ML20196F242

Summarizes Observations Re Cv Barry Rept to Governor on Emergency Preparedness for Accident at Pilgrim Nuclear Power Station

ML20196F242
Person / Time
Site:	Pilgrim
Issue date:	01/21/1987
From:	Ronald Bellamy NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20150E198	List: ML20150E195 ML20195G141 ML20196F053 ML20196F242 ML20196F264 ML20196F327 ML20196F336 ML20196F342 ML20196F348 ML20196F412 ML20196F418 ML20196F424 ML20196F430 ML20196F443 ML20196F452 ML20196F459 ML20196F469 ML20196F474
References
FOIA-88-198 NUDOCS 8812120239
Download: ML20196F242 (23)

Text

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JAN 2 1 1987

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MEMORANDUM FOR:

Thomas T. Martin, Director, Division of Radiation Safety and Safeguards FROM:

Ronald R. Bellamy. Chief Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety and Safeguards

SUBJECT:

CHARLES V. BARRY DECEPBER 16, 1986 PILGRIM REFORT After an initial review of the Charles V. Barry "Report to the Governor on Emergency Preparedness For an Accident at the Pilgrim Nuclear Pcwer Station",

we have the following observations.

1.

Mr. Barry tv anstritted the report to thc Governor of Massachusetts on December 16, 1986.

Mr. Barry states that the Governor has accepted the conclusion that the current off-site radiological emergency plans for Pilgrim are inadequate.

2.

The report sumarizes the history of ernergency preparedness around Pilgrim, in particular:

The applicable NRC and FEMA regulations, their history, and how they a.

are implemented; b.

Emergency plans were certified by a fonner Comonwealth of Massachusett.s Governor June 16, 1981, and submitted to FEMA for fonnal approval under 44 CFR 350.

RAC reviews generated coments and plan deficiencies, for which FEMA is awaiting response.

FEMA has put the 350 review process for Pilgrim on hold, awaiting resolu-tion of identified items, c.

On four occasions since 1981, FEMA has concluded that plans for response to an accident at Pilgrim provide reasonable assurance that the public can be adequately protected.

3.

Excerpts from the recent NRC SALP report, and other NRC management comitments (including Dr. Murley's August 27, 1986 request for a readiness assessment status from BECo prior to restart) are included.

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4.

A sumary of the findings of the October 21 - November 3,1985 INP0 evaluation is included.

5.

The concerns of Mark I contairments, and the following potential improve-ments in accident mitigation for Mark I containments, are identified:

a.

Establish stricter hydrogen controls; i

b.

Improve drywell spray system; c.

Establish reliable pressure control on venting capacity; d.

Ensure debris control; and Institute new policies and procedures for operators, managers and e.

state officials to make appropriate protective action decisions in an accident involving core damage.

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2 6.

The r.umerous appendices (to include copies of regulations, speeches, meeting sumarius, testimony, and supporting documents) are of public record.

7.

The report contains the follcwing specific recomendations that Mr. Barry states the Governor insis,ts must be taken before any consideration is given to restart:

NRC to transmit a copy of the report to FEMA (accomplished January a.

16,1987).

b.

Comonwealth of Massachusetts to create, by Administrative Order, a Technological Hazards Division within the Civil Defense Agency, funded by nuclear utilities to 1) u Pilgrim Radiological Emergency Response Plans (RERp), and 2) pgrade create and maintain a state-wide emergency response data base of all available material and personnel resources.

Massachusetts Civil Defense Agency to file a work plan, within 10 c.

days of the Administrative Order, to upgrade the Pilgrim RERP.

d.

Governcr's Advisory Council on Radiation Protection to study 1) expanding the EPZ and, 2) dissemination of emergency planning infor-mation to the public, Massachusetts Civil Defense Agency to publish, within 30 days of the e.

Administrative Order, plans for annual review of RERP for Pilgrim, Rowe and Yemont Yankee, f.

Governor's Advisory Council on Radiatier Protection to report, within 30 d ys of the Administrative Order, en installing off-site radiation monitoring systemt around the plants, Boston Edison Con,pany, within 10 days of the Administrative order, g.

should:

1.

Make significant contribution to creation of the Technological Hazards Division; 2.

Improve comunications with transport vehicles by studying the feasibility of instal'.ing NOAA tone alert radios in all school buses and other vehicles, to include those vehicles used for the elderly and handicapped, and also the schools themselves; i

3.

Prepare updated Evacuation Tire Estinate study as quickly as possiblet 4.

Prepare a comprehensive shelter survey; I

5.

Improve distribution of Emergency Planning Infomation to the public in the EPZ; 1

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3 6.

Improve comunications with State and Local Officials by hardware improvements (or replacerent) to radio system; 7.-

Obtain FEMA and /assachusetts Civil Defense certification of Siren and Alert and Notification System; 8.

Make all hardware and procedure improvements at the plant reovired by the NRC to mitigate severe accident consequences; and 9.

Address all management problems that have surfa ed in the past year and provide an accounting to the public prior to restart.

The report is sumarized as being a "proposed... plan of action" to improve four areas of concern:

plant management; reactor safety; regulatory enforcement; and emergency planning.

Runald R. Bellamy, Chief Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety and Safeguards cc:

T. Murley, RI J. Allan, RI W. Kane, R1 S. Ebneter, R1 S. Schwartz, HQ D Matthews. HQ J. Gutierrez, R1 W. Lazarus, R1 J Wiggins,feQ 4 F

J. Schumacher, Ri M. McBride, SRI i

R. Bores, RI P. Leech, hRR I

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l Reportable Event number 10911,

Facility :

PILGRIM Date Notified : 12/08/67 Unit 1

Time Notified i 23:25 Region : 1 Date of Event 12/08/87 Vendor i GE Time of Event 21:45 Operations Officer :

James Brown Classification : 10 CFR 50.72 NRC Notified By STU MINNENHAN Category 1 ESF Actuation Rad Release ! No Category 2 :

Cause : Procedure Inadequacy Category 3 Component Category 4 :

EVENT DESCRIPTION i

UNIT IN REFUELING. UNIT WAS IN THE PROCESS OF PERFORMING A HYDRO WHEN IT RECEIVED AN INBOARD S/D COOLING CONTAINMENT ISOLATION VLV CLOSURE (VLV "1001-50") PER DESIGN WHEN RX PRESSURE EXCEEDED 100 PSI. THE OUTBOARD S/D COOLING CONT. ISOL. VLV WAS AIR!:ADY CLOSED PER PROCEDURE. THE INBOARD VLV WAS NOT EXPECTED TO C CSE AS THE INTERLOCK W/ RX PRESSURE (MODE WITCH DEPENDENT-SHUTDOWN) WAS SUPPOSEDLY JUMPERED OUT;HOWEVER, THE LOGIC WAS NOT PROPERLY JUMPERED OUT FOR THE OUTBOARD ISOL. VLV AND WHEN RX PRESS. EXCEEDED 100 PSI IT SENT A SIGNAL TO CLOSE BOTH VLVs. SYSTF.M FUNCTIONED AS DESIGNED. RX PRESS WAS REDUCED AND THE ISOLATION RESET. THE PROCEDURE IS TO BE MODIFIED AND THE NYDRO TEST PERFORMED. RI WILL BE INFORMED. NOTIFIED RDO(KEN MURPHY).

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f CT Repor tcblo Event F4 umber 10664 i

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(3 Facility :

PILGRIM Da t e F40 t i f i ed : 11/12/07 Unst : 1 Time Notified : 02:55

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Regson : 1 Date of Event : 11/12/G7 gg vendc.r : GE Time of Event : 02:10 Operations Officer :

TOM SILhD Classsfication : 10 CFR 50.72

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NRC F40t i f ied Cy : MI NAllAN Ca tegor y 1 : SCRAM gg Rad Release : No Category 2 : LOSS OF OFF-SITE PWR Cause : Clectrical Fa i l ur e Category 3 :

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Component : SWITCH YARD Categor y 4 :

gg CORE FU.'Y LOADED WITH THE UNIT COLD AND MODC SWITCH IN REFUELING. SEVERC g

jg WEATHER (40-50 MPH WINDS WITH SNOW) ilAS CAUSCD A LOSS OF OFF-SITE POWCR AT g) 1HE SITE. PROULEM IS DELIEVL D TO CC WITH THC LICENSEES SWITCHYARD. COT;I i

I DIESELS STARTED AND LOADED AS REOUIRED AND ARE CARRYING llOUSE LOADS. AN 3

OPERATOR IS ASSIGNED TO TitC DG's AND THEIR OPERATION IS NORMAL. PLANT IS gg STAbtE. EFFORTS ARE UNDERWAY TO DETERMINE PROCLCM AND RCSTORE OFF-SITE POWER.

A SCHAM SIGNf,L (NO ROD MOTION) WAS ALSO RECEIVED (PER DESIGN) ON THE LOSS OF POWER.

LICENSEE WILL KEEP HOO INFORMCD OF CllANGCS IN PLANT STATUS. RI WILL

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DF INFORMLO CY THE LICENSEE. NOTIFIED RIDO (CAPHTON), R1 (WIGGINS), R1 (CLOUGH). *** UPDATE AT OOOOHRS *** AN ADDITIONAL CONCERN AT THE PLANT IS THE ADILITY TO OPEN Tite SCRAM DISCHARGE INSTRUMENT VOLUME (SDIV) VENT AND DRAIN

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VALVCS AND CLOSE Tile SCRAM INLET AND OUTLET VALVCS. Tilt SCRAM SIGNAL HA3 BCCN RLSET CUT DUE TO THE LACK OF INSTRUMENT AIR PRESSURE (3 AIR COMPRESSORS ARE 3

POWEREO FROM NON-VITAL DUSCS AND TitCREFORC DECNCRGIZCD, AND TWO OF

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TitC THREE COMPRESSORS FROM THE VITA;. CUS ARE OUT FOR MAINT), THE ACOVE VALVES l

CAN NOT CC RETURNEO BACM TO THEIR NORMAL POSITION. THIS IS NOT A SAFETY

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SIGNIFICANT CONDITION WITil TitC PRESENT PLANT CONDITION. NOTE: REGION 1 IRC g3 MANNED AT 0430 HRS.

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f A-I POTENTIAL DEGRADATION OF CONTAINMENT SPRAY SYSTEM PROBLEM RUST FOUND IN THE PRIMARY CONTAINMENT SPRAY HEADER AND N0ZZLES AT PILGRIM SIGNIFICANCE SPRAY PATTERN AND FLOW RATE MAY NOT BE THAT ASSUMED INTEGRITY OF HEADER MAY BE COMPROMISED BACKGROUND

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PILGRIM SHUTDOWN AND DEFUELED SPRAY N0ZZLES BEING PLUGGED (6 0F 7 H0LES) 1 CONTA!'JMENT SPRAY IS A REQUIRED SYSTEM AT PILGRIM i

00ALITATIVE AIR TEST OF CONTAINMENT SPRAY SYSTEM AT PILGRIM IN 1982 SPRAY PIPING IN BWRs IS CARBON STEEL SPRAY PIPING IN PWRs IS STAINLESS STEEL 1

CONCLUSIONS OPERABILITY T$ST FOR CONTAINMENT SPRAY SYSTEMS MAY NOT BE ADEQ FOLLOWUP LICENSEE TESTING N0ZZl.ES WITH RUST STAFF TO ASSESS NEED FOR SPRAY 4

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Reportable Event nu@ e'r 08516.

Fccility PILORIM Date Notified 8 04/28/87 Unit 1

Time Notified 19:15 f

Rosion 1

Date of Event t 04/28/37 Vendoe GE Time of Event 18:30 l

Oporations Officer Joseph Olitter Classification 8 10 CFR 50.72 NRC Notified By NEN TAYLOR Catesory 1 b.2.1 R3d Release No Catesory 2i Cause Elect $1calFailure Catesory 3 :

Ceaponent DIFF LOCKOUT SWITCH Catesory 4 8 EVENT DESCRIPTION I UNIT IS IN COLD SHUTDOWN.

