ML20236B172
| ML20236B172 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 11/17/1987 |
| From: | Bellamy R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Dinan M AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML20236B042 | List: |
| References | |
| FOIA-88-198 NUDOCS 8903200401 | |
| Download: ML20236B172 (1) | |
Text
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, fg NW I 7 1937 Ms. Mary A. Dinan 15 Jeremiah Drive hfMd -
Duxbury, Massachusetts 02332
Dear Ms. Dinan:
Your letter of October 27, 1987, our recent telephone conversations, and our conversation at the Duxbury Public Meeting on October 29, 1987, communicated a r concern that recent Boston Edison submittals were not appropriately characterizing necessary data needed in the offsite emergency planning process for the Pilgrim Nuclear-Power Station. I am sending you as an attachment to 3 this letter, a clarification I have received from Mr. Ralph Bird, Senior Vice President - Nuclear for Boston Edison, Mr. Bird indicates that the studies they have conducted, particularly for sheltering beach / transient populations, are designed to provide the town with the necessary data to allow the town to
- identify final usable shelters.
I have forwarded an October 13, 1987 letter from the Duxbury Citizens Committee on Nuclear Matters with similar concerns, and the October 21, 1987 letter.from Boston Edison, to the Federal Emergency c Management Agency Region I office in Boston for their use in the continuing l review of offsite emergency preparedness around the Pilgrim Station.
- Sincerely, Original Signed By: ;
Ronald R, Bellamy j t
Ronald R. Bellamy, Chief l' Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety i' and Safeguards Attachments: 1 Letters dated October 13, 1987 '
October 21, 1987 .
October 27, 1987 I bec: i T. Martin l W. Lazarus' l D, Matthews !
R. Weissman R. Blough I I
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In re: Freedom of Information Act Request l No. 88 __, Concerning Pilgrim Nuclear Power
! Station
Dear Sir:
In accordance with the provisions of the Freedom of i Information t ':t, 5 U.S.C. 5552 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:
- 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.
- 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.
I 3. All records prepa ldated on or after,J(nTar 1, 1980 (but excluding d'ocument 0-293 accession list'Ings ava$js1able ' included fromon Dock'et the PublicNo.
Doc ent Room) of NRC: Region Operations I, the
/ the Of fice0,f of fice of the Executive Inspecti6n and Enfor Diment, ector forthe/,e'-
Office of Investigations, the Office of Nuclear Reactor /'
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I Regulati6n,theOffipeofNucle'arMaterialsSafetyand' Safeguards,theAdv$soryComm'itteeforReactofSafeguards,
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the Office for Evalpation Qf Operational Datar, and the d NRC Emergency Operatioqs Cente'r which discuss, r pfey/to, take positions on, or fqrm the basis for decisionnW oncerning,
, thd performance of (thp' Pilgrim Nuclear Power Station in the /
pd11owingareas:
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a A. -Management B. Staffing i C. Organization and - Organizatif..- 5tructure {
D. Radiation Protection E. Quality Assurance F. Surveillance G.- Maintenance-H.- Offsite Emergency Planning ,
I. Fire Protection J. Security y, . Management Response toL NRC ~ t .:latory Activities
- 4. All. records of Region I, the' Office'of Suclear Reactor' Regulation, the Commission, the Of fice of Inspectio'n and Enforcement, ol other Staf f or Commiss:,on.of fices relating to, discussing or forming the basis or support for, the-Director's Decision (DD-87-14) dated A; gust 21, 1987.
- 5. All records (other than those categories of documents excluded from Item 3) of any office referred to in Item 4, above, discussing, describing, - assessi..g, evaluating, or otherwise relating to actions by the EC staf f,. FEMA, the j ACRS, or other NRC or Commission of fices, to follow-up or- l monitor actions by Boston Edison Compa .f, the Commonwealth i of Massachusetts, ot'.er jurisdictions within the 10-mile ;
emergency planning zone. for Pilgrim Nu: lear- Power Station, Q to address issues raised in the Direct:r's Decision (DD 14) da ed August 21, 1987.
