ML20205E153
| ML20205E153 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 10/14/1988 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| CON-#189-8176, REF-10CFR9.7 2.206, NUDOCS 8810270318 | |
| Download: ML20205E153 (230) | |
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- NUCLEAR REGULATORY COMMISSION i
l l l Thie: Discussion /POCSIBLE VOTE ON PILGRIM RESTART i ) Location: ONE WHITE FLINT NORTH, ROCKVILLE, MARYLAND $ l ! l l Date: FRIDAY, OCTOBER 14, 1988 1
! Pages: 1-104 l
i ! l i i I ! i i { \: 4 l l I 'l i i Ann Riley & Ascociates l Court Reporters 1625 i Street, N.W., Suite 921 l Washington, D.C. 20006 l (202) 293-3950 l ss10'70318 881014 0 ,\ F 10CFR (
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C 0 DISCLAIMER ! This is an unofficial transcript of a meeting of the United States Nuclear Regulatory Commission held en 10-14-86 in the Commission's office at One ! White Flint North, Rockville, Maryland. The meeting was open to public attendance and observation. This transcript : has not been rev'fewed, corrected or edited, and it may contain intccuracies. The transcript is intended solely for general ,. informational purposes. As provided by 10 CFR 9.103, it is not part of the formal or informal record of decision of the matters discussed. Expressions of opinion in this transcript , do not necessarily reflect final determination or beliefs. No pis 'ing or other paper may be filed with the Commission in any oceeding as the result of, or addressed to, any . 3 statement or argument contained herein, except a. the l 1 o l Commission may authorize. i a A , i i a4 B 4 l
o e 1 1 UNITED STATES OF AMERICA e 2 NUCLEAR REGULATORY COMMISSION 3 *** i 4 DISCUSSION /POSSIBLE VOTE ON PILGRIM RESTART 5 *** 6 PUBLIC MEETING 7 *** s 8 Nuclear Regulatory Commission 9 Room 1130 , 10 1717 H Street, N.W. 11 Washington, D.C. I 12 Friday, October 14, 1988 13 14 The commission met in open session, pursuant to 15 notice, at 2:00 p.m., the Honorable LANDO W. ZECH, Chairman of 16 the commission, presiding. 17 COMMISSIONERS PRESENT: 18 LANDO W. ZECH, Chairman of the Commission
. 19 THOMAS M. ROBERTS, Member of the Commission ,
t 20 KENNETH CARR, Member of the Commission l 21 KENNETH ROGERS, Member of the Commission l 22 23 24 25 l l
2 1 STAFF AND PRESENTERS SEATED AT THE COMMISSION TABLET
- 2 S. CHILX j 3 W. PARLER 4 E. KENNEDY t
5 E. MURPHY ! <6-G. STUDDS
- 1 7 S. SWEENEY 8 R. BIRD !
9 V. STELIO 10 T. MURLEY 11 W. RUSSELL 12 R. BELLAMY i 13 ! 14 15 , 16 t 17 ; 18
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20 l 21 ! l 22 1 l 23 f 24 [ 25
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l l 3 , l 1 PROCEEDINGS , 2 (2 00 p.m.) j
- 3 CHAIRMAN ZECH
- Good afternoon, ladies and gentlemen.
4 l 4 The Pilgrim Nuclear Power Station at Plymouth, 1 5 Massachusetts was shut down by the Boston Edison Company on l 6 April 12, 1986 due to a series of equipment problems. The l 7 Nuclear Regulatory Commission, NRC, Region I Office, l 8 subsequently issued a confirmatory action letter confirming ; 9 Boston Edison Company's intent to keep the plant shut down 10 until certain technical and managerial problems had been 11 corrected to NRC's satisfaction. 12 Since that time, other issues have been raised in the l t 13 course of NRC and the Federal Emergency Management Agency's, ; 14 FEMA's regulatory reviews, including emergency planning. The ! L 15
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NRC staff and the Boston Edison Company will be addressing l 16 these issues this afternoon. l 17 Numerous actions have taken place by the Boston is Edison Company to address the issues raised prior to and during (
, 19 the shutdown. Boston Edison Company and the staff have briefed l
l 20 the Commission previously on progress related.to correction of j 21 the identified deficiencies. Today we will hear from Boston l 22 Edison Company and the NRC staff concernirg the corrective l 23 actions taken and the readiness of the facility to return to j i 24 normal operations. ! 25 During the course of the shutdown, a majorit ' of the ! l
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4 1 Comainsion has visited the Pilgrim facility in order to gain 2 personal knowledge concerning the cendition of the facility, 3 the performance of its management, und the status of corrective 4 actions being taken. i 5 In addition, since the April 12, 1966 shutdown, the ,
"6 NRC staff has held or participated in 13 public meetings in the 7 Pilgrim area which providad for extensive input by local 8 officials and citizcns into the staff's considerations of the :
9 bdequacy of Bosten Edison Ccapany's corrective actions. 10 Further, the NRC has received nucerous written comments and 11 reports from citizens and elected officials from all levels of 12 government concerning the progress at Pilgrim and potential 13 restart of that facility. 14 In addition to the specific issues I have already t 15 addressed, the commission has previously asked the staff to be t 16 prepared to address the licensee's implementation of its i 17 maintenance work control program during today's meeting. ! 18 However, beforts we proceed with the Boston Edison Company the 19 NRC staff presentations, we have several additional speakers. 20 The Commission has received requests from members of 21 Congrass and the Governor's office of Massachusetts for 22 permission to address the Commission at today's meeting. The 23 Commission has agreed to hear from several members of the 24 congrossional delegation from the Commonwealth of Massachusetts 25 and the Lieutenant Governor of Massachusetts. % ~- --
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p , ,
l 5 1 We regret the need to limit presentation by members 2 of the public to the Governor's Office and rembers of Congress. 3 However, this limitation was necessary at today's meeting in 4 order to enable the Commission to conclude our business within 5 a reasonable allocation of time. I would note again that the 6 Commission has provided substantial opportunity for public 7 participation in the vicinity of the plant so that we would 8 have the benefit of the views of local government officials and 9 interested parties.
- 10 The question before the Commission is clear. Pilgrim i
11 will not be allowed to restart unless the Commission is 12 confident that the health and safety of the public can be
- 13 adequately protected during operations.
14 Copies of the slides used during the meeting today 1 15 should be available as you enter the meeting room. 4 16 Do any of my fellow commissioners have any opening l ] 17 comments before we begin? . 18 (No response.) l 19 If not, our first speaker is Senator Edward M. 20 Kennedy of Massachusetts. Senator, you may proceed. Welcome. ! 21 SENATOR KENNEDY Thank you very much, Mr. Chairman 22 and members of the commirazion. 23 7 at the outset want to extend the regrots of my 24 colleague, Senator Korry, who wanted to be here today and ir, l 25 necessarily absent. He has an amandment on the Floor of the I
6 1 United States Senate where we are continuing to debate the 2 Omnibus Drug Bill, but he has a statement and I would like to 3 have the opportunity to include that as a part of the record. 4 CHAIRMAN ZECH: Certainly. We will be pleased to
'S receive that, Senator. '6 SENATOR KENNEDY: I welcome the opportunity to appear 7 today before the Regulatory Commission on the proposal to 8 restart the Pilgrim Nuclear Power Plant at Plymouth.
9 Maasachusetts. Although I am pleased that the Commission has 10 provided an opportunity ror the state and federal legisla. ors 11 to speak on the questlun, I am dismayed by the commission's 22 refusal to hear other witnesses on this issue. 13 People who live and work near the Pilgrim Reactor
'14 have the most at stake in the event of an accident, but thoso ~15 same people have been repeatedly denied the opportunity for 16 genuine participation in the decision. I am here today to 17 speak for them, but they should be here and be able to speak 18 for themselves. One of the fundamental principles of American 19 justice and American democracy is to hear the other side. That 20 principle should apply to the Nuclear Regulatory Commission and 21 every other government agency, and I regret in this case it has 22 not.
23 The problems with the Pilgrim plant are well 24 documented. The NRC itself rated the plant as one of the worst 25 in the country. In 1982 the plant received one of the largest
I fines ever levied by the NRC for providing falso information 2 and for improperly operating the plant. The plant has been 3 cited in recent years for literally dozens of violations 4 related to substandard operating procedures, lapses in 5 security, fire protection and radiological controls. 6 How, in the face of this less than reassuring past 7 record, the Commission is proceeding on a course to restart the 8 plant in a decision process that effectively relles on private 9 inspections and the word of the utility to verify that 10 improvements have, in fact, been made. 11 This plant has one of the worst safety records in the 12 history of nuclear power. The utility claims that significant 13 imrpovements have been made since the shutdown in April of 14 1986, and this may be so; but the burden of proof should be on 15 Boston Edison to demonstrate in an open and adjudicatory 16 process that the defects have been remedied. l ', A decision as important as this one, with the 18 potential to affect so many lives in Massachusetts, should not 19 and must not be made in an ivory tower on a paper record in 20 Rockville, Maryland. The people here today have made the 21 effort to come all the way from Massachusetts to tell you about 22 the Pilgrim Plant. They are not high paid lobbyists from i 23 downtown Washington. They are parents, teachers, concerned 24 residents from Plymouth, Duxbury, Kingston and other 25 communities near Pilgrim in Massachusetts who honestly believe
a O 8 1 that this plant should not be restarted again. They have come 2 here to let the Commission know that they fear for their 11 safety, for their children if the NRC is wrong and Pilgrim 4 becomes another Chernobyl. 5 They are here not to talk about Boston Edison profit-6 to-loss ratios but because they want to know how the Nuclear 7 Regulatory Commission intends to protect their children in the 8 avant of an accident at Pilgrim. They are here because they 9 are appalled that the NRC is even considering a decision to 10 restart the plant at a time when there is no emergency 11 evacuation plan in place. 12 They are here to speak for thousands of their friends l 13 and neighbors who are not able to come all the way to 14 Rockville, and they should have had the opportunity to talk 15 with you commissioners face to face in Plymouth. They sit here 16 silently because the Commission has told them they have no f 17 right to speak and they are not part of the decisionmaking 18 process, that their opinions are not worth hearing. Well, I f t l . 19 believe that they do have a right to be heard and that this i 20 Commission has an obligation to hear from them. I 21 Y want to say, Mr. Chairman, I appreciate the fact in 22 your opening statement you mentioned that a majority of the 23 members of the Commission had 4) opportunity to visit that , j l 24 plant. A visit in the plant is one thing, but having the 25 opportunity to listen to those whose lives are most directly I
O 8 9 1 affected is another. I think that is the principal enneern. 2 We appreciate the fact that you have been willing to 3 have members of the NRC staff come to public hearings. They 4 came to public hearings that we had that I chaired. As the 5 Chairman of the Health Committee of the United States Senate, 6 we have had health hearings on the implications of Three Mile 7 Island, the adverse health implications of that failure. We 8 have had health hehrings on the health implications in the 9 Soviet Union of tne meltdown in Chernobyl. We had academician 10 Belikov who testified and he continues to work with our Health 11 Committee on those particular measures. 12 I must say that the kind of testimony that I heard in 13 Plymouth from the healti specialists and the researchers, those 14 that have spent the time, was equal in terms of professionalism 15 and in terms of competene:y to anything I have heard from any of 16 those who have represented many of the agencies of the 17 government during those two very important hearings. la This past January I chaired a field hearing in
, 19 Plymouth for the Senate Labor and Human Resource Committee.
20 During that hearing 1 made a commitment to the people of 21 Massachusetts. After hearing compelling testimony from those 22 who believe that the plant should not be permitted to start 23 again, I urged the NRC to provide these witnesses with an ' 24 opportunity to speak directly to the Commissioners. 25 such an opportunity was not provided. I said that I
10 1 would personolly convey to the Commissioners some of the major 2 concerns that were raised during the hearing, and here I am. 3 Members of the Nuclear Regulatory Commission have 4 been entrusted with the responsibility of' protecting the lives ; 5 and safety of Ameri.nans who live near nuclear power facilities. 6 It is time the NRC lived up to that sacred trust by putting ) 7 aside its own personal views on nuclear power and by looking at 8 the facts. The credibility of the Nuclear Regulatory
- 9 Commission is at one of the lowest points in its history. Thio l ,
10 has come about not by ideology but because of fairness. l l
- 11 The Commission has allowed the interests of the a 12 nuclear power industry to run roughshod on the interests of the r
; 13 public safety. The time has come for the NRC to try to salvage l
14 its credibility by living up to its responsibilities under the l j 4 15 Atomic Energy Act, by not allowing any nuclear plant to be . 16 operated in a way that it could endanger the public. If the f i
- 17 NRC were, in fact, putting public safety first, then these [
0 18 discussions in Plymouth would not be taking place today, for it j 19 is clear that the public cannot be adequately protected in the i j 20 event of an accident at Pilgrim. , 21 The Federal Emergency Management Agency is entrusted I 22 by the NRC with the duty to evaluate the adequacy of er.erger.cy ( 1 23 preparedness plans for nuclear power plants, on August 6, ! 1987, TEMA withdrew its finding that there was reasonable d 24 25 assurance that the public could be protected after an accident 1 l i i l j 1
11 1 at Pilgrim. 2 FEMA based its findings on several critical areas of 3 deficiency in emergency planning first, the lack of a , 4 reception center for people being evacuated to the north; the 5 lack of evacuation plans for public and private schools and day r 6 care centers; the lack of identifiable public shelters for the , 7 beach population; inadequate planning for the evacuation of the l 8 special needs population; inadequate planning for the 9 evacuation of the transport-dependent population; overall lack 10 of progress in planning; and apparent cutbacks in emergency ; 11 preparedness. 12 over a year has passed since FEMA withdrew its , 13 approval for the Pilgrim off-site emergency preparedness plan. I 14 Since that time, to their credit, the commor. wealth of 15 Massachusetts and the surrounding communities near Pilgrim have l 16 worked diligently to try and remedy the deficiencies identified ; I l 17 by FEMA. There is no question that progress has been made; but 18 we are far from finished. To date, not a single community l i 9 19 within a ten-mile radius of the plant has submitted a final l i 1 20 emergency preparedness plan to Massachusetts for review. ] 21 Not a single issue identified in the FEMA self-l l 22 initiated review of August 1987 has been fully resolved. There 23 is still no assurance that school children will be safely and 24 quickly evaluated from the area in the event of emergency. l 25 Questions still remain about the adequacy of the proposed r _a___ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ . _ _ _ _ _ _ . _ _ _
12 1 evacuation center in Wellesley.
.2 The special needs population and the transportation-
.3 dependent population still have no assurance of protection in 4 an emergency. Sufficient shelters for the beach population
.5 still have not been identified.
6 They say that a picture is worth a thousand words, 7 and it is certainly true in this case. Let me just take a 8 moment to show the members of the Commission this aerial 9 photography of the Duxbury Beach. I could put it on the easel,
.to but it is a small blowup and I think it is perhaps better if I 11 just hold it.
12 This is the Saquish Beach area four miles here from 13 Pilgrim. On the average summer day, you get from four to five 14 thousand people that come along this beach here. Some 250 15 homes are in this area. This is Duxbury Beach. During the 16 course of the summer there are several thousands, in excess of 17 ten thousand. This is the only area, this small bridge here, 18 with two lanes on it. This is the only way to be able to
, 19 evacuate this. It gives you some idea in one area here. I 20 von't bother talking about Plymouth Beach where there are 21 several thousand similar problems, where there is no shelter.
22 This is just one area during the period of the summertime. 23 This picture here just shows the number of cars along 24 the Duxbury Beach, whers you just see them virtually parked. 25 It is almost gridlockwd. It's altost as bad as the callahan
- * " "N"**** ** .t r .y-- -
o . r I 13 , 1 Tunnel in Boston, but it is really a~ packed and crowded area. i i
; 2 This, Mr. Chairman, is a picture of the road at I !
3 saquish when the water is at high tide. This is the road here. , 4 It is virtually closed off. The pecple come down there. 3 5 obviously, the tide is every six hours. Usually at one time or l l
! 6 the other during the course of the day there are several i 7 thousand people there that make their own plans of when they
] 1 8 are going to leave there, but their leaving there is dependent f l l l' 9 on what the tide would be. That is virtually imparsable at the j 10 seasons, high tides. L L l 11 I make those available for the file. j 12 As you can see, as I wentioned, there are 250 homes s 13 at Saquish Beach, another 35 homes at Gernet Point, the [ s t
- 14 residents of this area about three miles from Pilgrim. The f i
j 15 only access is by four-wheel drive vehicle traveling about five f j [ j 16 miles on sand, and if any of you commissioners have driven a , r q 17 four-wheel on a barrier beach, you know it's slow going. la There is also the problem of the crowds of summar , [
! . 19 beachgoers. As the other photograph reveals, they park their [
i 20 veTicles on the beach, and I ask you how are these people going j I 21 to be protected if there is an accident, j J i 22 It is not clear to me how the Nuclear Regulatory 1 l ! 23 commission can contemplate restarting Pilgrim at any power { i i 24 level till these issues are resolved. At this time no one is i
- 25 certain that the problems with energencf preparedness can ever i i
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14 1 be satisfactorily addressed. Certainly FEMA has not detarmined 2 that these deficiencies are remedied. 3 1? e NRC repeatedly states that it looks to FEMA for 4 advice on matters relating to emergency preparedness. Well,
.5 FEMA has given you its advice and you have chosen to ignore it. ,6 You have ignored FEMA, you have ignored the Governor of 7 Massachusetts and our experts on public safety, ignored the 8 pleas of disabled residents, of parents, of beachgoers, and you 9 are ignoring the Massachusetts Congressional Delegation as 10 well. Yet in spite of this, you expect that the people of 11 Massachusetts are going to believe when you reassure us that 12 all is well at Pilgrim, that the NRC is watching out for their 13 safety and their welfare.
14 One of the witnesses at our Senate hearing last 15 January was Dr. Thomas Murley, the Director of the NRC's Office 16 of Nuclear Regulatory Regulation. In his testimony he said, 17 "The NRC will not pernit the facility to resume operation until 18 corrective actions satisfactory to the NkC have been taken to ,
, 19 address the emergency planning deficiencies identified by FEMA.
20 We will gf.ve special attention to the improved evacuation plans 21 for schools, day care centers, as well as the improved 22 evacuation plans for special needs and transportation-dependent 23 populktion in the ten-mile emergency planning zone. 24 "We will require some demonstration of the critical 25 aspects of these evacuation plans before we can decide that l i N '--'A w -
o . 15 1 Pilgrim is ready to resume operation." 2 It is puzzling to me how the commission could 3 possibly feel that corrective action satisfactory to the NRC 4 had been taken when the emergency preparedness plans are still i 5 in draft form. Even more puzzling is the fact that Dr. Murley ; 6 also stated that the NRC will requirs some demonstration of the 7 critical aspects of the plants before the restart decision is 8 made. 9 In fact, there have been no exercises to test thcse 10 plans. There have been no off-site exercises of emergency 11 plans for Pilgrim over three years becausa the NRC has granted 12 Boston Edison two exemptions from Federal requirements to 13 perform emergency exercise. 14 If the NRC now chooses to rush ahead with an ill-15 advised and potentially dangerous decision, the Pilgrim plant 16 will have the dubious distinction of being the only operating 17 nuclear power plant in the country for which FEMA has withdrawn 18 its approval of emergsncy prertredness.
. 19 Finally, I want to mention two additional important 20 matters. The first concerns the Mark-I boiling water reactor, 21 the type used at the Pilgrim facility, which Brookhaven 22 National Laboratory identified as having an 80 to 90 perient 23 chance of melt-through during certain accidents. The l 24 Brookhaven report was issued nine months ago. The NRC has 25 still made no decision on whether to require Boston Edison to
16 1 make safety improvements such as the installation of a direct 2 torus vent. 13 It is premature to consider restarting Pilgrim at 4 this time if the safety modifications are needed to ensure that 5 the containment vessel .ls structurally sound. In fact, doubts 6 remain as to whether any improvesents can be made to 7 substantially reduce the probability of containment failure in 8 this type of nuclear reactor. 9 The last isnue relates to the uncertainties of the 10 potential effect: of nuclear power facilities on public haalth. 11 Last January I asked the National Institutes of Hecith to 12 undertake a study to determine whether populations near nuclear 13 power plants are at higher risk for certain types of disease. 14 .T requested this study because of my concern over information 15 released by the Massachusetts Depcrtment of Public Health 16 indicating an increased incidence of leukemia in the coastal 17 communities near the Pilgrim reactor. 18 While no conclusions can yet be drawn concerning the 19 causal relationship between the Pilgrim reactor and the higher 20 leukemia rate, more analysis is needed to determine whether the 21 plant has had an impact on public health. That study is an 22 extensive study. We have been able to get really ione of the 23 best people in our country as part of thi Department of HHS, 24 National Instituter. to do that study. 25 They expect it will take in excess of a year to get
o . 17 4 1 their final conclusions, but we have been continuing to monitor 2 that study. They have taken that work seriously. He have had 3 important indications of increases of cancer in these coastal 4 areas, and it seems to me that by and far that issue ought to 5 be resolved before eny consideration of other factors. 6 I suggest that a restart decision should be postponed - 7 until the National Institutes of Health have completed the , t 8 study. In the absence of meaningful health data, area . i 1 9 residents continue to be duly concerned over the role of i r i 10 Pilgrim in these leukemia cases. j 11 In the years since Three Mile Island and Chernobyl, 12 we have come to learn more about the awesome power of nuclear
.J energy. We know that accidents happen, and when they do, !
4 : 14 consequences can bring enormous tragedy. The most important i 15 lesson we have learned from these disasters is that we must l l 16 exercise the greatest caution and care in regulating our l 17 nuclear power plants, i i 18 only by applying the stric*.est safety standards can 19 we reduce the likelihood thet the history of TMI, let alone 20 Chernobyl, will repeat itself. These strict standards have not 21 been applied at Pilgrin, but it is not too late for the l l 22 Commission to change course, t
.3 I urge you to defer action on the decision to restart
) 24 until all the emergency preparedness issues have been resolved, l
- 25 until there is real assurance of safety for the Mark-I reactor, l
i
18 1 and until all questions relating to public health are answered, 2 and I thank you for the opportunity to be able to make this 3 appearance. 4 CHAIRMAN ZECH: Thank you, Senator. 5 Let me just say we appreciate very much your taking
,6 the time to appear before us today. I do not want to take the 7 time now to discuss a number of the details that you brought up 8 but only to say that we do not ignore our safety
, 9 responsibilities. We have a lot of hard-working professionals i 10 in this organization. We have people committed to the safety 11 of their fellow citizens. We have more than 3000 peopin, many 12 of then in Washington and many throughout the country, that are ( 13 dedicating their lives to the safety of their fellow citizens. , 14 So I must at least say that much. I do not agree f 15 with some of your insinuations. We care a lot about our 16 responsibilities, and I must say that to you, sir, while you ! 17 are here. 1 i i 18 SENATOR KENNEDY: I appreciate that, and I appreciate ; j 19 the restraints on time to be able to respond more completely to ;
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20 the points that I have made; but let me just say, Mr. 21 Commissioner. I know I speak for those in the community of 22 Pilgrim and also at Seabrook who would not accept that l 23 evplanation. They would say that you basically have run 24 roughshod over the recommendations of the organization that has ] 25 been selected by the NRC to make proposals with regards to 1 i
. . ~.
1 19 1 safety. This is the FEMA. 2 I take direct issue with the suggestion that you have ; t 3 followed both the procedures and past practices. We may differ : I 4 with that and I'm sure we do, but I know I represent myself, my i 5 own view in following this issue closely over a period of years ; . l l 6 that I have not seen any agency of government, any agency of l l l 7 government that has been willing to run roughshod and take the ! i I 8 risks on the issues of health and safety. I say that as one f 9 who has had the oversight responsibility on OSHA and MSHA to 10 ensure the safety of mine workers in the deepest mines, of t li occupational health and safety, to ensure that workers in this ! t 12 country are going to have safe workplaces and be concerned 13 about the dangers of chemicals. ; 14 I take a step back to no one in the Senate or at any 15 agency on the issues of safety. Mr. Commissioner, this agency, ; 16 I think quite frankly, has treated that issue, by the way that 17 you have reacted to those regulations that have been put in is place and have been respected by this commission over a period , 19 of years, cavalierly. We have a difference on it and this is j 20 not the place to debate it, but I have -- l 21 CHAIRMAN ZECH: Can I take issue with what you have , 22 said, sir? You may have your view. I have mine. This is a ! I 23 dedicated agency to safety. You may not think so, but I do. ! l 24 We do have an issue, and so be it. ( 25 SENATOR KENNEDY The last 30 seconds. I don't i r l l
e O 20 1 question the dedication of the professionals in this agency. 2 No question at all. No' question at all. What I do question is 3 the policy decision that starts right here. That is an 4 important distinction. That is an important distinction. I l 5 have seen that in agency after ager.cy. I have seen it in the 6 TDA where we have dedicated people and policy decisions made to 4 7 overrule their decisions. I have seen it in agency after 8 agency, Mr. Commissioner. The policy decision is set right ; 9 here, and the policy -- i 10 CHAIRMAN ZECH: That's right. We set the -- ) 11 SENATOR KENNEDY But I don't question the dedication 12 of the people in this agency to safety. I question the policy ! 13 decisions that basically handicap those individuals to do the L L 14 kind of job that we expect them to do in the Congress of the ' 15 United States.
- 16 CHAIRMAN ZECH
- And those policy decisions, in my 17 view, Mr. Senator, are sound and solid and committed to public i
18 health and safety, and that is what we make to the best of our t 19 ability. I 20 SENATOR KENNEDY: You are good to let us come by, and 21 I appreciate it very much, j 22 CHAIRMAN ZECH: Thank you very much. 23 Senator Kerry, did you have a statement? i 24 SENATOR KENNEDY: I will include it as part of the 1 25 submission. l
21 1 CHAIRMAN ZECH: All right, sir. Thank you very much. t 2 Thank you, Senator, for coming. 3 We vill now hear from Lieutenant Governor Evelyn 4 4 Murphy, please. Welcome very much. It is nice to have you L 5 with as this afternoon. 6 LIEUTENANT GOVERNOR MURPHY: Thank you very much. I 7 appreciate the opportunity to be here. 8 Mr. Chairman and members of the Commission, for your ! 9 information and my introduction, I am Evelyn Murphy, the j 10 Lieutenant Governor of Massachusetts, i , 11 Before I begin my remarks, let me express my deep l 12 disappointment in the NRC's unwillingness to provide an i 13 opportunity for local elected officials and for local public l 14 safety officials to appear before you today. These public !
- 15 officials throughout the Plymouth area of Massachuset's have l i I l
16 spent two years and thousands of hours in an attempt t* protect l 1 l i 17 public health and safety. The very least the Commission could ; 18 do and could have done would be to allow them to respond today 1
, 19 and to hear their legitimate concerns.
l 20 You are here today to consider the restart. I an } ] 21 here today to oppose the restart of Pilgrim at this time. Let 22 me go rignt to the point. I 23 Energency planning is the responsibility of the l i 24 Consonwealth of Massachusetts, .at Boston Edison's, not the i 25 NRC'b. We take this responsibility very seriously. In i i
22 1 carrying out this responsibility, the commonwealth concludes 2 that no emergency response plans exist at this time, and 3 consequently, no reasonabir, assurance can be given that 4 people's health and safety can be protected. Therefore, 5 Massachusetts' strongly held position is that the pilgrim
.6 Nuclear Reactor should not be permitted to restart w).thout an 7 approved emergency response plan that has withstood the rigors a of a full-scale graded exercise.
9 You will undoubtedly hear today different versions of 10 the status of the emergency preparedness. Boston Edison and 11 your own NRC staff will report great progress has been made to 12 improve emergency response plans. They will report that 13 cooperative efforts are going well. They will report that 14 agreements are in place with service providers and that 15 training is well under way. They will report that implementing 16 procedures and draft plans are available for all the emergency 17 planning zone communities, '3 thef will report that Boston 18 Edison has delivered on its commitments.
. 19 Progress has been made. Cooperation has improved.
20 But progress and cooperation do not save families. A family's 21 chance for a safe evacuation will not come until emergency , l 22 response plans are complete, tested and approved, and until 23 equipment and personnel are fully in place. 24 The fact is no ermraency response plans exist for . l 25 Pilgrim. Previous emergen , ans from 1981 and later years no l
e 23 1 longer are operative. Following th0 commonwoalth's 1986 report 2 and FEMA's 1987 se2f-initiated review, state and local 3 officials and Boston Edison vont back to the planning -- the 4 drawing board to develop a totally new energency rosponse 5 organization. That process is still under way. 6 Let me list some of the specific pr0blems that have 7 yet to be resolved. First, no local community has yet to 8 approve a plan or a set of implementing procedures. At best, 6 9 ve are evaluating draft material. Second, training for more I 10 ~than 6000 emergency workers is less than one-third complete. 21 Third, letters of agreement with transportation providers, the 12 persons who would assist with the evacuation of school children 13 and persons with special needs, have not been completed. 14 Fourth, the system for notifying local communities ; t 15 and emergency workers during an emergency is not cosplete.
'16 Procedures for using equipment have not been approved. Some 17 communicatione, equipment has yet to be delivered, and there is !
1 i is yet to be a test. Fifth, procedures for the evacuation of l 19 school children and persons with special needs have been j I 20 drafted but not approved by school superinte:idents or by school l
- 21 committees. In some cases, parents and school officials have I
22 not even discussed when and how children would be released at i ) 23 the alert stage of an accident. 24 Sixth, there exists no workable procedure for the 25 evacuation or sheltering of the up to 16,000 seasonal residents i ) - )
24 1 1 of Saquish and the Gernet, as Senator Kennedy was just pointing 1
.2 out, and the roads, as he pointed out, in this area are l t
c3 primitive and sometimes under water from high tides. l 4 4 Seventh, traffic management within and outside the l 5 EPZ remains unresolved. Adequate numbers of personnel and the
;6 procedures for traffic control at the reception centers are l
7 still under study by the licensee. Eighth, there is no I i i 8 northern reception center. A final designation is still six ; I 9 months away. Millions of dollars in capital improvements must I i 10 be made in reception facilities before they can function as i 11 intended. 1 12 These are not trivial issuest they are serious i 13 deficiencies. That is why every Jocal elected official and i l I 14 public safety official in the emergency planning zones believe j 15 that in no event should the Pilgrim Plant. be permitted to i l 16 restart without a full-scale graded exorcise. i 17 I an deeply disturbed by the NRC's total lack of l l 18 public documentation on emergency planning. In contrast, our l J
; . 19 position on this issue is clear and wcil-documented in a l I i 20 comprehensive 200-page report submitted to you this week. Our i !
