ML20245C279
| ML20245C279 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 07/31/1987 |
| From: | MASSACHUSETTS, COMMONWEALTH OF |
| To: | |
| Shared Package | |
| ML20244D847 | List:
|
| References | |
| FOIA-88-198 NUDOCS 8904270089 | |
| Download: ML20245C279 (262) | |
Text
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THE COMMONWEALTH OF MASSACHUSETTS REPORT OF THE SPECIAL COMMITTEE ESTABLISHED FOR THE PURPOSE OF MAKING AN INVESTIGATION AND STUDY RELATIVE TO THE PILGRIM NUCLEAR GENERATING FACILITY AT PLYMOUTH UNDER THE PROVISIONS
'OF SENATE ORDER 2044 ADOPTED IN THE YEAR 1986 i
JULY 1987 i
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l' , 1 1 1 l This report has been prepared by Brian J. Prenda, M.P.A., Lisa Kaminski, Kevin Considine, Linda Marley and. Lucy DeLaney for the Special Committee to investigate and study.the Pilgrim Station Nuclear facility at Flymouth. The staff of the Special Committee extends its sincere thanks
-to those who so geneously contributed their time and expertise to the preparation of this report.
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y m .v.v - - - ,e - u. _ , , r.~. - , - .- - -, - - -. .. - -- - TABLE OF CONTENTS Letter of Transmittal----------------------l Membership of Special Committee------------2 Purpose of the Committee-------------------3 Agenda-------------------------------------4 L TOPICS 5 Topic l-----------------------------------14 Topic 2---------------------------------- Topic 3---------------------------------- 32 Topic 4---------------------------------- 33 Topic 54-r.-------------------------------37 Topic 6-----------------------------------38 Topic 7-----------------------------------47 Topic 8-----------------------------------52 Topic 9-----------------------------------67 Topic 10----------------------------------82 RECOMMENDATIONS i Recommendation I--------------------------88 Recommendation II-------------------------92 Recommendation III------------------------94 Recommendation IV-------------------------95 Recommendation V--------------------------96 Recommendation VI------------------------103 Appendix---------------------------------109 .
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A- ~' Ehe 6cutntottfntalth of Massachusetts G 3 q SPECIAL JOINT COMMITTEE ON THE J
.' Jy' - INVESTIGATION AND STUDY OF THE PILGRIM STATION
.g - NUCLEAR GENERATING FACILITY AT PLYMOUTH State House, Boston, MA 02133
' sENATOM THOM As C. NORTON REPRESENTATIVE PETER FORMAN
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( To the Honorable Senate and House of Representatives: We, the undersigned, having voted in the affirmative, - do hereby transmit this report of the results of the investigation-and study authorized.under the provisions of Senate order 2044 adopted December 15, 1986 describing the activities of the committee and its recommendations concerning the Pilgrim Nuclear Power Generating Facility. at Plymouth. Respectfully submitted, THOMAS C. NORTON . PETER FORMAN Senate Chairman House Chairman Senator Anna P. Buckley Rep. Lawrence Alexander [ Senator Paul V. Doane p.JohnC. Bradforg Senator William B. Golden Rep. Thomas S. Cahir
' i Senator Edward P. Kirby Rep. David J. Cohen 1,. , , . . . ..
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LETTER OF TRANSMITTAL Page f 9 Senator William MacLean, Jr. Rep. Robert Durand Rep. William Flynn Rep. Kevin Honan Rep. Frank M. Hynes Rep. Charles W. Mann Rep. Susan C. Tucker Rep. Peter A. Vellucci
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l 1 1 l THE COMMONWEALTH OF MASSACHUSETTS 1
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i l MEMBERS OF THE COMMITTEE ] Appointed by the President of the Senate: Senator Thomas C. Norton, Senate Chairman Senator Anna P. Buckley Senator Paul V. Doane Senator William B. Golden Senator Edward P. Kirby Senator William Q. MacLean, Jr. Appointed by the Speaker of the House: Representative Peter Forman, House Chairman Representative Lawrence R. Alexander Representative John C. Bradford Representative Thomas S. Cahir Representative David B. Cohen Representative Robert A. Durand Representative William J. Flynn Representative Kevin Honan Representative Frank M. Hynes Representative Charles W. Mann j Representative Susan C. Tucker Representative Peter A. Vellucci Committee Staff: Brian J. Prenda, M.P.A. Lisa Kaminski Kevin Considine
, Linda Marley Lucy DeLaney
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I The Special Joint Committee to Investigate and Study the Pilgrim Station Nuclear Generating Facility at Plymouth was established by a Senate Order adopted by the Senate on December 15, 1986 and the House of Representatives on October 15, 1986. The Committee was ordered to investigate and study: (1) the effect on public safety of the operation of j the Pilgrim Nuclear Generating facility at ] Plymouth; (2) the response of the Boston Edison Company and the l Nuclear Regulatory Commission to findings of ) i inadequate or less than excellent performance at the Pilgrim Nuclear Generating Facility at Plymouth; (3) whether there is danger from escape of radiation, and the severity of any past escapes or emanations of radiation from the Pilgrim Nuclear Generating facility, and the effects thereof on public health; (4) the adequacy and practicability of planning to prepare for any emergency which may affect public safety, including the plans of the Massachusetts Civil Defense Agency, and its relations with the Federal Emergency Management Agency (FEMA); (5) present methods by which the Commonwealth finances such planning, acquisition of supplies, equipment, facilities and personnel for such planning, and the execution of such plans, including provisions for evacuation of all segments of populations and provisions for their shelter; (6) ene clarification of jurisdictional questions as between state agencies and between the Commonwealth, its subdivision and the federal government; and (7) the effect of the presence of the Pilgrim Nuclear Generating Facility on the municipal fiscal affairs of the town of Plymouth and surrounding communities. Said committee shall report the results of its investigation and study and shall present any recommendations not later than the first' Wednesday of December, 1987.
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{ I ( l AGENDA The Committee to Investigate and Study the Pilgrim Station Nuclear Generating facility at Plymouth established an agenda that would allow a systematic study of each of the seven specific charges contained in Senate Order 2044. The committee approached tne seven-matters individually enabling it to hold as comprehensive a hearing as possible. The Committee held a total of eight hearings along with an organizational meeting and an on-site tour of the Pilgrim Station. Some of these topics required further investigation due to their complexity, therefore, additional hearings were scheduled. The following is an outline of the schedule that was followed.by the Committee: DATE TIME PLACE TOPIC 1/21/87 10 a.m. Rm. 446 ORGANIZATIONAL MEETING 1/27/87 10 a.m.- Gardner PLANT OPERATIONS 4 p.m. Auditorium 2/2/87 10 a.m.- Gardner JURISDICTIONAL QUESTIONS 4 p.m. Auditorium 2/3/87 11 a.m.- TOUR OF PILGRIM 5 p.m. 3/2/87 10 a.m.- Gardner EMERGENCY PREPAREDNESS 4 p.m. Auditorium 3/9/87 10 a.m.- Rm. 466 PLANT VIOLATIONS 4 p.m. 3/23/87 10 a.m.- Gardner EMISSIONS /PUBLIC SAFETY 4 p.m. Auditorium 3/30/87 10 a.m.- Gardner ENERGY FORECASTING 4 p.m. Auditorium 4/6/87 10 a.m.- Rm. 462 ECONOMICS / FISCAL AFFAIRS 4 p.m. 4/27/87 10 a.m.- Gardner PILGRIM'S STATUS REPORT 4 p.m. Auditorium
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I l l TOPIC 1 THE EFFECTS ON PUBLIC SAFETY OF THE OPERATION OF THE PILGRIM NUCLEAR FACILITY AT PLYMOUTH ) The committee hearing dealing with issues of public safety was held on March 23, 1987 at 10:00 a.m. in Gardner Auditorium, State House, Boston, Massachusetts. The committee sent written requests to testify before it to the following individuals: f
- 1) Dr. Edward V. Cosgrove, Assistant Commissioner, l Department of Public Health, for Commissioner Bailus Walker;
- 2) Bruce Buckbee, Citizens Urging Responsible Energy (CURE);
- 3) Dr. Peter Chapman, Jordan Hospital, Plymouth, Massachusetts;
- 4) Charles Poole, Epidemiologist, Epidemiology Resources, Incorporated; and
- 5) Patricia Circone, Assistant Commissioner, Massachusetts Department of Labor and Industry Officials from the-Department of Public Health (DPH), DR.
EDWARD COSGROVE, Director of Disease Studies, and MR. GERALD PARKER, Assistant Commissioner, reported to the committee on studies that have been conducted on cancer rates for *,he area encompassing the five towns surrounding the Pilgrim nuclear power facility. Dr. Cosgrove acknowledged that the Department of Public Health has not followed up on studies showing high rates of cancer around the Pilgrim nuclear plant due to lack of funding and resources to do more research. Explaining that the DPH did not presently have the resources and staff to concentrate solely on the Pilgrim study, he said it would take S106,000.00 and another year of study to draw any conclusions on a possible link between cancer rates and operation of the Pilgrim plant. l
- Dr. Cosgrove next discussed the release en July 31, 1986 of I the DPH's report entitled, " Health Surveillance of the Plymouth l
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Area." He stated that there was much confusion resulting from the l release of health data contained in this report. This confusion was 1 followed by accusations that information was being withheld by the DPH. In addition, the Massachusetts Cancer Registry, which registers l l
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I f cancer reports received from hospitals, identified a hospital error l in the reporting of the town of residence and sex of a cancer patient. These events led the DPH to re-analyze the cancer data for the five towns, using the corrected data for both males and females. The DPH issued a clarification to convey this new information to the public and to avoid further accusation that they were withholding information. l Dr. Cosgrove explained that an essential component of ) epidemiologic research and sound scientific method is first to l identify the extent and nature of a problem beforo undertaking an l intensive and comprehensive study of it. Doing so permits the second phase of study--that of determining what may have caused the problem--to be properly planned and executed. He stated that the data released last July did not provide a complete and focused view of cancer risks among females, nor did it describe the risks of specific types of cancers, such as various leukemias. This more detailed information is essential to determining what cancers and what cancer patients should be I' studied. It also provides clues as to what causal factors should be studied more closely since different cancers are known to have different causes. A re-analysis of the July 31, 1986 data, completed in January 1987, has provided the DPH with the necessary direction that their efforts should take in assessing the cancer rates in the five towns. Dr. Cosgrove noted that during the final preparation of this report, the DPH also began to develop a detailed study plan to investigate the observed excess risk of leukemia in the five towns. The proposed study would identify approximately 100 male and female leukemia cases diagnosed between 1978 and 1986. Each patient would be interviewed, along with approximately 200 control subjects randomly selected from the area. Through these interviews, the DPH would obtain the information deemed necessary to assess those factors that might have caused the leukemias. This information will include a full characterization of where the patients lived and what jobs they held during their lives. Dr. Cosgrove further clarified that this study would not { prove or disprove the theory raised by Commissioner of Public Health j Bailus Walker, Jr. and others that these cancers might be caused by j radioactive particles emitted from the Pilgrim plant that become trapped by coastal winds, thus posing a danger to people living along the coast. Dr. Cosgrove concluded that the DPH has no plans to test this theory at the present time. l i MR. BRUCE BUCKBEE rep, resenting the Citizens Urging Responsible ( Energy (CURE) testified this day for the purpose of responding to j Boston Edison's claim to regular and careful radiological monitoring i l of the Pilgrim Nuclear Power Station. Mr. Buckbee pointed out that after a review of hundreds of Nuclear Regulatory 1
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l l l Commission (NRC) reports that CURE has found various problems with monitoring, surveillance and detection devices used at the Pilgrim i facility. Mr. Buckbee reviewed four specific cases for the l Committee. They are as follows: ; i
#1. On August 12, 1985 it was discovered that a portion of !
the Maintenance " Hot Shop" ventilation had become contaminated and provided an unmonitored release path to the environment. Immediate corrective action was to tag the associated fan and breaker, seal the ductwork, and secure a downstream damper in the. isolated position. Cause of the event is a design inadequacy. The general area ventilation will remain tagged until final corrective action has been completed. The question that has to be asked is exactly how long did this unmonitored path to the environment exist?
- 02. On July 19, 1985 with the plant at 100% power, a review of plant records revealed that the weekly analysis for gross radioactivity of the reactor building vent particulate filter had not been performed. At shift turnover on July 2, 1985 the technician responsible for performing the analysis presumed that, as part of his daily routine, he had performed it along with other analyses. That means that at least 17 days went by without any radiological monitoring of this filter.
#3. On November 27, 1985 during an NRC inspection, it was identified that monthly instrument channel checks of the main stack and reactor building vent waste gas monitors were being performed as required. Cause was determined to be previous management deficiency in that the requirement to perform the test, which was in place in September 1972, was not incorporated into the technical specification implementing procedures. Does this mean that Boston Edison had not performed this check in 13 years?
#4. On May 3, 1985 a drain in the licensee'r " Hot Machine Shop
- was identified as apparently backing up. Since the drain was plugged and located in a contaminated area, an investigation was initiated to determine the ultimate disposal point of the drain.
The radioactive effluent was directed to an onsite leaching field and was periodically pumped out and sant to the Plymouth Sewage Disposal Facility. This represents an unmonitored effluent release path. Again we ask, how long had this gone on? Mr. Buckbee stated that Boston Edison is not capable of adequate monitoring, maintaining or running Pilgrim Nuclear Power Plant. CURE believes that accurate impartial monitoring cf the Pilgrim Station is required before it is ever restarted. In place of Dr. Peter Chapman, DR. STEPHEN HOXP"" Medical oncologist at Jordan Hosptial in Plymouth presented the .ollowing testimony: Jordan Hospital has worked in conjunction with the Massachusetts Cancer Registry for the last 10' years. Hosptial _m._-_-_--.m__ _-_______m ___ _ _ _ _ _ _ . _ - - . . . _ _ -_m - . _ _ _
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. researchers, through their own studies, have not found any increases in cancers or leukemias in the Plymouth area as a whole since beginning their research.
In 1983 Jordan Hospital was able to access and fully utilize the. Massachusetts Cancer Registry's research and reports. It was through this data that they found increased incidents of leukemia That finding raised among middle aged males in the Plymouth area. many questions when cross referenced with Jordan Hospital research. These leukemia instances could be the result of dual reporting. If there is a finding of a rise in cancers in middle age males in the area, Dr. Hoxden recommends that the cases be further broken down to investigate each individual's occupation, length of residence in the area, medical history and other specific factors. In 1982, for example, childhood leukemias and solid tumors were on the rise at a school in Cedarville. On further investigation it was found that the affected children had only recently moved into the area, thus allaying community concern. On the local level, citizens have been concerned by clusters of leukemias and solid tumors in other specific areas of Plymouth. One such cluster was located at the Cherry and Terry Streets junction. Dr. Boxden requested that the Massachusetts cancer Registry review these cases. This review is currently ongoing. Other areas in which cluster incidances have occured are Winter and Sandwich Streets, and Washington and Duxbury Streets. At the time of the hearing, Dr. Hoxden requested that the Department of Public Health research the significance of these cases. He k suggested that the DPH concentrate their studies u. these cases bef ore trying to link them trith the Pilgrim plant. Jordan Hospital is also approaching the epidemiological departments of several universities to conduct int.ependent studies on these clusters. In further support of this request, Dr. Hoxden revealed that residents of the Cherry Street area suspect that a closed toxic waste dump in North Plymouth may be the cause. This suspicion should be investigated for a possible link. The citizens of Carver are also eencerned about the use of pesticides for the upkeep of bogs in the cranberry industry. This, too, should be thoroughly investigated for any link to area cancers. l MR. CHARLES POOLE, an epidemiologist with primary interest in j occupational and environmental epidemiology and epidemiologic ; methods, and spokesman for Epidemiology Re. source Incorporated (ERI), ) updated the committee on work that has been done on behalf of Boston Edison Company.
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.x c Boston Edison asked ERI to perform two tasks. The first was to review analyses by the Massachusetts Department of Fablic Health of cancer rates in Plymouth and four other towns. The second was to make recommendations for possible epidemiologic studies of Boston Edison employees. At the time of the hearing ERI was still trying to accomplish the first task. ERI has produced a preliminary critique of what now appears to be only a portion of the Department's output on this topic.
Mr. Poole provided the coamittee with an indepth look at events that occured over the issuance of the ERI report (see Appendix 1). Mr. Poole summarized and supplemented the report with a brief list of major points.
- 1. Selection of the Five Towns: I have essentially no information at this time on the rationale for this central decision of study design. The key question is whether residence in trose particular towns, as opposed to any other aggregation of towms, creates the sharpest possible differentiation of radiation exposure in a comparison with the rest of the Commonwealth. The magr.itude of that difference, if any, must be sufficiently great for an effect on leukemia rates to be reliably estimated. Radiation monitoring data must be reviewed in depth in order to answer this question.
- 2. Classification of Leukemias: Both DPH documents I have seen give the same, reasonable breakdown of leukemias into four major categories. The various types of leukemia differ greatly in the age distributions and in the influence of causal factors on their occurrence. Thus, it is best at the outset of an analysis to treat the different categories of leukemia as separate diseases.
Neither DPS document, however, follows its own four-part categorization in presenting its results. In order to conduct an analysis of each of the four leukemia categories, I will need to obtain more detailed data. ,
- 3. Reliance on Statistical Significance Testino:
Statistical significance is perhaps the most misused criterion of interpretation in epidemiologic research. A statistically significant result is often treated as though 4.t should . automatically be considered significant from a medical, biological, or public-health point of view. This interpretation is well-known to be erroneous, but it is still common.
- 4. Suberouc Analvses: The DPH reports analy:e data separately for men and women without stating why. There should be a 1 good reason for conducting such an analysis of subgroups. The search for a statistically significant result is not a good reason.
For an environmental exposure, location of residence should be a bette'r indicator of exposure on average for women than for men. Thus, a good reason for analysis of subgroups defined by gender in this case is the expectation of a greater effect among women than among men. As I am sure you are aware, the July presentation did not even include cancer incidence data f or women. 9_
. . =.w a.~ .w . .: v. : .w .. . . :: 1 ...w . .n.- .: .- .- w - w-Another interesting subgroup analysis would focus on people a of different ages. The age distributions of the different types of I leukemia differ much more sharply than do their distributions by gender. Thus, acute lymphocytic leukemia (ALL) among children is often considered to be a disease entity distinct from ALL among adults. Age-specific analyses do not appear in the DOH reports I have seen thus far. MR. FRANK ARCHIBALD, Radiation Control Supervisor in the Division of Occupational Hygiene, Department of Labor and Industries. Boston Edison's Pilgrim Station is one of over 1,000 companies in Massachusetts that are registered with our Division as having sources of ionizing radiation. It has been my practice to visit Pilgrim Station several times each year in an effort of staying abreast of changes and developments with respect to their Health Physics or Radiological Safety program. I would like to say a few words in the way of background; 1984 was a year of major refueling and modification work at Pilgrim and was also a year when two separate incidents occurred involving unplanned radiation exposure to two contractor employees. As a result of the second incident which happened during August, a meeting was held between Boston Edison and the NRC. Following this meeting, Boston Edison contracted with Hydro Nuclear Services for certain efforts including a comprehensive team appraisal of the l Radiological Safety Program. The resulting Appraisal Report was subsequently devised which detailed the efforts to be undertaken. Milestone dates were established. The Radiological Improvement Plan addressed each of the fourteen areas or categories delineated in the Appraisal findings and the many recommendations that have been made. Implementation of the tasks associated with the Plan occurred during 1985 and completed during 1986. An overview of the areas covered by the Radiological Improvement Plan is contained in my August 1985 visit Report. Additional information relating to the Radiological Controls function at Pilgrim is contained in the report of my October 1986 visits. This latter report contains the conclusion that the~ Health Physics functional role at Pilgrim has been strengthened as a result of the implementation of the NRC directed Radiological Improvement Plan including the restructuring of the Radiological Section. Each of the referenced Reports, one dated in October 1985 and the other in November 1986 contain an Appendix that shows a bar graph,of the Man-Rem exposures sustained by Station, Utility and Contr, actor personnel at Pilgrim over a ten year period. The graphs are based on data contained in the 1.16 Reports and excluded exposures less than 100 millirems. The 1.16 Reports are prepared by Boston Edison in accordance with NRC Regulatory Guide 1.16. A review of the graphs indicate that 3,966 Man-Rems were sustained during 1984, a year that Pilgrim was down for major refueling and modifications. The Man-Rem figures for 1985 and 1986 are 525 and 561, respectfully. The total reported Man-Rem Exposure for 1987 as of March 11 is 270.5. See Appendix 2 for reports.
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_ = - . - ;; ; .g , l I ( l i KATHLEEN M. LESLIE, M.D. of CURE requested and was granted permission to submit testimony to the committee. Her testimony is as follows: "Not only am I a physician at Plymouth's Jordan l Hospital, but I raise a family of three children within Pilgrim's
" exclusion area", that is we live about one-half mile from Pilgrim Station. I don't see any reason why I shouldn't feel safe doing so.' I am depending upon you, my elected representatives to ensure that my life and those of my family aren't being shortened because we live next door to Pilgrim.
What safeguards are in place not to assure that? Boston Edison, the Nuclear Regulatory Commission and the Department of Public Health do radiation monitoring in the environs of Pilgrim Station. To monitor airborne radiation Boston Edison has a collection system consisting first of cellulose particulate filters and secondly of charcoal filters used to collect particulate matter and iodine nuclides respectively. There are 11 sites where these filf s are in place including onsite and offsite locations. The, control station is in East Weymouth. These filters operate / continuously, but are collected and analyzed weekly for beta particles and quarterly for gamma radiation. To monitor direct gamma radiation, thermoluminescent dosimeters (TLDs) are used. These are the same as the dosimeter an X-Ray technician wears to monitor radiation exposure. The TLDs are read quarterly for gamma radiation. Locations are similar to those for the air particulate filters. To analyze for water borne contamination, samples of seawater are collected from the plant's discharge canal every 1/2 hour.
" Grab" samples are taken weekly from a Plymouth pond and the bay in the Powder Point area of Duxbury. Shellfish, lobster, fish, Irish moss, and sediment from the ocean floor are analyzed quarterly or semi-annually; and incidentally, have been found to contain isotopes which Boston Edison identifies as coming from the liquid releases of Pilgrim Nuclear Power Station. .
Milk, cranberries, vegetation, and beef forage are also analyzed; milk monthly or semi-monthly, plant-life usually at the time of harvest yearly. In some instances, Pilgrim-related isotopes have been found according to Boston Edison. All of this data is catalogued and made available to the public in our local library 6 months after the year ends (Environmental Radiation Monitoring Program Report). In addition, the State DPH is monitoring radiation releases from the plant. They visit the Pilgrim Station weekly to examine the automated strip chart recorders from the main stack monitors and - the reactor building vent for releases of radioactive gases, particulate, and iodine-131. In addition, the recording for liquid releases is inspected. Boston Edison has the data, but it is only reviewed, after-the-fact a week later. The DPd has its own TLD monitors within a five mile radius of the plant. These are read quarterly for gamma radiation exposure.
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l l l l controversy exists within the scientific community over what level of radiation exposure is safe for humane. Factors of age, health, and length of time of exposure are a:so important in whether radiation damage will be induced. We also know that all nuclear plants emit radiation into the environment as a part of their normal operations. My point is all of this is timeliness. From the perspective of the person who is potentially being exposed to radiation, all of these monitors are of little value in detailing after-the-fact that an event has occurred and radiation has been excessive. The , citizens of Plymouth and the surrounding South Shot 3 communities q must be able to protect themselves in the event of any unusual : radialton releases....not weeks, months, or years afterwards. The State must prepare to be involved day to day in monitoring radiation emitted from Pilgrim Station, both planned and unplanned. With a complete system of. radiation detection devices, on site, in Plymouth, and in surrounding towns, with the capability of continuous readings, then the people around the plant could know in a timely fashion if their health is threatened. Why not the Illinois model? A central computer to continuously monitor all radiation releases and mechanical parameters of every nuclear plant in the State. Someone with no vested interest should be watching Pilgrim! Not a utility motivated by economic concerns, not a federal agency who must preserve the nation's nuclear option. The State of Massachusetts must take on this responsibility to ensure the health and safety of its residents. At the time of the March 23, 1987 hearing the committee requested that Boston Edison Company respond to a number of informational requests. A letter was received by the Chairman in response to those requests. They are as follows:
- 1) HOW MUCH SPENT FUEL CAPACITY DID PILGRIM HAVE WHEN IT BEGAN COMMERCIAL OPERATIONS?
When Pilgrim 1 began commercial operation in December 1972, ! the spent fuel storage capacity was 880 spent fuel assemblies.
- 2) HAS'THAT CAPACITY BEEN EXPANDED?
The spent fuel storage capacity at Pilgrim has been expanded in increments as the need arose. The original capacity of 880 was first increased to 1770 in 1979 and just last year to its current capac'ity of 2320.
- 3) HOW MANY FUEL RODS ARE REPLACED PER CYCLE?
The amount of fuel replaced each cycle is dependent on several factors and, therefore, can vary over time. However, based
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on the latest fuel cycle plans available from our fuel. vendor, it is projected that Pilgrim will replace about 200 fuel assemblies each cycle.
- 4) IS THE COMPANY CURRENTLY CONTEMPLATING FURTIIER EXPANSION OF STORAGE CAPACITY?
At this time, Boston Edison is , sot actively pursuing a
- further expansion of spent fuel storage capacity. The Company is monitoring the need for expansion and will initiate the actions required to implement this expansion as the need arises. i 9
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p ;.a w ; m a =.u v a a ,= w a .w.sa.., w n w .m m a m .s m.x p c a wwca. w.a :.9 a :. m a w,x w;u w j i I il i i TOPIC 2 THE RESPONSE'OF BOSTON EDISON COMPANY AND THE NUCLEAR REGULATORY COMMISSION TO FINDINGS OF INADEQUATE OR LESS THAN EXCELLENT PERFORMANCE AT THE PILGRIM NUCLEAR GENERATING FACILITY AT PLYMOUTH The committee held a hearing on the issue of the Nuclear Regulatory Commission citing of the Boston Edison Company for code violations and the reasons causing the shutdown of the Pilgrim plant in April 1986. The hearing was held on March 9, 1987 at 10:00 a.m. in Room 466, State House, Boston, Massachusetts. The committee sent a written request to testify before it to the following individuals:
- 1) Lee Oxsen, vice President of Nuclear Operations, Boston Edison Company; 1
- 2) Ralph Bird, Senior Vice President of Nuclear Operations, Boston Edison Company;
- 3) Dr. Robert Henry, Consultant to Boston Edison Company; and
- 4) Thomas Murley, Regional Administrator, U. S . Nuclear Regulatory Commission l MR. LEE OXSEN's testimony was as follows: " Substantial progress has been made at Pilgrim towards a safe restart of the unit and reliable operation of the plant. ,
The entire core of nuclear fuel has been unloaded from the reactor vessel and~ temporarily stored within the spent fuel pool. j The unioading took six-and-one-half days as compared to the ten days 1 which had been predicted based on previous experience. This is the seventh refueling at Pilgrim and we believe that procedural < improvements made based on our experiences plus the installation of a new refueling bridge made it possible to shorten the time for the unloading. The complete removal of the core makes it possible to perform maintenance and make modifications in the safest and most efficient period. In addition to the scheduled refueling and the maintenance that would normally be done at this time, Boston Edison has committed to a number of safety enhancement programs which were outlined in December and are now well underway. 1
wT ;uva , ;; u:. . . :2 2 w. _ ,,w. v . :, . .yu , .. .a u m., , c On the issue of containment enhancement, we continued to take a position of industry leadership in advance of rulemaking by the Nuclear Regulatory Commission (NRC). Boston Edison has been commended by the NRC for its aggressive actions to implement design and procedure changes to prevent containment over pressure failure and,to maximize the use of the water in the suppression pool as a filtering medium. As you will hear from Dr. Robert Henry of Fauske and Associates in greater detail, the changes proposed by Boston Edison
- are consistent with American research and the actions taken by utilities in Sweden, France, and Italy. The modifications will:
allow the operation.to fully utilize the plant's capabilities in the event of an accident; provide the operators with dedicated core cooling capability even with a complete loss of AC power; and maximize the plant capabilities for fission product retention and essentially eliminate environmental release under severe accident conditions, particularly land contaminating fission products. Improvements to the fire protection systems are still on schedule. Completion of the cur'.ent program will bring Pilgrim into full compliance with Nuclear Regulatory requirements for fire protection in.10 CFR50 Appendix R. Boston Edison has made further changes to the management structure of the Nuclear Organization as planned. Mr. Bird, Senior Vice President -- Nuclear, reporting directly to the Chairman of the Board, guarantees that nuclear matters will continue to receive top level oversight on a regular basis. Mr. Bird brings with him the high standards of the United States Navy's nuclear program where he served for 28 years. After retiring with the rank of rear admiral, Mr. Bird worked for Westinghouse Electric Corporation and performed consulting services for several utilities. In addition, Kenneth P. Roberts has assumed the responsibilities as Station Manager with overall control including outage management. All key management positions in the Nuclear Organization have been filled and progress is being made in achieving the authorized complement which now totals 794 positions. We are actively recruiting to fill open positions with top candidates from the industry, the military and the academic world in addition to providing opportunities for promotion from within the organization. We have also put in place programs to build morale in the workforce, increase productivity and ensure an orderly succession within the Nuclear Organization in the years ahead. Some key management changes made in the last year have been separation of training, fire protection and security with a senior ) level manager in charge of each operational area and the addition of 1 j a system analysis and a waste management group. 1 i l l
==y= .p . c . .m. ,. ,- ... ,... .7 . w. . , These changes were designed to ensure additional senior management attention to each of these critical areas and the early results have shown substantial benefits from these modifications. The need to increase the number of licensed reactor operators has,been addressed in a phased program which is well underway. The i components of the program include recruitment, training p'. and ant retention as well as the installation of an S8 million specific simulator at the company's training center in Chiltonville. The simulator is complete but it will remain at the manufacturing location until this summer so as not to interfere with operator ' training currently in progress. Our plans are to increase the total number of operators by one-third which will prevent the excessive overtime noted in past criticisms. The work control process initiated last fall is being used during the outage and has resulted in clear improvements in identifying necessary activities, establishing accountability and tracking progress'. The management performance indicator program, initiated in 1985, has been upgraded to provide overall results to plant' management. This program is designed to measure effectiveness based on results as compared to the work control process which is designed to assist in achieving the desired result. There are 210 people specifically assigned to radiological protection. In addition, training and employee communications include intensified direction that radiological protection is everyone's responsibility. All section managers are responsible for the protection of their staff through communication, on the job
-reinforcement of training, and supervision. .
