ML20245B773
| ML20245B773 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 03/31/1988 |
| From: | Murley T Office of Nuclear Reactor Regulation |
| To: | Rehm T NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20244D847 | List:
|
| References | |
| FOIA-88-198 NUDOCS 8904260268 | |
| Download: ML20245B773 (214) | |
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MEMORANDUM FOR: Thomas A. Rehm, Assistant for Operations Office of Executive Director for Operations FRON: . Thomas E. Murley, Director Office of Nuclear Reactor Regulation
SUBJECT:
KENNEDY QUESTIONS - 1/7/88 HEARING ON PROPOSED RESTART OF PILGRIM (EDO #003569)
Enclosed are NRR's responses to the questions Senator Kennedy has raised.
l Question 3 was answered by OGC. Where appropriate, answers were reviewed by the Region. If you have any further questions, please contact Suzie Black of iny staff on (X21255). i Thomas E. Murley, Director Office of Nuclear Reactor Regulation
Enclosures:
Kenned.y Responses Distribution \
Central File H. Thompson t PDTSS Rdg E. Beckjord }
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L QUESTION 1. There remains a great deal of uncertainty as to how the NRC will evaluate whether.the Pilgrim reactorz is ready to restart.
As you know, I fully support the adjudicatory hearing process and hope that the NRC will agree that an adjudicatory hearing is the proper way to proceed. I am aware that there has been one public meeting'in Plymouth and that another meeting is contemplated. Would you provide me with a schedule of planned-or proposed future meetings, including the location of the meetings, who will attend from the NRC, and what public involvement there will be at the meetings. I am also interested'in learning if a final decision has been made on !
Governor Dukakis' and Attorney General Shannon's petition.for an adjudicato:y hearing. If a decision has not yet been made, when will it be made?
ANSWER.
The NRC staff and local officials in Massachusetts have engaged in a continuing dialogue on th im s n lojue luded public meetings with the Ply namoer of comerce, the Duxbur'y Board of Selectmen, the
' Massachusetts Joint Committee on Energy, the Massachusetts Legislative Committee on the Investigation and Study of the Pilgrim Station, the Town of Plymouth Advisory Comittee on Nuclear Matters, and others. The NRC staff also participated in a public forum on the Pilgrim situation at the Duxbury 1
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l Kennedy /NRR 3/30/88
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S QUESTION 1. (Continued)- 2 High School on October 29, 1987. This meeting was sponsored by the Duxbury Board of Selectmen. Representatives from some of these groups also have ;
participated in NRC Region I management meetings dealing with the Pilgrim facility, including the Systematic Assessment of Licensee Performance (SALP) meeting held on May 7, 1987. On October 8, 1987, the NRC met with representa-tives of the Commonwealth of Massachusetts in our Region I office. This meeting, which was open to the public, was held to discuss agenda items proposed by the Commonwealth, including emergency preparedness issues, the status of various NRC technical reviews, and inspection activities expected in the next few months.
Subsequently, other meetings have been held with representatives of the Commonwealth discussing the same topics.
The most recent meeting, which was coordinated with the Commonwealth and invited participation by interested members of the public, was held in Plymouth on February 18, 1988 to receive comments on the Pilgrim Nuclear Station Restart Plan.
The following is the projected schedule, location and expected participation for future meetings which are currently planned. The schedules are tentative and subject to change depending on several of the integrated activities being conducted by both the licensee and NRC staff.
i l 1. Public meeting (s) will be held in the Plymouth area, currently projected for late April or early May to discuss the disposition of comments and concerns raised in the February 18, 1988 public meeting. The meeting (s) j will be chaired by NRC senior staff members and members of the public will participate.
Kennedy /NRR 3/30/88
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QL'ESTION 1. (Continu;d) 3 Y *
- 2. A Comission meeting, currently projec ed for une, to brief the Comis-sion on the status of Pilgrim activities relating to plant restart and the NRC staff's plans and schedule for completing their readiness review.
i This will be a public meeting held in the Washington, D.C. area. The $
extent of public participation will be detailed in the Federal Register .
Notice of the pending meeting.
- Jt' A public meeting, currently projected for July, will e held between NRC senior staff and State Senator William Golden and the other petitioners f
who submitted the July, 1986, 10 CFR 2.206 Petition, if the petiti ners desire a meeting. i r.: r:;:rdir,g the 2
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.._ quesuAThismeet&willdisc ons of the petitioners. It will be held in the Plymouth area. The petitioners and members of the pub c wi l participate.
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SAh % oJ L d 3 oSm3_e, 4 M NQt 4 A public meeting wilt be held in the Plymouth area to discuss the results of NRC
_'sJteam ins ection of the readiness of the plant and licensee
-pamand to support the restart and safe operation of the plant. This meeting is tentatively scheduled for July or August.
- 5. The Comission will hold an additional public meeting at NRC Headquarters prior to making any decisions regarding the readiness of Pilgrim to resume operations. The staff will provide a full accounting of its recommendations and supporting bases in relation to the restart of the Pilgrim station during this meeting. This meeting is not currently scheduled. The extent of public participation will be detailed in the Federal Register Notice of the pending meeting.
Kennedy /NRR 3/30/88
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'00fSTION 1. (Continued) 4 Other public meetings, including those with Boston Edison, will be held as circumstances warrant. These meetings will be announced pursuant to NRC staff i
policy on open meetings (43 FR 28058 which is enclosed).
A final decision has not been made on Governor Dukakis' and Attorney General Shannon's petition for an adjudicatory hearing. The petitioners were notif'ed in our letter dated November 13, 1987 that the Petition would be treated as a request for action according to 10 CFR 2.206 of the Commission's regulations.
The staff is nearing completion of their evaluation of the information related to the petition and we expect to render a decision under 10 CFR 2.206 in the near future.
Enclosure:
l Kennedy /NRR 3/30/88 l
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Enclosure to
' UNITED STATES NUCLEAR REOULAT@RY C@MMIS$10N Question ~1 RULES and REGULATIONS Ting te.0MAPTEA 1. CODE OF PEDIAAL A80Ut.ATIONS-ENEABY r -
CCMMISSION NOTICES POLICY STATEMENT 0 Cond'ict of Proceedings -
es an asses - summary of the unclassified and non- reenammaties of the entire seguintory cuanshee sisens proprietary poruons ef such meeunes dructus. AberDE.for over a year and forward the summary to interest
- e half.the Commsensen's attsames cosassuc ucswu ApeucAnoses ed persons unable to attend so that mesmee wese lscasod espama w Pb * "
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.a . p,. - a,y op - reco unendauens, or advice ont be offered
- ase-enne esasementof tbonemidse 2.nes pernut appl 1<. ants to confer in- on the merits of the applicauens Altbeesh starreview of farasany e.ut the NRC techrocal staff durtns the meetins. Ilsenee a span wee dois durtas reviews of domesuc license or when a party or peuuoner Sa seave this sendee whieb permit applications. These aseetings to intervene reeuests. seasonable ef*
have served as an eenential means for forts wul be made by the NRC staff to esaseusdes passits eenth t bdid the enchange of technical informauen inforia the party or petitioner of Ibo sothertsed planten The is easy I and views neos.uary for the technimi forthcoming meetings conducted by supuutag h metow of es " '
review of oppucauensc Pee several the NRC technical stati ao wat appro. and as upmedened -of years other par'.las or potential parties priate arrangements for attendance bearings am schmialedist mem15.
to dossesue licensins proceedinsa as - can be made.15 is recognised that in s. ethm. 3 deny of these well as membere of the seneral public. '
come cases the need for a prompt cotaserm applications fer ting j have, upon reeuest, been permitted to meeting may make it tropensible or in- licensee,if these
( attend applicant.NRC technical stati ese est J practicable to noufy su parties and pe- coachsdod prier to the ties of meetings sa obervers. Howner, the uuoners. The polley described above ese .tnseties, the cost of deley Comunisasee's regulations do nu M* anse cannot procucably be applied to outre that others be permitted to chance encounters between NRC tech-esed sneak bu5eas of Herane attend such informal meetings be* nical staff personnel and other parties thW wiD seek evoid at reduas tween applient and staff. and the or petitioners but such chance encoun- such deh I ' wh**
seneral precuce beins followed in this gare slH not be permitted to serve as a evadabb est de act he rusard has peer been formany art 4cu- Cennieeles e otal enemiteuet lased. 'ftnis statement is intended to source of information for the conduct of licensing reviews. to a fair and beartag pseesse.
provide auch articulauon. It is also Derefase, tbs t' misalan le noted that this matter is mlated to the this polley stat prowlsion for inemaaed public particl* t on the need far 48 F A ssS3s baletoed and
- t conduct of an 7,",8*"M*"g,"rtns IE Id re '" " W M MON 3"****
of stuRao ossa (Denten Reportl. Commission opp tw he many As a seneral matter, the Comentaslon Statement of PoAcy on Condust un fa Wa Mis armi maff try to involve concerned clu. g,ge, - -
coeducttag conten6ous and sens in any Commission acuvity in '
esoples Py and ._ the which they have empressed an intemet. I. Beckpound boards have ormed very Die All specusss senduc*.d4 tF tha h*RC techsucal staff na part of its review of De Comakske bes We 6e det 1: ' *:r. dad to daa! wttk a particular donnestic License or peringt docket of the Atomic Esfe problems no primardy of the boards' applicauen .uncludins an application Licensing Board Panel ( and the
,,, g ,g g for an amendament to a license er current status of p before its g, ggg permat) wGl be open to attendanos by individual boards la a e of public gg all parues ar peuuoners for leeve to muungs, the Coaumi has emandned Individ I adjudicatory boards are intervene in the case. These meetings encours d to expedite the beartag etlonge aH major el ta is i a are intended by the NRC technical Pm y malag &me assagement licenems pruced t la clear that a staff to factiltate an enchance of infor- method already r,oatained in Part 3 of mauen between the appilcant and the B& of difHed bkasfm &e the tassee's Rules and staff. It is espected that the NRC agency as it en ore to meet its tact.nical staff and the applicant will M8Poesibdities the licenciap aros.
gg g,, .I acuvely paructpate in the meeting. Hisle y theease sieb seged to Mk g% h Othere may suand as observers.1Jke- etafreviews bearings webce th berd held emwo hat wise. when moeunes are scheduled be- the atings ase fair,and produae a -
l 1 tween the staff and other parues or reguesemb oppucaabnee formaalear- db ludm $iluehty P88'er P OP8g,,y,,,,,,
l peuuoners.. applicants would be per. then edestuetely protest the l smitted to attend only as observers. * , MC "*"""T beelth and anfaly and the I
ne seneral policy of open meetins, m* ebue end dur i
described above win admit of onts a few eseepuons, which must be ap.
F@M br enmuse theseslaar medy *e opesets.Blenderte a5 et tbs pe==d-st dovessa proved by the Director of the relevant e time beamage en a mantes of g, gg, gg,,,,,,, ,,
-C dlvision. Per example, some pertens snap not be permitted to attend mee'*
o 11cumse eppMastimme smy net concheded belosessmetrusilmate by altbag besde h arrug dagmemTheComadselsh enos whe:e claasti.ed or proprietary Me eged.This estantienise gg g formauon (includins sensluve safe' consegnance of the Thsen beimideas immaded h redmalb M suards information)is to be discussed
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( na NP.C staff will prepare a written guidabnea est farth are not to be PS.CN.1 December 31,1985 (reset)
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e OUESTION 2. During your testimony, you mentioned that the NRC. had asked i
Boston Edison a series of questions relating to direct torus venting. Specifically, Edison was asked when and under what conditions they would utilize a direct torus vent. - At the time of the hearing, Boston Edison had not yet responded to the ,
l NRC's questions. You indicated that a response would be i necessary before the NRC could proceed with considering whether the installation of a direct torus vent was warranted at
. Pilgrim. Has Edison responded to the NRC's questions? If so, has the NRC made a decision on whether it will permit the licensee to make the direct torus vent improvement?
ANSWER, The Boston Edison Company (BEco) has not yet responded to our questions of August 21, 1987 relating to their submittal of a design for a direct torus vent (DTV). As stated in the testimony, the questions must be resolved before the system is placed into service. The vent line, which would be capable of providing a hardened (high pressure) path from the containment torus structure to the plant stack, has physically been installed with blind Ganges to isolate the DTV from the existing low pressure vent path through the plant Standby ;
Gas Treatment System to the plant stack. The install a on of the piping, supports, and blind flange were installed by BEco pur.,3nt to provisions of ;
1 10 CFR 50.59.
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Kennedy /NRR 3/30/88
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QUESTION 2. (Continued) 2 10 CFR 50.59 allows licensees to make changes to their facility as described in the safety analysis report without prior Comission approval, if the proposed change does not insolve a change in the technical specifications incorporated in the license or an unreviewed safety question.
1 An inspection team was sent to the Pilgrim site during the first week of March to review the non-operational physical plant modification. The n A tive of the inspection was to verify the adec,uacy of the plant modification and associated licensee safety evaluations. The vent line is not operational as installed, however, we chose to confirm that the plant modification (including -he in-stc11ation of the piping, supports and blind flange) does not adversely affect f
the function of the other plant systems, structures or the plant response under !
accident conditions. The inspection team concluded that the plant modification i i
was adequately evaluated by the licensee and the design change had been made ;
with no adverse impact on plant safety. The conclusion was based on a system walkdown, inspection of the supporting documentation and interviews with utility personnel. At this time the NRC has not made a decision on allowing i the installation or operation of a direct torus vent system, i i
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QUESTION 3. During the hearing, I asked you how many times the NRC has been formally requested to hold adjudicatory hearings in relation to restarting or licensing a nuclear reactor. I would be interested in learning who made the requests (i.e., whether they came from the licensee, from a State government, or elsewhere), and whether '
the NRC acted favorably or unfavorably on the requests (and/or petitions)?
i ANSWER.
i
'There have been contested operating licensing proceedings for most operating nuclear power plants. Our log shows some 80 proceedings. There have also been some 70 proceedings involving amendments to power plants' operating licenses. Many amendment proceedings could affect continued reactor operation.
We have identified 6 proceedings directly involving power plant restarts:
Browns Ferry - 1975; Changes involving startup after fire; Intervenor B. Garnar. Comission authorized operation.
Humboldt Bay - 1977; Request to delete seismic upgrade requirements allowing startup of the facility; Intervenor Sierra Club, Friends of the Earth.
Proceedings terminated after licensee notified NRC of intent to decommission the facility.
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QUEST 10N 3 0 (Continued) 2 Trojan - 1978; Proceedings on Comission Order requiring modifications to Control Building; Interveners D. McCoy, C. Parson, N. Bell, E.Roso11e, S.Willingham, Coalition for Safe Power, Columbia Environmental Council, Bonneville Power Authority, State of Oregon. Comission authorized operation.
Rancho Seco - 1979; Proceeding to permit operation after post-THI shutdown Order; Licensee requested hearing; Intervenor California Energy Comission et.al. Comission authorized operation.
Three Mile Island 1 - 1979; Proceedings to permit operation after post-TMI shutdown Order; Interveners Commonwealth of Pennsylvania, UCS, TMI Alert, Mr.& Mrs. Aamodt. Comission authorized operation.
I San Onofre Unit 1 - 1984; Seismic shutdown Order recission; Hearing requested by Sierra Club et.al. Comission denied request for hearing and authorized operation.
We also looked at 81 published Director's Decisions issued since February,1979 that relate to power reactors. In 30 of those cases petitioners made requests under 10 CFR 9 2.206 that could fairly be construed as requests for adjudicatory hearings. (Petitioners rarely used the word " adjudicatory".)
A brief explanation of the process associated with petitions filed under 10 CFR i 2.206 is called for. Under 10 CFR 2.206, any person may file a request with an NRC director "...to institute a proceeding pursuant to i 2.202 [c;ders to show cause] to modify, suspend or revoke a license, or for such other action j l
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QUESTION 3. (Continued) 3 as may be proper." There is no requirement for the petitioner to demonstrate a legal interest in the matters raised in the petition.
Only ,i_f the NRC institutes a proceeding in response to the 2.206 petition, will members of the public be given an opportunity to request a hearing and demonstrate the requisite legal interest in the proceeding so as to be allowed to intervene. The demonstration of requisite interest is not affected by the fact that the petitioner to intervene had filed a 2.206 petition; it is an independent requirement.
Thus, granting an adjudicatory hearing directly in response to a 2.206 petition would be legally ine,ppropriate. The reason is that a 2.206 petitioner has no right to a hearing. Illinois v. NRC, 591 F.2d 12, 14 (7th Cir., 1979). For this reason, the NRC has never granted an adjudicatory hearing in direct response to the request of a 2.206 petitioner.
Nevertheless, in two instances, requests by petitioners did indirectly result in adjudicatory hearings. In one case, an Order to Show Cause issued in response to a petition, see Dairyland Power Cooperative (Lacrosse Boiling Water Reactor), DD80-9, 11 NRC 392 (1980), resulted in a proceeding. In a second case the Commission decided to hold a discretionary adjudication to resolve
! safety issues raised by a petition and Director's Decision responding to the petition. See Consolidated Edison Co. of New York Inc. (Indian Point Unit No. 3), DD-80-55, 11 NRC 351 (1980). See also Consolidated Edison Co. of New York Inc. (Indian Point Unit No. 3). CLI-81-1, 13 NRC 1 (1981).
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1 QUESTION 4 You may be aware that the Massachusetts State Legislature is considering a bill which would expand the Emergency Planning Zone around nuclear power plants in Massachusetts to 50 miles.
Would the NRC support this initiative?
ANSWER.
We assume that the proposal for expanding the Emergency Planning Zone (EPZ) referred to in your question relates to the current 10-mile plume exposure pathway EPZ, as there is currently a 50-mile EPZ for the ingestion exposure pathway. It is the NRC view that the current detailed planning requirements for the 10-mile plume exposure oathway EPZ and 50-mile ingestion exposure pathway EPZ are adequate to assure that prompt and effective actions can be taken to protect the public in the event of an accident. Thus we do not believe there is a need from a public health and safety standpoint to expand )
l the 10-mile plurae exposure pathway EPZ around nuclear power plants to 50 miles.
However, this does not at all preclude a State and utility from working together l to develop supplemental planning for the plume exposure pathway for areas beyond 10 miles if they so desire. !
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l QUESTION 5. In your prepared statement you said, "The NRC will not permit the facility (Pilgrim) to resume operation until corrective actions satisfactory to the NRC have been taken to address the Emergency Planning deficiencies identified by FEMA". Have those l
l corrective actions been taken? You also indicated that the NRC .l would allow the plant to restart without the resolution of all l Emergency Planning deficiencies. What deficiencies would the NRC allow to be left unresolved at restart?
ANSWER.
Progress has been made to date toward improving the offsite emergency prepared-ness programs at Pilgrim and correcting the emergency planning . deficiencies identified by FEMA. Drafts of the local emergency plans have been completed and six of these plans have been forwarded by the Commonwealth to FEMA for informal j technical review. The draft Massachusetts Civil Defense Agency Area II plan has essentially been completed and is being reviewed by the commonwealth. The draft of the Commonwealth plan for Pilgrim is nearing completion.
As indicated in the testimony, the NRC may authorize restart with some planning )
issues not fully resolved. In reaching this decision, the NRC will examine each planning deficiency and weigh the significance of the deficiency, the i '
nature of any compensatory actions, and the progress being made by the Common-wealth, local governments and the licensee toward correction of the deficiency.
Emergency planning is a dynamic process at operating nuclear plant sites in the 1
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QUESTION 5. (Continued) 'Jnited States. In practice, We expect that emergency response plans will be revised and improved on a continual basis. Deficiencies identified during the ongoing review process and in biennial exercises at each of these sites are assessed for significance and plants may be allowed to operate while the defi-s ciencies are being corrected. Given the progress to date at Pilgrim, it is premature at this time to attempt to determine which, if any, deficiencies will remain when restart decisions are to be made. However, the NRC will give special attention to the corrective actions involving the emergency response plans for schools and day care centers as well as the emergency response plans for special-needs and transport-dependent populations in the plume exposure pathway emergency planning zone.
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QUESTION 6. You said in your testimony that a detailed team inspection i will be performed at Pilgrim prior to a restart decision.
Has that inspection commenced? When will it conclude? How long will the public have to review the NRC's findings relative to the inspection and prior to a restart decision?
l ANSWER.
Prior to consideration of Pilgrim plant restart, the NRC will conduct an Integrated Assessment Team Inspection (IATI) at Pilgrim to review and evaluate the effectiveness of licensee corrective action programs in order to determine the readiness of the plant and licensee personnel to support the restart and safe operation of Pilgrim. The inspection will encompass a three week period and is tentatively scheduled for June 1988 based on a projection of licensee activities. It is expected that the report, documenting the findings of the team, will be issued approximately one month prior to the planned public Commission meeting to consider a restart decision.
I Kannedy/NRR 3/30/88
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QUESTION 7. A great deal of public concern has focused on a release of ,
l radioactive resin which occurred at Pilgrim in the summer of ;
W 1982. It is y understanding that radioactive resin was found '
on the rooftops of buildings owned by Boston Edison. Would you please provide all the dato the NRC has on file (including onsite and offsite readings, dosimeter readings and stack readings) indicating what the level of radioactivity had been in the period of time when the resin was released.
ANSWER.
In response to your request, we have made a comprehensive search of our files regarding information on the radioactive resin release at the Pilgrim Station.
Enclosed are all the documents which were found as a result of this search.
Enclosures 1 and 3 provide the most detail concerning the event itself. Figure 1 of Enclosure 1 indicates the extent of the contamination by the resin found on o
June 11, 1982. All contamination found was within the site boundry. Figure 1 A
of Enclosure 1 provides a detailed map, but basically contamination was found as follows:
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. QUESTION 7 (Continu:d) 2 I Location Activity in disintegrations per minute (DPM)*
Adminstration Building Roof 100,000 - 200,000 DPM Turbine Building 100,000 DPM A0G Building 200,000 DPM Retube Building 200,000 DPM Main Transformer Area 1,000 - 25,000 DPM Pavement curb near Retube Building 20,000 - 80,000 DPM Pavement curb near Administration 100,000 - 200,000 DPM Building
Enclosures:
- 1. Inspection Report No. 50-293/82-20, dated August 5, 1982.
- 2. Letter from R. W. Starostecki, NRC, to W. D. Harrington, BEco, dated June 16, 1982.
- 3. Letter from J. E. Howard, BEco, to R. W. Starostecki, NRC, dated July 15, 1982.
- 4. NUREG-0837, "NRC TLD Direct Radiation Monitoring Network," Progress Reports for January through September 1982, Vol. 2 Nos.1, 2, and 3.
- 5. Memorandum from R. J. Mattson, NRC, to H. R. Denton, NRC, " Generic Implica-tions of the Release of Spent Demineralized Resins from Pilgrim, Unit No.1," dated July 8,1982. ,
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- In descrete small piles of resin of several grams.
Kennedy /NRR ,
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, QUESTION 7 (Continued) 3
- 6. Memorandum from J. L. Pellet, NRC, to X. V. Seyfrit, NRC, " Technical Review Report on Pilgrim 1 Resin Migration," dated April 19, 1983.
- 7. Event Evaluation Sheet, " Spent Resin Release," dated June 14, 1982.
- 8. IE Information Notice No. 82-43, " Deficiencies in LWR Air Filtration / Ventilation Systems," dated November 16, 1982.
- 9. Pilgrim Nuclear Power Station, " Radioactive Effluent and Waste Disposal Report Including Radiological Impact on Humans," January 1 through June 30, 1982, dated September 1, 1982.
- 10. Pilgrim Nuclear Power Station, " Radioactive Effluent and Waste Disposal Report Including Radiological Impact on Humans," July I through December 30, 1982, dated March 1, 1983.
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QUESTION 8. In recent years, Boston Edison has had unsatisfactory ratings in the area of fire protection. I would like to know if Pilgrim is now in full compliance with fire protection requirements? Are all barriers, fire doors and penetration seals repaired and capable of passing required testing? Are fire watches still required in certain areas of the plant?
How many fire watches are still needed? Will the NRC require Edison to complete the upgrading of the entire fire protection system prior to allowing restart? How many maintenance requests are still outstanding in the area of fire protection?
Please also comment on the condition of the Halon system in the computer room at the plant and the smoke detectors over the spent fuel pool.
ANSWER.
I l
Pilgrim is either in compliance or will be in compliance with its fire protection requirements prior to restart.
One activity of the additional licensee fire protection personnel described above was a reevaluation of plant fire protection features, comparing those i
features against NRC requirements and guidance, in an effort to determine (a) the level of actual compliance, and (b) the adequacy of the features provided to prevent unacceptable fire damage. !
l l
l Kennedy /NRR 3/30/88
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-9 -QUESTION 8. (Continued) 2 During the course of this reevaluation the licensee found several cases where they did not literally comply with the NRC requirements or specific commitments they had made earlier. The licensee, however, provided justification to demonstrate adequate protection against unacceptable fire damage. On that basis, the licensee asked for exemptions from those requirements. In most cases the staff granted the exemptions. In those cases where the staff did not agree with the justification provided, the licensee made modifications so as to be in compliance.
Because of the more or less constent activity at operating plants, temporary changes, repairs, modifications, etc., may result in a particular condition that is not in compliance. These situations are contemplated and provisions are in place to assist in identifying the situation beforehand, providing interim protection measures (such as fire watches) and maintaining administrative control of the situation to assure that the out-of-compliance condition is corrected.
Before answering each of the specific sub-questions about fire protection at the Pilgrim Station, it is useful to address the overall programmatic status.
During the last one and one-half to two years Boston Edison Company has made significant improvements in their entire fire protection program. Additional personnel with extensive experience in nuclear power plant fire protection i
Kennedy /NRR 3/30/88
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- QUESTION 8. (C ntinued) 3 have been hired. Realignment of responsibilities and authority among these ]
1 licensee personnel have strengthened the entire fire protection program and j l
provided a higher level of accountability and continuity of effort that has resulted in substantial improvement in the program. This is evidenced by the methodology and thoroughness exhibited in identifying and correcting deficiencies.
The licensee has indicated that all modifications and work associated with upgrading required fire barriers, fire doors and penetration seals has been completed. The licensee has committed to having all of the necessary document-ation concerning the above work completed prior to plant startup.
Fire watches continue to be used in some areas at Pilgrim as well as most operating plants. At the beginning of the present outage approximately 18 months ago, eight persons per shift were assigned full time responsibility for fire watches covering approximately 180 individual postings. As of March 17, 1986 no continuous fire watches are required. Two persons per shift are assigned as fire watches covering 41 separate postings throughout the plant.
Of those 41 postings, 25 are related to fire barrier deficiencies, 15 are re eted to maintenance activities and one is related specifically to activities pertaining to the outage.
V.ennedy/NRR 3/30/88
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. QUESTION 8. (Continued) 4 Some minor upgrading to the fire protection systems may remain at the time Pilgrim restarts. However, those modifications yet to be completed will have been identified and the schedules for completion will have been reviewed for acceptability by the staff.
One hundred and sixty-one maintenance requests were still outstanding in the area of fire protection on March 17, 1988. However, this number by itself does not give an accurate picture of the Pilgrim fire protection maintenance program. On January 5,1987 there were 260 open maintenance requests related to fire protection.
Since January 1,1987, approximately 1,480 new fire protection-related maintenance requests have been generated and approximately 1,580 have been closed.
