ML20197E029
| ML20197E029 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 05/27/1988 |
| From: | Murley T Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20154N398 | List: |
| References | |
| 2.206, DD-88-07, DD-88-7, NUDOCS 8806080059 | |
| Download: ML20197E029 (113) | |
Text
{{#Wiki_filter:-- D0-88-7 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION q, 9 OFFICE OF NUCLEAR REACTOR REGULATION 'S DR. THOMAS E. MURLEY, DIRECTOR II DoCLUED 3 MAY 21Ms59 In the matter of ) Docket No. 50-293 i oocy2ma s
) stavics EMNCd S Boston Edison Company ) (10 CFR 2.206) g stcmc (Pilgrim Nuclear Power Station) ) g dp L'erimDirector'sDecisionUnder10CFR2.206 INTRODUCTION On October 15, 1987, Massachusetts Governor Michael S. Dukakis and Attorney General James M. Shannon filed a Petition on hetalf of the Commonwealth of Massachusetts and its citizens (Petitioners) with the Nuclear Regulatory Conmission (NRC) requesting that the Director of the Office of Nuclear Reactor Regulation (NRR) institute a proceeding to modify, suspend, or revoke the operating license held by Boston Edison Company (BECo, the licensee) for its PilgrimNuclearPowerStation(Pilgrim). In particular, the Petitioners reouested the NRC to (1) modify the Pilgrin license to bar restart of the facility until a plant-specific probabilistic risk assessment (PRA) is perfonned for Pilgrim and all indicated safety modifications are implemented, (2) modify the Pilgrim license to extend the current shutdown pending the outcome of a full hearing on the significant outstanding safety issues and the development and certification by the Governor of adequate emergency plans, and (3) issue an Order, effective imediately, to modify the Pilgrim license to preclude the licensee from taking any steps in its power ascension program until a fonnal adjudicatory bearing is held and findings of fact are made concerning safety questions raised regarding Pilgrim.
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The relief sought by the Petitioners is based on allegations of: (1) evidence of continuing serious managerial deficiencies at Pilgrim, (2) evidence that a plant-specific PRA as well as the implementation of any safety modifications indicated thereby should be required prior to Pilgrim's restart, and (3) evidence that the state of emergency preparedness does not provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency during operations at Pilgrim. On November 13, 1987, receipt of the petition was acknowledged. The Petitioners were advised that their Petition would be treated under the requirements of 10 CFR 2.206 of the Comission's regulations and that appropriate action would be taken within a reasonable time. The request for an imediately effective Order to modify the Pilgrim license to preclude BEco from taking any steps in its power ascension program until an adjudicatory hearing is held was denied. Notice of receipt of the Petition was published in the Federal Register (52 FR 44503). On December 17, 1987 Governor Dukakis wrote a letter to NRC Chairman Zech and restated the position of the Comonwealth of Massachusetts that an adjudicatory hearing should be held before any decision is reached on the plant's future. On January 6, 1988, NRC Chairman Zech wrote Governor Dukakis stating that the series of planned meetings described in Chairman Zech's letter would result in more citizens being heard by the Cormission than would have been likely if an adjudicatory hearing had been held. The Comission intends to hold a public meeting to be briefed by the staff on the readiness of Pilgrim to resume operations before allowing restart. The filing of a 2.206 Petition, however, does not require the NRC to
r-hold adjudicatory hearings with respect to issues raised by the Petition. Illinois v. U.S. Nuclear Regulatory Comission, 591 F.2d 12,14 (7th Cir.1979); Porter Cuunty Chapter of the Izaak Walton League of America, Inc. v. Nuclear Regulatory Comission, 606 F.2d 1363 (D.C. Cir.1979); Wells Eddleman et al.
- v. Nuclear Regulat,ory Cemission, 825 F.2d 46, (4th Cir.1987); Lorion v. Nuclear Regulatory Comissior, 785 F.2d 1038 (D.C. Cir.1986). See also Florida Power &
Light Co. v. Lorion et al. , 740 U.S. 729 (1985). Petitioners' reauest for an adjudicatory hearing is denied. For the reasons stated below, the Petitioners' request, insofar as it relates to the conduct of a PRA, is denied; a final decision with respect to the managerent and emergency preparedness issues is deferred. BACKGROUND The NRC staff found the overall performance at Pilgrim acceptable during the assessment period covered by the 1985 Systematic Assessment of Licensee Perfomance (SALP No. 85-99). O There was sufficient concern, however, about 1/ This Decision refers to two SALPs. The first is identified as SALP No. 85-99 and relates to the licensee's perfomance during the period October 1, 1984 - October 31, 1985. The report of this SALP was initially issued by Region I on February 18, 1986. It was the subject of further correspond-ence dated May 23, 1986, between Region I and BECo. The second SALP is identified as SALP NO. 86-99 and relates to the licensee's performance durirg the period November 1, 1985 - January 31, 1987. The report of this SALP was initially issued April 8, 1987. It was issued as a final report on June 17, 1987.
o i the facility's performance that Region I conducted a special in-depth Diagnostic Team inspection from February 18 to Mtrch 7,1986 (Inspection Report No. 50-293/86-06, issued April 2, 1986). The team found that perfomance improvements were inhibited by (1) incomplete staffing, particularly operators and key mid-level supervisory personnel; (2) a prevailing (but incorrect) view in the organization that the improvements made to date had corrected the problems; (3) reluctance on the part of the licensee's management to acknowledge some problems identified by the NRC; and (4) the licensee's dependence on third parties to identify problems, rather than implementing an effective program for self-identification of weaknesses. Nonetheless, as stated in a letter from Region I to the licensee dated May 23, 1986, the Diagnostic Team inspection results confimed the SALP Board conclusions for SALP No. 85-99. In that letter, Region I restated the belief that "... performance in the operation of the facility was ... acceptable although some areas were only minimally acceptable." On April 12, 1986 the licensee shut down Pilgrim because of equipment problems and operational difficulties. The NRC Regional Administrator for Region I acknowledged this shutdown in Confirmatory Action Letter (CAL) 86-10, which was issued that same date. On July 25, 1986 the licensee stated that the facility would remain shut down for the completion of various nodifications and for refueling. In an August 27, 1986 letter to Mr. J. Lydon of BECo, the Regional Administrator stated that although the licensee's actions in response to CAL 86-10 appeared to be thorough, additional issues had been identified that had to be resolved before the reactor could be restarted.
These issues included certain technical issues (overdue surveillances, malfunction of recirculation pump motor-generator field breakers, seismic qualification of emergency diesel-generator phase differential relays, and completion of modifications required by Appendix R tn 10 CFR Part 50), programatic matters (the licensee's action plan for improvements and the role of the licensee's safety review comittees), and the readiness of the plant and corporate staffs to support restart. Further, the Regional Administrator stated in the same letter: "In light of the number and scope of the outstanding issues, I am not prepared to approve restart of the Pilgrim facility until you provide a written report that documents BEco's formal assessment of the readiness for restart operation." F At this time, Pilgrim remains shut down. The staff has issued sal.P Report No. 86-99 (June 17, 1987). Although this report identifies a number of performance problems (as did the previous sat.P report), the staff believes the licensee is dealing effectively with identified problems and is making progress toward improving performance. The NRC asked the licensee to submit a readiness report at least 45 days before the planned restart of the plant. In response to this request, the licensee submitted a report entitled "Pilgrim Nuclear Power Station Restart Plan" (Plan), on July 30, 1987. This Plan, which consists of two volumes, describes not only the programs, plans, and actions considered necessary by BECo managerent for a safe and reliable restart, but also the longer term actions that are designed to ensure that there is continuing improvement in the safe operation of Pilgrim Station. Specifically, Volume 1 of the Plan contains
descriptions of all the utility's programs that are either in progress or planned to correct and prevent recurrence of previously identified weaknesses, as well as a very limited discussion of the early results of some of the programatic efforts already undertaken. Volume 2 provides the status of the licensee's efforts to meet comitments or resolve concerns in specific performance areas identified by either the licensee NRC, or the Institute of Nuclear Power Operations (INPO). On October 26, 1987 and January 4, 1988, the licensee provided revisions to Volume 2 of the Plan. The licensee plans to submit a final update (to be presented as a Plan revision) on the overall progress of the Plan approximately three weeks before the scheduled restart of the Pilgrim Nuclear Power Station. Because NRC is preparing to assess the overall effectiveness of the Plan in resolving previously identified weaknesses, NRC has welcomed public coments on the perceived strengths and weaknesses of both the programatic efforts contained in the Plan (Volume 1) and the success of specific actions in meeting specific comitments/ concerns (Volume 2). NRC provided an opportunity for such public coments at a public meeting held in Memorial Hall, Plymouth, Massachusetts, on February 18, 1988 and will factor the resulting oral and written coments into its assessment of the operational readiness of the Pilgrim Nuclear Power Station. A discussion of each of the three bases for this Petition follows.
DISCUSSION A. Management The Petitioners allege that serious managerial deficiencies continue to exist at Pilgrim. As the bases for their Petition, the Petitioners cite: (1) consistently low ratings in SALP reports; (2) the licensee's inability to sustain performance improvements; (3) the licensee's poor enforcement record regarding the severity level and number of violations; and (4) recent news articles concerning security problems and the use of excessive overtime. Documents cited by the Petitioners include SALP Reports 85-99 and 86-99 and various Inspectice Reports dated from 1985 to 1987. The Petitioners provided no substantial new information or evidence that was not known to the NRC when it issued the "Interim Director's Decision Under 10 CFR 2.206." 00-87-14, dated August 21, 19E7 thereintfter referred to as the Golden Interim Decision) in response to the Petition filed en July 15, 1986, by Massachusetts State Senator William B. Golden and athers, also alleging deficiencies in the licensee's management. A copy of the Golden Interim Decision is attached to this Decision and is incorporated by reference; we will not repeat here the discussion of the management issue given in that Decision. Because the Pilgrim Station is shut down and will not be allowed to restart until authorized to do so by the NRC, there is no additional safety assurance to be gained by addressing this aspect of the Petitioners' request at this time. A final Director's Decision regarding management issues is deferred
until (1) the management deficiencies have been suitably addressed by the licensee and (2) the NRC staff completes its assessment of the licensee's efforts. The managerrent portion of this Petition will, therefore, be addressed in a subsequent decision. l l l B. Probabilistic Risk Assessment and Attendant Plant Podifications , The Petitioners have requested that the Pilgrim operating license be modified to require, prior to restart from the current outage, a plant-specific prebabilistic risk assessment (PRA) and implernentation of all safety modifications indicated therein. The Petitioners assert that such a requirement is necessary because of the combination of three factors that influence the potential risk of a postulated severa :.tcident at Pilgrim Station. These factors are (1) a vulnerable primary containment (Mark I design), (2) a secondary containment (reactor building) not designed to provide an effective backup barrier, and (3) a large population in the immediate vicinity of the plant. Centrel to the Petitioners' request is the assertion that these three factors preclude consideration of the findings in draf t NUREG-1150 concerning the remote probability of a severe accident and attendant early fatalities. 2/ Finally, the Petitioners maintain that the licensee, by its voluntary action in initiating a Safety Enhancement Program has, in effect, raised as a restart issue the question of the adeouacy of the proposed plant modifications that are part of the Safety Enhancement Program. I 2/ The Reactor Risk Reference Document, Draft (NUREG-1150), February 1987, l
The draft assessment documented in NUREG-1150 concluded that the probability of a severe accident with early fatalities is extremely remote. The Petitioners incorrectly assert that the finding of draft NUREG-1150 is not applicable to Pilgrim because of the characteristics cited by the Petitioners: a Mark I containment, an ineffective secondary containment, and a large surrounding population. It is inappropriate to apply the specific numerical risk estimates from draft NUREG-1150 to Pilgrim. Nevertheless, it is also inappropriate to conclude that unacceptable risk follows by virtue of the fact that Pilgrim uses a Mark I containment design. In the Golden Interim Decision, the staff provided an extensive discussion of the design basis and adequacy of the Pilgrim containment. The Petition has not identified any issues with respect to the Pilgrim containment design that were not previously considered by the staff and resolved in the Golden Interim Decision. See DD-87-14, 26 NRC at 95-106. Petitioners assert that the "large population in the immediate vicinity of Pilgrim" (Petition, p. 13) constitutes part of the basis for their request for a PRA. Petitioners allege that there is a "...large population surrounding the plant...." (Petition, p. 14), and that "...the EPZ population at this plant is among the highest in the country..." (Petition, p. 21). 10 CFR 2.206(a) requires petitioners to "set forth the facts that constitute the basis for the ! request." Petitioners do not provide amplifying information or details in support of these statements concerning population.
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Although Pilgrim has an avove average population residing within 10 miles of the site, a number of other facilities have an even larger population residing nearby. Using 1982 data based on the 1980 census, the resident population (about 41,000) surrounding Pilgrim up to a radius of 10 miles ranked 26th of P,0 sites in operation or in the licensing prncess at that tire. As of 1987, the population residing within a 10-mile radius of the Pilgrim plant is estimated by the licensee to be about 62,000, with about 70,000 within the 10-mile Emergency Planning Zone (EPZ). El The 1982 data for U.S. nuclear power plants indicates that at least 17 sites already had over 70,000 people residing within a 10-mile radius of the site. Petitioners present nothing unique about the population in the vicinity of Pilgrim that would merit further consideration, r Although the Commission requested PRAs of the Millstone 3 and Linerir.x facilities during the licensing review process, the Commission's regulations do not require the conduct of a PRA as part of the licensing basis for nuclear power plants. PRAs also have been conducted by some utilities as part of facility upgrades, such as those made under the Commission's Systematic Evaluation Program (SEP) or , voluntarily by individual licensees. Although some licensees with facilities j in areas of substantially above average population density (Indian Point, Zion, 1 Limerick) have conducted PRAs, other licensees with facilities located in areas of higher population density than Pilgrim, such as Oyster Creek, Beaver Valley and Turkey Point, have not been required to conduct a PRA. 3/ The EPZ includes all of the town of Plymouth, Massachusetts, some of which is slightly more than 10 miles from Pilgrim.
The Petitioners have not provided sufficient evidence of significant risk vulnerabilities associated with the primary and secondary containment design that are unique to Pilgrim, or unique aspects of the surrounding population (when taken individually or when considered in combination) to warrant the requirement for a plant-specific PRA prior to restart of Pilgrim. The staff has reviewed all points raised in the seven page affidavit prepared by Steven C. Sholly that accompanied the Petition. This affidavit concerns the Pilgrim power ascension program, the potential risk associated with operation of Pilgrim at progressively higher power levels (based upon consideration of the Shoreham PRA and the potential impact of external events), and the need for a plant-specific PRA for Pilgrim. The affidavit also discusses the Pilgrim Mark I primary containment and secondary containment. The staff has dealt with the Pilgrim containments earlier in this response and in the Golden Interim Decision. Regarding the Pilgrim power ascension program, Petitioners assert that the details have not been supplied and that it will be a "rapid ascension" to full power. A description of the licensee's power ascension program was provided to the NRC on October 15,1987(BEColetter87-163). If power operation is approved by the NRC, the power ascension program to be performed as part of the Pilgrim restart effort will be a controlled and orderly process. It will have prior staff review and approval, augmented monitoring by the NRC staff, and "hold points" that require oral approval from the NRC before proceeding further. Thus, Petitioners' assertions regarding the Pilgrim power ascension program are without merit. I I
l Regarding the potential risk of operation at progressively hiqher power levels and the potential impact of external events, the staff agrees that operation at higher power levels may present higher risk than when operating at low power. Nevertheless, operation of the Pilgrim facility up to 100% power (1998 megawatts-thermal) has been previously analyzed and found acceptable by the staff. Applicable documents include the Final Safety Analysis Report (FSAR) and the associated Safety Evaluation Report (SER) dated August 25, 1971. Additionally the design basis for Pilgrim to withstand external events has already been considered and found acceptable in the FSAR and SER. Neither the Petition nor the affidavit provides information that renders these conclusions incorrect. The affidavit refers to a PRA for Pilgrim that has been in progress, the staff is aware that BECo has been conducting PRA activities for Pilgrim. However, this effort has not been completed nor has any portion of it been provided to the staff. The regulations do not require a PRA as part of the licensing basis for nuclear power plants. S/ If analyses being voluntarily conducted by the licensee reveal new information that materially alters the licensing basis, the Pilgrim Technical Specifications and 10 CFR 50.72 require that the NRC be infonned and appropriate corrective actions be taken. 4
~/ *i he Comission is presently considering imposing requirements for plant-specific evaluations under an Individual Plant Evaluation (IPE) progran. This program would include assessments of severe accident risk of individual facilities. Conduct of the IPE program would not be a pre-requisite to restart of Pilgrim or inhibit operation of other operating facilities. The Office of Nuclear Regulatory Research (RES) is also assessing the performance of the Mark I primary containment design. This assessment may impact decisions or yield regulatory action affecting Mark I facilities.
Accordingly, the affidavit does not present evidence that warrants the requirement of a plant-specific PRA prior to restart of Pilgrim. With regard to the Safety Enhancement Program, the staff also addressed this matter in the Golden Interim Decision. The staff is reviewing the modifications associated with the Safety Enhancement Program to ensure that they have no overall adverse safety impact on existing systems. Moreover, the licensee's initiative to improve plant safety beyond the point of complying with NRC regulations is not a basis for opening the issue of the efficacy of any proposed plant modifications. Because the Petitioners have not identified any unique or unacceptable severe accident risk for the Pilgrim plant nor documented that it poses an unreasonable threat to public health and safety, there is no rerit in their request that restart be delayed until a PRA is conducted. Therefore, this request is denied. C. Emergency Preparedness The Petitioners allege deficiencies in the current state of emergency planning and preparedness for Pilgrim Station. The Petitioners cite assessments perfortned by the Federal Emergency Management Agency (FEMA) E/ and the Massachusetts Executive Office of Public Safety 5/ that conclude that emergency planning and preparedness at Pilgrim are inadequate to protect the 5/ Federal Emergency Management Agency "Self-Initiated Review and Interim Finding for the Pilgrim Nuclear Power Station," dated August 4, 1987. l 6/
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Massachusetts Executive Office of Public Safety, Secretary of Public [ Safety, Charles V. Barry, "Report to the Governor on Emergency l Preparedness for an Accident at the Pilgrim Nuclear Power Station," dated December 16, 1986 (the "First Barry Report").
health and safety of the public in the event of an accident. The Petitioners state that both agencies have identified deficiencies in (1) evacuation plans forpublicandprivateschoolsaswellasdaycarecenters,(2) evacuation plans for the special-needs population. (3) evacuation plans for the transport-dependent population, (4) identifiable public shelters for the beach population, (5) a reception center for people evacuating by the northern route, and (6) the overall progress in planning and the apparent diminution in the state of emergency preparedness. FEMA fonvarded its report on the adequacy of energency preparedness at Pilgrin to the NRC on August 6, 1987. In this report, FEMA specifically addressed the information provided in the First Barry Report in developing its findings. On August 18, 1987, the NRC requested that the licensee provide an action plan and schedule for assisting the Comonwealth of Massachusetts and local governments in addressing the FEMA-identified emergency planning issues for Pilgrim. The NPC stated that it viewed the emergency planning issues to be a matter of serious concern and that the determination to restart the plant will involve, in part, consideration of the resolution of the emergency planning issues identified by FEMA. (A similer conclusion was stated in the Golden Interim Decision). By letter dated September 17, 1987, the licensee submitted to NRC an action plan and schedule summarizing the status of the issues and the assistance being provided by the licensee to the Coreenwealth and local authorities in the improvement of their emergency response programs. These efforts have included the development of an updated evacuation time estimate (ETE) study and traffic
O ranag* ment plan, a study to identify public shelters for the beach population, and the identification of and provision for the special-needs and transportation-dependent populations within the 10-mile EPZ. In addition, the licensee is providing professional planners to assist local governments and the Coninonwealth in upgrouing their plans and in the development of a new training program for offsite emergency response personnel. On October 26, 1987, the licensee provided additional information on beach population and sheltering to the Correonwealth. In a letter to the Commonwealth 6 ted December 23, 1987, the licensee fonvarded a report entitled "Reception Center Feasibility Analysis." The Petitioners acknowledge some progress has been made toward improving emergency preparedness, including identification of school / day-care populations, estimates of available resources to evacuate these populations, an updated ETE study, and estimates of the beach population and sheltering data. However, the Petitioners continue to identify concerns regarding the current planning efforts involving the identification of the special-needs and transport-dependent populations, shor2 comings in the ETE study, inadequacies in the sheltering data, detennination of a replacement for the northern reception center, and the conduct of an exercise. On December 17, 1987, Governor Dukakis forwarded to the NRC a report prepared by Secretary Barry entitled, "Report on Energency Preparedness for an Accident at Pilgrim Nuclear Power Station" (Second Barry Report). In this report, Secretary Barry provided additional information and background concerning the issues raised in the Petition. The current status of the efforts to improve the offsite emergency response programs is as follows:
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- Drafts of the local emergency plans have been completed. Six of these drafts have been forwarded by the Commonwealth to FEMA for rmal technical review.
f the local emergency plan implementing procedures have
- c. t repared and are being reviewed by town officials.
