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UNITED STATES NUCLEAR REGULATURY COMMISSION
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af KING OF PRUS$1A. PENNSYLVANIA le400 MAR 08 588 Town of Plymouth Office of the Selectmen ATTN: Mr. William R. Griffin Executive Secretary 11 Lincoln Street Plymouth, Massachusetts 02360
Dear Mr. Griffin:
Thank you for your January 25, 1988 letter, which forwarded the Town of Plymouth Comittee on Nuclear Matters report entitled, "Environmental Radiatica Monitoring - Pilgrim Nuclear Power Station."
In reviewing the report, we noted that it contains a number of recomendations that go beyond NRC requirements.
The recommendations are directed toward the Comenwealth of Massachusetts and the Boston Edison Company. From your letter, we infer that you will coordinate directly with the Commonwealth for those items suggesting their action.
We also understand that the Boston Edison Company has received, from you, a copy of the report and plans to comment in writing. We have asked them to also provide a copy of their comments to NRC Region I (see Enclosure 1). Also, based on our initial review of the report, we dre enclosing comments (Enclosure 2) from an NRC perspective on selected items in the report.
Please feel free to contact either Dr. Ronald Ee11amy (215-337-5200) or Mr. A. Randy Blough (215-337-5146), if you wish to discu s these natters further.
Sincerely, 9
Samuel J. Coll 's, Deputy Director Division of Reactor Projects
Enclosures:
1.
NRC Letter to Boston Edison dated 3/0/83 2.
NRC Region I Con ents on Town of Plymouth Committee of Nuclear Matter Report N
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miitaaR.Grufin MAR 081988 cc w/encis:
R. G. Bird, Senior Vice President - Nuclear R. Barrett, Nuclear Operations Manager B. McIntyre, Chairman, Department of Public Utilities Chairman, Board of Selectmen Plymouth Civil Defense Director J. D. Keyes, Boston Edison Regulatory Affairs and Programs E. O. Robinson, Nuclear Information Manager R. N. Swanson, Nuclear Engineering Department Manager Th( Honorable Edward J. Markey iiie Honorable Edward P. Kirby The Honorable Peter V. Forman Sharon Pollard, Secretary of Energy Resources Peter W. Agnes. Assistant Secretary of Public Safety, Commonwealth of Massachusetts Rachel Shimshak, MASSPIRG Public Document Room (POR)
' ocal Public Document Room (LPOR)
'1ar Safety Irformation Center (NSIC) nke Resident Inspector Commonwealth of Massachusetts (2) bec w/encls:
Region I Docket Room (with concurrences)
R. Wessaan. NRR
- 0. Mcdonald, NRR S. Collins, ORP J. Wiggins, ORP R. Blough, ORP L. Doerflein, ORP R. Bellamy, CRSS W. Pasciak, DRSS R. Struckmeyer, DRSS R. Bores, DDSS
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I SAFETY ENHANCEMENT PR OGR A 'l BOSTON ED'.IS ON GOALS i.!cotify and knphsnent Plant hnproverments Responsive to Bernaro's Draft Policy Prior to g.'
Startup. Revise Procedures and Train Operasers o Improve Operational Ramrliness for to.