IN THE PROCESS OF OETTING READY TO RUN THE "B"

EDO LOADED FOLLOWING ITS QVERHAUL. OPERATORS DISCOVERED DAMAGE TO THE DIFFERENTIAL LOCKOUT SWITCH.

EDO "B" WAS RECENTLY OVF.RHAULED AND HAD BEEN TESTED PERIODICALLY DURING THE LAST COUPLE OF DAYS UNLOADED.

OPERATORS RACKED UP THE OUTPUT BREAKER IN PREPARATION TO RUN THE EDO LOADED AND i

RECEIVED A 'B EDO AUX RELAY TRIP' ALARM.

UPON INVESTIGATION IT WAS DISCOVERED THAT THE DIFFERENTIAL LOCKOUT SWITCH WAS DAMAOED--APPARENTLY IT HAD GOTTEN EXTREMELY HOT BECAUSE INSULATION AROUND THE SWITCH HAD MELTED.

LICENSEE IS CURRENTLY TRYINO TO DETERMINE WHEN AND HOW THIS DAMAGE OCCURRED.

l Q SIMILAR PROBLEM WITH DIFFERENTIAL RELAYS OCCURRED ABOUT 6-7 MONTHS AGO.

i NOTIFIED RDO (ANDERSON).

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l Repsetable Event number 06513.

l Focility FT. CALHOUN Date Notified 1 04/28/87 Unit i 1 Time Notified i 1 $8 00 Rooton 4

Date of Event t 04/23/67 Vondor a C-E Time of Event i 12:13 Oporations Officee Joseph Otittee Classification 10 CFR 50.72 49C Notified By FRANK SWIHLE Catesory 1 ESF Actuation sd Release No Catesory 2

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........... ~..

MEETING BETWEEN BOSTON EDISON AND NUCLEAR REGULATORY COMMISSION BACKGROUNO DOCUMENTS TAB NUMBER ITEM 01.................. Agenda 02..................Fac111ty Statistics

03.................. BEco Organizational Cha rt

04.................. Mu rl ey N o t e s

05.................. C AL 86-10 of 04/12/86

06.................. Letter f rom Dr. Murley to BECO of 08/27/86 regarding need for Restart Assesment

07.................. SE P Program (07/08/87)

08.................. Ini tial Assessment of SEP (08/21/87)

09..................Lette r to BEco rega rding FEMA report (08/18/87) 10..................BECo response to 08/18/87 letter on EP T/C 1

MEETING BETWEEN BOSTON EDIS0N AND NRC SENIOR MANAGEMENT 9/24/87 - 1 p.m. - 4 p.m.

Phillips Building - Conference Room Pll8 Bethesda, Maryland AGENDA NRC Introduction Boston Edisoi, Introduction Restart Plan Managerent Inpronements Closure of Restart Regulatory Responses Power Ascension Program and Panagement Assessment Process

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Outage scope and Schedule Safety Enhaacement Program Offsite Emergency Plan 4

Action Plan Esemption Request Concluding Remarks Boston Edison hRC f

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7/ir/n Plant:

Pilgrin Nuclear Power Plant License No. OPR-35 Docket: 50-293

,0wner/0perator:

Boston Edison Company Address:

Boston Edison Company M/C Nuclear ATTN: Mr. Rclph G. Bird Senior Vice President, Nuclear 800 Boylston Street Boston, MA 02199 WR1 Tyye,:

Boiling Water Reactor e

NS$$ Sup 211er/AE/ Turbine Supplier: GE/Bechtel/04 Max. Capacity:

1998 W t, 690 We (gross), 670 MWe (net)

Fuel:

580 fuel assemblies (8 x 8 design) active fuel height 3

~~

= 144 inches; sintered U0, pellets; core volume = 1740 ft ;

Zircaloy clad; 4 types ave, enrictnnent 2.19, ?.62, 2.65, 2.82%

Control:

145 sheather crucifortn array of SS tubes filled with boron -

carbide powder - controlled by hydraulic control units. Each control rod is surrounded by 4 fuel assemblies. The CRDN is a double acting mechanically latched hydraulic cylinder, Reactor Yessel:

224 in. 10; 770) in Ith; 5.7 in, thick; design pressure and temperature: 1250 psig e 575'F; St.533Gr8 Carbon Steel /

clad with S.S.

Therr.a1 &

1020 psia operatint pressure; 359'F feedwater temp; 558'F Fydraulic:

average fuel rod surface temp; four (4) 20 in, dia. steam pipas; two (2) 28 in. dia, recirculation linest rec lgculation pump flow rate 45,200 gpm; steam flow rate 7.98 x 10 lb/hr.;

255 turbine bypass valve capacity.

Certainnent:

Primary - light bulb shape - steel 56 psig interral design pressure, 281' temperature;.51 f ree volure/ day design leak

( N'k N rate. Secondary - reinforced and precast concrete steel sheet roofed building; design controlled leakage 1001/ day I

at.25 in. H,0 vacuue; includes Standby Gas Treatment Systee and reau ir butiding ventilation isolation systee.

ECCS:

Quantity Drive h

GPM HPCI 1

Str 4250 A05 4 SRV's N/A Safety 155 f.tm Relief Valve CS 2

Elec.

Centrif. 3600 LPCI 4

Elec.

Centrif. 4800 (RCIC 1

Stm 400)

Containment Torus /drywell cooling provided by 4 RHR purps via 2 RHR HX's; cooling:

6 RBCCW puwps; 2 RBCCW HX's; and 5 Salt Service Water pumps.

Electrical:

Offsite Pcwer: 2 345 Kv. Trans. lines 1

24 Ky. Trans. lines Battery: 125, 250 V DC Diesel Generator: 2 ?600 KW (.8PF), 4160v.

9/t[57 h] u.w 7

%w BO5 TON EDISCN C0".PANY PILGRIM CHA!RW.AN BOARD 08 CIRECTORS AND CHIEF EXECUTIVE OFFICER r

5, Sweeney I

l SENIOR VP, NUCLEAR i

R. Eird I

EXECUi!VE ASSIST ANT-----------!- - -

[No. $(([

(0wtage Oversight)

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Sta YA elb R. Ledgett 1

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I V.P. NUCLFAR EN31NEERING OIRECTOR V.P. NUCLEAR AND QUALIT1 A55URANCE PLANNING &

OPERATIONS RESTART E. Howard D. Gillispie Va: ant I

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hUCLEAR bf.1USiv6 I

NUCLEAR OVALITY EN31N j l

MANAGE.

A55URANCE I

0.Cronin H.Brannan 0.5wanson l

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i FlRC NUCLEAR E. P.

TRAIN!N3 PROTECTION SECURITY OPERATIONS COORDINATOR E. Ziemianski G. Votnial C. Higgins K. Roberts

4. ON-I S. Hook l

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TECHNICAL.

DVTAGE OPERATION 5 RADIOLOGICAL MINTENANCE SECTION MNAGER SECTION SECTION SECTION J. Seery N. Brosee

5. Hudson T. Sowdon R. Sherry i

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-PROPOSED OPENING REMARKS-by Dr. Murley Pilgrim has been shut down since April 1986. Over the past several years, significant facility deficiencies have been identified through the inspection process and were reported in the Pilgrim SALP. We note that BEco has Javoted substantial resources totard resolving these deficiencies and welcome this opportunity for BECo co present the scope and status of its restart plan.

However, we recognize that considerable effort remains.

Although the staff has been quite active in its review and inspection efforts at Pilgrim, we must satisfy ourselves that programs established by BEco are not only adequate, but that these programs have been implemented and are effective. We feel that our reviews will take at least eight weeks from the tire we have received a complete and corprehensive restart assessment package from BEco, The conduct of these reviews will be coordinated through a Pilgrim Restart Assessment Panel.

Bill Russell will briefly sumarize the panel's makeup and activities in a moment.

Several technical areas are of particular interest. As you are aware, the staff has found a nurrber of your Safety Enhancement Program modifications acceptable; however there are a nurrber of unresolved questions regarding the Direct Torus Vent. Additionally the staff will review recent changes to your I

emergency operating procedures. We also recognize the efforts being made by BEco to resolve the emergency preparedness deficiencies identified by FEMA.

Although consideration of an exemption to the biennial exercise may be l

premature, we 1(,ok forward to understanding your progress in this area.

NOTE: The following 5 pages provide additional information in support these i

remarks.

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Level of NRC staff activity on Pilgrim is high and will remain high in the next few months.

The level of Comission interest as well as level of public intarest in this facility is high, Resolution of SALP and Technical Issues BECo has generally been optomistic regarding their schedule for dealing with many of the M 1 grim issues.

BECo must demonstrate substantial improvements and progress in areas of SALP "3" and resolve the technical issues identified by the staff as necessary for restart.

We will promptly look at technical issues and items when we have confidence BEco is ready for our inspections and review.

Staff must receive results of BEco's self assessment and have time to make our independent evaluation.

111. Management issues BEco has made a number of management changes and instituted programs to address NRC concerns.

NRC must satisfy itself that management changes have brought substantial improvements and that new programs are effective.

A successful Diagnostic Inspection and satisfactory completion of the staff assessment of BEco readiness are key aspects of a staff decision regarding restart.

I !Y.

Safety Enhancement Procram (SEP)

Staff evaluation of SEP (submitted 7/8/87) was transmitted to REco August 21, 1987 Staff found a number of the SEP modifications acceptable under provisions of 10 CFR 50.59 or approved related Technical Specification changes.

These include:

Containment Spray Nozzle Modification Diesel Fire Pump Diesel Fire Pump Fuel Oil Transfer System Blackout Diesel Generator ATVS Feedwater Pump Trip ATWS Recirculation Pump Trip Enriched Boron to SBLCS (Tech. Spec.)

ADS Logic Modification (Tech. Spec.)

The generic issue of torus venting is still under evaluation. We look forward to your response to our questions in this area, but expect it may require extensive deliberation before we are prepared to rake a decision on this issue.

As a related matter, we expect to expand our review of your Emergenca Operating Frocedures and Procedure Generation Program.

The staf f has not yet approved Revision 4 to the Emergency Procedu 1 Guidelines and we must assure ourselves that BECo work in this area is consistent with our approach.

4 V.

Emergency preparedness issues FEMA report was transmitted to BEco on August 18, 1987.

FEMA concluded Massachusetts offsite radiological emergency planning and preparedness was inadequate.

FEMA identified six issues:

1.

Lack of evacuation plants for public and private schools and daycare centers.

2.

Lack of a reception center for people evacuating to the north.

3.

Lack of identifiable public shelters for the beach population.

4 Inadequate planning for the evacuation of the special needs population.

5.

Inadequate planning for the evacuation of the transportation dependent population.

6.

Overall lack of progress in planning and apparent diminution in emergency preparedness.

_ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ We have received your letters of September 18, 1987, and the staff is reviewing your progress with State and local entities.

Consideration of any exemption may be prenature at this tine.

BECo and the State must continue to work to resolve the issues identified by FEMA, t

FEMA's assessment of progress towards resolution and the conduct of the December exercise will need to be considered.

Yl. Conclusion Staff will continue its aggressive review of BECo actions at Pilgrim.

Restart Panel will coordinate staff actions and keep NRC Senior Management appraised.

It is a focal point for BEco to interface with NRC.

BECo must demonstrate that changes have been made and that management is successfully dealing with issues.

NRC cannot consider restart until all the issues raised during the facility's prolonged shutdown have been dealt with to our satisfaction.

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NOTES FOR REMARKS BY OR. MURLEY, i

I.

Introduction Pilgrim shutdown April 12, 1986 due to technical issues (MSIVs, containment isolation and intersystem leakage to RHR system).

Shutdown confirmed by CAL 86-10, of 4/12/86.

Issues and NRC concerns in a number of areas have expanded and on August 27, 1986, we stated our need for a formal reassessment by BEco of their readiness for restart.

SALP Report of April 8,1987 identified significant.~ificiencies (Category "3") in areas of:

-Radiological Controls (was "3" previous SAlp)

-Sarvet11ance

-Fire Protection

-Security and Safeguards

-Assurance of Quality l

BECo has devoted substantial resources towards the resolution of many of these issues and we view many actions, such as management changes, new programs, and in-plant improvements as positive steps towards eating the Pilgrim facility ready for restart.

i Still such to accomplish.

