ML20154E036
| ML20154E036 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 10/01/1987 |
| From: | Agnes P MASSACHUSETTS, COMMONWEALTH OF |
| To: | Mark Miller NRC |
| Shared Package | |
| ML20150E217 | List: |
| References | |
| FOIA-88-198 NUDOCS 8809160199 | |
| Download: ML20154E036 (10) | |
Text
_.
t; l
/?l/? M2/ N /SC Q
- O 480 U4LYd' e.
&nsc qtpqAm Mg 0~tv..?bbbtdan.tkue.
%st BenY k/.vo.. Nl,uacAwM rt/M (cit) nr.nr.1 MEMORANDUM TO: MARIE MILLER, NRC STATE LIAISON OPPICER FROMt PETER W. 7 M ASSISTANT SECRETARY DATE: OCTCBER 1, 1987 RE: MEETING SCHEDULED FOR OCTOBER 8, 1987: PROPOSED AGENDA
- 1. On the basis of our telephone conversation yesterday, I propose the following agenda items for our meeting on October 8, 1987 in King of Prussia, Pennsylvania:
(a) Status of HRC Review of Security Violations reported by BEco. and allegations of excessive overtime.
(b) HRC Position on offsite emergency planning deticiencies identified in the August, 1987 FEMA Interim Finding and by the Commonwealth of Massachusetts in Secretary Barry's report of December, 1986.
(c) HRC Response to BECo. proposal to postpone Biennial Exercise.
(d) Review of, and if possible the schedule of, the events that are planned between now and the determination by the NRC whether to permit restart of the Pilgrim Plant.
e oo E'
(e) HRC position on Proposed federal legislation (!!.R.
8 c) 1570) to establish national offsite monitoring system for all O C licensed commercial nuclear power plants.
(f) Status of Proposed Rev. 4 of Emergency Procedure Guidelines Developed by BWR Owners Group and NRC position on whether these will be mandated before Pilgrin is allowed to
]
gz ggg restart.
ca a.n (9) NRC position on BECo.'s Safety Enhancenent Program, i ncludi ng, in particular, the Proposed Torus Vent.
( b) NRC position on state's determination to enlarge the BM Pilgrim EP3.
t O
C/??//Zd/244fC
/
(Z
&if e_m e%eamsp, he,,,,
hrw h bu/M $ r "2w
%,...r~., a m m a,,,,,,.,,,,
EXECUTIVE
SUMMARY
OF THE PROGRESS REPORT ON EMERGENCY PREPAREDHESS FOR AN ACCIDENT AT P!LGR!M NUCLEAR POWER STATIOF E_XECUTIVE S_UMMARY_
On December 16, 1986, I transmitted to the Governor a comprehensive report on safety at Pilgrim Nuclear Power Station.
This is a progress report about the activities by state and local government, the Boston Edison Company, the U.S. Nuclear Regulatory Commission and the Federal Emergency Management Agency since that time to address the concernt we i
found.
i In April of 1986, operation of Pilgrim Station was halted because of several mechani-cal problems.
The U.S.
Nuclear Regulatory Commission has ordered that the Bostor.
Edison company keep the plant shut until a variety of corrections regarding the management and operation of Pi* grim Station have been made.
As of this date, Pilgrim remains closed, although Boston Edison has asked the NRC for i
permission to restart the facility.
In my December, 1986 report, I concluded that Radiological Emergency Response plans for the Pilgrim 1
l facility were not adequate to protect the public health and j
safety.
I further identified serious problems regarding the management of the power plant and the engineering safety of the reactor.
In my view, these three issues -- amergency i
planning, plant management, and reactor saf ety -- were to serious and the weaknesses and deficiencies so severe t5tt I recommended that the plant should not be allowed to restart unless and until these concerns had been satisfactorily i
addressed.
l There has been a considerable amount of activity at all l
levels to address these concerna since my report was issJed.
In some cases substantial progress has been made.