- 21 report is backed by testimony from local public safety 22 professionals and from local civil defense directors. Their
)
- 23 testimony supports each of these deficiencies and was made
) 24 available to the Commission as an attachment to our status J 25 report filed with you this week.
1 i - i
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_ _ _ _ _ . . . . _ . ~ . . ,__ , .r - . ,. _ . . . - . - _ , . , . -,
25 i 1 over the past two years the NRC hts made it quite 2 clear to the licensee that regardless (.! how long.it takes to 3 respond to all the management and reactor safety concerns 4 raised by the NRC, the plant will remain closed until the 5 commissioners are satisfied. By the NRC's own account, 6 thousands of hours of inspections and progress report) have I 7 been maintained to ensure that Boston Edison is performing to J 8 the total satisfaction of the NRC. l l 9 According to the NRC, this scrutiny has been 10 unprecedented, so I would ask your hhy hasn't the NRC applied 11 the same level of scrutiny to the issue of emergency 12 preparednees? Why hasn't the NRC published written findings on ! I 13 emergency preparedness for public view and comment? Why hasn't 14 the NRC ever prepared a detailed response to any of the three 15 comprehensive reports submitted by Governor Dukakis and by 16 Public Safety Secretary Charles Barry? l 17 Why, at the only NRC hearing where the status of l l I la energer.cy preparedness was an efficial agenda iten, did the NRC ] 1
- 19 fail to recognize local civil defense directcrs who had j
] 20 travelled to Rockville to testify? And finally, why won't you 21 wait for completion and testing of energency response plans as 22 has been requested by our two U.S. Senators, our Congressmau, l 23 our Governor, our Attorney General, all the local Boards of I 24 Selectmen, all local Civil Defense Directors, all local School 25 Superintendents, all local Police and Fire Chiefs, and from
)
. o ,
26 1 concorr.ed citizens throughout the region? 22 These questions trouble us. Without some direct, [ i
,3 forthright answers, we can only conclude that the emergency 4 preparedness has been treated more like a box that needs to be t
5 checked off than like the legitimate and critical public safety l
,6 '
issue that it is. For the record, let me cite some exampir- of 7 the lack of public process by both FEMA and the NRC to addresa t 8 these serious plan deficiencies. I 9 The NRC has failed to respond in any way to the i 10 detailed reports prepared by the Commonwealth in 1986, 1987 and , 1 11 1988 on the inadequacy of the emergency prepare (:ess. FEMA has l 12 never actively participated with the state and localities in i 13 the development of new draft plans despite the fact that the l i 14 Agency took the extraordinary action of stripping the plan of 15 its interin approvals, i i 16 l Neither FEMA nor the NRC has ever held a publie ! L 17 meeting to receive input from state and local public safety 18 of ficials on the status of emergency preparedness. Weither ! 19 FEMA nor the NRC accepted the Commonwealth's invitation to 20 attend the state's public meeting held in Duxbury on October 6, t 21 1988 to discuss this issue. I 22 As you are aware, in October of 1987 Governor Dukakis f 23 and Attorney General Shannor filed a show cause petition with { t l 24 this Commission for k full adjudicatory hearing on the issues i 25 related to management deficiencies, reactor safety questions, f
~ - -
27 1 and the status of emergency preparedness planning. To date the 2 Commission has denied the Commonwealth's request for an 3 adjudicatory hearing on management and reactor safety issues 4 and has postponed judgment on the issue of emergency 5 preparedness. 6 Since no final action has been taken on this item, I 7 request on behalf of the Commonwealth and the residents of 8 Plymouth that the Commission withhold any restart decicion 9 until a full adjudicatory hearing has be'en held on the issues 10 associated with emergency preparedness, 11 Finally, the lack of emergency response plans for the 12 Pilgrim EPZ is appalling. I doubt there is another licensed 13 operating nuclear reactor in this country where FZMA has . 14 officially withdrawn all interim approvals and where the host 15 state and the emergency planning zone communities have done the 16 same. I doubt there is another plant with such an 17 extraordinary history of safaty violations where the NRC would 18 consider a restart without emergency plans. 19 Since the NRC is unable to provide assurance that an 20 accident at the Plymouth Reactor will not occur, the Commission 21 could and should assure the citizens of the Commonwealth that 22 an approved and tested emergency response plan is in place. To 23 do less is unconscionable. 24 In closing, on behalf of Governor Dukakis and the 25 citizens of the commonwealth of Massachusetts, I call on the
,, .,...-,n. , -- , . - , . - , , , ..,
28 1 Nuclear Regulatory Commission to deny Boston Edison's request
~2 to restart Pilgrim Reactor unless and until new emergency '3 response plans are completed, tested and approved. '4 Thank you very much.
5 CHAIRMAN ZECH: Thank you very much. We appreciate
'6 you being with us today.
7 LIEUTENANT GOVERNOR MURPHY: I appreciate the 8 opportunity. Thank you. 9 CHAIRMAN ZECH: I believe that Congressman Studds is 10 here also. Welcome, Mr. Congressman. 11 CONGRESSMAN STUDDS: Thank you, sir. I'm given to 12 understand that it is somewhere between unusual and 13 unprecedented for you to subject yourselves to members of 14 congress in this setting. 15 Perhaps that's a reflection on the extreme of the 16 circumstances, but you are very kind to do that. 17 CHAIRMAN ZECH: We've done it before and you're l 18 welcome to appear this afternoon. 19 CONGRESSMAN STUDDS: I should tell you that obviously 20 the themes of what I have to say have been spoken by the 21 preceding speakers. I'm going to pick one subject in ' 22 particular that I'm concerned about. You've heard about it 23 before but perhaps I can ask you to focus on it a little more 24 carefully and that is emergency planning. 1 25 I'm here to speak for a lot of people who are not j i
29 1 here, basically my own constituents. The town of Plymouth lies 2 as far as there is a middle in the middle of my coastal 3 district and I'm here to speak for constituents. 4 I should warn you that one of them is Senator Kennedy 5 as you get the drift of what it is that I may have to say. I'm 6 representing them as you have heard others say before me 7 because they have asked me to do so. You have not afforded 8 them the opportunity to speak to you themselves either today or 9 as I must say sadly, on any other occasion. 10 Some of you have visited the plant, perhaps n.ost of 11 you no doubt have spoken to Boston Edison officials. Those 12 same officials are here again today to make their case to you. 13 Your staff has presided over public meetings in Plymouth but 14 not once have any of you met either formally or informally with 15 the people whose health and safety lie in your hands. 16 Your staff convened several public meetings in the 17 public area but not one was for the sole purpose of discussing 18 the critical issue of emergency planning. When this 19 opportunity was recently provided by the governor, scores of 20 citizens spoke their piece until the late hours of the night 21 but there was no one there from the NRC to hear them. 22 Your staff recently held a meeting on emergency 23 planning issues hore in Rockville. They allowed Boston Edison 24 which does not have primary responsibility fcr carrying out the 25 off-site emergency plan to make a presentation. But would they
l 30 1 also listen to the Civil Defense Officials from towns in the 2 emergency planning zone report on their state of readiness? 3 They would not. 4 With this history, it is no wonder that my 5 constituents and those of the Senator, Lieutenant Governor, 6 feel that their views are of minimal interest to the NRC. In 7 yesterday's New York Times, a front page article described how 8 five planned nuclear power plants in the Soviet Union have boon 9 cancelled because of the opposition of local officials and 10 residents. 11 It is a sad commentary that Soviet officials appear ' 12 to pay more attention to the concerns of the local citizenry 13 than their American counterparts. If you had spent more time 14 speaking with the residents of the area, you would have learned 15 several things about them. I must tell you that you would 16 discover that they're not left-wing radicals. 17 In fact, the majority of them have twice voted for 18 President Reagan. They are not by and large anti-nuclear, 19 believe it or not, but virtually all of them, even those who 20 are strong supporters of the nuclear power industry, believe 21 that Pilgrim should not be allowed to reopen at this time. 22 What unites them in this belief is their deep concern 23 which I share that the existing state of emergency planning 24 will not protect their health and safety in the event of a 25 radiological accident. ! p , , . , - '
f l l l 31 l 1 My most recent letter to you and we've become 2 correspondents over some time as you know, discussed this issue 3 in considerable detail. Although I don't want to spend a great 4 deal of time today discussing technical legal matters, there is 5 one point that I would very much like to make. 6 In my letter, I argue that certain provisions in 7 federal law and your regulations prohibit you from issuing an 8 operating licenso without an adequate emergency plan and an 9 exercise of the plan. Your staff asserts that these rules do 10 not apply because Pilgrim is already licensed. They maintain 11 that another regulation dealing with licensed facilities is 12 operable in this case. 13 That regulation gives a utility a fotr"month graco 14 period to correct deficiencies in emergency plans. Statements 15 by your staff have given the impression that you would probably 16 invoke this rule if you decide to allow Pilgrim to restart at 17 this time. 18 I want to point out that under this regulation, the 19 four-month grace period is supposed to begin when it is 20 determined that existing emergency plans are inaaeque.ta. I 21 want to remind you that FEMA made this finding in Auguut of 22 1987. According to my humble calculations, the four-month 23 grace period expired last December. 24 The utility is not entitled te another one. This { 25 being the case, the rules require Boston Edison of ficin)s to ' i
32
. 1 demonstrate. now, not t:our montha from now, why the deficiencies 2 in the plant are not significan~. c Since an emergency 3 preparedness plan does not even exist in usable form, they 4 would have in ny view an impossible task.
5 Members of your staff have painted a very rosy 6 picture of the status of emergency planning, grossly 7 exaggerating the amount of prog'ress that has been made. There a are many who fear, I think yoc may know this, I hope you de, 9 that with this conclusion in hand, you will cite a conveniently 10 vague provision of the law and regulations and send Boston 11 Edison on its way to restart. 12 I suggent that instead of hiding behind the letter of 13 the Inu, you pay a little more attention to the intent of the 14 law, vnich is purely and simply to protect the people in the
,15 event of a nuclear accident and I would further suggest that 16 what this entire discussion needs is a big healthy dose of 17 common sense even though we're dangerously close to Washington 18 and what conman sense compela us to do is tn look for the ,
- 1) answers to some very practical questions.
20 Just yesterday, my staff spoke with the civil Defense 4 21 Directors in several of the towns within the emergency I
.12 preparedness zonc. They provided responses to some of these 23 common sense questions that are far more useful than any 24 requirations could ever be in determining whetner or not the 25 people living in the Plymouth area or nn Cape Code,down wind I - - **
33 1 fron Pilgrim, are protected. 2 If you bear with me, I'd like to go over them with 4 3 you. If Pilgrim resumes operation and if there is an accident 4 within the next few months, have the local polico and fire 5 departments received the training they need t o carry out an 6 evacuation? The answer is no. 7 Has a plan been developed to evacuate the special 8 needs population and havo those people been identified? The 9 answer to both quesuions ic no, Have the towns of carter and 10 Kingston end Duxbury and others received the radios and 11 generators and traffic management equipment they need? The 12 answer la no. 13 Are the teachere in the many schools throughout the 14 area trained and prepared to see the thousands of 15 ochocichildren to safety in the event of an emergency? The 16 answer is no. Is the absolutely essential communications 17 system that will ?. ink the operating centers in place? The 18 answer is no. l l
, 19 Han there been a tull-scale exercise to test the 20 adequacy of plans within the last three years? The answer is 21 nn. Most impcrtantly, do the selectmen, the Civil Defense 22 officials, the police chiefs, the fire chiefs, the school 23 superintendents and others who have to carry out an emergency 24 ple.n, feel that they are even close to being ready? The answer 23 is a unanimous, resounding, no. !
I
34 1 If your staff and Boston Edison officials argue that
,2 the answers to these questions are yes, then they are directly 3 contradicting the statements of local emergency planning )
4 officials. If the responses'to these and myriad other critical 5 questions are indeed no, then common sense tells us that 6 existing plans which exist in draft form only, are clearly not 7 adequate in the event of an accidant at Pilgrim. 8 State and local officials have said time and again 9 that they are not yet ready to carry out any type of emergency 10 plan, especially orm that requires evacuation. They are not 11 saying that they will never be ready. They are simply saying 12 that they are not ready now. 13 The governor has attempted to provide his Civil 14 Defense staff with the resources that they need to perform the 15 laborious and time-consuming task of coordinating the planning 16 effort. He's also to be commended for insisting that local 17 residents play a significant role in this process but more work 18 needs to be done. 19 A few more months to wait is inconsequential in the 20 light of two and a half years of shutdown and if it provides 21 the measure of safety that is necessary and the assurance 22 residents need to sleep more easily, then it is certainly worth 23 it. 24 I join with those who preceded me in urging you in 25 the strongest possible terms to delay restart of the Pilgrim i l
35 1 plant until final emergency plans have been approved by 2 federal, state and local officiala and that exercises are 3 performed to test their adequacy. 4 It could be a very tragic mistake to do otherwise. 5 Let me just close by reminding you that again, Y think it's 6 common sense and that is that if there is an emargency and if 7 there are emergency plans to be carried out, they will not be 8 carried out by the members of this Commission, they will not be 9 carried out by the members of Congress. They're going to be 10 car.eied out by the very local officials who tell ue that they 11 are not ready. 12 I would ho;:e that would be as sobering to you as it 13 is to thoso of us are here to speak for them and I thank you 14 for your time. 15 CHAIRMAN ZECH: Thank you very much, Mr. Studds. I 16 appreciate your baing with us this afternoon. Thank you, s!Lr. 17 CHAIRMAN ZECH: We will now call on the Boston Edison 18 Company to como to the tabin, please. Mr. Sweeney, welcomo. !
. 19 You may proceed.
20 MR. SWEENEY: Good afternoon, Mr. Chairman. I'm 21 Steven Sweeney, Chairman of thn Board and Chief Executive of 22 Boston Edison Company. 23 Ralph Bird, the Senior Vice President for Nuclear, 24 will speak for the company this afternoon but before ho begins, 25 I want to confirm on behalf of the ontire board of directors of
1 36 JL Boston Edison Company and our senior management of our l l
- 2 commitment to retaining the top people, to developing our 4
;3 people to be among the best in the industry and to rising
;4 standards of excellence in the operation of Pilgrim Nuclear 5 Power Station, r
; 6- We have institutionalized that commitment in o -
7 corporate goals and long-term plans. Both capital and expense 8 budgets allocate the necessary resources. The Board of 9 Directors has overseen chcnges we've r le in nuclear 10 organization and has been involved in the process of decision-11 making that we've gone through. ; 12 Besides being briefed by Ralph Bird at every Board i 13 meeting, the Board has visited the site on a number of 14 occasions and conducted a final review and inspection on 15 September 21, 1988. On September 22, 1988, the Board 16 authorized us unanimously to seek our agreement for restart of 17 Pilgrim. N o't , I'll ask Mr. Ralph Bird to continue on behalf of 18 the company.
. 19 CHAIRMAN ZECH: Thank you very much. You may ! 20 proceed.
21 MR. BIRD: Good ai'ternoon. We're here today to tell 22 you why we believe we are ready to restart the Pilgrim Nuclear r 23 Power Station and to seek your agreement. Our management tear. ' 24 in in place ar.d I believe thet in terms of att:ucture, 25 experience and overall ability, it compares favorably with that i 4 ,
- ~ .,7 - - - - - , - - , -- , e - , --, , ,<n- , , - , , ,
37 I 1 at other utilities. 2 The competence and effectiveness of our team has been 3 recognized by the integrated assessment team inspection report 4 and of the Advisory Committee on Reactor Safeguard's letter to 5 you. All of the key employees, section head and above, ara 6 Boston Edison employees. 7 The NRC's Integrated Assessment Team inspection 8 confirmed the conclusion of our self-assessment that with the 9 completion of specified items, the Pilgrim plant is physically 10 ready for safe and reliable restart and for continued 31 operation. 12 Two restart items in the restart plan are open. Two 13 of the items determined to be necessary for restart by our 14 Management oversight and Assessment Team in our Restart 15 Readiness Self-Assessment Report remain open. These items 16 involve updating a few drawings, some procedure validations, 17 system preoperability tests and a final certification of the 18 responsible managers to me that restart prerequisites are all 19 closed. 20 We expect to close these items by October 19th. The u
- 21 NRC items required for restart are closed and the restart 22 commitwents that we made as a result of the integrated 23 ase.essment teac inspection are also closed.
24 Virtually all accessible areas, 90 percent of the 25 process buildings, are radiologically clean and we intend to
38 l 1 keep them that way. I have an additional slide which is not in
'2 your hand-out to show where we stand as of today in our 3 prerequisite and startup procedure.
4 Surveillances and checks now in progress would lead 5 to shifting the mode switch to startup and to reactor 6 criticality on the 20th of october if you agree that we're 7 ready to restart Pilgrim. 8 We've expended considerable resources to improve the 9 material condition of the plant and we intend to keep it in 10 good shape. Since the completion of the last SALP period and 11 the NRC maintenance inspection No. 88-17, we have made a number 12 of maintenance improvements that have proven to be effective. 13 We implemented a revised work process which includes 14 planning checklists and we trained 545 people including the 15 managers on its use. We issued a greatly improved maintenance 16 manual. We implemented detailed travellers for our work 17 packages which improved work performance and made the audits of 18 the work easier. - 19 We proceduralized, supervised reviews to ensure 20 thorough maintenance closecut and we assigned operations and 21 systems engineering to have the lead on prioritizing the work 22 to be done. We have added a Deputy Maintenance Section Manager ; 23 to the organizat on and we filled the position with an 24 individual who has 30 years of broad experience in this field. 25 We have expanded the maintenance organization by
39
- 1- transferring personnel from other areas and at the same time, 2 we havJ improved the supervisor to craft ratio. All 2
3 maintenance supervisory positions are now filled by Boston 4 Edison employees who have attended Supervisory Training before 1 5 assuming their responsi\(lities. 6 The duties tha*. in the past prevented supervisors t 7 from getting out in the field and supervising work have been t
- 8 reassigned. We have improved the organization's ability to 9 integrate radiological and operational c,cnsiderations by j 10 assigning Health Physics and Senior Reactor Operator Qualified 7
11 People to assist in the maintenance planning. 12 Our recent assessments of the new work control 13 process have shown both the value of the process and its l A i 14 acceptance by the work force. While we improved our ; ! 15 Maintenance Work Control Process recently, we also continued to j i e < 16 reduce the maintenance backlog. The number of open power block 17 maintenance requests has been reduced to 275 as of today which 18 is 125 less than our most recent goal of 400 and equates to a l 19 3-week backlog of work. I 20 By the say, our goal of 400 is more conservative than 21 the 500 that INPO recommends as an industry goal. New work is
- 22 reviewed and prioritized at the beginning of'each workday by a 1
23 committee chaired by the chief operating Engineer. The 24 Committee includes representatives of systems engineering, 25 maintenance, construction management, planning and outage
.= _ - .
e 40 1 management and fire protection.
'2 The. work items are assigned to one of five priority
'3 categories which range from priority one which is urgently
-4 required work to correct an active limiting condition of
'5 operselon or some persor.nel safety hazard down to priority five
*6 which is fill-in work.
7 In addition, emergency work items are processed 8 separately in accordance with the following restrictions. 9 Priority E may only be assigned by the nuclear watch engineer l 10 who is the senior operator on shift or by the chief operating i 11 engineer and can only be used when troubleshooting, 12 investigation, or repair must commence immediately and it can 13 only be used for work needed to directly or indirectly assure 14 public or employee health and safety and we use very, very few , 15 of those categories of work requests. ! i 16 We've also increased emphasis on radiological issues J
- 17 throughout the organization and the expanded training and these ,
18 are showing clear and measurable benefits. Last spring we met 19 the goal to have 90 percent of the plant's process buildings j 20 radiologically clean. i 21 We've made the changes in. attitudes, in training and 22 in work practices required to maintain that level of 23 cleanliness and it has become a source of pride for the , l 24 organization. The goal for total radiation exposure for our 25 people this year has been set at 390 man-rem which is 20 'I s _ _ , , .--er.,-e-.--,..- - - - - --
-rv -&-- ,
e-' ' ' ' 'Y *'Yn " *'* ~~* ' ' " ' ' ' ' ' * ~ ~ ~ ' ~ ~ " " ~ ~ ' " ~ ~ ~ ' " ' ~
41 1 percent better than the industry boiling water reactor av'erage 2 and it is less than the 1990 INPO industry goal. 3 We are pursuing that goal aggressively and we are on 4 track to meet it. There has bean a sustained improvement in 5 the number of radiological currents reports issued despite l 6 lowering the threshold for that report three times and we 7 continue to show progress in reducing the backlog of open RORs. 8 The operations, the radiological and the maintenance 9 sections, are communicating well in planning and in day to day 10 operations. There is health physics coverage on all of the i 11 shifts and there is a representative from health physics at 12 each shift turnover in the control room. 13 People with backgrounds in operations and ir. health 14 physics have been assigned to the maintenance section also. 15 The plant manager, Roy Anderson, who has those groups with the 16 greatest range of activities in the process buildings reporting 17 to him now chairs the ALARA Committee which is responsible for i 18 lowering the radiation exposure to as low as is reasonably 19 achievable. l 20 We've also begun a long-term source reduction project 21 under Ed Wagner who has extensive experience in that area. 22 substantial further reduction of radiological exposure will be 23 achieved through the use of a videodisc tour program which will 24 be completed in December of this year. This program will 25 consist'of 65,000 photographs of plant spaces, systems and
42 1 equipment and be on a videodisc controlled by a personal c2 computer. 13 The program will be used primarily by radiological, 4 maintenance, planning and outage, training, engineering 5 systems, public information, operations and quality assurance. 36 To illustrate the benefits during the current outage, we spent 7 about 15 percent of our radiological exposure reviewing work 8 areas for interferences, locating inspection areas and in the 9 general familiarization alth the work area. 10 Using this new program, we expect we can achieve 11 significant savings of man rem over the life of the plant
- 12 because these things can be done from outside of the plant by 13 reviewing the photographs.
14 Even though the last SALP rating for radiological r15 protection was a three, the improving trend was noted and many 16 accomplishments were cited. The company has a corporate 17 strategy to reduce exposure to radiation and we are allocating 18 the resources in our capital and expense budgets for 19 implementation as part of the long-term plan. 20 I also focus attention on radiological controls at 21 both large and small acetings of employees and I plan to - 22 continue that. The IATI report and our restart assessment 23 readinosa report have confirmed that we have built on our 24 pro 9 cess. 25 The improvements have continued and our improvement
,, ___m-
43 1 will be sustained over the long-term. The success of our 2 rigorous self-assessment was. confirmed by the small number of 3 items found by INPO or by the IATI. We are absolutely 4 determined to avoid complacency or backsliding in any area. 5 We have made a commitment to extensive programs to 6 institutionalize continued progress towards rising standards of 7 excellence. Today I'll mention only a few of those which are 8 in areas that are keys to safo and reliable operation or which ) 9 have been a concern to Boston Edison or to the NRC in the past. 10 Our commitment to retain the best talent and to 11 develop our employees to be among the best in the industry will 12 continue. Because of the clearly demonstrated benefits, we 13 will maintain the program of self-assessment under the 14 Management Oversight Assessment Team which I chair. The 15 lessons learned from our self-assessments at various points 16 during the power ascension program will be incorporated into 17 our permanent programs. 18 The Radiological Action Plan and the Material 19 Condition Improvement Action Plan which we developed, are the 20 most comprehensive programs resulting from our self-assessments 21 and they have shown their importance to the organization. 22 However, we have covered tl.ese in past discussions, so today 23 I'd like to highlight a few of the many others which although 24 narrower in scope than the progrcas I just mentioned, combine 25 to be an important part of the basis for our continued
44 1 progress. 2 Engineering was strengthened by an original 3 assessment of the nuclear organization and engineering and 4 technical support has been given the highest possible SALP 5 rating ever since the NRC began evaluating this as a separate 6 category. 7 Within this area is a safety enhancement program i 8 which is a Boston Edison initiative which emphasizes prevention 9 of core damage accidents. The program, which includes i 10 equipment modifications and revised emergency operating 11 procedures, has placed Pilgrim at the forefront of the 12 technology. I 13 Installation of all of the components in the safety 14 enhancement program has been completed including the Direct 15 Torus Vent. The vent will become operational during the power 16 ascension program. 17 All of the watch standers have been trained on the 18 new emergency operating procedures which have been revised l 19 through revision four of the boiling water reactor owner's 20 group guidelines. , 1 l 21 We have not finished reviewing the completed station 4 > ! 22 improvements against the newly-issocd station blackout rule, ; l 23 but we will of course meet the rule. Our preliminary ' 24 conclusion is that vu have probably exceeded the general 25 requirements .'nce wo have extended Dc battery capability and W
,r ------ - - _ . ,, _ _ _ - - - - - ,--
-7
. o 45 1 we have installed a third backup diesel generator.
2 In the operations area, the past criticism of 3 operations was based on the fact that we had too few licensed 4 operators who worked too much overtine. The competence of the 5 5 operators was not in question. We have tripled the number of l 6 licensed operators and we will be able to staff a 6-shift l 7 rotation near the end of the power ascension and test program. t 8 (Slide.) ; 9 MR. BIRD: To ensure that we cbntinue to have plenty 10 of operators, classes leading to licenses for new reactor 11 operators and new senior reactor operators will begin in 12 January, 1989. The morale within the operations area is ! 13 improved. One senior reactor operator is leaving this year to l i 14 take an engineering job, and we intend to have enough operators I
, 15 in the pipeline so that in the future, more operators can move l ! l 16 to other jobs without adversely affecting the operation. [
l 17 (Slide.) . 18 MR. BIRD: New and improved procedures to help !
. 19 operators do their job include such things as foran1 20 communications and uniforms which add to the professional t
?
i 21 atmosphere. Our new state-of-the-art plant-specific simulator I i 1 22 has enhanced training. All watch standers have been trained on i 1 P ] 23 the emergency operating procedures which, as I mentioned, have I j 24 been revised to the Revision 4, BWR Owner's Group Guidelines. i 1 l 25 (Slide.) i I l
46
~
1 MR. BIRD: The use of the simulator has also allowed 12 the operators to perform casualty drills that validate'the <
~3 emergency operating procedures, as well as the drills that 4 validate other operating procedures for the plant. The 5 establishment of the Systems Engineering Division was a major i '6 step toward improved plant reliability. Each major system now 7 has an owner assigned in the Systems Engineering Group.
f 8 Their programs include routine walk-downs of major 9 plant systems to identify and correct problems before failure 10 occurs, and routine trending of key system operating parameters ; 14 for early identification of any equipment degradations. The I l 12 system engineers provide in-depth root cause analysis of plant i 13 events and equipment failures, and technical support of
'14 maintenance activities to ensure that the repairs are effected.
45 It think that among the more important steps to 16 ensure future success are those that prepare people to move up 17 and to take on added responsibilities. This is a path that i 18 starts with recruiting the best possible person for every job l 19 and then providing training and opportunity. 'I feel a very ! 20 strong personal responsibility for recruiting, training, and 21 developing our people. l 22 We have a first-rate group in Boston Edison's nuclear 23 organization and we will have the programs that they need to 24 succeed. We'll have a college degree program available to 25 operators ar.d other personnel for anhancing professionalism, I
47 i i for personal fulfillment and for future advancement. We are 2 developing expanded career development programs and planning 3 for key management and nuclear personnel rotations, backup and 4 so on. 5 We'll have more initial continuing unvelopment i 6 training for managers. We have also implemented an improved 7 performance appraisal system which will improve our ability to 8 achieve accountability through all levels of the organization. 9 (Slide.) 10 MR. BIRD: on the subject of emergency preparedness, ! t j 11 in December, 1987, the NRC staff evaluated an exercise of the i 12 on-site emergency plan and found it adequate to protect the l 13 public health and safety. On october ist of this year, we 14 implemented an enhanced on-site plan and emergency response 15 organization. I'd like to make it very clear here at the
- 16 outset that we believe that the off-site programs belong to the !
l l 17 Commonwealth and to the towns. . d 18 In my following remarks, I am not speaking for them.
. 19 Even though the off-site emergency preparedness is the '
20 responsibility of the state and the local authorities, Boston 21 Edison has made a corporate enemittment to provide substantial 22 resourcas to assist those authorities in meeting federal l 23 requirements. ( 24 To confirm that commitment, we have completed letters 25 of agreement with all of the communities involved for variouc ! l
e 48 1 types of assistance. By the end of '988, we will have 2 committed $15 million of support in off-site planning.through
*3
. personnel, equipment and facilities. Our committment is
'4 evident from our agreement to fund a civil defense staff 5 position in each town for the operating life of the plant. ,
[ 6 (Slide.) ) j 7 MR. BIRD: We believe that very substantial progress i 8 has been made in upgrading the status of off-site emergency
, 9 preparedness around Pilgrim station. The progress to date has 1
10 been explicitly recognized by FEMA. The basic improvements i 11 include renovated emergency response faci 3 ities, enhanced draf t ; l l 12 emergency plans, new draft implementing procedures for those 13 plants, implementation of a new training program and a revised
- i
.14 and updated evacuation time estimate.
(
.15 The current program addresses comprehensively and in i
l 16 detail, the six areas of major concern identified by FEMA in , 17 1987 as a result of their self-initiated review. The current i i 18 program is a substantial improvement, particularly since the ! t 1
. 19 revised plans and procedures are being prepared by the same '
20 people who will use them. We are firmly committed to ; 21 continuing to assist the commonwealth and the towns in further . j 22 improving their off-site emergency preparedness program. 23 (Slide.) 24 MR. BIRD: Turning to the power ascension and test ; i j 25 program -- we have worked very hard to be ready to restart 1 (' 1 l l
49 1 Pilgrim. Restart is not the end of the process, but is the 2 beginning of our careful and deliberate power ascension and 3 test program which has been approved by the NRC staff. The 4 company has upgraded plant systems, expanded and improved its 5 nuclear organization and assisted the Ccmmonwealth of 6 Massachusetts and the local towns to improve off-site emergency 7 plans. 8 We are taking the same careful, methodical approach 9 to powers ascension. There are five NRC approval points in the 10 power ascension program -- startup; 5 percent, 25; 50 and 75 11 percent power. At each lovel, operator training an6 related 12 assessments will be conducted. We will have an extra senior 13 reactor operator on each shift. He will be an assistant to the . 14 watch engineer who in the senior person in charge of the shift. 15 His primary function will be out in the plant , 16 overseeing and supervising the non-licensed operators. An 17 experienced senior management oversight team will provido 18 additional supervision at key points. Ascension from one power
. 19 level to the next, will require approval both by Boston Edison 20 management and by the NRC staff who will be on-site.