Effevtive Managesnent of Severe Accident Risk l
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o yj Perform a Comprehensive Safety Assesnwnt Supported by Deterministic and Probabilistic u_
Analyscs of Scvere Accidents to ensure that:
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The Pilgrim Specific Response to Severe Accidents is WeX Understood x
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- 1bese fnsights are Effectively Used Within Besten Edison to Reduce the
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Probalstify and Consequences of a Core Damage Accident by Improving Design, Z
ProceduresandTraining ca r
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These imighh are Available in Support of Emergency Preparedness Planning r-O) if)
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3AfETY ENHANCEMENT IPR DOR AM Procram Dements E
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Safety Analyses - Both Probabilistic And Deleinimistic E
Plant Equipment Modifications M
e mo Opentions ProcedureImprovernents E
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SAFETY ENHANCEMENT PROGRAM
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A p_p r o a c h Assemble The Most Experienced Technical Team AYailable 1
Pursue A Paralle! ElTort to Identify PossibleImepswements n
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a' Prepare Conceptual Design Based On Expert Judgessent l
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Analyze Plant Capabilities Both As Built And With Possibfe Improvemer'
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Maintain Active InvolvementIn The Industry Programs E
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1FETY SEl' M ANCEMENT Ph0 GRAM d
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Station Blackout Addition Of A Third Diesel Generator. '
e' Suppression Poot Van To Main Stack - Sined For Decay Hess Removal I
Fire Water Inter-Tie so RHR - Additional Source Of RPV Makeup
-I Addition Of Ibiteries With AC Inverters-PourTo Critical Valves and Inmunenes O
Cruss Connection l' rom The TSC Emergency Diesel Generator To Recharge Normal b
Basseries eZ hnproved len;;Tenn. Nitrogen Supply x
g Set Point And Logic Change:To Extend The Duration Of HPCI And RICI Operatino Z
i Addition Of Second Diesel Fire 1%snp Fire Water Inter-Tie to CondensateSrorage Tank i
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I SAFETY ENEANCEMENT PROGRAM k
Results i
Containment Performance 1
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Optimization Of Drywell Spray Design-Nozzle Change And Flow Reduction 5g Fire Water Inter-Tie To RHR - AMieinnat Source Of Di.;3 Spray f
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Supression Poof Vent To Main Stack -Containment Overpressure Control o
Improved ImgTerm NitrogenSupply g=
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SAFETY ENEANCEMIRNT PROGRAM
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Results eg Anticioated Transient Wilht Scrara Enriched Boren ForSELCSystem a.
e TRAC G Analysis For ATWS e5 RECIRC MG Field Breaker ReNability Improvements x
i g Automatic Depressurization System Logic Changes z
Feedwater Pump Trip On Iligh Reactor Pressure m
4 MSIV Reactor Low Water Level Isoiation Signal Manual Bypass
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e SUBAGREEMENT :-
PERTAINING TO LOW-LEVEL RADI0 ACTIVE WASTE PACKAGE AND TRANSPORTATION INSPECTIONS BETWEEN THE COPMONWEALTH OF PENNSYLVANIA AND THE U.S. NUCLEAR REGULATORY COMMISSION This Subagreer.ent is entered into under the provisions of the llemorandum of Understanding between the Comonwealth of Pennsylvania and the United States Nuclear Regulatory Comission ef fective November 4,1986.
The Comonwealth of Pennsylvania, in fulfilling its obliga rake periodic inspections of the areas cf low-level radioactive waste packages and transport activities of generators located withits its borders if shipt.unts of such wt.ste are destined for disposal at a low-level radioactive waste disposal facility.
The United States Nucicar Regelatory Comission (NP.C or Comission) has the rtatutory responsibility to inspa n its licensees to dat'.rrrine'complia ce with likt requirements, including requirements pertaining to th2 shiptcent, packaging In the and transportatien of 1.cw-level radioactive waste destired for disposci.
j exe'rcise of this responsibility, the Comission regularly conducts a review of 1
the waste packaging and transportation programs of its licensees including the 4
licensees' procedures for quality assurance, packaging. rarking labeling and loading of vehicles. These prograr, reviews usually have betn found adequate to ensure licensee compliance with the Comission's regulations regarding low-level radicactive waste packaging and transportation without the need for Comission l
j inspection of each individual shipment.
Under Section 2741 of the Atomic Energy Act of 1954, as amended, the I
Comission in carrying out its licensing and regulatory responsibilities under the Act is authorized to enter into a Mencrandum of Understanding (agreement) with any State to perform inspections or other functions on a cooperative basis-i While the Comission does not conduct l
as the Comission deems appropriate.
on-site inspections of every low-level radioactive waste shipment of its licensees, it desires to foster the goals of the Low-level Radioactive Waste Policy Amendments Act of 1985, the Comonwealth of Pennsylvania, and the Appalachian Compact.
Accordingly, this Subagreement between the Comonwealth of Pennsylvania and.the NRC estabitshes mutually agreeable procedures whereby the Comonwealth may i
perform inspection functions for and on b2 half of the Comission at certain NPf reactor and materials licensees' fact 11 ties which generate low-level radio-active waste, 4
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p It is hereby agreed between the Comission and the Comonwealth as follows:
The Commission hereby authorizes the Comonwealth to perform, for and on 1.
behalf of the Comission, the following functions with respect to low level radioactive waste, as defined in Section 2(9) of the low level Radioactive Waste Policy Amendments Act of 1985, in the possession of Comission licensees located within the Comonwealth:
Inspections to deternine compitance with the Comission's rules and (a) regulations 'regarding waste packages and transportation of low level radioactive waste destined for disposal at a comercial icw level radioactive we
' disposal site; and J
(b) hotification of Comission licensees and the Comission in writing of All enforcement actions any findings disclosed by such inspections.