The draft Massachusetts Civil Defense Agency Area II Plan is complete and being reviewed by the Commonwealth.
- The draft of the Commonwealth Plan for Pilgrim is complete and being reviewed by the Commonwealth.
- A training program has been jointly developed by the licensee and the Massachusetts Civil Defense Agency. The Massachusetts Civil Defense Agency, which has approved the training program, is reviewing the attendant lesson plans as they are being developed. Training for offsite emergency response personnel has begun.
- A northern reception center has been designated by the Commonwealth.
l The NRC will continue to monitor the progress of the licensee's efforts to assist Massachusetts and local governments in improving their emeraency response programs. The licensee has committed to conduct a full-participation
- exercise following the completion of these efforts. On September 17, 1987, l
the licensee requested an exemption from the NRC requirement to conduct a l l biennial full-participation exercise in 1987. On December 9, 1987, the NRC l
s. granted the exemption, stipulating that the licensee is to conduct a full-participation exercise for Pilgrim no later than June 30, 1988. On April 4, 1988, the licensee requested a further extension of the full participation exercise to the end of 1988. On May 11, 1988 the NRC granted a further extension of this requirement, but stipulated that a full-participation exercise be conducted prior to the end of calendar year 1988. A decision on this portion of the Petitioners' request is deferred. However, the determination as to whether to restart Pilgrim will involve consideration of the emergency planning issues identified by FEMA. CONCLUSION For the reasons discussed above, a decision cannot be made at this time regarding the management and emergency preparedness issues. These portions of the Petition will be addressed in a subseouent response. However, the NRC has required, and will continue to require, that the Pilgrim facility remain shut down until the management and emergency preparedness issues are dealt with to the satisfaction of the NRC. For the reasons discussed above, the information identified by the Petition does not warrant the initiation of the requested actions in regard l to the probabilistic risk assessment and attendant plant modifications. l l Accordingly, the Petitioners' request for action pursuant to 10 CFR 2.206 on l this issue is denied. l l
As provided in 10 CFR 2.206(c), a copy of this Decision will be filed with the Secretary for the Comission's review. FOR THE NUCLEAR REGULATORY COMMISSION 4;;'-r-( ' Thomas E. Murley, Director Office of Nuclear Reactor Regulation Dated at RockvDie, Maryland Jg'dayof } \(3, this I l ,; J,
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JOHN W. McCoRMACK STATE OFFICE BUILDING g g oNE ASHBURToN PLACE. BOSTON 021o81698 , JAMES M. SHANNON Mb ATTORNtv GENERAL g TITING8 % SElfilcnERA SECY'"8C MJ b October 15, 1987 -- l FEDERAL EXPRESS 1 Director of the Office of Nucled: Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC. 20555 RE: Enclosed 10 C.F.R. 3 2.206 Petition concerning the Pilgrim Nuclear Power Station
Dear Sir:
Enclosed is the Petition of Michael S. Dukakis, Governor and James M. Shannon, Attorney General for the Institution of a Proceeding Pursuant to 10 C.F.R. S 2.202 to Modify, suspend, or Revoke the operating License Held by the Boston Edison Company For The Pilgrim Nuclear Station, which I am filing on behalf of myself and Governor Michael S. Dukakis.
. Very uly you ,
p w l Jamed .M. Shannon Atta :ney General i i l i l l l E c3
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1 3 y, i. i UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATC.Y 9 COMMISSION PETITION OF MICHAEL S. DUKAKIS, GOVERNOR AND JAMES M. SHANNON, ATTORNEY GENERAL FOR THE INSTITUTION OF A PROCEEDING PURSUANT TO 10 C.F.R S2.202 TO MODIFY, SUSPEND, OR REVOKE THE OPERATING LICENSE HELD BY THE BOSTCH EDISON COMPANY FOR THE PILGRIM NUCLEAR STATION e Dated: October 15, 1987 I .. 4
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t UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION PETITION OF MICHAEL S. DUKAKIS, GOVERNOR AND JAMES M. SHANNON, ATTORNEY GENERAL FOR THE INSTITUTION OF A PROCEEDING PURSUANT TO 10 C.F.R 52.202 TO MODIFY, SUSPEND, OR REVOKE THE OPERATING LICENSE HELD BY i THE BOSTON EDISON COMPANY FOR THE
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i .:.._, - ,. . s Ij. ' i TABLE OF CONTENTS I. INTRODUCTION . . . ................. 1 II. EVIDENCE OF SERIOUS MANAGERIAL DEFICIENCIES . . . . . 3 A. OVERVIEW . . . . . . . . . . . . . . . . . . . . . 3
- 8. DECO'S PAST PERFORMANCE . . . . . . . . . . . . . 4 3Eco's SALP Evaluations . . . . . . . . . . . . . 5 BECo's Regulatory Violations . . . . . . . . . . . 7 C. RECENT INDICIA OF BECo'S PERFORMANCE LEVEL , . . . 9 BEco's 1987 SALP Report . . . . . . . . . . . . 10
, Recent Reports of Violations . . . . . . . . . . 12 III. EVIDENCE THAr INDICATES THAT A PLANT SPECIFIC PRA FOLLONED 3Y IMPLEMENTATION OF ANY INDICATED SAFEIY MODIFICATIONS SHOULD BE REQUIRED PRIOR TO PILGRIM'S RESTART . . 12 IV. EVIDENCE OF INADEQUATE EMERGENCY PREPAREDNESS . . . 15 I 21 V. CONCLUSION . . . . . . . . . . . . . . . , . . . . . .
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i UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION PETITION OF MICHAEL S. DUKAKIS, GOVERNOR AND JAMES M. SHANNON, ATTORNEY GENERAL FOR THE INSTITUTION OF A PROCEEDING PURSUANT TO 10 C.F.R 52.202 TO MODIFY, SUSPEND, OR 1 REVOKE THE OPERATING LICENSE HELD BY
-; THE BOSTON EDISON COMPANY FOR THE i PILGRIM NUCLEAR STATION i .i ,
i I. INTRODUCTION Governor Michael S. Dukakis dnd Attorney General James M. Shannon, pursuant to 10 C.F.R. S2.206, hereby request that the Director of the Office of Nuclear Reactor Regulation
- institute a proceeding pursuant to 10 C.F.R. 52.202 to modify, j suspend, or revoke the operating license held by Boston Edison I
( company ("BEco." or "the Company") for the Pilgrim Nuclear Power Station ("Pilgrim") in Plymouth, Massachusetts. This { i l petition is filed on behalf of the Commonwealth of Massachusetts and its citizens. The Governor and the Attorney 1 l l i General base this request on evidence of continuing serious d managerial deficiencies at the plant, on evidence that a plant specific probabilistic risk assessment ("PRA") as well as the l t implementation of any safety modifications indicated thereby [ should be required prior to Pilgrim's restart, and on evidence l l l that the state of emergency preparedness does not provide reasonable assurance that adequate protective measures can and l
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operations at the Pilgrim plant. The Governor and the Attorney General submit that this evidence, as set forth below, demonstrates the necessity of Nuclear Regulatory Commission i ("NRC") action pursuant to 10 C.F.R. 52.202. d Further, the Governor and the Attorney General believe that
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t the public interest requires that the NRC exercise its authority under 10 C.F.R. S2.202(f)1/ so that BECo. is j' .; , J prevented from proceeding any further with the restart of Pilgrim 2/ until a formal adjudicatory hearing has been held and findings of fact are made concerning the safety questions surrounding the continued operation of the Pilgrim plant. In fi particular, the Governor and the Attorney General request that
! the NRC issue an order, effective immediately, modifying BECo's i
j operating license to preclude BECo. from taking any steps in j 1/ 10 C.F.R. 2.02(f) provides: When the Executive Director for Operations,
] during an emergency as determined by the EDO, or i the Director of Nuclear Reactor Regulation, i Director of Nuclear Material Safety and l
Safeguards, Office of Inspections and i Enforcement, as appropriate, finds that the public health, safety, or interest so requires or that the violation is w3.llful, the order to i show cause may provide, for stated reasons, that
, the proposed action be temporarily effective pending further review.
2/ At each step of BECo's so-called "power ascension" program there is an increase in the probability of an accident at Pilgrim as well as in the potential consequences of such an accident. See Affidavit of Steven C. Sholly (attached hereto as Attachment 1).
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.>s +. .. . . . .. . . . . . . _ _ . - ._ . . . . . . _ _ . . . . , e ,I 3
its power ascension program until the hearing is held and the 1 findings are made. II. EVIDENCE OF SERIOUS MANAGERIAL DEFICIENCIES
- Recent events at Pi'lgrim indicate that BECo. has not 1
corrected the long-standing managerial shortcomings that have d plagued the plant. In the areas of security, radiological sj g controls, personnel management, and corporate culture, the i 1 management of Pilgrim continues to be seriously flawed. As a result, Pilgrim poses an unreasonable risk to public health and
., safety. Its continued operation under the present i
circumstances is inimical to public health and safety. l i i
) A. OVERVIEW i
Pilgrim commenced commercial operation in June, 1972, when BEco. received an operating license for the plant. During the i intervening fifteen year period of operation by BECo., Pilgrim has had a capacity factor of approximately 50 percent,1! b which compares quite unfavorably with the average for all New England nuclear plants of approximately 67 percent.A# 3/ The "capacity factor" for a plant is a measure of performance in terms of the power it has actually delivered over a period of time relative to the power It it was capable of is calculated by delivering over that came period of time. i dividing the actual number of kilowatt hours produced by the plant in the period of measurement by the proditet of the plant's rated kl.awatt capacity and the number of hours in the period. 4/ Electric Council of New England, New England Nuclear News,
- TJune, 1987) (Attached hereto as Attachment 2).
3-s s
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.j '
i B. BECo's PAST PERFORMANCE i
,l The plant has been out of service since April, 1986, when the NRC, in Confirmatory Act4an Letter 86-10, ordered a shutdown after recurring operational problems at the plant.E/
Pilgrim has been beset with managerial problems from the
~t j outset. BECo. has consistently received low ratings in the NRC's Systematic Assessment of Licensee Performance ("SALP")
reports. Pilgrim has been identified by the NRC as one of the
}';
worst run and least safe plants in the country /5and BECo. was ordered to initiate performance / management improvemen': programs in 1982 and 1984.2/ BEco. has been the sub]ect of a long line of enforcement actions as a result of regulatory violations. While,the NRC's efforts to spur BECo. to a higher i level of performance have, on occasion, met with some initial
! success, a review of BECo's performance record, however, shows I
that all such successes have been short lived. Indeed, BECo. i
'l
] 5/ Confirmatory Action Letter 86-10 was clarified and expanded in an subsequent letter, dated August 27, 1987, from the NRC
'l Region 1, Regional Administrator to BECo's Chief Operating
! Officer. (attached hereto as Attachment 3). In this letter, i, BEco. was informed that:
In light of the number and scope of the outstanding issues, I (the Regional Administrator) am not prepared to approve restart of the Pilgrim facility until you ! (BECo.) provide a written report that documents BEco's formal assessment of the readiness for restart operation. 1/ Boston Globe, May 28, 1986. Order Modifying License Effective Immediately, 47
~
I 2/ Fed. Reg. 4171 (January 28, 1987). i l 4-
.....o.., -
...:.... ..: . -~..:-~-,--.. .
ci l. 1 1 appears to have an organic inability to manage Pilgrim in an effective and safe manner.8/
** BECo's SALP Evaluations **
l { BEco, has consistently received low ratings in SALP reports.A!
-1 k
,.1 l 8/ Although it is the failings of BEco's management of the
, Pilgrim plant which are the subject of this petition, it is significant that findings have been made in other settings that confirm BECo's managerial deficiencies and indicate that they extend to the other aspects of its business. See e.g., Boston Edison Company, Massachusetts Department of Public Utilities Docket No. 87-1A-A (1987) (imprudence in operation of oil fired generating unit). Of particular relevance to the notion that BECo. responds to the identification of deficiencies with half-hearted (although sometimes quite showy), short-term
+
solutions that treat the symptoms, not the disease, is the s series of decisions by the Massachusetts Department of Public i Utilities that address BEco's need to consider and develop new 3 sources of power in the aftermath of the 1981 cancellation cf
; the construction of the Pilgrim II nuclear unit. Boston Edison _
. Comeany, MDPU 906 (1982) (ordering BECo. to develop a new plan to meet its future power needs); Boston Edison Company, MDPU
; No. 86-270 (found reason to believe BEco lacked commitment
! and/or skill to fulfill public service obligation).
9/ The SALP process is the mechanism by which the NRC on a
- periodic basis systematically assesses the overall performance j of a licensee. For each assessment period (generally 12 to 18 I
months) a Board of NRC officials evaluates, in accordance with i preestablished attributes and rating guidance, the licensee's { performance for each of the various, preestablished functional i areas and rates the licensee's performance in each area. The
! Board also compares the licensee's performance for the current
, period with that of the previous assessment period and identifica, for further followup and inspection, any areas where the licensee's corrective action to improve performance has not been fully effective.
Arizona Public Service company, (Palo Verde Nuclear Generating Station, Unit 2), DD-86-8, 24 NRC 151, 156 (1986).
.. . . ..s.. . . . <. . . . . . , . . . . . . . . . . .
j . 1
^?
In 1980, BECo. received ratings indicating significant weakness t in three of the nine functional areas evaluated. The most recent SALP Report, seven years later, indicates that l conditions have not improved but rather have worsened. BEco. received ratings indicating significant weaknesses in five of
.I j the twelve functional areas evaluated. It has only once received a SALP Report without a rating indicating a
]M j significant weakness. On all other occasions, it has received reports indicating significant weaknesses in at least two functional areas. (See Appendix I: BECo. SALP History Tabulation) of particular significance, every time Quality Assurance i has been assessed as a separate functional area during a SALP
-t review, BECo. has received the lowest possible rating. These 1
i findings are indicative of the ineffectiveness of BEco's
! management. They are a measure of its inability and/or its I lack of commitment to run the plant in a effective and safe i manner.
f Although BECo. has at one time or another received the s i lowest possible rating in all but three of the twelve i functional areas covered by the NRC's SALP process, these
.l individual poor SALP ratings are not the most troubling aspect of BECo's SALP record. Instead, the most troubling and telling facet of BECo's SALP record is the Company's distinct inability to maintain any period-to-period performance improvements.
BECo. has at one time or another improved its SALP performance 4
.._.._..r....._
. . ..s.... .. . . . . . . - ._ . . - . .
j- . 1
.t
! in eight functional areas. However, it has not been able to
. sustain the increased level of performance in seven of those eight areas. In all but one instance, BECo's improved performance proved to be short-lived and its performance
,i t
' subsequently fell back to lower levels. This is not surprising j as an ever recurring theme in NRC evaluations of BECo's
,; performance is that NRC oversight and prompting is necessary at every stage of Pilgrim's operation.1S! The increased NRC i
attention (i.e., oversight and prompting) that a "3" rating t calls for has, on occasion, produced better performance by a BECo. However, when that level of attention returns to that norm, BECo's performance falls below the norm. BECo's SALP
. track record is proof of the proposition that BEco, by itself i
l has not effectively operated Pilgrim and that the short-term i
' solutions it has adopted in response to criticism have
.! invariably permitted the reoccurrence of the original problems.
i i ** BECo's Regulatory Violations ** l l 1 BEco., an enforcement action record that is a mirror of its l l l SALP Report record. It has had at least one Severity Level III l violation during each of the past six years.11/ (See 4 6 10/ E.g., 1987 SALP Review at 8; 1986 SALP Review at 7. 11/ As set forth in 10 C.F.R. Part 2, Appendix C; General l Statementof Policy and Procedure for NRC Enforcement Actions, regulatory violations are categorized into five descending levels of severity. Level III corresponds with "violations l that are cause for significant concern."
. . . . . ...__.:.. .. . . . . . . . . . . . . .. _1 i '
.e
! Appendix II: BECo. VIOLATIONS TABULATIONS - SEVERITY LEVEL III l
} VIOLATIONS) In the area of Security and Safeguards, BEco, had i a Severity Level III violation in all but one of the years
; between 1981 and 1986. In 1982, a civil penalty in the amount i
.i of $550,000 -- at the time the largest penalty to have ever
't been assessed by the NRC -- was levied against BECo. for serious plant operations violations and for submitting false
, I! information to the NRC.13! While the number of such Severity
,1
! Level III violations discovered at Pilgrim has not exceeded two 1
1 in any single year since 1981, the number of Severity Level IV 4 violations per year has more than doubled in the past few years. BECo's enforcement action record also mirrors its SALP
,i
} Report record in demonstrating BECo's chronic recidivism. It
-j has been cited five times for Radiological Controls violations i involving waste shipment packaging requirements.1E!
i It has been cited five times for Security and Safeguards s
'l violations involving the control of sensitive material such as keys to vital areas, security plans, and firearms.1AI i
5 12/ U.S. General Accounting Office, Reoort to the Honorable l Alfonse M. D'Amato, U.S. Senate: Nuclear Regulation Efforts to Ensure Nuclear Power Plant Safety can Be Strengthened (GAO-RCED-87-141 August, 1987), pp. 36-37.
-! 13/ See NRC Enforcement Summary Tables taken from various SALP j Reports (attached hereto as Attachment 4).
1 14/ Id. i
,. - - . .2 _ _ -
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.i 0
C. RECENT INDICIA-OF BECo'S PERFORMANCE LEVEL The most recent indicia of the level of BECo's performance in managing Pilgrim are consistent with its p st performance, j They confirm the notion that BECo. appears to be organically incapable of managing a nuclear facility. Notwithstanding the
-1 M frequent incantation by senior management of a program for the
- t J "pursuit of excellence," the addition of new personnel and the expenditure of large sums of money,1E/ the available evidence 1 indicates that BEco. has not changed. Its 1987 SALP Report shows that the Company continues to merit the lowest possible
,t ratings in many functional areas. BECo. continues to be incapable of maintaining performance gains. On the basis of l news reports, it appears that BECo's management of the Security and Safeguards function is deteriorating, not improving.
i Further, on the basis of statements made by NRC officials at a i
! recent meeting, the NRC has received and is investigating 1
! allegations that the company may be compromising safety by
.l
.; overworking its or its contractors' employees in an effort to i
j return the plant to service soon. This evidence suggests that BECo's claim to be approaching readiness for restart may i 15/ E.g., NRC Docket No. 50-293, Official Transcript of NRC Office of Nuclear Reactor Regulation, "Meeting With Boston Edison Re: Pilgrim Status and Activities Leading to Restart Readiness," pp. 13-14, 18-20 (September 24, 1987) ( herei.1af te r i "9/24/87 NRC/BECo. Readiness Meeting"). (Testimony Submitted by Stephen J. Sweeney, President and Chief Executive Officer, Boston Edison Company, to the U.S. House of Representatives, Subcommittee on Energy Conversation and Power of the committee on Energy and Commerce July 16, 1986, pp. 4-5 (attached hereto as "Attachment 5"). e
. s... . . .. . . . .
.i ..-
'i!
[ be hasty and misleading.15!
** BEco's 1987 SALP Report **
On April 8, 1987, the Nhc released a SALP Report for BECo. i
; which was based on the results of various inspections and evaluations conducted at Pilgrim over the period from 1
..I November 1, 1985 through January 31, 1987. Ratings were given
'q for BECo's performance in twelve functional areas. In keeping
- with its past record, BEco. received the lowest possible i
ratings in five of the twelve functional areas.11/ It received the highest possible rating in only two functional
! areas.10/ The picture painted in the SALP report is one of a
.i plant with "(p)oor management control," an "obscured ... chain i of command and weakened accountability," and "(s)significant i
l- recurring program weakness ... in some functional areas,
. showing the effect of ... long-term problems."1EI
-4 j __
! 16/ BEco's claim of readiness should be measured against its
! adoption of 9/24/87 NRC/BECo. Readiness Meeting, p. 43. This I tendency to ignore reality in the operation of the plant has l been previously found to be undesirable. See Boston Edison l
Company, MDPU NO. 1009-F (1982) (BECo. denied where evidence i established that it had imprudently underestimated the j necessary time required to perform outage tasks), i
- ll/ The five areas were: Radiological Controls, Surveillance, i Fire Protection, Security ar.d Saf eguards, and Assurance of Quality.