21 The power ascension program is based on a 4-shift ) 22 rotation. All of the operators and watch engineers assigned to 23 the shifts, will have had experience in running Pilgrim. They 24 are all seasoned operators. This period will be used to fully 25 qualify the new operators so that we will then be ready to novo
50
.1 into --
.2 VOICE: Go out peacefully, or go out my way.
3 VOICE: I want that on the record. Could you give 4 this to the record, please. I'd like this on the record. 5 VOICE: You have to go, sir.
.6 VOICE: Why?
7 VOICE: Come on, sir, let's go. 8 VOICE: I didn't say a word, for heaven's sakes.
.9 CHAIRMAN ZECH: All right, let's proceed.
10 VOICE: Mr. Zech, I would like this on the record. 11 VOICE: You've got to go. 12 CHAIRMAN ZECH: Now, we can proceed. 13 MR. BIRD: To return to the power ascension program,
,14 it's based on a 4-shift rotation. All the operators and watch 15 engineers assigned to the shif ts have experience in running 16 Pilgrim. This period of power ascension will be used to fully l
17 qualify the new operators so that those who are newly licensed 18 will then be ready to move into a 6-shift rotation for
. 19 continued operation. The program is scheduled to last about l .20 four months, and it will confirm the readiness of the people.
21 and the plant for continued safe and reliable operation. 22 To summarize, based on the results of our restart 23 plan and our restart readiness self-assessment, we conclude 24 that the necessary conditions for restart which were set forth ; 25 in Confirmatory Action Letter 8610, and the supplement to that { 1 1
51 1 letter, have been satisfied, and that Pilgrim is ready to 2 proceed into the power ascension program. 3 Morale is high and it shows in many ways and has been 4 noted by all of our recen'c visitors. We are working to a 5 nuclear ethic that is common to the management team and that is
- 6 spreading through the organization. You can see it in the 7 professionalism of the operators and in the dedication of the 2
8 employees at every level. We are committed to making it easicr 9 for people to do the right thing and they are responding very ,
! 10 well.
11 Therefore, on behalf of Boston Edison, I request an , 12 affirmative vote on restart. 13 CHAIRMAN ZECH: Thank you very much. I appreciate 1 : I ' 14 your presentation. Questions from my follow Commissioners? 15 Commissioner Roberts? 16 COMMISSIONER ROBERTS: No. l 17 CHAIRMAN ZECH: Commission Carr? 18 COMMISSIONER CARRt No. j 19 CHAIRMAN ZECH: Mr. Rogers? 20 COMMISSIONER ROaERS: No, I don't think I have any. I 21 CHAIRMAN ZECHr All right. Thank you very much. ; j 12 We'll hear from the staff. Thank you very much. 23 CHAIRMAN ZECH: Mr. Stello, you may proceed. i 24 MR. STELLot Thank you, Mr. Chairman. As you are i 25 aware,'the Pilgrim Plant has been in extended shutdown since l r-- --e-. ,- - .,----m - - , , , - , - - - - . ----,---.r- - , - . . - - - - -n,,-------,------,,,7-
5? 1 April of 1986. The history of the poor performance at this r2 plant involving inadequacies in equipment and personnel 3 performance and inadequacies in management response to plant 4 problems had reached a point where we no longer had confidence 15 that the plant, as it was being operated at that time, could 6 continue to operate with an adequate assuranca of safety.
$ 7 At that time, the NRC launched a concertad effort to 9 assure that the Boston Edison company fully addressed the 9 safety performance problems which had plagued it. In the !
10 perled of about 9 to 15 months after the plant vaz ohut down 11 for safety reasons, a number o* problems were identified I
-12 concerning emergency planning matters at the facility which led i
13 to FEMA's August 1987 letter identifying six deficiencies in 14 emergency planning at Pilgrim and withdrawing the reasonable 15 assuranco finding. 16 The staff has periodically briefed the commission on 17 the status of plants for which agency-wide close monitoring has ! 18 been required. For some of these plants, the commission has 4
. 19 indicated that it wishes to be kept informed of the results of :
f20 the staff review. For others like Pilgrim, the commission haa
) 21 stated it will make the decision ?.egarding plant startup.
I 22 The staff is here ready to brief the commission on l' 23 why it believes that the Pilgrim Plant is now ready to operate 24 safely. Over the two and a half year period since the plant l l 25 was shut down, the licensee has made various significant 4
.- - . , - - . , , , - = . _ , , - . , . . . , . - . - - - , . --- - - - - - - - - - - ~
i 53 1 improvements in plant systems, in operational capability,~ and 2 with the overall management organization and attention to
.3 safety matters at the Pilgrim-Plant.
4 Tom Murley, t'irector of NRR and previous Region I
,5 Admi.istrator, and Bill Russell, Region I Administrator today, 6 are here to discuss the steps taken to improve the operation l 7 safety of the Pilgrim facility and the basis for our 8 conclusions that the plant is now ready to operate safely. In 9 shor\ the conditions which 16d to the plant shutdown have now 1
3 10 been rectified and the plant is ready for power ascension. l' 11 Bill will describe the power ascension program which i 12 will be followed if restart is approved. This phased program 1 13 will require some four to six months to thoroughly evaluate 14 equipment and personnel performance. During this period, the , 15 NRC will significantly increase its inspection activities, 16 including 24 hour coverage for selected evolutions. With 1 17 respect to emergency planning matters, there has also been f l 18 substantial progress in the improvement of emergency response ! t j . 19 planning for this facility especially directed toward the I ^ 20 deficiencies identified by FEMA in its August 1987 letter. )'i 21 I would note that the licensee and state and local j i
] 22 governments have been working cooperatively to resolve issues. '
i 23 This will be discussed later by Tom und Ron Bellamy of Region. i ! 24 I. There clearly is more work to be done in connection with l i l 25 emergency planning at Pilgrim. At this time, we do not have a j i l
54 4
- .1 schedule for the resolution of all of these issues. The staff 2 believes that a carefully constructed power ascension program 3 can taks place safely with emergency planning in its current 4 condition provided that there is continued progress toward 5 finalizing the resolution of outstanding emergency planning
,6 matters.
7 The staff plans to come back to the commission, if it 8 / Approves the power ascension phase, to brief the Commission on D operations during power ascension and to report to the 10 Commission on the progress being made on the emergency planning ,
'll during this period. Thank you, Mr. Chairman, and now I w.ill ! 12 turn to Dr. Murley to begin his presentation.
I . 13 CHAIRMAN ZECH: Thank you very much. You may
.14 proceed.
- 15 MR. MURLEY: Thank yo>2, Mr. Chairman. Bodton Edison 16 has come a long way in the 30 months since the Pilgrim Plant 17 was shut down. It took them about a year end a half to fully
- 18 analyza their problems and get the management team in place
, 19 that could deal effectively with the problems. The past year i
20 has seen a dramatic improvement in the condition of the plant 21 and the readliesa of the plant staff to operate the plant 22 safely. 23 I inspected the plant myself soveral times in recent 24 months and the contrast is striking between its present 25 condition and the condition when I was a Regional Administrator
55 1 in Region I a few years ago. I believe, and Bill Russo11 and 2 the NRR and regional staffs join in this belief, that the 3 Pilgrim Plant is substantially safer now than it was at the 4 time of shutdown in April 1986. 5 There are several reasons for this view. They havo , 6 more licensed operators, they work less overtime, they are 7 better trained, and they have a new simulator to train on. 8 There is a greater depth of management experience from the 9 Executive Vice President down through the first level 10 supervisors. They have implemented improved emergency 11 operating procedures. They have improved safety attitudes 12 among the plant workers. 13 Thera is an improved material condition of the plant 14 equipment and they have implemented a safety enhancement 15 program that goes beyond current NRC requirementu, particularly 16 for the Mark I containment. Boston Edison, on their own 17 initiative, has installed improvements that we are considering ; 18 as generic requirements for all BWR Mark I containments. In I 19 some cases they have gone beyond even what we are considering 20 for generic inprovements. 1 21 Now, Bill Russell will describe the comprehensive NRC ; l ! 22 ir.spections and evaluations that were done in recent months and i 23 I will return to a discussion of emergency preparedness issues l 24 later. J 25 MR. RUSSELLt Thank you, Mr. Murley, ter. Chairman. l l l 1
1 j 56 l 1 1 I'd like to cover the background a little bit in some detail to l 2 set the stage, review again the restart criteria that we ! 3 discussed with you in June when we vers here. I will describe 4 in-depth the staff assessment activities and the renults of 5 those activities. I will cover the physical condition of plant t 6 as it exists today and will discuss in-depth the power 7 ascension program and the plans for staff monitoring of that 8 program should you epprove restart. , 9 By way of background, the facility was chut down on i 10 April 12, 1986 for technical reasons. The stoff issued s il canfirmatory action letter that as a result of continuing 12 hardware problems. We had had repetitive failures associated t 13 with the PHR synten, with inter-system leakage. This is 14 leakage from a high pressure reactor coolant syntem into the
.15 lower pressure RHR system.
, 16 We h;d had spurious containment isolation and I 17 failures of the outboard main steam isolation valve to open . 13 when it should have. We reqvired in this initial confirnation 19 of action letter that the licensee investigate these technical 4 20 problems, develop the root caussa for them, and propose 21 corrective action satisfactory to the NRC staff prior to a ! 22 resumption of operation. ! 23 While that technical review was ongoing, the licensce 24 chose to enter into a refueling outage. Just prior to this, we i 25 had been concerned about the management activitisa at the plant t 7_ .
p 57 a 1 and we documented in a SALP report some substantial management 2 concerns, particularly as they related to incomplete staffing, i 3 the management view expressed to the staff on occasion that the i 4 improvaments to date were sufficient and further improvements 5 were not necessary, a reluctance to acknowledge problems at the i 6 facility, and a dependence upon third parties to identify j i 7 problems to get then resolved, 8 Based upon these concerns, the staff supplemented the 9 confirmation of ection letter to require' the facility remain 10 shut down until these management issues had been adequately [ t I 11 addressed .in addition to the technical issues. The supplement ) 12 required a formal assessment of the facility's readiness for !
- 13 resumption of operationu, a formal restart program with a'
! l f 14 schedule for implementing that program including a power
! 13 ascension program, and it specifically included NRC review and i ! 16 approval of those proorams. l 17 Approximately midway through the outage, at least 18 midway to where we are now, the staff issued a SALP report in 19 the period ended January of 1947. The report was issued i 20 approximately in April. Tnis report identified weak f 21 performance in five areas. In the areas of radiological 22 controls, surveillance, fire protection, security, and most [ 23 importantly, assurance of quality. l 14 This constituted the backgrcund of the performance at 25 the facility up until the time of early 1987. In August of
58 1 1987, we received the FEMA findings on emergency preparedness 2 which Dr. Murley has described. This was a self-initiated - i 3 review based upon planning deficiencies, not based upon an 1
- 4 exercise or identified exercise deficiencies.
5 Dr. Murley has described the safety enhancement 6 program which was initiated by the company in July of 1987 and i 7 also during this period we have received formal petitions as
- 8 has been discussed by earlier presenters today regarding a 9 request for a formal hearing, issues associated with the Mark I l
} l 10 containment management issues, and emergency preparedness l l 11 issues. 1 l 12 I highlight these petitions principally because the I 13 factual material on which the petitioners relied was , 14 information that was coming from NRC inspection reports and
,15 staff activities. These were matters which the staff was well 16 aware of and has been pursuing and in part are the principal i
j 17 bases for the staff's conclusions which were documented in Dr. l 18 Murley's response to those petitions. If I could have the next j - 19 slide, please. 20 (slide.) 21 MR. RUSSELL: The restart criteria which we discussed 22 with you in June has been documented in several pieces of 23 correspondence, from you, Mr. Chairman, to members of the j 24 Congress and others. The first criteria is a stable and ? 25 effective management and staff in place at the Pilgrim l
59
. 1 facility. Secondly, the resolution of the t hnical issues 2 which I described which were the basis fer the original 3 confirmation of action letter. Third, demonstrated improvement 4 in the SALP problem areas, and this is from the SALP reriod 5 that ended in January of 1987, regarding radiological controls, 15 fire protection, security, and assurance of quality.
7 We discussed in June the problems which were 8 identified in a maintenance tran inspection and we will discuss i 9 the status of that activity at this time and why the staff has
; 10 assurance, reasonable assurance that the maintenance prograns 1
11 are well in hand and that the istuss which we identitled in May 12 have been resolved. i 13 Finally, we have indicated that the staff must be , 14 satisfied that certain emergency plan improvements have been 15 made. I'd like to turn now te describe how the staff has gone I 16 about developing the necessaiy factual information to support ! 17 its conclusions in each of those areas. . 18 [ Slide.) 19 MR. RUSSELL: Our assessment activitle's have been I 20 managed by a Pilgrim restart assessment panel which is made up 21 of senior SES managers from the Region and from the Offica of 22 Nuclear Reactor Regulation. This panel has not cnly 23 coordinated all of the myriad of activities by the staff, the 1 24 licensing teviews, tha inspection reviews, but thsy have also i l 25 played a very key role in reviewing and accepting documents and ! t
1 60 1 proposals and plans from Boston Ed' son Company and most 2 importantly in a review and independent confirmation of the
._ 3 adequacy of the infocuation provided.
4 By say of example, I'd like to describe what the - _5 inspectien activity hao been that va have augmented during the 6 period of time of this chutdown. In the year immeClately 7 preceding the shatdown, the insoection activit/ was at a range 8 of approximately 3,500 direct inspection hours on-site per year 9 at the plant. In the early portion of the shutdown, that ' l 10 increased to 5,400 hours per yens. 11 During the period after January of 1987, the 12 resources that went into documenting the basis for th6 s:.a f f 's 13 conclusion regarding the current SALP report involved
- 14 ovpenditure at the rate of about 7,800 per year. And in fact,
- 10 since the Integrated Assessmont Team inspection and including 16 our estimates, what it vould take for the power ascension 17 program should you approve it, we are looking ct approximately 1
10 11,000 direct inspection hours per year.
. 19 This should be contrasted :o a nominal rate of about !
i
; 20 2,500'to 3,000 hours for a facility, The SATP report which we t -
l, j 21 have recently issued cad reviawed with the company this summer l 22 involved 9,600 hours of direct inspection activity. We I 23 obsorved improvament in all areas with s)gnificant improvement 24 in four of the five areas that had previously been evaluated as 1 25 Category 3. One area remained Category 3, improving, but it is
- ,, ,-- , _ - - - _ _ , , - - - , . -- +-
61 1 significant in that we have high confidence in thoaa findings 2 based upon the amount of inspection effort and evaluation 3 activity that went into the facility during that period. 4 Following the SALP report this summer and after 5 receiving the company's own self-assessment report and their G conclusions that the facility was ready, we conducted an 7 Integrated Assessment Team inspection. This involved 13 8 inspectors, approximately 1,100 hours of direct inspection 9 activity, and it was observed by two personnel for the i , 10 Commonwaalth of Massachusetts. I 11 In addition, we have held numerous meetings in the l l 12 vicinity and specifically meetings to solicit public and local I 1 13 official input as c relates to the plans submitted by Boston I i 14 Edison Company, the staff review, the conduct of the p5 inspection, and identifying issues of concerr. o the local l 16 people in the area. 1 17 MR. RUSSELL: Some specific examples of the kind of 18 issues that we followed up on based upon that public input or
, 19 associated with the questions regarding Capetown wire. The 20 management issues with respect to the span of control and the 1
l 21 effectiveness of the management team were raised in a public l 22 meeting and questions regarding the lack of boiling water 23 reactor experience on the part of some of the new managers that 24 came into the company. 25 These issues have been followed up on and have been I i
62 1 tddressed in our restart readiness assessment report. 2 In addition, we have had an. advisory committee of
- 3 Reactor Safeguards Subcommittee meeting and full Committee 4 meeting and they have forwarded a letter to you, Mr. Chairman,
.5 that indicates that the plant is ready for the resumption of
] 6 operation as it relates to management and technical issuss and l 7 recommends a plan as it relates to emergency preparedness 8 issues, that is, a staff plan. 9 I mentioned the Pilgrim restart assessment panel. I 10 They had performed an independent review activity. They 11 completed their work and provided a report to me on the 26th of 12 September. Based upon the hearing that was conJucted by ! 13 Senator Kennedy in the Plymouth area, I committed to make that 24 report public and to discuss with members of the public for the , 15 reasons for the staff's conclusion. In addition, I have 16 physically inspected the plant. I have reviewed the status of i l 17 all the open items since that time and I have given serious 18 consideration to the comments that I received during that
. 19 meeting.
4 ! 20 I have forwarded my recommendation to Dr. Murley and 21 I will review shortly with you the bases fer that 22 recommendation. 23 I would like to shift now to Slide No. 5. 24 I am now going to cover the criteria which we have 25 articulated on several occasions as the basis for a restart
. . l 63 1 1 decision and give you the rssults of our inspection and 2 assessment activities to date. <
3 In the first area of stable and effective management 4 being in place, the staff concludes that there is substantial ! 5 improvement in the depth of management experience within t.he ; 6 facility, from the Senior Vice President down to the first lino 7 supervisors. 8 The organizational structure has been expanded and 9 significantly strengthened. There are extensive managament 10 improvements and staff incr9ases. Let me highlight some of l 11 those managament improvements. l 12 The responsibilities and accountability of the ; i 13 organization are r.ow well definod and understood. Pruviously ; 14 there had been a series of various aanagement directives, , 15 documents issued. They had not been pulled together in one ; i 16 place, and in the coursu of staff interviews and inspections we 17 found that these policies were not wall understood at the first 18 line supervisor lesel. That has substantially been corrected. , i
. 19 They now have a mission, organization and policy ma?.ual which i 20 has been promulgated, which in one placs doacribes the policies !
j 21 and the procedures and the expectations of the organization. ;
; 22 We have interviesed all levels of the organization 23 !ncluding first line supervisors and conclude that they '
24 understand well what is expected. 25 The effectivonens of the uanagement team has boon !
- _ . _ - . . . , - ~ - _ _ . . - _, , - - - -
l E4 i 1 confi und through the results of the integrated assessment team 2 inspection. The process was one of holding the company i 3 accountable for taking the first "what is the condition of the 4 plant" and deteiling in all aspects on the results of their own ; , 5 rev!.aw. We then went in and ir. dependently evaluated to ses
'6 What vu found.
7 The results wero very close in agreezent. Thore were 4 C a few areas whure we had some differences jn priority but these .; i 9 were not substantial and we concluded that the management ( i
- lo organization policies and procedurer,were in placo to support !
11 rate operation of the facility. l t 12 In the second ares, utdor technical issues which were 13 the cause of the original shutdown back in 1986. These matters 14 have been resolved to the extent that'they can be with the j 13 facility shut dowra, cicarly there needs to be ratesting to I r i a 16 demonstrate that the corrective actions have been satisfactory 1 17 and these tests are planned during the early phases of the ! 9 l 18 power ascens ion program. L ], 19 r eut more importantly, the modificatione to the, i 20 facility, the upgrades, the. safety enhancement program that Dr. 21 Murley described, the company has not stopped with the narrov 22 focus of the original technical mattern which were uddressed in
- 23 the shutdown but rather has broadly taken a loor,at what needs i
24 to be done and I believe that the atfety enhanennent program j 25 has gone well beyond, for example. just Mark-I issues and har i l f
. , - , ~ . - , , _, , , . , , - - - - . . . - , . . , , , - . - _ , . ,e , - n -.,
- r. , ,-. , , - -, - - ,- --, - .. - - , . - . ~ - - - g., - , ,,- - , . . ,
65 1 addressed a number of issues which have teen of serious concern 2 to tho staff and they are ahead of us in our generic programs 3 in many respects. 4 As it relates to improvement in the SALP problem 5 areas which wero identified with the period that closed in 6 January of 1987, in the areas of fire protection, I would like 7 to by way of exarole identify what were the strengths and the 8 weaknesses that came out of the integrated assessmen: team 9 inspection such that you would be able to judge the bases for i 19 the staff's conclusions. l l 11 In the area of fire protection, a notable strength is 12 the quality of the staff and the maintenance of the fire 11 protection equipmsnt and the significant upgrades to fire 34 barriers in the maintenance program. We identified no 15 weaknosses in this area. In the area of security, the I L 16 contract guard force, there has been significant increases in 17 dedicated management activities to fire protection with t 18 increased oversight of the guard force and the contractor. 1
. 19 This was identified as a significant strength. We did not 20 identify any weaknesses in that area. ;
1 21 As it relates to surveillance testing, we did 3
- 22 identify a question on the once per refueling outage 23 surveillances or this plant would have been shut down for 30 j l
24 months and we felt it was appropriate to go back and re-look at
, 25 those surveillances to justify why some of those should not be l l
4 i
66 1 performed again. The licensee has agreed to do that and that
'2 review is now completed by the licensee. It is the only NRC
- 3 item which is open from the Appendix M to the restart report on f r
4 which I updated for you last night, indicated there were three 5 items open at that time. We are now down to one, with all 6 licensee actions completed. l 7 on that one item on the once per refueling outage , 8 review is about 80 percent complete by the staff and we have 9 agreed with their findings thus far. ' e just not complete in with our own review. I 11 We did conclude that there was a significant [ 12 improvement in the area of planning for surveillance testing l 13 and the coordination of survoillance testing. That was 14 identified as a significant strength.
- 15 In the area of assurance of guality, this is how well 16 does management manage the activitics and oversee the 17 activities, we found a significant strength in the safety s
18 review and audit committee, in the attitude throughout the 19 organization from the first-line supervisor right through to 20 the senior vice president and noteworthy communications 21 improvements between the quality assurance organization and the i 22 operaticas organization. I 23 We did identify some weaknesses associated with the ! i 24 operations Review Committee, the fact that they had multiple l l 25 action lists and they were not consolidated. It was not known l g
)
67 1 that everything was being covered and there were some questions 2 about tracking and follow-up on quality assurance reports. 3 Each of these items have been subsequently addressed to the 4 satisfaction c'. :he staff. 5 The reason I highlight these is these are the results 6 of the inspection that also included direct observation by the 7 Commonwealth. It was an extensive inspection. Those observers 8 had access to all parts of inspection planning on the staff 9 caucuscs, the results, and they participated in the exit 10 meeting with the company and had their opportunity to provide l ) 11 additional comments on both the strengths and the weaknesses 12 and the findings of the inspeculon. 13 In one area that was rated as a SALP Category 3, that 14 is the area of radiological controls, we noted in the most I 15 recent report that this was still a Category 3 but the 3 was 16 improving. 17 We looked into this area extensively during the ] i 18 integrated assessment team inopection and concluded that it was ;
- . 19 continuing to improve. What we were concerned about and why we [
20 did not rate it as a Category 2 is we felt that the problems 21 that had existed in the past were so sufficient, so serious 1 ; 22 that we wanted to see sustained improvement over a period of 23 time and we took the issue of looking at what types of , i 24 resources the staff would be applying because recall the ! r 25 Category 3 rating relates to staf f resources and how we budget : i i i i
68 1 and plan for activities.
.2 subsequent even to the close of the integrated 3 assessment team inspection, we have had additional meetings 4 with the licensee on the area of radiological controls and I 5 think a recent example establishes a good benchmark for how far "
6 they have come. , 7 We Lad problems with a control rod drive mechanism 8 lower unit jvat over the phst two or three weeks. This was an 9 activity which the company, planned, established a budget for 10 that was very ambitious and completed the work with a planned I 11 budget of three man-rem for the total job with an actual 12 exposure of 2.8 man-rem. It was well planned and well managed, 13 so we are seeing that the recent work in the area of 14 radiological controls is being very well handled. i 25 In the area of the maintenance program and the work- ' i 16 back log, this was a significant concern that we had back in 17 June when we met with you. There have been significant 6 18 increases in organization and staffing. Those have been , . 19 disscribed by Mr. Bird, the President of the company, and I l 20 von't repeat those. 21 There are some areas I would like to highlight, i l 22 however. There are improved maintenance and post-work test ; 23 procedures. This was a concern that we had, that there was not ! 24 adequate tracking of the early maintenance work and the - 25 necessary retest following that maintenance. !
69 1 There is a much more thorough program, set of 2 procedures, on how work is managed both from the time you atart 3 the work and you ga out of service until the it is returned to l 4 service and retested. This is the Traveler system as was -
'5 described by Mr. Bird. l 6 Most importantly, though, the backlog of maintenance 7 actions has been reduced and they have prioritized all open 8 work. In one area, the area that is germane to the restart, 9 the total maintenance requeats open for' restart as of about '
10 Noon today were'201 maintenance requests, 171 of those 201 are 11 complete and they are awaiting operation with the plant at 12 temperature and pressure such that the retest can be 13 accomplished, 27 are in the process of being closed out now 14 and there were three that were still working. This could be 15 completed 1 ster this afternoon or tomorrow, as it relates to 16 that work activity. 17 , We have noted significantly improved communications 18 within the organization and exceptionally noteworthy control of 19 field activities. The supervisors are getting out in the 1 20 plants where the work is being accomplished. 21 In sum, the issues that were of concern to the staff 22 in June of 1988 and documented in the maintenance team 23 innpection report have been resolved and with respect to 24 hardware performance I believe that some of that is awaiting 25 testing during power ascension. 1
70 1 During the period of initial low power operation it 2 may be necessary to take a shutdown to correct leaks or resolve 3 retest items. Recall that we've had two and a half years of 4 maintenance activity and while we have high confidence in the l 5 process and the programs in place now, we had concerns about
,6 some of those activities in the past.
7 We have tested them and observed the testing to the a extent we can in a shutdown facility and in fact the licensee t 9 has brought in a portable boiler -- I call it a shore boiler -- t 10 to test the reactor coolant injection system, HPCI and RCSI. ' 11 However, there is a limitation on how mucn you can test when 12 you are shut down and we are going to have to wait until the 13 plant is operational to complete some of that maintenance i 14 retest. t l ,15 I'd like to at this point discuss the program that we ' l 16 have planned from the power ascension program. This is slide r 17 No. 7. 18 This program provides for a deliberate and controlled i 19 return to power operation. It provides for special testing to 20 be accomplished, the testing that is necessary for the 21 maintenance items that I've just discussed. ' 22 In addition, we'll be conducting some unique tests. ; 23 We'll be performing a shutdown from outside the control room to 24 demonstrate conformance to the Appendix R requirements. ! 25 The program includes hold points as were described by
71 1 Mr. Bird, five -- initial criticality, 5 percent, 25 percent, 2 50, 75 and finally one at 100, which is the point at which the 't 3 staff will evaluate the total program and decide whether we can 4 release the company from the confirmation of action letter. 5 In this process are built in management wssessment 6 points where there will be a senior management team that will ! 7 assess the quality of operations. After they have satisfied 8 themselves with the quality of operations at each plateau, that 9 special team will stand down and we will get an opportunity to 10 evaluate, then, operations by the normal control room i f i 11 complement to determine ourselves that the facility is ready to j ] - t 12 operate without increased or augmented coverage. 1 I j 13 After observing both the results of the management ( 14 assessment activities by Boston Edison Company, our own -
! 15 observations during the plateau, the steady state cperation at f
) 16 reduced power, the NRC staff through the restart assessment I i 17 panel process will make a recommendation to me regarding the ( I j 18 readiness of the plant to proceed to the next power level or j 19 plateau, i l 20 This procers will be followed for each of the hold j ' 21 points. It is a very deliberative process and we will include i i 22 'round the clock coverage during the times of power changes ! 1 ! 1 23 when significant testing and activity is ongoing. ! l 24 As I indicated, we are expecting that this could 25 require as much as a thousand hours of direct inspection 4 i 1 +
i 72 , 1 activity 'per month for the next four to six months. t 2 Let me describe what would be the situation for plant ; i 1 3 status and the expected date that the plant would be ready for
- 4 criticality, should that decision be made by the commission.
i j 3 Presently we expect that most work items will be completed 3 G either today or over the course of the weekend. l Following l l 7 that, we anticipate that there are going to be approximately 1 8 four to fivs days of surveillance testing. l ! 9 The critical testing is a loss-of-power test no 1 j 10 demonstrate the on-site AC pcwor systems, and some load i 11 shedding which are associated with modifications and once l
,12 priority surveillancos that will be conducted. If that work i 13 progresses well and the schedule has been going well, n day or !
- i i 14 two later, we anticipate th3t the facility would have all l 15 requirements complete and ready to proceed to criticality on l L
j 16 the 19th of October, such that criticality could occur as early l i ] 2 17 as the 20th, bas 3d upon plant, setorial, readiness and l l la documentation. l l l . 19 At this point, I'd like to turn the discussion back [
,20 i
to Dr. Murley 'tho will provide some commen ;s regarding the l { 1
) 21 status of emergency preparedness. l 1
1 22 MR. NURLEY I need to set the stage with some ' l J 23 background on emergency preparedness. The accident at Three 1 24 Mile Island II, taught us the importance of energency 1 ~ 25 preparedness. It taught us that it's essential that decision-i l
73 1 makers have a range of options for protective actions, and that l 2 they do not have to rely on an ad hoc response to an emergency f 3 as was the case at Three Mile Island. , 4 In the aftermath of TMI, the NRC added what is S essentially a fourth layer to our defense-in-depth safety i 6 Philosophy. To see where this fits into our regulatory fabric, 7 you recall the first level of our safety defense, is to require - 1 a high quality in the design and the construction and the 9 operation of the plant in the first place. The second level of ; ( 10 our safety defense is to assume that there may be failures of !
) l l 11 equipment and to requirs that safety systems be installed to i 12 shut down the plant and *.he chain reaction and keep the fuel l
{ 13 cooled. 14 Beyond that, we add yet a third level of safety j j 15 defense, and we postulate that, in spite of those safety ! l : j 1 16 systems, that serious accidente can happen, and that we ! j 17 neverthelens require a containment structure to prevent the , t i la release of radioactivity. Now we have added yet a fourth level i 1
. 19 to that safety defense. We postulate the possibility of an 20 off-site release in any event, and we provide that there be ;
21 emergency planning options for authorities to take to protect , I i 22 the population in the vicinity of nuclear plants. 1 l 23 Thus we see that energency planning is the last in a ! ! 1 j 24 series of barriers in the defense-in-depth safety philosophy to 1 l 25 protect the public. We have just described the actions taken l l l -
. _ _ _ . . _ - ~ _ _ - _ , _ _ _ -- _ _ _ - . _ _ _ _ . _ . - _ . . - - _ . _ . _ _ _ _ . _ .
