, i
!!r . Collins , I may be wrong, but I see a situation in which, 20 in retrospect, there appears to be a long history of diffi-l 21 22 culty at this plant and yet, with the exception of a lot of j
- O 33 inspections at some plants, nothing was dono, the plant was f 24 n t shut down by the NRC. I don't know whether it should havo boon or not, but if it takes two years of concentrated effort 25 j Heritoge Reporting Corporotlon t => .
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'ei
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'and as many changes'as have occurred in that interim, in both 2 equipment and personriel, then there must have been some seriou s 3 problems. Maybe not serious enough to shut the plant.down, 4 but, in retrospect, they must have been perceived as serious s and yet, the NRCs interpretation of the regulations was such 6 that it did not feel it should shut the plant down.
7 MR. COLLINS: Well, I think you're using the two and a a half year timo span as an indicator'or the seriousness of 9 the-issues and I'm not sure that is appropriate. I think-it to is an indicator of the.prioritics, perhaps, that Boston Edisor 11 had in their arugment as to what they perceived needed to be 12 done and their ability to do it and the opportune time to do 13 it during the shutdown. It's up to them to address that issue . 34 Whether that could have been done sooner and could have is effectively been dono sooner, I think is a. matter of opinion. 16 Certainly there are significant issues at the site 37 which procede the shutdown and thoro.have boon significant la changes following the shutdown, very dramatic changes in fact, 3, Whether all of thoso changes are necessary, to provide for 20 Pl ant restart or not is up to BECO, it's their responsibility 21 to datormine that. We'll review their actions that they have 22 taken independently and datormine, at this point in time, 23 within the limited reviews done to dato, that they are 24 acceptable. I think the inspections now which are dono at the O 2s Heritoge Reporting Corporation
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i facility, there have been over 9,700 hours.during the last 2 SALP assessment period, 15 months, are indicative of the focuo 3 that we have on compliance with the rules and regulations. f 4 That does not include the amount of time that .is involved i 5 'with'the nanagers present here today. Their involvement in 4 6 cither the restart panel or the SALP process. So you're 7 looking at a layered process, I believe,iwhere one aspect of 8 the process sppplements another, t 9 I personally feel, I have to have a reason to under- : 10 stand why the performance is as ot is. Now, I think your ; 11 argument is that the regulations themselves, in and of 12 themselves, are they adequate. I think that's probably a 13 topic that is appropriate to address to the Commission. i 14 With the guidance that the staff has and given the amount of r 15 inspection hours that we have given to the site, I think j i 16 we have applied them on an extraordinary basis. 17 This plant has roccived approximately three times the 18 amount of inspection effort that the typical plant receives. > 19 MR. CARROLL: Just to continue along the:philoso-20 phical line of this thing, suppose the events of April 4th I 21 and April lith has not occurred. Would the plant still be , I l 22 running? ( O- I don't know, sir. I wasn't directly 1 t 23 MR. CARROLL: I 24 associated with the plant then. Would they still be running? ; Based on SALP, they would. There is the point () 23 I don't know. i Heritoge Reporting Corporation m usan
o 4 46 1 4
, !>1 I think we can'tLisolate, we have had those inspections J..
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2 for quito a period of time mow, but I think we have to r [ 3- ' acknowledge that there are other ef, forts besides the SAL'P 4 and the regulatory process that includes the senior management
! i 5 reviewa and meetingsLwith the Commission-to discuss plant 6 atatus, those types of things.
4
- 7 When a plant has the type of historical problems ,
4 8 that Pilgrim had had, at that point in time, the process 9 provides for those issues to be raised to a very high level, , to including direct discussions with_the Commission and those
- L' 11 discussions include the staffs intended response to those f
( 12 plants. They have direct input to that process. ( 13 DR. KERR: Any further comments or questions? 6 t 14 (No response) .' 15 DR. KERR: Rhank you, Mr. Collins. l 16 MR. COLLINS: Thank you. i i i ! 17 At this time do you want to proceed with the Boston 18 Edison discussion or do you want to take a break? 19 DR. KERR: I think at this point I will call for L i ! 1 20 a 10 minute break, since we are on schedule. t 2 ! 21 (Whereupon, a short recess was taken.) f 22 DR. KERR Let's proceed. Mr. Bird. (:) MR. BIRD: I am not going to use slides. We have 23 24 hand outs put at each of your places and I would ask that () 25 you follow through with those. Heritage Reporting Corperoflon
a 47 . 1 Anyonein.tifeaudiencethatwantsasetofhandouts, I 2 please help themselves. We have more than enough here. f 3 Good morning, I'm Ralph Bird, the Senior Vice i 4 President, Nuclear, for Boston Edison Compan 5 I joined Boston Edison on.the 1st of January, 1987 , t , >
- l. 6 and after spendingsa few months in an intennive, training ;
7 program on the Pilcjrim Plant. I assumed my responsibilities 8 at the end of February, 1987. Since then I have spent most of ! 9 my time at the plant ub ordeli to:be closer to tho' people and 10 tof.heirproblems. I i 11 When I arrived at Boston Edison my immediate task 12 was to assess the strength of the organi=ation'and determine
.Q 13 areas that needed improvement. The next step was to assign ;
O i4 priorieles end direce our eteeneien end reeeurcee eccording1 . 7 . We have continually reassessed our situation, [ 15 l 16 adjusting resources and refining the process which resulted [ 17 in the filing of'the SALP assessment of our readiness to re-l 18 start report. 19 We evaluated management practicos at Pilgrim : t L 20 and presented our conclusions to the Nuclear Regulatory { t 21 Commission at a September 24th 1987 public meeting. i f 22 We determined plans and actions necessary for re-O 23 start and we issuoci our restart plan in July of last year. l; l l 1 24 We conducted in depth assessments of maintenance and [ s 1 t
- 25 radiological controls and imp?.omented improvement action plan a .
l Heritoge Reporting Corporotlon [ o.n -=
i. I
; 48 o
g covering both restart related and long term actions. 2 We conducted investigations and critiques of speci-3 fic events at Pilgrim and identified actions appropriate to
. , 4 to prevent recurrence, f r
3 All of these assessments are building blocks that I i 6 support our recent SALP assessment report. It is our inten-7 tion and resolve to drive that SALP asse nment process down s through and across the organization and to make it afpart of i
, our everyday operation.
10 This morning, some of the key line managers and I !
+ , l
, gg will describe the corrective actions taken since the plant i
~
j , 12 was shut down and the status of our efforts to achievejcon-i
, 1 13 tinuining rise in standards of excellence.
34 The long term management organization has been l i t ! 15 defined and almost all key positions have been filled. All I
- 16 kay managers from the section head level and above, are ;
! 17 now Boston Edison employees and this is shown in the first ! ] l } gg slide that you have. g, The Senior Management Team is a seasoned team with 20 over 250 man years of successful nuclear power exp6rience. l
)
21 They are very strong individuals and they all have very high ! standards and they work well together. i' 22 4 O 23 We have strengthened the organization by adding f i I i 24 people who are among the very best in the field, in plant, ; I 4 I ec"rter ta r atotosic t
- O 2s ta e=er9e"cv vree reaae==> ta i Heritage Reporting Corporation 1
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,' '49. 3 protection, in operations, in plant support operations, in
'/
; 2' P l ant support in special projects and in quality assurance.
3 In addition, we have maintained continuity of the - 4 work force and of management through the retention.of most 5 of the long term Boeton Edison employees. i 6 You will shortly hear from the Station Director, j 7 Ken flighfill,'from the Manager of Emergency Preparedness, Ron ! e a Varley and from the Vice President of Nuclear Engineering, j 9 Ed !!oward. . We have also upgraded the Nuclear Safety Review and 30 , 1 ! 11 Committee and we brought in Bill Wagner as Chairman and -' l 12 added other new highly qualified outside members-to this i fp 13 important group who are widely recognized experts in their e 14 field. [ t i- is Looking at the next slide-- l 4 j 16 MR. WYLIE: This is what is normally referred to 17 as the Safety Review Board. l 1 i la MR. BIRD: Safety--The off Site Safety Review , J-39 Committee or the Senior Safety Review Committee which [ 1 20 reports directly to me. l 21 MR.lWYLIE:
.It's an independend Board? f i'
22 MR. BIRD: Yes, it is. About half are outside i O 23 people and about half senior Boston Edison managers. { 24 MR. WYLIE: I noticed that it didn't shov on l f O 2. vour caere- t I i Heritoge Reporting Corporation I j <wo man . 1 f
50 1 MR. BIRD: It does.- If it were on there,Eit 2 would be directly under me at the top. level. 3 MR. WYLIE: Thank you. AJ 4 MR. CARROLL: How many members are on that 5 committee and could you tell us a little bit about who the 6 non Boston Edison menbers are? f 7 MR. BIRD: Yes. Bill Wagner is the Chairman and he 8 served as the Deputy Director of Naval Reactors, Admiral 9 Rickover's senior deputy for about 20 years and has served to on a variety of panels and consulting groups both as an advisor 11 to utilities and I believe he has worked as an advisor to the l 12 Department of Energy also. Henry Stone was for a number of years the Chief (] 13 14 Engineer of the General Electric nuclear organization. Beforo is that he headed the--I believe he headed the Knowles Atomic 16 Power Laboratory. So he understands both the Navy and the I 17 Commercial side. !!e was a member of the Reed Commission 1 l 18 that reviewed General Electric's reactor designs and as a 19 result of that, he was taken out of the Navy program and put i ? 20 in to head up and improve the GE engineering designs. l 21 Murray Milws who is an expert in radiological I
- 22 controls, chemistry. Again his'hackground is largely in the f 23 Naval program. !!c was the radiological and chemistry ;
t ! 24 chief reporting to Admiral Rickover for most of his career. f lie retired after a normal tour as a Civil servant and joined l (]) 25 l t i Heritoge Reporting Corporation , i .. i i i
~ . - . _-. .- - .
c 10 years, yes. l l 6 Jack Gregory, is also a new member. Greg is the 1 7 best person I know on instrumentation, controls, electrical I g and electronic systems. !!c was the Instrumentation control l 9 Inspection Chief for Rickover in the development of the Navy i I go program and assisted me some when I was in the Navy when.I ! i l j in had some particularly difficult problems. He also has served- - s Y 12 he retired about the same time to Civil Service, about 10 13 years ago. Ile has also worked as a consultant to industry, j g4 to the Department of Defense and to the Department of Energy l j 15 since he went into the consulting business. 16 Leo Duffy is the newest member. Leo's expertise 17 is in training. He was involved in the training of Naval j i j gg Operators. !!e was, a number of years ago, was the Manager : i i g, of the S-lw Nautalis training prototype in Idaho 'nd moved . il f o up. !!c was a GE employee most of those years--I'm sorry, t j ! 21 Westinghouse. 'to was with White-Westinghouse within the l ! . 22 Dettis operation. lie worked as a Section !!aad in Naval l l Reactors also with oversight of training. !!e wcs responsible l i i 23 ! l for some of the very significant upgrades in the Navy training { 24 1 i 0 2. groer== aad he at o h worxed ta verioe vect or the #ucte r j Heritoge Reporting Corporetion i
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52 I power industry. He is also an expert in waste management
" 2 and head a large section of Westinghouse in that area. He is 3 now employed with the Weston Corporation. He is also a 4 consultant at a number of nuclear utilities, most of them 5 in thi training and operations area.
6 I believe that about summarizes it, on our side, 7 we have essentially all of the senior managers, QA managers, 8 the Vice President of Engineering, the Plant Manager ^are 9 members along with Ed Wagner who is my senior staff assistant, 10 .MR. CARROLL: This committeo looks at the operation 11 and in an indopondent sense and gives you an assessment of hou 12 things are goitr;? 13 MR. BIRD: That's corrdet. I don't attend the imeting 14 for the entiro duration. I attend the beginning of each 15 mooting. They moot on site once a month for one or two 16 days. They have assigned subcommittees to look into various 17 areas of interest including operations, maintonanco, i l 18 radiological. l I :toglected to mention, in the tnajor subcommittoo 19 ) l 20 of the Nuclear Safety Review and Audit Committoo, is an } ] 21 independent radiological oversight committoo and in addition i 22 to Miles who hoa'Is that, we havo Charlie Minewold who, I !p
- V i 23 believo, is from Brookhaven National Laboratory and wo have i
24 Tom Potorson who has had extensive industry experienco and ! O >> heeds e suudivis an of cen- e1 ornemics w = gr- ides the l Heritage Reporting Corporation
53 l a ,
- g. servicos to industry and to government in the radiclogical ;
2 congrols area. He has dono consulting work for a number of { 3 . utilities as well as for the Department ~ of Energy. j i 4 D6ctor Corcoran is the one remaining outside i i , 3 membar. lie la involved in vveral nuclear safety committees j 6 at other sites and hiri backgrottnd is with combustion engineari j 7 ing and safety and design. f a Shifting now to the current plant status, the
, next slido, if you will turn the page, summarizes the major I . .
i work that we have dono during this outage. It's entitled, 10 J gg "Current Plant Status." , 12 The conditon of the plant has improved dramatically i 13 s!.nce the beginning of the outage in 1986 and the rate of . j g4 improvement has accolorated through 1987 and 1988. l ! 15 The ple..st is refueled. We have successfully complo- l ! 16 tod the hydrostatic and integrated leak rato tests. The l l major modification work has boon completed. We are now doing ! ] 37 1 is testing survoillances and routino continuing maintenance. ! l I j g, Details of the extensive work that has boon dono t l and in our Self i 20 during this period are in our restart plan ! i 1 21 Assossment of Roadinoss forPostart Report. [ I Turn to the next slido. Some of the major projects
. 22 23 of t' '
'tage woro completion of the Appendix R, firo pro- ;
i I'm back on the proceeding slido, Dr. Korr. I i 24 toctio.c i + 1
'toa i
O is ^rveadix a, 8 curiev v te= "vorado , ta t- ! of a plant specific simulator for training operators, ovor- [ j Heritage Reporting Ccrporation 5
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54 g haul of the turbine generators, refurbishment of plant systemt ,
, 2 including the main steam isolation valves, residual heat re-(G 3 moval pumps and core spray pumps and decontamination of the
(~\ r L._) 4! process buildings so that virtually of the accessible areas of 5 the plant can be entered without protective clothing or with-6 out breathing appratus. 7 Certainly one of the most significant projects has a been the safety enhancement program which includea both 9 equipment modifications and procedure improvements. in We dedicated significant resources to this program ll which excceds current NRC requirements and therefore is not 12 a prerequisitic for restart. Our program which emphasizca prevention of core (m) 13 34 damage was a Boston Edison initiative in :esponse to the 15 draft severe tecident containment policy for boiling water 16 reactors which the NRC staff presetned to the industry in 37 June of 1986. ja Ed floward, our Vice President of Nucicar Engineer-39 ing will discuss the safety enhancement program in more 20 detail later today. 21 We're proud of our accomplishments in this program , 22 because we have significantly improved our capability to re-spond to off normal events in a cafe and reliabic manner. 23 l 24 I We have dedicated significant resources toward the functional areas which were rated Category 3 () 25 l improving Heritage Reporting Corporation (m>.a.= ll
55 I in the last SALP period which ended in January, '87 for the f ) 2 5 areas so evaluated that moved up in category 2 for the p(riod LJ J ending in May of '88. These are Assurance of Quality, Fire 4 Protection, Surveillances, Security and Safeguards. And 5 ( we think that this is significant because the NRC staff has 6 said that their standards . e raised each year, so they'll 7 go from one category to another, it takes a little work. 8 Radiological Controls was rated as a 3 but improv-9 ing which means they expect it to go up into the next cate-10 gory. There has been a great deal af progress in this 11 area since our last SALP. Virtually all accessible areas b of the plant, 90 percent of the process buildings 13 radiologically clean. The health, physics, and readiological 14 protection staff hat. been greatly expanded and we are tracking 15 radiation exposures carefullly and emphasizing radiological 0 16 l safety throughou+. the work force. l 17 I Many of these changes were not fully implemented l 18 until rather late in the SALP evaluation period and it is 19 ; perhaps, therefore difficult to gauge their effectiveness 20 l but we now have cleat evidence that they have been effective 21 and accordingly, we will request that the NRC staff change g; cm 22 l1 this rating from 3 to 2. Of course, we have no assurance i t hl (J J 23 ll whether--how they will act on the request, but we believe we ' 24 fd can make a case, 1 ()
/m 25 Even as our SALP ratings improve, we will continue d Heritogo Ro9erting Corporution me .a a
. 56 g to make every effort to achieve rise in standards of O 2 excellence in every aspect of the operation. We will be O
3 relentless in this effort and we do have the right people to 4 be successful. 5 Shortly after we completed our self a:sessment, 6 of readiness to restart, the Institute c; ..aclear Power 7 Operations performed a two week plant evaluation. The g results of the INPO evaluation confirmed, as our own 9 self assessement of readiness for restart and our restart to report included that, upon completion of the actions gg identified in the restart readiness self assessment, 12 restart plant, Pilgrim will be ready for cafe and reliable ( , 13 restart and continued operations, y The INPO team examined the station organization is and administration, operations, maintenance, technical g support, training qualifications, radiological protection, 17 chemistry and operating experience. They also looked at
,g management involvement and commitment, material and outside gg services, human resources, and emergency preparedness.
20 INPO's mission is to assist member utilities in. 3 achieving the highest standards of excellence in nuclear plant 3, operations. The recommendations are based on the best 23 industry practices and are intended to lead to these rising 24 standards of excellence.
]- ;$
i In light of INPO's high standards, we are especially h Heritage Reporting Corporation imm.
57 g proud of their identification of the number of good 73 g practices and strengths in che most'recent report.-
\ l 3
I would now like to ask the Station Director, Ken [ 4 !!ighfill to continue with this status report. 5 MR. CARROLL: On the INPO assessment, were there 6 Si?"4ficant weaknesses identified? 7 l MR. BIRD: There were no signficant--I would say 8 , they were not significant weaknecsos. There were all those t 9 ! recommendations for improvement. There were no significant I 10 items that they telt needed to be addressed before we gg started. They were 3 or .4 relatively minor issues which 12 we have addressed. g 13 MR. CARROLL: Okay. Thank you. W 34 DR. KERR: Mr. Wylie? 15 MR. WYLIE: No. 16 DR. KERa: Mr. Bird, is the plant now in compliance 17 or do you have plans for early compliance with the so called gg "black out" rule? I MR. BIRD: We think that we comply with it. Ed, 19
;o would you like to comment or that?
MR. !!OWARD: I will address that during my later 21 J
'2 I presentation. ) h 33 g MR. BIRD: Ed lloward will be un here in a few Y '
i minutes. The black out will be--we wi.l be put nearly in 24 f) 23 compliance if not completely, , m . f [ Heritage Reporting Corporation q <m>u.
58 g DR. KERR: Much of what you have said and much of m 2 what your documentation indicates has to do with your efforts ( 3 to, satisfy is perhaps not the right word, but I'll use it, l'~) to satisfy the GRCs concerns and I can uncerstand that that (_/ 4 i 5 would be foremost on your agenda. 6 MR. BIRD. No, it's not, it is not foremost on our 7 agenda. 8 DR. KERR: What is foremost on your agenda? 9 MR. BIRD: Foremost on my agenda is satisfying n) our own standards. A sub set of those, if we satisfy our own 11 standards, we should easily satisfj NRC standards. 12 DR. KERR: I'm glad to hear you say that. I 33 would hope that is the case because I believe that if the {^y}'\_/ 34 plant is to be safe and reliable, one does normally have to 15 go beyond NRCJ program. 16 MR. BIRD: I agree completely. I could give you 17 a one minuto philosophy on that, gg DR. KERR I would Le glad to hear it for one 39 minute. 20 MR. BIRD: All right. In my view, say here at this i
- l level, if we tried only to meet the minimum set of standards
- 22 and we misjudge slightly, we will be below the minimum and , '~
that is an unacceptable place ot be. 23 l I on the other hand, if we are trying to be the very 24 best in the country, and we misjudge and we fall short a (]) 25 l I h q Heritage Reporting Corporation lj
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T r i t , 59 f i little bit, we're still one of the best. That's out standard, ; 2 DR 7 KERR: On'another; topic'.I read an article i O 3 recently, I can't remember exactly the connection,,but it 4 . was talking about resources *available for activities and it i i referred to some military organization as having infinite i f 6 resources--the Navy might have been one of the organizations. ! t 7 MR. BIRD: That's a different Navy than-I was in. 8 DR. KERR: My impression is that over the past 9 several years or so, that Pilgrim has not had infinite re- . l F 10 sources necessarily; but has had a fairly significant J 11 allocation of resources'in order to do what has been f J I 12 accomplished and I think they could'not have done that [ l 13 without a pretty significant allocation of resources. I t 14 Is there assurance, in your view, that the necessary ! 15 resources will continue to be available for what needs to be f i : l 16 done to keep this plant operating, if you are permitted to f' r i 17 start? l N < C MR. BIRD: Yes, I have absolutely no doubt about f - L F 1, that. I have attended overy board meeting since I joined the j J i 20 company. I have frequent conversations with the Board of I J I' 21 Directors and I report directly to the Chief Executive Offi-a g 22 cer. There is only on way to operate a nuclear power plant 1 V and that, in our minds, and that is to operate it with a view ! 23 24 toward achieving excellence across the board. Given that, t () 25 over the long term, the natural fall out would be an efficie nt f l Heritoge Reporting Corporotton I
60 I and also cost effectiva operation. The excellence must come (, 2 first, the cost effectiveness and profit will follow. If U 3 you do it the other way around, I don't believe we can be 4 successful and we are not. 5 My only direction from the Board of D:.2ectors was 6 l that we make the plant right, be sure the people were ready 7 and then proceed with actions to restart it. That is exactly 8 what we have done and there is absolutely no question in my 9 l mind thatthe company is committed to maintaining a high class 10 operation over the long term. 11 DR. KERR: Thank you. 12 MR. HIGHPILL: I'll une the same set of graphic] 13 and thefirst one is to get you in place and that will be the i 14 one on Personnel. 15 i Cood Morning, I am Ken Highfill. I joined Bos an b 16 l Edison in late 1987 as the Pilgrim Station Director. hl 17 0 I have 29 years of Navy and commercial nuclear 18 : experience. When I arrived, most plant modification plant 19 Work w as done. It was clear that they not only needed to get i 20 the remaining work done but that it should be donc, as much h 21 4 as possible, by Boston Edison people. that is what we are Ilo
- 22 ,
doing. I ) ! 23 The result is work that the individual can be L 24 p proud of. Collectively, the people of Pilgrim can be proud 25 proud of where they work and what they do and one can see the a g Heritage Reporting Corporation j = ma n
61 I improvements in their morale.
,- 2 We're mooting our goals to complete work, improve
( ) 3 housekeeping and preservation, reduce contractors, increase
/m
(_.) 4 Boston Edison staffing and to do high quality work. We're s generally meeting our schedule and visitors are commenting 6 very favorably upon plant conditions, worker attitude and our 7 sense of prido. 8 The first visusi is what I will address now. In 9 July of 1987, there were a total of 1,820 contract personnel 10 working for the nuclear organization at Pilgrim Station. Il Today there are 432. Included in that is guard force which 12 will continue to be contracted under Boston Edison supervision i at a year end level of abolut 160 people. (]} 13 () 14 We intend to be below 250 total contractors by that 15 time. We have achieved this reduction in nanpower while 16 removing most temporary modifications and driving the Bcchtel 17 contract work packages to zero. Is We heve instituted new management practices in 19 security and completed physical improvements to the secarity 20 systems so that we can eliminate guard posts as compensatory 21 measures and we have done that. l
- ! We are doing the bulk of our own programmatic and
() 23 administrative work. At the same time we are moving aggres-24 I sively to do better on planning work and improving productivity I 25 j so that we can reduce overtime. That is indicated in the next
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l 1 i visual. I J i 2 In June.we initiated upgraded work control processes 4 3 that provide better assurance of quality and improved
- 4. reliability.cf all of our safety related work.
i s , Pilgrim should be-a pleasant place to work and that ' 1 t 6 means that people should be working a 40 to 50 hour week most l 7 of the time. This enhances productivity, alertness and raorale .
- 1 8 To meet this. goal, we are filling approved vacancies in the 9 nuclear organizations ahead of schedule, as noted'in the next 10 graphic and we have not compromised ourstandards in the hiring f t
g il practices, j ] 12 MR. CARROLL: Back to the ove.ltJ me slide. } g 13 MR. IIIGIIFILL: Yes, s'ir. [ 14 MR. CARROLL: What do the current numbers mean-- L ! i 15 MR. IIIGilPILL : What they mean is that-- [ 4 [ j 16 MR. CARROLL: --in the sense of overtime? l I I .
; 17 MR. !!IGl! PILL: Yes, sir. They are targeted at 12 [
i 4 l la percent and then look at an increase of 18 percent during the ( ) 19 60 days prior to restart which is what we're in now. , i
- 20 MR. CARROLL
- Thank you. [
I I j 21 MR. IIIGilFILL: Despite the fact that we have, on 22 three occasions, lowered the threshhold for issuing !
- O radiological occurrence reports which is the method by which 4 23 ;
t j 24 we document and inspect corrective actions for minor ( O :s reatotosioet erodie - the a" der or eveat de arovvea dr a l P Heritoge Reporting Corporation i in wm
63 factor of about 5 and the severity of the error: rate has de-2 creased. 3 In addition, we have eliminated our backlog and O . we dea 1 with such events in a time 1y manner, usua11y under on. 5 week. This has generally driven the active files _to single 6 digit, as demonstrated'on the' graphic in front of you. 7 Quality assurance non conformanen reports are being a low and under 30 are presently outstanding on plant installed
, equipment, although a hand full of these should be cleared to this month and all well be cleared before we reach start up.
3: Additionally we have had only two overdue quality 12 efficiency reports in the past 7 months. They were cleared up 4 13 in a matter of days.
\._/ 34 We are also aggressively addressing quality assurance is recommendations with timeliness and thoroughness of responso 16 being the keynote.
17 As I stand here today, the outstanding QARs are is under 10. 3, The key component of successful management is
;o a system for measuring progress. We have decided to track 21 certain key indicators which are important because the
' indicators contribute to the safe and reliable operation of 22 O 23 the nuclear plant. The indicators are good guides for 24 overall operation and in some cases, the items have been 25 areas of concern for Pilgrim in the past years.
Heritoge Reporting Corporotion (800) W 4000
64 I would discuss four of these ares which are im-G 2 portant to achieving safe, reliable and continued operation.
.)
3 They are maintenance, plant decontamination, radiation 4 exposure control and operations preparedness. 5 First maintenance. We have worked on thousands of 6 maintenance requests and we intend to stay ahead of the work-7 load. Today we prioritize maintenance requests in order to g plan and control the work more effectively. There is a 9 visual that shows the MRs in process. 10 Using instituted nucolar power operations or INPO gg guidelines, we have focused on power block MRs. When we met 12 the INPO goal of 500, which is the industry aggregate, we rained our sights and toughei.ed the program legels. As you can see, O 13 g4 we're hovering near the new goals of 400 and, in fact, today 15 we are below 400. 16 Since the completion of the last SALP period and 37 NRC naintenance inspection 88-17, we have made a number of I gg dramatic improvements in maintenance. We have implemented a I g, revised work process which includes planning check lists,
- o we have trained 545 personnel on itc use, including me, my
;g i boss and all of my department heads. We issued a greatly in-i proved maintenance manual. We have implemented detailed work 22 O 23 i
progress which dramatically enhanced the viability of our i work packages. We expanded post work test maxtrixes. 34 , 25 We proceduraliz2d supervisory reviews to insure thorough 4 Heritage Reporting Corporation
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65 g maintenance close ups and we assigned operations and systems r'3 2 engineers to have the lead on prioritizing the work to be O' 3 done. ('\ (,) 4 We have added a Deputy Maintenance Section Manager 5 to the organization and filled that position with an individua l 6 who has 30 years of hands on experience in the field. 7 We have expanded the maintenance organization by a transferring personnel from other areas and at the same time 9 improve the supervisor to craft ratio. 10 All supervisory positions are now filled with Bostor , 3: Edison employees who have attended supervisory training prior 12 to assuming their new responsibilities. () 13 Some duties which, in the past, have prevented _ g4 supervisors from getting out into the field have been re-15 assigned. We have improved the organizations ability to 16 integrate radiological and operational considerations into 37 the maintenance process by assigning health physics and gg senior reactor operator qualified people to assist in the 19 maintenance planning process, 20 Our recent assessments of the new work control 3 process show both the value of the process and its acceptance by the entire work force. A direct benefit of this new
<s3 22 L N-] \
process is to increase the officience of our quality 23
)i 24 assurance efforts due to greater case of auditability and l
() 25 specificity of technician activities. l
! Heritage Reporting Corporation j m m me
66 We firmly intend to maintain the physical condition 7T 2 of Pilgrim Station such that it is a source of pride to all
\-)
3" employees and to our Navy and that it helps to meet the grow-en k_) 4 ing need for electricity in New England. 5 As regards decontamination, when this octage 6 began, only about 45 perccat of the process safety were 7 accessible without protective clothing. Entrance into some 8 of these areas required self contained' breathing apparatus. 9 We made a commitment that before restart, 90 per-10 cent or virtually all of the accessible areas in the plant 11 would be decontaminated and we already did it. 90 percent of 12 the plant is accessible in street clothes and we intend to We think a cleanor plant promotes safety (p') 13 keep it that way. (-) 14 and quality. Inspections are more frequent and more thorough is when the operators do not have to dress out in protective 16 clothing to enter the areas. 17 Beyond these benefits, however, we are also vitally 18 interested in reducing total worker exposure. Our policy is 19 as low as reasonably achievable and we are pursuing it 20 aggressively. We are communicating its importance in training 21 and we are making sure that every employee knows that g-) 22 individual exposure is the individual's responsibility. LJ 23 l L We originally set our exposure budget for the INPO h 24 f 9 guidelines. As the graph shows, we have been living well () 25 within that budget. Heritage Reporting Corporation m .a
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- The industry average has decreased but we are on
, 2 track to come in below that mark. We have established a new i
(# 3 and much tougher goal of 390 total man rem which is 20 percent eN (_) 4 below the 1987 industry average. Based on our performance 5 thus far, in 1988, we will meet this very difficult target. 6 Finally, I would like to discuss the readiness of 7 our Operat)ons Department for restart. 8 Since last summer, two successive classes of re-9 actor opera: ors and senior reactor operators have taken to their NRC e <ams with a 100 percent pass rate and with 11 excep4ionally high grades averaging over 90 percent. 12 Once the new licensees have met their operating () 13 experience requirements at 20 percent power, we will be able () 14 to staff a 6 shift rotation. To insure that there are always 15 enough operators in training to compensate for attrition, 16 we will start another licensing class in January, i7 I would point out as an indicator of staff 18 stability and high n. orale, not a single licensed operator 39 has left Pilgrim Station in 1988, 20 During restart we have planned for a 4 shift 21 rotation. This will permit an extra senior reactor operator 22 to be assigned to each shift and allows more proficient use () 23 ! i of our experienced operators. l 24 l Our operators look good. They are now in uniform 25 { and they sound good. Training in formal communications has
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, been effective and is showing clearly beneficial results (
2 in improved control and higher levels of professionalism. l O 3 All f ur crews have completed training on the
, 4 revised emergency operating procedures. Our operators have l 5 been observed as part of our SALP assessment by INPO and by ,
, the NRC as part of their area team inspection. l 7 Every assessing team has concluded that they are
! a well trained an'd well prepared to operate the plant safely , 3 f.
, and reliably. j l 10 There has recently bien some. misinformation i
I aborad concerning the staff experience level at Pilgrim and ( 12 I w uld like to take this opportunity to set that record I 13 straight with facts. The facts are that the 49 current licens e
^^ve *verie" -
O i4 h ' der 'o*- ' 524 x r- ' """2"^r ' which 462 years are at boiling water reactors. Over 450 of 1 g3 ( 16 those years of experience are at Pilgrim Station. These are L i i 1 37 very well qualified personnel with extensive industry, Navy { 18 and plant specific knowledge. They are professionals and 3, they carry out thei duties in a responsible, conscientious 7, and professional manner. 21 MR. h7 LIE: Pardon me. 22 MR. HIGl! PILL t Yes, sir. iO 23
!!R. STLIE : How much of that is at Prilgrim? !
I l MR. HIGHFILL: 452 years actually, sir. There is a 3 r graphic that displays that, 25 i ,L 4 j Heritoge Reporting Corporation ! L <=o . t h u_
69 t 3 MR. WYLIE: Thank you. j t 2 .MR. HIGHFILL: I left a little slack when I said 3 450. l 4 But 39 key managers in the nuclear organization I 5 have more than 800 man years of nuclear experience. Over 465 t i 6 of those years are at BWRs of which 385 are at Pilgrim Station . [ a-7 Here again, we have an extremely healthy mix.of Pilgrim, in-a dustry, INPO and Navy experience.? Both PWR and BWR that
, very few plant's in the country could equal and here again, 10 We Perform to'a strict professional ethic.
4-i gg I'MR., CARROLL: What is the 80'plus year on that vu
! i' 12 graph? j i
33 MR. HIGl! PILL : I'll have to turn to that, sir. 34 MR. CARROLL: Current positions. i 4 i 15 MR. IIIGHFILL: Oh, that means in these specific :
?
l 16 jobs that they hold at the plant, f
' f 17 MR. HIGl! FILL : In summary, quality, timliness, f
- 33 sense of ownership, professionalism and pride are evidenced j g, in the way we doing our business. I am proud to be part of !
l , 2e the Pilgrim Station team and so are my people. With this ; I ' 21 present team, and our recent track record, I am very confi- t 22 dont that we will be ready for restart when we next address j O 23 the Commission and that Pilgrim Station will have then have j
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24 become a source cf power and pride to our neighbors and to I "e* O 25 11 or ==9 1 #a- Ta =x vo"- i
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70 g b2. HIGE'ILL: Are shore any questions? gS 2 DR. KERR Mr. liighfill, on Page ES-5 of the materia l U 3 provided for the ACRS subcommittee, the statement is mader (m (_) 4 "To further strengthen operational performance at Pilgrim 5 Nuclear Power Station, Boston Edison management is placing 6 increased emphasis on development of procedures for the plant. " y What does that mean? 8 MR. !!IG!! PILL: The issuance of procedures that 9 can be adhered to verbatim--verbatim compliance is the industry 30 word. It is something that takes a great deal of time, 11 Typically plants have, over the years, developed procedures 12 that take a great deal of training and effort to work with, f^) w 13 You can increase the probability of success in every operatior k- y by providing procedures that are absolutely correct and that ir 15 the effort that we are heading down. 16 We have already trained our people to adhere to that 17 ethic such that now, as we do any piece of work whether it is be maintenance or operations, if there is a problem with the 19 procedures that the person cannot follow, he stops and to omTect. 20 the precedures. 21 We have just recently established a separate pro-f- 22 .cedures development route that will allow us to focus that 23 effort and keep a standard of cost. In many many procedures , 24 that we have--we have over 4,000 procedures on site, it's a large () 25 ladministrativeeffort, i
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- Many of these procedures--operational procedures T 2 or anything that had to do with any kind of an emergency, G
3 goes through a variety of steps before they are actually A L) 4 introduced as approved procedures into our process. 5 First,of course, the drafting of the procedure and 6 in that process the system and operational experts in the 7 field have their input into this. There are editorial form.to a i that inust be met but the technicia content is put in by l 9 technical experts in the field. The procedures are then 10 validated as to their accuracy by engineera, operators, who-3 ever, again the technical expert is, and then verified that 12 taking that procedure and the operators that we have, coupled O3 13 with people with the procedure and demonstrate that that V 34 combination would affect the thing that you want to have is affected. 16 Once that is done then every crew is trained with 17 l that verified, validated procedure and then it is issued I gg l as an effected procedure, as an approved procedure. l 39 l MR. CARROLL: With respect tc your transition from I 20 ! a 4 shift rotation to a 6 shift rotation, is that being 23 governed by the fact that you have got to get above 20 percent 22 power experience? n U h MR. HIGHFILL: Yes, sir. If you look at the 13 24 graphic, you'll see that we now have adequate people to do it i O 25
) ama caer are 11cem ea. amd tais te treicattr cattea the co-1 i
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- license and you need to have a certain amount of plant operat-2 ing experience for the NRC to upgrade that license to what is O' 3 called a hot license and that is what'we will do during the 4 power assension program under the supervision of the presently 5 hot licensed people.
6 MR. CARROLL: With 4 shifts, how do you get 7 training in and that is a required requalification. 8 MR. IIIGilFILL : Well, we actually have 5 shifts now 9 and one of those shifts is in training all the time, so we 10 i are continuing the training process right now with out 5.
- During the short term of the power assension 12 program, which would probably be about 90 days, we will go to purely a 4 shift rotation, however, I would say that the power
] 13 l O i4 e# to= eroer = it ett eive" ta t the v1 at a dee" aut is down for a long period of time, the power assension program 16 itself causes people to relearn things. It is a training I process in itself.
17 l 1s l Any kind of a start up of any complex instrument I is like this is always a ler.rning process regardless of the i 20 amoutn of cyperience you have on it. 21 MR. CARROLL: As far as people working overtime,
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22 during this geriod, particularly operators, I note that you O 23 d J have established a 60 hour a week guideline. H 4R. IIIGilPILL : Yes, sir. 24 MR. CARROLL: What does it take to exceed that? Wha t 25 O 0 l Heritage Reporting Corporation m m.= [
I , 73 i ! I are your views as to how often and how much and-- [ t 2 MR. IIIGl! PILL: It takes my signature to exceed that 3 and we very seldom exceed !.t. There are som NRC guidelines I 4 that require very strict compliance and we have set up a 5 very strict program to meet those guidelines. ( 6 Again, as we approach those guidelines, my signa-I 7 ture is required for an individual to exceed that--the
+
s authority to allow people to exceed 40 hours a week is 9 filtered won through the management structure. Certain levels to are allowed certain leeway in allowing overtime, but as they l 11 approach the NRC guidelines, that level reaches the Safety 12 Director. 13 MR. CARROLL: And those NRC guidelines are incorpora - la ted in your present toch specs, are they?
?
15 MR. HIGHI'ILL : No, sir, they are in an I&E Bulletin I 16 and in a generic letter that describes the guidelines and the j i ! 17 staff's interpretation of those guidelines and we have to [ l I '. It incorporate that into a nuclear operating procedure on the i ! I 19 site. It's a formal procedure. 1 i 20 ftR. CARROLLt Thank you. t i 21 MR. hTLIE t The NRC has identified as one of the key i issues the assurance of a stable and effective management 1 22 2 O $3 and staff. Could you explain--enlighten us as to what your 5 l 24 strategy is to accomplish that? 25 MR. HIGHFILLt Well, one of the things about i 1 i ! Heritoge Reporting Corporation 1 ;
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74 i stability of staff is, I think, the important thing to keep in G 2 mind is stability of policies and execution thereof. It is b 3 not necessary that the same individuals sit in the same 4 chair to cause a continuation of policy practices. So that 5 is the first guideline that I have in mind is that we want 6 to establish guidelines and practices that the entire 7 organization learns as they go and they live within them, 8 so that if we do have changes in personnel, which we are 9 bound to have, in an organization of this size, those changes to do not lead you in a direction of large changes or back-11 sliding of policies and practicos. 12 Now with that said, we have established some super-visory training recently that we have not had in the past. {} 13 34 Ke have hired some new people out of industry to bring in 15 the experience of the rest of the industry which, I think, is I 16 sonething that was lacking--it wa' aceded here. 37 And each of our senior managers has increased the gg day to day interplay with the people that work for them i, . directly. I think we are giving ourselves defense in depth, l
- o if you will, in this regard, and I couldn't name you a hand 23 full of managers today that if they walked away, we wouldn't !