(such-as Notices of Violations, Civ11 Fensities or Orders) pursuant to this Subagreement resulting from such inspection findings will t,e undertaken by the Comission.
The Co uenwealth agrees to utilize personnel knowledgeable in radiation st.ftty, waste psckaging requirem3nts, and packaging and tran: port.tica The Comonwealth agrees to perform its functions under this regulations.
St.b:greement at no cost or e7 pense to the. K.*:C. NRC may provide training to caployces of the Comenwealth at no expanse to the Co monussith.
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- ne Comission does not nornn11y evaluatt l
(except trase) and per diem).
i the Comonwealth's ability to perform such functions; however, prior to Comonwealth qualification of inspectors, comonwealth managenem, 1
1 accompanied by an NRC representative, will assess its inspectors pre-paredness to conduct independent inspecticns.
l The authority to inspect NRC liclasees pursusnt to the preceding paragrg.i 2.
is limited to the licensees' low-level waste packages and low-level trans.
l por'tation activitits. Specificaliy, this cuthority is limimi to:
(a) Review, for understanding, the licensee's written proceduiss; i
(b) Inspection of the licensee's written records; and (c) Inspection of completed packages and transportation activities.
The authority does not include assessment of she adequacy of the licensee's -[ J written procedures, plant equipment, quality control programs, training programs or staffing.
Specfific implementing procedures are attached hereto which may be modified, as required, j
3.
In takin'g any action authorized hereunder, the Cosenonwealth shall not undertake to amend or revoke Comission licenses. This Subagreement, however, shall not be construed to preclude the Comonwealth from exer-cising any authority lawfully available to it under its own laws.
both parties to avoid duplicative enforpement Efforts will be made b{tcensee for the same inspection finding'.
4.
- However, action against an NRC.
this 's not meant to preclude appropriate complementary actions for the j
same < nspection findings such es termination of a user permit by the Commonwealth and NRC enforcement action.
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5 Nothing herein shall be deemed to authorize the Commonwealth to inspect or otherwise enter the premises of any licensee of the Commission which is a 5.
Feder,a1 instrumentality without the prior consent of the Itcensee.
Nothing herein shall be deemed to preclude or affect in any manner the 6.
authority of the Commission to perform any or all of the functions described herein.,
Nothing herein is intended to restrict or expand the statutory authority 7.
of NRC or the Commonwealth or to affect or vary the terms of any agreement in effect under the authority of Section 274b. of the Atomic Energy Act of 1954, as amended.
i Nothing herein shall be deemed to permit the Commonwealth to impose 8.
packaging or transport standards beytind those contained in Federal regulations.
The principal NRC c:)ntacts under this Subagreement shall be the Emergency 9.
Preparedness and Radiological Pro'.ection Branch Chief for reactor licen-sees and the Nuclear Materials Safety and Safeguards Branch Chief for esterials licensee, both of whon are located in the Division of Ridiation The principal Commonwealth e.catut Safety and Safeguards, Region I, NRC.
shall be the Chief, Division of Nuclear Safety, Pennsylvania Burea>> of Radiation Protecti-)n.
- 10. This Subagreement shall become iffective upon signing by the Secr:tary,J Department of Envfronmental Resources, Cor. nwealth of Pennsylvania, an the Regional Admillistrator, Reglon 1. Nuc., Regulatory Commission cad shall remain in effect permanently unless terininated by either party on thirty days prior written notice.
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Cated this M"
day of bi t" 1987 at ky-usi% A.
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FOR itiE NUCLEAR REGULATORY COMMISSION I
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Regional Administra Tr l
FOR THE C0tNONWEALTH OF PENNSYLVANI A 3
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5ecretary, Department of Environmental SEP141987 Dated:
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IMPLEMENT!GPROCEDURES-$U8AGREEMENTIPERTAININGTOLOW. LE RAD 10ACT!VE WASTE PACKAGE AND TRANSPORTATION INSPECTIONS BETWEEN THE COMMONWEALTH OF PENNSYLVANIA AND THE NRC 1.
TRAINING A.
Pennsylvania staff attendance at NRC Sponsored Courses Pennsylvania staff riay attend NRC sponsored training courses 1.
when cutually agreed upon by Pennsylvania and NRC.