A computer located in a small room adjacent to the Cable Spreading Room is aoA cygnA.h t r b _e. Th % =e room. Q <by an automatic Halon fire suppression system ,
is protected hm"r , a^ ~aM+ h-t"^ #e- t " t r." r + -- i .. ; _ :- < p"ter u .m . Tw '
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.- QUESTI0N' 8. (Continutd) 15 i
~Six smoke detectors are located over the Spent Fuel Pool in.the ventilation system exhaust ducts. Four of-the six detectors have already been tested during this current plant outage. The other two are scheduled for testing prior'to plant startup.
i.
i l
I Kennedy /NRR l 3/30/83 1
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QUESTION 9. How many automatic and manual scrams have occurred at Pilgrim since the plant became operational? What is the annual industry-wide average?
ANSWER.
Table 1 provides data on unplanned automatic and manual scrams during critical operation for Pilgrim from 1984 through 1987 compiled from licensee event reports per 10 CFR 50.72 and 10 CFR 50.73. The comparable industry average rates are also provided in Table 1.
Prior to 1984, reactor scrams were not directly reportable to the NRC (Pilgrim entered commercial service December 1, 1972). As a result, that information is not readily available in our files, and in order to meet the timely response you requested only data from 1984 is listed.
Enclosure:
Table of Unplanned Scrams When Critical for Pilgrim and Industry Kennedy /NRR ,
3/30/88 1
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Enclosure to Question 9 }
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Table 1 Unplanned Scrams When Critical for Pilgrim and Industry 1984 - 1987 1984* 1985 1986 1987**
Pilgrim Automatic 0 4 4 0 Manual 0 0 0 0 Industry Average Automatic 5.4 5.0 4.0 3.2 Manual 0.6 0.5 0.5 0.6
- Pilgrim critical hours for 1984 = 170. j
- Pilgrim critical hours for 1987 = 0.
Kennedy /NRR 3/30/88 i I
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v QUESTION 10. How many " Unusual Events" and how many " Alerts" have been declared at Pilgrim since 1972? Please describe and give the date of each report. How does this compare to the industry-wide average?
ANSWER.
1 One of the major lessons from the TMI-2 accident in 1979 was the need to upgrade emergency planning at nuclear plant sites. As a result, the NRC published the definition and guidance for emergency categories of " Unusual Event" and
" Alert" in January 1980 in NUREG 0654/ FEMA-REP-1, codified them in Appendix E to Part 10 CFR 50 in August 1980, and embodied them in reporting requirement 10 CFR 50.72 in August 1983. The NRC staff has compiled a computerized data base, consistent with the definitions of emergency categories and the reporting requirements, from August 1982 to present. For comparison purposes, the computer data base information available dating from August 1983, the first complete year of collecting data, is provided. The computer records of notifications to the it Operations Center show that Pilgrim has declared R Unusual Events and no Alerts H
since 1983. Of the -17 Unusual Events, 2 were caused by fires in nonsafety related equipnient and I was due to a potentially contaminated individual being transferred offsite for medical treatment. The remainder were attributed to safety system inoperability which necessitated shutdown of the plant in accordance with the plani s Technical Specifications. A table of all Unusual Events for Pilgrim is enclosed which describes the events and dates of each.
Enclosue:
Table of Unusual Events at Pilgrim Nuclear Station Kennedy /NRR i 3/30/88
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, QUESTION 10. (Continued) 2 l.
1 A comparison of Pilgrim Unusual Events versus the industry average follows:
Industry Unusual Licensed Industry Pilgrim Unusual Year- Events Units Average Events
- 1982 - - - -
1983 205 85 2.4 0 .
1984 224 91 2.0 1- 1 1985 312- 98 3.2 5 1 1986 ~209 104 2.0 5 1987 231 109 2.1 _0, 5 Year Total 11.7 11
- Pilgrim reported one Unusual Event on August 18, 1982 relating to a fire in a face mask fitting machine. This and other licensee Unusual Events which may have occurred in this tirae frame are not included in the table because the M h informationisnotincludedinthecomputerdatabaseforthegear. Pilgrim also had one Alert on June 3, 1982 relating to a withdrawn incore detector resulting in abnormal radiation levels. This event lasted approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Pilgrim had no other Alerts from 1983 to 1987, however Alerts have been reported from other ' licensed facilities.
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, QUESTION 10.- (Continued)- 3 s
Enclosure to Question 10 l
1 Unusual Events at Pilgrim. Nuclear. Station .J August 1983 to Present l
i 1
i Event Description i
4/26/84 Potentially contaminated man taken to hospital.
5/16/85 2 safety system trains inoperable.
05/23/85 2 safety system trains inoperable. 1 09/20/85 2 safety system trains inoperable.
10/15/85 2 safety system trains inoperable.
11/04/85 Residual Heat Removal safety train A inoperable.
01/04/86 2 of 8 Main Steam Isolation Valves fail clusure time test.
01/09/86 Fire in line to hydrogen storage tanks.
02/11/86 Low pressure coolant injection inoperable.
02/14/86 2 safety system trains inoperable.
04/11/86 Loss of containment integrity.
02/11/88 Fire in machine shop.
i Kennedy /NRR 3/30/88 l 1
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OUESTION 11. How many violations of NRC regulations have occurred at Pilgrim I
since it began operation? What is the industry-wide average?
ANSWER.
I In order to respond to your question, a review of inspection report data was i
performed indicating that approximately 425 violations or deviations were identified at Pilgrim since beginning operation in June, 1972 through the end of 1987. This number alone does not measure licensee performance in that it does not reflect whether the violation contained multiple examples, whether it was subsequently withdrawn nor the severity level of the violation. Moreover, enforcement history is only one of a variety of factors NRC considers in assessing licensee performance.
In response to the second part of your question, for the reasons stated above, the NRC does not maintain industry wide statistics on the total numbers of violations, i
l Kennedy /NRR J 3/30/88 l
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QUESTION 12. There have been a number of allegations concerning the filegal J dumping of radioactive waste on Boston Edison property.
1 Concerns have also been raised over Edison's use of the town {
l dump for disposal of radioactive material. Would you please describe what monitoring the NRC conducts or requires on materials and waste leaving the Pilgrim site. Has the NRC or the licensee performed tests on Edison property and at the town dump to ensure that there are no elevated levels of radiation at areas suspected of containing radioactive waste?
Where and when were tests conducted? What were the results?
ANSWER.
The NRC staff does not itself monitor materials and wastes leaving the Pilgrim site. The licensee is reouired to monitor all items containing or contaminated with radioactivity that are leaving the site. There are several facility procedures that provide specific guidance and instructions to plant health physics workers regarding this activity. All radioactive wastes that are sent to sites specifically intended for burial must meet federal regulations for radiation dose rate and contamination levels as well as special requirements of the burial sites. NRC performs routine inspections of the radioactive trans-portation area to ensure that licensees are conforming to these regulatory requirements. Further, onsite materials not thought to be contaminated that are being shipped offsite that have the potential of being contaminated are surveyed prior to being allowed off the site. The licensee is not allowed to dispose of contaminated objects in non-radwaste facilities without a special Kennedy /NRR 3/30/88
a ;.s amysrw a. x.n :a wu. mu m. . w . a a.w,, < . , . m ;u . ,- a, i < QUESTION 12. (Continued) 2 variance provided for in 10 CFR 20.302(a). BEco has not applied for these variances. To our knowledge, no contaminated objects have been disposed of in the town dump or in other public facilities not specifically intended for contaminated objects.
Some cut shrubs with slight contamination were disposed of on BEco property in 1987. The contamination was not detected with standard survey meters, but was so low that it was only detected on clippings using sensitive laboratory equipment. The clippings had been taken after these shrubs had been taken from the site. Notwithstanding, the contamination levels were lower than typical soil background levels and they posed no health hazard (see enclosed Inspection Report 50-293/87-57, dated March 11,1988,p.12). NRC has not performed surveys for contamination of the town dump or at other BECo properties. NRC does not routinely perform contamination surveys of this type. As stated in the Inspection Report, the inspectors reviewed the licensee's program for release of material from the site and concluded that it was adequate.
Enclosure:
Inspection Report dtd 3/11/88 Kennedy /NRR 3/30/88
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QUESTION 13. Has Pilgrim ever violated established radiation emission levels i.e., have there been any releases from the plant which exceeded standards set by the NRC?
ANSWER.
The permissible levels of radiation in unrestricted areas and of radioactivity in affluents to unrestricted areas are established in NRC regulations embodied in 10 CFR 20, Standards for Protection Against Radiation. These regulations specify limits on levels of radiation and limits on concentrations of radio-nuclides in the facility's effluent releases to the air and water (above natural background) under which the reactor must operate. Further, the regulations require that there be no unmonitored release paths from the plant. The regulations are structured to provide reasonable assurance that no member of the general public in unrest-icted areas will receive a radiation dose, as a result of i
facility operation, of more than 0.5 rem in I calendar year. These radiatien-dose j limits are established to protect the health and safety of the public, i
In addition to the Radiation Protection Standards of 10 CFR 20, 10 CFR 50.36a establishes license requirements in the form of license Technical Specifica-tions on effluents from nuclear p;.ic, rw. tors. The purpose of the Technical l Specifications on effluents is to keep releases of radioactive materials to l unrestricted areas during normal operations, including expected operational j l
4 Kennedy /NP.R 3/30/88
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o 00ESTION 13. (Continu2d) 2 occurrences, as low as is reasonably achievable (ALARA). Another regulation ;
(Appendix I of 10 CFR 50) provides numerical guidance on dose-design objectives for light water reactors to meet this ALARA requirement. The dose-design objectives are low, about 1% of the Radiation Protection Standards of 10 CFR
- 20. Thus, it is possible for a licensee to exceed the dose-design objectives, but still be within the Radiation Protection Standards.
The NRC staff has reviewed the agency records on radioactivity releases from the Pilgrim nuclear power plant. Although there were situations when the radioactivity releases exceeded Pilgrim's Technical Specifications, these releases did not exceed the Radiation Protection Standards of 10 CFR 20.
We have also reviewed the agency records on the amounts of radioactivity measured in the environment around the Pilgrim nuclear power plant. The licensee has reported elevated levels above normal background of some radionuclides in some environmental samples over the time period 1978 through 1981. However, it should be noted that Pilgrim's previous guidelines for reporting elevated levels of radioactivity in environmental samples were conservative. Under Pilgrim's current Technical Specifications, many (if not all) of the previously reported elevated levels would no longer be considered reportable. The previously reported elevated levels of radioactivity in environmental samples would lead to doses less than specified in the Radiation Protection Standards and thus would be below NRC regulatory limits.
1 i
In summary, radioactive emissions from the Pilgrim nuclear power plant have occasionally exceeded the plant's Technical Specifications; however, they have l
not exceeded the NRC's Radiation Protection Standards, i
Kennedy /NRR 3/30/88 i
w .r o -PROPOSED OPENING REMARKS-by Dr. Murley Pilgrim has been shut down since April 1986. Over the past several years, significant facility deficiencies have been identified through the inspection process and were reported in the Pilgrim SALP. We note that BECo has devoted substantial resources toward resolving these deficiencies and welcome this l opportunity for BEco to present the scope and status of its restart plan.
However, we recognize that considerable effort remains.
Although the staff has been quite active in its review and inspection efforts at Pilgrim, we must satisfy ourselves that programs established by BECo are not only adequate, but that these programs have been implemented and are Effective. We feel that our reviews will take at least eight weeks from the time we have received a complete and comprehensive restart assessment package from BECo. The conduct of these reviews will be coordinated through a Pilgrim Restart Assessment Panel. Bill Russell will briefly suunarize the panel's makeup and activities in a moment.
Several technical areas are of particular interest. As you are aware, the staff has found a number of your Safety Enhancement Program modifications acceptable; however there are a number of unresolved questions regarding the Direct Torus Vent. Additionally the staff will review recent changes to your emergency operating procedures. We also recognize the efforts being made by l I
BEco to resolve the emergency preparedness deficiencies identified by FEMA. I Although consideration of an exemption to the biennial exercise may be premature, we look forward to understanding your progress in this area.
I NOTE: The following 5 pages provide additional information in support these l remarks.
I// !
j
W ,e NOTES FOR REMARKS BY DR. MURLEY I. Introduction '
Over the past few years the NRC has had a number of concerns with Pilgrim performance.
Pilgrim shutdown April 12, 1986 due to technical issues (MSIVs, containment isolation and intersystem leakage to RHR system).
Shutdown confirmed by. CAL 86-10, of 4/12/86.
Issues and NRC concerns in a number of areas have expanded and on August 27, 1986, we stated our need for a formal reassessment by BEco of their readiness for restart.
1 i
SALP Report of April 8,1987 identified significant deficiencies (Category "3") in areas of-(
-Radiological Controls (was "3" previous SALP)
-Surveillance
-Fire Protection
-Security and Safeguards !
-Assurance of Quality k
BECo has devoted substantial resources towards the resolution of many of these issues and we view many actions, such as management changes, new programs, and in-plant improvements as positive steps towards making the Pilgrim facility ready for restart.
Still much to accomplish, Areas of focus as BECo prepares for restart, include:
-SALP and Technical Issues
-Management Issues
-Safety Enhancement Program
-Emergency Preparedness Issues
.a' ,-u
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Level of NRC staff activity on Pilgrim is high and will remain high in the next few months, .l' The level of Commission interest as well as level of public intarest in this facility is high.
II. Resolution of SALP and Technical Issues BEco has generally been optomistic regarding their schedule for dealing with many of the Pilgrim issues.
BEco must demonstrate substantial improvements and progress in areas of SALP "3" and resolve the technical issues identified by the staff as necessary for restart.
We will promptly look at technical issues and items when we have confidence BECo is ready for our inspections and review,
- i Staff must receive results of BECo's self assessnent and have time j to make our independent evaluation.
{
III. Manaoement Issues l
BECo has made a number of management changes and instituted programs to address NRC concerns.
l NRC must satisfy itself that management changes have brought substantial improvements and that new programs are effective.
l A successful Diagnostic Inspection and satisfactory completion of the staff assessment of BECo readiness are key aspects of a staff i decision regarding restart. I
~
Le-IV. Safety Enhancement Program (SEP)
' Staff evaluation of SEP (submitted 7/8/87) was transmitted to REco l August 21, 1987.
Staff found a number of the SEP modifications acceptable under provisions of 10 CFR 50.59 or approved related Technical Specification changes. These include:
Containment Spray Nozzle Modification Ofesel Fire Pump >
Diesel Fire Pump Fuel Oil Transfer System Blackout Diesel Generator ATVS Feedwater Pump Trip ATWS Recirculation Pump Trip -
Enriched Boron to SBLCS (Tech. Spec.)
ADS Logic Modification (Tech. Spec.)
4 The generic issue of torus venting is still. under evaluation. We look forward to your response to our questions in this area, but expect it may require extensive deliberation before we are prepared to make a decision on this issue.
As a related matter, we expect to expand our review of your Emergency Operating Procedures and Procedure Generation Program.
The staff has not yet approved Revision 4 to the Emergency Procedure Guidelines and we must assure ourselves that BEco work in this area is consistent with our approach, f
1
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4
- j. V. Emergency Preparedness Issues FEMA report was transmitted to BEco on August 18, 1987.
~
FEMA concluded Massachusetts offsite radiological emergency planning and preparedness was inadequate.
FEMA identified six issues:
i
-1. Lack of evacuation plants for public and private schools and daycare centers..
- 2. Lack of a reception center for people evacuating to the north.
- 3. Lack of identifiable public shelters for the beach population.
4 Inadequate planning for the evacuation of the special needs population.
- 5. Inadequate planning for the evacuation of the transportation dependent population.
- 6. Overall lack of progress in planning and apparent diminution in emergency preparedness.
1 l
-N s
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We have received your letters of September 18, 1987, and the staff is reviewing your progress with State and local entities.
Consideration of any exemption may be premature at this time. !
BEco and the State must continue to work to resolve the issues identified by FEMA.
FEMA's assessment of progress towards resolution and the conduct of the December exercise will need to be considered.
l VI. Conclusion Staff will continue its aggressive review of BECo actions at l Pilgrim.
Restart Panel will coordinate staff actions and keep NRC Senior Management appraised. It is a focal point for BEco to interface with NRC. ,
BECo must demonstrate that changes have been made and that management is successfully dealing with issues.
NRC cannot consider restart until all the issues raised during the j facility's prolonged shutdown have been dealt with to our l satisfaction.
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DIRECT TORUS VENT OPTIONS I. Approach Review existing documentation
- SEP submittal of June 37
- Initial staff assessment of 8/21/87
- BEco 50.59 packages on DTV with valve and flange Formulate Staff Position
- URSQ?
- How does BECo implement
- Valve or flange (Valve allows potentially operable system)
- Position on system operability (Not prepared to support operable system)
- Why containment design still OK ... or why design is compromised
- Policy question: Can we support .ajor modifications to the containment under~50.59?
- What changes to Tech Specs?
Brief Director . Site visit by NRR technical staff Supplemental submittals by BECo? Document staff position II. Two Fundamental Options
- 1. Blind Flange
- Currently in place at Pilgrim
- Appears _that it can be accomplished under 50.59
.Folicy question: Can we support major modifications to the containment under 50.59?
- Requires no submittal by BECo (Answer to 8/21/87 questions not required)
- Staff would do onsite review and document in inspection report
- OGC acceptance (S. Lewis indicated probably OK; Scinto?)
- TEM would prefer valve
- 2. Install Valve 5025
- Will require change to Tech. Specs. and submittal from BECo
- Involves significant hazards considerations
- Must separate installation and operability issue Lb
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- Need answer to 8/21/87 questions (BECo reviewing a current draft response with owner's group. Owner's group vote required before BEco submittal - probably several months away).
- 3. Return Line to Pre-SEP configuration
- Appears to be a step backwards L-_-_-_____
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(._~ . . ~ -- .. -. .- -- - .. --. . - - - - - - - p EXPECTED OUESTIONS , ITEM A. Mark I Containment A.1, What action is the staff taking regarding reactors with a Mark ! containment? A.2. Who constitutes the expert group involved in the development of the
" Review of the Status of the BWR Mark I Melt-Through Issue" report referred to in Inside NRC of 12/7/87?
A.3. What is the implication of the Mark I Containment Evaluation Program for Pilgrim? A.4. What will NRC require by way of Mark I Containment improvements at Pilgrim before restart? A.S. What is the status of the Safety Enhancement Program? A.6. What action is the staff taking regarding the Direct Torus Vent? A.7. What is the status of the staff's review of Pilgrim Emergency Procedures? B. Emergency Preparedness B.1. What action is NRC taking in response to the FEMA findings of July 29, 1987? 8.2. Why is the Pilgrim restart process continuing with the FEtiA-identified deficiencies unresolved? B.3. What emergency preparedness actions will be necessary by BEco, state and local entities, and FEMA before a restart is authorized? B.4. Do NRC regulations allow a nuclear plant to operate during the four months after an NRC findina of inadequate emergency plans? B.S. Can the NRC allow Pilgrim station to operate without adequate emergency plans? B.6. How will the NRC evaluate the status of the resolution of emergency preparedness issues? 8.7. If the NRC finds that the state of emergency preparedness does not provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency, what action can the NRC take? B.8. Will we require all of the FEMA and Barry deficiencies to be corrected prior to restart? B.9. Will we require a satisfactory emergency exercise with a FEMA report before restart?
w a m .x;2.:-: = x. m . x: x .a .u . :. - : <.1 . . c.~ c z < m u . v.m : .. . = o ;, 4 8.10. Is an approved offsite emeraency preparedness plan required for restart? 8.11. What would NRC do if the state can't prepare and provide a plan to FEMA? R.12. Does NRC have emergency preparedness experts with qualifications equivalent to FEMA experts? B.13. Your testimony refers to "some demonstration of the critical aspects" of the evacuation plans. What do you mean by "some demonstration?" 8.14 What do you mean by " addressed prior to restart" when you refer to the FEMA identified deficiencies? B.15. What is the NRC position on the Commonwealth's plan to enlarge the EPZ? C. Public Health C.1. Some studies have shown that certain communities surrounding Pilgrim have cancer rates two to three times the average U.S. rates. Could this be due to Pilgrim? C.2. Could the above average cancer rates be due to exposure of workers? C.3. How does Pilgrim rank in terms of exposure to members of the general public? C.4 How does Pilgrim rank in terms of exposure to workers at the facility? D. Federal and State Roles D.1. What is the statuatory basis for the authority of the NRC and : the states in regulating radioactive materials? D.2. What NRC programs are in place to facilitate interaction between the NRC and the states? E. Miscellaneous E.1. What specific actions / steps will NRC take prior to authorizing restart? E.2. Explain why there appears to be continued problems at Pilgrim, as evidenced by the Loss of Offsite Power Event of November 12, 1987. E.3. What is the criteria for determining that manacement is effective? E.4 Why is an adjudicatory hearing inappropriate in this case?
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4 1.5. Would Pilgrim as currently designed, constructed and sited be t;uildable and operable under today's standards? If not, then why should we let Pilgrim go back on line? E.6. Discuss the Commission's Safety Goals, referred to in GAO I- Report RCED 87-141, issued in Aucust 1987 What are typical "cuidelines" that implement these goals? What is the status of guideline development? How do these guidelines apply to Pilgrim? I
gn ..n _. . n. ~ . ~-- . n.~.~.;..w.~. . .. . . . , . . . , . . - . . .... .~ ti g. k QUESTION-A.1. What action is the staff taking regarding reactors with a Mark I containment? I. ANSWER: Dealing with severe reactor accidents at al.1 types of nuclear plants requires a comprehensive approach which addresses 3' principal elements related to plant safety: 1) plant operations, 2) severe accident vulnerabilities, and 3) containment performance. Plant operations refers to the manner in which a plant is , normally operated, including maintenance, surveillance and testing. It encompasses the level of performance of operators during routine and emergency situations. Any serious attempt to improve plant safety should examine this facet of a plant for possible improvements. The second element of a severe accident risk reduction program should involve a systematic search for specific design features which significantly contribute to the likelihood of a core melt accident. Finally, the assessment of risk to the public posed by any nuclear plant should include consideration of the containment performance ! during severe accidents to determine if plant improvements can be made which would result in substantial risk reduction. The elements described above serve as a framework for reducing risks at all nuclear plants and are not limited to treatment of the BWR Mark I type plant. 1 - _ . _ _ _ _ _ . - - - - . _ . _ - - _ _ - - . _ _ _ - - _ _ _ . _ _ _ _ _
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. S a/ :.. .a... a.. _ .a>. : . is: ;a- T =c mim a QUESTION A.I. (Continued) 1 i.
Because of concerns over the particular vulnerabilities of Mark I containments and in part due to a belief that reasonable cost effective plant improvements have been identified, the staff has proposed a program plan with an expedited schedule to resolve the generic issue of Mark I containment performance. This plan and schedule is discussed in SECY 87-297, issued on December 8, 1987. There are a number of-potentially important challenges to a Mark I containment which may arise during the course of a severe accident. These failure mechanisms include: 1) early overpressure or overtemperature failures (due to molten fuel quenching in-vessel, direct containment heating, and combustible gas generation and ignition), 2) core debris attack on the steel containment liner resulting in liner melt through, 3) later overtemperature or overpressure failure, of the containment, 4) containment bypass (due to failure to isolate containment, suppression pool bypass and interfacing systems LOCA's), and 5) basement penetration. To reduce the threat posed by these challenges a number of potentially cost effective improvements have been suggested and preliminarily assessed by t.he staff, its contractors, two utilities (Vermont Yankee and Boston Edison) and an industry group (IDCOR). These improvements are related to the following
- containment performance issues: k)
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- 1) Hydrogen control -Reduction of allowable time during which operation is permitted and improved long-term inerting capability.
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- 2) Containment spray -Improvements to containment spray capability during accidents in which all AC electric power is lost.
l 3) Containment venting -Improvements to containment venting capability.
- 4) Core debris control -Provision for core debris control on the drywell floor and in the torus room under the suppression pool.
- 5) Reactor Building -Provision for reduction of fission products Fission Product outside containment by additional or modified Attenuation reactor building sprays.
- 6) Basemat isolation -Provide means for isolating core debris for accidents involving basemat melt-through.
- 7) Procedures and -Improvements in existing emergency procedures training and operator training.
The expedited program plan for resolution of Mark I containment issues calls for a two stage process. The first stage will consist of issue
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o .. e . ~ . -. s QUESTION A.I. (Continued) I. characterization, parametric studies, experiment assessments and a critical focus on each of the relevant technical issues. The second stage will involve the determination as to whether an issue is either 1) resolved or unimportant,
- 2) amenable to resolution by additional testing / analyses, or 3) a candidate for additional regulatory requirements. The current schedule calls for staff conclusions and recommendations to be provided to the Commission by August, 1988. The staff believes that this program involving representatives from National Labs, industry, other experts and interested members of the public is essential to the process of resolving safety issues related to Mark I containment performance and thereby improving plant safety.
The probability of a severe accident that could challenge the Mark I containment is to considered to be extremely low. Consequently, the staff has concluded that the potential risk to the public is acceptably low enough for reactors with Mark I containments to continue operating while evaluations are being conducted. s Db a. r k . ***d op. A t q c u f t 4y L yskfvC m.m M & v o --.a , 4Q qat,L4 Lo w pA4 c + de I L'< (c j a wa ( D i< .