9
- 6. All records of the NRC of fices referred to in Item 4 discussing, describing, assessing or e taluating, or ;
otherwise relating to actions of the NRC staff to evaluate i
the July 1987 Restart Plan, and other actions by Boston !
Edison Company, its agents or contractors, relating to the i restart of the Pilgrim Nuclear Power S ation.
- 7. All records of communications (whether written or oral and l occurring from April 12, 1986 to the present)'between any !
of fice of the NRC Staf f, or of the Com.ission or of fices j reporting directly to it, and Boston Edison Company, 1 concerning the status or startup of the Pilgrim Nuclear Power Station.
- 8. All records of communications (whether written or oral, and l occurring from April 12, 1986 to the present) between any ,
of fice of the NRC Staf f or of the Commission' or of fices . I reporting directly to it, and FEMA, other Federal or State' agencies or governmental entities, .or persons concerning the status, startup, or issues relating tc startup, of the Pilgrim Nuclear Power Station.
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- 9. All records in the possession of any NRC Staf f. or Cor. ssion of fice pertaining to ( a ) the evaluation by FEMA, NRC, er any other entity or -agency, of the adequac/ of of f site erergency plans for- the Pilgrim Suelear Power Station, and (b) the
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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 l Station.
1 For purposes of this request, " record" or " document" :s de fined to include, but net be' limited to, notes, memorands, reports, meeting minutes, legs,. transcripts, letters, posi ;on or policy papers, interpretations .of l requirements, and guidance documents, and refers to draf ts as well as any final versi:.. of any record or document requested.
Sine ly, l l' f k eE Jo son, Esq.
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L/ tw The Honorable William B. Golden Massachusetts State Senate Boston, Massachusetts 02133
Dear Mr. Golden:
1 This is in further response to your Petition of July 15, 1986 requesting that the Nuclear Regulatory Comission order the Boston Edison Company to show cause why the Pilgrim Nuclear Power Station should not remain closed or have its
. operating license suspended by NRC until the licensee demonstrates that the issues raised by you have been resolved. Your Petition is based on allegations of: (1) numerous deficiencies in licensee management, (2) inadequacy of the existing radiological emergency response plan, and (3) inherent deficiencies in the facility's containment structure. You also request that we require the ,
licensee to submit a feasibility study on all possible structural modifications prior to NRC approval.of specific modification proposals.
Pilgrim is presently in a shutdown status and we have been infonned by the licensee that it will not be ready to comence start-up until April 1987.
Start-up will not be permitted until the NRC determines that there is reasonable assurance that the public health and safety will be protected.
That determination will involve consideration of the licensee's readiness to operate the facility including licensee management, emergency planning and containment issues related to those outlined in your petition. ~
We believe that it would be more meaningful to fonnally respond to your Petiti'on after the licensee has had an opportunity to address issues outlined in your petition and the NRC has had an opportunity to review the licensee's actions.
Concerning your request that NRC schedule a comprehensive public hearing to address the issues raised in the Petition, we would be happy to meet with you and other petitioners to discuss these matters as well as the overall status of NRC's regulatory activities at Pilgrim when the licensee has completed j those actions necessary for restart of the plant. Our Philadelphia Regional office will contact you to further discuss this matter and to arrange for an appropriate time and setting. i Sincerely.
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s M. Taylor Director ffice of Insp ction and Enforcement SL in .,
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\ ..... / October 26, 1987 Sta. Ac.1cu ha M NOTE TO: F. Miraglia, NRR R. Starostecki, NRR
$. Collins, R1 FROM: Bruce A. Boger, Assistant Director for Region i Reactors
, Division of Reactor Projects I/II- !