Atter.dar.cc at any particular course will be scheduled o, 2.
a space available basis.
3.
Staff applying for attendance must falfill any necesscry course prerequisites.
Attendan:e will nortally be limited to 1-2 indivIr;uals et 4.
any one particular course.
Pennsylvania,will pay any transportation and par diem expenses 5.
except for cours2s offered in connection with the Agrecnent f
State Progrt where NRC pays for trevel and per dica of State parsonnel selected to attend.
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On the-Jcb Training On-the jeb training will be provided to the Pennsylvania staff 1.
duct of inspections to determine compliance with the in the et requirenents in 10 CFR Parts 20, 61 and 71.
The training accompanirents will normally k limited to NRC 2.
licensees located in the Comonwealth of Pennsylvania,
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.The training accompaniments will follow the protocol set out 3.
in Mr. Naynes' November 5,1980 letter to Mr. Gerusky. Under the protocol, the activities of'the individual accompanying the NRC inspector will,, be liatted to observation and familiarization 4
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- r The NRC with plant activities and the NRC inspection process.
inspector wll) be responsible for initiating action to correct any program deficiencies identified during the inspection through NRC's nomal inspection and enforcement process.
1 Comonwealth of Pennsylvania staff accompanying the NRC inspector 4.
wl11 normally be limited to two persons - the senior staff mette responsible for the program and the cognizant inspector for the plant being inspected.
Emphasis will be placed on training two sertor Pennsylvania sta" 5.
who can learn this area quickly and who, in turn, can begin to train other Pennsylvania staff.
The training may also involve pre-inspection planning at the 6.
Regional office or in the NRC resident iiispection office prior to the inspection. The Ccmonwealth inspection staff is exp:Mr to have reviewed prior inspection reports, inspection finding and enforcement actions for the facility being inspected.
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also expected that the Comonwealth inspectors are thoroughly i
knowledgeable of the NP.C inspection procedures and reference material cited in those procedures. These are important parts i preparing for the inspe. tion.
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Tha training acco:r.paniments will b: provided by a Region based inspector who rcutinely inspects waste packaging and transpoet; activities, not tlie resident inspector or THl-2 inspectiori stel.
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The contact for the training accompaniment ' inspections at reactors will be the Chief. Emergency Preparedness and Radio-l logical Protection Branch. Division of Radiation Safety and hafeguards.
The similar contact for materials inspections will be the Chief. Nuclear Materials Safety and Safeguards Branch.
Division of Radiation Safety and Safeguards. If either of the l
above are not available the contact w'11 be the Regional State t
!.iaison Officer.
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Initiaticn of Independent inspections by Pennsylvania $taff j
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The Comonwealth will ensure that its inspectors are qualified in accordance with NRC Inspection and Enforcement Manual Chapter
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3 1245, or its equivalent, and will keep NRC infomed of the s
Comonvealth inspectors that have been so qualified and certi-fled.. tor to Comonwealth rivalification of inspectors.
Comonwealth management, accompanied by an NRC representative, will assess the performance of its inspectors during an inspection to detennine their preparedness to conduct indepen-Following the accom)animent, the NRC repre-dent inspections.
sentative will provide a crt*1gue to tie inspector and his supervisor. Periodically, C monwealth mar.agement will accompany its inspectors during the performance of inspections to verify the inspector's,:entinued effectiveness.
Finally. NRC will inform Comonwealth management of problems identified during the NRC review of Commonwealth inspection findings for appropriate corrective action.
I Cemenwealth inspectors may periodically accompany HRC inspec-
'2.
tors during NRC's programatic waste package and transportation inspections to maintain familiarity with a Itcensee's program and NRC inspecticn requirements. The Comonwealth and NRC r..ay also r.ect periodically to exchange infomation and discuss Comonwealth inspectors may also con-changes in procedures.
tact the region based and resident inspectors prior to or during the Comonwealth's independent inspection at the site.
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Arrangements to gain access to any licensee's facility are a responsibility of the Comonwealth.
Specifically, individuals plar.ning to conduct inspections at reactor facilities sl.ould meet all licensge requirements for site access.
1
- 11. PROCEDUR:5 TO BE FOLL0k'E0 DY PENNSYLVANIA FOR 1HCPECTIONS CONDU UNDEP THE SUBAGEEMEN1 A.