The organizational changes made in the Nuclear Engineering Department to organize the department by major function, and r. educe the number of people reporting directly to the department manager as well as the establishment of a field engineering section at the site, have resulted in measurable benefits during this outage. On one final personnel matter, all Pilgrim employees are now being testing for drug and alcohol use during their required annual physical. We will continue testing of all employees as well as those who are promoted or transferred and where there is just cause. On the subject of emergency planning, I believe that the company has demonstrated its commitment to upgraded emergency planning by improvements in facilities such as the new Emergency Operations facility and the upgrading of the joint news center at Memorial Hall, as well as continued emphasis on procedures and training. As a demonstration of the latter, the company has implemented a quarterly drill schedule. We continue to be committed to providing assistance to the State and Local governments where we can to improve existing emergency plans. e
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i e It is important to note'that emergency plans are not static, but are part of an on-going process of review and revision. However, the fact that plans need revision because of change demography or the availability of physical resources does not mean that they are fundamentally flawed. The revision prccess is an integral part of all emergency planning and cur expa.'ded emergency planning organization is fully committed to that process. We will continue to monitor our progress on all fronts and make adjustments to our programs as necessary to achieve our goals. We are fully committed to excellence as the only appropriate standard for operation of a nuclear power station." HR. RALPS BIRD's testimony was as follows: "I'm the new Senior Vice President - Nuclear for Boston Edison Company. I joined the company in January and assumed my responsibilities on the 20th of February, after about six weeks of intensively reviewing Pilgrim's Boiling Water Reactor design and operation. I report directly to Steve Sweeney, who is our Chairman, Chief Executive Officer and President and I am responsible for all aspects of our Nuclear i Organization, including operation, engineering, maintenance, and training for the Pilgrim Station. Some relevant parts of my background and experience may be of interest to you. I am a 1956 graduate of the U.S. Naval Academy. Most of my 28 years in the Navy were in the Navy's Nuclear Propulsion Program, with several assignments in nuclear powered submarirms, including Engineer Officer and Commanding Officer Assignatats as well as staf f assignments directly related to the supervision, operation maintenance of nuclear propulsion plants, and assessment of their performance. For example: As Material Officer for the Polaris Submarine Squadron in Scotland, I was responsible for oversight of maintenance of twelve nuclear powered submarines; as Chief of Staff of the Pacific Submarine Force, I had broad responsibility for operation and maintenance of about 40 nuclear powered submarines as well as their repair base and other support; as Senior Member of the Pacific j Fleet Nuclear Propulsion Examining Board, I was responsible for annually assessing the ability of each Naval Nuclear Propulsion I Plant in the Pacific fleet -- about 50 units -- to operate nafely for the forthcoming year. One other assignment may be of interest to you. I was the ) First Senior Instructor and was responsible for setting up a course of instruction for Admirals and Senior Captains going to the Navy's major commands to teach them about operation and maintenance of Ship Propulsion Plant- The emphasis here was on oil-fired plants, to impart to their commanders the standards which had been l C - _ _ _ _
p w.w w w . .r. . ~ - .:w a .. . .s - x ,..n. .x, , . . . . , .u n : It I developed over the proceeding 25 years of the Navy's Nuclear Propulsion Program. The course was set up at the request of the Chief of Naval Operations and I reported directly to Admiral Rickover during that year and a half. During the past three years I have held consulting and management positions in nuclear utility and related fields. The manegement philosophy and approach which I intend to ; follow at the Pilgrim Plant are based heavily on my nuclear navy training and experience, reinforced by my subsequent civilian experience. The fundamental principle is to maintain the highest possible standards in every thing we do, every day; with emphasis on careful, conservative operation, maintenance and training. Achieving consistent high standards is not something which can be done and then forgotten. Continuing attention to detail, and a questioning, skeptical attitude are required. My own observations and discussions with the top management in Boston Edison Company, with people at Pilgrim, with the Nuclear Regulatory Commission Staff and Commissioners, and with the Institute for Nuclear Power Operations, in preparation for assuming my responsibilities ,
- indicate that we can and should do better than we have in the past.
It is important to mention here that even though there have been some problems Et Pilgrim Station, neither the Nuclear Regulatory Commission, nor the Institute of Nuclear Power operations, nor the Company management, including our outside consultants, have said that the Plant was unsafe; nor have I seen evidence of unsafe plant operations. There were indicators that the people at the plant did not critically assess their own performance to the depth that they should have. There were some equipment problems and some indication of inattention to details which are being corrected during this outage. We have made management, training and maintenance improvements to ensure that the very large margin of safety which is designed into these plants remains intact. At the same time, improvements beyond the requirements or regulations are being made to the containment which will place Boston Edison at the forefront in these kinds of improvements to further increase design safety. There is absolutely no question in my mind that the Chairman and the top management as well as the Board of Directors are completely committed to supporting the Nuclear Organization to achieve and maintain excellence at Pilgrim. There are many good people at Boston Edison Company and at Pilgrim. They want to do well. They want to be part of an l i organization that has a good reputation. I believe that a high standard of excellence is achievable." l l 1 _____.__-__4__..._
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DR. ROBERT HENRY's testimony encompassed the following: "The capability of nuclear power plants to withstand severe accidents has been under study for more than two decades. The overwhelming concensus of analysts who have studied these issues is that the design features of US commercial light water reactor power plants, including Boiling Water Reactors (BWR's) with Mark I type containments such as Pilgrim Station, provide adequate protection to the health and safety of the public. The conclusion of these efforts is best summarized in the Nuclear Regulatory Commission's Severe Accident Policy which states " existing plants pose no undue risk to the public health and safety". Because Boston Edison believes that it is important to restore and enhance public confidence in the continued safe operation of Pilgrim, Boston Edison has, at its own initiative, undertaken a Safety Enhancement Program to evaluate a series of questions raised about the consequence mitigation capability of Mark I containments f ollowing the extremely unlikely occurance of a severe accident. One of the important goals of the Safety Enhancement Program is to identify plant's specific conditions that are important to minimize risk, and then implement improvements in plant design, operating procedures, and operator training that would:
- 1) reduce the possibility that a core damage event could occur; and
- 2) improve the capability of containment to mitigate offsite consequences should a core damage event occur.
To achieve this goal Boston Edison is performing a detailed safety assessment of the Pilgri= Station. Two major interrelated investigations comprise the Pilgrim Safety Assessment. These are:
- 1) An Individual Plant Evaluation (IPE) that examines how accidents leading to core damage might possibly occur at the plant, and the capsbility of the plant design and the effectiveness of the emergency operating procedures to prevent these accidents; and 2) a Containment Safety Evaluation that provides an in-depth investigation of the ability of the Pilgrim Containment to respond effectively in mitigating the consequences of a core damage accident.
In addition to supporting the Safety Enhancement Program goals, these analyses and their supporting documentation will provide a thorough assessment of the ability of the Pilgrim Plant to prevent or mitigate severe core damage events. The NRC Severe Accident Policy Statement conclude that current US plants are safe and currently designed. This conclusion is supported by the Industry Degraded Core Rulemaking Programs (IDCOR) examination of four reference plants. These conclusions can be drawn because current US reactor systems and their containments have the necessary features to cope with possible severe accident conditions. These features are: strong containments, substantial water sources, and heat removal capability. I
, w .u . :a we r ..w u . w :. n w. z . - m:a w : . .r: .. u - ..m: a :w r I k Based upon the availability of these features, the goal of a safety enhancement program must be to formalize and expand the manner in which these systems could and would.be used under severe accident conditions. The safety enhancement program must be based upon detailed expectation of how a particular plant will behave under severe accident conditions, such as that gained throegh IPE methodology, and must involve hardware, procedural and training enhancements designed to maximize the utility of available features. While Pilgrim Station presently meets all regulatory standards, Boston Edison is performing an IPE to determine where plant modification or improvements in Emergency Operating Procedures can be beneficial in reducing the probability of core damage, or improving containment performance. Based upon this analysis, Boston Edison is implementing a number of safety enhancement measures. Most fall within the categories of: 1) emergency power; 2) decay heat removal; 3) hydrogen control; 4) containment sprays; 5) containment wetwell venting; 6) emergency operatint procedures; and
- 7) training.
As a result of public concern over Cherncbyl, other Western world countries (France, Germany, Sweden, Italy and others) are considering plant modifications to essentially eliminate the releases of land contaminating fission products. A containment wetwell vent and a filter was designed and built at the Barseback reactor in southern Sweden, which is a Mark II type containment. The other Swedish plants (Mark II type BWR's and PWR's with large dry containments) have a commitment and an ongoing effort to evaluate other possible designs which could provide similar protection. These design concepts are not limited to the Barseback large gravel bed filter. Another design being considered uses a water pool for retention of fission products. It is noteworthy that the various strategies being considered for these Swedish plants are comparable to those being implemented for Pilgrim. The French (PWR's with large dry containments) are presently considering sand filters to allow for containment venting under severe accident conditions. In addition, the containment sprays would be used to provide cocling of the core debris in the containment. In essence, this strategy provides for protaction against containment overpressure, a filtering of releases during the venting process and a cooling of the core material in the containment. It should be noted that cooling the debris in containment can preclude the need for venting, which would keep all fission products in the containment building. The strategy for coping with severe accident conditions for the French reactors is comparable to that being implemented at Pilgrim. Similar considerations are being made by the Italian government in considering both their operating plants and those under construction, with their goal being to essentially eliminate the release of land contaminating fission products. This would
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likely be done through the use of containment sprays and containment l heat removal with the possibility of containment venting to prevent containment overpressure. Similar considerations of containment venting with a filtered release through a separate filter or through the existing suppression pool for BWR designs is being considered l for the German reactors.
. As indicated above, the features being considered in European !
reactor communities are consistent with those considered for the Pilgrim Station. The major features of the Pilgrim Safety Enhancement Program are those needed to cope with severe accidents and reduce fission product releases.
- 1 Current US BWR and PWR plants are safe because all necessary l features (redundant safety systems, strong, effective containments, substantial water sources and heat removal) are available. A program to further enhance the safety of a specific plant should '
formalize and expand the manner in which these systems could and
.ould w be used. The program should include hardware, procedural and The Pilgrim Station Safety Enhancement l
training enhancements. ; Program will accomplish these objectives, and is consistent with industry-wide analyaes and actions, NRC initiatives, and actions { taken by Western European utilities". The following is testimony of THOMAS MURLEY: "I appreciate the opportunity to be here today. I understand that many of you have concerns about the safe operation at Pilgrim and we want to be responsive to your concerns. We share the same goals of safe operation of Pilgrim. We in the NRC recognize that times are changing with regard to States' interest in nuclear regulation. We want to work with Massachusetts in a cooperative way and to be responsive to your concerns and those of the Governor. To begin, I would like to discuss how we got where we are today with Pilgrim. With the Committee's indulgence, I will go back several years. Boston Edison ordered the Pilgrim plant in the late 1960's. They received a construction permit in August 1968 and an operating license in September 1972. If one looks back, we can see that the seeds of many of their current problems were sown in those very early days. The design, construction and operation of Pilgrim was treated much like any other fossil-fired plant in the Boston Edison system. This is, they had a nuclear plant being operated in a fossil plant environment. One can contrast that situation with the Yankee plant, where the plant was operated within a nuclear corporata ethic from the very beginning. The demands, the training, and the attitudes are much different for operating a nuclear plant than for a fossil plant. __m_m_-___ _ - - - _
8 L l l l In 1980 and 1981, there were management problems at Pilgrim that led to a $550,000 fine. Boston Edison Company responded positively by creating a separate nuclear organization with a Senior vice President in charge. During 1980 to 1984, we started to see improvements: they invested millions of dollars in plant hardware, improving conditions of the plant; they increased spare parts inventory; they began to clean-up the radioactive contamination in the plant that was caused by fuel failures in the 1970's; and they replaced some large diameter pipes that had become cracked. , 1 During this same period, the NRC was issuing a flurry of new requirements in the ' aftermath of the TMI accident. Thus, we saw a paradox. While there were visible signs of improvement, the workload was growing too fast, and the management systems at Pilgrim were being overloaded. That' bring us to 1986. Early that year, we issued a Systematic Assessment of Licensee Performance (SALP) review covering a 12 month period from October 1984 to October 1985. That report brought into focus a number of problem areas: a shortage of licensed operators causing excessive operating overtime; a large maintenance backlog with a number of management vacancies in the maintenance area; radiological protection program weaknesses; emergency preparedness program weaknesses; instances of poor procedural adherence and administrative practices at the plant; and too frequent failure of managers to ensure proper planning and scheduling of required surveillance tests and maintenance. These problems were compounded by a lack of critical self-assessment on the part of Boston Edison and a tendency toward superficial corrective action. I talked with the senior management of Boston Edison Company in January 1986 and forcefully told them of NRC's concerns. In February 1986, I sent in a special team of inspectors for a few weeks of round-the-clock inspection coverage in order to obtain a more complete understanding of the underlying reasons for the poor performance. This team confirmed the SALP conclusions. In April 1986, a series of plant hardware problems caused the plant to shut . down. At that time, I issued a Confirmatory Action Letter keeping l the plant shut down and I sent in another NRC inspection team. Later in the summer of 1986, I revised and extended the Confirmatory Action Letter to assure that Boston Edison Company would keep Pilgrim shut down until those management deficiencies identified in i the SALP and the diagnostic team inspection were resolved. The f plant has since remained shut down for refueling and modifications. Boston Edison Company subsequently decided to make additional safety improvements to the plant, including their Mark I containment , structure. In this safety initiative, they are leading the rest of the industry. Two specific questions can be asked:
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- 1) What is the adequacy of Boston Edison Company's actions?
I believe they are clearly on the right track. We see signs of improvement at the plant. There is a new Senior Vice President in charge of the nuclear program who has extensive experinnce in the nuclear Navy. A recent emergency preparedness exercise showed better planning and senior management involvement in thnt program. 1 However, out in the plant the workers are still struggling to get their arms around the problems. The management team has not yet jelled. There is still a large work activity backlog and still a shortage of reactor ope.rators. In addition, the security, fire protection and radiological protection programs are not as ef fective as they need to be. The organization has to overcome the legacy of years of fossil-plant type of operation that mere words at the top 1 cannot change overnight. In the past, we in the NRC mistook good intentions and management assurances for real, fundamental changes in performance. We will not fall into that trap again. NRC has been giving enhanced inspection coverage and oversight at the plant and will continue to do so for the foreseeable future. We are having bi-monthly senior management meetings to assess their progress. There are now three NRC Resident Inspectors assigned to the site.
- 2) Will the plant be ready to return to full power operation safely? The plant remains shut down. NRC will not permit its restart until we make a finding that it can be operated safely. We will require a comprehensive report from Boston Edison that describes the improvements that have been made in the plant, personnel, programs, and in their management systems. This report will be made public. In addition, NRC will conduct a readiness team inspection and will also make public the team's inspection report.
This inspection will be similar to the special diagnostic assessment team inspection which was conducted at Pilgrim in February 1986 and will focus on the general readiness of the plant with specific emphasis on those problems areas which have been identified at Pilgrim. Finally, there will be a public meeting with the NRC Commissioners before NRC makes a decision to allow restart of the reactor. If a restart is authorized, NRC would augment its inspection coverage for the startup program. This coverage will be like that which we applied during the Three Mile Island Unit 1 startup and will provide around-the-clock coverage of startup and site activities. There will be a number of " hold-points" beyond which Bostbn Edison Company would not be permitted to proceed without NRC authorization. These decisions would be based upon the evaluation of the plant's operation by the on-site inspection team. What will we look for to see that the situation has improved l at Pilgrim in preparation for restart? In general terms, we will . look for: 1) a stable and effective management team at the plant; 1
- 2) management vacancies are filled and licensed reactor operator and n
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1 I i i senior reactor operator positions are filled; 3) the work backlog is j under control and a system is in place to track the backlog; 4) { { solid improvements have been made in long-standing problem areas j such as radiation protection, fire protection and plant security; I and 5) solid improvements have been made in the off-site emergency planning weaknesses. , Finally we will expect to see that Boston Edison Company is dev'elopir.y its own internal high standards of performance and the means for self-critical analysis relative to those standards. Of course, there will be detailed inspections of many specific issues within these general areas." In addition to the scheduled guests that were to appear on this date the committee allowed MRS. DIANE BUCKBEE, Chairwoman of the Plymouth Citizens Urging Responsible Energy (CURE) to address the committee. Her testimony was as follows: "I will concentrate on Boston Edison's performance since the plant was shutdown in April of 1986, when Boston Edison instituted its " Pursuit of Excellence Program". The documents I am using to substantiate my testimony are Nuclear Regulatory Commission (NRC) bi-monthly status reports. In the interest of time, I will present five incidents representative of what we consider to be continuing poor management, performance,
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and safety related problems. I
#1. On August 27, 1986 a potential design deficiency in the standby gas treatment (SBGT) system was identified. In the event of an accident, the SBGT system processes the reactor building atmosphere to remove radioactive iodine and particulate prior to release from the main stack. Because of the design flaw, the potential exists for a percentage of the reactor building exhaust flow to pass through the main stack without being processed.
Licensee Event Report (LER) No. 21 stares that the susceptibility of the SBGT System to a single active failure resulting in elevated off-site releases is beyond the desian basis of the plant and involves a reduction in the degree of protection provided to the public health and safety. This report further states that prior to conducting operations which would require the SBGT to be operable, it will be verified to be operable in accordance with the Technical Specifications. Yet Boston Edison has purged the containment and defueled the reactor, and we have received no documentation that this problem has been resolved.
#2. Boston Edison f ailed to perf orm Nitrogen Make-Up monitoring. During operation, the primary containment atmostphere is inerted with nitrogen. A system is in place to add nitrogen as needed. The significance of not monitoring is that they would be unaware of any large increase in containment leakage. To make matters worse, the instrumentation used to perform the monitoring had been out of service since January of 1985.
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#3. The licensee is recuired to perform an extensive inservice inspection program. As pait of this program, visual examination of piping system supports are conducted. One type is a hydraulic shock suppre'ssor. This component allows the pipe to move freely during system expansion and contraction, but will also act to suppress any abnormal vibrations as might be experienced in an earthquake. Damaged supports could result in ruptured or broken pipes. Two such supports were identified as inoperable.
- 64. Certain equipment important to safe operation of the i plant is protected by fire barriers. These barriers prevent a postulated fire from spreading to adjacent areas for at least three hours, allowing time to extinguish the fire. The licensee is required to periodically inspect the barriers to ensure their integrity. Inspections have identified numerous discrepancies between the fire barriers and inspection criteria. Compensatory fire watchers were initiated. Unfortunately, 17 f.natances in a twenty-four hour paried had been identified where hourly fire watchers were probably missed. This is certainly a dangerous situation.
#5. In a later related event we are witness to the coup de grace. In November, Ecctcp Edison was cited by the NRC for a violation of their operating license because adequate procedures and drawings had not been established for the station fire water system. This left the pirnt with no primary water supply to fight a fire for six days. The backup supply calls for the use of the municipal water system in the form of two hydrants. One of these hydrants had been tagged for repairs six weeks earlier. The inspection report on this incident states that forty " hot job" permits (those allowing activities that could initiate a fire, e.g.
welding, grinding) were active. Four jobs were actually in progress and had to be stopped. A 31censee owned fire truck is required to be connected between the town water supply and the power plant to be held in standby. By procedure, a municipal truck would only be summoned after a fire brcke out. The on shift fire brigade leader, a licensed reactor operator, was asked to demonstrate use of the truck and was unable to do so as he had not operated the pumper in several years. We have here a situation of degraded fire barriers, missed fire watches, ongoing hot jobc, no main water supply, one available fire hydrant and a man that cannot operate the station fire truck pumping unit. l Above and beyond the fire incider.ts we have mentioned, Boston Edison has allowed trucks to leave the site on three occasions without required radiological surveys; has dumped radioactive materials on their property; discovered main steam line weld flaws; found piping corrosion so severe that it extended through wall, causing a pipe leak; and found Residual Heat Removal Pump damage which was a result of overheating. This list is not even complete. l
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In closing, I would like to suggest to this committee that we of CURE continue to be amazed and appalled at the ineptitude of Boston Edison's management and the NRC's unwillingness to enforce compliance with safety regulations. At the time of the March 9, 1987 hearing the ccmmittee requested that the Boston Edison Company respond to a number of informational requests. A letter was received by the Chairmen in response to several of those requeste. They are as follows:
- 1) WHAT POSITION DID STEPBEN J. SWEENEY HOLD AT THE TIME OF THE $500,000 FINE IN JANUARY 19827 In January 1982, Mr. Sweeney held the position of Senior Vice President in charge of Corporate information Services and Special Projects. Mr. Sweeney had no responsibility for the Nuclear Organization at that time. Mr. Sweeney first assumed organizational responsibility for the Nuclear Organization when he became President and Chief Operatir.g officer on September 1, 1983.
- 2) WHAT IS THE STATUS OF BOSTON EDISON'S HEALTH INVESTIGATION OF ITS PILGRIM VS. NON-PILGRIM EMPLOYEES?
Boston Edison has committed to fund such a study. Funds have recently been allocated in the medical budget to hire a contractor to conduct the health study. As of now, the contractor has not yet been identified and the study has not yet commenced.
- 3) WHAT IS BOSTON EDISON'S RESPONSE TO THE CONTENTION THAT THE 1982 RESIN INCIDENT RESULTED IN INCREASED RADIATION LEVELS NEAR THE PLANT 7 The incident in question involved the unintent'onal release, through the reactor building vent, of some radioacti/e resins l normally used to purify condenser water. Small amounts of these resins were found on the roof of the reactor and turbine building and on the pavement adjacent to those buildings, all within the secure area of the plant. Thorough investigations were also made off-site for additional resin materials, but none were found. This incident did not result in any measurable radiation increases either on or off.the Pilgrim Station site. As a result of this incident, several critics of the plant have contended that radiation levels around the plant increased at this time. In particular, Mr. William Abbott has testified in front of the Special Committee that examination of radiation measuring devices (TLDs) supports this increased radiation allegation. This is incorrect. j The event occurred during June of 1982. The resins in question were all identified and collected by June 12, 1982. Mr. !
Abbott looked at third quarter radiation levels and correlated them 1 with the June 1982 event. To determine the radiological implications of the event, which concluded in June l'$82, one most examine second quarter statistics. n u- - - - - - - - _.-----_----_-------__s-- - - . - - - - - - - - - , - - - - - - -
m a.ww : . a. . . . i . e. .. .. .:: v . . .z : . -. .: . . . .u O l l When the second quarter radiation statistics are examined there is no evidence of unusual increase. As you can see from the Figure A (see page 28) that follows, the second quarter radiological readings are lower than either the thrid or fourth' quarters. Since j the plant was off-line during thr first quarter, the second quarter j radiation levels (during which the resin event took place) are ) acutally the lowest for the year while the plant was operating. 1 The third quarter increase in radiation can also be easily explained. Figure B (see page 29) shows the relationship between plant capacity factor and radiation levels. In 1982, the plant was off-line during the first quarter, ran at 70 percent of its capacity during the second quarter, achieved a high point of 80 percent capacity factor in the th-ird quarter, and ran at 72 percent in the fourth quarter. The increase in third quarter radiation correlates with the increase in capacity factor. This has nothing to do with the resin spill in the previous quarter. Even though in a boiling water reacto radiation levels do increase measurably during operation, the radiation emmissions are always within strictly controlled radiation standards which were enacted to protect the public safety. The 1982 resin incident did not result in measurable radiation increases, and at no time have radiation releases from Pilgrim Station ever posed any threat to the public health and safety. The following answers are in response to a second set of questions the committee requested to be answered.
- 1) WOULD THE COMPANY PROVIDE A FLOW CHART OF THE NUCLEAR ORGANIZATION?
A flow chart was provided (see page 31).
- 2) WOULD THE COEPANY PROVIDE MORE DETAILED INFORMATION ON ,
WHAT WORK HAS BEEN DONE ON THE STANDBY GAS TREATMENT SYSTEM 7 A detailed explanation of both the interim solution used on the Standby Gas Treatment System during fuel handling and the final solution were provided to all committee members. See Appendix 3 for the Standby Gas Treatment Report.
- 3) WOULD THE COMPANY PROVIDE THE RESULTS OF THE LATEST PRESSURE TEST OF THE PILGRIM CONTAINMENT? j l
A langthy summary of the latest pressure test of Pilgrim was provided to all committee members (see Appendix 4).
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- 4) WOULD THE COMPANY PROVIDE MORE DETAILED ANSWERS TO DI ANE BUCKBEE'S FIVE POINTS?
Boston Edison provided detailed information on each of Ms. B ckbee's five points to all committee members (see Appendix 5). Bri*ef answers to the five points are summarized below:
- 1) The Stand By Gas Treatment problem is being addressed on an interim basis by. operating both fans during fuel handling. The permanent solution will be the replacement of two pressure switches.
- 2) Boston Edison promptly notified the NRC of the nitrogen monitoring problems. The probeim arose because of the inoperability of certain instrumentation. There were, however, other ways of determining nitrogen levels.
- 3) Out of 79 snubbers (devices used toTwo support piping during others were an earthquake) one was found to have failed.
inoperable per the applicable criteria, although they were both still functional. All these snubbers will be replaced before start up.
- 4) There were 17 instances of fire watches which could not.
be confirmed and which were reported to the NRC. As a result, immediate corrective action was taken by the Company. Boston Edison management has provided increased direct oversight of the contractor fire watches.
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- 5) Immediate action was taken to correct the problem with the Fire Suppression Water System. A diesel driven fire pump and associated water supply provided the required fire water supply capability to alleviate the immediate problem.