22 have somebody that was up to stuff and able to fill his jh 23 position. 24 MR. WYLIE: I believe since you have been shut down f l 25 that you have hired about 50 percent of the personnel from o P j Heritage Reporting Corporation ; im> 3
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). 1 l outside,'is that correct?
2 MR. !!IGliFILL : Fifty percent of those that have 3 been hired since we have been shutdown, is that the question? l 4 MR. WYLIE: I mean of the total management staff. i 5 MR. HIGi! FILL: Of present management staff? ! l' 6 MR. WYLIE: They were hired from outside? 7 MR. HIGHFILL: It would depend on where you-take the :/ ( s cut as to what the management starf is. I can't address the s specific statistic. I mean myself and a senior vice president, ; a j go a 100 percent, but as you go down through the staff, the j t j 33 percentage decreases and most of the peopic that sit back j t J i 12 there whom you're going to see today, I guess about half of l l l 13 them are new and half of them have been here for awhile. [ i l ) 34 MR. WYLIE: About 50 percent? ! b 15 MR. BIRD: The effort has been*not to replace one i i 16 for one. It just depends on the effort--the focus of the f effort is to bring in additional strength. If you look at 17 1 d is the organization chart, the second page of the handout. [ [ i, We have split up the staff and of our total manager s j _ , t 20 we have more managers, top echelon than we had before so that . f ' 21 each manager build his supporting staff. l 1 f ' 22 As far as stability, too much stability can be
- O 23 just as much a problem as too little. We put our managers L
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j 24 through various positions so that when it comes time to [ i ree1 ceme=t < r =e. eor him. ror vt =t a ser we O >$ vicx l l Heritage Reporting Corporation i ! <me . {
76 I will have several highly qualified individuals who have had 2 experience in a number of advance management positions. 3 MR. WYLIE: Well, didn't you say your objectivo (q _/ 4 is to develope your managers from inside Boston Edison rather 5 than hire them from the outside? 6 MR. !!IG11 PILL : No, sir, I would not say that that 7 is our objective. I would say that our' objective is to a have a team of as good a managers as we can build and to 9 have a healthy mix of long term Boston Edison employees and 10 incoming experience from elsewhere in the industry. That it is our objective. 12 MR. WYLIE: It's not unusual to see 50 percent of () 13 team managers from outside an organization. If that is 14 intended, I am not so sure that is a worthy objective. 15 MR. IIIGi! FILL t I don't see that continuing. We 16 believe we have about the right mix right now and obviously 17 l people who have been tore for a year of two and are Boston 18 Edison employeen years from now, they will be old time Boston 19 l Edison employees. l 20 Now we will continuo, occasionally, to bring in l 21 j people where we think the strength is needed. We are also n 22 l, getting our people out into industry more so that they can l We have had members 23 h bring that experience back themselves. I 1 on INPO inspection teams recently. We have that coming up 24 a l again in the near future so we can be helped by people from (]) 25 d : [ Heritage Reporting Corporation mm [
77 I within. 2 But I would not proscribe bringing people in from [] v 3 outside from time to time. f) v 4 MR. WYLIE: I understand that. You mentioned s supervisory training. Do you have--does Boston Edison have 6 management development programs? 7 MR. !!IGl! PILL : That, in itself, is in the process of a developement. We have a new resources staff assistant and 9 he has experience in that field and he is developing a pro-to gram for uclear managers that should go into effect, I 11 believe, .n January. 12 MR. WYLIE: I see. Thank you. 13 MR. CARROLL: On that issue of training, I guess 14 the taterial that we had to review prior to this meeting 15 h ..idicated that you had 4 of your 10 INPO programs accredited? i MR. !!IGl! PILL : A 100 percent, sir, all of them. 16 l 37 MR. CARROLL: I wanted to clarify that because I la thought I heard that-- gg l MR. IIIGl! PILL : That was in the last SALP period but f' they are all accredited now. In one of the area plants--thera 20 23 are 16 plants in the country out of the 55 that had been i 22 !! accredited. O 23 [ n MR. CARROLL: Thank you, f One other stuostion. I believe you have 24 { MR. WYLIE: n 25 !l set as your objectives to have all of your senior reactor
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78 g operators or al.1 operators collegs (,raduates. 2 MR. IIIGilFILL: No sir. [\ 3 MF. WYLIE: That's not correct? q'o 4 MR. HIG!! PILL: No, sir. 5 MR. TiYLIE: I thought I understood that that was 6 C'errect. All right, thank you. 7 DR. KERR: Mr. !!Ighfill, I notice in a number of g SALP reports here, there was a good bit of emphasis on 9 Appendix R and Pac Techs. Can you tell me how many fires 10 have occurred inside the plant since the plant has been in gg f operation? 12 l'R . !!IGI! PILL : How many fires have occurred in the () 13 plant since the plant has ben operational? DR. KERR: Yes,
) g4 MR. l(IGIIPILL: I can't--no, sir, but I am sure we is 16 can find that out.
I DR. KERR: I didn't know whether this emphasis had 37 to do with the fact that the plant had been prone to fires is ' g, or-- l MR. !!IGilFILL : No, sir, no, sir. Appendix R is a 20 ll i 0
- ] major change to the fire safety rules that applies to all i
plants around the country. There are extensive changes that l 22 r l l\
\ We have our fire protection engineer here I 33 y need to be made.
n I I 24 g today--manager here today. d 25 DR. KERR: Maybe you could find out how many fires-- l 0 Heritoge Reporting Corporation j j mm t
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- MR. !!IG!! PILL: I can tell you that since I have boon 2 here, that's for the last 8 months, we have had 2 very minor ;
'- ) 3 ovents, neither one inside the roector building, but 2 O, 's_ 4 events in which we have called out the Plymouth Firo Depart-f 5 mont.
6 One of them was a wolder had dropped something on a 7 . picco of plastic that smoked and flamed for ab>ut 7 minutes. l s Another one was there was an air conditioning unit in a 9 trailor, outsido in the assembly area and soll away from the 10 plant that an air conditioning motor burned up and then there was another event whern a cable wrapped in insulation 12 over heated and smoked. That is what has happened in the 8 33 months in a largo industrial facility since ! have been here. (] L. () 34 DR. 1 ERR: On Pago V-1 and V-2 of the material is provided by Boston Edison to the ACRS, there is the followingt 16 i "As used throughout this report, the term ' goal' is not 17 intended as a go - no go acceptance criteria. It is intended is to have the dictionary meaning, the end to which effort is l 39 l directed. In this sense Boston Fdison's goals are intended ! l 20 I to guido its efforta and if performance falls reasonably 21 ; within the range of the goal or if trends toward the goal \ 22 h are positivo. a positive management assessment of performance i () 23 p would be indicated." d 24 That sort of seems to no to say it locsn't matter a 25 d how quickly you get there, as long as you're aimed in the O c l Heritage Reporting Corporation [ ! y on: m
11 0 I right direction. Is that what I am supposed to conclude from 2 that or-- V 3 MR. !!IGl! PILL : No, you're not. Basically a set of 4 goals encompass a variety of subject areas that was set over s a year and a half ago and the idea there was to apply 6 jj resources in appropriate mix to address each and overyone of 7 those areas. 8 , What we have found is that we have met nearly all 9 of them, in fact, several of them we have changed because wo 10 found that,1f you will, the goal is lower than it needed to 11 l be because we were able to reach it. 12 We vill take all of those goals to the point where
] 13 [ they are, I'll use the word, "optimum," as time goca on and Ih 14 I have continued to encourage my people in their offorts as 15 g they go along.
l 16 h In other words, that if we are heading toward the 4 1 15 goal, at a reasonable and timely rate, then they're doing wel: .. Is h You can't reach all goals instantaneously, but timeliness is, r 19 . in fact, a hallmark of my management style. ! intend to dehl 20 with things in a timely way, h 21 f Now many of those goals have addressed backlogs that 22 we have had and a personal goal of mine and one therefore
'3 ; that I transmit to my managers is that we're going to and l
l 24 have, in most cases, heaten theoc backlogs down to t.he point l l 25 where we're not dealing with last years problems, f Heritage Reporting Corporation L (nr o. a
l 81 I We're dealing with day to day events and that's
- 2 the goal that I am pointing for. In many of the areas that (w
3 are listed in the goals that we have there, we are there to-(__) 4 day. There are still backlog areas where we have not reached I s lourgoals, there are a few. 6 DR. KERR: On occasion then,in the past, this 7 committee in discussing safety with people at plants has 1 8 l raised the question of where the safety conscience in t.he I 9 orgardization resides, n) If I ask you that question, would you know what I 11 I was talking aboot, could you respond to it? 12 MR. HIG!! PILL : Yes. At Pilgrim Station, we're () 13 trying to get that conscience to reside in actually a wide 14 body of people. is ! In the Senior Vice President, in myself, in the 16 plant manager, in the plant operators. There is a formalized 17 L requirement that conscience be addressed and be made visible F la in an organization that Pilgrim Station is called the operatior ,s d le d Review Committee. I hope I have addressed it. ' If you want the legalistic form, then it would be
- 0 U[
c 21 jaaidtoresideinthework. In the ethical form, it resides J 22 J where I just stated. 23 : DR. KERR: Thank you. Any further questions. 24 MR. BIRD: I might add that among my first policy
- s directives, it was made clear to each watch engineer, senior
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82 I on shift operator that they have direct access to me for any g3 2 safety related issue. (_) 3 MR. h"lLIE : In that regard, is there an on site C 4
!' safety review group?
5 MR. !!ICl! PILL: Yes. That's the organ, the off 6 site safety review group is the NASRAC which you have already 7 addressed. 8 MR. WYLIE: But there is an on site safuty review 9 group? 10 MR. !!IGilPILL : Yes. Yes, sir. The Chairman of it 11 is here if you have any specific questi.ons of him. 12 l MR. WYLIE: Let me clarify a statement I made l C 13 regarding college. 14 i I believe it was in a meeting with Chairman teck 15 earlier in the year that someone said that you had initiated , l < 16 l a college degree program for the operators. Is that still in 17 p! effect? l I 18 MR. LIRL: That is true, but it i ts not a requirement , Il Is that because you beliove the 19 l MR. WYLIE: 20 operator's should have degrees? 21 t MR. !!IGl! PILL: Not in my mind, i 22 MR. WYLIEt You don't consider tuat it chuald Le i l J 23 ( a requirement for reactor cperators? MR. IIIGl! PILL : Personally I do not. 24 [o MP. WYLIP: All right. "hank you.
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.: MR. HIGHFILL:- In my' mid they ; deserve the J 2l oppor,t unity. .I; felt.the same!way inithe Navy where we had
.3 ledicated. enlisted. personnel who were very bright, who ,
'p'had the oppurtunity to go te college but entered the ;
_4 5' .s young men who was.in the mid. 20's or.early '30's 6' y' .etliair career path would be hampered or their own self , 7 .esteom'6imes. Some people vi'ewed ths' as something they 3: wanted to'do and the, Navy made that available in the program.- 9 that was'very well accepted and Boston Edison has been doing 10 the.same thing. .
,gg It~is not riecessary for the execution of their
, 12 duties. . 13 MR. WYLIE: Well, that's what I was getting at. i 34 Fine, thank you. MR. HIGIIFILL: There are others in the industry who - 15 will give you a different answer, but personally I do not 4 16 17 consider it so. 'l I 33 MR. WYLIE: Thank you. . f 19 MR. CARROLL - I was rather concorned in reviewed , , 20 the material that we had prior to the neeting about the loss i r of off site power. Is that somothing that you can cover or is 21 . 22 Mr. Howard going to cover that?
- 33 11R. HIG!! PILL
- Doctor Howard will cover that.
MR. CARROLL Thank you, 24 i ! 25 } DR. KERR: Any other questions?
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- '. NMR.;., BIRD: Next?is Ron Varley'who~has'.the Emergency.
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s; ~ Preparedness.Yc 6 MR. VARLEY:- Good Itarning. - My-name is Ron-v
, ri 5 ; 7- .Varley. I am the Manager 'of Emergency Prepcrednest for , PilgrirU s
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-9 I came to Pilgrim Station from Toledo Edison [ik ,
.10.
June of 1987 with 17 years combined nuclear Navy.and indUstryM
-11 experience, 10 of them in emergency preparedness. p 12 My top priority since joining Boston Edison has bee n O 13 the develop! rent of improved relationships with the authorities 14 responsible for off site planning and the provision ;f the is necessary types of support to insure that their efforts to 16 upgrade their programs could be successful.
17 Ne have recognized that Boston Edison, with the la effort required to maintain an emergency preparedness program 19 for Pilgrim Station, requires greater resources than the towns , t 20 can typically muster on their own.
. 21 Accordingly we have made commitments to provide the 22 necessary types of resources to all of the 5 towns in our i O 23 cmorgency planning zone and to the two reception conter 24 ' communities which support both towns. ;
i We currently have signed letters of agreement with h 25 I Heritoge Reporting Corporatio - ;
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;7 g4 2 types'of:supportlbeing provi' dei 1[are;shown on the handout Jn 3 . < - .
p3 your--are shown.on a,page in.your handout a'nd they include _ a [Mp ,' , ' o, , s 4 large staff of professional planners: end they're working on w ' u:. ,
} 5 a daily basis with the Commonwealth and with the communitice to ;
N;;.Sy l 6 -insure the upgrade in programs that we are working on, will a.
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. 7 meet .or: exceed. allL of the applicable regulatory requiments .. ,
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, 8 and that.they will: address all.of the legitimate concerna t 9 of the.l locall officials..
10 , iMR.' CARROLL:. Whatfdoes "large" mean? 11 .MR. VARLEY: LWe!' h ave about 35 people right now f 12' 'workincl.withEthe off site ! agencies in revising their programs. l- ' 13 We're also funding.'a full time Civil Defense Staff O n goue1oninmechofth<1-e1c-un1uesf- eheeg-eeing < . 15 life of the station, someone that the community can have on a 16 daily basia to dral with the planning issues, not only for 17 Pilgrim but also'for natural disasters as well. t 18 We have also funded the upgrading of the towns j l 19 omorgency operation centers in each of the 7 communities. j 20 and that includes the revision of their buildings and the 21 provision of all the'necessary equipment to carry out their i responsibilities. i l 23 And lastly, we're providing compensation-- j 24 MR. CARROLL: Is that new engine generator sitting ) i 25 out along side this building part of that? I Heritoge Reporting Corporation ! m u- c _.--~ .__. . _ _ _ . _ . - , . _ _
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p g MR. VARLEY: Yes.- That is the"emergency diesel ' 2 generator for this facility.- 3 We're al'so providing compensation'to the emergency workers that participate in the training programs to learn : 4 5 about what their~ responsibilities and roles would be in the 6 event of an emergency. 7 We will continue to work closely with all the'off g site officials in the agencies involved to insure that we 4 9 can build upon the substantial, progress that has been made , 10 to this point and draw the program to a conclusion. 33 That's all I have. 12 DR. KERR: Thank you. Questions. ; 13 MR. CARROLL: Where does FEPA stand in all of this 14 at this instant in time? Have they reviewed what you have is done? . 16 MR. VARLEY: Well the-- i 17 MR. CARROLLr Do they review what you have done? ; ! 18 MR. VARLEY: Well the towns have been working on 19 draft emergency plans and draft implementing procedures and, ; I 20 at this point, the towns have submitted draft plans for an , 4 ; 21 informal technical review by the Federal Emergency Management Agency and that review was conducted in May and those comments 22 ,
- 23 have been f actored back into the towns program and they a
- :a 24 working on a addressing FEMAs comments to that informal O >> techatcet review-
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8 7 .. i MR. CARROLL: And what'is the next step? When is g. 2 that going to be' finished ~and FEMA review the revised--- O MR. .VARLEY: The. process currently is that the 3 , b3 r y 4 towns are; finishing up.on,their emergency plars implementing,
- y. , , - . w .
. procedures'and several of the towns have reached the, point 6 where they,have' finished (that and they are resubautting y 7 both their emergency plan which addresses FEMAs co'. aments and their detailed implementing procedures for a seconi l'n-.
8 .- , i 9 formal review by. FEMA. l 'e Once that is done, then they will enter into a 10 (' gg training and a drill program culminating in an exercise 12 that FEMA will attend and observe. Thank you.
"- *"""' '"""* ' "' "" """ "Y-O >>
MR. BIRD: The next presentation will be a little g4 j 15 longer. Do you want to take a break vr do you want to pro- ; 16 coed? J DR. KERR: Let's take a 10 minute break, 37 i ! 18 (A short recess was taken.) , g, DR. KERR Mr. Howard. l l! MR. ItOWARD : Thank you. I am Edward !!oward, Vice i 20 i 21 President of Nuclear Engineering at Boston Edison Company. , 1 l Attending with me today are Dave Blanchard of : 22
- O 23 Delion Corporation; Dr. Robert llenry of Faust and Associates 24 and Richard Swanson who is the Manager of the Nuclear Engineer -
( i 2s ing Department. Heritoge Reporting Corporation
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- All these gentlemen have been active id our 2 safety enhancement-program.
I plan ~this mor'ning to provide a summary descrip ' s i [ 3 4 tion.of the Safety Enhancement Program which Boston Edison 5 initiated in July ofl19 86 and,'to, explainy the current impleneta- - 6 tion status of that program. e 7 _For'conveni$nce~and consistent with the fine a tradition of this industrp in the use of acronymns, I'll refer 9 to the Safety Enhancement Program as the "SEp" from now on. 10 The actions we have voluntarily taken in the SEP 11 go significantly beyond current regulatory requirements, 12 therefore are not requirements affecting the restart of Pilgrim 13 Station. O i4 we ere vroua or our ecc 911 a eat i= ehe see aa is ,I believe we are contributing at the leading edge of technolog'r 16 on many of the severe accident issues which industry, through 17 the IDCOR Program and the NRC through their studies have been 18 evaluating during the past decade. 19 In order to maintain perspective in a discussion of 20 severe accident issues, we need to keep a few facts in mind. 21 Postulated severe accident sequences are highly 22 improbable events that require multiple failures and extensive 23 P l ant damage to occur. 24 The conservative design and licensing practices 25 employed by industry end the NRC provide significant margins Heritoge Reporting Corporation (ast) M6dete
, 89-g of protection against such events.
2 Both IDCOR and_the NRC have performed extensive
'Q- 3 studies of severe accident issues since the accident at Three ,
4 Mile . Island in order to advance the state of technical knowledc e 5 and toN evaluate,the adequacy of current design and operational 6 Prac tice s... 7 '?he availability of these state of the art studies' , g do provide significant additional insurance which currently 9 regulatory requirements effectively protect public health 4 10 and safety. h gg I will proceed with a discussion of the SEP but 12 I would like to keep those in mind because we begin discussing , infrequent events and it's easy to lose track of.the infrequency Q 13 y elements that can seem more real as one talks about them. 15 MR. CARROLL: Do you have some definition of 16 "unfrequent"? j7 MR. HOWARD: Well, you can determine that as you 18 do risk studies and begin to quantify them but they clearly 19 are sequences that go well beyond the design basis accidents 20 that are required by regulation to be a part of the design 21 and licensing of those unit.s. 22 We believe the SEP is one measure of the substance O 23 underlying Boston Edison's commitment to excellence in the 24 oporation of its Pilgrim Station. First I would like to discuss the goals that 33 Heritoge Raporting Corporoflon ine) ...
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g _, 90 g Boston. Edison set lfor the Safety Enhancement Program. It
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2 w uld both sa near term goal and a; long term goal. 3 he -near term goal, we. established to identify and 4 implement plant.' improvements rer.c7nsive to the'NRC's Nevero 5 reactor containment policy f6tl BWRs. Revise Emergency c ' s 6 Operating Procedures and train operators to improve their 7 operation 1 readiness and ensure an' effective'use of plant g capabilities in the unlikely event of an accident.
, The LongLterm' goal we'esdablished was to perform to a comprehensive safety assessment supported by both determinis.
gg tic and probabilistic analyses of-severe accidents to ensure g; .three things: 13
- 1. The Pilgrim specific response to postulated g severe accidents is well understood; 2. These insights are 15 ef fectively used within Boston Edisor. to reduce both the 16 probability and consequences of such events and last, that g .,
the insights are available in support of our emergency pro-18 paredness planning. 39 While implementation of the SEP has considered 20 both accident prevention and accident mitigation, we have 21 placed priority emphasis on accident prevention. W have a simple viewpoint. The best strategy 22 O 23 f r accident management is to avoid the occurra..a oZ an accident. It is not only cost effective, but it ic also far 24 25 more satisfying to the many people who have been working to O Heritoge Reporting Corporation
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g contribute'to the' attainment of our SEP goals.
,2 Our action plan is to meet the near term goal 3 or essentially complete it and we have mado significant pro-( 4 gress on current.re-planned activitieserelating to the long 5 term goals. I'll provide more detail on implementation 6 status as I proceed._
a 7 , The next item I would like to discuss are the
' elements of the AEP. program which includes the following types s
9- Lof activities. The safety analysis element, including both in probabilistic and deterministic analysos; plant equipment- , i 33 modifications; emergency operating procedure improvements, i 12 training improvements'and last management system improvements. I' () i' To achieve the SEP goals, these activities must l 13 V 14 be implemented in a well coordinated and interactive manner 15 with continuing attention to the operational application. 3 16 The next topic is the strategy and approach that i "\' i 17 we use'in the SEP. Probably the most important thing was the I i 18 CXPert technical team that we assembled to support the r l9 implementation of SEP, 20 The contractors that we utilized included General l l 21 General Electric and Bechtel, the original designers of l 1 i Pilgrim Station. They brought the knowledge of the existing .( 22 23 design and the site analyses and licensing basis that already , . 24 existed. 1 () 25 Secondly Delian Corporation and Faustic Associates, l Heritage Reporting Corporation i .; < => m .=
4 92 , i 1 Incorporated, these two firms were the developers of the 2 boiling' water reactor. individual plant evaluation methodology (' 3( developed under t8e IDCOR program. The two firms showing their O 4 IDCOR knowledge and their benefit was their prior leacership 4 5 role in the IDCOR Program. 6 Third,-Picket,-Lowe and Derek, because of the 7 relevant airial' work they had done on Pilgrim Station and 8 because of their widely recognized literature from developing' g 9 risk assessment methods. , 10 The fourth expert resource was Operations Engineering Incorporated, were the developers of the Boiling Water Reactor 4 11 ) 12 Owners Group Emergency Procedure Guidelines. They brought the I t unique knowledge of boiling water reactor systems ~and BWR I (]) 13 i () 14 response characteristics and their recognized leadership j is in developing symptom oriented emergency operating procedures. 16 Boston Edison also contributed individuals to the 17 team, but particularly relevant experience obtained from 4 i is presious career experience and from managerial participation ; i i I 19 in both the IDCOR program and the boiling water reactors owner s 20 group program in in reserve. This team provided the unique combination of 21 i 22 specialized expertise and knowledge which we felt was necessar r i
; 23 to implement the SEP as the leading edge of BWR safety tech-
- 24 nology.
i 25 Because of the aggressive type of schedule we
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JY 93 3 established for the SEP we moved immediately'to prepare 2 . conceptual designs for plant modifications before plant specif.i c "O 3 = risk results were available. This required us to rely 4 initially on expert judgments to be generically filled on 5 the considered excellent behavior of BWRs. 6 Scope decisions were'made considering the knowledge
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'frcm insights available from the IDCOR Program, from relevant a work by the BWR o'wners l group," froni discussions with the NRC 9 staff regarding the perspective which they had in developing 10 the draft for the reactor containment: pol' icy and some discus-gg sions with a highly qualified expert team we had assembled to 12 support us.
13 In parallel, we initiated a probabilistic safety O i4 eeeeeement, e etene egecific one end eegerete1r en individue1 15 plant evaluation with an IDCOR developed methodology performed 16 Delian Incorporation and Faustian Associates. 17 Preliminary results from these evaluations were 18 used as they b'ecame available in or' der to fine tune the initial 19 scopo decisions in the SEP. 20 DR. KERR: Excuse me. When did these two efforts 21 get under way? 22 MR. IIOWARD: The probabilistic work in early--mid O 23 '86. We had previous preliminary work which had been initiated 24 before we started the SEP and was a pick up and expedito and 23 the IPC work in late 1986. Heritage Reporting Corporation g m emes
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'l DR. KERR: In late '86?
4 vy 2 MR. l!OWARD: In late '86, I believe it was November. 3 .DR. KERR: Thank you.
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4l MR. CARROLL: The IPE work was based on the IDCOR s methodology? 6 MR. t. HOWARD : Yes. 7 MR.' CARROLL: And how would you characterize the ' 8 PRA in' terms of 9 hat, level system?. ' 9 MR. !!OWARD: :!It'is~ a' Level I probabilistic study, directed f . 10 at evaluating. core damage through thecsystem. 11 During the early~ phase of'the'SEP, the entire team-12 of experts mot fiegularly to review _the results of ongoing work 13 and to share knowledge and ideas for continuing activities. i U 14 These meetings provided for technical interaction among team ' l 15 members and they worked to perform an application oriented 16 . mission. 17 An opportunity for substantive inter action of I l 18 this type with such a qualified team of diversified experts ; t ] 19 had never before existed, to my knowledge. 20 1 believe it has boon an exciting and stimulating , 21 experience for everyone. i 22 Throughout the SEP implementation, FEBOS and Edison 23 personnel have maintained continuing involvement in relevant l 1 24 ongoing IDCOR and EWR owner group activities. We have done 4 that in order to share our knowledge with them and also in (]) 25 Heritoge Reporting Corporation
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95 3 order to' remain informed of the ongoing work that they were 2 involved in. (_-)s . One last point and'I will. complete discussion of-3 4 the process and focus- have'.taken and then move into a descrip-s tion of specific implementation actions. 6 That last point I think is. simply that the~effectivo - 7 ness of the SEP lies in the strength of process that we have. , 4 8 followed and not rushing the implementat' ion action that we
- 9 were taking. The' depth'and breadth of technical expertise to which the SEP utilized and'the inter active involvement of 13 these specialists in the team environment has produced an j 12 integration unique to PWR expertise.which has never happened 4
13 beforn and has never before been applied to an individual plant program. .f 14 1 15 We have all labored hard to apply that expertise , 16 and the benefits of a multi disciplinary team capabilities- - 7 l s 17 in the future of our SEP implementation.
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is As you recall, from an earlier vu graph, the i g, near term SEP goal included the requirement that we identify 20 and implement plant improvements responsible to the NRC . 21 draft of BWR, CRS and containment policies. , f 22 Bob Burnell who, at the time, was responsible for l 23 BWR licensing activities at NRC had first presented that j l 24 draft policy back in the discussion in June 1986. Bob's i idea is vary much parallel with my own emerging perspectives f ([) 25 Heritoge Reporting Corporation mam !
[ 96 I from several' years of involvement with the IDCOR experiences.. m 2 While Bob advocated the policy and it's context as U 3 a basis for improved containment performance or accident ( 4 litigation, I envision implementation of those ideas as a 5 basis for core damage accident prevention as well. 6 Discussions with Dr. Henning, a preeminent. technical 7 contributor to the IDCO'R program supported both perspectives 8 and further convinced me of the merits of adopting the draft 9 NRC policy has drawn major focus, within the framework 10 of our SEP implementations. 11 A second' basis for'the focus within the SEP derived cl2 from both the industry respo'nse to,the IDCOR studies and the 13 NRC sponsored studies of severe accident behavior. 14 Both study programs had adopted a reference plant 15 confidence and both had selected Peach Bottom as its reference 16 plant for BWR Mark I containment type of design. Pilgrim, of 17 course, is a BWR Type I containment plant. 18 The NRC evaluations of the reference plants, at that 19 time, was showing Station Blackout events to be the dominant 20 contributor to risk followed by anticipated transients without 21 clearance. 22 IDCOR evaluations, on the other hand showed ACWS 23 events to be the dominant sequences followed by transient 24 involving f ailure of container heat removals and Station Blackou' ; 25 at the plants. Heritoge Reporting Corporation (Det) 6844000
a 97 1 Considering the results of both_from._both of these 2 evaluations, BECO decided to focus mid term SEP implementa-v 3 tAon on 3 items: Station Black Out events, ACWS and contain-kh 4 ment performance, events. 5 of course all these sequences are highly unprobable 6 when you look at the risk, but looking at the family of in-7 frequent' events, they are the dominant contributors. 8 As a result, because of our increase in events, 9 they don't--the existing levels of accident risk _in the 10 plants is low. 11 I know that there are people that make good argumen- :s 12 for accepting the current margins of safety as evaluated 'by the On >> 1 tese = tate or ene ere ecotaeat ovatuatioa - - U 14 ,'!!owever, in the:SEP implementation Doston Edison 15 has attempted to use such studies as a focus for making 16 integrated improvements to existing plant designs, emergency 17 operating procedures and the training of plant personnel in 18 order to further reduce these already low levels of accident 19 risk. 20 In implementing the SEP, we recognize that accident s 21 relative to design, procedures and training, must be implemen - 22 ted in a fully coordinated manner in order to obtain the 23 optimum operational benefits. 24 The SEP program was not directed at producing analyses, it was directed at tracing what we could identify C 25 Heritoge Reporting Corporation
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98 I from the information available and determining to the best 2 could, the actions that would beneficial and the application ( 3 of actions were very important. 7+ \ (.) 4 Lealing with Station Blackout, the most important 5 important SEP action is the addition of a third emergency 6 diesel generator which is available power any one of our 7 two emergency safety buses that supplies all plant 8 safety systems. The SEP diesel gonerator has been located 9 in an area remote from the two existing emergency diesel 10 generators, has'a deducated fuel storage supply, has it own 11 storage and supply system and is independent of station 12 support systems in performing its emergency functions. (^j) m 13 Succesful operation of the SEP diesel generator () 14 would climinate the loss of AC power in station blackout 15 ovent. But diesel generator installation is complete 16 and available for operation. 17 MR. WYLIE: Is that diesel protected against 18 external events? 19 MR. !!OWARD : No, that is not one of the design 20 parameters. Field emergency vehicles are pot protected against 21 external events, tornados, high winds, but we did not find <, 22 a rich benefactor ca/rying 'ho same standards for the tur-(_)s 23 bine. 24 The main bor fi' $.he turbine is its availability 25 under total loss the bulk of the two existing (/3 x_ i Heritage M erting Corporoflon (Nt} 614 4444
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, emergency vehicles are assumed to be inoperable.
2 MR. WYLIE: Would it comply with the Blackout Rule? O>- MR. HOWARD: No. The Blackout Rule did not exist 3 l' V)- 4 except in draft form and in discussions at the time we.were 5 making theso decisions. 6 The actions we have taken in this program, in con-7 sideration for Station Blackout event'goes beyond thoso that g tho' rule would require.
, Now that the rulo has been issued, usually there to are some prescriptivo elements in it that we will have to
- gg examine and wo may have to make minor refirements because 12 of those but the rule, by itself, would.not require the installation of a third diosol, for examplo.
f 13 ) - g ,g rt. WYLIE: I see. But what about that diesel-- . gg is that diosol seizmicly designed? , i MR. HOWARD:'No, it is not. ) 16 1 j g7 MR. WYLIE: Thank you. gg MR. CARROLL: Is the seizing of that diosol the ] 4 , g, same as the originally installed diosol? MR. !!OWARD : This diosol is slightly smallor ! 20 i j thatn the two omorgency diosols. It is not designed to copo j 21 i It is designed lo { 22 with design basis plus going after it. j 23 for a load that occurs under loss of outsido power and l 24 it's about 13 porcent smaller. ( i MR. CARROLLt This would requiro oporator action 25 i ,i t Heritoge Reporting Grporation m m.= I
rcn , 6 100 I to strip buses and that sort of thing? 2 MR. HOWARD. It will require it. 3 MR. CARROLL: In order for it-to function--
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4 MR. HOWARD: ~ Existing emergency buses are 5 designed to the individually except . for loading all three ' e 6 largeemergency cooling system pumps, two residual heat removal t pumps and.one spray pump on each bus. 7 [ 8 The station blackout diesel is capable of operating 9 any two of those which exceeds the system requirements it wou:.d le have for a normal station blackout, 11 MR. CARROLL: Special. operator action is required 1 12 here'and that is apparently part of your training? 13 MR. HOWARD: They have been proceduralized as part 14 of their training. That may be one area where we sort of 15 refino specific features of this third diesel in terms of 16 simplifying some:of those actions depending on the results of 17 of our studies and the benefits obtained. 13 DR.-KERR Have you calculated:the risk reduction t 1, achieved by the addition of this third vehicle? MR. HOWARD: We're not donc with etudie being dpno. 20 We implemented them very inter active way. We hope to get 21 22 them compAeted, but they are not completed at this time. 23 We will do that when we complete them. 24 DR. KERR: I guess I thought that you must have since you said that udding the size of the qualifications () 25 .& Heritoge Reporting Corporotlon i.
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a a 4 f 101 I was not really cost beneficial, for example. At least you , 2 must have calculated the incremental risk reduction'due to = 0 3 seismic qualifications. ; 4 MR. HOWARD: That was almost back of the envelope I s calediations. To do that, given the low frequency assignment
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_i I 6 combined with these other things-- I 7 DR. KERR: It's hard for me to see how you get
- 8 the incremental reduction unless you know what the risk i
- 9 reduction of the machine is by itself.
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- Whether it's from seismic condition.
11 DR. KERR: Yes. You chose to talk about the SEP ! 12 and I think that is ' commendable. I'm trying to find out as much as I can about it both because I'm curious about what (]) 13 () 14 this will accomplish and also because, to me, it is some is indication how carefully you approached this problem. ; I 16 I think, certainly, if I were going to do a PRA , j 17 as you are for an IDCOR assessment, I would find out how a j 18 much risk reduction this would achieve. [ i i 19 If you would prefer'not to talk about that at this I t I [
! 20 point-- t i- i i
21 MR. HOWARDs. That's the number. As I say, it's l ! 22 just preliminary and I'm not going to rely on it, but until l , 23 we finalize our numbers we will have an evaluation to do. l 1 I
! 24 Again, this program did not start with risk l I
25 studies as a basis for making a SALP decision. It started . ( I i Heritoge Reporting Corporation (300) MetBS 7
.t 102 I with general, knowledge and we.
"% 2 All I am saying is that we have preliminary results-3 and it won't be too long until they are finalized and.the-
.k e) m 4 report and the whole IPE response will be completed.
5 One thing that keeps us from finalizing our IPE 6 work is that some of the information from the staff and 7 we will be sure that we don't have to revise our work s at some later time. 9 DR. KERR: Okay. ' 10 MR. !!ONARD: Another SEP action is directed at 33 expanding the plant's capabilities to operate on D.C. 12 power, completely independent of AC power and two actions 13 that are taken which provides the DC load sotting and the j4 balancing of loads between the two battories expanding the is duration time before emergency batteries are depleted. 16 The second item-- MR. CARROLL: Does this third diosol provido 17 33 power to your existing battery chargers? MR. !!OWARD : It does. None of tho 3 omorgency 39 20 diosols function. Tho way the plant is today, they are 21 operating DC alone. The other change is to reviso-- 22 DR. KERR: If I could ask another question.about 23 24 the third diosol. In your analysis of the risk reduction. () 25 did you take trado cost account on thoso failures among the Heritoge Reporting Corporation m m.=
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i three diesels? ii p 2 MR. HOWARD: Yes. We were concerned about 0 3 maintenance and we come up with a contributor when you 4 go through that. o 5 'The final station blackout related SEP action is 6' directed at providing a new plant capability to remove decay
; 7 heat from containment supression pool which is not dependent 8 on,the availability of AC power. This can be accomplished .
~ h 9 by tho use of two SEP plant modifications. 10 One of those is a new inter connection between the 11 firo -water system and the ' residual heat removal' system which-12 provides an AC independentsource of make up water for reactor
! 13 pressure vessels fcr cooling arxl the second feature is the use of the j 14 direct flow system which provides an improved capability 4
15 to vent steam from the toras for decay heat removal from the j 4 16 supression pool. ! 17 Those two now design features are also beneficial is under other postulated sovoro accident sequences such'as. l 19 transients which include the failure to contain heat romoval. 20 MR. CARROLL: tiow the first one, the firo water i 21 intor tio, that is because this is a diesol fire pump or I ' i 22 more than one diosol fire pump? l' j 23 MR. !!OWAPD: No. It's because thoro is a diesol 24 driven fire pump which the existing capability for containmont i erav. ror exemete, 1 timitea to ^c artvea tieta artvea l O >> f , Heritoge Reporting Corporotion
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i 104 pump. This adds now a separately diesel driven fire water 2 pump available for another source of water, an hc independent 3 source. > [( MR. CARROLL: And is that' fire pump protected I 4 5' against external events? 6 MR. HOWARD: It is not. I
; And throughout the SEP SALP, we have not adopted- l
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a the standard regulatory response to those safety related 9 designs. To do so would have significant increase costs, 4 i 10 at least from a back of the onvelope perspective, we did a 11 not see the merit of those. It also has extended the l 12 schedule. 1 () 13 DR. KERR: In the course of your PRA, are you () 14 going to work at the possibility that one might reduce l 15 risk if one could intor connect to diosols? l i 16 MR. HOWARD: We could. We would have the capability l [ L ! 17 perhaps, but it would be an interesting question. [ l Is DR. KERR: You say you will have the capability l J 19 to do that. l f 20 MR. !!OWARD: The models will be able to do that and ' ' 21 we have some swing bucklos in the plant at the 480 volt lovel , l ! I i 22 Wo do not have the ability to intor connect at the 4150 volt , 23 level without finding a* modification for it. f f I i 24 DR. KERR It syoms to me that it would be intorost-25 ing to look at that. I O' : t ! Heritoge Reporting Corporation i=> ; l
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1 MR. HOWARD: That's a good idea. I think it would : 2 be. 3 By way of'the status of these.two modifications,
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4 the f',re water inter. connections to the residual heat removal ;
.5 system has been' completed and is operational. We have ,
6 decided to proceed with the physical work on the direct 7 flow system and the physical work will complete the flow a s> at that time. I
- 9 Currently, we do not plan' to maka that system, f
i 10 the' direct flow system operational until NRC reviews the ( 1 11 progress that has been completed. l l 12 The second area I mentioned is anticipated - r () 13 transients without SCRAM. I 14 MR. CARP.CLL : You skipped over the nitrogen supply.