18/ The two areas were: Outage Management, Modifications, and Technical Support. Activities and Engineering and Corporate Technical Support. l 19/ 1987 SALP REPORT at 8. i i l l
. . . . , ~ + . . . ~ s .. . .- .- , .. ..<..<.I je .
l l l i l 1 4 i 1 i of particular importance to this Petition, were SALP i ratings in three areas where BEco. had previously improved its performance. In the functional areas of Surveillance, Fire Protection, and Licensing Activities, BEco. had in the past improved its ratings between periods -- in fire protection, it l had gone from a "3" to a "1" between its third and fourth SALP , 1
! Reports -- but by the time of the review for the 1987 SALP Report, its performance had fallen back to earlier levels.
With respect to the functional area of Security and Safeguards, the 1987 SALP Report discussed continuing hardware problems, BECo's excessive reliance upon contractors, and I management's failure to give this area sufficient attention.22/ The report noted that BECo's corrective
- i. actions for deficiencies in this area had not generally been effective and referenced three degradations in vital area barriers that had occurred during the evaluation period.21/
i _2_0/ Id. at 31-34. 21/ The Commission's regulations define a "vital area" as any l area which contains:
.j any equipment, system, device, or material, the failure, destruction, or release of which could
< directly or indirectly endanger the public health and safety by exposure to radiation. Equipment or
- systems which would be required to function to protect public health and safety following such failure, destruction, or release are also considered vital areas. 10 C.F.R. S73.2(h) and I (i) (emphasis added). Such areas are to "be located within a protected area such that access to vital equipment requires passage through at least two physical barriers." 10 C.F.R.
Access into a protected area is to 573.50(b)(1). be controlled through the checking of ( authorization and identity at entry control points to which barriers surrounding the protected area "channel persons and material." 10 C.F.R 573.45(b)(1)(i) and 73.50(c). I _ 11
r ( ... . a
,}*
i I ** i Recent Reports of Violations ** On the basis of news reports and statements made by NRC officials at a recent meeting, it appears that BECo. has j suffered from at least four significant Security and Safeguards
.i q lapses in the past six months: a misplaced guns a misplaced a
,j set of sensitive keys; a "serious degradation in a vital area 1
'. y barrier;" and ineffective identification cards.SS/ While all
-q
'j four alleged lapses would be significant, the latter three would be a particularly strong indication of BECo's failure to learn from its past mistakes -- nearly identical lapses have occurred in the past.EE!
i j Further, allegations have recently been made which NRC
.I
' stated at a recent meeting that they are investigating that BECo. may be compromising worker and/or plant safety by requiring excessive overtime.2f/
i III. EVIDENCE THAT INDICATES THAT A PLANT SPECIFIC PRA FOLLOWED BY IMPLEMENTATION OF ANY INDICATED
, SAFETY MODIFICATIONS SHOULD BE EsQUIRED TO PILGRIM'S RESTART.
] .
Pilgrim is a GE Mark I design plant. As such, it has a primary containment which, by nearly unanimous agreement, has an extremely high probability of failure in the event of l 22/ Boston Globe, September 4, 1987, p. 1; Boston Globe, September 9, 1987, p. 21; Boston Herald, September 10, 1987, i I p. 24. l i 23/ See 1985 SALP Reoort, p. 40; 1983 SALP Reoort, pp. 41-43; i 1982 SALP Report, p. 38 (included in Attachment I hereto). I t l 11/ Boston Globe, September 29, 1987, p. 21.
..' .m 8 ,,'4 o Y ' .i, 1
certain accidents.E / This characteristic is especially critical since Mark I design reactors, such as Pilgrim, do not have the backup of a secondary containment structure which can withstand any significant position pressure. ("PWRs").E! In
! fact, Pilgrim's so-called "containment building" ic not really - I designed to perform a backup function. It has "blow panels" i.., which in some design and most severe accidents would activate and create a ready path for hazardous radioactive materials to escape into the environment.E! Tha combination of an extremely vulnerable primary containment structure, a secondary containment not designed to provide an effective backup, and i the large population in the immediate vicinity of PilgrimE!
I
' compel the Governor and the Attorney General to request that the NRC modify the Pilgrim operating license to bar restart i until a plant specific probabilistic risk assessment ("PRA") is 1
l performed for Pilgrim and all indicated safety modifications I are implemented. Until this occurs, the operation of the plant l would pose an unreasonable threat t public health and I safety.E!
,2_5_/ See NUREG-ll50, Reactor Risk Reference Document, Draft for Comment, Feb. 1987, at 4-33, 4-39.
1 g/ Affidavit of Steven C. Sholly (attached hereto as Attachment 1). 2/ M. 1 M/ M. B/ M. 4
's....._..m.. . _. . . . ,d a- .
l q The Governor and the Attorney General are aware that the j NRC has to date declined to order mitigative modifications for Mark I design plants.ES! They submit, however, that the evidence presented here -- the combination of extremely vulnerable containment structures and a large population
.l I
1 surrounding the plant -- precludes application of NUREG-1150's (d finding that the probability of a large reactor accident with j early fatalities is extremely remote. The NUREG-1150 findings do not reflect the amalgam of risks posed by Pilgrim. f BEco. has proposed a number of modifications as remedial actions for the plant's design deficiencies.21/ These actions do not, however, address the inherent defects of the
. plant's design in any real way. The Governor and the Attorney General do, however, submit that through its so-called "safety l
enhancement program," BEco. has put the question of the f
, appropriate modifications to be made to remedy the defects of 't j the Mark I design in issue. .1 l
30/ E.g., Boston Edison Comoany (Pilgrin Nuclear Station), DD-87-14, __ NRC __ (1987) (slip at 31-32). 31/ Letter with enclosures dated July 8, 1987, from l Mr. Ralph G. Bird, Senior Vice President-Nucledr, Boston Edison l Company, to Mr. Steven A. Varga, Director, Division of Reactor Projects, I/II, Nuclear Regulatory Commission (attached hereto i as Attachment 5). l l ( . l \ . l 14 -
,,......z..._.. - . . . . . . .. . - _ . . . # .4 n= .
1 j IV. EVIDENCE OF INADEQUATE EMERGENCY PREPAREDNESS r
! Within the past twelve months, two authoritative assessments have been made of the Pilgrim Radiological
. Emergency Response Plan and the state of emergency preparedness
! within the Emergency Planning Zone ("EPZ") for Pilgrim.EE!
! Both conclude that the plan and the state of preparedness "are
-1 4
not adequate to protect the health and safety of the public in
.; the event of an accident at the Pilgrim Nuclear Power Station."$d! Both also concluded that the plan and the state l of preparedness have significant deficiencies and suggest I potential remedies for those deficiencies that will require a ~l substantial commitment of time, resources and i cooperation.2d! BEco.'has not quarreled with these I
conclusions.2E! The Governor and the Attorney General submit
! that these conclusions compel immediate action by the NRC. The t
I. { 12/ FEMA, "Self-Initiated Review and Interim Finding for the i Pilgrim Nuclear Power Station, Plymouth, MA" (August 4, 1987) j (hereinafter "FEMA Self-Initiated Review"); Secretary of Public l Safety, "Report to the Governor on Emergency Preparedness for an Accident at the Pilgrim Nuclear Power Station" (December 16, 1986) (hereinafter "Barry Report"). J3/ FEMA Self-Initiated Review at 1-2; Barry Reoort at 74. 34/ FEMA Self-Initiated Review, pp. 12-13, 19, 22, 29-32, 43-44; Barry Reoort, pp. 47-55. J 35/ 9/24/87 NRC/BECo Readiness Meeting", pp. 49-54. f a
~} authoritative expert agencies 25/ agree that there is no ?
reasonable assurance that the public can or will be protected in the event of an accident at Pilgrim. It is, thus, incumbent upon the NRC to take action immediately to insure that no steps I are taken by BEco. which could increase the likelihood or the i tj consequences of an accident.22!
.1
- A. THE PLANNING AND PREPAREDNESS DEFICIENCIES IDENTIFIED
,i BY PEMA AND THE MASSACHUSETTS EXECUTIVE OFFICE OF PUBLIC SAFETY
- The deficiencies of the Radiological Emergency Response
- Plans for Pilgrim are manifold. Although the analyses of FEMA and the Massachusetts Executive Office of Public Safety do not
' reach the same conclusions on all issues, the following areas of substantial deficiency have been identified by both agencies:
[
'l ; 1. the lack of any articulated evacuation plans for public and private schools as well as day l care centers; l 2. the lack of any articulated evacuation plana i
for the :pecial needs population;
.l 1
{ 36/ FEMA is explicitly recognized by the Commission as the expert Federal authority on questions of nuclear power plant offsite emergency preparedness (Memorandum of Understanding, 50 Fed. Reg., No. 75, 15,486 (April 18, 1985) and the Commission is expressly required to base its findings on off-site 1 emergency issues on FEMA's conclusions concerning such issues. 10 C.F.R. S50.47(s)(3). The Massachusetts Secretary of Public Safety oversees the Massachusetts Civil Defense Agency and
! Office of Emergency Planning, which pursuant to M.G.L. c. 147, S1 is responsible for the Commonwealth's emergency activities.
37/ Each step of BECo's power ascension plan corresponds with j a substantial increase in the probability of an accident at Pilgrim. Affidavit of Steven C. Sholly (attached hereto as
- Attachment 1).
t i I w.....~. .- . . . . , - . . . . . . . . . ~ . . .. . . . . A 4 . . w
- l l 3. the lack of any articulated evacuation plans j for the transport dependent population; Li
- 4. the lack of identifiable public shelters for the beach population;
- 5. the lack of a reception center, as required
; in the plan, for people evacuating by the northern route;
- 6. the lack of real progress in planning and the diminutioningpestateofemergency preparedness.__
These are critical deficiencies. The plans do not even purport to provide any measure of protection for significant numbers of people: pre-school and school age children; those
; who require special measures to transport; and those without ready access to private transportation. They fail to address the significant beach population in an adequate fashion. They
- i
! do not incorporate current or reliable evacuation time estimates ("ETEs"). Nor do they incorporate a delineated 1
1 inventory of identified and identifiable shelters which are
.I' accessible to the public. Moreover an integral component of the current plans -- a northern reception center3 2/
1 i 1 38/ FEMA Self-Initiative Review, pp. 12-13, 19, 22, 29-32, 1 43-44; Barry Report, pp. 47-55. l r 39/ The lack of a reception center for those evacuating to the north is as worrisome as the more general planning failures. l . The lack of a northern reception center indicates that even if
, evacuation from the EPZ were successful -- a heroic assumption j -! in light of the assorted planning deficiencies -- those who l . '
received and followed instructions to evacuate to the north would find no facilities available at their designated destination. According to FEMA, approximately 60,000 people would be left without facilities at which to register, be i monitored and decontaminated if necessary. FEMA Self-Initiated Review at 19. i (- l t i l
. . . . . . . , . . . . ~ . . . . . . . . - . . . . . . . .: . . u . . . ,
I j 1 -- is missing altogether. Finally, offsite exercises and drills -- the most effective means of assuring preparedness -- have not been held in years.
- B. THE CURRENT STATUS OF PLANNING AND PREPAREDNESS 1
I
. The specific functional deficiencies in the first four areas enumerated above, as well as the functional areas in ] which work must be done before any determination can be made if i .j adequate plans can be developed, encompass the entire set of tasks required for adequate planning and preparedness:
- 1. Identification / Estimation of populations; f
- 2. Identification / Estimation of resources; l 3. Develop plans for emergency actions to be j taken for each population with potentially j available resources;
- 4. Obtain commitments for required resources;
, 5. Provide education /information to public; I
i 6. Conduct exercises / drills. 1 At present, it appears that the school /daycare population has been identified but that the special needs and transport dependent populations have not.dE/ Preliminary estimates of { the resources potentially available to evacuate these i populations have now been obtained, but neither plan
, development nor obtaining commitments of resource availability can proceed in the absence of reliable ETEs.S1/
e 40/ Executive Summary of the Reoort on Emergency Preoaredness For an Accident at Pilgrim Power Station) (October 15, 1987) (hereinafter "Barry Report Update"), p. 2. 41/ Id. at 2. 18 -
.._ . .m ._ _. ._. _ . . , , . . . . . ,.a .,a .
1 1
') While BEco. has recently -- August 18, 1987 -- delivered an J}
ETE study to the Commonwealth's public safety officials,32/ the document is still being reviewed by chose officials and preliminary analysis has uncovered shortcomings that will
; necessitate further work. It is, thus, unlikely that final j ETEs will be available within the immediate future for use in I developing specific plans.SS/ This shortcoming is critical.
A consequence of the unavailability of reliable ETEs is that
,j emergency planning is effectively on hold. Even when the task of identifying / estimating populations and resources is completed, radiological emergency planning cannot in any real sense proceed without reliable ETEs and a traffic management l Plan. As FEMA and the NRC well recognize, a realistic set of 4
I ETEs is an essential element of a workable emergency plan. See Cincinnatti Gas & Electric Company (Wm. H. Zimmer Nuclear Power
]
1 Station, Unit No. 1), ALAB-727, 17 NRC 760, 770-71 (1983). l With respect to the beach population, preliminary f population estimates and sheltering data have been provided to y the Commonwealth's public safety officials but, at least in the case of the sheltering survey, these materials have been found i 1 32/ KLD Associates, Pilgrim Station Evacuation Time Estimates and Traffic Management Plan Update (Final Draft for Review) August 18, 1987.
, 43/ Barry Report Update, p. 2.
i l l l 19 - ! . - - - _ = - _. - . . - _ _ . - - - _ _ _ .- -
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. }-
.k
, to be inadequate for planning purposes.Ad!
l
.i Again, plan development and resource availability commitments,
! much less public education /information efforts and exercises / drills, cannot proceed usefully without reliable final ETEs and sheltering data.11!
j No replacement site for a northern reception center has been foundd5! and no determination has yet been made whether j an emergency plan incorporating only two reception centers would provide an adequate assurance of protection.S2/
;~
i 44/ Barry Report Update, p. 2; Letter with enclosures from
'. Robert J. Boulay, Director, Massachusetts Civil Defense Agency, dated September 18, 1987, to Ralph C. Bird, Executive Vice j
, president-Nuclear, Boston Edison Company (attached hereto as j Attachment 7) 1 45/ Barry Report Update, p. 2; See also FEMA Self-Initiated Review at 26-27:
Before FEMA and the RAC can make a determination on this (whether protective actions for thebeach population are or readily can be made adequate) i it must receive the following information:
,l 1) an updated geographical description of the
; beaches and their capacity; 2) a detailed 1 analysis of the beach population, including the j number of permanent and temporary residents and 4
the number of day visitors, together with their
'j" geographical dispersion; 3) an updated estimate of the length of time it would take to evecuate the beach population; and 4) a list of suitable buildings available for sheltering the beach 4
population at each beach, including the
; capacities of these buildings and their
'l distances from the beaches. If these buildings
! are not open to the public, the plans must
; clearly state how they will be made accessible and letters of agreement must be obtained as appropriate.
I 46/ Id.
, 47/ 9/24 NRC/BECo. Readiness Meetino, p. 52. But see FEMA Self-Initiated Review at 19 (The use of only two reception centers "is not likely to be logistica11y i
feasible."). j f
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.]
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Finally, in the absence of new plans, public l information/ education efforts and exercises / drills cannot, by 3 definition, occur. There are no plans to inform the public of [ exercises, much less to exercise. Although the provisions of l 10 C.F.R. Part 50, Appendix E, Section IV.F. require that a J
- j. full participation biennial emergency preparedness exercise for
.i.: Pilgrim be held this year, the NRC is presently considering a il
! request from BECo. for a one-time exemption from that
.)
l requirement to allow the exercise to be postponed to the second quarter of 1988.SO/ IV. CONCLUSION f In light of all of the foregoing deficiencies of the current state of emergency planning and preparedness, as well as the substantial questions raised herein concerning the I managerial ability of the licensee, BEco., and the safety of I l the Pilgrim reactor, the Governor and Attorney General submit l 1 that the NRC must take action pursuant to 10 C.F.R. S2.202 to
.'l l insure that BECo. does not take any action that could increase either the risk or the consequences of an accident at Pilgrim.
j Since that Pilgrim is a GE Mark I design reactor, and the EPZ population at this plant is among the highest in the l country, it is evident that the deficiencies in emergency I
- .! planning and preparedness are significant for Pilgrim. These t .
48/ Letter with enclosures dated September 18, 1987, from l Mr. Ralph G. Bird, Senior Vice President-Nuclear, Boston Edison 1, Company, to NRC (attached hereto as Attachment 8). 5
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1 l deficiencies are so substantial and their potential i ramifications are so significant, that it is impossible to conclude that any interim compensating actions have or can be taken. The NRC's regulations leave it no course other than
} issuing-an order modifying BECo's license to extend the current 'l shut down pending the outcome of a full hearing on the .]
{ significant outstanding safety issue and the development and
. 1
! certification by the Governor of adequate emergency plans.SE!
i Respectively submitted, James M. Shannon
- Attorney General j commonwealth of Massachusetts i Michael S. Dukakis
- Governor
! Commonwealth of Massachusetts
'\
l Dated: October 15, 1987 i I l 49/ Compare 10 C.F.R. S50.54(s)(2)(ii): i
! ... In determining whether a snutdown or other
! enforcement action is appropriate, the Commission shall take into account, among other factors, i
whether the licensee can demonstrate to the Commission's satisfaction that the deficiencies in the plan are not significant for the plant in question, or that adequate interim compensating 1; actions have been or will be taken promptly, or t that there are other compelling reasons for
! continued operation.
i i J I
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t APPENDIX I: BECo. SALP HISTORY-TABULATION
'i _Inspec. ' Plant . Radiol. Maint. Surveil. Fira Emergen, jj , Period Operg Control Prot. Prepared 01/01/80 2 3 2 2 2 2 j 12/31/80 09/01/80 3 2 3 2 2 _1
.- l
'j -
08/31/81 i 09/01/81 3 -2 2 2 3 -1 06/30/82 I 07/01/82 2 2 -2 1 1 1 06/30/83 07/01/83 2 3 1 1 2- 3
-l 09/30/84 1
i 10/01/84 3 3 2 2 - 3 10/31/85
, 11/01/85 2 3 2 3 3 2 01/31/87
'l Inspec. Secur. Out.Mgt. Licen. Eng/ Corp Train Quality
-{
j Period Safeqds Mod.Act Activ. Tech.Sup Qual.Ef Assuran
~
I
! 01/01/80 2 3 - - -
3
.s
! 12/31/80 3
l 09/01/80 2 2 - - - 08/31/81
' ~
,09/01/81 2 2 2 - -
i 06/30/82 07/01/82 - - 2 - 1 -
! 06/30/83 i
4 07/01/83 2 1 1 - - j 09/30/84 10/01/84
!- 2 1 1 -
10/31/85 1' 3 11/01/85 3 1 2 1 2 01/31/87 3 i
o
'l
- -1,
-8
. .g -
4 BEco. VIOLATIONS TABULATIONS APPENDIX II: i
! SEVERITY LEVEL III VIOLATIONS: 9/1/81-1/31/87 1981 1982 1983 1984 1985 1986 1987
, Functional Area
'l d Plant Operations 3 1 2 1
) Radiological Controls Mainenance Surveillance Fire Protection 1 Emergency Preparedness' 1
?
1
~
Security / Safeguards 1 1 1
- Outage Mgt ...
j Licensing Activities Training ... Eff' ness Assurance of Quality i Engineer / Corp. Support BECo. VIOLATIONS BY SEVERITY LEVEL: 9/1/81-1/31/87
> Severity Level 81/82 82/83 83/84 84/85 85/87 I I i II 7 1 1 2 1 I III 21 9 18 17
'i IV 20 9
20 6 5 6
'i V 2
- ! VI 1 1 3
} Deviations 2 3 26 27 29 Total Violations 40 33
~
i i 9 5 i
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.}
i, UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
- BEFORE THE COMMISSION t
, In the matter of
~i BOSTON EDISON COMPANY Docket No. 50 293
-1
- (Pilgrim Nuclear Power Station, Unit 1) 1 A_EEiDAVIT OF STEVEN C. SHOLLY Steven C. Sholly, being on oath, deposes and says as follows:
- 1. I am an Associate Consultant with MHB Technical Associates,1723 Hamilton i
Avenue, Suite K, San Jose, Califomia,95125. A statement of my professional j qualifications is attached hereto and marked Attachment A. In brief, I have I more then six years experience in the review, analysis, interpretation, and j application of probabilistic risk assessment to the analysis of safety issues
- related to commercial nuclear power plants, including issues related to l
-l radiological emergency planning. I have served as a member of the peer review group for the NRC publication NUREG-1050 (1984) (Probabilistic Risk i
Assessment (PRA) Reference Document. September 1984), and have more recently served as a member of the Containment Performance Deslan Oblective Workshoo. the Panel on ACRS Effectiveness (1985), and the Severe
$ Accident Policv Imolementation Extemal Events Workshoo (1987). I have previously testified as an expert witness on probabilistic risk assessment and emergency planning rnatters in NRC proceedings on the Catawba Units 1 and i 2, Indian Point Units 2 and 3, and Shoreham Unit 1 nuclear plants, and also in the Public inquiry regarding the proposed Sizewell-B nuclear plant in the United
! Kngdom. in addition, I have co authored two major reviews of source term 4
4 l
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! and risk estimate issues published in NRC reports NUREG-0956 and NUREG-4 1150. I have also pecformed reviews of various technical aspects of the Shoreham, Limerick, Indian Point, Sizewell, Zion, Seabrook, Millstone-3, and Oconee-3 probabilistic risk assessments and the Vermont Yankee ' Containment Safety Study.