Areas of focus as BEco prepares for restart, include:

3

-$ ALP and Technical Issues

-Management Issues

-Safety Enhancement Program

-Emergency Preparedness Issues E

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Level of staf f activity on Pilgrim is high and will remain high in the next few months.

The level of Commission interest as well as level of public interest in this facility is high.

II.

Resolution of SALP and Technical Issues BEto must demonstrate substantial improvements and progress in areas of SALP "3" and resolve the technical issues identified by the staff as necessary for restart.

We will promptly look at technical issues and items when we have confidence BEco is ready for our inspections and review.

Staff must receive results of BECo's self assessment cnd have time to make our independent evaluation.

111. Management Issues BECo has made a number of management changes and instituted programs to address NRC concerns.

NRC must satisfy itself that management changes have brought substantial improvements nd t g new programs are offective.

(2Lp&r iM A successful Di c Inspection and satisfactory completion of the staff assessment of BECo readiness are key aspects of a staff decision regarding restart.

-3,

o IV, Safety Enhancement Program (SEP)

Staff evaluation of SEP (submitted 7/8/87) was transmitted to BECo August 21, 1987.

Staff found a number of the SEP modific tions acceptable under provisions of 10 CFR 50.59 or approved related Technical Specification changes. These include:

i Containment Spray Nozzle Modification Diesel Fire Pump Diesel Fire Pump Fuel Oil Transfer System Blackout Olesel Generator ATWS Feedwater Purap Trip ATWS Rectreulation Pump Trip Enriched Boron to SBLCS (Tech. Spec.)

ADS Logic Modification (Tech. Spec.)

The generic issue of torus venting is still under evaluation. We look forward to your response to our questions in this area, but espect it may require extensive deliberation before we are prepared to make a decision on this issue.

As a related matter, we expect to expand our review of your Emergency Operating Procedures and Procedure Generation Program.

The staff has not yet approved Revision 4 to the Emergency Procedure Guidelines and we must assure ourselves that BECo work in this area is consistent with our approach.

-4 V.

Eme*gency preparedness Issues

. FEMA report wes transmitted to BEco on August 18, 1987.

FEMA concluded Massachusetts offsite radiological emergency planning and preparedness was inadequate.

FEMA identified six issues:

1.

Lack of evacuation plants for public and private schools and daycare centers.

2.

Lack of a reception center for people evacuating to the north.

3.

Lack of identifiable public shelters for the beach population.

4.

Inadequate planning for the evacuation cf the special needs population.

5.

Inadequate planning for the evacuation of the taansportation dependent population.

6.

Overall lack of progress in planning and apparent diminution in emergency preparedness.

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5-We have received your letter of September

, 1987, and the staff is reviewing your progress with State and local entities.

Consideration of any exemption may be premature at this time.

BECo and the State must continue to work to resolve the issues identified by FEMA.

FEMA's assessment of progress towards resolution and t!o conduct of the December exercise will need to be considered.

VI. Conclusion Staff will continue its aggressive review of BEco actions at Pilgrim.

Restart Panel will coordinate staf' actions.

BECo must demonstrate that changes have been made and that i

management is successfully dealing with issues.

NRC cannot consider restart until all the issues raised during the facility's prolonged shutdown have been dealt with to our satisfaction.

}

MEETING BETWEEN BOSTON EDISON AND NUCLEAR REGULATORY COMMISSION BACKGROUND DOCUMENTS TAB NUMBER ITEM 01.................. Agenda 02.................. Facility Statistics b

03..................BEco Organizational Chart

04..................Mu rl ey No te s 05.................. CAL 66-10 of 04/12/86

06.................. Letter f rom Dr. Murley to BECO of 08/27/86 l

regarding need for Restart Assesment

07.................. SEP Program (07/08/87)

08.................. Initial As ses sment of SEP (08/21/87) 1 09.................. Letter to BEco regarding FEMA report (08/18/87) 10..

...............BE0o response to 08/18/87 letter on EP l

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UNITcO STATE 3 NUCLE AR REGUL ATORY COMMISSION a,s1/

3 wascotos.o.c tw

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August 21. 1967 Docket No. 50 293 Roston Edison Company ATTN: Ralph G. Bird

$*nior Vice President Nuclear 800 Boylston Street Boston, Massachusetts 0?199

SUBJECT:

INITIAL ASSESSMENT OF PILGRIM SAFETY RNHANCEMENT PROGRAM

Dear Mr. Bird:

On July 8,1987, Boston Edison Company (BEco) stbmitted a detailed description of the Pilgrim Safety Enhancement Program (SEP) to the NRC. This letter transmits the staff's initial assessment of this program (Enclosurel.

The staff's initial assessment has been conducted to provide an understanding of the SEP modifications and assess the safety significance of those changes, when considered singularly or along with other cianges. Additionally the staff examined your evaluations of these changes and the BEco schedule for inclenentation of the modi.~ications. The staff's review included a visit to Ceco offices in Braintree on July 22, 1987, convitrsations with representatives of your staff over the past few weeks, and a mee:ing with BEco representatives in Bethesda on August 4, 1987.

The staf f expects to continue its dialogue with llEco regarding the SEP program as part of its larger effort on severe accidents,. The generic issue o' containnent venting has been under consideration by BWR owners and the NRC for several years. It is a complex issue fraught wit.h conflicting safety objectives. Pecause the severe accident effort is ongoing, the staff is not prepared to endorse the use of the Direct Torus Yent System (DTVS) at this tine.

To assist the staff in its consideration of the DTYS, we request you provide the staff your written response to the concerns contained in the enclosure.

Installation of the DTVS under the provisions of 10 CFR 50.59 is precluded by the need for Technical Specifications on a containnent isolation valve.

i The staff still has questions regarding the propcsed modification to the I

reactor core isolation cooling (RCIC) system. Prior to implementing this i

modification the staff requests that BEco conduct an assessment of l

hydrodynamic loads on the RCIC piping and supports, based on the proposed i

exhaust pressure of 46 psig, and make the results of that assessment available to the staff.

l l

The staff requests clarification regarding the function of one valve in the backup nitrogen supply system. As described in the enclosure, valve A0 4356 appears to be a containment isolation valve and, consequently, would be appropriate for inclusion in the Technical Specifications.

$?C N700si I?/p

August 21. 1937 2

The staff requests clarification regarding the modification to the RHR system to provide additional sources of water for RPV injection and containment spray. This modification may require a change to the Technical Specifications.

As described in the enclosure, the valves to be added to the RHR system become part of the reactor coolant pressure boundary during operation of the RHR system and, consequently, are subject to surveillance testing.

We comend your efforts and leadership on this program. The quality of your July 8, 1987 submittal is impressive and the cooperation of your staff is a pprecia ted.

As you are aware, the NRC will continue its inspection of SEP modifications, review of affected plant procedures, and observation of related onsite activities. We will keep you infonned, should we have additional concerns about this program. Please contact the NRR Project Manager if you have any questions.

Si erely, ve

94. O re or Division of Reacto P jects I/l!

Office of Nuclear e :or Regulation

Enclosure:

As stated cc w/ enclosure See next page m

Mr. Ralph G. Bird Boston Edison Company Pilgrim Nuclear Power Station cc:

Mr. K. P. Roberts, Nuclear Oparations Boston Edison Company P11 grin Nuclear Power Station ATTN: Mr. Ralph G. Bird Boston Edison Cornpany Senior Vice President - Nuclear RF0 #1, Rocky Hill Rnad 800 Bo.vlston Street Plymouth, Massachusetts 0?360 Boston, Massachusetts 02199 Resident Inspector's Office Mr. Richard N. Swanson, Manager U. S. Nuclear Regulatory Comission Nuclear Engineering Department Post Office Box 867 Boston Edison Company Plymouth, Massachusetts 02360

?5 Braintree Hill Park Braintree, Massachusetts 02188 Chaiman, Board of Selectmer 11 Lincoln Street Ms. Elaine D. Robinson Plymouth, Massachusetts 02350 Nuclear Infomation Manager Pilgrim Nuclear Power Station Office of the Comissioner RFD fl Rocky Hill Read Massachusetts Departnent of Plyrouth, Massachusetts 02360 Environmental Quality Engineerirg One Winter Street Mr. Mike Ernst, Rrsearch Director Boston, Massachusetts 02108 Energy Comittee Statehouse - Room 540 Office of the Attorney General Boston, Massachusetts 02133 1 Ashburton Place 19th Floor Boston, Massachusetts 02108 Mr. Robert M. Mallisey. Director Radiation Control Progran Massachusetts Department of Public Health 150 Treront Street, 2nd Floor Boston, Massachusetts 02111 Regional Administrator, Region !

U. S. Nuclear Regulatory Comission 631 Park Avenue King of Prvssia, Pennsylvania 19406 Mr. Janes D. Keyes Regulatory Affairs and Programs Group Leader Boston Edison Company 25 Braintree Hill Park Braintree, Massachusetts 02184

Enclosure INITIAL ASSESSMENT OF PILGRIM SAFETY ENHANCEMENT PROGRAM Note: Section numb (,rs refer to section nurbers in the BEco submittal of July 8, 1987 1.

Sect. 3.2 - Installation of Direct Torus Vent System (OTVS)

The proposed design nodification associated with the direct torvs vent system (DTYS) provides a direct vent path from the torus air space to the main stack, in parallel with and bypassing the Standby Gas Treatment System (SGTS). The DTVS provides a new 8" line branching off the existing torus ourge exhaust line between the containment isolation valves (outside containment) with a reconnection to the existing torus purge exhaust line downstream of the SGTS. The new torus vent line is also provided with its own containrent isolation valve and a rupture disc set to relieve at 30 psig.

The installation of an additional branch line and containment isolation valve would require a change to the plant Technical Specifications. Therefore, it is our view that installation of the DTVS cannot be implemented under the provisions of 10 CFR 50.59.

To assist the staff in its consideration of the proposed DTYS, we request a written response to the following concerns:

1)

Provide comprehensive analyses of accident sequences, with their estimated frequency of occurrence, for which the vent would be called l

upon to operate, l

2)

Provide estimate of the fraction of those sequences where the vent would be operated but where the accident would have been terminated short of containment failure without vent operation. Consider the following situations in the accident sequences:

(a) tiectric power returned to service (b) equipment returned to service (c) mis-diagnosed situation corrected by operators 1

2 3)

Provide comprehensive analysis of those accident sequences that:

(a) could be improved by correct use of the vent, or (b) could be initiated or made worse by incorrect operation of the vent.

4)

Provide analysis of sequences that could lead to containment failure by operation of the vent followed by excessive pressure differential (buckling).

5)

Provide analysis of the probability of vent failure when called upon.

6)

Provide analysis of maintenance or surveillance errors on the vent system that could induce accidents.

7)

Provide an estimate of the radioactivity released for all sequences when the vent could be opened, including both correct usage according to procedures and incorrect usage due to human error or equipment malfunction.

2.

Sect. 3.3. Contaiteent Soray Header Nozzlet The objective of installing new containment spray header nozzles in the drywell is to improve the performance of drywell spray under severe accident conditions and to provide greater flexibility of use of the sprays under a variety of accident conditions. The replacement spray nozzles are identical to the existing nor:1es except that the replacement nortle assec61y has 6 out of 7 nozzle outlets capped while the original norrie assemblies had all 7 nortle outlets open. The effect of capping nozzles is to reduce drpell spray flow when the spray water is provided by the RHR pumps (5000 gpm) and preserve a basic spray pattern when the spray

3 function is perforwed using the new backup diesel fire purp (750 ppm).