- 15 I was interest in--
16 MR. HOWARD: I'm sorry. We have extended the ; 1 I 17 amount of nitrogen that is short on site. This provides i I i 18 longer nitrogen source to power the target block safety ( i 19 release Valve and it also supplies the nitrogon in the event f ',
- t 20 wo nood to make up to the containment in order to maintain l
[ 21 the inerted atnosphere. j i l 22 It is not as important in this application as it 23 is in a later one. l 4 24 The most important action we havo taken roiativo i l () 25 the the anticipated transient without SCRAM are the ATWS l Heritoge Reporting Corporofion l l mm ;
106 9 i events is the rigorous implementation of new emergency 2 operating procedures using Revision 4 of the Boiling Water O-3 Reactor Owners Group Emergency Procedures Guidelines. These 4 latest guidelines are technically superior to earlier revision s 8 and are particularly robust in their ATWS mitigation strategy. 6 Boston Edison is one of the first utilities to I 7 implement state of the art emergency operating procedures using f
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8 the new guidelines which are currently under review at the 9 1 NRC. t j 10 Emergency operating procedures provide symptom f Il oriented strategies that direct the optimum use of available , 1 12 condition and to r plant equipment to achieve a safe stable i
-O =1at=1=e the eveat coa eeue=ce -
- O i4 They ere tru1y streteele in their eutdence end :
15 are developed so as to be independent of any specific event l u
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16 sequence or set of accidental assumptions. j i 17 Our new EL" are developed in ~ a flow chart for:nct j 18 which is supported by a narrative type datellite procedurou. I 19 We find this combination to be significantly more offective 1 l 20 than our earlier ELTs which were developed completely in a ; 1 ; j 21 narrative procedure format. ! j I 22 These'EOPs were developed as a multi disciplinary 23 activity involving operations engineering. The developer f 24 Dmrgency Procedures Guidelinos, Boston Edison sent their 25 Engineering Department, their Operations Department and our r Heritoge Reporting Corporation ! I mm. ! 3
F' , c'( ii ; 107 1 Nuclear Planning Department. We also utilized EOP expertise r 2- 'from General Electric and independent human factors'precedento, O 3 feed back from our risk analysis Panel at both at Picador.and 4 Derek and Dolion and resulted--in State of the Art plant 5 specific deterministic ACWS analyses performed by General 6 Electric. 7 Both EOPs allegation and operating crew training g activities utilized in the new Pilgrim Specific Simulator
, with particular emphasis on a diverse range of possible 10 sequences.
11 EOP training was implemented for our operating 12 crews with proficiency in the applied use of EOPs as the goal. 13 The EOP training program was implemented as an U 34 integrated program by planning and operations which included 15 both classroom training and extensive hands on simulator
- 3. training combined with training and discipline and control 17 room communication practices.
lg At the end of training for each ct;w, each crew as i, examined for proficiency in the use of the ops by a combined 20 team of Training Department Instructors and Operating Depart-21 ment Managers. This was done by observing the crews using 22 the ops on the simulator in response to event scenarios O 23 which they h'ad not experience. 24 The advisory ops and the proficiency of our 25 control and operating crews were used and this is undoubtedly Heritoge Reporting Corporation
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in , l 108 i i i the most important end resul'; of the SEP. 2 The benefits of the new EOPs extend beyond ATS O 3 events and provide P11 grim operating crews with the guidance { JO 4 heeeed eo effective use 11 avei1ab1e 91 ent eauigment in 5 response to any conceivable challenge. 6 Unfortunate 1y the benefits are most difficult to i 7 quantify in risk assessment analyses given the current state [ s of the art and the human action modeling.- ,
, Selective plant modifications--
10 DR. KERR: I'm sorry, you said something was the gg most difficult to quantify, what-- 12 MR. HOWARD: Quantify the benefits of our new EOPs. r g3 Se1ective plant modifications were also included ll 14 h the SEP to reduce ATW cha11enges and to facilitate the 15 expected operator use of the now EOPs with modifications : i 16 including the use of enriched born and the stand by liquid ; L 37 control system which was an action that completed our ; 18 implementation at Pilgrim with al1 requirements of the NRC and j i g, the ATWS rules. By the way, this could have boon implemented l l 20 in a different way before the SEP looked at this. Wo had ; r 21 intended to use the existing boron concentration and modify [ 22 the plant to permit the simultaneous operation of the two i O 23 pumps in a stand by liquid contro1 system. [ r 24 Dut after out work, we realized that onriched I O 25 Doron and the ability to have redundant pumps had a benefit. t Heritoge Reporting Corporation I
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, [ Secondly,' we made modifications to thn automatic 2 depressurization system logic which included a manually actu-O' 3 ated EDS inhibit switc), '
a change which originated in
.,. 4 the TMI action plan.
5 Third, we installed an automatic' feed water pump 6 trip which reduces reactor power after.ATW events which occur 7 in combination with mainstream isolation valve closure events ; a And forth, we installed an additional back up, f ( 9 ATWS Trip in the reactor recirculation punps.which further in- f 10 crease the reliability of'this function. l i 11 CR. KERR: hhat were you going to say about the TPAC G j 12 analysis?
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15 Electric using their latest state of the art, a deterministic 16 ATWS code which is called TRAC G. i 17 It is the TRAC thermo hydraulic code modified-is to include a neutronic--a coupling neutronic code with it. l 1, Those analysos havo boon dono previously and only i 20 ono caso that I am awaro of under an EPRI project and in ! I 21 Pilgrim wo did a number of those analyses. l 22 The purpose of them was to datormine whether the 23 operator errors from implementiag EOPs was significant with ! 24 regard to success paths. [ 25 The code was used to ovaluate and observo low l h
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e i < g probability, atlas sequences'in which we were looking at the 2 effective operator. errors. 3 Those analyses confirmed that the strategies in those ! O- 4 1ow Eeae ere very robuee end eher cen ee1eraee sien1ficene 3 operator deviation from the guidelines and still have success 6 coping with Atlas. 7 DR. KERR: In usos, does your simulator simulato 8 that operation power that is expected to occur when one is 9 operating at slow power, natural circulation that would be i 10 the case in an Atlas? i 11 MR. HOWARD: The simulator responses that we-ob-
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l 12 tained have been from a core modeling responsive to--consistent i 13 with the overall analyses of Atlas response. We are still O i4 1ooxiee et evecietce or eue t#eeeditier eevece or te e=d 1-- 15 DR. KERR: I don't know that you need specific i i 16 response. I was just curious. 17 MR. IlOWARD: Wo soo significant--the dynamics of the 1 la ATWS transient. on the simulators is a significant ossilatory l I l 1, behavior in mahy plant parameters which is expected in an Atlas. 1 20 DR. KERR In the cowol that would achicro and does 21 reach its quasi stable situation, the onorgy is being transferre d ! 22 to the pressuro coolant? j O 23 MR. !!OWARD: That's right. ) And there is some combination of water 24 DR. KERR: l i 23 and steam, I guess. Did you look at the affect of wash out Horitogo Reporting Corporation
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Nj h 9 I m-y ' of)the Boron as the accident proceeds or as time goes on?
'4; 2 *MR. !!OWARD: The'EPG doesn't precede the guide- 7 i
3 ilines, they have ' considered ' that and' they set the acceptable ; boron concenthtion levels on the basis of larger volumes i 4 3 -; 5 in our inter active pressure losses, so the systems are J 6 . designed that when the boron injection is complete, that then
,; .m 7 you have such high levels of boron, that warh out affectsi,,' I,1 no; '
a other problems. , Y 9 We did not see--we do not see in the analyses ', l 1 10 'any washout effects in the dynamics of the transient. [' { gg it woald be only after the event were over and you were bach l i 12 moving to normal water levels and the potential of a difreren t. l i i I
- j. 13 kinds of sequences, then it would be a co.isideration.
g4 MR. !!OWARD : The guidelines parth clarly not very 15 high levels with consideration of potential for dilution of-- 3 l 16 DR. KERR What do you mean that you don't see any I
- 17 transiento? Do you mean computer models? j gg MR. !!OWKRD : The computer model, we don't see [
3, washout in the computer modeling, t 20 DR. KERR: That's not a very strong indic6 tion i I L r 23 it wouldn't occur, I don't think--I was just curious as to.- 4 l at least you thought about it, j 22
- O MR. CARROLL
- What do you two mean when you say, i
1 23 , j 24 "W' shout"? ! !' MR. !!OWARD: Well, as the water goes out of the f
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1 vessel-- 2 MR. CARROLL , Yes.
.(
~
. ? ,
3 MR. !!OWARD : --it carries it'along with it, the i O- 4 boron.
~
As you, add new water, it don't have.the same boron l 5 concentration, it has a lower concentration. ! i 6 MR. CARROLL: So you're' talking about physical and :
, ~i 7 volatility carry over in the boron?
i 8 MR. HOWARD: Right. 9 MR. CARROLL: All right. l L
. 10 MR. IlOWARD : Ther are two possible phenomena, I
v 11 When you're in the event, it's sbeaming off the vessel to l 12 remove energy through'the safety release vale into the ; f There is not boron in the air and that is, (]) 13 supression pool. () 14 in fact, largely a steam flow system. 15 The major concern is there are large systems 16 capable of injecting water from the supression pool which t 17 wan not borated. Later in the event, as the vessel de- i 18 pressurizes and you have these very large ECCS systems, , 19 their procedures do direct the actions to control that. l r 20 In the simulator, we have, in particular, trained 21 operators on some of those very degraded cases where there l l 22 is depressurization and watched and trained them in the f C.%- t 23 control of systems, but the boron levels are sent, hopefully, - 24 to some of those systems. : ' L 25 MR. CARROLL: Baching up again to the training of (]) i I Herttoge Iteporting Corporotion !
- n. ,
'f t
o 113 ^
- , c . ,
g your operators.- 'I!wouldilike the-. staff to comment either ! c , 2 now or this afternoon on their evaluation of the efficacy r o 3 of that training'.- O . MR<nO a , we heve had e euu insgecelen hy the 3 staff at our training., There is a documented report I am f 1 I 6 sure No can make available to you. From my presence at the 7 exit, we were recognized as having implemented many innovated [ g features in the training, particularly the concept of
, training the crew in a disciplined way. The addition--the t i
, 10 incorporation of communications practicon in the training l gg and the approach we took to examining the results of that 12 training, the proficiency exam concept that we used, I think, if I remember, were noted strengths. Q 13 O i4 s"' ee eattv *e a ve n a rutt i== recti = or ! r 15 that program by INPO into an area of part',cular concern to i 16 them, of course and again, we did well. 37 MR. BIRD: I was at the exit briefing for the NRC 18 inspection and the team leader for the URC staff said at the i g, exit briefing that it was the best training program that he ! I 20 had ever seen. I 23 MR. COLLINS: The third area that we had focused f 1 ! t i j 22 on, as I mentioned, is containment performance. [ l
- 13 The most important action relative to containment ,
i t h 24 performance we have taken in the SEP is the redesign of the . 1 25 containment drywell sprays combined with the fire water l i Heritoge Reporting Corporation [ j = m -.
114 inner connection into the residual heat removal system which 73 2 has permitted optimization of the containment spray function (_) t considering potential challenges to containment.
.; The capability of the spray containment, using the r
sI Rl!R pumps was provided as part of the original design, o 6 however, the spray function wac not required to satisfy NRC 7 re901ations and was not considered under design basis accident s evoluations. 9 The R!!R pumps provided very high dry wall spray 30 flow rates which required that operators establish procedural 13 limitations of the use of dry wall sprays to avoid excessively 12 rapid containment depressuri?ation. 13 During emergency drills, I have observed several ({ k 14 times a containment spray capability was unavailable 15 because of the procedural restrictions when, at the same 16 time, the spray function would have been very beneficial 17 considering the conditions of the scenario that we were is exercising. gg I resolved to change that situation as part of our 20 SEP action and this has been accomplished by reducing the ! 21 number of individual dry wall spray nozzles to 1/7th of i 22 those in the original design. We can show you how simple 4 23 that change turned out to be once we figured it out. 24 bl The dry wall spray system, there are two separate l () 23 l l systenr. There are two headers in the dry well. There are l Heritogo Reporting Corporation
, m us.s.s f
i 115 g a 104 of these nozzle assemblics on each header and before 2 the original plant design, each of these 7 jet nozzles on tha t 3 assembly was opened and was a spray nozzle and we basically 4 left one in place and capped the other six and that is the ,
$ configuration that it is now in.
6 We did not alter the suppression pool spray system, 7 that was not a problem. 8 This reduced rather the cpray flow rate as 9 essentially eliminting previous concerns about sudden con-jo tainment depressurization, permits a significanly wider gg range for operator use of containment sprays under accident 12 conditions, which is particularly important when you look "t " id "'" t'"' 9 ' r "* * "1 5 " '""1" * ** "t" ""* "* O >> O n ecteettv erovide t'e ceve'111tv to ="e t'e etre weter 1"aer 15 connection to the RIIR system as an AC independent source of 16 water for the containment spray function. 37 The redesigned system provides an ample supply of is water to the dry wall sprays to control containment pressure 19 and temperature, to cool core debris and to prevent contain-20 ment liner melt through under postulated severe accident 33 conditions.
;; Other SEP actions relative to containment perfor-O 33 I mance include the direct toras vent system, provides an 1
24 improved capability for toras venting to prevent containment over pressure utilizing the strategies that already exist in
] 25 1
1 Heritage Reporting Corporation g (= m 1 1
116 1 the DWR emergency procedure guidelines.
~~ 2 The second area was increase the on site storage
- k. 3 of hydrogen, long term maintenance of the nitrogen inerted 4 atmosphere which is the basis for control of hydrogen in 5 the Mark I containment design.
6 These actions will be completed prior to restart 7 with the possible exception of the direct toras standards 8 as I indicated earlier. 9 We have also certified experimental tests relative to to the effectiveness of water in protecting against contain-Il ment liner melt through under severe accident conditions. 12 This has been a concern expressed in the NRC studies, IDCOR (} 13 studies. The contractor to that did not see this as a con-( 14 cern. 15 These tests have provided us with additional 16 confidence in the strategies we have adopted to imprcve con-17 tainment performance. The electric Power Research Institute is has now provided additional funding for testing. The detailed 19 analysis of all test results, and for preparation of a 20 report documenting these results. 21 Doctor llenry, through his IDCOR involvement has i 22 ! long recommended the merits of performing such tests to l 23 p reduce the perceived uncertainty associated with Mark I o 24 , containment performance. II The test results we find already have favorably (]) 25 l I I Heritage Reporting Corporation imw. = [
% 117 r
J. g affected perspectives on Mark I issues in'the research !
' community and I anticipate will lead to a technical concensus
() 2 3 once the ongoing test program is completed and the test
- () 4_ results are made available for peer review.
3 DR. KERR These test results will be generally. r 6 available or.are they going to be proprietary? 7 MR.-HOWARD: We will'make them available through the ; e, , a EPRI Report. I i
, DR. KERR Okay. This, you said, was a test to i(
go determine whether the addition of water would have a beneficial I gg effect or a significant beneficial effect? 1 MR. IlONARD : Yes. Would be beneficial and what our ; 12 \
- 33 studies say is it would end--with water spray, you won't have ,
I
- g4 a liner melt through'. If you have an interest, we just l i
) is happen to have Dr. !!onry, the expert on that available, j i 1 ) 16 DR. KERR I will look forward to the report.with ,,) g7 a great deal of interest. 1 MR. !!OWARD : And in summary, the key features of 4 33 ( t g, the Boston Edison Safety Enhancement Program can be i i 3 i
- a summarized as fol37ws
- The Pilgrim Safety Enhancement l 21 Program addresses the complex sovere accident issues, both
- 22 from preveat and mitigation standpoints.
I( Broad technical expertise is being employed to ! l 23 l 1 24 resolve technical issues. [ i () 25 Improvements are the result fo the most comprehen- [ l , Heritoge Reporting Corporation c j i nan .= == ! 4 i
118 i sive safety analysis since the issuance of the operating
,_ 2 license.
() 3 Improvements are investments in safety, enhancing C'i (> $ the existing plant design and operational capabilities. 5 The most important result is a proficiency of 6 Pilgrims simulator trained operating crews in the use 7 of the state of the art omorgency operating procedures to 8 effectively apply the Pilgrim capabilities including th2 9 new SEP modifications to both prevent and control accidents, 10 And lastly, oru programs are not done and we 11 expect continuing benefits and additional applications 12 that will build upon our current state of knowledge. (} 13 DR. KERR: That concludes your presentation? () 14 MR. !!OWARD: Yes. Any questions? 15 MR. WYLIE: This doesn't pertain to the Safety 16 Enhancement Program that you covered, but I failed to ask 17 this questi sn earlier of Mr. Varley, but maybe you can answer 18 it. 19 Could you address any problems that you experienced 20 with lightening strikes on this plant? 21 ; MR. IlOWARD : I'm trying to think back. We had 22 originally--there had been some experience with lightening 23 I strikes affecting filers at the base of the main stach, if 24 I believe was one minor item early in history. That was one h ll type of incident the industry had had and I believe we had one () 25 c [ Heritage Reporting Corporation j mo m.m
119 1 occurrence. 2 We have had, early in the operating history of
~'
3 this plant some loss cf off site power events that wero /\ U 4 initiated by lightening and we had modified the transmission 5 and we have not experienced those events recently. 6 Other than that, I am not aware of any problems 7 with lightening. 8 MR. WYLIE: Nothing inside'the plant? 9 MR. 1:OWARD: No. 10 MR. WYLIE: Controls, instrumentation-- 11 MR. IlOWARD : No. 12 MR. WYLIE: Safety systems? 13 MR. HOWARD: None that I am aware of, y MR. WYLIE: Okay. Thank you, is MR. CARROLL: I guess I asked earlier for some 16 commentary on the November 21st loss of power event where 17 you were without power for some 21 hours, gg I guess you're telling me your answer is that you gg are not going to have that again because you put in the 20 additional dicsol or-- 21 MR. HOWARD: Well, we-did not lose that AC power in 22 that event, of course, which is what the third diesel is 23 l geared to do. We have had loss of off site power events, a b 24 , higher frequency of them at Pilgrim than above industry average ,
- s characterized by the proximity of this site to the coastal
[] J Heritage Reporting Corporation c=an l
1 120 i environment and the prevailing northeast storm wind directions , 2 that we have.. Our transmission system sits in the forefront i 3 on an RT' scale._ O 4 1 den e know that we won.e heve 1oss of off stee j 4 s power events. We have taken actions and have been continuing f 6 to sock to understand those ovents.and tako actions, t 7 During this outage, we have modified the insula-t a tors in our switch yard to further strentJthen their tolerance ; 9 to salt contamination. We had done th'at prior to the last-- to that November event and wo did not get any--we think that 10 f 1 11 worked because we.did not get any flash overs in the switch ; i I 12 yard, but we lost the off site supply.due to storm effects i l 13 further out on the system from the site. 1 O i4 oae or the erobte=e we hea ia nove= der, we were I is having to interpret what occurred in the transmission system ' } ! j 16 using records from remote stations. We did not have in the ! , 17 Pilgrim switch yard ol. orating equipment that really would help i i i < 18 us from a diagnostic poict of view, so we have upgraded that 19 equipment to be more useful !n future diagnostic evaluations. l 4 ! 20 The other action, we had taken as a result of that t { \ I 21 event, which was not; a part of the Safety Enhancement Prgoram f
- 22 but while there are not safety issues in our design associated ,
!- i a
! 23 with of instrument air supplies, it was a nuisance in the event to have lost instrument air so we have a back up instru- I I 24 i
25 ment air system that is on site now, available to tie in if 4 Heritoge Reporting Corporation
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121 1 if we need it. 2 Some of the things that occurred in the event (_s) 3 were aggravated by the plant han been in a long outage and (^T k> 4 a lot of equipment was out under maintenance request a d 5 doing its routine maintenance activities so that they 6 aggravated the plant conditions during the event. 7 MR. BIRD: The weather conditions were particularly 8 bad and we deliberately chose to not go out at the switch 9 yard and try to anything until after daybreak, but we did 10 not lose all AC power. We proceeded very slowly. Il MR. HOWARD: The other thing is affecting the 12 conservative approach and our response. Of course we had O tg 13 almost 18 months of decay heat on the core. We have been shut down ( l4 for almost 18 months and therefore it's very low level decay is heat. We didn't need any heat removal equipment because 16 it was just sitting in the system and you could hardly see 17 a response in just the volume of water, so clearly we did not is have a concern with regard to protecting the core from a heat 19 removal capability. 20 MR. CARROLL: Are you saying that if there had 21 ,been substantial decay heat or whatever, you could have l 22 recovered from that event? 23 MR. HOWARD: We did not lose AC power and even 24 the decay heat issue was relative to what if you lose some of () 25 h your existing AC supplies and that wasn't a dominant concern. I i , [ Heritage Reporting Corporation j mm.
122
- WE have had extremely reliable performance of our
,- 2 two emergencies, diesel generators. So, without talking about iJ 3 whether the loss of off site power, the normal response where ^
() (_/ 4 we get normally both diesels and now a third one would be 5 a problem. We're talking having to not have more failures 6 beyond that to be of concern, obviously. 7 I don't know how to answer the question other than 8 to try and put some perspective on if there were other 9 failures, it would have been necessary, in order to be a 10 threat to the core even if we didn't have 18 months decay time. 11 We are very sensitive to the importance of having AC power, 12 obviously, is why we're doing some of the things we are, but
~
13 also sensitive to the assuring a long capability on DC alone. (d' ) 14 We have a long time when this plant can run on DC 15 power alone for recovery of any failures. 16 MR. CARROLL: I guess there was 6ne other thing. l7 I was curious about the routing of the 23 kv start up power. 18 MR. HOWARD: Yes. 19 MR. CARROLL: That is not on the same trasnmission 20 right of way as the 345 line? l 21 ' MR. HOWARD: No, In some cases it passes under 22 and wherever that is, the 23 kv line is buried. The 23 kv , O 23 line is generally accepted right of way, but it does cross 24 under the main one if you go down to Rocky Hill Road and where () 25 it does, it is undergrounded for protection. l
' Heriloge Reporting Coiporation
123! 1 g MR. CARROLL: Is that as vulnerable to storms 2 as the other or the main transmission line? n k_) 3 MR. !!OWARD . No, it does not seem to be. It is l'h (_) 4 potentially the same vulnerability because if we lose the 5 main transmission grid, then it can cascado down. In many 6 cases, when we have the 34,0 wind, we have lost the 345 kV 7 supply to the station, but we have had the 23 kv available, g It is supplied from a 115 kv station a few miles from the 9 station and eventually interconnects back into the 345 kv in grid, but most of our experience we have had the 23 kv gg available even if we did not have 345. 12 MR. CARROLL: Thank you. () 13 MR. !!OWARD: And that is factored into our modeling . (} g4 DR. KERR In your choice of containment, did you 15 also do a PRA on that or is that part of your decision making 16 process? g7 MR. !!OWARD: We used the IPE results to look at 18 compare the benefits, compare situations within and without 19 venting, and presented those results to NRC at a meeting at l 20 the site last May. 21 There is information in the NRC record on that. 22 , DR. KERR: But you did do an analysis? O- ! el 23 l MR. HOWARD: Yes. , d 24 l! DR. IlOWARD : At least it was a part of the il 25 fdecisionmakingprocess?
)
f Heritage Reporting Corporation m u.- [
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. 124 i
i MR. HOWARD: There.wasn't--- The analysis s 2 came after the decision making process. Venting as a.strateJy l O 3 as I indicated, has been a part of the Emergency Procedures 4 Guidelines as approved by the NRC almost at the beginning, , t s I think, since the first revision. 1 6 DR. KERR: It does not always make me comfortable { 7 to hear NRC approval of something. That's not meant to be a { tu s criticism because occasionally they don't do PRAs either. 9 MR. !!OWARD: That's exactly the reason,Dr. Hurly j 3 10 was also uneasy about that, and it has been very carefully J ll examined in their current ongoing review of Revision 4 oven 12 though it was in earlier because of Dr. Murley's hensitivity {Q 13 to that and that?is'one reason we had the meeting with him,
- O i4 was sho ing their agecific resu1ts since you cen t ree11y de
15 those evaluations on a generic basis very well. i r 16 But we did and they basically--the benefits of l 4 17 it, the venting strategy in the EOPs, the principal benefit-- [ 18 it has two benefits, but the major one is it avoids core damage 1 19 accident. It takes TM' sequences, transients associated with ! 1 1 j 20 failure, loss of bontainment heat removal' capability which , I i j 23 in most risk studies, those events cause over pressurization i [ l 22 of the containment, containment failure and then the contain- i i O 23 ment failure, in turn, causes the loss of emergency core cool- I i l 24 ing systems that had been operating up to that time and then : 25 that progresses into other scenarios. The venting terminates l Heritoge Reporting Corporation 2 o. inn am .
125 g that. 2 DR. KERR: But now if you make the loss of k/ 3 contained heat removal capability less, as I assume you (" (_)n 4 do because'you referred to the-diesel. Does that have any 3 influence on--are they in conflict onevith the other? I 6 i have no reason to think that they are. I just-- 7 !!R . !!ONARD: I don't know--they're not in conflict , 8 that is right, but you're right, there is interaction-- 9 from a benefits point of view, some of the modifications 10 that we have made are sort of belts and suspenders. One 33 might give you 90 percent of it or 80 percent of a benefit 12 and you do two and individually, each would give you 80, but together they don't give you as much. (]) 13 f'l 34 What does do, however, it gives the operator more ,
\_/
15 response capability and a lot of times, in our program, wo 16 have given the operator more capability and there may not, 17 in a quantification, some of that is redundant in its 18 quantified benefits. 19 TW sequences were the second largest contributor 20 in the IDCOR studies of the reference Mark I plant and there 21 l were significant contributors in Pilgrim if you don't vent, f- 22 they really do have a--venting has a beneficial influence on (' l core damage frequency even with a third diesel. 23 j i The reason for that is, what you're scoing is
- 24 l I
25 the diesel gives you the power for equipment, but then you're a Heritage Reporting Corporation
126 i still limited from availability of the nechanical components 2 and in most containment heat removal systems you have trains O of equipment getting from your ultimate heat sink through 3 A C) 4 some, in our case, an intermediate cooling loop, the reactor 5 building cools cooling water system and eventually into a 6 residual heat removing system. 7 The combination of our fire water system to provide g make up to the core the ability to vent to the target rocks
, to get the core decay heat into the pool, the ability to 10 vent the pool gives us a capability to cope with loses gg anywhere in that heat removal train, whether it's the salt 12 service water system or the residual heat removal system 13 or in the AC power system that supplies those systems, so 34 it really does provide quite an independent capability 15 to the operator, but again, given that the risks were 16 already low, they may still just be low.
37 DR. KERR: Any more questions. gg MR. CARROLL: I guess I have one more question, 19 but I don't know if Ed is the right one to answer this. 20 DR. KERR: Go ahead and ask the question. 21 MR. CARROLL: All right. One of the things I 22 j always Look at in the performance of a power plant and the
\
23 l management is the industrial safety record. What has been 24 j the experience in the last couple of years at Pilgrim 4
, 25 in that area? I guess I relate to using the INPO performance f Heritage Reporting Corporation 3
127 i indicator. 2 MR. IIOWAhD: You're right, I don't have the answer. R' 3 MR. BIRD: I'll answer it and hopefully someone in
/ \s) 4 my organization will correct me if I'm wrong, i
5 DR. KERR: Would it make sense to collect the 6 information report it just after lunch? 7 MR. BIRD: Uc keep track of our performanco in-8 dicators and my recollection is that we set our objective 9 for the year and what the standard is and we're below it. 10 MR. CARROLL: And that has improved with time? 11 What was it 5 years ago or 3 years ago? 12 MR. BIRD: I don't know. I can get that for you () s 13 over lunch, th 14 This complates our presentation for Boston Edison. IS Do you want to break at this timo? 16 DR. KERR: Yes, I think this will be a good time 17 for a lunch break. 18 (Whereupon at 11:59 a.m., the subcommitted 19 recessed for lunch.) 20 l 21 l : 22 C_ ! 23 il 9 F 25 l Heritage Reporting Corporation q y m ma
128 1 AFTERNOON SESSION 2 (1:10 p.m.) ( ! 3 DR. KERR: We'll continue the mooting with a p () 4 further presentation by the Nuclear Regulatory Commission. 5 Mr. Colline. 6 MR. COLLINS: Good aftornoon, my name is Sam 7 Collins. I am the Deputy Director of Division of Reactor a Projects. 9 There are agendas in the back of the room as part o:f 10 the handout. I am on Page 3 of the agenda. It is Item No. gg 4, NRC Staff Presentations. 12 The slides I will use this afternoon are also 13 available as a handout at the back of the room. I will be ( ) 34 referring to the slido numbers as I progress th rough the l l Is presentation. 1 16 Slido Number 1 is the staff portion of the agenda l 17 to be presented this afternoon. It is Section IV. I will is briefly overview the slides during the course of the presenta - 19 , tion and stop where the ACRS committee has questions. 20 Slide 2 is a cover shoot of the Milestone Chart 21 l which is actually Slide 3 of the handout. This Milestone Chart is a tool that is used by the staff to provide for a 22 il j l tracking, planning and documentation of NRC activities in 23 2g conjunction with the assessmunt of the restart of the Pilgrim h 25 Station.
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129 I I I'll put what I can of the slide up. It is 2 availabic as a handout. The significant milestones which O 3 I warrant some discussion during my presentation are acknowledg e-i) k' 4 l ment of where we are to dato and that is that the ACRS 5 subscommittee presentation here on the slide. Significant 6 activities which led up to that presentation, which is here 7 on the slide. 8 Significant activities which led up to that presen-i 9 tation includes a series of SALP assessments, the confirmatory 10 action idtter, following the plant shutdown, the supplement 11 to the confirmatory action letter on August of 1986, a series 12 of public meetins in conjunction with Boston Edison's
) 11 response to that confirmatory action letter which includes
() 14 submittal of a restart assessment plan, the power assension 15 plan and the SALP assessment readiness for restart report. 16 We have had a briefing of the commission which 17 took place in June of 1988 by both the NRC staff and Doston 18 ! Edison. The staff has accepted the restart readiness report. l 19 i The staff is still reviewing the power assension program, , i 20 We did have an ACRS briefing in July of 1988 The IATI, 21 the Integrated Assessment Team Inspection has been performed . 22 d The exit was Wednesday of this week. The SALP management i 23 meeting on 8-25 was performed and that brings us to date. ll 24 ;j Activities in the future include the full ACRS 0 committee meeting now scheduled for September 7th. The (} 25 ; O Herttoge Reporting Corporation , me u. a
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130 g issuance of the IATI Report--
<s 2 DR. KERR: Mr. Collins.
( )
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3 MR. COLLINS: Yes, sir. (_/ 4 DR. KERR: I th ink that should be September 8th. 5 MR. COLLINS: The 8th, which is Thursday. 6 DR. KERR: Which is Thursday. 7 MR. COLLINS: Thank you. I'll change that on the a update of the milestone chart. 9 The IATI report issue is out of sequence on this 30 document. It is expected to be issued prior to the ACRS gi full committee meeting. 12 The next sequence of milestones-indicate what is now currently envisioned to be the steps necessary to issue (") 13 v,_) k_ 14 the restart readiness report which include resolution of 15 . any outstanding safety enhancement program issues, Emorgency i 16 Operating procedure Issues which we're prepared to discuss 17 later on in the presentation, suplements to the response to is the 2.206 petitions. There were 2 petitions which have been i, submitted. A series of public meetings, including the public 20 meeting on the results of the Integrated Assessment Team In-21 l spection, a public meeting concerning the 2.206 petition sub-l. 22 mittals and a public meeting to discuss the Region Administra -
]
(1) h tors decision on the restart of the plant in conjunction 23 hI, with the Restart Peadiness Asse<- .c nt Rep ort, 24 h
~m t O r te o f a
() 25 i s All of this leads v Heritage Repc , [u tam h hm
131 1 Commission briefing projected for mid October. Emergency 2 Preparedness is certainly a consideration. You notice in the 7 (~ 3 bottom loft hand of the chart, Emergency Preparedness Issues
/^N O 4 are scheduled to be addressed prior to the Commission 5 meeting.
6 Are there any questions on the Milestone Chart? 7 MR. CARROLL: If and when restart is permitted, 8 it is your intention to do another SALP in 6 months or so? 9 MR. COLLINS: Yes, sir. We are committed to a shor t to cyclo SALP following restart of the plant, along with a 11 fairly extensive power assension program which I'll detail 12 later on in the presentation. {) 13 MR. COLLINS: I'm now on Slide 4 Slide 4 details 14 some of the assessment activities--one of the assessment 15 activities that the staff is performing in conjunction with 16 the review of the restart activities. There is a memorandum which was issued in July of 17 l l 18 1987, the memorandum was from the Director of Division of 19 Peactor Projects in Region 1 to the Regional Administrator 20 and it detailed the fast approach to the review of the restar t 21 activities at Pilgrim. 4 22 , I'll get into all of those approachos in a moment, h 23 L but one of them is the formation of the Restart Assessment i h 24 f Panel. The Restart Assessment Panel, its charter is to 1" coa-O :$
! c orai" te "a ei " the exec"ti a r "ac =ctivitie !
I a [p Heritage Reporting Corporation
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132 I junction with the assessment of Program Restart. It's 2 membership includes myself, Mr. Bruce Boger 5.ho was introduced U 3 this morning, Associate Director of Region 1, Reactors and 4 NRR is co-chairman. The Chief of the Radiological s Projects Branch, Jim Wiggins; Project Driector, Dick Wessman 6 who is here today; Licensing Project Manager, Dan Mc Donald, 7 who is here today; the Chief of the Engineering Branch; the 8 l Chief of.the Radiological Protection Branch, who is Ron 9 Bellamy. 10 Those individuals come from diverse backgrounds j it with diverse responsibilites. Some from headquarters, some 12 (rom region. The panel meets every other week and every 13 second meeting is conducted on site, la This panel is also being assigned to the Peach l$ Dottom atomic power station to coordinate the activities 16 in conjunction with the Peach Bottom restart. It's focus is 17 on integrated NRC attention. It insures a high level of la NRC involvement, the ability to commit resources and to l9 Commit to Schedules and to meet milestones, and in my mind, 20 it has been very effective to achieve that purpose. 21 Slide 5 depicts augmented inspection and review 22 li activities which is another commitment out of the July a 23 . 1987 letter. 24 h The management of activities include a unique I
- s plan for managing the NRC activities. We acknowledge that l!
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133
- we must complete the reviews to provide for an independent 2 judgment of the plants readiness for operation and it must C
3 provide focuse and guidance for the NRC process. 4 Again t.he actions incidde the augmented inspection 3 program. I'll give details of the results of that in a 6 moment. 7 The Pilgrim Restart Assessment .;.ncl which I just a reviewed; a Diagnoctic Team Inspection which was the IATI, 9 Integrated Assessment Team Inspection which has been performe d to and the Assessment Report to the Regional Administration gg which is the Restart Assessment Report I referenced earlier. 12 Those are the actions which were promulgated by the July '87 memorandum, ] g3 It's been 34 It provides for a premeditated process. is approved by the Regional Administrator and it provides for 16 the authority to implement the program. 37 Slide 6 details the results of some of the i is assessment activities which the starff has performed. I g, referenced this slide earlier in the morning presentation 1
- o as an indication of staff effort, f 23 There is a trend of effort in regards to the 22 Pilgrim Station which indicates increasing activities as i O 23 far as reviews are concerned.
{ Aho annual hours depicted on this slide indicate 24 q 0 " ' '"" "#" """"'""*"' ' d ""*' '"""" " " " - '""' ' O j' Heritoge Reporting Corporation
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134 i supervisory time in :or 4 e .: : on with your Restart Assessment 2 Panel, SALP assessa et. -
.3 like.
(m)
' ~ '
3 Inspection Jours in the middle column indicate p) x_ 4 the inspection hours that are contained in the SAIP period. 5 They are annualized on the right hand column. 6 We did assign three resident inspectors in January 7 of 1987 in recognition of the need for assessments at the a site. 9 They have also performed ? team inspections. They to focused on compliance. They were conducted as team efforts it with diverse leadership and diverse background. 12 MR. CARROLL: How many resident inspectors were (}A l3 involved in the proceding period?
'() 34 MR. COLLINS: Two, sir. They were initially, at 15 the onset of the Resident Inspector Program, in the '80's, 16 the Senior Resident was assigned to the site. It was 17 shortly thereafter a second inspector was added.
is There has been some exchange of positions. Clay is ig the third Senior Resident Inspector on the since 1980, however, 20 l the third resident was initiated as a result of this situa-21 tion. 22 MR. CARROLL: Okay. f-23 j Slide 7 indicates an additional effort in regards r^ assessment activities and that is meeting activities in
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conjunction with the inspection program. There have been 28 (]) 25 y j Heritage Repori'ng Corporation o.e .a m J
135 meetings conducted since the last SALP period commenced in
, 2 February of 1987. Then 42 neetings conducted since the April I' )
1986 shutdown. 3 g
'( j The slides that follow, I'll go through them 4
5 quickly because the slides that follow are an indication of 6 the types of meetings. 7 The mootings were used to understand the process a and the progress that DECO is making towards resolution 9 of the issues that were presented in the 86-41 inspection p) report. 11 The meetings are also used in the public form 12 to explain the process and status with public participation ( ,) 13 as well as to provide for feedback to the public or staff (n_) 34 activities. Some of those meetings have been quite spirited 15 I think, as people who have attended can attest to. 16 I'll go dowr. through these quickly. This is a 17 SALP Table that is entained in the 87-99 SALP. It depicts 18 a combination of technical meetings, management meetings, l 19 i site tours, NRC presentations and participation with local l 20 and state officials. There is a high level of interest in 21 . activities by local and state ~of ficials. I I This further indicates a series of meetings to (- 22 y!
% )) I 23 include a Regional Adminstrator's Meeting with Massachusetts i !