1 i
- 2. MHB Technical Associates ('MHB') has been requested by the Nuclev Safety Division, Department of the Attorney General, The Commonwealth of i Massachusetts, to evaluate the increase in risk resulting from a startup
. program for return to power from the current refueling and modifications outage for the Pilgrim Nuclear Power Station, Unit 1 (PNPS-1).
- 3. In its current configuration (refueled) and considering the duration of the current shutdowr., Pilgrim currently poses very little risk to the public health and safety. This is due to the multiplicity of systems theoretically available to inject water into the reactor vessel and due to the low decay heat level present in the fuel. In the event of a core heatup transient with the plant in its current configuration, considerable time would elapse between initiation of coolant loss l
and the onset of fuel damage, time during which measures could be taken to i initiate coolant makeup and/or other recovery and mitigative actions. l Moreover, in theory a longer time period is available within which to implement i offsite protective actions due to the slower accident progression time I compared with accidents at higher power levels. I 4. Boston Edison Company (BECO), the licenses for Pilgrim, currently envisions restart power ascension program with a minimal number of hold points in brief, BECO proposes to institute holds on restart (pending approval from NRC in accord with Confirmatory Action Letter No. 86-10), recovery from reactor
.] ~! mode switch testing prior to conducting a test for shutdown from outside the i
control room, and prior to movement of the scram set point above 95% power. [Seg, Boston Edison Company, Pilarim Nuclear Power Station Restart Plan. l pages IV-29 to IV-31.] The details of the power ascension program in Attachtrent 13 of the Pilarim Nuclear Power Station Restart Plan have not yet been provided.
&..._. _;...c__....,.. . . . _ _ _ . _ . . . . . . . _ . . . . _ . . . . . . . ... [ . .;.
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- 5. My current understanding of the BECO power ascension program is that the program would result in a relatively rapid ascension from the current shutdown condition to full power operation. In so doing, the risk to the public health and safety posed by operations at the Pilgrim plant will be increased markedly.
- 6. The Commission has concluded generally that the risks from 5% power operation are negligible. [Ste, for example, SECY-84-155,12 April 1984, and attachments; and letter dated 15 June 1984 from Nunzio J. Palladino to Hon.
4 Edward J. Markey, and attachments.) The evaluations upon which the Commission has drawn these conclusions, however, were for plants with very little operating history and no spent fuel pool inventory. Clearly, Pilgrim is different in this regard, with a substantiallong half life fission product inventory present in both the refueled reactor core and the spent fuel pool. Moreover, these evaluations did not concider the unique risks posed by accidents resulting from extemally-initiated events (specifically, in this case, seismic
.: events), in my opinion, tha presence of more than 1100 spent fuel assemblies, l prior operation of two thirds of the core at equivalent full power for most of an i
! operating cycle, and the matter of external events render the circumstances at Pilgrim sufficiently different from those previously evaluated for 5% power l operation that the previous evaluations understate, perhaps significantly, the j risk posed by operation of Pilgrim at 5% of full power. This conclusion is i further supported by the likelihood that the primary containment will not be inerted until operation above 5% power is commenced. In my opinion, virtually l
j any severe accident at 5% power with the containment de inerted will result in early containment failure (due to hydrogen bum or hydrogen detonation in the primary containment, and/or other causes). ,
~i l
, 7. As power level increases, risk to the public increases. This is due to several
! factors, including a marked increase in volatile fission product inventory and a marked increase in decay heat level, which results in accident progression times which are much shorter than at low power levels. This reduces the
' mount of time available for implementation c f recovery and/or mitigation l
l l l l
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w ., 7. . actions and reduces the amount of time available to implement offsite f protect:ye measures, 1
; 8. A full scope probabilistic risk assessment for the Pilgrim plant has been in j progress for several years. It is my understanding that this study is nearly completed. It is my expectation that this study will identify seismic initiating ~, events as a significant contributor to core melt frequency (i.e., contributing 10%
or more to core melt frequency from all causes). This expectation is based on j my familiarity with seismic risk assessments performed on similar designs and performed on other plants in the general region of Pilgrim (e.g., Shoreham,
];
Seabrook Units 1 and 2, Millstone Unit 3, and Umerick Units 1 and 2). Seismically-initiated accident sequences are accompanied by potentially severe impacts on offsite emergency response even when there are fully-approved and operational emergency plans. In the case of Pilgrim, the current status of emergency planning is such that there is not adequate assurance that protective actions can and will be taken in the event of an accident. Given the j more severe conditions of a seismically initiated accident scenario, this conclusion is all the more applicable. [ A I 9. A study of risk at 25% power for the Shoreham nuclear plant, which possesses a nuclear steam supply system which is grossly similar to Pilgrim, indicates that
, the core melt frequency for operations at up to 25% of full power may not differ
! dramatically from the core melt frequency at full power. The 25% power PRA estimates a core melt frequency of 2.8 x 10-5 per reactor year. [ Sag,E.T.
}
l Bums, S. Mays, and T. Mairs, Drobabillst/c R/sk Assessment of the Shoreham A Nuclear Power Station: Initial Power Ooeration Limited to 25% of Full Power. J
~q Delian Corporation, prepared for Long Island Ughting Company, April 1987, J'
page 4-12.) The full power PRA analyses for Shoreham estimated a core melt frequency of about 6.5 x 10-5 per reactor-year. (Sea, Science Applications, i Inc., Final Reoort: Probabilistic Risk Assessment. Shoreham Ouclear Power Station. prepared for Long Island Ughting Company,24 June 1983, page 4; and V. Joksimovich, et al., Maior Common-Cause initiatina Events Studv:
! Shoreham Nuclear Power Stat /on. NUS Corporation, NUS Report No. NUS-4617, prepared for Long Island Ughting Company, February 1985, page 18) 0
.. _ _ . _ . . , . ~ _ . _ _ . _ . . . _ . . . . . _ . _ . - . _ _ . . . _ . _ . . .
i 5 This represents less than a factor of three difference in the likelihood of a core
; melt accident at 25% power versus full power. Although this assessment is for Shoreham and not for Pilgrim, it suggests that the likelihood of an accident is i not markedly different for 25% power versus 100% power, i ! 10. Further, a limited scope PRA of Shoreham at 5% power was prepared for
-! LILCO. This study, which did not include external events, concluded that the l core melt frequency for 5% power operation was about 4.9 x 10-6 per reactor- ~j year. [Sge, Delian Corporation and Science Applications, Inc., Probab///st/c
; Risk Assessment. Shoreham Nuclear Power Station. Low Power Ooeration UO to 5% of Full Power. prepared for Long Island Ughting Company, draft, May i 1984, page 78.] This indicates that core melt frequency at 5% power is , significantly reduced from 25% power or full power, by a factor of roughly 20, i but not nearly as significantly reduced as previously predicted by the NRC staff, i, which predicted a reduction factor of 1,000 or more.1/ Moreover, the 5%
power reduction factor of 20 is an underestimate since the 5% power estimates
; do not include extemal events.
- 11. The 5%, 25%, and 100% power PRA studies for Shoreham indicate, in my opinion, that the core power level for Pilgrim will have at best a moderate
! impact on the likelihood of an accident. Considering the uncertaintiec involved, l the likelihood of an accident may be nearly indistinguishable at the various i power levels indicated above. Moreover, the Shoreham results are lower than ! the core melt frequency estimates for many other plants. A Brookhaven National Laboratory review of the Shoreham PRA for internal events only estimated a core melt frequency of 1 x 10 4 per reactor-year. An average value 4 per reactor-for full-scope PRAs completed to date is of the order of 3 x 10 year.
i 1/ The NRC staff, in SECY-84-156, predicted core melt frequency reduction factors
; for various classes of BWR accidents ranging from 1,000 to 100,000. (See, SECY-84-156, Enclosure 1, 'Statt Review Process for 5 Percent Power Operation ~,
page 2.) Thus, in the aggregate, the NRC staff would have expected a core melt fraquency reduction of at / east 1,000, compared with the Shoreham value of 20. The results for Shoreham indicate a reduction factor approximately 50 times less than the NRC staff expected based on engineering judgment. 4 t 9
~
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! 12. These results are especially significant for a plant with a containment design similar to Pilgrim. Pilgrim employs a steel Mark I pressure suppression containment. Such containments have been estimated in a variety of studies sponsored by IDCOR, NRC, and utilities to have an early containment failure j
probability - given a severe accident - in a range from 10-90%. This means i that there is a significant chance that, given a severe accident, the accident will
-} be accompanied by a large early release of radioactivity to the environment.
1 I i 13. The Pilgrim plant, like all Mark I containment design plants, also employs a
) secondary containment, usually referred to as a reactor building. This structure is not designed to withstand the high internal pressures which would accompany a severe accident, and is unlikely to survive in a leak-tight condition following primary containment failure. High pressure in the secondary containment due to a severe accident would be produced by a combination of blowdown due to primary containment failure, primary containment leakage, primary containment venting, and burning of combustible gases. Indeed, Mark j i plants are designed with both intemal and external "blow-out panels" which j are des /oned to relieve pressure. In the case of Pilgrim, there are blow-out l*
panels at the refueling deck elevation which relieve pressure directly to the environment. In my opinion, there is little basis for assuming that releases from l j the primary containment will be significantly mitigated by the presence of the secondary containment. l e
- 13. Based on the above considerations, it is my opinion that Pilgrim Unit 1 should not be restarted until the offsite emergency response plans are upgraded and evaluated to adequately protect the public health and safety. Further, it is my recommendation that BECO be required to promptly submit the Pilgrim probabilistic risk assessment study to the NRC for public review and evaluation j prict to restart. The review of such a study should indicats whether there 5
l 9 i
. .: . . -. - -. .~ - -- -.-- - .. - - - - - - ' - - - - - ~ - - - - - - ' - - ~ ~ '
't i 7 remain significant operational risks which must be amelioriated in order to provide adequate protection to the public health and safety. A .A'q - 1 Steven C. Sholly Associate Consultant 1 [ CENERAL ACKNOWLEDGMENT No. of
' state of j On this the/ 9 day of 1922, before me, y, County of- .
,u 1an L .Se a.w ,
l' the undersigned Notary Public, personally appeared j-,4ns C .Cl, A
/
Un elCIAL SEAL 0 personally known to me MY LB Fproved to me on the basis of satisfactory evidence
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@ Nonw pg a m Wy cerne. tr>m JUN 24, 1991
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to be the person (s) whose name(s) within instrument, and acknowledged that WITN Ess my hand and of ficial seal.
/J Se Subscribed to the executed it.
l 5 s--J ~ 2n-Notary's sigria h m 'j t0122 __m , .- - MDoAAL NOTARY AssoQADoN e 23012 ventwra 8svd.
- PO Boa 4625 e Wooctand M.ms CA 91365-4625 l
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-j 1 PROFESSIONAL QUALIFICATIONS OF STEVEN C. SHOLLY STEVEN C. SHOLLY MHB Technical Associates 1723 Hamilton Avenue Suite K San Jose, California 95125 !
(408)266-2716 .
.i
; EXPERIENCE:
~I
, September 1985 - PRESENT l
Associate - MHB Technical Associates, San Jose, California l a Associate in energy consulting firm that specializes in technical and economic assessments of energy production facilitiis, especially nuclear, for local, state, and federal governments and private organizations. MHB is extensively involved in regulatory proceedings and the preparation of studies and reports. Conduct research, write repets, participate in , discovery process in regulatory proceedings, develop testimon) and other i documents for regulatory proceedings, and respond to client inquiries. { Clients have included: State of Califorr.ia, State of New York, State of
. Illinois.
I
'{ February 1981 - September 1985 i
i Technical Research Associate and Risk Analyst - Union of Concerned fcien-tists, Washington, D.C. E j Research associate and risk analyst for public interest group based in
- Cambridge, Massachusetts, that specializes in examining the impact of ad-i vanced technologies on society, principally in the areas of arms control i and energy. Technical work focused on nuclear power plant safety, with I emphasis on probabilistic risk assessment, radiological emergency planning and preparedness, and generic safety issues. Conducted research, prepared reports and studies, participated in administrative i
proceedings before the U.S. Nuclear Regulatory Commission, developed testimony, anlayzed NRC rule-making proposals and draft reports and prepared connants thereon, and responded to inquiries from sponsors, the l general public, and the media. Participated as a member of the Panel on j ACRS Effectiveness (1985), the Panel on Regulatory Uses of Probabilistic i Risk Assessment (Peer Review of NUREG-1050; 1984) Invited Observer to NRC Peer Review meetings on the source term reassessment (BMI-2104; 1983- , 1984), and the Independent Advi-sory Connittee on Nuclear Risk for the Nuclear Risk Task Force of the National Association of Insurance
- Commissioners (1984). .
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- i i
.t
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- . . . .. _.. . .. . .. . ... .. a.. ... ,,o .
f i . January 1980 - January 1981 Project Director and Research Coordinator - Three Mile Island Public Interest Resource Center Harrisburg, Pennsylvania Provided administrative direction and coordinated research projects for a public interest group based in Harrisburg, Pennsylvania, centered around issues related to the Three Mile Isicnd Nuclear Power Plant. Prepared fundraising proposals, tracked progress of U.S. Nuclear Regulatory Com-mission, U.S. Department of Energy, and General Public Utilities activi-ties concerning cleanup of Three Mile Island Unit 2 and preparation for-1 restart of Three Mile Island Unit 1, and monitored developments related g to emergency planning, tnc financial health of General Public Utilities,
;. mG NRC rulemaking actions related to Three Mile Island.
July 1978 - January 1980 Chief Biological Process Operator - Wastewater Treatment Plant, Derry Township Municipal Authority, Hershey, Pennsylvania Chief Biological Process Operator at a 2.5 million gallon per day ter-tiary, activated sludge, wastewater treatment plant. Responsible for bi-ological process monitoring and control, including analysis of physical, chemical, and biological test results, procees fluid and mass flow man-agement, micro-biological analysis of activiated sludge, and maintenance i of detailed process logs for input into state and federal reports on treatment process and effluent quality. Received certification from the Commonwealth of Pennsylvania as a wastewater treatment plant operator.
.i' Member of Water Pollution Control Association of Pennsylvania, Central Section, 1980.
July 1977 - July 1978 l Wastewater Treatment Plant Operator - Borough of LemoyN, Lemoyne, Penn- { sylvania j l Wastewater treatment plant operator at 2.0 million gallon per day sec-ondary, activated sludge, wastewater treatment plant. Performed tasks as assigned by supervisors, including simple physical and chemical tests on wastewater streams, maintenance and operation of plant equipment, and maintenance of the collection system.
, September 1976 - June 1977 Science Teacher - West Shore School District, Camp Hill, Pennsylvania i
i Taught Earth and Space Science at ninth grade level. Developed and im-I piemented new course materials on plate tectonics, environmental geology,
- and space science. Served as Assistant Coach of the district gymnastics team.
I t t 2 ___ M = ___ _ _ __1.__
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r September 1975 - June 1976 I Science Teacher - Carlisle Area School District, Carlisle, Pennsylvania Taught Earth and Space Science and Environmental Science at ninth grade level. Developed and implemented new course materials on plate tecton-ics, environmental geology, noise pollution, water pollution, and energy. Served as Advisor to the Science Projects Club. EDUCATION: i B.S., Education, majors in Earth and Space Science and General Science,
, minor in Environmental Education Shippensburg State College, Shippens-i burg, Pennsylvania, 1975.
(' Graduate coursework in Land Use Planning, Shippensburg State College, Shippensburg, Pennsylvania, 1977-1978. PUBLICATIONS:
- 1. "Determining Mercalli Intensities from Newspaper Reports," Journal of Geological Education, Vol. 25, 1977.
l 2. A Critique of: An Independent Assessment of Evacuation Times for Three 1 Mile Island Nuclear Power Plant, Three Mile Island Public Interest
] Resource Center. Harrisburg, Pennsylvania, January 1981.
- 3. A Brief Review and Critique of the Rockland County Radiological Emergency 3
Preparedness Plan, Union of Concerned Scientists, prepared for Rockland County Emergency Planning Personnel and the Chairman of the County Legis-l ; lature, Washington, D.C., August 17, 1981. i
- 4. The Necessity for a Prompt Public Alerting Capability in the Plume Expo-sure Pathway EPZ at Nuclear Power Plant Sites, Union of Concerned Scien-tists, Critical Mass Energy Project, Nuclear Information and Resource Service. Environmental Action, and New York Public Interest Research Group, Washington, D.C., August 27, 1981. *
- 5. "Union of Concerned Scientists. Inc., Cossnents on Notice of Proposed Rulemaking. Amendment to 10 CFR 50, Appendix E. Section IV.D.3." Union of Concerned Scientists. Washington, D.C., October 21, 1981. *
- 6. "The Evolution of Emergency Planning Rules," in The Indian Point Book: A i Briefing on the Safety Investication of the Indian Point Nuclear Power l
- Plants, Anne Witte, editor, Un' on of Concerned Scientists (Washington.
l
! D.C.) and New York Public Interest Research Group (New York, NY),1982.
l l l 7. "Union of Concerned Scientists Coments. Proposed Rule,10 CFR Part 50, l i Emergency Planning and Preparedness: Exercises, Clarification of Regula-tions, 46 F.R. 61134," Union of Concerned Scientists, Washington, D.C., January 15, 1982.
- l i t
i
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- 8. Testimony of Robert D. Pollard and Steven C. Sholly before the Sub-comittee on Energy and the Environment, Comittee on Interior and Insular Affairs, U.S. House of Representatives, Middletown, Pennsylvania, March 29, 1982, available from the Union of Concerned Scientists.
- 9. "Union of Concerned Scientists Detailed Comments on Petition for Rulemak-ing by Citizen's Task Force, Emergency Planning,10 CFR Parts 50 and 70, Docket No. PRM-50-31, 47 F.R. 12639," Union of Concerned Scientists, Washington, D.C., May 24, 1982.
- 10. Supplements to the Testimony of Ellyn R. Weiss, Esq., General Counsel, Union of Concerned Scientists, before the Subcomittee on Energy Conservation and Power, Comittee on Energy and Commerce, U.S. House of Representatives Union of Concerned Scientists, Washington, D.C., August 16, 1982.
T
- 11. Testimony of Steven C. Sholly, Union of Concerned Scientists, Washington, D.C., on behalf of the New York Public Interest Research Group, Inc., be-fore the Special Comittee on Nuclear Power Safety of the Assembly of the State of New York, hearings on Legislative Oversight of the Emergency Ra-diologic Preparedness Act, Chapter 708, Laws of 1981, September 2,1982.
- 12. "Coments on ' Draft Supplement to Final Environmental Statement Related to Construction and Operation of Clinch River Breeder Reactor Plant',"
Docket No. 50-537, Union of Concerned Scientists, Washington, D.C., j September 13, 1982. *
- 13. "Union of Concerned Scientists Coments on ' Report to the County Comis-sioners', by the Advisory Comittee on Radiological Emergency Plan for Columbia County, Pennsylvania," Union of Concerned Scientists, Washing-ton, D.C., September 15, 1982.
{
- 14. "Radiological Emergency Planning for Nuclear Reactor Accidents," pre-sented to Xernenergie Ontmanteld Congress, Rotterdam. The Netherlands.
I Union of Concerned Scientists Washington, D.C., October 8,1982.
- 15. "Nuclear Reactor Accident Consequences: Implications for Radiological Emergency Planning," presented to the Citizen's Advisory Comittee to Re-i view Rockland County's Own Nuclear Evacuation and Preparedness Plan and
} General Disaster Preparedness Plan, Union of Concerned Scientists. Wash-1 ington, D.C. , November 19, 1982.
l l 16. Testimony of Steven C. Sholly before the Subcomittee on Oversight and l 1 Investigations, Comittee on Interior and Insular Affairs, U.S. House of i Representatives Washington, D.C., Union of Concerned Scientists, Decem-ber 13, 1982.