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] TOPIC 4 1 l THE ADEQUACY AND PRACTICABILITY OF PLANNING TO PREPARE ] FOR ANY EMERGENCY WHICH MAY AFFECT PUBLIC SAFETY, ] INCLUDING THE PLANS OF THE MASSACHUSETTS CIVIL DEFENSE ' q AGENCY AND ITS RELATIONS WITM THE l FEDERAL 2:iERGENCY MANAGEMENT AGENCY l-The committee addressed the issue of the planning and financing of emergency preparedness plans for the Pilgrim Nuclear Generating facility by the Massachusetts Civ'l Defense Agency and ~ ^ the Federal Energency Management. Agency, at a hearing on March 2, 1987 at 10:00 a.m. in Gardner Auditorium, State House, Boston, Massachusetts. Where TOPIC 4 of the committee's order required an analysis of emergency preparedness plans and TOPIC 5 below required an analysis of the financing of s ;h plans, the committee decided to hear all relevant testimony on both TOPIC 4 and TOPIC 5 at its hearing on March 2, 1987. The committee thus did not have to duplicate much of the same testimony at a second hearing on the issue of financing for the emergency preparedness plan. The committee sent a written request to testify before it to the following individuals:
- 1) Governor Michael S. Dukakis;
- 2) Sharon Pollard, Secretary,. Executive Office of Energy Resources; 3') ' Stephen Sweeney, President, Boston Edison Company;
- 4) Henry Vickers, Feder".1 Emergency Management Agency;
- 5) William Parler, Nuclear Regulatory Commission;
- 6) Charles Barry, Secretary, Department of Public Safety;
- 7) Robert Boulay, Massachusetts Civil Defense;
- 8) James Shannon, Attorney General;
- 9) C. Martin Delano, Selectman, Town of Duxbury; i
- 10) Joseph Palomo, Selectman, Town of Kingston; 11). Frank R. Mazzilli, Selectman, Town of Carver;
- 12) James Finucane, Selectman, Town of Marshfield;
- 13) David Malagate, Selectman, Town of Plymouth;
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- 14) Carl O'Neil, Duxbury Civil Defense;
- 15) Robert Mulliken, Kingston Civil Defense; 16)- David Pierce, Carver Civil Defense;
- 17) Douglas Hadfield, Plymouth Civil Defense; and
- 18) Daniel McGonagle, Marshfield Civil Defense Assistant Secretary of Public Safety PETER AGNES, speaking on behalf of the Governor and the other secretariats that were to l
appear today, reviewed the Department of-Public Safety's (DPS) progress and actions that have taken place from December 1986 to present. The first step taken by the DPS was to advise the Nuclear . Regulatory. Commission (NRC), the Federal Emergency Management Agency (FEMA), and the Boston Edison Company of the release and findings of Secretary Barry's Emergency Preparedness Report. Secretary Barry's report was also distributed to local officials and community groups for their review. Assistant Secretary Agnes spoke on the DPS's involvement with an administrative working group to review Pilgrim issues. The DPS was also taking part in playing a strong role in the development of the Governor's Fiscal Year 1988 Budget initiative. The DPS has assessed in depth the organizational needs of this initiative. Mr. Agnes explained to the Committee that the DPS has assessed the role of the NRC, FEMA, and the Boston Edison Company in emergency planning, and will implement the following actions to improve their active roles
- 1) Periodic meetings with federal officials;
- 2) Review of status reports from the Nuclear Regulatory Commission and the Boston Edison Company; and
- 3) Periodic meetings with Boston Edison Company officials.
The Department of Public Safety reviewed its responsibilities under Chapter 796 of the Acts of 1979, and revised and implemented several measures.- The DPS will hold weekly meetings with local Civil Defense directors. Also, interagency meetings among the Department of Public Safety, Executive Office of Energy Resources, Civil Defense, Department of Public Health, and the National Guard to plan for improved coordination. Bi-weekly meetings with Boston Edis6n Company officials shall be scheduled along with periodic meetings with local community groups. The DPS will establish a local review process and examine the potential for 1987 supplementary appropriation. Assistant Secretary Agnes stated that the Commonwealth's position regarding the adequacy of eff-site emergency response plans remains the same as it was when the Governor addressed the Joint l -- .. .
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Committee on Energy on December 17, 1986. At this time the plans were not adequate. The state's position likewise remains that the Pilgrim nuclear power plant should not restart until all previously identified concerns regarding plant management, reactor safety, and , off-site plans have been addressed. J l' ROBERT BOULAY, Director of Civil Defense, emphasized the importance of statewide emergency planning to ensure public safety in the event of a nuclear accident at either of two licensed nuclear plants in Massachusetts (Yankee Rowe in Rowe, and Pilgrim in Plymouth) and at the nearby Vermont Yankee plant in Vernon, Vermont. l He stressed that the 1986 accident at Chernobyl, which reminds state 1 officials and the pu'blic that nuclear accidents, regardless of fail-safe technology, can occur, has propelled us into a new era of l nuclear emergency preparedness. l Director Boulay explained that the Civil Defense Agency ) (Executive Order 144, September 27, 1978) is responsible for j coordinating the activities of all state agencies preparing for and responding to an accident at a nuclear plant. The director of Civil Defense (M.G.L. Ch. 33 appendix, Sec. 13-26) is mandated to prepare l and maintain emergency response plans to a nuclear accident. 1 He pointed out that off-site emergency planning is required by federal regulations (NUREG 0654) and by other lega) obligations created by laws, executive orders, and regulations. In his opinion, Massachusetts Civil Defense and the Office of Emergency j Preparedness, both within the Department of Public Safety, must do j more than meet minimum standards to protect Massachusetts citizens. Nuclear emergency response plans must be workable, implementable, tested and retested plans of action tailored to the specific public safety requirements of ecch emergency planning zone. Ha concluded that Governor's 1988 budget proposes a major new initiative to address nuclear emergency planning needs that will ) place the Commonwealth at the forefront of states' efforts in ) Director Boulay, who will be responsible for off-site preparedness. implementing this initiative, is presently formulating a plan, to be available shortly, which details how state agencies will work together in the face of a nuclear emergency. The Committee was presented with verbal testimony from the Selectmen and Civil Defense officials from the five towns surrounding Pilgrim which are: Carver, Duxbury, Kingston, Marshfield and Plymouth. Each official echoed similar concerns regarding public safety in the event of an emergency. The issue of increased assistance in emergency planning was stress by each testifier. It was stated that the plans must be reviewed in order to insure public safety for each community within that plan. ._u------ - - - - - - - - - - - -
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l The Civil Defense officials were concerned with the lack of funding for equipment such as radios and information packets; and for the development of a workable plan for each community re:arding . public safety. The officials appealed to the committee to have state and local involvement in the review of current emergency evacuation plans and assistance in updating these plans. The evacuation plan for each community should encompass all details and problem areas that officials feel relates to their specific community. The problems that many of the Selectmen and Civil Defense officials pointed out were as follows: transportation I of the elderly, school children and handicapped; traffic patterns; siren systems; and lack of public information in the event of an emergency. In closing, all the officials who testified stressed their willingness to work with State officials in incorporating their community's concerns to develop a workable emergency avacuation plan.
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. PRESENT METHODS BY WHICH THE COMMONWEALTH FINANCES SUCH PLANNING, ACQUISITION OF SUPPLIES, EQUIPMENT, FACILITIES, AND PERSONNEL FOR SUCH PLANNING, AND EXECUTION OF SUCH PLANS, INCLUDING PROVISIONS FOR EVACUATION OF ALL SEGMENTS OF POPULATION AND PROVISIONS FOR THEIR SHELTER The committee addressed the issue of financing for the planning, acquisition of supplies, equipment, facilities, and personnel, and for the execution of such emergency preparedness and evacuation plans at its March 2, 1987 hearing. Due to the inherent interrelationship between the issues of preparing the plans and the financing for the plans, the committee decided to hold a comprehensive hearing on both of the issues. A complete list of all those who testified, and a detailed discussion of their testimony can therefore be found under TOPIC 4 above.
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TOPIC 6 THE CLARIFICATION OF JURISDICTIONAL QUESTIONS AS BETWEEN / STATE AGENCIES AND BETWEEN THE COMMONWEALTH, ITS SUBDIVISIONS, AND THE FEDERAL GOVERNMENT OF THE UNITED STATES The committee addressed the issue of jurisdiction between agencies of the state and federal governments at its hearing on February 2, 1987 at 10:00 a.m. in Gardner Auditorium, State House, Boston, Massachusetts. The committee sent a written request to testify before it to the following individuals:
- 1) Governor Michael S. Dukakis; j l
- 2) Martin Malsch, General Counsel, Nuclear Regulatory Commission;
- 3) Sharon Pollard, Secretary, Executive Office of Energy Resources; Wayne Kerr, State Programs Office, Nuclear I 4)
Regulatory Commission;
- 5) Lee Breckenridge, representing Attorney General James Shannon;
- 6) Peter Agnes, Assistant Secretary, Department of Public Safety;
- 7) Gerald Parker, Assistant Commissioner, Department of Public Health; and l 1
1
- 8) William Abbott, Plymouth County Nuclear Information Committee Secretary SHARON POLLARD speaking on behalf of Governor l Dukakis and her office reiterated that the Pilgrim facility not resume operation unless all reacter safety issues and management
' deficiencies are fully resolved, and until adequate emergency response plans are in place. She declared public health and safety to be' the principal criteria governing decisions regulating the restarting of the Pilgrim plant. j 1
She testified that the division of authority between federal i and state government in legal and jurisdictional matters regarding i the regulation of nuclear facilities is complex and not clear-cut. Although federal law states that on-site safety is a federal l l l l E l - ~_
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responsibility, state government is responsible for off-site l safety. She continued that the state also has the right and the responsibility to insist that the plant be constructed properly and operated safely, and that the evacuation plans be adequate. Secretary Pollard expressed her strong concern that the Nuclear Regulatory Commission has not been consistent, vigilant, and agg'ressive enough in its oversight of reactor safety. While relieved that the NRC has publicized and continues to monitor Boston Edison's performance at Pilgrim, she stated that the history of problems leading to today's situation should never have been allowed to develop. She maintained that despite any federal pre-emption of certain aspects of the regulations of nuclear plants, the Commonwealth's posit' ion is that they are constitutionally responsible for the protection of the public health and safety of its citizens. She reported that at least the following six state agencies are involved directly or indirectly in overseeing various aspects of nuclear power issues:
- 1) The Executive Office of Energy Resources has broad statutory authority to " advise, assist, and cooperate with state, local, and federal agencies in developing appropriate programs and policies relating to energy planning and regulation in the Commonwealth." (M.G.L. c. 28a, Sec. 6)
- 2) The Massachusetts Civil Defense Agency, within the Executive Office of Public Safety, is responsible for preparing emergency preparedness and response plans which would protect citizens in the event of an accident at a nuclear plant. (M.G.L. c.
App., Sec. 13-2B)
- 3) The Division of Inspections, also within the Executive Of fice of Public Safety, i's responsible for licensing nuclear power plant operators and engineers. (M.G.L. c. 146, Sec. 50A-C)
- 4) The Department of Public Health is responsible for operating a monitoring and surveillance program for all nuclear reactors. (M.G.L. C. 111, Sec. SK)
- 5) The Cepartment of Public Utilities, within the Executive Office of Consumer Affairs and Business Regulations, has general supervision.over all electric companies, and must " ... keep itself informed as to the condition of properties...and the manner in which they are conducted with reference to the safety and convenience of the public." (M.G.L. c. 164, Sec. 76) The DPU also regulates the rates which electric companies may charge for electricity generated from any source. (M.G.L. c. 164, Sec. 94)
- 6) The Energy Facilities Siting Council coordinates the siting of new energy facilities within the Commonwealth and requires electric companies to file annual forecasts which describe how the companies will provide the electricity needed to serve their customers. (M.G.L. c. 164, Sec. 698-R)
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In conclusion, Secretary Pollard urged the committee members to' support. funding in the upcoming budget for a nuclear safety initiative to supply the Commonwealth with the needed resources to engage in emergency planning, monitoring, and regulation of licensed nuclear power plants. 4 WAYNE KERR speaking on behalf of the Nuclear Regulatory and Martin Malsch explained the role of the Office The Commission (NRC) of States Programming and the activities of several states. Office of State Programming is responsible forVarious conducting states play intergovernmental relations between states.Section 274 of the Atomic different roles in. nuclear activities. Energy Act is the statutory basis for the delineation of jurisdiction, and sets the framework for cooperation among states in nuclear matters. There are a number of areas in which states can become involved with nuclear matters.
- 1) Under the Agreement State Program, a state can regulate Twenty-eight states are radioactive materials used in that state.
in this program at this time.
- 2) Monitoring the transportation of radioactive materials.
- 3) Monitoring low-level waste disposal and generation.
- 4) High-level waste disposal monitoring and facility capability. Three states are currently involved in the western United States.
State
- 5) Security, response and training at licensee sites.
and local officials are sometimes involved in training for emergencies and emergency preparedness.
- 6) Active state involvement with the NRC licensee facilities.
There has been a heightened involvement among states in the after math of.Three Mile Island and Chernobyl. Wbenever there is a plant specific problem, state involvement.will usually increase. Various statec have different approaches to the issue of nuclear power. Examples are as follows: i In 1980 the State of Oregon assigned a resident inspector to their Trojan Plant. This was done under a memorandum of understanding between the NRC and the State.
'In Vermont there is one nuclear engineer with their Public Service Commission. This engineer follows the activities of Vermont He follows plant activities on a daily Yankee and any NRC actions.
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basis . Vermont has also set up a Nuclear Advisory Committee to advise the Governor on nuclear issues. The State of Illinois, which is in the process of becoming an
" agreement state", set up a cabinet level Department of Nuclear Safety in 1980. This Department covers the handling of all radioactive materials and regulates radiation machines, transportation, environmental monitoring, and all power plants. The Department has set up direct data links to the power plants, which provide plant parameters, stack monitoring, and environmental monitoring. This agency is made up of 170 individuals.
In Pennsylvania the Department of Environmental Resources l trains nuclear engineers to monitor each individual power plant. ! These engineers are housed in Pennsylvania's B"reau of Radiation j Protection, which numbers about 55 individuals, ten of whom are in their nuclear safety operations unit. One nuclear engineer will follow each specific site. New Jersey has a Department of Environmental Protection, which is now staffing nuclear engineers to perform.an operation similar to that in Pennsylvania to monitor each individual site. Their Radiation Protection Bureau contains about 70 positions, 16 of which are in a Nuclear Engineering Division. New Jersey may consider establishing resident inspectors in the future. In the State of Washington, there is a recent move to create a Department of Nuclear Safety. This Department would cover and perform the same operations that the State of Illinois has been conducting. This state has two uranium mills and a low-level radioactive waste site, along with several power plants. Currently j these facilities are monitored by the Department of Ecology, Social and Health Services, and the Energy Facility Siting Council. In Ohio, Governor Celeste has created an emergency planning review team. Ohio is also contemplating data links to each nuclear j plant. j The NRC has entered into agreements with several states to allow inspections of waste to be transported. The NRC believes that the Stare of Massachusetts still pursuing " agreement state" status, which would allow the state to control over 85% of the generators in the state. This concludes a review of the policies of. states actively seeking more control over nuclear activities in their state. i ATTORNEY LEE BRECKENRIDGE, appearing on behalf of the Attorney General James Shannon, stressed the Attorney General's strong commitment to protect the health and safety of the citizens of Massachusetts, and to make certain that both federal and state laws are carried out to safeguard the public interest.
qc y- ;-- -- ,, , , 7 . 3, .g , % y. , , . I l She noted that the scope of state and federal regulatory powers has been the subject of much recent litigations, and that the delineation of state and federal authority over nuclear facilities will continue to be litigated in years to come, as states enact laws or take actions that affect the production and use of nuclear pow,e r. Because of the substantial possibility that the Commonwealth itself may.become involved in this litigation in the future, she limited her remarks to past developments in the law. I Attorney Breckenridge continued her testimony on specific federal and state case law as follows: The Supreme . Court case law confirms that federal legislation does not preempt the historic police powers of states unless Congress clearly manifests its intention to do so. And conversely, if Congress acts within Constitutional limits, it can preempt state authority by stating expressly that it intends to do so. With respect to nuclear facilities, Congress has been quite explicit in preserving some state regulatory authority. Under the Atomic Energy Act states retain the power to regulate the
" generation, sale, or transmission of electric power from nuclear The Nuclear Regulatory facilities." (42 U.S.C. Sec. 2018).
Commission has control,over "the construction and operation" of nuclear facilities, but this grant of federal authority does not affect "the authority of any state or local agency to regulate activities for purposes other tank protection against radiation hazards." (42 U.S.C. Sec. 2021). The major Supreme Court case interpreting the scope of the State authority preserved to the states is Pacific Gas & Electrie v. 190 Energy Resources Conservation & Deveicoment Commission, 461 U.S. (1983). The Court in the case upheld California's authority to impose a moratorium on the certification of new nuclear power plants under the State's regulatory system. The Court accepted California's avowed economic concerns about the lack of approved means for nuclear waste disposal as a legitimate basis for the moratorium, even though the effect of the moratorium was to preclude construction of nuclear facilities. The Court's opinion draws a distinction between the economic matters that the states may continue to regulate, and the nuclear safety concerns that are regulated by the Nuclear Regulatory Commission. The Court concludes that under the Atomic Energy Act, Congress 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 and utilities for determining questions of need, reliability, cost, '
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other related state concerns." 461 U.S. at 207. Stating the same conclusion another way, the Court says that " Congress has preserved the dual regulation of nuclear-powered electricity generation: the Federal Government maintains complete control of the safety and
' nuclear' aspects of energy generation; the States exercise their traditional authority over the need for additional generating capacity, the type of generating facilities to be licensed, land
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v .m.; ,. zx ' use, ratemaking, and the like." 461 U.S. at 212. The determinative factor in the Court's decision to uphold California's authority was that the moratorium was grounded on economic considerations rather than safety concerns. The other major Supreme Court decision upholding an exercise of state authority is Silkwood v. Kerr-McGee Corp., 464 U.S. 238 (1984). The Court there found that a jury award of $10 million in punitive damages should stand, even though the availability of i punitive damages under state law turned in part on nuclear safety j questions. l The federal regulatory scheme itself also explicitly l preserves some kinds of state authority over health and safety j matters, specifically, the exercise of police powers in the event of j a nuclear accident. The regulations require that the plans for a ; nuclear facility provide " reasonable assurance that adequate ' protective measures can and will be taken in the event of a radiological emergency." 10 C.F.R. Sec. 50.47(a) (2). The state remain free to plan for and carry out police power functions in the vicinity of nuclear power plants; and indeed, the Nuclear Regulatory Commission's at41ysis under its regulations focuses on the extent to which state and local governments can and will perform various tasks in the event of an emergency. As you know, the implications of this state emergency planning function remain the subject of ongoing litigation over the licensing of both the Seabrook and Shoreham nuclear power plants. Assistant Secretary PETER AGNES of the Department of Public Safety (DPS) addressed the committee on the Department's jurisdictional position. Mr. Agnes testified that Secretary Barry had released an in-depth report on December 17, 1986 on the state's role in oversight of nuclear power facilities. The report presents a history and outline of various actions taken by those state agencies responsible for nuclear oversight; namely, the Department
'of Public Saf ety and the Department of Public Health. The report specifically states the DPS's views on the role that should be played and the steps that should be taken by, Boston Edison Company in preparing plans for emergency preparedness. The report also stresses the DPS's belief that the Federal Emergency Management Agency should create federal standards for these plans.
Assistant Secretary Agnes further testified that the DPS has statutory authority under the provisions of Chapter 796 of the Acts of 1979 to provide the guidelines for the Civil Defense Agency, emergency planning, and state off-site monitoring. On the point of off-site monitoring, the DPS has been researching current monitoring systems, most notably a system being utilized in the State of Illinois. Assistant Secretary Agnes stressed that the tools are in place statutorily for the Department of Public Safety and the Department of Public Health to properly conduct mon'itoring and
ww. w. g. = x. s .. w w c. .. ~ . . . . , . ,~ , , , - . . . . E i public safety provisions. The Governor's nuclear initiative will bring together the responsibilities of these two departments. The initiative is concentrating on emergency preparedness, monitoring, and new nuclear engineering.- Mr. Agnes concluded that under this initiative the state would assess the utilities for the cost of the programs. MR. GERALD PARKER, Assistant Commissioner of the Department of Public Health testifying on behalf of Commission Ballus Walker, Jr., and the Department of Public Health. The summary of testimony was as follows: The Department of Public Health has been conducting extensive monitoring activities in the vicinity of the Pilgrim nuclear power plant in Plymouth since the 1970's. Since 1980, at 46 locations, the DPH has had thermo-
. luminescent dosimeters (TLD's) which, measure gamma radiation exposure at each site over a three month period. These detection devices are maintained and counted by the DPH, the Nuclear Regulatory, or the Boston Edison Company. Of these, 24 are Department of Public Health stations, 36 are Nuclear Regulatory stations, and 17 are Boston Edison stations. A number of these ars located jointly. These TLD's are changed quarterly and information from these detection devices would indicate any increase in gamma radiation exposure above background levels to individuals living within a five mile area.
Also since 1980, the Department has had a cooperative agreement with the NRC in which continuous air monitoring at Pilgrim is conduct: ., as well as periodic environmental sampling, including water, miix, food, fish and sediment. Staff members of the Department's Radiation Control Program make weekly inspections at Pilgrim, which include a review of the previous week's activities at the plant with the resident Nuclear f Regulatory Commission inspector, the plant chemistry supervisor, che plant engineering supervisor, and the plant public relations officer. Most importantly, during this weekly visit the inspector reviews documentation of all recent environmental effluent releases and looks for any releases of radioactive material, any contaminated i areas, any contaminated workers, and any new pathway for radioactive releases. )
' i The Department forwards copies of a monthly report of environmental results and plant inspection results to the Plymouth Public Library, and also sends an annual report of all environmental results to the Nuclear Regulatory Commission. Mr. Parker concluded by stating that these acts are in fulfillment of the duties set forth by Chapter 111 of the, Massachusetts General Laws for the j Department of Public Health.
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ATTORNEY WILLIAM S. ABBOTT discussed the ramifications of the following precedent-setting legal cases in an effort to define the scope of state autnv ity to regulate nuclear power facilities. He testified that Northern States Power Company v. Minnesota is the first case dealing squarely with the issue of federal ; pre-emption in the area of nuclear safety regulation. In this case the Northern Power Company sought a waste disposal permit f rom the Minnesota Pollution Control Agency. The permit was issued subject to conditions limiting the discharge of radioactive pollution into i the ambient air to levels lower than those allowed by the Atomic l Energy Commission (AEC). The Federal District Court ruled that this was expressly pre-empted by-the Atomic Energy Act of 1954. This ruling was further upheld on appeal to the Eighth Circuit Court and the Supreme Court on the grounds of implied rather than express pre-emption. Mr. Abbott stated that Congress later overruled this decision legislatively by passing the Clean Air Act Amendments of 1977. Under Section 122 of these amendments, the regulation of radioactive air pollution from nuclear power plants was transferred from the l Nuclear Regulatory Commission to the Environmental Protection Agency (EPA). Because radioactive emissions are thus classified as air pollutants,-states may independently regulate such emissions pursuant Section 116 of the Clean Air Act. - Mr. Abbott also noted that the NRC has clearly articulated the scope of state power in Consolidated Edison Company of New York, Inc. (Indian Point Station, Unit No. 2), ALBA-453, 7 NRC 31 (1978) in that " ... states may establish and enforce emission standards for radioactive pollutants into the air either under the Clean Air Act l itself or under State law." Furthermore, in both Pacific Gas and Electric Co. v. State Energy Resources Conservation & Development Commission, 102 S.Ct. ; 17(3) (1983), and Silkwood v. Kerr-McGee Corp., 104 S.Ct. 615 (1984), the Supreme Court has recognized that the Clean Air Act represents an area where Congress has specifically delegated to the States authority to regulate nuclear plant safety. He concluded that is seems beyond question that a state may establish maximum emission levels for radioactive pollution lower than those established under Federal law, and that it is equally clear that a State is free to enforce such levels, even if such enforcement leads to the closing of an existing facility. 1 i The committee received, after the February 2, 1987 hearing, l the following information from the NRC regarding enforcement { petitions and possible radioactive material releases at Pilgrim. With regards the the former, the statistics are as follows: l i l l Till____ ______T__Mll'__ _ __ J -- )
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Pilgrim Nuclear Power Station ...a i aem;t- , ",,*g : Unit 1 oistotolot 29l386 1 i 0 l 2l3 - 0 :0 012 or 0 l3 ftKT fa aiene asess s enousse oss - 48C Arm JE8'eslUI While performing a surveillance of fire penetration seals on 9/5/86, as described in t.ER 86-020 entitled " Unidentified Fire Barrier Walls and Penetrations" a deficient fire seal around a HVAC Ouct in the screen house was identified. A continuous fire watch was ordered on 9/5/86, as required by the Technical
. Specifications Section 3.12.F.
On 9/12/86, during a routine station walkdown the Pilgrim Nuclear Power Station (PNPS) Fire Protection Engineer discovered that the screen house fire watch was not manned. Immediate corrective action was to establish the required watch. Further investigation showed that the screen house fire watch had not been manned since it was orcereo on 9/5/ M . A review of fire watch occuma.tation oy tne N S Fire Protection and Prevention Officer (FPPO) verified thit all other fire watches which had been ordered were manned. The fire watch persontel'were subsequently admonished of their responsibilities to establish fire watches as directed and appraised of the seriousness of oversights of this nature. On 10/1/86. additional problems with the fire watch program became apparent. A review of fire watch patrol sign-in sheets identified 17 discrepancies where hourly patrols were not documented for periods of one to three hours. However, the results of follow-up investigations indicate that the fire watch patrols were performing their intended function but neglected to document their actions. Cause The recent problems with providing documentation of fire watches at the intervals required by the Technical Specifications have been attributed to (1) recent increases in the number of fire watches required. (2) contractor difficulties in meeting the increased staffing requirements in a timely manner, (3) the inexperience of the newly hired fire watch patrol personnel (4) the lack of supervision provided by the fire watch contractor and (5) insufficient Boston Edison Company (BECo) manageme'nt oversight of the fire watch process to identify and resolve potential problems prior to a program breakdown of this nature. Corrective Action Immediate corrective action was t'o ensure that all fire watch patrols were adequately manned and maintained. Subsequently BECo management has provided increased direct oversight of the contractor fire watches. Fire watch personnel have been formally briefed of the identified problems and have signed documents attesting to their understanding of fire watch requirements. BECo is evaluating . the adequacy of the organizational structure, staffing level, and training needs of-the Fire Protection and Prevention Program to meet the current and long term goals l of the Nuclear Organization. Safety Consequences Fire watch patrols are established as a compensatory measure to survey area (s) in which the active and/or passive fire detection, suppression or barrier system (s)
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are in a degraded mode. In such cases fire watches are utilized for detection and reporting of fires. The fire watch patrols identified in this report were established as a result of possible deficiencies in the passive fire barrier systems.
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Unit 1 l o is t o lo Io ! 219 l 3 8 16 .- 0 E l3 --1010 O!3 0F 0 !3 _ e w m.wim ruW Udtrier systems are required by 10CFR50 Appendix "R" to provide separation of redundant safe shutdown systems. Safe shutdown systems are those systems which must operate after a loss of offsite power and are required to achieve and maintain safe shutdown conditions. A functional fire barrier is the barrier itself with all penetration seals, doors and dampers intact. This design feature minimizes the possibility of a single fire rapidly involving several areas of the facility prior to detection and extinguishment. It has been BECo's practice to establish fire watch patrols when a defect has been notea in a tire parrier witnout regar1 to Ine acequacy of tne fire carrier to perform its intended function. Engineering analysis has not been performed to determine the adequacy of the subject fire barriers in their existing condition or to determino if the subject fire barr'ers provide separation of systems required to maintain the reactor in a cold shutdoun condition. Therefore, without specific
- .;ir.:: ring analysis to determine the true effect penetration seal degradation has on a given boundary, BEco treats the subject fire barriers as if they would not prevent a single fire from rapidly involving redundant areas required to maintain the reactor in the cold shutdown condition.