74 1 by Boston Edison over the past 30 months to strengther.their 2 operational staff, the safety equipment and their containment 3 structure to strengthen these first three lines of defense. 4 Now, I'll discuss what's been done to improve the fourth line 5 of defense which is emergency planning. 6 Our regulations do not require perfection in 4 1 7 engrgency planning. In fact, it is not possible to guarantee a that emergency planning actions will protect 41) of the people j 9 near a nuclear plant under all accident conditions and in all 10 weather conditions. Our regulations recognize this reality and t t 11 they only require a reasonable assurance finding that 12 protective actions can and will be taken in the event of an , 13 emetgency. 14 We recognize that emergency planning is a dynamic 15 process; that perfection is not attainable; that deficiencies l l , 16 vill occur from time to time, and that the deficiencies can be i l 17 corrected while the plant is operating. With this general l 18 background on emergency planing, let me summarine the specific , 1 j . 19 case at Pilgrim. Our conclusions, I should add, at Pilgrim, 20 consider all of the information that's available to us today, 21 including the recent report from secretary Barry. 22 The initial plans for P11 grim were submitted to FEMA l l 23 by the commonwealth of Massachusetts in June, 1981. There were l 24 revisions required and they were resubmitted by the 25 Commonwealth in October of 1981. With those plans in place, ,
75 1 the first full scale exercise at Pilgrim was held in March, 2 1982. There were several deficiencies noted. They were 1 3 corrected and in September of 1982, FEMA issued an interim - 1 4 finding that the state and the local plans were adequate. 5 In June of 1983, there was a second full-scale i 6 exercise. I was the regional administrator at the time, and I 7 personally observed this exercise with the FEMA regional 8 director. I was in the control room. I was at the TSC. I was 4 l 9 at the amargency operations facility, and I saw the local l d l 4 10 activities at the plymouth Armory. l 11 I watched the civil defense authorities, the police 12 authorities, the liaison with the coast Guard -- all of the , 13 normal emergency response facilities and activities that take 14 place. They had extensive communications equipment and one j 15 could see the communications with the civil defense authorities 16 in Framingham. 17 There were several deficiencias noted at that 18 exercise. They were corrected and FEMA issued a finding of
, i l ,
19 adequacy at that tir.e. In August of 1984, there was a drill or ! 20 a partial exercise. There was one deficiency found in that, ; 21 after which FEMA issued a finding of adequacy of state and l
! 22 local plans. In 1985, a year later, FEMA wrote to l
23 Massachusetts that nonetheless, there were several planning 24 problems that were unresolved and that the state did not seem 4 j 25 to making progrests in corrective actions. l
76 1 Later that year, in September of 1985, there was yet 2 another full-scale exercise in which four deficiencies were 3 noted. They had a remedial exercise a month later, october of 4 1985. The deficiencies were corrected and FEMA issued us a 5 finding of state and local response as adequate. 6 Six months after that then, in April of 1986, the 7 plant was shut down. In December of 1986, Secretary Barry from l 8 the Commonwealth sent a report to NRC and FEMA describing 9 problems that Massachusetts saw with emergency plans near 10 Pilgrim. In August, 1987, FEMA sent to the NRC their report to 11 the NRC of their findings from a self-initiated review. These _12 have been discussed and will be discussed in more detail. 13 There were six major deficiencies that FEMA found. 14 They found that the off-site emergency preparedness
- 15 had deteriorated at the site and that they could no longer make 16 the finding that state and local plans were adequate. The 17 plant was shut down at the time, of course, and we concluded 18 that there was no need to take any enforcement action. Bostan 19 Edison had been working with the state and local officials at 20 that time to improve the plans, and we could see that 21 improvements were already being made. '
i 22 Now, the situation at Pilgrim is not unique. The NRC 23 oversees 108 operating plants at 72 different sites in the 24 country, in 33 different states. We have a great deal of f 1 25 experience in worka.ng on emergency planning with FEMA and with l l l
i 77 1 1 the 33 states with nuclear plants. Emergency planning is a l 2 dynamic process. It's not uncommon for deficiencies to appear l
, 3 in the plans or in the exercises. I l
l ' 4 For example, even today, at Duane Arnold site, FEMA 5 has notified the state of Iowa of defi.encies regarding 6 relocation centers, bus drivers and other matters. These 7 deficiencies are being corrected and there will be an exercise 8 later to verify those corrections. Our regulations provide us 9 with a range of enforcement options that we can take when 10 deficiencies are found. j 11 In most cases, the deficiencies can readily be i 12 corrected and observed in remedial exercises. In one case I 13 remind you that in 1982 and 1983 at the Indian Point site, one ] i 14 of the counties in the energency planning zone, refused to i 15 participate altogether in emergency planning. FEMA could not i 16 make an adequacy finding in that case. In that case, the state ] l 17 of New York ultimately stepped in to compensate for the county. 18 The plants were permitted to operate while these
, 19 corrections were being made and while there was sn exercise to 20 verify the compensatory action by the state. In the case of 21 Pilgrim, the staff judged the deficiencies identified by FEMA 22 were significant enough that we said that we would not permit 23 the plent to restart until improvements were made in the plans 24 and we observed some demonstration of those improvements.
25 ' In fact, there have been substantisi improvements in
0 e 78 1 the off-site plans, and the NRC staff has observed the 2 demonstration of some key elements of the plans. We'll discuss 3 those details in a moment. Boston Edison, as you heard, has 4 spent $10 million already on improvements to the plans and 5 facilities in the local communities. They intend to apend 6 about $5 million more. 7 Nonetheless, we recognize that there is more work 8 that needs to be done before we can receive a FEMA finding of 9 adequacy. In some cases, Massachusetts wants to go beyond )RC 10 requirements. We don't object to that, of course, but it does
'l l delay the state in finalizing the plans. The next steps are 12 that the state will have to submit final plans to TEMA. FEMA 13 must review them and approve them and schedule an exercise.
14 The state and the licensee and FEMA and the NRC then 15 must condact the exercise. If there are any deficiencies, they
- (
16 must be corrected. Finally, we would get a formal report from 1 17 FEMA to the NRC of the finding of adequacy. We estimate that it 18 would take about six months after Massachusetts submits the 19 final plans before we could receive such a formal TEMA finding.
'20 In the meantime, the staff believes that we have 11 sufficient informatio'n to come to our own conclusions 22 concerning the significance of the outstanding issues, pending l 23 completion of the formal FEMA process. The last full exercise, 24 as I mentioned, was in 1985. We have issued an exemption to 25 the regulation requiring a full participation exercise every
79
- 1 two years.
2 of course, we cannot schedule an exercise until the 3 Commonwealth of Massachusetts submits revised plans to FEMA. 4 Ron Bellamy will now summarize the improvements that have been 5 made in the plans and the NRC observations of these 6 improvements. 7 CHAIRMAN ZECH: Thank you very much. You may 1 8 proceed. j l 1 9 MR. BELLAMY: Thank you, Mr. Chairman. I am the t 10 regional branch chief with the responsibility for the review of . .i 11 emergency preparedness issues. Next month will complete six
- 12 years that I have ber.n charged with that responsibility. If ,
I 13 you'll turn to the next slide, the next slide will discuss the f 14 I
; status of emergency preparedness.
1 l 15 (Slide.) j 16 MR. BELLAMY: Although emergency preparedness was not ! 17 an issue of the pilgrim plant shutdown in April, 1986, the NRC ! t 18 staff has continuously monitored the status of emergency l 1
, 19 preparedness. The Federal Emergency Management Agency began e
, 20 their self-initiated review in September of 1986, due to a lack 21 of progress toward resolution of document concerns. The FEMA ! 22 self-initiated review was issued in August 1987, and identified i 23 six specific issues the lack of evacuation plans for certain 1 j 24 public and private schools and daycare centers; the lack of a . t i 25 reception center for people evacuating to the North the lack i
I 80 1 of identifiable shelters for the beach population; inadequate 2 planning for the evacuation of the special needs populations 3 inadequate planning for the evacuation of the transportation i 4 dependent population and an overall lack of progress and I 5 planning and apparent diminution in emergency preparedness. . 6 This report was immediately transmitted to the Boston 7 Edison Company by the stsff and a written plan for resolution 8 was received by the staff on September 17, 1987. Based on , 9 these FEMA identified deficiencies, FEMA in its report, t 10 withdrew its interim finding of adequacy for off-site emergency 11 preparedness and concluded that there was no longer adequate i 12 ascurance that public health and safety could be protected. 13 This previous finding of adequacy was based on plans and 14 procedures being in place, and demonstration of the
,15 implementation during full-scale exercises.
16 In order to asr.ess progress, the NRC staff has 4
- 17 reviewed local plans and procedures, discussed the icsues with
. 18 FEMA Region I staff, Commonwealth officials, local town i 19 emergency planning officials, local residents, and Boston i 20 Edison representatives. We have attended numerous public l 21 meetings in the area and have toured the area, with special ! j 22 emphasis on the beaches and the local emergency operating i l 4 23 centers. ' 1 24 Considerable progress toward resolution of the issues 25 pertaining to the schools and daycare centers, the special l 4 4 d
- _ _. . - , _ _ _ _ _ _ . . . _ - , , _ _ . . , _______._,.,,__.___..__,.__.____37 ,..,.7_ , -. . , , , .,
81 1 needs population and the transportation dependent population is 2 evidenced by the drafts of plans and implementing procedures 3 that have been prepared. Draft plans for all five communities 4 within the ten-mile emergency planning zone, as well as plans 5 for the two reception communities have been sent to the 1 6 Commonwealth and from the commonwealth to FEMA for a technical 7 review. 8 Implementing procedures for three of the EPZ 9 communities and the two reception communities have also been 10 forwarded to the Commonwealth and of these, the procedures for ] 11 one of the EPZ communities and the two reception communities 12 have been forwarded to TEMA for a technical review. The 4 13 Massachusetts civil Defense Agency Area II Plan, which covers 14 the area around Pilgrim, has been sent to FEMA for technical 15 review and work is progrossing on the Commonwealth statewide l 16 plans and procedures. 17 It is noted that the statewide plans and procedures 18 were demonstrated at full-scale exercise at Yankee Row in 19 April, 1988, and at Vermont Yankee in August, 1984. The 20 progress jn generating revised plans and procedures is due to 21 the efforts of local officials, including Selectmen, town c 22 managers, civil defense directors, police chiefs, fire chiefs, 23 department of government officials, school administrators, 24 nursing home administrators, hospital administrators, day care 25 center administrators, harbor masters, owners of private
. o 82 1 buildings identified for use as shelters and members of the 2 general public working in concert with licensee employees.
3 As such, these individuals are thoroughly familiar 4 with the contents of these documents and could implement thess 5 plans and procedures if necessary. There are five procedures 6 for two EPZ communities for Plymouth and Ducksberry that, 7 although prepared, have not yet been approved by the local 8 of ficials for forwarding to the commonwealth fer technical l 9 review. l l 10 Although in draft, the revised plans and procedures 1 11 are in sufficiently final form that a training program,
.12 approved by the commonwealth, is being conducted. The NRC 13 staff has audited this training program, including the l 14 individual lesson planc and staff from both Region I and NRR t ;15 have observed the training of bus and ambulance drivers from 16 companies providing transportation for school and daycare 17 centers, the special needs population, and the transportation-18 dependent persons. . 19 This training includes use of route maps and travel 1
20 on the actual routes to be used 3 4a 9tergency. The ststf has j 21 audited six different training sens er , and witnessed l 22 implementation of the training for cpproximately 5C 23 transportation providers, which is 25 percent of that training 24 that has already been conducted. These 12mited demonstrations 25 provide the staff with the basis to concluds that significant
33
.. 1 progress has been mad 2 in improving the emergency plans and ~
2 p*tocedures for schools and daycare centars and for the special 3 needs and transpertation-dependent populations in the emergency 4 planning zone. S Regarding lack of a reception center for people 6 evacuating to the north, the Commonwealth har tentatively 7 designated a state-run facility in Wellsley as a northern 8 reception center and has conducted a feasibilit/ study that 9 indicates the facility is 'asible for use as a reception 10 conter. Boston Edison has performed an analysis which 11 concludes that the two reception centers that are presently in 12 existance at Taunton snd Bridgewater, with appropriate 13 renovations and additional equipment, have the capability to 14 support an evacuation from the emergency planning zone, yet 15 they are supporting the potential for a third conter. 16 The Bridgewater State College facility is capnble of 17 serving as a location for evacuees from the amargency planning 18 zona to assemble and lacks improvemonts and hardware for
, 19 monitoring of radioactive, material to be able to nonitor the 20 20 percent of those arriving at the reception center within 12 l
21 hours. These modifications could be completed in a short 22 timeframe, and by a short timeframe I mean approximately one 23 month after approval by the Commonwealth.
~
24 The reception center at the Taunton State Hospital is 1 25 an existing stcucture that needs modificationc including
. v B4
- 1 monitoring equipment that would take three to four monthz to
-2 complete after approval by the Commonwealth. The Taunton Civil 3 Defense Director has documented his belief that he would use 4 portions of the facility in an energency, even if the 5 renovations wore not complete and he also stated that there arc 6 no outstanding progran issues that would interfere with 7 implementation of workable plar.s and procedures.
8 Regarding a lack of identifiable beach shelters for 9 tite beach population, Boston Edison ccepleted a shelter survey 10 and developed a shelter implementation program, including
?ll shelter identification, lettors of agreement with the providers 12 and shelter procedures. FEMA's position, which the NRC staff 13 supports, is that a range of prottotive actions are required ,
14 and that sheltering is only one protective action to be 21 5 considered and is not, in and of itself, a requirement. 16 Therefore, FEMA has removed this issue as a concern. 17 llonetheless, a snelter program for the bench population is 18 continuing. The deficiency regarding an overall lack of
. 19 progress and support in emergency preparedness is being.
<20 resolved by tPe progrens being made in correcting the other 21 specific FEMA-identified issues, including the development of 22 revised state plans.
23 I'd like to quickly summarize the information already ; 24 providod fer the FEMA self-initiated deficiencies and the sub-25 issues. The next slide.
. e 85 1 (Slide.]
4 2 MR. BELLAMY: The next slide shows the status for 3 resolution of a school children concern and the third reception 4 center, and I have hard copies of this slide if you'd like to 5 see them.
- 6 CHAIRMAN ZECH: Yes. You better give us copies of 7 to explain it. Do you have that passed out for the audience or 8 not?
9 MR. RUSSELL: Mr. Chairman, this is an hbbreviated 10 form of the materials thnt were available in the room when 11 people came in. It was in the memorandum that the staff has 12 forwarded to you. 13 CHAIRMAN ZECH: Well, explain it first. 14 MR. BELLAMY: This first slide shows the status for i 15 resolution of the school children concern and the third 16 reception center. It is evident that the required information 17 has been included in the draft plans and procedures and that 18 approval by the Commonwealth is still required for other
, 19 issues.
20 Now by complete on this slide, I mean that if the i l 21 information was supposed to be included in the plans and I 22 procedures, it is now in those draft plans and procedures. 23 (Slide.) 24 MR. BELLAMY: The next slide shows the status of 25 resolution for the beach sheltering issue and the concerns with I
- w
. o 86 1 the mobility impaired. The shelter program is ongoing, even 2 though wheltering is not specifically required. The 3 information has, again, been provided in the draft plans and 4 procedures.
5 (Slide.) 6 MR. BELLAMY: The next slide shows the status for the J 7 concerns for the transportation-dependent population and the C overall lack of progress. Once again, information has been 9 included in the draft plans and procedures with, again, certain
- 10 issues needing approval by the Commonwealth.
+11 In conclusion, the NRC review of the status of I
a.12 emergency preparedness of Pilgrim indicates that while all 13 tasks have not been completed, progress is being made toward ] r14 resolving the issues identified by FEMA in their August 1987 e.15 report. In particular, significant progress has been made in 16 improving the emergency plans and procedures for schools and i 17 daycare centers and for the special needs and transportation-18 dependent populations in the emergency planning zone.
. 19 The development of these plans and procedures, in 20 conjunction with the training program directed toward the
- 21 transportation providers responsible for evacuating school
- 22 children and the special needs and transportation-dependent ,
, 23 populations, indicates that the off-site response plans include 24 measures to protect these groups. 25 The NRC staff will continue to assess the progress i 1 l 1
. . - . . , - , - - . - - - - , - - - - - - - - - , - . - - . ,--,,,.,.n., - , - , - - , , , - . , ., -,,,,,,,,,,,.,,n . . - ----.
87 1 being made for fully resolving the FEMA-identified issues in 2 off-site emergency preparedness. 3 CHAIRMAN ZECH: Thank you very much. 4 MR. MURLEY: Our findings than on energency 5 preparedness at Pilgrim are the following. First, hasc3 on the
,6 several previous successful exercises at Pilgrim over the years 7 where FEMA has found the plans to be adequate, the 8 infrastructure to handle emergency preparedness is still 9 largely in placc. Most of the local individuals who would take 10 part in emergency actions, that is civil defense authorities, ,
11 police authorities, school authorities, have been working 12 closely with Boston Edison in developing the revised plans, as i 13 Dr. Bellamy described. 14 Therefore, it is 1cgical to conclude that those l 15 individuals can an! would implement the revised plans, even 16 though the plans are still in draft and even though there has 17 not been a full scale exercise with the revised plans. Of the 18 six major deficiencies identified by FEMA, the NRC staff has . 19 reviewed improvements in the pluns and observed come 20 demonstrations of these improvements and we have concluded thar 21 adequate progress has been made on the deficiencies. 22 Based on auccessful exercises at Yankee Rows and at 23 Vermont Yanhoe within the past year, the Commonwealth of
~
24 Massachusetts nas demonstrated capability to manage an 25 emergency at the state level. Based on the findings above
. o I
88 1 then, we believe there is reasonable assurance that even with 2 the lack of a recent ek3rcise adequate protective actions can 3 and will be taken in the event of an emergency c.t the Pilgrim 4 P.1.a nt . 5 Furchermore, we expect that the status of emergency 6 preparedness will continue to improve in the coming seoks as 7 Massachusetts and local officials continue to finalize the 3 plans in preparation for a full scale exercise.- In summary 9 then, our overall conclusions with regard to Pilgrim are that 10 the staff believes the Pilgrim Plant is substantially safer
- 11 today than at the time of the shutdown in April of 1986.
3 12 There are more licensed operators and they are better
-13 trained, a greatnr depth of management experience. There are
, -14 improved emergency operating procedures in place. There are
;15 improved safety attitudes among the plant workers. There are 16 improved conditions of plant equipment and there have been 17 nafety enhancement improvesents made. We further believe that 18 emergency preparedness is in better shape today than it was in . 19 April 1986.
20 We believe that the Pilgrim Plant is ready to restart 21 and can and will be oparated safely. We also believe, however, 22 that there must be continued progress in finalizing the 23 resolution of outstanding emergency preparedness issues. In 24 light of the extended shutdown of the plant, we will closoly 25 observe the plant and the operating staff performance as well 4 e
O ! 89 1 as the expected continuing progress in emergency planning to 2 assure ourceives that our findings remain valid. 3 MR. STELLO: We are through, Mr. Chairman. 4 CHAIRMAN ZFCH: All right, thank you very much. 5 Questions from my follow Commissioners? Commissioner Roberts? 6 COMMISSIONER ROBERTS: Two quick ones. The increased ,, 7 NRC oversight, if I've got the numbers the right, an average < 8 plan would be 2,500 to 3,000 up to 11,000, where is that coming 9 from, out of Region I o't from Washington? 10 MR. RUSS"LL: It has principally thus far come from 11 Region I, although we have had substantial support from NRR and 12 also we have had commitments from NRR to provide additional 13 support from both NRR and/or the other regions to support the 14 augmented inspection activities during power ascension. < 15 COMMISSIONER ROBERTS: Second question. Is Pilgrim 16 the only Mark I BWR to affect the torus venting? 17 MR. RUSSELL: No, sir. There are other facilities 18 which have that capability, but not hardened. That has been in . 19 existence since Revision 2 of the Emergency operating 20 Proced;1res for General Electric and the change in this instance 21 is piping systems which are designed to handle the elevated 22 pressure rather than using installed duct work associated with 23 standby gas treatment systems, which would likely fail under 24 the increased pressures. Nine Mile Point 1, for example, has a , l 25 hardened vent that is similar. Peach Bottom has a venting i l
- O 90 1 capability. Some vent paths are capable of handling the higher 2 pressures.
3 This is one that is designed specifically for that 4 purpose. It does include a rupture disk in the design. So d even though it is a vent, it would not be used until you got to
,6 elevated pressure so that there is not a potential for an 7 inadvertent release through that path.
8 COMMISSIONER ROBERTS: Thank you. That's all I have. 9 MR. STELLO: I might add, Commissioner Roberts, that 10 that's the best one we've seen. 11 CHAIRMAN ZECH: Mr. Carr? 12 COMMISSIONER CARR: Yes. I would like to ask about 13 the Area 2 state plan. You said it was submitted to FEMA for a
>14 technical review. My understanding is it was just going down e15 there for information and comment rather than for any official 16 review. Is that right?
17 MR. BELLAMY: Sir, I think that's a term that we've 18 used a great deal over the last couple of months in our
. 19 discussions with both FEMA and the Commonwealth of
.20 Massachusetts.
21 COMMISSIONER CARR: It wasn't down there for i 22 approval, I guess, is what I'm told. l 23 MR. BELLAMY: The plans and procedures and the l Massachusetts Civil Defense Agency Area 2 plan have been 24 25 forwarded with documentation from Massachusetts Civil Defense
91 1 Agency to FEMA for what they term 3 technical review. It does 2 not imply that the Commonwealth has approved those plans and 3 that caveat is in each transmittal letter. 4 CHAIRMAN ZECH: Commissioner Rogers. 5 COMMISSIONER ROGERS; Well, I've heard a number of 6 presentations here today, people from Massachusetts and people 7 from the staff and we've been asked to consider then all very 8 carefully and te weigh them in making a decision. I'm trying 9 to sort out in my own mind whether I'm hearing the same things 10 from everybody. 11 I heard that there are no plans for dealing with an 12 emergency at Pilgrim in place and that none of the local 13 agencies are ready to deal with c.ny of this. I first wonder 14 whether Massachusetts seer.s to be in that happy circumstanca 15 that it never has any nacu'tal disasters or it can unticipate no 16 natural disasters and if it does face the realit'/ of these, how l 17 does it do it if thero are no plans in place. 18 I wonder, Dr. Bellamy, if you could just say a few 19 words to try to put into some context your views and statements 20 with respect to the cooperation of local officials and their 21 ability to deal with an emergency plan with the statements thet 22 we heard from other folks from Massachusetts earlier before the 23 NRC and licenson presentations. 24 MR. BELLAMY Yes, Mr. Commissioner, I'd be glad to. 25 I think the casteat that you heard earlier today a number of
92 1 times that there are no plans and procedures in place 2 apacifically implies or specjtien11y scates that the 3 Commonwenitb has not rfficially approved those plans and 4 procedures and nent them to FEMA with that approval and until 5 the Commonwaalth gives those plants and procedures that 6 officisl opproval, they will continue to state that there are , 7 no plans and procedures in placo. 2 I have been intimately involved in this review for 9 six years. As I've indicated, the last three years have been - 10 - a lot of time spent on Pilgrim. I have personally met with 11 some of the local planning officials in the Plymouth area. I 12 have toured the Ouxbury beacbes. I have visited the local 13 emergency operating centers and thosa facilities are there and
.14 they ate ready to be used in an emergency.
15 The peaplo that are ganerating the procedurea and the 16 people that have generated the plans are the specific 17 individuals, the loca) emergency planning officials, the select 18 sen, the mayorc, fire chiefs, the civil defense directors who 4
. 19 would be charged to use those plans and procedures in the event . 20 of an emergency.
21 So, they arc aware of the information in those 22 procedures and would be prepared to use them if necessary. 23 COMMISSIONER C\RR: Do they have copies of them? 24 MR. BELLAMY: The individuals who havs be9n preparing 25 procedures at the admitiistration level -- yes, sir. Thuy do.
. . I 93 ,
l 1 COMMISSIONER ROGERS: Just with respect to another 2 statement that was made, I guess by Senator Kennedy, Dr. 3 Murley, I wonder it you could comment on his statement that you 4 had made a commitment that emergency preparation plans 5 including a demonstration exercise of such plans would be held
'6 before restart. ,,,,.
7 MR. MURLEY: Yes. That was -- what he was referring 8 to was in my testimony in Plynouth in January of this year. 9 What I said was that we would sxpect to'see progress in 10 improving the plans and that we would expect to have -- to 11 obcerve a limited demonstration of those improvements. 32 What Dr. Bellamy described -- what his staff and my 13 staff have done over the last I believe month or two have been 14 in fact the demonstrations that we mentioned. The school bus i5 drivers and that sort of activity. 16 COMMISSIONER ROGERS: In other words, you feel you 17 have -- , i 18 MR. MURLEY: Wo 61d not say -- we never had an f 4 19 intention that there would be an exercise or a limited 20 exercise. Of course, that can only happen once the state l 21 submits plans to FEMA and that gets scheduled. We did have in ! l 22 mind and we have completed our observation to our satisfaction ! i 23 that the key elements necessary to implement this plan, that 24 is, bus drivers and routes and ambulance drivers have taken
)
25 place and we have observed that. l l j
94 1 COMMISSIONER ROGERS: Is that in fact what you were 2 talking about when you made that statement?
'3 MR. MURLEY: Absolutely, yes.
4 MR. RUSSELL: Mr. Commissioner, if I could expand on 5 that because I had a meeting in Region I with various
-6 representatives from the commonwealth including the Governor's 7 office, the legislature, the Attorney General and others and I 8 described quite clearly at that meeting that there are a range 9 of ways that the staff can evaluate deficiencies. It can be 10 from a tabletop exercise. It can be from a review of the 11 plans. It can bf. from a limited demonstration with staff 12 members riding buses with bus drivers.
13 So, we made it quite clear in each case that the 14 standard we would use for judging is that which is necessary
;15 for the staff to get the information it needs to reach its 16 conclusion. In each case, the Commonwealth has taken the 17 position that they, the Commonwealth, would only be satisfied 18 with a full-scale exercise.
19 COMMISSIONER ROGERS 1 think I heard something that
~2 0 I'd like you to repeat just once again, Dr. Murley, if you 21 could. Did I hear you say correctly, energency procedures are 22 in better shape now than they were in 1986?
23 MR. MURLEY: That is our conclusion. Yes. i 24 CHAIRMAN ZECH: Dr. Bellamy, it sounds to me like l I 25 from what you're telling us is that you've received a' fair 1 l l
95 1 amount of cooperation from the state and local officials; is 2 that correct? 3 MR. BELLAMY: Mr. Chairman, the cooperation that I 4 have received is in the lines of making sure'that I'm aware of 5 the status of the information and the cooperation in making 6 sure that I know exactly who has done what, what plans and 7 procedures have been written, where they stand in the review 8 and the fact that they are going to FEMA now for a technical 9 review without the -- 10 CHAIRMAN ZECH: But you've had a fair amount of 11 interface with the local officials. 12 MR. BELLAMY: Yes, sir. 13 CHAIRMAN ZECH: And they seem to be conversing with 14 you and working with yout is that correct? 15 MR. BELLAMY: Pretty much so. I have a number of the i 16 public that call me quite regularly, that are here.today and we 17 converse probably on a daily basis. Yes, sir. 18 CHAIRMAN ZECH: Do you have any difficulty as far as i i
. 19 the local officials are concerned with articulating the federal l
20 responsibilitiec as they might be in working with the state and 21 local responsibilitieu? 22 MR. BELLAMY: No, sir. There's been no problem in 23 that area. We have held a number of public meetings up in that 24 area and I have in any number of occasions been up in front of 25 a large number of members of the public and elected officials f
-m -
96 1 to make sure that they understand the responsibilities of the
~
2 federal community, the Nuclear Regulatory Commission, the 3 Commonwealth and the local officials. Some of these meetings 4 have dragged on till 1:30 in the morning, sir. 5 CHAIRMAN ZECH: Could you talk to me a little bit 6 about the training and perhaps when do you think that the
~
7 training might be completed and could you talk a little bit 8 about any other plans and procedures that should be exercised 9 at least to the extent that you might have satisfaction that in 10 a real emergency, the public health and safety would be
.11 protected.
12 MR. BELLAMY: Yes, sir. There are approximately 300 13 as a round number of required impivmenting procedures and as I 14 indicated, there are five of those procedures that have yet to 15 be sent to the commonwealth with any type of approval from the 16 local officials. These procedures deal specifically with the 17 schoolchildren and some of the special needs populations in 18 Plymouth which is the town that the Pilgrim Station is in and 19 in Duxbury chich is also in the Emergency Planning Zone. ;
. 20 The -- to use the term, training is complete, I think 21 is misleading. You will never complete the training for t 22 emergency preparedness. Emergency preparedness is a living l
23 area and you always will be training new people and you always 24 have new people becoming involved in the process. 25 I would think that by the end of the year, there will l e
97 1 be the overwhelming majority of the 6,000 people trained that 2 have been specified in the Commonwealth-approved training 3 program. 4 CHAIRMAN ZECH: How about some of these areas that 5 are difficult to evacuate in the area. Could you discuss that 6 a little bit? 7 MR. BELLAMY: Yes, sir. I think the two specific ' 8 concerns that come up -- one is for the schoolchildren and I'd 9 like to comment on that first. The draft plans and 10 implementing procedures now indicate that at the alert stage of 11 a nuclear emergency, they will begin to assemble the necessary 12 transportation for evacuation of the schoolchildren and at the 13 site area emergency stage, they would implement that 14 evacuation. 15 That's a much necessary and needed and far-reaching 16 improvement over what's been seen in the past whereas you could 17 wait until that general emergency stage to actually consider l 18 that evacuation. The schoolchildren will be moved out long
. 19 before that stage.
20 l The beach population area -- I have toured that beach 21 population -- it is required to get on and off that beach with 22 a four-wheel drive vehicle. You could not take your car on it. 23 So, there is some limited access. There are a fair number of I _ i 24 permits that are issued to those four-wheel drive vehicles.
]
^
l 25 The number is in the several thousands and they have j l
98 1 made sure that the plans and procedures indicate that those 2 beaches will be closed at an early stage so that you would not 3 put more people on those beaches if there is any type of event 4 at the Pilgrim Station. 5 COMMISSIONER CARR: Do they overnight on those 6 beaches? 7 MR. BELLAMY: No, sir. They do not. , 8 COMMISSIONER CARR: So they must clear out between 9 high tides. 10 MR. BELLAMY: The high tida issue is for a very small 41 section of that beach and there are approximately 2,000 to 12 4,000 people at the most that would be there during a bright, 13 sunny, summer weekend. 14 COMMISSIONER CARR: No, but I mean if they can't stay 15 overnight, it's only twelve hours between low tides. They must 16 come off in 12 hours. 17 MR. BELLAMY: The low tide issue is not for every i 18 tide. That is only for flood tide type conditions. So, if you
. 19 got the perception from some of our earlier speakers that every
~2 0 twelve hours that beach is isolated, I think that's a 21 misconception.