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1 l OUESTION A.?: What is the implication of the Mark I Containment Performance I l Prooram for Pilgrim? , t, ANSWER: At the completion of the Mark I Containment. Performance Program, currently scheduled for August 1988, the staff will have identified appropriate containment improvements which will extend the capability of Mark I plants to cope with core nelt accidents. Upon Comission approval of the staff . proposals, implementation of any additional requirements at Pilgrim, as well as at Mark I plants, will proceed consistent with the plants operating schedule. Furthermore, utility and NRC activities related to the Mark I Containment Performance Program will be coordinated with activities associated with the 1 Individua1' Plant Examination (IPE) Program. t
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.4 QUESTION-A.3:
Who constitutes the expert group involved in the development of the " Review of the' Status of the BWR Mark I Melt-Through Issue"~ reportreferredtoinInsideNRCofDecember7,~198k? ANSWER: The expert group referred in the Inside NRC article is comprised of five t individuals from National Laboratories involved in severe accident research, G.A. Green (Brookhaven National Laboratory), S.A.'Hodge (Dak Ridge National Laboratory), K. D. Bergeron (Sandia National Laboratory), D. A. Powers (Sandia National . Laboratory), and.J. Dallman (Idaho National Engineering Laboratory). l l i l' l l l
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( l QUESTION A.A. What will the NRC require by way of Mark I Containment improve-ments at Pilgrim prior to restart? . ( ANSWER: The NRC clarified its position and approach to resolution nf severe accident issues for all nuclear reactors, including those with a Mark I containment, by the " Policy Statement on Severe Reactor Accidents Regarding Future Designs and Existing Plants." This policy statement issued on August 8,1985 reaffirmed - the Comission's position that existing plants pose no undue risk to public health and safety. To verify the conclusion of acceptable risk on a plant specific basis, the Commission indicated in the policy statement its intent to require that individual licensees perfom safety analysis of severe accidents to identify plant specific vulnerabilities. These studies will be conducted as part of the Individual Plant Examination (IPE) Program, which will assess accident likelihood and containment performance. Pilgrim will participate in this program, which is expected to get underway early 1988. Boston Edison has voluntarily taken the initiative at Pilgrim to improve containment performance. This program is called the Safety Enhancement Program. The staff will review the plant modifications to ensure they have no overall adverse safety impact on existing systems. However, the licensee's initiative to improve plant safety beyond the point of complying with existing NRC regulations is not a precondition for restart or a basis for modifying the license to operate the Pilgrim facility. u_____________m - - - - - _ _ - - - - - -
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OVESTION A.S. What is the status of the Pilarim Safetv Enhancement Program? I ANSWER: The Boston Edison Co., by letter dated sluly 8, 1987, provided the staff with a description of the Safety Enhancement Procram (SEP) design chances that Boston Edison elected to implement at the Pilgrim plant. The coals of the SEP are:
- 1) to identify and implement plant improvements responsive to previous NRR draft BWR containment policy, 2) revise emeroency procedures in accordance with Revision 4 of the BWR EPG's and 3) perform a comprehensive safety ,
assessment of severe accidents. The licensee identified 12 plant changes to improve safety. Since the licensee's program is not solely limited to containment issues, a number of the proposed plant improvements are intended to address other areas of plant safety. Furthermore, a number of items would serve two functions, i.e., to enhance containment performance and to reduce the likelihood of core melt accidents. The Pilgrim SEP identified the following improvements related to containment performance: 1) direct torus vent system, 2) drywell spray nozzle optimization, 3) fire water intertie to the residual heat removal system, 4) additional diesel pump capability, and 5) long tern nitrogen supply capability. A brief comparison of the Boston Edison proposed plant improvements with those identified earlier by the staff as possible candidates reveals that the Pilgrim SEP has addressed many of the relevant issues. (The Licensee has not found that measures for core debris control on the containment floor are needed). _ .___ __-________ a
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.m QUESTION A.S. (Continued) .
i The staff has performed an initial assessment of the proposed Pilgrim plant modifications and reported that evaluation in a letter to Boston Edison dated August 21, 1987 The minimum objective of the staff review is to ensure that l the plant modifications associated with the Safety Enhancement Program have no overall adverse safety impact on existins systems. In that regard the staff requested additional information prior t) implementation of several items. Staff found a number of the SEP modifications acceptable under provisions of 10 CFR 50.59 or approved related Technical Specification changes. These include: Containment Spray Nozzle Modification Diesel Fire PJmp Diesel Fire Pump Fuel Oil Transfer System Blackout Diestil Generator ATWS Feedwater Pump Trip ATWS Recirculation Pump Trip Enriched Boron to SBLCS (Tech. Spec.) ADS Logic Modification (Tech. Spec.) j _.___.._____._A______2___________m._um______._________._U
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-QUESTION A.5. (Continued) l l
i. Sta#f has additional concerns with Direct Torus Vent System (DTVS) and questions regarding: i RCIC Modification Backup Nitrogen Supply
~
Modification to RHR System
' One of the proposed improvements 'Ofrect Torus Vent) was not endorsed by the staff for implementation at this time, pending resolution of a number of questions regarding its use.
Ouestions to BEco (sent on August ?l,1987) regarding DTVS include: - Analysis of accident sequences
- Analysis of vent failure Estimates of releases for various sequences l
Maintenance or surveillance errors l t Boston Edison has not yet responded to the staff's letter of August 21, 1987. L_, _m.m__u_. -___--__-m-------- - - - - - - - - - - - - - - - - - - - " ' ' - - - ' - - - - - - ~ ' ' - -
M L 2 E U 3i5l W N d G ; :.~-: W V: &);' .:D ,:a . u:. , m '. . .. . . . 71:: .L =. . . ;n n. u. . :. .. x. OUESTION A.6. What action is the staff taking regarding the Direct Torus Vent? I ANSWED: l As part of their Safety Enhancement program (SEP), Boston Edison Company (BECoi, the Pilgrim licensee, proposed the installation of a Direct Torus Vent System (DTVS) as one of several SEP measures to improve containment performance at Pilgrim. The Direct Torus Vent provides a path from the torus l to the plant stack and would be used to relieve containment pressure in certain. severe accident situations. i The staff's initial safety assessment (issued August 21,1987) of the SEP I modifications did not endorse the use of the DTVS at this time. The staff has asked Boston Edison a number of questions regarding the use of the DTVS. PEco will not be allowed to place the DTVS system into service until it is thoroughly evaluated and approved by the staff. 1 l i 1 I e 1 - - - _ - _ _ . - = = _ _ - .
m . n . ., =- :., ..n. c. . w nn. , .- ~a, . ~ . , , x~ .. - -w- -- . ~ , - - - - QUESTION A.7.' What is the status of the staff's review of Pilgrim Emergency Procedures? . ANSWER Boston Edison has prepared Emergency Operating Procedures that are written to Revision 4 of the Emergency Procedure Guidelines (EPGs). (Although the staff has not yet approved Revision 4 to the EPGs, they represent an improvement over previous EPGs and are endorsed for use by the industry while the staff
- review proceeds).
The Pilgrim E0Ps and associated procedures generation package (plant-specific technical guidelines, verification procedures and training program) were submitted for staff review in November 1987. Staff review will take a couple months and will include a site visit to observe simulator usage of the E0Ps. Concerning revision 4 of the BWROG EPGs, the staf f is not expected to complete i its review o' that revision until early 1988. Although the staff has previously approved a strategy for containment venting for Pilgrim and other boiling water reactors in conjunction with their review of current RWROG EPGs, { the proposed revision 4 guidelines recomend a new approach, with containment
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'before specific containment venting modifications may be found acceptable et Pilgrim.
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memr n_w.ccrcerc,c wa w..n:c .'ce w c, w.u cc. .. u: - c .- -. - m . . e r J s OVESTION B.1.: What action is NRC taking in response to the FEtiA findinos of l July 29, 1987? I ANSWER: On August 18, 1987, the NRC requested an action plan and schedule for correction from Boston Edison Company addressing the FEMA-identified deficiencies. Boston Edison submitted their action plan on September 17, 1987. Headquarters and regional NRC staff have closely monitored the proeress of the utility's efforts. regarding the resolution of offsite emergency preparedness issues. On various occasions, NRC staff members have discussed the status of emergency preparedness with the utility as well as the Commonwealth and local officials. Information j from these parties indicates that significant progress has been made toward j resolving the FEMA-identified' issues. The NRC will continue to nonitor the progress of the utility, Commonwealth, and local officials in correcting the emergency preparedness deficiencies. The determination whether to restart the Pilgrim plant will involve consideration of the corrective actions taken to address each of the emergency planning issues identified by FEMA. The NRC will coordinate review efforts with Boston Edison, FEMA, State, and local officials to identify the most important aspects of these deficiencies and the actions necessary to demonstrate adequate preparedness. ._______.-_L.-___ .__-__:_. _
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00ESTION B.2: Why is the Pilgrim restart process continuing with the FEMA-
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identified deficiencies unresolved?
-ANSWER:
The restart process principally involves BEco's correction of identid ed deficiencies to the NRC's satisfaction. Pilgrim is presently shutdown with plant activities being conducted in accordance with the conditions of their license as nodified by our Confirmatory Action I.etter. While the NRC agrees that emeraency planning deficiencies do exist at Pilgrim and further agrees that correctite actions should be taken, we have not agreed that such concerns present an "iminent danger" to the public that would warrant an enforcement action affectino the Pilgrim license. Consequently, any actions that'may be taken with regard to emergency planning concerns at Pilgrim do not preclude the NRC from authorizing Boston Edison to resume operation of the facility pending final resolution of all emergency preparedness deficiencies. None of the FEMA identified deficiencies appears to be of such complexity that it can-not'be corrected. FEMA has outlined in their report what would be necessary for each item to be corrected. Therefore, it is reasonable to assume that the deficiencies will be satisfactorily resolved.
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4 OUESTION B.3.: What emergency preparedness action will be necessary by BECo. State and local. entities, and FEMA before a restart is t
- authorized?. 1 ANSWER:
Any actions that may be taken with regard to emergency planning concerns at Pilgrin do not preclude the NRC from authorizing Boston Edison to resume operation of the facility pending final resolution of all emergency prepared-ness deficiencies. Notwithstanding the fact that NRC has taken no enforcement action affecting the Pilgrim license, NRC will not permit the facility to resume operation until corrective actions satisfactory to NRC have been taken to address the emergency planning deficiencies identified by FEMA. We will give special attention to the improved evacuation plans for schools and day care centers as well as the improved evacuation plans for special-needs and transportation-dependent populations in the ten-mile emeroency planning zone. We will require some demonstration of the critical aspects of these evacuation plans before we can decide that Pilgrim is ready to resume operation. The NRC will coordinate review efforts with BEco, FEMA, State and local officials to identify the most important aspects of the identified deficiencies and the actions necessary to demonstrate adequate preparedness. t a
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00ESTION B.4.: Do NRC regulations allow a nuclear plant to operate during the four months after an NRC finding of inadeouate emer ency preparedness?
- ANSWER:
The Commission recognizes that there can be deficiencies in the emeroency planning and preparedness associated with a nuclear facility. However, there must be substantial compliance with the regulations, i.e., compliance sufficier,t to find that there is reasonable assurance that adequate protective measures can and will be taken in a radiological emergency. Indeed, even in those instances where the Commission can no longer make its reasonable assurance finding, emer-gency preparedness deficiencies may not require facility shutdown. See 10 CFR 450.54(s)(2)(ii). In practice, radiological emergency response plans are rarely if ever perfect and complete. This is the reason for the continuing FEMA and NRC oversight of this area. Deficiencies will be found and assessed for signif-icance. While all deficiencies are expected to be corrected, not all will change a finding of reasonable assurance by the NRC. For an operating plant, such as Pilgrim, the regulations provide considerable enforcement flexibility to the NRC. Whereas significant deficiencies in a safety system at an operating reactor could cause it to be shut down at once, the identification of significant deficiencies in emergency plannino results
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n OUESTION B.4.: (Continued) i in the initiation of a four-month period within which the deficiencies are addressed, not in an automatic shutdown of the facility. Even after this "120-day clock" has run, the regulations provide that the NRC has the enforce-ment discretion to allow the plant to continue operation even in the face of such a deficiency. In determining whether a shutdown or other action is appropriate, the Commission will take into account such factors as whether the licensee can demonstrate that the deficiencies in the plan are not significant, or that adequate interim compensating actions have been or will be taken - promptly, or that there are other compelling reasons for continued operation. 0 s . =
00ESTION B.S.: Can the NRC allow the Pilgrim station to operate without adequate emergency plans? , ANSWER: k While the NRC acrees that emergency planning deficiencies do exist at Pilgrim and further agrees that corrective actions should be taken, we have not agreed that such concerns present an " imminent danger" to the public that would warrant an enforcement action affecting the Pilgrin license. Consequently, any actions. that'may be taken with regard to emergency plan < ting concerns at Pilgrim do not preclude the NRC from authorizing Boston Edison to resume operation of the facility oending final resolution of all emergency preparedness deficiencies. For an operating plant, such as Pilgrim, the regulations provide considerable enforcement flexibility to the NRC. Whereas significant deficiencies in a safety system at an operating reactor could cause it to be shut down at once, the identification of significant deficiencies in emergency planning results in the initiation of a four-month period within which the deficiencies are addressed, not in an automatic shutdown of the facility. Even after this "120-day clock" has run, the regulations provide that the NRC has the enforce-ment discretion to allow the plant to continue operation even in the face of ; such a deficiency,
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wwwwwa: w car.:- w n wcw ,: 1,:.= - w a mc:.=.. ws z: .w . v .u ., r - ~ w ~:. . . - C 00ESTION B.6.: How will the NRC evaluate the status of the resolution of energency preparedness issues? ANSWER: The determination whethee to restart the Pilgrim plant will involve consid-eration of the corrective actions taken to address each of the emergency planning issues identified by FEMA. Based on information obtained from the licensee, FEMA and State and local officials, the NRC will review the emergency planning issues to determine which are of highest priority and what actions are necessary to demonstrate that reasonable preparedness exists prior to restart.
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s 1 1 I OUEST10N B.7: If the NRC finds that the state of emeroency preparedness does l not provide reasonable assurance that adequate prottetive { measures can and-will be taken in the event of a radiological emergency, What action can the NRC take? ANSWER: If the deficiencies in emergency preparedness are not corrected within four months of the NRC findino, the Commission will determine whether the reactor . shall be shut down until such deficiencies are remedied or whether other enforcement action is appropriate. The Commission will take into account such factors as whether the licensee can demonstrate to the Commission's satisfac-tion that the deficiencies in the plan are not significant for the plant in question, or that adequate interim compensatory actions will be taken promptly, or that there are other compelling reasons for continued operation, i e C .__________l_._.___
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.'O OUESTION B.8: Will we require all of the FEMA and Barry deficiencies to be corrected prior to restart? .
ANSWER: It is the NRC's pnsition that all of the deficiencies identified by FEMA will be addressed prior to restart. Deficiencies concerning the evacuation of ;c":<1s and daycare et.'ters as well as the evacuation of special needs and transpo fa tion dependent populations will be given special attention. We will require - some demonstration of the critical aspects of these evacuation plans before a decision is made that Pilgrim is ready to resume operation. With respect to the deficiencies identified by Secretary Barry, FEMA has indicated that these have been included in the FEMA self-initiated review. _________1.__ . _ _ _ _ _ -- -
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4 Ol!ESTION R.9: Will.we require a satisfactory emergency exercise wjth a FEMA report before restart? ' ANSWER: Adequate emergency preparedness can be demonstrated in a number of ways, includ-ing evaluation of plans and procedure, verification of trainino in specific areas, drills, table top exercises, and full or partial participation exercises. The 1987 full participation exercise for Pilgrim has been deferred as requested by the licensee to the first half of 1988 The correction of some of the issues in the emergency preparedness program for Pilgrim may be demonstrated in a drill or exercise of the plan changes, however, we see no need'to reauire a full-par-ticipation exercise prior to restart. The NRC will, nonetheless, verify that
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the overall state of eneroency preparedness is adequate to protect the public health and safety prior to restart. y6Hg y a,y' kmL LxLrN A l h, ~ \ L- - .
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l A ll 1' OUESTION B.10: Is an approved offsite emeraency preparedness plan required for restart?
- k ANSWER:
i An approved offsite emergency plan is not required for restart. The restart ' process principally invnives BEco's correction of identified hardware and management deficiencies to the NRC's satisfaction. Pilgrim is presently shut-down in accordance with the conditions of their license as modified by our confirmatory Action Letter. While the NRC agrees that emergency planning , deficiencies do exist at Pilgrim and further acrees that corrective actions should be taken, we have not agreed wthat such concerns would warrant an j enforcement action affecting the Pilgrim license. Consequently, any actions that may be taken with regard to ecerpency planning concerns at Pilarim do not preclude the NRC from authorizing Boston Edison to resume operation of the facility pending final approval of an offsite energency plan. i l a _l_________._____l.___.__-------- -
g~.v.- . - . - .- nc ..a _ , . ~ .c.- . ~ . , , ..w . . . - - - - ~ ~ - - - i l nUESTION B.11: What would the NRC do if Massachusetts cannot preoare and provide an nffsite emergency plan to FEMA' ANSWER: The NRC requires the development of offsite emergency plans that are adequate and can be impleme,ted. If Massachusetts cannot prepare an offsite eneroency plan, Boston Edison wculd have to prepare a compensating offsite plan and sumit it for FEMA and NRC review. FEMA has determined in its April 1987 interim finding, that the deficiencies in offsite plans identified in that findino are correctable. The resolution of the deficiencies would be based on a review of the offsite olans and consideration of any other information available to FEMA. Over the past several months, Boston Edison, the Connonwealth and the local
- governments in the Pilorim area have committed considerable re-sources and effort toward improving offsite emergency response programs. The ste.tus of these activities would be considered in the determination of a finding of .
adequacy. The NRC would consider the overall status of offsite emeroency ; preparedness, including FEMA's evaluation, when determining whether a reasonable assurance finding can be made. FL i I
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00ESTION 2.12: Does the NRC have emergency preparedness experts with qualifications equivalent to the FEMA experts?
. 1 l
ANSWER: Yes. The NRC recognizes the expertise of FEMA in evaluating offsite emergency preparedness and in interfacing with State and local governments for inter-pretation of emergency planning criteria; however, many NRC staff members have extensive equivalent expertise. NRC regional emergency preparedness specialist,s are members of the FEMA Radiological Assistance Committees that review all off-site emergency plans. These NRC personnel have equivalent qualifications and experience in offsite emergency preparedness. The development of NUREG-0654/ FEMA-REP-1, the guidance criteria that is used to evaluate all emeroency plans, was a joint NRC-FEMA effort. NRC personnel routinely review FEMA offsite findings in order to make an overall finding of adecuacy of emergency pre-paredness. In addition, NRC staff in the Office of Governmental and Public Affairs regularly coordinate activities with State and local officials. The responsibilities and experience of this NRC office include administration of State Agreements programs and training of State and local government personnel in radiation control programs. J_'______-l---x----- - - - - - - - - - --
7= wa:cu.m u m a, n .,av 7;uun:n m 1. m . := ;c:.:.w , ..x rec r.x ;: - -- . w.; - < . cr.rx; . . . . ..a . t 00ESTION B.13: In your testimony you refer to some demonstration of the critical aspectsoftheoffsiteemergencyplansbeforeadecjsionthat Pilorim is ready to resume operation. What do you dean by some demonstration? ANSWER: Adecuate emergency preparedness can be demonstrated in a number of ways, includ-ing evaluation of plans and procedures, verification of training in specific . areas, drills, table top exercises, and full or partial participation exercises. The correction of some of the issues in the energency preparedness program for Pilgrim will require demonstration in a drill or exercise of the plan changes, i l = _ ____ 1 :__ _:=___ . _ _ . . - - .
OUESTION B.14: What'do you mean by " addressed prior to restart" when you refer to the FEMA identified deficiencies? I.
. ANSWER:
l 1. 1 1 NRC will not permit the facility to assume operation until corrective actions satisfactory to NRC have been taken to address the emergency planning deficiencies identified by FEMA. We will aive special attention to the improved evacuation plans for schools and day care centers as will as the improved evacuation plans for special-needs and transportation-dependent populations in the ten-mile emergency planning zone. Ve will require some demonstration of the critical aspects of these evacuation plans before we can decide that Pilgrim is ready to resume operation. ud.it m,k ~M Siac c i:ENA . l 4
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a- m. un; n.- =.,. .w. ..--.cn~.,.- - -,.-n . , , , - - - - ,, - s v - - 3 00ESTION B.15: s What is the NRC position on the Commonwealth's plan to enlaroe l the EPZ?
. i ANSWER:
The present EPZ has been reviewed by FEMA and the NRC and found to be acceptable. We are not aware of the details of a proposed enlargement; however, we under-stand that the reconfiguration of the EPZ has been deferred by the Commonwealth to enable priority attention to be given to improve emergency preparedness with-in the current EPZ. In general, we have no ob.fection to providing more detailed plarning for the areas outside the existing EPZ, but due to the greatly reduced risk, see no need for the same level of planning as required for the population within the current EPZ. i l I i a
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OVESTION C.I. Some studies have shown that certain communities surrounding 1 Pilgrim have cancer rates two to three times the ave, rage U.S. rates. Could this be due to Pilgrim? ANSWER. It is very unlikely that such an increase in cancer rates could be due to pilgrim for several reasons. First, the radioactive materials released from Pilgrim result in exposures to humans similar to that from nature. Low levels of natural radiation are all around us. Natural radiation (measured in millirers per year and abbreviated as mrems/yr) is typically about 100 mrems/yr in the U.S., although it varies from about 70 to about 300 mrems/yr depending on the location in the U.S. It is important to note that, when exposure to radiation is quantified in units of millirems (or rems), there are no differences in the health risks associated with a given amount of radiation, be it natural or man-made. Natural radioactivity is in the air we breathe and the food we eat and drink. For example, the amount of radiation
- received by humans from potassium-40, a natural radioactive material in the body, is about 20 mrems/yr. Even though human beings have always been exposed to natural radiation, there is no evidence that such expnsure has significantly affected human health. The dose to a maximally exposed member of the public near Pilgrim is estimated to be less than 10 millirems per year. This exposure is a small fraction of exposure to natural background radiation. '
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OUESTION C.I. (Continued) -?- i. Second, even assuming that there is some increased risk due to exposure to low levels of radiation, any increase in cancer rates would be so small so as to be undetectable. This conclusion is based on widely accepted scientific reports, such as those compiled by the National Academy of Science's Advisory Comittee on the Biological Effects of Ionizing Radiation. This conclusion is consistent with the recommendations of recognized radiation-protection organizations, such as the National Council on Radiation Protection and Measurement (NCRP), and the International Comission cf Radiological . Protection (ICRP). ? . . . _ -_.x _ ._ -...____.-___---_L____-_. --_.._____.----L--__._.-___.-.__-:_._.____.-.
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OUESTION C.P. Could the above average cancer rates be due to exposure of workers? , i Exposure of workers must be kept within the limits of NRC regulations. While worker exposure at Pilgrim has been high compared with other plants in the U.S., it is still unlike y that this would result in a detectable increase in cancer rates. This con ys;on is based on widely accepted scientific reports, such as those compiled by the National Academy of Science's Advisory Conmittee on the Bioloaical Effects of Ionizino Radiation. This conclusion is consistent with the recommendations of recognized radiation-protection - l organizations, such as the National Council of Radiation Protection and ! Measurement (NCRP), and the International Comission of Radiological Protection (ICRP). t l l l l l l l \ - _ _ _ _ - _ _ _ _. .
QUESTI0fi C.3. How does Pilgrim rank in terns of exposure to members of the general public' ; In terns of exposure of members of the general public, Pilgrim ranks 10th highest among U.S. plants. This is based on a population dose of 94 person-rem accumulated over the years 1975 through 1983 (the latest year for which this information is available). Exposure of individual members of the public has been within the dose design objectives of 10 CFR 50 Appendix I, which are 100 times less than the public health and safety limits of 10 CFR
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QUESTION C.d. How does Pilgrim rank in tems of exposure to workers at the facility? , i In tems of exposure of workers, Pilgrim has the highest " cumulative average exposure" of any plant in the U.S. Occupational exposure at Pilgrim has averaged over the years 1973 through 1986 about 1670 person-rems /yr, compared with the PWR industry average of about 830 person-rems /yr. (The PWR fndustry average is about 500 person-rems /yr.) 0 a i
I I OVESTION D.1. What is the statutory basis for the authority of the NRC and the states in regulating radioactive materials? , ANSWER l Energy Act of 1946, Congress has since enacted other statutes effectively j dividing up the government's authority not only among many agencies but also between the federal and state governments. This has led at times to problems o' fragmentation, unclear lines n# responsibility, and overlapping jurisdictions. l The Atomic Energy Act of 1954 superseded the earlier act and centralized control over all aspects of the fuel cycle in the federal government, giving the Atomic Energy Comission an administrative monopoly of the industry. The Atomic Energy Act of 1954 established the regulation and ifcensing procedures for nuclear power plants. l
. Prior to 1959 the states had no role in nuclear policy. In 1959, Congress added an important amendment to the Atomic Energy Act of 1954, I?74, which !
delegated authority to the states over limited areas of nuclear policy. Although 1274 does not contemplate dual or concurrent regulation, it includes provisions, among others, for the Commission to (1) relinquish and states to assume regulatory jurisdiction over defined areas of source, by-product and special nuclear materials; (2) enter into agreement with states to perform inspections or other
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ym.nn r. aam . ;;rsw=w w ..:s.=a x.v:m.::. .wx mp:<.uca m= w..uc= x. : -m:w s QUESTION D.I. (Continued) i. functions; end (3) notify states of license applications ard afford opportunity to advise the Commission. The ambiguity of this amendrent has formed the basis of subsequent con-stitutional challenges on the issue of federal preemption. Under the Supremacy Clause of the Constitution, Article VI, Clause 7, federal law has supremacy over state law when the two conflict. The 1974 Energy Reorganization Act abolished the Atomic Energy Commission, but retained the Atomic Energy Act of 1954 and divided the promotion and regulatory functions between two federal agencies, the Energy Research and Development Administration (FRDA) and the Nuclear Regulatory Commission (NRC). In response to public demands for protection of the environment, Congress has enacted several statutes which affect the nuclear power industry directly and indirectly (i.e., National Environmental Policy Act of 1969 (NEPA), Federal Water Pollution Control Act of 1972, 1977 Clean Air Act amendment, Safe Drinking Water Act of 1974, Resource Conservation and Recovery Act of 1976, and the Hazardous Materials Transportation Act of 1975). State activities parallel those of the federal povernment in many respects. Most states have authority under specific radiation control laws or'under O e
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OUEST10N D.1. (Continuedi ! general public health laws to regulate activities using radiation. Since the federal goverrment is so extensively involved in this area, states operate f within the federal legislative framework and are occasionally pre-empted by j federal activities. ( In recent years, states have taken an activist stance on nuclear policy by i passing moratorium legislation. Such legislation has raised questions concerning interstate commerce and federal preemption in the courts. Even for those materfels and facilities which under the Atomic Energy Act of 1954, as - amended, as interpreted by the courts, must be licensed and regulated exclusively ; by the NPC to protect against radiological health and safety hazards and for national security interests, the states have a role. This matter is the issue dealt with in _ Pacific Gas and Electric Company vs. State Energy Resources Conservation and Development Consnission. Justice White had this to say; among others,
". . . as we view the issue, Congress, in passing the 1954 Act and in subsequently amending it, intended that the federal government should regulate the radiological safety aspects involved in the construction and operation of a nuclear plant, but that the states retain their traditional responsibility in the field of regulating electrical utili-ties for detennining questions of need, reliability, cost and other related state concerns."
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( .. : u.:.= u w .r...~a -3 j 5 QUEST 10t:D.2. What NRC programs are in effect to facilitate interaction i between the NPC and the states? , i ANSWER The Comission has had extensive interaction with the states, both formal and informal, throughout its history. With the reorganization oc th ?!PC I in April 1987, State, local and Indian Tribe Programs was created . ochieve a more proactive relationship with state and local governments and with Indian . Tribes. The NRC Agreement State Program has often been cited as an outstanding example of Federal-State partnership in dealing with mutual interests. At present there are 29 Agreement States administering a total of approximately 15,000 licensees. The State liaison Officers' Program provides for interactive between the NRC and Governor-appointed state officials, whose role is to provide a communication i j channel between the state and the NRC. i 4 I i The Conference of Radiation Control Program Directors promotes all aspects j of radiological health and encourages cooperative enforcement programs with I
QUESTION 0.2. (Continued) i federal agencies and between related enforcement agencies within each state. j The NRC is an active participant in the Conference and along with other federal agencies provides financial and technical support to the Conference. L The NRC actively interacts with the National Governors Association, the National Conference of State Legislatures, other national associations of states, and i regional organizations such as the Southern States Energy Board. - i
- The NRC and several states have signed letters of agreement and Memoranda of Understanding on reactor and waste issues, entailing among others, information sharing and state inspection activities.