The suspect penetration seals represent a small percentage of the fire barrier g systems at PNPS. Therefore it is reasonable to assume that (1) the functional fire barriers in combination with (2) administrative procedures, (3) operable fire j detection systems, (4) automatic fire suppression systems, and (5) trained fire 1 brigade personnel would be sufficient to limit the spread of a postulated fire. Due to the designed redundancy in safe shutdown systems, the ability to prevent core damage and/or increased radiation releases to the environment, would be maintained. The missing documentation for fire watch patrols represents a temporary degradation in the overall Fire Protection and Prevention Program. This program like all of
*"a ***e+6r protection systems are built on a defense in depth principle.
Therefore SECo believes that the program was adequate to assure safe operations of the reactor and at no time was the public health and safety compromised. l s e
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i.e s .ve C" us Bc0 5 rst: it'e+' 5:s v ?/assa:Nse"s c2'99 James M. Lydon - c e'ocera:rg o"icer February 23, 1987 BECo Ltr. #87- 32 U.S. Nuclear Regulatory Commission Attn: Document Control Desk F n 9 ng t:.a. , D.C. 20555 Docket No. 50-293 License No. OPR-35
Dear Sir:
The attached Supplement Licensee Event Report (LER) 86-025-01 "Mi -alignment of the Fire Suppression Water System and Inoperable Pumps" is hereby submitted in accordance with the requirements of 10CFR50.73. This supplement report is provided to address. fire pump operability problems identified subsequent to the original issuance of this LER and to address tile special report i i requirements of the Pilgrim Nuclear Power Plant Technical Specifications. If there are any questions on this subject., please do not hesitate to contact me. Respectfully submitted, gn % - James M. Lydon [ l BPL/la .
Enclosure:
LER 86-025-01 cc: Dr. Thomas E. Hurley Regional Administrator, Region i U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 Dr.'M. McBride l Standard BECo LER Distribution 1
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2.206. PETITIONS RECEIVED AND PUBLISHED DECISIONS ON THEM 1974-1986
- Petitions Granted in Whole Received- or in Part Partial Deferral Year 189 24 Undetermined 1974-1982
- 27. 3 1 1983 3 2 1984 26 1985 12' 1 11 1 1986 3 265 32 ,
*If several petitions were considered in a single decision, for.the purposes of this listing they are counted as one petition.
The Department of Public Health forwarded to the committee an update of the GPH's monitoring activities (see Appendix 6) and a description of the role of DPH in Emergency Response at Nuclear Power Plants-(see appendix 7). k r 46-1
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g_- ..m- _ _ .- , . - _ . _ s m. , _ . . . _ TOPIC 7 THE EFFECT OF THE PRESENCE OF THE PILGRIM NUCLEAR GENERATING FACILITY ON THE MUNICIPAL FISCAL AFFAIRS OF THE TOWN OF PLYMOUTH AND SURROUNDING COMMUNITIES The committee addressed the issue of the effect of the Pilgrim Nuclear Generating facility on the fiscal affairs of Plymouth and surrounding communities at its hearing on April 6, 1987 The at 10:00 a.m. in Room 462, State House, Boston, Massachusetts. committee sent a written request to testify before it to the following individuals:
- 1) Paul Levy, Commissioner, Department of Public Utilities;
- 2) William Griffin, Executive Secretary, Town of Plymouth Selectmen's Office;
- 3) Mary Ford, Tax Assessor, Town of Plymouth;
- 4) Charles Berg, CURE; and .
- 5) Rachel Shimshack, Mass. FIRG MR. PAUL LEVY, testified that the cost of shutting down the Pilgrim nuclear reactor could exceed $1 billion after calculating the value of the plant and the cost of replacement power.
Estimating the plant's value, he cited the following figures: ORIGINAL COST S231 (in millions) CAPITAL ADDITIONS S493 5724 (minus) $153 DEPRECIs. TION S571 NET WORTE OF PLANT The shutdown presently costs Boston Edison $200,000/ day in replacement energy costs, and costs Commonwealth 1 Electric, which buys power frcm the Pilgrim reactor, S30,000/da-(. The total cost of the shutdown could reach well over $100 million. When asked if Boston Edison rate payers or stockholders would
- be responsible for the cost of the shutdown, Mr. Levy replied that if the Legislature passes a bill forcing the permanent closing of the Pilgrim plant, not as a result of mismanagement but as a result of some new environmental standard, Boston Edison customers would have to pay, because it would be very hard for the Department of Public Utilities (DPU) to rule otherwise. If, however, the NRC m e ..m.m... =e e.eein.m *wses e ai-..e *=ismsw em
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~I rules that the plant remain closed because of mismanagement, the DPU will have more authority to hold Boston Edison stockholders responsible for some portion of the costs. Mr. Levy said the DPU, which sets rates for utilities in Massachusetts, will not review the question of who will pay for the cost of the shutdown until the plant resumes operation, possibly in August.
He remarked that the Commonwealth can meet its energy needs without Pilgrim (and Seabrook) with the implementation of intensive conservation and load management programs, and the aid of new facilities and cogeneration. He noted that Boston Edison consultants reported that there is the potential for 1,000 megawatts worth of energy cons.ervation in Boston Edison's territory. MR. WILLIAM GRIFFIN, Secretary of the Plymouth Beard of Selectmen, and MS. MARY FORD, Assessor for the Town, jointly presented the following testimeny: Finances for the Town of Plymouth reflect a fast growing residential community. Plymouth's annual tax levy is $34 million, with a total valuation of S1 billion. The Pilgrim Nuclear Power facility represents 35% of this valuation, or S10 million annually. The Town of Plymouth is presently conducting a revaluation, of which Pilgrim oill represent a valuation slightly less than what is currently assessed. The town is also confronting a 56.9 million nyerride of Proposition 2 1/2, which is pending. It is extremely difficult to determine the ramifications on the town should Pilgrim close. On one hand, Boston Edison owns a very large amount of land in Plymouth that could become available for development if the plant closes. This would add to the tax rate. There is also a training center that could become available for use. , On the other hand, one must consider that monies lost with the closing of Pilgrim would constitute the amount of the override taking place this year. The town's population has grown from 18,000 in 1970 to approximately 42,000 at present. The town is in need of revenue to open a new high school, and other services must be paid for. An important point to consider is that improvements made to the plant have been regarded as new growth on the tax levy. Boston Edison is an integral part of tha tax base, and if the plant is closed, the burden is cast upon the taxpayers. If this happens, the town will be very close in covering its costs. The town would be required to shift the tax revenue collection to another part of the total valuation.
_,.=m=.- -a u a .w .. u ~ ~. .w.. . The Assessor stated that the Pilgrim's value is assessed at
$305 million for the plant, and a combined $448 millien total valuation for the plant and land. At a 100% valuation, the figure would be approximately 5550 million.
MR. CHARLES E. BERG, of Citizens Urging Responsible Energy, Inc. (CURE) expressed the view that the permanent closing of The Pilgrim would not spell economic disaster for the Town of Plymouth. greatest impact of the plant's closing would be felt on local property tax rates. In the property revaluation that is about to take place by Plymouth assessors, CURE predicts that Boston Edison's share of local property taxes will decrease from 36% to 20% of the total, because (1) the value of residential and commercial property has the more than doubled since the last revaluation in 1978, and (2) replacement cost of Pilgrim must begin to be depreciated to reflect the fact that the plant has a predictable useful life, at the end of which, it will have little, if any, economic value. the Without Pilgrim's 20% share, he further predicted that average homeowner would face a 25% increase of Si a day, or $365 a This increase would be greater year, based on this year's tax levy. if town spending increased. the Mr. Berg acknowledged that, should Pilgrim close, resultant loss of jobs and the ripple effect to the local economy would be serious, but not as grave as losses suffered during the closing of the town's textile mills in the 1950's and of the Pilgrim Cordage Company at about the same time. In conclusion, Mr. Berg stated that if Pilgrim closes today or at the end of its natural life cycle in the late 1990's, the day will come, sooner or later, when the plant is no longer a major source of tax revenue or employment for area residents. He advised the town of Plymouth to prepare for that day now in order to preserve a strong local economy. l { RACHEL SHIMSHACK presented testimony representing the In the ! Massachusetts Public Research Interest Group (MassPIRG). I opinion of MassPIRG, one cannot gain a clear view of nuclear power without looking at all costs related to nuclear power generation. Although nuclear powerTheoretically is inexpensive, onesubstantial can expectcosts are a nuclear continually added on. generating plant to run at 80%Companies of its capacity; in reality, a plant are forced to make up the operates at an average of 53%. difference in this percentage of power generation by purchasing power from another source, which proves to be costly.
I i 1 ( Fuel costs, operating and maintenance expenses, and recent major repairs have been expensive. Repairs since the plant came on line in 1972 have reached 5493 million. Other problematical questions that have arisen from ccelear power generation are: (1) Where will high-level radioactive waste (2) What will be be disposed and when will a facility be available? the cost of disposal? A third unanswered question is, "What is the cost of decommissioning a 1,000 megawatt plant?" Estimates on decommissioning range from 50 million to 3 billion. One cannot answer this accurately because no plant has ever been decommissioned. Additional costs that may be incurred relate to the possibilities of severe accidents at a plant. Costs associated with an accident at the Pilgrim plant are estimated at $80 to $100 billion. The federal government's " Price Anderson Act", which is now under review, is another considerable cost to consumers related to nuclear power generation. Many savings associated with the closing of the Pilgrim plant are as follows: (1) elimination of fuel costs; (2) elimination of maintenance and repair costs; (3) discontinuance of production of nuclear waste and disposal cost; and (4) the cost of decommissioning is said to be less if a plant is shut down at the midpoint of its estimated useful life. It is stated in a 1984 report, that retirement of a twelve year old Robinson II plant would reduce the cost of decommissioning by 16%. This study was performed by the Energy System Research Group (ESRG). MassPIRG believes that the power generated by the Pilgrim facility can be replaced by using effective measures of conservation. Boston Edison commissioned an outside report that pointed out that Boston Edison could save 1,000 megawatts through aggressive load manang=ent and conservation measures. These programs could be implemented immediately if Boston Edison commits its resources to these measures. Based on previous testimony regarding tax rates in the Town of Plymouth, MassPIRG concludes that revenueFurthermore, lost from closing the MassPIRG Pilgrim plant could be raised by taxpayers. believes that the plant should remain closed until health and safety issues, which are crucial, are resolved. s
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ADDITIONAL MATTERS In addition to the seven specific topics enumerated in Senate Order 2044, the Committee decided to hold hearings on the issues of plant operations and energy forecasting; a separate hearing was held to provide the committee with a Pilgrim Status Report. 1 e
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c . . .-. . . - . . .. - , , , .. . I I i l l PLANT OPERATIONS The Committee held a hearing on the technical operations of the Pilgrim Nuclear Generating facility. Committee members sought a j f detailed, technical explanation of the operating procedures for the plant. The hearing was on January 27, 1987 at 10:00 a.m. in Gardner 3 Auditorium, State House, Boston, Massachusetts. The committee sent a written request to testify before.it to the following individuals:
- 1) William Armstrong, Nuclear Engineer, Boston Edison Company; and
- 2) Carl Gustin, Vice President of Corporate Relations, Boston Edison Company All of the individual testimony that was heard at this time will be summarized and documented in the final report.
At this time the committee had requested that Boston Edison Company provide the committee with an explanation of physical plant operations at the Pilgrim Nuclear Power Plant in Plymouth, Massachusetts. Mr. William Armstrong provided a presentation of charts which are provided below and answered many of the committee's questions concerning operations. Mr. Armstrong's charts provided an in-depth look at the plants mechanical outlay. The charts are as follows:
- 1) Nuclear fission: How it works in the generation of electricity;
- 2) Pilgrim Station Site Layout;
- 3) Reactor Water Level;
- 4) Water Systems;
, 5) Fuel Assembly;
- 6) Reactor, Auxiliary and Turbine Buildings;
- 7) Reactor Cut-Away;
- 3) Reactor Top and Crane; and
- 9) Fuel Pellet L___________
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ww c,.w.o.= . =. -m wxru.u :. ,x :- .~ ~ w :: .- -- -x.:::a . . . . = . , ce v -- : .r. . ; = c-1 i Questions directed at Boston Edison that'could not be answered at this-hearing were later responded to through , correspondence received by the. chairmen from Carl Gustin, vice l
~ President of Corporate Relations. The questions and response were as follows:
- 1) HOW LONG CAN PILGRIM STATION CONTINCE TO STORE-SPENT FUEL?
9 The spent fuel storage capacity at Pilgrim station will last, at least, until tho' year 2010. This is well past the current license expiration date of the plant. Storage capacity of spent fuel'at Pilgrim is not a problem. ,
- 2) WHAT PERCENTAGE OF TIME HAS PILGRIM ACTUALLY PRODUCED ELECTRICITY SINCE IT BEGAN OPERATIONS IN 19727 Since it began operations in 1972, Pilgrim station has produced some amount of electricity 63% of the time, and it has produced the equivalent of all its potential output 53% of the time. The committee is provided with a complete record of Pilgrim station's operating performance since it began operations (see pages 63-65). An explanation of some of the. terms that are in that performance report is supplied on page 66.
It was also requested of Mr. Gustin by the committee a list of unusual events and an alert on Pilgrim Station. See Appendix.8 for this information. l i 1 1 l i i
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t , AN EXPLANATION OF THE TERMS " AVAILABILITY FACTCR" AND " CAPACITY FACTCR" Attached is a report on the performance of the Pilgrim Nuclear Power
' Station since it began commercial operation in 1972. In order to understand tlie report, two terms have to be explained. They are " Availability Factor" and "Cacacity Factor". j Availability Factor: The amount of time a unit is capable of producing some. amount of electricity divided by the total time period. Or, the amount of time a unit is available to produce some amount of electricity.
Amount of time unit is capable of producing scme Availability Factor - amount of electricity Total time perioc Capacity Factor: The ratio of energy actually produced to that which would have been produced.in the same perioc had the unit operated continually at its highest level. Capacity Factor . Amount of electricity unit actuallv creducsd . Amount of electric 1ty tnat would nave Deen produced if unit had run at 1007. during entire period The Pilgrim Nuclear Power Station since it began operations in 1972 has achieved an availability factor of 62.7*. and a cacacity fact:r of 52.9*.. To put this in the terms that were used at the recent committee hearing,. If the time period since 1972 . vere considered to be 100 days, then Pilgrim would have been ;ro ucing s:me amount of electricity :n a::coximately 63 of those days, and it would have procucea the equivalent of ICC". of its potential electricity on approximately 53 of tnose 100 days. The availability factor is always larger than the cacacity factor because a unit is gradually brought up to full power and gradually brought down during i shut downs. Also, certain tests are run at less than full power. s ____u__.__.___.____..____
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9 TOPIC 9 i
Me , . e 9 .
m-pyma,wy v ,,, _,, ; c mw m , e. f .~ 2 m ,s , -; g m , m , I 1 i l l FORECASTING
- The committee held a hearing to address the issue of forecasting electric energy demand and supply. The committee j
decided such a hearing was required dueThe in part to the uncertain hearing was held March j future of the Pilgrim Generating plant. ' 30, 1987 at 10:00 a.m. in Gardner Auditorium, State House, Boston, Massachusetts. The committee sent a written request to testify before it to the following individuals:
- 1) Richard S. Hahn, Manager of Supply & Demand Planning; Boston Edison Company 2 ). Sharon Pollard, Secretary, Executive Office of Energy Resources;
- 3) Gerald R. Brown, Directory of External Coordination, New England Energy Pool; and
- 4) James Stetson, Legal Counsel, Departmeng of Public Utilities The purpose of MR. RICHARD HAHN's testimony is to summarize the Company's current long range resource plan and to show tPTt Pilgrim is an important energy source within that plan. Pilg~im's generating capacity is 670 megawatts. Boston Edison sells approximately 170 megawatts to other electric companies in Massachusetts. The remaining 500 megawatts service Boston Edison's customers.
Mr. Hahn reviewed with the Committee four exhibits (see pages 68-71). Exhibit I-1 graphically depicts the Company's latest Long Range Resource Plan; Exhibit I-2 details Peak Lead Reduction; Exhibit I-3 details Boston Edison's Cogeneration /Small Power Production Contracts; and Exhibit I-4 A Long Range Resource Plan assuming Pilgrim is unavailable. If Pilgrim were removed f rom service, Mr. Hahn states, two types of costs would be incurred. The Thia first is replacement energy type of cost is incurred costs or replacement power costs. when the plant is down temporarily for maintenance to replace the lost kilowatthours. Pilgrim currently incurs approximately $75 million for replacement energy costs at today's low fuel prices at
$15/ BBL.
The second type of cost incurred is replacement capacity costs which is the money needed to build a new power plant to I replace one that has been permanently shut down. To replace The Pilgrim, the cost would be in excess of $1 billion dollars. time period to build a new plant would be six to twelve years.
. . - - - - - - - - - - - - - . _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___ __ [
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m m .= w w.- - : m,,.m . . . .::w. w .. a ~ . ~ , ., a . . = .w . EXH888T f-2 Peakloadhductioil 2000 CONSERVATION MW LOADMANAGEMENT MW ! Apt.PublicLtg. 6.8 TheralStorage 12.4 Res.Circlite22 0.9 GeneratorAssistance 6.8 Eff Refrig. 6.7 G-3 Load Curtailment 35.6 Eff.HeatPumps 1.3 G-2LoadCurtallment.19.4 l 34 Fluorescent 25.3 G-1 EMS 0.6
. 28 Fluorescent 14.4 Res. EMS 0.2 Compactfluorescent 4.5 G-1AlCInter 1.9 EmergencyExits- 11.8 Res.CentralAl0Cy 11.1 OpticalReflectors 2.4 Res.RoomAlCCy 25.8 Eliptical Lamps 2.2 Res.WaterHeater 7.2 DaylightControl 4.0 SwisingPoolPumps 3.8 MotionSensor 0.4 Solarfilm 7.2 -
i Com'l Heat Pump 1.2 fluor.Lt. Current Delimiter 1.4 . Com'lEff.AlC 0.3 ' SecurityLtg. 11.0 Eff. Motors 8.0 EASY . 25.9 ENCORE 3.4 . BHA 2.6 i
, TOTAL 141.7MW 124.8 TOTALLOADRE0VCTION 266.5MW RESERVEMARGIN 141 ,
GPACITY NEED REDUCTION 304 MW
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EXHIBIT I-3 4 C0 GENERATION /SMALLPOWERPRODUCTIONCON1RACTS SizelBECoEntitlement NW _ Status IDENERGY 10 DPUApptvi.e EverettEnergy 80 DPUApproved NortheastEnergyAssoc. 165/100 DPUApproved Feat Products 23- DPUApproved - Power Recovery - Weymuth 11 DPUApproved , PowerRecovery-Quincy 11 DPUApproved GullMountain 2 Signed AmericanREF-f0EL 38 underNegotiation Bio-Energy 37 UnderNegotiation Re(cestforProposal 23 SolicitationEnds5/15l87 Total of BECo : i Entitlement 512MW j l
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G .. V: .w',. ' s . . , , Mr. Hahn states that the total cost of a Pilgrim shut down would be $325 million a yea:. If these costs were added to the total company revenues of approximately $1 billion dollars, an increase of 30% would result in the cost of electricity. Pilgrim is an integral part of the Company's least cost resource plan and is needed to meet the electricity needs of Massachusetts, concluded Mr. Hahn. Massachusetts State Secretary of Energy SHARON POLLARD testified that Massachusetts can meet its energy demands through the year 1991 without building any new power plants and with Pilgrim Nuclear Power plant remaining down, as long as the Seabrook plant comes on line. She further testified that the Pilgrim Nuclear Power plant would not be needed providing utilities increase and improve conservation programs and measures; a new 200-megawatt gas-fired plant comes on line in Rhode Island and the recently closed plants in Maine and Connecticut are reopened. These measures could avoid an energy shortage in New England if Seabrook never comes on line. Pollard said that without the two nuclear plants up to 463 megawatts of power, even if the other measures are taken, would be needed annually. She concluded that this summer we could experience some power problems because several plants are scheduled to be refueled and there may be a need for a voltage cutback. But, she noted, there will not be any brownouts or blackouts. Secretary Pollard briefly reviewed Table I, II, IIIa, and IIIb with the Committee. For these tables see pages 73-76. GERALD BROWNE, Director of External Coordination, New England Power Pool (NEPOOL) testified before the Committee on the future needs of Massachusetts. He stated that New England's energy requirements have increased nearly 20 percent in the past four years. NEPOOL participants expected that they could receive emergency assistance from neighboring systems; however, very little emergency power may be available from adjacent pools. As a result, Mr. Browne states, it now appears likely that there will be
~
~ shortagas in generating capacity available to meet peak load and the requir?d operating reserve in NEPOOL in the summer of 1987. He further states that the pool's annual maintenance schedules indicate that in virtually every week of the summer, the total installed genbrating uapacity, less planned maintenance outages and a 2,000 megawatt allowance for unplanned outages, will not be adequate to meet the weekly peak load exposure of 18,400 megawatts plus the required operating reserve of approximately 1,725 megawatts.
~~
_ _ = _ _ _ _ _ _ _ _ - _ _ _ _ _ . _ _ - _ _ .
xa=.2.:e , w an..:y 25.; = n~ - x;, : :i.a --::: . n;;gy 7;:;z5x;=ri;a r 7z.;-;;:;m;;- . Table la Based Upon April 1986 CELT Report "3ase Case" New England - Load and Capacity 1987 to 2000
. Assumes 2.1% Demand Growth 1986-2000 Includes SBI and HQII Years 1987 1990 1995 0000
- 1. Lead 18,491 19,494 21,664 23.53;
- 2. Required Capacity 23,040 23,217 26,430 28,- O
'3. Planned Capability 23,728 24,575 25,711 24,785 4 Excess (Deficiency) 688 1,358 (719) (3,985)
Added Re sources - Not in Line 3
- 5. Ocean State I 200 000 ;00
- 6. Add'1. Load Management 20 100-200 200-500 500-1.000 and Conservation ,
7 Add'1. Cogeneration - - 100 300 6 Small Power
- 8. Plant Life Extension * - - 100 500-800
- 9. Subtotal - lines 5-8 20 300-400 600-900 1500- 300
- 10. New Resource . .
0 - 100 1700- 500 Requirement aa
- NOTE: The accompanying Notes are an -integral part of this Table.
aa These resources are described in Section II.C. 5
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ra~irmnjiriz:Lu .. :, , ' ~; ; rW u i;ws: u r.u . T 57-l l l Table iia Short Run " Contingency Case" Scenario 1 New England - Lead and Capacity 1987 to 1991 Assume at Demand Growth for 5 Years No. SBI - No. HQII - Less *50 MW Cap. iiil
-tta Years 1987 1988 1989 1990 1991 H. I!
- 1. Load 18,495 19,235 20,005 20,805 21,637 21.:3~
- 2. Required Capacity 22,342 23,044 23,606 24,238 25,315 25.915 1
j 3. Planned Capability 23,728 24,179 24,514 24,5*5 26,152 26.152 i ! 4 Less 750 MW (750) (750) (750) (750) (*50) (~50)
- 5. Less Seabrook I (1,150) (1,150) (1,150) (1,150) (1,150) '1.150:
- 6. Less Hydro-Quebec II (1,500 7 Net Capability 21,828 22,279 22,614 22,675 22,'52 24,252
- 8. Excess (Deficiency) (514) (765) (992) (1,563) (2,563) (1,563.
Added Resources
- 9. Ocean State I 200 200 220
- 10. Add'1. Lead Manage- 20 80 180 300 430 450 ment 6 Conservation
- 11. Add'1. Cogeneration 6 Small Power aa 340 600 600 600 600 i ; '.'
- 12. Retired Capacity
- 13. New Resource 154 85 212 463 1,333 US Requirementaa*
a The accompanying Notes are an integral part of this Table.
** Included in line 3 above (see Note 3).
a** See. Note 13 and Section II.C. C-- _ . - . - - - ___.m_
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Table IIIa Short Run " Contingency Case" Scenario 2 New England - Load and Capacity 1987 to 1991 Assume at Demand Growth for 5 Years Less 750 MW Cap. Years 1987 1988 1989 1990 1991
- 1. Load 18,495 19,235 20,005 20,805 21,63-
- 2. Required Capacitya 23,045 23,736 24,246 24,779 26,39~
- 3. Planned Capability 23,728 24,179 24,514 24,575 26,152
- 4. Less 750 MW (750) (750) (750) (750) (~50)
- 5. Net Capability 22,978 23,429 23,764 23,825 25,402
- 6. Excess (Deficiency) (67) (307) (482) (954) (995)
Added Resources 7 Ocean State I 200 000
- 8. Add'1. Load Manage- 20 80 180 300 430 ment & Conservation
- 9. Add'1. Cogeneration 6 Small Power a*
- 10. Retired Capacity 340 600 600 600 600
- 11. Net' Excess 293 373 298 146 235 (Deficiency) a The Reserve percentages used in the above calculation are 24.6%,
23.4%, 21.2%, 19.1%, and 22.0% f or 1987 through 1991 respectively reflecting Seabrook I's and Hydro Quebec II's inclusion in Line 3. The remainder of this Table is consistent with Table II. aa ' Included in Line 3 above. i
.- 1
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l I. Table IIIb Short Run " Contingency Case" Scenario 3 New England - Lead and Capacity 1987 to 1991 Assume 4% Demand Growth for 5 Years Less Seabrook I Years 1987 1988 1989 1990 1991
- 1. Load 18,495 19,235 20,005 20,805 21,63-
- 2. Required Capacitya 22,342 23,044 23,606 24,238 25,915
- 3. Planned Capability 23,728 24,179 24,514 24,575 26,152
- 4. Less Seabrook I (1150) (1150) (1150) (1150) (1130)
- 5. Net Capability 22,578 23,029 23,364 23,425 25,002
- 6. Excess (Deficiency) 236 (15) (242) (813) (913)
Added Resources
- 7. Ocean State 1 200 200
- 8. Add'1, Load Manage- 20 80 180 300 430 ment 6 Conservation
- 9. Add'1. Cogeneration 6 Small Poweraa
- 10. Retired Capacity 340 600 600 600 600
- 11. Net Excess 596 665 538 287 31-(Deficiency)
- The Reserve percentages used in the above calculation are 20.8%,
19.8%, 18%, 16.5%, and 20% for 1987 through 1991 respectively reflecting Hydro Quebec II's inclusion in Line 3. The remainde r of this Table is consistent with Table II.
** Included in Line 3 above.
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l The Pilgrim Nuclear Generating facility has been out of service since March, 1986. If the facility is returned to service no voltage reduction would be anticipated, states Mr. Browne. However, if Pilgrim is not returned to service, then need for actions such as voltage reductions or radio and television appeals for voluntary load curtailment are anticipated to occur several times. He states that voltage reductions, if implemented, wor ' be However, he for a period of 4 to 6 hours during midday peak. .asibly states, that the situation threatens to be more serious and affecting firm customers if actual peak loads are unusually nigh, forced outages planned generator maintenance outages are extended, exceed the allowance for unplanned outages, or emergency assistance from neighboring pools is not available. Mr. Browne supplied the Committee with charts that outline the 1987 Summer Capacity Situation with Pilgrim (June - September 1987) and 1987 Summer Capacity without Pilgrim (June - September 1987). See pages 78-31 for these charts. JAMES STETSON, Legal Counsel, Department of Public Utilities does not have an ongoing forecasting function. The department looks to New England Power Pool (NEPOOL), Energy Facility Siting Council and individual power companies for forecasting information. Mr.
~
Stetson requested that any questions the Committee may havethe be next referred to Chairman Paul Levy, who will be testifying at committee hearing. i
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PILGRIM STATUS REPORT The Committee held a hearing to address the issue of vidlations which exist at the Pilgrim Nuclear Generating Facility cited by the most recent SALP report. The committee at this time also allowed the representatives from Boston Edison Company to provide an update on the progress and construction taking place at their Plymouth Plant. The hearing was held on April 27, 1987 at 10:00 a.m. in Gardner Auditorium, State House, Boston, Massachusetts. The committee sent a written request to testify before it to the following individuals:
- 1) Ralph Bird, Senior Vice President of Nuclear Operations, Boston Edison Company;
- 2) Dr. Robert Henry, Consultant to Boston Edison Company;
- 3) Martin McBride, Senior Pesident Inspector, Nuclear. Regulatory Commission
- 4) Ronald Bellimie, Radiological Safety Division, Nuclear Regulatory Commission; and
- 5) William F. Kane, Director, Division of Reactor Projects, Nuclear Regulatory Commission The fol' lowing is MR. RALPH BIRD's testimony. Dr. Robert Henry, consultant to Boston Edison Company was available for i
questioning.