- 17. Testimony of Gordon R. Thompson and Steven C. Sholly on Comission Ques-tion Two Contentions 2.1(a) and 2.1(d). Union of Concerned Scientists and New York Public Interest Research Group, before the U.S. Nuclear Reg-ulatory Comission Atomic Safety and Licensing Board, in the Matter of Consolidated Edison Company of New York (Indian Point Unit 2) and the Power Authority of the State of New York (Indian Point Unit 3), Docket Nos. 50-247-SP and 50-286-SP, December 28, 1982. *
,. . . . . . . . . . . . . - . - - . . . - - . - . .-. .. ... - - . . ~.
a . . I
! 18. Testimony of Steven C. Sholly on the Consequences of Accidents at Indian Point (Comission Question One and Board Question 1.1, Union of Concerned Scientists and New York Public Interest Research Group, before the U.S.
Nuclear Regulatory Comission Atomic Safety and Licensing Board, in the Matter of Consolidated Edison Company of New York (Indian Point Unit 2) and the Power Authority of the State of New York (Indian Point Unit 3), Docket Nos. 50-247-SP and 50-286-SP, February 7, 1983, as corrected February 16, 1983. *
- 19. Testimony of Steven C. Sholly on Comission Question Five, Union of Con-cerned Scientists and New York Public Interest Research Group, before the '
U.S. Nuclear Regulatory Comission Atomic Safety and Licensing Board, in the Matter of Consolidated Edison Company of New York (Indian Point Unit 2 and the Power Authority of the State of New York (Indian Point Unit 3 , Docket Nos. 50-247-SP and 50-286-SP, March 22, 1983.
- l 20. "Nuclear Reactor Accidents and Accident Consequences: Planning for the Worst," Union of Concerned Scientist:, Washington, D.C. , presented at Critical Mass '83, March 26, 1983.
- 21. Testimony of Steven C. Sholly on Emergency Planning and Preparedness at Commercial Nuclear Power Plants, Union of Concerned S:1entists Washing-ton, D.C., before the Subcomittee on Nuclear Regulation Comittee on Environment and Public Works, U.S. Senate, April 15, 1983, (with "Union of Concerned Scientists' Response to Questions for the Record from Sena-i tor Alan K. Simpson," Steven C. Sholly and Michael E. Faden).
- 22. "PRA: What Can it Really Tell Us About Public Risk from Nuclear Ac-2 cidents?," Union of Concerned Scientists, Washington, D.C., presentation to the 14th Annual Meeting, Seacoast Anti-Pollution League, May 4,1983.
- 23. "Probabilistic Risk Assessment: The Impact of Uncertainties on Radi-ological Emergency Planning and Preparedness Considerations," Union of -
Concerned Scientists, Washington, D.C. , June 28, 1983.
- 24. "Response to uA0 Questions on NRC's Use of PRA," Union of Concerned Sci-entists, Washington, D.C., October 6,1983, attachment to letter dated i October 6,1983, from Steven C. Sholly to John E. Bagnulo (GAO, Washing-i ton,D.C.).
I
- 25. The Impact of "External Events" on Radiological Emergency Response Plan-
- i ning Considerations Union of Concerned Scientists, Washington, D.C., De-cember 22, 1983, attachment to letter dated December 22, 1983, from Steven C. Sholly to NRC Comissioner James K. Asselstine.
i 26. Sizewell 'B' Public Inquiry, Proof of Evidence on: Safety and Waste Man-agement Implications of the Sizewell PWR, Gordon Thompson, with supporting evidence by Steven Sholly, on behalf of the Town and Country Planning Association, February 1984, including Annex G. "A review of Probabilistic Risk Analysis and its Application to the Sizewell PWR," *
. Steven Sholly and Gordon Thompson, (August 11, 1983), and Annex 0, i
"Emergency Planning in the UK and the US: A Comparison," Steven Sholly .
i . and Gordon Thompson (October 24,1983). i , _. _ _ . _ n - _ -. _ = . _ _ _ _ _ . _ _ . _ _ _ _ . . . _ . _ _
=:..-.. . . . . ~ . - . . .- . .. . . - . . . . - . . . . . - . .
1 1 i
- 27. Testimony of Steven C. Sholly on Emergency Planning Contention Number
. Eleven, Union of Concerned Scientists, Washington, D.C., on behalf of the Palmetto Alliance and the Carolina Environmental Study Group, before the U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board, in the Matter of Duke Power Company, et. al. (Catawba Nuclear Station. Units 1 and 2), Docket Nos. 50-413 and 50-414, April 16,1984. *
- 28. "Risk Indicators Relevant to Assessirig Nuclear Accident Liability Premi-ums," in Preliminary Reoort to the Independent Advisory Committee to the NA!C Nuclear Risk Task Force, December 11, 1984, Steven C. Sholly Union of Concerned Scient'sts, Washington, D.C.
- 29. "Union of Concerned Scientists' and Nuclear Information and Resource Ser-vice's Joint Comments on NRC's Proposal to Bar from Licensing Proceedings the Consideration of Earthquake Effects on Emergency Planning " Union of Concerned Scientists and Nuclear Information and Resource Service, Wash-ington, D.C., Diane Curran and Ellyn R. Weiss (with input from Steven C.
, Sholly), February 28, 1985. *
- 30. "Severe Accident Source Terms: A Presentation to the Commissioners on the Status of a Review of the NRC's Source Term Reassessment Study by the Union of Concerned Scientists," Union of Concerned Scientists, Washing-ton, D.C. , April 3,1985. *
- 31. "Severe Accident Source Terms for Light Water Nuclear Power Plants: A
; Presentation to the Illinois Department of Nuclear Safety on the Status of a Review of the NRC's Source Term Reassessment Study (STRS) by the Union of Concerned Scientists," Union of Concerned Scientists, Washington, D.C. , May 13, 1985.
- 32. The Source Term Debate: A Review of the Current Basis for Predicting Se-l vere Accident Source Terms with Special Emphasis on the NRC Source Term Reassessment Program (NUREG-0956), Union of Concerned Scientists, Cam-
, bridge, Massachusetts, Steven C. Sholly and Gordon Thompson, January 1986.
I
- 33. Direct Testirony of Dale G. Bridenbaugh, Gregory C. Hinor, Lynn K. Price, and Steven C. Sholly on behalf of State of Connecticut Department of Pub-lic Utility Control, Prosecutorial Division and Division of Consumer Counsel, regarding the prudence of expenditures on Millstone Unit III.
February 18, 1986, t
- 34. Implications of the Chernobyl-4 Accident for Nuclear Emergency Planning i for the State of New York, prepared for the State of New York Consumer
! Protection Board, by MHB Technical Associates, June 1986.
- 35. Review of Vermont Yankee Containment Safety Study and Analysis of Co n ta inmen t Venting Issues for the Vermont Yankee Nuclear Power Plant, pre;sred for New Englar.d Coalition on Nuclear Pollution Inc., December l
- 16, 1965-i e
! i l 1 l
~
.j r
4
- 36. Affidavit of Steven C. Sholly before the Atomic Safety and Licensing Board, in the matter of Public Service Company of New Hampshire, et al., regarding Seabrook Station Units 1 and 2 Off-site Emergency Planning Issues, Docket Nos. 50-443-OL & 50-444-OL, January 23, 1987.
- 37. Direct Testimony of Richard B. Hubbard and Steven C.
Sholly on behalf of California Public Utilities Commission, regarding Diablo Canyon Rate Case, PG&E's Failure to Establish Its Committed Design QA Program,
;, Application Nos. 84-06-014 and 85-08-025, Exhibit No. ; 10,935, March, 1987.
- 38. Testimony of Gregory C. Minor, Steven C. Sholly et. al.
1 on behalf of Suffolk County, regarding LILCO's Reception Centers (Planning Basis), before the Atomic Safety and Licensing Board, in the matter of Long Island Lighting Company, Shoreham Nuclear Power Station Unit 1, Docket No. 50-322-OL-3, April 13, 1987.
- 39. Rebuttal Testimony of Gregory C. Minor and Steven C.
Sholly on behalf of Suffolk County regarding LILCO's Reception Centers (Addressing Testimony of Lewis G. Hulman), Docket No. 50-322-OL-3, May 27, 1987. i 40. Review of Selected Aspects of NUREG-il50, "Reactor Risk l Reference Document," prepared for the Illinois Department of Nuclear Safety by MHB Technical Associates, September 1987. Available from the U.S. Nuclear Regulatory Commission, Public Document Room, Lobby, 1717 H Street, N.W., Washington, D.C. l I i 4 l l l i l l ! i l 4 l
. . . ~ . . . . . . . . . . . . - . . . . . --
J 3 i 0lllllNew England Nuclear News CONNECTICUT YANKEE JUNE 1987 (April Data) On April 16, the plant shutdown because of problems with turbine control valve #4. After , chemistry holds and a load runback, the plant reached full power (94%) on April 21st. ,l The Institute for Nuclear Power Operations (INPO) will conduct its annual critique of plant operations beginning on June 8th. 1 MAINE YANKEE Maine Yankee shutdown for refueling is proceeding generally according to schedule with startup expected in early June. Very small cracks found in the disks of both low pressure turbine rotors have necessitated the replacement of one and the repair of the other. YANKEE Yankee began its 18th refueling on May 2nd. The last cycle of the plant produced more than 2 million megawatthours over a 17 month period with a capacity factor of 93 percent. PILGRIM Pilgrim remained off-line during the month. ! i VERMONT YANKEE l On April 4, Vermont Yankee came down in power and took the turbine off line to repair j a small steam leak in a main steam drain line. The plant came back on line the same day ; and operated at full power for the remainder of the month. l MILLSTONE 1 & 2 Millstone Unit 1 operated routinely for the month of April. A scheduled refueling outage will begin in mid-June and last for approximately 10 weeks. Millstone Unit 2 operated routine-ly except for a trip on April 16 due to a generator exciter field circuit breaker opening on presumed bistable transformer fault indication. Instruments in place to monitor the suspect
/ bistablo. The unit returned to service after a 20 hour outage on April 18.
MILLSTONE 3 Millstone Unit 3 returned to service after a scheduled outage. After startup on April 11, the unit tripped on the next day while at 10 percent power level due to steam generator low level when turbine driven feed pump oscillated. Feedwater regulating control valve failed to open on demand due to a control air leak. The unit returned to service on April 14 after being out fo 29 hours. ecna i . -. , c
. ,s pa%". umin starts - . .
*,, c. NUCLEAR REGULATORY COh MISSION ., h '
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***** AUG 2 71986 Docket No. 50-293 Boston Edison Company M/C Nuclear 9Q{
ATTN: Mr. James M. Lydon Chief Operating Of ficer , . f(M 800 Boylston Street . Boston, Massachusetts 02199 Gentlemen:
Subject:
Confirmatory Action Letter 86-10 This letter is to provide further guidance on the requirements we expect to be met prior to the restart of the Pilgrim plant. We acknowledge receipt of Boston Edison Company's (BECO) letter of June 16, 1986, in response to CurTirmatory Action Letter (CAL) 86-10. Your actions with regard to the issues in CAL 86-10 appear to be thorough and technically sound.,.My staf f has a few remaining questions, which have been discussed with your staff and which will be documented in Inspection Report 50-293/86-25. In addition to the specific plant hardware issues involved with CAL 86-10, several other issues have been identified that require resolution prior to restart of the l Pilgrim plant. Soecific technical issues of concern include: ,qverdue surveil-lances, malfunction of recirculation motor generator set field breakars, seismic oualification of emergency diesel generator dif ferential relays, and completion of
. Accendix R modifications. please be prepared to discuss these issues at our next manacement meeting at the plant on September 9, 1986. Me would a'so like to hear at this meeting the scope and status of all your crocrams related to restart of pilarim. These include (a) the results of your six week action plan for improve-ments. (b) the role of BECO safety review committees includino;he Procram For_
Freellence Task Force. in assessing readine"; for restart, and (c) the readiness o,f I the plant and corporate staff to support plant startup, testing, and operations. l In light of the number and scope of the outstandino issues. I am not orecared to approve restart of the Pilorim facility until vou orovide a wri t ten ente r t that l documents BECO's formal assessment of the readiness for restart operatign. This assessment should include your detailed check list for assuring that all out-l standing items have been satisfactorily resolved and that plant systems aaie been restored and prepared for operation. A formal restart program and schedule should also be submitted for NRC review and approval. This program should includ.y hold points at appropriate stages such as criticality, completion of soce switch test-i ing, and at specific milestones during ascension to full power. Authorization to j proceed beyond each hold point will be contingent upon my appraval and will be based on my staff's evaluation of the operational performance of the plant. We will have substantially augmented NRC inspect!c coverage during this Nstart
. period.
Please olan to submit your readiness As_s,es' dpt end entArt program and schedul_e at least forty-five days before your 01 W rhode 'mJurrent cougt My decision on restart will be based in parr vieu sf chese Gecuments,
?
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- Your cooperation is appreciated.
Sincerely, r-G,; 2: -1 Thomas E. Murley Regional Administrator CC: L. Oxsen, Vice President, Nuclear Operations
. A. E. Pedersen, Station Manager Paul Levy, Chairman, Department of Public Utilities Edward R. MacCormack Senior Regulatory Affairs and Program Engineer Chairman, Board of Selectmen Plymouth Civil Defense Director The Honorable E. J. Markey J. O. Keyes ,,
Senator Edward P. Kirby The Honorable Peter V. Forman Sharon Pollard Public Occument Room (POR) Local Public Document Room (LPOR) Nuclear Safety Information Center (N5IC) NRC Resident Inspector . Commonwealth of Massachusetts (2) 4 1 1 i
~~~"
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APR 0 81997 . Docket No. 50-293 Boston Edison Company M/C Nuclear 4 ATIN: Mr. Ralph Bird - i Senior Vice President - Nuclear
! 800 Boylston Street i Sosten. Massachusetts 02199 Gentlemen:
Subject:
Systematic Assessment of t.icensee Performance ( SALP) Report No. 50-293/86-99 Tr.e Region I SALP Boarc has reviewed and evaluated the performance of activ-ities at the thrcugh JanuaryPilgrim 31, 1987.Nuclear Power Station for the pterlod November 1,1985 The results are presented ir. the enclosed repert. A . eeting to discsss this assessment will be scheduled for a mutually accept-act e ca.e. The reeting will be held en or near the sit e so that apprcpriate se. or corporate ma9agerent anc olant efficials ccn st e..;ths and eair. esses noted. discuss with as the It is our intent that th is meeting be ce=bined Ith the periodic manage ent meeting to review improv ement program status.
? .e sal.P Boarc identi fi ed significant recurring progra m weaknesses ta so e Nr.:tional area s. Improvements, such as in the area of e mergency preparedness,
.ere also notec. However, the SALP Boarc found the rat.e of such change was slow during most of the assessment pericd.
We recognize that the Boston Edison Company (BECo) has made significant staff-ing anW hedware comnitments to impreve performance at th e Pilgrim Staticr. and-we believe they are beginning to have a positive impact. As you are aware, ti e' NRC is looking for progress in correcting the previcusly identified lor; tem "
- -cblems at the. Ptigrim Station prior to clant restart, carticularly ir : :n
%reticnai areas witn a Category 3 rating.
In : reparation for the SALP meeting, please ce . prepared t.o discuss your evalua-tien of our assessment and the status of your performance? 1mprovesert pr:gra?.s. Any :oet.ents you may have regarding our report may be dis cussed at the mee .!sg. f ect .t onallyg.you may provide written co.t ents within 30 cays af ter the r ,eet-ing. Following our meeting and receipt of your written response, the enclosed report, your response, and a summary of our findings ar.d planned actica.: will-ce pieceo in the NRC Public 'ocument Room. l 1 f I
..._a- . . . . .
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0 i 63 TABLE 4
. ENFORCEMENT
SUMMARY
(11/01/85 - 01/31/87) PILGRIM NUCLEAR POWER STATION
. A. N;mber and Seve-ity Level of Violations ; Severity Level ! 0 1 Severity Level !! 0 l Severity Level III 1 Severity Level IV 21 Severity Level V 6 Ceviation 1 Tesal 29
- 5. ' vie *ations Vs ~unctieral Area Severit. Les s' s
~.r::icna'. Areas I !! !!! IV V 'lv Tetal
- 1 art Operati:ns - - -
1 1 4
- 0. :a:tological Certrels 1 3 - -
va'ntenance - - - 1 1 l 3 1 S;rveillance - - - 6 3 - 9
- 5. :'re Drotectic, - - -
5 - 2 6 l 1 1 6 ( E ergency P e:a-edness - - - - - - 0 7 59:. t:y Safeg. ares - - - 1 1 2 3 Gstage Manager.ent anc Medifi,tation A:tivities 1 1 2
. .a
- 9. Li:ensingActivities 0
4 i ;0. Tra'rtng anc Caalification Effectiveness - - - - - - 0 4 - - '
- t.-an:e c' ~.i t ity - - -
. E :* et-* ; a : :r::-ate - -
"e: rical S.:::-
- ats C . 1 21 6 1 25
}
t 6s IAbtE 4 (Continued) C. Summary Inspection i Report Severity Functienal ' Number level Area Violation 85-32 V Surveillance Instrument channel tests were not being performed monthly f'or the reactor butiding vent and stack waste gas sonttors. t 25-32 V Secu ity Failure t o perform a Safeguards proper se arch of a package becught i nto the protected area. Ei-C; V ;! ant Dost trio review 86-01 anc 0:4 ations 66-02 lac (ed required recorder .cha-ts. Inadequate control a com leg entries on disabled annunciators.
,' 55-04 lI: Radiological A waste stierea.: of solid Cc-tecis metallic oxices on non- ,
compactec tra sh lacked requireo . strong packsging anc cuality c.cntrol measures. if-05 IV Sveveillance Replacement squib charges were inst.alled in the stane::y liquid ccetrol systa.- fec a batch tha t had not been testec during a manual initiation c f
'the Stancby Liquid Centrol i Sy s ters.
25-10 IV Radiological Radiatf or surveys of packageo Controls irradiated reactor compenents j were not cocumented on appropriate radiation survey I f o rm s anc' ma c s .
!!-1C I '. Ass.;rance of Quality c ontec1 reasures we e
~.aty not take- 'n transfe-ring ractcact' ve wa ste shipments
..__ . . . . _ . . . . . ~ . _ . . , . . . _ . .. . _. . . ... ... . . .
i 65 I TABLE 4 (Continued) C. Summary inspection Report Severity Functional level Area Violation j Num.b e r IV Assurance of Previous 3y identified
, $5-14 inadequacies involving Quality surveillance testing of the ' high pressure coolant ' injection system were not
- corrected for six months.
Surveillance Failure to' properly control 36-14 V measuring and test equipment. 35-2; lV Surveillance Battery r atec ".cac di scha rge Test proc edure was not updated tz eflect syster alterattoms are restorations. lv Assurante of Failure a nd $'alfunct* on h F 55-25 Ouali:y Report. wa s n:t completed by engine ering personnel af ter i they iden tified deficient station f ire barriers. J 36-25 V Su rv eillanc e' Surve111ar.ce tests were performec without incependent verificat ion of system res;er.se and systen restoration. Deviation Fire Drotheti:n Failure to comply with tr.e 36-25 commitment to conduct quarterly fire brigade drili: j for all fire brigade mes.bers. j IV Security Improper package search anc 15-34 . inadequate follew up.
- Safeguards IV Fire Protection Fire brigade members had c.et I 36-36 received the required l l training, t
Fire : :te:tiem :'re watenes f ailed to pe-f: - Ei"2i lV the required hourly patrei of the motor generator set r: - l 1 1
-g
, . - - - , - - - - - _ _ _ . - - . . _ , _ - _ , _ _ - . . . - , .y -_,
,.. .... a . . . . . . .. . -. . .. .. . . . . .. ... . . .
i
' 66 TABLE 4 (Continued 1 C. Summary inspection Report Severity Functional Area Violation Humber __ Level ] Inadequate fire brigade drill.
86-37 IV Fire Protection Modifications Safety-related modifications
' i 86-37 IV were not performed in
; accordance with applicable i'
desigt. requirements. Fire Prctection Adequate procedures and I 55-39 IV drawings had not been estabitsbed "or the station fire wat er sustem. i :adiological Failure to 1 ;?ement a V H-44 radiolog ical costrol proce:gre j , Oc9trols ! i for chec king: venicles leaving ( the site , IV Surveillance Failure no adhere te ti:e i 97-01 procecure gcverning
,j surveilliance testing of t9e i Post Acc Ident Sampling System (;3A55 ) system.