Installation of the capped nozzle assemblies in conjunction with an RHR pump will reduce the drywell spray flow from the original design value of approxinstely 5900 gpm to a calculated spray flow rate of 543 gpm.

t Because installation of the new spray nozzles results in reduced drywell spray capacity and reduced flow through the RHR heat exchangerS the Itcensee evaluated the consequences of this modification. With regard to drywell spray flow capacity, the design basis (and licensing basis) require use of the drywell sprays within roughly 30 minutes after the onset of a small break LOCA in the drywell in order to reduce the drywell atnosphere terperature. In order to address this utter the licensee perfonned reentlysis of the containment response to steam line breaks for 2

2 sizes ranging from 0.02 f t to 0.5 f t, as originally discussed in the FSAR. The licensee detentined from the reanalyses that the reduced drywell spray ficw was sufficient to reduce the dryvell atmosphere terTerature and maintain the drysell liner temperature below the design temperature of ?81'F.

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Because total flew through the RHR heat exchanger would otherwise be l

l dranatically reduced when operating the RHR system in the containment spray mode, the operator will be instructed to open the RHR suppression pool bypass valve so that rated flom may be maintained through the heat exchanger and decay heat adequately removed.

f t

I testallation of this modification is expected to be completed before plant restart.

I Installation of this modification under the provisions of 10 CFR 50.59 appears acceptable.

i 3.

Sect. 3.4 - Additional Sources of Water for RPV Injection an

• Contain.

p nt Spray 1 e basic objective of this design change is to provide additional t

l sturces of water that are not dependent on AC power and thus available l

I for core cooling and containment spray Gring severe accidents, including station blackout. The design modification consists of a piping crosstie i

I

4.

between the Fire Protection System and the RHR system as well as the reinstallation of the RPV Head Spray line. The RPV Head Spray line was included in the original design but was disconnected due to water harrvr concerns. Reinstallt. tion of the line is accompanied by design changes, rerouted piping, and a bypass line with restriction orifices added in order to reduce the potential for water hanner.

The connection between the fire protection system and the RHR system is rade by adding a piping connection from the fire protection system piping and the RHR Salt Service Water injection line. The design of the connection leaves the path interrv,pted; when the connection is desired a rem >vable pipe section, 16" in length, post be installed with quick connect Victaulic couplings. When the removable pipe section is not installed the piping ends are capped. Isolation of the RHR system is provided by the addition of a gate valve (local manual) and check valve.

During operation of the RHR system, these valves becore part of the reactor coolant pressure bot.ndary. Isolation of the line from the fire 4

protectun system is provided by gate valve. The gate valves will be locked clised. The crosstle on the RHR side of the renovable pipe section is to be designed with ASME Section 111 Class !! piping and ASWE Section

!!!, Class 1 valves (gate valve and check valve). On the fire protection side of the coinection the crosstie is designed to ANSI and NFPA $tandards and is designated Quality Class FPQ (Fire Prote. tion).

The effect of these changes will be to allow the use of diesel fire pumps, including a newly proposed diesel fire cump, which draw water from the fire water storage tank and the city water supply line to provide water for core injection and containment sprays.

The licensee has evaluated the effect of the proposed design modifications and concluded that there is no adverse impact on the perforir.ance of safety related systems or the fire protection system. The staff has similarly concluded, bastd on our initial assessment, that the design changes have no significant deleterious effects on the design or operation of the plant. However, the licensee should consider the need to propese Plant Technical Specifications regarding surveillance testing to b

5 verify leak tightness of the RHR isolation valves to be added as part of this change.

This modification is expected to be completed after plant restart.

installation of this modification under the provisions of 10 CFR 50.59 h

may not be acceptable and the licensee should provide clarification regarding the need to include RHR isolation valve leak testing in the Plant Technical Specifications.

4 Sect. 3.5 - Diesel Fire,Pumo for RPV Injection and Containment Spray This design change was prompted by the licensee's desire to provide a j

redundant pumping capacitj to the existing diesel fire pump and thus provide additional prctection for extended station blackout accident sequences or other severe accident scenarios. The design change includes the addition of a new diesel fire pump and auxiliary equipment consisting j

t f piping, valves, and an enclosure with foundation and Itghting. The new diesel fire puep reouires no AC power to perfore its function, however, enclosure lighting and HVAC, if needed, will be powered by the i

newly proposed station blackout diesel. The neu diesel fire pump has a capacity of 750 gem at 125 psi which is compatible with the water supply provi6ed by the 6 inch city water line. The licensee has not provided analyses to justify the adequacy of the pump capacity to prevent the j

occurrence or mitigate the consequences of a severe accident.

The addition of a new diesel fire pumo to the plants fire protection system has been evaluated by the Itcensee to determine if there were any i

concomitant effects on plant safety functio',s.

In as much as the plant fire protection system is not a safety relat(d ly; tee, addition of the l

new puro and its auxiliaries were detemined not to effect plant safety functions or systems. To the entent the design c5ange effects the fire protection system the new cocconents are designated 0 (fire protection).

This redification is expected to be cocpleted atter plant restart.

i Installation of this modification under the provisions of 10 CFR 50.59 appears acceptable.

r.

5.

Sec. 3.6 - Diesel Pumo Fire Puep Fuel Oil Transfer System This design change is to provide a redundant (non-electric power dependent) diesel fuel oil transfer pump for the diesel fire pump P-140.

This redundant pum will allow extended operation of the diesel fire pump as a water source for the RHR systein during extended station blackout and other potential hevere accident scenarios beyond the design basis. The change adds a hyroturbine driver (AC power independent) fuel oil transfer pump in the intake structure, and associated auxiliaries and piping.

The addition of this feel oil transfer system to the plant's fire protection sy*. tem has been evaluated by the licensee to determine effects on plant safety functions. In that the plant fire pnotection system is not a safety re16ted system, addition of this system was detemined to not effect plant safety functions or systems. The staff agrees with the lit.nsee's euluation.

Installati::n of this system is expected to be completed before plant re s ta rt.

l Installation of this modification under the provisions of 10 CFR 50.59 l

appears acceptable, l

6.

Sect. 3.7 - Backup Nitrogen Supply System l

As the title i'@ lies, this proposed design change involves the addition of i

a backup nitrogen supply te provide nitrogen during a station blackout.

l The backup N supply will provide a motive source for critical valves and 2

instruments and a source of N for torus and drywell atmosphere makeup.

2 The backup supply consists of an additional 20 cylinders of N with 2

piping and valves and a new liquid N / vaporizer trailer. The purpose of 2

the additional cylinders is to provide a N supply in an interim period 2

while the N trailer is being aligned. The nitrogen supply from the 2

l cylinders will automatically, in the event of a loss of the existing N 2

l storage facility, provide makeup to drywell instmment supply piping.

The cylinders are capable of supplying N for a minimum of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> based 2

upon assuming two cycles of the MSlY'F. two cycles of the HSRV's and other leakage. The liquid N / vaporizer tralier will be sized for a minimum of 2

20,000 scfh for 7 days ur at less flow for extended periods. Nitrogen is l

supplied at 110-120 psig for inprument supply lines; nitrogen frt>m the trailer is provided at 70 psig for toms and dywell makeup.

l

7 In order to improve the reliability of nitrogen supply the licensee has inodified the design to alter the fail safe position of gate valve A0-4356 from fail closed to fail open.

As part of the design process the licensee has determined that the design i

modification will not adversely affect the safety functions of the Inerting and Drywell Testing System nor adversely affect the safety function of the reactor buildng (modified by an additionel penetration through the reactor building wall).

During discussions with the ifcensee on July 22, 1987 the staff inquired about the effect of altering the fail safe position of valve A0-4356. At that time tha licensee indicated the valve in question was not a containment isolation valve, and thus a change in fail safe position would not affect the containment isolation design. The staff, however, during subsequent review, has detemined that the valve is listed as a containment isolation valve (FSAR Table 5.2-5).

Therefore, the staff concludes that effects en the containment isolation function need to be reassessed by the licensee. To the extent a change in the technical specifications is involved, this matter needs to be considered as part of the issue of 50,59 applicability.

9 This modification is expected to be completed prior to plant restart.

l 7.

Sect. 3.8 - Blackout Diesel Generator including Protected Installation l

Jacilities l

As part of the Safety Enhancement Program Boston Edison Ccrnpany will install a non-safety related Station Blackout (580) diesel generator rated at 2000KW to provide a non-safety related source of onsite ac power l

to the 4.16kV safety buses. This unit will be utilized to operate one ECCS pump and all other associated loadt froen one safety train required for reactor shutdown, without LOCA, when all other suurces of ac power are unavailable. Boston Edison states that this unit can be made l

available (manually) from the control room within an hour. This backup

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power source is being installed to reduce the probability of a station l

blackout which could lead to core daruga and/or containtnent failure. The l

unit is skid mounted and housed in a pre-engineered enclosure to protect it from the environment. The unit is fully self-contained, not dependent on any permanent Sant systems (except for a non-safety 480V feed from j

the plant for diesel generator maintenance loads when the unit is not l

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9 running) and has a independent fuel tank (no connection with emergency diesel generator fuel supplies), and a cooling radiator. The new diesel generator and the two existing emergency diesel generators for Pilgrim are ALCO engines. The new unit will be located south of the plant adjacent to the switchyard relay house.

The new diesel generator will be connected between the secondary side of the shutdown transfonner (third tource of power to the safety related buses) and emergency buses A5 and A6 (Figure 1). The diesel generator and the existing SMYA shutdown transformer will be connected to the existing safety-related 4.16kV buses A5 and AS through a new two-breaker 4.16kV bus A8. The diesel generator wil' be connected to the new switchgear A8 thru breaker 1801 and the shutdown transformer will be connected to switchgear A8 thre breaker #802. The outgoing feed from the switchgear A8 will be connected to the existing 4.16kV breaker #600 which is in turn connected to breakers #501 and #601 of the safety buses A5 and A6. In the original design the secondary of the shutdown transformer was directly connected to breaker #600.

Breaker #802 which is connected to the shutdown transformer will be kept closed during nonral operation to supply power when raquired to safety buses A5 and A6 thru breaker 600 (nonna11y closed) ano breakers 501 and 601 (nonna11y open). This alignment of breakers is consistent with the present arrangement which maintains shutdown power transfonner power available for automatic connection to the emergency buses (via automatic closing of 501 and 601) upon a unit trip, loss of the start-up transformer (preferred source) and failure of the emergency diesel generetor. The blackout diesel generator output breaker 801 will be maintained open during normal operation and will be closed to the safety related buses only during station blackout (loss of all ac power) or test. The diesel generator will be tested at regular intervals, when the plant is operating, for its ability to start and assume load by synchronizing to the shutdown transfonner during plant operation. During j

this time breakers 802 (NC), 600 (NC) 501 (NO), 601 (NO) are maintained in their nonnal line up. The diesel generator will also be tested by energizing safety related loads when the reactor is shut down.

I 1

The controls of breakers 801 and 802 are interlocked to prevent interconnection of the SB0 diesel generator with the shutdown transfonner except for testing of the diesel generator. The diesel generator and the 4.16kV breakers of switchgear A8 are controlled manually either from the main control room or locally f rom the diesel generator enclosure. Protective relaying is provided to prevent damage to the diesel generator. An independent 125 de system (battery and charger) is proviced to supply control power to diesel generator unit controls and associated 4.16kV switchgear A8 (breakers 801 and 802). Loss of de power will be annunciated in the control room.

In addition, annunciation will be prsvidtd in the main control room for diesel generator trouble, diesel generator breaker (801) trip / inoperative and shutdown transformer breaker (802) trip / inoperative. The diesel generator has an independent sufficient fuel system with capacity to supply rated load for a minimurr of one week.

The cabling for the diesel generator controls and new breakers 801 and 80? will be routed in separate conduit and duct banks from the diesel generator enclosure and switchgear A8 to the control room. The physical j

separation within the control panels between non-safety related diesel l

generator control wiring and existing class IE wiring will be in accordance with R.G.1.75. All conduit and cable installed by this design change located within safety related areas will be supported in accordance with seismic ! criteria.

The staff has reviewed the infonnation provided by the licensee on its proposed modification to add a new diesel generator at Pilgrim which r:

power required loads for safe shutdown without a LOCA when all other ac l

power sources are unavailable (Station Blackout). The new diesel generator is a backup to the secondary offsite power source (shutdown transformer) and is manually started. The unit is fully self-contained and interfaces or,1y

(

with the shutdown transforver (which is the third power source to the safety i

buses) and no other system except for a 480 volt ac feed from a non-safety related load center. The diesel generator breaker 801 is nonnally closed l

and the present alignment of breakers 600, 501, and 601 are not changed by this modification. Therefore, the shutdown transformers ability to supply power to buses A5 and A6 under design conditions will not be affected.