"I would like to start by giving you a brief status report on our progress at Pilgrim Station. The plant which was shut down by Boston Edison for refueling, maintenance, and safety enhancements still has all fuel removed from the reactor. Our target date.to begin refueling is about the firat week in June, and refueling should be.complaced about ten days later. While we still do not have a firm schedule, 1 do not expect startnp before August.
We will meet with the Nuclear Regulatory Commission (NRC) to obtain their approval to start up the plant only when we are satisfied that we are ready to resume operations and after a thorough inspection by NRC staff has been completed. i At this point, it is appropriate to review quickly the work that has been completed and the work which is still in progress. Earlier this year, we removed all 380 fuel assemblies from che reactor after replacing the refueling bridge to expedite the process.
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Work that is near completion includes: major fire safety modifications, improvements to the instrumentation that allows our operators to read water level in the reactor and an automatic reactor protection automatic shutdown system that is more efficient and requires less maintenance than the previous mechanical one it is replacing.
. Other work in progress includes: the new hydrogen water chemistry system that will extend the life of reactor piping; inspection and maintenace of the two emergency diesel generators which supply emergency power if we lose the off-site power supply; j inspection and overhaul of the turbine generator; and the extensive inspection and maintenance of the plant's mechanical and electrical systems.
In addition to refueling the reaJtor, work remaining includes improvements to the station security system, and a safety ent: Ancement program which is expected to include improvements to the containment, and installation of a third diesel generator to increase the backup power supply. Engineering and design for the safety enhancements which will further increase the existing very large margin of safety in the plant are being completed. Construction will take place during the spring and summer period. We have also made significant staffing improvements at Pilgrim. The complement which was 356 in the last quarter of 1985 has been increased to 523 currently, Many of those positons have been filled, including key management jobs. We are aggressively recruiting to fill the remaining posts within the next few months. In the meantime, we are using contractor personnel to temporarily fill essential positons. , l Perhaps the most significant increase has been in the operations department where the complement has nearly doubled from 29 in the last quarter of 1985 to 55 now. All but one of those slots have been filled and the people are either in training or scheduled to begin training later this year. Nine prospective operators will take their NRC license exams next month. We expect to meet our goal, which is to have six shif te of operators by the , end of this year. We have also made major increases in maintenance, technica], radiation protection, security, and fire protection. l Finally, I wculd like to discuss the latest MRC report -- The f Systematic Assessment of Licensee Performance (SALP). Io put the results of that report into perspective, it is important to remember that the reporting period began in November 1935 and ended in January of this year. Looking at the time frame as a baseline against which to judge our performance, we can fairly say that we
ww777 7a.: r mwa;; m .g .22 . - -, - , ,. , , , , ;. .g g have made significant progress at Pilgrim, and, as the NRC noted, the rate of progress increased as the SALP period drew to a close. They also recognized changes made after the reporting period. We recognize that we still have a great deal of work to do before startup and before,we can regain public confidence. I believe strongly that at Pilgrim our standards must be higher than they were in the past, even though the plant was and is safe. Our future plans are, quite simply, to be relentless in our pursuit of excellence". MR. WILLIAM KANE submitted the following testimony with Ronald Bellimie and Martin McBride available for questioning.
"My name is WILLIAM F. KANE and I'm the Director, Division of Reactor Projects at the NRC's Region 1 Office. I wish to thank the Special Joint Committee on the Investigation and Study of the Pilgrim Station for giving me the opportunity to present the NRC's view of the Boston Edison Company's (BECO) progress, since the shutdown on April 12, 1986, on correcting identified deficiencies and improving performance at Pilgrim. I have kept my prepared statement brief in order to allow more time for answering specific questions the committee may have.
Prior to the April 1986 shutdown, the NRC determined through its inspection activities and through the SALP process that BECO's performance in certain program areas was weak. In spite of corrective actions taken by the utility since 1982, BECO continued its weak performance. In our view, the principal causes of these continuing problems included: 1) incomplete staffing, in particular, operator and key mid-level supervisory personnel; 2) a prevailing view in the organization that the improvements made to date had corrected the problems; 3) reluctance, by management, to acknowledge some problems identified by the NRC; and 4) dependence on third parties to identify problems rather than implementing an effective program for self-identification of weaknesses. Consequently, following the plant trips which shut the plant down in April, the NRC Regien L administrator expanded the prerequisites for restaru to include resolution of organizational and staffing ! deficiencies and hardware issues at the plant. Further, periodic meetings between senior NRC and BECO management were established to monitor BECO's correctiva action programs. During the shutdown, BECO has made several organizational changes and staffing and hardware changes and commitments in an attempt to corrset the longstanding issues. In general, the NRC views these changes la positive with the potential to result in performace improvement. Some of the more significant changes are j assignment of a new senior vice president responsible for BECO's nuclear program; an onsite reorganization to eliminate a dual reporting chain which had obscured ths chain of command and weakened accountability; hiring a new operation section manager, a chief l
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l l l radiological engineer, and filling the maintenance supervisor vacancies; approving increases in the number of licensed operator i i staff and actively recruiting candidates from outside the company; staffing increased in the security and fire protection area; forming a new onsite system specialist group to provide engineering support 1 and augmenting the onsite quality assurance auditor group; { initiation of a maintenance backlog clearing program and work l j planning process; increasing corporate nuclear engineering department presence onsite; increasing the emergency preparedness i staff and completing the new emergency operations facility; extending overtime controls to all employees; initiation of a major effort to clean up the contami~nated areas of the plant; initiation of the safety enhancement modifications to improve the conditions and safety operations of the plant; and completion of the plant specific simulator and initiation of training of it. However, while some improvement has been made, the NRC found progress has been slow during this outage on resolving identified problems. Many of the changes noted above have not been fully implemented or in-place long enough to determine their effectiveness or durability. Nonetheless, they do indicate a change of attitude by BECO. The defensiveness and reluctance to recognize problems are by and large gone from BECO's approach. It is clear that BECO senior corporate management is committed to establishing effective leadership of its nuclear program and has taken steps to provide adequate staffing and improve accountability. Also, the increase in the site support functions provides BECO the opportunity to identify problems and reduce dependence on third parties. The decision that extended the outage to correct management and hardware problems indicates that BECO recognizes there are problems and has taken d steps to identify the scope of the problems and actions to resolve them. As the committee is aware, the NRC recently issued the Pilgrim Systematic Assessment of Licensee Performance (SALP) for the 15 month period November 1, 1985 through January 31, 1987. The report identifies the specific improvements BECO has made. Most notable were: a significant reduction in the number and extent of contaminated areas in the plant; completion of a new emergency operations facility; and improvements in the licensed operator training and requalification programs. Revever, the report Liso identifies recurring programmatic weakness in several functional areas including: radiological controls; surveillance; fire protection; secu'rity; and assurance of quality. The NRC believes the low SALP grades reflect the magnitude of the problems and confirms BECO's prudence in extending the outage to resolve them. The NRC also believas that the changes made during the SALP period and two othnr changes, the assigraent of the new Senior Vice
- President-Huclear Operttions and the elimination of dual headed enstte organization, mAde after the SALP period are especially significant and vill provide a solid foundation for future improvement.
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Currently, BECO requires NRC approval prior to restarting Pilgrim. BECO is aware that the NRC is looking for progress in correcting the identified problems prior to obtaining that approval. BECO is required to submit a formal readiness f or restart assessment and a restart schedule for NRC review and approval. The NRC also intends to conduct and independent in-depth readiness inspection team inspection prior to approving restart to ensure that the prqblems have been satisfactorily resolved and the plant is ready for safe operation. In addition, Pilgrim, as a high priority site, has and will continue to receive a considerable amount of P*e Region 1 inspection resources. This includes permanently assignio three resident inspectors to the site, supplemented with periodic inspections by experienced resident inspectors from other sites, and programmatic reviews of all SALP functional areas by region based specialists inspectors In summary, the NRC believes BECO is taking many steps to . resolve the longstanding problems at Pilgrim. However, to date, progress has been slow. The NRC intends to continue to closely monitor BECO improvement programs to insure that the actions taken do result in real progress and that the improvements made will be permanent". 1 3 I I I l I 1 1 l LL__ _L_ _ _ __ _
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RECOMMENDATIONS Il Creation of the Division of Nuclear Facilities Safety. II) Endorsement of Comprehensive Lead Management and Conservation Programs. III) Prioritize Massachusetts Based Electrical Generating Facilities. . IV) Department of Public Utilities to Establish a Five-Year Supply Plan without reliance on the Pilgrim Plant. V) Committee Review of the Nuclear Regulatory Commission (NRC) Systematic Assessment of Licensee Performance
. Report (SALP) and Recommended Measures to Correct Serious Functional Deficiencies at the Pilgrim Nuclear Generating Facility at Plymouth.
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7 c I 2 T:fs u.,, w :. m m ;3 , , 7 ,, y , l RECOMMENDATION I CREATION OF A DIVISIOh OF NUCLEAR FACILITY SAFETY After many hours of deliberation over topics such as emergency preparedness and planning, monitoring of radiation and other aspects of nuclear safety, the committee has concluded that many areas regarding public safety need immediate attention and improvement. After reviewing and hearing the testimony of the Department of Public Health (DPH) and the Department of Public Safety, the committee concluded that lack of funding, along with shortfalls in strict compliance with many sections of Chapter 796 of the acts of 1979, have led to a less than appropriate handling of The committee, radiation monitoring and emergency preparedness. therefore, recommends that the Commonwealth adopt and implement the formation of a Division of Nuclear Facility Safety to oversee nuclear generated power production in the Commonwealth. The Division of Nuclear Facility Safety shall provide the following provisions and services: The Division of Nuclear Facility Safety shall be a division of the Department of Public Safety and shall be responsible for monitoring the operation and modification of the two nuclear In addition, it shall be power plants within the Commonwealth. responsible for developing emergency response plans in conjunction with Massachusetts Civil Defense for responding to accidents involving nuclear power plant facilities. Major activities shall include: installation, operation and maintenance of a syst;m for remote monitoring of radioactive discharges from the nuclear power plants, in conjunction and under the supervision of the Department of Public Health; development and review of the Massachusetts Radiological Accident Emergency Preparedness Plan (MRAEPP); oversight of training of state and local civil defense personnel responsible for implementation of the MRAEPP. Enforcement of rules and regulations prescribing standards for in service testing of pressurized systems at nuclear power plants which the Department of Public Safety oversees.
- 1) The Massachusetts Radiological Accident Emergency Preparednetis Pian.
"'he Massachusetts Radiological Accident Emergency Preparedne2s Plan shall estsolish a progrs.m for statewide, integral canagement proccdures in tha event of an accident which may occur At a nuclear power reac'cer site. The primary purpose of tan plan la to
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l provide a coordinated response by state and local governmental I officials for the protection of the citizens of the Commonwealth. The plan shall include site specific planning to cover the urgency of protecting citizens living near nuclear plants; a concept of operations so'that the plan can be effectively carried out; and an effective allocation of resources and personnel. The plan shall pre-assign the duties and responsibilities that would be taken by ) all the respondents to a nuclear accident thus enabling actions to i be pade quickly and efficiently. The Massachusetts Division of Nuclear Facility Safety I and the Massachusetts Civil Defense Agency shall share the primary l responsibility for developing the plan with integral component { agencies such as the state police and the Emergency Planning Zone l (EPZ) communities' local officials. The utilities' security and l safety personnel must also play a major role in planning. Specifically, the Division of Nuclear Facility Safety shall be responsible for the technical f. unctions of this effort, and the Civil Defense Agency shall be responsible for the operational l aspects. The plan shall be reviewed every year for accuracy and j proper appropriation to assure a fully functional quality plan. The l appropriate components shall be distributed to the proper state, county and municipal agencies and organizations in the Commonwealth for implementation. The Division of Nuclear Facility Safety sh,all plan to ; expand the EPZ to 50 miles from each reactor with the understanding i that greater planning and preparedness efforts are necessary closer I to the reactor and that evacuation will not likely be recommended for all areas within a 50 mile radius. These plans should be , tailored to meet e'ach community's specific needs. The Division of Nuclear Facility Safety shall clarify ', evacuation plans for regional schools which have students from at
- least one, but not all, towns in the school system which are part of an EPZ. Division and Civil Defense officials working with school j administrators and parents' groups must develop workable student and i teacher evacuation plans and establish criteria for determining when, if ever, it would be appropriate to send children home first j t6 evacuate with their families.
The Division of Nuclear Facility Safety shall establish emergency evacuation time estimates and traffic control plans based ,
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on evacuations of people within ene EPZ to reception centers at { least 30 miles from the reactor and should anticipat a secondary or shadow evacuations.
- The DLvisioe of FJclerr raciaity Safety shall commission a site-specific probabilistic risk snalysis of severe !
) accident probabilities at Pilgrim and the consequences of radioactive l releases and the probable health effects at. various discances from { l ~ the plant, i Major operations specified in the Plan and agency responsibilities are outlined in Recommendation VI. I l 1
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- 2) Monitoring.
The committee recommends that the Division of Nuclear Facility Safety and the Department of Public Health adopt and develop a Remote Monitoring System (RMS) which shall incorporate three major components: gross gamma detectors radially positioned arbund each nuclear power station; an automated, isotopic gaseous effluent monitor system which samples from major engineering release points; and a reactor parameterIndata communication addition there shalllink be to each provided facilities on-site computer. liquid effluent monitors, which will be located at each plant's All of these RMS components shall be liquid discharge points. connected through a dedicated data communications link to provide instantaneous readings to the Division of Nuclear Facility Safety Headquarters. Technical staff shall review the data and perform analyses of plant conditions. The a) ENVIRONMENTAL RADIATION MONITORING SYSTEM: Division of Nuclear Facility Safety shall develop a dual ring system of environmental radiation monitors utilizing gross gamma detectors and automated isotopic detectors which shall be installed and maintained around each reactor site that would measure a change in radiation levels resulting from a radioactive release at the reactor It shall site. This system shall serve a multitude of purposes. define the existence of a radioactive release sufficiently large enough to impact upon the environment, as well as detect a release through an unmonitored release path. In addition, the system shall provide a backup capability should the effluent monitoring system be inoperable, and shall also help reveal the presence of atmospheric conditions (windshear) which could result in plume dispersal not following anticipated direction of travel. l The Environmental Radiation Monitoring System shall be { developed to provide the following features: (1) upattoa16 monitors distance of per site (1 detector for each 22.5 degree segment) approximately 2 miles from the reactor site; (2) minimum detection level of 1 microRoentgen per hour (natural background levels are l l approximately 7 to 10 microRoentgens per hour); (3) maximum j detection limit is at least 10 Roentgens per hour (one million times normal background levels); (4) automatic transmission of radiation l readings to the Nuclear Facility Safety Division headquarters l computer system every 8 minutes; and (5) transmission of alarm i
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signals to the Nuclear Facility Safety Division headquarters in the event of high radiation levels or failure of environmental monitoring system components. b) REACTOR PARAMETER DATA LINK: The Massachusetts Division of Nuclear Facility Safety shall install a direct data communication link betveen the Division headquarters computer and each nuclear reactor's control room computer for the monitoring of the Commonwealth's two nuclear power reactors and their safety , systems. This data link shall be developed for early notification I of events that could lead to nuclear accidents. This system is an essential element in providing continuous plant safety assessment, early detection of abnormal conditions, and evaluation of nuclear plant transients.
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The system signals to be received at the Divisica's headquarter 3 shall be the same signals available to the nuclear plant personnel on-site. The Division shall select particular parameters to be transmitted to them from an index containing all available plant system information. Parameters selected by the Department provide detailed information on the operation characteristics of all essential plant safety systems. Some major features that are available that may be j included in this system are: (1) 1,000 to 1,300 parameters l (signals) per reactor accessible for transmission every two minutes; (2) technical parameters include: reactor power levels, reactor water levels, steam generator water levels, containment temperatures, engineered safety system availability, and essential pump flow rates; and (3) system software for displaying either current or historical signals. c) THE RADIOACTIVE GASEOUS EFFLUENT MONITORING SYSTEM: The Division of Nuclear Facility Safety and the Department of Public Health shall be directed to utilize and implement a custom designed automated system to monitor gases routinely released by nuclear power plants. The Radioactive Gaseous Monitoring System is designed to identify and quantify the radioactive components of the gaseous discharges from each stack and other gaseous release points to the environment and transmit the information immediately to the Division so that appropriate emergency action can be directed in the event of a nuclear accident. The Radioactive Gaseous Effluent Monitoring System is a state of the art, computerized system which continuously transmits data from the nuclear power plant to the Division's headquarter l computer. This system includes the following features: (1) dedicated computer at the power plant sites for operation and analysis; (2) minimum detection level of 10 to 13 microcuries/ cubic centimeter; (3) maximum accident detection limit of 10 microcuries/ cubic centimeter; (4) collection and analyses of radiation in three forms: iodines, particulate, and noble gases; (5) automatic background level checks; (6) automatic check on source verifications; (7) remote computer access to determine operational status and data; (8) signal alarms in the event of high radiation levels or failure of a system function; (9) detection of specific isotopes based on radiation energy; and (10) accelerated operatien rates designed to maximize data collection during an accident j
' d) EMISSION STANDARDS: It is essential that Massachusetts Public Health Officials review and determine the maximum permissible levels of airborne radioactive emissions from nuclear power plants that do not threaten the public health and safety. By adopting state emission standards as authorized by the Clean Air Act amendments of 1977, the Commonwealth vill ensure that safe standards are in place and strictly enforced. Until such standards are set by the Department of Public Health, the federal
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standards should be adopted as state standards so that the state officials immediately have the power to inspect onsite and off-site monitoring equipment and have independent enforcement authority over emissions. The state shall assess all licensees for the cost of setting up a monitoring system for the Commonwealth. Perhaps the most important safety function of a monitoring system is to assist emergency response officials in determining the extent of a serious accident and the amount and direction of radiation releases. We recommend installation of a comprehensive and sophisticated new monitoring system similar to the one that is already installed and functioning in Illinios.to provide substantially more public protection.
- 3) Possible Adverse Health Effects From Pilgrim Radioactive Emissions - -
a) Radiation exposure can cause cancer, birth defects and chromosomal damage. The Department of Public Health has determined that there has been a significant increase in leukemia cases in the area surrounding Pilgrim, although the department is still studying what the cause of those leukemias may be. b) The Special Committee recommends that four health studies be conducted:
- 1) A follow-up study on the leukemia cases in the Plymouth area to determine what environmental or occupational exposures may have caused those leukemias.
- 2) A study to test the theory ~that coastal winds may concentrate the radioactive emissions from the Pilgrim plant in such a way as to cause adverse health consequences in coastal areas.
- 3) A regional study of adverse health impacts, including leukemia incidences, birth defects and infant mortality, downwind from other nuclear reactors in New England.
- 4) A health study of all past and present Pilgrim employees to determine the adverse effects, if any, of exposure to radiation from Pilgrim.
- 4) The cost of the Division of Nuclear Facility Safety and the Depa-tment of Public Health's monitoring system should not be borne by all taxpayers but by the utility ratepayers through an assessment of the nuclear plant licensees..
-91a-
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. re.: : , ma' RECOMMENDATION II ENDORSEMENT OF COMPREHENSIVE LOAD MANAGEMENT AND CONSERVATION PROGRAMS The special committee investigating the Pilgrim Nuclear Generating Facility reviewed testimony involving energy supply,The load management and conserva tion measures during several hearings.
committee concluded ths.t in order to meet current and future power supply demands all utilities in the Commonwealth must implement stringent load management and conservation programming. The committee ' stresses that authority should be given to the Department of Public Utilities to oversee the implementation of aggressive load management and conservation programs for any electric utility relying on the continual operation of the Pilgrim Generating Facility. LOAD MANAGEMENT: The committee endorses the concepts contained in the Final Report of the Boston Edison Review Panel as they relate to increased load management programs by Boston Edison Company. The committee recommends that the Department of Public Utilities (DPU) be required to encourage and assist Boston Edison in implementing the specific load management programs. The DPU shall also be required to encourage and assist Commonwealth Electric Company in implementing appropriate cost-effective load management programs that offer the company similar energy-saving results. Boston Edison Company should identify and fund effective " load management" measures, such as radio-controlled water heaters and nighttime water chilling systems, which reduce peak j' energy use and are cheaper than the cost of producing electricity f rom new power plants.- In addition, the utility should provide incentives for commercial and industrial sector customers to form
" load-shedding cooperatives," where a group of participants agrees-to share minimal energy use reductions during peak demand emergencies. ,
1 CONSERVATION: The special committee endorses the concepts contained in the Final Recort of the Boston Edison Review Panel as they relate to increased, cost-effective conservation programs by Boston Edison Company. The DPU'should be required to encourage and assist Boston Edison in implementing the specific conservation programs. The DPU shall also be required to encourage and assist Commonwealth Electric Company in implementing appropriate, cost-effective conservation
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,, . ;- , :; . . e programs that offer the company similar energy-saving results. The j DPU should direct all utilities to make significant investments in energy conservation and energy efficiency programs, known as "damand-side management" programs, to reduce the energy demand of all utilities' customers. The DPU should set target investment levels and participate in the design of demand-side management p r ograms . Such programs should include, but not be limited to the following, where shown to be cost effective:
- 1) The special committee recommends all utilities should employ design teams to go into buildings that use large quantities of electricity to identify the full package of demand-side management measures and practices that are cheaper than the utilities commensurate cost of producing electricity from new power plants over the useful life of the conservation measures. The utility should then fund the purchase and installation of identified cost-effective measures.
- 2) All electric utility companies shocid offer their customers incentives for a wide range of efficiency measures. This incentive program should go far beyond the limited scope of current and prior utiltity rebate programs for refrigerators and efficient lights.
- 3) All electric utiltity companies should also provide incentives for electrical energy efficiency in new construction including hook-up fee and penalties.
- 4) All electric utility companies should convene an auction for energy efficiency improvements similar to the bidding process that is currently being used to promote the development of small power and cogeneration facilities.
- 5) The committee recommends that the DPU should be allowed to provice all utilities with a profit,'or
" rate of return" on the investment the company makes in demand-side management programs. This rate of return, to be recovered from the companie's ratepayers, could be at least as high and or up to two percentage points higher than the rate the utiltities are authorized to receive for capital investments in new power plants.
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PRIORITIZE MASSACHUSETTS BASED ELECTRICAL GENERATING FACILITIES I. The Committee recommends that the Energy Facilities Siting , Council and the Department of Public Utilities give priority l consideration to the construction of non-nuclear
- electric generating plants located within the Commonwealth when reviewing ~the plans of
- any electric utility for the construction of a.new generating plant.
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I The Massachusetts General Laws and regulations promulgated by regulatory agencies require utility companies to provide'ratepayers with. electricity at the lowest possible economic cost and with the least possible environmental impact. In planning to meet the electrical energy needs of ratepayers, the Department of Public Utilities,.the Energy Facilities Siting Council, and the utilities should consider and evaluate the following factors:
't The full " life cycle" economic costs of each energy l
resource option. These include costs for construction, financing, operation and maintenance, and decommissioning. With respect to energy efficiency and load management programs, costs for materials and installation and program administration.should be considered.
. 2) The full environmental costs of each energy resource.
option. Environmental impacts associated with the siting of facilities, degradation of outdoor and indoor air quality, potentially adverse impacts on water quality, and risks to public health should all be fully considered when deciding which energy option to pursue. l i
- 3) The number of jobs created by the use of each energy resource option. The number of long and short-term jobs that are directly and indirectly created as a result of developing various energy resource options should be considered and compared. Other state and local economic development costs and benefits, such as support of indigenous industry and inflows or outflows of capital resulting from development of each energy resource option should also be considered.
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- 4) The reliability of the energy resource option.
Massachusetts needs affordable and reliable energy . I resources to help sustain a healthy economy. Energy resource options that decentralize and diversify the region's fuel mix, and which reduce reliance on non-indigenous fuels, should be prioritized. All potential resource options--including energy efficiency improvements and practices, load management measures and practices, small power production, co-generation, and small and large oil, natural gas and clean coal technologies should be evaluated and compared using the above criteria. The Committee believes that priority should be given to Massachusetts based plants. The Committee is concerned about the increased dependence on plants located outside Massachusetts for our electric generating needs. It believes that this trend increases the likelihood of supply disruptions, thereby complicating unduly our ability to forecast long range supply. This trend of reliance on plants outside Massachusetts is also detrimental to our economy, since it creates jobs in other states that would otherwise benefit Massachusetts workers. 4
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M575fWMZ:EW6.2 PMW " W a., ; si MSXI:'.,2nFsi3W', o l' M ' . - ,; . - %:n a RECOMMENDATION IV DEPARTMENT OF PUBLIC UTILITIES TO ESTABLISH A FIVE-YEAR SUPPLY PLAN WITHOUT RELI ANCE ON THE PILGRIM PLANT The Committee has found that the Pilgrim Nuclear Generating Facility at Plymouth, Massachusetts has suffered from serious and continuous mismanagement. Although significant efforts are being made by its owners to rectify the management problems, considerable uncertainty remains over the reliability of the plant to contribute to the electric supply needs of the Commonwealth. The Committee therefore recommends that the Department of Public Utilities (DPU) establish a five-year plan for ensuring adequate supply without consideration of the electrical production of Pilgrim plant. Due to the uncertain future of Pilgrim, the DPU should establish a supply plan.for the Commonwealth that does not require any dependence on the Pilgrim plant. Such plan shall include a forecast of future supply and demand which deliniates each source of power and its location. January 1, 1988 is the due date for the implementation of the initial five-year plan. The Committee recommends that in determining whether to restart the Pilgrim Nuclear Power Plant, the availability of sufficient cost effective and safe alternate energy resources shall be taken into consideration. 1
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citTe m m m.ic.;acrn w s uu2=a.n m. m m a imm u.m n :: a a= m aw , .x a w 1 i RECOMMENDATION V COMMITTEE REVIEW OF THE NUCLEAR REGULATORY COMMISSION (NRC) l SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE REPORT (SALP) AND RECOMMENDED MEASURES TO CORRECT SERIOUS FUNCTIONAL
- DEFICIENCIES AT THE PILGRIM NUCLEAR GENERATING FACILITY j
AT PLYMOUTH The Pilgrim nuclear power plant has a well documented, and well publicized, history of problems. This history has called into question both the level of safety when Pilgrim is operating and Boston Edison's ability to run the plant. With an issue as emotional as nuclear power the loss of public confidence must be addressed in addition to the actual safety problems. _ Massachusetts, particularly residents of Southeastern Massachusetts, have every right to demand that Pilgrim be one of the best run. plants in the country rather than one of the worst. Clearly the initiative for this belongs to Boston Edison. Pilgrim has been "off-line" for more than a year. -During that time the utility.has undertaken significant initiatives to improve its performance.. In some cases they have taken a lead in the nuclear industry to address certain problems. More work remains to be done, however, and how effective the company is in its wo.rk will have to be judged when it is completed. This is neither a " pro-nuclear" nor an " anti-nuclear" report. The committee feels that where there are problems, they must be addressed, prior to restart, and that the plant should not operate until all major deficiencies are corrected. Individual members will have their own views on nuclear power but everyone agreed that the overriding issue here was not to resolve the nuclear debate but to address the problems of one particular plant. The committee heard testimony en specific operations and plant problems from Boston Edison, the Nuclear Regulatory Commission, and representatives from citizen groups. In addition, the committee has had access to Public Safety Secretary Charles Barry's report to the Governor on the plant and volumes of NRC
. reports.
To try and identify every single problem and the appropriate solutions would be beyond the committee's capability and jurisdiction. The sheer number of technical matters, the lack of experit staff, and the debate within scientific and regulatory circles over some issues made it unrealistic for us to devise the specific solutions to many particular problems. Likewise, it makes little sense to list every specific problem since it would make more difficult our Aim to focus public attention on the most substantive problems.