Maintenance Lack cf procedure guidance en 57-01 IV maintenance of the heat tracing control circuit reiays 1
; for the DASS system.
3 \ Fire Prote: tion Failure to take required 57-03 IV action for inoperable fire i2 ,. protection equipment. p?!,A IV Radiological Failure to control a master 87-03 ';- Centrois key to all Ic: Led nt;h radiation areas. 1 IV Assurance of Failure and Malfunction I , 53 -03 Osa ! ' ty Repe-t not ecmpleted af te-
! a saf ety-rel a .ed bus trars'e-die not occur during a surveillance test.
( t L '" NI"' -._e
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ew
..ki 67 I
TABl.E 4 (Continued) C. Summary Inspection Report Severity Functional Nu..be* t.e v e l Area Violation 27-04 IV Surveillance A surveillance test on Standby Gas Treatment System failed to meet the intent of the Tech Spec requirements. 87-04 IV Surveillance Failure to calibrate measuring and test equf scent. 57-Oc V Medification Performing post-modi fication test or. the rifuel bridge without ap; :ved procedure changes.
+
67-04 IV Surveillance Master test r*: gram procedures do not ace: nely acdress survet lar: test at:d pcs: 9 modi fica s t - test programs. I x -
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dW S. UNITED STATES
! f- NUCLF A R REGUL ATORY COMM11SIO!!
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m x U - m 2 a as RECE VEL Oceket No. 50-293 MAy y g --- Boston Edison Company M/C Nuclear ATTN: Mr. William O. Harrington F
- P* O' Senior Vice President, Nuclear 800 Boylston Street I _
. . . . . , , _ d Boston, Massachusetts 02199 II Centlemen:
Subject:
Systematic Assessment of Licensee Performance (SALP) Report No. 50-293/85-99 Thit letter refers to the Systematic Assessment of Licensee Performance (SALP) of the Pilgrim Nuclear Power Station for the period of October 1, 1984 through October 31, 1985, initially forwarded to you by our February 18, 1986 letter (Enclosure 1). This SALP avaluation was discussed with you and your staff at a meeting held in Plymouth, Massachusetts on March 5, 1986 (see Enclosure 2 for attendees). We have reviewed your March 26, 1986 written comments (Enclosure 3) and herewith transmit the final report (Enclosure 4). Overall, your performance in tne operation of the facility was found acceptable although some areas were only minimally acceptable. As projected in our letter of February 18, 1986, a special in-depth team in-spection was conducted from February 18 to March 7,1986 (Inspection Report No. 50-293/86-06) to determine the underlying reasons for the poor performance discussed above. The team found that improvements were inhibited by (1) incom-plete staffing, in particular operators and key mid-level supervisory personnel, (2) a prevailing view in the organization that the improvements made to date have corrected the problems (3) reluctance, by management, to acknowledge some problems identified by the NRC, and (4) dependence on third parties to identify problems rather than implementing an effective program for self-identification of weaknesses. Ve believe these findings confirmed the SALP Board conclusions. We acknowledge your discussion of program and staffing improvements in plant 1 operations, radiological controls and emergency preparedness. However, we . believe that .the success of your programs depends upon resolution of the four principal fagters inhibiting improvement noted above which, in turn, depends heavily on management attitudes and aggressive followup. In this regard we request that you be prepared to discuss the scope, content and schedule of each ; improvement program at a management meeting scheduled for 1:00 p.m. on June 12, 1986 at the NRC Region I Office. B
I i T-4-1 TABLE 4 ENFORCEMENT
SUMMARY
(10/1/84 - 10/31/85) PILGRIM NUCLEAR POWER STATION Severity Levels FUNCTIONAL AREAS I II III IV V DEV Total 1 A. Plant Operations - - - 4 2 - 6 B. Radiological Controls - - 1 1 1 2 5 C. Maintenance & Modifications - - - 1 1
- 0. Surveillance - - -
9 2 1 12 E. Emergency Preparedness - - - 2 - - 2 ! F. Security & Safeguarts - - 1 - - - 1 G. Refueling & Outage Management - - - - - - 0 ilh l H. Licensing Activities - - - - - - 0 Te:als by Seve itj Le.ei 0 C 2 17 5 3 27 l 1 l
. (:) .
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T-5-1 IABLE 5 ENFORCEMENT DATA PILGRIM NUCLEAR POWER STATION Insp. I0so. Severity Functional No. pate level Area Violation 84-36 11/1-11/85 IV Plant Failure to conduct an adequate Operations shift turnover for control room personnel curing refueling IV Plant Operations Failure to continuously monitor source range monitors during refueling 8f-39 11/21- IV Surveillance Failure to promptly. identify 12/31/84 J conditions adverse to quality (i.e. failure to initiate Failure and Malfur.ct. ion Reports)
, 84-41 12/10-13/84 IV Emergency lf Preparedness Failure to diseminate emergency planning information
' IV Eeergen:y l
Ore; art:r. ass Failure to update the emergency plar at:: pr::edures 84-44 12/16-19/84
/
III Radiological Failure to follow radiation work Controls 1 - permit instructions and failure to establish a procedure for a l' remote reading teledesimetry system l 85-01 1/1-31/85
> V ' Plant Failure to maintain control room l
' - Operations staffing af levels required by i
10 CFR 50.54
-i IV Surveillance Failure to test the containment
- cooling subsystem 1enediately when the low pressure coolant injection system was inoperable 1
85-03 2/1/85- IV Surveillance Failure to conduct surveillance 3/4/85 tests for the reactor protection systay, (six examples) IV Surveillance Failure to conduct rod block g surveillnee tests (five examples) unitt-
,y .
-.--_-,-, ,-_.,w.. . , _ , , . . - . _. . . - , . _ . . . . . _ , . - , - ~ - -
.. ~ . . ,
/
. /
! T-5-2 1 ) Insp. Severity Functional Insp. Violation Date Level A-ea No.
IV Plant Failure to promptly correct con-Operations ditions adverse to cuality (i.e. failure to take timely action - on Quality Assurance surveillance findings) a-V Surveillance Failure to use 4ese most current revision of s epweillance tes* procedure ;fr-V Surveillance Failure to calibrete test equip-ment within the calibrated period 3/5/E5- V Plant Failure to maintain an uncali-85-06 Operations brated local power range monitor 4/1/65 in a bypassed ctate IV Maintenancs Failure to conduct a dioctyl phthalate test of HEPA filters following maintenance on the standby gas treatment system V Radiological Failure to have the Operations 85-13 5/20-24.'85 Review Cor.mittee (ORC) review
' Co.trols two radiclogical procedures and failure to control work in the fuel pool with a maintenance request ,
Radiological Failure to conduct an adequate' Oeviation review of systems that could Controls generate an uncontrolled, un-monitored radioactive effluent release, as recommended in IE Bulletin 80-10 6/13/85- IV Surveillance Failure to conduct a surveillance l 85-17 surveillance test ef the 250 V 7/15/85 battery system regt tred by the technical specifica ion and to
- follow station procedures for additional battery tests Radiological Failure to specify high radiation IV area surveillance frequencies Controls on radiation work permits 1
e T-5-3 Insp. Insp. Severity Functional No. Date Level Area _ Violation Deviation Surveillance Failure to conduct inservice tests as specified in an NRC submittal I 85'20 7/16/85- IV Surveillance Failure to maintain the trip 8/19/85 level setting for the "B" and "C" sain steamettee high radi-ation monitors within technical specification Ifmits P l 85-21 7/16/85- IV Surveillance Failure to maintain secondary 7/30/85 containment IV Suaveillance Failure to test alternate safety system when an emergency diesel generator was found to be inoperable IV Surveillance Failure to initiate Failure and
- Malfunction Reports as required by station procedures
) Security Failure to maintain an adequate 85-24 8/6-E/55 III i vital area barrier 85-26 5'20/85- IV Plant Failure to properly authorize 9/25/55 Operations excessive licensed operator
- overtime as required by station
! ~< procedures (thirty-five instances) l Radiological Failure to install a protective 85-27 9/16/85- Oc dation 9/20/55 Controls conduit 1 i
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,' 4.j .s ee, #o, UNITED STATES 4
J' , . , NUCLEAR REGULATORY COMMISSION
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% %, % ,e'f x No op emussiA, peNNsYt.VANIA 19406 Docket No. 50-293 N 19 $$5 c' c. f .,
Boston Edison Company M/C Huclear ATTN: Mr. William D. Harrington ' n
, ,n Senior Vice President, Nuclear 800 Boylston Street ,
l 1 Boston, Massachusetts 02199 'Y, p' 4 [, Gentlemen: l
Subject:
Systematic Assessment of Licensee Performance (SALP) Report No. 50-293/
~
84-34 and Your Reply Letter BEco 85-031 Dated February 12, 1985 Thank you for your reply to SALP Repert No. 50-293/84-34 In your letter you pre-sented additional information concerning assessments and requested we reconsider some of the assessments to better account for the assessment period's extraerdinary circumstances (i.e., the extended outage for piping replacement). Based on our discussions with you at the January 23, 1985 management meeting and
' the information presented in your reply letter, the SALP Board found it appropriate
' to revise the declining trend of the Category 2 rating for fire protection / house-i keeping to a Category 2 rating with a consistent trend. We feel this is appropriate l
as we may not have properly accounted for the extended outage in our evaluation k for trend. However, we continue to feel that the extent of contamination that existed throuohout the plant was inconsistent with a Category 1 rating. The en-closed sal.P Report has been supplemented to reflect this change. The SALP Board { also found that the other ratings should remain unchanged. With regard to the current status of your operations, we acknowledge the improving trend of your performance in the plant operations and maintenance areas and en-
, courage you to continue your efforts in these areas. Further, we note the progress l being made in implementing your recently established Radiological Improvement Pro-gram and encourage your efforts to decontaminate the plant, to reduce plant radi-ation levels, to enhance oversight of the radiation protection program, and to establish support for the program by plant personnel.
.i Your cooperation with us is appreciated.
Sincerely, A% - - l Thomas E. Murley Regional Administrator 1 t
.a i
i l 38 1 l TABLE 2 VIOLATION
SUMMARY
(7/1/83 - 9/30/84) PILuRIM NUCLEAR POWER STATION I A. Number and Severity Level of Violations
, 1 Severity Level I O
-] Severity Level II' 0
, ; Severity Level III 1 Severity Level IV 18
- Severity Level V 6 Deviation 9 _1 Total 26*
B. Violations Vs. Functional Area Severity level
, Functional , Areas I II III IV V OEV 1
.; A. Plant Ooerations
; 2 5 j B. Radiolecical Controls
- 1 7 1 1 C. Maintenance 2
.; 0. Surveillance 1 E. Fire Protection and Housekeepino 4
F. Emercency Preparedness
. G. Security and Safeguards 6
!' H.
Refueline and Outace Manacement I. Licensing Activities Totals
- 1 18 6 1 t
- Totals do not include three apparent violations and one apparent deviation in the area of radiological controls that were identified during inspection 84-25.
NRC enforcement action was under review at the end of the assessment period.
- _ . , _ _ . , . ..,,,,,,,c-.
I l 39 i i C. Summary Inspection Inspection Severity Report No. functional Oate 1.evel Area Violation 83-19 8/16-10/3/83 V A
,' Failure to review and up-date special orders
- 'j V e A Failure to vent piping from
. . .,)
. the high point in the core spray system
'l 83-20 8/8-12/83 IV
+
1 B Failure to follow a Radi-
<! ation Work Permit 83-21 8/22-24/83 V A Failure to schedule 'exter-nal audits V A Failure to document defi-ciencies in deficiency reports 83-23 10/4-11/7/83 IV 0 i Failure to conduct an in-
.e service test on a high
'j .
pressure coolant injection
.q (HFCI) valve
,.! IV Failure to review a proce-C
- i dure for procuring safety-t i related items, l l 83-24 11/8-12/31/83 IV l :i A Failure to record reactor I : vessel cool down rate
'j 84-03 1/20-27/84 i
III B Failure to label a container
'!d of licensed material, use extremity dosimetry, and j instruct workers on radi-ation levels 84-04 2/7-3/12/84 IV A Failure' to maintain a pro-cedure for the proper operation of the contain-ment atmospheric dilution system 84-06 2/13-17/84 IV B Failure to follow a radi-ation work permit
,-.-...-,r _ - - - - - - - . - - _ _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ -
,.AB 40 Inspection Inspection Severity Report No. Functional Date level Area Violation 84-11 4/23-27/84 IV
, C Failure to maintain a pro-
! cedure for controlling i
welding slag t 84-13 4/24-27/84 IV B Failure to properly review
.g- O and approve contractor pro-cedures involving transpor-tation of radioactive materials
' IV B Failure to comply with the requirements of a Certifi-cate of Compliance for a transport package V B Failure to properly document
, a quality assurance program for transport packages 4
DEV
.) B Failure to fulfill a trans-g portation training commit-ment '~
84-14 5/9-11/84 IV
- " B Failure to instruct workers
'j on the presence of radio-
.i active materials
', IV B Failure to survey radiation hazards l N' IV B Failure to implement pro-cedures consistent with 10 CFR 20
.J
,; 84-22 7/16-20/84 IV G Failure to control a
]
i security key card *
- IV G Failure to maintain photo 10 badges IV G Failure to respond to two vital area alarms IV G Failure to maintain one guard radio and one offsite communications net operable
7 . ... , 4
- ]
- 41 Inspection Inspection Severity Functional i' Reoort No. Date level Area Violation 4
IV G Failure to maintain effac-tive compensatory measures.
- 4 IV G Failure to maintain effec-
. .i tive compensatory measures.
3
-:, 84-25 8/6-10/84
- l 8 Failure to perform radiation sai surveys 0: *
'i 8 Failure to instruct workers
' on radiation hazards
. ?!
- B Failure to properly approve procedures 8 Failure to implement recom-mandations in Regulatory Guide 8.8 84-26 8/28-10/8/84 V A Failure to properly approve QA program related proce-
--j dures t
4
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1 t i u- j
- Apparent violations and deviations. Enforcement action was under review at the l } and of the assessment period.
! { l ') l : Y,
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A 1 l i 1 1 I
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4 UNITeO $7Afe5 NUCLEAR REGULATORY COMMl1510N [# 'o,
- ReGlON l
- , p4 l't PARK AVENUE
{e J KING OP PRWS$1 A. PENNSYLV ANI A 19486
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- SEP1 4 ?S83 ce:,et so. 50-293 gesten Ecise Cce:any M/C Nuclear Airs: M . William O. Harrington Senior Vice President. Nuclear RECEIVED
. ,l-j 300 Sey1stor Street 5eston, Massacnusetts 02199 SU 15 Lc3 i
Geatlemen: W. D. H.
+o 'i:' fl S*.EJ ECT: SYSTEMATIC ASSES $Y.ENT OF LICENSEE PERFORMANCE (SALP)
'.]
'l The NRC Region I SALP Board conducted a review on August 25, 1983, and evaluated
- ne ce fermance of activities associated witn the Pilgrim Nuclear Power Station.
I Ine results of this assessment are documented in the enclosec SALF Scard Report. ' A teeting has been seneduled for September 21, 1953, at Braintree, Ma. te ciscuss tnis assessment. At tre meeting, you should be preoared to discuss our assessment and your
- lans to it crove oerformance. Any cer ments ycu may have regarding Our recort may :s cis:Ussed at tne meeting. Additionally, you may provice written com:-erts witnin 2C days af ter tne meeting.
a C F01'cwing our meeting and recelot of your response, the enclosed reocrt. your rescense, anc a summary of our findings and planned actions will ce placec in
<b .,
tre NRC hblic Occ' ment Room.
.- ',f - Ycur cocceration is appreciated.
Sincerely, 2
, il lt icnarc . arestecki SALP Scard Chairman, Director
- q Oivision of Project and Resident Programs
' ',,]
\ .
- n:losure: As Statec
\
- J l c
-l
! c: w/ encl:
'. 4 A. V. Morisi, Manager. Nuclear Ooerations Supoort
! C. J. Matnis, Station Manager 9
l l 4
= ~ . . .
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. .. . . .. . . . . .w...
5
; 39 i
~.~
TABLE 4 VIOLATIONS (7/1/82 - 6/30/83) PILGRIM NUCLEAR POWER STATION
! . A. Number and Severity level of Violations
.. f
.)[I Severity Level I O
~"l Severity Level II O C. -t Severity Level III 1
- i Severity Level IV 9
- Severity Level V 20 Deviations 3 .
Total Violations 30 Total Deviations 3 B. Violations Vs. Functional Area Severity Levels i FUNCTIONAL AREAS I II III IV V OEV l 4 8
- 1. Plant Ooerations Radiological Controls 1 7 1
.A 2.
-h 1 1
, ;l
- 3. Maintenance 9
-l A. Surveillance 3 1 S. Fire Protection /Heusekeeoino s
-:1 6. Emergency Preoaredness Security and Safeguards 3 2
- 7. 1 l,
- 8. Refueling I 9. Licensing Activities Totals 0 0 1 9 20 3 l
l l 1 i Total Violations = 30 Total Deviations = 3 I
. c- , , . . . . . . . . _ . - - ........._..m. -
1F"
-j 40 TAGLE 4 (Continued)
~. Sunna ry inspection Inspection Require-Nel Date Subject ments Severity Area 82-19 June 14 - Blocking open a fire T.S.
V 5 August 1 door without proper controls Failure to evaluate
~t T.S. V 5 fire loading prior to moving combustibles
__ , into safety related area . Failure to translate 10CFR50 V 1 design bases into App. B drawings Failure to perform 10CFR50.59 V 1 j t an adequate safety l evaluation prior to
-)
changing a station valve lineup procedure Failure to maintain T.S. V 5 l . a fire door position
.j continuously annunciated i
J Failure to perform Fire
.1 l daily checks of non- Protet: ion 0 5 j alarmed fire doors Review as committed to the NRC B2*22 August 2 - Failure to make a T.S. IV I prompt notification j
Failure to make a 10CFR50 V 1
; 50.72 notification Failure to perform a T.S. IV 4 leak rate test required by the LCO for an inoperable Vacuum Breaker
' Alarm System
)
4 4 i
,. . . g .-. -
- .. w.. . . ~u
, 41 I
TABLE 4 (Continued) Summary Inspection Inspection Require-No. Date Subject ments Severity Area 82-24 Septemcer 7 - Failure to revise Licensee 0 2 October 18 procedures for radio- Response
.i active discharges as to
- l committed to the NRC Violation
. - 81-19-01 82-29 October 19 - Imoroper equipment T.S. V 1 Novemocr 15 tagging Failure to properly
- set a main steam safety valve Failure to properly 10CFRSO IV 1 control distribution App. B of the Q-List Failure to use proper Security V 7
~
methods of access Plan control 1
; Failure to prevent Security IV 7 unauthorized entry into Plan
.i vital area or followup
! on a security deficiency e
l'j N/A(1) January 31, Safeguards information 10CFR73.21 III 7 j 1983 not properly controlled j resulting in a loss of 7 copy of the site physical 1 Security Plan
;83-03 January 25 Failure to perform T.S. V 2(1)"
FeDruary 2I chemistry samples l Failure to assure that 10CFR50 V 1
' training certification App. B forms were completed prior to watch assignment Failure to properly T.S. V 1(5)"
i control high pressure gas cylincers T: .. -_: :: :, ~ ~ L- L~
~
. . . . . _ . . ~ - - - _.
..i i
\
1 42 TABLE 4 (Continued)
! S p ary I Inspection Inspection Require-A No. Date Subject ments Severity Area 1
83-07 March 22- Failure to imple- T.S. V 2(3)* -, April 18 ment a station pro-cedure for inspection
; at.d cleaning of the SBGT System inlet
; plenum 83-08 May 9 - Failure to conduct T.S. V 2 .'
May 13 an audit of the Radiological Environ-mental Monitoring Program report when required 83-09 April 4 - Accepting, in receipt 10CFR50 V 1
,1;! May 3 inspection, material App. B not in conformance g with the F.O. Require-j ments 1
J Failure to maintain 10CFR50 IV 1 1 the G-List App.B d
~ j (2) Failure to upcate the 10CFR50.71(e) V 1 l FSAR l
1 Failure to perform IEB 79-09 0 3 preventive mainten- Commitment ance as committed to ths NRC 83-10 April 19 - Safeguards infomation 10CFR73.21 IV 7
. .; May 23 not properly centro 11ed Security access card IV Sacurity 7 key not properly con- Plan trolled i
1 i
, . _ + - _
. . . . a . ... .