22 COMMISSIONER CARR: Well, even if it is shorter than 23 that, that would be the longest if they have to clear out by 24 dark. 4 25 MR. BELLAMY: Yes, sir, and those beaches are -- only
99 1 approximately four hours a month. 2 MR. MURLEY: Mr. Chairman, there is one thing that I 3 would like to add that might help to clarify. The deficiencies 4 that were found by FEMA were planning type deficiencies, not 5 execution deficiencies. Generally, as I said, there have been 6 many exercises up there, both full and partial. I mentioned 7 that I personally observed one. 8 The authorities know how to do their job. Bus 9 drivers know how to drive buson. Ambulance drivers know how to 10 drive ambulances. The problems have been that not all the 11 places were accounted for in the plans that they had to go to 12 and so forth. That is what we have been focusing on, to make 13 sure that those plans are in draft form have been updated. , l 14 CHAIRMAN ZECH: All right. To -- 15 A VOICE: Mr. Chairman. 16 CHAIRMAN ZECH: Dr. Bellamy. 17 A VOICE: Mr. Chairman. 18 CHAIRMAN ZECH: Dr. Bellamy. 19 A VOICE: I wish to challenge th3t this presentation 20 has been made, and it's full of half-truths.- I'r not going to 21 stand here and listen to this, Mr. Chairman. 22 CHAIRMAN ZECH: You don't have to stand here. 23 Dr. Bellamy, you have told us that you believe they 24 have made considerable progress and there has been a fair 25 amount of interface, at least I would consider a lot of good l
100 1 working relationship between you and the people that are doing 2 the job in that area; is that correct? 3 MR. BELLAMY: Yes, sir; it is. 4 CHAIRMAN ZECH: On the other hand, how long would it-5 take you do you think or how much time would we need to make 6 the progress that perhaps would ba necessary for a little more 7 confidence that all of the emergency planning procedures could 8 be satisfied and in your interfaces, can you give us any 9 estimate of how long it would be before the state, for example, 10 would be satisfied that their procedures are in place to the 11 point where they could submit them to FEMA and we would have 12 what I would term a closure on this? Can you give any estimate 13 at all? 14 MR. STELLO: Mr. Chairman, we talked about the issuo 15 of the amount of time, the schedule it will take to complete 16 it. In my opening comments I said we talked about whether wo 17 could make that estimate. We can't. We don't have that 18 schedule. Dr. Murley has indicated that once the plans have 19 been submitted to FEMA, our estimate, with no extra offort, in 20 order to get the plans reviewed, the exercist plannod for and 21 conducted, would be about six months. How long it will bc 22 before the Commonwealth will submit the plans, Dr. Muriny has 23 indicated in our conversations when I have asked the question 24 that he has been unable to got that schedule. We will continuo 25 to try to get it. The candid answers, we don't know. I 1
101 1 COMMISSIONER CARR: Six months after submission of 2 the plans by tne state before the exercise could be scheduled? 3 MR. STELLO: Without doing anything unusual. I think 4 if we tried, we could Co better. 5 COMMISSIONER CARR Normal. 6 MR. RUSSELL: I might point out, Mr. Chairman, that 7 issue has been requested several times in correspondence from 8 FEMA to the Commonwealth requesting the schedule and the 9 Commonwealth has not responded to that. We specifically 10 requested that of the commonwealth on the October 5th meeting 11 and they would not give us a schedule at that time as to when 12 they would be willing to commit to submitting plans. 13 CHAIRMAN ZECH: Are you telling us, is it the staff's 14 conclusion that in your considered opinion that the Pilgrim i
! 15 plant is ready to re-start in view of what we have heard 16 regarding emergency planning and all other issues?
17 MR. STELLO: Yes, sir. 18 CRAIRMAN ZECH: Any other comments from my fellow ' 19 commissioners? 20 (No response.) ; 21 CHAIRMAN ZECH: Let me just say first that I would i i j 22 like to thank the Boston Edison Company for their participation 23 here today and for their addressing these issues over the past 24 months and years. It looks like progress has been made, 25 significant efforts have gone into it, management efforts as , i l l
. o 102 1 well as equipment improvements. I'd also like to commend the 2 staff for their very close and extensive work in this area on 3 the Pilgrim plant. I know an awful lot of effort has gone into 4 it, in Region I as well as Headquarters.
5 I believe that the earlier presentations we heard 6 today are important for us to consider, too. Certainly it 7 would appear from what we have heard I believe that protection 8 of the public health and safety at the Pilgrim plant has been 9 substantially enhanced by the corrective actions that have been 10 taken since the plant was shut down. 11 I'd also like to commend the continuing efforts of 12 the state and local officials for their work especially in the 1 13 area of emergency plans for the Pilgrim facility. The states' 14 ability to participate in and execute emergency planning 55 responsibilities has been demonstrated repeatedly at various 16 nuclear facilities within and bordering the State of a 17 Massachusetts. 18 I would encourage continued efforts of the state and 19 local governments in order to complete the work on the proposed 20 improvements to the Macsachusetts' portion of the program 1 21 emergency plans. I 22 I would like to thank senator Kennedy, Genator Kerry , 23 for his efforts to be here today also, Lieutenant Governor 24 Murphy for coming to appear before us today as well as 25 Representative Studds.
103 1 Frankly, from what I've heard today and given the 2 information we have heard, I would propose to my fellow 3 Commissioners that we not make a re-start vote today but I 4 would ask my fellow Commissioners to caretally consider all 5 that has been said towards reaching a conclusion considerinc 6 re-start of the Pilgrim facility. I hope we can come to a 7 timely conclusion. O On the other hand, I do believe we need time to 9 reflect on what we have heard today and perhaps a little more 10 time to make more progress to enhance what we have done already 11 towards emergency planning. 12 The commission does indeed have to have the 13 confidence that emergency plans could be executed if necessary. 14 I'd ask my fellow Commissioners if they would agree 15 with me that we not hold a vote today. Any opposed to that? 16 (Commissioners nodding in agreement.) 17 CHAIRMAN ZECH: I see none opposed. The decision in 18 that we not have a re-start vote today. I would ask Boston
. 19 Edison, the state and local officials with the involvement of 20 the NRC staff and FEMA as necessary, I would encourage you and J
21 commend you to continue working together on this emergency 22 planning issue at the Pilgrim site so that the Commission can 23 be confident that we will be making a proper decision. We need 24 time to reflect en this. That is the decision of the 25 Commission today. I would ask those who are involved in this j
a . 104 1 very important matter to continue their efforts and in the 2 meantime the Commission will reflect on this issue and we will 3 expect to be hearing from the staff as progress continues in 4 the future. 5 Anything else to come before us? 6 (No response.) 7 CHAIRMAN ZECH: If not, we stand adjourned. Thank 8 you very much. 9 (Whereupon, the meeting was adjourned.) i t 10 11 12 13 14
-15 1
4 16 I 17 .I : i 18 (
. 19 \
i
! 20 ,
i 1 21 : 1 22 l l l 23 24 25
l CERTIFICATE OF TRANSCRIBER This is to certify that the attached events of a meeting of the U.S. Nuclear Regulatory Commission entitled: : TITLE OF MEETING: DISCUSSION /POSSIBLE VOTE ON PILGRI}i RESTART PLACE OF MEETING: Washington, D.C. DATE OF HEETING: FRIDAY, OCTOBER 14, 1988 i were transcribed by me. I further certify that said l , transcription is accurate and complete, to the best i i of my ability, and that the transcript is a true and l ; accurate record of the foregoing events. (' eb l a s : 4 1
; I
- I l
Ann Riley & Associates,~Ltd. rt . 1 a
c HANDOUTS
- 1. Scheduling Notes
- 2. Boston Edison company viewgraphs
- 3. NRC staff viewgraphs
- 4. NRC Staff Summary of the Status of Pilgrim Offsite Emergency Planning Issues ATTACHMENTS
- 1. Senator Kennedy's viewgraphs
- 2. Statement by Senator Kerry
- 3. Slides submitted for the record by David L. Quaid
- 4. C.U.R.E.
- 5. "Regulatory Ferformance History"
- 6. Letter to NRC from Board of Selectmen, dated October 4, 1988
- 7. Letter to NRC from Board of Selectmen, dated September 27, 1988
- 8. Lotter to Governor Dukakis from William Griffin, Executive Secretary, Board of Selectmen, dated October 12, 1988
- 9. Letter to Senator Glenn, dated October 14, 1988, from Mary C. Ott, Citizens Urging Responsible Energy
- 10. October 14, 1988 press release by C.U.R.E.
- 11. Letter to Stephan B. Comley from Thomas Murley, dated
. October 4, 1988
- 12. Letter to President Reagan from Stephen B. Conley, dated August 15, 1988
- 13. Letter to Stephen B. Conley from Thomas Murley, dated October 4, 1988
- 14. October 14, October 6, and September 16, 1988, press releases by "We The People of the United States"
- 15. Letter to Commissioner Zach from Mary A. Dinan, dated October 12, 1988
I
- 16. Letter to Peter Agnes, Jr. from Ronald Varley, dated .
September 21, 1938
- 17. Letter to David J. Vogler from Mary Dinan and others, dated March 4, 1988
- 18. Letter to C. Martin Delano from Carl D. O'Neil, dated December 18, 1986
- 19. Letter to Barnie Yetman from Enrico Cappucci, dated February 19, 1988
- 20. Letter to Secretary Barry from patricia A. Dowd, dated
, June 23, 1988
- 21. "Implementing Procedure for an Emergency at the Pilgrim Nuclear Power Station," IP-01 thru IP-08, dated July 26, 1988 (submitted by Mary Dinan). Due to the volume of this document, IP-01 thru IP-08 will be placed'in the Public Document Room.
- 22. October 14, 1988 Press Release by the Commonwealth of Massachusetts
- 23. "Stop Chernobyl Here" poster 1 :
l i t B l 5 i i
10/14/88-SCHEDULING NOTES I TITLE: DISCUS $10N/PosstBLE VOTE cH PILGRIM RESTART l t SCHEDULED: 2:00 P.M.,' FRIDAY, OCTOBER 14, 1988 (OPEN) DURATION: APPROX 1-1/2 HR$ - 5 t PARTICIPANTS: [b1 SENATE
- 40 MIN 5
- SENATOR EDWARD M. KENNEDY (MA)
[ I l,l - SENATOR JOHN F, XERRY (MA) l 4 2 STATE GovEaNoRJ {
] -
LIEUTENANT GOVENOR EVELYN MURPHY (MA) i i House or REPRESENTATIVES j - CONGRESSMAN GERRY E. STUDDS (MA) l BOSTON Edison COMPANY {
- I
- - STEVEN J. SWEEHEY, CHAIRMAN AND 5 MINS
{ j CHIEF EXECUTIVE OFFICER i i 1 - RALPH G. BIRD 25 MINS f ii SENIOR V!CE PREEIDENT, NUCLEAR I i ! BEis 1 l VICTOR STElle 5 MiHS i i l 4 j - THOMAS MURLEY 40 MINS j - { WILLIAM RURSELL j i SAM COLLINS t l l
\
i
- i i
I 1 ! I
- ORDER OF PRESENTATIONS MAY VARY DEPENDlHG ON ARRIVAL TIME OF SPEAKERS.
I , 1 ; i ! 3 r i
l PRESENTATION TO THE COMMISSIONERS UNITED STATES NUCLEAR REGULATORY COMMISSION by BOSTON EDISON COMPANY STEPHEN J.SWEENEY, CEO and Chairma n of the Board RALPH G. BIRD, Senior Vice P resident -- Nuclear L
- October 14, 1988
#1 -
i i i i BOSTON EDISON j Pilgrim Station Resta rt Recolution i Board of Directors , J September 22, 1988 ' i NOW, THEREFORE, BE IT RESOLVED, that the management of the Company Is hereby authorized to request the j Nuclear Regulatory Commission to vote Its agreement that Pilgrim Station is ready to resta rt.
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i n I . 1 PLANT STATUS I i i j i i i' RESTART PLAN ITEMS MO&AT RESTART ITEMS 1 )
- NRC OPEN RESTART ITEMS l
l IATI RESTART COMMITMENTS '
. PLANT 90% RADIOLOGICALLY CLEAN l
I _ _ _ _ --_-_ - _ __- _ - -_
l MAINTENANCE IMPROVEMENTS i i i I ! REVISED WORK CONTROL PROCESS : 1 ! i j IMPROVED MAINTENANCE MANUAL 4 DETAILED WORK TRAVELERS ' i l PROCEDURALIZED SUPERVISOR REVIEW
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l. OPERATIONS AND SYSTEMS ENGINEERING LEAD ON PRIORITIZING WORK l i i .;
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l o, j RADIOLOGICAL CONTROLS l 90:4 CLEAN LOWER M AN-R E M GOAL: 390 1 1 j DECREASED RORS 1 PLANT MANAGER IN CHARGE OF ALARA ; i k i SOURCE TERM REDUCTION PROJECT , l INTERACTIVE SURROGATE TOUR 1 - i ) ) _ _ _ _ _ . _ - _ -_ . - - _ - _ .
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i i a i i l 8 I 4 ) MAINTAINING THE POSITIVE TREND 4 l i I COMMITMENT TO RISING STANDARDS OF EXCELLENCE i I l EM','LOYEE RECRUITMENT AND DEVELOPMENT I CONTINUED RIGOROUS SELF-ASSESSMENT ll 1 1 I l
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- I l SAFETY ENHANCEMENT PROGRAM i
i ! i ! EMPHASIZE PREVENTION OF CORE DAMAGE 1 l i 1 1 l EQUIPMENT MODIFICATIONS l REVISE EOPs TO REV. 4 BWR GUIDELINES i i - \ I i l i l i i . i 1.__ _ _ , _ _ _ - _ _ . _ . _ _ . _ _ _ _ _ . _ - _ _ . - _ . . _ _ _ _ _ - _ _ - . . . . _ _ _ _ . . - _ _ _ _ . _ . _ _ _ _ . _ _ . . _ . _ . _ _ _ _ _ -
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; OPERATIONAL READINESS LICENSED OPERATORS TRIPLED SINCE 1986 l
( I t ! SIX-SHIFT ROTATION AFTER POWER ASCENSION ! NO OPERATOR TURNOVER THIS YEAR i ENHANCED PROFESSIONALISM i i - 1 1 4 SIMULATOR ENHANCED TRAINING l I' ) l l i l - 4
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i l I t t I SYSTEMS ENGINEERING DIVISION ! l EARLY PROBLEM IDENTIFICATION i i l ROOT-CAUSE ANALYSIS j TECHNICAL SUPPORT OF MAINTENANCE i \ - i } I
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1 i i ! ) TRAINING AND - DEVELOPMENT i i ! DEGREE PROGRAMS l ) CAREER D EVEI.OPM ENT I I IMPROVED PERFORMANCE APPRAISAL i 1 I i MANAGEMENT DEVELOPMENT TRAINING
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l - _ _ _ _ _ _ _ _ _ _ - -___ _ -- - _.__.- -.-_--_ ._-____- _. _- ._ _ - - _ _
fil i i STATUS OF EMERGENCY PREPAREDNESS for l ! PILGRIM NUCLEAR POWER STATION I l i I i l ! GENERAL OVERVIEW j l l FEMA SIR ISSUES I
i - F12 I 1 i POWER ASCENSION AND TEST PROGRAM CAREFUL, METHODICAL APPROACH l NRC APPROVAL POINTS AT 5 POWER LEVELS l OPERATOR TRAINING 1 MANAGEMENT OVERSIGHT ! i i l _ - . _ _ _ _ _ _ _ _ _ _ _ _ _-_ ___ ____ _ __ _ ________ ____ _ __.__ _ ___._ .-___ ___ _ _ _ _ ___ -.___ _ _ _ _ _____ _
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- i i i' 1
I i t I i t CONCLUSION l r i PILGRIM IS READY FOR RESTART . O 9 i k I
COMMISSION MEETitiG CONSIDEPATION OF RESTART OF THE PILGRIM NUCLEAR POWER STATION OCTOBER 14, 198P,
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r PRESFNTATION Of,lTLINE PACKGROUND PFSTART CPITERIA STAFF ASSESSMENT ACTIVITIES AND RESULTS l POVER ASCENS!ON PROGRAM
. EMERGENCY PPEPAREONESS STATllS j
CONCLtJSINl 1 I ( e 4 l J f 1 1
BACKGROUND SHilTDOWN APRIL 12, 1986 CONFIRMATOPY ACTION LETTER 86-10 AND SUPPLEMENT TECHNICA.L AND MANAGEMENT ISSUES TECHNICAL AND EQUIPMENT PROBLEMS MANAGEMENT CONCERNS SALP FINDINGS OTHEP ISSUES FEMA EMEDGENCY PREPAREDNESS FINDINGS SAFFTY ENHANCEMENT PROGRAM (SEP) INITIATIVE 2.206 PETITIONS AND PUBLIC PARTICIPATION 1 e l l 2 1
? l l r RESTART CRITERJA STAT.Le AA'D FFFECTIVE MANAGEMENT AND STAFF AT PILGRIP RESOLUT!nN OF MAJOR TECHNICAL ISSUES DEMONSTPATED IMPROVEMENT IN SALP PROBLEM AREAS Mtit'TENANCE PROGRAM AND WORK BACKLOG ISSUES ADDRESSED FPC SATISFIED THAT CERTAIN EMERGENCY PLAN If1PROVEMENTS PAVE BEEN MADE O I l 1
.A i i
\ l l ! I i.
\
ASSESSPENT ACTIVITIES ARJESULTS j
- AllGPENTED INSPECTION AND PEVIEV EFFORTS I i
' l PILGRIM PESTART ASSESSMENT PANEL l
AllGMENTED INSPECTION EFFORT THR0llGHOUT SHUTDOWN PERIOD l SALP REPORT NO. 50-293/87-99 l l INTEGRATED 19SESSPENT TEAM INSPECTION (IATI) ; MEETINGS AND PUBLIC/ LOCAL CFFICIALS INPUT ! t RESilLTS l RESTART READINESS ASSESSMENT REPORT j ACRS RECOMENDATION l l-i i k
t s i I I l i l l l ! 1 ; f ASSESSMENT ACTIVITIFS AND RESULTS (cnNT) i
- 2. STABLE AND EFFECTIVE MANAGEMENT IS IN PLACE !
OPGH'IZATIONAL STRUCTUPE EXPANDED AND STRENGTHENED I FXTENSIVE MANAGEMENT IMPROVEMENTS AND STAFF INCREASES i BECo SELF ASSESSMENT Pf0 GRAM
- 2. FAJOR TECHNICAL ISSilES ARE RESOLVED l ORIGINAL TECHNICAL ISSVES THAT LED TO PLANT SHUTDOWN RESOLVED l 6
- I EXTENSIVE PLANT AND PROCEDURE MODIFICATIONS SAFETY ENHANCEMENT PRCGRAM ;
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! ASSFSSPFNT ACTIVITIES AND REstiLTS (CONT)
I 3. IMPROVEMENTS IN SALP PROBLEM AREAS ,
- PROGRAMMATIC IMPROVEMENTS IN SECllRITY,
' FIPE PROTECTION, SURVEILLANCE AND i ASSURANCE OF OVALITY RESULTED IN j CATEGORY 2 RATING (UP FROM CATEGORY 3) i i
- i
- PAD 10 LOGICAL CONTROLS RATED AS CATEGORY j 3-!MPROVING, WITH FURTHER IMPROVEMENTS !
NOTED SUBSEQUENT TO SALP l l
- 4. MAINTENANCE PROGRAt1 AND WORK BACKLOG IMPROVEMENTS l
j OPGANIZATION AND STAFFING IMPROVEMENTS [ I IMPROVED MAINTENANCE AND POST-WORK TEST PROCEDURES i ! BACKLOG PEDUCED AND PRIORITIZATION OF OPEN WORK
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! ACCOMPLISilED l i i
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I : I ! i l , 1 I I I i
! 6 l
l l l l l l l i l POWER ASCENSION PROGRAM i PROVIDES FOR DELIBERATE AND CONTROLLED RETURN l TO POWER OPERATION FIVE HOLD POINTS SPECIFIED AND NRC APPROVAL RE0tilPED TO PROCEED BEYOND EACH POINT AUGPENTFD INSPECTION COVERAGE WILL BE PROVIDED STAFF VILL FORM CONCLUSION ON EFFECTIVENESS OF f PROGRAM AND BECo OPERATION OF PILGRIM p l 7
1 ,e i 0FFSITE EMFRGFNfY PREPAREDNESS STATUS SIGNIFICANT PROGRESS MADE TOWARD RESOLVING ISSllES iPENTIFIED BY FEMA IN AUGltST 1987 l PROGRESS ON IPPROVING PLANS AND PROCEDURES FOR 1 SCHOOLS, PAYCARE CENTERS AND SPECIAL NEEDS AND , TRANSPORTATION DEPENDENT POPULATIONS IN EPZ TRAINING FOP OFFSITE EMERGENCY RESPONSE PERSONNEL IS IN PROGRESS !
! DRAFT REVISIONS OF LOCAL PLANS AND MCDA AREA 11 PLAN ESSENTIALLY COMPLETE AND SUBMITTED TO FEMA. l l DRAFT IMPLEMENTING PROCEDURES LARGELY COMPLETE.
REVISION OF STATEWIDE PLAN IN PROGRESS. ;
, NRC STAFF HAS OBSERVED LIMITED DEMONSTRATIONS i i ASSOCIATED WITH EVACUATION PLANS FOR SCHOOLS i AND DAY CARE CENTERS, TRANSPORTATION DEPENDENT '
l AND SPECIAL NEEDS POPULATIONS STAFF ASSESSMENTS OF EP PROGRESS PILL CONTINUE : ! l P 1 i*
, i i
1 i
) 8 i
O
- CONCLUSION TECHNICAL AND MANAGEMENT ISSUES RESOLVED EMERGENCY PLANNING IMPROVEMENTS MADE AUGUMENTED INSPECTION OF POWER ASCENSION PROGRAM CONTINUE ASSESSMENTS OF EFERGENCY PREPAREDNESS I
, 9
l l l October 14. 1985 t NRC Staff Sumary of the Status of Pilgrim Offsite Emergency Planning Issues A number of emergency preparedness (EP) issues have been raised since the - Pilgrim plant was shutdown in April of 1986. As a result of its self- ! initiated review (SIR) of the overall state of emergency preparedness at Pilgrim. the Federal Esergency Management Agency (FEMA) identified (August 1987) six areas of major concern in the emergency plans for the Pilgrim ten-mileemergencyplanningzone(EPZ).* Although separate from the technical and management issues which initiated plant shutdewn by the licensee and NRC Con- j firmatory Action Letters, the NRC has indicated that the progress towards resolution of these issues will be considered by the agency as a part of a l decision on Pilgrim restart. Specifically the six significant emergency pre- ! i paredness issues identified by FEMA are sumari:ed below: I i i f
- 1. Lack of evacuation plans for public and private schools and ;
day-care centers.
- 2. Lack of a reception center for people evacuating to the North. l t
- 3. Lack of identifiable shelters for the beach population.
l
- 4. Inadequate planning for the evacuation of the special needs !
population. i l
- 5. Inadequate planning for the evacuation of the transportation- l dependent population, i 1
- 6. Overall lack of progress in planning and apparent diminution in emergency preparedness.
*As a result of the specific issues identified in the existing Comonwealth and local offsite emergency plans. FEMA withdrew (8/87) its interim adequacy finding on offsite emergency preparedness for Pilgrim. The adequacy finding on Connon-wealth and local response p'ianning was issued by FEMA in September 1982.
l l
.g.
The staff has been carrying out an on50ing asses,sment of progress towards resolving these issues. In evaluating the current status of emergency plan-ning, tLe NRC staff has reviewed the revised emergency plans and implementing procedures, available to the NRC staff, which have been developed through cocperative efforts by the utility, and Ccmonwealth and local governments. NRC staff efforts have also included discussions with FEMA Region 1 staff, Comonweaith emergency planning officials and Boston Edison representatives, in addition, NRC Region 1 and Headquarters staff have rade several vicits to the site area to observe limited demonstrations, asssociated with emergency worker training, cf evacuation plans for schools and day care centers, the transportation-dependent population and the special-needs populatien. Considerable progress has been made in drafting plans and procedures for the plume exposure pathway mergenc) planning zone (EPZ) and reception center comunities to correct the FEMA-identified issues (Issues hos.1, 4 and 5). The draf t revised plans for all seven of the EPZ (5) and reception center (2) comunities have been submitted by the Commonwealth for inferral technical review by FEMA. FD.A and the NRC member of the Regional Assistance Ctanittee (RAC) have reviewed and comented on the draft plans submitted by the Common-
- wealth for the EPZ communities of Plymouth, Kingston, Carver and Duxbury, and the reception center comunities of Taunton and Bridgewater. The FEMA comments, as well as additional coerents from the Massachusetts Civil Defense Agency (NCCA),
have been incorporated into the plans and procedures drafted for these towns as well as the remainino EPZ coseunity of Marshfield. The status of the plans is sunrarized as follows:
1 4-
- 1. Marshfield - the craft Plan. Irplementing Procedures (IPs) anc Shelter Implerentation Program were authcrized by the Selectmen for submittal and have been forwarded to MCDA and transmitted to FINA for review.
- 2. Taunton - the draft Plan and Implementing Procedures were authorized by the Mayor for submittal and have been forwa-ded to MCDA and trans-mitted to FEMA for review.
I
- 3. Duxbury - all docurents are cce.plete except for two IPs. These are in draf t form and have been sent to the town planning comittee for
- review prior to submission to MCDA.
i 4. Plymouth - all docutchts are corplete except for three IPs. These i are in draft form and have been sent to the town planning committee ! for review prior to sut' mission to MCCA. i I 5. Kingston - all documents are complete and were authorized by the Selectmen for submittal and have been forwarded to MCDA. i 6. Carver - all documents are complete and were authorized by the Select-2 men for submittal and have been forwarded to MCDA.
- 7. Bridgewater - the draft Plan ano implecenting Procedures were
] authorized by the Selectmen for submittal and have been forwarded to MCDA and transmitted to FEMA for review. ] The revised planc and procedures include; 1) identification of schools, day-l care centers, the special needs population and the transportation-dependent f { population; 2) detailed evacuation procedures for these populations and 1
- 3) identification of transportatice resources. In support of the revisto plans f
) andprocedures.BECOhAsdevelopedanevacuationtimeestimate(ETE)andtraffic I* , management plan update for the 10-mile EPZ which was submitted to FEMA by the Comonwealth in March 1988 for review. The ETE study was further updated and distributed to the local planners and MCDA on August 26, 1988. SECO is also i developing, for submittal to MCOA. a traffic managewnt plan for certain areas 1
- beyond the EPZ.
i I l i 3
4 In addition to the local plans, the revision of the MCDA Area !! emergency plan
- and procedures and the revision of the Commonwealth's state-wide plan emergency plan ** and procedures which support local piens are essentially complete. The MCDA Area !! plan has been transmitted by the Commonwealth to F0MA for informal technical review. The state-wide plan rer.atns to be submitted by the Copron-wealth to FEMA for review.
Thus far the plans submitted by the Commonwe61th to FEMA have been submitted for "informal technical review." The Cenconwealth while participating in the revised plan development prccess continues to characterize all of the revised plans as "draft". In corresponderr.e with the Ccmmonwealth dated March 30, 1988 and August 22, 1988 FEMA has recognited the progress being rade in improving emergency plans for Pilgrim and has encouraged the development, by the Common. wealth, of a schedule indicating Cosmonwealth milestores for completing the overall planning process. The Connonwealth has not yet indicated when revised plans will be forwally submitted to FEMA. i The revised plans and procedures for the EFZ and reception center towns are in sufficient 1,' final form that training is oeing conducted in accordance with a
- The HCDA Area !! Plan prevides for coordination of response among EPZ and reception center comrunities, and detatis how State resources should be requested and provided to support local response.
**The State Radiological Omergency Response Plan dotatis overall coordination of emergency response, the duties of State agencies in support of local response, and the relationships with Federal agencies and adjacent States.
. _ _ _ - - . __ _ ._= _ . __
-S-1 i-i q
training program approved by the Comonwealth. Almost all of the training l f modules and lesson plans have been prepared, and tratning of emergency response personnel by Comonwealth certified instructors is well underway. General over- : l 1 view training has been conducted for many offsite organizations, and specific ; l f training is being conducted including training for transportation prcviders. l ) The NRC staff has reviewed the training prograri, including the individual lesson t i i plans, and has obsersed the training of bus and ambulance drivers freci companies { providing transportation for schools and daycare centers, special-needs popula- j I tion and transportation-dependent persons. The training includes use of l j dosimetry ard route maps, and travel on the actual routes to be used in an emer-l gency. The training progrcti is currently ongoing and most emergency response l I i personnel are expected to ce fully trair.ed in their response duties by the end ! of the year, j
. i 4
t i Regarding issut ho. 2, lack of a reception center for people evact.ating t,o ; 3 j the north, the Comonwealth has tentatively designated a state run facility in ; c j the town of Wellesley as the northern reception center and is currently con-i ducting a feasibility study to deterviint: if the facility is suitable for a j j reception center. This study is espected to 'ce completed in several weeks and, ! J - l
- if the results of the study are favorable, the Comonwealth has indicated that l it will undertste capital irprovements and procedure gavelopment. As a ;
i l related matter, Boston toison has performed an analysis that concludes that ! theexistingtworeceptioncenters(TauntonandBridgewater),withappropriate 1 i renovations and additional equipment, have the capability to support an evacus-j tion from the EPZ. The Commonwealth has not yet authorized these is9roverents
- and has indicated that it will pursue developeent of a third reception center.