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r The committee does feel, though, that it is useful for the Legislature to summarize the patterns of problemsThis, and our we hope, will perceptions of the work which needs to be done. not only focus greater attention on the major problems but also give the Legislature and the public some standard by which we can measure Edison's progress. The NRC, on many occasions, has claimed it will force Edison to prove significant improvements before restart is allowed. As part of their process they willThe develop committeea detailed urges the check NRClist of to include matters requiring solutions. our concerns as part of that process. If addressed, we feel plant safety will be enhanced and public confidence raised. The Nuclear Regulatory Commission recently issued the Pilgrim Systematic Assessment of Licensee Performance (SALP) for the 15 month period of November 1, 1985 through January 31, 1987. SALP is a comprehensive assessment of the plant analyzed into twelve functional areas. The report identifies recurringradiological programmatic weaknesses in five functional areas including: controls; surveillance; fire protection; security and assurance of quality. These five functional areas received low SALP grades of 3. The NRC rates on a 1,*2, and 3 basis and defines a 3, the lowest rating, as follows:
"Both NRC and licensee attention should be increased.
Licensee management attention or involvemen't is acceptable and considered nuclear safety, but weaknesses are evident; licensee resources appear to be strained or not effectively used so that minimally satisfactory performance with respect to operational safety is being achieved." i The following is an outline of the problems in each of the five functional areas as reported by.the NRC, followed by the committee's recommendations.
" This assessment covers radiation f (1) RADIOLOGICAL CONTROL -
protection, effluent monitoring and controls, radwaste shipping and environmental monitoring. SALP found that the licensee made numerous improvements in the overall l However, quality of the radiological controls program. l implementation of the program continues to be weak. When problems with program implementation or adequacy are identified, corrective actions are sometimes not i l adequate or not implemented resulting in the need for l l further NRC involvement. In the area of effluent monitoring and control, the licensee implemented the 1
WM kwam.:xwmana enww;%um av a nw mu..wsu .u irruw r.~ m w new effluent technical specifications in a generally accepta.te manner, however, failure to take-action on significant long standing deficiencies in the environ-mental Thermolumenescent Dosimeters (TLD) program detracted from the good effort."
. COMMITTEE RECOMMENDATIONS:
a)--Aggressively supervise the radiological control program.. ' b)--Establish and implement measures to verify program. implementation and implement corrective actions for deficiencies, c)--Interactions with personnel outside the radiological group should be ~ ' significantly strengthened. d)--Continued clean up of plant and reduction of contaminated areas. e)--Strengthen the role and company jurisdiction of radiation control department over the other departments. f)--Exposure histories of past and present employees and contracted workers be compiled, continually updated, and reported to DPH and Nuclear Facility Safety Division, g)--Improve programs for replacement of thermo-luminescent dosimeters. h)--Improve training of employees in radiological environmental technical specifications. 1)--Improve control and accounting of special nuclear material under one gram. j)--Improved access control to high radiation areas. k)--Improved inspection of vehiclec leaving site for any contamination. (2) SURVEILLANCE: " Individual surveillance tests were well conducted and controlled. The response to recurring local leak rate test failures was also positive However, the licensee has been slow to recognize and correct weaknesses in the control of the program tests. This lack of progress is reflected in the large number of surveillance-related licensee event reports and NRC violations issued during the current period. The control of the program is fragmented and not always effective-and appears to depend more on historical past
' practice then in a well founded, systamatic approach. The This is a major weakness that must be corrected.
licensee's measuring and test equipment control program also need improvement." CCMMITTEE RECOMMENDATIONS: a)--Significant site and corporate management attention is needed to correct deficiencies in this area.
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b)--Place a single qualified individual in overall charge of the surveillance program. (3) FIRE PROTECTION: "The licensee has been slow to strengthen the fire protection program. Problems . included inadequate surveillance procedures, degraded fire barriers, inoperable' fire protection system equipment, and poor quality fire brigade training. Although action has been taken to address these concerns the program has suffered from a chronic lack of attention and should be closely monitored." COMMITTEE RECOMMENDATIONS: a)--Significantly reduce the amount of inoperable fire protection equipment in the station. b)--System for assessing priority needs and timely correction of any deficiencies in fire barriers and protection equipment. c)--Improved supervision and training of fire watchers. d)--Provision for independent water and power supplies. e)--Completion of all Appundix R improvements. f)--System to control combustible material on-site. (4) SECURITY AND SAFEGUARDS: "The previous SALP report identified serious NRC concerns regarding the licensee's awareness of, and attention to, NRC physical security objectives and the need for additional management attention to, and support of, the security program to insure that the program was properly implemented. The previous SALP report also identified NRC's belief that the licensee had initiated actions to resolve those concerns and that the security program was receiving increased management attention. However, shortly after the beginning of this assessment period, it became apparent to the NRC that, due to the number and complexity of the identified problems and some other problems which were then surfaced, far more extensive management attention and resources would be
' required. As evidenced during this assessment period, the need for additional attention and resources by the licensee continued until late in this assessment period.
As a result, little physical progress toward improving the program was accomplished by the licensee during the period." w= _ _ _ _ _ _
m:dF.M:'Y :!r::.lY%:Ms 2ma ,2,5 ~& 4::~ anw ~ 3 . ; '. Ci MM:,1 ~ 6.' %:@ l.C. COMMITTEE RECOMMENDATIONS: a)--High level corporate and site management attention to the recently established priority level for the security program upgrade should continue in order to implement commitments and develop an ef f ective program. b)--NRC/ Boston Edison review of relationship of contracted security force over Boston Edison and other contracted employees. Does Security have adequate power to control pla,nt personnel and question employee activities? c)--Develop and implement ef fective program to eliminate any presence or use of alcohol and drugs.
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d)--Elimination of any violations or weaknesses in security barriers. (5) ASSURANCE OF QUALITY: "Although the licensee has exhibited good performance in certain activities such as outage control and engineering and has displayed initiative in its safety enhancement program, significant 4 deficiencies still were f ound to exist in radiological controls, surveillance, fire protection and security. Some of these deficiencies have existed throughout the period and have been identified in previous SALP reviews, and by the licensee's own quality assurance organization. The ambiguity of the site organizational structure and the instability in the corporate and site management team have resulted in the licensee's inability to address and resolve these long-standing problems without repeated prompting and overview by NRC. Senior corporate management was slow in confronting the problems and in implementing corrective actions. Late in this assessment period and immediately following
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it, the licensee took steps to address its organizational weaknesses. However, the effectiveness of these efforts in improving the licensee's performance remains a matter of continuing NRC interest and concern." COMMITTEE RECOMMENDATIONS: a)--Continue senior management attention to identify problems to ensure that they are i promptly and effectively resolved. b)--Improve tests and surveillance of equipment program. c)--Greater authority of quality control staff over other departments to resolve any conflicts between procedures and personnel in different operation groups.
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u,m,ua m m.m;r.sem m a w2em,. m m m ;x:,rxc.m w w. w. a m v.. a . - 4 -u ; d)--Improve training and supervision over contract workers. e)--Improvements in visual surveillance system to properly _ identify and describe-deficiencies. f)--Improve training, testing and requalification of personnel.
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(6) PLANT / EQUIPMENT COMMITTEE RECOMMENDATIONS: a)--Maintenance requests back log be eliminated, b)--Complete review of maintenance and testing schedules with all incomplete testing being finished and any deficiencies corrected. c)--Identification and repair of Main Stream Isolation Valve and RHR pumps which caused initial spurious scram which closed the plant. d)--NRC investigation and public explanation of recent reports of deficiencies in certain General Electric reactors, including Pilgrim. The public should be informed of the possible problems and any action taken by General Electric or Boston Edison which has corrected these deficiencies. All uncorrected problems should be corrected, e)--The NRC and General Electric should also make available to the public the General Electric report. (7) GENERAL MANAGEMENT CONCERNS: The following are recommendations which address general management areas which the committee feels need review. COMMITTEE RECOMMENDATIONS: a)--Staff vacancies in key areas should be filled to adequate levels, b)--Demonstration that the new programs, divisions and personnsi can actually perform as planned. c)--Resolution of inter-group conflicts and clearer lines of authority for safety, ALARA (As low as reasonably achievable), and fire i protection personnel over other divisions. d)--Review and planning of transition from outage and maintenance mode to on-line operation so that they are prepared if restart is approved. (8) REACTOR CONTAINMENT: In its most recent SALP report the NRC noted the following: " Plant hardware changes were also impressive, particularly the planned Mark I containment enhancements. The modifications go considerably beyond'NRC recommendations and show a
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y nnzu.2:w.wcc :nm;wrnv n y .w nvaw- /~,, ~ a i;. mv2 r,; ~ :: ' mm- , l I concern for nuclear safety." Nevertheless, serious concerns have been raised, both inside and outside of the NRC, about the Mark I containment and its ' possible failure in the even.! of a major accident. The Committee has sent a lettet to Boston Edison seeking more information on exactly what work is -1 planned to enhance the containment system. In addition, the committee strongly urget that prior to restart the NRC, the state, and Boston Edison shall hold a public hearing on: a) The possible defects or weaknesses of the Mark I containment; b) the work planned by Boston Edison to improve it; c) the schedule for that work; d) NRC studies and others done on the itegrity or possible failure of the containment in the event of a major accident. The containment is such a crucial safety feature in nuclear plants that all work to strengthen any weaknesses must be completed prior to restart. e) An evaluation of any additional safety features such as filtered venting of the containment, molten core barriers, underground residual heat removal system, and a secondary steel containment. (9) STANDBY GAS TREATMENT SYSTEM: Prior to refueling the problems identified with tne Standby Gas Treatment System should be corrected. (10) DECOMMISSIONING PLAN: It is unclear what happens.to the plant and storage of radioactive waste when the plant is permanently closed. The questions of the cost involved decommissioning, the impact on Plymouth taxes, waste storage, security, and dismantling or " sealing" of the reactor building are of great concern to area residents. The NRC, the state and Boston Edison should develop decommissioning plans, well before a scheduled closing, to answer these and other questions. The Committee after intensive review of the NRC SALP report recommends the Boston Edison Company immediately take positive action on all of the above recommendations. Boston Edison shoul,d improve all of the categories which received grades of category 3 on the most recent SALP report. The two primary causes for the NRC's category 3 findings were slowness in making improvements and lack of management attention. These problems should be resolved so that none of the functional areas maintains a category 3 grade. It is imperative that all improvements are completed before action is taken to restart the Pilgrim Nuclear Power generating facility at Plymouth. '
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a .ta s e 4 e RECOMMENDATION VI
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p.a.a - u; .a m u % m ..w.w m . m.;a m :. m ., ":<; i a c _ .m c.w _ ,. ,a ~2#:m,m r m RECOMMENDATION VI IMPROVED EMERGENCY PREPAREDNESS PLANNING Emergency preparedness is the last layer of protection for public health and safety in the event of an accident at a nuclear plant. Until recently, emergency planning seems to have been perceived more as a. regulatory requirement than.a form of protection which might be called into use. As public concern over nuclear plants.has increased over the past year, so has emergency planning come under greater scrutiny. This scrutiny has found the obvious current emergency planning is inadequate. The primary responsibility to correct these inadequacies rests with the state. Working with federal officials, local officials, and the utility the state must take immediate action to develop plans that are more realistic and dependable. The federal government has reserved to itself most powers dealing with nuclear power plants. The state, however, is left with almost total responsibility in protecting the public should an accident ever happen. While this may be jurisdictionally awkward .' there is no substitute for state and local planning. Local and state officials are the most qualified to prepare and implement , emergency plans. It is unacceptable to this committee for a private utility or federal agency to try and fulfill or usurp state and local responsibility. The committee feels that prior to restart emergency plans must first be reviewed and approved by town officials, in the Emergency Planning Zone (EPZ) communities, and by the state. I Nuclear Regulatory Commission (NRC), Federal Emergency Management Agency (FEMA), Boston Edison, the State, and. towns should work on a schedule to coordinate the review and decision on whether to approve, prior to restart. There is growing debate over how far states can use the f planning approval requirement as a means of preventing a new plant from being licensed or of closing a licensed pinnt, if a state does l not believe an emergency response plan can adequately protect the public health and safety. It appears that the NRC, Congress, and undoubtedly the courts will be reviewing this issue as more states I withhold approvals. The state should pursue two courses. State and local governments should develop the strongest possible emergency plans. The public's health and safety demands nothing less. If, after those plans are developed, the Governor feels they are.still inadequate.then he may withhold approval.
-103-I a_ _ _ _ _ _ _ _ _
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my,;.-- -- .m7 gg . .. , , , l l I { The committee heard testimony from the Department of Public {' Safety about the need to plan beyond a set limit of ten miles. The Department stressed, though, that with deficiencies in current ten mile planning any work beyond the ten mile zone should not deflect any attention from the communities within the zone. Communities closest to the plant require a higher level of planning than communities farther away. The Department also testified that while Civil Defense is the primary agency for dealing with emergencies other divisions are involved such as the National Guard, Public Safety, and Public Health. The Department noted that coordination between state agencies for nuclear emergency planning needs to be improved. Local Civil Defense officials from severai towns in the EPZ . testified before the committee. Their concerns included: A) Lack of a reception / decontamination area; B) A need for greater technical and material assistance from 1 the state and utility; C) Criticism that the plans lacked specific written agreements with parties which might be involved with an emergency, such as bus companies and hospitals; : D) A need to plan for regional school systems in which , students come from one but not all towns within the EPZ; and j E) The need for more inter-community planning in order to have a coordinated regional plan. The town of Plymouth has created its own lo6al advisory committee on nuclear matters. That committee has thoroughly reviewed the town's emergency response plan. Their report has been j made available to the committee and demonstrates the kind of detailed planning necessary for a strong response plan. It also demonstrates the indispensable role of local governments in developing plans. Many of their recommendations would be helpful to other towns. Their report is included (see Appendix 9). 1 While primary responsibility for planning rests with state and local officials there is necessary assistance whie.h should come from the utility. This includes technical advice ar. well as I material support accepted by the state, a county, or a town. The I committee feels that this assistance should be paid for through I utility assessments which will be passed on to utility ratepayers ! rather than all taxpayers. l Specific improvements to the emergency plans. need to come ! from the utility, towns and state. The committee recommends the l following improvements:
-104-
wwn.a wn.m:. ... . m;sm;w w.r= am u x.. a .. ww w w,a . . - .. -a. m,n m .- BOSTON EDISON PLANNING ASSISTANCE: (1) Boston Edison Company should provide updated and accurate Evacuation Time Estimates under a wide variety of accident scenarios. This will
- enable state and local officials to better plan traffic management in the event of an emergency.
(2) Identification, notification and workable evacuation plans for mobility impaired and individuals who will have difficulty being notified of an emergency or in being familiar with the emergency response procedure. Such individuals include the physically disabled, those depending on public transportation,'the hard of hearing and those who apeak limited English. Greater attention of these individuals will. help ensure that no cne is excluded from,the planning. BOSTON EDISON EQUIPMENT: (1) Boston Edison should improve Public Alert Systems including testing. Sirens should be tested j more frequently with improved monitoring and ' identification of individual siren deficiencies. Siren systems should be audible in the entire EP3, and loud enough to be heard in buildings with closed windows. In addition, this system should be supplemented with an adequate number of loudspeaker equipped vehicles. (2) Review and supply of needed equipment for shelters and re,ception areas for evacuations. During summer months local population swells, increasing the need for sheltering areas for non-resident visitors. (3) Provide greater information in the event.of an emergency. During an incident, people may not have written,information on hand about procedures to be followed. This is particularly true for non-residents. Printed material with procedures for an emergency should be pre-printed for quick distribu-tion in group shelters, relocation areas, hospitals, public transportation, and through school children during an emergency. (4) Boston Edison should update the Nuclear Energy
, Pamphlet to impress upon the public the importance of following official instructions. Necessary information should include maps, location of public shelters, locations of public transportation facilities, Emergency Broadcast System affiliates, traffic routes, reception areas and personal safety precautions.
-105- l
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- F EMERGENCY PLANNING ZONE (EPZ):
I ! (1) . Clarify that when any part of a town lies within an j EPZ,.the entire town shall be.part of the EPZ. I Planning end resources for these towns will have to be upgraded. q (2) Clarify planning for regional schools which have , students from at least one, but not'all, towns in the school system which are part of an EPZ.
*(3) Clarify authority of Public Safety to plan- for a radiological emergency beyond a 10 mile EPZ.
(See Recommendation I--Division of Nuclear Facility Safety) (4) Evacuation time estimates and traffic control plans should be based on evacuations of people within the EPZ to centers well beyond the 10 mile zone and j should anticipate secondary or shadow evacuations. 1 STATE PLANNING: j (1) Increase state assistance to' local planners. This should include technical assistance as well as . financial assistance for local use. The' goal should be coordinated regional planning as well as strengthened local plans. (2) Inventory and where necessary create adequate local shelters to protect non-resident visitors in the event of emergencies which may not require j evacuation. (3) Identify area medical services, hospitals and medical personnel available for use outside of the EPZs. ! Also evaluate any additional services and supplies which may be necessary to serve EPZ population in the event of an emergency, including emergency treatment facilities and training of medical personnel. (4) The state and towns should participate in appropriate emergency drills. , l (5) Specific planning shall be developed for emergency notification, evacuation planning, and traffic control planning should be imposed in areas outside of an EPZ which pose unique problems, e.g.: Cape Cod and the Islands. (6) Inventory-of available buses, ambulances and handicapped / elderly vans, to assist in an evacuation. Develop an inventory of service
-106-
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planning by towns, ensure'a coordinated, regional plan, and ensure' cooperation between the q utilities and area towns. 1
, (8) Identify and designate adequate reception and decontamination centers and ensure the.availabiltiy- '
of adequate supplies and equipment..'
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(9) Ensure appropriate annual review and' publication of plans working with the utilities, towns and Federal Emergency Management Agency (FEMA). l
- 1. (10) Evaluate and where necessary correct effectiveness l .of notification and communication systaa between' . D state and local officials.
(11) Identification, notification and workable evacuation plans for people in all institutional facilities --
,such as hospitals, nursing homes, schools and prisons -- inside the EPZ.
(12) Contractual agreements for the above services where appropriate should be made to avoid'any erroneous assumptions of transportation in the event of an. evacuation. LOCAL PLANNINGi (1) Each town in an EPZ should consider establishing an Radiological Emergency Response Plan Committee to review matters pertaining to emergency response planning. (2) Local plans need more thorough documentation and letters of agreement between involved ~ parties to ensure clear lines of responsibilities in the event of an emergency. (3) Local officials should inventory local planning needs, equipment and resources which can be provided by the Division of Nuclear Facility Safety or the utilities. (4) In addition to plan for their own communities, local officials should work closely with neighboring communities to ensure workable regional planning. (5) Each town in an EPZ should establish plans for-informing non-residents of procedures to be followed in the event of an emergency.
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1 l l The state and utility have been ineffectual and too informal in developing adequate emergency response plans. The committee, therefore, finds: A) The Pilgrim Nuclear Power Plant should not restart until, and unless, an emergency preparedness plan, including evacuation, has been approved by the Selectmen in the EPZ communities and by the Governor; B) Federal, state, and local officials and the utility should coordinate actions in order to reach a decision on whether to. approve emergency response plans prior to restart. C) The cost of emergency planning should not be borne by all taxpayers but financed through utility assessments. 4 I i i
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mmne uw.4 m;amr.v n a au.m ; m n.ag;, c.a w w ;r.. w . c g:::;; u w . ;.: o y m.r m .w - T = v .. .., APPENDIX 1 STATEMENT OF CHARLES POOLE March 23, 1987 My name is Charles Poole. I am an epidemiologist with primary interests in occupational and environmental epidemiology and epidemiologic methods. I hold a position with Epidemiology Resources Inc., which is located nearby in Chestnut Hill. ERI is l an independent firm specializing in epidemiologic research. _ Through its educational division, known as the New England Epidemiology Institute. ERI p rovides pos tgraduate training and sponsors a three-week Summer Session each year in c onj unction with Tufts University. I have been with ERI since 1983 and I teach a course in the Summer Session. Boston Edison asked ERI to perform two tasks. The first was to review analyses by the Massachusetts Department of Public j 1 Health of cancer rates in Plymouth and four other towns. The second was to make recommendations for possible epidemiologic studies of Boston Edison employees. At this time, we are still trying to accomplish the first task. We have produced a preliminary critique of what now appears to be only a portion of the Department's output on this topic. i The analyses that Boston Edison asked us to review appeared in a presentation last July before the Joint Committee on Energy by Drs. Bailus Walker and David Gute of the DPH. I called the DPH on December 10 and 11 and asked for a copy of the text of the l l l
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1: :DR9.. :K. ii::M. s: M. . % o TYL:-. , V ;Gr J. , P :2: s:x. . , W :. *..u 7.G e ..< r W . %V :,C l Page 2 July presentation. I was told that a follow-up report had been prepared and that I should expect it to be released by the end of the week. I received the text of the July presentation and some sup plement a ry mat e rials from the DPH on December 16 and 19. l 1 Over-the ensuing weeks. I called the DPH occasionally to { check on the status of the update. After two months, it became clear that we would need to report to our client on the information we had received thus far. Je anne Loughlin and I produced a preliminary critique, put it through internal IRI i review, and sent it to Boston Edison on Feb rua ry 19. Our plan was to obtain comments from Boston Edison and then from the DPH prior to making the preliminary critique final. Two weeks later, on March 6 I received several calls from news reporters. The preliminary critique had been released and, as the first author. I had been named as the person to contact. I immediately called Boston Edison to see what was going on, called the DPH to let my colleagues there know that the preliminary ctatique had been released, and sent them copies of it. This is not the way I prefer to go about my job. Many people find it un p l e as an t to have o the rs r eview their work. No one likes to le arn ab out the contents of a critique for the first time from the press. It is difficult f or us at ERI to contend with the attitudes of people who assume that our work is biased en @@ he-+e- e ,eeplmmm- frg ee aw,wees A w egas ow.e se ee e 5---ud-_,-x_-,_-- - _ _ - _ _ _ . - - - - _ . , . _ _ - - - - . - - _ , - - . - - - _ . . . - - - .
% .. E .:.aD W %i? : % Ti.~GP.!GdG & % .s "e F R C J2.i.JoOi m M G;L EN A 1:I)c;;W 7 &?DW&C P = r-~ Page 3 because of their opinion of our cliants. I have learned that the only defense'against such cynicism is to insist that my work be judged on its merits.- Consequently. I want any report I help p r o'd u c e to undergo as tho rough a review as possible before it is released. I have received apologies and assurances from people in appropriate positions of responsibility within Boston Edison. ERI now expects'to be consulted before the release of any report we provide. Unfortunately. I have also le a rn ed that communication between Boston Edison and the DPH regularly takes the form of surprise attacks, often conducted through the news media. The long-awaited DPH report arrived on my desk six days ago, on March 17. This past Friday. March 20 I attended a meeting called by representatives of the DPH for the purpose of asking Boston Edison to provide information. The very next day. I ran across an article in the newspaper describing what appear to be two or three DPR reports that I have neve'r seen. One of them. > according to the article, is a paper that Dr. Walker and several l co-authors submitted for publication in th's medical literature some time ago. i According to the newspaper article, these reports give a detailed exposition of a meteorological theory about circulating l wind patterns that trap radiation and continually expose coastal a
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i residents to it. This theory apparently forms the rationale for ] selecting, out of the 24 towns that lie within 20 miles of the Pilgrim I facility, just five for this analysis. In the ] i documents that have been provided to me, there are but two sentences about this pivotal hypothesis. As a consequence of the foregoing, I am in no position to give informed testimony on the March 16 DPH report or on the 9 other reports about which I learned in Saturday's newspaper. I would prefar not to offer an off-the-cuff critique of such important material. This Committee and the people it s e rv es have j been placed at a resi disadvantage by the downward spiral of communication between the DPH and Boston Edison. 1 I wish to emphasize that I stand behind the maj o r comments in the preliminary critique, its premature release ~ notwithstanding. I would like to close by summarizing and ; i supplementing that r ep ort with a brief list of the maj or points as I see them: 1 I I _1 _. Selection _o_f the Five _ Towns I hav e essentially no information at this time on the rationale for this central decision of study design. The key j question is whether residence in these particular towns, as ) j opposed to any other aggregation of towns, creates the sharpest possible differentiation of radiation ex p o s u r e in a comparison with the rest of the Commonwealth. The magnitude of that 1 e m_A.-__ ._______m_m__r__________t_ _.__a._ __
9KKKLM5!L%T+1129.V%%i3.;WaFN:&RMuerin:.G .' :h:;ww.ws:f;w&. %.A:.0':nLam Page 5 difference, if any, must be sufficiently great for an effect on l leukemia rates.to be reliably estimated. Radiation monitoring data must be reviewed in depth in order to answe r this question.
- 2. Classification of Leukemias Both DPH documents I have seen give the same, reasonable breakdown of leukemias into f our maj or categories. The various types of leukemia differ greatly in their age distributions and in the influence of causal f actors on their occurrence. Thus, it is best at the outset of en analysis to treat the different categories of leukonia as separate diseases. Neither DPH
-document, however, follows its own four-part categorization in ,
presenting its results. In order to conduct an analysis of each of the four leukemia categories, I will need to obtain more detailed data
- 3. Reliance on Statistical Significance Testing S t at is tic al significance is perhaps the most misused criterion of interpretation in epidemiologic research. A s tatis tically signifi'c ant result is often treated as though it should s.urenatically be considered significant from a medical, biological, or public-health p oint of view. This interpretation is well-known to be erroneous, but it is still common.
i i Subgreue Analyses The DPH reports analyze data separately for men and women without stating why. There should be a good reason for
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D.M2F. %Q:.F L_:u . ::: r L:Xhm:nN.' "' , i._!:n.w.;.3 . .- , % :D.U = . ) G. MEDICAL TACILITIES, DEFICIENCIES:
- 1. nere are inadequat e plans for treating large numbers of victims of radiation exposure.
- 2. The two hospitals listed in the Plan (Jordan and St. Luke's) can treat j buly a limited number of people with radioactive contamination,
- 3. One hospital is within the EPZ and could be simultaneously receiving and evacuating patients.
RECOMMENDATIONS:
- 1. Clearly determine response capacity of Jordan and St. Luke's Hospitsis.
- 2. Identify all possible referral hospitals outside EPZ.
- 3. Document capacity, types. of care and provisions available at referral hospitals outside EPZ.
4 Obtain signed agreements with referral hospitals.
- 5. Develop procedures for transportation of patients outside the EPZ.