N UNUED STATES j *[ e%
- t., NUCLEAR REGULATORY COMMISSION REGION I l- 1'! j
! ! .I $31 PARK AVENUE
#, ' if ! KING of PRu$sl A, PENNsY LVANIA 19404 g,. 4j/
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- Docket No. 50-293 Boston Edison Company M/C Nuclear ATTN:
Mr. William O. Harrington Senior Vice President, Nuclear 800 Boylston Street
} Boston, Massachusetts 02199 l
xi j Gentlemen:
Subject:
Systematic Assessment of Licensee Performance (SALP) This letter and its enclosures document NRC's asse The enclosed SALP Report, dated August 12, 1982, i 1,1981, to June 30, 1982. includes performance assessments for each of the nine func were evaluated. staff by Mr. R. W. Starostecki of this office on September 1, 1982, at the Boston Edison Company offices in Braintroe, MA. ( Our overall assessment of the performance There now appears toof be NRC l personnel changes which took place earlier this year. j
.g a satisfactory level of management attention and involve etatte rs .
!Y We recognize that efforts are underway to improve the These management changes safety.
i systems and utilization of resources at the Pilgrim facility. i and plans are documented in the Performance Improvement Although Plan whic r;ttted to the NRC on July 30, 1982. j several months before some of trese impr::verrents will be completed.s performance has improved recently, In particular, we believe additional have included them in this report. attention is warranted on your part in the areas of day-to-day plant opera-We will i, tions and fire protection /preventiin activities. attention to these are
] corrected.
i in the meeting of September 1,1982, the NRC staf f benefited f rom your comm j i y concerning the SALP Program and the functional area 20, 1982 andperformance have included assessnents. 1 have also reviewed your letter of SeptemoerThe SALP Board also considered l responses to your comments in this package. The results of these a l your concerns and I had the benefit of their input. considerations are presented below. 4
. _"- -.- *"Mh+
. j. ,
l __
,i -
Y I ~ _ TABLE 5 l VIOLATIONS (9/1/81 - 6/20/82) PILGRIM NUCLEAR POWER STATION l ., A. msber and Severity level of Violations
, _ [. a.
InteHe NRC Policy Se erity Level (September 1,1981 - March 9,1982) SeveHty Level I O l Severity Level II O t l Severity Level III 6 Severity Level IV 5 SeveHty Level V 17 Sevedty Level VI 2 Deviation 1
- b. MRC Policy 3everity Levels (March 10, 1982 - June 30, 1982*) .
SeveHty level I 0 g Severity Level II o seveHty Level III 1 Severity tant gy 4
' "Ferity Leye; y 3 j
i bittion j
!! inal yt'I4ti:^t 38 Total Deviations 2 DFunctional Area 1
P 1.1981 - March 9,1982
'I a
.'~l W 3U Severity 1.evels I II III IV V VI OEV 0 0 3 3 5 0 0 is 0 0 1 1 3 0 1 4 s , 0 0 0 0 2 0 0
; 5. Fire P 0 0 0 1 1 1 0
sC W J 7. ll lll l.
- 8. Refuelin%o %
0 0 1 0 0 0 0 9 Licentino A 0 0 0 0 1 0 0 o 0 0 0 0
. 1 0
, z i
l
. . . . . . - l 4
TABLE 5 (Continued)
; 8. Violations Vs. Functional Area
-l (2) March 10, 1982 - June 30, 1982*
l 1
- Severity Levels I
..i FUNCTIONAL AREAS I II III IV V OEV c .).
.i 1. Plant Operations 0 0 0 1 1 1
- 2. Radiolecical controls
- 0 0 0 1 0 0
- 3. Maintenance 0 0 0 1 0 0
- 4. Surveillance 0 0 0 0 2 0 l 5. Fire Protection
- 0 0 0 0 0 0
- 6. Emergency Preparedness 0 0 0 0 0 0 l
- 7. Security & Safeguards 0 0 1 0 0 0 0 0 0 1 0 0 l 8. "Refiebn'a ~~
l 9. Licensing Activities 0 O_ _ 0 1 0 0 t
- Totals 0 0 1 4 3 1 f Total Vioistions = 38 Total Deviations = 2
-
- Oces not include the following reports, not yet issued:
j 82 Resident Inspector
, 82 Special Health Physics i
i 1 36 l 4 \
- i. .
1.., \ .
'{
'l
)
TABLE 5 (Continued)_ C. Sumary Inspection Inspection Area
.{ Subject Rea. Sev.
, i No. Date June 15 - Failure to have an operable 10 CFR III 1 (9)* 81-18 50.44 Sept. 30 combustible gas control system
- (multiple examples of design j errors, procedural and drawing errors.)andinadequatesafety j reviews 81-18 June 15 - Failure to infonn the NRC of T.S. III 1 (9)*
Sept. 30 the erroneous statement that an installed system met the require-ments of 10 CFR 50.44 - Material False Statement 81-19 August 18 - Failure to follow station pro. T.S. V 1 Sept. 30 cadure ( Failure to perfonn a safety 10 CFR IV 1 i 81-19 Atsust 18 - 50.59 Sept. 30 evaluation prior to disabling i protection for an RHR pump 81-21 August 31 - Failure to post a high radia- T.S. IV 2
. Oct. 2 tion area j 81 21 August 31 - Failure to adhere to radiation T.S. Y 2 Oct. 2 protection procedures for
' radiation work pennits.
81-21 August 31 - Failure to post copies of NOV's 10 CFR V 2 oct. 2 involving radiation protection 19 j
'i 81-22 Sept. 16 - RCIC containment isolation valves T.S. III 1 i Sept.17 were left open when their control
' instrumentation was inoperable 8b24 Dec.1.1981- Operation at drywell temperatures 10 CFR IV 1 Jan.18,1982 above FSAR description without 50.59 adequate safety evaluations 81-24 cec.1.1981- Failure to adequately prepare and T.S. Y 1(4)
- In. 18, 1982 implement procedures for coping with high drywell tarperatures
/
l 37 L ._.. _ _ _ _ .._ ___ _ - _
c ,f -, . ~ l \ i i Xl x 1 TABLE 5 (Continued) C. Sunsnary Inspection Inspection
., No. \
Oate ! Subject 81-24 ! Dec. 1, 1981- Reo. Sev.
/; A r.a_!
2 Jan. 18, 1982 Failure to prengtly evaluate and 10 CFR V correct conditions adverse to quality 50 App B 1 i 81-24 Dec. 1, 1981-7 2 Jan. 18, 1982
. Security perly access card keys not pro-controlled SecuHty III 7 81-24 Dec. 1, 1981- Plan Jan. 18, 1982 Cembustibles were not renoved from area near het work T.S. Y 5 81-24 Dec. 1, 1981-Jan. 18, 1982 Improper equipment tagging T.S.
81-25 V 1(3) Oct. 15 - Oct. 18, 1981 Failure to have all CRC members 1 i present at a pre-refueling meeting T.S. Y 8 k 81-26 July 20, 1981
?
Transported radioactive materials i with liquid in dmms 10 CFR j 81-35 Nov. 1 - 30.41 III 2 i Nov. 30 Control / Storage of combustible gas cylinders was not in acc.ord- T.S. Y 5 ance with station procedures 81-35 Nov. 1 - Nov. 30 Failure to establish and imple~ ment procedures for t T.S. V 5
' of combustible scrap,he control wasta, debris 81-35 Nov. 1 -
i Nov. 30 Failure to estabitsh and imple-T.S.
; , ment procedures for the control V 5 of combustible oil
!' 81-35 Nov. 1 -
Nov. 30 Control of foreign mateM al during repairs to MSIV's was not T.S. Y 3 in accordance with procedure 81-36 Nov. 30, 1981-Dec. 4, 1981 A master surveillance schedule wasT.S. VI not established 4 81-36 Nov. 30, 1981-Dec. 4, 1981 T.S. Amendments were not properly entered into controlled volumes T.S. VI 9(1) h 38 ea
, -" " ' ^ ^
- ,,,-,,,-,,,-,----------,--,----w----,------e,--- - - - - - - - -----,---w
! j l
i I i l TABLE 5 (Continued) l C. Sumary :
$ Inspection Inspection
.. No. Date Subject Rec. Sev. Area _ l J
.: 81-36 Nov. 30, 1981- Program and procedures were not 10 CFR y 3 (5) *
. . Mi Dec. 4,1981 established for housekeeping and 50 App B J system cleaning that meet the QAM f standards stated in the'QA Manual 82-01 Jan. 18, 1982- Workers were not properly in- 10 CFR Y 2 Feb. 28, 1982 structed of the storage and 19.12 transfer of radioactive resins 82-01 Jan. 18, 1982- Procedures were not adequately T.S. V 5 Feb. 28, 1982 established and implemented to provide required numbers of SCBA units for fighting fires t
82-02 Jan. 1 - Uncalibrated brush recorders 10 CFR V 4 j Jan. 15, 1982 were used during RPS surveillance 50 App B
; 82-02 Jan. 1 - Maintenance activities were per- T.S. IV 3 Jan. 15, 1982 formed without using approved procedures j 82-02 Jan. 1 - Instrumentation was not calibrated T.S. V 4 l Jan. 15, 1982 at frequency specified in station procedures
) i 82-02 Jan. 1 - Improper control of access to Security III 7 Jan. 15, 1982 Vital Areas Plan 82-04 Jan. 25 - Failure to frplement procedures T.S. V 4 (1)
- l Jan. 29, 1982 for LLRT and drawing change i revisions 82-04 Jan. 25 - Drawings and procedures did not 10 CFR IV ' 1 Jan. 29,1982 identify the as-built condition 50 App B l of valves in piping systems l ,
82-05 Feb. 1 - Untimely corrective action to 10 CFR V 1 Feb. 5,1982 internal QA Audit Deficiency 50 App B Reports 82-06 Feb. 10 - Training and requal, program for Comitt:nent DEY 2 i Feb. 12, 1982 personnel who operate and process IES 79-19
~
radioactive waste not implemented ! as connitted l 39 l _ _ = = _ .
, , . . . . . , . . . . . , - ....e. - . . .~ . . . . . . ~
\
\, /,,,,
- s. .
~j -
- i J g 1
* \\, ,
\
t e,,,.c TABLE 5 (Continued) i C. Sunnary
-i Inspection Inspection
] No. Date Subject Rec. Sev. Area I
J N/A Feb. 12, 1982 Prompt Notification System 10 CFR III 6 (sirens) not installed by 50.54 February 1, 1982
! 82-10 March 1 -
; April 4,1982 Performed maintenance on valve with T.S. V 1 (3)
- red tag attached 82-10 March 1 - Plant shielding study mod.'
April 4,1982 (truck lock door panel) not NUREG 0737 DEV 6 completed as stated in response to NRR 82-11 Feb. 25 - An unauthorized adjust:nent was 10 CFR IV Feb. 28, 1982 made to a leaking flange during 4 50 App J {' the conduct of the PCM?T I 82-12 April 5 - May 9, 1982 Failure to fo11cw actions re- T.S. IV 1 quired by T.S. with inoperable
! reactor vessel water level instnant.ntation
}
- 82-13 April 12 -
- Inadequate design control, for 10 CFR IV April 16, 1982 interfaces and verification 9 (5)
- l 50 App B i ; 82-16 May 10 -
June 13, 1982 Failure to lock or control access T.S. IV 2 l t to a high radiation area (stuck l TIP drive) e i ( )* secondary area involved t 6 40 T _ E' _ _ . .l--
- ~
7_ c;
.:_. w._ ,_- . - - - - - - - - __ - - 1
,t t
I t 1 Testimony Submitted by i Stephen J. Sweeney
! President and Chief Executive Officer i
Boston Edtson Ccmpany to the U.S. House of Representatives tubcommittee on Energy Conservation and Power of the Committee on Energy and Commerce July 16, 1986 vn k ' -- % f' [ . w L. : . l ,,,' ,. / 3 t k i 1 , i
. , 1__ _ _ _ _ _ _ _ _ _ - ,l 9
1
.,- INTRODUCTION .i Boston Edison Company appreciates the opportunity to address a number of issues involving the Pilgrim Nuclear Power Station which are of 8
concern to this committee, the Nuclear Regulatory Commission and to me i personally. At the outset let me stress that most of the issues raised by f the NRC in various reports and by this committee were of concern to me more than a year ago and that corrective actions were underway as early as l j September 1985. As discussed in the following pages, those actions are meeting with success. In today's environment, public concern about nuclear power is heightened substantially. Dublic confidence in the technology and the institutions involved with it is at a low point. i Boston Edison Company has a great deal of work to do in this j environment to gain public confidence in our ability to manage and run Pilgrim Station. I personally will not be satisfied until we have achieved a level of public and regulatory confidence that allows Pilgrim Station to j place among the best. We have made an internal commitment to measure i i curselves against the best, which is a significant change in how we are
! approaching our current problems, l
As will be evident in reviewing our testimony, we were historically
'l
! plagued by not looking outside to measure our success and to undertake the Intensive self-criticism necessary to assess performance honestly and objectively. That has changed. We are moving in a new direction, one based
,,1 rising standards of excellence which are set, not by regulation, but by the performance of those plants judged to be among the best.
m
_. - .~z'-
,: E i
It should be noted that the concerns we are addressing today are different from those for which we were fined in 1982. The issues then were safety-related and failure to comply with regulations. Today, the issues are not directly related either to compliance or to safety. They instead involve a rising standard of performance going far beyond mere compliance with rules to a much broader dimension in the regulatory process. That new dimension is one that dictates comparisons and success is measured by
! relative performance. We endorse it.
Before discussing our current activities, let me offer perspectives on three time frames. The first time frame is 1972 to 1979 and Three Mlle Island. major management shortcoming then was the failure to recognize fully that
/
the operational and managerial demands placed on a nuclear power plant are very different from those of a conventional fossil-fired power plant. Boston Edison structured its nuclear organization as part of a traditional l coerating arm. While many members of the Pilgrim Station organization
! recognized the differences in the technologies, they had limited success in
- arguing for the resources necessary to meet a set of standards that already
.] were rising fairly rapidly. This was also a period of poor quality fuel
; .htch resulted in significant 1 -ternal radiological problems that affected the plant for years.
Then came Three Mlle Island. From March 1979 until early 1982 the same structure, under one vice president, attempted to deal with the l cost-THI demands on operations and engineering, while at the same time
- ursuing a construction permit for a sec0nd unit at Pilgrim Station. The staff increased dramatically to 200, 300 and then 400 people. It was an unreasonable workload for the structure and we paid a costly penalty for not recognizing it -- 5550,000 in early 1982.
~~
s ii 3.j bi I From 1982 until mid-1985, we operated with a new and improved management structure that recognized the unique nature of nuclear power l plants and the demands of the post-THI period. We committed the financial i.
! and human resources necessary to upgrade equipment and hardware and to
.I
,] install various improvement programs to meet NRC concerns. More than
.' $300 million went into hardware improvements, the staff grew from 400 to nearly 600 people and the organization was restructured under a senior vice 3 president and two vice presidents. We achieved a significant measure of i success for which we were recognized by the NRC and in the plant's outstanding operating performance in both 1983 and 1985. But in managing the equipment improvements and the new management i systems and programs we put in place, we didn't focus enough on what was I i going on outside the company in the industry and within the NRC. What we didn't see because we were so internally focused was the fact that the
, industry itself and the NRC were looking under, behind and around all of the hardware and management programs reaching for excellence.
In our case, not seeing that put us in a defensive posture. He j weren't identifying weaknesses that were inhibiting continued imorovement l ourselves. We weren't being self-critical, others had to tell us what was i wrong. He weren't holding managers accountable enough for the end result of 1
' an action or inaction. He weren' t working well enough together.
l Those problems were very real, very serious and of great concern to
, me and to the Board of 01 rectors. I became particularly concerned about management performance, not management systems and programs, but the results I
of those systems and programs as measured by effectiveness. In mid-1985, I 18' asked the Vice President of Nuclear Operations to investigate my concerns, which he shared, and issue a report. As he progressed through the study, he i i
.: 4 j !
1 and other managers began identifying needs. In September 1985, we increased tne operator staff by a third. In December, we reorganized plant management to improve reporting relationships and build in greater accountability. In February 1986, the NRC issued their report. They said the same
'! thing: We had attitude problems that were seriously interfering with our ability to get the results we should be seeing given our financial and human resource commitments.
By March, we had taken a number of other actions, all of which are
, detailed in the following pages. We began eliminating those old attitudes that were not serving us well and began to inject the nuclear organization alth the skills and perspectives necessary to achieve a measure of cerformance which would place us among the best. In the same time frame we l made further human resource commitments. We increased our emergency J
l planning complement five-fold, we increased the number of radiological i techniciar,s 35 percent and we implemented an apprentice program for the
'l long-term development of skilled personnel.
l I The shutdown on April 12 gave us an opportunity to accelerate that change. A different approach to problem solving was taken. It stressed a more deliberative and integrated effort at identifying root causes and I taking corrective action. In early Hay, a new plant manager and a new i s.
- cerations section head were brought on board, nearly rounding out a new 16 l ;
Tecer plant management team. Of the 16, 11 were new in their positions in . the cast a months and 5 were new to the company. We have new perspectives.
; We have people with strong nuclear navy backgrounds, people with NRC ins ection experience and people who grew up professionally not in l
ccnventional fossil-fired power plants, but in nuclear plants. l .
1 . ! i On May 27, having accepted that management is just as important as equipment, we took the unprecedented step of giving the ner plant manager and his new team additional time, while the unit was shet d)wn, to beccme famillar with the issues, to accelerate the development of ciew programs and, f most importantly, to infuse the organization with attitucas and behavior that will make those programs work. These are attitudes tit demand
] self-criticism, demand accountability, demand teamwork and Jemand results which go far beyond mere compilance with a set of rules, regulations and i
technical specifications. Excellence is our gcal. But excellence is, after all, an attitude I wnich accepts nothing less. Achieving excellence will not be easy; we klow that. We know our problems. de have made the human resource and financial commitment to solve them. We know what has to be done and we are doing it.
; As a result, I am confident we will, in time, demonstrate to you, to the
; Nuclear Regulatory Commission and the public that we have responded I i l effectively to the concerns which are shared by all of us.
] As a final point, I know that an important question on the minds of i
l j ! many people is "ahy should Bosten Edison be believed today given the l l problems over the years at Pilgrim Station?" I hope I already answered that question in part. It is perhaps the most difficult question and can only be answered fully by performance over i
! time. But in closing I would underscore two major differences t0 day frem the past. The first is our forceful acceptance of the need for us to measure our performance against an ever increasing set of standards set by those plants judged by industry and the NRC to be among the best.
* . \ ;._ ,,._w .
3 l. The second is the fact that we have adopted the basic principles and criteria for good management that are applied to the nucle n lavy. They are the same principles and criteria that are in evide.1ce at a'l of the top
' rated plants.
i
' This is a demanding industry witn a vital role in the social and .l It operates in a demanding regulatory economic health of the country. ~
climate as evidenced by this hearing today. For us as a company with a single unit to succeed in this environment means that we must impose on
; ourselves the highest standards of performance found in the industry. He i
i are doing just that.
$ The balance of this filed testimony is arranged in the ceder of the six sections on which you requested information in your letter of July 2, 1986. We have repeated your request at tht: beginning of each section.