Pennsy'vania will perfom the following inspection activities relating to 10 CFR 71:
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- 1. Examine the licensee's written waste shipment records. As the situation allows, observe completed packages so as to:
,a. Verify that the licensee has marked the package with the
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'n applicable general and specific package markings which are required (49CFR172.300 through310).
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4 Verify that for NRC-certified packages, or DOT-revalidated oackeges of foreign origin, the outside of the package is durably and legibly marked with the package identification marking indicated in the COC or the DOT Competent Authority Certificate.
Verify that for non exempted packages, the licensee provides b.
for and accomplishes labeling of each package with the appropriate category of RI.010 ACTIVE (White-1, Yellow-ll, or Yellow-!!!) label, one each on two opposite sides of the package; and accurately completes the entry of the rcquired infoimaticn,intheblankspacesJhereon(49CFR172,Subpart E).
Verify that the liccr. slo provides 'for and accomplishes monitoring of each comp'eted package to assura that ex*.src0 c.
radiatien and renovable surface contamination are stithin the i
ailewable limits [49 CFR 173.470(1), 49 CFR 173.411, t.9 CFr.
173.443,and10CRF71.87(1)and(j)).
the licensco's written vasto ship 5ent r'ecords. At the i
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situation allows, observe actuel transport operatior s so as to:
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terify whether the licensee prepared the required shipping p;por dccurentation, so as'to occurately incluce all of tr.?
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cpplicible required elei.sents of information, including th?
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- r. Sipper'scertificate.[ NOTE: for licensee privat: rstor vehicle shipments, the certificate is not required (49 Cf R i
172,SubpartC).)
Fer non-exclusive use shipments, verify that the licensco b.
Trovides to a highway carrier or applies directly to a rcil
. vehicle, the required placards whenever he delivers any
' quantity of RADIDACTIVE-Yellow-!!! labeled packages to such carrier for transport (49 CFR 172.506'and 508).
For exclusive use shipments, verify that the licensee
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assures that the package and vehicle radiation [contamin-ation 1c<els are within the replatory) limits L49 CFR 173.475(1) and to CFR 71.87 (1) and (j ).
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Yerify that except for* uranium or thorium cres, the transport vehicle is placarded by the licensee when delivering to a carrier any exclusive-use shipent for which placarding (is required [49 CFR 172, Subpart F, and 173.425(b)7)).
For exclusive use shipments, verify that shipping paper documentation provided by the licensee to the carrier contsins satisfactory instructions for itiintenance of exclusive-useshipmentcontrols(49CFR173.441(c)and49 CFR 173.425(b)(9)).
Verify that for exclusive-use shipments of low-specific activity r.aterials, the licenst.e has prnided for the additions 1 specific require.ents (49 Crr. 173.425 (b)(1) thro.;h(r)).
Verify that the licenser. cecvides for r,3-ifiestion (o the d.
the dates of snipx.ent and censignet tefore shipmer.t:
expectM cerival, eny s;ecial lo6dioc/..iording or orcratin-instructi.ons whanever any non-exerpt fi ;ile tc.sterfil and/cr packages cer.taining "highuty route cont-011ed quantities" are involved [49 CFR 173.*ti(b) and 10 C/R 71.89).
Verify t at the licensee provices for a#snce notificction c.
to the t'overnor of a State, or his design, of as.y shipaer.t of rt.dio::tive traste requiring Type B p;ckag[ing 1.hrough, te.
or acrcss a state boundary (10 CFR 71.97).
NOTE: This re-purposes pursucnt to 10 CFR 73.72.) quired for safe
'quirer.ent is not the sema as that re I'
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Review the Itcensee's records and reports to verify that a syste r.
is in place to:
Maintain on file for two' yeari after shipment a record of a.
each ship)ent of licensed material (which is not exempt therefrom and tht.t such records contain the required informatfor.[10CFR'/1.87and10CFR71.91(a)).
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Report to the Director, HMSS. within 30 days, any instances where there has been a significant reduction in the effectiveness of any packaging during its usel providing e-f l
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cance to the packaging af ter first use and the sneans employed to repair such defects to prevent their recurrence (10 CFR 71.95).
Iernediately report to DOT. when transporting ifcensed snateritl as a private carrier, any incident that occurs in c.
which as a direct result of the radioactive material:
any person is killed; re'ceives injuries requiring hospitalirs-tion; property damage exceeds $50,000; or fire, breakage, spillage, or suspected radioactive contamination occurs (49 Cfr. 171.15 and 49 CFR 171.16).