H. RADI0 PROTECTIVE DRUCS PRESENT POLICY: The Massachusetts Department of Public Health does not advise distribu-l tion to the general public of Potassium Iodida (II) as a radioprotective I drug. RECO)DENDATION: That the Department of rublic Health provide for the distribution of Potassium Iodide or a proven alternative to the general Plymouth population prior to reactor start-up. In conclusion, the Committee notes, once again, that the deficiencies identified herein and the recommendations made relative to the Plymouth RERP are by no means exhaustive or all-inclusive. Those listed are, however, serious enough that , were they not to be addressed, the selectmen might be unable to fulfill their legal responsibilities during a radiological emergency. Hence, the Committee respectfully urges the Selectmen to give immedia'te attention to the matters contained in this report. In addition, the Committee expects that even af ter the comprehensive revision of the RERP I and the implementation of recommendations, the Town vill continue to monitor I regularly and to improve its response plan whenever neccesary. 9 . e W L - _- _-__ _ - _ . _ _ _ _ _ - :- - __ _ ':-- -
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]fd /Vowdm 0.2/65 October 11, 1985 Mr. Charles J. Mathis Nuclear Operations Manager Pilgrim Nuclear Power Station Rocky Hill Road Plymouth, MA 02360
Dear Mr. Mathis:
Enclosed is a copy of a report by Mr. Frank R. Archibald of this office on his visit to your facility on August 19, 20, and 28, 1985 to review your Radiation Safety Program. Mr. Archibald's report reflects information relating to the Radiological Improvement Plan developed by your Company in concert with and in response to findings and recommendations submitted by Hydro Nuclear Services. Mr. Archibald ' also reviewed certain aspects of your ALARA program and exposure records. He also made a brief visit to your Chiltonville Training Center. Mr. Archibald concludes that the Boston Edison Company is committed to the achievement and maintenance of an effective Radiological Safety Program at the Pilgrim Nuclear Power Station. Recommendations are submitted relative to providing information copies of available quarterly Landauer Dosimetry Reports to Boston Edison Company'and contractor personnel, and also making available to workers laundered protective garments with minimal (=: 2mR/hr) levels of " fixed" radioactive contamination. Very truly yours,
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Richard Levine Assistant Director rf e ;-_.. , . . . ._ . - . . ~
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Subject:
Boston Edison Company, Pilgrim Nuclear Power Station, Rocky Hill Road, Plymouth, MA 02360 Persons Contacted: Mr. Adrian R. Trudeau, Chief Radiological Engineer Mr. . James A. Kane, Sr. H. P. Engineer Mr. Larry Schrall, Safety Engineer
.Mr. John Aboltin, Sr. Reactor Engineer Mr. William Leacon, Assistant to Senior V.P. - Nuclear Mr. Russell Laroue, Training Specialist Mr. Warren Rogers, GET Instructor - Numanco Mr. William Hoey, Acting Sr. ALARA Engineer Mr. J. J. Purcell, ALARA Engineer - Bartlett. Nuclear Mr. Michael Bonnett, Waste Management Coordinator ,
Mr. Duncan Sanford, Training Manager Dates of Visit: August 19, 20, and 28, 1985
- Two separately reported incidents involving unplanned radiation exposures
-being sustained by 2 employees of contractors to the Boston Edison Company (BECo) occurred during the 1984 major refueling and modification outage at the Pilgrim Nuclear Power Station.(PNPS). Both incidents occurred in the Control Rod Drive (CRD) Repair Room. The first incident occurred on January 18, 1984 and involved a contractor Health Physics (HP) technician. As a result of this incident the U.S. Nuclear Regulatory Commission-(NRC) levied a $40,000 civil penalty against BEco. Despite'the subsequent initiation of corrective actions including inauguration of a requirement for constant EP coverage of all operations in the CRD Repair Room, a similar incident occurred on August 18, 1984. The second incident involved a General Electric Company technician picking up a small, highly radioactive metal chip. After the second incident the,NRC met with BECo management to discuss short and long term corrective actions needed in the radiation protection program at PNPS to prevent avoidable radiation exposure incidents in the future. BECo management advised NRC that necessary actions would be taken to enhance the radiological protection program so as to preclude incident )
recurrence. BECo management contracted with Hydro Nuclear Services, Inc. for the following . Ph ased support to the PNPS Radiological Group: . a) Phase I. Evaluation of the adequacy of radiation protection measure during CRD disassembly operation and recommendations of necessary corrective actions. This phase was completed by a 5 man audit team from Hydro Nuclear Services (ENS) during the period September 10-25, 1984. i b) Phase II. Perform an in-depth assessment of the Radiological Controls Program at PNPS. (The requirement for an independent assessment was imposed as a license condition by the NRC.) This phase was completed by a 5 man HNS audit team during the period September 25 to December 7, 1984 The comprehensive l appraisal included detailed discussions of the findings and deficiencies observed 1
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Boston Edison Company 86-347 Pilgrim Nuclear Power Station I in various aspects or components of each of fourteen (14) areas or categories of the then prevailing Radiological Protection Program. The HNS Appraisal Report contained recoc=endations for correcting the root cause of the deficiencies reported for the 14 areas or categories evaluated. c) Phase III. This phase pertains to the implementation of the recem-mandations arising from phase II. Support and assistance is being furnished to BECo by on-site HNS employees and other contractor personnel. This phase is expected to be completed by December 31, 1985. A Radiological Implementation Plan (RIP) was developed to implement the recommendations that evolved from phase II. Initiation of the RIP was made on March 15, 1985. The major elements of the RIP include: a) Establishment of an interim organization for the Radiological Group with specific functional job descriptions. b) Establishment of managerial Radiological Oversight Committee independent of the Station Radiological Group. The Committee has an on-site assessor who audits work in progress and the status of RIP improvements. The com=1ttee reports findings to the Senior Vice President - Nuclear, at biweekly intervals. c) Upgrading of the training of BECo HP technicians. d) Dissemination of radiological occurrences and corrective measures via notices and meetings at various supervisory levels including daily meetings of the Radiological Group staff. A composite schedule was formatted for each of the 14 areas or categorit' covered in the Radiological Controls Program appraisal performed by HNS. Implementation of action items in categories 3 through 14 are scheduled to be completed by December 31, 198f. Category number 1 relating to long term organi-zation of the Radiological Group and category number 2 concerning selection, qualificatied and training are continuing functions. The following is a summary of the actions that have been or are being implemented with respect to the 14 areas or categories delineated in the KNS appraisal findings:
- 1. Organization An interim organization structure for the Radiological Group was developed and staffed by March 31, 1985. Functional and administrative radiological responsibilities for each position have been defined for the interim organization and are expected to be defined for the long term organization by September 30, 1985.
- 2. Personnel Selection, Qualification and Training Action has been initiated to make available to the Chief Radiological Engineer (CRE) adequately qualified technical support personnel through the establishment of formal qualification and selection criteria based on a cask analysis of each position. The Nuclear Training Department is developing a supervisory training program to meet the needs of new supervisors and the continuing needs of experienced supervisors.
_ . . . . _ _ . _ . _ . . . , _ - --- - l
v ., mm .rm = ,- m u ~ n a a. .. , w .n - , -. .a uv, ; Beston Edison Company 86-347 j Pilgrim Nuclear Power Station - l f j Development of Technician Training materials is milestoned for October 31, 1985. A formal continuing training program for all Radiological Group personnel is cargeted for completion by December 31, 1985. 31 Radiation Workers and General Emoloyee Training (CET). This area of training has been recently and completely revamped. All employees including contractor personnel are required to attend a general employee training orientation session and pass a level I examination before unescorted access is granted. Those indi-viduals whose duties involve access te radiation areas are required to accend additional training and pass a level II examination. This latter training includes an exercise by each potential radiation worker in anticontamination clothing dress and undress procedure and use of the Frisker. The Nuclear Training Department has developed a 55 page General Employee Handbook which summarizes the radiation protection policies and procedures that must be followed during an individual's employment at PNPS. The handbook is given to each individual upon completion of GET. Specialized training for crafts with emphasis on mockups, special tooling, Radvaste minimization, ALARA, and contamina-tion control is being developed with an expected completion date of December 31, 1985. 4 External Exposure Control All aspects of the external exposure control program have and are being examined and evaluated to assure that exposures received by personnel at PNPS continue to be measured, recorded, and reported in accordance with applicable regulations, standards, and BECo procedures. Included is an upgrading of the QA program with respect to TLD dosimetry, development of support data to document the beta correction factor being used, development of criteria for setting trigger levels for performing skin dose exposure calculations, and improvement of the level and quality of physical controls applied to high radiation areas. Targeted complation date is October 31, 1985.
- 5. Re/iratoryProtectionProgram The quality of the respira' tory protection program has and is being enhanced by ensuring that all compressors are tested for air quality, evaluation of the breathing air quality testing requirements, instruction addendum and improvement of respirator smear checks. A procedure and program for training technicians to inspect and repair respirators has been prepared. BECo plans to evaluate the use of alarming Constant Air Monitors (CAM's); also to evaluate its air sampling program to determine if appropriate air samples are obtained. BECo also plans to develop and implement as necessary an expanded engineering controls program into their training and procedures. A completion date of December 31, 1985 is planned. On-site compressor used for filling the Selfcontained Breaching Apparatus has been repaired.
- 6. Internal Exposure Control BECo has implemented or plans to impleoent the following measures to improve the in-vitro bicassay program:
(a) Prepare an approved procedure or group instruction containing minimum requirements, description of equipment and/or supplies needed and a methodology for using the results of the sample analyses to determine uptakes and intakes. (milestone date: Sept. 30, 1985) (b) Determine the need for a QA program fcr the com=ercial', off-site analytical laboratory. (August' 31, 1985) 77 -
m m ,= r n :. :x .: :: 2 :: w w.w :- ...n.,a - . n . .. . ,,:.- s., . ..: ,. Boston Edison Company 86-347 Pilgrim Nuclear Power Station (c) Procure additional calibration sources to span the energies of the isotopes of interest. (On order)
. (d) Standardize the configurations and uses of the Whole Body Counter calibration phantoms.
(e) Correction of errors in the analysis library for the Whole Body Counter (WBC) complaced May 31, 1985. (f) Adoption of more stringent controls and checks on critical WBC operating parameters such as the energy window settings. (g) Inauguration of a program for evaluating and trending internal depositions.-- (h) Development of systematic methodology for investigation, documentation and records maintenance of abnormal internal exposures. l (1) Development of procedures containing approved methods and calculations for determining intakes, and for periodic verification of the effectiveness of engineering controls. (j) Formulation of a policy establishing specific work restrictions for personnel found to have internal depositions.
- 7. Radiological Surveillance Program BEco has improved the Surveillance Program through development of a formal summary / matrix of all required surveys, removal of unnecessary posting and labeling, development of more specific survey proce-dures, standardization of air sampling requirements, assignment of a HP Supervisor to a survey improvement program, restructuring of the Radiation Work Permit (RWP)
, program, contamination control points, ventilation studies and procurement of additional monitoring equipment.
- 8. Radioactive Waste Management Responsibility for Rodwaste Management Pfogram rests with the Station Services Support Group which is responsible for the packaging, processing, on-site storage, and shipment. The Radiological Group is primarily involved' in afeas of surveillance of on-site storage and volume reduction. BECo has implemented ENS recommendations relative to evaluation of radwaste seurage area for consolidation, volume reduction, and use of enclosures and shielding.
- 9. ALARA Program The ALARA Program is intended to keep all radiation exposures "as low as reasonably achievable". Among the actions taken or being taken by BECo in response to ENS recommendations are a formal statement of BEco's corporate-wide ALARA policy, delineation of responsibilities, description of majob program elements, a specific charter for each ALARA committee and a listing of responsibilities assigned to key management personnel. Additionally, BECo plans to establish by November 30, 1985 ALARA committees, key perf ormance indicators and ALARA goals. The Radiological Group and the Nuclear Training j Department will jointly develop an ALARA training program, j
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- 10. Facilities and Ecuipment BECo as reco= mended by ENS, has initiated action to upgrade the level of housekeeping and professional appearance in all facilities involved in the radiological controls program. Additional EP equipment will be ordered as required. Software for WBC system will be expanded to accommodate 3 detectors. Operations and technical accuracy of the Ge(L1) system and analysis of charcoal cannisters have been improved. Increased use of radio communications and data telemetry equipment by the Radiological Group is planned. Calibration procedures for instrumentation are being improved. Provisions have been made for checking High Efficiency Particulate (EEPA) filter units for breakthrough.
- 11. Precedures A Procedure Plan has been developed whereby all Radiological Group procedures are reviewed for basis, consistency, clarity and simplicity, applicability, assignment of responsibility, current requirements, methodology and technical accuracy. Completion'is targeted for December 31, 1985. Each new or revised procedure or group instruction will be field tested prior to approval.
- 12. Radioactive Materials controls BEco has initiated action to develop and implement a plan for radioactive material control which will encompass the following elements:
(a) Responsibilities (b) Storage capacity and adequacy (c) Shielding and inventory (d) Posting and labeling (e) Classification (f) Predetermined action levels (g) Procedures Development of recommended facility modifications is scheduled to be complaced by September 30, 1985.
- 13. Management Oversight BECo has developed and is presently engaged in concerted efforts to implement an NRC approved Radiological Improvement Plan (RIP). The plan addresses each of the areas or categories of recommendations contained in the ENS in-depth appraisal of the Radiological Controls Program at PNPS. A composite schedule has been developed which sets forth target completion or milestone dates for the major tasks in each of the appraisal areas. An Independent Oversight Committee was established. The Committee provides periodic reports to the Senior Vice President, Nuclear Operations,
_ regarding implementation progress. Goals and objectives are b eing established for the Radiological Group as a whole and for individuals within the Group. 1 Key performance Indicators are also planned to be established to be used as I guidance in measuring performances and effectiveness of the Radiation Protection Program. A personnel development program will be for=ulated that is in concert with the functional responsibilities of the personnel.
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r ' r,xyr ;~-- ' Boston Edison Company 86-347 Pilgrim Nuclear Power Station 14 Corrective Action System The current system for correcting significant deficiencies at FNFS has been expanded to include a follow-up evaluation. The purpose of the evaluation is to assure that the corrective action has been effective in precluding a recurrence of the identified deficiencies. ALARA Program ALARA program records were reviewed during the August 28, 1985 visit. The program records include the results of tracking area radiation levels in the Process Buildings. A total of 129 points are surveyed and recorded at semimenchly intervals by ALARA personnel. A continuous graph of the measured radiation levels is made for each of the designated points. The graphs facili-tate an awareness by ALARA personnel of plant areas where radiation levels are
' increasing and in turn acts as a trigger for additional monitoring and/or other actions such as shielding installation to reduce dose rates.
During the visit radiation levels were measured at a representative number of designated points in Radwaste , Turbine and Reactor Buildings using the Division's Ludium Model 3 GM Survey instrument. The measured levels contrasted favorably with those most recently recorded by BECo ALARA personnel. Exposure Records Attached is a bar graph showing the total man-rem exposures sustained by station, utility and contractor personnel during the years 1975 through 1984 Individual exposures less than 100 millirems are not included in the total exposures shown. As expected, the largest total exposures occurred in those years during which major refueling and modification activities were carried on. The last major (refueling) outage occurred during the period December 10, 1983 to December 24, 1984 The exposures shown on the graph also reflects exposures resulting from NRC mandated actions. The total combined exposures sustained by station, utility, and contractor personnel for the first 7 months of 1985 is reported to be 511.7 man-rems. Chiltonville Training Center Visit was made to the Training Center in Chiltonville (part of Plymouth) which is located approximately 3 miles west of Pilgrim Nuclear Power Station (PN?S). The Center Building comprises 6 classrooms 4 laboratories, audio-visual and production studios, a technical information center, computer equipment, lunchroom and a lounge. Training has or is being planned for reactor operators, and in the areas of electrical and mechanical maintenance, health physics, chemistry, instrumentation and control. installation of a computerized s1=ulator is expected to be completed at the Center during the latter part of 1986. The Simulator is planned to be an exact replica of the Pilgrim Control Room and will be used in conjunction with the annual NRC required training of nuclear plant operators.
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- 1. Provide an information copy of the Quarterly Landauer Desimetry Reports
. to BECo and contractor personnel. .
- 2. Take necessary action to provide workers required to enter radiation areas with laundered protective garments that have minimal (<2mR/hr) amounts of residual " fixed" radioactive contamination.
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% Nw mes nov..b.c 27,1986 8710015 Mr. Alfred E. Pedersen, station Manager '
Pilgria Nuclear Power Station Rocky L'111 Road Plymoute, MA 02360
Dear Mr. Pedersen:
Enclosed is a copy of a report by Mr. Frank R. Archibald of this office on his visit to your facility on October 20 and 30,1986 to review your Radiological Safety Program. Mr. Archibald's report reflects inforattien relating to the Restructuring of the Radiological Section, review of certain aspects of your ALA*A Program, and exposure records. He also made a brief visit to your Ch11tenv111e Trr.ining Center. Mr. Archibald concludes that implementation of the Radiological Improvement Plan has strengthened the Health Physics role at the Pilgrim Nuclear Power Station. Recommendations are submitted relative to an apparent safety deficiency at the Spent Fuel Pool, and making protective garmen:s with reduced " fixed" radioactive contamination av,a11able to workers. Please feel free to contact this office if there are questions relative to the enclosed report or it we can be of assistance to you. 1 Yory truly yours, Richard Levine s Director RL/mi Enclosure
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l l To: Mr. Levtue 87R-0015 From: Mr. Archibald
Subject:
Boston Edison Cc=pany, Pilgrim Nuclear Power Station, Rocky Hill Road, Ply =outh, MA 02360 Persons ) Contacted: Mr. Thomaa L. Sowden, Radiological Section Manager j Mr. Ed Gordon. ERHS Grpup Leader
- Mr. J. J. Posselt, Senior Radiation Engineer Mr. Bruce Eldredge, Acting Chief Radiological Engineer Mr. George Smith, Consultant, Hydro Nuclear Services Mr. Larry Dooley, Tech Training Supervisor Mr. Al Morisi, Outage Management Dates of Visit October 20 sud 30, 1986.
3 The Pilgrim Nuclear Power Station has been in an outage or off-line status since April 11, 1986. The shut down on April 11, 1986 was for the purpose of implementing certain priority maintenance activities. The e erent Refueling Outage #7 was officially declared on July 25, 1986. Pilgrim Station
. is not expected to be on-line before April 15, 1987. Many asjor maintenance activities involving inspections, repairs, replacements, modifications and
- testing are being performed during the current refuel outage. (See attachment
- 1) Additionally, decontam%mtin of a nu=cer of plant areas and reactor containment enhancement actions are being pursued.
Radiological Section Restructuring Pursuant to the implementation of a Radiological Improvement Plan (see report 86-347 dated October 7. 1985), the Radiological Section has been restructured and is divided into 2 on-site crganisational elements. One elemect is concerned with daily operational responsibilities and is headed by the Chief Radiological Engineer. The second cesanisational element is the Environmental Radiological Health and Safety (ERES) Group. This group was J previously a corporate function and was relocated from the Company's Nuclear { Engineering Depart =ent at Braint;ree to Plymouth during September 1985. The j ERES Group is responsible for providing support in the areas of ALARA, Respiratory Protection, Internal Dosi=stry, External Dosimetry and other technical Radiological issues. (Please refer to attach =ent 2 for copy of a j chart of the current Radiological Section organization). l ALARA Procram The ALARA (as low as reasonably achieveable) function is one of the j major responsibilities assigned to the ERES Group. The Boston Edison Company j I (EECO) ALARA policy is set forth in a recently revised Nuclear Organization Procedure, NOP83RC1. This policy and procedure document delineates the responsibilities of various personnel for the i=plementation of BECO's ALARA l
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rc.w - m ,-- . . me .7 ;n - <z m e :.- .x , . ,. . = c. r um- ,- m. r, - , J 1 policy. NCP83RC1 provides for the establish =ent and membership of an ALARA j Com=1ttee which is to meet at least each month. By charter, the ALARA Committee serves is an advisory capacity to the ALARA Section of the ERES Group and performs a review function of ALARA actions taken in support of Station activities. The ALARA Committee is also charged with recom=ending ALARA goals ; to the Vice President of Nuclear Operations. Based on a review of the minutes i of the first 2 meetings of the ALARA Committee, the ALARA goals have not been established but are expected to'be developed and announced during the first calendar quarter of 1987. A number of additional ALARA pregram records were reviewed. The program records include the results of tracking area radiation levels in the Process Buildings. A total of 129 designated points are surveyed and radiation levels recorded at bi-weekly intervals by ALARA personnel. The Report of Radiation Surveys performed on October 9,1986 was reviewed. During the October 20 visit, radiation levels were measured at twenty six (26) of the designated points in Radwaste and at various elevations in the Reactor Building. Measurements were made using the Division's Ludium Model 3 GM Survey instrument. The measured levels contrasted favorably with those recorded by EECO 111RA persennel. Seent Fuel Pool Visit was made to the Spent Fuel Pool at the 117' elevation of tt9 Reactor Building. No life preservers or other safety gear was observed at the pool railing. This apparent deficiency was mentioned to a BECO employee assigned to the area. The employee made an effort to locate a life preserver and after a time interval of approximately 2 1/2 minutes reported finding 3 preservers lying on the floor en the west side of the Spent Fuel Pool area near the step off pad. Torus Control Potni. I Visit was made to the Torus Dress Cut Area at the 23' Elevation in the Reactor Building. A survey was =ade of the stored laundered garments. A cu=ber of the gar:ents appeared to have fixed Radioactive contamination in excess of 2 mR./hr. Chiltonv111e Traini:2 Center i follow up visit was made to the Nuclear Training Center in Ch11tonv111e (part of Plymouth) which is located approx 1:ately 3 miles west of the Pilgrim Nucisar Power Station. The center is the home of the Nuclear Training Depart =ent. Four general types of nuclear training programs are planned,as follows: (a) Operatices: This training is intended for Reactor Operators and Senior Reactor Operators. The trnW yr will include full-time course , l work in the fundamentals of operating Pilgrim Station. Students will examine the plant's major syste=s and will be taught over 400 tasks f 't ] j f
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i which licensed operators are responsible. Subjects covered will include mathematics, che=1stry and physics. A computerized training si=ulator is presently under contract and is expected to be installed at the Chiltonv111e Center during the Summer of 1987. It is expected that ! training on the simulator will start during the Spri s of 1987 at the contractor's plant in Montreal, Canada. The simulator will be a replica of the Pilgrim Station Control Roca panel and have the capability of initiating scenarios students may face on the job. (b) Technical: This training will embrace 3 different course programs designed to teach'esployees how to perform technical functions at Pilgrim Station. Programs will include courses in electrical and mechanical maintenance, health physics and chemistry, and instrumentation and control. (c) Staff Development: This traininqr will include courses to meet the needs of plant managers and supervisors at Pilgrim Station. Courses will cover such topics as planning, time management, labor relations,
. CSE1 requirements and administrative procedures.
(d) Comprehensive: This tredning is intended to orient BECO employees on the procedures of Pilgrim Station and will include General Employee Training, Safety traising and Fire Brigade training. Most of the classes are held in the Indoctrination and Security (I & S) Building at Pilgrim. EECO plans to seek full accreditation of its nuclear training programs by the National Nuclear accreditation Board, an arm of the Institute for Nuclear Power Operations (INPO). INPO is an industry group that sets standards for nuclear powei operations beyond *hd*=1 regulatory require =ents. BECO has received accreditation for four operator programs and became a provisional member of the National Academy for Nuclear Training. BECO v111 become a full member when all ten of its courses are accredited. Excesure Reeerds Attachment 3 is a bar graph showing the total man-rem exposures sustained by station, utility and contractor personnel during the years 1916 through 1985. I dividual exposures less than 100 millirems are not included in the total exposures shown. As expected, the largest total exposures occurred in those years during which major refueling and modification activities were carried on. The last majer (refueling) outage occurred during the period { December 10, 1983 to. December 24, 1984. The exposures shown on the graph also reflects exposures resulting from NRC mandated actions. The total combined exposures sustained by station, utility, and contractor paracenal for the period January 1, 1986 to October 15, 1986 is reported to be 557 2 man-rems.
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4 Starting January 1, 1986,.BECO acquired the services of the Yankee Atomic Electric Company (Y1EC) for personnel whole body dosimetry (TLD's). Previously the TLD badges were furnished by R. S. Landauer, Jr. and Company. The TAEC TLD badge consists of two cards with 2 TLD chips per card. All four chips are proceseed at the same time for beta, gamma and neutron results. TLD badge changeout occurs on a quarterly basis with random processing of TLD's on a monthly basis. Processing of TLD's is accomplished on-site during the current refueling outage. Findiers and
Conclusions:
Implementation of the NRC directed Radiological Improvement Plan (RIP) including restructuring of the Radiological Section appears to have strengthened the Health Physics functional role at the Pilgria Nuclear Power Station. Recommendations:
- 1. Provide appropriate and readily accessible life safety gear at the railings of the Spent Fuel Pool.
- 2. Take necessary action to provide workers required to enter radioactive contaminated areas with laundered protective garments that have less than 2 mR/hr levels of residual " fixed
- radioactive contamination.
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. AFD No. I Rocav HILL Roac PLvuouTw. MAssAcmustTTs C23 6o a a scatars October 31, 1986 OMG Letter #86-273 Mr. Frank R. Archibald, P.E.
Industrial Radiation Control Supervisor Commonwealth of Massachusetts Department of Labor & Industries 1001 Watertown Street West Newton, MA 02165
Dear Mr. Archibald:
Refuel Outage #7 was officially declared on 7/25/86. Prior to RFC #7, Pilgrim Nuclear Power Station was shut down on April 11, 1986, for maintenance activities. RF0 #7 consists of the following: Maior Activities to be Performed B & D RHR Pume Inspection / Repair
-. B Core Soray Pump-A & C RHR Pump !nscaction/ Repair .. , , ~ - - - - - - -
A Core Spray Pump Inspection / Repair A Olesel Generator Appendix R Cutover B Diesel Generator Appendix R Cutover Remove Center Fuel Cell for Inspectic'n Platform Invessel Inspections Fuel Offload Rectace 20 Control Rod Drives - . Replace LPRM's-Replace Dry Tubes
- Replace Position Indicator Probe Cables / Connectors
- Replace LRPM Cables / Connectors Fuel On-Load Vessel Reassembly j
System Leakage Hydrostatic Test ' Integrated Leak Rate Test (ILRT) Start-up Checklist Items Closecut - Start-up Sequence Start-up
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, 4 Frank R. Archibald. P.E.
October 31, 1986 Page 2-Channel and Inspect 192 New Fuel Bundles Refuel- Floor . Preparations
' Test and Accept New Refuel Bridge Vessel Otsassemely Control Rod Blades Replacement H2 In-Vessel Probe Installation RF0 #7 Modification Closecuts and Turnovers Hydrogen Water Chemistry Installation
. Extended Test System (ETS) Hydrogen Water Chemistry Appendix R Electrical / Mechanical (Modifications)
Analog Trip System Modification
' EPIC Comcuter. Installation , .
Rx Water Level Reference Leg Modifications i Reg.oGuide 1.97 Control Room Modifications PM/ Overhaul Both Emergency 01esel Generators-Upgrade Fire Dammers and Security Fire-Ocors Herlth Physics Access Control Check Point Modifications Electrical Buses and Breaker Preventive Maintenance INPO Programmatic Issues SALP Programmatic Issues Emergency Battery Pack Lighting - 8 Hour Service Inservice Inscection Program Implementation CR0 - HCU Pipe Clips Diesel Generator Exhaust Drain Modification New Refuel bric;e Installation Pressurize and Inspect Low Pressure Systems l Mode Switch Testing l Start-up Physics Testing and Slow Escalation to Power l l If I can be of any further assistance to you, please do not hesitate to contact me at (617) 746-7900 X8189. - -, s s - ,, ,- ~ -- ~- Sincerely; ,,
/
K.P. Rcberts AVM/ke i
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$AFETY Eval.UATION_
PILGRIM NUCLEAR POWER STATION _ Rev. No. 0 System Calc. POC PCN No.: Date: No.: Name: Dept: Group: Standby Initiator: Gas Treatment N/A 1/29/87 l R. Williams NED S&SA N'/A Uperate ui.. 2:. ey 0.- f i nt: l handling in Hru et. Description of Proposed change, test or exper retreatme - SAFETY EVALUATIQ.N CONCLUSIONS: The proposed change, test or experiment: f occurrence or to i nt important
- 1. (X) Does Not ( ) Does increase the probability co safety previously evaluated in the F5AR.for accident or .
1 J (X) Does Not ( ) Does increase the possibility t d previously in th l ,
- 2. malfunction of a dif ferent type than any eva ua e FSAR. f safety as defined in the 3.
(X) Does Not ( ) Does decrease the margin o basis for any technical specification.See Attachment 1 sAsis iOR SAFETY EVALUATION t0NCLU$10N5 Change Change ( ) Not Recommended (X) Reconnended Date ~50/97 _ 1% SE Perfonned by Rev. 2 Exhibit 3.07-A Sheet 1 of 3 . U NTTACJf. 3 o Ac 77-/.r, j
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DISCUSSION OF CHANGE It has been determined that the Standby Gas Treatment (SBGT) fan circuit does not perform as described in FSAR Section 5.3.3.4. According to this section,
'Upon receipt of any of the initiation signals, both fans start...after a preset time delay, one fan is stopped". While performing a surveillance test ,
(Procedure 8.M.2-1.5.8.3 & 4), the standby fan failed to trip after the time. l delay.
]i SAFETY EVALUATION CONCLUSION !
i I This safety evaluation demonstrates that under the present plant conditions, I the 586T system is operable and fuel handling may proceed. 0 200!T OE*,0GTION (San M234 & E241) The ' Standby" fan is intended to start upon 586T initiation along with the _,
" Auto" fan. This is accomplished by a normally closed contact off of TOR 2-1526 (TOR 2-1426 for other train) which picks up the fan motor starter relay ..
42-1526 (42-1426). The fan is supposed to remain running until the relay
- times out (approximately 20 minutes) af ter which it will trip.