Other NRC activities with the states include: providing training for state personnel reviewing state legislation and regulations providing infomation on high level and low level waste technologies and on transportation issues providing infomation on NRC licensee activities hosting national and regional workshops on nuclear issues. '
i 1
. l
. i 1
4 QUESTION D.3 What are the specific cooperative interactions between the NRC and the Commonwealth of Massachusetts. f ANSWER l I The NRC and the Commonwealth of Massachusetts have had extensive cooperation j in areas of mutual interests. These activities include the following: i Formal Ongoing Activities
. State Request to Become an NRC Agreement State '
NRC worked with MA Special Legislative Committee on Low Level Waste to ' develop legislation that would pennit NRC to delegate to Massachusetts the authority to regulate all aspects of LLW Management. The NRC will be f reviewing the Commonwealth's draft regulations and program to become a i full Agreement State, which will give the authority for MA to regualte byproduct radioactive material and source material.
. State Environmental Contract with NRC 1
Commonwealth collects and analyzes environmental samples and participates in NRC TLD program for Yankee Rowe and Pilgrim under contract to NRC. State and NRC share data and both issue annual reports.
. Verification of Licensees 10 CFR 50.72 reports Letter agreement was signed on June 18, 1987 between W.Kane and R.Boulay, Director, Massachusetts Civil Defense Agency regarding verification of licensees 10 CFR 50.72 reports. This agreement was requested by R. Boulay in response to an oral Executive Order from Governor Dukakis.
. State Request to Observe NRC Inspections at Pilgrim In response to a State request to attend the exit meeting of the AIT Inspection conducted because of the Pilgrim Loss of Offsite Power (11/87)
NRC Region I permitted State attendence. On case by case basis, a State observer will be pennitted to attend other NRC Inspections, including the Pilgrim Restart Readiness Inspection. NRC also discussed with the State the fonnal agreements that are in effect with some States whereby a State technical representative would be permitted to attend NRC inspections, enforcement conferences and technical meetings.
. Interface with Dept. of Public Health State Inspectors NRC notifies State of planned saterial inspections and permits State to observe NRC Inspections. The State also notifies the NRC Resident Inspector that they are onsite to perform State required inspections and discuss issues of mutual interest. Recently, Civil Defense personnel have made announced visits to the NRC Residents Office to discuss plant events.
. Exchange of Information through SLO Program Sig'nificant information, e.g., safety issues, emergency conditions, issues that may receive press attention, and enforcement actions, is exchanged between the Governor's SLO and the RSLO in a timely manner. For example, technical briefings were arranged between the State and NRC throughout the Pilgrim Loss of Offsite Power Event.
O s d 2 9 .L, isqE+g e % m m g <- %jnam.
a:gpen zsx::fs e.w _ c s:.w2 .:. ;w . v.m. . .. .. . zew3.. , ,u m ,,.ccc. a. a m s. w 00ESTION E.1: What specific actions / steps will NRC take prior to authorizing restart? I ANSWER:
- 1. Conduct public meetinas in the Plynouth area to solicit comments and concerns on the Restart Plan from the general public, and present the resolution of those commments and concerns.
l
- 2. Complete review of the BEco Restart Plan, including resolution of comments and concerns expected to be received from the Commonwealth, the public, and Boards of Selectmen within the EPZ.
- 3. Conduct a Restart Readiness Assessment, to include an Integrated Team Inspection of the facility readiness. In general terms, we will be looking for:
a) A stable and effective management team at the plant. b) Management, licensed Senior Reactor Operator, and licensed Reactor Operator positions at the plant are filled with oualified individuals. c) The work backlog is under control, and a system is in place to track the backlog. d) Solid and continuing improvements have been made in long-standino problem areas such as radiation protection, fire protection, and security. e w___.___ .- - -
J
.. l QUESTION E.1: (Continued) !
I
. I e) Boston Edison to be developing its own internal high standards i
of performance, and the means for critical self-analysis rela-
)
3 tive to those standards. 4 Complete those reviews 1ecessary to assure that solid improvements have been made in the offsite emergency planning weaknesses.
- 5. Conduct a public meeting with State Senator Willien Golden and other petitioners, (if they desire such a meeting) to address their Concerns.
- 6. Conduct a full Comission meeting at which restart authorization would be considered.
NRC will, of course, continue its detailed inspections of many specific issues within these general areas. i ________.___.__.__E_i_.__._l____.. ____i_.__________ _
OUESTION E.2: How does the Loss of Offsite Power Event reflect past management concerns? I The management response to the November 12, 1987 Loss of Offsite Power event was evaluated by an Augmented Inspection Team. Their report was issued on December 14,1987. It states, in part "The recovery efforts were well planned and reasonably well implemented once the conditions were properly assessed by station management." The enneensus of the AIT.nembers was that the response to the loss of power was appropriate and well organized, and that reactor plant safety was never in question. The plant Management mounted sn organized recovery effort employing multiple approaches, including attempts to restore the startup transformer, provide power through the auxiliary transformer, and assassing the reenergization of the 23Kv shutdown transformer. The Nuclear Operations Department Manager administrative 1y staffed the Technical Suppert Center about midday, allowing the operatino shift to focus on plant conditions. In addition, a recovery team was forned under the direction of the Outage Manager, consisting of personnel from outage management, station management, corporate oversicht, nuclear j engineering department, administration, technical, and maintenance, l i Overall management of the recovery effort appears to have been somewhat fragmented. The AIT experienced difficulty in determining who had overall respo,nsibility
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. u m m. ;7; n:.x.w. . e:s:: ..:c; ca: a. : .. i. y ~ a ;..w;u - x.:n. ur; - ma . :.us OtlESTION E.2: (Continued) i. for managing the recovery. In ceneral, the Nuclear Operations Manaaer remained in the Control Room, except when attendino meetings in the Maintenance Section Manager's office. His operational management involvement was clear, however, his overall direction of station activities seemed less clear. The overall recovery appears somewhat lengthy. This may be attributed, in part, however, to the weather, the cold shutdown condition of the plant (which did not mandate speedy action), and BECO manacement's stated directive to proceed slowly and deliberately during the recovery. Initially, power restoration was precluded by the severe weather and lack of clear knowledge of conditions in the switchyard. Later, power restoration by means of the Startup Transformer was precluded by the need to properly test and check out the transformer. Power restoration via 'backscuttle' (backfeeding through the main and auxiliary transformers) was not immediately possible due to the need to clear tags, open the main generator disconnect links, and and complete ! insulator washdown. BEco management acted effectively and responsibly in administrative 1y staffing the TSC. This contributed to effective management of the recovery. Interviews by the AIT indicate that BECO personnel believe the TSC could have been of even creater value had it been staffed sooner. One noteworthy aspect is.that the 1 _n___ _ _ _ _ _ _ _
=_x, . - - . ~ . . _ . ~ - . . . .
.~ - . . . . - - . . - . - - - . . - . -~. --- - . ,
O O OVESTION E.2: (Continued) ) i i 1 Nuclear Operations Department Manacer, who would normally be stationed in the ; l TSC when activated pursuant to the Emergency Plan, remained in the Control j Room. Had he been in the TSC, he may have been able to more effectively direct the overall recovery effort. BECo is reviewing several procedures for adecuacy based on experience cained during the November 12, 1987 event. Those include: 2.4.16 Distribution Alignment Electrical System Malfunctions 2.4.144 Decraded Grid Voltage 2.2.36 Instrument Air System 2.2.37 Service Air System 2.2.46 Control Room / Cable Spreading & Computer Room Heating, Ventilation, and Air Conditioning System 5.3.8 Loss of Instrument Air 5.2.2 High Winds (Hurricane) This review for adequacy indicates a long-awaited change in the management i
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C OUESTION E.2: (Continued) !. outlook of BECo in that it indicates a proactive stance. It shows that current BECo management is trying to prepare for possible events, and be ready for thair occurrence, rather than merely responding to events as in the past. This is not meant to imply that all the management problems are resolved, but rather that there is clear evidence of improvement.beino made. The NRC has made several recommendations to BECo as a result of this event. They are documented on pages 59 and 60 of the AIT report (attached). These actions, if properly implemented, could result in improved personnel performance, and increased . operational flexibility during shutdown periods. _ , _ _ _ _ _ _ _ _ _ __ - _ . - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ^^ ^ ~ ^ ~ ^
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e OUESTION E.3: What are the criteria for determining that manacement is effective? I Management effectiveness is a concept that does not easily lend itself to straioht-forward definition. However, there are certain traits that are tyDiCally evident in effective manaoement organizations. Some of these traits are: 1 Structurally, the organization is established to bring to bear appro-priate management attention and focus on the various mission areas . of the organization. For a nuclear power plant, these areas include Operations, Maintenance Surveillance, Engineering, Radiological Controls, Security, Emergency Planning, and Licensing. 2. Manacement positions are filled with qualified persennel. Turnover in these positions is centrolled such that management development and succession plans can be implemented without resulting in significant degradation in performance. 3. Management policies are clearly stated and widely understood within tbc organization. Policies and procedures are satisfactorily imple-mented and rarely violated. i 4. Manrgement information systems exist that can provide adequate records and trends of organizational performance, and can serve as a credible basis for management decisions. ____=-_--___-----_-
( ~ 0-QUESTION E.5. Would Pilgrim as currently designed, constructed and sited be buildable and operable under today's standards? If;no, then 4 why should we let Pilgrim go back on line? 1 ANSWER Part 50 of Title 10 of the Code of Federe.1 Regulations provides the regulations regarding licensing of nuclear power plants such as Pilgrim. The Pilgrim facility, was licensed in 1972, subsequent to an NPC review and approval process that dated back to the mid-1960's. This review and approval process assured that the facility was designed and constructed in accordance with the Commission's regulations and applicable codes and standards in effect at that time. The utility's Final Safety Analysis Report (FSAR) and the staff's evaluation contained in a Safety Evaluation Report (SER) constitute what is called the " licensing basis" for the plant.
' Each licanse for operrtion of a nuefear power plant contains technical specification 2 which set forth the safety and er.vironmental protection mearures to be imposed on the facility and the conditions that must be met for the facility to operate. Once licensed, a nuclear facility remains under NRC surveillance and undergoes periodic inspections throughout its operating life.
_--_-___1___E-..-
e h OUESTION E.5. (Continued) i Because U.S. nuclear facilities have been built and licensed at different times they are coverned by different codes, criteria and regulations. Newer plants throughout the U.S. are governed by more recent, and in some cases more stringent, requireme7ts. In cases where the NRC finds that substantial, additional protection is necessary t'7r the public health and safety or the common defense and security, the NRC pay require "backfittino" of a licensed plant, i.e., the addition, elimination or modification of structures, systems or components of the #acility. Some examples of this "backfitting" are the - imposition of changes required after the Three Mile Island accident and certain fire protection requirements. Many of the fire protectinn improvements are currently being implemented at Pilgrim. As part of the onooing inspection process and as part of specific licensing reviews in support of changes to the operating license or in support of ) Commission required generic actions, the staff assures that the Pilgrim facility meets it original licensir,a basis and those subsequent regulations necessary for the public health and safety. 4 3
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+
nUESTION E.6.: In re..ponse to the GA0 report received in Auoust, 1987, (87-141) what are the NRC's safety coals, status of cuideline preparation, and how will these guidelines apply to~ Pilgrim? ! ( b' O uf 8 ANSWER: The GAO report referred to above discussed the lack of guidelines for determining when a plant should be shut down for safety reasons. The NRC response stated that the operating license includes conditions and technical specifications which identify operatino conditions that require the plant to be shutdown and time limits for achieving shutdown conditions. If violations of Technical Specifications are of sufficient maonitude, an NRC enforcement option is to Order immediate shut down. When evaluating overall performance the NRC considers s 1 areas of hts *ALL activity to determine if plant operations are ecceptable. This is part of the Systematic Assessment of Licensee Performance (SALP). The SALP reviews, plant performance indicators, and the seriiannual senior manaoere.nt meetings or plant performance are adequate neans of determining wnen license performance has deteriorated to an unacceptable safety level. Appropriate action atill then be taken. No 5dditional guide'ines for determining " safe" operations are beino prepared. e
t e OUESTION E.6.: (Continued) k i NRC actions at Pilgrim have been cor.sistent with our response to the GA0 l
, report. Pilorim shut down on April 17, 19R6 due to equipment problems. This shut down was confirmed by a Confirmatory Action Letter (CAL). Deteriorating )
management controls were identified by NRC and considered as part of the SALP process. NRC management met frequently with Boston '.dison manacement and, in August 1986, the April CAL was supplemented to include cur management i concerns. Boston Edison has kept the Pilgrim facility shutdown while ' addressina management, emeroency preparedness and technical issues. NRC enforcement action, such as shutdown Order, has not been required. l I
O 1 LEM OUTLINE 1 l GUIDELINES FOR PERMANENT BWR HYDROGEN WATER CHEMISTRY INSTALLATIONS 1 l
- 1. INTRODUCTION Explain why hydrogen water chemistry (HWC) is used Explain what HWC is and different methods of hydrogen addition, i.e., liquid, gas, electrolytic, recycle Describe purpose of this report, i.e., allows installation of HWC via 10CFR50.59 ~ Identify what plant changes can and cannot be implemented via 10CFR50.59.
Explain what the issues are: Main steam line radiation monitoring Effect on materials ** Effect on fuel Plant ALARA Sky shine /off-site doses External events Industrial uses/ hazards of hydrogen & oxygen Effect on reactor (physics)** Equipment qualification Siting 9A, 1 S 1 j hl
l i 1 l,. Explain that mechanistic approach c1111 be used to
- address hazards
- 2. GENERAL SYSTEM DESCRIPTION Design basis [i.e., capacity, electrochemical potential,uses (e.g., feedwater)]
Supply facilities Supply options (EPRI report), write off chemical and recycle options Storage Siting Delivery Hydrogen injection (location of injection into FWsystem) Oxygen injection (location of injection) Monitoring Controls Interface with other systems
- 3. SUPPLY FACILITIES Hydrogen Gas
System Design
Tank construction, if applicable ASME compliance Overpressure protection system Excess flow check valves Instrumentation and control, including leak detection 2 I J_ _ _ - _ _ - - _ _ __
ymm::ux =:..;ra:w,wruu. .w:.::cv.a.u.un.ww.x v; .., . . ;, wy.m , := ".a w ,w.:w - s Capacity.-tanks, piping, valves, materials of construction, cleanliness-Purging Site Characteristics l l Location of tank and security Truck routing and frequency Truck barriers Hydrogen delivery system, purging Fire protection, NFPA requirements Tank resistance to projectiles External Events Consequence analysis for nonmechanistic large spill (reference NASA reports) Behavior of hydrogen No detonation expected Fireball n.ost likely event Consequences of fireball Seismic Tornado Aircraft Fire Flood Construction activities Truck accidents Other (Section 2.2.3 of SAR or SRP) l System specific events l Overpressurization l j Relief valve / rupture disc release and impact on plant (habitability, diesels, etc.) I _:arL--_: _- _ __: L __ _ _ a_ : _ ___ _ __ - -_ . r L _
r.. E. Hydrogen Liquid
System Design
Tank construction ASME compliance Overpressure protection system i Excess flow check valves Instrumentation and control including leak detection Capacity, tanks, piping, valves, materials of construction, cleanliness Pumps / compressors Purging Site Characteristics Location of tank and security Truck routing and frequency Truck barriers Hydrogen delivery system, purging Fire protection, NFPA requirements Tank resistance to projectiles External Events Consequence analysis for nonmechanistic large spill (reference NASA reports) Behavior of hydrogen No detonation expected Fireball most likely event Consequences of fireball _a_
w-_ ... n.. .-n_.-~._-,-.-- .
. . . . . - - . ~ . . . , - - - - - . _ _ - - .
1 Seismic L Tornado l Aircraft l Fire - j Flood Construction activities Truck accidents Other (Section 2.2.3 of SAR or SRP) i System specific events 1 Overpressurization Relief valve / rupture disc release and impact onplant(habitability, diesels,etc.) Electrolytic
System Design
Tank construction, if applicable ASME compliance Overpressure protection system Excess flow check valves Instrumentation and control including leak detectiott Purging Facility design considerations (shelterj ventilation,etc.) Internal ecuipment design Separation cf hydrogen and oxygen Pumps /conprassers capacity, tanks, piping, valves, materials of construction, cleanliness l
r. l' - l \ j i Site Characteristics Location of tank and security Truck routing and frequency, if applicable Truck barriers, if applicable Hydrogen delivery system, purging
)
Fire protection, NFPA requirements I l i External Events Seismic Tornado Aircraft Fire Flood Construction activities Truck accidents Other (Section 2.2.3 of SAR or SRP) System specific events Overpressurization of building / shelter Relief valve / rupture disc release and impact on plant (habitability, diesels, etc.) Liquid Oxygen
System Design
Tank constructier, ASME compliance ; Overpressure protection sys. tem Excess flow check valves Instrumentation and control including leak detection ! _ _____.a. __ -
- - - _ n - .. _ . . - . _ . _ . . . . . - - - . , . ... - . . ~. - - - . - - - - - - -
Capacity, tanks, piping, valves, materials of construction, cleanliness Purging Site Characteristics Location of tank and security Truck routing and frequency Truck barriers Oxygen delivery system, purging Fire protection, NFPA requirements Tank resistance to projectiles External Events Consequence analysis for nonmechanistic large spill Behavior of oxygen Consequences i Seismic Tornado Aircraft Fire
, Flood Construction activities 1 Truck accidents l Other (Section 2.2.3 of SAR or SRP) ,
i ) i System specific events Overpresstiriration Relief valve / rupture disc release and impact on plant (habitability, diesels, etc.) I
)
1
- 4. DELIVERY Hydrogen Injection points Line routing (in- and ex-plant)
Materials, codes, standards Purging and cleanliness Valves, equipment Leak detection Potential for accumulation Oxygen Injection points Line routing (in- and ex-plant) Materials, codes, standards Purging and cleanliness Valves, equipment Leak detection Instrumentation and Control 1 Basis Hydrogen flow, dissolved oxygen, offgas oxygen, trips Control philosophy (auto / manual) Location, type, etc.
]
- 5. VERIFICATION Electrochemical potential (ECP)
Constant extension rate test (CERT) , On-line crack crowth monitoring Water chemistry guidelines
~ '
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C. Gas purity fuel (write-offusingEPRI/CECotests)
- 6. OPERATIONS, MAINTENANCE, AND TRAINING Operating procedures Hydrogen water chemistry system Material handling Purging Integrate with other plant procedures (e.g., start-up, shutdown,etc.)
Mainten.ance/ inspection of HWC system and equipment Fire training (hydrogen and oxygen) - use APCI guidelines as appendixes Plant specific procedures (e.g., offgas) Rad protection Water chemistry guidelines
- 7. SURVEILLANCE AND TESTING Leak testing (with helium at shop and site)--
construction phase and later maintenance Preoperational and periodic testing Trip verification Purity, if hydrogen supplied by generation General items Excess flow check valves
)
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-8. :ALARA/ RADIATION MONITORING
.j I
Main steam line radiation monitoring Dual set point 20% power Effects on equipment qualification ALARA In-plant-No significant hazard-Access control Shielding Added monitors or surveys Other? Off-site Site-specific verification No 10CFR50 Appendix I revision
- 9. REFERENCES (Reference by Number in Text) 1
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n-STATUS OF REV. 4 0F EPGs AND NRC POSITION ON PILGRIM Staff currentiv reviewing Revision 4 of Emergency Procedure Guidelines (EPGs). Will complete review in early 1988. Staff generally agrees with proposals contained in Revision 4 (Improvements over Revisions 7 and 31 but containment venting aspects are still unresolved, l Most BWRs employ Revision ? or 3 of EPGs; several NT0Ls (River Bend, l
' Limerick) employ most concepts that are included in Revision 4 I
- l Containment venting approved in Revisions 2 and 3 of EPG's - use existing '
ventilation path and could vent at about 2x design pressure, if circumstances warrant. l Pilgrim has developed procedures generation program (PGP) and emergency operating procedures (EOPs) that are based on Revision 4 EPGs. BECo will submit their PGP and E0Ps to NRC for review (we expect submittal
<s within ? weeks). We will aftess these documents before we consider restart decision. " Flow chart" E0Ps are an improvement.
NRC is not prepared to endorse containment venting provisions of EPG Rev. 4 at this time. Still evaluating. l l Su 5.th) nw tv.4,Lp ; 1 l l
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i 4 1 i 0VERVIEW 0F l BWR EJ1 E R G E N C Y PR0CEDURE GUIDELINES.. , SCOPE 8 STRUCTURE l f l l e
. . ~ . _ . . - _ _ _ . . . . - - _ . . . . . .. - - .-. .- - . - - _ 4 EPG FUNCTIONAL REQUIREMENTS ' CRITERIA USED BY THE EPC TO DEVELOP THE EPGs EPGs must: -
- 1. Be symptomatic Enty
- Execution of operator actions
- 2. Not require that the operator identify an initiating event in order to determine how to proceed
- 3. Specify appropriate acitons irrespective of the initiating event or events
- 4. Specify appropriate actions for the complete spectrum of emergencies Design basis accidents 1
Beyond design basi.s accidents
- Wdhin design basis accidents .
RAG /3 l 10/7/86 l
,-=.-. ~ - - _ .~. . . . ~ . . . . ~. -.- EPG FUNCTIONAL REQUIREMENTS (CONTINUED) - EPGs must: -
- 5. Specifiy appropriate actions for any mechanistically possible plant condition which can be practicably addressed, irrespective of its probability of occurance
- Multiple failures
- Operator errors
- 6. Not require actions which may not be possible System capabilities Operator capabilities
- 7. Specify the best possible actions, irrespective of licensing or design basis assumptions / restrictions i
Provide guidance for operator action beyond technical l specification limits under degraded conditions l 4
- No restrictions sucn as "no operator action for 10 minutes" l
- 8. Be based on best-estimate (as opposed to licensing or design basis) analysis
- 9. Specify appropriate actions for plants as currently built irrespective l of modifications which may be incorporated at a later date (except ;
instrument range extensions) ! m r A 0 :s 41s w RAG /4 10/7/86 l_-----.--..__._.'__
(~ _ -~ -.,.,.~,.c .. -~ . . . -. r EPG FUNCTIONAL REQUIREMENTS (CONTINUED) EPGs_must: ..
- 10. Specify appropriate actions for use of all useful plant equipment, irrespective of its qualification or safety classification
- 11. Be applicable to all BWR NSSS product lines and containment designs D
RAG /5 10/7/86
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ma.w:: 2, <.u m, :c:a.- u, . .. x.: .s.,: . w - ,,, . , . . , . . , . - . . .. . , ..; , ,- OVERVIEW RPV CONTROL GUIDELINE RPV Water Level RPV Pressure Reactor Power - (RC/L) (RC/P) (RC/0) . . . db 5 A A d A IP C3 Steam Cooling IP C1 3r 3r Altemate Level C2 Control Emergency RPV Depressurization ir 1P if if C4 RPV Flooding d IP 1Fes 1P C5 Level / Power Control es IP if if C6 Primary Containment Flooding A es PRIMARY CONTAINMENT CONTROL GUIDELINE Suppression Primary Suppression Hydrogen Drywell Containment 00I Containment Pool Water and Oxygen Temperature Temperature Temperature Pressure Level Concentration (SP/T) (DW/T) (CN/T) (PC/P) (SP/L) (PC/H) i 7 _ 1 SECONDARY CONTAINMENT RADIOACTIV!T/ RELEASE CONTROL GUIDELINE CONTROL GUIDELINE , Area Area Area Offsite Radioactivity Temperature Radiation Level Water Level Release (SC/T) (SC/R) (SC/L) (RR) STR/1 10/7/86
. _. L_ - _ _ !. - .. - _ _ . _ - _ _ - _ . . _ - - _ _ - _ _ - _ _ _ _ _ .
e PRINCIPLE DIFFERENCES between -
}
EPGS Rev 3 AND Rev 4 {
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Cautions reworded and integrated where appropriate
. (
Alternate control rod insertion steps restructured and simplified i Heat Capacity Temperature Limit redefined Drywell Spray Initiation Limit revised Containment venting extended l Suppression Pool Load Limit replaced with SRV Tail Pipe Le Hydrogen Control incorporated Alternate RPV water level control restructured and simplified
~*
Spray Cooling replaced with Containment Flooding
- i Alternate Shutdown Cooling deleted
- l RPV venting incorporated i l * !
RPV water level control below TAF incorporated ! l i i STR/2 10/7/86
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' l'h ' h , ENCLOSURE 1
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N WOt5 di. PILGRIM BACKGROUND INFORMATION Fire Protection Prooram Severa'l deficiencies in the Fire Protection Program have been identified as a result of NRC's review of the program and inspections. These are in the areas of maintenance, degraded fire barriers, excessive use of i fire watches as compensatory measures and inadequate training. Staff is also reviewing the requested exemptions from Appendix R. BECo has committed to resolve all open items prior to restart from the present Refueling Outage 7 (R0 7), (Tentative Restart date June 1987). The fire protection audit is scheduled for May 1987.
- Control Room Design Review As a result of NRC's review of the sumary report, BECo has informed the staff (1/20/87) of its intention to re-screen the Human Engineering Discrepancies using a more detailed process than previously used. The schedule for the supplementary sumary, report is 4 months following the end of R0 7.