24 l State officials. Regional Administrator toured the site. l l l l ([) 25 h There have been a number of commissioners who have also toure d l l l 4 y Heritage Reporting Corporation m m m. g
136 I the site. 2 This is the last slide in this serica. There was a O
!/ 3 field hearing held by Senator Kennedy in the area to discuss p
(_) 4 the Pilgrim Station. There was a meeting to discuss the 5 retart plan. It was a public meeting to provide for public 6 comments. There was also a public meeting in the area to 7 provide for feedback on a Postart Plant, comment and a dispostion. 9 Carry this slide a little bit further, there was an to 8/24 exit from the Integrated Inspection Team Assessment it which was part of the inspection, i t was not a public meeting . 12 Yesterday we did hold the SALP management meeting, That meeting was open public obsetvation and today we (} 13 8/25. () 14 have the ACRS subcommittee meeting. Is In the future, as I mentioned, we have the Inte-li 16 y grated Assessment Team Inspection public meeting. The
)
i 17 response to the 2.206 public meeting. The Restart As,essment l I la Public Meeting, ACRS full committee public meeting, and, of 19 courso, the Conmission Mooting. j 20 !!cre we get into the technical results of the review I 21 activities as well as the assessment results. We refer here l
- 22 i to the cifferent unique initiatives which have taken place 23 j at Pilgrim including the SALP, the Diagnostics Team Inspec-f 24 h tion, this his historical so far, the Confirmatory Action 0
Letter, the Pilgrim Assessment Plan---NRC Pilgrim Assessment (} 25
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d g Heritage Reporting Corporation no ... [
137 i Plan which is the July /87 letter I mentioned earlier. The
<~ 2 Safety Enhancement Plan; the Pilgrim Restart Plan was sub-3 mitted for review and reviewed by the staff. The FEMA Self D
b 4 Initiated Refiew of Emergency Preparedness was submitted to s the 11RC and subsequently submitted to BECo. Pilgrim Power 6 Ascension Program has been submitted to the NRC and is still 7 the subject of"review, DECO /NRC Staff Commission Briefing 8 in June; the DECO request for the Integrated Asseesment Team 9 Inspection which required the staff conclusion as far as the to assessment of the plant's readiness for that inspection. I 11 The ACRS Committee Briefing, preparation for this meeting; 12 the IATI Salp Management Meeting, I guess it yesterday and O 13 todays mooting. 14 There have been a number of review activities is outside of the inspection program which have been conducted l l 16 at the site. 17 We're prepared now to speak to the EOP Rev. 4 la Review Results. There was an inspection performed, the i 19 Inspection Report is Number 88-11. It was performed !! arch 20 14th through 18th, 1988 There were 6 individuals on site l l 21 ! for that inspection and two representatives of the office it of NRR, including the Team Leader. There were 2 Regional i 22 h b l qualified examkners, licensed operator examiners. There was l 21 [ l 24 i one, Patel Northwest Labs, a qualified examiner and there was one research psychologist on that tean. O 25 l Heritoge Reporting Corporation [q =ma l u
138 )
- As a commitment of that inspection, I will let 2 Mr. Blough address the inspection results in a moment, n
3 but as a commitment out of that inspection, we have asked (') C/ 4 BECO to submit the EOPs to Region I to provide for our use 3 during the events at the site. That is in response and 6 l addresses BECOs concern for our awareness of the content of 7 the EOPs. s Mr. Bloughwas the Section Chief at the site and 9 he will address the specific results of that inspection. 10 DR. KERR: Excuse rac. !!ow would you use these gg during an emergency? 32 MR. COLLINS: We would use t as a method of
,] 13 try to understand Boston Edison's recommendations for
() 34 actions in response to the event by using the proceduro is as a reference resource. We would not, ef course, provide 16 , that as NRC activities, to provide direction to the site. 37 MR. BLOUG!!: The NRC looked at the methodology in the development of the EOP, looked at the procedures themselves lal and looked at the training. g, 20 We looked at the Emergency Operating Procedures 21 as well as the Extensive Training Plan. 4 22 As with other inspections, we confirmed it as an ' O 23 9 Integrated Assessment Team Inspection, l f Also we found that the licensee has commitment ! 24 b] to the EOP Refresher Plan. As of now, we concluded 4 hours 23 i a Heritoge Reporting Corporation [ h - o.e m h
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'3 which L were--the issue.of Emergency Operating Proceduree
'4 status,,that is a field procedure'which had support has 5 been slow to come to frttition becm. lac of a effort'on the 6 part of the licensee.
- 7. My team inspection identified one curo relative s to a procedure where there was some feature or procedure.
9 Although it appeared the licensee was doing'the 10 procedure correctly, there was concern that it differed 11 by adding stress in an actual event and.it could lead to gn 12 delays in implementing procedures O 13 The. licensee has been quite responsive to that 14 item and is committed to recheck the valve with the other 15 procedures. 16 MR. COLLINS: At this point in time, it is my 17 understanding that the licensee intends to check the valida-18 tion of thoco procedures in conjunction with the proposed 19 continued training. i 20 Are there any further questions on this slide? 21 In addition to the inspection assessment activities , 22 which have taken place at the site, which included the O 1 23 direct inspection routine effort as well as the assessment 24 activities wnich I detailed in the previous slides, they thet =re oa9ot=9 1" coa $u"ceto" O 28 a ve 11eea >=9 ceivitte t i Heritoge Reporting Corporation i
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p , _ _ f,,, a ', p 140. e < l ph'(1, with the s.hutdown 'and the restart. -
'gj- '2I The_ licensing l activities to date, which are out-
' :!g.hs . , standing include the Resolution:of the 2.206 petition
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L , 3 4 issues; the completion of safety enhancement program reviews 5 and the technical specification-licensing actions. There
.J 6 are three items which remain outstanding for restart.
7 Fire protection Appoxdix A fire wall rating clarifications; 8 degraded grid voltage and organizational changes. 9~ Those are all considerations for Tech Spec changes lo' at'this time. 11 MR. CARROLL: Did you comment on what the issue is 12 on degraded grid voltage? () 13 MR. CARROLL: Yes, sir. I would defer that () 14 question to Mr. Dan Mc Donald, Licensing Project Manager. Is MR. MC DONALD: I am Dan Mc Donald, Project Manager 16 for Pilgrim. The Licensee's verifying analysis that they 17 have done, they identified that they have not taken intc. 18 account the line drops, so they went back into the system ) 1 19 and came back with modification set points and some other , q 20 corrective action related to the degraded grid. l' ! 21 We expect to issue this amendment in about threc 72 wooks. O 23 l MR. CARROLL: And what is the issue with fire
;4 protection, Appendix A, Fire Wall Rating?
() 25 MR. MC DONALD: The licencee- '..cre is an issue of
- Heritoge Reporting Corporation i < => m
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.s I safety eval ation done by.the staff,infl978. The licensee ; R .e. i
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I oelieve the're were 182-that report'will-2 had indicated.
- m. 3 also be out in 2 or 3 weeks.
4 MR. CARROLL: What' is the ' requirement?. -1s a $3.00 '-
- 5 required or--
6 MR. MC DONALD: The eventual evaluation was for 7 $3.00 but when they went back and re-evaluated it, there-8 were other characteristics and it d'dn't require the $3.00 9 Wall, and there is support for the reduction.in the rate. 10 MR. COLLINS: Dan, while you're available, do you 11 want tu detail the organizational change also, since it's 12 tho'last hour. , 13 MR. MC DONALD: The remaininginne'is the Administra -
'O i4 uve S-uen' T-h Sg-e w-e chenee on the oreanizeuena 15 chart and all. The Tech Specs were to be used to go 16 ahead and implement reorganization and they come in with a 17 supplemental amendment to update the administration portions 18 of the toch specs.
19 MR. CARROLL: I guessed that one. 20 MR. MC DONALD: I guessed that one. 21 MR. COLLINS: There have been approximately 20 I 22 licensing actions completed in the past one and a half years , 23 in conjunction with the Pilgrim Station which is a high level 24 of activity. Those major areas addressed typically include l 25 fire protection, containment, safety enhancement, organza- r P Heritoge Reporting Corporation ,
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E -142 it U g tional and administrat'ive changes. The three outstanding j 2 are representative of,thestypes of changes that took place. l ()- .3 I i.: <
"Any further questions'on Slide 12.
l' . l i 4 In conjunction with the. augmented inspection 3 and review activities and the licensing activities, there 6 were also SALP activities conducted in conjunction with the 7 suspension of activities in the plant shutdown. 8 The last two columns in this rather busy slide 9 indicate the results of the last two SALP assessments for 10 the period 11/85 through 1/87 and the period 2/87 through 5/88 . t 11 The 11/85 - '87 SALP was still during the period of 12 time when Boston Edis'on was reorganizing, setting corrective actions in place, getting appropriate staff in place and Q. 13 O i4 aue11frine the 1eeuee thee needed to he eddreeeed.
- 15 The.2/87 to 5/88 SALP is more indicative of the 16 results of those activities. If you will notice across the 17 board, the trends indicate that radiological controls, is that is a 3 - improving. It didn't show up on the slide when 19 it was reproduced and Emergency Preparedness is a 2 - improv-L 20 ing. That is using the current definition as provided in the 21 instructions which measn that at the end of the assessment 22 period, the performance indicated that a continued performanco 23 would result in a change in category during the next assess-
; 24 ment period. We would expect, based on the results at t.he t e=d or 5/88, thoee erosreme c eta he vro9reeei=9 ve11 towerde O >> 1 i
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- 2 The most recent SALP is to be discussed in the next
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3 slide. , s , t
'4 DR. KERR: I note there'h' ave been cases in which 5' the SALP ratin'gs for oneiperiod to;the next have dropped ,
l 6 two points. Has there ever been a case when it increased by. <
~7 two points from one period to the next?
8 MR. COLLINS: Not in conjunction with this) plant, , 9 but there was, in operations, if I recall correctly, Dr. Kerr, , in operations'at Nine Mile Point I, Operations increased from
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10 ; [ 11 a 2 to a 1. It'w'as later indicated that their performance l I-i 12 went to a two in a subsequent SALP. ; 13 UR. KERR: Thank you. 14 MR. COLLINS: They had been shut down for the 15 piping outage. t 16 DR. KERR: Is this sort of an aberration. 17 MR. COLLINS: I'm sorry. l 18 DR. KERR: An increase from 3 to 1, would that be ! l 19 considered an aberration? i M TR. CARPOLL: The most recent SALP average is 2.0. 21 HR. COLLINS: That was brought t6'my attention by
. 22 Mr. Peter Agnes who nay be here, as indicative of what was !
3 23 being read in an "Inside NRC". I think our position, on the I 24 technical staff, is that we tend not to do that. e Q 25 I understand-- Heritage Reporting Corp 9rotion l
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ik4 g MR. CARROLL: Just out of curiosiry, what is the 2 average in Region I' compared to all the plants in-- O 3 MR.' COLLINS: I don't have the information, but 4 IcangetIttoyouat.the'fdllcommitteemeeting',ifyou 5 like'. We would have to como up with that. 6 I guess I caution you that it's a figure of 7 interest but not used by the staff. 8 MR, CARROLL: Intuitively, would you say that 9 this is better than the average plant? 10 MR. COLLINS: I don't think i could really. properly
!! address that. I guess I cna answer that in~part though.
12 I think it is representative of programs in.a 13 elant that has been shut down for that period of time. O i4 where ere reesens why these rerines ceme ue the is way they do, of course. Radiological controls, you notice 16 there are 4 Category 3's. That indicates some fairly deeply ; 17 intrenched problems in that program as well as the inability gg to sustain any type of lasting performance. It would have 39 taken an heroic effort to have that program increased beyond j i 40 a 3 improving although they did do that. That rating is, in ; 21 fact, a 3 improving and the IATI confirmed that the prorjram i 22 continues to improve. [ i O 23 Emergency preparedness, you see the drop from, i
- i 24 which vas the question Dr. Kerr had from 1 to a 3, that was the result of a very extensive and very secret preparedness plan Q 25 i
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4 changes which back them up. MR.' CARROLL:10kay. 5 , i t 4 6 , MR. COLLINS: As I mentioned, this is a detail.' 7 of the last SALP. :The SALP report number is 87-99. I'highliCht s 'it because it was a SALP-that was mandated by the 86-41
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9 inspection report as_a tool to be used by the staff in conjunc-10 tion with restart assessmert activities. It does. cover a 15 11 month period. 12 The SALP board met for two days, you'll note, that' s not typical of SALP. It was a fairly long SALP board, a lot of ! (]) 13 1 () 34 material to discuss, a lot of information. 33 The board report was issued in July and the 16 management meeting, of course, was conducted yesterday. i 17 The issues, in summary, indicate that the personnel 18 and organizational changes continued throughout that period i g, and a functional reporting change in the organization appeared 20 to be working well. 21 Significantly higher staffing allocations were 22 acknowledged at that time. There were aggressive actions in O 23 most program areas of weakness. There was some delay nott 1 in 24 implementation of improvements and I will qualify that. 1 The twc areas which were focused on in regard to () 25 Heritoge Reporting Corporation
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! that statement.are maintenance and health physics. Health; h
2 physics, I detailed previously, had had a history of ' Q, N 3 Category 3 performance which indicates that it needs 4 additional attention both-by the' licensee and the NRC. 5 Substantial changes in that area took place'toward the end 6 of the assessment period as far as' staffing,, management, 7 and programs and we thought at the end of the SALP that 8 although those -initiators warrantied acknowledge, they had i y
- s. 9- not been in place for as long' a periiod of time.' as necessary 10 to provide for the same type of qualification as the other 11 functional areas.
12 Maintenance - the niaintenance program was used 'dur-Q 13 ing the outage., BECO did have intentions to upgrade that 14 program and made a conscious choice not to do that during 15 the outage. We did perform, a maintenance team inspection 16 in the spring of 1988. That maintenance team' inspection 17 confirmed that some changes were warranted and 'BECO 18 implemented those changes following the maintenance team 19 inspection and prior to the integrated assessment team 20 inspection. There offectiveness was assessed during Mr. 21 Blough's team inspection, j 22 The conclusions are that, I think,. support--are i > O. 23 supported by the facts in the SALP. Originally they were ; 24 confirmed by the IATI which we will get into in a moment on ! t 25 a further slide. [ l I Heritoge Reporting Corporation m eau
v (. 147 m Any questions on Slide 14? 2 DR. KERR: I think this question has to do with O 3 Slide 14 because it has to do.with a more detailed report, f~y V 4 so with the-July 27th, '88 report-- 5 MR. COLLINS: .Yes, the board report, correct. 6 D
,.}. KERR Well Page 22, I found the statement--
7 the, comments on"thel Radiation Protection Program, however', 1
, L y.
8 management attention is still required to exceed minimum 9 regulatory requirements in the in ' Plant Radiation' Protection 10 Program. { 11 There are a couple of questions that I have. In 12 the first place,"I don't underst:and what.is meant by 13 "minimum regulatory requirements." It seems to me one has 14 regulatory requirements, period. i 15 In the second place, I don't understand how a 16 regulatory agency can ask a licensoo to exceed regulatory' 17 requirements. One could, perhaps, hpe for this or whatever, 18 but it seems to me that the regulatory requirements do not 19 bring a licensee to an acceptable level of performance. Then 1 i 20 the regulatory requirements ought to be changed rather than . 21 encouraging someone to exceed them. 22 MR. COLLINS: I think the paragraph that you're 4 O 23 referring to has to do--will you poin*, that out to me again, i i 1 24 Dr. Kerr? I 25 DR. KERR: It is under "Summary" on Page 22, about Heritoge Reporting Corporation 4 twinnam
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148 3 the second sentence-there.' s 2 MR ' COLLINS:
. Okay. I t.hink the. intent there, O 3 of course,. realizing that tlie SALP document itself is 4 performance based and within the context of the ratings ,
5 of the categories, the subjective judgment ': hat' is used in
~I SALP is, as I mentioned previously, to focus ma.'agement 6
7 of resources to improving performance. s Category 3 performance, as you acknowledged, is 9 acceptable for operations. It is unde'sirable because-- 10 DR. KERR: It seems'to me that if it is undesirable , 11 from the standpoint of a' regulatory agency, the regulations 12 ought to be changed.
""- c "'"S: " *^er t"-- " 'e 2a*r-O >>
l O i4 There is no reeutetions on meneeemene other than 15 the qualifications of staff. l 16 DR. KERR: I had assumed that this had to do with 17 a radiation protection program. 18 MR. COLLINS: Correct. 19 DR. KERR It isn't management that's the end, 20 it'a the radiation protection program about which you're 21 concerned, isn't it? 22 MR. COLLINS: It's the implementation of the 23 radiation protection program. It's implemented to at least 24 meet minimum standards. 25 However, meeting minimum standards does not-- Heritoge Reporting Corporoflon ; m .m = l i
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149 s
.,. I DR. KERR: I don't understand what "minimum standard s" 2 are. I mean--
o - I 3 MR. COLLINS: You're talking about ninimum 4 standards on a regulatory basis. I'm referring to minimum 5 standards on a. SALP basis, which are two different defini-6 tions. - l 7 I agree with you that there is a minimum level of 1 8 regulatbrycompliance. When you're outside that level, 9 you're violating your license. The SALB document does not 10 focus on.that. It focuses on performance. 11 DR. KERR: I don't understand what'is meant by-12 minimum standards in a SALP' document, but maybe that's a O 13 p int of philosophical discussion. If this doesn't have O i4 eomethine ee do with reeu1eeion, I den e eee whv ehe NRC 15 staff was involved with it because that's their responsibility 16 as the staff, to regulate. 17 MR. COLLINS: I understand your issues, however, is the answer to that is contained in the definition of 19 category which is in the front of that report which was taker 20 verbatim out of an NRC manual. I understand your point. 21 DR. KERR: Okay, continue. 22 MR. COLLINS: We had the question earlier, I 23 believe it was Mr. Carroll on the change of the staff
, 24 and during this period, there were a~ number of staff changes 25 of significance and I'll run down through them briefly. This Heritage Reporting Corporoflon (MS) utemt
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'1 isn't a total list, but it is a partial list and I will go 2 drom-the most recent back.
3 This month there is an acknowledgement that the 4- Training Manager is leaving the site and that will take 5 elace in November, 1988. .In April of '88, there was a change 6 in the Maintenance Manager position. In March.of '88, 7 the, current Plant-Manager was assigned. In 12-87, there was a a major site reorganization including the assignment of a 9 Site Director, Plant Manager positions--these are position 10 changes now inl the .or'ganization. 11 Plant Manager position, Planning and Outage Manager, 12 Plant Support Manager, Ops Sectio Manager, Outage and Reset 13 Group was disbanded. QA Manager was reassigned. There was a O i4 aew vo tetoa or oevuty or o^ "e=eser- sentember or 87, 15 the EP Coordinator was assigned reporting directly to the e 16 Senior Vice President, Mr. Varley. In July of '87, there was 17 a new Radiological Section !!ead. June of '87, the Vice 18 President Nuclear Ops resigned. lie was subsequently replaced 19 by Mr. Ilighfill, Site Director. In May of 1987, the Outage l 20 and Restatt Group was created and in February of '87, there 2 21 was also a Plant Manager change. 22 Corporate reorganization, there was a new Senior 23 Vice President assigned to the site and an' Assistant to the 24 Senior Vice President assigned. 25 Those detailed are in the handout which we'll w.,i.... n.,,o,un,c.,,,,, i.n l
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- give you, which Mr. Lyanh keeps on site.
2 I think the significance amongst that is what it O 3 took in BECOs corrective action plan to get the right people 4 in the right spots at the site. The most significant changes 5 are the December of 1987 reorganization which broadened 6 the span of responsibilities for Site Directors. The 7 reassignment or reclassification of the position of Vice g President Nuclear to Station Director. The individual is 9 now looking into the site rather'than having collateral 10 duties looking out. And, of course, the assignment of Mr. y 3g Bird'to the sitie as Senior Vice President. 12 The assessment activities conducted todate, in 13 addition to the Restart Assessment Panel, the Augmented 34 Inspection and Review Activities, the Licensing Activities 15 and the SALP which I just covered include the Integrated 16 Assessment Team Inspectors. 17 This was committed to by the managemer.t of NRC 18 activities memorandum of July 1987. We committed to conduct 19 a Region I diagnostic team inspection after BECO submitted 20 its readiness inspection report. It was actually a Readiness 21 Restart Report and after the Pilgrim Restart Panel had 22 independently concluded that licensee program areas are O 23 reasonably ready to warrant this inspection. p The sequence that was followed in those events was Q 2s that Boston Edison submitted their letter requesting the Heritoge Reporting Corporation o.n .. l
. 152 3 inspection. We reviewed the status of the activities on 2 site. We then committed to'the inspection and the inspection
-O' 3 was performed in August.
' We have accepted the Restart Assessment Plant and 4
5 w have accepted the Restart Plan. As I mentioned the Power 6 Assension. Plan remains under review'. 7 DR..KERR: What does "accepted" mean? g MR. COLLINS: It means that the, staff has reviewed 9 the documents and the way that review was conducted was that the Restart Assessment Panel convened a Task Force consisting I 10 gg of Mr. Larry 'Doertlein, as the Task Force Leader and-that Task Force' reviewed the plan'for adeq acy based on the
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12 O '> **""** ""' " """ "'""#*"S ""* '"* "" " ""d " ""*"'*"" O i4 actions-15 And when we wrote back and you point is well 16 taken, when we wrote back, we acknowledged that that plan l met the intent of the Confirmatory Action Letter requirement. 37 18 That was the languagu used in the letter. t It is not--I need to emphasize, it is not an NRC 19 20 plan, it's a BECO plan. 23 The second bullet depicts a sequence which I went 22 through. DECO asked for the inspection in June of '88. We , O commenced the inspection, the first part of the inspection in I 23 24 July with a week on site and the inspection concluded this l week with the exit on Wednesday and it took place the 25 Heritoge Reporting Corporotlon [ i nosnn me i
r- , t 153
- preceding two weeks.
2 Any questions on the Integrated Assessment Team-
. /-m k- 3 Inspection? I'll get into the results of that' inspection in 4 a moment.
5 slide 16 further indicates the extent and purpose 6 of the Integrated Assessment Team Inspection. 7 Our purpose was to independently review and g assess the readiness of Boston Edison's management controls, 9 programs and personnel to cupport safe restart of the go facility. 'That',s under.the response letter from the NRC gg to Boston Edison.. 12 The schedule is,as I indicated. It's a fairly
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extensife effort. ~ It resulted in'approximately 1,100 hours (]) 13 of inspection on site. The IATI Operating Plant Objective (]) 34 15 is indicated, I won't read it, but it is out of the inspectic n 16 plan which Mr. Blough initiated and which was approved by 17 Regional Management. 18 It is significant to note that the objective is 19 to review the adequacy of the issues not previously inspected . 20 This particular review effort can't be taken in 21 isolation. 9,700 hours in the last SALP period which led up 22 to this inspection. We had committed to a large augmented
.O 23 inspection program, as I previously indicated.
2 To track the status of the activities and the issues 25 which were contained in the CAL and in the report 86-41. Heritoge Reporting Corporation
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154 3 By design, the process required that Boston Edison 2 submit their plan, that it be reviewed by the NRC and'that
'O. 3 the NRC.have a high confidence that the programs and 4 actions were in place"to correct.those problems before we 5 started the inspection. So in that regard, the NRC inspec-6 tion was expected to confirm Boston Edison's conclusions.
7 It was an independent measure, however, to do that. 8 Slide 17, I won't spend a lot of time on this. It 9 indicates the organization that was used and the-levels of 10 involvement. I'was the senior manager of the team. .I was 11 present on site,with the exception of, I believe, two days 12 that I went'back to the region-for a meeting. Team Leader Randy Blough was present throughout,the whole inspection.
'( ) 13
() 14 The Tech'nical Assistant was the SeniorERosident from the 15 site, Mr. Clay Warren, at the back table. i 16 We did have Shift Inspectors and Specialist 17 Inspectors and I'll get into their background in just a , 18 moment. 19 MR. CARROLL: What's the distinction? What's j 20 a Shift Inspector. He is there looking at things around the , i 21 clock? , 22 MR. COLLINS: Yes, sir. The inspection process i ( 23 itself provided for 24 hour coverage for a period of 3 days f i ( 24 and that included parallel operations with the people on ; () 25 shift as well as observations of activities that are going Heritoge Reporting Corporation
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'2 It includes maintenance surveillance and routine 3~ operations, health physics aptivities.
4 MR. CARROLL: Okay. 5- MR. COLLINS: Briefly,-just to give you a flavor ' 6 of how the Restart Assessment Panel has' attempted to provide 7 for looks at the station from the outside, we provided for
-t, 8 this team to be-as diverse as possible, given the resources 9 that the agency has.
.10 In that regard, we called on the Shift Inspectors
! 33 Mr.' Larry Rossbach, is the Senior Resident at the Indian 12 Point Station. lMr. Loren'Plisco was the Senior Resident 13 at the Susquehannah Station,,is .' now assigned to headquarters. 14 Mr. Bill Raymond is the Senior Resident at the Millstone I 15 Station. "Mr. Frank Akstulewicz reports to Dan Mc Donald. 16 The point is that he is from the Headquarters NRR organiza- ; 17 tion. Mr. Tom Dragoun is from the region. Greg Smith , la is from the Region, Jeff Lyash, of course, is one of the 19 Resident Inspectors. Mr. Larry Doorflein is a member of the ! I 4 20 Task Force and a Project Engineer. Dan Mc Donald has been l i 21 introduced. Ile is a Licensing Project Manager. Michelle i 22 Evans is from the Region Division of Reactor Safety. 23 I also want to add that there were two observors i 24 from the Commonucalth of Massachusetts on the inspection, f i Mr. Steve Shelly from MNV Associates who was a consultant ! Q 25 l Harltoge Reporting Corporation ; o= = i t
( 156 M i on retainer to the Attorney General's Office and Ms. 2 Pamela Chan, who is a member of the Massachusetts Energy S: i 3 Agency. She is under contrant right n'ow to the Executive ., 4 Department of Massachusetts. 5 Those details were negotiated with the Common-6 wealth through Mr. Peter Agnes who is a State Liaison 7 Officer. The original provisions, under the protocol were 8 for one observof. The state requested multiple observors
, 9 and we onded up with 2. They were given access to all 10 aspects of the inspection which I'll detail in'a moment, 11 In conjunction with the inspection, the observors 12 were asked to comment on the inspection plan. They were 13 .given the opportunity to partake in the site review, prepara-14 tion wook in July. They were given the opportunity to 15 observe any~ aspect of the inspection which they so chose.
16 We requested the state to provide input to the inspection 17 plan. The stato did not provide an input to the inspection is plan. We used the inspection plan that the region had 19 depicted and the state has indicated at the exit that they're 20 in agreement with the results of the inspection. 21 There has been public comment by the state liaison 22 officer that thoro are further technical issues outstanding. 23 We need to understand those a little better and why 24 they weren't included in conjunction with the inspection. 25 We have a meeting proposed with the Commonwealth Heritoge Reporting Corporation o.
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y ( 157 4,. 4 I 1 in that regard. ; , 2 TheITATConclusionsindiNateacceptable n 3 . Performance. Inspection generally con $1rmed the results of 4 the recently issued SALP repcrt as well as validating the 5 ; general SALP conclusion that performance,was improving.at 6 the end of the SALP. period. Licenseo performance appears to 7 be steady or. improving in all functional areas examined .,
.r, a during the Integrated Assessment Team Inspection.
, Also the current level of Safety Performance is 10 equal to a better than that described in the SALP.
11 In the areas of Maintenance and Radiation Protec-12 tion, which wo discussed earlier, performance was noticeably improved. Q. 13 "O i4 The te>= found thae 11ceneee menacemene centro 1s 15 programs and personnel are generally ready and performing i 16 at a lovel to support, with high competence safo atart up 37 and operation of the facility. Those technical items' s requiring resolution of work completion prior to restart 3, are being addressed and tracked by the license.. Wo do have 20 a number of commitments which we have confirmed with Boston I d 2: Edison which would be subject of the report and will be con-22 firmed prior to startup. O 23 There are currently no fundamental flaws in the 24 l licensoos management structure of maintenanco performanco, 25 Programs or program implementation that would pono a hazard Heritage Reporting Corporation m m .= l
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1 to reactor or public safety in the event of an NRC deci,sion 2 to allow for restart .of Pilgrim.
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3 Those were the summary conclusions of the inspec-4 tion. ,
/ 5 The specific details of the inspection which 6 resulted in thoso conclusions will be contained in the report .
4 7 MR. CARROLL: Is this a case where you inspected
/
i a some comments from the state?
- n ..
9 MR. COLLONS: We did provido , the opportunity l 10 fortheStatetoinputtotheinspectionplanbothduring 11 the preparation week and up to the time when the inspection !
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12 was-implemented, yes. r Q 13 MR. CARROLL: I thought that you said that their ! O i6 ebservors hed some commente due you hedn't received them L is yet. , ! i \ 16 MR. COLLINS:-- Two different topics. The first [ l 17 topic was the request,for'an input to th3 inspection plan i l s i is on what noods to be looked at. !
?
19 The State went to the extent of conducting a 1 , 20 public mooting to provide for the public to provido an 21 input on their concerns and the results of that public , 22 mooting woro to be taken under consideration by the Stato O 23 as mooting to the input or to the inspection plan. .i [ 24 So whether we oXpocted an input or not, I think [ ] ! it's the State's decision, it's the Commonwealth's Q 2s I Heritoge Reporting Corporation ,
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159 t '. ; i decision and we did not receive an input. 2 What I referred to which might have been mis-
- .O 3 construed, was the State observors participation and their A ,
J 4 agreement would be some refinements of the inspection itself. *
$ MR.. CARROLL: You said and their agreement with 1 6 the results?-
7 MR. COLLINS: The State's observor's agreement. ; a Subsequent to that exit, we understand thattthe State has- ; I t
, some technical issues which they consider'to bo outstanding.
, I r l 10 Those are the issues which we propose a meeting to disc',blu'. , l 33 MR. CARROLL: Would that meeting take place before 12 our full ACRS meeting so we could be privy to what these Q i3 technical issues are? _O i. "a cotttnS: correce- wae nue eio= we waeener is that meeting will be conducted prior to the ACRS meeting i 16 and our intent is to do that. 17 !!ere I have a milestone chart which indicates , gg future activities. For clarity, im are now at the ARCS l g, subcommittee meeting here at the top. The future activities . t
- f 20 include issuance of the IATI report which our goal is to
! 21 make that report available for the full committoo meeting. l i I 22 The resolution oC the safety enhancement program l
!O l 23 issues which include a review of the most recent submittal 1
i i
- i 24 on the droctor is sont.
< 25 The EOP issues addressed, as Mr. Blough indicated, Heritoge Reporting Corporation j
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160 there is one ite'm outstanding-in the resolution of the EOP. 2 issues. (3' \'- The 2.206 issue status there. We have had two'2.206 3 4 petitions issued. There was a petition on July 15th', 1986 3 by Senator Golden. They were concerned with management, 6 emergency preparedness-and Mark I containment. The Director 7 of NRR denied the petitions request in an interim decision ,e ; g in August of 1987 but deferred the response on management t 9 so the item remains outstanding. 10 In July of '88, the petitioner's appeal of that gg decision by the NRC was denied by the First Circuit of 12 Appeals. 13 The second petiton was filed in October of 1987. O g4 It was filed by the State of Massachusetts on behalf f the 15 of the Governor and the Attorney General. It also had concerns with management, the need for 16 17 a PRA and emergency preparedness. The Director of NRR gg denied the petitioner's request in an interim decision in j g, May of 1988 and deferred the response on managemen't and the ! 20 emergency preparedness issues. I i 21 So in summary, in the first 2.206 petition, the f 22 management issues remain outstanding and the second 2.205 O 23 petition, the management and the emergency preparedness t I i i 24 issues remain to be responded to, i
- 2) The NRC Rostart Assessment Report will contain the Heritoge Reporting Corporation l o an l
161
-3 basis for _a recommendation that the Restart Assessment Panel . 2 makes to the Regional Administrator that.will include, for 3 example, the IATI Report, the SALP document, the results of 4 the staff reviews of BECO, submitta'ls supplied LJ the 3 Confirmatory Action Letter, a record of the NRR liconuing 6 actions whi.ch took place in a summary conclusion and basis 7 for a restart decision.
8 It will be submitted to the Regional Adminstrator 9 who will then make the decison on its adequacy and the 10 ability of the plant to restart and he is then committed to a public meeting.to provide the basis for that decision.
~
11 12 The Emergency Preparedness issues are still 13 outstanding. There is a commitment that Doctor Murly has ee-4 O i4 mede taet, e 1=1===, eae emerse=cv ereseredee 1 15 need to be addressed. The issues of particular concern 16 are the movement of the mobility impaired and the identi- ! 17 fication and movement of school children and there will be 33 some limited demonstrations regarding those areas. 1 39 Emergency Preparedness is the subject of much l 20 activity on the state and local levels and much discussion j between the state and FEMA. The most recent being a August 23 22nd letter from FEMA to the state clarifying the require-22 .O 23 monts of Emergency Preparedness and requesting a schedule 24 for resolution of the issues. 25 MR. CARROLL: As to the Emergency Preparedness Plan, ] 4 Heritoge Reporting Corporation (ted) 6M met
m O 162 1 did it contain' provision for evacuation o'f school children 2 from.their schools within the-LPZ? '
- >Q
~ v' MR. COLLINS: I can't address .w hat it.actually 3
4 contained, but I.can say that based on the FEMA Self. 5 . Initiative Reviews, what was currently available was found 6 to be inadequate. Whether there was some information there 7 and it was inadequate or there was no information, I don't l s' 'have that. 9 Finally the Regional Administrator's Decision, 10 it is required that he make recommendations to the Director . 11 of NRR who is Dr. Tom Lily and that follows the sequence 12 up to the Commission for'a Commission meeting with an Q 13 ultimate decision. O 14 If the Commission does not agree, of course, j is then there are further corrective actions necessary. If 16 the Commission does agree , a restart decision will be 17 issued by the Commission and the Power Assension Program I 13 would then be authorized. 19 We expect that there,will be additional issues L i l 20 which will have to be addressed between now and any decision ! I I
- 21 by the Commission and those will be tracked as 'no start our ,
J interest as' appropriate. i 22 O 23 The licensne does have a fairly extensive power i I 1 l 24 assension program. The purpose of that power assension pro- j 23 gram was to provide for controls, orderly restart of the
- i i
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\. b 163 6 +- I plant. There are proposed plateaus where NRCs permission 2 is required prior to power escalation. The present plan 3 provides for two of those. We are discussion a course.of s 4 plateaus for the licensee.
5 The. latest discussions indicate that'there will be. 6 a resubmittal of the plan to provide for a 5, 15, 75 and 7 a 100 percent power assension. 8 One of the issues--focuses of the staff there 9 there, of course, in to provide for low power level 10 operation of machinery, check out of equipment and training 11 of the operators who currently have licenses. 12 Any question on Slide 20. ' 13 It is important to note that the dates on those O i4 mt1eseone cheres, of course, ere eereee deees ee fer ee is going in the future and they may change based on your 16 staff activity or licensee activity. 17 This is a conclusion overview. I have one more la slide which depicts the restart criteria, but in conclusion, 19 as a summary, the plant was shut downon April 12th, 1986, duo 20 to technical issues. I guess it actually started on the 21 lith of April. There were MSIVs, the PCIS containment 22 1 solation and the intersystem leaking into the R!lR system. 23 The shutdown was confirmed with a confirmatory action letter 24' whoso purpose was to keep the plan in a shutdown conditon 25 until those technical issues could be understood. Heritoge Reporting Corporation
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1- The issues and tho'NRC concerns were then expanded 2, 'nd'the a supplement to Confirmatory Action Letter 85-10, once ' c 3 the licensee had decided to proceed into their review of ! O U outage 7 and expanded the issues into further technical 4 5 issues which were outstanding at that time as well.as l i 6 performance issues. indicated by the diagnostic team i, spec- , 7 tion and the SALP reports. I 8 , Since that time,~ Boston Edison has devoted j l 9 substantial resources towards tne resolution of the 1 10 issues. The NRC has reviewed those actions regarding 11 management and organizational programs--changes, excuse me. 12 The new programs, the in plant improvements and'the ; 13 offectiveness of those actions, the level of NRC staff O i4 activiev en ei1erim is very hieh. ze witt remein hieh in : 15 conjunction with completion of the restart assessment actt- ! 16 vities. And the level of Commission Interest as well as i ! 17 public interest in the facility remains high. And the i l 3 is level of Commission interest as well as public interest in the [ I ! i I, facility remains high. i 20 The criteria that has been used by the staff, 21 as stated by Tom Murly in his briefing to the Commission, f f 22 provides broad guidelines for the restart of the plant ; . O 23 is that'we would expect a stable and effective management l would exist. at Pilgrim prior to a restart decision. f l 24 i 25 we would expect that the resolution of the major Herit6ge Reporting Corporation l 4 im) .
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. '165' Jt I technical issues are reached. We would expect the maintenanc n- ~. '2 program and the work backlog issues to be addressed and the O. .. 3 NRC must be satisfied, that certain emergency plan improve-4 ments have been made.
, D ': 5 We have conduc'ted'a technical review'of the l 6 organization staff'and their qualifications based on the l 7 NRC accepted standards, in this case it was'18.1. We have ! t a dones this objective assessment of effectiveness of the ; q l - 9 programs 1:oth as ,a result of implementing the inspection f , t i 10 . program itself, in conjunction' with tr em insepctions and , l 11 diagnostic reviews. . t l 12 The technical issues are being tracked. We have'a ! ( e r 13 150 items that were originally on the restart check list.
.O i4 ^e this goint in time, there ere aggroximate1r e items 1efe ;
4 ' is on the restart check list. There are about 10 items left on . I 16 the outstanding items list and we have the commitments that l
. .l l 17 are contained in the integrated assessment team inspection t
j la report, not all of which are restart items. l t I, Wo have conducted the most recent SALP, 87-99.
- 20 Wo havo reviewed the results of that SALP in conjunction p l
i l 21 with the integrated assessment team inspection. We performed l ! 22 a maintenance team inspection.to. address the maintenanco ! f ! 23 program and a work backlog. t i l I 24 BECO ir41tiated corrective actions with a major j l ' t l
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166. I that. That additionally was reviewed in the integrated 4^ 2 ass.-esment team inspections.
-O , 3 The EP status, there is a lot; of activity between
( 4 FEMA and the Commonwealth. That interaction appearc '.) be
- s. working. We are working with the Commonwealth to (St*.n 6 the status of the emergency preparedness. FEMAs most recent~
7 submittal asks for a schedule. We do intend to review the r 8 procedues, at least in part, and to make limited observations 4 9. of training activities to provide for demonstration. H) As I iantioned, there are two areas of verification it which are the local schools and the movement of the mobility i
. 12 impaired.
1
-() 13 Any questions on Slide 22?
i () 14 DR. KERR: It was not clear to me what your is conclusions were. For example have you concluded that there h5 is a stable and effective management and staff at Pilgrim? 1 i l 17 MR. COLLINS: Yes, sir. That wac included in I 18 summary as a result of the confirmed--as a result of the i ! 19 1.*tegrated assessment team inspection. i i 20 DR. KERR: And have you concluded that there has l l 21 been a demonstrated improvement in the SALP problem areas? I 22 MR. COLLINS: Yes. That was acknowladged in tho O 23 cover letter from '87-99 as well as acknowledge a i ! 24 result of the integrated assessment team, i 25 That concludes the staff presentation. Are there (]) i Heritage Reporting Corporoflon
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167 3 any additional questions? t i 2 DR. KERR Mr. Collins, let me refer to Page 14 of ^ [i t y 3 the most re:ent SALP. In the second paragraph, about mid i
!\ 4 way through the paragraph I find a reference to problems 5 in the operations area that contributed to the licensees ,
4 work ctoppage on November 9th included--I'm sorry, it's , 7 the next sentence.that I wanted. [ - t s "Some weakness in coordination and communications f i
, between the operation staff and other groups was noted during !