SUB,1ECT: RESPONSE TO MASSACHUSETTS ?.206 PETITION OF OCTOBER 15, 1947 REGARDING PILGRIM On October 23, 1987, representatives of Plant Systems, OGC, Emergency
, Preparedness, and Region. I (by telephone) met with the Pro.iect Manager and I to discuss the proposed schedule and approach to the response to.the Massachusetts 2.206 Petition of October 15, 1987. Assignments and due dates for inouts to the PM are shown on the Enclosure. Several initial observations regarding our approach are inade:
-The initial response to Petitioners (letter of receipti needs to be issued promptly. It must put the issue of Petitioners' request for preventing any BEco actions leading to restart (Power Ascension Program) in perspective with current plant activities that appear to be leading to restart.
-The management issues appear to call for'a response similar to our response of Auoust 21. 1987 to Senator Golden.
-Plant Systems will have to determine if the containment concerns are essentially the same as the issues dealt with in our response to Senator I Golden on August 21, 1987. If additional issues must be dealt with, additional time will be~ required for their portion of the response.
-Emergency preparedness issues in this Petition are different than those issues raised by Senator Golden, and a conclusion regarding these issues may hot be possible at this time.
The point of contact for this activity will be R. Wessman. The TAC number to be used is 66425 Bruce. A 80 r, Assistant Director for Region I Reactors Division of Reactor Projects I/11
Enclosure:
As stated cc w/ enclosure:
T. Murley A. Thadani &@Slath W. Russell J. Craig J. Kudrick
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RI LB Management (Incl. SALPs, s_e cu ri t_y , enforce /8 PRA 11/6 11/13 i
l SPLB Containment Adequacy s Assess if issue.= similar to Golden 10/30-If like Golden, devel, response 11/13' If unlike Golden, provide approach & sched. 10/30 l PEPB Emergency Preparedness 11/6 PM Integrate inputs and provide to OGC 11/20 kemaining milestones are primarily dependent on completion of the l containment adequacy area, but a dispatch target of early December is desired.
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\ MAY 2 31986 Docket No. 50-293 Boston Edison Company M/C Nuclear ATTN: Mr. William D. Harrington l Senior Vice President, Nuclear 800 Boylston Street ,
Boston, Massachusetts 02199 j Gentlemen:
Subject:
Systematic Assessment of Licensee Performance (SALP)
Report No. 50-293/85-99 l I
This letter refers to the Systedatic Assessment of Licensee Performance (SAlp) j of the Pilgrim Nuclear Power Station for the period of October 1,1984 through October 31, 1985, initially forwarded to you by our February 18, 1986 letter (Enclosure 1). This SALP evaluation was discussed with you and your staff at
, a meeting held in Plymouth, Massachusetts on March 5,1986 (see Enclosure 2 for l attendees). We have reviewed your March 26, 1986 written comments (Enclosure 3) l and herewith transmit the final report (Enclosure 4).
1 Overall, your performance in the operation of the facility was found acceptable although some areas were only minimally acceptable.
As projected in our letter of February 18, 1986, a special in-depth team in-spection was conducted from February 18 to March 7,1986 (Inspection Report No. 50-293/86-06) to determine the underlying reasons'for the poor performance discussed above. The team found that improvements were inhibited by (1) incom-plete staffing, in particular operators and key mid-level supervisory personnel, (2) a prevailing view in the organization that the improvements made to date -
have corrected the problems, (3) reluctance, by management, to acknowledge some problems identified by the NRC, and (4) dependence on third parties to identify i problems rather than implementing an effective program for self-identification of weaknesses. We believe these findings confirmed the SALP Board conclusions.
i We acknowledge your discussion of program and staffing improvements in plant operations, radiological controls and emergency preparedness. However, we ;
believe that the success of your programs depends upon resolution of the four l principal factors inhibiting improvement noted above which, in turn, depends l heavily on management attitudes and aggressive followup. In this regard we l request that you be prepared to discuss the scope, content and schedule of each '
improvement program at a management meeting scheduled for 1:00 p.m. on June 12, 1986 at the NRC Region I Office.