Lonc Term Prooram (LTP) (, m h G b. ;I . t On July 13, 1984, the NRC staff, by Amendment No. 75 to the license, approved BECo's Plar for the Long Tem Program. It is an integrated program for scheduling safety modifications at the Pilgrim Station. The program integrates the engineering, procurement and installation of planne6 WRC-required modifications with BEco's own requirements for plant modifications, maintenance, refueling, and operations. The semi-annual update to LTP is_ overdue. Hydrogen-Water Chemistry BEco is one of the first facilities to install a pemanent Hydrogen Water Chemistry process. This will be completed prior to restart "^ from RO 7. The syst m will inject hydrogen into the reactor coolant via the feedwater system to reduce the dissolved oxygen concentration. . ^ " Peducing the dissolved oxygen concentration and maintaining high purity ' in the reactor coolant should reduce the susceptibility of reactor piping and materials to intergranular stress corrosion cracking. 1 Park I Enhancements
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The licensee is planning several enhancements to its Mark I containment L.. . ,' W y including modifications that would permit direct venting from the torus I3 to the main stack, modification to the containment spray nozzle, fire- . water intertie to RHR systen, and the addition of a third diesel generator. These will be completed before restart from R0 7. Technical Specification (TS) Changes I Over the last few years, the licensee has requested many TS changes which should be either withdrawn or modified to reflect the current plant design. BECo was informed and is currently reviewing all the previous TS change requests. _-m___. _
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0 EDO HIGHLIGHTS PILGRIM-INITIAL ASSESSMENT OF SAFETY ENHANCEMENT PROGRAM The NRR Project Manager and a multi-disciplined team visited Boston Edison Company (BECo) July 22, 1987 to make an initial assessment of the Pilgrim Safety Enhancement Program (SEP). This program, including several significant changes to the Mark I containment (e.g. direct torus vent to plant stack) was submitted to the staff for information July 8,1987. The submittal describes' hardware changes that BECo has voluntarily elected to implement at Pilgrim. BECo states in their submittal that none of the physical plant changes ) increases the probability or consequences of a design basis accident and that 1 all of the changes will result in a reduction in the frequency of core melt scenarios or an improvement in the performance of the containment response. BECo has advised the PM that all of the changes could be implemented under the provisions of 10 CFR 50.59. BECo has also advised the staff that they. intend to implement these changes"prf'orToldsthrt "o'f the Pilsfrim"facilit'y (estimated by BECo to be in late September). The results of the initial assessment will i be available in the near future. l
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~g UNITED STATES 8 -
8' o NUCLEAR REGULATORY COMMISSION y, ,1 wAsmuoron. o. c. 2ones
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Docket No.: 50-293 Boston Edison CompanyjATTN: Mr. Ralph E. Bird 800 Boylston Street Boston, ! Massachusetts 02199 l
Dear Mr. Bird:
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SUBJECT:
EXEMPTION FROM CERTAIN REQUIREMENTS OF 10 CFR 50, APPENDIX R, SECTION III.G IN CERTAIN AREAS OF THE PLANT - PILGRIM NUCLEAR POWER STATION (TAC NO. 53416) The Commission has issued the enclosed exemption from certain requirements of 10 CFR 50, Appendix R, Section III.G. Specifically, four exemptions were requested mope. for relief in three areas from the requirements for provi' ding $levT e 4 %f.c (1) 3-hour rated fire barrier separation between redundant trains' $ located g g in Fire Zones 1.2, 1.1 and 1.8, respectively. 4 7 , Q g . (2) 3-hour fire proofing for structural steel in the Reactor Building Torus Compartment, Elevation (-) 17 feet, Fire Zone 1.30A. (3) 3-hour fire proofing for structural steel in the Reactor Building Steam Tunnel, Elevation 23 feet, Fire Zone 1.32. Based on the staff's evaluation contained therein, the Commission has granted this exemption pursuant to 10 CFR Part 50.12. The exemption is being forwarded to the Office of the Federal Register for publication. Sincerely, Richard H. Wes an, Senior Project Manager Project Dire orate I-3 Division of Reactor Projects I/
Enclosure:
Exemption A Nc.bN ' cc: See next page ! i I I
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e Docket No.: 50-293 Boston Edison Company ATTN: Mr. Ralph E. Bird 800 Boylston Street Boston, Massachusetts 02199
Dear Mr. Bird:
SUBJECT:
EXEMPTION FROM CERTAIN REQUIREMENTS OF 10 CFR 50, APPENDIX R, SECTION III.G IN CERTAIN AREAS OF THE PLANT - PILGRIM NUCLEAR POWER STATION (TAC NO. 53416) The Commission has issued the enclosed exemption from certain requirements of 10 CFR 50, Appendix R, Section III.G. Specifically, four exemptions were requested were for relief in three areas from the requirements for providing: (1) 3-hour rated fire barrier separation between redundant trains of located in Fire Zones 1.2, 1.1 and 1.8, respectively. (2) 3-hour fire proofing for structural steel in the Reactor Building Torus Compartment, Elevation (-) 17 feet, Fire Zone 1.30A. (3) 3-hour fire proofing for structural steel in the Reactor Building Steam Tunnel, Elevation 23 feet, Fire Zone 1.32. Based on the staff's evaluation contained therein, the Commission has granted this exemption pursuant to 10 CFR Part 50.12. The exemption is being forwarded to the Office of the Federal Register for publication. g . Sincerely, i p :. 2 \ i /\ c Richard H. Wessman, Senior Project Manager b Y\ Project Directorate I-3 Division of Reactor Projects I/II
Enclosure:
Exemption cc: See next page DISTRIBUTION: Docket File 50-293, NRC POR, Local POR, POI-3 r/f, SVarga, BBoger, VNerses, RWessman, 0Gormley, MRushbrook. OGC-Bethesda, EJordan, JPartlow, ACRS (10), Dhotley, JCraig, GRequa, CRossi, TBarnhart (4), GPA/PA, ARM /LFMB, TMurley/JSniezek, FMiraglia
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C F(, :P01-3 :P01-3 :PDI-3 :0GC-Bethesda: ACTDIR/P01-3: AD/0RP :0:0RP NAME :0 Gor ey:1m :MRushbrook :RWessman : : :BABoger :SVarga DATE - / /87 :11/ /87 hil/ /87 :11/ /87 :11/ /87 :11/ /87 :11/ /87 0FFICIAL PCCORD COPY Mr. Ralph G. Bird Boston Edison Company Pilgtim Nuclear Power Station F n,a ! 1
9 cc: Mr. K. P. Roberts, Nuclear Operations Boston Edison Company Pilgrim Nuclear Power Statics ATTN: Mr. Ralph G. Bird Boston Edison Company Senior Vice President
#1, Rocky Hill Road Nuclear RFD Plymouth, Massachusetts 02360 800 Boylston Street Boston, Massachusetts 02199 Resident Inspector's Office Mr. Richard N. Swanson, Manager U. S. Nuclear Regulatory Commission Nuclear Engineering Department Post Office Box 867 Boston Edison Company Plymouth, Massachusetts 02360 25 Braintree Hill Park Braintree, Massachusetts 02184 Chairman, Board of Selectmen 11 Lincoln Street Ms. Elaine D. Robinson Plymouth, Massachusetts 02360 Nuclear Information Manager Pilgrim Nuclear Power Statfort -
Office of the Commissioner RFD #1, Rocky Hill Road Massachusetts Department of Plymouth, Massachusetts 02360 Environmental Quality Engineering One Winter Street Assistant Secretary Peter W. Agnes Boston, Massachusetts 02108 Executive Office of Public Safety; One Ashburton Place Room 213 Office of the Attorney General Boston, Massachusetts 02108 1 Ashburton Place 19th Floor Charles Y. Berry Boston, Massachusetts 02108 Secretary of Public Safety Executive Office of Public Safety Mr. Robert M. Hallisey, Director One Ashburton Place Radiation Control Program Boston, Massachusetts 02108 Massachusetts Department of Public Health 150 Tremont Street, 2nd Floor Boston, Massachusetts 02111 Regional Administrator, Region I U. S. Nuclear Regulatory Comission 631 Park Avenue King of Prussia, Pennsylvania 19406 Mr. James D. Keyes i Regulatory Affairs and Programs Group Leader Boston Edison Company j ) 25 Braintree Hill Park Braintree, Massachusetts 02184 i 4 I
y.,..~__. ~. . - . . . - . . ~ . . . . , , . , _ _ . , . _ . . , , = . . . . . . 7590-01 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of ) Docket No. 50-293
) BOSTON EDISON COMPANY
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) PILGRIM NUCLEAR POWER STATION
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EXEMPTION I. The Boston Edison Company (BEco), the licensee, is the holder of Operating License No. DPR-35 which authorizes operation of Pilgrim Nuclear Power Station.
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The license provices, among other things, that the Dilgrim Nuclear Power Station is subject to all rules, regulations, and Orders of the Commission now or hereafter in e.ffect. The plant is a boiling water reactor at the licensee's site location in Plymouth County, Massachusetts. II. On November 19, 1980, the Commission published a revised Section 50.48 and a new Appenuix R to 10 CFR Part 50 regarding fire protection features of nuclear power plants (45FR76602). The revised Section 50.48 and Appendix R became effective on February 17, 1981. Section III of Appendix R contains 15 subsections, lettered A through 0, each of which specifies requirements for a particulu aspect of the fire protection features at a nuclear power plant. One of these subsections, III.G is the subject of the licensee's exemption request. i l 1
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Section III.G.1 of Appendix R requires fire protection to be provided for structures, systems and components important to safe shutdown and capable of limiting fire damageA $h at:
- a. One train of systems necessary to achieve and maintain hot shutdown conditions from either the control room or emergency control station (s) is free of fire damage; and
- b. Systems necessary to achieve and maintain cold shutdown from either the control room or emergency control station (s) can be repaired within 72 hours.
Section III.G.2 of Appendix R requires that one train of cables and equipment necessary to achieve and maintain safety shutdown be maintained free of fire damage by one of the following means:
- a. Separation of cables and equipment and associated nonsafety circuits of redundant trains by a fire barrier having a 3-hour rating.
Structural steel forming a part of or supporting such fire barriers shall be protected to provide fire resistance equivalent to that required of the barrier.
- b. Separation of cables and equipment and associated nonsafety circuits l
1 of redundant trains by a horizontal distance of more than 20 feet with no intervening combustibles of fire hazards. In addition, fire
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I detectors and an automatic fire suppression system shall be installed in the fire area.
- c. Enclosure of cable and equipment and associated nonsafety circuits of
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-r.c #-t-auania; c= Lei.ibl. vr iii. heze t . In addition, fire detectors and an automatic fire suppression system shall be installed in the fire area.
If the above conditions are not met, Section III.G.3 requires that there be alternative or dedicated shutdown capability independent of the fire area of concern. It also requires that fire detection and a fixed suppression system' be installed in the fire area of concern. These alternative requirements are not deemed to be equivalent; however, they provide equivalent protection for thofie configurations in which they are accepted. Because is is not possible to predict the specific conditions under which fires may occur and propagate, design basis protective features rather than the design basis fire are specified in the rule. Plant-specific features may require protection different from the measures specified in Section III.G. In such a case, the licensee must demonstrate, by means of a detailed fire hazards analysis,thatexistingprotectionforexistingprotectioninconjunctionwith M proposed modifications will provide a level of safety equivalent to the technical requirements of Section III.G of Appendix R. In summary, Section III.G is related to fire protection features for ensuring that systems and associated circuits used to achieve and maintain safe
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n- ~ ~ ~ - -. , - - , - . ., . - - , . , . , ~ . . -. . . . . - . shutdown are free of fire damage. Fire protection configurations must meet the specific requirements of Section III.G or en alternative fire protection configuration must be justified by a fire hazard analysis. Generally, the staff will accept an alternative fire protection configuration if:
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.The alternative ensures that one train of equipment necessary to W
l- achieve hot shutdown from either the control room or emergency control station (s) is free of fire damage. The alternative ensures that fire damage to at least one train.of equipment necessary to achieve cold shutdown is limited so that it can be repaired within a reasonable time (minor repairs using components stored on the site). Fire-retardant coatings are not used as fire barriers.
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- W Modifications required to meet Section III.G would hance ire protection safety levels aoove that provided by either existing or proposed alternatives.
Modifications required to meet Section III.G would be detrimental to overall facility safety. III. By letter dated November 16, 1983 (BEco 83-281) the Licensee, Boston Edison Company (BEco) requested four exemptions from the technical provisions of Section III.G of Appendix R to 10 CFR 50. The four exemptions requested
were',Nos.11 and j12 which pertain to lack of rated fire barriers between the k Reactor 8 i h Torus Compartment and the Control Rod Drive Quadrant rooms,- g-No. 13,which pertained to unprott.:ted structural steel in the Reactor Building 2., - Torus Compartment; and No.j14 which pertained to unprotected strutural steel in the Reactor Building Steam Tunnel. In orde simplify the review, Nos. 11 and 12 I considered together as one requ stk h tion and Nos. 13 and 14 N
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considered separately. The requests for exemptions were clarified and also modified to refl.ect both improvements in separation of redundant featuresj and refinements in (- - calculating the effects of varying combustible loadings. This supplementary information was furnished in letters dated December 27, 1984 (BEco 84-214), July 28, 1986 (BEco 86-110), November 14, 1986 (BEco 86-176), April 21, 1987 (BEco 87-062), August 4, 1987 (BEco 87-132), and in a meeting on November 24, In addition NRC Region I fire protection engineers, vi it the Pilgrim (*?1987.
.gPlantanApril1,1986( e a Dr. Notley visit o inspect fire y h Ti g4 protection improvement *and to examine the fire areas where the exemptions from 4
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9 M Appendix R were requested.
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\ Tables 1, 2 and 3 consolidate { all the information receivedjand reflect the Pilgrim Plant configuration W pru, 44: 44 &ik kke.%
- r. ::t:rt - '.^=.* Both the information in the tables and other information presented in the text were used in the staff evaluation leading to the conclusion that these exemptions should be granted.
Exemptions #11 and #12 pertain to the lack of 3-hour rated fire barrier separation between redundant trains of safe shutdown equipment. The most s{-
l l obvious location for those barriers, would be in the doorways between the reactor torus compartment and surrounding compartments as described below. The reactor torus compartment is an annulus with an approximately circular , outer wall roughly 150 ft in diameter. This is enclosed in a square section of the Reactor Building, about 160 ft on a side. The cutoff corners of the square outside the torus compartment house some safe shutdown components, and connect to other areas also containing safe shutdown equipment. 7g o... . According to good design practice, redundant trains of safe shutdown-equipment and cables are segregated so that only one train is in any one >l quadrant. The location of affected safe shutdown equipment is shown in able
- 1. The Torus compartment is designated Fire Zone (FZ) 1.30A and is abo t 40 ft high. Doorways to three of the four corners have been placed about ha f way up the 3 ft thick walls. The doorways connect to FZ 1.2 at the northwes corner, Y)!Z1.8atthenortheastcorner,andFZ1.1onthesoutheastcorner. FZ 1.2 and J:--
1.1 are 40 ft high. FZ 1.8 is 20 ft high with FZ 1.6 below it ---also 20 ft high. The relationship between redundant trains and interconnected fire zones "1 is given in Table 2. TA ble 3 gives the combustible loadings in the affected e l standard fire '. & fire zones along with the burning times for p "l l 43 M JL $ stc. _ E s -~ .g <- T he only common point between trains A and B is Y ables 1 and E 2 r --' " in FZ 1.30 A, the torus compartment. Access the torus compartment to train A 3 / isthroughtheFZ1.1and1.8doorwaysandaccesstotrainBcompartmentsis e through the FZ 1.2 doorway. Therefore, with two exceptions, the analysis can be simplified to an evaluation of the torus compartment (FZ 1.30 A). One exception is, that train B cables of the High Pressure Coolant Injection System
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y a- j p, .. Cr/d" ' s Yd*(kOh Q h& (HPCI)j run in a cable tray 8 ft above the-FrTB doorway. One would n consult with , but it has been alleged that HPCI and RCIC are not y Safe Shutdown Systems at Pilgrim. If so, then the si '6f that cable W . . . . tray is only as a source of 16teFvening combustible terial. i that is not true, then a much more vigorous analysis by BECo and/ Dr. Notle will be q-required which considers the presence of combustibles insi .8 and connecting areas, the closeness of HPCI and RCIC train A components to the doorway etc. 9T ef . ThesecondexceptionisthepresenceofbothtrainsoftheIorus
- f lnstrumentsinsidethetorus. This is unavoidable. Perhaps, some optimization is possible, eg protection for cables, but modifications to provide significant separation and fire protection of the redundant trains would degrade the basic function of providing redundant measurements of forus compartment conditions.
Dr. Notley can confirm this, but the Torus Mmperature/ struments and their .4-cables probably.do not contain enough energy to bridge the 5 ft gap between them on the inner torus wall, and the train A temperature instruments go up through the Torus ceiling without passing other combustible material or within l 20 ft of a doorway. We don't seem to have information ortlevel indication, e/ t An acceptable alternative to 3-hour rated fire barriers is to provide - separation of cables and equipment associated non-safety circuits of redundant trains of safe shutdown equipment by a horizontal distance of more than 20 ft with no intervening combustibles or fire hazards. In addition, fire detectors and an automatic fire a.sppression system shall be installed in the fire area. i i
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t . Once the two exceptions discussed above are satisfactorily resolved, the 20 ft separation is present. The distance between doorways is over 100 ft. The closest major combustible to the torus side of the doorways is cable l insulation in a tray which terminates over 20 ft horizontally ano about 8 ft above the FZ 1.2 and 1.1 doorways. TheTorus,tlmperatureJnstrumentcablesat elevations of (-)5 ft and (-)10 ft on the inner Torus wall are also over 20 ft 31 horizontally from the FZ 1.2 and 1.1 doorways. On the outer wall, the Trpm B < Torus < temperature i' / nstrument cables run close to the top of the FZ 1.8 door, (and Dr. Notley will be addressing that.) but, stop more than 20 ft short, fo,. 4::- u the FZ 1.2 and 1.1 doorways. Having established the 20 ft of separation without intervening combustibles, the remaining question is whether fire detection and automatic ire suppression should be required. The factor leading to the conclusion that detection and automatic fire suppression were not required, is the low combustible loading producing a " standard fire" duration at about 1 minute. In the event of a fire which is less intense than a " standard fire", (and t fw longer in duration) the fire is accessible for manual fire fighting. The radiation levels are low enough, fire fighting equipment located in the quadrants (through doorways, Table 2) provides full coverage and the fire does af* not make the area inaccessible. Thisisbecausethelowquafityof x-combustibles does not heat the large volume of air and concrete surface in the Torus compartment, and because the combustibles are located above the levels of the tops of the doorways where they do not interfere with fire fighting activities. The acceptability of fire hoses and portable extinguishers for fighting electrical fires in trays 36 ft above the closest access, will need to be evaluated. Backup fire detection is also available (Table 2) in the S-
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' l quadrants in case the fire is larger than expected.
L Inaddi5on,the h 1 rus( l temperature instruments would react to a much larger fire. (wouldthey?)[,h l Consequently, we have conclEded' hat the potential fire in the Torus compartment (FZ 1.30A) doeY not wa t additional detection or suppression measures in the fire area and that sufficient backup measurements exist. In ranted based summary, we have - ,/ concludeh that exemptions #11 and #12 s
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(1) Satisfactory resolution of the HPCI, RCIC question and the two Torus instrument issues (also what about level instruments?) by BEco and/or Dr. Notley. "M (2) There will be no combustibles within 20 ft horizontally of the doorways to FZ 1.2 and 1.1 eg no wooden stairs. (3) Combustible loads in FZ 1.30A (Torus compartment) do not exceed 1500 BTU /Ft2, (4) Combustibles are located where they do not interfere with fire fighting activities. (5) The material discharged from the fire hose stations and portable extinguishers in the quadrants adjacent to FZ 1.30A is suitable for fighting electrical fires. 1 l l - -
(6) That thee fire fighting equipment is effective idr fighting a fire in a cable tray 36 ft_above the closest' access.
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nnr. .wo .,.w.- s w ma,c c .. .m . -w : .: u , , = , . - . = . :.- y. . . .=-- = s.. .;.. qJ T'ABLE [ s Location of Affected Redundant Safe Shutdown Components SYSTEM TRAIN A TRAIN 8 l l Reactor Heat Removal FZ 1.1, 1.9. 1.8 FZ 1.2, 1.10
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Core Spray FZ 1.1,1.9 FZ 1.2, 1.10 Reactor Building Cooling FZ 1.1, 1.9 FZ 1.2, 1.10 '- Water Area Coolers FZ 1.1, 1.9 FZ 1.2, 1.10 High Pressure Coolant FZ 1.30A Injection Reactor Core Isolation FZ 1.30A Cooling Torus Water Level FZ 1.30A FZ 1.30A Torus Water Temperature FZ 1.30A FZ 1.30A
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_ . . ~ _ . - . , . .. . - . - - - - . . . . _ - - . . - . . . - - . _ . - - T A B 1. E k J Fire Access / Protection Features i l Train Fire Adjoining Fire Zones / FireProtection/ l Zone Fire Propagation Paths Fighting Features I i A 1.1 - 1.9 above by open stairwell A, C
- 1.30 A by open doorway A 1.9 - 1.1 below by open stairwell A,B,C
- 1.1 0adjoining Water curtain -
between 1.10 A 1.6 - 1.8 above by open stairwell A,B,C A 1.8 - 1.9 above by open stairwell A,B,C ,
- 1.6 below by open stairwell
- 1.30A by open doorway i
B 1.2 - 1.10 above by open stairwell A B, C
- 1.30A by open doorway !
B 1.10 - 1.2 below by open stairwell A,B,C 1.9 adjoining Water Curtain
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Fire Access / Protection Features Train Fire Adjoining Fire Zones / Fire Protection Zone Fire Propagation Paths Fightino Features I between 1.9
- Also has alternate shutdown panel B 1.30A - 1.1 by open doorway None except covered
- 1.2 by open doorway by Portable Fire j - 1.8 by open doorway extinguishers and '-
- Also is connecting paths manual tations between Train A and Train (inotheradjoinin B Components '\., i'AM '
I A - Smoke Detectors B - Portable Fire Extinguishers C - Manual Hose Stations 1 L- _
TABLE (3
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i Fuel and Fire 'DdiA ;
> I kva/It Fire Zone Combustible (Qua~iT) Fire Duration (Btu /Ftz) (in minutes) 1.1 Cable, Lube oil 15,300 12 . .
- 1. 9 Cable 39,200 30 ,
1.6 Cable, Lube oil 11,000 8
- 1. 8 Cable 1,600 1 1.2 Cable, Lube oil 14,900 11 1.10 Cable 36,400 28 1.30A Cable 1,400 1 1.32 Cable 5,800 4 s t-( ~
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BEco Exemption request #13 was for relief from the requirements of Section III. G.2.a to the extent it requires Structural Steel forming a part of or supporting a 3-house rated fire barriers to be protected to provide fire resistance equivalent to that required of the barrier. The barrier in quettien is the ceiling of the Torus Compartment (FZ 1.30A) which forms the floor of Fire Zones 1.9 and 1.10. BECo surveyed all of the structural steel in the Torus compartment and found that six types of beams were required to maintain the integrity of the FZ 1.30A ceiling as a fire barrier. Then,me BEco 14enasee utilized two separate 4 methods to analyze the unprotected steel for potential failure caused by exposure to burning cable in trays . Both methods demonstrated an adequate margin of safety for the structural steel and indicated that additional protection for the steel, either in the form of fire proofing applied directly to the steel or tray covers installed on the cable trays in the area, is not required. The first method considered all of the fuel (cable insulation and jacket material) in the torus compartment to be burning, and evaluated the effect of l the heat released on the unprotected structural steel. L.M&.C: ro::: calculated l the average fuel loading per squa're foot of area in the locality of the exposed (,5 A y, e.ds e.*J To I M a S e e cable tray in the torus compartment to be about 2100 btu /sq ft with an mle $) i equivalent fire severity of less than 2-minutes. Existing fire test results have already shown these six beam types can survive a " Standard" fire for 14 to { 21 minutes before failure. Therefore, a fire lasting less than 2-minutes will not lead to failure even if all of the heat released by the burning cables is 1 assumed to heat only the steel.
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,, . - . . . ~ . , . . . , ~ ,, . ., , . . . ~ . , _ . , InthesecondmethodBECoassufedthatthecabletraycrossedunderthe t-structural steel at 90* angle and about 12-inches below the beam. The combustible insulation and jacket material in the cable tray was assumed to ! burn completely and release [100% of its potential heat of combustion. This M heat of combustion was assumed to consist tantly of. rMiar}t_ heat and __ convective heat in the fire plum seems too much radiation for an oxygen >. >
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starved cable fire in a ay). The finil a'ssumption is that 100% of the convective 5eatinthefireplumeisabsorbedinthesteelsectiondirectly above the cable tray with no losses into the air, the surrounding concret,e oc by axial conduction into the remainder of the structural steel beam. (ignoring radiation energy of cable burning in an open tray which faces the beam, thereby, reflecting it that way, seems unconservative to me) Each of these assumptions is individually conservative. The temperatures calculated using those assumptions for the six beam types (or sizes) ranged from 685*F for the heaviest beam to 970*F for the lightest. This is 1 below the critical failure temperature of 1100 F for this type of steel. ( O V I " h h * /0 70 Based on the above evaluation the staff concluded that no additional fire , protection features are required in FZ 1.30A tse the structural steel supporting the floor forming the fire barrier between FZ 1.30A and Fire Zones 1.9 and 1.10 above it. I 1 In exemption request #14 BECo sought relief from Section III.G.2.a to the 1 extent that it requires structural steel forming a part of or supporting the ! floor which forms the fire barrier between the reactor building steam tunnel, FZ 1.32, and Fire Zones 1.11 and 1.12 to be protected to provide fire resistance equivalent to that required of the barrier.
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l l.. 6 ECo Tha 1__fran W performed an analysis to determine the quantity of combustible material which would be required to raise the temperature of the steel to 650'F, above which it would fail to support the floor. The analysis indicated that a combustible loading of 21,500 Btu per square foot would be required. The combustible contests of FZ 1.32 consist of a few exposed electrical cables which could yield approximately 5,800 Btu /ft2 This would result in an equivalent fire severity of approximately four minutes. The majority of the cables in this fire zone are routed in conduits and there are no other combustible materials there. (are the cables in conduits included if i the 5,800 Btu?). Fire protection consists of a portable fire extinguisher and a manual hose station in an adjacent area (will these be good on electrical l fires). The licensee's analysis indicates that the structural steel would not fail even if it instantaneously absorbed the entire heat of combustion of the combustible materials present in Fire Zone 1.32. Although the licensee did not considered the effect of the fire plume impinging directly on a structural member as in FZ 1.30A, the negligible combustible loading makes it unlikely that such a fire exposure would be significant. (If a 2100 Btu /ft2 fueled fire with 50% of the released energy J70'F of 1100'F required for failure - why wouldn't a 5800 Btu /ft2 fu ?roduce 2 times that temperature ris i.e. 2200*F using the same as ). Therefore, reasonable assurance exists that that a fire orig this fire zone will not prevent the r plant from safely shutting Based on the above evaluation, the staff concluded that the existing fire protection features for the structural steel in FZ 1.32, which supports the
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ima = 2 aa.ca u am =.ww w. ax ..m a . u w. , . . a. x o. . : .a.s . ~ w n . . , .
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u =: floor of Fire Zones 1.11 and 1.12, provide an acceptable level of protection for the redundant trains of cables and equipment located in Fire Zone 1.11 and 1.12. , l 3 Conclusion Based on the evaluations describec above, the staff concluded that the level of fire safety in Fire Zones 1.30 and 1.32 is equivalent to that achieved
.by compliance with the technical requirements of Section III.G of Appendix R,to ,
10 CFR 50 and, therefore the licensee's request for exemptions in these zones should be granted. f i l l l t i i i 1 l l l 1 t6-c - - a
- - - _ _ _ _ _ _ _ _ _ . . _ - _ _ _ _ _ . ~ - _ - _ ... _ , - -. . . . _ . . , -_- . h t IV. i Accordingly, the Commission had determined that, pursuant'to 10 CFR _i 50.12(a), % (1) the exemption as described in Section -III is authorized by M 1 law, will not present an undue risk to the public health and safety, and is consistent with the common defense and security and (2)-in this case, special : circumstances are present in the configuration of the plant and the quantities ! of combustible materials present to achieve the underlying purpose of Appendix R to 10 CFR Part 50. Therefore, the Commission hereby grants the exemption from the requirements of Section III.G.2.a of Appendix R to 10CFR Part 50 regarding fire barriers and protection'of structural steel as follows: i
'(1) 3-hour _ rated fire barrier separation between redundant trains of safe shutdown equipment located in Fire Zones 1.2, 1.1 and 1.8 which are connected through FZ 1.30A.