10 the loss of off site power again on November lith, '87.- j P 3: The lack of clear management directions both in : i 12 and out of the control room were somewhat fragmented in the s recovery effort and poor communications may have delayed sj
]Q 13 O i4 the re11 recoverv trom the toon end resetted in inedvertent- !
15 manua1 shutdown in one of the emergency diesel generators. , 16 My impression of Mr. Howard, who I think was [ t 37 talking about the samo incident, was that there was a l t la careful and deliberate program to go through what needed to l [ g, be done. This doesn't sound as if it is describing the t;ame ) 2o. incident. Is it? ;
- MR. COLLINS: It is. The general approach and ther L L
12 I'll defer to the people who have the details of that, j iO i 23 The general approach during the event was well l ( 1 thought out. There were some issues in the implementation f 24 f 4 of that approach which resulted in equipment being made { Q 25 , I
; Heritoge Reporting Corporation f I
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; , <; l 3 unavaiLtle as a' result of, in this case, of mis-communica-
! 2 tions on.whether to secure a diesel generator or not. 3' If you want to know the details of that, we can 4 get-- 5 DR.'KERR: No. I was just trying to reconcile the t 6 two descriptions of the event that I heard and I guess : i 7 I'm still not certain that both descriptions are the same a o event, but you tell me they are. 9 MR. COLLINS: Well, I think they're the same f 10 event. I think they're locking at the event from two , r 11 different angles. One is the overall approach to the j 12 event, in general, as far as how to respond and how to t 5 provide for the safety of the reactor. The other is the l( ' 13 ! 14 implementation of that plan. During the implementation ! 15 there were a number of instances which we reviewed, we '[i 16 responded' to that event by redirecting people who were in f 17 transient and conducted a fairly extensive review 'of the ! l f l Is activities both during and following the event. 3, DR. KERR: And they just came to their conclusion i 20 that there was a lack of clear management direction and a 21 somewhat fragmented recovery effort? [ l 22 MR. COLLINS: In the case of securing the diesel i
- O 9enerator, that's correct.
23 [ 24 DR. KERR: Any questions for Mr. C::".ns? f 1 ,
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' I (No response) Q 23 $ Heritoge Reporting Corporation l j . m = == [ t i
169 i DR. KERR: Mr. Collins, I believe you said 2 carlier that there are current if the start up is approved 3 to start the assension program at the first stop, if I
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(_) 4 remember at 50, then 75 and then 100. 3 Over what period is it anticipated that those 6 plateaus would be held or is that to be decided later 7 on? 8 MR. COLLINS: The recent submittal does not 9 contain all of those points. The schedule has not been 10 initiated by BECO. Il My understanding is that it will be 3 to 4 montha. 12 I think, in summary, what we are looking for is () 13 a demonstration that the primary containment isolation circutry () 14 issue has been resolved and that would include cycling is plant preesure about and below that set point. 16 The licensee is also committed to remote shutdown 17 outside the controls. 18 DR. KERR: .lfas the staff donc a careful analysis 19 so that it is convinced that it is safer to operate the 20 plant this way than go directly to a 100 percent power? 21 I ask the question because the plant is clearly 22 designed to operate at 100 percent. Almost all the training 23 that operators have is operated at 100 percent power under l 24 normal situations, j 23 I wonder, does the staff have documented evidence (]} f
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170 that it is. indeed, safer to up the steps rather than go
, 2 to 100 percent and operate?
I T 3 MR. COLLINS: Yes, sir. This is very similar ()
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4 to the programs which e e reviewed and approved for near 5 term operating license. 6 DR. KERR: I recognize that, but I have never seen 7 any justification for this. If it exists, I would like to s have a copy. 9 MR. COLLINS: We have an analysis of approval to lo operate at, I believe it's 5 and 25 percent power in 11 conjunction with the off site emergency preparedness 12 considerations. We'll look at that and see if that analysis f~N) 13 is available to you.
'-), Generally this plant needs to be around 25 percent
'() 14 15 to support self sustaining automatic feed reg valve on the 16 grid type of operation so the time around 5 percent and 17 trending to 25 percent is the time where the operators 18 would be taxed.
pp DR. KERRt It would be very hard to convince me
- o that operating at 5 percent is very safe.
r 2 I am also thinking of what could happen to the 22 equipmeat operating at those normal situations which could s/ l 23 i affect the plant later on. l The 25 and 50, I don't trust my intuition too 24 much at even 5 percent, but I assume that there has been () 25 Heritage Reporting Corporation
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3 ,. r 171 l t some sort of staff analysis but I have never one. 2 MR. COLLINS: I believe there is a 5 percent O 3
. analysis in conjunction,with the Shorham.
We'll review 4 that. 5 DR. KERR: You understand what I'm asking you. l 6 It's not whether it's safe to operate at 5 percent as it is 7 at zero, but rather is it safer to go up step by step s and hold' that operating power for several weeks or months l 9 than it is to go direct 4y to the design power of the plant to which is 10L percent. L !! MR. COLLINS: My co'nsideration in that regard 1' I 12 is, along with the characteristics aad design of the reactor
' I3 would be the ability to assess the performance of the %s -
U 14 operators. I think there is a consideration there as far 15 as the control restart. l i l 16 DR. KERR: Again, you're assessing the operators ! 17 but you're also operating a plant and I'm trying--I'm really is asking the question, which I must confess I had not thought o f 1, very much until several months. 20 In the long run, is it riskier to go through 21 this process than it is to go directly to a 100 parcont? 22 1 don't pretend to know the answer and I assume 23 that somebody has given that son.e thought because that seems 24 to be a well developed' approach. () 25 MR. COLLINS: Most final, I guess it's the Heritoge Reporting Corporation (SEE) MM
172 I preliminary safety hazard analysis for the new construction
,- s 2 reactors contained in the power assension program and it's t \
U 3 reviewed by the staff, so we'll get you that information. ' ) a 4 MR. CARROLL: What you're saying is to 'rbitrarily 5 hold at 25 percent after you have finished all that to see 6 how the operators perform. 7 MR. CARROLL: Any further questions from the 8 staff? 9 DR. KERR: Any further questions? 10 (No response) 11 DR. KEER: Thank you, Mr. Collins. 12 MR. COLLINS: Thank you. (';)- 13 k-) 14 15 16 17 18 19 20 21
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,\ ef } > l#h l l OR. KERR I'm less interested in what it is than r 2 whether'somebody has looked carefully to make sure that's ; O 3 the way to.do things. But if you could give me a few details 4 that might be helpful. Would you? 5 MR. BIRD: I didn't hear your last comment. 6 DR. KERR l'say if you could~give us some brief 7 details, we do have a few minutes. l 8 MR. BIRD :- Well, the first= thing is we're at 5 per-9 cent. We'll not stay there very long, I don't believe be-10 cause it is not easy to sit at 5 percent power--it's a very ; i il low power level. It may be useful to stop there to check 12 release and that sort of thing. O >> 8 icetty we'a ae the v te te
- it we deve to >
14 shut down again next week so we'd have a back up to verify 15 that the systems are operating satisfactorily. 25 percent j 16 power level--actually I'm waiving to 25 percent to establish j 17 the conditions that existing when the main valves shut down. 18 We've already tested the llPCI and RCCI systems l l 1, using temporary water but we would test those again through ! i 20 surveillance. And we've checked for the valve pipes, i 21 At 25 percent or perhaps on th way up we might probably wait 22 until we get to 25 percent power to test the turbines. We , f i ! 23 are considering perhaps a period of about eight to twelve ; i
; 24 days at each of these power plateaus, 25, 50, 75 percent. !
l 25 We would do the multi-stage testing also at the 25 percent l , i Heritoge Reporting Corporotion
T v 174 I power. 2 ! We would do shutdown of the control room after we'd 3 built up the decay heat and start up again up to 25 percent h 4y and then 50 percent. By the way, each of these have 25, 50,
$ 75 percent and 100 percent hold points where they do an assess -
l 6 ment by our operations and obtain concurrence from the NRC o 7 staff to proceed to the next hold point. [ 8! At about the 50 percent point again they'd check 9 . for calibrations. At the 75 percent point you have another 10 assessment. At the 100 percent power, check valves, perform-1 11 j ance. And an assessment of the operator performance. 12 Probably while we're at the 75 percent plateau,
,~ it 13 H since the program appears to probably stretch out longer, (w-) g
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- p 14 h initially we propose about a forty-five day power extension d
15 program, a more typical duration is about three to four 16 months, so that's probably what we'll end up with. So we I would expect sometime perhaps at that 75 percent plateau that 17 i 0 18 4 we could go to a four-to-six shift rotation and get into our U s 19 H normal operator rotation and then at 100 percent plateau I u h 20 p would have done our manager self assessment and if the NRC d 21 p agrees, we would declare the test program at an end and the d 22 [ plant would be at a normal mode of operation. f 23 L During the entire test program that you mentioned 24 ear'ier, we did four shifts which allowed us to double up on 73 I l i%, ! n 25 the ser,ior watch program. We had evaluators on shift around gg 1 I q Heritogo Reporting Corporation Y, m u. ,
L w 175 the clock and we will have senior managers in during a great
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2 deal of the time for any changes, and we will have the senior O- Management Oversite Assessment Team to see if the assessments 3 s .. 4 are satisfactory to proceed to the next power level. 3 DR. KERR Thank you. Is thero anything else? 6 On behalf of the Subcommittee and the Committee 7 I certainly Want to thanh all of you who have been participat-m a ing today for a well< organized.and informative session.
, It has been said earlier and I simply. repeat.that there will be a. meeting of the full Committee in Washington-to 3, on the 8th of. September, a' presentation by the staff. The 12 meeting will hear a report from the subcommittee during the course of the meeting, probably on Saturday the 10th. We 13
,4 will try to write a report to the Commistion.
That ends this part of the session. We now have 15 scheduled to begin in about five minutes oral presentations g7 by those who may here and want to make five-minute oral presentations to the subcommittee. la So I'm going to declare about a five-minute recess 3 and we will then beatn the session. 21 (Whereupon, there was a short recess.) g DR. KERR Since some of you may not be familiar 3 with the Advisory Committee on Reactor Safeguards, let me say a few words in introduction. The Committee was established in the late 1950s by g j f i t Heritage Reporting Corporation L
N 177 l-
- l. I Congress to advise the Atomic Energy Commission on safety l
l 2 consideraticn: in the licensing and in the operaticn of civi-l r l O 3 lian nuclear power plants. The enabling act stipua..tedlthat 4 the Commit $ tee; must review and write a report on each applica-5 tion for a license to construct or to operate a powel reactor. l 6 The report, although addressed to the Commission, was to be l 7 made public, although originally the meetings in which the a committee gathered some of the information on which the report 1 , The Commission 9 was based were not. The report is advisory. j 10 was not bound by.it. In the.carly 19?Os, Congress decreed i l 11 that the meetings should be public. l 12 The original charter also gave the Committee the O 13 responsibility for advising the Commission on other matters Q 14 involving reactor safety as the Commission might request. j 15 And in addition, the Committee may investigate and advise the 16 Commission on safety related matters on its own initiative. 17 In 1975 when the Nuclear Regulatory Commission was is created by Congress, the ACRS with its original responsibili-19 ties, was transferred to the NRC. 20 The Committee is a part of the NRC in the sense that 21 its memberc are appointed by the Commission, and its budget 22 is part of the Commission budget. It does however have a con-23 siderable measure of independence. None of its members are 24 full time government employees. Some are retired, some em-25 ployed by universities, three are retired utility engineers O Heritage Reporting Corporation
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l 17'? I I who had long experience in nuclear power, one is an employee (~') k/ 2 of a national laboratory where he has been involved for many 7-k- 3 years in reactor related activity. Eight of the members are 4 engineers, one is a physicist. 5 The advice we give is almost entirely on technical 6 matters and is related to safety. The three members of the 7 committee here today make up a subcommittee of the full 8 committee. Our purpose today is to obtain and to discuss 9 information bearing on the capability of the staff of the 10 Boston Edison Company to operate the Pilgrim Nuclear Reuctor 11 in a way which will not pose an undue hazard to the health 12 and safety of the public. At a meeting of the full Committee () 13 to be held in Washington on September 8th we will report our () 14 findings to the committee. It will also hear from the NRC 15 staff and from members of the Boston Edison staff. After 16 discussion among members of the Committee, we will prepare a 17 report to the Commission which will be made public. 18 it is our custom to receive either oral or written I 19 I statements from those members of the public who request to Y 20 make such statements. We have scheduled time after the pre-l 21 sentations by the NRC staff and the Boston Edison staff for : il 22 this purpose. g! 23 I count eleven names here that have asked to make n 24 4 presentations. We would ask that you keep the oral presen-O 1 i: tations to five minutes. Not more than five minutes, I should Oms 25 [ j d
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i k) 'J' 198 i say. I'll simply go down the list of those who have signed 2 up and ask for presentations in that order. O 3 The first person I have is Sue Asei. Is that 4 person present? 5 The next name that I have on the list is J. Douglas 6 Hatfield. Is Hatfield here? Mr. Hatfield. 7 MR. HATFIELD: Good afternoon. I am Douglas Hat-8 field, the Civil Defense Director for the town of Plymouth. 9 Over the past. year the town of Plymouth has been given the 10 opinion that offsite emergency. planning will be taken very 11 seriously. Both myself and the Board of Selectman of the 12 town have stated'that we believe the plant should not be i 13 allowed to reopen until and unless the towns have a plan in 14 place and tested that we feel comfortable with. We are 15 working towards that goal, but we are not at that point. 16 My question is basically to the NSC team that was 17 at the plant the last two and a half weeks. If offsite emer-18 gency plans are going to have a bearing in the decision to I, restart Pilgrim, is there any reason that the Team did not 20 have the courtesy to even call me, even up to today, to ask 21 for an update of the town of Plymouth planning process status. 22 This lack of contact leads me to believe that the NSC has 23 already made up their mind that offsite plans will not have 3 any effect on their decision to restart Pilgrim. 25 I realize that the NRC relies on FEMA to give them Heritage Reporting Corporation
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- input as to this phase of the final decision. But I would !
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. 2- mention also that FEMA has not talked to me directly about'
.3 that status. If this is a factfinding meeting, as it appears 4 to be, I question where is a representative of FEMA at this 5 meeting? f 6 - .The NRC had the perfect opportunity to check firat-7 hand while the team was here on the status of the plans. I [
s am very disappointed in the inspection team's lack of in- i L 9 terest in the EPZ planning. I l 10 I say again to you that Pilgrim should not be
- : allowed tot restart until an approved plan has been developed [
j 12 and tested. 13 Thank you. , g4 DR. KERR: Thank you. I'll make note of your is comments. ; i Ms. Alva Thompson. 16 i i 4 37 MS. THOMPSON: I am Alva Thompson. I am' Chairman Is of the Board of Selectmen of the town of Plymouth. Lest you ; 4 ! g, think of us as a small town with a certain level of unsophis- 3 I i o tication, I will tell you that if Boston Edison takes pride 21 in where its people have come from, of the five selectmen, f b 22 three of us have milit.try backgrounds. My own was a military [ E l ,3 occupational specialty, maintenance and supply and civil [ j ?
,4 affairs. I haven't junt pushed papers around. I have been iO! ,5 involved in evacuation and retreat of large numbers of people i
j i i Heritoge Reporting Corporation
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1 180 l in Korea, Japan and much of the paper pushing in the United
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2I States, that is, involved with emergency planning.
'i 3 I want to thank the Nuclear Regulatory Commission 4 staff for three in-depth technical reviews of the Pilgrim 5 nuclear power station. The integrated inspection, the SALP 6 report, and today's reactor safeguard subcommittee inquiry.
7 I The troubled history of the Pilgrim plant is reason enough 8 to proceed carefully and with unusual attention. 9 i Should like to point out, however, that in the 10 j main, the three inspections are technical in nature as if the 11 nuclear plant somehow stands as a piece of complex and po-12 tentially dangerous machinery but in isolation. Herein lies [') x - 13 the residual flaw of such procedures. Adherence to technical
) 14 regulations at a particular time in history will not satisfy is all the safety requirements, least of all the public safety.
16 The NRC records going back a number of years show 17 clearly that Pilgrim, quote, "had not yet demonstrated the i i 18 ability to sustain improved performance." End of quote. 19 This is a disturbing and recurring theme repeated 20 , in the latest nystematic assessment of licensee performance 21 [l board report. The last one 87-99. The message is try, try L 22 again, and we shall inspect, inspect and inspect again. 23 Given that proviso, who is it that is considering the risk to h all the citizens in the EPZ, the Emergency Planning Zone.? g) t 24 p I have yet to see any inspection of the public safety plans and
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181 ; I 'indeed, any consideration of the Radiological Emergency Re-2 sponsing planning in any NRC inspection. You will reply, I 3 know, that it is FEMA, the Federal Emergency Management Agency , F 4 which can advise the NRC. Recent fact changes in FEMA seem [
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5 to signal new direction leading to suspicions that the cri-6 teria for emergency planning are being changed in the middle 7 of the game. f 8 I shall remind you that FEMA has withdrawn even ! l 9 interim approval of all emergency plans. In the case of i 10 Plymouth they are dated 1985. And that there are no plans ; 11 ta place that.have been approved for this town of 45,000 : i 12 population, seventeen miles in length, and entirely within i O >> *ae rez- ^to=*a
- urrer <romeriatoox 11*aro=9athe <
O i4 sum,er when eur ever1eeded mein routes, 3 and 2A and 44 are f 15 unable to handle the influx of visitors. The same thing ? 16 happens in our severe winters. And in the fall, hurricane ! 17 season. In fact, the rapid growth of this town from a popu- - la lation of 18,000 when Pilgrim opened to today, roughly six-(
? t to teen years later, 45,000 and indeed of this entire EPZ area l' i
! 20 and of all of southeast Massachusetts, makes evacuation a ! 1 j 21 monumental task and maybe an impossible one. I 22 ')' But planning absolutely must result in at least l 23 some hope that parts of our response will work. After all, ! we're talking about life and death and assessing who is likely ( 24 f Q 25 to be most at risk. It is not reassuring to note that I Heritoge Reporting Corporotion imm. L
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10 18f3 i Plymouth even with heavy output and a full-time Civil Defense (3
't, ') 2 director and an Advisory Nuclear Matters Committee and a V
3 Radiological Emergency Responso Plan Committee, that we do 4 not have a complete or an approved emergency plan. The imple-5 menting procedures, the core of any response plan, of the 6 police, the fire and.the schools, have not been presented 7 oven in a draft form to the Board of Selectmen. This should 8 indicate the magnitude of the problem to you. 9 If you respond that these problems have been solved to in other areas, then I reply, Plymouth's problems are peculiar 11 to where she is and just as the Pilgrim plant's problems have 12 been treated by the NRC as particular and specific to that O >> L >te-14 At any rate, Boston Edison was granted exemptions 15 for the 1987 full participation exercise. Meaning that the 16 ; effectiveness of any plans have not been tested for almost 17 two years. It is my duty to report to you that the Plymouth 18 . Board of Selectmen has repeatedly stated its position to FEMA, 19 to the NRC, to the Commonwealth of Massachusetts, and to the l 20 j people of Plymouth. It is that quote "the Pilgrim Nuclear j 21 Power Station ought not to be permitted to restart until ll 22 there is an approved Radiological Emergency Response Plan U 23 p in place." End of quote. 24 Between you the technical experts and us the public
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l 25 [ b safety sector lies a whole and largely unexplored territory. l Heritage Reporting Corporation i me u. ti
4 I 183 I It is the dilemma zone of ethical considerations. It is 2 where the public, the young, the old, the dependent population ,
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V 3 finds itself. The NRC, by a narrow interpretation of its 4 chargo, can avoid the public safety issue, but it cannot 5 avoid the reponsibility which comes to all of us, ncientists 6 and laymen, engineers and plumbers, physicists and officials, 7 from what happens as a result of our decision. 8 I would hope that you see yourself as having a 9 l wider range of inquiry. Obviously there's been a massive 10 infusion of money and a considerable effort by Boston Ediscn 11 to upgrade an aging plant, and one, with an intolerable his-12 tory of peor performance. f 13 Those goals are laudible. Ilowever, the effort is 14 clouded by the following considerations. 15 DR. KERR: Ms. Thompson, how much longer? 16 MS. THOMPSON: Not much. 17 ; The great administrative changes, especially of I But that's 18 l key personnel, have taken place in the past year. I 19 l during the period of outage entirely. Some of this personnel h 20 j has limited experience with the boiling water reactor regard-1 21 ! less of what has been said today. You might turn to page 10 1 22 j of the SALP report. I 23 The same detriment can be placed against many of 3 24 g the newly licencsed control room operators. A simulator is f n 25 [ not an operating plant. It's a useful educational tool. U p Heritage Reporting Corporation m asen b;
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I There is no substitute for experience, especially in the nu-O YJ 2 clear field where there is a narrow range of options in terms O
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3 of human error and a very narrow range of what can be borne 4 by way of tension. There is no sustained record at TNTS over 5 a sixteen-year life of consistently operating at Level 1. 6 Indeed, except for the latest SALP report, the report cards 7 were poor and Level 3 was repeatedly used. 8 l Of all their technical inspections and inquiries I 9 just finished or in progress, these were made during the 10 outage period of the two years. There has been no operating II I periods to observe during this period of inspection. I 12 I What are we? ?. microwave oven that doesr.'t have 13 to cook. A school that doesn't teach? A Mercedes-Benz or O i4 j e oesoto thet doeeu t heve to trevet e 1ene trie in order to II determine whetbur or not it is in good season. 15 I 16 , There are two huge problems of history to saddle 1 17 I; this community with. The feasibility of the site and the h large buildur cf radioactive waste which grows with every H 18 p 19 g operation. We can't undo that history but we surely could li 20 d learn from it. U 21 q In summary, there are many doubts, concerns and b 22 fears that enter into the position of the Plymouth Board of dl y 23 Selectmen. These doubts have led us inescapably to our T 24 I.j position and to our oath, to maintain the public safety. In
/ 2$ t!', present condition of both past plant performance and the I Heritage Reporting Corporation i .n x us l
i t 185 1 I situation of our emergency planning, the Pilgrim Nuclear Power k' 2 Station ought not to be permitted to restart until effective (^'; C 3 radiological emergency plans are in placc. Anything else 4 leaves our citizens unprotected. They have a right to be l 5 ; considered in the total picture of restart. They are most at 6 risk. 7 DR. KERR: Peter Agnes. 8 MR. AGNES: Good afternoon, Mr. Chairman, and mem-9 , bers of the subcomnittee. My name is Peter W. Agnes, Jr., 10 and I'm the Assistant Secretary of Public Safety for the 11 Commonwealth of Massachusetts. 12 And I ani here today as the State Liaison Officer 13 of the Commonwealth to the NRC representing Governor Dukakis. l I 14 We too appreciate the effort that you, the members is l of the subcommittee, and that the full ACRS Committee is mak-d 16 ; ing as part of the NRC's evaluation of the readiness of Pil-n 17 gram Station to restart. Ib ! Yesterday at a SALP meeting between the licensee il 19 . and the NRC I acknowledged those efforts by the NRC Region 1 H 20 0 staff and also by the licensee, since the outage in 1986, to . l 21 improve safety at Pilgrim Station and to work with the Common-22 ll wealth in an effort to address serious concerns about offsite n 23 emergency preparedness, i 24 h Like you, we are trying to understand why the plant O 25 p 1 had the serious mechanical problems it experienced in 1986 v q" h Heritage Reporting Corporation sus m.een
t c\ 1.8 G before the shutdown and whether in fact they are ready to o U 2 resume operations. I expressed yesterday and will express (3 V 3 again to you today the Commonwealth's skepticism at the 4 , readiness of Pilgrim Station to restart and want to outline 5 briefly some of the areas of concern that we have. 6 l First, as I said, we undoubtedly join in those 7 i f who have previously presented information to you today about a the progress that has been made since the April 1986 outage, 9 both in terms of the new management team at Pilgrim Station, 10 which has many years of experience, both in terms of the im-3 provements, as part of the Safety Enhancement Program, and the i g y other kinds of technical improvements and quality checks that 0 (] 13 have boon made on the safety systems, and the efforts that have been made to address the offsite emergency planning y gg deficiency. Nevertheless, we think that these near-term 16 marks of progress which have most recently resulted in favor-37 able reports from the IATA inspection which the Commonwealth h did observe and wM eh the Commonwealth's observers concurred g
,l in the findings of, have to be measured against an historic 19 l record of management failing at Pilgrim Station and an histo-20 l,
;g h ric lack of attention to offsite emergency preparedness.
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I would like to present for your considoration to-day two reports we have prepared for the Governor in the 23 J
,4 J past two years regarding some of these issues and would like O k y u to note that we are in the process of preparing a third 25
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d L Heritage Reporting Corporation
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h 10 '! I report which will bo ready within several weeks about our l'~') C' 2 position with respect to offsite emergency preparedness, the 3 (V 3 areas where progress has boon made, the areas where work 4 i still needs to be done, as well as some of the other issues
'I 5 that are of concern to us.
6 Now, in the few remaining minutes, I want to make l 7 some very specific cornents about some of the concerns that 8 I voiced. 9 First, with respect to onsite issues. Management 10 l and reactor safety. To be sure, as I said, there has been l 11 l progress made as most recently noted in the IATA report. 12 But in my assessment of the SALP report and in my remarks 13 yesterJay, as I indicated to you a few moments ago, I indi-l 14 cated that I think that needs to be balanced against the is [ record that Pilgrim Station has established over the years. 16 ll And I understand that one of you carlier today asked a ques- l 4 17 I tion about average SALP history at Pilgrim Station. It was ! I o 18 a question that I raised yesterday, and in fact, when you ( l 19 l look at the record, it indicates that over the past three i 20 years by using NRC SALP scores, Pilgrim Station ranked at the U 21 bottom of licensed commercial nuclear power plants in the L 22 [ United States in terms of the SALP scores. l 23 ? And I want to also offer into the record an analysis i 24 that was recently conducted and appeared in a publication 25 called "Inside the NRC," of licensed nuclear power plants in 0 : q Heritage Reporting Corporation n (=t m a ; e
Y t 180 t i I ! terms of their SALP ratings using NRC data. 2 The point again is not to deny that there has been 3 progress but simply to suggest that this progress needs to ll 1 4h be placed in the context of the historic record, and that d 5 over the years Pilgrim Station has had one of the worst operat -
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d 6 L ing records and der,pite the improvements that have been made, 1 7 as you gentlemen have heard throughout the day and from the d 8 j! reports that have been made and the presentations that have U 9 u been made by NRC Region 1, Pilgrim Station has continued to h to have problems even since the new management team has been 11 installed at the plant. There were questions earlier about 12 the loss of power incident in November of 1987. There have ( ,) 13 t since that time been augmented NRC inspection reports, which mg b 14 j I knew you are aware of which have documented problems in is other areas including maintenance. And again notwithstand-16 p ing the obvious progress that has been made of late, we think I n
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that in assessing the readiness of the plant to restart, that is progress has to be put in the context of the historic record. 19 Now, with respect to offsite issues. We are par-20 . ticularly concerned about the lack of specificity on the 21 part of the NRC regarding just what will be required to be 22 demonstrated in that area before restart. At the present 23 time, we have the FEMA report indicating that interim appro-val has been withdrawn. We have reports that we have pre-g) ( uw
$4 pared. We can say with assurance today that the offsite (v )' 25 Heritage Reporting Corporation x u.
I' 180 i emergency plans are not complete, that serious deficiencies rT i k- s 2 remain and although we are continuing to work with the li-g G 3 consee in an effort to address those concerns, there are p 4L serious problems. And those problems have to be taken into l 5 consideration we think by the NRC. We move towards that day 6 when a decision will be made on restart. And it is our posi-7 tion that all of the components under the regulatory require-8 ments for offsite emergency preparedness should be and must 9 ; be in place before restart and that there ought to be in this I 10 special circumstance a full-scale exercise and test of any 11 0 such offsite plan before a restart decision is made. 12 It has boon three years since there was an exercise. 13 We are not talking about a plan that has been revised. We ( 3) l 14 are talking about a totally revemped and totally new plan l 15 with new implementing procedures. We are talking about a 16 f totally new training program and despite the efforts that i 17 everyone has made at the local and state level with support i 18 from the licensee, there simply is more work that needs to be l 19 done. And while We are continuing to address those concerns, l! 20 ll we think it would be unconscionable to go ahead with restart I 21 ;! given assumptions that exist about the importance of emergen-h 22 [ cy planning without assurances that in fact the plan la in , f 23 [ place and has been tested. 24 f so we hope that insofar as that is an area of con- :
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25 cern that you will be reporting to the Commission on, that c Heritage Reporting Corporation ; g mr u. i
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ISO I you take due note of it as well. K ;, 2 Thank you very much.
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3 DR. KERR: Thank you, Mr. Agnes. 4 MR. CARROLL: The report that we have is unsigned 5 and undated. Do you know the date of this? 6 > MR. AGNES: It was December of 1987, and I can 7 submit a signed and dated copy if that would be more helpful. 8l MR. CARROLL: That will be fine. I 9 i MR. AGNES: Thank you. 10 ! DR. KERR: Is Mr. Laurence Alexander here? 11 MR. ALEXANDER: Thank you very much, Mr. Chairman. 12 For the record, my name is State Representative (t-) 13 Laurence R. Alexander. I am House Chairman of the Legisla-o p) , 14 ture's Joint Committee on Energy here in Massachusetts. 13 I'd like to thank you for the opportunity to speak 16 to you today. I very much appreciate the chance to address il 17 li a scientific panel on some of the problems that still exist I 18 h at the Pilgrim Nuclear Power Plant. 4 19 As House Chairman of the Legisture's Joint Committee i 20 ' on Energy, I have chaired oversight hearings on design flaws Ii 21 I in the MARK I reactor containment, on deficiencies in the r 22 cmergency response plans on inadequacies in current radiation u v 23 p monitoring systems, and also on the increased incidences in d gS 24 p leukemia in communities downwind from the Pilgrim plant.
%-) f The Atomic Energy Act and the NRC regulations
('} t-25 A g 1 g Heritage Reporting Corporation o.t m .=
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'K^ 191 provide that nuclear power plants may only operate quote "con-2 sistent" unquote with the quote "health end safety of the O 3 public" end of quote.
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4 1 believe that mandate means that the regulatory 3 agency and the licensee must follow the letter and the spirit j 6 of the Atomic Energy Act and the regulations promulgated by 7 the NRC thereunder. So with that standard in mind, I would' s urge you to recommend against the restart of Pilgrim unless i
, and until'the following conditions are met. l t
Number one, all identified reactor safety problems i to t have been corrected, including improvements to the MARK I 3: 12 containment. Number two, workable emergency response plans 13 s are developed that are adequate to protect the public and are y g in place. And number three, plant management has demonstrated [ l is its competence in operating the reactor by improving its 16 performance well beyond their quote "marginally satisfactory" [ 37 unquote grades in all of the NRC SALP categories.
- Now, in view of the terribly operating record of Is this plant thus far, which over the years has been termed ono .
3 of the worst in the nation by various NRC commissioners, I [
;g urge you to recommend that the conditions I have mentioned be met before restart is allowed to take place.
Let me begin with reactor safety. There are sti?.1 23 [ I l unresolved questions about exactly why the plant shut down t y 25 [ automatically in 1986, thus initiating the closing of the i I I a Heritege Reporting Corporation } y m m.= l t
y) 1' .O, O v i ] plant for the past two years. How can Pilgrim be ready for
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V 2 restart when MIT scientists are still studying the cracking 3 of an Rl!H motor housing and valve? Numerous recent events l 4 raise additional serious concerns about the safety of Pilgrim. i 5 l Could Pilgrim experience the same wild power oscillations I 6 , that occurred at the LaSalle boiling water reactor in Illinois 7 this year? lias Boston Edison analyzed Pilgrim's vulnera-i 8 bility in this regard and hava its operators been thoroughly I 9 trained to take the appropriate responses? !!as Boston Edison 10 tested all the potentially defective pipes, circuit breakers 11 and other safety equipment that were recently revealed to I 12 / have been fradulently certified as safety grade? What exactly 0 q1theexte== r imbriteteme"t < xer re et r eaeiv=eet t 14 l Pilgrim? I 15 ! Thirteen years after the Brown's Ferry fire has 16 Boston Edison finally completed the fire protection improve-i 17 monts required by 10 CPR Appendix R7 llave the problems with , L l 18 h the main steam isolation volve finally been resolved? il 19 d The U.S. General Accounting Office, or GAO, last h 20 lj year criticized the NRC for not having resolved 163 generic h ; 21 [ safety issues that may take up to ten years or more each to h 22 resolve ar'd correct. 23 In fact, according to the GAO additional generic 24 d safety problems are being four.d faster than the NRC is solv-O 25 ; t ing them. Many of these problems directly affect safety at Ov h p Heritage Reporting Corporation 3 me u.
f 193 i Pilgrim, yet because they've been labeled generic, the NRC () V's
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2 may allow Pilgrim to restart before they are resolved and L)\ 3 corrected. 4 I would hope that your committae would investigate 5 each of these generic issues as they pertain to Pilgrim 6 , specifically and would recommend in view of Pilgrim's age 7 and prior operating history that the plant not be allowed a l to restart until necessary corrective measures are undertaken l 9 concerning these generic issues, r I 10 The Governor, the Attorney General and a large 11 j number of us Massachusetts kgislators have sought a full ad-l 12 L judicatory hearing pursuant to NRC regulations on these and (') L 13 ! other issucs, so that technical consultants could be called O i4 kontoearticipateinemeaniaefu1xindofereviewofthese f is matters with the NRC and the licensee. The NRC. however, has i
'i 16 ] thus far refused to conduct such a proceeding. It's impera-17 l tive that you examine these matters carefully. The plant i
isI should not be allowed to restart unless these matters have L 19 been satisfactorily and fully resolved. d t 20 [a Another zeactor safety problem involves the flawed h 21 MARK I containment design of the Pilgrim reactor- Major NRC 22 j staffers, as you know, have acknowledged that the MARK I 23 , i containment is likely to fail and release radiation during i 24 , a . serious meltdown. Two years ago the NBC staff recommended s five measures to reduce, altho 1gh not eliminate, the o d Heritage Reporting Corporation
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f 10' I likelihood of MARK I containment fai?ure. F63mer NRC Commis-g V 2 sioner Jaraes Applestein felt that waiting until April of 1987 3 l to implement these measures was an unwarranted delay. Yet 4 here we are now, almost a year and a half after that date, t 5y i and the NRC has still not even approved these measures let I 6 alone impicmented them. 7 I Finally, after a long delay, the NRC staff is j 8 l apparently expected to make it, final recommendation on cor-I 9 rectivo measures in a month cr two. O 10 h Now, Boston Edison has constructed one measure
!! event to relieve over-pressurization. Bet so far it has not I
12 , been officially allowed to connect it to Pilgrim yet. Cer-1 tainly tha owners of Pilgrim should wait until the NRC issues hs 13 O i< i o# corrective e uree otaevce=imeie-15 P[litreceeatio#- a mont then and make sure that they train their staff--thet 16 l their staff is trained appropriately on how tc use it before 17 l! they are allowed to restart the plant. i' 18 !! Now, before the Commission will be asked to review U 19 4 the reccmmendations before restart of Pilgrim. I urge you 20 [ to recommenu that any additional events include radiation H 21 y filters auch as those that have already been added to re-22 h actions in various European countriN. 23 l I also hope you'll recommend the construction of 24 barriers on the floor of the dry well to help prevent the , 25 flow of a molten core to and through the steel wall liner j Heritage Reporting Corporation L mm U
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-. I as nostulated by the NRC's R? actor Risk Reference Document,
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( 3 In addition,.I urge you to consider some other
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M. 4 design features that are being added to foreign reactors, 5 auch as an additional independent decay heat removal system, 6 improvementc i.i the reliability of reactor. control systems'
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an$ emergen'cy power supply systems, and equipmsnt'to protect , 8 against the loss of electrical power to operate cooling.and
- 9 safety systems. '
,10 I believe it's most unfortunate that Boston Edison i f
11 recently installed a diesel generator that was not safety t 12 grade. O >> r"rener ore, ' uree vo" to ce11 ror the vro=9e O '4 i=ttiett " or ite- vectricarobedi11 etcri x e me=* 15 for Pilgrim so that appropriate additional plant specific 16 improvements can be implemented as soon as possible. 17 As you know, the NRC stated in FJREG 1150 that a 18 probabilistic risk assessment conducted for some other plar.t ] 19 is not directly transferable to other nuclear reactors. Thus l 20 a Pilgrim-specific probabilistic risk assessment is needed. ! 21 Let me talk a little bit about. emergency planning. 22 No plant is allowed to operate until workable omorgency re-23 sponse plans are in place that will protect the public's i 24 health and safety. When the NRC established emergency plan-l O 25 ning regulations after Three P"le Island, the Commission i Heritoge Reporting Corporation l mn us au
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190 I l included that quote "a'dequate emergency preparedness is an ; t 2 ess'ntial e aspect in.the protection of the public health'and
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'3 ' sa fety. " End of quote.
4 I hope that your Committee agrees with the Henry
. Commission that quote'"the protection'provided by siting and 6 engineer design features must be bolstered by the ability to 7 take protective measures during the course of an accident."
8 End of quote. l 9 Now, both the Massachusetts Department of Public 10 Safety and the Federal Emergency Management Agency, FEMA, 11 have determined that Pilgrim evacuation plans are not ade-12 - quate to protect the public. To my knowledge, except for (]) 13 maybe one or two other instances, these are the only plans in 14 the country that FEMA has found to be inadequate. Because 15 the deficiencies for Pilgrim are so fundamental and so ex- ! 16 tensive .ts documented in a 100-page report by Secretary of 17 Public Saiety Charles Barry, substantial work remains to be 18 done. L ) 19 I urge you to insist that workable emergency re- , l r 20 sponse plans be in place and that no exemption be given con-21 corning the requirem,at of a successful drill before restart [ 22 is auttsrized. ; 23 It makes a sham, frankik, of the entire emergency 24 planning process to allow a plant to operate before adequate l i 25 plans are developed to protect people in case of a bad Heritage Reporting Corporation ; imi.a a
r ( d I < accident. To do so'is to play Russian roulette with people's kj 2 lives. D ~ 3 Now, NRC commissioners in testimony to Congress 4 labeled Pilgrim one of the worst managed plants in the nation. 5- And the recent SALP which places Pilgrim with the 12th SALP 6 average in the nation has provided little solace frankly to 7' the residents of communities surrounding Pilgrim. If Pilgrim 8 received such a low evaluation when it was not running, what 9 should we expect if it is allowed to restart. I'm especially to concerned about management performance when faced with real 11 unanticipated problems such as the loss of offsite power last 12 November which you addressed earlier today as I understand () 13 it, Dr. Ker.. () 14 Citizens of Massachu<etts are disturbed that the 15 NRC appears to be willing to go to any lengths to encourage 16 the operation of nuclear power plants. The NRC often acts 17 more like an advocate than a regulator. We've reached a sad 18 state of affairs when the public has no trust in the experts 19 who are supposed tc protect them and assure the proper opera-20 tion of these plants. 21 I hope and trust that you will utilize your exper-22 tise and your influence to assure that' Pilgrim does not re-23 start until and unless all the cutstanding reactor safety 24 issue.a have been corrected. Until workable emergency re-O(]) 25 sponse plans are in place. And until management has Heritage Reporting Corporation (M3) 6N 4400
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s 196 y demonstrated a substantial improvement-in its ability to 2 Perate Pilgrim safel l . 6 O 3 Thank you very much. 4 DR. KERR: The next'name I have is Mr. Conlin. Is 5 Mr. Conlin here? Oh, are you Mr..Conlin? 6 MR. CONLIN: Yes. 7 DR. KERR: Oh, I'm sorry. 8 MR. CONLIN: Good afternoon.