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l The purpose of such discussions will be to better understand how BEco manage-ment is monitoring the programs and the milestones that.have been established.
This meeting is the first of a series of periodic management meetings which will continue until it is clear to me that (1) your schedules are being met ,
(2) real progress is being achieved and (3) it is highly likely that such progress will continue.
Sincerely, Thomas E. Murley Regional Administrator
Enclosures:
- 1. NRC Region I letter, T. Murley to W. Harrington, February 18, 1986
- 2. SALP Meeting Attendees, March 5, 1986
- 3. BECo Letter, W. Harrington to T. Murley, March 26, 1986 4 SALP - Final Report cc w/ enc 1:
L. Oxsen, Vice President, Nuclear Operations A. Pedersen, Station Manager Joanne Shotwell, Assistant Attorney General Paul Levy, Chairman, Department of Public Utilities W. J. Nolan, Chairman, Plymouth Board of Selectmen Plymouth Civil Defense Director Senator Edward P. Kirby Public Document Room (POR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector Commonwealth of Massachusetts (2)
Chairman Palladino Commissioner Roberts Commissioner Asselstine Commissioner Bernthal Commissioner Zech
m Boston Edison Company 3 bec w/ enc 1:
Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o enc 1)
Section Chief, DRP W. Raymond, SRI, Vermont Yankee T. Shediosky, SRI, Millstone 1&2 H. Eichenholz, SRI, Yankee P. Leech, LPM, NRR T. Murley K. Abraham (2 copies)
D. Holody J. Taylor, IE l
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...../ Keseo or causs:4.esseessytvAssia somos Docket No. 50-293 Boston Edison Company M/C Nuclear ATTN: Mr. William.0. Harrington Senior Vice President, Nuclear 800 Boylston Street Boston, Massachusetts 02199 s
Gentlemen:
Subject:
Systematic Assessment of Licensee Performance (SALP) Report No.
r 50-293/85-99 -
The Region I SAlp Board has reviewed and evaluated the performance of activities at the Pilgrim October 31,.1985. Nuclear Power Station for the period October 1,1984 through-The results are presented in the enclosed report. A meeting to discuss this assessment has been scheduled for 1:00 p.m. on March 5,1986.
The meeting is being held ori-site so that appro~priate senior corporate management and plant officials can discuss with us the' strengths and weaknesses noted. It is our intent that the meeting provide a forum for a candid. exchange. of views.
^
.o We have found the ~overall performance at the' Pilgrim Station to be acceptable
'during the 'recent assessment period. T.he. steady upgrading of plant hardware has been noteworthy during this period. Notwithr' Jing these hardware improvements, there are areas.such as operations, . 41ntenance, . radiological controls NRC.
and emergency preparedness where marginal performance is o.f concern to During its review, the SAlp Board found a recurrent theme of inadequate personnel staffing and inadequate supervisory oversight at the plant. A special concern we have is with regard to the chronic shortage of licensed reactor operators and the routine exceeding of NRC overtime guidelines.
The enclosed review of SALP history for Pilgrim shows a pattern of performance that raises other questions. ~ For instance, the areas of operations and radiological controls have shown essentially no improvement over the years.
In other areas, such as maintenance, surveillance and . emergency preparedness, there performancehave been improvements in later years. This followed by a slippage back to the lower. level of ,
inability to improve performance, or sustain improved performance once achieved, is of concern to us, and we would like to discuss your views on the reasons for this. .
In order to better understand the nature of your on-site efforts, we are conducting an in-depth team inspection. One.of our objedtives is to attempt.to determine the underlying reason (s) for the poor performance discussed above and to ascertain plant operations.whether or r.ot they could have an adverse impact on the safety of Likewise, the results of this inspection will be used to ,
assess whether your corrective action programs are properly structured and focused to achieve the desired improvements.