There are no changes to the safety related portion of the emergency service buses as a result of this change.

The control cabling of diesel generator and breakers 801 and 802 are routed in a separate conduit and duct banks from the diesel generator enclosure and switchgear A8 to the control panels C3 and C5 in the control room. The physical separation between new non-safety wiring and existing class IE wiring within the panels will be accordance with R.G.

1.75 (verbal agreement by the licensee). Therefore, although the licensee has not specifically addressed confomance to R.G.1.75, the acceptance of this design is based upon our understanding that the proposed snodification will satisfy R.G.1.75.

Based on the above, the staff concludes that the addition of the non-safety-related diesel generator at Pilgrim will reduce the probability of station blackout and have no adverse effect on the offsite power systems, the Class 1E emergency diesel generators or the shutdown transfomers and is, therefore, acceptable. It is also concluded that this modification does not requir2 any Tech. Spec. changes or result in an unreviewed safety questien per 10 CFR 50.59. The irrplementation of the design will be verified by Region 1, with support from NRR as requested by the Region.

This modification is expected to be completed after plant restart.

Installation of this modification under the provisions of 10 CFR 50.59 apnears acceptable.

8.

Sect. 3.9 - Automatic Depressurization System Logic Modifications This modification provides a timed bypass of the high drywell pressure initiation signal and a manual inhibit of existing ADS actuation logic. This podification responds to the BWROG evaluation for Item II.K.3.18 of NUREG 0737. The modification and proposed Technical Specification (BEco letter of May 20,1987) have been reviewed and approved by the staff. A license amendment is currently being processed.

"fication is expected to be completed before plant restart.

iO - Addf tion of Enriched Boron to Standby Liquid Control System te of enriched sodium pentaborate in the Standby Liquid Control

. em (SLCS) allow pilgrim to meet the requirement of the Anticipated Transient Without Scram (ATWS) Rule (10 CFR 50.62) with one pump operable, thereby retaining the redundancy of the SLCS design.

The licensee submitted a proposed Technical Specification change which was approved oy the staff on August 5,1987 (Arnendment 102).

This modification is expected to be completed before plant restart.

10. Sect. 3.11 - ATVS Feedwater Pump Trip This change will provide an automatic trip to all feedwa'er pumps at 1400 psig reactor vessel pressure. This setpoint is selected so that feedwater pump trip occurs only when en ATWS event occurs following closure of Main Steam isolation Yalves.

It serves as a backup to the existing ATWS protection. The current ATWS design consists of trips of the recirculation pumps and initiation of the Automatic Rod Insertion (ARI) system on low water level or high reactor pressure.

The existing reactor feedwater pump trip logic will be modified to accept an additional trip signal from ATWS, A new trip coil (in addition to the existing trip coil) will be installed in the breaker associated with each reactor feed pump. The coils are "energized to trip" coils.

The Itcensee has analyzed this modification and concluded that the modifications to the feedwater pump, trip breders, ATWS system, and safety related power supplies do not have an adverse safety impact. The staff agrees with the licensee's evaluation.

This modification is expected to be completed before plant restar'.

l 1

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__,m Installation of this modification under the provisions of 10 CFR 50.59 appears acceptable.

11. Sec. 3.12 Modification to Reactor Core Isolation Cooling System Turbine Exhaust Trip Setpoint During Station Blackout (SBO) events, the RCIC system is available to supply cooling water to the reactor and maintain the reactor water level. The RCIC pump is driven by a turbine using tne primary system steam. The turbine exhaust is piped to the suppression pool. Continuous discharge of the steam to the suppression pool, however, will increase the suppression pool temperature and the containment pressure. The existing RCIC exhaust + rip pressure is 15 psig, which will be reached at about 0.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> into the SB0 event.

'o extend the use of the RCIC system, the licensee proposed to ocrease the trip pressure to 46 psig.

This increase of trip pressure *.111 allow the RCIC system to operate until about 15.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> into the event.

Steam discharge into the suppression pool, where the steam is condensed, results in thermal-bydraulic loads both on the containment structures and the discharge pipe. These loads will be increased significantly with increasing exhaust back pressure. Assessment of the magnitude of these loads is required in order to ensure that the RCIC exhaust pipe will not fail during the increased trip setpoint. Discussions with the licensee's technical staff indicated that the licensee has assessed the loads on the basis of static pressure. Since experiments and analytical methods indicate that the dynamic load differs substantially from static load, the licensee's present method based on static pressure is not acceptable.

i t

Based on the above, we conclude that, prior to iglementing this l

modification, the licensee should conduct an assessment of hydroofnamic loads on the RCIC piping and supports based on the proposed exhaust pressure of 46 psig. It should be noted that the analysis should consider both air clearing loads and steam condensation loads.

l 1

12. Sect. 3.13 - Addition al ATWS Rectreulation Pump Trip f

Trip of the recirculation pugs is a feature for the mitigation of ATVS l

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events. Pilgrim currently has the capability of tripping the recirculation pumps by opening the field breakers.

Installation of a new trip coil within the breaker associated with each recirculation pump HG set drive motor will increase the pump trip reliability.

The design change will add an ATWS initiated trip signal to the 4160 volt drive motor breakers of the recirculation pump motor generator sets A and B.

The trip will be at either high reactor pressure (1175 psig) or low reactor water level (.46 inches indicated level). Signals will be taken from existing sensors. The system will be an "energize to trip" system.

The licensee has analyzed this modification and concluded that it does not degrade the existing recirculation system, ATWS system or safety related power supplies. The staff agrees with the licensee's evaluation. The overall compliance of Pilgrim with ATVS Rule (10 CFR 50.62) is currently under staf f review.

This nodification is expected to be completed before plant restart.

Installation of this modification under the provisions of 10 CFR 50.59 appears acceptable.

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'g UNITED STATES NUCLEAR REGULATORY COMMISSION c

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August 18, 1987 Docket No. 50-293

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Mr. Ralph G. Bird Senior Vice President-Nuclear 600 Boylston Street Bosten, Massachusetts 02199 SURJECT: FEMA REPORT ON OFFSITE EMERGENCY PLANNING FOR PILGRIM

Dear Mr. Bird:

Enclosed is the Federal Emergency Fanagement Agency (FEMA) report titleri, "Self-Initiated Review and Interim Finding for the Pilgrim Nuclear Power Station," which was transmitted to the Nuclear Regulatory Comission (hRC) by memorandum dated August 6,1987. Based on a review of the overall state of offsite emergency preparedness for Pilgrim, FEMA has concluded that Massachusetts offsite radiological emergency planning and preparedness are inadequate to protect the public health and safety in the event of an accident at the Pilgrim Nuclear Power Station. This findirg by FEMA superseder FEMA's previous interim finding of adequacy regarding offsite emergency preparedness for Pilgrim.

FEMA has identified six issues during the court: of iti review:

1.

Lack of evacuation plans for public er.0 private schools and daycare centers.

2.

Lack of a reception center for people evacuating to the north.

3.

Lack of identifiable public shelters for the beach population.

I 4

Inadequate planning for the evacuation of the special needs population.

S.

Inadequate planning for the evacuation of the transportation dependent population.

l 6.

Overall lack of progress in planning and apparent diminution in erergency l

preparednes s.

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O'lZ l'A $0 $$ A V

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2 The FEMA report a"so addressed the seven alleged deficiencies in emergency planning identified in William P. Golden's July 15, 1986 Petition to the NRC.

FEMA found that while these areas of plan weakness were not sufficient to sustain the contentions raised in the Petition, resolution of these weaknesses would enhance the State's ability to protect the public.

We view the emergency planning issues identified by FEMA to be a matter of serious concem. The deterinination to restart the Pilgrim plant will involve, in part, consideration of the FEMA identified emergency planning issues. We are aware that you are providing assistance and information to the Connonwealth of Massachusetts pertaining to several of these issues. We request that you respond to us with an action plan and schedule for assisting the State and local governments in addressing the FEMA identified emergency planning issues for Pilgrim.

Please contact the Project Manager if you have questions.

Sincerely, ven a

ctor Division of Peact rojects - 1/II Office of Nuclear Reactor Regulation

Enclosure:

As stated 4

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'c, UNITED STATES i

NUCLE AR REGULATORY COMMISSION j

WASHINGTON, D. C.10555

', s September 18, 1987 h

Dr. Murley F. Miraglia R. Starostecki S. Yarga Richara H. Wessman, Pilgrim Project Manager rt BEco Emergency Preparedness letters

ached 3 letters dealing with Pilgrim emergency preparedness were td today.

They deal with:

-Exemption From Required Biennial Exercise (until Spring 1988)

-Pilgrim Onsite Exercise - December 9,1987

-Action Plan and Schedule for Dealing with FEMA findings Qi Richard H. Wessman, Senior Project Manager

!' rom Project Directorate I-3 Division of Reactor Projects I/II trcise Sniezek Congel that

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.s U.S. Nuclear Regulatory Commission Page 2 In view of these extensive ongoing efforts, the Commonwealth and the local governments have indicated that they are not able to participate s'9 an exercise during calendar year 1987. Moreover, it is apparent that under these tircumstances, corduct of the full participation exercise will be much more effective after the ongoing improvements have been implemented.

In granting one-time exemptions authorizing deferral of exercises for licensed plants in the past, the NRC has recognized that the most effective and beneficial exercises are those which include the full-scale participation of State and local governments and that it is appropriate to defer.an exercise until program revisions or facility improvements have been completed.

Since the last full participation biennial exercise at Pilgrim, Boston Edison has held an onsite exercise at Pilgrim in December 1986; has held quarterly onsite drills in March, June and August of 1987; and has scheduled its annual onsite exercise for December 9, 1987 (in which the Commonwealth will exercise various offsite objectives as described in BECo Ltr. #87 -147 "Scheduling of Pilgrim Onsite Exercise").

The previous exercise and drills have included limited participation by the Commonwealth, and the March and June 1987 drills included limited participation by several of the towns.

The towns within the EPZ have also cooperated in the full scale siren test reviewed t,y FEHA, which was conducted on September 29, 1986.

It addition to its activities involving Pilgrim, the Commonwealth has also participated in full participation exercises at the Yankee Nuclear Power Station in June 1986 and is scheduled to participate in a full participation exercise at the Vermont Yankee Nuclear Generating Station during the week of November 29, 1987.

This rec;est meets a number of the special circumstances listed in Section 5 3.12(a H 2) rirst, granting the request will provide only temporary relief from the applicable regulation and the licensee has made good faith efforts to comply ith the regulation.

Over the past year, Boston Edison has assisted

ommonwealth and local authorities in a variety of ways to accomplish as many improvements as possible in their offsite emergency response programs.

For example, Boston Edison has developed substantive information for the enhancement of those programs.

The major products of this effort include the "Pilgrim Station Evacuation Time Estimates and Traffic Hanagement Plan Update" (August 18, 1987) prepared by KLO Associates, Inc. and "A Study to Identify Potential Shelters in the EPZ Coastline Region of Pilgrim Nuclear Power Station" (August 1987) prepared by Stone & Hebster Engineering Corporation, as well as information generated in surveys to identify the special needs and transportation dependent populations within the EPZ.

In addition, Boston Edison is providing a Mistance to the local governments in their offsite er.iergency program enhancement efforts in accordance with the Massachusetts Civil Defense Act of 1950 (Chapter 639, Section 15 Acts of 1950 as amended). This assistance includes the provision of two professional planners to work under the direction of the officials of each town within the EPZ in upgrading its plan, procedures and training; one MC27 W 33}

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.s U. S. Nuclear Regulatory Comission Page 3 professional planner to assist each reception center comunity; and four professional planners working under the direction of HCOA in the upgrading of the HCDA Area II and Commonwealth program.