In j
t l
particular, the Massachusetts Civil Defense Agency and office l
of Emergenc/ Preparedness has devoted all available staff and resources to the effort of developing the best possible energency response plans.
l
. _.,,,_,. ws.
. MCDA/0EP has instituted a planning process at the state and local level and revisions are well under way.
In addition, a new system has been installed for of f-site notification in the event of an accident at Ptigrin station.
We now have the advantage of a new Nuclear Safety Emergency preparedness Program and a professional staff which for the first time is dedicated to of f-site emergency preparedness and planning.
This new program and staff are the result of the Covernor's initiative in the riscal Year 1988 budget.
The Governor has requested additional funds for the new progran as a supplementary appropriation for the current fiscal year.
Nonetheless, I continue to make the finding that adequate plans for response to an accident at Pilgrim Station do not exist, and I reaffirm my earlier position that the pilgrim f acility should not be allowed to restart until such plans have been fully developed and have been demonstrated to be workable and effective through a graded exercise of all j
plans and fccilities.
This finding is based on the fact that in every critical area in which I found a deficiency to exist in my December, 1986 report substantial work remains to be done before a 4
determination of adequacy can be rade.
For example, analysis 1
of a new Evacuation Time Estimate and Traffic Management J
Study by state and local authorities is still underway.
The CTE is one of the most critical pieces of information in the i
entire process and the f oundation of ef f ective emergency planning.
Our preliminary review of the ETE suggests that rore resources are required to successfully implement the traffic ranagement plan.
The shelter survey which was prepared by loston Edison has been returned to the company f or f arther study because is was found to be woef ully inadequate.
plans and implementing procedures for special needs 3
i populations remain incomplete, and it may be necessary to undertake an additional survey of people who would need assistance in emergency response or to do f urther statistical 4
analysis of this patter.
The development of implementing procedates and the identification of resources to care for i
sci.ool age populations also requires additional work.. In
)
regard to the adequacy of recepe. ton centers, the question of need for a f acility to serve people in the northern portion of the EP2 remains open.
We cannot make decisions on the need for or identification of a third reception center until Boston Edison has provided us with an analysis of the adequacy of the existing two reception f acilities.
. w s., m,
ne an w_.
-3 With regard to plant management, we have seen numerous changes in hoston Edison's personnel and organization for management of Pilgrim Station.
The most notable change is the appointment of Mr. Ralph C. Bird as Senior Vice President, Nuclear, who directly reports to the company's chief executive officer.
Yet despite these changes, I cannot say at this time that the management problems have been fully resolved.
For examplo, we are concerned about recent incidents including violation of NRC regulations in the area of plant security, and allegations of excessive overtime worked by utility employees.
We are also concerned by Boston Edison's action to refuel Pilgrim Station without having responded to my objections and the objections of several state legislators.
The Systematic Assessment of Licensee Performance ($ ALP) perfomed by the NRC is the most comprehensive study and report on nuclear management at Pilgrim Station,.
The last SALP report was issued on April 8, 1987 and it showed deterioration in several aspects of nuclear management since the last report.
Until a similarly comprehensive analysis of management under the new organization has been conducted and the above concerns resolved, I cannot concerns have been addressed.
say that our management 4
With regard to reactor saf ety issues, we have caref ully reviewed Boston Edison's "safety Enhancement Program" (SEP).
The SEP has been undertaken since the issuance of a "Draf t 1
l Generic Letter" from Mr. Robert Bernero of the NRC concerning safety at Mark I containment 4ttucturec such as the Pilgrin t
containrent, We have two major concerns in the area of reactor safety, s
First, despite the fact that the NRC letter was prompted by a finding that there was a high probability of Mark I containment failure during certain severe accident
)
scenarios, the NRC has yet to adopt an official position regarding safety enhancement.
Moreover, according to NRC Region I Administrator William Russell, with whom my staf f and other state otticials met at NRC's regional of fices in King of Prussia, Pennsylvania on october 8, 1987, enhancement of the Mark I containment at Pilgrin is not an issue that the NRC 1
believes must be finally resolved before restart.
i Our second concern is the uncertainty that continues to exist about at least one feature of the Boston Edison SEP, the direct torus vent.