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. FEB 181986 evaluation of the situation.In preparation for the SALP meeting, please your comments in writing within 30 days of receipt ofAfter thisthe letter.Fo we will provide you our conclusions relative to them a our results from the team inspectibn.
3 Sincerely, 4
I ???
Thomas E. Murley Regional Administ
Enclosures:
- 1. SALP Report 50-293/85-99
- 2. Pilgrim SALP History cc.w/ enc 1: *
' A. V. Morisi, Manager, Nuclear Management Services Department .
C. J. Mathis, Station Manager..
Joanne Shotwell,-Assistan,t Attorney General ,
Paul levy, Chairman, Departnient of Poblic Utilities * .
- W. F. Nolan, Chairman, Plymouth Board of Selectmen * }
- Plymouth Civil Defense Director I 5enator Edward P. Kirby
- Pub 1'ic Document Room (POR)
Local Public Oc:. e t Re:- (Lo0R)
Nuclear Safity inforanlon Center (h5:C)
NRC Resident Inspector Commonwealth of Massachusetts (2) b:c w/en:1 l Regicn ] Docket Re:- (with ce currences)
Manage er.t Assistant, DD'A ( w. e e r.t i )
DRP 5ection Cr.ief W. Raymond, SRI, Vermont Yankee T. Shediosky, SRI Millstone 1&2 H. Eichenholz, SRI, Yankee P. Leech, LPM, NRR D. Holody, RI J. Taylor IE SALP Board Members T. Murley K. Abraham
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E9m190_Edis90_G9e9aDr S. J. Sweeney President and Chief Executive Of ficer W. D. Harrington Sr. Vice President J. P. Tyrrell Executive Vice President J. M. Lydon Executive Vice President J. E. Howard Vice President A. L. Oxsen Vice President H. F. Brannan Duality Assurance Manager R. N. Swanson Nuclear Engineering Manager A. V. Morisi Assistant Director, Dutage Nanagement C. J. Mathis ' Nuclear Operations Manager P. E. Mastrangelo Chief Operating Engineer E. Zi emi ansLi Management Services.Section Manager M. N. Prosee Maintenance Section Manager T. Sowdor, Radiation Section Manager R. E. Salva Emergency Preparedness Coordinator D. J. Cronin Nuclear Material Services Manaoer E. Eldridge Chief Radiation Engineer J. A. Seer, Technical Section Hanager R. Sherry Chief Maintenance Engineer J. A. Nane Senior Radiation Engineer J. D. Leyes Regulatory Affairs Group Leader D. Sukanel. Station Services Group Leader E. Gr e b en. Compliance Group Leader M. Pyle Radiation Protection Training Coordinator T. Sol l enber ger Radiation Protection / ROR 's C. Gustin Public Information
- 6. Tas Puolic Information
- 0. A. M:lls CMGL C. Smith Hydro-Nuclear Services J. Crockfore Patriot-Ledger F. Creer e Enterprise NWGlERC_BE9Wle19tY.G95GLEEl90 T. E. Murley Regional Administrator, Region 1 R. H. Starostecki Director, Division of Reactor Projects (DRF)
R. Vollmer Deputy Director,0ffice of Inspection and Enf orcement T. T. Martin Director, Division of Radiation Safety and Safeguards W. F. Kane Deputy Director, DRP J. A. Zwolins6 i Project Director, Office of NJclear Reactor Regulation (NRR)
E. C. Wenzinger Chief, Projects Branch 3,DRF i L. E. Tripp Chief, Projects Section 3A,DRF
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In o vIc'e'P e ident - Nuclear BECo Ltr. #87-146 U.S. Nuclear Regulatory Commiscion Document Control Desk Hashington, D.C. 20555 Oocket 50-293 l i License No. DPR-35
Subject:
Boston Edison Company Request for.