In the first half of 1987. Boston Edison provided introductory emergency training to about 350 personnel within the five towns in the EPZ and enhanced introductory training modules are currently being prepared for review by the MCDA pri r to further implementation.

The planners provided by Boston Eoison have also begun to prepare task-based modules for training of specific categories of emergencyIn personnel and will be available to participate in the training programs.

addition, Boston Edison is executing agreements with each of the fivt towns within the EPZ, as well as the two reception center communities, for assistance in the renovation of their EOC's. Moreover, four of the five EPZ towns and both reception center comunities, to date, have accepted BECo's offer of funding support for full-time civil defense staff positions.

Second, literal compliance with the regulation would not serve its underlying purpose and would result in undue hardship to Commonwealth and local emergency response agencies by requiring an exercise of portions of the of f;4a emergency plans that are in the process of significant revision and improvement. This would necessarily involve disruption of the ongoing process of impiementing these changes, and consequently, the imposition of additional costs and delay in accomplishing the planned improvements.

The NRC's emergency exercise requirements clearly were not intended to disrupt the orderly implementation of improvements in such manner.

Finally, because granting the request will allow work to proceed without disruption, it will result in a net benefit to the public health and safety.

The NRC has acknowledged that flexibility is appropriate in applying emergency planning requirements.

Thi: flexible approach is especially appropriate in this case, where granting the request will facilitate more prompt and effective implementation of improvements.

For all these reasons, Boston Edison asks that NRC grant the requested In accordance with 10 CFR $170.12(c), a fee of one hundred and exemption.

fif ty dollars ($150.00) will be electronically mailed to your offices.

If you should refluire any additional information in connection with this request, 617 -

please contact either myself or Mr. Ron Varley of my staff (telephone:

424-3832).

O Ralph G. Bird RAL/dlw

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U. S. Nuclear Regulatory Comission Page 4 cc: Dr. Thomas E. Murley, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Comission The Phillips Building Hashington, D.C.

20555 Mr. R.H. Hessman, Project Manager Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Comission 7920 Norfolk Avenue Bethesda, MD 20814 Mr. Richard Krim, Assistant Associate Director FEMA 500 C Street - Federal Plaza Hashington, D.C.

20477 Mr. Edward Thomas FEMA - Regiun 1 J. W. McCormack Post Office and Court House Boston, MA 02109 Mr. Peter Agnes, Jr.

Commonwealth of MA Assistant Secretary of Public Safety 1 Ashburton Place - Room 2133 Boston, V.,

02108 U. S. Nuclear Regulatory Comission Region 1 - 531 Park Avenue King of Prussia, PA 19406 Senior NRC Resident Inspector Pilgrim auclear Power Station i

Rocky Hill Road Plymouth, KA 02360 Henry Vickers, Regional Director FEMA - Region 1 J.W. McCormack Post Office and Court House Boston MA 02109 l

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nosmvmsav becutw Offices 800 Boylston Street Boston. Wssachusetts 02199 September 17, 1987 Ralph G. Bird BECo Ltr. #87-147 Senior Vice Prescent - Nuclea, U.S. Nuclear Regulatory Commission Document Control Desk Hashington, D.C.

20555 Docket No. 50-293 License No. DPR-35

Subject:

Scheduling of P11 grin.

Onsite Exercise

Dear Sir:

In accordance with Mr. Lazurus' discussions with my !taff, this letter is to request that Boston Edison's emergency preparedness exercise be conducted at the Pilgrim Nuclear Power Station (Pilgrim Station) on December 9, 1987.

Boston Edison intends to conduct a complete onsite exercise on this date.

The Commonwealth will also exercise various offsite objectives to support the onsite activities. The proposed scope and objectives are described in the enclosure. The individual on my staff with whom the NRC should interface on this matter is Mr. Stephen Hook, Boston Edison Company, Emergency Operat*ons Facility, Obery Heights, Plymouth, MA 02360.

Boston Edison realizes that in accordance with the requirements of 10CFR Part 50, Appendix :.Section IV.F. a biennial full participation emergency preparedness exercise, should be conducted during calender year 1987. As you are aware, since the last full participation exercise in 1985, Boston Edison has developed a significant amourn of information relevant to the updating and upgrading of the emergency programs of the Commonwealth of MassacFusetts, towns within the plume exposure pathway emergency planning zone (EPZ) and reception center comunities.

This information includes the "Pilgrim Station i

Evacuation Time Estimates and Traffic Management Plan Update" (August 18, 1987) prepared by KLD Associates: "A Study to Identify Potential Shelters in the EPZ Coastline Region of the Pilgrim Nuclear Power Station" (August 1987) prepared by Stone & Hebster Engineering Corporation; and a survey of special needs and transportation dependent populations within the EPZ.

The Commonwealth and the local governments, with the assistance of Boston Edison, are currently fully engaged in implementing information of this type into numerous improvements of the Commonwealth and local programs.

In view of these extensive ongoing efforts by the Commonwealth and local governments. Boston Edison is filing under separate cover a request under Section 50.12 (a) of the NRC regulations for a one-time partial exemption from l

the requirements of 10CFR Part 50, Appendix E.Section IV.F., authortF ng the t

full participation joint exercise of offsite emergency response capabilities I

I to be conducted in 1988.

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U.S. Nuclear Regulatory Commission Page 2 1

If you have any questions or require additional information, please do not hesitate to contact Mr. Book at (617) 424-3808.

hG Enclosure RAL/div cc: Mr. William J. Lazurus Emergency Preparedness Section Division of Safety and Safeguards U.S. Nuclear Regulatory Comission Region 1 631 Park Avenue King of Prussia, PA 19406 Mr. Walter Thomas Emergency Preparedness Specialist U.S. Nuclear Regulatory Comission Region 1 631 Park Avenue King of Prussia, PA 19406 Mr. R.H. Nessman, Project Manager Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation U.S. Nuclear Comission 7920 Norfolk Avenue Bethesda, MD 20814 Senior NRC Resident Inspector Pilgrim Nuclear Power Station Mr. Edward Thomas FEMA-Region 1 J.H. McCormack Post Office and Court House Boston, MA 02109 llenry Vickers, Regional Director FEMA-Region 1 J.M. McCormack Post Of fice and Court flouse Boston, MA 02109

]

PROPOSED EXERCISE SCOPE AND OBJECTIVES

f BOSTON EDISON COMPANY PJLGRIM 3UCLEAR POWER STATIQE EMERGENCY PREPARE 0 NESS EXERCISE EXERCISE SCOPE AND OBJECTIVES 1

Stone The 1987 Pilgrim Station Emergency Preparedness Exercise, to be conducted on December 9, 1987, will provide the opportunity to evaluate the Boston Edison Emergency Plan and Emergency Plan Implementing Procedures.

It will also test the emergency response organization's ability to assess and respond to emergency conditions and take adequate actions to protect the health and safety of the public. Whenever practical the Exercise incorporates provisions for "free play" on the part of the participants.

The scenario will simulate a sequence of events resulting in a radiological release to the environment of sufficient magnitude to warrant utilization of Conwnwealth and local agencies.

The Commonwealth will exercise various offsite objectives.

The Exercise will also incorporate the conduct of the Station's semi-annual health physics d.ill, annual medical drill and our annual Post A:ctdent Sampling System drill which includes the acquisition and analysis of a sample.

2 On11te_0hintly_e1 (Pilgrim Nuclear Power Station)

A.

Radiological Emeroency Precaredness Plans Demonstrate the adequacy of the Emergency Plan and Emergency Plan Implementing Procedures both in terms of management's control of an emergency situation a9d the usefulness of the procedures.

Demonstrate the capability to successfully and effectively

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critique drill activities.

B.

KQ.t10 Cation Procedprgi Demonstrate the ability of Boston Edison emergency response personnel to notify offsite agencies within fifteen (15) minutes after declaration of an emergency.

Demonstrate the ability to alert, notify and mobilize Pilgrim / Boston Edison emergency response personnel.

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C.

Emeraency Conditions Determine the adequacy of comunication links between emergency fact 11 ties, teams, and offsite agencies.

Demunstrate the capability for formal comunications on plant internal comunication links.

Demonstrate the ability to comunicate technical information to the Commonwealth.

D.

Eublic Information Demonstrate the ability to create and issue press releases prior to Media Center Activation.

Demonstrate the ability to create press releases and provide information to the media via press briefings and media requests.

Demonstrate the ability to effectively respond to technical questions at the Media Center.

Demonstrate the capability to respond to rumors and exercise effective rumor control.

E.

Emeraency Resconse Facilities Demonstrate the capability for prompt activation of emergency response facilities.

Demonstrate the effective control and staging of onsite emergency teams.

Demonstrate the functional adequacy of the emergency response facilities.

Demonstrate the ability to maintain and update status boards in the l

emergency response facilities, Demonstrate the capability to staff and maintain a manpower roster j

for protracted operations, ensuring sufficient personnel are l

available for a 24-hour assignment schedule.

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F.

Comand and Contr_ol Demonstrate the ability of key personnel to make timely and effective decisions with refpect to a radiological emergency.

Demonstrate the ability to make periodic and comprehensive verbal updates and briefings in the emergency response facilities, l

Demonstrate the transferral of emergency comand and control throughout the event.

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G.

&ccident Assessmerit Demonstrate the ability to assess plant conditiens, classify events as they occur and identify projected trends and potential consequences.

Demonstrate the ability to make accurate assessment of core damage through acquisition and analysis of a sample from the post accident sampling system.

Demonstrate the ability to effectively assemble, dispatch and control Environmental Monitoring Teams.

Demonstrate the ability to perform dose assessments and to determine actual or potential offsite radiological hazards.

H.

Protective Resoonst Demonstrate the ability to maintain adequate access control and personnel accountability in the TSC/OSC.

Demonstrate the ability to make timely Protective Action Recommendations (PARS) to offsite agencies.

I.

Radiolocical ExoosurLCentrol Demonstrate the ability to implement personnel dosimetry for emergency response personnel.

Demonstrate the ability to disptch entergency re-entry and repair teams in a timely fashion and maintain doses ALARA.

Demonstrate the organizational ability to authorize emergency worker exposure in excess of 10CFR20 limits.

K.

Em1f9tACy Medical Response 1

Denonstrate the ability to provide first-aid for a contaminated l

injured individual.

Demonstratw the ability to provide proper radiological and contamination controls in the handling of a contaminated injured individual.

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Re-Entry and_ltcoYefl Demonstrate the ability to activate the Recovery Center.to assist the TSC in accident assessment activities.

Demonstrate the capability of the Recovery Center to develop recovery l

plans and strategies.

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3 Offsite Obiectives (Commonwealth of Hassachusetts)*

Demonstrate ability to make initial notifications to EPZ towns.

4.

Demonstrate ability to continuously monitor and control emergency 10.

worker exposure.

Demonstrate ability to brief the media in a clear, accurate and 11.

timely manner.

Demonstrate the ability to make the decision, based on predetermined 13.

criteria, whether to supply and administer KI to emergency workers.

Demonstrate ability to robilize and deploy field monitoring teams in 18.

a timely fashion.

Demonstrate appropriate equipicnt and procedures for determining 19.

ambient radiation levels.

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Demonstrate appropriate equipment and procedure for measurement of 20.

airborne radiodine concentrations as low as 10-7 uC1/cc in the presence of noble gases.

Demonstrate adequacy of ambulance facilities and procedures for 31.

handling contaminated, injured and exposed individuals.

Demonstrate adequacy of hospital facilities and procedures for 32.

handling contaminated, injured and exposed individuals.

The offsite objectives have been extracted from FEMA Guidance The Commonwealth of Hassachusetts Memorandum EX-3, 06/10/86, Rev.1.

has reviewed these objectives and has agreed to provide EOF, Hedia Center and Field Honitoring Team functions solely to support the He therefore do not anticipate the Commonwealth's onsite exercise.

submittal of the above objectives to FEMA, nor FEHA's evaluation of l

the exercise other than the annual medical drill.

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.osnw-scw Esecutre CS 800 Bo/ston street Boston. Massachusetts o2199 Ralph G. Bird senior vece President - Nucwar September 17,1987 BECo Ltr.#87-146 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C.