, I just want to say in the beginning that'this isn't 3,
intended for any one of you personally at a.11. And I don't g, want you to take it personally. 12 It's been quite a journey for the last two and a
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g ins; 6 the NRC for about two years. Very good people. They 15 want to see the right thing be done. I'm director of We the People, Inc. It's a , 16 national organization with offices at 50 Court Street in l 37 18 Plymouth. We are already known to you at the NRC because i our attorneys and private investigators have uncovered docu-20 montation that substandard material including pipe fixtures i were sold to plants, including Pilgrim, and Seabrook as well 73
.g as thirty-six other plants throughout the country. In some !
ar as they have alrnady been tested. These fixtures '. hat have 23 i been used by thirty-eight reactors is failing today in some areas. - O . Heritoge Reporting Corporation - (Mt) 6M aset
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}gg I We are here today to urge the NRC to cease and de- ~ (3 %! 2 sist the efforts to reopen the troubled Pilgrim nuclear power O 3 plant until after the November state-wide referendum comes 4 to a vote here in Massachusetts on the issue of whether this 5 plant should be allowed to operate. This~ plant is unsafe to 6 operate. Although Boston Edison has spent $500 million re-7 pairing the reactor, they have not spent one cent to replace 8 the faulty equipment in question.
9 .If this plant goes back on line in this condition 10 America's hometown may become America's Chernobyl. We have 11 witnessed the NRC's behavior with respect to Seabrook and the 12 politics that have been' played to turn that plant on. We O >> eeeece eo11tice1 = eive i= v er ===oueceme=t or e vo id1* 14 mid-October restart date for Pilgrim. Conveniently, you had 15 proposed to turn it on just two or three weeks before the 16 referendum comes to a vote. This is an insult to the people 17 of Massachusetts. By rushing to turn it on in order to in-18 fluence the election, you endanger lives and trample on the 19 democractic principles embodied at Plymouth Rock. 20 Today we urge you to at least wait until the people 21 decide before you decido for them. Such behavior may be 22 allowed among Soviet officials near'Chernobyl, but remember, 23 gentlemen,'you are not just the NRC. Your full title is the 24 Unitdd States Nuclear Regulatory Commission. And need I re-25 mind you that in the United States, the people decide. Heritage Reporting Corporation sma us e g
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200' 1 Please keep Pilgrim closed or find that the people f')s l- 2 will do it for you. 3 I'have to say in my experience over the last two 4 and a half years that the reason why I'm here and t'he reason
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5~ why these people are here is because we feel and know that 6- the NRC are not doing their-job. 7 Now, I don't go on assumptions. I go by facts. 8 And from what the people have told me inside the NRC, there 9 is corruption going on. , s 10 I recently passed a letter to President Reagan last 11 Monday. And I had people inside the NRC that are willing to 12 meet with him privately to tell him about the corruption and show him what really has been going or.. (]) 13 [} 14 Now, there's one way, if people don't believe in ; 15 that, there's one way to find out. And that is, allow me to 16 see the President. And that's really up to him. But I think 17 during the 200th anniversary of the Constitution and being 18 where we are here today, that the question of nuclear power i 19 really belongs to the people. It doesn't belong to you. It l , 20 doesn't belong to the industry. It belongs to us. And I ~ , 21 feel that come November that we, the people are going to set l 22 some priorities in this country and we are going to start 23 right here where America was discovered. ! And if the people feel and if the NRC feels and the 1 I () 24 25 industry feels that the people are not going to have a voice Heritage Reporting Corporntion im> = I
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/ 3 20.1 I in this, I submit to you that you are in the wrong country.
'v/ 2 .Because there's one thing that we have here. We have the O 3 truth. And the industry and the NRC have the lies.. And I
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4 hope--I don't know, you know--I.know one thing. We aren't-5 going to continue to have fence sitting on_this issue. 6 There's only one way to go. And either ycu are for nuclear 7 power or you are against nuclear power. There's no more room g, 8 for any. fence sitters on this issue. 9 The industry alone have proven that this industry lo is uneconomical, it's unreliable, and it's unsafe. Yet, the 11 NRC' and some of our government officials allow this industry ; [ 12 to continue to produce a byproduct that we still have not got () 13 a solution for. 1 () 11 And I'm for business. I'm a businessman mysel f. 15 But I am against any business that jeopardizes the health L 16 and safety of the American people and we can't have a say. 17 You know, it's unbelievable to me, and I think it's very 18 fitting, that the decision on the future of nuclear power 19 be decided in November, beginning right here. Because our l l 20 founding fathers--I can't imagine what they would be thinking 21 today. There is something very, very wrong in our government ( 1 22 and we have overy right to have a say in it. Yet the NRC and i 23 the industry have thrown up road block after road block pre-l venting the people to have a say about the future of their j () 24 l 25 own children. And you don't have to be an Einstein to figure Heritoge Reporting Corporation cmm. . I
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out that this industry is bad for our people. 2 Well, I just want~to ask you--now, I'm sure you'
-3 are aware jus't like some of us are aware that there are some--
4 .DR.-KERR: Do you have some idea of how much longer 5 you are going to talk? 6 MR. CONLIN: Oh, I'd say about six minutes. 7 DR. KERR: You've already talked about ten, i 8 MR. CONLIN: All right. Well-- 9 DR. KERR: I'll give you one minute. ! 10 MR. CONLIN: One minute. l 11 Are you aware of the substandard equipment that's
- 1 12 in Pilgrim right now?
l () 13 DR. KERR We are here to get information not to 14 answer questions. l ' i 15 MR. CONLIN: Well, I don't think you can guarantee l 16 to me today that some of the substandard equipment that was i 17 sold to this plant--you can't guarantee to the people that 18 that isn't going to fail. And I think it's very premature 19 and very ir esponsible to be allowing the utility the right 20 to inspect equipment that was falsified as being tested be-6 21 cause it's to their advantage not to find anything wrong with i 22 it. I 23 Now, I want to submit to you some evidence. One 24 is I want to give you the President's letter. The other I ! l 25 want te give you some quotes that have been given to me by i ( Heritoge Reporting Corporation l
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'l -NRC' people. And two, I'm-gol'ng to give you whatever I'have'
( 2 here. \ 3 DR. KERR: Can you 9 ive tlAt to.us now? s 4 MR. CCNLIN: 'Yes, I_will. I'll give it to you. 5 DR. KERR I don't want to spend the afternoon 6 listen'.ng to you because I think there are other people here 7 who want to talk. " \ 8 s MR. CONLIN: Well, that's the~one thing that we 9'a feel that the NRC and the industry haven't done and they 1 to haven't listened to the people. But I'll tell you, come-11 Noveober we're going to be looking for alternatives to r.. clear 12 power and one of those alternatives is we're going to shut 13 the lights off at the NRC building in Washington and that's f] 14 one place to start and save some energy, because you people ' 15 are not representing the people. (
. 16 Thank you very much.
17 DR. KERR Thank you, Mr. Conlin. 18 Ann Arnold. 19 MS. ARNOLD: Good afternoon. 20 My name is Ann Wakis Arnold and I am here today 21 representing the Commonwealth of Massachusetts, Office of 22 Handicapped Affairs, as the Chairmar of the newly formed 23 Disabled Persons Advisory Group on Nuclear Evacuation. The statewide group was formed in response to lack 24 l 25 of emergency planning for tne one million elderly and/or Heritoge Reporting Corporation i o.a [.*
41/ 204 1 disabled people in this state living.near Pilgrim, Yankee
~h . (V 2 Rowe,'from Mt. Yankee and the Seabrook ruclear power stations.
3 We have met with Boston Edison, Yankee Atomic, 4 Mass Civil Denfense, the Department of Public Safety. We 5 are expected to. choose and work with professional consultants 3 6 to research the demographics of people with disabilities near 7 nuclear plants to deterhu c *S'tir needs in the event of an 8 cmergency, to determine which people cannot be evacuated, and 9 to determine the attendant risk in remainint; here they are. 10 There are no real plans at this time to evacuate 11 this population. This blatant discrimination is illegal as 12 well as immoral. Q 13 Some of the people who are left out of planning O i4 ere veovte wno ere 9ar ic 117 ai ebtea, ene enouee#ae or 15 medically f: agile elderly citizens, people with development 16 and mental cisabilities, people who have problems with hear-17 ing, vision and speech. People at home with temporary long-
- 18 term disabilities. People in acute care facilities or hospi-39 tals. People in long-term settings, nursing homes, group 20 homes and institutions. Disablad people who are transitory 21 in and out of the EPZ an1 who leave their place of residence .
22 for schooa, sheltered employment or adult day-care services. 23 School children needing special assistance in public schools. 24 Day care centers and collaboratives. And people who need 25 special medication, foods and equipment. l Heritoge Reporting Corporotion o.r. . .=
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I Many of these people could be t$e children, parents
*2 or grandparents-of people in attendance here today. The U.S.
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Disabilities Centers in the Census tell us that 20 percent of 4 ourpohulationhavedisabilities. We are considering that 5 -16 percent of these people will need assistance during an -
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6 evacuation in the event of a nuclear accident in the state.- l 7 There are over 94,000 people in the EPZ'and 16,000 8 .of those are people with special needs. 9 xAfter initiating meetings for the past four years 10 with Boston. Edison, Civil Defense and the Department of 11 Public Safety, it is clear that we still have no provisions 12 for identifying, alerting er evacuating the sizeable dis-O '1ea e 9"1 ti " 1" *ae tez-
>> 8o e = sai o", 19 "ori"o o"r
- 14 suggestions and offers <>f assistance, circulated their own is incomplete survey which was designed in such a way as to 16 ~ exclude most people with disabilities. It was not even 17 disseminated in a form accessible to people with visual dis-18 abilities or low reading skills, and was not even sent to 19 overy home in the EPZ.
20 of course, they only came up with a small number of 21 800 people in the entire EPZ. They incorporated these small 22 figures into their evacuation time estimates showing that 21 people w.uld be able to leave the area in six and a half 24 hours. The reality though is more like 16,000 people, twenty 23 times that figure, making the real evacuation time estimate Heritage Reporting Corporation (MI) 4M e400
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\ 2 It is very clear that Boston Edison has no connit-3 ment to assist in planning for people with' disabilities and 4 in fact seem them as expendable.
t 5 For four years now I have testified to the NRC at i 6 hearings such as this that Edison has refused to comply with 7 new regulationc to alert and notify all segments of the popu-8 lation' including deaf and hard-of-hearing residents who are 9 not able to hear the sirens. And for four years the NRC has 10 done nothing to enforce their own regulations. 11 Deaf and hard-of-hearing people to this day have 12 no equipment to alert them in case of an accident'at Pilgrim (]) 13 I. We seem to have a regulating agency who is not capabic (} 14 of regulating the utilities. 15 The NRC in their wisdom haa also approved the use 16 of potassium iodide to be given to people who will have to 17 stay behind. This is not what I consider a safe evacuation 18 plan. It is NRC's way of avoiding facing the problem of evacu-19 ation and it may solve their consciences, but it is not a 20 Lolution.- 21 As you know, this drug is only 60 percent effective 22 if taken within one hour of a radioactive release and is only 23 effective in partially protecting the thyroid from radioactive 24 iodine. It may cause severe allergic reactions including ; O 25 hemorrhaging and death. This is inhumane and totally f Heritoge Reporting Corporation - imi m l
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- 1 3 unacceptable to.most. people in this country. We all know :
[}N'(- 2 there are many, many'. kinds of radiation that would sprew
, l 3 out during an accident. Are the thousands of.. people supposed 4' to sit home while everyone else tries to leave their town, 5 locked in their houses with their windows closed, swigging 6 down their bottles of pottasium iodid'e? 'You can imagine the 7 frustration of disabled and elderly' people who are both shut 8 in their homes and locked out. of this process. +
9 The last time I testified before Dr. Bellamy of the < 10 NRC I requested a copy of the State of Connecticut's plans l 11 which ne stated had, quote, "Full, final, signed, certified 12 and delivered approval.'" I was not surprised to find that , O >> eaeir 9 1 e cor ve ete with eec$et =eea were su e e=etr 14 as the plans here. They have never really even identified 15 pocple with special needs. What does this mean? I think 16 it's clear that the NRC has and continues to license nuclear l 17 plants without evacuetion plans that work for people with ; 18 disabilities, i 19 Last February the Office of Handicapped Affairs i i 20 submitted a proposal to Boston Edison, Civil Dcfense and ' 21 Department of Public Safety to begin the process of preparing ; i. 22 to evacuate the elderly and disabled. We feel it was an l 23 appropriate and cogent scope of work to be carried out by j 24 vendors with expertise in disability issues and will be a rea] ; [ 25 first step in this country in dealing with a massive task of i l l Heritoge Reporting Corporation ; tmi m .m i l
t) . - , .L > f300 ' I addressing the' problem'of evacuat'ing' people who are vulnerable , n ' 2 However, after many months of meetings with Boston Edison, 1 3 Civil Defense and the Department of Public Safety,.the utility 4 rejected this proposal. You may have heard that Edison,and ., 5 , Civil Defense have recently proposed their own survey for 6- identifying people with special needs. The Department of 7 Public Safety has demonstrated to me that they are quite dis-8 turbed by the fact that the Office of Handicapped Affairs has 9 said this proposal is irresponsible and will not work and we 10 do not support it. And they are attempting to get the Office 11 of Handicapped Affairs to backtrack, but there.is no way that 12 we will back down from our responsibilities to advocate for C 13 the health and safety of the one million people we represent No matter what the practice of other Q 14 here in Massachusetts. 15 state agencies or the NRC may be. 16 It seems to me that some state agencies and Boston 17 Edison are working hand in glove in attempting to prepare a 18 plan which gives the illusion that they are actually prepar-19 ing to evacuate this population. But they don't have the 20 support of the people fc: vhom the survey is being done. Nor 21 do they have the support of the state agency who represents 22 these people.
?? l But don't allow yourselves to be misled or de-d 24 ' ceived. It is only a masquerade of a plan to make plans.
25 It's my responsibility to point out to you that the Emperor O Heritage Reporting Corporation m as
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.i 1 has no clothes'.. Elderly and disabled pe.'ople living hear.
. b' 2 Yankee Rowe, in western Mass., the oldest running nuclear h'- .3 plant in this country, are in the'same boat we're in here in
-4 Pilgrim'I.
5 In Nazi Germany many of.the first to die were-6 handicapped people and I see an unfortunate parallel here 7 in this country. Nobody really cares. However, as long as 8 we have a voice in this process and can come before the TV 9 cameras and the press, we will reveal these policies for what 10 they'really are and we will do our very best to use the public 11 support that we have to ensure that Pilgrim I does not 12 operate until and unless there are safe evacuation plans 13 for all people. l l h 14 I'd like to speak for just a moment as a Plymouth l 15 resident. I think that you know that Pilgrim I continues to l 16 be one of the worst run plants in the country. You know that 17 oven your agency has said there is a 50 percent chance of a l is serious nuclear accident in this country. But I and you 19 should know that if you permit the restart of Pilgrim I there 20 is a good chance of you signing our death warrant. Conse-2 quently, many people in Plymouth hold you personally and pro-22 fossionally accountable for any more harm that comes to us, 23 our loved ones, and our children, if you advise the restart 3 . 24 of this dangerous plant. 23 Thank you. Heritoge Reporting Corporation i inn. I
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- DR. KERR: Mr. or Mrs. Fales, F-A-L-E-S?
O n (-- - 2 MRS. FALES: Good afternoon. 'My name'is Eton Fales. 3 And I'thank you for the opportunity,to speak. 4 You have heard substantive and' full details for the 5 reasons by Pilgrim should not be reopened at this point. So 6 I won't attempt to bore you with repetitions. I'm only a 7, resident, a voter and a taxpayer in Duxbury, Massachasetts. 8 -' And I can see Pilgrim plant from the place where we swim, 9 from our house, from where my grandchildren come to visit us, 30 and I would urge you'to consider very seriously not to re-33 open that plant. 12 It presents a danger to life, health and property, and there is no realistic way to evacuate tens of thousands (]} 33 () y of people, from the handicapped to the elderly to school , 15 children to just ordinary Americans who happen to be in the 16 part of a radioactive accident. There is no way to get these 17 people from the Plymouth area, from the Cape and the islands 18 or for that matter from Boston, which is only forty miles i, away. The Greater Boston area is very near, and the wind has 20 never heard of a ten-mile limit. The wind just blows across 21 Cape Code Bay into Massachusetts Bay and into Boston. 22 I have read that there is an eighty kilometers 23 radioactive area around Chernobyl which will remain a ghost 24 area for ten thousand years or more, which is an eternity to the average citizen. When I think of our beautiful bays, <
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n.1 .i.i ev > I Plymouth Bay, Kingston' Bay, Duxbury Bay, Pitcock Bay, Massa-
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2 chusetts Bay, t e~ town of Plymouth,.where our entire American fs, .- , k / 3 history began, when I thin'k'of all that' treasure, a nat'ional I 4 treasure, that could be laid' waste,.I urge you all directly . 5- and personally, whoever you may be, whatever function you may . 1 p 6 have, you.are all' Americans. You all have children. You all ! 4 7 have lives and people to protect. I urge you to show your , 8 patriotism that you keep F11 grim closed.
- 9 Thank you.
4 10 DR. KERR: Is Mr. Robert Reed here? i 11 MR. REED: Good afternoon. 12 My name is Robert Reed. I'm the town Administrator * () 13 for the town of Kingston, and I'm here to of fer some brief () 14 remarks on behalf of the Kingston Board of Selectmen. 15 Kingston is the town immediately north of Plymouth 16 and lies for planning purposes I believe entirely within the 17 ten-mile EPZ. The Kingston Board of Selectmen opposes the 18 restart of the Pilgrim nuclear plant until an approved and 19 tested emergency, radiological emergency response plan is in l
'O place.
21 Thank you. l 22 DR. KERR: Is Kathleen O'Brien here? 23 MS. O'BRIEN: My name is Kathleen O'Brien and I 24 come before you as a member of Duxbury Nuclear Affairs Com- i l O 2s mittee and I am speaking from my own personal point of view Heritage Reporting Corporation ! om sn au ;
af 1 i # M13 l' and from my perspective asia registered nurse as my back-
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g And I would lik'e.to mhke a, proposal to you that I 4 ! use'a medical metaphor today to make my point clear. If you
'. ,i 5 will please imagine yourself'and I'were in a reverseyposition ,
- 76. where I.am sitting as a registered nurse with other technical 7 experts with medical backgrounds taking statements from you.
8 And you find yourself in the albeit intimidating place of 9 attempting to plead your case feeling inadequately equipped to to address the crisis facing you. . A hypothesized situation
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11 that you've been diagnosed as having ARC, which is aides 12 related complex for those not familiar with the medical acro-Q 13 nym. This syndrome develops when in the presence of anti-O '4 doate to the ^'os viru tor = 1" re vo#ee to *ne virue- 'aere 4 15 are developed sign.s of a depressed immune system among others 16 and I would further liken this to the Pilgrim nuclear power 17 plant as a metaphor of developing' signs of fatigue, broken
- 18 parts, the first line of defense has been pentrated, and the j 19 back-up systems have begun to fail. The signs progress to
! 20 the inevitable underlying systems of the disease which is l 21 generic problems. For instance, the scram leading to the . 22 '86 shutdown which is the question, are we in remission? 1 23 Attempting to treat the symptoms of this terminal illness?
- 24. Continued contamination and failure of mechanics persist.
25 The disease has been contracted by Pilgrim and has spread to
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Y 213 J _g the NRC which manifests signs' at this point of ,having a com-
. s) 2 plex. ,
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Yoa.are facing a' disease of catastrophic proportions
,3 with a, terrifying prognosis.: We are .to [f$ce the complex 4
issues involving, conscience affects morality. If these are not 5r
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, enough weighty' issues to be considered, you must also face 7
the financial catastrophy facing k.he indi'vidual and society. g You are in a position to prevent the spread i o'f this' disease
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9 to any future generations of nuclear plants which exist or which might.be on the drawing board. And I would like to ask 10 you to what extent you are going to allow this illness to 12 Spread. 13 DR. KERR: Ms. Diane Buckbee.
,4 MS. BUCKBEE: My name is Diane Buckbee. I'm here to testify on behalf of Citizens Urging Responsible Energy.
15 I als came here as a mother of three very small children. ( 16 Wo live about three miles from the plant. If Pilgrim is { g
,g allowed to reopen in the near future, the Commonwealth of Massachusetts has lef t my children defenseless because of their lack of a workable evacuation plan.
20 It is Boston Edison's abysmal record in running the 21 g plant that makes these evacuation plans so necessary to the ~ community. g I'm angered that citizens like myself are forced O 3 to shoulder the responsibility for protecting our own safety. Heritoge Reporting Corporation
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...; .I We don't have the exper tise that state and federal agencies -;
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\-- a 2 have at.their disposal, yet here we are again today trying.to
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\) 3 do a job we really aren't' qualified to do.
4 -I would like to mention some areas of concern re-5 garding the' restart of Pilgrim. One question before I even
'6 get into this. It was interesting for me .ta) hear.you say you 7 are not here to answe'r questions. You.are here to gather in-
'8 formation. When people like'myself bring up areas of concern, 9 do you want us to document that for you or do you do that
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10 yourself or how does that work? You have all--this information b! il available to~you, that's what I'm assuming. Am I right? I
. 12 hope.
() 13 DR. l' ERR: I don't think we have all.the informa-
) 14 tion and that's not the question you are asking, of course. ;
15 We are=here to try to gather information. There are certain , , 16 questions which we could answer but if we spend the time i 17 answering questions we wouldn't have time to hear everyone. - 18 MS. BUCKBEE: No, no. I don't expect an answer. l 19 That's not what I meant. I meant when we bring up areas of ; i 20 concern, do you expect us to provide you with the documenta- i 0 L ! 21 tion for that? You'll do that yourself? I r i' . 22 DR. KERR I don't expect you to bring it up unless 2J' you have something that's available, like literature-- 1 i l 24" MS. BUCKBEE: Okay, good. \ I (} 25 I'd like to ask that you would look into and review
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d; I 25 I the documentation concerning the RHR valves and cracked hous-2 ing. I understand recently Boston Edison did send that hous-n
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3 ing to MIT to have it tested and I'm sure they would make 4 available to you the results of that. It's had a long his-5 tory of many, many problems. 6 I'd ask that you also look into the standby gas 7 treatment system that's historically'been a problem at Pil-8 grim. During this SALP period BECO chose to refuel when a 9 design deficiency went uncorrected. I ask that you check to 10 make sure this has been corrected and that things are in 11 working order. 12 i I would also ask that you would review all documen-() 13 tation concerning the original incidents that caused the () 14 April shutdown. Have they been resolved or have they over 15 . even found out exactly what caused the initial shutdown, 16 these crams back in April of '86? 17 When it was discovered BECO had never tested circuit 18 breakers in the life of the plant, they were only given a 19 Level 4 violation which, as you know, 5 would be the least 20 uo it was more or less a slap on the hand. This was after 1 21 having discovered that circuit breaker fuse boxes and other 22 electrical equipment there might possibly be bogus. It may 23 have come--in fact, sone of it apparently did come from a I x 24 (J x- 1lcompanyinOhiothathadbeenfalselylabeledbadmaterial. I would ask that you look into whether DECO has 25 i 0 Heritage Reporting Corporation m m me l
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21G 1 I tested all electrical equipment, every' thing, in the plant. - p 2 As we all know, circuit breakers and fuse boxes are all safety O,. 3 related. 4 Piping was sent td Pilgrim that apparently had been 5 falsified,~ standards had been falsified and some of the piping 6 was bad. Has that all-been t!ested? Has it been'X rayed or 7 'whatever it is that's normally done,; all of it, before we j 8 start? Has it been tested for corrusion and cracks?
, 9 A worker in Pilgrim was fired for changing a radia-10 tion reading. I'm not sure what. month it is. I could get 11 that for you. Why was the supervisor not fired? And more 12 importantly, what caused the elevated radiation reading in mea rou=ar There ao
-O i> the arv wett enee tattietty eat
**e re atas O '4 =e=etoa or thet et ett- 3" * **et he ret iriea 15 and was let go.
16 And I would be curious to'know why the reading was 17 elevated anyway. 18 Also is there any indication that changing radia-19 tion reading is a routino practice at Pilgrim? Has that been 20 investigated and looked into? 21 On November 12th of 1987 BECO lost offsite power 22 for twenty-one hours. They had I believe one diesel genera-23 tor down and one backup and I believe another one was being 24 put in. As I say, the loss of offsite power went on for 25 twenty-one hours. And according to NRC material, apparently O Heritoge Reporting Corporation (let) 4M este
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i r i that's a very dangerous and, vulnerable time for a nuclear , em What has bben done to assure us that that will
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b 3 never happen again? 4 Fire protection, radiation control, the integrity 5 of the containment are all areas ~ of concern. And these are 6 only partia1 lists.
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Boston Edison Corporation has not shown itself.to 8 be honest.or forthright in its.. dealings with this community. 9 I don't feel that they are ready for restart and I ask that 10, you consider the safety of this community first. 11 Thank you. 12 DR. KERR: Joe Kreisburg?: () 13 MR. KREISBURG: Thank you for the opportunity to l () .14 speak today. My name is Joseph Kreisburg and I am the Re-15 search Director with Massachusetts Citizens for Safe Energy. 16 We are a coalition of thirty citizen groups around the state 17 which came together to sponsor this fall's initiative Question 18 No. 4 which would close the Pilgrim reactor here in Plymouth l 19 and the Yankee Rowe reactor in western Massachusetts. l. 20 We believe the Pilgrim reactor should not be re-opened. 21 We are deeply distressed that the ACRS and the NRC 22 would even consider allowing the plant to reopen when serious 23 safety and management problems remain unresolved. Four major 24 issues stand out. First, emergency planning. Emergency evacuation plans for Pilgrim are completely unworkable. (} 25 The Heritage Reporting Corporation
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, I plans are so poorly designed that Governor Dukakis and the 1
2 Federal Emergency Management Agency.have both. withdrawn their , 3 support. We are shocked that the NRC is essentially bypass-4 ing this issue and proceeding with restart. We believe that 5 doing so violates the spirit'if not'the letter of the NRC's 6 own evacuation plan and regulations. More importantly, doing 7 so puts at risk the lives of thousands of people. The NRC ' s and ACRS and others may be tired of hearing of this issue,
.9 but it will not go'away until it's resolved.
10 . Secondly, Pilgrim's containment and other safety 11 issues have not been fully resolved. The design problems
- 12 with Pilgrim's General Electric Mark I containment remain.
^ cordi"9 * "e ""c O >> t i= *^t c "* t"=e"* " "
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,0 i4 vercene chence ef fa11ere in en eccidene end e erookheven 15 National Laboratory study says that the containment is quote
, 16 "virtually certain to fail." Many scientists believe these l 17 problems cannot be resolved. And while Boston Edison has la completed some changes to the containment system,.we have no 19 assurance that they have corrected the fundamental problems 20 with the Mark I design. 21 The NRC staff is now preparing a list of recommenda-22 tions for how utilities can upgrade their systems and at the 23 very least the NRC should wait until this report is available 24 and its recommendations impicmented before considering re-25 start. Heritoge Reporting Corporotion (H3) 6M eese
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I Boston Edison should also be required to complete r k~)/ . a probabilistic risk assessment to determine the likelihood o 2 .i
'3 of containment failure during"an accident.
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. 4 other safety issues also need to be resolved.
5 Could there-be wind power' fluctuations like there were at the :
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6 LaSalle plant earlier this year? Have all the pipes been ; 7 checked to make sure that they are operating and functioning l 8 properly?' And has embrittlement been examined and are we i 9 satisfied that there,is no cmbrittlement in'the reactor. 10 The only way to address these concerns fully is to
- II -have an independent investigation and a adjudicatory hearing.-
12 At the very least, the ACRS should take it upon itself.to-l () 13 fully investigate these concerns and the NRC should wait un-f l () 14 .til the ACRS has issued a recommendation before announcing l 13 its intentions. ! 16 Finally, or thirdly, management problems remain. 4 i i . j 17 We have no confidence in Boston Edison's ability to safely [ l 16 manage Pilgrim. It has taken Boston Edison two and a half l 19 years and $500 million to get ready for this inspection. l 20~ During this time period there have been more than a dozen 21 scheduled delays and budget revisions. The most recent NRC l 22 SALP report gave Pilgrim's score far below the national t i 23 average. Pilgrim'a average score of 2.0 was much higher than l i l 24 the average 1.7 and it was the thirteenth worst score among i 4 ( ' {} 2$ the 102 operating reactors in the U.S. which have SALP scores. , Heritoge Reporting Corporotion l tr.o m t
g, l' o "' I / z 220 1 In the SALP report the NRC gave Pilgrim the lowest possible
-: 2 . score for radiological controls, an areatwhere' Pilgrim has M
4\ /- 3 historically been'among the worst in the country. We-find ,
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4 this to be an appalling record. ,,: 1 g 5 And despite these poor' score, Boston Edison has 6 cited the SALP report as evidence'that Pilgrim is' ready. Mr. s
/,' 7 S. J. Sweeney sent a special note to Mr. Ralph Bird to' extend l i
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8 .his quote "congra,tulations." Mr. Sweeney? told Mr. Bird that I 9 ! . he and his staff, quote, "Have a right to be proud of this 10' accomplishment." Such statements reflect low standards, not i I 11 solid performance, and suggest th'at dangerous levels of com- } m .
' 12 placency among Boston Edison's management. !
) ((]) 1 13 Finally, politic versus safety considerations need i 1
'( ) 14 to be looked at. We~are concerned that Boston Edison is 15 rushing to restart the plant before November 8th in order to 16 influence the voters. Doing so would-compromise safety con- i t
17 siderations for political considerations and seriously [
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- 18 threaten tho lives of thousands of people.
l 19 There is no reason to move forward with the risky ; I < ! 20 process of restarting Pilgrim in October if in November the
- e 21' voters decide to close the plant permanently. I I
22 Therefore, in order to avoid the implicit conflict , f 23 between political and safety considerations, or even the l l t l ( p 24 public perception of'such conflict, we urge the NRC and Boston i l U h 25 Edison to consider the people's vote in November and delay [
)
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lj ~ making a decision on restart. The NRC's apparently willing-
- 2 nass to allow Pilgrim to restart in spite of this shows that l 0e D' - 3
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once again the NRC is more interested in the health of the 4 nuclear utilities'than the general public. . Allowing Pilgrim 5 to reopen despite the unresolved problems with evacuation [.* 6 plarining , the containment system, plant management, is like 7 allowing a high school senior to graduate even if he is fail-ing math, English and history. And by allowing restart with- ' s i .
.9 out allowing any opportunity for public comment, the NRC ex , ,
o- 10 Poses itself for what it has sadly become, a kangaroo court
, i
- is stacked against'the public. ;
The NRC's refusal to address the very-real safety. 12 l gi problems at Pilgrim, the continued squandering of hundreds I c O n of 1111ons of do11ere et e11erim end venkee Rowe end the < is , coming nuclear waste crisis have prompted 120,000 citizens
- 16 to sign petitions to put Question 4 on the ballot. We have I,
! 17 petitioned NRC to keep Pilgrim closed and were rejected. l 18 Obviously we cannot rely on the NRC to protect us and thus [ i g, we must let the people decide. It is our lives. It is our {i f, l o
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20 money. And we say keep Pilgrim closed. - I 21 Thank you, l i i 22 DR. KERR Pricilla San'Jston? l I : MS. SANGSTON: No, Mary Ott is here now. l ) 33 ! 1 l 24 DR. KERR: Is she speaking for you or-- l 25 MS. SANGSTON: No, Mary Ott is speaking for herself. !r , i Heritoge Reporting Corporation (
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( l MS. OTT: Evidently someone signed me up early. I
,a 2 had called in that I would be late.
- r 3 -Good. afternoon. My name is Mary Ott,.:and I'm a
. 4- resident of Duxbury. I am the co-chairman of the group callbd 5 Duxbury Citizens ~ Urging Responsible' Energy. My co-chair is 6 Dr.' Donald Murhead, Jr.
7 Diano Buckbee of Plymouth, who spoke earlier, is ,; 8 the President. i 9 He appreciate'this opportunity to speak before your I 10 committee and to raise questions regarding the safety of the l
- 11 Pilgrim Nuclear Power Station. But we object to this process,
~
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. 12 The SALP Review Table 'of Meetings creates an illusion of 13 public access during the restart process. But in fact it f 14 isnft true because there baan't boon any public notico posted [
l j 15 of this meeting and no real invitations to participate. It's l 4 16 one of the reasons my notes are all in writing and I am per-i l 17 haps somewhat unprepared. But actually we feel this meeting 4 18 nas been a well-kept socrat and that if it had.been advertised l i 19 more people would have taken advantage of sharing thoLr cor.- s l 20 corns with you, i 21 I must call to your attention that the reason we 22 are before you Eoday representing thousands of people who f . 23 live in the shadow of Pilgrim is becauso we have been unable ! 24 to resolvo our concerns with the Boston Edison Company or the
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Q 25 NRC officials in Region I. ! Heritage Reporting Corporation im>.a .
p- :m e r . s .y . 1 My husband and I at one juncture in this two-year struggle even went to King'of Prussia to meet with the PRC and
, 2 3 found to our surprise that some of the questions they said [
4 they would surely answer were not answerable and I have still
! not been answered. ,
4 6 I began my quest for answers as an individual con- ; 1 ;
-7 cerned about the number of unusual event accidents I was read- ,
[ s ing about.in the newspaper. When questioning BECO about these , [
~ , < 9 they responded that they'didn't have the number that occurred, q t to they responded that they didn't have those figures with them, l 11 and Mr. Richard Steristecki of the NRC was present and he i r
i 12 raid there couldn't h' ave been as many as I imagined. They wouldn't have had four or five in even a two-year period. So lO 13
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eaareathevoticetos O '4 twe=*decxtothe"eweeer i
- 15 discovered that between the spring of 1985 and 1986, there f
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!' 16 were nine unusual event accidents at Pilgrim.
- 17 We became quito concerned at that time and suspi- !
i la clous and so we formed our group and began to research Pil- [ i, grim's hiatory. And we've been trying to find out the truth f L to ever since. 21 The NRC has told us that the accident that shut i 22 Pilgrim down was just a hardware malfunction. And I see [ c 2 documents in the library reveal a different story. That the { 23 e 24 Potentiel existed for an intersystem loss of coolant accident f O 25 outside of containment. That there were unnecessary ,. J> c I Heritoge Reporting Corporation mm _ _ _ - . _ _ ,-_ _ _ __.._,,, ,_.m_..,_, _ ,___ __,_ _ _ _ _ _ _ _,,__,,__.~,,_.,,c_____ _ . _ m.___.
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g challanges to safety systems, gross Jeakage, failures of main im (- 2 steam isolation valves, all of which centributed to a pres-
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3 surization of the plant's residual heat removal system. 4 According to the SALP 86-99, pages 2 and 3, this 5 ovent was proceded by serious operational occurrences which 3 should have been an indicator of the trouble to come. 7 1 can quote from that. "The unit began the evalua-a tion period- " This is January 3rd 1986- "operating at 100 9 percent power. On January 3 a reactor shutdown was initiated 10 to investigate increasing main turbine generator bearing
- fibrations. Three days later on January 6th the reactor was 12 restarted af ter completion of main steam isolation valve ad-
,} 33 justments and bearing maintenance. During the startup the O i4 reector scremmed frem 1o eerce=t vower en 1ow vesset weter is level due to feedwat.or control valve leakage and operator 16 error. Startup commenced on January 7th and full power was 17 eached on January 10th. Leaking hydrogen ignited during is the reolacement of a regulator in the main turbine generator g, nydrogen supply system on January 9th. On Januhry 16th an l
20 automatic scram occurrod due to a spurious reactor high pres-
- , sure signal when a technician inadvertently bumped an instru-
;; ment. The restart began two days later on January 18th and 1]f 4
full power by the 20th. 33 btheunitwasoperatingat 34 A severe fibration transient in a main turbine generator bearing forced reduction to 10 percent power on d{)v 25 [ h , n o i y Heritage Reporting Corporation j mr u.
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i January 29th. The unit was, returned to full power following 2 turbine generator adjustment. On February 13th in response O 3 to recurring residual heat removal discharge piping high 4 pressure alarms, the licensee temporarily removed the RHR I 5 system loop from service. Severe water damage was identified [ 6 ln a portion of the RHR piping on March 7. The effective e 7 piping had not been used for several years and was subsequent- r i 8 ly removed intact. 9 On March 15th the reactor was shut down due to a i ] to leaki coactor vessel instrument line weld. The weld crack 11 was located and repaired. While shut'down, a spurious primary i 12 containment group one isolation occurred. No cause for this [ t i O >> i oi tio= taeatiriea- rae re ctor re t reea ixtee# O '4 aer 1 ter o# a rca 31- ^ ia turbi#e av areu11c v te-l
- 15 oil leak resultad in a unit shutdown on April 4th.