Exemption from 10 CFR Part 50,- d Appendix E.Section IV.F.
Dear Sir:
In accordance with 10 CFR. section 50.12(a), Boston Edison Compny requests .
that the Nuclear Regulatory Commission (NRC) grant a one-time exemption from the requirements of 10 CFR Part 50, Appendix E, Section IV.F.,.that would autnorize the next biennial full participation. emergency. preparedness exercise for the Pilgrim Nuclear Power Station (Pilgrim) to be' conducted in the second quarter of 1988.. The schedule for' future biennial exercises will not be
. affected by this one-time exeinption, but rather will. continue.to provide that such exercises will-be conducted every second year (i A ,'the following biennial exercise will be held in 1989).
The proposed deferral of the full participation exercise has been discussed with the Commonwealth of Massachusetts (Commonwealth) and local emergency response officials. All of the parties'have indicated that they support the-proposal.
The request will not affect the onsite exercise at Pilgrim planned for l December 9, 1987.
The requested exemption is necessary because the Commonwealth, the local governments within the ten-mile plume exposure pathway emergency planning zone (EPZ) and the two emergency reception center communities are at present engaged in implementing numerous improvements in their offsite emergency preparedness programs, with the assistance of Boston Edison. These improvements include revision of the emergency plans of the local governments, revision of the Massachusetts Civil Defense Agency (MCDA) Area II plan as well as the' Commonwealth's state-wide plan, the development of. revised related procedures, the. development and implementation of training programs for officials and emergency personnel, and the upgrading of Emergency Operation .
Centers (EOC's). A substantial commitment of rasources and time has been made to accomplish these improvements, and the work is expected to continue through-the remainder of the year and early 1988. Infmmst on in this reccrd was de'eted-
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In view of these extensive ongoing efforts, the Commonwealth and the local
- governments have indicated that they are not able to participate.in an exercise during calendar year 1987. Moreover, it. is apparent that under these :
circumstances, conduct'of the full participation exercise will be much more g effective after the ongoing improvements have been implemented. 'In granting-one-time exemptions authorizing deferral of exercises for licensed plants in the'past, the NRC has recognized that the'most effective and beneficial exercises are those which include the full-scale participation of State and local governments and that it is appropriate to defer an exercise until program revisions or facility i;provements have-been completed.-
Since the last full participation biennial exercise at Pilgrim, Boston Edison has held an onsite exercise at Pilgrim in December 1986; has held quarterly onsite drills in March, June' and' August of 1987; and has scheduled its annual onsite exercise for December 9,1987 (in which the Commonwealth wi11' exercise various offsite objectives as described in BECo Ltr. #87 -147 ,
" Scheduling of Pilgrim Onsite Exercise"). The previous exercise and drills l have included limited participation by the Connonwealth, and the March and ~
June 1987 drills included limited participation by several of the towns. The towns within the EPZ have also cooperated in the full scale siren test 1 reviewed by FEMA, which was conducted on September 29, 1986. In addition to. (
its activities involving Pilgrim, the Commonwealth has also participated in full participation exercises at the Yankee Nuclear Power Station in June 1986 and is scheduled to participate in a full participation' exercise at the l Vermont Yankee Nuclear Generating Station during the week of November 29, 1987. l This request meets a number of the special circumstances listed in Section 50.12(a)(2) .
First, granting the request will provide only temporary relief from the applicable regulation and the licensee has made good faith efforts to comply with the regulation. Over the past year Boston Edison has assisted Commonwealth and local authorities in a variety of ' ways to accomplish as many improvements as possible in their offsite emergency response programs. For example, Boston Edison has developed substantive information for the enhancement of those programs. The major products of this effort include the
" Pilgrim Station Evacuation Time Estimates and Traffic Management Plan Update" (August 18, 1987) prepared by KLD Associates, Inc. and "A Study to Identify.