Pennsylonia will perfom the following inspection activities relating to 10 c.." Parts 20 ard 61:
Fev' e the licensse't records and, as the situat* m allows, i
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obt:.ve actual packages and transpart activitie*, to verify tht*.
eac* shi pment of radioactive waste intended for cff-site disp:3.*.1 i
te a brecer or a licensed land dispv al facility is acceepeni h ta. shipment ranifest which incicJe. all of tne r.: quired in?: ration [10 CFR 20.311(b) and (c)).,
Dvity the licensee's documentation and records to detemine' 2.
eeing niin-c'. 9.;r procedures have been esta511r.i:ed and ar ti r.: to properly classified all 1@.t-level wastet according
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to is CFR 61.55.
Re f ew the licensee's documentation and records to deterr.ine 3.
w%:.ner procedures have been established and are t Jing main-taired, to properly characterize low-level waste tit confor.mance.
wita the requirements of 10 CFR 61.56).
Review the licensee's records and as the situation allows, observe actual packages and transpcrt activities to verify that each package of low-level waste intended fer shipment to a licensed land disposal facility is labeled, as appro-priate, to identify it as Class A. 8. or C waste in accor-derce with the classification criteria of 10 CFP 61.55 [10 i
CTR20.311(d)(2)).
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Review the licensee's records and, as the situation ellows.
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observe actual pa'ckages and transport activities to verify that the licensee hcs forwarded to recipients or delivered to waste collectors at the time of shipment, a copy of the waste Verify that acknowledgement of receipt of the ena ni f est.
Yerify that the licensee hes e procedure ranifest is obtained.
in place to effect an investigation in any instances wherein acknewledgement of receipt of the shipment has not teen received Yerify that procedures are in within the specified period.
place to report such investigations to the appropriate'NRC Regional Office and file the required written report [10 CFR 20.311(d),(e).(f).and(h)).
W eeble T'eview the Itcensee's records to verify that the ap, 6.
disposal site license conditions are being ret.
Verify that the licensee has or file a current version of the disp.:'1 site Itcense.
i' of the Inspections perforrad by the Co nonwealth fnr ar.d on bett C.
Comission are not to include those elements of NRC inspe:{on proce.
d tres dealing with evaluation of the Itcensce's writter. ;.Nd1res.
equipment, quality control progre.:as, training programs n.,teffing.
!!!.. DOCUF.ENTATION OF lhSPECTION FINDINGS, Fo)1 ewing each inspection. the Com.sowcalth will document the was I
covered and findings of the inspectien in an inspection repor, t. zing guidance set out ir URC Inspection a.td Enforce /.ent mnual Cha;; rs Fo11 cuing Comonwealti management approval, the report 0610 and CC11.
util be sent to the NRC contact listed in Section 9 of the.5%:1ree-ment with a copy to the licensee.
The Comonwealth will coit;.i s.e and forward the inspecticn report to the HRC within 30 days of cwale-tion of the inspection. Following appropriate NRC review, tl.e report will be placed in the Pubite Document Room and a request sent to the licensee by the NRC for proper corrective action if deemed necessary.
For those inspections performed by the Comonwealth which resci t in deficiencies in compliance with NRC regulations, the Comonw?alth shall identify the deficiencies in the coger letter transmitting the report, ar.d "-
specify that any enforcement action is a responsibility 0" the NRC.
I, In addition, when any findings which would become a violation once the shipment departs the plant gate are identified, such findings should be i
furnished to the licensee and the NP.C Resident Inspector before the it is the Connission's sole dis-shipment departs the Itcensee's site, l
cretion as to whether the licensee will be requested or ; equi.d to take 4
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s, corrective action or to respond to discrepancies in compliance with NRC Commonwealth
' ' regulations as a result of findings from these inspections.
a inspectors will provide support to NRC during any hearings and other r
meetings relating to their inspections, as re.gired.
IV. CHANGES 10 IMPLEMENTING PROCEDURES These implementing procedurer may be changed by mutual written agreement the Director Division of Radiation Safety and Safeguards, NRC, j
.betwei.)
and the Chief, Division of Nuclear Safety, Commonwealth of Pennsylvania.
FOR THE NUCLEAR REGULATORY COMMISSION
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ivision of Raciation Safety and Safeguards Dated; do.$.5"
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Margh 25, 1988 FREED 0'A 0F INFORMA1105 MIENUUI l
Director Office of Administration
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U.S. Nuclear Regulatory Commission g kh %3'd/'1fk Washington, D.C.