I 4 1
0 61) 4 1ssue No. 3, lack of identifiabic shelters for the beach population, letter to the Commonwealth dated August 22, 1988, reiterated its 10 supported by the NRC, that "a range of protective actions" could be > ' - ...-ted by evacuation alone for the beach population. The FOMA positinn on , shelters for the beach population was developed subsaquent to the issuance of FEMA's Pilgrim report in August 1987. Thus the issue of shelters for the beach ; population has been removed as a concern by FEMA. Prior to this determination, BECO completed a shelter sur vey and developed a shelter implementation program, including shelter identification, letters of agreement, a'nd shelter procedures. BECO has indicated that, FEMA's position notwithstanding, it will contine? it's shelter program for the beach population. issue No. 6, ove.rall leek of progrest ar.d support in emergency preparedness, is being reso'Ived by the progress 5eing made in correcting the other specific FEMA-identified issues including the development of revised State plans, in summary, the NRC revien of the status of emergency preparedness at Pilgrim indicates that while all tasks have not been completed, progress is being made ; toward resolving the issues identified by FEMA in their August 1987 report. Tn
- pcrticular, significar , progress has been nade in improving the emergency plans ena procedures for schools and day care centers and for the special-needs and transportation dependent populatioris in the EPZ. The development of these plans e.nd procedures, in conjunction with the training program directed teward the transportation providers responsible for evacue. ting school children tnd the special needs and transportation dependent populations, indiceter that the off- '
i l 3 l 4
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1 l l 1 sits response plans include measures to protect these sensitive groups. The NRC plans to continue to assess tlie progress made toward fully resolving the . FEMA-identified issues in offsite preparedness. f Regarding the scheduling of an exercise, Boston Edison was granted an exemptior, from conducting a full-p3rticipation exercise because ongoing improvement efforts in the offsite response plaris were not complete. A full-participation i-i emergency preparedness exercise will be required to be conducted, in accordance t i with the regulations, upon the completion and submittal of the revised plans and i procedures by the Commonwealth to FEMA. l l l l I L i i
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b ATTACHMENT 1 Senator Kennedy's viewgraphs*
*Viewgraohs condensed. Original copy is on file at the Office of the Secretary, NRC.
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s ATTACHMENT 2 Statement by Senator Kerry d r l r f i e i i n
Statement by Senator John Kerry before the Nuclear Regu.'t.ory Commission regarding the restart of the Pilgrim Nuclear Power Plant October 14, 1988 Mr. Chairman, I want to thank you for giving me the opportunity today to testify before the Commission on an issue which is so important to me and the citizens of my State, the issue of whether or not the Commission should ; vote for the restart of the Pilgrim Nuclear Power Plant in i Plymouth Massachusetts. Before I begin my testimony, 1 however, I must also express my deep disappointment that the J ' Commission has decided not to allow local elected and public l safety officials to present their views today. As you know, the Commission has denied itself the opportunity to hear from those citizens with the greatest expertise and knowledge about an issue that should be of tremendous concern; whether restart of this plant before a tested and approved emergency plan is in place threatens the health and safety of the communities surrounding Pilgrim. l / I would also once again like to state that opportunities for public input to date have not satisfied the
2 Commonwealth's request for a full adjudicatory hearing on the adequacy of emergency preparedness and containment problems. I believe that the Commission har failed to provide sufficient opportunities for meaningful input from the surrounding communities, and has only reduced its own access ; to valuable information. As I and my colleagues have stated repeatedly, the recent history of the Pilgrim Nuclear Power Plant is one of failure and neglect. Served with the largest penalty ever issued by the Commission, the plant was closed in April, 1986 because of repeated failures of its emergency equipment and for chronic management problems. Even after the shutdown, the plant continued to experience serious safety problems, including the loss of off-site power, as late as November, 1987. Since the shutdown, a great deal of time and money have been spent addressing these problems. Boston Edison has undertaken an extensive upgrade and management improvement program. The NRC staff has spent considerable time inspecting and reviewing the plant. At Governor Dukakis' initiative, the state has established a unit devoted l exclusively to nuclear emergency safety. And local public
- cafety officials and selectpeople have spent thousands of -
1 l hours in an effort to develop workable off-site emergency plans. No doub,t, all involved in the process are working l
"O b 3 i toward making this facility safe from the rtandpoint of
. public health and safety. While I applaud these efforts, this process is far from [ complete, and I believe that today's hearing'is premature. l The NRC should postpone its decision until all outstanding safety issues have been adequately addressed. ; i Most important is an issue that the NRC has not addressed l ) in any meaningful way - offsite emergency preparedness. 'l Despite the extensive efforts by civil defense officials to prepare workable emergency plans, their task is far from complete. At a recent public meeting conducted by NRC i Region I in Plymouth, Massachusetts, Commission staff indicated that "progress has occurred in drafting upgraded plans," and that " FEMA and RAC have reviewed and commented on ! some draft plans." While technically accurate, these j statements present a picture that is far too optimistic. ! Because they are unable to speak for themselves today, I would like to quote some of the people who have worked 3 diligently on preparing workable plans. At a hearing *
\
) sponsored by the Massachusetts Office of Public Safety.on , Octobea 6, public safety officials were unanimous in their opposition to the restart of the plant until tested and li 3 approved emergency plans are in place. ,
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o . 4 Mrs. Alba Thompson, Chairman of the Plymouth Board of Selectmen, stated that "Plymouth, while working every day on planning issues, has no accepted plan and even our draft document is lacking in implementing procedures for police, for fire, for our hospital and for our schools, the very core of preparedness." Mr. Daniel MacDonald, Selectman of the Town of Marshfield, stated that the claim by an NRC official that Marshfield's plans have been approved by the Selectmen was false. "It must be clearly understood that the Marshfield Board of Selectmen has not approved or endorsed the plan. We still have major reservations regarding its' viability." Mr. John MacMahon, Chairman of Marshfield's Board of Selectmen, eloquently summed up the situation. He said, "this is not an issue about the merits or deficiencies of nuclear power. This is not an issue about Boston Edison's efforts to date, to improve the structural integrity of their facility...The only relevant matter before the Board of Selectmen...is whether or not we have a workable plan to safely evacuate our citizens in the event of a radiological accident at Pilgrim Nuclear Power Plant. The answer is emphatically, no." 1 1 And Mr. Dennis Tavares, Civi Defense Director of the Town of Kingston said, "Until we have an approved plan, until we 1
. o 5
have all our personnel trained, until everything is in order, I think that it would be foolish for me, as Civil Defense Director, to ray that we are 100% ready." These comments come from people who have worked long and hard on this issue. They have both professional responsibility and personal concern for the safety of all residents in their communities. They have made considerable progress on improving plans that FEMA found to be wholly j inadequate in August, 1987. However, they have all concluded , that these plans, as they stand today, could not protect their communities in the event of an accident. L Further, the Commonwealth Office of Public Safety has recently issued its own report finding that progress on 1 ? emergency preparedness is incomplete, and that only through a successful, full-scale emergency exercise of all off-site emergency plans will the adequacy of thosu plans be able to be assessed. These are the agencies and ind' iduals who must respond in , the event of an emergency. These are the people responsible . for the movement of children, the elderly, the handicapped, l and those in hospitals, for whom there are no tested plans. ; By granting a restart license today, you give them the responsibility but none of the' tools. Plans approved only in concept, plans without the necessary equipment to implement
6 them, and plans which at the present time leave out entire portions of the population are, in reality, no plans at all. 7 am aware of the fact that NRC regulations do not require an approved emergency plan for facilities licensed before Three Mile Island. But I am also aware that the mission of the NRC is to ensure the safe operation of commercial nuclear facilities. And the NRC itself has already indicated in the case of Pilgrim that emergency preparedness is an important, although not determinative, issue. I urge the Commission not to ignore the overwhelming evidence that emergency planning is still too incomplete to support the restart of this plant. I would also like to raise two other critical issues which I believe have not received the full attention that they dese rve . First, I was deeply disturbed by the most recent SALP report, covoring the period from February, 1987 through May, 1988, which indicated only modest improvement. Most disturbing was the fact that the rating for Radiological Control remained at the lowest level, despite Boston Edison's efforts. The report cites recurring problems, including the loss of off-site power and inadequate procedures and guidance for technicians. In spite of these continuing problems, the NRC granted Boston Edison's request for an Integrated Assessment Tean: Inspection in August of this year. While I have no doubt that this week-long inspection was thorough, I
e . 7 seriously doubt that adequate improvements have been made in areas found deficient in the SALP report just three months earlier. In addition, I am extremely troubled that serious concerns i regarding the Mark I containment have yet to be addressed by the Commission. Despite the fact that last January, Brookhaven National Labratory Report raised serious safety , concerns with the containment and despite the fact that this report was presented to the Commission, -- to date, no final I decisions have yet been made. It is my understanding that the Commission does not plan to take up this issue until December of this year. If that is true, why are we considering restart? No restart of Pilgrim should be made until the Commission has addressed this critical problem. Secondly, however, I am very concerned about how the Commission plans to integrate the backfit rule, which asserts I that if safety improvements are not "cost-effective" they need not be implemented despite their safety value. The
, backfit rule should not be used to allow this plant to avoid making safety-related improvements which might not be cost-effective because the plant is back on-line.
l Finally Mr. Chairman, as you know the show cause petition d filed by State Senator William Golden and the Massachusetts Public Research Group in July 1986 was denied by the Commission on the issues of emergency response plans and
- O 8
design flaws in the plant's containment structure. On appeal, the First Circuit court determined that these issues were not subject to judicial review but stated that "the NRC will not allow the restart of Pilgrim until the deficiencies are resolved to its satisfaction." With untested, incomplete emergency response plans and unresolved containment issues, the Comsission can hardly state that these deficiencies have i been resolved. Unfortunately, it appears the the Commission may do just that. I urge the Commission to prove the court right and to postpone its decision until these issues are fully resolved. i i a 1 e . . t
. o ATTACHMENT 3 Slides submitted for the record by David L. Quaid l
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. o ATTACHMENT 4 C.U.R.E.
l 4 I i
Pdgrim StEon Docket No. 50-309 REGULATORY PERFORMANCE HISTORY As produced by the Subcommittee on Energy Conservation snd Power of the Committee on Energy and Commerce A tabulation of significant rnilestones and enforcement actions The following is the regulatory history of the Pdgnm Nuclear Power Plant:
' June 1972 issued operating license.
- December 1973 ShutdowTi order issued to irspect for and repair fuel channel bos damage.
- December 1974 Fuel Failure: Hydridmg and pellet-clad interacuon failures resulted in high gaseous ac6vity.Operauon with fuel claddmg perfors.
bons resuhed in high dose rates in locations requinng access for operadon and maintenance. During 1975,76, snd 77, power m as hmited between 60 80% to rnaintam of fgas acuvity within regulatory requirements. The last of the defecuve fuel bundles w as rep! aced during the 1977 refuebng outage.
- May 1975 A civil penahy (014,000) w as assessed for violations concernirg insersice inspection activ ities identJwd during an inspcuon conducted recember 1974 Febniary 1975.
- July 1976 Management meetmg to discuss concerns related to the management and the implementanon of the Heahh Ph> sics Program.
- October 1976 Management meeting to &se .ss concems related to the management and the irap;ementabon of the Health Phy sics Program.
- November 1977 M anagement meeting to res iew heensee efforts to strengthen Rdation Protection Program.
- March 1978 A civil penalty (516,000) m as assessed for violations iden6fied in inspection report 50-29307 31.The violations wcre: os er ciposure of one individual; failure to instruct personnel in accordance with 10 CFR 19; failure to perform required air sampimg; and failure to follow proce.
dures. ,
- September 1978 Management meeting to discuss concerns on recent impcetion findmgs (all areas)
- September 1979 Management mecims to discuss violadon of pimary containment integrity.
- October 1979 A civil penalty (55.000) was usessed for a violanon idenufied in inspection repen 50-2930915 involsing a failure to follow Secunty Plan.
- February 1980 A civil penalty (55,000) was assessed for shi l ping ra&oacuse materials with estemal radiation levels in excess of regulatory limits.
*Much 1981 (S ALPJ Management mecung to discuss the resuhs of the S ALP for the period January 1,1980 to December 31.1980.
*Arnl 1981 A cisd penahy ($13.000) w as assessed for events sunounding mosement ofinadiated fuel without secondary contatnrnent as iden6fied in inspection rep 3rt 50-293/80-09.
- July 1981 a management meetmg w as held in July 1981 to dacuss concems for TM] Ac6cn Plan Itenu involvmg post accident samphng pocedures ad equipment and an immediate Acdon Letter w as issued regardmg implementadon of these items. Meedng w as promped by a June 1981 radiadon protecdon inspection (50-29341 14) which found the licen ee fuled to conf. n with NRC cnteria in connection with 4 of 5 NUREG.0578 Category A items uupected.
- June Sep 1981 Insgcuens 50-293/81 18 and 8182 idenufied sin problens; inoperable combus6ble gas control system; fadure to grform an adequate 50 59 reviem; fidure ,o prov ide appopiate pocedures and drawings; failure to make a report required by Technical Specificadons; failure 4 to Fovide accurate information to the NRC; and failure to satisfy a Limiting Con & don for Operation (LCO) regarding primary containtnent isolation valves. T%c inspec6ons sere subsequendy the subject of enforcement acuons taken in January 1982.
*'.1rAug 1981 A performance AppaisalImpection (50-293/8120) found 6 of 8 areas esamined below average.These were: committee activides; quahry assurance au&ts; mairitenance; correcuve aedon systems; bcensed and non licensed trairung; and pocurement. Plant operations and design changes and rno&ficauor:s were found to be average; howes er, significant weaknesses mere iden6fied in both areas.
*Octokr 1981 Enfc cement conference to dacuss management controls of safety related activities including the violauom ,denufied during inspec.
bons 50 293/81 18 and 8182, the Performance Apprusal Inspecten result, and in intenm S ALP review (priod Sepember 1,1980. August 31, 1981).
- January 1982 Civd yna!ty (5550,000) usessed for folute to cornply with requirements of 10 CFR 50.44; submittal of false infonnatbn to NRC eM subsequent delay of nonfication to NRC of known inaccurate information; and failure to comply with LCO for RCIC containment isoladon s alv e,.
(PlP) Order mWifyms hceme required liceroce to submn a ecngeheruive plan of action that would yield an indegndent appraisal of saa and corperate management, ruommendations for irr povements m management controls and osersight, and a review of pevious compbanr4 with NRC requirements. Managemeru meeung to escuss ineptementmg requirements of the NOV/ pop > sed civil penahy ard ocder modJying licerise regnrdmg the indepeM. era appaisaJ of Boston Edisco Company (BEco) management pacuces.
- January 1982 Inspation report 50-293/81 26 iden6fied a sev erity lev el til violauon for eransponstion of
- adioactive matenals sith liquid in the conteners. Thu = wlauen m u based on an inspecton in August 1981 by the State of South Carohna wh2ch resuhed in issuance of a cis d penalty (11,000)
*Manh 1982 Bostm Edson Company (BECo) submated the Performance impos ement Program (PIPJ required by the January 1982 Order, j NRC Management rneetmgs to review status of the Performance impovement Program were held apsuumately escry us wecks unul September 19&4.
*Jone 1982 A speaaj mspecnon (50-293/52 20)corducted of twensee acuens a^ct rdoacuse spent tesin wu found on roof tops and paseraent i
e a withm the proted stes. No violadons identified. Confirme ory Acuon letter issued conceming actions to be taken regardmg the spent resin.
- July 1982 Enforcement Conference to discuss exceedes an LCO associated with the Raaet,,r Protection System s ater level instrument:Uon. i
- August 1982 Enforcement Conference to dacuss esceeding an LCO asscciated with the Vacuum Breaker Alarm System.
- September 1982 (S ALP) Management meedng to dacuss the results of the 5 ALP for the period September 1,1981 to June 30,1982.
- August 1983 A sha:Jos n orJcr w as issued requinns the licensee to shut down in December 1983 and inspect the rectreutuian system pip.n; fer .
Intergranular Stress Corrosion Crocking. h required them to remain in coM shutdown und' authorized to restart by the Director of NRC.The licetaev replaced the recirculadon system pipeg and w as aathorized to restart in December 1984. *
- September 1983 (SALPn Management meetet so dacuss the rewits of the S ALP for the penod July 1.1982 to June 30.1963.
' November 1983 Management meeting to discuss refuehng8 pipe replacement preparabons.
' January 1984 confirmatory Action Liter issued regarding Ikensee actions reistise to health physics pactices following the dacosery of small. ,
highly rMioacdve sources in the control rod dnve repair room. ,
- February 1984 Enforcement conference recwding the uncontrolled handling of small, highly radioactive sources in the control rod drive repeir room.
*Arn! 1984 A civil penalty (540,000) w as usessed for problems in connection =ith the uncontrolled handling of sme", highly radioective sources in the control rod drive repair room betw een January 14 and 18,1984. The violation invobed identified problems with the labeling of containers, the 4 u.e of entremity d3simetry, and the adequacy of instructions given to individuals working in the repair room.
- September 1984 Management meeung to dacuss a second instance of the uncontrolled presence of small. highly radioactive sources in the control -
tod drise repair ronm. i
'OctoWr 19M Enforcement conference on the unplanned entremity exposu.e (within regulatory lunits) connected with the small, highly radioacdve i sources in the control rod drive repair room. (Follow.up to Septernber 1984 management meetings on same subject.)
Confirmatory Action buer issued in connection with recurreg radiadon protecnon pogram weaknesses. Ti.e lener outtmed licensee plans for evaluadnr and conectmg these weaknesses.
'Nevember 1984 An croct modify tng the beense w as inucd m connection with recurring wcaknesses m th: radiation potection prograr.s. The order required the hceruee to complete an independent contractor assessment of the radiological controls pogram ard to submit to NRC review and
! appro al a Radiological Imprm ement plan (Rip) for upgradmg the radiological controls pogram. Follow.up mspections conducted in May, August. : ard Nosember 1985 and April 1986. l A severity Level 141 violation (ao civil penalty ) wu issued for failure io perform radiation urv eys; failure to instruct w orkers in accordance sith 10 l CF R 19. and faalute to properly implement a procedure m connection with the unplanned esposure noted above. f Enfersement conference to dir:uss wcakmsses in the control and monitonns of neutron Mrumentstion during refueling operations.
' January 1985 (SALP) Management meeung to discuss LN resu!Ls of the 5 ALP for the pm haly 1.1983 to September 30,1984.
I Enforcement conference to dccvss an unplanned occupauonal radianon exposure within regulatory limits assocised with sludge. lancing operadons on a w aste tank as identified in mspecuan 50 293/8441.
- August 1985 Enforcement conference to discuss licensee's a: tion on abnormal surveillance test results and a degraded vital area hrrier.
' October 1985 A civil pen.lry (550,000) was assessed for the degraf auon of a vital area barrier. .
' November 1985 A safety system functional tearn inspecdon (50 293/85-30) was conducted by the Office of Inspection and Enforcement to nuess 1 the operational readmess and function c.f selected safety systems.The utspection ideritified the the hcense had noe affectively rnidgated a water ,
i hammer poblem associated with the HpCI turbine exhaust bne which had been occumns since the beginning of plant operation. Weaknesses were ' j ' also idenufied *ith the bec a e's design change pocess; control of plant mstrumentation; handhng of vendor informayon; program for appoving l and wahdaur.g emergency o :taung pocedures; capebthty to conduct a plant shutdowt from outside the control room; and maintenance pogram for l l' rnotor operated valves. - l
' February 1986 Inspection retort 50 293/8444 identified a seventy level III violation for failwe to meet peckaging requirements for low specific ;
activity radioactr e materials. Thts violation w u based on an inspecdon in January 1986 by the Sta e of South Carolina which resulted in issuance si l , a civil penalry ($1.000).
' March 1986 (5 ALP) Managernent meeung to daeus: the results of the $ ALP for the reriod October 1,1984 October 31.1985.
- 'Fe>M arch 1986 A special diagnos6c team inspect 4on (50-293464)6) = as corducted to d:eeemine the underlying reasons Ice the bcemee's poor !
] performance described in the mu recent S ALP and to ucertain whether they could have an ariverse impact on the safety of plant operations.
'Apil 1986 An AugmentedV n 'on Team (AITsconducted an inspection of recent opera 6ons events which included:
I) the sparious group one pirnary contamment is.Juions (ard associued reactor scrams) that occwred on Agesl 4 and 12.1986; i 2) the failure of the main sieam isolence valvea io pomptly reoper, after the containment isolations, ana J 3) the reewrmg pesswissuons of the residual heat remov al system. l 4 The AIT found the bcensee's ev aluauons follow mg the second event to be carefully structured and thocough. 44 Confirmswry Action laust conceen. l t:s the evenu = as inued w hich required the licenses to povide a wntteri repon por to restart containing the resuha of the evaleason and corrective actions. The CAL also required Regiona2 Adtruniurstor authoruanon for rutart. 1r.specuce (50 29M610) reviewed implemenudon of the RIP.The mspctaen found the bcenses siequately m$dretted 13 of 34 nems reviewed.- 1
'May 1986 Management mee6cs to discuss evaluauens and cortective actions oncerning th operadonal eventa of Agil 4 and 12,1966.
j
- June 1986 The first in a planned series of management meetings schehled to review BECo management oversight of the implementauon of the i luensee impos ement postams in progress.
FOR MOR E INFORMAT10N CONTACT: DUXBURY CURE P.O. BOX 062I l DUNBURY. M ASS ACUSE1TS 02331
, O J.
ATTACHMENT S "Regu3 atory Performance IIistory" . a e
C.U.R.E.
- Box 2621 Duxbury, MA 02331 We urge you to write to any or all of the following officials stating your concems regarding the safe operation of Pilgrim Nuclear Power Station.
Governor Michael Dukakis Stain Senator William Golden Room 300 Room 416B State liouse State llouse Boston, MA 02133 Boston,MA 02133 727 3600 '122 1646 - l U.S. Congressman Gerry E. Studds Peter Agnes 237 Cannon llOB Asst. Secretary PubP.c Safety Washington, DC 2051f- 1 Ashburton Place, koom 2133 826-3866 (Pembroke, MA) Boston,hiA 02108 ' 727-7775 , U.S. Senator Edward M. Kennedy [ Room 2400A Edward Thomac t J.F.K. Federal Building Federal Emergency Management Agency ; Boston, MA 02203 422 J. W. McCormick Bldg. l 565 3170 Boston,MA 02108 i ( i State Representative Charles Mann Nuclear Regulatory Commission Room 489 Lando Zech i State llouse 1717 H Street, NW , Boston, MA 02133 Washington,DC 20553
- 722 2000 L
Robert Boulay U.S. Senator John F. Kerry Director / Mass. Civil Defense Agency - Room 3220 400 Worcester Road l Transportation Building P.O. Box 14% 10 Park Plaza Framingham, MA 01701-0317 ' Boston, MA 02116 , 565 8519 i i Duxbury Citizens Urging Responsible Enugy (C.U.R.E.)is a non profit grassroots, action group formed in i September of 1986 to educate and inform members and the public as to the public health, safety, and environ- ! mental dangers inherent in the irresponsibic use of nuclear energy. We are not anti nuclear. 'Ihe group is not. , affiliated with or supported by utility companies. Membership is open to all. *Ihe group is made up of doctors, l lawyers, hormmakers and even nuclear engineers who support the common goal of keeping the Pilgrim Nuclear Power Statios. shut down because of unresolved safety, evacuation, and health concems. For more infonnation or to ask about other ways you can help, please telephone 934 5574. Donald M. Muirhead Jr., M.D. Mary C. Ott : Co-Chaimien
. - - .- .-. - ,_-.__ _ . - l
The following information is for you to consider,if you e:rlsh, when writing officials listed on the reverse ! side of this sheet, PLANT DESIGN- The Pilgrim Nuclear Power Station (PNPS)is a boiling water reactor (BWR) with a GE Mark I containment structure. Even the Nuclear Regulatory Commission (NRC) said in a recent risk assess-ment study,"In 9 out of 10 types of serious accidents, the GE Mark I would fall- the small containment shell would not be able to withstand high pressures of steam or gas - the shell would crack with resultant release of radioactive gases into the atmosphere." Boston Edison Company (BECo ) says that they have resolved the problem by spending 30 million dollars on a Safety Enhancement Program which includes Direct Torus Vent-ing. But the NRC has halted construction on this improvement, saying in Ohio (Ju'y,1987) that they were dropping specific solutions proposed last year because of uncertainty about unintended side effects. Dese same officials say that they have no plans to do anything about the problem soon, even though they concede that the nation's 24 Mark I's,if new, would not be able to obtain a license unless dramatic changes were made. M AN AG EM ENT RECORD - Since its licensing in 1972, Pilgrim's management has been, and continues to be, a serious regulatory concern. The NRC has rated Pilgrim among the ten worst licensed reactors in this country (109 current total), in a "show cause" petition filed with the NRC, Governor Dukakis and A orney General James S hannon point out that the "short term solutions B ECo has adapted in response to criticism have invariably permitted i the re-occurrence of original problems." , l January,1982- Edison was hit with the highest fine in the history of the NRC $550,000 for majordeficiencies l in management controls. The details behind this fine were outlined in a "Report to Congress on Abnormal l Occurrences (NUREG 0090, Vol. 5). Associated with this fine was a violation for submitting false information to i the NRC. De most recent S ALP (Systematic Assessment of Licensee Performance) report from the NRC says in i part... The lack of a clear organizational structure, recurring management changes, and chronic staffing vacancies , ] delayed the establishment of a stable licensee management team at the plant and inhibited progress..." Since that report, eight key management people have left Pilgrim. EVACUATION PLAN - We do not have one. Duxbury Selectmen, State Secretary of Public Safety, the Governor, and even the Federal Emergency Management Agency have withdrawn their approval of the 1985 plan, stating that it is "not adequate to protect public health and safety in the event of an accident at Pilgrim." Glaring deficiencies include:
,
- A lack of evacuation plans for public and private schools and daycare centers. :
!
- A lack of a reception center for people evacuating to the north.
]
- A lack ofidentifiable public shelters for the beach population. ,
!
- Inadequate planning for the evacuation of the special needs population. *A l
- Inadequate planning for the evacuatien of the transport dependent population. ;
- An overall lack of progress in planning and apparent diminution in emergency preparedness.
. I WASTE STORAG E - A federal repository for high level waste has never been sited, therefore all the high level radioactive waste that Pilgrim has generated since it began operation in 1972 is presently stored on site in a spent i fuel pool, and amounts to well over 400 tons. The spent fuel pool was originally designed to store 880 spent fuel l aswmblies, yet with NRC permission, Edison has "reracked" to accommodate the current total of 1,320. '
.n IIEALTH ISSUES - Although a conclusive link has not been found,' Pilgrim's history of abnormal releases of radi.stion into the atmosphere have heightened suspicion of the connection between the plant and the alarming increase ofcancer in towns downwind, ne State Department of Public Health issued a report confirming the cancer l increase. Because the report was widely criticized for omitting crucial data, a new study was promised two years j sgo. The new report, yet to be released,is to include more recent data, causal factors, occupational risks, and a study of cancer incidence in communities near nuclear power plants in New England. The Department of Public licalth
! however, has recently confirmed the wind theory stating that "winds blow onshore and these winds would (r Ty)
Pilgrim plant power emissions over populated regions."
I ATTACHMENT 6 Letter to ??RC from Board of Selectmen, dated October 4, 1983 l
/ TOWN OF PLD10UTH OFFICE OF SELECTM EN C
u - THE SELECTMEN =1rdi4RS 11 Lincoln Street ALBA C. THOMPSON Chairman 1D wnuAM R cRimN Plymouth. Massachusetts 02360 {gpg}[,^y EXECtJTWE SECRETARY (508)747 1620 October 4, 1988 Nuclear Regulatory Commission Washington, D.C. 20555 Gentlemen: 1 The Plymouth Board of Selectmen is astonished to learn that the' Nuclear Regulatory Cemmission has requested Boston Edison ; to appear in Washington on October 5, 1988 to discuss off- ' site emergency preparedness and to provide a written description of Boston Edison's "Outrent understanding of the state of the of f-site program and t status of the issues ( raised in FEMA's August, 1987 "Sei.. .nitiated Response." { Why is the "current understanding" of a utility seeking restart of the Pilgrim Nuclear Power Station a valid basis for judgement? Since the utility is not responsible for off-site preparedness and the Town of Plymouth h , why was the Town not invited to testify at the October 5, 1988 meeting? We repeat here the findings of FEMA's Region I, August 22, 1988 in*a letter responding to Charles V. Barry, Secretary, Executive Office of Public Safety; Commonwealth of Massachusetts concerning radiological off-site emergency planning and preparedness for Pilgrim and quoted to this
, Beard by FEMA, Washington, D.C. in its letter to us under
, date of September 9, 1988: ". . . reviews indicate j;jlgt, there .lLa_g b,een some proaress made ,[D improvina ,gnd uparadina local plans. Overall, however, ib.2 plans remain incomplete, Ms h s p e c i f i c d e t a i l s .iD c e t t a i n a r e a s , puid ,d,q ngj; i n c l u d e required implementina procedures." (emphasis added). It should be clear to your Commission from the above as to the truth of the status of off-site radaological planning in this and other communities in the EPZ. This Board knows tne truth far better than any utility which ( will, without doubt, seek to put the best face on a dangerous situation. That you should ask it and not a town official to tell you the present status of the Town of Plymouth's emergency planning is to lose credibility.
J . . 1 J
, ( Nuclear Regulatory Commission October 4, 1988 i Page 2 .
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We thoroughly question the validity of this course of action ! and deny that you can arrive at the truth of areas under our : jurisdiction by asking for "current understandings" from { Boston Edison. ; i i
- Indeed, we are astonished that you should do so while !
ignoring our own officials' "current understandings." de J refer to our civil defense director, our chairman of our r Radiological Emergency Response Planning Committee, and to l our selectmen who are responsible for writing, implementing, ; testing, and approving our plans. ; J ! We invite your response, but more particularly we urge you to (
; consult with Plymouth's Board of Selectmen and our Civil 1 i
Defense Diiector, and our heads of departments if you are i truly interested in the status of emergency planning in this 1 community. Any other course avoids t'te f acts. That surely
! (_ cannot be your purpose.
i Very truly yours ; ) BOARD OF SELECTMEN j I i 4 i Alba C. Thompson ; } Chairman j I t i ACT/lt ! j 4 ; 1
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ATTACllMENT 7 Letter to NRC from Board of Selectmen, dated September 27, 1988 ($ I 1 i i 1 l l 9 L 1 ^ l l l
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TOWN OF PLYMOUTH g' OFF1CE OF SELECTMEN EN,,
\ '
THE SELECTMEN 11 IJncoln Street
""$'ondonas" ALBA C. THOMPSON Chatrmati
%1LLt\M R cRIFRN o oRGE CAM oN EXECLTTIVE SECRETARY (508)747 1620 J
September 27, 1988 Nuclear Regulatory Commission Washington, D.C. 20555 Gentlemen: We, the Plymouth' Board of Selectmen, have tried in every way to apprise you of the fact that this community does not have ; an approved nor tested radiologigal response plan in being. , , L We have repeatedly advised you that the Pilgrim Nuclear Power l Station ought not be permitted to restart until the citizens ; of this town are protected by a response plan in the event of t i J a major accident. j j We have many times testified, witnessed, and written to this effect. The Nuclear Regulatory Commission, its staff, the 1 Faderal Emergency Management Agency, the Reactor Safeguards ,
) Committee, and the Commonwealth of Massachusetts,are well
- informed of our position.