16 During the shutdown a spurious primary containment 17 group one isolation occurred again. This isolation caused L 1 ; i 18 an automatic reactor scram. Initial attempts to open the j 19 Outboard main steam isolation valves were unsucccssful. The
- t l 20 reactor was taken critical on April 10th. Reoccuring HRR }
+
j 21 systems discharge piping, high pressure alarms prompted a
- 22 plant shutdown on April lith. A third spurious primary
! 23 containment group one isolation occurred during the shutdown ! ( ! 24 and the outboard MSIVs could not be r'.pennd. This isolation l [ 25 also caused an automatic reactor scram. j Heritoge Reporting Corporation g m m.= c
dbO I NRC issued Confirmatory Action Letter 8610 as a ( ) 2 result of these reoccurring events to maintain the plant in x-q'_) ( 3 shutdown condition until the NRC could review in detail and 4 ! understand the causes of these events." l 5 It is our understanding that this letter is still 6 open, no apparently all the problers of April have not been 7 resolved. 8 It is interesting to note that the NRC has failed 9 to include in the summary of activities that I just read that to an unusual event accident occurred on February lith 1986. At 11 that time improper management control of maintenance work 12 resulted in reduced primary containment isolation valve re-On >> dundancy and defeated the automatic operation of the low l () 14 i pressure coolant injection system. 15 Although a recent inspection report closed out this 16 item, saying there had been no reports of a similar nature, 17 we disagree. On September 12th 1981 a similar event happened 18 at Pilgrim. It was cited in the Abnormal Occurrence Report 19 to Congress and was one of the reason for BECO's $550,000 20 j record-setting management fine. Failure of isolation valves 21 to close when required during certain accident sequences is 22 said to cause a significant increase in the amount of radio-g! 23 I active material released to the environment. Were there in-24 I creased radioactive materials released in September of 1% 1? Do you want to respond to my questions or should I l qu 25 y l Heiltage Reporting Corporation i <m1 m i
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I just go in and you can record them? O v 2 DR. KERR We don't propose to respond to any of 3 your questions. We're here to gather information and not t'o l 4 answer any questions. ;
$ MS. OTT: I see. Thank you.4 '!
6 Fine. I would appreciate it if perhaps the NRC i t 7 would answer these questions in writing at a later date. _ _[ 8 DR. KERR We'll certair.ly make an attempt. 9 MS. OTT: Well, I will be happy to give the floor l 10 to anyone else who' wants to spetk at this time and come back , e I 11 at a later time if you feel.I'm taking too much time, f
.12' DR. KERR How much longer do you--
=
i ; Q 13 MS. OTT: -I'm not certain. Maybe another five O '4 t""*e - ( i 15 I think it's very important that the statement l'm r 16 making is recorded as part of this meeting. [ i 17 DR. KERR: Go ahead. 18 MS. OTT: We '<ould like to know if there were in-l 3, creased radioactive materials released in September of 1981? ! i 20 Were there increased radioactive releases in the first four l 21 months of 19867 i r 22 A valve failure also happened which was said to be l' 23 a generic concern with GE reactors on 9/29/83, which also f i ! 24 pressurized the HRH system. Were there releases at that time?
- 0 t n
U 23 People have invested millions of dollars in , l Herltoge Reporting Corporation l o.o m [-
c ftj t 9,gg 7 I ~ improvements to their cooling system, yet over two years
- 2 later, this past June 8th 1988, a'large crack was found in 3 their HRH pump housing. A flaw was ' found in A backup sysveni.
q 4 On March 3rd 1988 an outstanding item was revealed that t 5 fatigue cracks had been noted on the RHR drain line. An in-teraal document addressed to Ralph Bird, dated July 8th, 1988, f 7 confirms that not only the housing but also the RHR B valves t 8 This material was sent to MIT for analysis. were cracked. : i 9 The result has not b.en shared with us and we would like to [ 10 know if embrittlement was the cause of this cracking. And if ; it ! so, can replacement of parts ensure the rest of the system is 12 not in similar condition? !O i> eo ton edi on eve tuer mer rix tai grodtem derore ! 34 restart but Robert Pollard of the Union of Concerned Scien-I ! I 18 tists have told us that one of these two systems must be f 16 operational for restart. If embrittlement is found in the ! 17 components of these systems, which is said to be primary for ! l 18 safe shutdown, how can the NRC allow Pilgrim to restart? ( j 19 On August 21st 1986 BECO notified the NRC that they f 1 O had identified a potential design deficiency in a standby !
- i 21 !
gas treatment system. A malfunction of that system would' ! l l 22 also result in higher radioactive releasiis, ifo have obtained [ l i 23 a copy of an internal report from the Company, dated March f 24 2nd 1982, that says that problems with the system are not f l i 1 25 something new and that the situatic.a has existed for almost l Heritoge Reporting Corporation ( i
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)!l 039 I as long as the station has been operating. This design o 2 problem has not been addressed to NRC satisfaction. Yet they O. 3 allowed Boston Edison to refuel the reactor and it is re-4 quired for safe handling of fuel.
5 Will BECO b9 allowed to restart Pilgrim before.this 6 system which ensures public health and safety is properly 7 designed and tested? 8 In 1985 it was reported that workers playing ball 9 with a rubber glove wrapped in masking tape may have caused a 10 shutdown at Pilgrim. In April of 1986, debris, said to be
!! yellow plastic and paper, were found in an isolation valve.
12 A document we obtained through the Freedota of Information Act () 13 dated April 26, 1982 from the NRC to BECO said that personnel () 14 were sent to a leak site with plastic sheeting and tape. Is
^
15 this how leaks are fixed at a nuclear power plant? 16 Numerous NRC information hotices have been sent to 17 licensees rega. ding the possibility of their receiving fradu-18 Xent components from manufacturers. Will the NRC require 19 BECO to complete inspections to ensure that they have none
.0 of these materials installed at Pilgrim.
i 21 Examples are flawed pipe, pipe fittings, defective 22 circlit breakers, corroded pipes, substandard fasteners, and I ! 23 electrical wiring. Have any of these materials been found at I Pilgrim to date? 24 i () 25 And accident at a LaSalle, Illnois, GE plant
- Heritoge Reporting Corporotion
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I prompted the NRC to say that there were significant generic ;
\ 2 . safety implications for similarly designed plants like Pil-O 3 grim.
j 4 Robert Pollard has called for the NRC to modify or l l 5 revoke or suspend the licenses of sister plants until the , r 6 safety issues are resolved. Will the NRC allow Pilgrim to 7 restart before this matter is resolved? 8 The last fifteen months have recorded the same 'l
' sorry history at Pilgrim. Radiation leaks, fire, power out- i 10 ages, work stoppages and 1987 recorded the highest worker i
11 exposure to radiation. The NRC's unprecedented favorable - t 12 comments in the past few' days praising BECO's management i O >> 1eeve them ia a verv teauou voettioa- seceu e o etatae O i4 w111 eo wrone e d thea it 111 certain1v.he e rettection en F l 15 their judgement. Pilgrim is an accident waiting to happen. l 16 And anyone who has read its history are very concerned about , i 17 it. l
- i 18 We hope that you will consider all these matters ,
{ 19 in your judgement. Thank you.
, 20 DR. KERR Does Priscilla Sangston want to make a (
j 23 presentation? ! 22 (No response.) i
- 23 DR. KERR
- Is Senator Golden here? j l
j t i 24 (No response.) !
- E 25 That completes the list of people who have signed i Heritoge Reporting Corporation (
- <=== ;
fh y '. 03 :. s-W N I up to appear. 2 Let me say that I think I can understand the frus-O 3- trations you feel. I have been in a lot of similar situations . 4 It is a national policy set by the Congress of the. l 5 United States'that nuclear power should be developed and 6 should be developed safely. I sense that there are many of 7 you who are against nuclear power no matter what. 8 Congress also gave the responsibility to the Nuclear 9 Regulatory Commission.that it would be safe and it certainly J 10 makes mistakes, as we all do. And as I say this, the NRC is Il a creature of Congress. So if you fl.;d Congress not very i 12 responsive, that's a mechanism that exists if in your view l O 12 e'rie mistexe ere beine mede-14 In the case of the State of Massachusetts it is my l 15 guess that the Commonwealth does want this thing operated, 16 for whatever reasons. 17 Even if you say, and if there is some information i is not available to us 'and to the wmmission which has to go intc 19 the final decision. And the decision has not yet been made. i 20 And I don't have enough information at this point to do so. 21 As I said earlier, we are not NRC or do we have i 1 ' 22 the execu' ive authority--we make recommendations to the Com-
'3 mission. In the main I think they listen to them, and if 1
! 24 they think they have substance, they act on them. We wul O It does have Q 25 certainly try to give them consideration. i Heritoge Reporting Corporotion l
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23 % i serious consequences to all of you.
. 2 And again, thank you for your participation.
3 (Whereupon, the proceedings were concluded at 4:10 4 p.m. 5 6 7 8 9 10 11 12 13 O i. l l is i6 l l 17 I [ 18 19 l i 20 , i 21 i l [ 22 i ; l l l 23 l l00 lll 4 l l Heritage Reporting Corporation
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'l CERTIFICATE 2
cf) 3 This is to certify that the attached proceedings before the 4 United States Nuclear Regulatory Commission in the matter of: 5 Name: Advisory Committee on Reactor Safeguards Meeting of the Ad Hoc Subcommittee on Pilgrim Restart .' 6 7 Docket Number: 8 Place Plymouth, Mass. 9 Date: August 28, 1988 10 were held as herein appears, and that this is the original i 11 transcript thereof for the file of the United States Nuclear 12 Regulatory Commission teken stenographically by me and, ; 13 thereafter reduced to typewriting by me or under the direction 14 of the court reporting company, and that the transcript is a 15 true and accurate reco'r of the foregoing roceedings. 16
~
/5/ 1 11h ($ 5/O'/
$ 17 (signature typed): 18 Official Reporter 19 Heritage Reporting Corporation 20 21 22 23 24 25 () Heritage Reporting (202) 628-4888 Corporation
-e r-t}c SLIDE 1
) UNITED STATES fiUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS TECHNICAL MEETif4G - AUGUST 26, 1988 REVIEW 0F PILGRIM NUCLEAR POWER STATION RESTART ACTIVITIES MEMORIAL HALL 83 COURT STREET PLYMOUTH, MASSACHUSETTS
(, ,) SAMUEL J COLLINS DEPUTY DIRECTOR, DIVISION OF REACTOR PROJECTS, REGION 1 FTS 346-5126 l p () _ l
< 4, .
II, [4RC STAFF PRESENTATIONS SLIDE 2 AGENDA II, tiRC STAFF PRESENTATIONS A, IllTRODUCTION B, HISTORICAL PERSPECTIVE-ISSUES
- 1. ISSUES LEADING TO APRIL 1986 SHUTDOWN
- 2. APRIL 1986 SHUTDOWN, CONFIRMATORY ACTION LETTER (CAL) (86-10)
- 3. NOVEMBER 1986 MANAGEMENT MEETING (86-41)
- 4. SALP FINDINGS (86-99) 5, OTHER ISSUES O
O l ;
o'n . II.A. IfiTRODUCTION EllDE 3
~q IfiTRODUCTION OF f1RC STAFF o SAMUEL J. COLLillS, DEPUTY DIRECTOR, DIVISION OF REACTOR PROJECTS, REGION 1 o ALLEf1 R. BLOUGH, CHIEF, REACTOR PROJECTS SECTION 3B, DRP o LAWRENCE T. DOERFLEIN, PROJECT EfiGitlEER, RPS 3B a
o BRUCE A B0GER, ASSISTANT DIRECTOR FOR REGION I REACTORS, OFFICE OF NUCLEAR REACTOR REGULATION o DANIEL G. MCDONALD, LICENSING PROJECT MANAGER, f1RR g~)s L 1 I
!!.B. . HISTORICAL PERSPECTIVE SLIDE 4 ISSUES PURPOSE: o TO PROVIDE . BACKGROUND AND HISTORY OF ISSUES AT PILGRIM NUCLEAR POWER STAT 10fi IN ORDER TO PLACE PERSPECTIVE Oft fiUCLEAR REGULATORY COMMISS10ft (fiRC) AND BOST0ft EDIS0f1 COMPAfiY (BECO) ACTIONS If1 REGARDS TO RESTART ACTIVITIES.
CONTEXT: o A REVIEW OF PAST ISSUES TO PROVIDE HISTORICAL BACKGROUND. o ISSUES PRESEfiTED HAVE BEEF 1 THE SUBJECT OF BECO CORRECTIVE ACTIONS AfiD f1RC STAFF VERIFICATION ACTIVITIES. o ISSUE RESP 0f1SE BY BECO AND VERIFICATION BY
) NRC WILL BE ADDRESSED IN SUBSEQUENT PRESENTATIONS, l
II.B. HISTORICAL PERSPECTIVE SLIDE 5 BACKGROUND INFORMATION O ON O PILGRIM NUE EAR PONER PLANT Utility: Boston Edison Location: 4 Mt SE of Plymouth, Massachusetts County: Plymouth County, Massachusetts Docket No.: 50-293 CP lssued: 8/26/68 Operating License Issued: 9/15/72 Initial Criticality: 6/16/72 (Based on a 20% power Itcense issued 6/9/72) Elec. Ener, 1st Gener: 7/19/72 t Commercial Operation: 12/1/72 Reactor Type: BWR 3/4 i Containment GE MK! Power Level 670 MWe; 19h MWt Architect / Engineer: Bechtel NS$5 Vendor: General Electric Constructor: Bechtel Turbine Supplier: General Electric Condenser Cooling Method: Once Thru Londenser Cooling Water: Cape Cod Bay Licensing Project Manager: Daniel G. Mcdonald (Telephone: 492-1436) , NRC Responsible Region: Region I, King of Prussia, Pennsylvania s William T. Russell, Regional Administrator , James M. Allan, Deputy Regional Administrator c Div. of Reactor Projects: William F. Kane Div. Director (Tel: E-346-5229) (Region I) Samuel J. Collins. Deputy Director (Tel: E-346-5126) James T. Wiggins, Branch Chief (Tel: ' E-346-5224) , A. Randy Blough, Section Chief (Tel: E-346-5146) r Lawrence T. Deerfietn, Project Engineer (Tel: 8-346-5132) Senior Resident Inspector: Clay C. Warren (Tel: E-617-747-0565) Resident Inspectors: Jef f rey J. Lyash (Tel: -S-617-747-0565) Tae K. Kim (Tel: 8-617-747-0565) I O i
II.B.1 , HISTORICAL PERSPECTIVE SLIDE G ISSUES O MILESTONE CHART 1/80 - 12/87 SALP CYCLE 1 SALP CYCLE 2 SALP CYCLE 3 1/80-12/80 9/80-8/81 9/81-6/82 REP 0aT 4/81
. RED 0RT 12/81 REPORT 11/82 k'
SALP CYCLE 4 SALP CYCLE 5 12/83-12/84 ORDER TO SALP CYCLE 6 INSP 85-30 7/82-6/83 7/83-9/84 OUTAGE FOR MODIFY 10/84-10/85 SAFETY SYSTEM REPORT 1/84 REPORT 6/85 PIPE LICENSEE REPORT 5/86 FUNCTIONAL REPLACEMENT RADIO- INSPECTION LOGICAL 10/22-11/22/85 674 HOURS hIhrk8 11/29/84 I s INSP 86-06 PLANT CAL INSP 86-17 DIAGNOSTIC SHUTDOWN 86-10 AUGMENTED SPECIAL SPECIAL INSP 4/11/86 4/12/86 SAFETY TEAM INSP 2/18-3/7/86 4/12 - 4/25/86 C,, 962 HOURS 574 HOURS i ) BECO SHUTDOWN CAL 86-10 MANAGEMENT MASS. REPCRT CONTINUATION FOR SUPPLEMENT MEETING 86-41 ON EMERGENCY RF0-7 8/27/86 11/24/86 PREPAREDNESS 7/86 2.206 RPT 12/31/86 12/86 PETITION 7/86 I 5 5 ALP CYCLE 7 FEMA REVIEW 2.206 LOSS OF 0FFSITE INSP 87-53 PETITION POWER (LOOP) LOO? AUGMENTED 11/85-1/87 EMERGENCY 11/12/87 INSPECTION REPORT 6/87 PREPAREDNESS 10/87 ISSUES TEAM 8/87 11/16-20/87 380 HOURS 9 O
II.B.1 HISTORICAL PERSPECTIVE SLIDE 7 SALP RESULTS PRIOR TO APRIL 1986 SHUTDOWN (.
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ASSESSMENT PERIOD CYCLE 1 CYCLE 2 CYCLE 3 CYCLE 4 CYCLE 5 CYCLE 6 1/80- 9/80- 9/81- 7/82- 7/83- 10/84-FUNCT10flAL AREAS 12/80 8/81 6/82 6/83 9/84 10/85 OPERAT10llS 2 3 3 2 2 3 RADIOLOGICAL CONTROLS 3 2 2 2 3D 31 SURVEILLANCE 2 2 2 1 1 2 MAINTENANCE 2 3 2 2 11 2 EMERGENCY PLAftfilftG 3 1 1 1 3D 3 FIRE PROTECTION 2 2 3 1 2 - SECURITY 2 2 2 2 2 2 EfiGINEERING O' AND TECHNICAL SUPPORT - - - - - - LICENSING - - 2 1 11 1 TRAINING - - EFFECTIVENESS - - ASSURANCE OF - - QUALITY /QA 3 3 - - OUTAGE MANAGEMENT 3 2 2 - 1 1 O
ll.B.1. HISTORICAL PERSPECTIV1 SLIDE 8 O PROGRAM ISSUES LEADING TO APRIL 1986 SHUTDOWN o HISTORY OF P00R PERFORMANCE l 0 IMPROVEMENT PROGRAMS INHIBITED BY: l (1) INCOMPLETE STAFFING, IN PARTICULAR, 0PERATORS AND KEY MID-LEVEL SUPERVISORY PERSONNEL, , (2) A PREVAILING VIEW IN TiiE ORGANIZATION THAT THE IMPROVEMENTS MADE TO DATE HAVE CORRECTED THE PROBLEMS, l (3) RELUCTANCE, BY MANAGEMENT, TO ACKNOWLEDGE SOME PROBLEMS IDENTIFIED BY THE NRC, AND (4) DEPENDENCE ON THIRD PARTIES TO IDENTIFY PROBLEMS O RATHER THAN IMPLEMENTING AN EFFECTIVE PROGRAM FOR SELF-IDENTIFICATION OF WEAKNESSES. l
REFERENCES:
- 1. SPECIAL SAFETY TEAM INSPECTION 50-293/86-06, REPORT 4/2/86
- 2. SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP) 50-293/85-99, REPORT 5/23/86
- 3. MANAGEMENT MEETING REPORT 50-293/86-41, REPORT 12/31/86 i
i t O !
F g. II.B.1 HISTORICAL PERSPECTIVE SLIDE'9'
"$ ) TECHNICAL ISSUES LEADING TO APRIL 1986 SHUTDOWN i, ,
OPERATING
- 4 1 5 10 15 20 25 30 DAYS
********************************** 30 NOV 85
********************************** 31 DEC 85 JAN 86
***** *****************?******** 28
****************************** 28 FEB 86
******* **** 11 MAR 86
***** ******* 6
- -APR 86 i
l'l l (:) t I 4
REFERENCE:
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP) 50-293/86-99, l REPORT 6/17/87 i i ( O
, 7, II.B.1 HISTORICAL PERSPECTIVE SLIDE _10 TECHNICAL ISSUES LEADING TO 1986 SlIUTDO'TN (COMTIMUED)
Q ~ I UNPLANNED AUT0*.ATIC SCRA*.5 AND SHUT 00kN5 (11/01/25 - 01/31/87) PILGRlM NUCLEAR P0kTR STATION Power ! Date Level Description Cause i 01/03/86 10 % Main turbine generator Equipment failure - l bearing vibration rancom , required a controlled ' plant shutdown for , repairs ; 01/06/E6 Restart
! 01/06/56 1% Reactor r. cram on ves- Operator error and ;
sei low level during inadequate main- ' restart. Causec by tenance - excessive P ' operator inattentive- leakage past feed-ness while manually water regulation ( controlling level and valves ' leaking feed *ater - regulation valves . (LER86-001) i l 01/16/86 10 % With the unit in a Technician error half scram configura-and design , tion for maintenance ceficiency-changecut of a hypersensitive reactor high pressure pressurt switches i switch, slight bu:p - en the second preisure switch caused a false high reactor pressure scram (LER 86-002) 01/29/86 10 % A recurrence of main Equipment fatlure - turbine generator random bearing vibration problems resulted , in a forced power reduction to 10 percent power ,
REFERENCE:
SALP REPORT 86-99 . ? O
.II,B,1 HISTORICAL PERSPECTIVE SLIDE'll
, TECl!NICAL ISSUES !EADING TO 1986 SilVTDOWN (CONTINUED)
O Power
- Date Level Descriotion Cause 03/07/86 100% Weld leak'in the 4" Equipment failure head spray piping required a controlled shutdown to facilitate repairs. (LER 86-005) 03/12/86 Restart -
03/15/86 80% Increasing unidenti- Equipment failure - fied drywell leakage randon required reactor shutdown.
- The 11cen-see found and repaired a weld leak on reactor wat,ar level instru-mentation line.
(LER 86-006) 03/31/86 Restart . 04/04/86 100% A controlled reactor Ecuipment O shutdown due to the cesection of small oil failure - random i leak in the turbine hycrawlic control system. (IR 86-07) . !< 04/04/86 5% During a controlled Ecuipment, failure - . reactor shutdown, spurious actuation automatic closure of the MSIVs cf the Main Steam Isolation Valves
- (MSIV) initiated a reactor scras
( LE R. 86-008)
- 04/04/86 0% Following the rea
- tor Operator error scram described above,
. a second scram signal was received due to
- the scram discharge volume (50V) high level signal
- (LER 86-008) i 04/09/86 Restart O
4
. r . .
II.B.1 HISTORICAL PERSPECTIVE filDE._12 I TECHNICAL ISSUES LEADING TO 1986 SilUTDOWN (CONTINUED) Power Date level Descriotion Cause 04/11/86 93% Indicated leakage from Ecuipment failure - I the reactor water random rer.irculation system !
. through the 'B' loop Residual Heal Removal (RHR) System injection valtes forced a shut-down for maintenance l
04/11/66 10*4 During a contro1Ied Equipment, f ailure -
' reactor shutdown.' s'purtous actuation automatic closure of the M51Vs i of the M51Vs '
initiated a l reactor scram (LER 86-00E!!R 86-07) 04/12/86 C*i A Confirmatory Action l Letter 66-10 was issued ' regarding the April 4 i and April 12 M51V ise-l O 1ations and the RHR injection valve leakage. ! The Confirmatory Action Letter wa s subs ecuent,1y l estenced to cover , correction of signifi- l cant program atic ceficiencies. In July 1986, the licensee l ceciced to continue the ; shutdown into 1387 and l conduct refueling, l install certain Mark 1 > containment enhance-ments, and complete ! 10 CFR 50 Appendix R ! fire protect, ion ! modifications. I i Restart of the unit is i pending NRC authori- I tation in accordance -
, j with Confirmat.ory Action Letter $6-10.
O
I I . B. 2 HISTORICAL PERSPECTIVE SLIDE 13 O APRIL 1986 SHUTDOWN CONFIRMATORY ACTION LETTER (CAL) 86-10 o APRIL 11, 1986 PLANT SHUTDOWN REQUIRED BY TECHNICAL SPECIFICATIONS o WHILE SHUTTING DOWN AN UNPLANNED SCRAM OCCURRED LUE TO THE SPURIOUS PRIMARY CONTA!NMENT GROUP 1 ISOLAT!0fi, THE OUTBOARD MAIN STEAM ISOLATION VALVES (MSIVs) COULD NOT BE OPENED o NRC ISSUED CONFIRMATORY ACTION LETTER 86-10 ON APRIL 12, 1986 AS A RESULT-0F THESE RECURRING EVENTS TO MAINTAIN THE PLANT IN A SHUTDOWN CONDITION UNTIL THE NRC COULD REVIEW lh DETAIL THE CAUSES OF THESE EVENTS AND THE LICENSEE'S CORRECTIVE ACTIONS o CAL 86-10, 4/12/86 REQUIRED:
+ MAINTAIN PLANT CONDITIONS TO PROVIDE FOR NRC REVIEW
, O . OF THE EVENT l
+ PROVIDE A WRITTEN REPORT TO THE NRC PRIOR TO RESTART EVALUATING:
I A, INTERSYSTEM LEAKAGE OF RESIDUAL HEAT REMOVAL SYSTEM B. SPURIOUS PRIMARY CONTAINMENT ISOLATION SIGNALS C. FAILURE OF OUTBOARD MS!Vs TO REOPEN o BECO DECISION 7/86 TO REMAIN SHUTDOWN FOR RFO-7 o CAL 86-10, 3/27/86 SUPPLEMENTED TO INCLUDE OTHER HARDWARE AND SALP-RELATED PERFORMANCE ISSUES: t RESOLUTION OF SPECIFIC TECHNICAL ISSUES O
\
II.B 2 HISTORICAL PERSPECTIVE SLIDE 13 (C0 fit'D) O~ + FORMAL ASSESSMErlT OF THE READitlESS FOR RESTART OPERAT10fi ,
+
FORMAL RESTART PROGRAM AND SCHEDULE
+
ASSESSMEt1T AfiD RESTART PLAff TO BE SUBMITTED FOR l tiRC REVIEW Af1D APPROVAL b 1 II O 6 t l i I
II.B.2 HISTORICAL PERSPECTIVE SLIDE 14 o) (_ APRIL 1986 SHUTDOWN CAL 86-10 NRC INSPECTION 86-17 o AUGMENTED SPECIAL SAFETY TEAM INSPECTION o 4/12 - 4/25/86 IN RESPONSE TO 4/11 PLANT SHUTDOWN o 3 OPERATIONAL PROBLEMS: (1) THE SPURIOUS GROUP-ONE PRIMARY CONTAINMENT ISOLAT!0N ON 4/4 AND 4/12/86 (2) THE FAILURE OF THE MAIN STEAM ISOLATION VALVES (MSIVs) TO OPEN AFTER THE ISOLATIONS (3)
- RECURRING PRESSURIZATION EVENTS IN THE RESIDUAL HEAT
() REMOVAL (RHR) SYSTEM o BECO APPROACHES TO PROBLEM SOLVING WERE CAREFULLY STRUCTURED AND APPEARED THOROUGH I O
.. t
- II,B,3 HISTORICAL PERSPECTIVE SLIDE 15
[1ANAGEMENT MEETING 86-41 o C0fiDUCTED 11/24/86 TO DISCUSS BECO PLANS FOR PROGRAM IMPROVEMENTS AT PILGRIM AND THE STATUS OF OUTAGE ACTIVITIES o JTECHNICAL AND PROGRAF 1 ISSUES TO BE REVIEWED PRIOR TO - STARTUP WERE LISTED AS ATTACHMENT 1 TO MEETING REPORT : r o NRC LOOKING FOR STRONG EVIDEllCE OF PROGRESS AT PILGRIM PRIOR TO RESTART l o NRC INTENDS TO C0fiDUCT A SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP) REVIEW PRIOR TO REACHING A POSITION REGARDING THE RESTART OF THe PILGRIM FACILITY ! O 1 l l f O i
9 o . .
~11.B.4 HISTORICAL PERSPEif!VE SLIDE 16 c'1 v
SALP FINDINGS 86-99 o ASSESSMENT PERIOD 11/1/85 - 1/31/87 o SALP BOARD REPORT ISSUED 4/8/87 o SALP MANAGEMENT MEETING 5/7/87 o SALP REPORT 50-293/86-99 6/17/87 o ISSUES:
+
BECO MADE SidNIFICANT STAFFING AND HARDWARE COMMITMENTS TO IMPROVE PERFORMANCE
+
PROGRAN IMPROVEMENT BEGINNING TO HAVE A POSITIVE EFFECT
+
ASSESSMENT OF PERFORMAiiCE NOTED SOME IMPROVEMENTS
+
ORGANIZATION CHANGES TO CLARIFY RESPONSIBILITY AND O ACCOUNTABILITY 1 - STABILITY IN STAFFING KEY MANAGEMENT POSITIONS STAFFING VACANCIES SLOW DEVELOPING IMPROVEMENTS IN SOME PREVIOUSLY IDENTIFIEC LONG-TERM PROBLEM AREAS o NRC ACTIONS: ' o CONTINUE AUGMENTED INSPECTION PROGRAM o MONITOR CAL 36-10 ACTIVITIES t
II.B.5 HISTORICAL PERSPECTIVE SLIDE 17
- 0THER ISSUES O
o EMERGENCY PREPAREDNESS (1) ONSITE
- NO SIGNIFICANT DEFICIENCIES OR PROGRAM WEAKNESSES (2) 0FFSITE - DEFICIENCIES IDENTIFIED BY COMMONWEALTH REPORT t
AND FEMA SELF-INITIATED REVIEW
- SIX FEMA DEFICIENCIES REQUIRE PLAN CHANGES AND SOME DEMONSTRATION
- ANNUAL FULL PARTICIPATION EXERCISE EXEMPTION GRANTED
~
o SAFETY t : MENT PP.0 GRAM (SEP) (1) VOLUNTARY PROGRAM NOT A PREREQUISITE FOR PLANT RESTART (2) BECO IMPLEMENTING SEVERAL SELF-INITIATED ENHANCEMENTS TO THE PILGRIM MARK I CONTAINMENT (3) IMPLEMENTED UNDER 10 CFR 50.59 (4) NRC HAS REVIEWED SAFETY EVALUATIONS n o LEGAL AND LICENSING ACTIONS (1) TWO 2.206 PETITIONS HAVE BEEh SUBMITTr? hEQUESTING THAT BECO SHOW CAUSE WHY PILGRIM SHOULD NOT REMAIN SHUTDOWN UNTIL CERTAIN ISSUES HAVE BEEN RESOLVED. PETITIONS REQUEST FULL ADJUDICATORY HEARINGS TO ADDRESS ISSUES RELATED TO MANAGEMENT, MARK I CONTAINMENT AND EMERGENCY PREPAREDNESS (2) ALL LICENSING ACTIONS HAVE BEEN REVIEWED, THREE REMAINING ACTIONS WILL BE COMPLETED PRIOR TO RESTART c ( O f
., g-- ,
5 < e,
, . 1'V 1 IIRC STAFF PRESENTATION 3.( e SLIDE 1 f% - - 'qf . >
AGENDA m.. h [ .g _ . [ IV. NRC STAFF PRESENTATIONS A. ASSESSMENT ACTIVITIES TO DATE
- 1. RESTART ASSESSMENT PANEL
- 2. AUGMENTED' INSPECTION AND: REVIEW ACTIVITIES
- 3. LICENSING ACTIVITIES f4. SALP ^
- 5. INTEGRATED ASSESSMENT TEAM INSPECTION ,
c- 'B. FUTURE ACTIVITIES 4 C. CONCLUSION O. i 4 1 i "t I 4 , i s ? [,
'O :
t I
.,.--,.,_,,d-..,~-.L-
___.,..-..__,._,--_,-.__.s_. -
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IV.A ASSESSMENT ACTIVITIES SLIDE 2 v MILESTONE CHART o PROVIDES FOR TRACKING, PLAfiNING AND DOCUMEf1 TAT 10N OF NRC RESTART ASSESSMENT ACTIVITIES O I O
Lnt 66-13 flRC Ltr nn SALP l Dirgnos CAL 86- I R 0 ,. Request Re-ftgat f!RC SEP Ltr R start SE$ Team 10 AIT Start r.!2eting 66-99 Assess. from Plan " " E' 85-99l p;7 g start Asses' 86-41 i Plan nrrn Rev. 0 3"
- h. - ~ . 2 ,.=-- . J- c , ,) , : .. - _ . - L- .= - . -L= . . -. 3- . . . - n A.,-. , a n - h- _ , A * =
=
10/1/84- 2/16/86- 4/12/86 7/86 8/27/86 11/24/86 11/1/85- 7/8/87 7/8/87 7/30/87 MW ai~ 10/31/85 J/7/86 1/31/87
@O FEftA SEP Ltr EP 3.tr UECo flRR fitg Pwr Asc Restart ' Site LOOP SelI to tc EP Re- with Prg Plan kark i9-Int Rev BECn l DECO sponse _, BECo Submit Rev. I Stop "U"E v b .m -.- . .- N_- ,- . c . =J= .: _,-. ,-b.m . u- J m .. . A== - - . ,,.=uA== m. m. mH _, ,,,,_. ,, j(, _ ,__,,J ';
8/5/87 8/21/87 9/17/87 9/17/87 "'24/87 10/15/87 10/26/87 11/8/87 11/12/87 12/87 3. 3
- - ~
3 r - -- - - '1RC Al f Re- DECO /fhiC
~ ~
f MC PuEfiI BR6SelT -" Public fitg Start BECo BECo SEP 0 Restart Pilgrim on Restart Pre-Self Ltr to fiRC start Plan Resolution Mtg Re: Pe-Assessment n sk p;an A:.scssment Except DTV Comments to R/S Plan start Plan IrlPO Report S liECo Comments Coment s Review Submitted h F,..% .N 3 = - =-- 3 - -. ~ = X .::: T:.~~E. -.
= - 1., .._, 4 .:L=., ,.. J I/4/88 1/27/88 2/18/88 2/22/88 2/22/88 3/18/88 5/6/88 5/11/88 5/9-20/88 5/26/88
[jppgey g[' BECo/ Staff 5[Co De lifECo 5elT ~. RCns~5 iib 7 ITECo Sel f- Enior Commission ion on , ,_
, ! assess /lfiP0 -
SALP ihTI S A'. P Assessment i't95.n t Brief/ 2/1/87- ACRS Rpt Results Prepara- lATI fig t t Public litg ness IATI 5/_1 / Brief
--,- J Presentatfor tigns Site g ,,, ,.L_.~. ~_Zb- - l -- ** "'" * "3 8_- *. ' " ' " - - - - - - -
,p - u~ fitj
*~ ~ G N _ __ _ J._
5/26/88- 6/2/88 6/9/88 6/25/88 8d 7/5/38 7/15/88 7/09-21/88{1/8-24/8fl 8/25/88; 6/24/88 Rpt 7/26/88 8/26/88 1ATI - l _ .__206 tiltC/ CAL .r!RC Comp f4RC Restart Restart ntp3 y;gC Ties EDP Restart lATI unc 2.206 R p rt 'SS"U Powei- Assessment Assessmer full olution Issues issue Public Public com Mt 153"" SEP iss Addressed Status Status Meeting Meeting Ascension Rs crt Panel T. ;a P Recom RA
~ ~ {__1 .. q . . Q, - _. = - -Q=7, - 4 ..- --- @j b-=Z _1_an RqvM ~_ g' -> !!
{ji/[7[k] [ ] l ll 1 l I jlw/o 9/19188]l"lo 9/19/88l l l (_ l l l s
'RCRecom U/fiflit IDD Cc'hinis- MRC"UvEr- P to to Recomenda- sion Brief- - - ' - - -
sight rit -
. C ,nirector/ EP tion to .ing Public Conan Restart Restart /PWR f1RC 6 Mo. s C7 Issues 3, "
j!!RR EDO Assent Decision Ascension SALP o m l Release
-,-. = F C llteeting - . m_-} _ _ _- m . _-{- m_----, , = g -_ _ ,_, ,q p_,q__,q h I, ]_]' b -.L_} m l [ ] L_] l _JL__j [7 j l ll ll 3g l
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IV. A.1' ' ASSESSf1ENT ACTIVITIES
. SLIDE 4-f: '
O RESTART ASSESSMENT PANEL' o SPECIAL RESTART ASSESSMENT PANEL FORMED BY 7/8/87 MEMORANDUM TO NRC REGION I REGIONAL ADMINISTRATOR
'o PANEL CHARTER IS TO C0 ORDINATE THE PLANNING AND EXECUTION-
< 0F NRC ACTIVITIES AND TO ASSESS THE RESULTS 0F THESE ACTIVITIES o' 1 RESTART ASSESSMENT PANEL MEMBERSHIP:
o DEPUTY DIRECTOR, DIVISION OF REACTOR PROJECTS, REGION I - CHAIRMAN o ASSOCIATE DIRECTOR, REGION I REACTORS, NRR, CO-CHAIRMAN
-O o CHIEF, REACTOR PROJECTS BRANCH 3, DRP c PROJECT DIRECTOR, NRR o PROJECTS SECTIONS CHIEF, DRP o LICENSING PROJECT MANAGER, NRR '
o CHIEF, ENGINEERING BRANCH, DIVISION OF REACTOR SAFETY, REGION 1
- o CHIEF, RADIOLOGICAL PROTECTION, EMERGENCY PREPAREDNESS AND SAFEGUARDS,' DIVISION OF RADIATION SAFETY Af4D SAFEGUARDS, REGION 1 !
l ' o PANEL MEETING BI-WEEKLY, EVERY OTHER MEETING AT PILGRIM SITE ! l O ! i 7 _ _ _ - - - - - , . - - = - - - - -
IV.A.2 ASSESSMENT ACT:VITIES SLIDE 5 0 AUGMENTED INSPECTION AND REVIEW ACTIVITIES o 7/8/87 MEMORANDUM FROM DIRECTOR, DIVISION OF REACTOR PROJECTS TO THE REGI0fiAL ADMINISTRATOR, REGION 1 c MANAGEMENT OF fiPC ACTIVITIES REGARDING PILGRIM RESTART: (1) UNIQUE PLAN NEEDED FOR MANAGING NRC ACTIVITIES (2) NRC MUST COMPLETE REVIEWS TO PROVIDE AN INDEPENDENT JUDGEMENT OF PLANTS READINESS FOR OPERATION < (3) MUST PROVIDE FOCUS AND GUIDANCE TO NRC PROCESS o ACTIONS: (1) AUGMENTED INSPECTION PROGRAM TO IDENTIFY NEEDED IMPROVEMENT AND NEEDED NRC STAFF ACTIVITIES (2) SPECIAL PILGRIM RESTART ASSESSMENT PANEL - SENIOR STAFF f1Ef1BERS (3) DIAGNOSTIC TEAM liiSPECTION (IATI - INTEGRATED ASSESSMENT i TEAM INSPECTION) (4) ASSESSMENT REPORT TO REGIONAL ADMINISTRATO,R (RAR - RESTART ASSESSMENT REPORT) 1 1 1
o - .
.IV.A.2 : ASSESSMENT ACTIVITIES- ,
SLIDE 6 ( .
' AUGMENTED INSPECTION AND REVIEW ACTIVITIES INSPECTIONS
. SALP PERIOD lNSPECTION HOURS ANNUAL' HOURS 1/80-12/80 1950 1950 .
9/80-8/81 2328 2328 9/81-6/82 3735 4482 7/82-6/83 3234 3234 7/83-9/84 4960 3968 10/84-10/85 3792 3500 11/85-1/87 6762 5409 2/87-5/88 9698 7758 DURING THE LAST.(2/87-5/88) SALP ASSESSMENT PERIOD, NINE NRC TEAM INSPECTIONS WERE CONDUCTED: O '
- 1. APPENDIX R FIRE PROTECTION PROGRAM REVIEW
- 2. PLANT N0DIFICATION PROGRAM REVIEW 3.
PLANT EFFLUENT AND ENVIRONMENTAL MONITORING PROGRAM REVIEW 4. AUGMENTED INSPECTION TEAM (AIT) REVIEW 0F THE LOSS OF 0FF-SITE POWER EVENT ON NOVEMBER 12, 1987
- 5. ANNUAL EMERGENCY PLAN EXERCISE OBSERVATION 6.
ONSITE ELECTRICAL DISTRIBUTION ADEQUACY REVIEW 4
- 7. EMERGENCY OPERATING PROCEDURES REVIEW
- 8. MAINTENANCE PROGRAM REVIEW 9.