No concensus has been reached on whether installation of the torus vent creates unreviewed I
te tMm tai 20 men wiw 4
safety issues or if the torus vent is authorized, how it will be used in the event of a severe nuclear accident.
The findings of my December, 1986 report have been strengthened by two other analyses of safety at Pilgrim Station.
The Gpscial Joint Legislati'te Commission to Study Pilgrim Station has issued its report which further studies and documents many of the same saf ety concerns.
In addition, the Federal Eme rgency Management Agency has issued a Self-Initiated Meview of plans for response to an accident at Pilgrim Station.
Based on several of the issues raised in my report FEMA has changed its interim finding and new agrees that the off-site plans for an accident at Pilgel.a are not a dequitt e,
i fBMA has transmitted their new finding to ti,e Nuclear Reg ula *,ory Commission.
However, the NRC has yet to indicate whethet or not development of adequate off-site plans will be a condition to the restart of Pilgrim.
We are not satisfied with the view recently expressed by the HRC Region I staff t hait emergency planning problems must be "addressed" before restart.
Such problems must be satisfactorily resolved before restart.
Off-site response plans are just as important ta nuclear management and reactor safety in protecting the public from an accidental rsigase of radiation.
Therefore, for these reasons -- the absence of adequate energency response plans, lack of demonstrable assurance thLt i
managenent problems have been solved, and uncertainty about the safety of the Mark I containment structure -- I continue to find that Dosto3 Ediaen has not met the heavy burden of showing readiness to ' restart the Pilgrin Nucleat-Power plant.
I also continue to believe that it remains to be seen if adeqJate emergency respCnse plans Can De dwyeloped and if all other saf ety issues can b5 resolved to our satisfaction.
Finally, I recomnend that in light of the number of out standing issues end t'.neir complexity, and Boston Edison's evident determination to press ahead with the ef f ort to restart, that there should be a full scale public hearing by the NRC before any decision is made regarding the restart of Pilgrim Station.
October 14, 1987 CHARLES V.
BARRY StCRETARY or PUBLIC SAFETY
e'
-e-02504171 8
News Release i
Attorney General James M. Shannon Commonweafth of MassachuSens FOR IMMEDIATE RELEASE THURSDAY, OCTOUER 15, 1987 SWANNUN PETIT 10HC NRC TOR TORMAL HEARING ON PILCRIM RESTART 1
Attorney General James M. Shannen today filed a petition with the Nuclear Requiatory Com.Tission (NRC) requesting an order to show cause why the Pilgrim Nuclear power Plant should not remain closed until a full adjuoicatory hearing resolves the serious l
j safety prcblea<s posed by the plant's poor meragemen'., faulty structural design ano inadequate eraerger.:y planning.
Shannon said the petition f orces the NRC to consider neV issues underscoring the plant's serious deficiencies.
Shannon's petition, filed on behalf of his office and Governor I
Michael S. Dukakis, also asks the NRC to issue en imnediate order
)
bar ring the Boston Edison Corpany (BEGo.) from taking further actions to restart, j
"The puLlic deserves a complete hearing en the safety vf this troubled nuclear f acility," Shannon said.
"We desurve the s'ight to have Boston Edison meet the burden of proof in a public h44 ring that it can operate this p1' int saf ely -- sor.ething which it nas yet to prove.
j "If this petition is granteo, and we hope that it will be, we i
-more-i i
Afery Breslover, 1 Ashburton Flece Press Secretsry Boston. MA 02108 1693
~,.
.t.
provide exper t testimony to the NRC on each of the saf et/
wil]
We would expect Boston Edison to f
issues raiseo by our petition.
khile Boston Edison and the NRC continue to argue
\\
do the sara
.n 'rion to restart the plant should not be made otherwise, th without meanin' public scrutiny."
Governor Dukakis said the action was "necessary because there are too many outstanding public saf ety issues that have not been Pilgrim is acequately aodressed by the NRC and Boston Edison.
just not ready to open.