1 (2) 3-hour fire proofing for structural steel in the Reactor Building Torus Compartment, Elevation 17 feet, Fire Zone 1.30A. .j (3) 3-hour fire proofing for structural steel in the Reactor Building Steam Tunnel, Elevation 23 feet, Fire Zone 1.32 Pursuant to 10 CFR 51.32, the Commission has determined that the granting of this exemption will not result in any significant environmental impact (52FR35603 September 22,1987). A copy of the licensee's request for exemption dated November 16, 1983 and subsequent documents are available for public
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inspection at the Commission's Public Document Room, 1717 H Street, NW, Washington, D.C. and at the Plymouth Public Library, 11 North Street, Plymouth, l Massachusetts 02360. Copies may be obtained upon written request addressed to the U. S. Nuclear Regulatory Commission, Washington, D.C. 20555, Attention: Director, Division of Reactor Projects I/II. This Exemption is effective upon issuance. 1 Dated at Bethesda, Maryland, this day of 19 ,,. FOR THE NUCLEAR REGULATORY COMISSION Steven A. Varga, Director Division of Reactor Projects I/II Office of Nuclear Reactor Regulation i
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'e Pilgrim Station Emergency Preparedness I Exercise Timeline March 3, 1982 On-site Adequate response; no major negative fin ings, (Full participation minor improvements oeemed necessary.
exercise) ! Off-site First FEMA evaluation; interim finding t at State and local response is adequate. 72 defie 1encies noted, 13 considered significant. June 29, 1983 On-site Adequate response; no major negative fin.ings; (Full participation numerous minor improvements deemed neces: ary. exercise) Off-site Interim finding that State and local rest onse is adequate; 15 deficiencies noted. August 15, 1984 On-site Although tne response was adequate, a rer edial (Partial participation drill was necessary tu retest certain exercise with a FEMA deficiencies. These included: drill)
- 1. recognition of emergency initiating events
- 2. escalation and classification of emt rgency conditions in relation to EAL's
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- 3. timely notifications to offsite auticritie:. -
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- 4. calculation and estimation of piojected l doses and dose rates
- 5. determination and coordinatici of I decision-making process for prttective measures off-site (Drill conducted); State and local respor se adequate; one deficiency noted.
November 8, 1984 On-site (Remedial drill) Adequate response; (NRC remedial drill) improvements noted in areas found deficiant during August 15, 1984 exercise. EOF intdequacy raised as an issue; improvements deemed necessary.
car.x;. r.w. a .. . = : < :~ = c =- , w - ,x =.- < + - i DEC'2J '57 09 07- NRC MILLSTONE i P12 a .r 2 September 5, 19Bd On-site (Full participative Adequate respon=e; vo significant findin). identified: exercise) 1. radiation exposure to re-entry tei ts was not adequately evaluated.
- 2. no plans or procedures in effe ct to !
implenent a relocation to the al:ernate EOF. Off-site Interim finding that State and local resp inse is i adequate; 4 deficiencies noted; reredial drill planned for October 29, 1985. October 29 1985 Off-site (Drillconducted) Deficiencies from September (FEMA remedial dril ) 5. 1985 exercise corrected. December 10, 1986 On-site Adequate response; significant improvement over (Partial previous exercises; new EOF in use; minor exercise) participation discrepancies in connunications and HP trtining noted; all previous on-site e)arcise deficiencies closed. S 4 l l i I
3 '8 09:29 NRC Miu: T. NE 1 FG2 Historical Sequent.e of P11grini Offaite Issues 6/16/81 Director of MCDA submitted Stat RERP (for PiaveIm) to FEM / with statement that the plan was adequate. 10/81 FEMA and RAC reviewed and reported on the Mass. RERP. MCDI revised the RERP based upon FEM's coments. 9/82 FEMA and RAC reviewed the revision anc reported on wens an n. FEMA received no response from the Commonwealth on further revisions. 6/3/82 FEM held a public meeting. The following issues were ral:ed by the puolic:
- ability to evacuate communities within the 10 mile EPZ
- ability to evacuate Cape Cod beyond the 10 mile EPZ
- Reliability and effectiveness of sirens
- Training of teachers, school bus drivers and hospital personnel
- Public infomation brochures
- KI policy
- Procedures for elderly and special needs persons no date Commonwealth responded to all the ahnya issuss by stating 4.he RERP addressed these concerns and pledging to work towards further plan improvement.
9/29/82 FEMA issued Interim Finding for Pilgrim. ! 3/3/82 Annual Exercise, FEM observed 6/29/83 Annual Exercise, FEMA observed 9/5/85 Annual Exercise, FEMA observed i 10/29/85 Remedial Exercise, FEM observed , 8/15/84 Drill, FEM observed ; 3/85 Status of off site RERP was: )
- many planning problems unresolved from 10/81 RAC review '
- Commonwealth had not responded to 10/82 RAC review I
- Commonwealth had not provided FEMA with schedule of corrective acticns for problems identified in 1982 and 1783 exercises 3/6/85 FEMA suspended processing of Commonwealth request for 44 C R 350 approval.
6/20/85 Cosenonwe61th sent a schedule to FEMA delineating steps to se taken to correct 1982 and 1983 exercise problems. These revision. were not delivered to FEMA. l 9/5/85 FEMA noted many previous exercise deficiencies were resols ed but identified new p 4blems. 10/29/85 Remedial exercise corrected new problems. The Commonwea11 h has not provided FEMA with a schedule of corrective actions.
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'l 10/30/d5 FEM agafn infomed tne Commonwealth that 44 CFR 350 review v as not progressing.
6/86 Commonwealth provided RERP and local plans tnat were requesta 1 in 1985. j 6/6/86 Commonwealth responded to FEMA. The reply did not provide a schedule for completion. Review was based upon 1982 RERP and 1985 local plans. 9/5/86 FEMA infonned MCDA of intent to conduct self initiated review. 12/22/86 Commonwealth forwarded copy of Barry Report. 8/4/87 FEMA Self Initiated Review issued. I l l l
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4 v3. CONCLus!oM This study of our preparedness for an accidant at the Pilgrim Nuclear Power Plant establishes the interdependence of plant T.anage ent, reseto: safety, rega: story enfv: cement and emergency planning. A deficiency in any one of these areas may jeopardize the safety and health of not only those in the ( \ l ir. mediate vicinity of- the plant, but others who may live many j i l miles away. [ There is cause for concern about the quality of each of these four functional areas. Unfortunately, the Commonwealth l i L is limited in its ability to bring about improvements in the I
- f. : : tree aress. S +::.elear, we have s:;gSt to ider. :!y the problers and weakneeses that presently exist in all these areas with specificity. We have proposed a plan of action that includes recommendations for activity by Boston Edison Corpany, t'.e S;cles: Peg;1atory C =r'.ssion, the Con;tes: and state and
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I. our vie.', there has been such a disappointing history of performance at P.1; ir by Boston Edison Comp.sny since 1972 and i there currently exists problems of such magnitude that Boston Idison Company bears a heavy bu: den of pe:susding the Commonwealth of Massachusetts that it should be permitted to resJ e nuclear operations at the Pilgrim Power Plant. Resce tfully submitt d,
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Charles V. Barry Secretary of Public Safety ( e e l l 4 1t _ _ _ _ _ -. .______._.___ ____ _ _.____ _ ________ . .
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. REPORT TO THE GOVERNOR ON EMERGENCY PREPAREDNESS FOR AN ACCIDENT AT. THE PILGRIM NUCLEAR POWER STATION
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, I. INTRODUCTION. . . . . . . . . . . . . . . . . . . . . 1 II. B A C Y.C R O U " D . . . . . . . . . . . . . . . . . . . . . 5 A. The Pilgrir. Reactor . . . . . . . . . . . . . . 5 B. The Development of the Regulatory Framework
! for Er.ergency Planning. . . . . . . . . . . . . 7 C. A !!istory of Energency Planning and Related
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i A. Plant E r.agerer.: Concerns. . . . . . . . . . . . 21 B. Siren, Alert and notification Systems. . . . . . 31 C. .c. s. .' c. . "y w.. "^.~*.-..e. **.5
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- 3. Nature of Emerge.cy Plans. . . . . . . . . . . . 4:
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j O. The P.a;;r Wes'<nese cf t.e P:1;ri.- P'ans. . . . . . 4-
- e. Pilgt. : The Bes:P Pc;;1stior. . . . . . . . . . 45 T. Pilgrir: The Transport Depender.: Pcpalation. . . 51 G. Completing the Process of Formal Approval. . . . 54 H. Pr:po ed Pilgrir Plar. F.r.'.Encerer.ts . . . . . . . 59 V. R z-wn s. . r...... .: ... .s
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VI. CONCLUSION. . . . . . . .. . . . . . . . . . . . . 74 VII. INDEX TO APPENDICES . . . . . . . . . . . . . . . . 71
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pg ,q 4 , S Wm r -n T0 --- 2 7 9 o 0-C 6 sw feS7~) tp 7-- l par. or ccN m ts_ , doGDew Pm rv oy ") , q JURISDICTION AND INTRODUCTION 1 Jurisdiction 2 Description of the Petititioners 3 Introduction STATEMENT OF THE FACTS I. MANAGEMENT 5 7
- 1. Licensee's Management of Pilgrim is Deficient 2. L 8 9
- 3. Deficiencies in the Area of Plant Operations 4. Deficie 14 15
- 5. Deficiencies in the Area of On-Site Preparedness 16 19 6.
- 7. Deficiencies,in the Area of Surveillance 20
- 8. Deficiencies In'the Area of Security and 21 21 Safegua
- 10. Deficiencies..in the Area of Liciensing Activities
- 11. Deficiencies in the Area of Fire Protection 23 12. Deficie 23 13.inStatement All its Endeavors of Law as it Applies to Standards of Management II. EMERGENCY RESPONSE PLAN 25
- 14. Deficiencies in the Radiological Emergency Response Plan 26 27
- 15. DeficienciesininNotification
- 16. Deficiencies Advance Information During an Accident .
27 28
- 17. Deficiencies in Evacuation' Plans .
29
- 18. Deficiencies in Medical Facilities 30
- 19. The Emergency Planning Zone is Too Small20. Lac III. CONTA1'NMENT STRUCTURE 32
- 21. Inherent Design Flavs of Pilgrim's Containment Structure APPENDIXSS 150-293/85-99) A-1 B-1 Table 5, Enforcement Data (SALP report 150-293/85-99)
Appendix A: Table 7, Plant Shutdowns (SALP report C-1 Appendix B: Pilgrim Station Regulatory Performance History Appendix C: l 1 " ~ - - - _ - - - - - - - - - - ~ _ _ _ _ _ _ . _
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w . o UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATO N COMMISSION PETITION FOR SHOW CAUSE CONCERNING PILGRIM I NUCLEAR POWER STATION JURISDICTION AND INTRODUCTION { J Jurisdiction This petition is filed pursuant to 10 CFR F2.206 and 10 CFR F2.202. The action requested is that an order be issued to the Boston Edison Company to show cause as to why the Pilgrim I Nuclear Power Station Station ('P11 grim') should not remain closed cnd or have its operating license suspended by NRC unless and until that time at which the licensee demon'strates conclusively to the NRC and the public: (1) that itr management is no longer hampered by the deficiencies noted by the petitioners herein; (2) that the Radiological Emergency Response Plan fully complies with 10 CFR #50.4*/ and 10 CFR #50.57, is given high organizational priority and sufficient funding by the ; licensee, the Federal Emergency Management Agency (FEMA), the Massachusetts civil Defense Agency (MCDA) and local governments; and (3) that the inherent design flavs noted by petitioners herein which render Pilgrim I's containment structure extremely vulnerable in most accident scenarios have been overcome to the extent that the public health and safety will be assured. The material which follows demonstrates that there is not reasonable assurance that Pilgrim I can be safely operated due to numerous deficiencies in licensee management, the inadequacy of the existing Radiological Emergency Re.sponse Plan (RER.), and inherent deficiencies in the Fac111tyra containment structure. The deficiencies discussed in detail below cut a broad swath across the spectrum of safety requirements . It might be argued that one or more of the deficiencies taken individually does not pose an intolerable risk. In the aggregate, however, they
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UNITED STATES f b, <3 g NUCLEAR REGULATORY COMMISSION j WASHINGTO N, D. C. 20555 *
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MEMORANDUM FOR: Harold R. Denton, Director Office of Nuclear Reactor Regulation ) FROM: Darrell G. Eisenhut Director
- Division of Licensing q
SUBJECT:
ENVIRONMENTAL ~PR0tiKTION -PLAN -
Reference:
- 1) Memorandum Dated October 26, 1982 from DGE to RHVollmer 2' Memorandum Dated January 5 3j Merndrandum,DitM Qecember f,1983 1974 from from RHVollmer HKShapar to HRDenton to HRDenton i
I have received a copy of Mr. Vollmer's January 5,1983 memorandum to you i on this subject (Reference 2) and wish to reaffirm and expand the position
-- of DL contained in my memorandum. to.&. Vollmer of October 26, 1982 (Reference 1 - Attachment 1). <- - -
As noted in Reference 2, an Environmental Protection Plan (EPP) has been incorporated into all new operating licenses since 1980 and has been backfitted into a number of operating licenses during this period. Attachment 2 provides a tabulation of facilities indicating whether or not deletion of water.
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qualify (TS) has been requested by the licensee and providing the status of NRC review of these licensee requests. In all cases whe7e an EPP has been bai:kfitted to an operating reactor the licensee has, for assorted reasons, elected to propose (or agreed to accept) such a requirement as a condition of its operating license. As supported by Reference 3, (Attachment 3), I believe that deletion of all water quality related Technical Specifications, where an effective NPDES permit is held by the facility, is consistent with the Federal Water Polution Control Act and the ASLB and ASLAB decisions on this matter. Accordingly, I also do not believe that an EPP shodd either be backfitted to operating reactors without an explicit licensee request or implemented on new operating licenses. It is stated in Mr. Vollmer's January 5,1983 memoran-dum to you that "it appears that licensees would have little resistance to the EPP if NRR demonstrated a clear consensus - - - in the direction of ' standardization by this method." In this regard, the specific licensee dis-l cussed in Reference 2 (Boston Edison) requested that all non-radiological water quality requirements be deleted from its operating license for Pilgrim. The licensee did not propose and has indicated (as have several other licensees) that it will not accept an EPP requirement. In the case of Prairie Island, the licensee was adamant in challenging the legal basis for requiring an EPP and none was issued in connection with removal of water quality related Technical j Specifications. In addition, ELD has stated that an environmental impact appraisal l need not be~ prepared in connection with a license amendment deleting water quality J TSs when an EPP is not added by the amendment.
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. zr.ca...=m 2-Therefore, 'it is DL's plan, with your concurrence, to comunicate with the 12
. licensees who have not requested deletion of water quality related TSs within the next week or so and suggest that they propose a license amendment as soon as possible, but in any case within 30 days, deleting the non-radiological water quality related requirements.
Action will then be taken by DL within one month of receipt of the licensee submittal to approve these amendment requests as "a ministerial action required as a matter of law." Likewise, for.those cases where a licensee has already requested deletio'n~oT watpr'qT;'ality TSs, it is DL's plan to similarly approve these amendments within one month.
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- - -- Darrell-4. Eisenhut, Director Division of Licensing cc: R. Vo'llmer i G. Lainas l D. Muller
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B. Emergency Preparedness 1 QUESTION B-1: What action is NRC taking in response to the FEMA findings of , July 29, 1987? ANSWER B-1: On August 18, 1987, the NRC requested an action plan and schedule for correction from Boston Edison Company addressing the FEMA-identified deficiencies. Boston-Edison submitted their action plan on September 17, 1987. Headquarters and regional NRC staff have closely monitored the progress of the utility's efforts regarding the resolution of offsite emergency preparedness issues. On various. occasions, NRC staff members have discussed the status of emergency preparedness with the utility as well as the Commonwealth and local officials. Information from these parties indicates that significant progress has been made toward resolving the FEMA-identified issues. The NRC will continue to monitor the progress of the utility, Commonwealth, and local officials in correcting the emergency preparedness deficiencies. The determination wh'ther e to restart the Pilgrim plant will involve consideration of the corrective actions taken to address each of the emergency planning issues identified by FEMA. The NRC will coordinate review efforts with Boston Edison, FEMA, State, and local officials
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to identify the most important aspects of these deficiencies and the actions necessary to demonstrate adequate preparedness. I I
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4. 2 00ESTION B-2: Why is the Pilgrim restart process continuing with the
. FEMA-identified deficiencies unresolved?
I ANSWER B-2: The restart process principally involves BECo's correction of identified i deficiencies to the NRC's satisfaction. Pilgrim is presently shutdown with plant activities being conducted in accordance with the conditions of their license as modified by our Confirmatory Action Letter. While the NRC agrees that emergency planning deficiencies do exist at Pilgrim and further agrees that corrective actions should be taken, we have not agreed that such concerns present an " imminent danger" to the public that would warrent an enforcement action affecting the Pilgrim license. Consequently, any actions that may be taken with regard to emergency planning concerns at Pilgrim do not preclude the NRC from authorizing Boston Edison to resume operation of the facility pending final resolution of all emergency preparedness deficiencies. None of the FEMA identified deficiencies appears to be of such complexity that it can-not be corrected. FEMA has outlined in their report what would be necessary for each item to be corrected. Therefore, it is reasonable to assume that the deficiencies will be satisfactorily resolved.
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- e w QUESTION B-3: What emergency preparedness action will be necessary by BECo,
. State and local entities, and FENA before a restart in authorized?
ANSWER B-3: Any actions that may be taken with regard to emergency planning concerns at Pilgrim do not preclude the NRC from authorizing Boston Edison to resume operation of the facility pending final resolution of all emergency prepared- I ness deficiencies. Notwithstanding the fact that NRC has taken no enforcement action affecting the Pilgrim license, NRC will not permit the facility to resume operation until corrective actions satisfactory to NRC have been taken to address the emergency planning deficiencies identified by FEMA. We will give special attention to the improved evacuation plans for schools and day cere centers as well as the improved evacuation plans for special-needs and j transportation-dependent populations in the ten-mile emergency planning zo w. We will require some demonstration of the critical aspects of these evacuation plans before we can decide that Pilgrim is ready to resume operation. The NRC will coordinate review efforts with BECo, FEMA, State and local officials to identify the most important aspects of the identified deficiencies and the ! i actions necessary to demonstrate adequate preparedness. 1 00ESTION B-4: Do NRC regulations allow a nuclear plant to operate during the l four months after an NRC finding of inadequate emergency preparedness? l l . - , _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
g3 7 . g g. ,, _ ANSWER 8-4: The Commission recognizes that there can be deficiencies in the emergency planning and preparedness associated with a nuclear facility. However, there must be substantial compliance with the regulations, i.e., compliance sufficient to find that there is reasonable assurance that adequate protective measures can and will be taken in *a radiological emergency. Indeed, even in those instances where the Comission can no longer make its reasonable assurance finding, emer-gency preparedness deficiencies may not require facility shutdown. See 10 CFR 950.54(s)(2)(ii). In practice, radiological emergency response plans are rarely if ever perfect and complete'. This is the reason for the continuing FEMA and NRC oversight of this area. Deficiencies will be found and assessed for signif-icance. While all deficiencies are expected to be corrected, not all will change a finding of reasonable assurance by the NRC. For an operating plant, such as Pilgrim, the regulations provide considerable enforcement flexibility to the NRC. Whereas significant deficiencies in a safety system at an operating reactor could cause it to be shut down at once, the identification of significant deficiencies in emergency planning results in the initiation of a four-month period within which the deficiencies are addressed, not in an automatic shutdown of the facility. Even after this "120-day clock" has run, the regulations provide that the NRC has the enforce-ment discretion to allow the plant to continue operation even in the face of such a deficiency. In detennining whether a shutdown or other action is l appropriate, the Commission will take into account such factors as whether the i L - ___-_ - - .
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2 .t: . l I licensee can demonstrate that the deficiencies in the plan are not significant, or that adequate interim compensating actions have been or will be taken promptly, or that there are other compelling reasons for continued operatica. QUESTION B-5: Can the NRC allow the Pilgrim station to operate without adequate emergency plans? ANSWER B-5: While the NRC agrees that emergency planning deficiencies do exist at Pilgrim and further agrees that corrective actions should be taken, we have not agreed that such concerns present an " imminent danger" to the public that would warrant an enforcement action affecting the Pilgrim license. Consequently, any actions that may be taken with regard to emergency planning concerns at Pilgrim do not preclude the NRC from authorizing Boston Edison to resume operation of the facility pending final resolution of all emergency preparedness deficiencies. for an operating plant, such as Pilgrim, the regulations provide considerable enforcement flexibility to the NRC. Whereas significant deficiencies in a , safety system at an operating reactor could cause it to be shut down at once, the identification of significant deficiencies in emergency planning results in the initiation of a four-month period within which the deficiencies are addressed, not in an automatic shutdown of the facility. Even after this "120-day clock" has run, the regulations provide that the NRC has the enforce-ment discretion to allow the plant to continue operation even in the face of l such a deficiency. -- _ _ _ _ _ _ _ _ w - .
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QUESTION B-6: How will the NRC evaluate the status of the resolution of
. emergency preparedness issues?
ANSWER B-6: The determination whether to restart the Pilgrim plant will involve consid- ) I eration of the corrective actions taken to address each of the emergency planning issues identified by FEMA. Based on information obtained from the licensee, FEMA and State and local officials, the NRC will review the emergency l planning issues to determine which are of highest priority and what actions are necessary to demonstrate that reasonable preparedness exists prior to restart. QUESTION B-7: If the NRC finds that the state of emergency preparedness does not provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency, what action can the NRC take? ANSWER B-7: If the deficiencies in emergency preparedness are not corrected within four months of the NRC finding, the Commission will determine whether the reactor shall be shut down until such deficiencies are remedied or whether other enforcement action is appropriate. The Commission will take into account such ; factors as whether the licensee can demonstrate to the Commission's satisfac-tion that the deficiencies in the plan are not significant for the plant in question, or that adequate interim compensatory actions will be taken promptly, or that there are other compelling reasons for continued operation.
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7.. QUESTION B-8: Will we require all of the FEMA and Barry deficiencies to be
.. corrected prior to restart?
d ANSWER'B-8: It;is the NRC's position that all of the deficiencies identified by FEMA will 4 be addressed prior to restart. Deficiencies concerning the evacuation of schools and daycare centers as well as the evacuation of special needs and'transporta-tion dependent populations will be given special attention. ~We will require same. demonstration of the critical aspects of these evacuation plans before a decision is made that Pilgrim is ready to resume operation. With respect to the deficiencies identified by Secretary Barry, FEMA has indicated that these have been included in the FEMA self-initiated review. QUESTION B-9: Will we require a satisfactory emergency exercise with a FEPA report before restart? ANSWER B-g: Adequate emergency preparedness can be demonstrated in a number of ways, includ-l- . ing evaluation of plans and procedure, verification of training in specific areas, drills, table top exercises, and full or partial participation exercises.
- .The 1987 full participation exercise for Pilgrim has been deferred as requested by the licensee to the first half of 1988. The correction of some of the issues in the emergency preparedness program for Pilgrim may be demonstrated in a drill
su. .. . .m.=x=:.na=wmu.w.,a.x m:ume : +.m w. a w. . - :.x; ,.~,= . w:w:=. 4 i or exercise of the plan changes, however, we see no need to require a full-par-ticipation exercise prior to restart. The NRC will, nonetheless, verify that the overall state of emergency preparedness is adequate to protect the public health and safety prior to restart. QUESTION 8-10: Is an approved offsite emergency preparedness plan required for restart? ANSWER B-10: An approved offsite emergency plan is not required for restart. The restart process principally involves BEco's correction of identified hardware and management deficiencies to the NRC's satisfaction. Pilgrim is presently shut-- down in accordance with the conditions of their license as modified by our confirmatory Action Letter. While the NRC agrees that emergency planning deficiencies do exist at Pilgrim and further agrees that corrective actions should be taken, we have not agreed wthat such concerns would warrant an enforcement action affecting the Pilgrim license. Consequently, any actions that may be taken with regard to emergency planning concerns at Pilgrim do not preclude the NRC from authorizing Boston Edison to resume operation of the facility pending final approval of an offsite emergency plan. QUESTION B-11: What would the NRC do if Massachusetts cannot prepare and provide an offsite emergency plan to FEMA?
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1 9 ANSWER B-11: I The NRC requires the development of offsite emergency plans that are adequate and can be implemented. If Massachusetts cannot prepare an offsite emergency plan, Boston Edison would have to prepare a compensating offsite plan and sub-mit it for review by FEMA and the NRC. FEMA has determined in its April 1987 i interim finding, that the deficiencies in offsite plans identified in that I finding are correctable. The resolution of the deficiencies would be based on a review of the offsite plans and consideration of any other information avail- , 1 able to FEMA. Over the past several months, Boston Edison, the Commonwealth I and the local governments in the Pilgrim area have committed considerable re-sources and effort toward improving offsite emergency response programs. The status of these activities would be considered in the determination of a finding of adequacy. The NRC would consider the overall status of offsite emergency preparedness, including FEMA's evaluation, when determining whether a reasonable assurance finding can be made. QUESTION B-12: Does the NRC have emergency preparedness experts with { qualifications equivalent to the FEMA experts? ANSWER B-12: Yes. The NRC recognizes the expertise of FEMA in evaluating offsite emergency preparedness and in interfacing with State and local governments for inter-L l ___c_-_-_______ __ _- ._
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. pretation of emergency planning criteria; however, many NRC staff members have extensive equ,1 valent expertise. NRC regional emergency preparedness specialists -
are members of the FEMA Radiological Assistance Committees that review all off-site emergency plans. These NRC personnel have equivalent qualifications and i experience in offsite emergency preparedness. The development of NUREG-0654/ l FEMA-REP-1, the guidance criteria that is used to evaluate all emergency plans, was a joint NRC-FEMA. effort. NRC personnel routinely review FEMA offsite findings in order to make an overall finding of adequacy of emergency pre-paredness. In addition, NRC staff in the Office of Governmental and Public Affairs regularly coordinate activities with State and local officials. The responsibilities and experience of this NRC office include administration of State Agreements programs and training of State and local government personnel in radiation control programs. QUESTION B-13: In your testimony you refer to some demonstration of the critical aspects of the offsite emergency plans before a decision that Pilgrim is ready to resume operation. What do you mean by some demonstration? ANSWER B-13: Adequate emergency preparedness can be demonstrated in a number of ways, includ-ing evaluation of plans and procedures, verification of training in specific areas, drills, table top exercises, and full or partf al participation exercises. The correction of some of the issues in the emergency preparedness program for Pilgrim will require demonstration in a drill or exercise of the plan changes.
- - - _ - - - - - - _ . _ - - - - _ _ _ _ - _ _ _ . _ _ ~ *
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9 QUESTION B-14: What do you mean by " addressed prior to restart" when you refer to the FEMA identified deficiencies? - ANSWER 8-14:
-NRC will not permit the facility to assume operation until corrective actions satisfactory to NRC have been taken to address the emergency planning deficiencies identified by FEMA. We will give special attention to the improved evacuation plans for schools and day care centers as will as the improved evacuation plans for special-needs and transportation-dependent populations in the ten-mile emergency planning zone. lle will require some demonstration of the critical aspects of these evacuation plans before we can decide that Pilgrim is ready to resume operation.
QUESTION B-15: What is the NRC position on the Commonwealth's plan to enlarge the EPZ? ANSWER B-15: The present EPZ has been reviewed by FEMA and the NRC and found to be acceptable. We are not aware of the detaf f s of a proposed enlargement; however, we under-stand that the reconfiguration of the EPZ has been deferred by the Commonwealth to enable priority attention to be given to improve energency preparedness with-in the current EP7.. In general, we have no objection to providing more detailed planning for the areas outside the existing EPZ, but due to the greatly reduced risk, see no need for *.he same level of planning as required for the population l within the current EPZ. I
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TO: (Name, otllce symbel, room number, In6tials Date
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S. Action File Note and Retum Approwel For Clearance Per Conversation As Requested For Correction Prepare Reply Circulate For Your Information See Me Comment investigate Signature Coordination Justify RD4 ARKS aHr#
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~ 11nf$ 'Te) &E Aeb W Ya/ &Vp'e K vQ AgfT s 00 NOT use this form as a RECORD of approvals, concu nces, disposals, A -eft clearances, and similar actions VI9086:(Name, org. symbol, Agency / Post) Room No.-Bids.
ch sost-102 7/% S J#7 A " " * - OMIONAL FORM 41 (Rev. 7-76)
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u,x - .v d,bl PROPOSED AGENDA FOR MEETING: BECD/ FEMA /NRC . , _ } n ' e. .'_ A Objectives: ,'N+ 't. 1.