The Board of Selectmen of the 45,000 inhabitants of the t j historic town of Plymouth, all of whom live within ten miles of the Pilgrim Nuclear Plant, now reiterate our position that until an approved radiological response plan is in place, the
; plant ought not be given permission to restart.
l Not once in the past three years has any official of the NRC r not of FEMA visited this community to monitor the conditions ; 1 of cur readiness to respond to nuclear emergency or to : consult with our Civil Defense Director or any elected ;
- official. Yet 20,000 hours of inspection have been recently 1 completed by the NRC at Pilgrim. This is a deplorabl'e ratio 1
of concern, particularly since we have been told at public i hearings that the NRC would indeed consider emergency L; planning prior to restart. 4 I
Nuclear Regulatory Commission September 27, 1988 Page 2 l l We who have sworn to uphold the public safety and who know l best the circumstances of the community remind the NRC that l all the technical evaluations do not outweigh the necessity l to consider the public health and safety. Let it be known that the full weight of decision rests with the NRC, and we hold it accountable in this matter. Very truly yours, BOARD OF SELECTMEN Alba C. Thompson . Chairman ACT/1t cc Congressman G. Studds Senator J. Kerry Senator E. Kennedy ' Secretary Barry, MA Department of Public Safety State Representative P. Forman State Senator E. Kirby FEMA Plymouth Civil Defense Director
t < l f i e i i ATTACHMENT 8 Letter to Governor Dukakis from William Griffin, Executive Secretary Board of Selectmen, dated October 12, 1988 1 L l
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9 L t i i 1 l
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o TOWN OF PLYMOUTH , OmCE OF SELECTMEN THE SELECTMEN 111.incoln Street "fnLs Attu c. TlioMI' son chairman Plymouth, Massachusetts 02360 DF
%1LLMM H. GidmN U^ygc5 ON ExtrtmvE strHETARY (508)747 1620 ;
I October 12, 1983 ' t The Honorable Michael S. Dukakis > Governor of the Commonwealth . State House t Boston, MA r Dear Governor Dukakis It is with a strong sense of urgency that the Board of , Selectmen writes to you in reference to the Pilgrim Nuclear ' 1 Power Station. By unanimous vote of the Board of Selectmen - J on Tuesday, October 11, 1988, the Board hereby requests that j you take all action necessary to prohibit the restart of the Pilgrim Nuclear Power Station in the event of a restart vote i by the Nuclear Regulatory Commission. l i This definitive action is necessitated by the lack of a complete and tested radiological emergency response plan for i the Emergency Planning Zone encompassing Plymouth, Carver, ! Kingston, Marehfield and Duxbury. The lack of a complete and i
- tested plan has been verified by local boards of selectmen,
! civila defense directors, communities radiologicri emergency j response plan committees and many other interested nfficials ) and committees. 2 The Board of Selectmen again calls upon you to exercise the auth)rity of your office av Governor of the Commonwealth to i physically prohibit the restart of the Pilgrim Nuclear Power l Station until a complete and tested radiological emergency response plan is in place for the towns in the Emergency i Planning Zone. , Thank you. I S t J Very truly yours, F 06 [
; William R.'Grif 1 !
Executive Secretary i l c. c. Selectmen, carver ; Selectmen, Kingston ' Selectmen, Marshfield Selectmen, Duxbury i l . l ! I
l l l l l \ ATTACHMENT 9 Letter to Senator Glenn, dated October 14, 1988, from Mary C. Ott and others, Citizens Urging Responsible Energy a t l P l o
l CITIZENS URGING RESPONSIBLE ENERGY October 14, 1988 The Honorable John Glenn, Jr., Chairman Government Affairs Committee Hart 503 Washington, DC 20510 Dear Senator Glenn Citizens Urging Responsible Energy is an educational safe energy group founded in the summer of 1986 in response to residents growing concerns about safety issues involving the restart of the Pilgrim Nuc1 car Power Station in Plymouth. We are not anti-nuclear. Over the past two ynars we have dono extensive research on the subject of Pilgrim, and have tried to work with the utility and with the Region I office of the Nuclear Regulatory Commission to resolve our concerns and learn the truth about Pilgrim's troubled history. To our surprise, the "system" is not working. The past two years have demonstrated that the Nuclear Regulatory Commission is more concerned with getting Pilgrim back on line then they are with protecting public health and safety. Meetings held for public participation have been a farco and have limited testimony from even state safety officials to 5 minutes. We have no workable evacuation plan. The health study of our high cancer rates is incomplete. There has been no resolution of the GE Mark I containment issue. Pilgrim has shown signs of embrittlement. Investigations into the receipt and installation of fraudulent equipment at Pilgrim are incomplete. The current SALP lists 26 violations of Edison's operating , t license, 39 mishaps and the highest worker exposure to ; radiation at a domestic reactor in 1987. This report l encompasses the first 15 months of Pilgrim's new management team. In the face of all this evidence, Regicn I NRC I officials have given the go ahead for Pilgrim's restart. ; Today the commissioners will hold at meeting to hear ' Eoston Edison's request. We have been denied an adjudicatory hearing to learn
, the truth about Pilgrim's history, the NRC has not responded ,
to many of our inquiries; forcing us, as well as state officials to resort to the use of the Freedom of Inforaation Act to obtain answers. In short, the NRC'S conduct has caused thousands of citizens to lose confidence in their government. , t
Page 2 We charge that the NRC is in violation of the Code of Federal Regulations, Part 0, subpart A. We would like to request that a congressional investigation of the Region I NRC office be initiated. Please inform us of the type of evidence your committee vould require to undertake such an inquiry. We vill gladly provide testimony, transcripts, correspondence and recordings. Wo look forward to hearing from you at your er.rliest convenience. Sincerely yours, f! A '
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Mary C. Ott Donald M. Muirhead, I .,M.D. Diane Buckbee Duxbury Chapter Plymouth Chapter 1 P. O. Box 2621 P.O. Box 1754 i Duxbury, MA 02331 Plymouth, MA 02360 4 i l 1
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- I ATTACHMENT 10 October 14, 1988 press release by C.U.R.E. I b
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October 14, 1988 For Immediate Release Prom: Citizens Urging Responsible Energy (CURE) 1 Mary Ott, Duxbury, MA. 617-934-0498 l Diane Buckbec, Plymouth MA 617-747-4286 l Citizens Urging Responsible Energy, a Massachusetts based safe energy group, today hand-delivered a letter to the office of Senator John Glenn, Chairman of the Government Affairs Committee, requesting a congressional investigation of the conduct of the Nuclear Regulatory Commission's (NRC) Region I office. Plymouth CURE President, Diane Buckbec, and Roxbury CURE Co-Chairman, Mary Ott said today that they made the committment to come to Rockville, Maryland representing thousands of CURE supporters to formally request an inquiry. The group, which is not anti-nuclear, is opposed to the restart of the Pilgrim Nuclear Power Station located in Plymouth, MA. CURE has been an active participant in the controversy about the plant which has been closed for over 2 years because of serious operational and management problems. The NRC has rated Pilgrim among *.he nation's worst reactors for the last 3 evaluations. The group contends that neither Boston Edison or the NRC have been accountable in resolving the serious safety concerns of area residents. Ott and Buckbee stated that it is unconscionable that the Boston Edison Company would request or the NRC consider Pilgrim's restart without workable, tested evacuation plans in place to
- O protect the health and safety of area residents. They charge that today's NRC meeting illustrates the failure of the regulatory process. t A
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e . October 14, 1988 i For Immediate Release From: Citizens Urging Responsible Energy (CURE) . Mary Ott, Duxbury, MA. 617-934-0498 , Diano Buckboe, Plymouth MA 617-747-4286 l Citizens Urging Responsible Energy, a Massachusetts based safe energy group, today hand-delivered a letter to the i office of Senator John Glenn, Chairman of the Government ) Af f airs tenumittee , requesting a congressional investigation t of the conduct of the Nuclear Regulatory Commission's (NRC) Region I office. I Plymouth CURE President, Diane Buckbec, and Duxbury CURE Co-i i Chairman, Mary Ott said today that they made the committment , 4 to come to Rockville, Maryland representing thousands of CURE l supporters to formally request an inquiry. The group, which is not anti-nuclesr, is opposed to the restart
, of the Pilgrim Nuclear Power Station located in Plymouth, MA.
CURE has been an active participant in the controversy about the plant which has been closed for over 2 years because of serious j j operational and management problems. The NRC has rated Pilgrim l I i among the nation's worst reactors for the last 3 evaluations. The group' contends that neither Boston Edison or the NRC have i been accountable in resolving the serious safety concerns of area residents. Ott and Buckbee stated that it is unconscionable that the i' Boston Edison Company would request or the NRC consider Pilgrim's 4 restart without workable, tested evacuation plans in place to 1 1 1 2
I I t i ATTACl! MENT 11 Letter to Stephen B. Comley from Thomas Hurley, dated October 4, 1988 -
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f-/ Mr. Stephen 8. Comley *O - ExJcutive Director Wf The People of the United States 7532 a .- m A M] Box til "O Rewley, Massachusetts 01969 J /* / TP A Dear Mr. Comleyt Your letter of August 15, 1988 to President Ronald Reagan expressing your concerns regarding .Seabrook Station has been referr.ed to me for response. . I share your concern about the potential use of substandard piping fixtures at nuclear power facilities. Therefore. ARC issued hRC Eulletin No. 88 05 and Supplements 1 and 2 thereto (copies enclosed) to infom applicants and licensees of this potential problem. The Seabrcok Station licensee reviewed the Seabrook Station construction records in accordance with the requirements of the bulletin and supplements and datemined that 369 suspect fixtures were installed in the Seabrook Unit 1 plant. A report of the licensee's review was submitted to hRC on August 25. 1908, and is currently being reviewed by the NRC staff. The applicant must demonstrate to the satisfaction of the NRC staff that all of these suspect fixtures provide an acceptable level of quality and safety. A second concern expressed in your letter was that an unqualifted inspector l had been used at Seabrook Station. An Authorized Nuclear Inspector (ANI) l trainee was assigned to the Seabrook Station from May to December 1985. The NRC review determined that the ANI trainee perfomed assignments in accordance with his assiered training program and that Qualified AN!$ had evaluated and
- monitored his training, progress, and inspection work. The NRC concluded that there was neither a noncompliance with the American Society of Pechanical Engineers Code nor evidence of wrongdoing.
j You also expressed a concern regardine the thoroughness of the licensee's inspection to deten9fne that "counterfeit" bolts were not built into Seabrook Station. The licensee's initial irscettion, perfomed in response to NRC Pulletin No. 87 02 (copy enclosed), detemined that the fasteners used in Seabrook Station were acceptable. After tnat initial inspection. NRC issued Supplerents 1 and 2 (copies enciesed) to hRC Bulletin No. 87 02. These supplements reouested and then clarified the request for additional infomation en the suppliers and ranufacturers from whom the subject fasteners nay have been purchased. The NRC reviewed the information subettted by the Seibrook Station licensee in response to Supplements 1 and 2 to hRC Sulletin No. 87-02 and concluded that the actions taken by the licensee were both complete and adequate and that the fasteners installed in Seabrook Station are acceptable for their intended uses. Thank you for your interest in these matters.
" Perely.
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I t L ATTACllMENT 12 Letter to President Reagan from Stephen B. Comley, t dated August 15, 1988 I 4 J i : I a l J l d
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- .4 the United States Stop Cher:obylHere LF RWrA W 6Ms ME, Jr Wlu-- Hcw 95Rds-
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August 15, 1988 President Ronald Reagan The White House 1600 Pennsylvania Ave. (( f(( M
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Dear Mr. President:
I am writing to y5u as a lifetime member of the Presidential Task Force and Inner Circle. I have written to you in the past on the matter of nuclear power in this country, and have sent you information on safety problems in the industry. I have also sent you information on the Nuclear Regulatory Commission's inability to regulate nuclear pcwer plants adequately. A recent General Accounting Office report (enclosed) substantiates the belief of the people of the Town of Rowley, Massachusetts, that the NRC does not always properly investigate problems with nuclear plants and poor practices within the agency itself. Two years ago, 80% of Rowley signed a petition (enclosed) asking you to undertake an investigation of the NRC's practices. The people of Rowley are still waiting for an acknowledgment of their request. I am the owner and administrator of Sea View Nursing Home in Rowley, Massachusetts which lies just outside the Emergency Preparedness "one for the Seabrook, New Hampshire, Nuclear Power Plant. I fully agree with the State of Massachusetts' conclusion that the population could not be evacuated in the event of a serious nuclear accident at the plan'.. I am also the Executive Director of We The People Inc. of the United States which is a non-profit organization established to ecucate the American public about nuclear power. Several years ago, regarding the Shoreham, New Yo t < . nuclear plant, you said you would not interfere with the . tate's powers to decide if evacuation is possible in case of a nuclaar accident. (enclosed) New you are considering sign.ng an executive order which would take that power away from the state of Massachusetts for the communities near the Seabrook, New Hampshire, nuclear plant. I strongly urge you to avoid signing such an order. ! Apart from the fact that evacuation of those communities is impossicle, there are serious safety satters at Seabrook Station still under investigation by the NRC and others. One is the strong possibility that substandard piping fixtures were built into the plant i (see enclosed documentation-NRC bulletin No. 88-05, May 6, 1988), such l piping in the safety system compromises the health and safety of the l public. These piping fixtures are currently failing testing and could l result in a serious accident at any of the 38 plants involved. l Another pecblem under investigation at Seabrook Station is the ! Inspection of important safety systems by an unqualified inspect 0r. (enclosed) Despite knowledge of the plant builders that this inspector did not have the proper credential: to perform the work, he wa allowed to act in an inspectors' capacity for a year. Da ??7, Rowley, M A 01 4 ),(50 4 945.'954
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l Another problem, also common to m111tary equipment, is substandard bolts which become malleable or shear off under stress. Although the NRC claims that the utilities' inspection proves that these ,
"counterfeit" bolts are not built into Seabrook Station, the inspection 4 was very cursory and incomplete.
For reasons of safety, and also to uphold the idea that the i toderal government should not interfere in powers reserved to the states, I urge you to forego the executive order which would undermine Mossachusetts' determination that evacuation around the Seabrook ' l nuclear plant is impossible. 4 Last October 26, at the gala event for you hosted by the Inner Circle. I gave you a letter (copy of letter enclosed) with information and asked you to east with me. I was trying to convey to you information we had about substandard materials, information which was not widely known at the time. I would att11 like to meet with you
! bocause there is additional information available other than what has ! ; now been provided, and more will be forthcoming. Like the problem **
the substandard equipment, the NRC also has the information we have l,l about nuclear plant problems, but is doing nothing about it, excert ( i perhaps to cover it up. Lastly, the NRC people that we have bee 3 j werkine with fee the past two voarc are willing to meet with you [1
' p-4vatmiv ts inferr veu of the corruption which has deliberately teerardi:ed the safetv of the Amertean people. These violattons, ! ! have been told, are Just the soft under:e3ly of the nuclear industry j and the NRC.
1 I am sure veu can understand the eeneern of these individuals =ver the eensecuences of coming forward and, I am ,sure you can understand t i th , 5 t.e ;; ;;d;vidlei- o' t' -a
?y e--a ??rward if there are sese r-=-*"=h'a mamurances that a full and fair investigation will ensue.
I strongly believe that a full and fair investigation w111 uncover t
; one of the biggest violations of the public trust this country has ;
experienced. It is clear that, at this point in time, a large segment. L
. if not a vast majority, of the American people have lost confidence in the ability of the Nuclear Regulatory Commission to protect their interest in health and safety over the financial interests of the large utility corpantes. An impartial investigatica of the NRC will to a l' i step t0 ward restoring the confidence Of the public in its government.
I I knew you have to be eencerned ateut these ratters, and I want t: ! thank you fer your eenstderation of them. Please let me know when it I wculd be convenient for us to meet. h Ste .en B. Comley Executive Director [ p Ene: 3AO repert, Rowley Petttien, j th:reham :Prent. NRC Eu11etan 99-25. j Seatr::k Allegat ens, Letter :t 0:t. 25, li , 1 l 1 s l l 1 1 I
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- ATTACHMENT 13 Letter to Stephen B. Comley from Thomas Murley,*
i dated October 4, 1988
- Enclosure to letter not provided.
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u s .m g e NUCLEAR REGULATORY COMMISSION C A5HINGTON, O. C. FOMS av Mr. Stephen B. Comley, Executive Director We the People of the United States
- Box 277 Rowley, Massachusetts 01969
Dear Mr. Comley:
In your letters of August 26, 1988, to Chairman Zech and Mr. Stello regarding hRC Bulletin No. 8&-05, you stated that you wouy like to knew why hRC suspended Bulletin ho. 88-05 while the available data is being assessedI instehd of continuing investigations and gathering as inuch information 45 possible. partially addressed this question in the third paragraph of my August 15, 1988, letter to you. Enclosed is a copy of Supplement 2 to Bulletin No. 88 05 that provides additional information supporting the hRC decision to suspend Note that temporarily the requirements of Bulletin No. 88-05 and Supplement 1. engineering analyses have been perfonned to demonstrate that material that coes not meet certain hardness values is still acceptable for its application in nuclear power plants. Further nuclear industry tests and analysis of the material have shown that the continued use of these materials does not present a safety problem. i NRC is reviewing these data and tests to detennine what future regulatory action is appropriate. Sincerely, t l Thor.as E. Murley, a rt_. Office of Nuclear Reactor Regulation L
Enclosure:
hRC Bulletin 56-05 Supplement 2, dated August 3,1908 l l 1
ATTACHMENT 14 1 1 October 14, October 6, and September 16, 1988, press releases by "We The People of the United States" l l \
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We The People cf the United States Stop ChernobylHere , J ! 1 IMMEDIATE PRESS RELEASE 1 DATE: FRIDAY OCTOBER 14, 1988 LOCATION: EETHESDA, MARYLAND s . j Hassachusetts antinuclear groups today urged the NRC to keep the troubled Pilgria nuclear plant closed, and charged that state officials are not acting strongly enough to keep it ' l closed. At the NRC meeting in Bethesda, MD Stephen Conley representing the groups We The People, The Anti Nuclear Media , Fund and the Mass Alert Referendum Campaign expressed little . l hope that the NRC will vote to keep Pilgrim closed.
"The NRC is racing to turn this plant on before the November h 8th referendun vote," charged Conley, "they are endangering I
i the public". A binding referendum appears on the j Massachusetts ballot which would close down Pilgrim and the amaller Yankee Rowe plant by July 4, 1989. 7 i 1 Copley also h.ad advice for Lt. Governor Evelyn Murphy who is l
! representing the state in Bethesda. "In 1986 when Evelyn !
i i Murphy ran for Lt. Gov., she was attacked for accepting l nuclear industry campaign contributions. One week later to I prove no conflict, she held a press conference in front of Pilgrim calling for the shut down of both P11 grin and Yankee !
' Rowe*, said Conley. "We believed her and she was electod.
( But now, she won't raise her voice in favor of the only way to keep Pilgria closed - voting yes on Question 4." l "The state has already admitted the law suit to keep Pilgrim
- closed will fail. The only alternative left is to vote yes ,
on 4", added Coaley. "We're getting tired of politicians who say one thing and do the opposite. If she's really serious ( j about closing Pilgria, she'll endorse a yes vote on 4." j j l
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We The People cf the Ucited St:tes Stop ChernobylNere IMMEDIATE PRESS RELEASE DATE: OCTOBER 6, 1980 LOCATION: PARM SQUARE, BOSTON & ROUTE 6, WAREHAM IN PILGRIM EVACUATION EONE I PRESS CONTACT: STEPHEN 3. COMLEY, EXECUTIVE DIRECTOR WE THE PEOPLE, INC. OF THE UNITED STATES 508-948-7959 BILLBOARDS URGE: "MEEP P!LGRIM CLOSED" The national antinuclear group, We The People, Inc. today erected billboards in Boston's Park Square a. the Pilgrim Evacuation 2one (Route 6 in Wareham) with the message "SAVE MONEY. SAVE LIVES. MEEP PILGRIM CLOSED." The troubled P11 grin nuclear plant in Plymouth is scheduled to be restarted this month by the U.S. Nuclear Regulatory Commission (NRC). "The NRC is about to turn on the nowt dangerous nuclear reactor in America," said Stephen B. Conley, Director of We The People, "we hope these billboards will help alert the public." Earlier this year, We The People co-sponsored billboards , against the Seabrook, N. H. nuclear plant with the Institute l of Contemporary Arts in Boston. The anti-P11gris billboard is designed by artists Jay Critchley and Mathy Chapman who also designed the Saabrook project.
"The NRC and public need to know that if Pilgrim reopens, it will raise electric rates and endanger all of eastern Hassachusetts" said Conley, a north shore nursing home administrator. "If Chernobyl happens here, the elderly, the handicapped and everyone on Cape Cod will be stranded. An accident here would cause 3,000 immediate deaths and 20,000 cases of cancer according to the federal government's own study. By keeping Pilgrim closed, we indeed save money snd lives."
l I Bos 277. Rowley, M A 01969,(508) 948-7939 50 Coun St . Plymowth, M A 02%I,(617) 746 9M0 Naticul Press BtJg ,14 & E Sts . .iW., Washieston, D C. 20043 OfNes 5 & 6
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. We The People cf tlae United States l Stop ChemobylHere FOR IMMEDIATE RELEASE: SEPTEMBER 14, 1988 PRESS CONTACT: STEPHEN B. COMLEY, EXECUTIVE DIRECTOR BOX 277 ROWLEY, MA 01969 508-948-7957 The Commissioners of the Nuclear Regulatory Commission'have again demonstrated their willingness to sacrifice the t public's health and safety for nuclear industry profits.
"In deciding to excuse Seabrook Station f rom evacuation planning requirements that all other nuclear plants must f eil l ow , the NRC is violating their own regulations," said Stephen B. Comley, Director of We The People.
I Comley pointed out that the NRC's action today, particularly endangers the public since recent investigations reported in NRC Bulletiri 88-05 show that safety systems at Seabrook Station have been built with substandard materials. "Since the NRC knows Seahrook Station is not as safe as it is required t. be, common sense should tell them that they should strengthen, not weaken, evacuation plans meant to protect the public during a nuclear accident," Comley said. Even though the NRC found that at least 57 nuclear plants including Seabrook Station and the Pilgrim Plant, have used substandard materials in safety systems, the agency told the industr y they need not test or replace those materials. The NRC based that conclusion on an industry-sponsored preliminary computer analysis using insufficient data. The analysis by Bechtel, a multi-national nuclear corporation, stated that testing and replacement of substandard materials was too expensive. Theref or e, Bechtel argued, further testing by utilittes would not turn up any rel evant inf or mation.
"What happened was the NRC reali:ed that this substandard materials pr oblem was so massive, it could mean nuclear l ut111 ties would find it mor e pr of i tabl e te close the plants I than to r epla:e bad parts," Comlev satd. "Since auch an l outcome is unthinkable for the NRC, the agency instead eager l y accepted the industry argument that there is no problem."
"Every time the NRC makes this kind of decision, public opinion tur ns even mor e ag& inst the agency and the nuclear industry. The NRC ignores the fact that this is a democracy ond they ar e accountable to the people, just as they have consistently ignored thc Congressional mandate to protect public health and safety," Comley conc *;uded.
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ATTACliMENT 15 Letter to commissioner Zech from Mary A. Dinan, dated October 12, 1988 - l l l l l 1
r 15 Jeremiah Drive C u >. b u r y . M r. 0 2 3 3 2 Octcher 12.1998 Commissioner Lando Zech United States Regul atory Commission Washington D.C. Commissicncr Zech , I wash to nave the following statment added to the Public Recoro, The October 16.1988 hearing on the Restart of the F11 grim 1 fiuc i ear Fower Fiant (operated by ine bos to Eoi sor. Comoanv). I wish to tal:e exception to following statments made by MA. Ronal d Varl ey an a letter to Mr. Peter Agnes. The information he uses and forwarded to the U.S. Nuclear Regulatory Commisssion and to The Federal Emergency Managmen' agency is incorrect .In particul ar ,the f ollowing , s statements are not trae i t 1.1 tem 2' "Compl eted draf t pl ans have ,in f act , been devel oped by each of the five EPZ and two reception center
, towns and forwarded to the Commonwealth for transmittal to FEMA for informal technical review." ,
i The f ollowing f rom the March 4.1988 sel ectmens l etter i i containin9 the comments of the Emergency Response Committee l i 1 (Ece attached letter) re f l er.t the Intent of the Committee. l 4 i
-L * .
"The draft as a framework or skel eton which will be fleshed out by a series of procedures sometime in the f uture .Onl y -
when we have reviewed all of the procedures at some time in t he f uture can we know whether the draf t the draft plan will be adequste and workable."
"Col l ectivel v our study committee has found the drafs to be lacking. Lace.Ing . n .> t only in cetail s but in evidence ss to whether or not these plane will work".
f "No studies have been completed to date by the Commonwealth of Massachusetss to verliy the workability of the KLD Time j Estimate Studv. the Stone and Webster Shelter report, the bus survey and the necessity of a third reception center.The material we have caemined uses these studies as a basis for the Duxbury Drait plan,yet we are uncertain as to their , valaditv."
"The issue and difficulty is not in devel oping a '
structure. Ratner.1t is in the devel opment of a practical and workable plan. At this point no such plan exists" These comm'ents ref l ect the tr'Je intent of the "Draft". They are the on!" statments made collectively by the Emergency Response Study Committee and by the Selectmen of the Town of Duxbury as of this October 15,1988 . ( 2.1 tem 3 "when in fact such ofilcals have been intimatelv involved in the preparation of such materials working ,
3 cl osel y w '. ; i Boston Edison Reprsentatives for well over a rotr." The f ol l owing changec are not reflected in this dreft The Fire Departm:nt p30- 32 references are made regarding Martin Delano as Eelectmen. Mr. Del ano was repl aced by Mr. Abdul Hamadeh last March, p33 of the seme section references the Town Manager Mr. Thomas Groux, Despite the facts that Mr. Groux is r e t:p on s i b l e for all town departments, he is compl etel y omitted trom the "draft". The town manager form of Gover n me r. L AL nuted nuner cu k. t1ies in this dratt. l c N nas T n c. r . . ' = 'Itne, seid l iste: er directer :f fvt: 1: , 1 Wcr6 c . As of last June Mr. Litchfield was no Icnger emploved l i l by the town of Du:: bury . l l
- 3. item 5 "On the contrary, the i mpl ement ing procedures are the product of considerable interaction and cooperation with local officals."
The Town mane 9e- 5er within the part month under t al en the responsibil ity of rewriting the Sel ectmens procedure. This is long after the Sept. 21,1980 date of Mr. Varl ey's letter.
"It is important to understand that each of the towns impl ement inn procedures was prepared in a col l aborative effort with the cogni: ant l oc al officair and auency heads
4 . .
, and modlized until responsibl e of f ical s were satisfied with their c;gnaturcc."
Thare is no evidance to date of sny procedure being signed. PgE 35-42 of the agency head and cognirant l ocal of f ical s are blant. There as no signature en record any where within this "draft". See attached l etter Pol ice Chief Enrico Caopucci to Mr. Dornes retman February 19,1986. "However ,I have very serotus concerns as to whetier or not we can tupol v the amount of personel necessary to carry out the olan .... Our budget i.as somewhat significantly limited resources available."
"It is absolutely essential that Edison understands that w2tocut the resources 65 mentioned in that correspondence.It would be virtually impossibl e as Chie4 of Police in thic town, to summon t'> necessary manpower to carrv cut the roso3nsibilities of the evacuation es proposed in this draft." February 19,1988
- 4. item 6 Mr. Varl ey letter."In addition the specfic reference to the school procedure (there is no separate school plan) creates in our view.the misrepresentation that the school program is not as far al ong as other elements of the revised planning program. This is not accurate since school rel ated pl anning documents were prepared contemocraneously with other planning documents."
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I pps 30 through 81 of the School procedures are blank forms wnile pgs 25-35 are near -cuplicate blan6. forms of School status Eheets. Currently it has not been established whether the school
-age children will remain at the school or be sent home at es an earl y dismissal . Nursarv school chil dren have beer promised an approorlate r esponse by The Edison pl anners whicri han t rie supertindent notifying the school s even thovah ha hon no l egal responsibility for them.
No decontaimaticn / reception center has been set for these student , Only 20 % of.the entire population within the EPZ are planneo f or . Tns Echca; age children in Dunbur y alone are over three thousand chi ldren. This i s 20** of our towns popul at ion in and of itself. 5.iten 7 of Mr. Varle,s letter, refers to a trird reception cento . The : o ' e t +.e n o' the Town of Dunbury are unanin :Us in their oppsition of the Wel l esl y site. See attached letter June 23,1988.
- 6. Item 9 Mr. Varleys glib response to the Commonwealth's Justifiable concern for the handicapped and transporatation dependent is at best deporable. Large segments of the populatica are left stranded in this dratt. They are not even noted. "they are not even mentioned even in the most basic planning phases." a p p e n d 1 >: A Sel ectemen 's March 4,1988 1rter.
6 . . In c onc l u s i cre I too hopc: that my comments pr ovide you with useful insights on some o# the September 21,1988 issues.end that they will assist you in devel op ing an accurate report regarding the progress made concerning emergency planning . Sincerly, lia r 'r A. Dinan , f - y * ,/40 C. . *MW ( Vice ; h a i r'm a n Towns f the Dv':burv Emergenv Response Stude Committeo.) i i l l l l l l
O O ATTACHMENT 16 Letter to Peter Agnes, Jr. from Ronald Varley, dated September 21, 1988
M BOSTON EDISON E~e Geg/ {e y seo g y *1 Pymou:a Vasseeuse.s c2360 September 21, 1988 EP 88-1160 Mr. Peter W. Agnes, Jr. Assistant Secretary of Public Safety Commonwealth of Massachusetts Executive Office of Public Safety One Ashburton Place Boston, Massachusetts 02108
Dear Peter:
He are in receipt of your minutes of the August 22, 1988 meeting between N Commonwealth officials and NRC Region I representatives. The minutes describe the Commonwealth's impressions of the status of offsite emergency preparedness around Pilgrim Station (as presented during the August 22 meeting), and state that a report for the Governor is currently being prepared on that subject. Our review of the minutes indicates that the Commonwealth may be under some misimpressions regarding the status of offsite emergency preparedness. Since we are aware that you are engaged in preparing the resort to the Governor, I I thought it might be useful if I pointed out some of tie more important aspects i of the minutes which we believe to be in error. I should note, however, that l I have not attempted to address every issue raised in the minutes, or to take issue with the Comonwealth9 apparent crittetsms on the overall adequacy or status of the program. Nevertheless I felt that providing the coments below might aid you in your effort to complia an accurate report to the Governor. ; I First, in item 2 of the August 22 minutes, you state that "a completed draft
.k of the Pilgrim plans has yet to be produced." Completed draft plans have, in
/' fact, been developed by each of the five EPZ and two receptior, center towns and forwarded to the Comonwealth for transmittal to FEMA for inf0rmal technical review. As you know, FEMA has comented favorable on each of those reviewed to date and provided specific comcats which have been incorporated.
