ML20205B799
| ML20205B799 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 09/12/1988 |
| From: | Studds G HOUSE OF REP. |
| To: | Zech NRC |
| Shared Package | |
| ML20205B797 | List: |
| References | |
| NUDOCS 8810260320 | |
| Download: ML20205B799 (4) | |
Text
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, GERM E. STUDOS
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Dear Mr. :
och:
I am writing once again with regard to the reopening of the Pilgrim tiu: lear Power Plant in plymouth, Massachusetts.
1 As you know, this facility -- closed since April 1986 -- was recently inspected by an ilRC Integrated Assessment Team, in conjunction with Boston Edison's plan to request restart approval.
Upon completion of the inspection, agency of ficials indicated that they could identify no major obstacles to prevent the plant's restart.
It is my view that the resultc of the Systematic Assessment of Licensee Performance (SALP) and the current status of emergency planning do not warrant such optimism.
First, although it is true that the utility did improve its 4
i ratings in several areas, comments within the body of the SALP report raise serious questions about Boston Edison'a readiness to resume operations.
I am particularly troubled by the evaluation af the utility's response to unusual events.
The report states:
3 A review of the LERs (Licensee Event Reports) indicates a number of problems, some recurring.
In particular, loss of offsite power has been a continuing problem at Pilgrim.
In addition, Pilgrim has experienced repeti-tive events associated with inadequate procedures administrative control problems associated with failure to conduct adequate reviews prior to maintenance and required surveillances and inadequate guidance and j
cautions for technicians. (pg. 63) t The report noted that half of the events had been repeats of earlier or similar events at Pilgrim and concluded that
... the large number of events involving deficiencies in administrative controls, inadequate procedures and repeats of earlier, similar events points to the need for close monitoring of the effectiveneas of licensee management in these areas. (pg. 64)
I would argue that it points to a further need -- to keep the plant closed until the number of such unusual events is significantly reduced, l
G810260320 881013 PDR COMMS NRCC CORRESPONDENCE PDC a-
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Page Two The Honorable Lando ech, Jr.
September 12, 1988 It seems to me that of all the analyses performed, this is the most revealing -- and the most disturbing.
No a*.tter how nuch 1mprovement there has been in management, qdality assurance, surveillance or other areas, if these changes do net prevent the frequent occurrence of potentially catastrophic accidents, they are meaningless.
The bottom line is whether the Pilgrim plant is being l
Safely operated.
The SALP report demonstrates that it is not.
l Second, I would also like to express my very grave concern about another aspect of Pilgrim's readiness for restart emergency evacuation planning.
9efore raising a number of questions about this issue, I would like to briefly review the current situation.
l
- n August 1987, the Federal Emergency Manegement Agency (FEMA) concluded that "Massachusetts offsite radiological emergency planning and preparedness are inadequate to protect the public health and safety in the event of an accident at the Pilgrim Nuclear Power Station."
FEMA, state and local planne~s have been hard at work developing a new evacuation plan, but it is far from complete.
l Draft plans for the five towns in the emergency planning :one have undergone technical review by FEMA.
These are, however, just draft plans. Before FEMA can sign off on an evacuation plan for the plan'.,
I it must review l
a final reviseo Massachusetts state plan a final revised Area II plan final revised plans for the five towns, including implementing I
procedures 1stters of agreement with bus companies and schools revised public information brochures revised training modules.
Finally, FEMA will have to observe an exercise of the completed i
plan.
As you know, a full participation exercise is recuired by NRC l
regulations.
l Given these f acts, how can NRC of ficials say, as they have on several occasions, that emergency planning is nearing completion?
i l
How can : hey conclude that there is even a plan to be "corrected"?
An April 29 ajency letter to Senator Edward Kennedy included the following statement:
I
...the NRC may authorire restart with some pAanning l
issues not fully resolved.
In reaching this decision, the NRC will examine each planning deficiency and weigh I
the significance of the deficiency, the nature of any compensatory actions, and the progress being made by the l
Commonwealth, 1.ocal governments and the licensee toward I
correction of the deficiency.
1 l
l.
Page Three The Honorable Lando Iech, Jr.
September 12, 1988 The clear implication is that there is an existing evacuation plan which simply needs some fine-tuning.
The fact is that since the old plan declared inadequate by FEMA is considered inoperative by all federal, st1te and local emergency planning officials, there l
is now no plan far the evacuation of,anyone.
The draft plans that have been reviewed by FEMA are useless as they stand; they do not include the basic operating procedures on which an evacuation is based.
For example, Selectmen from the l
Town of Plymouth have approved e71y about 10 of 40 implementing procedures.
The final plan for Plymouth will not be reviewed by FEMA until all of the procedures are developed and approved.
l The deficiencies noted by FEMA are also far from being corrected.
There are as yet no arrangements for the evacuation of special needs or transportation dependent populations or students of public and private schools and daycare centers; a third reception center has not yet been designated; there are no identifiable public shelters for the beach "opulation.
Finally, I woule. like to know your views on the need for an exercise to tr.st the workability of a completed plan.
As you know, ;ppendix G of Part 50 of the NRC regulations requires a full participation exercise.
It seems incomprehensible to me that you could contempince approving restart of che plant before performing an exercise of a plan that has never been tested.
I In summary, I want to make it clear that I very much chare the i
L views of state and local officials and Plymouth area residents who l
are deeply disturbed by indications from NRC officials that Pilgrim will be allowed to restart as early as the end of Occober or November.
Imergency response planners at all levels of government have been working diligently over the past year to l
develop a workable plan.
This is a time-consuming process, l
however, and there is no conceivable way that emergency planning can be completed by chat date.
It will be several months before i
i the plans are completed and approved, and an exercise will take several more months to develop and carry out.
I believe that it would not only be highly irresponsible of '.he NRC to allow restart before FEMA gives final approval to an evacuation plan but it would be a clear violation of the intent, if not the letter, of the law.
As you know, Section 109 of P.L.96-295 provides that the NRC cannot issue a nuclear plant operating license unless an adequate emergency plan exists.
Section 50.47 of the Code of Federal Regulations sets forth the standards f or emergency response plans.
There is at this time no plan for the Pilgrim plant that meets these requirements.
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Page Four The Honorable Lando Zech, Jr.
September 12, 1988 I would very much appreciate your response to the issues I have raised and I look forward tc your reply.
With kind regards.
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Ge ry E. Studds Mr. Lando :ech, Chairman tiuclear Regulatory Commission Washington, D.C.
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