"he remain concerned about the saf ety of the reactor, the structural integrity of the containment vessel, serious management i
ceficiencies, and the lack of an adequate evacuation plan.
Therefore, a full public hearing must be undertaken to consider these serious safety issues before any decision is made concerning whether the power station resumes operation," the governor said.
"The bsalth and saf ety of our citizens depend on it."
The Pilgrim power plant has been shut down since April 12, f
1986 when the NRC cedered it closed after recurring operational In July ISS6, Shannon Joined as a private citizen in ar, problems.
earlier petition filed with the NRC by the Massachusetts Public Interest Resaatch Group (MassPIRG).
That petition called on BECo.
to show why its Pilgrim operating license shouldn't be pulled structural and because of earlier evidence of management,
/
evacuation planning problems.
1987, the NRC re]ected aspects of the cetition In August
-more-
- %.-a
. ; w== w y.,- es.aui a m. %.wg an supg stne.wr; m e r;"U +,, -- -
a
-.-. g cualing with plant safety and evacuation planning questions but has yet to rule on the issue at management deficiencies.
The NRC l
ruling iollowed a repcrt by the rederal Emergency Management Agency (FEKA) ea-lier in August which f ound major deficiencies in i
Pilgrim's evacuation planning.
Because that report was not considered in the NRC ruling, MassPIRG and several other plaintiffs are appealing the NRC's decision in the First Circuit Court of Appeals.
Attorney General Shannon has filed a petition j
to intervene in that case.
Shannon said that while the NRC has said it will schedule public meetings in the Plymouth area prior to approving the plant's rostart, those meetings are not part of a legal process in which BEco, can be held accountable.
"What the NRC proposes is nothing more than a town meeting on Pilgrim," Shannon said.
"That simply Won't do.
The history of this plant has been so abysmal that nothing short of a full adjudicatory hearing will suffice.
We must have the opportunity
~
to present our experts and cross-examine BECo's management to deteritine if the company's bravado public statements actually match the facts."
Shannon's request is based on such evidence as:
Continuing serious managerial deficiencies. including new l
excessive overtime and secu ' / concerns.
Questions surrounding the 6 14*/ of the containment vessel itself.
The Pilgrim reacto'
' ' Mark I, a design which is
-more-
.c i a.
'; _ _.- suserswr i.
i e
f acknowledged by the NRC to be especially prone to f ailure in several possible accident scenarios; and I
Deficiencies in the evacuation plans for the area, as cited by both FEMA, the f eceral agency with the recognized expertise in amergency planning, and by the state Office of Public Safety.
Stating that "Pilgrim has been identified by the NRC as one of the worst run and least saf e plants in the country," the petition argues that BEco's past performance demonstrates that it lacks the managerial skills and/or commitment necessary to operate a nuclear facility.
"While the NRC's ef f orts to spur BECo. to a higher level of performance have, on occasion, met with some initial success," the petition argues, "a review of BEco's performance record sheys that all such successes have been short lived and that BEco appears to l
have an... inability to manage Pilgrim in an ef fective and saf e manner."
Specifically, Shannon's office charges that BEco has consistently received low ratings in the NRC's Systematic A sessnent of Licensee Perf ormance (SALP) reports.
In fact, every SALP report, with the exception of one for 1982-83, has foJnd a sign'
- ant weakness at Pilgrim, and recent reports reflect a declining performance.
Additionally, every time Quality Assurance has been assessed separately in a SALP review, 3Eco. has received the lowest possible rating.
"Given that Pilgrim is a GE Mark I design reactor and that the EPZ (Emergency Planning Zone) populatio, of the plant is among thq
' - ~ - - '
-l-
- I higheat. In the country," the petition concludes, "it is evident that the def leiencies in emergency plant.4ng and preparedness are significant for Pilgrim.
Further, the deficiencies are so subetential and their potential ramifications are so enormous, that it is impossible to conclude that any interim compensating actions have or can be taken and that the NRC's regulations leave it any course other than issuing a shut down orcer." i o
1 1
_