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- a. To introduce Ralph Bird and Ron Varley - *
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- b. To receive direction from FEMA on how to proceed _ _ _ .
- c. To set up working relationship with McLo,ughlin 's staf f f"'I ' 4 .. ~.{s .,
- 2. Items for discussion
- a. FEMA self-initiated review
- 1) Ground rules for response by the licensee
- b. EPZ expansion
- 1) Rationale for existing boundaries
- 2) Reasons for opposing expansion
- 3) National's policy on EPZ expansion I
- I __ _ _ _ _ _ . _ _ _ _ _ _ ._.___.______________d
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PLAN OF THE DAY ' EFFECTIVE: 1500 HOURS 7/23 TO 1500 HOURS 7/24
- 1. SYSTEM AND PROJECTS -
4
- 11. ISSUES AND ACTION ITEMS. 5 -
Ill. DAILY ACTIVITIES-3 DAY SCHEDULE
-NOTE-ALL WORK PERFORMED ON SITE MUST BE IDENTIFIED ON THE PLAN OF THE DAY OR DESIGNATED "A" PRIORITY BY THE WATCH ENGINEER.
APPROVED BY: 9 I
- h. m n Exhor&kned '
OMG Coordinator Chief Operating Engineer r*1W lity Cptrol fpfup Leader Ch (08nn0 fiadfological EI1 gin i I MA I CMG Group Leader n_ m . Chief Maintenance Engineer A-_--s----- ____z __-----..-___a.----- -
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PLAN OF THE DAY SYSTEMS AND PROJECTS
.s RPV ACTIVITIES (CRITICA1. PATH) .. ,,
- PIPS 43 (communication line) ECD 8/4 WiCH
-Verify positions (PIPS)
- Stroke CRDs ESD CPS
- LPRMs NA 200 Voltage breakdown test 100% ECD 7/25 i & C / Tech.
NA 300
-IR and voltage breakdown problems ECD GE/ T. Beneduci 210 Cable replacement ESD 7/27 E
- Final LPRM TDR Testing ESD 7/25 T.Beneduci SECONDARY CONTAINMENT
.s
- Preop testing ( TP 87- 100 ) ESD 7/30 T.Beneduci
- Standby gas treatment Replace ductwork (PDC 86 70) ECD 7/29 D. Mills hydro deluge piping ESD 7/29 J. Sabina
-functionaltest of ME8123 & ME8124 ESD R. Sherry
-replace charcoal filters ESD D. Mills
-Perform 7.1.30 ESD Chemistry
.- procure rupture disc DUE Bechtel
-Preop testing (TP 87128 ) ESD 7/30 T.Beneduci SBGT overcurrent relays ESD R. Sherry
- Modify Torus Vent (PDC 86 51) ECD 8/28 D. Mills
- Resotve criticalitem punchlist NED/SEO
- Preop testing (TP 87- ) ESD 8/21 T.Beneduct
- Secondary containment fire seats
-repairs ECD D. Mi!!s
-upgrades ECD D. Mills CONTROL ROD DRIVE
- HCU upgrade ECD 7/24 R. Sherry
- Rework B CRD motor ECD R. Sherry 1
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- PLAN OF THE DAY
)
SALT SERVICE WATER '
- Buried pipe repairs ECD 7/28 D. Mills , l 1
- JF 29151,2,3,4,6 Repair plan
)
- repair indications ECD 7/28 0. Mills !
-insta!! spools ECD 7/28 D. Mills (
- perform hydros ECD 7/30 D. Mills I ECD 7/28 D. Mills !
- repair screenhouse wall
- additional repairs to spools ECD 7/28 D. Mills
- Rework hangers ECD 7/25 D. Mills
-NCR 87-182, NCR 87 205, NCR 87 255
-NCR 87 256, NCR 87 264, NCR 87 265
-NCR 87 266, NCR 87 286, NCR 87-291
-NCR 87-386
- Replace spools at screenhouse
- JF 29-17 2 ECD 7/24 R. Sherry
- JF 29-17 4 ECD 7/28 R. Sherry
- Complete MOV & MCB ECD 8/14 R. Sherry
-3800 /52 1564 R. Sherry
-3806 /52 1464 R. Sherry
-3808 /72 741 R. Sherry
-3813 /72 834 R. Sherry REACTOR WATER CLEANUP
- 8.M.2-1.2.1 ECD R. Sherry
- Complete MOV & MCB EDC 8/14 R. Sherry
-1201 02/52 2054 R. Sherry
-1201 80/52 2056 R. Sherry
-1201 133/52-2066 R. Sherry
- Rework hangers ECD D. Mi!!s
-NCR 86105
-NCR 87184
- CV 1239 in service test per NEDWI 348 ESD PCD 2
~. r: .; y . m :u:.a. a , a :.y . w a , mc.c. L:n.: n;.:a.:.cna;.. w,;m;i _ a:: ; .L ;x:=- - PLAN OF THE DAY CORE SPRAY
- Hydro test (intersystem' leakage)
ECD 7/2.5 J. Sabina 1400-9A ECD 7/25 J, Sabina
-1400-98 .,
' Rework Hangers .
- NCR 87 074. NCR 87183, NCR 87 263, NCR 87 283,
-NCR 87-295, NCR 87 302, NCR 87-369.
-NCR 87-191/ALARA Hold CLOSED COOLING WATER
- RHR heat exchanger repairs ESO 7/24 R. Sherry EDC 8/14 R. Sherry
- Complete MOV & MCB R. Sherry
- -4010A/521883
-4060B/521784 (bucket PWT only) R. Sherry 4065 /521786@uu!?WTonly) R. Sherry
-4085A/ 521791(bucket PWT only) R. Sherry
-4085B/ 52-1793(bucket PWT only) R. Sherry R. Sherry
-4127 / 52-1051
- LLRT Containment cooling ESD P. Mandarino CONDENSER
' Tubesheet coating (1 1)
ECD 7/25 D. Mills
-pu!! old plugs ECD 7/26 D. Mills
-blow clean tubes ECD 7/27 D. Mills
-install blast plugs ECD 7/28 D. Mills
-profile tubesheets .
-blowdown and remove plugs ECD 7/29 D. Mills ECD 7/30 D. Mills set form plugs ECD 7/30 D. Mills
-apply prime coat and cure ECD 7/31 D. Mills
-apply build coat and cure ECD 8/1 D. Mills
-grind build coat
- Install sleeves (11 only) ECD 7/23 D. Mills
- Install sleeves (13 only) ECD 7/24 D. Mills ECD 7/25 R. Sherry
* 'A' Condensate pump after backfeed of unit main 3
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; n PLAN OF THE DAY i RESIDUAL HEAT R7MOVAL Spray head replacement
-spray header repairs ECD 8/20 D. Mills Repairs to 28A AB ECD 8/4 R. Sherry 29 B replacement -
ECD 7/30 D. Mil's 36A&B replacement ECD 8/18 D. Mi!!s MO-100150 ECD 'R. Sherry , Hydro test (intersystem leakage )
-8.5.7.2 procedure change to ORC ECD J. Sabina ?-
-1001-688 ECD 7/30 J. Sabina .-
-100168A ESD 8/4 J. Sabina q Bypass leakage testing ESD M. Williams Complete MOV & MCB EDC 8/14 R. Sherry
-100123A / 521756 R. Sherry
-100126A / 501761 R. Sherry ,
-100126B / 521861 R. Sherry Rework Har.gers :
- Field Complete
-NCR 87 342, NCR 87 068, NCR 87 069,
-NCR 87 073, NCR 87-089, NCR 87109,
-NCR 87-110, NCR 87-111, NCR 87-113,
-NCR 87123, NCR 87132, NCR 87-144,
-NCR 87-206, NCR 87 207, NCR 87 2' R.
NCR 87 221, NCR 87 262, NCR 87 270,
-NCR 87 278, NCR 87 279. NCR 87 281,
-NCR 87 292, NCR 87 309.
- Remaining to work
-NCR 87-070, NCR 87 075, NCR 87 078, l NCR 87 083, NCR 87-131, NCR 87135,
-NCR 87-138, NCR 87139, NCR 87140
-NCR 87-154, NCR 87182, NCR 87188,
-NCR 87190, NCR 87 201, NCR 87 202,
-NCR B7 212, NCR 87 213, NCR 87 222.
NCR 87 223, NCR 87 244, NCR 87 272,
-NCR 87-297, NCR 87 298, NCR 87 306, NCR 87 307, NCR 87-308, NCR 87 318,
-NCR 87 328, NCR 87-349, NCR 87 350,
-NCR 87 374, NCR 87 375, NCR 87 381, NCR 87-280.
- Parts Hold NCR 87124, NCR 87-125, NCR 87128
-NCR 87-136, NCR 87 203, NCR 87 259, HPCI 4
m_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ , _ _ _ _ , _ _ _ _ _ _ _
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t . a . PLAN OF THE DAY HPCI l
- Alignraent ECD 7/30 R. Sherry
-Evaluate steam intet pipe test results ECD 7/21 J. Roberts /D. Heard 1 .
- Check valve 230145 repair ESD R. Sherry STANDBY LIQUID CONTROL
- Rework Hangers
- NCR 87-097(visualinspection) ECD R. Sherry l
l
- PDC 86 75 ECD D. Mills
- Paperwork Closeout
-Panel C905 wires reversed (F&M 87 380)
Need ESR for print change Recal PT 1150
-NCR 87-097 hanger nuts
-F&MR 86-042 OC F&MR 87 298 OC Technical spec change (PDC 86 75)
REACTOR RECIRCULATION
- Complete MOV & MCB EDC 8/14 R. Sherry
-202-4A /52-2081 R. Sherry
-202 4B /52 2094 R. Sherry 202-5B /52 2096 R. Sherry
- Recire MG sets
-generator repairs ECD 7/25 R. Sherry
-erect wall (secondary containment) ECD 7/25 R. Sherry APPENDIX R
- Fire barrier upgrades (PDC 87 32) _ _ _ FQD 8/18 D. Mills Sec. Cont. fire barrier repairs / upgrades /', D. Mills
- Fire barrier repair ECD 9/15 ' D. Mills
/
DIESEL GENERATORS
- Doble test ESD R. Sherry i
- Paint B diesel ECD 8/7 E. Menslage 5
. anx x..c.. . . -:2 - l :::..~:v:a : 2. ::c :.%. a.y: w. . r,:!cxn,w a y w . r i PLAN OF THE: DAY ' SECURITY MODIFICATIONS ,
- CCTV (PDC 86-77) ECD 1 6 D. Mills
- PIDS (PDC 86 78) ECD 12/26 O. Mills *
- Security fence (PDC 86 74) ECD 12/26 D. Mills
- Security Lighting ( PDC 83-09 ) ECD 12/26 R. Sherry JSSUES AND ACTION ITEMS OPERATIONS
- Switchyard Coating insulators
- ACB 103 - Power factor / timing ECD
' Rx Water conductivity is (US/CM) 0.69
- EPA breakers 384 out of service ADMINISTRATIVE LCO'S
' Security Compensatory Measures
-zone 146, 87 63 296/87 63-213 (unassigned) zone 147, MR not submitted (unassigned)
-zone 148, MR not submitted (unassigned)
- Fire Protection Compensatory Measures
-Fire door # 58, 85 33 225/85-33 098 D. Mills
-Fire door # 69, 86 33-119 R. Sherry Radwaste trucklock, A Priority (working) R. Sherry H2 seat oil sprinkler, 87 33 846/87 33 815 (unassigned) 6
-__ ___ ____.____.__._..__m _ _ _ _ _ _ _ _
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I PLAN OF THE DAY i ENGINEERING ACTION PLANS . Bob Anderson , OER (onsite engineering representative) *
~
359-4707' "
-extension 8489 .
-beeper 2138
- PDC 86-68 HPC1/ RCIC sux. boiler DUE 7/28 W. Riggs
- PDC 87 39 Torus Safety holst DUE 7/28 M. Selling /T.Tracy
- PDC 86 52A FRN for cont. spray rust ECD 7/31 G. Miteris/T. Hauske ESR 87410
- Predisposition NCR 87-78 ECD 7/27 T. Burns /D. Heard
-HL-10-7 2C Arc Strikes
- ESR 87 022 ' 120178 Valve (Jog) ECD 7/24 D. Heard OUTAGE MEETINGS
- System turnover meeting ( P&R conference room @ 10 am )
- CRD, Sea Water, Diesel Generator, Diesel Lube Oil, Core. Spray, Reactor Water Cleanup
- Turned over to operations:
- Service Alf, Demineralized Water, Condensate Transfer, Fuel Pool Cooling
- Fuel handling, Instrument air, Reactor vessel 7
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HARDWARE NNEDS ' SMA/PO DESCRIPTION NEED DATE DUE D TE RESP, ,, Procure Q vent vahre (A SSW vent) REO. 7/25 EDD J. Vender 4252 O Screenhouse SSW Hanger material .EDD 8/1 Bechtel System 10 ' ' 000367 Bolt Hex HD SA307 GRB EDD Nut Hex SA307 GRB Nut Hex SA307 GRB 3/4" PH HVY 17256 Pressure Seal Ring for 100128A&B EDD W. McCann 21048 Valve Disc for 100128A&B (VB-2) EDD 7/30 W. McCann 22398 Relay Cover GE 7216118588G1 EDD Panel Meter GE 90310A A1B EDD Card Logic GE 14708652G002 EDD (Obtaining from River Bend) System 11 Bolt Stop Valve 2' 20860 EDD Disc. Stop Valve Main Washer Lock 1/2" GE M10113 Washer Flat 1/2" GE M10113 Seal Stub Crosshead GE 632 Gasket GE A Cover To Channel 23731 P-207 A. LKS Possible Stutnng Box EDD 21269 Ring O GE 40654 FDWTR CNTRL EDD Disc Control Vafve GE 752E753 Gasket Head Cylinder GE 619 Segment Ring GE 0652L280G0011 System 30 22461 Plug Pipe 31 A7C3 EDD Plug Pipe SE 31 A7C7 Key 23A9C606 Cover Bearing and Collar Lockwasher and Screw Socket System 48 22196 Sensor Humidity Relative EDD 7/26 8 i l
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HQ Management Briefing by BEco 9/24 at 1:00 PM Core reload target - late September Ready for restart - November? Critical Path Includes: Fire Protection Modifications System Testing HFA Relay Work II. MAJOR LICENSEE ACTIVITIES
- 1. Restart Plan - Vol. 2 expected week of 9/14
- Staff has provided verbal comments on Vol. I to BEco
- 2. Safety Enhancement Program
- BWR Owners Group Met with Staff 9/10/87
- BECo response to our 8/21/87 letter expected in a few weeks
- Torus Vent Pipe Installed with blank flanges on SBGT Piping
- 3. Emergency Preparedness
- Interim response to our letter of 8/18/87 expected by 9/1B
- Limited exercise scheduled for 12/10/87
- BECo will request exemption from requirement for full scale exercise 4 Personnel Changes
- Bernard Resznicek (Omaha Public Power Dist.) to become new president October 1, 1987
- Ron Varley (from Davis Bessel new Emergency Preparedness Coordinator III. MAJOR STAFF ACTIVITIES
- 1. Restart Panel
- Last met 9/3/87 at site
- Discussed BECo Power Ascension Program
- Maintaining RI - NRR Coordination
- 2. Amendments
- Issued Core Reload & ADS Amendments
- 3 more " Restart Licensing Actions" by end of September
- Remaining licensing actions (inc12 for restart) on schedule l
- 3. SIMS
- NRR Project Engineer met with BECo and Region I
- No new safety issues identified
- Will obtain BEco " concurrence" by mid-October
- 4. Inspections and Enforcement I - Enforcement Conference on Safeguards Issues held 9/10/87
- Recent inspections of modifications progress, fire protection progress, ano close out of open items.
- Radiological controls inspection the week of 9/14/87.
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I i l Cite as 20 NRC 157 (1984) DD 8415 1 UNITED STATES OF AMERICA l NUCLEAR REGULATORY COMMISSION l l OFFICE OFINSPECTION AND ENFORCEMENT Richard C. DeYoung, Director in the Matter of Docket No. 50 293 (10 C.F.R. I 2.205) BOSTON EDISON COMPANY (Pilgrim Nuclear Power Station) July 3,1984 The Director of the Omce of Inspection and Enforcement denies the remaining portion o ra petition under 10 C.F.R, { 2.206 which requested that the Nuclear Regulatory Commission take action to remed) alleged serious deficiencies in the offsite emergency response plans for the Pil. grim Nuclear Power Station. On February 27,1984, the Director issued an interim Decision, DD 84 5,19 NRC 542. which denied relief on all issues eucpt potential trame bottlenecks to evacuation of the area sur-rounding the Pilgrim facility. The remaining issue was referred to the Federal Emergency Management Agency (FEM A) for evaluation. Based on FEMA's evaluation that trame management issues have been ade-quately addressed by the Commonwealth of Massachusetts. the Director denies the remainder of the petition. LOW POPULATION ZONE: EVACUATION Trame management issues related to potential bottlenecks to evacua. tion have been adequately addressed by the Commonwealth of Massachusetts. i
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KKKW /.;GiM: : Zu .WSam.M.? =, a1.a. ' , & Tw;; u . ~ : ~- TL ut: 'a . . v ' ~~ . FINAL DIRECTOR'S DECISION UNDER 10 C.F.R. 5 2.206 i INTRODUCTION in its " Petition of the Massachusetts Public Interest Research Group for Emergency and Remedial Action" (Petition) dated July 20, 1983, the Massachusetts Public Interest Research Group (hereinafter referred to as Petitioner) requested that the Nuclear Regulatory Commission (NRC) take action to remedy alleged serious denciencies in the offsite emergency response plans for the Pilgrim Nuclear Power Station in Plymouth, Massachusetts. On February 27,1984, I issued an " Interim Director's Decision Under 10 C.F.R. } 2.206" examining a number of issues raised by the Petition and denying the relief requested with re. spect to those issues.8 However, the Petitioner's concern regardmg potential bottlenecks to evacuation of the area surrounding the Pilgrim facility was noted to be still under consideration. The Petitioner was in-formed that the NRC had formally requested the Federal Emergency , Management Agency (FEM A) to evaluate the potential bottlenecks in the area near the Pilgrim site which may impede effectise evacuation of the plume exposure pathway Emergency Planning Zone (EPZ). FEM A has now responded to the NRC's request and a Onal decision in this matter is now possible. DISCUSSION The Interim Decision noted that, in its review of the Petition, the NRC staff considered information available to it concerning evacuation 'd planning and determined that, as the Petitioner had suggested, potential bottlenecks to effective evacuation of the EPZ may exist on the periph. l cry of the EPZ3 The Interim Decision noted that it would be important to control traffic beyond the EPZ so that such trafSc, e g., on Route 3, did not lead to evacuation traffic congestien. Two notable points beyond , the plume EPZ which could cause congestion are Route 3 at Route 128 l and Route 3 at the Sagamore Bridge. Consequently, the NRC staff for. l mally requested that FEM A review these trafDc issues for the Pilgrim , l 8 # wan h on fu IPilgrim Aucicer Po.et sunons. DD.84.4.19 NRc $42 #1984s. heremarier reierred so siihe emerim Dcowon 2 Imerim Deuuun. were.19 SRc ai .442 158 l m
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t facility and I deferred resolution of that portion of the Petition until after the staff received FEM A's response. On May 13,1984, FEM A responded to the NRC request. Its "Re-sponse to January 20,1984, Request for Assistance on Evacuation Time Estimates ror Pilgrim Nuclear Power Station" and the attached
" Analysis Report on Issues Related to the Pilgrim Evacuation Time Estimate, Pilgrim Nuclear Power Station, Plymouth, Massachusetts" dated May 1,1984 (hereinafter referred to as the FEMA Analysis) are attached hereto as Exhibit A (not published).
The FEMA Analysis notes that the bottlenecks at issue had presiously been identified in the NRC's " Safety Evaluation Report related to the construction of Pilgrim Nuclear Generating Station Unit No. 2," NUREG-0022, Supplement No. 5 (heremafter referred to as NUREG-0022). NUREG 0022 indicated that the Evacuation Time Estimates
- (ETEs) did not adequately reDect the two potentialimpediments to evac.
uation located outside the 10 mile EPZ discussed above. These potential impediments were identified by Dr. Thomas Urbanik,11, of the Texas Transportation Institute who, as a consultant to the NRC, conducted the review of the ETEs discussed in NUREG 0022. As is set forth in the FEM A Analysis, FEM A has reviewed this matter by consulting with Dr. Urbanik, reviewing the pertinent plans and documents developed in response to NUREG 0022, and consulting with the State agencies responsible for implementing evacuatic,n plans. The FEM A Analysis revealed that, following the issuance of NUREG. 0022, impediments to evacuation were carefull> studied by the Boston Edison Company, operator of the Pilgrim Nuclear Power Station. and a traf0c management plan was deseloped to climinate the problems identi-fied in NUREG-0022. FEM A concludes that, after extensive analysis, the traffic management issues raised in NUREG 0022 have been ade-quately addressed by the Commonwealth of Massachusetts in accordance with proper emergency management standards and the evacuation time estimation methods now availabic. CONCLUSION In summary, the single issue remaimng after issuance of my Interim Decision in this matter was the existence of potential bottlenecks to ef. fective evacuation of the EPZ for the Pilgrim facility. This matter has been examined by FEM A and it has been found that the traflic manage-ment issues base been adequately addressed by the Commonwealth of Massachusetts. Consequently, 'clude that evacuation planning, 159 1 L_ E_ia a_l_1_:__ * * ' _ e
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including the associated traffic management, is adequate for the Pilgrim facility. e-
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Accordingly, the remaining portion of Petitioner's request for action pursuant to 10 C.F.R. s 2.206 is hereby denied. As provided b.10 s l C.F.R. t 2.206(c) a copy of this decision will be filed with the Secretar) for the Commission's review.
' Richard C. DeYoung, Director Office ofInspection and g' Enforcement Dated at Bethesda, Maryland, this 3rd day of June 1984.
IThe attachments hase been omitted from this publication but may be found in the NRC Public Document Room,1717 H Street, NW. Washington, DC 20555.1
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NUCLEAR REGULATORY COMMISSION g ,h' 1 j OFFICE OFINSPECTION AND ENFORCEMENT
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Richard C. DeYoeg, O'rt ntor Y..] }l1 In the Matter of Docket No. 50 293 ! (10 C.F.R. I 2.206) 80STON EDISON COMPANY (Pilgrim Nuclear Power Station) February 27,1984 I The Director of the Office of Inspection and Enforcement grants in part and denies in part a petition submitted by the Massachusetts Public Interest Research Group requesting that the NRC take action with re-spect to the state of emergency planning at Pilgrim facility. Among the 6 specific relief requested was the initiation of the 4-month period speci. fled by the Commission's regulations within which to correct the alleged deficiencies at the Pilgrim facility and consideration by the Commission [ as to whether the state of emergency preparedness in conjunction with the alleged poor safety record at the Pilgrim facility warrants immediate shutdown or operation of the facility at reduced power. TECHNICAL ISSUE DISCUSSED: EMERGENCY PLANNING L The Federal Emergency Management Agency takes the lead in offsite i, emergency planning and reviews and assesses State and local emergency plans for adequacy. The NRC assesses the licensee's site emergency plans for adequacy and makes decisions with regard to the overall state i of emergency preparedness. EMERGENCY PLAN: EMERGENCY PLANNING ZONE The Commission's regulations preclude an Emergency Planning Zone (EPZ) radius significantly in excess of 10 miles. An EPZ of about 10 542 l N_-- == - w 4
MiR ,d.aG%;u uCCd.MM:;r ::h, k a f..W:i Vn h WHL.% H zi'GM , . . Knb .:%%:. . L d:. >. % -. F-i l miles is considered large enough to provide a response base which would support activity outside the planning zone should this ever be needed. EMERGENCY PLAN: EV ACUATION PLAN The Commission has adopted an approach to emergency planning in which evacuation is only one of several possible responses to an emergency. It is unlikely that evacuation of the entire plume EPZ would be required in the event of an accident. Pending a final determination regarding the adequacy of evacuation time estimates, it is reasonable to conclude that the public health and safety will be reasonably assured in the interim by continued licensee compliance with Commission require-j ments regarding emergency planning and other health and safety re-quirements aimed at keeping the probability of serious accidents very low. INTERIM DIRECTOR'S DECISION UNDER 10 C.F.R. 9 2.206 INTRODUCTION in its " Petition of the Massachusetts Public Interest Research Group for Emergency and Remedial Action (Petition) dated July 20, 1983, the Massachusetts Public Interest Research Group (hereinafter referred to as Petitioner) requested that the Nuclear Regulatory Commission (NRC) take action to remedy alleged serious deficiencies in the offsite emergency response plans for the Pilgrim Nuclear Power Station in Plymouth, Massachusetts. Among the specific relief requested was the initiation of the 4 month period specified by the Comm:ssion's regulations, specifically 10 C.F.R. 6 50.54(s)(2)(ii), within which to cor-rect the alleged deficiencies at the Pilgrim facility and consideration by the Commission as to whether the state of emergency preparedness in conjunction with the alleged poor safety recordi at the Pilgrim facility i The Petstion in the rehef it requested, made reference to the poor safety record al the Pilgrim facihty l as a reason for granting the relief As staied m the september 6,198) letter to the Petitsoner, with regard to Pilgnm's safety record smce 1981,in med 1982 the licensee mmated a Performance Improve-ment Plan pursuant to an NRC order 147 Fed Reg 4171 (1982)) so improve the plant's performance This plan, which was sutemetied to the NRC on July 30,1982, has semor utahly management mvolve-ment m assurms quaht) and has resulted m marked improvement in Pilgnm's operstmg record over the l (Cattmaedi i 543
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The Petitioner's request is based upon a report by the Petitioner en. [ titled " Blueprint for Chaos 11; Pilgrim Disaster Plans Still a Disaster" (hereinafter referred to as the Chaos 11 Report), the " Comments of At. torney General Francis X. Bellotti Relatne to Off Site Emergency Plan. ning for the Pilgrim Nuclear Power Station" (hereinafter referred to as the Comments of the Attorney Generall, and upon two reports by the Federal Emergency Management Agency (FEM A) - " Interim Findings: Joint State and Local Radiological Emergency Response Capabilities for the Pilgrim Nuclear Power Station, Plymouth, Massachusetts " dated September 29.1982, and " Report on the Pilgrim Nuclear Power Station Siren Test, June 19,1982," dated January 1983. In its Chaos 11 Report. the Petitioner has reviewed offsite emergency planning for the Pilgrim facility and claims to have identified certain defi-ciencies with regard to the size of the plume exposure pathway Emergen-cy Planning Zone (EPZ), advance information provided to the public on what actions 'o take in the event of an emergency, required notifications during an accident itself, and evacuation planning and sheltering includ-ing the adequacy of reception and medical facilities. In each of these areas, the Petitioner makes various recommendations as to actions which it believes are required to improve the state of preparedness at the Pilgrim facility. The Petition states that the findings of the Chaos Il
' Report are st+ ported in part by a telerhone survey of 100 residents of the EPZ conducted by the Petitioner. The survey was conducted between February and May of 1983,
^i. In further support of its Petition, Petitioner references the Comments of the Attorney General which also question the adequacy of emergency planning for the Pilgrim facility. Specifically, Petitioner argues that the Comments of the Attorney General support Petitioner's claims that the EPZ has been drawn too small and that evacuation plans are inadequate.3 The Comments of the Attorney General are based in part upon a study prepared for the Attorney General by MHB Technical Associates of San Jose, California.
past 2 years The last systemaur Assessment of Licensee Performance repi for the period July 1. 1932 so June 30, 1933. gave Pilgnm a Category I (*high level performan ') raung in emergency planmng. a Caiegory 2 ("sausfactor) performance") raung m plant operauons. and an overall Caiegory 2 raung en the eighi runctional areas assessed smce late 1931. there has been conunued improvement in Pilgnm's performance with respect to opershonal safet> 4 sausfactory levelof management auennon and mwolvement m plant safety maners now esists a The Comments of the Anorne) General were for uded io FEM A on Auguu 25. 1932 While lhe
& Comments of the Anorney General raise other issues related to the Pilgnm faceht', the Comments are rehed upon tip the Peuhoner only to support sts claims regareng the adeewact of the curreni EPZ aus and evacuauon plannmg See Pennon si 6. Chaos 11 Repon ei 26
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w Jc2;c d:.2b h .. %:D.4 N N N : Winde .' ;h@ 1;;.< _ 9 - l a DISCUSSION Emergency preparedness at the Pilgrim facility has been resiewed by l both the NRC and FEMA. The NRC Final Rule on Emergency Planning (45 Fed. Reg. 55,402) became effective on November 3,1980. FEMA and the NRC have jointly developed criteria for implementing these regulations specifically the agencies have developed a guidance docu-ment entitled, " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear ' Power Plants," NUREG-0654/ FEM A REP-1, Rev.1 (NUREG 0654). The cooperative relationship between NRC and FEMA is described in a
" Memorandum of Understanding Between NRC and FEMA Relating to Radiological Emergency Planning and Preparedness" of January 1,1980 (45 Fed. Reg. 5847). Under the Memorandum of Understanding, !