In addition, based on our recent conversations, it is my understanding that a revised draft MCDA Area II plan has now been completed and is being forwarded i to FEMA as wall. 1 Second, item 3 of the minutes states that the planning process "was desi k to initially permit local officials to review draft planning material...gned 4
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This statement suggests that the Commonwealth is "permitting" local officials to merely "review" materials, when in fact such officials have been intimately involved in the preparation of such materials, working closely with Boston Edison representatives for well over a year. It is, of course, the Commonwealth which is undertaking the "review" of the draft planning documents prepared by the tcwns, with Boston Edison assistance. Third, item 5 of the minutes states that "most implementing procedures exist in draft form; many have been provided (by BECo) to towns, but have not been U formally reviewed or approved." It is important to undsrstand that each of l the town implementing procedures was prepared in a collaborative effort with ! the cognizant local officials and agency heads, and modified until the responsible officials were satisfied with the. fidelity of the procedures and indicated so with their signature. The impression left by the quoted segment is that Boston Edison has "provided" materials to the towns with which they are not familiar. On the contrary, the implementing procedures are the product of considerable interaction and cooperation between local officials . i and Boston Edison. ' Fourth, item 6 states that six of seVen draft plans have been completed and that "plans and procedures for schools have been completely revised and the local review process is not yet complete." Draft plans for all seven towns 3 are now complete. In addition, the specific reference to the school ! A procedures (there is no separate school plan) creates, in our view, the ; misimpression that the school program is not as far along as other elements of the revised planning program. This is not accurate since school related planning documents were prepared contemporaneous 1y with other planning documents. Fifth, item 7 refers to the possibility of a third reception center. Boston Edison did not "recommend" the use of two reception unters, but did assess the feasibility of relying on two and did issue a resort summarizin its
% analysis. He believe that it should be noted that tie Commonwealth s feasibility analysis of the proposed Hellesley facility has been underway since March, 1988.
' Next, item 9 of the minutes states that the "special needs lists currently in inadequate ...." Secretary d use by1987 Barry's local Civil report to Defense Directors the Governor stated thatare woefuligit may not be neces prudent to compile exhaustive lists of special needs populations." In any event, it should be noted that Boston Edison stands ready and willing
- to comissioh the new speClal needs survey to provide information to upgrade l the lists as soon as HCDA/0EP forwards the modified Request for Proposal I (RFP), and we have received and reviewed the Commonwealth's policy on protectica of the special needs population (which is referenced in the RFP).
He have been awaiting both the MCDA/0EP modified AFP and the cited policy for some time. In addition, we have encouraged the towns to upgrade " eir existing itsts through telephone contacts with individuals and social service agencies, and are aware that some of the lists have been upgraded. Moreover, we have assisted in the development of Town Implementing Procedures which permit prompt "self-identification" in the event of an emergency. In addition, while we agree with your apparent recognition that there has not been a "lack of progress in planning", we think there are numerous areas where ] Comonwealth action would most assuredly help speed the planning process, t
, [ Page ?
EP 88-1160 Next, item 10 refers to agreements "between BECo and orivate [ transportation) g providers for emergency response resources." As you know, the form -f those agreements is between the providers and the Commonwealth, not Boston Edison. NC0A authored the agreements and MCDA representatives participated in their negotiation. While transportation providers representing a large number of resources have entered into such agreements, the agreements have been in the Comonwealth's hands for signature since March 1988. idhcf 9umm/s ? Next, while item 13 points out that the Taunton State Hospital and Bridgewater State College reception centers are in need of capital improvements, it should be noted that we have been awaiting authorization from the Commonwealth to begin im3rovements since December,1987, when our feasibility study listed what we 3elieved were the appropriate improvements. Next, item 14 states that Cape Cod (which is outside the EPZ) would be
' isolated" in the event of a plant accident. On the contrary, planning provisions call for one of the two bridges over the canal to remain open at all times to provide access from Cape Cod and for the other to be opened at the Commonwealth's discretion.
Item 15 refers to "substantial revisions" to the PIB made by the Comnnwealth. The numerous revisions made by MCDA, to date, have not in our opinion significantly altered the original format or content, and MCDA has not scheduled a meeting on this issue until October 17. Finally, item 18 states that an exercise is required before final approval of the plans can be given, and that such an exercise is "premature given the unfinished statt of the plans." He believe that given the considerable lead time associated with the preparation for an exercise, it is not at all too early to julgin to work toward that objective. While we have broached this subject on several occasions erith the Commonwealth, it has been unwilling to act to even laitiate the ex<,rcise planning process. Moreovar. FEMA has now responded to the two referenced Comonwealth letters, and has commented extensively on the draft local plans. While the program does remain "unfinished" to some degree, this is not due to intransigeance on the part of Boston Edison, ths towns, or FEMA. In conclusion, I hope that my ccaments provide you with useful insights on some of the issues raised in the August 22 minutes and that they will assist " l you in preparing an accurate report to the Governor. Recognizing the significant progress that has been made in offsite planning over the last year, we look forward to reviewing the Secretary's report. Sincerely, r R ald A Varle cc: Samuel J. Collins William Kerr Hilliam Lazarus Jack Dolan AS/cs IDA 1811 1 _ _ _ - _ _ _ - .
l ATTAC!! MENT 17, Letter to David J. Vogler from Mary Dinan and others, dated March 4, 1988 l
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Town . a .' Duxt ry. Dear Chairw- ' 6_trt The . e r, Response Plan Cc..eittee requests that the Selectmen forward . .4vil Defenr Area II for technical review, the Phase 1 DRATT of 09tsury's Tiergency Response Plan. Area II will forward the DRAT! to T'.MA for a ,icilar technical review. In. eskin. this request we vant to be clear that our Committee is not makiag a recoceendation with respect to approving the DRATT. The l DRATT is a framework or skeleton which will be fleshed out by a series of "procedures" av sece time in the future. Only when we have reviewed all of the "procedures" can we know whether the DRATT piso vill be adequste and workable. Yet we cust start secevhere, and the "t ec hnic a l review" step is first. After technical review, certain additions and anendeents vill be ne:essary. A similar process will be followed with t l. e detailed procedures. Our reasons for being careful that the forwarding of the DRATT is not construed as approval, are that docueents have been mis-described in the recent past. 1 Our Comeittee, upon review of the Phase I DRATT material submitted by
. Boston Edison Company, has in no way endorsed any part of this plan nor vill we do so until the fully coepieted plan and procedures have been subeitted. While the DRAFT has provided an outline, it must be underscored.that it merely represents the form, not,the substance. 4of s a7Ime rg enc y: p lan/ p r oc ed u re . ;
I Collectively our s tudy commit tee has f ound many areas in the draft to ) i bt__ lacking. Lacking, not only in details, but also lacking in l e v id e nc e as to whether or not these plans will work. No studies have been compteted to date by the Commonwealth of Massachusetts to verify I the workability of the KLD Time Estimate study. the Stone and Webster Shelter report, the bus survey and the necessity of a third reception center. The esterial we have examined uses these studies as a basis for the Duxbury DRATT plan. yet we are uncertain as to their validity. 1 l
l We have been asaared by both the Commonwealth (Civil Defense and Departetnt of Public Safety) and by Boston Edison Company that these "details" vcild be coepletely dealt with in Phase II procedures. Given the inadequacy of cast detailed plans, some doub t mus t exist for such prospective plans. The Committee feels it is dif ficult to determine t he feasibility of any plan when it is being considered as a single, separate entity and not part of a whole. Agreeing "in concept" has little meaning if the facte are not s olid ly b a s ed . The areas of long-term evacuation, lack of any details for the elderly and special needs populations, the complete omission of provisions for "latch key" children, strong reliance on volunteers (especially in re f e renc e to snow removal, teachers staying with children, bus drivers without contracts, afterschool activities -- a heavy populaton) are some of the details that must be forthcoming in Phase II procedures. In addition, the necessity of a viable decontamination and reception conter must be addressed. A procedure must be devised that insists contaminated individuals be decontaminated not only for their own protection, but for the general vell-being of society. This critical issue of a reception center must be resolved before the process continues. Further, many emergency workers vill function in situations which can lead to acute radiation sickness. Serious thought must be given to persons who have had this exposure. These matters must be anticipated and addressed in the procedures. The* issue and difficulty is not in developing a structure. Rather, it is in the developcent of a practical and workable plan. At this point, no such practical and workable plan exists. The sixteen questions our Coccittee identified over a year ago have yet to be
. answered. Thus, we vant to be clear once again: our request for a t ec hnic a l review ef the DKAFT plan --
a DRAFI which at the moment lacks its implementing procedures -- is simply a request for feedback from Civil Defense and TEMA, not an endorsement. We vill continue to proceed in good faith with the planning process. We trust that our actions will be reported and portrayed accurately. Rad ioing ic al Eme rgenc y Response Plan Study Coccittee Carl D. O'Neil, Chairman OdT( Chief of the Fire Department and Oivil Defense Director Mary Dinan. Vice ChairmanMD' gg,_ Enrico Cappucci, Chief of Police ES Claire Donahue Helen Dyer ., Neil Johnson Donald C. Kenne , Superintendent of Schools Thorndike Litchfield, Director of Public Works Donald Muirhead, M.D. 9 2
Appendix A Phase I of three phases for the emergency response plan has been submitted by, the Boston Edison Cocpany for review. From our perspective our Committee's original questions'that have been identified and applied'to subsequent plans have not yet been asswered. Also, subsequent questions have not been answered. It is our opinion that Phase I is merely an outline, a paraphrase of Nuclear Regulation 0643 dated October, 1980. Phase I p r ovid e s only definitions, or answers only base requirements. It does so in an outline form and could serve as a format. It must not be presented or viewed as a major improvement. Committee members have elected to address their concerns individually. From our perspective we have found the following areas to be worth particular note:
- 1. The svcond paragraph of the int roduc tion. We question its pertinence to an Emergency Response Plan. The basic premise of a plan is that one is needed. To speculate on the likelihood of its being invoked is just that - speculation. Such a paragraph has no meaning.
- 2. There seems to be an inconsistency in a basic assurption i cade in the draft evacuation plan: the source term used as the basis for evacuation planning and sheltering assumes that the containcent remains intact in the u n l ik e l y event of a worst case occident.
Vhile this is consistent with present regulatory requitecents, coccon sense would dictate that higher source term requirements may be appreptiate for a plant such as Pilgrim I which has a GE boiling water reactor with a Mark 1 Containment. It is our understanding that with the GE boiling water reactor eith a Mark I Containment, the odds are high (Barold Denton - Chief Reactor Regulator) that this type of containment would fail uncer a worst case accident. 3 The Special Needs Population. The Phase I draft deals in a > very ineffective manner with these populations. The draft assuces that only the handicapped, the gravely ill, or those populations in detention centers have special needs. Nowhere in the outline are provisions made f or child ren of working parents. These children comprise a large section of our population. They . are of an age where they are left at home alone. Comments as to wh' ether this parental practice is appropriate (or not) serve only to confuse and muddle the issue. Yet it is a fact of life. Large numbers o f c hild ren and dependent and aust be provided for. A bus that they might flag down is simply not enough. Twenty- i seven telephone lines in an eeergency operations center will hardly suffice to "mitigate the damage", not will the potential distribution of r,otassium iodide. Much work even in the outline phase remains to be done in this area. It is totally unacceptable t9 leave these dependent populations behind, yet there seems '.o be no provision anywhere for them, even in the : cost basic planning phases. Ironically these populations are an i ever-changir.g segment. There are at present no adequate means of
even identifying thee, let alone protecting thea. 4 The sirens. The sirens have been tested and found to be lacking. Although Boston Edison contends that the sirens need not be heard (Duxbury meeting 1987 Mr. Ron V a r 'l e y ) . If that point were correct, why would sirens be required? One would again question sirens' effectiveness as a primary means of notification. In addition, we are not aware that it has ever been established clearly as to who owns and is responsible for the sirens. Nor has it been established whether the sirens are capable of alerting the community.
- 5. The lack of any information available for long-term evacuation (more than a few hours). On several occasions we have attempted to discuss these issues with the Boston Edison Company cnd with the Commonwealth. No data are currently available to us and it is coepletely omitted from the Thase I draft. If a family is to evacuate for a long period of time, they will take family l
pets with them. At first glance this may seem like a minor problem. It does, however, pose a very real health threat for the Commonwealth, as many potentially radioactive animals will be randomly abandoned by their owners in the reception communities.
- 6. The evacuation of only eight percent ( 8%) of the Town of Marshfield. This estimate is a particular concern to the Town of Duxbury. The main evacuation routes for Duxbury are through
, Marshfield. It is reasonable to assume that the remaining unaccounted ninety-two percent (921) of Marshfield will not sit id l y by while the Town of Duxbury passes though it, nor is it easily feasible to contend that the buses for Duxbury's special needs populations and schools, will be able to pass through Marshfield u r. c o t i c e d and unimpeded to arrive at their designated spots. It must be reiterated that any Emergency Keeponce Plan has serious overtones. The Phase II aspects of the plan must contain the implementation procedures. The Commonwealth zust validate the accuracy of anything that is written. Reception communities must not be designated if they are not feasible. Shelters must be in place for dependent populations. They must be functional as well as available. Time estimates and bus providers must be documented by separate studies. i The people l'n the area of Pilgrim I continue to bear a risk. Outlines of a response plan serve a purpose. They make the prcblems very real and very concrete. The emergency response l issues, however, still remain' abstract. i Comments submitted by the following: Mary Dinan E6 f> ' Donald Muirhead. H.D. Belen Dyer #O Claire Donahue L Neil M. Johnson Donald C. Kenned k Carl D. O'Neil O
. e ATTACHMENT 18 Letter to C. Martin Delano from Carl D. O'Neil, dated December 16, 1986 l
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D e c e=b e r 16, 1986 C. Martin Delcno. Chairman Board of Selectmen Duxbury Town Ball Trecont St. , D u x b u r y , l' A 0 : 3 3 2
Dear Marty:
Attached is the list o f questions that we hav e c oepiled in the process of revieving the Energency Response Plan for the Town of Duxbury. Vo request that you submit these questions to Secretary Barry and to hebert 3ouIcy o f the Civil De f eese to bring a t tention t o the lack o f icf or=a tion that we hav e te p rovid e fer the heal th and
- safety ofthe c itiz er s o f Duxbu ry. ,In o r d e r t e h a_v e aplan,we r:ust have answers cicarly spelled eat so there can be no i s u r. d e r a t a n d i n g on hov ve are to conclude our review cf this plan.
This agenda-setting step is in preparation for s' joint meeting of the Selecteen and our Coccittee with Civil Defeese -- ho p e f u 11y in J a nu a ry. As s oon a s Civil De f ens e of ficials havc had a f ew d ay: t o r e v iew our qu e r tions , ve vill speak with thee to l e a r n whic h que s cion s are b eyond the sc ope o f Civil D e f e ns e and who they can suggest to answer the questions. We expec t Civil tefense vill arrange for persons from appropriate agencies ();& s s ac hu c e t t s Depart =ent o f Pub lic Eealth! T E P. A 7 ) to attend our i joint meeting in order to answer the quescions. Tha nk you f or your c onc e rn f or t he he s ich and s af e ty of Duxbury r e s id e n t s wh ic h you e x h ib i t e d at the teeting of November 24 Cincerely, 1 l Carl D. O ' t; c i l . Chairesc l Duxb u ry Er.e r g e nc y Re s p on s e P lan Coccitte e - i Zoe. l ec: Area II Civil Defense l l
P[ , . l ACIND A T OR JOINT MEETING OF S'ELECTMEN AND EMERGENCT RESPONSE PLAN COMMITTEE i The questions belov vill be forwarded to Massachusetts Civil I Defense, so that they can have time to prepare ansvers. If
- que s tions are b e t t er answe red by ano the r agency, wha t ag ency d o they suggest? Can Civil Defense o f fic is t s arrange for the prosence of these additional persons at our joint meeting?
Related to e ach o f thes e ques tions is the f o llow-u p "Vi t h whom verify this point!" Our reason for asking the can we a verification question is that our Committee has found in making tolephone calls to other agencies '. N a t i o n a l Gu a rd , .Hano v e r Town Rs11, TEMA, Boscon Ed is on , etc.) that promised planning steps have not always been followed through upon, even though Duxbury At the had b een as sured that the steps a 1r e ad y had b e en t ak en. joint meeting, ,our Committee vill ask the verification question . in e ac h instance where it is otitted.
- 1. Vhose responsibility is it to educate the general publie obcut types of radiation and r ad ia t ion hazards inVbo order to reduce pay s f or the panic sbould the plan need to b e implemented?
t r a in ini;t Vbo org anizes training f o r bu s ine s s e s , restaurants, after se,bool coaches, etc7
- 2. What is the status of the Banoyer Mall as D u x b u r y 's des.zncted reception center Vhat alternative locations are 7 understanding unde: c ons id e r a tion? It is our from conversations i vith the Ranover Town Exil that E a n o v,e r d o e s n o t with its es11 to be o reception center, partially because the drates run off into the town water supply. Eov cany people are ez;ected at the rec ep tion c enter? Bov =any parking spaces are there?
3. Vhan vill a traffic study be c omp le t ed , and by whom, to assure that evacuation routes are c ap ab l e o f bandling evacuees? Vill traffic from towns outside of tde 10 mile zone be restricted?
- 4. Vill traffic prevent (or make d if ficult) school busses from Vill the school le s sing Duxbury enroute to the rec ep tion c enter!
bu s s e s b e ab le to re turn to Duxb u ry 7 Vhat is the e s ti=a ted round
. trip time under the traffic conditions which ar e predic ted ?
- 5. Vill a d d i t i o t. a 1 b u s s e s b e sa a d e immediately available in order to transport school children directly to the reception eeneer in one trip? If s o, whe re vill the bus se s e one from and D u xb u r y's how long vill it t ak e them to a rriv e at the schools!
bus c ontr ac tor c an transport only one-third of our students on a single run.
- 6. Vill specialized v ehic le s such as ambulancesIfand whee lc hair so, where vill vans be p r o v id ed for citizens requiring them?
they come from and how long vill it taket 4 1
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- 7. In to whos e cus tody are school children turoed ov er b y bu s drivers at the' r ec ep tion center? ... pre-school children / infants la day care?
- 8. If sheltering of school chi 4dren and ad u l t s is to be ac c omp lis hed in Duxbury, what provisions vill be made to create the shelter (food, water, trash bags, masks with glycerine, cedical s upplie s , shelte r manag emen t p e rs onnel, b edd ing , etc.?
who pays?
- 9. Should potas sium iodid e tab le t s be mad e av ailable and stored in Duxbury Civil De f ens e headquarters? ... Dusbury shelters?
- 10. How vill the decontamination facilities for emergency wo rk e r s b e p ro v id ed ? Whe r e vill the equipment come from? Eov long does the d ec ontamina tion p roe e s s take? (In f orma tion f rom CD: Showers c oming "f ro= ve s t of Boscon". Where7; Information
~
from CD: "Cotton gowns would be a v a il ab l e." From wheret; ic f orma t ion f rom CD: "Tove i s vou Id b e e on fisc at ed f rom s t ore s." Do stores know thist if ac c id e n t occurred during vinter, would shoes, jackets, etc. be avtilable? From where?)
- 11. Who covers the rest of implementing the various functions of the plant
- 12. Should a graded response plan be developed rather than the present plan?
- 13. What is the sequence for aiproving a T o w n 's proposed response plan? Who is the final approving authority 1 Is there an appeal procedure if a Town is not satisfied? Vho d raws up a plan for Duxbury if Duxbury is not able tot 14 What is ad vis ed regarding pets in the evest of an evacuation? Leave food 7 Bring pets?
- 15. What is ad vised regarding the special problems of evacuating Duxbury Beach?
- 16. What t raining ha s the Na tions 1 Gua rd / Army Re s e rv e had , or vill have, to assist with the emergency response. From whom can we learn more about this point. ,
2
. o ATTACHMENT 19 Letter to Barnie Yetman from Enrico Cappucci, dated February 19, 1988 .
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.RICO C. CAPPUCCI 443 West Street Cb':f of Police (617) 934 5656 Duxbury, Mass. 02332 February 19, 1988 o
Mr. Barnie Yetman Boston Edison Cherry Street Plymouth, MA 02300 Re: Duxbury 1.vacuation Plan , l
Dear Mr. Yetman:
j As a result of a meeting with your assistant, Carlos Carcia, on February 5, 1988 I would like to e.2ke the following notations concerning the Duxbury Evacuation Plan drait as submitted to ce by your company. As 1 expt'essed to Mr. Garcia in reviewing the draft as submitted to me, I am in complete agreement sich Boston Edison with regards to the general the=e of the plan itself. There is little doubt in my =ind that with the proper resources and avai'2bic t.:n p ow e r , the plan as it presently exists in a draft form would sicnificantly improve the chances of the I Community of Duxbury to evacuate tes eituens in the event of a rajar- ' i emergency at the Edison Plant. - 1 i However, I have very seriou.. concernsastowhetherornotwecan\ supply the amount of personnc1 naessary to carry out the plan. bis \ concern arises from the fact that the Duxbury Police Department, due to 1 Proposition 2} and other limitat.ons on our budget overthepastseversii years, has so=ewhat significant!y limited resources available. 1 i Understanding that the plan itsvif is predicated on the ability of Duxbury to respond with sufficisot manpu.er, I have recce. .cnded to Mr. , Carcia that Boston Edison seriously consider purchasing portable radios I for all of the officers tu the departe.snt and to inc'.ude in that purchase ' nine car radios to replace the old and outdated radios which no longer voti effectively. 1 am enclosing in thi= letter to !oston Edison a report f rom Of ficer Robert M. M.duncy concerning radio pro)lems in the very area that would be addressed in the event that we need to (vacuate the Town of Duxbury as a result of a probles at the Power Plant. 1 can assure you that this has been an ongoin; problem for the last several years, but, due to limited funds, the town has not been able to address this situation.
February . 19, 1988 ., g* . -(.g ,Kr. Barate 'letaan
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',ji 1 an also enclosing within this letter a list of the necessary radios *' and a repeater system which would be mounted on the water tower in the
- .o very area of major concern to the Duxbury Police Department with regard to present radio communications. A recent study in that area indicated that,
, because of the present location of our repeater in the Town of Pembroke, ;
,f, we hava serious radio frequency problems in the southeastern part of our community. The placement of a repeater at the varer cover would eliminate this situation. ,
." It is absolutely essential that Edison understands that without the resources as sentioned in this currespundence, it would be virtually
; impossible in my opinion as the Chief of Police in this town, to sum on the necessary manpower to carry out the responsiblities of the evacuation as proposed in the present draft. Therefore, it is important to note that !
vould be unwilling to give my support to any such draft or plan without such esources. I uust Ne enphatic about the need for these particular ite:s
- a order to carry out my duties and responsibilities as presented in the resert draft.
r g*6 1 thank you for your cooperation and for the time and concern you have
/- given to this coc= unity in the preparation of such a draf t.
*. s Sincereg
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y .o Enrica . appucci ,
- f. Ch2 f of Police
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*I cc: teter Agnes - Office of Put.lic Safety Ralph G. Bird - Boston Edi:.on Carolos Garcia - Boston Edisaa Chief Carl O'Neil - Duxbury Fire Department
- Daytd Vogler - Chairman, Board of Selectmen 1
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PATRICIA DOWD ffo%'* ' DAW NM June 23, 1988 ABDULKADER C. tRMADDi Chorles Barry S;cretary of Public Safety M ssachusetts Civil Defense Agency On] Ashburton Place Boston, Ma. 02108
Dear Secretary Barry:
Tho Board of Selectmen have voted Jnamlnously to advlse the Mstsachusetts Civil Defense Agency that i t. is opposed to the choice of Wellesley as an emergency reception center for Duxbury residents in the ovent of an incident involving the Pilgrim Nuclear Station. The Board believes that the Wellesley site would not be suitable for the following reasont;
- 1. Access via Route 3 would be very c'ifficult due to congestion, especially if any incident occurred during rush hours; poor weather conditicns, etc.
- 2. lack of easily accessible fuel (gasoline) along the route
- 3. distance (time and miles) from Duxbury is too great and would pose problems regarding transportation and supervision of children; problems involving food and drink, etc.
4 capacity would appear to be limited - assuming the Wellesley site could accomodate 20% of Durbury's population where will the remaining residents be sheltered. To our knowledge Duxbury officials have not yet been given a tour of tho Wellesley site, thus it is diffs. cult to assess the specific fccility. In any event, the Board wishes to be certain that your offace is aware of the Town's objection to a Wellesley shelter location at that time. S rely, oa._ 0. 4~.x Patricia A. Dowd Chairman, Board of Selection cc: Attached List DD/fbh 878 Tremont Street
- Duxbury, Massachusetts 02332 * (617) 934 658o
e . CHAEF CARL D. O'NEIL-CIVIL DEFENSE DIRECTOR DUXBURY FIRE DEPA M ENT DUXBURY, MA. 02331-1153
; ROBERT J. BOULAY, DIRECTOR ' '
' CIVIL DEFENSE AGENCY 400 WORCESTER RD., P.O. BOX 1496 r TRAMINGHAM, MA. 01701-0317 EDWARD THOMAS l
FEDERAL EMERGENCY MAAAGEMENT AGENCY * ., 422 JORN MCCORMACK BUILDING
- POST OFFICF SQUARE ;
BOSTON, MASS. 02109 PETER AGNES AS31STANT SECRETARY OF PUBLIC SAFETY 1 ASHBURTON PLACE I
, BOSTON, MA. 02108 i
CHIEF ENRICO CAPPUCCI CHIEF OF POLICE
! DUXBURY POLICE DEPARTMENT
- DUXBURY, MA. 02332 1
AL SLANEY ] MASS. CIVIL DEFENSE AGENCY, AREA 11 ] MASS CORRLv'TIONAL INSTITUTE j P.O. BOX 54 BRIDGEWATER, MA. 02324 ! NEIL JOHNSON NUCLEAR AFFAIRS COMMITTEE 261 HIGH STREET i DUXBURY, MA. 02332 l MARY DINAN a EMERGENCY RESPONSE STUDY PLAN COMMITTEE i 15 JEREMIAH DRIVE j DUXBURY, MA. 02332 l
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!$ ailing List for Pilgrim Nuclear Correspondence - June, 1988 - BOS - Surrpu,nding Towns
, Chairman . Board of Selectmen Town Hall, 23 Green St., Kingston, Mass. 02364 Chairman Board of Selectmen Town Hall, 870 Moraine Street Marshfield, Mass., 02050 Chaitaan i Board of Selectmen Town Hall, 11 Lincoln Street Plymouth, Mass. , 02360 ; Chairman 1 Board of Selectmen Town Hall 100 Center Street Pembroke, Mass. 02359 Chairman 7 Soard of Selectmen i Town Hall, Main Street j Carver, Ma. 02330 I l l i i 1 3 [ t i e b l i i 5 i 1 l i
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- ATTAC!! MENT 21 "Implementing Procedure for an Emergency at the Pilgrim !Juclear Power Station" l IP-01 thru IP-08 1
dated July 26, 1988 (Submitted by Mary Dinan) Due to the volume of this document, IP-01 thru IP-08 vill be placed in the Public Document Room, 1 1 i l l
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- ATTACilMENT 22 October 14, 1988 press release by the Commonwealth of flassachusetta 4
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b THE COMMONWEALTH Oyr MAggACHUSETTS 9 sVsLYN F.MuaPHy usuiswm sevenwee Exrcutivs DEPARTMENT sTaTu Housa e sosTON Oalas pese an selFi7s1 78e8 TOR IMMEDIATE RELEASE CONTACT: Carrie Rimball 617-727-7200 LT. COVERNOR_ MURPHY URCES ACAINST PILGRIM RESTART Rockville, Maryland. . .octobe r 14, 1988...In a strongly 5 worded staterent, Lieutenant Governor Evelyn F. Hurphy today urged the Hua lear Regulatory Commission to prohibit the Pilgrim Huclear Powe r Station f rom reopening until adaquate emergency plans a:e tested and in place. Murphy, speaking f or the Dukakis A6 ministration at a special HRC reeting on Pilgrim, stated that while the Boston Edison and the NRC staf f will argue that Pilgrim has achievsd sone progress, the Commonwealth is f ar f rom antisfied.
"Boston Edison argues that progress har, been nade and that coope ration has improved. But progress and coope ration do not save f amilie s," Murphy said. " A f amily's chance for a safe l evacuation will not come until eme rgency response plans are complete, tested and approved, and until equipment and 1 pe rsonnel are fully in place . The re is no eme rgency reponse i
plan for Pilgrim."
-nore-
1 l l l Murphy demanded that specific problems be kolved. "T he re has been no local cor= unity approval of a plan and implementing p rece du re s , the 6,000 eme rgency worke rs have not been trained, there is no way to evacuate children and persons with special nee ds, and the re is no system for notifying local comr. unities and eme rgency workets during an eme rgency," Murphy said. ' Thia is unacceptable." MJrphy stated that in light of the unprecendented scrunity
- of Pilgrim Station, the NRC must not allow a restart until the se problems are re s olve d. "The NRC is unable to guarantee that an accident at the Pilgrim reactor will not occur, the Commi ssion the re f ore must assure the citizens of the commonwe alth that an approved and tested emergency response plan is in place," Murphy said.
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ATTACl! MENT 23 "Stop Chernobyl Here" poster :
CHERNOBYL l l 1 HERE l l JOIN - l We 'iithe l l People of ** l l l Enited States ;. Mr to form a 2" l M , KEER PlLGRIM CLOSE l voTgES40N$ National Press Bldg. l M ...- '50~CNrt St. 3 Pleasant St. Pl>1nouth, MA 02361 Concord, NH 03301 14 & F, Sts., N.W. l Box 277 (603) 228 9484 Suite. 994 Rowley, MA 01969 (506) 746 9300 Washington, DC 20045 l (508) 948 7959 ! (202) 628 6611 WE THE PEOPLE. INC OF THE UNITED STATES IS A T AX DEDUCTIBLE. NON PROFIT ORGANIZATION. 1p _ _ _ . _ - - _ _ _ _ - _ ___ . . . . - - - .}}