20555 Docket 50-293 License No. DPR-33

SUBJECT:

80, ton Edison Company Action rian and Schedule for Providing Assistance in Addressing FEMA Issues

Dear Sir:

As requested by Mr. Varga's letter of August 18, 1987, transmitting a copy of the FEMA report entitled "Self Initiated Review and Interim Finding of the Pilgrim Nuclear Power Station", we are enclosing an action plan and schedule for assisting the Commonwealth of Massachusetts and local governments in

.t addressing the FEMA identified emergency planning issues for Pilgrim Nuclear Power Station.

The Commonwealth has reviewed and concurs with our assessments as presented in the action plan and schedule.

The enclosrJ action plan and schedule identifies various "subissues" derived from the FlHA report and sets forth the current status, the planned assistance to be provided by Boston Edison to.the Commonwealth and local governments, the As target sihedules for resolution, and as necessary, an explanatory comment.

explainet more fully in the introduction, the action plan and schedule is part of a comp ehensive program of assistance by Boston Edison to the Comonwealth and local governments in upgrading the offsite emergency response programs relating te the Pilgrim Nuclear Power Station.

g

U. S. Nucle!.r Regulatory Comission Page 2 Please do not hesitate to contact either myself or Mr. Ron Varley at (617) 747-8544 if any additional information is required.

h RalphfS

. Bird RGB/dlw l

Enclosure l

cc: Mr. Steven A. Varga, Director Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Hashington, D.C.

20555 Mr. R. H. Hessman, Project Manager Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Comission 7920 Norfolk Avenue Bethesda, MD 20814 Mr. Richard Krim, Assistant Associate Director FEMA 500 C Street - Federal Plaza Washington, D.C.

20472 Mr. Edward Thomas FEHA - Region 1 J. H. McCormack Post Office and Court House Boston, MA 02109 Mr. Peter Agnes, Jr.

Commonwealth of HA Assistant Secretary of Public Safety 1 Ashburton Place - Room 2133 Boston, MA 02108 U. S. Nuclear Regulatory Commission Region 1 - 631 Park Avenue King of Prussia, PA 19406 Senior NRC Resident Inspector P11 grin Nuclear Power Stattor.

Rocky Hill Road Plymouth, MA D2360 Henry Vickers, kegional Director FEMA - Region 1 J.W. McCormack Post Office and Court House Boston, MA 02109

BOSTON EDISON COMPANY ACTION PLAN AND SCHEDULE FOR PROVIDING ASSISTANCE IN ADDRESSING FEMA ISSUES Introduction In a letter dated August 18, 1987 the Nuclear Regulatory Commission (NRC) transmitted to Boston Edison Company (BECo) a copy of the Federal Emergency Hanagement Agency (FEMA) report entitled "Self-Initiated Review and Interim Finding for the Pilgrim Nuclear Power Station" (August 4, 1987) (FEMA Report).

It requested that BECo provide to the NRC "an action plan and schedule for assisting the State and local governments in addressing the FEHA identified emergency planning issues for Pilgrim."

To prepare this action plan and schedule, BECo first reviewed the FEMA Report to identify the ;recise issues raised by FEMA. This task was simplified by the fact that in Section III of the FEMA Report ("Evaluation of Issues"), FEMA identified six major issues (A through F) and under each issue stated its current position, including in most instances, the information required to resolve its concerns. Using those statements by FEMA, BECo has identified a number of "subissues" that, we believe, collectively comprise the concerns raised by FEMA. -.

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Under each subissue BECo has set forth the current status, the planned BECc assistance to the Comonwealth of Massachusetts (Commonwealth) and local governments, the anticipated schedule for such assistance, and, as necessary, an explanatory coment.

The action p an and schedule set forth below is part of a comprehensive program of assistance by BECo to the Commonwealth and local governments in upgrading the offsite emergency response programs relating to the Pilgrim Nuclear Power Station (Pilgrim). Hell over a year ago, BECo began developing information which would be useful in the enhancement of the offsite programs.

This effort has resulted in, among other things, the "Pilgrim Station Evacuation Time Estimates and Traffic Management Plan Update" (August 18, 1987) (ETE) prepared by KLD Associates, Inc. and "A Study to Identify Potential Shelters in the EPZ Coastline Region of Pilgrim Nuclear Power Station" (August 1987) (Shelter Siv,y) prepared by Stone & Hebster Engineering Corporation, as well as information generated in surveys to identify the special needs and transportation dependent populations within the EPZ. Much of this information is relrevant to the concerns raised by FEMA and will be useful in the resolution of such concerns.Il Thus, as reflected in the action plan and schedule, the remaining task is primarily to incorporate such information into enhanced offsite programs, il Some preliminary information regarding the enhancement of the offsite programs was submitted in letters from BECo to the NRC dated June 4, 1987 and June 12, 1987, and from BECo to the Comonwealth dated June 30, 1987. To the extent that such information has not been superseded in the ongoing planning process, it uill also be useful. One item in such correspondence involved the possible use of the Edgar Station as a third reception center, which is no longer under consideration..

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It is also significant that, even prior to the issuance of the FEMA Report, BECo, the Commonwealth and the local governments developed a sequence of actions for the upgrading of the Pilgrim related offsite emergency response programs, and are cooperating in the accomplishment of the following actions:

(1) Revision of the emergency plans of the towns within the EPZ, the reception center communities, and the Massachusetts Civil Defense l

Agency (MCOA) Area II; (2) Revision of the associated procedures of the local governments and HCOA Area II; (3) Conforming revisions of the Commonwealth's state-wide emergency plan and procedures; (4) Ocvelopment and implementation of training programs for officials and emergency peisonnel; and (5) Renovation of the Emergency Operation Centers (EOCs) in each of the towns within the EPZ and the reception center communities.

BEco has provided and is continuing to provide assistance to the local governments and the Commonwealth in these efforts in accordance with the Massachusetts Civil D? ense Act of 1950 (Chapter 639, Section 15 Acts of 1950 f

as amended).

For example, BECo has provided two professional planners to work under the direction of the officials of each town in upgrading its plan, i,

procedures and training, and one professional planner to assist each reception center community. BECo and the Commonwealth have also 6>

W an arrangement under which four professional planners are being pivvided to work under the direction of HCDA in the upgrading of the HCOA Area II and Commonwealth programs.

This cooperative effort is further i?lustrated by the fact that the professional planners are presently completing training modules on "Emergency Plan Overview" and "Introduction to Radiation", subject to HCDA's review, and additional task-based modules will be prepared for training of specific categories of emergency personnel.

The planners who are currently involved in assisting the towns and MCDA Area II in developing ravised plans and procedures will also participate in implementing the training program.

Moreover, agreements are being executed with each of the five towns within the EPZ as well as the two reception center communities for assistance in the renovation of their EOCs.

In addition, four of the five EPZ towns and both reception center communities, to date, have accepted BECo's offer to fund full-time civil defense staff positions.

The availability of much of the required information and the steps already l

taken, including the retention of experienced professional planners, have enabled BECo to estimate target schedules for cornivtion of t5ese efforts.

The major efforts are now directed toward the offsite plans that are the fundamental source of the FEMA issues -- the town ar. Mf,:a A a II plans.

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goal for completing revisions of the town and MCOA Area a.' plans is about October 31,.987.

The associated operational procedures should be completed by about December 15, 1987, and the Cocoonwealth has stated that revisions of the state-wide plan necessitated by the revisions of the town and HC0A Area II l

plans should be completed by the end of 1987. Renovation of etch of the EOCs 4

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will be performed individually, but all such renovations should be completed by April 30, 1988.

Thus, as discussed specifically below, the concerns rt.ised by FEMA, which are encompassed within this overall program, are being addressed in a timely and comprehensive manner.

Beston Edison iad the Commonwealth are committed to working jointly to resolve all nf FEMA's concerns and to establishing the best possi'.)le of fsite emergency response projram for de communities around Pilgrim Nuclear Power Station, i

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i Issue A.

Evacuation of Schools Subissue A.1 (FEMA Report. Dagt_15).

"Ths 1985 version of the town plans for Plymouth, Duxbury, Carver, Kingston, and Marshfield are inadequate in that they do not identify all private schools and daycare centers within the plume exposure emergency planning rene."

Current Status Private schools and daycare centers within tne plume exposure pathway emergency planning zone (EPZ) are identified in Figures 10-1 and 10-3 of the "Pilgrim Station Evacuation Time Estimates and Traffic Management Plan Update" (August 181987), (ETE) prepared by KLD Associates, Int;.

Planned BfCo *ssistance and Schedule Yhe list of schools and daycare centers associated with each town will be included in the respective town procedures, rather than in the plans. The l

goal for completing the anticipated revisions to the procedures is about December 15, 1987.

Pending those revisions, the pertinent lists will be made available to each town prior to October 31, 1987.

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BEco is providing professional planners who are working under the direction of MCOA and town officials in preparing the necessary revisions of the town and HC0A Area !! procedures.

Subissue A.2 (FEMA Recort. Dage 15)

"Detailed plans and procedures must be developed for these institutions, identifying sufficient resources and arranging for the availability of these resources to evacuate children and staff in the event of an accident at Pilgrim "

Current Statja BECo is providing professional planners who are working under the direction of town and MCDA officials in revising town and MCDA Area II plans and procedures, which will identify sufficient resources and arrange for the availability of those resources to evacuate private schools and daycare centers.

Planned BEco Assistance and Schedule i

l The goal for completing the plans is about October 31, 1987. The l

associated procedures should be completed by about December 15, 1987.

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1 Coment Arranging for transportation providers is discussed under Subissues A.3 -

A.S.

Subissue A.3 (FEMA Recort. eace 15)

"The Commonwealth's current position is that it will not use the vast state controlled bus resources of the MBTA and that it can no longer rely on ad hoc planning, at least during a fast breaking accident.

Detailed plans and procedures must, therefore, be developed for the early dismissal and evacuation of each comunity's schools and daycare centers."

4 Current Status The updated ETE takes into consideration evacuation of all public and private schools, and daycare centers in the EPZ. The professional planners provided by BECo are assisting town and MCDA officials in developing plan and procedure revisions relating to these institutions.

At a meeting with FEMA, NRC and BECo on August 14, 1987, the Commonwealth made clear that, if required, i's would use all available resources, including those of the NJTA.

If in the current planning process it is determined that MBTA buses Day be useful, detailed arrangements providing for the availability and use of MBTA resources will be included in town, HC04 Area II and Comoawealth plans and procedures.

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Planned BECo Assistance and Schedule The goal for completing revisions of town and MCDA Area II plans which will address early evacuation and/or early dismissal of schools and di ctre centers (and the use of private or public transportation resources fe such evacuation or dismissal) is about October 31, 1987.

Revisions to i

associated procedures should be completed by about December 15, 1987.

Comtat Although current programs may include early dismissal, it appears that early evacuation of schools and daycare centers cculd be a more approp-riate precautionary response.

Nevertheless, the planners provided by BECo will be assisting school, town, and MCDA officials, in accordance with the i

schedule described above, in developing revised plans and procedures th.'.t l

incorporate whichever precautionary response is selected in the planning l

process (.LA., early evtcuation and/or early dismissal).

Subissue A.4 (FEMA ReDort. eigt_Uil "Letters of Agreement w % h transportation providers not under direct control must be obtained." -

Current Status As described under Subissue A.2, the planning efforts underway will identify the transportation resources available for evtcuation of schools and daycare centers.

Planned BECo Assistance and Schedule The planners provided by BECo will assist NC0A and town efficials, as appropriate, in obtaining Letters of Agr,eement (LOA's) to formalize agreements with a sufficient number of transportation providers to provide for evacuation of schools and daycare centers.

Subissue A.5 (FEHA Reoort. eage 15)

"Personnel designated to drive vehicles during an evacuation must also receive proper training as emergency workers."

Current Status The professional planners provided by BEco are presently completin2 training modules on "Emergency Plan Overview" and "Introduction to Radiation," which will be promptly provided to MCDA for review.

Planned BEco Assistance and Schedule Additional task based modules will be prepared for specific categories of emergency personnel, including bus drivers.