Potential Shelters in the EPZ Coastline Region of Pilgrim Nuclear Power Station" (August 1987) prepared by Stone & Hebster Engineering Corporation, as well as information generated in surveys to identify the special needs and transportation dependent populations within the EPZ.
In addition, Boston Edison is providing assistance to the local governments in their offsite emergency program enhancement efforts in accordance with the Massachusetts Civil Defense Act of 1950 (Chapter 639, Section 15, Acts of 1950 as amended). This assistance includes the provision of two professional planners to work under the direction of the officials of each town within the EPZ in upgrading its plan, procedures and training; one.
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P U. S. Nuclear Regulatory Commission Page 3..
professional planner to assist each reception. center community; and four professional; planners working under the. direction of MCDA in the upgrading of l, the.MCDA Area II and Commonwealth program. -In the first half'of 1987. Boston Edison' provided introductory emergency training to about. 350 personnel within the five towns in the EPZ and enhanced introductory training modules are currently being prepared for. review by the MCDA' prior-to further
-implementation. The planners provided by Boston Edison have also begun to l'
prepare task-based modules for training of specific categories of emergency personnel and will be available to participate in the training programs. In addition, Boston Edison is executing agreements'with each of the five towns within the EPZ, as well as the two reception center communities, for assistance in the renovation of their EOC's. Moreover, four of the five EPZ towns and both reception center communities, to date, have accepted BECo's offer of funding support for. full-time civil defense staff positions.
Second, literal compliance with the regulation would not serve its underlying purpose and would result in undue hardship to Commonwealth and local emergency response agencies by requiring an exercise of portions of the offsite emergency plans that are in the. process of significant revision and improvement. 'This would necessarily involve disruption of the' ongoing process of implementing these changes, and consequently, the imposition of additional costs and delay in accomplishing the planned improvements. The NRC's emergency exercise requirements clearly were not intended to disrupt the orderly implementation of improvements in such manner.-
Finally, because granting the request will allow work to proceed without disruption, it will result in a net benefit to. the public health and safety.
The NRC has acknowledged that flexibility.is appropriate in applying emergency I planning requirements. This flexible approach is especially appropriate in
, . this case, where granting the request will facilitate more prompt and l' effective implementation of improvements.
For all these reasons, Boston Edison asks that NRC grant the requested exemption. In accordance with 10 CFR ll70.12(c), a fee of one hundred and fifty dollars (5150.00) will be electronically mailed to your. offices. If you should require any additional information in connection with this request, please contact either myself or Mr. Ron Varley of my staff (telephone: 617 -
424-3832).
LE. L -
Ralph G. Bird RAl./dlw i
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U. S. Nuclear Regulatory Commission Page 4'
'l cc: Dr. Thomas E. Hurley, Director 1
- Office of Nuclear Reactor Regulation ;
U.S. Nuclear Regulatory. Commission The Phillips Building {
/ Hashington, D.C. 20555 Mr.'R.H. Nessman, Project Manager Division of Reactor Projects - I/II ,
Office of Nuclear Reactor Regulation !
U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue i Bethesda, MD 20814 Mr. Richard Krimm, Assistant Associate Director FEMA 500 C Street - Federal Plaza Washington, D.C. 20472 Mr. Edward Thomas FEMA - Region 1
. J. H. McCormack Post Office and Court House !
Boston, MA 02109 i Hr. Peter Agnes, Jr.
Commonwealth of MA
, Assistant Secretary of Public Safety 1 Ashburton Place - Room 2133 l l
Boston, MA 02108 ,
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U. S. Nuclear Regulatory Commission Region 1 - 631 Park Avenue King of Prussia, PA 19406 i
Senior NRC Resident Inspector ,
Pilgrim Nuclear Power Station )
Rocky Hill Road l Plymouth, MA 02360 1 Henry Vickers, Regional Director FEMA - Region 1 J.H. McCormack Post Office and Court House Boston, MA 02109 -
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