{ IN-PLANT RADIOLOGICAL CONTROLS REVIEW ' 1 O
- s. IV.A.2 ASSESSMEfT ACTIVITIES SLIDE 7
-)
AUGMENTED INSPECTION AND REVIEW ACTIVITIES MEETING ACTIVITIES o 42 MEETINGS CONDUCTED SINCE 4/86 SHUTDOWN o 28 MEETINGS CONDUCTED SINCE 2/87 o TABLE 5 0F SALP REPORT C7-99 (SLIDE 8, 9, 10) O O
IV.A.2 ASSESSMENT ACTIVITIES
. SLIDE 8 1
m
) TABLE 5 -
y MANAGEMENT MEETING AND ptANT TOUR
SUMMARY
DATE SPONSOR TOPIC 02/02/87 NRC Management meeting at Plymouth, K8 to discuss , the status of licensee improvement programs (IR 87-08) 02/03/87 Massacnusetts NRC Region I Adninistrator and other Region I secretary of managers met in Bestent MA with several Energy Commonwealth administrators to discuss NRC activities regarding Pilgrim 03/09/87 . Massachusetts Legislature NRC Region I Administrator and other members of the staff appeared in Boston, MA before the Massachusetts Joint Committee on the Investigation and Study of the Pilgrim Station at Plymouth (IR 87-16) 03/10/87 NRC NRC Chairman Zech' toured Pilgrim accompanied by the Regional Administrator and attended a
~
licensee preseritation (IR 87-16) 04/27/87
' Massachusetts legislature NRC Region I Adminis+.rator and other members of the staff appeared in Boston before the Mass-chusetts Joint Committee on the Investigation and Study of the Pilgrim Station in Plymouth (IR 87-18) 05/01/87 NRC Management meeting at NRC Region I to discuss a surveillance r.rogram violation and program weaknesses (IR87-23) 05/07/87 NRC 1987 SALP management meeting at Plymouth, MA 05/22/87 NRC NRC Commissioner Carr toured the plant and attended a licensee presentation 05/27/87 Plymouth Four NRC Region I management representatives Board of participated in a public meeting in Selectmen Plymouth, MA 06/24/87 NRC NRC Commissioner Asselstine toured the plant and attended a licensee presentation O
IV.A,2 ASSESSMENT ACTIVITIES SLIDE 9 Table 5 2
'(~l DATE \_J - SPONSOR -TOPIC 4
06/29/87' NRC Management meeting at NRC Region I to discuss the outage status, program improvements and licensee preparations for restart (IR 87-28)
, 07/23/87 Commonwealth of Mass. The NRC Section Chief, licensing Project Manager and Resident Inspectors for Pilgrim met onsite with representatives of the Commonwealth to discuss the NRC inspection process (IR 87-27) 09/09/87 NRC Enforcement conference at NRC Region I to discuss several security violations (IR 87-30)
~
09/24/87 NRC NRC Director of the Office of Nuclear Reactor Regulation, the Region I Administrator and other senior NRC managers met with the licensee in Bethesda, MD to discuss licensee activities and restart readiness (NRR meeting transcript) 09/30/87 NRC Enforcement conference at NRC Region I to discuss several security violations (IR 87-30) 10/05/87 NRC NRC Commissioner Bernthal toured the plant and () 10/08/87 Commonwealth attended a licensee presentation NRC Region I Administrator and other senior NRC of Mass. managers met at Region I with representatives of the Commonwealth of Mass. and two private citizens to answer questions regarding the NRC inspection process (IR 87-45) 10/29/87 Duxhury Board Four NRC Region I and NRR management of Selectmen representatives participated in a public meeting sponsored by the Ouxbury Board of Selectmen. Duxbury Emergency Response Plan Committee and the Duxbury Citizens' Committee on Nuclear Matters in Duxbury, MA 12/08/87 NRC NRC Region I Administrator toured the plant and met briefly with licensee management to discuss tour observations (IR 87-57)
+
4 O
IV.A.2 ASSESSMENT ACTIVITIES SLIDE 10 Table 5 3 (_) DATE _ SPONSOR TOPIC - 01/07/88 United States NRC Director of the Office of Nuclear Reactor Regulation and the Region I Administrator Senator Kennedy appeared before the Senate Labor and Human
, Resources Committee regarding Pilgrim. Tha public hearing was held in Plymouth, Ha.
02/18/88 NRC NRC Region I and NRR managers conducted a public meeting in Plymouth, MA to solicit public comments on the licensee's Restart Plan 02/24/8B NRC , Management meeting at NRC Region I to discuss
, the licensee's self assessment process to be used 88-10) for determining restart readiness (IR 03/10/88 NRC The NRC Director of the Office of NRR and the Region I Administrator toured the plant and interviewed licensee staff regarding the design basis 88-07) for the direct torus vent modification (IR '
04/08/88 NRC () Management meeting at NRC Region I to discuss the licensee's proposed tower ascension test program (Meeting Minutes 88-43) ' 04/22/88 NRC NRC Commissioner Carr toured the plant and attended a licensee presentation (IR 88-12) 05/06/88 NRC NRC Commissioner Rogers toured the plant and attended a licensee presentation (IR 88-19) 05/11/88 NRC NRC Region I and NRR managers conducted a public meeting in Plymouth, MA to provide responses to comments and concerns on the licensee's Restart Plan raised during the 2/18/88 public meeting (Meeting transcript) f O l
1 IV.A.2 ASSESSMENT ACTIVITIES SLIDE 11 7.
\~)#
AUGMENTED INSPECTION AND REVIEW ACTIVITIES REVIEW ACTIVITIES o SALP 85-99 o DIAGliOSTIC TEAM INSPECTION o CAL 86-10, 4/86 o CAL 86-10, 8/86 ' o SALP 86-99 o f1RC PILGRIM ASSESSIENT PLAN, 7/87 o SAFETY ENHANCEMENT PLAN (SEP), 7/87 o PILGRIM RESTART PLAN, REV O, SUBMITTED 7/87 o FEMA SELF INITIATED REVIEW 0F EMERGENCY PREPAREDNESS (EP), 8/87 (]) o PILGRIM POWER ASCENSION PROGRAM, SUBMITTED 10/87 o PILGRIM RESTART PLAN, REV. 1, SUBMITTED 10/87 o INP0 REVIEW, 5/88 o PILGRIM SELF-ASSESSMENT REPORT, 5/88 o BEC0/NRC STAFF COMMISSION BRIEFING, 6/88 o BECO REQUEST FOR lATI, 7/88 o SALP 87-99, 7/88 o ACRS COMMITTEE BRIEFING, 7/88 o IAT1, 8/88 o SALP MANAGEMENT MEETING, 8/88 o ACRS SUBCOMMITTEE BRIEFlfiG, 8/88 , (2) l l ( ,_-
' i IV.A 3 ASSESSMENT ACTIVITIES SLIDE 12 C/ LICENSING ACTIVITIES o RESOLUTION OF 2,206 PETITIONS o SAFETY ENHANCEMENT PROGRAM (SEP) REVIEWS o TECHNICAL SPECIFICATION LICENSING ACTIONS - 3 ITEMS REMAIN OUTSTANDING FOR RESTART: (1) FIRE PROTECTION APPENDIX A FIRE WALL RATING CLARIFICATION (2) DEGRADED GRID VOLTAGE (3) ORGANIZATION CHANGE o
/
/
O'
L IV.A.4 ASSESSMENT ACTIVITIES C SLIDE 13 1 T
.NJ SALP REPORT Pilgrim SALP History Assessment Period Post Shutdown 1/80- 9/80- 9/81- 7/82- 7/83-Functional Area 12/80 10/84- 11/85- 2/87 8/81 6/82 6/83 9/84 10/85 1/87 5/88 Operations 2 3 3 2 2 3 2 2 Radiological controls 3 2
, 2 2 30 3-1 3 3I
~
Surveillance 2 2 2 1 1 2 3 2 Maintenance 2 3 2 2 11 2 2 2 , Emergency Planning 3 1 1 1 30 3 .2 21 Fire Protection 2 2' 3 1 2 - 3 2 Security 2 2 2 2 2 2 3I 2 O Engineering and Technical Support . 1 1 Licensing - - 2 1 11 1 2 2 Training Effectiveness - - - - - - 21 2 Assurance of Quality /0A 3 3 - - - - 3 2 Outage Management 3 2 2 - 1 1 1 - 9 i O I l -~
..y - - -
( .. :.. IV.A.4 ASSESSMENT ACTIVITIES SLIDE 14 O SALP 87-99 f o 2/1/87-5/15/88 ASSESSMENT PERIOD: o SALP BOARD: 7/5-6/88
- o. BOARD REPORT ISSUED: 7/27/88 o MANAGEMENT MEETING: 8/25/88 c ISSUES:
. + i PERSONNEL AND ORGANIZATIONAL CHANGES CONTINUED THROUG THE PERIOD, FUNCTIONAL REPORT CHAINS WORKING WELL
+
. SIGNIFICANTLY HIGHER STAFFING ALLOCATIONS
+-
AGGRESSIVE ACTIONS IN MOST PROGRAM AREAS OF WEAKNESS SOME DELAY IN liiPLEMENTATION OF IMPROVEMENTS o CONCLUSIONS: (1) EXTENSIVE BECO EFFORTS TO IMPROVE CORPORATE AND SITE MANAGEMENT ORGANIZATION STRUCTURE (2) EFFORTS GENERALLY SUCCESSFUL IN CORRECTING STAFFING, ORGANIZATION AND MATERIAL DEFICIENCIES > (3) SELF-ASSESSMENT PROCESS SUCCESSFUL IN TARGETING MANAGEMENT ATTENTION (4) PERFORMANCE IN SOME AREAS LAGS BEHIND DUE TO LATER IMPLEMENTATION OF PROGRAM AND ORGANIZATIONAL IMPROVEMEN DUE TO HIGHER PRIORITY OUTAGE WORK (5) A CONTINUED BECO COMMITMENT IS NEEDED TO SUSTAIN THE OVERALL IMPROVING TREND IN PERFORMANCE O
IV.A.5 ASSESSMENT ACTIVITIES SLIDE 15 ( ) INTEGRATED ASSESSMENT TEAM INSPECTION (IATI) o COMMITTED T0 "CONDUCT A REGION I DIAGNOSTIC TEAM INSPE AFTER BECO SUBMITTED ITS READINESS INSPECTION REPOR THE PILGRIM RESTART ASSESSMENT PANEL HAS INDEPENDEN THAT LICENSEE PROGRAM AREAS ARE REASONABLY READY TO W THIS INSPECTION "(1) o 6/25/88 BECO LETTER 88-099 REQUESTED THE NRC TO COMME INTEGRATED ASSESSMENT TEAM INSPECTION (IATI) ON 7/11/88 ON COMPLETION OF THE BECO RESTART READINESS SELF-ASSES (RRSA) AND IDENTIFICATION AND SCHEDULING 0F REMAINING A TO BE DONE BEFORE RESTART. o 7/11/88 IATI, NRC LETTER CONFIRMED REVIEW OF RRSA AND SCHEDUL O
REFERENCES:
(1) NANAGEMENT OF NRC ACTIVITIES REGARDING PILGRIM RESTART, MEMORANDUM 7/8/87 ()
IV.A.5 ASSESSMENT ACTIVITIES SLIDE 16 O lATI (CONTINUED) o IATI PURPOSE:
"T0 INDEPENDENTLY REVIEW AND ASSESS THE READINESS OF YOUR MANAGEMENT CONTROLS, PROGRAMS AND PERSONNEL TO SUPPORT SAFE RESTART OF THE FACILITY "II) o IATI SCHEDULE" 0NSITE PREPARATION 7/19-21/88 INSPECTION 8/8-19/88 DOCUMENTATION 8/20-24/88 INSPECTION EXIT MEETING 8/24/88 0 1ATI OPERATING PLAN OBJECTIVE:
"THE NRC HAS PERFORMED NUMEROUS INSPECTIONS TO DETERMINE THE STATUS AND ADEQUACY OF THE IMPROVEMENTS.
m C THE OBJECTIVE OF THE IATI IS TO REVIE'.i THE ADEQUACY OF ANY ISSUES NOT PREVIOUSLY INSPECTED OR WHICH REQUIRED FOLLOWUP INSPECTION, TO DETERMINE IF IMPROVEMENTS 11ADE ARE EFFECTIVE AND APPEAR LONG LASTING, AND TO DETERMINE IF BECO IS PREPARED TO SUPPORT THE RESTART AND SAFE OPERATION OF PILGRIM."
REFERENCES:
(1) NRC LETTER TO BECO, 7/11/86 O '
'~ -
-;'., y' s .-
;g,'
o IV.A.5'[ ASSESSMENT ACTIVITIES .
._ 4' ,.
' SLIDE 17 '
~
I ATI' !(CONTINUED)
. r'i . y :(v ATTACHMENT'A.
- ORGANIZATION l SENIOR
]; '
I l MANAGER l. I I ' i S. Collins l I I I . I s. .. I i l TEAM l l TECH l l LEADER' l l ASST [ l I l li I N l R. Blough l l C. Warren l ,, l i l q l
'. I l
l l ADMliiASST I l l l M.J. DiDonato j , I l 1 O' l l l l l 1 i (
.I l ~l I I I l
/ ) SHIFT INSPECTORS I I SPECIALIST INSDS I I i I l L. Rossbach ! l T. Dragoun l
l B. Raymond l l L. Plisco l l G. Smith l l l D. Mcdonald I F. Akstulewicz l l J. Lyash l l l l 1 l L. Doerflein l l l M. Evans l I I e l
.L O
f f
, _ . , . . . - . . . . _ _ _ . . . , . . . _ _ _ . . . . _ . , ~ _ . . - - . _ . . , _ , , . .j..,,...._.-
d ,4 '
-g g~
' s IV.A'5 1
ASSESSMENT ACTIVITIES
- s. .~ SLIDE 18 HTI (CONTINUED)
~ ' '
ATTACHMENT B s i ,
+ , Pilcrim IATI Roster Senior Manager: i
. Sam Collins Team' Leader: Randy Blough , !
- Technical Assistant: Clay Warren s
Administrative Assistant: Mary Jo DiDonato Shift Inspectors: Larry Rossbach Loren P11sco Bill Raymond Frank Akstulewicz ' Speciali.st Inspectors: HP: c' Tom Dragouii ' ' Security: , Greg Smith Maintenance: Jeff Lyash (Bill Raymond) ' Surveillance:- Larry Doerflein (Frank Akstulewicz) Training / Management: Dan Mcdonald i O 4 Additional Area Michele Evans Assignments: Fire Protection: Larry Rossback OA/0C: Loren Pitsco I Review Committees: Loren Plisco (Frank Akstulewicz) l Inspection Report Coordinator: T. J. Kim O
7 IV.A.S. ASSESSMENT ACTIVITIES
,- SLIDE 19 L) ,
_lATI_ CONCLUSIONS ' i
^
o EXII MEETING CONDUCTED - 8/214/88
- o. IATI REPORT SCHEDULE -
9/2/88 o PUBLIC MEETING SCHEDULE - WEEK 0F 9/9/88 i O O
r v IV,B FUTURE ACTIVITIES SLIDE 20
.s FUTURE ACTIVITIES IATI SALP '
EXIT ACRS IATI MGT SUBCOMMITEE REPORT MEETING MEETING I I 8/24/88 8/25/88 s 8/26/88 9/2/88 ACRS RESOLUTION FULL E0P 2.20G OF SEP ISSUES RESTART / CAL i COM MTG ISSUES ISSUE ISSUE ADDRESSED STATUS __ 1 i STATUS i i 9/7/88 . __ t
)
POWER lATI ASCENSION 2.206 NRC PUBLIC PUBLIC PROGRAM MEETING RESTART REVIEW MEET!NG ASSESSMENT REPORT l 1 l I W/0 9/19/88 s W/0 9/19/88 9/30/88 ' ()' RESTART ASSESSMENT PANEL EilERGENCY RECOMMENDATION PREPAREDNESS TO REGIONAL ISSUE REGIONAL ADMINISTRATOR ADMINISTRATOR STATUS RECOMMENDATION TO _D_I_R_ECTOR, NRR I D/NRR COMMISSION RECOMMENDATION COMMISSION RESTART BRIEFING ASSENT TO EDO PUBLIC MTG DECISION l I
)
COMMISSION CORRECTIVE DISSENT ACTIONS POWER NRC NRC
)
t ASCENSICI, RELEASE ASSESSMENT /SALP PROGRAM I
)
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IV C CONCLUS100
- SLIDE 21^
./m e >
CONCLUSION i c' "
' PILGRIM SHUTDOWN APRIL 12,'1986 DUE TO TECHNICAL !SSUES ,
(MSIVS, CONTAINMENT ISOLATION AND INTERSYSTEM LEAKAGE -
'T0 RHR SYSTEM)
, 0:
SHUTDOWN CONFIRMED BY CAL 86-10 0F I4/12/86 o elSSUES AND NRC CONCERNS EXPANDED BY SUPPLEMEN CAL 86-10,-8/27/86, WHICH REQUIRED A FORMAL ASSESSMENT BY BEC0 0F THEIR READINESS FOR RESTART AND A F RESTART PROGRAM WITH A SCHEDULE BE SUBMITTED T NRC o BEC0 HAS DEV0TED SUBSTANTIAL RESOURCES TOWARDS RESOLUTION OF THE ISSUES AND THE NRC HAS REVIEWED
'O ACT US REGARDING MANAGEMENT AND ORGANIZATIONAL l CHANGES,'NEW PROGRAMS AND IN-PLANT IMPROVEMENTS o
THE LEVEL OF NRC STAFF ACTIVITY ON PILGRIM IS VERY HIGH AND WILL REMAIN HIGH IN CONJUNCTION WITH RES ASSESSMENT ACTIVITIES o THE LEVEL OF COMMISSION INTEREST AS WELL AS PUBLI INTEREST IN THE FACILITY IS HIGH p i i L O
o e IV.C CONCLUSION SLIDE 22 h
,NJ I
CONCLUSION (CONTINUED) RESTART CRITERIA STABLE AND EFFECTIVE MANAGEMENT AND STAFF AT PILGRIM RESOLUTION OF MAJOR TECHNICAL ISSUES DEMONSTRATED IMPROVEMENT IN SALP PROBLEM AREAS MAINTENANCE PROGRAM AND WORK BACKLOG ISSUES ADDRESSED g-) NRC SATISFIED THAT CERTAIN EMERGENCY PLAN
\>
IMPROVEMENTS HAVE BEEN MADE 1 l (S)
P o o o
^
i EOSTON E DI[G O N COMPANY ~ PILGEEM __ NUCLEAR POWER STATI:ON RALPH BIRD SENIOR VICE PRESIDENT, NUCLEAR KEN HIGHFILL STATION DIRECTOR RON VARLEY MANAGER, EMERGENCY PREPAREDNESS ED HOWARD VICE PRESIDENT, NUCLEAR ENGINEERING ipisasa
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l l CURRENT PLANT STATUS PLANT REFUELED
- REACTOR REASSEMBLED HYDROSTATIC TEST COMPLETE ILRT COMPLETE MAJOR MODIFICATION WORK COMPLETE PLANT CLEAN AND DECONTAMINATED 1pi8248f
l i MAJOR OUTAGE PROJECTS
- APPENDIX R
!
- SECURITY SYSTEM UPGRADES PLANT SPECIFIC SIMULATOR TURBINE GENERATOR OVERHAUL l
- REFURBISHMENT OF PLANT SYSTEMS I
DECONTAMINATION i 1phS248g
~
O 3 2 FACILITY PE sORMANCE n O FUNCTIONAL AREA CATEGORY CATEGORY RECENTTREND LAST PERIOD
- THIS PERIOD "
- 1. Plant Operations 2 2
- 2. RadiologicalControls 3 3 Improving
- 3. M3intenarre and Modifications 2 2
- 4. Survei!!ance 3 2
- 5. Fire Protection 3 2
- 6. Emergency Preparedness 2 2 Improving
- 7. Seconty and Safeguards 3 2
- 8. Engineering and Techrucal Support 1 1
- 9. Licensing Activities 2 2
- 10. Training and Qua!ificatio:n Effectiveness 2 2
- 11. Assurance Of Quai!!y 3 2 Outage Management and Modifications Activities 1 Novetaber 1,1985 to January 31,1987 " February 1,1987 to May 15,1988 Not evaluated as a separate functional area; findings relative to cutage activities are integrated into "Engineering and I Techrucai Suppo't". "Maintenance and Modificitions", and oid.er functional areas as appropriate.
i I l 1pis248h
PILGRIM STAF!OF NON-BOSTON EDISON RA.MP DOWN
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- 1
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i'. ., 7 E s 7 N g . ., t . h 1000 s , w 800-- 7 4 4 4 4 , 0 - ' - - k\ Ih - - - - - Sep- Oct Nev~ Dec- Jan- Feb- Mar- Apr- Mcy- Jun- Jul- Aug- Sep- Oct- Nov- Dec-87 87 87 87 88 88 88 88 88 88 88 88 08 88 88 88 E FRCRPT 8 ACTLS -*- GUAOD FRCST + ACTLS BP&BC 08/19/88 1pi8248a i I .
O O O . l PILGRIM STATION NUORG OVERTIME 6 6 6 ! 7000 - $ a ! 7
- 4
! M 4 3000- a S A _ l N 5000- : , 3 , ,, a 3 j ,
" 4000-O 2 2 ff l j$ $
I Jan- Fab- Mar- Apr- May- Jun- Jul-88 Aug- Sep- Oct- Nov- Dec-88 38 88 88 88 88 88 88 88 88 88 i NOTE:JUNTriRU DEC E FRCST REFLECTS BUDGET . B ACTUALS l BP&BC 08/19/88 REFORECAST 1 pi8248t, i \,
PILGRIM STAT'.ON NUORG STAFFING 1000
- T e 8 9 A 7 7 7 7 $ ! s 7 7 7 8 9 9 0 2 0 0 Jan-8EFeb-88 Mar- Apr- May- Jun-88Jul-88 Aug- Sep- Oct-88 Nov- Dec-88 88 88 88 88 88 88 NOTE: MONTHLY AVERAGES BF&BC 08/19/88 1pi8248c
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; i i ; 100--
'I 90-- 80- ! 70-RADIOLOGICAL 80- OCCURRENCE so- REPORTS (RORs) l 0 E t 2/12 3/3 3/24 4/13 5/3 5/24 6/13 7/5 7/25 8/17 O number issued E total open ' l l 1pi8238d I - 1 i
O O u[\ LICENSED OPERATOR STAFFING STATUS 25-
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Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Jd Aug 1986 1987 1988 1TR8228A
a O . O O LICENSED PERSONNEL - YEARS TOTAL EXPERIENCE 200 - 180 - W O - Z 160 W E W I40 D.
- COLD UCENSE - NEED 20 DAYS ON E ij WATCH >20% RCTP +5 REACTIVITY CHANGES 100 -
j > 10% CHANGES RCTP J 80 - i 4 : : F- i O p 60 - i Q .i j ' i 40 - i n 20 - l y i : : f'T } .
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- NPRO WATCH (COLD UCENSE)
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'. . . EXPERIENCE- EXPERIENCE TOTAL YEARS NUCLEAR NAVY A{ 'x ]
i BECo/OTHJR EXPERIENCE tir8198d
o O O PILGRIM NUCLEAR POWER STATION 49 KEY MANAGEMENT POSITIONS 802+ YEARS W 800 , O di, Z W [E r.. g i. :. m , :; - O. 600 9 "W x 4.. a m sq.g . 467+ m YEARS g .93
< h 386 +
" 400 ..;d;) YEARS gm s gibn 4 frstgg H y ;
O [M r 200 P.bQ) g t.;e -
.I Siiji 80+ YEARS ir O-l . }.~;# }
ljf'M-h - sha m --i - NUCLEAR BWR PILGRIM CtHENT POSmON l 1 fr8198a
O O O
; TOTAL OPEN MRs 3500 " - , r r .
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( a . , j 500- . ," r y y ; E q [ i l E - 9 O l :- : :- :- : :- : .: : 5/29 6/26 7/24 8/21 9/18 10f16 11/13 1987 1pi8258b
O O O I TOTAL OPEN MRs 3 ~ n$es$$Iu*rrov*er
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11/20 12/10 1/15 2/12 b/1k $/1h 5/11 6/6 7/4 8/3 1987 b Total Open MRs E All Other Open 1988 ] 1pi8258c O
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POWER BLOCK MRs 700 - ! {: 5 20 6/19 7/10 7/31 8/21 9/11 1012 10/2511/13 12/4 12/25 1 15 2/ 2/26 3/22 4/11 5/2 5/23 6/13 7/5 7/25 8/17 i 1piB258a l
0 O O O PILGRIM NUCLEAR POWER STATION FP T M IF O m k ] m M C E [W C[0.[LIN CI DMm0CmV@ m 2 ( STATUS AS OF AUGUST 23,1988 ) ALARA TRACKING 400 350_ 300_ 250_ b YTD 4 200_ 261.92 8 e i g 150-100 - 50 - 1 0-k;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;; JAN FEB MAR APR MAY JUN JUL ALG SEP OCT FOf DEC _ BUDGET __ ACTUAL ITR822SB
l ! O O O i ! RESOURCES PROVIDED BY BECo , i
- PROFESSIONAL EMERGENCY PLANNERS l
i
- FUNDING OF CIVIL DEFENSE POSITIONS i e UPGRADING OF FACILITIES AND EQUIPMENT i e COMPENSATION FOR TRAINING
} l 1pi8248e
]
O O O BOSTON EDISON COMPANY BAMETX :EEIEIAEIGEM:ENT :EED@_ GRAM Presentation to ACRS August 26,1988 1br8238a
b' O O naux unmoxwac zwoum L89@FE@lsf EIDXEDE GDELE Near Term Goal; identify And implement Plant improvements Responsive To NRC Draft BWR Severe Accident Containment Policy. Revise Emergency Operating Procedurcs And Train Operators To improve Operational Readiness And Ensure Effective Use Of Plant Capabil; ties in The Event Of An Accident. Long Term Goal: Perform A Comprehensive Safety Assessment Supported By Deterministic And ! Probabiiistic Analyses Of Severe Accidents To Ensure That:
- 1. The Pilgrim Specific Response To Severe Accidents is Well Understood l 2. These insights Are Effectively Used Within Boston Edison To Reduce The Probability And Consequences Of A Core Damage Accident i
j 3. These insights Are Available in Support Of Emergency Preparedness Planning j Ibr8238b t . 1
o O O
/
,4 - -
_ i
~
l Program Elements i l j . Safety Analyses - Both Probabilistic And Deterministic P! ant Equipment Modifications Operations Procedu; improvements 1 Training Management System !mprovements Itx8238c
=.
~
T. O O O GiAEE5N EEEAEICl8MEHY :ERDEGRAM Proaram Strateay And Approach Assemble The Most Experienced Technical Toam Available Pursue A Parallet Effort To identify Possible Irtprovements Prepare Conceptual Dasign Based On Expert Judgment Analyze Plant Capabilities-Evaluate Possible improvements Integrate Conceptual Designs And Analytical Results into Approved Plant Modification Procedures improvements Training inprovements
. Maintain Active involvement in The industry Programs 1br8238d
O O
~
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k h((dbN[.I. bb51Ibbb[bkIbb$[I\ bbbNdhd i imDiementation Focus NRC Draft Severe Accident Containment Policy-BWR NRC And IDCOR BWR - Mark I Containment Refererce Plant Otudies Station Blackout Events ATWS Events Contcinment Performance issues a ll Ibr8238e
- , . _ _ . . . . _ . ,, -- - -- .,c,, - . , - - - - - , , - - - . - - - - - - - - - --
O
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*s-E)ATEEiEI :EECH4 W H E M ER T :ER@_ B:RAE MG?>1JllSG :
Station Blackout - I Addition Of A Third Diesei Generator
~
Procedure Changes To Extend DC Battery Operation Set Point Changes To Extend The Duration Of RCIC Operation ! Fire Water inter-Tie to RH!! Additional Source of RPV Makeup t Suppression Poc! Vent To Main Stack - Sized For Decay Heat Remova! Improved Long Term Nitrogen Supp!y lbr8238f a
o O O SAIEETY E M A ?i H E M ElsIP ER@fGIRAM Resulata Anticipated Transient Without Scram i
- New Emergency Operating Procedures Based On Rev. ' EPGs Extensive Training Of Ooerating Crews Using Pilgrim Specific Simulator Enriched Boron For SBLC System Automatic Depressurization System Logic Changes Feedwater Pump Trip Backup Recirc Pump Trip TRAC G Analysis For ATWS waeg
~
O _ M n o A i t c u y a or - R t r n _ d p e S o R C E w l l e e O L l F o w y r u s I P d D r s e 2 n f r p 1 A O r e e g e c v n r O - a u - T t - h o n - C S e _ NR l e z z d t n e i m n a E o t N n n e V1 n p e C-o E a i g s d n k c l y p t a O Q l D e I C S t p u S M u s y A n n s e - i AI e c n S a r p R H M o a e g o I B R a m l l R o T t i N r N e t _ r T n g _ o w y e m n _ E f r e D r i T-e V l T r e i t s e P f r e o g T _ o O t n a P o l t n n l a - T S e m i t o a z t r e a i o s n L d e t n e m n s v E W i i i m e r o r r e . E a i t p e p p p _ I t n i r u m x O F S E A C o I F; O - i; 1
';ii!: : i l1 : !
l llIl
s O O O FERE5IT EHJAMCJf0rMENT TED@BRAM summarv Pilgrim Safety Enhancement Program Addresses Complex Severe Acciden't issues Both From Prevention And Mitigation Standpoints.
. Broad Technical Expertise is Being Employed To Resolve Technical Issues.
Improvements Are The Result Of The Most Comprehensive Safety Analysis Since The issuance Of The Operating License. Improvements Are investments in Safety Enhancing The Existing Plant Design And Operational Capabilities. Most importarit Result - Proficiency Of Simulator Trained Operating Crews In Application Of New EOPs. Continuing Future Benefits Expected By identifying Additional Applications To Further improve Management Of Safety At PNPS. 1br238i O - - - - - , . - - - - - - _ , - , - , , - - , - - ,-,.,.,-e--e-e---- -------v,---r--- -.- , , --- . - -,-- - - . - - - - , . - - - - - - - - - - - - - - - - - - - - - - - - -
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*(s 0/N/?M3/UtneGY I v ChY p 4[ h, MOUSE OP' REPRESENTATIVES
% srATC Housc. nosToN 02:33
~O & < /j LAWRENCE R. ALEXANDER Choi, men MEPRESENTATIVE Cownettee on (ners,
- '"A"!!a I NARSLEME AD MA 01945 a==/,0,;;.all,"a" 786. 639 7648 Ressapen pengeven Acumestaattyg Atestf amt WICHAEL ERNST '
LUCnt RICE TESTIMONY OF STATE REPRESENTATIVE LAWRENCE R. ALEXANDER, HOUSE CHAIRMAN OF THE JOINT COMMITTEE ON ENERGY, TO THE ADVISORY COMMITTEE ON REACTOR SAFEGUARDS AUGUST 26, 1988 Thank you for the opportunity to speak to you this afternoon. I I appreciate the chance to address a scientific panel on some of the problems that still exist at the Pilgrim nuclear power t O et at- i As House Chairman of the legislature's Joint Committee on Energy, I have chaired oversight hearings on design flaws in i the Mark I reactor containment, deficiencies in the emergency l response plana, inadequacies in current radiation monitoring systems and the increased incidence of leukemia in corrsunities downwind from the Pilgrim plant. The Atomic Energy Act and NRC regulations provide that nuclear power plants may only operate "consistent" with the "health and I safety of the public." (42 USC Section 2013(d)). I believe that mandate means that the regulatory agency and the licensee j must follow the letter and the spf. fit of the Atomic Energy Act and the regulations promulgated by the NRC thereunder. *
~O t v i 4
__ ,, .r --,- -r, _ . - . _ r_---., r- e e ,w w -- -- - -
*[ *
(]) With that standard in mind, I would urge you to recommend against the restart of Pilgrim unless and until the following < conditions are mets f
- 1) All. identified reactor safety problems have been corrected, T
including improvements to the Mark I containment. !
- 2) Workable emergency response plans are developed that l r
are adequate to protect the public and are in place. !
- 3) Plant management has demcnstrated its competence in
- 1 operating the reactor by improving its performance well '
beyond "marginal.ly satisf actory" grades in all NRC SALP 1 I
- categories. ;
In view of the terrible operating record of this plant, f i , which over the years has been termed one of the "worst" in the () nation by NRC Commissioners, I urge you to recommend that the l
- f. conditions I have mentioned be met before restart is allowed !
to take placo, i p
- Reactor Safety i
q Let me begin with reactor safety. No one nas ever yet been ft
- a l able to explain adequately why the Residual Heat Renoval System l shut down twice in 1986, thus initiating the closing of the plant i
- for the past two years. How can Pilgrim be ready for restart {
r o I when MIT scientists are still studying the cracking of an RHR i motor housing and valve? l i i Numerous recent events raise additional serious concerns t about the safety of Pilgrim. Could Pilgrim experience the same j . i ( wild power oscillations that occurred at the LaSalle boiling l
?
water reactor in Illinois this year? Has Boston Edison analyzed I
,i !
Pilgrim's vulnerability in this regard, and have its operators I l
. t
__J
t
~, I 3-j been thoroughly trained to take the appropriate responses?
Has Boston Edison tested all the potentially defective pipen, , circuit breakers and other safety equipment that were recently revealed to have been fraudently certified as safety grade? What is the extent of embrittlement of key reactor equipment ' at Pilgrim? ; Thirteen years after the Brown's Ferry fire, has Boston Edison finally, completed the fire protection improvements required i by 10 CFR, Appendix R? Have the problems with the Main Steam Isolation Valve finally been resolved? ( P The U.S. General Accounting Office (GAO) last year criticized _;
- the NRC for not having resolved 163 "generic safety issues" that !
t may take up to ten years or more each to resolve and correct. ; i In fact, according to the GAO, additional generic safety problems
- are being found faster than the NRC is solving them. Many of j lc these problems directly affect safety et Pilgrim, yet because i l
l they have been labelled "generic", the NRC may allow Pilgrim r 0 1 4
.' to restart before they are resolved and corrected. I would hope l f'
that your Committee would investigate each of these generic issues f . as they portain to Pilgria specifically and would recommend in I ! { I view of Pilgrim's age ind prior operating history that the ' plant l not be allowed to restart until necessary corrective measures [ ! are undertaken. I The Governor, the Attorney General, and a large number of j l Massachusetts legislators have sought a full adjudicatory hearing [ I j pursuant to NRC regulations on these and other issues, so that () technical consultants could be called in to participate in a [ neaningful review of these matters with the NRC and the licer.aee. i f
4._ [} The NRC, however, has'thus far refused to conduct such a proceeding. It is imperative that you examine these matters carefully. The plant should not be allowed to. restart unlees these matters have > been satisfactorily and fully resolved. ; Mark I Containment I Another major reactor safety problem involves the flawed l t Mark I containment design of the Pilgrim reactor. Major NRC , staffers he.ve acknowledged that the Mark I. containment is likely to fail and release radiation during a serious maltdown. Two [ r years ago the NRC staff recommended five measures to reduce--though not eliminate--the likelihood of Mark I containment failure. Former NRC Commissioner James Asselstine felt that waiting until ( April of 1987 to implement them was an unwarranted delay. Yet i r [} now, almost a year and half after that date, the NRC has still [ not even approved these measures, let alone implemented them. l Finally, after a long delay, the NRC staff is expected to make its final recommendations on corrective measures in a month or two, Boston Edison har constructed one measure, a vent to relieve l overpressurization, but it has not been allowed to connect it [ to Pilgrim yet. Certainly the owners of Pilgrim should wait l until the NRC issues its recommendations on corrective measures, j 20 that they can implement them before they are allowed to restart { f the plant. l Because your Advisory Committee will be asked to review I and comment on the proposed Mark I improvements, I urge you to ( (} recommend that any additional vents include radiation filters , i
such as those that have already been added to reactors in various ( )' European countries. I also hope you will recommend the construction of barriers on the floor of the dry well to nelp prevent the flow of a molten core to and through the steel wall liner as postulated by the NRC's Reactor Risk Reference Document (NUREG-ll50, Vol. 1, p. 4-33). In addition, I urge you to consider other design features that are being added to foreign reactors, such as an additional, independent decay heat removal system, improvements in the reliability 1 of reactor control systems and emergency power supply systems, and equipment to protect against the loss of electrical power to operate cooling and safety systems. I believe it is unfortunate that Boston Edison recently installed a diesel generator that was not safety-grade.
- ( Furthermore, I urge you to call for the prompt initiation of a site-specific probabilistic risk assessment for Pilgrim l
4 so that appropriate additional, plant-specific improvements can be implemented as soon as possible. As you know, the NRC stated in NUREG-1150 that a probabilistic #sk assessment conducted for some other plant is not directly transferable to other nuclear reactors. Thus, a Pilgrim-specific probabilistic risk assessment { is needed. I Emergency Planning i j No plant is allowed to operate unless workable emergency i 1 response plans are in place that will protect the public's health j and safety. When the NRC established emergency planning regulations () after Three Mile Island, the Commission concluded that "adequate
emergency preparedness is an essential aspect in the protection O of the public health and safety." I hope that your Committee agrees with the Hendrie Commission that "the protection provided by siting and engineered design features must be bolstered by the ability to take protective measures during the course of an accident." Both the Massachusetts Department of Public Safety and the Fedecal Emergency Management Agency (FEMA) have determined that Pilgrim evacuation plans are not adequate to protect the public. Because the deficiencies for Pilgrim are so fundamental and extensive, as documented in a 100-page report by Secretary of Public Safety Charles Barry, substantial work remains to be done. I urge you to insist that workable emergency response plans be in place--and that no exemption be given concerning the requirement of a successful drill--before restart is authorized. It makes a sham of the entire emergency planning process to allow a plant to operate before adequate plans are developed to protect people in case of a bad accident. To do so is to play Russian i roulette with people's lives. Plant Management NRC Commissioners, in testimony to Congress, labelled Pilgrim one of the worst-managed plants in the nation. The recent SALP, which places Pilgrim with the 13th worst SALP average in the nation, has provided little solace to the residents of communities surrounding Pilgrim. If Pilgrim received such a low ovaluation when it was not running, what should we expect if it is allowed ! to restart? O
.,..- i Conclusion l -0 Citizens of Massachusetts are disturbed that the NRC appears to be willing to go to any lengths to encourage the operation i of nuclear power plants. The NRC often acts more like an advocate l than a regulator. We have reached a sad state of affairs when the public has no trust in the experts who are supposed to protect !
them and ensure the proper operation of these plants, j I hope and trust that you will utilize your expertise and ! your influence to assure that Pilgrim does not restart until ( 1 and unless all outstanding reactor safety issues have been corrected,
- workable emergency response plans are in place, and management has demonstrated a substantial improvement in its ability to t
I operate Pilgrim safely. i ; Thank you, t j . l ! l i 1 ( } J ) ) (2) I
._.. _.__ _ . _}}