The goal for completing the specific training module for bus drivers is shortly after completion of applicable procedures on or about December 15, 1987.

The professional planners provided by BECo to assist in the development of plans, procedures and training programs will be available to assist in implementation of the training programs.

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Issue B. Reception Center Subissue B.1 (FEMA Report. Dagt_l91

"(A) new reception center must be found to replace Hanover."

1 Current Status The planners provided by BECo, in concert with the reception center communities' Civil Defense Directors, are currently evaluating the feasibility of using two rather than three re:eption centers.

The updated ETE analysis demonstrates that EPZ evacuation times will not be adversely affected by the use of two reception centers rather than ihree.

In conjunction with the above effort, the Commonwealth has indicated that it will continue in its attempt to identify a third reception center to i

accommodate persons evacuating to the north of Pilgrim Station in the event of an emergency, i

Planned BECo Assistance and Schedule I

BECo expects that the evaluation of the feasibility of using two reception centers will be completed by about October 1,1987. Associated procedures should be completed by about December 15, 1987.

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ighissue B.2 (FEMA Renort. naae 19)

"(P]Ians and procedures must be developed to register and monitor evacuees."

Current Status l

The planners provided by BECo are assisting the reception center communities and MCOA officials in revising plans and procedures governing or related to reception center operations. Those revisions will include 4

reception center monitoring and registration of evacuees, Planned BEco Assistance and Schedule The goal for completing the relevant reception center community plans is about October 31, 1987.

Associated procedures should be completed by t

about December 15, 1987.

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Issue C. Beach Poeulation

$ybissue C.1 (FEHA Recort. eace 26)

"FEMA and the RAC... must receive the following additional information:

(1) an updated geographical description of the beaches and their capacity:

Current Status BECo has developed preliminary estimates of the expected maximum number of people on the public beaches within the EPZ.

i Planned _ BECo Assistance and Schtdgli BECo will verify the preliminary estimates of the expected maximum number of people on the beaches, and will develcp an updated geographical description of the beaches by about October 1, 1987.

SVillige C.2 (FEMA Report. Dage 261

"(2) a detailed analysis of the beach population, including the number of permanent snd temporary tesidents and the number of day visitors, together with their geographical dispersion; I

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Current Status The current planning process is based upon the assumption that sufficient sheltering capacity for permanent and temporary residents and day visitors on the beaches will be provided.

Planned BEco Assistance and Schedule BECo will identify by about October 1.1987 the geographical dispersion of the beach population for each of tile public beaches in the EPZ.

Coment Since the current planning process is proceeding on the basis that sufficient sheltering capacity will be foend for the entire beach population, a breakdown of the number of permanent and temporary residents and day visitors is not presently being developed.

Subissue C.3_(FEMA Regort. DutEl

"(3) an updated estimate of the length of time it would take to evacuate the beach population; Current Status The updated ETE (Tables 9-4 through 9-8) contains estimates of the length i

of time it would take to evacuate portions of the EPZ encompassing each of the beaches.

Planned BEco Assistante and Schedule None Comment As part of the effort to upgrade the offsite plans, including provisions for shelterir.g and/or evacuation of the beach population. BEco, town and MCDA officials are exploring the possibility of precautionary clearing of the beach psvulation at the "Alert" classification stage in order to facilitate implementation of protective actions for this segment of the EPZ population.

Subissue C.4 (FEV!,_Recort. Dages 26-27)

"(4) a list of suitable buildings available for sheltering the beach population at each beach, including the capacities of these buildings and their distances from the beaches.".

Current Status "A Study to Identify Potential Shelters in the EPZ Coastline Region of the Pilgrim Nuclear Power Station" (August 1987) (Shelter Study) has been performed by Stone & Hebster '.ngineering Corporation to identify potential sheltering capabilities of, among other facilities, municipal and commercial buildings for emergency use by the beach population within the EPZ.

The Shelter Study contains a preliminary list of potential shelters in each of the towns that contain beaches.

From the preliminary information contained in the Shelter Study, Stone & Webster is identifying the specific locations and relative distances from the beaches of the identified shelters.

In addition, a detailed effort is being undertaken in each of the towns to identify and incorporate into their planning program specific shelters that would be utilized for the beach population which will take into account their distances from the beaches.

Planned EICo Assistance and Schedule BECo estimates that the additional Stone & Hebster analysis will be completed by about October 1,1987.

The goal for ider.tifying final shelter locations is about December 15, 1987.

Subilne C.5 UEMA Renort. Dage_221 "If these buildings are not open to the public, the plans must clearly state how the,'r will be made accessible and letters of agreement must be obtained as appropriate."

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Current Statui Planners provided by BECo are assisting EPZ town officials in revising

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plans and procedures to identify how shelter facilities will be made accessible and how the beach population will be made aware of the location and availa0111ty of such shelters. The planning approach is to preferentially identify public facilities which will not require the I

execution of letters of agreement. Should an insufficient number of public facilities exist, then LOA's will be obtained to formalize agreements with private facilities.

Planned BICo Assistance and Schedult i

The goal for completing the plans for the EPZ towns is about October 31, 1987.

The associated procedures should be completed by about December 15, 1987.

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Issue D. Soncial Needs Pooulation Subissue D.1 (FEMA Reoort. Page 35)

The information on mobility impaired persons "must include the updated, comprehensive procedures esed to identify the mobility impaired, together with the program in place to periodically review and update all relevant information rertaining to them; Cur.n nt Status A survey previously performed by BECo identified the general size and characteristics of the mobility imptired population in the EPZ.

Planned BECo Assistian_ lad Schedule l

The planners provided by BECo will be assisting town officials in identifying specific mobility impaired persons (including their locations, specific impairments, and needs) and in developing procedures for n.aintenance and periodic updating of relevant information pertaining to i

these individuals.

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The goal is to identify specific mobility impaired persons by December 15 j

1987 and to develop procedures for annually updating and revising this information by about March 15, 1988.

BEco is comitted to working with the responsible Comonwealth agencies to ensure the best possible program i

for addressing the needs of the nobility impaired population.

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Subissue D.2 (FEMA Renort. Paae 35)

"The resources available to meet the needs of... this group; Cur.ttnt Status The planners provided by BEco are utilizing 11 stings of ambulance resources in the State provided by the Commonwealth Department of Public Health / Emergency Medical Services and other sources to assist town and MCOA officials in identifying the specific transportation resources that j

are available to meet the needs of the mobility impaired population in the EPZ.

The planners are t.lso assisting town and MCDA officials in revising plans and proceduret that will provide for the needs of the mobility 4

impaired population.

P_lanald BEco Assistance and S etdgli l

The goal for incorporating information regarding available transportation 1

resources into town and MCDA Area II plans is about October 31, 1987.

Associated procedures should be revised by about December 15. 1987.

$yh111ue D.3 (FEMA Renort,_P.agt 351 "Letters of Agreement for the use of these resources as appropriate.".

u on providers from which LOA's must be obtained are being s described in Subissue D.2.

ures for protection timates of the Assistance and Schedule prCvided by BECo will assist town and MCOA officials, as in obtaining LOA's to formaltre agreements with a sufficient insportation providers to provide for evacuation of the 15 ns i the EPZ are tired population in the EPZ.

provided by BEco are ed plans and iss protection of the

<1sions addressing ber 31, 1987.

cember 15, 1987.

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Current Status Table 10-7 of the ETE identifies the estimated number of buses required to provide for the transportation dependent population.

The professional planners provided by BEco are working with town and MCOA offletals to verify the actual number of buses needed, and to identify those buses that will be available for emergency use.

Planned BECo Assistance and Schedule The goal for incorporating information on needs and available resources in town and MCDA Area II plans is about October 31, 1987. Associated procedures should be revised by about December 15, 1987.

Subb ige E.3 (FEMA Reaprt. eage_iQ1

"[Alppropriate letters of agreement."

Current Status As described under Subissues E.1 and E.2, the planning efforts underway will identify the transportation resource', available for evacuation of transportation dependent persons.

Planned BEco Assistance and Schedule Planners provided by BEco will assist town and MCOA officials, as appropriate, in obtaining LOA's to formalize agreements with a sufficient number of transportation providers to prov14e for evacuation of the transportation dependent population in the EPZ.

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Issue F.

Overall Lack of Progress in Plannina and Annarent_ Diminution in Emeroency Precaredness iubissue F.1 (FEMA ReDort. Daaes 43. 47)

"(1)(T]he Comonwealth has failed to correct the numerous problems noted in FEMA's review of its plans and during its exercises... including issues from:"

(a) the 1981 Regional Assistance Committee (RAC) review; (b) the 1982 RAC review; (c) the March 3, 1982 Exercise; (d) the June 19, 1983 Exercise; and (e) the September 5, 1985 Exercise.

Current Status BEco has reviewed the issues remaining open from the referenced RAC reviews (including those identifled in FEMA's October 30, 1985 letter to the Commonwealth) and exercises, and believes that these issues can be resolved through the current effort to revise the relevant plans and procedures, through training on the applicable procedures and Pi"ough the procurement or repair of equipment.

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Planned BECo Assistance aAd Schedule The goal for completing town and MCOA Area !! plan revisions addressing the issues identified by FEMA (Issues A-F) is about October 31, 1987.

BEco expects that the remaining issues identified in prior FEMA reviews l

will be addressed in the subsequent effort to revise the associated procedures and train emergency response personnel, and in the upgrading of the overall state of emergency preparedness.

Sub11 gts F.2 - F.7 (FEMA Recort. Dage 47) i

"(2) (The Commonwealth) has not updated its plan, and so advised FEMA of its actions on an annual basis...; (3) it has not implemented State and local training...; (4) it has not pursued an adequate program of public education and information for the media...; (5) and it has not... submitted to FEMA the required Annual Letters of Certification for calendar years 1985 and 1986.

(6) In addition, representatives of the Commonwealth have indicated that the state and local plan is inadequate; and (7) they have been unable to answer numerous questions posed by the public and by local officials in public meetings..."

Curriat Status l

See Comment.

l Planned BEco Assistance and Scheoule See Comment.

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Comment Subissues F.2 - F.7 relate primarily to relationships between FEMA and the Comonwealth or to alleged past events involving the Commonwealth.

Although it is inappropriate for BECo to address these matters, much of the information being developed and actions being taken under Issues A-E and Subissue F.1 are relevant to Subissues F.2 - F.7.

In addition,should the Commonwealth desire any further assistance from BECo under the Massachusetts Civil Defense Act of 1950 (Chapter 639, Section 15 Acts of 1950 as amended), BECo will provide such assistance.

Suhillue F.8 (FEMA Reoort. eages 47-48) j

"(Aldditional areas of plan weakness are identified in the... FEMA Report, I

' Analysis of Emergency Preparedness !ssues at Pilgrim Nuclear Power Station l

Raised tii a Petition to the NRC Dated July 15, 1986.'"

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Page 33 of the FEHA Report on the July 15, 1986 Petition states that the "Commonwealth's plan would be enhanced if the policy for the administration of KI to institutionalized people were clearly stated; and if procedures for the distribution of K! to the institutions were more fully developed."

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Current Status l

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l Supplies of KI ave been made available by BECo and arrangements have been I

made to have a small supply in each of the towns in the EPZ under lock and key controlled by the local civi* defense director. As noted in a memorandum dated August 10, 1987 from Robert Hallisey, Comonwealth Department of Public Health, Director, Radiation Control Program, to Gerald Parker, Commonwealth Department of Public Health. Assistant i i

Commissioner, Bureau of Environmental Health Services, it would be possible to address FEKA's concera by "spell (ing) out that the local civil i

defense director could transfer this supply to an institution within his/her community if needed."

Rico Planned Assistance and Schedule If requested by the Commonwealth, the professional planners provided by BECo could assist in the revision of plans and procedures to clarify this policy.

Comment BECo's review of the FEMA Report on the July 15, 1986 Petition indicates l

that the only "additional area of plan weakness" identified in that report which is not encompassed by Issues A-E and Subissues F.1-F.7 is FEMA's recommendation concerning the Commonwealth's policy and procedures for administration of KI to institutionalized persons.

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