20555 r
l In re:
Freedom of Information Act Request No. 88 __, Concerning Pilgrim Nuclear Power Station
Dear Sir:
In accordance with the provisions of the Freedom of Information Act, 5 U.S.C. $552 and Part 9, Subpart A of 10 C.F.R., it is requested that the records identified below be made available for inspection and copying i
1.
Records of any votes taken by the Commission, and records or transcripts of Commission meetings, with respect to the shutdown of the Pilgrim Nuclear Power Station, or the restart thereof, on or after April 12, 1986.
I 2.
All SECY papers, attachments thereto, records and other materials supporting or forming the basis for positions taken therein on the subject of the Pilgrim Nuclear Power Station, prepared on or after January 1, 1980.
3.
All records prepared or dated on or after January 1, 1980 (but excluding documants included on Docket No. 50-293 accession listings available from the Public Docurent Room) of NRC Region I, the Office of the Executive Director for Operations, the Office of Inspection and Enforcement, the Office of Investigations, the Office of Nuclear Reactor i
Regulation, the Office of Nuclear Materials Safety and Safeguards, the Advisory Committee for Reactor Safeguards, the Office for Evaluation of Operational Data, and the NRC Emergency Operations Center which discuss, refer to, take positions on, or form the basis for decisions concerning, the performance of the Pilgrim Nuclear Power Station in the followinc areas p % n.,,,_
,rm i
o o v o cm i t
-2 A.
Management B.
Staffing C.
Organization and Organization Structure D.
Radiation Protection E.
Quality Assurance F.
Surveillance G.
Maintenance l
H.
Offsite Emergency Planning 1.
Fire Protection J.
Security K.
Man.gement Response to NAC Regulatory Activities 3
4.
All records of Region I, the office of Nuclear Reactor Regulation, the Commission, the Of fice of Inspection and Enforcement, or other Staff or Commission offices relating to, discussing or forming the basis or support for, the Director's Decision (00-87-14) dated August 21, 1987.
i 5.
All records (other than those categories of documents extiuded from Item 31 of any office referred to in Item 4, above, discussing, describing, assessing, evaluating, or
)
otherwise relating to actions by the NRC staf f, FEMA, the ACRS, or other NRC or Commission of fices, to follow-up or l
4 j
monitor actions by Boston Edison Company, the Commonwealth i
of Massachusetts, other jurisdictions within the 10-mile emergency planning zone for Pilgrim Nuclear Power Station, to address issues raised in the Director's Decision (DD i
- 14) dated August 21, 1987.
6 6.
All records of the NRC offices referred to in Item 4 l
discussing, describing, assessing or evaluating, or otherwise relating to actions of the NRC staf f to evaluate the July 1987 Rentart Plan, and other actions by Boston Edison Company, its agents or contractors, relating to the i
restart of the Pilgrim duelear Power Station.
i 7.
All records of communications (whether written or oral and occurring from April 12, 1986 to the present) between any of fice of the NRC Staf f, or of the Commission or of fices reporting directly to it, and Doston Edison Company,
(
concerning the status or startup of the Pilgrim Nuclear t
Power Station.
f 8.
All records of communications (whether written or oral, and j
occurring from April 12, 1986 to the present) between any i
of fice of the NRC Staf f or of the Commission or of fices l
reporting directly to it, and FEMA, other referal or State l
agencies or governmental entities, or persons concerning the status, startup, or issues relating to startup, of the Pilgrim Nuclear Power Station.
1 J
l
l 3-l 9.
All records in the possession of any NRC Staff or Commission office pertaining to (a) the evaluation by FrHA, NRC. or any other entity or agency, of the adequacy of offsite emergency plans for the Pilgrim Nuclear Power Station, and (b) the conduct and/or evalustion of drills, full scale / full i
participation or partial scale / partial participation exercises conducted or planned for the Pilgrim Nuclear Power t
l Station.
For purposes of this request, "record" or "document" is l
l defined to include, but not be limited to, notes, memoranda, I
reports, meeting minutes, logs, transcripts, letters, position or i
policy papers, interpretations of requirements, and guidance l
documents, and refers to draf ts as well as any final version of j
.sny record or document requested.
l Sine ly,
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R. Q e t) tact, son,esq.
(202)944-438a GEJ/Ve9 i
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