FEMA takes the lead in ofTsite ernergency planning and reviews and as-l sesses State and local emergency plans for adequacy. The NRC assesses
, the licensee's site emergency plans for adequacy and makes decisions with regard to the overall state of emergency preparedness. The NRC and FEMA undertook a review of the state of ernergency preparedness at the Pilgrim facility in accordance with the requirements of the final rule in emergency planning.
NRC REVIEW ! The NRC irtitiated the process of reviewing the licensee's emergency plan in 1979 in connection with its review of the construction permit ap-plication for Pilgrim Unit 2. Following the rule change in November 1980, an upgraded site emergency plan was submitted for the Pilgrim facility. The results of the NRC's evaluation of the licensee's upgraded ernergency plan and an examination of the implementation of the plan, conducted during an Emergency Preparedness Implementation Appraisal l (EPIA) on July 13-24, 1981, are summarized in Inspection Report 50-293/81 15 dated June 22, 1982. The findings of the EPIA indicated l that certain corrective actions were required by the licensee in the emergency plan and in the implementation of its ernergency plan in order to achieve an effective emergency preparedness program. The EPIA also identified areas oflesser significance where the licensee could irnprove its emergency preparedness. The licensee responded to the con-cerns identified by the NRC in a letter dated July 28,1982, wherein the licensee concluded that the significant findings which had been identified in the EPIA report had been adequately addressed. Following the receipt of the licensee's response to the EPlA report, on August 5,1982, the 545 M_
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NRC met with the licensee to discuss the status of EPIA findings. The NRC agreed with the licensee's actions on sixteen of the twenty signifi-cant findings, and only four of the twenty significant findings required further discussion. These four areas were dose assessment, recommend-ed protective actions, in plant surveys, and procedures related to emergency repair and corrective actions. After discussion of these four
, items, it was resolved that the licensee would take the necessary correc.
g live actions, in its November 1,1982 correspondence, the licensee reported that all planned actions relevant to the sir.nificant findings had been compfeted, informed the NRC of the progress on actions planned pertaining to the improvement items, and transmitted its response to i the emergency plan evaluation findings. The licensee's response ad-t=>f : dressed each item identified in the EPIA. On December 29,1982, the NRC Region 1 Ofnce acknowledged the corrective actions that had al. ready been taken and those planned by the licensee and informed the licensee it.at all corrective actions would be examined during a future inspection. The licensee's action on the significant findings was verified during ) follow up inspections conducted by Region I of the NRC on March 1-4, 1983, and June 21-August 15, 1983, and summarized in Inspection Reports 50 293/83 05 dated April 20.1983 and 50 293/83-17 dated September 8,1983. Within the scope of the follow up inspections, no , violations were observed and only one inspector follow up item was l identified. In addition, on March 3,1982 and June 29, 1983, the licensee con. ducted full-scale emergency exercises which were observed by both the ! NRC and FEMA. The NRC's findings are presented in Inspection ( Reports 50 293/82-09 dated March 24,1982 and 50-293/8316 dated Y ! July 29,1983, in which it was determined that the emergency response { actions taken by licensee personnel were adequate to provide protective measures for public health and safety. As a result of these review ] activities, there continues to be reasonable assurance that onsite emergency preparedness is adequate to protect the public health and safety.
; FEMA REVIEW g FEMA, in accordance with the Memorandum of Understanding, has
} reviewed the adequacy of offsite emergency preparedness at the Pilgrim N facility. A preliminary review of the Massachusetts State Radiological
[ Plan was conducted in October 1981 by the Regional Assistance Com-i 546
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4 j l mittee (RAC).3 Based on the preliminary review, the RAC concluded that the plan was in an advanced but incomplete stage and that further revision to the plan was required in order to conform to the guidance criteria of NUREG 0654. The NRC requested that FEMA review the process for prompt protective action decisionmaking in Massachusetts 1 based on draft State plans and information submitted to the RAC in early 1982. On June 11,1982, FEMA issued an interim finding that the I current protective action decisionmaking process in Massachusetts was adequate to provide for public protection. Formal submission of f I emergency plans to the RAC by State and relevant local jurisdictions was followed by the first joint radiological emergency response exercise on March 3,1982. The exercise involved emergency preparedness or-ganizations at both the State and local levels. The performance of these organizations in implementing their radiological emergency response plans was observed. Deficiencies were identified as a result of this exer-cise and corrective actions initiated by the parties involved. On Septem-ber 10,1982, FEMA Region I issued its " Exercise Report - Joint State and Local Radiological Emergency Response Exercise for the Pilgrim Nuclear Power Station, Plymouth, Massachusetts, March 3,1982." By memorandum dated November 2,1983. FEM A provided to the NRC its
" Interim Findings - Joint State and Local Radiological Em;rgency Re-sponse Capabilities for the Pilgrim Nuclear Power Station, Plymouth, Massachusetts" dated September 29, 1982. The interim findings were based on a summary evaluation of the Massachusetts Radiological Emergency Response Plan and the exercise of t.ie State and local emergency response plans held on March 3,1982. Although deficiencies were identified which required corrective action, FEMA found that the Massachusetts State and local emergency plans and preparedness for coping with the offsite efTects of radiological emergencies that may occur at the Pilgrim Nuclear Power Station were adequate to protect the public.
The second joint radiological emergency response exercise at Pilgrim was held on June 29,1983. A seventeen-member Federal team was as-signed to evaluate State, local and field activities. By memorandum dated November 29,1983, FEMA transmitted to NRC its " Final Report of the Joint State and Local Radiological Emergency Response Exercise 3 There esists m each of the ten standard Federal Regions a Regional Asmstance Commmee (RAC) (formerly the Regional Advisory Commmee) chaired by a FEM A Regional omeial and havms members from the Nuclear Regulatory Commission, Department of Health and Human services. Depenment of Energy Department of Transportauon Environmental Protection Agency, the Unned states Depart. unent of Agnculture and Department of Commerce. The RACs assm state and local government om. cnals in the development of their radiological emergency resportse plans. review plans, and observe ener. eases to evaluate the adequacy of these plans and related preparedness A Oescripimn of the RAC author. ity aM responsibihines is found in 44 C.F.R. Part 350 547
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for the Pilgrim Nuclear Power Station. Ph mouth. Massachusetts," dated September 26. 1983 (1983 Exercise Report). The 1983 Exercise l Report identifies no denciencies that would lead to a negative finding
- Deficiencies requiring corrective action were identiGed by FEM A in two areas - the State police radio notification system and the transmission of meteoroingical information. FEM A also identified other deficiencies and additional areas ofimprovement for consideration by the State and local authorities regarding their offsite emergency preparedness progrr- rE"A will furnish a copy of the 1983 Exercise Report to the Commonwealth of Massachusetts and will request a schedule of actions for the correction of deficiencies. A copy of the 1983 Exercise Report was sent to NRC Region I on January 12,1984 for its use in coordinating with FEMA Region I in ensuring that the identified deficiencies are ad-dressed in a timely manner.
Following receipt of the Petition, the Petition and the supporting Chaos 11 Report were forwarded to FEM A for its evaluation and revi w since the Petition questioned the adequacy of offsite emergency pre-paredness at the Pilgrim facility. By memorandum dated November 9, I 1983. FEMA provided to the NRC its Gnal report entitled " Analysis of Emergency Preparedness issues at Pilgrim Nuclear Power Station Raised by the Massachusetts Public Interest Research Group (MASSPIRG)," dated November 3,1983, attached hereto as Appendix A. The Novem-ber 3,1983 report indicates that FEMA has reviewed the Petition and has also consulted with members of the RAC and ofDeials of the Com-monwealth of Massachusetts. This review resulted in FEM A confirming its interim finding referred to above that the Commonwealth of Massa-chusetts has demonstrated that there is reasonable assurance that the public would be adequately protected if there were an accident at the Pil-grim Nuclear Power Station. In addition, in its November 3,1983 report, FEMA indicated that the results of the 1982 Exercise Report l have been superceded by the results of the 1983 Exercise Report. In effect, the numerous deficiencies identified by FEMA in its 1982 Exer-cise Report have been corrected or otherwise resolved Thus only two deficiencies requiring corrective action, as described above, remain -l outstanding.
- On August 5.1983. FEM A Headquaners revised their procedural poiscy on esercise observation and evaluation in order to provide a more untrorm, workable approach for une en the sen FEM A regional or.
nces m their esercise reporting process The guidance provides for reporting dergencies which would Icad 10 e negative rinding. deficiencies ohich require correctne action but otherwise would not lead to a pelative nnding, and other dersciencies where a correctable weakness is nosed ror which correceive action should be considered. oernesencies thai would lead to a negative finding would cause a rinding that offsite emergenc3 preparedness is not adequate to pro *ide reasonable amusance that approptisie proleCisve measures could be taken to proirci the heshh and safen) or the pubir 548 i 4 l { I
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l i l The NRC has reviewed the November 9,1983 FEMA response and concurs with the conclusions reached therein. However, further discus-sion is appropriate regarding the following issues raised by the Petitioner and addressed in the FEMA report. I. Capability of the Licensee to Make Accurate Release Estimates The FEMA report notes at 6 7 that the role of the licensee in prepar-ing release estimates upon which to make protective action determina-tions is more properly an NRC evaluation responsibility than that of FEMA. The NRC agrees that the licensee's capability is a proper area j for NRC evaluation. During the EPIA, dest:ribed previously, NRC ! inspectors conducted walk through inspections with members of the licensee's onsite emergency organization. These inspections were con- ; ducted in the areas of control room dose projections, dose assessment, )
- event classification, offsite notification, offsite monitoring and environ-mental assessment. The inspections identified deficiencies in the areas of the dose assessment scheme, basis for recommended protective ac-tions and related procedures and training. The licensee took corrective actions on these deficiencies and, as mentioned above, follow-up inspec-tion on the EPIA findings conducted by NRC Region I verified that cor-rective action had been taken by the licensee on all signifn: ant findings identified during the EPIA. Additionally, on March 3,1982, a team of j NRC observers was on hand to witness the full-scale exercise held at Pilgrim. During the conduct of the exercise, eleven NRC team members made detailed observations in various areas including: detection, classification and assessment; direction and coor,dination of the emergen-cy response; notification; and dose projection and consideration of pro-tective actions. The NRC team concluded that, while there was some room for improvement, there were no items which exhibited a potential for significant degradation of emergency response. Similar observations were made at the second full scale exercise at Pilgrim on June 29,1983.
In this instance, the NRC team concluded that the licensee demon-strated the capability to implement its emergency plan and emergency plan implementing procedures in a manner which would adequately pro-v' --Gm im;%d safety of the public. II. Size of the EP The Petitioner suggests that the EPZ size may require considerable expansion. However, this is in effect an attack on the Commission's regulations, specifically 10 C.F.R. 6 50.47(c)(2). The Commission's 549 e sen __-_ ____-_,__$ -___.2_ A__5___-___.h___2______.____.____a, . _ _ _,._ . . . . _ _.
a . c.m. ..an x w.u , nm. n i;w. ~ w.w. m- :w. m. .mme. war =: n - - c - 5 B regulation sets EPZ size at "about 10 miles." While the regulation would allow leeway for a mile or two in either direction based upon local factors, it clearly precludes an EPZ radius significantly in excess of 10
. miles as suggested by the Petitioner. See Southern Ca!{ornia Edison Co.
(San Onofre Nuclear Generating Station Units 2 and 3) LBP-82-39,15 NRC 1163,1177 84 (1982), aff'd. ALAB-717,17 NRC 346 (1983). However, even considering the Petitioner's assertion on its merits, the information provided by the Petitioner does not support enlargement of the EPZ. The FEMA report of November 3,1983 makes reference to the MHB Technical Associates Study used by Petitioner to support its request that ' the EPZ size for the Pilgrim facility should be enlarged. Petitioner's re-quest is based in part on a review of preliminary Calculation of Reactor Accident Consequences (CRAC) results conducted by MHB Technical - Associates for the Attorney General. The MHB Study is entitled-
" Review of Calculation of Reactor Accident Consequences (CRAC 2)
Results and Liquid Pathways (NUREG 1596) Study: Implications for Emergency Planning in the Vicinity of the Pilgrim Nuclear Power - Station." Under contract to the Department of the Attorney General for the Commonwealth of Massachusetts, MHB Technical Associates reviewed the CR AC computer code and its results for the Pilgrim Station and NUREG/CR 1596 " Consequences from Liquid Pathways After a
. Reactor Meltdown Accident," August 1981. The Petitioner argues that the MHB conclusions regarding the CRAC code require enlargement of
, the Pilgrim EPZ. The MHB study attempts to apply a generic study to a site specific case. The CRAC calculations were carried out for a report i which was written to support the formulation and comparison of possible
! siting criteria for nu: lear power plants, and generic rather than site-specific parameters were used.5 A realistic estimate of the risk from
, severe accidents at each plant was not attempted for that report, j' The plume EPZ6 for the Pilgrim facility is based upon NUREG-0654 guidance criteria.' The joint NRC/ EPA Task Force that developed i NUREG 0396 considered several possible rationales for establishing the !
3 Technical Guidance for sitnia Creieria Developmem. NUREG/CR.2239. December 1982 in NUREG/CR.2239. a generic rathei' than plant-speceric power levet oss used, regional ralher than ste. specific assumptions regarding erscusison and relocation were used. and generic releases were assumed.
, as opposed to the design-speciGc release categories used for heensing
') 6 The plume esposure pathway Emergency P4nning Zone (EPZ) estabhthed for the site is located en.
brely within the state of Massachusetts lis boundary estends 9 s to !? miles from the sue and includes porhons of Ove townships
'The guidance criteria of NUREG 0654 are derived from NUREG.0396. EP A 520/178 016
" Planning Basis for the Development of staie and Local Gesernment Radiological Emersefic) Response Plans in support or Light Water Reactors." December 1978. which provides the concept of generic Emergency Planning Zones 550 e
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i size of the EPZs. These included risk, probability, cost effectiveness and an accident consequence spectrum. The Task Force chose to base EPZ size on a full spectrum of accidents and corresponding consequences ) , f f n ep', l tempered by probability considerations. It was the consensus of the Task Force that a plume EPZ of about 10 miles would provide an adequate $- j planning base beyond which actions could be taken on an ad hoc basis using the same considerations that went into the initial action [J [e},.h i determinations. In its statement on " Planning Basis for Emergency Re-sponse to Nuclear Power Accidents," 44 Fed. Rep. 61,123 (1979), the ' j* Commission noted that an EPZ of about 10 miles is considered large .. . 4 enough to provide a response base which would support activity outside 5 ,; - ,., the planning zone should this ever be needed. i The Petitioner contends that, based upon the referenced CRAC code / results, an enlargement of the current Pilgrim plume EPZ is warranted because the projected doses exceed the EPA Protective Action Guides (PAGs)8 outside the 10 mile EPZ. Both NUREG-0654 and NUREG-0396 recognite, based upon CR AC code results, that the PAGs might be exceeded beyond the 10. mile plume exposure EPZ in the event of the worst possible accident and meteorological conditions. However, a 10-mile plume exposure EPZ was still chosen as a planning basis in NUREG-0654 because:
- a. projected doses from the traditional design basis accidents would not exceed Protective Action Guide levels outside the zone;
- b. projected doses from most severe fuel degradation sequences would not exceed Protective Action Guide levels outside the zone;
- c. for the worst fuel degradation sequences, immediate life-threatening doses would generally not occur outside the zone; and
- d. detailed planning within 10 miles would provide a substantial base for expansion of response efforts in the event that Ahis proved necessary.
On balance, the MHB Study referred to in the Comments of the Attor-ney General and used by Petitioner in support of its Petition does not 8 The EP A has developed and the NRC has adopted a Manual or Proiectwe Act'en Guaden and Pro-tecine Actions for Nuclear incidents.* EPA.520/175 001.remed February 1980, ohich proudes guid ance criteria for public health ofTicials m determmmg the need for and in choosing the appropriate prt& tecuve actions The Protectwe Action Guide (P AG) e the proscled dose to mdmtluals in the popula-tion which marrants taking protecine action. e g., shelterms or etscuauon 551 YW$h; ? & k& _ =_ : _
w.x. . : u ;w unacuw a ,, , ' ' ; . :. x L .s . :.c.. . - w , :n O , m:...m m "Mi: TY- ' ., ,u 3, provide an adequate basis fo- reconsideration of the specific size of the Pilgrim plume EPZ.' 111. Evacuation Time Estimates in reviewing the Petition, the NRC staff considered inform 2 tion availaNe to it concerning Evacuation Time Estimates (ETEs) and deter-mined that, as Petitioner suggested, potential bottlenecks to effective evacuation of the EPZ may exist on the periphery of the EPZ. It would be important to control traffic beyond the EPZ so that such traffic, e.g., on Route 3 did not lead to evacuation traffic congestion. Two notable points beyond the plume EPZ which could cause congestion are Route 3 at Route 128 and Route 3 at the Sagamore Bridge. These points could lead to larger ETEs than those now used. The NRC staff reviewed the ETEs now used while reviewing the construction permit application for Pilgrim, Unit 2, and has now determined that this matter should be spe-cifically brought to the attention of FEMA for its consideration in the review of ETEs for the Pilgrim facility. Consequently, this matter was referred to FEMA on January 20, 1984 for consideration and my staff has requested a response from FEMA by March 30,1984. Therefore I am deferring resolution of this part of the Petition until after I receive FEM A's response. I see no adequate reason to suspend operation of the Pilgrim facility pending this response. The overall state of emergency preparedness is adequate. No deficiencies *hich would lead to a negative finding on pre-paredness have been identified by FEMA. The sole remaining issue is the adequacy of ETEs for planning an emergency evacuation. The Com-mission has adopted an approach to emergency planning in which evacu-ation is only one of several possible responses to an emergency. See NUREG 0654, NUREG 0396 and 10 C.F.R. f 50.47(b)(10). It is unlike-ly that evacuation of the entire plume EPZ would be required in the event of an accident. Pending a FEMA determination on the adequacy of the ETEs, it is reasonable to conclude that the public health and safety will be reasonably assured in the interim by continued licensee compliance with Commission requirements regarding emergency plan-1 ning and other health and safety requirements aimed at keeping the 9 ja ets hovember 3,1983 report. FE 4 A notes that current hRC studies related to accident source terms, probabilstics and consequences are expected to resalt an a revision to NUREG 0t64 , which
< eculd lead to reconsideration or eassus EPZ requirements Current NRC proposals mclude a graduated
(* response capability wethan the present EP2, involveris additional recuiremenis for predetermined prompi actions elPhan the rirst ret mdes or the reactor The SRC is not cons dering si this time shering the overall sue of the EPZ 552 __M___--- ._---.$ _..___a __ _ .,
m ::s:wa:5 tis::-?;a ;, u. .u.b.sze a mu .r.La &.: .w h c O m .: w w :e n N": n L.e u.m ...;p .a.. r. i i probability of serious accidents ser) low.'a Cf. Consolidated Eduon Co. of Neis Fork (Indian Point. L' nit No. 2). CLI 8316.17 NRC 1006 (1983). In view of the overall adequae) of emergency preparedness for Pilgrim and the low likelihood that an evacuation would be required as a re-sponse in the event of a radiological emergency at Pilgrim, Petitioner's requests that the NRC (1) issue a finding that the state of emergency preparedness at Pilgrim does not provide reasonable assurance that pro-tective measures can and will be taken in the esent of a radiological emergency, (2) suspend operation of the plant or order operation at re-duced power, or (3) start the 4 month time period for correction of defi-ciencies are denied at this time. j CONCLL'SION l I in summary, both onsite and offsite emergency preparedness at the
- Pilgrim facility have been gisen conimued resiew by both the NRC and FEMA. Onsite preparedness has been determined to be adequate based upon direct NRC evaluation of the licensee's emergency planning capa-bilities and based on the results of the continuing inspection program in this area conducted by Region i of the NRC. Offsite emergency prepa-redness has been reviewed by FEM A and it has been found that offsite plans are adequate and capable of being implemented. The most recent examination of offsite emergenc) preparedness by FEM A speciGcally considered the allegations raised by Petitioner and specifically found con-tinued assurance of the adequacy of cffsite emergency preparedness to protect the public health and safet). Consequently. I conclude that the overall state of emergency preparedness at thd Pilgrim facility is suffi-cient to assure the public health and safety while the remaining issue of Evacuation Time Estimates is considered by FEM A.
Accor'd ingly, the Petition's request for action pursuant to 10 C.F.R. { 2.206 has been denied in part and deferred in part as described in this decision. Once FEMA provides the Commission with its findings regard-ins Evacuation Time Estimates. the staff will provide the Petitioner with l a copy of FEM A's evaluation and willinferm the Petitioner of the staffs ! decision as to whether further action should be taken. h I i f 60 0n December 10. 1983. ihs Pilgrim lauhi> me shiis dr** n het ensperhnn nr pipe (tedeny an the . socorruistoon system sa d for replacement of delessisc pipes 4 as antuipated th41 the reality mill bc shut l down for approiiarnatel) 6 monins This should en4 hic the stoft in rewihe the issue or the adeuuao of the ETEs prior to piam stari-up 553 l I
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As provided by 10 C.F.R. l 2.206'c). a copy of this decision will be Sled with the Secretary for the Commission's review. Richard C. DeYoung, Director l OfDee ofInspection and Enforcement Dated at Bethesda, Maryland, { this 27th day of February 1984. l { l 1 i l t
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- PILGRIM SALP HISTORY Assessment Period OPS RADCON MAINT SURV EP FP SEC REFL '{@. LIC 01/01/80 - 12/31/80 2 3 2 2 3 2 2 3 3' N 09/01/80 - 08/31/81 3 2 3 2 1 2 2 2 3 N 09/01/81 - 06/30/82 3 2 2 2 1 3 2 2 N 2 07/01/82 - 06/30/83 2 2 2 1 1 1 2 N N 1 07/01/83 - 09/30/84 2 3 1 1 3 2 2 1 N 1
,10/1/84 - 10/31/85 3 3 2 2 3 N 2 1 N 1 OFFICIAL RECORD COPY 314 STAROSTECKI - 0004.0.0 02/11/86 ,][ ,1hE
'~~'~rEi fn th OO 5b h.m .h .ocuc ;. 1 a a sN.;_.n .. ~. J x. .y - 1 x.~ , 26 E. Emergency Preparedness (310 hours, 8%)
- 1. Analysis During the previous assessment period the licensee was rated as Category 3 in Emergency Preparedness, due principally to observa-tions made during the August 1984 exercise. Weaknesses were iden-tified in the preparation and planning for the exercise and in com-mand and control in the Emergency Operations Facility (EOF). Based -
on the performance during this exercise, a remedial drill was held in October 1984, to reassess the licensee's dose assessment cap-abilities and decision making process. During this assessment interval, the remedial drill was observed, a routine EP follow-up inspection was performed, and the September 1985 exercise'was observed. The remedial drill demonstrated im-provements in the areas of dose assessment and decision making, which had been identified as weaknesses during the August 1984 exercise. During the December routine inspection, two problems were identified concerning implementation of provisions of the Emergency Plan. (Failure to mail information brochures to the general public and failure to perform an annual update to the Emergency Plan and pro-cedures). During the review of the scenario package submitted for the 1985 exercise, it became apparent that the scenario package did not contain sufficient detail. It was recommended the the exercise be postponed in order to take time to clarify and complete the exercise scenario. The licensee agreed to delay the exercise from August I to September 5,1985 to make the necessary improvements to the scenario package. During the exercise, two significant areas of concern were identi-fied by the NRC. The first involved a lack of svaluation or control of radiation exposure for re-entry teams sent into the plant for var;ous tasks. Serious overexposure would very likely have resulted from the actions taken if this had been an actual situation. The second concern involved the fact that there were no procedures in effect for relocation of the EOF to the alternate location, in spite of the fact that the trailers which presently function as the EOF are positioned near the stack with no shielding or ventilation fil-tering. Improvements were evident over the 1984 exercise, however, a remedial drill was required to demonstrate the ability to evaluate and control radiation exposures of re-entry team personnel. The licensee has indicated that plans for construction of an off-site EOF are nearing completion, which will help solve some of the con-cerns relating to the facility. In summary, some improvements in emergency facilities and in the annual emergency exercise were noted during the assessment period. However, performance was only minimally acceptable in this func-L-__----------- -- ----- E -
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1 t.. . .s 27 ^ 1 tional area for the second year in a row. Portions of the annual exercise were unsatisfactory and had to be demonstrated in a sup- -{ plementary drill. The lack of thorough exercise critique was a recurring problem. Personnel errors were evident during the exer-cise and may reflect weaknesses in program staffing and training.
- 2. Conclusion Rating: Category 3.
Trend: Consistent. ..
- 3. Board Recorr.mendation -
Licensee: Promptly implement plans for construction of off-site EOF. Assess staff resource commitments for this area to assure that it receives adequate attention between exercises and drills. 1
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