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- A f81Dh G 8ird July 3, 1987 u v . :e du :e- ..: ev
' SECo L:r. 87 l i
l Mr. Steven A. Varga, Cirect:r
~
l Olvisten e,f Reactor orejec:s, I/II
-I Unitec S:ates Nuclear Regula:ory C mmissien l Wasning::n, O. C. 20555
]
License CPR-35 Occket 50-293 4 c3 INFCRMATION REGARDING PIIGRIM STATION S AFETY ENHANCEMENT PRCGRAM
Reference:
NRC Letter 3recosed Enhancement to the Mark I Containment - Pilgrim S:a:!cn, dated Acril 30, 1987 Cear Mr. Varga:
.j As agreed during July 1, 1987 discussiens te: ween Frank Hiraglia, USNRC, j and Jonn Futten, Sosten Ecison Company (SECo), ae are submitting :nis res:ense
.'i to your letter to SEco cate: Acril 30, 1987. Enclosed for your information is
! a detailec :escrietten of tne Safety Ennancemen: 3regram (SEP) harcware j :hanges tn. 5EC: nas voluntarily elected to imolement for Pilgrim Nuclear
- Power Statten (PNPS). The cescriptien of procecural changes and personnel j training will be furnished under sacarate cover. A current imely.nenta: ten senecule fer :ne SEP mcdif! cations will also be furnished secarately. A i
c:nditicn is tnat tne modifications scheduled during the current cutage ce not require orter ;cvernmental accroval. Shculd :nts c:nciticn not te me: for any of tnese voluntary eccifica:icns, wl:n the resul: :nat fle current imolementation s:nedule mus be extenced, :nen SECo will be unable to implemen: :ne affected mccifications curing tne current cutage. f' Adcitional dccumentat i on will be availaole f:r review cy the NRC Staff a: SEco's Braintree officat er ne PNPS site. C:gni: ant SECo cersonnel *ll' :e availaole at tnose loca:i:ns for discussicn wl:n :ne Staff. 1 Carrent evaluatt:ns of :9e enefit frem the SE? modifica: tens are casea i primarily ucon ex:ensive, al:nougn s:lli creliminary, analyses and cualita:'ve engineering jac;ments. Final cuanti:ative analysis must, in accercance i wl:n :ne s:stec long :erm ;:al of the SEP, awal: final identificatten Of 1 modificatiens anc :: mole:icn of the Indivicual Plant Evaluation (IPE). SECo understancs :na: :ne NRC Intends to issue later this year a generic le::er re:utring all plan:s :o crform an IPE as par: Of :ne 9
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ecuiremen: !s issue:. 5EC: ei:ec:s c ::.toli:t :Pe *2E ano : rem:::y raKa : 4 resu;:s avaliacia in 1:::r:anca ni:n :.9e avia. :r:cits pres:rt:ac cy :ne i genert let:er. i please feel free :: c0ntact me er I: ar: Howars, :/ my s:aff at (617)
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- 8
{ inclosures cc: Nuclear Regulat:ry Cennission l Occument Control Oesk Washing::n, D. C. 20555 1 Nuclear Regulatory Cennission i Region I
'. 631 Park Avenue l King of Prussia, PA 19406
! Senior NRC Resident Inscector
] Dilgrim Nuclear Power Station i
Mr. R. H. Wessman, Project Manager Oivision of Reactor Projects, I/II
- 1 Q] Office of Nuclear React:r Regulation U.S. Nuclear Regulatory Ccemission 7920 Nondolk Avenue Bethesda, MD 20814 l
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$sYommonweafb(o bzMacluael/Ai Mop-c/masyy ~Lsy asweu lllyf h]odan da uardeae/4 C2/CS (si7) 727 777s ~; EXECUTIVE
SUMMARY
OF THE PROGRESS REPORT ON EMERGENLY PREPAREDNESS FOR AN l
! ACCIDENT AT PILGRIM NUCLEAR POWER STATION I
j I. EXECUTIVE
SUMMARY
On December 16, 1986, I transmitted to the Governor a comprehensive report on safety at Pilgrim Nuclear Power Station. This is a progress report about the activities by state and local government, the Boston Edison Company, the U.S. Nuclear Regulatory Commission and the Federal Emergency Management Agency since that time to address the concerns we found. In April of 1986, operation of Pilgrim Station was j halted because of several mechanical problems. The U.S.
.j Nuclear Regulatory Commission has ordered that the Boston Edison Comiany keep the plant shut until a variety of
}
corrections regarding the management and operation of Pilgrim Station have been made. As of this date, Pilgrim remains closed, although Boston Edison has asked the NRC for
- permission to restart the facility.
In my December, 1986 report, I concluded that Radiological Emergency Response Plans for the Pilgrim facility were not adequate to protect the public health and l
- safety. I further identified serious problems regarding the j management of the power plant and the engineering safety of
; the reactor. In my view, these three issues -- emergency
! planning, plant management, and reactor safety -- were so I serious and the weaknesses and deficiencies so severe that i recommende.d that the plant should not be allowed to restart unless and until these concerns had been satisfactorily addressed.
I There has been a considerable amount of activity at all levels to address these concerns since my report wasIn issued. l In some cases substantial progress has been made. particular, the Massachusetts Civil Defense Agency and Office of Emergency Preparedness has devoted all available staff and l resources to the effort of developing the best possible I emergency response plans. t f , 1
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MCDA/OEP has instituted a planning process at the state and local level and revisions are well under way. In addition, a new system has been installed for off-site notification in the event of an accident at Pilgrim Station. We now have the advantage of a new Nuclear Safety Emergency j Preparedness Program and a professional staff which for the d first time is dedicated to off-site emergency preparedness
.O and planning. This new program and staff are the result of
, ". the Governor's initiative in the Fiscal Year 1988 budget.
'!j The Governor has requested additional funds for the new program as a sapplementary appropriation for the current
.,l fiscal year.
4} .Nonetheless, I continue to make the finding that
< adequate plans for response to an accident at Pilgrim Station do not exist, and I reaffirm my earlier position that the Pilgrim facility should not be allowed to restart until such q plans have been fully developed and have been demonstrated to
, be workable and effective through a graded exercise of all
, plans and facilities.
'1 This finding is based on the fact that in every critical area in which I found a deficiency to exist in my December,
.,i 1986 report substantial work remains to be done before a
- s. !
determination of adequacy can be made. For example, analysis j of a new Evacuation Time Estimate and Traffic Management Study by state and local authorities is still underway. The
' ETE is one of the most critical pieces of information in the j entire process and the foundation of effective emergency J planning. Our preliminary review of the ETE suggests that more resources are required to successfully implement the ll traffic management plan. The shelter survey which was 4 prepared by Boston Edison has been returned to the company for further study because is was found to be woefully
.J] ,
inadequate.
~.s Plans and implementing procedures for special needs i populations remain incomplete, and it may be necessary to undertake an additional survey of people who would need c
assistance in emergency response or to do further statistical analysis of this matter. The development of implementing procedures and the identification of resources to care for
.j school age populations also requires additional work. 7n regard to the adequacy of reception centers, the quest'en of need for a facility to serve people in the northern r ton :
l of the EPZ remains open. We cannot make decisions on .ne need for or identification of a third reception cente until Boston Edison has provided us with an analysis of tha adequacy of the existing two reception facilities. i, n
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With regard to plant management, we have seen numerous
- changes in Boston Edison's personnel and organization forThe most notab management of pilgrim Station. Bird as Senior Vice the appointment of Mr. Ralph G. Nuclear, who directly reports to the company's President,
., Yet despite these changes, I cannot j chief executive officer.the management problems have been fully O say at this time thatFor example, we are concerned about recent
' *] resolved.
incidents including violation of NRC regulations in the area 1
"I of plant security, and allegations of excessive overtimeWe are also conce
! worked by utility employees.
'_ Edison's action to refuel Pilgrim Station without having
]-
responded to my objections and the objections of several state legislators. l The Systematic Assessment of Licensee performance (SALP) i perfomed by the NRC is the most comprehensive study and The last report on nuclear management at Pf' grim Station.1987 and it showed
- l SALP report was issued on April 8, since l
-l deterioration the last report.
in several aspects of nuclear managementUntil a simil
.; management under the new organization has been conducted andsa bl.e above concerns resolved, I cannot
"' concerns have been addressed.
With regard to reactor safety issues, we have carefully (SEP). reviewed Boston Edison's "Safety Enhancement Program"
} The SEP has been undertaken since the issuance of safety at Mark I containment structures such as the Pilgrim containment.
We have two major concerns in the area of reactor safety. that the NRC letter was prompted First, despite the factthere was a high probability of Mark I by a finding thatfailure during certain severe accident scenarios, containment the NRC has yet to adopt an official position regardingMoreover, safety enhancement. i l Administrator William Russell, with whom my staff and other l ] state officials met at NRC's regional offices in King of1987, enhanceme l i i Prussia, Pennsylvania on October 8, an issue that the NRC Mark I containment at Pilgrim is notbe finally resolved before restart. l l believes must
! Our second concern is the uncertainty that continues to one feature of the Boston Edison SEP, exist about at least the direct torus vent. No concensus has been reached on
)
j whether installation of the torus vent creates unreviewed
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'3 safety issues or if the torus vent is authorized, how it will be used in the event of a severe nuclear accident.
The findings of my December, 1986 report have been 1 strengthened by two other analyses of safety at Pilgrim Station. The Special Joint Legislative Commission to Study
.jj l Pilgrim Station has issued its report which further In studies addition, and documents many of the same safety concerns.
7] the Federal Emergency Management Agency has issued a Self-Initiated Review of plans for response to an accident at Pilgrim Station. Based on several of the issues raised in my
]i report FhMA has changed its interim finding and now agrees 7
that the off-site plans for an accident at Pilgrim are not adequate. FEMA has transmitted their new finding to the Nuclear
~, Regulatory Commission. However, the NRC has yet to indicate whether or not development of adequate off-site plans will be a condition to the restart of Pilgrim. We are not satisfied i
with the view recently expressed by the NRC Region I staff that emergency planning problems must be "addressed" before restart. Such problems must be satisfactorily resolved before restart. Off-site response plans are just as
.,a important as nuclear management and reactor safety in protecting the public from an accidental release of radiation.
i Therefore, for these reasons -- the absence of adequate l , emergency response plans, lack of demonstrable assurance that management problems have been solved, and uncertainty about the safety of the Mark I containment structure -- I continue to find that Boston Edison has not met the heavy burden of j showing readiness to restart the Pilgrim Nuclear Power Plant. I also continue to believe that it remains to be seen 1 if adequate emergency response plans can be developed and if
'd d
all other safety issues can be resolved to our satisfaction. Finally, I recommend that in light of the number of
-, outstanding issues and their complexity, and Boston Edison's l
evident determination to press ahead with the eifort to restart, that there should be a full scale public hearing by of the NRC before any decision is made regarding the restart
Pilgrim Station.
i I : october 14, 1987 CHARLES V. BARRY j SECRETARY OF PUBLIC SAFETY s I t 1051J
.~~....-........~.-....u.... *
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.1h*b THE COMMONWEALTH OF MASSACHUSETTS
~
EXECUTIVE DEPARTMENT .h, 4 cm.oerews: Actacy Axo orres or cuaauwer cautaronau i h.. /.)
, a weacuran nomo -
4 i
- k . p.o. een i e FRAW6NOMAM, WA&& 017014317 MICHAEL s. DUKAKis Ro8ERT J. BoULAY coVEANOR ,
olRECTCA September 18, 1987 i _ j'
! Mr. Ralph Bird
' Senior Vice President
'l
-{ Boston Edison Company j 800 Boylston Street
," Boston, Massachusetts
Dear Mr. Bird:
My staff has reviewed the August, 1987 "Study to Identify Potential Shelters in EPZ Coastal Region of the Pilorim Nuclear l Power Station," which was prepared for you by Stone and Webster. We find that this study is deficient in several resoects and that additional work is required to provide information to local officials which is sufficient to' support development of implementable shelter utilization plans. I have attached a copy of a memorandum prepared by my staff which details our specific concerns regarding this study. If you have any questions or. observations reaarding our j evaluation, please contact Buzz Hausner of.my staff. l Thank you for your cooperation in this matter. Sin obert ulay % C l Director - i cc: Assistant Secretary, Peter W. Agens, Jr. Deputy Director, John L. Lovering Mr. Buzz Hausner l l l l i
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, THE COMMONWEALTH OF MASSACHUSETTS A@88t -
.[ EXECUTIVE DEPARTMENT , , . .[%
F Crv1L Of PtNS4 ActNCY ANO Cf rict or tutRotNCY PREPAREDNE$s f, j 1 co wometsitR RoAs / { ' Q), P.O. SCI teos S - '
}'h F RAurNOHAM. W ASE $1701431F f
'HAEL s. DUKAKis ROBERT J. BoULAY OOvtRNOR OtREC1CR TO: DIRECTOR BOULAY
,FROM: BUZ USNER
'{'INRE:
" SHELTER SURVEY OF PILGRIM EPZ PREPARED BY 00STON EDISON COMPANY j DATE: SEPTEMBER 11, 1987 ,
s I
-q _:.__ ___ ________ . ___ _______________________________________
We have made a preliminary review of the shelter survey of the Pilgrim EPZ which was prepared by the Boston Edison Company and
. Its consultants. While this document compiles some very useful data, we feel that more work must be done to estimate the effectiveness of shelter as a protective action.
Our principal concern is that we must be able to put data in the i hands of local officials.which are sufficient for the development i of shelter utilization plans for all areas of all five , 'l communities within the Pilgrim EPZ. With this in mind, we have i
! the following comments.
1 i
- The survey only covers an area approximately one mile
! .I wide along the coast. The shelter capabilities of the 4 entire EPZ must be surveyed and reported.
.j
- The survey does not separate out those structures which could "most reasonably" be used as shelters from those where shelter is less appropriate.
3 For instance, it would help to have a separate list or
, public buildings and facilities for each town,
)
j
, including an estimation of the actual useable shelter space and protective factors for shelter under government authority.
4
- Many of the shelters listed, such as jewelry stores and pharmacies are. clearly not suitable for public shelter. In a severe emergency, every available resource will of course be put to use. However, to develop an implementable shelter utilization plan, local officials must be able to match estimated needs with the most appropriate resources available,.
G
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- j. Director Boula - -
Page 2 , Regarding protection of the beach oooulation, the survey identifies shelters within.a mile of the coast but does not indicate the distances that beach goers would have to travel to find shelter. In addition, the survey must demonstrate that adequate proximate shelter is available for the total population at' the individual
.. beaches.
For instance, Ouxbury beach is about seven miles lona 2 and the survey should indicate the distance peonle at Saquish Head are required to travel to reach adequate shelter. Further, an implementable shelter utilization plan must demonstrate that the nearest shelter would not be full to capacity before the people at the most remote"points of the beaches arrived.
- The survey must identify' adequate shelter which is handicapped accessible.
The survey does not distinguish between available space i and usable space. For instance, residents of Plymouth have indicated to us that some basements listed in the
; survey are no more than crawl spaces. Crawl spaces
.i cannot be considered for public shelter. Further, in j most buildings, a good deal of floor area will be
" occupied by machinery, counters, of fice furniture, et cetera. The survey must identify accurately the actual useable shelter space available in each structure.
l i i - Stone and Webster uses'a FEMA nuclear attack value of l i ten square feet per person to estimate the potential , l population.which can be sheltered. Local' Civil Defense Officials may wish to allocate more space -- uo to ! ; twenty square feet per person -- in their utilization l ; plans. The value used in the survey overestimates the 1 potential capacity of various buildings. We doubt.that
.1 17,000 people can be sheltered at Duxbury High School,
] or that 89,700 can be sheltered at the 5 Cordage Park j
Buildings. . The survey must demonstrate that public shelters are
! free from asbestos and other environmental hazards.
The report estimates residential "sheltering capability" in individual communities as between 53% and 81%. These figures indicate that a significant number of residents do not have adequate domestic shelter and emphasize the need for a full study of public shelter capacities throughout the entire EPZ. l -
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i,' Director Boulay
, Page 3 l Further, even if it can be established that the vast I majority of residences offer adeouate shelter, local i officials must be prepared to offer public shelter of a known protective capability to residents who demand assistance. ,
- This report makes no definitive statement of what 1; -
constitutes adequate shelter to protect pecole from the - 3 effects of a radioloolcal release from Pilorim i Station. This is necessary to determine what
^
facilities are most appropriate for a local shelter utilization plan and to determine the public shelter j , needs of each community. In summary, we would say that this survey is a useful beginning but that much more work is required before we can assess our ability to develop implementable shelter utilization plans consistent with the public safety concerns in Secretary Barry's
; report to the Governor.
.! cc: Assistant Secretary Peter W. Agnes, Jr. -
l Deputy Director John L. Lovering J
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<a Executhe Offices 800 Boylston street Boston, Massachusetts 02199 i i
! Ralph G. Bird September 17, I987
.. senior vice President - Nuc! ear BECo Ltr. #87 146
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U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Docket 50-293
' i, License No. OPR-35 1
Subject:
Boston Edison Company Request for Exemption from 10 CFR Part 50, Appendix E Section IV.F.
Dear Sir:
f j In accordance with 10 CFR section 50.12(a), Boston I the requirements of 10 CFR Part 50, Appendix E, Section IV.F., that would
# authorize the next biennial full participation emergency preparedness exer for the Pilgrim Nuclear Power Station (Pilgrim) to be conducted in the secon quarter of 1988. The schedule for future biennial exercises will not be
; affected by this one-time exemption, but rather will continue to provide that j
such exercises will be conducted every second year (1.JL,., the following biennial exercise will be held in 1989). The proposed deferral of the full participation exercise has been discus
.J .
.; with the Commonwealth of Hassachusetts (Commonwealth) and
;i response officials.
'l proposal.
The request will not affect the onsite exercise at Pilgrim planned for December 9, 1987. 1 The requested exemption is necessary because I
! (EPZ) and the two emergency reception center communities are at presen I
' engaged in implementing numerous improvements inThese their offsite emergen preparedness programs, with the assistance of Boston Edison.
improvements include revision of the emergency plans of the local go revision of the Massachusetts Civil Defense Agency (MCDA) Area II p j as the Commonwealth's state-wide plan, the development of revised re procedures, the development and implementation of training program j officials and emergency personnel, and the upgrading of i Centers to accomplish(EOC's). these improvements, and the work is expected to conti
! the remainder of the year and early 1988.
I I i
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" Page 2 l
.i j In view of these extensive ongoing efforts, the Commonwealth and the local governments have indicated that they are not able to participate in an exercise during calendar year 1987. Moreover, it is apparent that under these circumstances, conduct of the full participation exercise will be much more effective after the ongoing improvements have been implemented. In granting onetime exemptions authorizing deferral of exercises for 1.icensed plants in
. the pa:t, the NRC has recognized that the most effective and beneficial
- l exercises are those which include the full-scale participation of State and
local governments and that it is appropriate to defer an exercise until J program revisions or facility improvements have been completed.
-1 Since the last full participation biennial exercise at Pilgrim, Boston Edison
. ,1 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 4 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 i 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 by FEMA, which was conducted on September 29, 1986. In 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.
l I This request meets a number of the special circumstances listed in Section j 50.12(a)(2) .
} First, granting the request will provide only temporary relief from the applicable regulation and the licensee has made good faith efforts to comply
.' with the regulation. Over the past year, Boston Edison has assisted Commonwealth and local authorities in a variety of ways to accomplish as many
- l For improvements as possible in their offsite emergency response programs.
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 Management Plan Update"
- (August 18, 1987) prepared by KLD Associates, Inc. and "A Study to Identify Potential Shelters in the EPZ Coastline Region of Pilgrim Nuclear Power l ; Station" (August 1987) prepared by Stone & Mebster Engineering Corporation, as -
well as information generated in surveys to identify the special needs and l transportation dependent populations within the EPZ. In addition, Boston Edison is providing assistance to the local governments in their offsite emergency program enhancement efforts in accordance with the
; Massachusetts Civil Defense Act of 1950 (Chapter 639, Section 15, Acts of 1950 i
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 s i-.c - .~ _. - , ._. - . . . . .
g_.._z....._.._.-....-... . . ~ . . . . _ . . ._ _ _. ._. .. . _ _ . . i l U. S. Nuclear Regulatory Commission Page 3 ] l
! professional planner to assist each reception center community; and four , professional planners working under the direction of HCDA in ths. 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 l currently being prepared for review by the HCDA prior to further implementation. The planners provided by Boston Edison have also begun to I prepare task-based modules for training of specific categories of emergency
~1 personnel and will be available to participate in the training programs. In
; addition, Boston Edison is executing agreements with each of the five towns
'! within the EPZ, as well as the two reception center communities, for i assistance in the renovation of their EOC's. Moreover, four of the five EPZ 1 towns and both reception center communities, 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 offsite emergency plans that are in the process of significant revision and improvement. This would necessarily involve disruption of the ongoing process of implementing 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 l 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. This flexible approach is especially appropriate in i this case, where granting the request will facilitate more prompt and
! effective implementation of improvements.
I For all these reasons, Boston Edison asks that NRC grant the requested
.1 exemption. In accordance with 10 CFR $170.12(c), a fee of one hundred and j fifty dollars ($150.00) will be electronically mailed to your offices. If you i should require any additional information in connection with this request. .i please contact either myself or Mr. Ron Varley of my staff (telephone: 617 -
9 424-3832). Ralph G. Bird
] RAL/diw I
4 i 4
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' U. S. Nuclear Regulatory Commission Page 4 cc: Dr. Thomas E. Murley, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission '
The Phillips Building , Hashington, D.C. 20555 Mr. R.H. Nessman, Project Manager Division of Reactor Projects - I/II ' Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission
; 7920 Norfolk Avenue i
Bethesda, MD 20814 Mr. Richard Krimm, Assistant Associate Director FEMA 500 C Street - Federal Plaza Washington, D.C. 20472 Mr. Edward Thomas FEMA - Region 1 J. H. 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, MA 02108
- U. S. Nuclear Regulatory Commission l
Region 1 - 631 Park Avenue King of Prussia, PA 19406 Senior NRC Resident Inspector Pilgrim Nuclear Power Station
. Rocky Hill Road Plymouth, MA 02360 .
llenty Vickers, Regional Director j FEMA - Region 1 ,
- J.H. McCormack Post Office and Court House Boston, MA 02109 1
__ _ . . . . .}}