There is a pressure switch PS8136 (PS8135) which will then sense loss of flow-induced pressure. This switch will close a contact when the downstream duct pressure fails below 1.5* we restarting the standby fan. The problem at hand is that the pressune switch has a deadband of 4.5' we which means that its contact will not Pe-open until it senses a pressure in excess of 6" we. Initially, when the 586T gets its initiation signal, the pressure switch senses O' we because the fans are both tripped. When the fans J reach steady state flow, the pressure switches will be exposed to I approximately 3* we which is not enough to reset the 9ressure switch. This ) energizes a second TOR 62-8136 (TDR 62-8135) which, after a 10 second time J delay, closes a contact which maintains the fan motor starter relay in the energized condition. The result is that the standby fan never trips. ]
$86T OPERABILITY j I'
Safety Evaluation 2027 proves that the only operability parameters required of 586T during RF0 #7 fuel handling are its ability to maintain 1/48 we differential pressure across the secondary containment boundary, and its ability to provide a flow rate of at least one air change per day . . Neither of these criteria are compromised by this situation. Safety Evaluation 2027 also proves that during RF0 #7 assuming one fan and 05 filter efficiency SBGT is considered operable. It is, therefore, also true that with two fans and 0% filter ef ficiency 5867 is operable.8oth flow rate and differential pressure can be more easily maintained if both fans are running. The only concern is that the '58GT Trouble or Test' alarm will always be energized which would mask loss of power to a train, or secondary containment isolation system logic train test alarm initiations. Loss of safety bus power would be ]; identified in many other waysby the control room operator. Verification of )i i y
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the secondan containment isolation mode switch on panel C7 in the control room is possible to mitigate loss of this alarm function.- Furthermore, the standby f an can be manucily tripped by the control room operator.Mneref ore, extra diligence on the part of the control room operator would be suf ficient to offset any anomalies. It is for the above reasons that the SBGT system is deemed operable. war owrar 9 h sm ec suse er Tws Fw wu I ge l
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s S l I BOSTON EWsCW i Eiecutive offices I 800 Boyiston Street ' Boston, Massachusetts 02199 J$mes M. Lydon U 0"'***' September 29 '1986 BECo Ltr. #86- 151 f nec'reat Coatrol Des &. U.S. Nuclear Regulatory Consission Washington, D.C. 20555 i Docket No. 50-293 i License No. OPR-35
Dear Str:
The attached Licensee Event Report 86-021 " Standby Gas Treatment System Deluge System Single Failure Mode" is hereby submitted in accordance with the requirements of 10CFR50.73. If there are any' questions on this subject, please do not hesitate to' contact me. Respectfully submitted, J
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l s M. Lydon 1 J BPL/ko
Enclosure:
LER 86-021 cc: Dr. Thomas E. Murley Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission ~ 531 Park Avenue s!ng of P ussia, PA 19406 - Standard BECO LER Distribution I l l c_1___ :- Z '
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On 8/27/86, Boston Edison concluded that a single active failure of the Standby Gas i Treatment (SBGT) Deluge Systes during a design basis loss of cooling accident i (LOCA) or fuel handling accident could result in offsite radiation doses . exceeding 10CFR100.11 limits. An automatic or manual initiation of ther 58GT Delugs Systes l
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would result in the charcoal beds of one 58GT filter train being water. soaked.. Soaking of the charcoal filters would significantly reduce their efficiency for retaining radioactive lodines. The plant is currently in the cold shutdown condition and not conducting operations I that require the S8GT System to be operable. Single failure and effects analysis ' l on the SBGT systes in its entirety is ongoing and is expected to be completed'by l October 31, 1986. This will identify any other active single fatturw which could j prevent the SBGT from performing its safety function. l Prior to conducting operations which would require the S8GT System to be operable. the 58GT System will be verified to be operable in accordance with the Technical Specifications. , mer s e a. 3
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. - ac m , a On 8/27/86, the Boston Edison Nuclear Engineering Department concluded that a single active failure of the Standby Gas Treatment (58GT) Deluge System during a postulated design basis loss of cooling accident (LOCA) or fuel handling accident could result in offsite radiation doses exceeding 10CFR100.11 timits.
The NRC was notified of this conclusion by telephone on 8/29/86, and by letter on 8/30/86, pursuant to the requirements of 10CFR21.21(b)(2). The cause of this condition is an inadequate 58GT System / Deluge System interaction which was included in the original design. The Energy Industry System, system name is " Emergency Standby Gas Treatment System". An Energy Industry Systen, component name is not included in this report as a specific component inadequacy has not been identified. TheS8GTSystemhastwocross-connectedfiltertrainsconsistingofHEPAfliters for particulate reeoval and charcoal filters for todine removal. The 58GT System will start automatically under the following circumstances: 1) upon receipt of high drywell pressure or low reactor water level signals or 2) upon.a.high radiation signal from the ope?ation of the refueling floor ventilation exhaust duct monitors. Automatic initiation of the 58GT Systes starts both 58GT. fans and opens the 58GT isolation campers. Each fan draws air from the isolated Reactor Bu11 ding at a flow rate,of approximately 4,000 SCFM. After a preset time delay,'one< fan.ls , stopped. Cross tie lines with "normally open/ fall open" butterfly' dampers between , filter trains are provided to maintain the required decay heat removal.. cooling 3tr
- 2 flow through the charcoal beds in the inactive (back-up) treatment . train /G,1th'one -
58GTfaninoperation,flowthroughtheactivetreatmenttrainisapprostaagly? 3 y 3.200 SCFM and 800 SCFM through the inactive (back-up) treatment 'tra16.]i g: g",. **J l The 58GT Deluge System *provides cooling and fire protection spray .inJresposise .'t'o" i & high temperatures sensed in the 58GT charcoal filter beds. There.are two'. charcoal . filter beds in each of the 58GT filter trains. Eachbedhas.anas,soclae6de,1uge ;; solenoid valve and a temperature element. An electronic contro10systee} mon,1, ~ tor.s ;;s y , the two temperature elements from one train and opens both solenoid .vajv.es...wheit. . either temperature element senses temperature in excess of 280*F. This automatic' functioning of the deluge system was defeated February 25, 1983, whe'n/ttwas7~e-discovered that the "B" 58GT charcoal filters had been soaked due to leakage,Jpast ,. the Alison Control solenold valve #191004 as reported in LER 83-011., Atithat: time , -" thesanualvalveforthedelugesystemwasclosedandafirewatchwa's"2.'.YO . established. It was during the evaluation of a permanent
- fix to this probles-that ,
the subject scenario was postulated. , An automatic (prior to February 25, 1983) or manual initiation of the deluge system as a result of a real high temperature event or a single failure of either temperature sensor simulating a high temperature, or the automatic ltti ttation (prior to February 25, 1983) as a result of the electronic control systes erroneously tripping would result in the charcoal beds of one SBGT ft'lter train being water soaked. It is known that soaking of the charcoal filters would significantly reduce their efficiency for retalning radioactive lodines. Control Room operators would be alerted to the deluge system operation by annunciation on ' the C7 Panel.
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Pilgrim Nuclear Power Station "'" ' "O# ' E**U 0 !s to jo lo I 2!9 I 3 81 6 - 0I211 -- 0IO 0 13 o' 013 rar . - c. .- e w mawm However, the only prompt action the operator could take to mitigate the release would be to align the deluged filter train as the inactive (back-up) train if it was not already aligned as the inactive (back-up) train. If non-safety related instrument air was not available to close the "normally open/ fall open" butterfly dampers in the system cross tie lines, the minimum flow of approximately 800 SCFM must be assumed to pass through the deluged 58GT train unfiltered for radioactive lodines. The susceptibility of the 58GT System to a single active failure resulting in elevated off-site releases is beyond the design basts'of the plant and involves a reduction in the degree of protection provided to the pubitt health.and safety. Because the $8GT System has not been challenged to perform its design function, the health and safety of the public has not been compromised. The plant is currently in the cold shutdown condition and not conducting operations that require the $8GT System to be operable. Single failure and effects analyses on the 58GT System in its entirety is ongoing and is expected to be completed by October 31, 1986. This will identify any other active single failure which could prevent the 58GT from performing its safety function. Prior to conducting operations which would require the S8GT System, the SBGT System will be vertfled to be operable in accordance with the Technical Specifications. O e a i* O
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Executive offices 800 Boylston Street Boston. Massachusetts 02199 November 25,1986 James M. Lydon Ch ef operating officer BECo Ltr. #86 181 Document Control Desk U.S. Nuclear Regulatory Comissicn Washington, D.C. 20555 Docket No. 50-293 License No. OPR-35 t
Dear Sir:
The attached supplement Licensee Event Report 86-021-01 " Standby Gas Treatment System Single Active Failure Modes" is hereby submitted in accordance with the requirements of 10CFR50.73. If there are any questions on this subject, please do not hesitate to contact me. Respectfully submitted, ws
- hm J s M. Lydon BPL/la ,
Enclosure:
LER 86-021-01 cc: Dr. Thomas E. Murley Regional Administrator, Region i U.S. Nuclear Regulatory Comission 631 Park Avenue King of Prussia. PA 19406 Standard BECo LER Distribution Y I '_ .. ^8_*?"_. __ _ E*.. ?_ 9 "~ . _ . . . .__ [7 ..__.U.t ____.___.__.I_*".N'7__.__.__.___i_Ilm._i._m__________.__1m.___w
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Pilgrim Nuclear Povet Scacion naa " 21 0 ' I'JJ.O Unit No.1 015 t o lo lo l 2l 913 81 6 -- Of 2l1 -- Of 1 Of 2 CE O I 5 TTJct a news ames a opsumet ese asseow awec Asan Juhaw atn This LER is submitted to supplement the information provided on September 29, 1986. On 8/27/86, the Boston Edison Nuclear Engineering Department concluded that a single active failure of the Standby Gas Treatment (SBGT) Deluge System during a postulated design basis loss of coolant accident (LOCA) or fuel handitng accident could result in offsite radfation doses exceeding 10CFR100.11 limits. The NRC was notified by telephone on 8/29/86, and by letter on 8/30/86, pursuant to the requirements of 10CFR21.21 (b)(2). The Energy Industry System, system name is " Emergency Standby Gas Treatment System " code "BH". An Energy Industry System, component name is not inclucea in this report as a specific component inadequacy has not been identified. The SBGT System has two cross-connected filter trains consisting of HEPA filters for particulate removal and charcoal filters for todine removal. The SBGT System will start automatica11.y under the following circumstances: 1) upon receipt of high drywell pressure or low reactor water level signals or 2) upon a high radiation signal from the operation of the refueling floor ventilation exhaust duct monitors. Automatic initiation of the SBGT System starts both SBGT fans and opens the SBGT isolation dampers. Each fan draws air from the isolated Reactor Building at a flow rate of approximately 4,000 SCFM. After a preset time delay, one fan is stopped. Cross tie lines with "normally open/fati open" butterfly dampers between filter trains are provided to maintain the required decay heat removal cooling air flow through the charcoal beds in the inactive (back-up) treatment train. With one SBGT fan in operation *, flow through the active treatment train is approximately 3.200 SCFM and 800 SCFM through the inactive (back-up) treatment train. Additional single failure and effects analyses on the SBGT system were completed on 10/31/86. These analyses concluded that three (3) SBGT . subsystems and related components are' subject to single active failures which could diminish the ability of the SBGT system to perform its safety function;
- 1. Automatic Deluge Subsystem A. Solenoid operated pilot deluge valves SV9008 A&B and SV9007 A&B B. Temperature elements TE9008 A&B and TE9007 A&B C. Contro1' Panels C-68-C and C-69-C i
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Filgrim Nuclear Fever Swation Unit No. 1 01510 t o l e 121913 W6 -- 012 l 1 011 nI' C' n Ic > vsrr , . e, am..nm The deluge subsystem is a totally automatic water spray system with Thea manual override form the Control Room and a local reset switch. active components consist of four solenoid operated ptiot deluge valves. ' SV9008 A&B and SV9007 A&B; four temperature elements. TE9007 A&B and TE9008 A&B: two local " control panels", C-68-C & C-69-C; two pressure indicators and one flow switch. The pressure indicators and flowswitch However. provide indication only and cannot affect the SBGTS in any way. fatture of any of the other active components could result in the soaking of one train's charcoal beds. Soaking of the charcoal beds would In summary. reduce failure of their efficiency for retention of radiolodines. any deluge system active component (with the exception of the indication) cannot be tolerated by 58GTS. The deluge subsystem provides alternate cooling capabilities to remove The decay heat from radiotodines decay heat from the charcoal beds.
' deposited on the charcoal beds during a design basis accident would hypothetically be suffletent to cause deadsorption of radiciodines from the charcoal. Decay heat removing cooling air is provided at If approximately 800 SCfM through the inactive (back-up) treatment train.
the cooling air flow system would withstand a single active failure then the deluge subsystem would not be required to perform the alternate cooling function.
- 2. SBGT cross tie subsystem A. Camper AON-135 Damper AON-135 provides a flow path to allow the required cooling flow to be conducted through either filter train when aligned as the inactive (back-up) treatment train. This is its only safety function. If it were to fully or partially close. It would defeat the cooling air path required to remove the decay heat of the radiolodines deposited on the inactive (back-up) treatment train Closure of the damper could lead to elevated charcoal beds.
temperatures in the inactive (back-up) treatment train charcoal Therefore, it beds is which could release the deposited radiolodines. concluded that single active failure of AON-135 to the closed or partially closed position could defeat the safety function of the SBGTS.
- 3. Humidity Control Subsystem A. Air heaters VGTF201 A&B B.
Contacts on blower motor starter relays 42-1526 and 42-1426 l { I
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( is Unic No. 1 * ,,.. ; ,eg;p - g,,.y mer ,, . =c = m.mm o is Io lo lo l 2l 913 8t 6 - 01211 - 0 11 01 4 0' 015 C. High temperature switches TSW 1 A&B , D. Loss of AC power to the heaters E. Heater contactors (relays) - In order for the activated, impregnated charcoal filters to maintain their efficiency for filtering out radiolodines,-the relative humidity in the air passing through the filters must be maintained at a lov level. This is because the charcoal will preferentially adsorb the humidity in the air. This condition must be met in both the active and inactive'(back-up) treatment train, because, in a design basis 1.0CA, 800 SCFM is passed through the standby train and significant radiolodine deposition will occur. To this end, a multi-element heater is provided in each train. It is separate from and upstream of the NEPA filters that precede the charcoal beds. It is energized whenever; 1) the blower in that train is energized, and
- 2) the temperature switch (TSW 1A or TSW 18) is exposed to less than 150* F.
In the present configuration, the blower in the inactive (back-up) treatment train is not energized and therefore the multi-element heater in that train is not energized. Also, the bypass flow is diverted to the inactive train without passing through the multi-element heater in the active train. Therefore, no humidity control is provided for the bypass flow of approximately 800 SCFM. If sufficient high humidity bypass air is presented to the inactive (back-up) charcoal filters, those filter's efficiency to adsorb radiolodines could-degrade to the point of exceeding the system design basis. Furthermore, failure of the heaters AC power, the control relay (42-1526 or 42-1426), the temperature switch (TSW 1 A or 8), or the heater contactors on the active treatment train could also reduce the charcoal filters' efficiency to the point of exceeding the system design basis. The potential inability of the 58GT system to tolerate certain single active failures has existed since initial plant startup. The impact and root cause of the 58GT system deficiency is.under investigation and is expected to be completed by .1anuary 30, 1987. Modifications to the system are currently being investigated to provide'the 58GT system the ability to withstand any single active component failure. The susceptibility of the 58GT system to a single active failure which could result in elevated off-site releases represents a condition which does not conform to the design basis for the plant, and involves a reduction in the protection provided to the public health and safety. However, because the 58GT has not been challenged to perform its design function, the health and safety of the public has not been compromised. l
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o ls je lc lc j 2] 9l 3 8;6 0l 2l 1 -- 0l1 0I 5 0' 0l5 The plant is currently in a cold shutdown condition and is not conducting 1 operations which require the SBGT.to be operable. Prior to conducting operations which would require the system to be operable, the SSGT system will be vertfled to be operable in accordance with the Titchnical Specifications. No similar previous occurrences have been identifled, however a related problem was identified in LER 83-011.
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APPENDIX 4 REACTOR CONTAINMENT BUILDING INTEGRATED LEAKAGE RATE TEST TYPES A, B, AND C PERIODIC TEST
- BOSTON EDISON COMPANY PILGRIM NUCLEAR POWER STATION UNIT NO. 1 DECEMBER 1984 DOCKET NUMBER 50-293 i
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i Prepared by STONE & WEBSTER ENGINEERING CORPORATION BOSTON, MASSACHUSETTS
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PURPOSE This report describes and analyzes the surveillance Types A, B, and C Containment Leakage Rate Test results. Tests were conducted on Boston Edison Company's Pilgrim Nuclear Power Station, Unit No. I and reported as required by 10CFR50 l Appendix J, Paragraph V.B (Reference 1). l l Specifically, these tests were 'the December 1984 containment ! Integrated Leakage Rate Test (ILRT) and the Types B and C tests performed from April 1982 through December 1984. Stone & Webster. Engineering Corporation provided engineering l consultation services to BECO during their performance
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J ll e SECTION 2 SUMhARY l 2.1 TYPE A
SUMMARY
This ILRT is the first successful ILRT ever performed at the ) Pilgrim Nuclear Power Station. Previous ILRTs at BECO have be e n-successful but only after a .significant leakage path was isolated, or after the containment boundary was inadvertently altered, or after the containment was depressurized to repair leaks. Thus, from a licensing aspect, previous ILRTs have not been considered successful even though the leak tightness of the primary containment was eventually demonstrated. The success of the December 1984 test is directly attributable to the excellent outage coordination and cooperation of the applicable management. , engineering, maintenance / construction, operations and test ! groups. The coordination helped BECO overcome the additional problems of a major recirculation piping replacement effort, the incorporation of several plant design changes, as well as the previous problems associated with past ILRT failures. Sections 2.2B and 2.3 detail the specific items BECO implemented to make this ILRT a successful test. Pressurization of the primary containment was delayed by two separate equipment problems. The first was the failure of the drywell airlock full volume leakage test. The cause of the failure was found when the inner airlock door was reopened for maim:.enanc e . Tie wraps, that had been used to support some tet.porary hoses and cables for some recent drywell work, were found across the 0-rings and the door channels. These were removed. A subsequent local leakage rate test confirmed that this had been the cause of the failure. The second equipment problem was the improper loop calibration for the primary containment dewpoint sensors. Its discovery occurred when the dewpoint temperature vne found to be higher than the corresponding drybulb icmperature. The calibration error was corrected and verified by in-situ comparisons using plant test equipment. Pressurization for the December ILRT was started at 0430 hours and was completed at 0928 hours on December 12, 1984. At 0810 hours on 12/12/84 drywell circulation fan VAC 206B1 was running close to its current limit and was manually secured. Subsequent investigation revealed that, although current readings were high, the current limit had not actually been exceeded and , the fan might not have had to be secured. At 1000 hours fan VAC 206A tripped on overload. TM $9 sonsafety-related fans are not intended to operate at the higher pressure accident condition. The blades had been rt.;4 for the ILRT to provide circulation. Loss of these two fans was not deemed significant 2-1 *
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i 1< to the ILRT because there were still enough fans running to circulate air in the drywell. During the temperature stabilization period,leakage extensive leakage path was investigations were conducted. A water 1984. This was identified at 1100 hours on December 12, high pressure identified as a cracked penetration turbine weld exhaust on a line test connection. coolant injection (HPCI) The leakage was quantified to be approximately 4.75 gallons per minute. No repairs or adjustments were performed. No other significant leakage paths were discovered. Temperature stabilization was indicated achieved at 1330 hours on December an acceptable leakage 12, 1984. Initial trend data , rate even with the identified HPCI test connection leakage path. Tne 24-hour test. period (required cy the Pilgrim Technical Specifications) was completed at 1330 hours on December 13, 1984. The Upper Confidence Limit for this reduced pressure test was 1 0.346244 percent per day as compared toderation the 0.75 Lt limit of test of 0.595986 percent per day. A shorter approximately 6 to B hours could easily have been performed with essentially the same results. The mass versus time plot of Attachment 3.3E gives the stability in the mass trend and the corresponding leakage rate results of Attachment 3.3B. The NRC required the superimposed leakage verification test The be performed in lieu of the mass step chang'e verification test. verification test flow was started at 1352 hours on December 13, 1984. A consistent and stable leakage trend was achieved at 1510 hours and this was used as the start of the verification test. The procedural requirements were satisfied at 1910 hours. It is felt that the last 16 to 18 hours of the 24-hour test provided . this case, the In sufficient confidence in test the test results. did not provide any additional superimposed leakage A potential 18 hours could have been reduced from information. substantially changing the test the actual duration without Ddpressurization was results or the confidence on of these December results. 13, 1984 and was completed started at 2015 hours during the early morning hours of December 14, 1984. After the ILRT, the HPCI test connection weld was repaired a under 3/4-inch the BECO ASME XI Repair Program. Because this was penetration, the leakage test with will be deferred until the next accordance the guideline of ASME II scheduled ILRT in IWE-5222. 2-2 _ a _= n .-_ , -. _,.; ~ - . .
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1 2.2A LOCAL LEAKAGE RATE TESTS (TYPES,B AND C) The local leakage rate tests (LLRT) of containment isolation i valves and primary containment penetrations were conducted as required in accordance with station surveillance procedures since the previous Type A test in February 1982. In accordance with Appendix J, 10CTR50 paragraph V.B, data for the LLRTs are summariced in Section 4. 2.2B VALVE BETTERMENT PROGRAM ] l As part of a review of the historical LLRT seat leakage results, j BECO instituted a valve betterment program. This program focused { en containment isolation valves with a previous history of i excessive seat leakage. Certain valves had been scheduled for ! major overhaul or in fact replacement during this 1984 outage. The following valves represent some of the valve betterment
' actions performed in 1984.
- Main steam isolation valves '(MSIVs) were overhauled.
New stems and peppets with extended nose pieces were installed, new valve guides were machined into the valve bodies, and the seats were rewelded, machined, and polished.
- The feedwater isolation check valves hinge pins were replaced and soft seats were replaced.
- Two reactor water cleanup (RWCU) isolation valves were replaced. The old valves had body to bonnet leaks.
- All the purge and vent valves were replaced. The new valves are butterfly valves with metallic seats.
- Several in-line solenoid valves were replaced with control valves in the H /0 analyzer system.
- Various other valves were -reworked as described in Attachment 4C.
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2.3 WORK CONTROL PROGRAM To ensure a- sucessful ILRT, a number of measures were taken to control work and maintain the containment boundary during the major maintenance and refueling outage. This included training, review of work performed, and daily monitoring of maintenance activites. . At the. commencement of the outage, all test personnel received Xppendix J training for the LLRTs and the ILRT. This included a
. general overview and specific training for Levels I, II, and III test personnel. At the beginning of the ILRT, all contract personnel received briefings on the'importance of work control during the ILRT and the precautions to be observed when working about. the containment or on matters related to the test. The test group reviewed all maintenance requests and plant design change packages to identify activities that could impact leakage
. For example, all of rate testing the or the containment work performed in regard boundary to the H /03 pipe cracking problem was closely observed by the test group. This included extensive post-work and pre-ILRT walkdowns. ,
Morning and afternoon daily status meetings were attended by test group personnel. Previous to the ILRT, an additional Plant Testing Meeting was held daily to discuss and plan actions on items relating to the ILRT. These programs enabled BECO to overcome the previous problems that had caused past ILRTs to be unsuccessful.
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2 APPENDIX $ Testimony before the Special Joint Committee On The Investigation And. Study Of The Pilgrim Station Nuclear. Generating Facility At Plymouth CITIZENS URGING RESPONSIBLE ENERGY.- Diane Buckbee, Plymouth Chairman March 9, 1987 On behalf of CURE, I would like to thank you for this opportunity to testify on the inadequacy of Boston Edison's management of the Pilgrim Nuclear Power Station (PNPS). As we are all aware, it www10 taka months to raviav Boston Ediscn's poor ps fsrmcnc: hist: y. It is a history that begins as far back as June, 1972 when their operating license was issued. I will, instead, concentrate on Boston Edison's performance since the plant was shutdown in April
- of 1986, when Boston Edison instituted its " Pursuit of Excellence Program". The documents I am using to substantiate my testimony are Nuclear Regulatory Commission (NRC) bi-monthly status reports.
In the interest of time, I will present five incidents representative of what we consider to be continuing poor management, performance, safety related problems.
#1. On A,ugust 27, 1986 a potential design deficiency in the standby gas treatment (SBGT) system was identified. In the event of an accident, the SBGT system processes the reactor building atmos-phere to remove radioactive iodine and particulate prior to release from the main stack. Because of the design flav, the potentLal exists for a percentage of the reactor building exhaust flow to pass through the main stack without being processe'd.
Licensee Event Report (LER) No. 21 states that the susceptibil-ity of the SBGT System to a single active failure resulting in elevated off-site releases is beyond the desien basis of the plant and involves a reduction in the degree of protection provi$ed to the public. health and safety. This report further states that prior to conducting operations which would requi,re the SBGT to be operable, it will be verified to be operable in accordance with the Technical Specifications. Yet Boston Edison has purged the' containment and defueled the reactor and we have received no documentation that this problem has been resolved. b " _m[. .. . _".m._%.h".. .,) a_. ,[,. J .' I _ [. , T -, * *'
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#2. Boston Edison failed to perform Nitrogen Make-Up monitoring.
-During operation, the primary containment atmosphere is inerted with nitrogen. A system is in place to add nitrogen as needed.
The significance of not monitoring is that they would be unaware of any large increase in containment leakage. To make matters verse, the instrumentation used to perform the monitoring had , ) been out.of service since January of 1985.
#3.' The licensee is recuired to perform an extensive inservice inspection program. As part of this program, visual examin- .
ations of. piping system supports are conducted. One type is a i hydraulic shock suppressor. This component allows the pipe to move freely during system expansion and contraction, but vill also act to suppress any abnormal vibrations as might be exper-ienced in an earthquake. Lamaged_ supports csuid rc ult in rup-tured or broken pipes. Two such supports were identified as inoperable.
#4. Certain equipment important to safe operation of the plant is protected by fire barriers. These barriers prevent a postu-lated fire from spreading to adjacent areas for at least three hours, allowing time to extinguish the fire. The licensee is required to periodically inspect the barriers to ensure their integrity. Inspections have identified numerous discrepancies between the fire barriers and inspection criteria. Compensa-tory fire watches were initiated. Unfortunately, 17 instances in a twenty-four hour period had been identified where hourly fire watches were probably missed. This is*certainly a dang-erous situation.
#5. In a later related event we are witness to the coup de grace.
In November, Boston Edison was cited by the NRC for a violation of their operating license because adequate procedures and draw- i ings had not been established for the station fire water system. ' This left the plant with no primary water supply to fight a fire l for six days. The backup supply calls for the use of the munici-pal water system in the form of two hydrants. One of these hydrants had been tagged for repairs-six weeks earlier. The inspection report on this incident states that forty " hot job" permits (those allowing activities that could initiate a fire, e.g. velding, grinding) were active. Four jobs were actually in progress and . had to be stopped. A licensee owned fire truck is required to be connected between [ the town water supply and the power plant to be held in standby. l By procedure, a municipal truck would only be summoned after a fire broke out. The on shift fire brigade leader, a licensed reactor operator was asked to demonstrate use of the truck and was unable to.de so as he had not operated the pumper in several years. We have here a situation of degraded fire barriers, mis-sed fire vatches, ongoing hot jobs, no main water supply, one available fire hydrant and a man that cannot operate the station fire truck pumping unit.
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q ENCLOSURE PILGRIM STATUS REDORT FOR THE PERIOD AUGUST 14, - AUGUST 27, 1986 1.0 Plant Status l As of 8:00 a.m. on August 27, 1986, the reactor was in cold shutdown with the reactor coolant temperature at about 120 degrees Fahrenheit. 1 1 2.0 Facility Doerations Summary ine piant has oeen shut down for . alatet:ance, and to mske pregetm improvements since April 12, 1986. An announcement made by Boston Edison on July 25, 1986 indicates that the present outage will continue until early 1987 and will include refueling of the reactor. _ 3.0 Items of Special Interest Standby Gas Treatment System Design problem An Emergency Notification System call was made on August 21, 1986, when the licensee identified a potential design deficiency in the standby gas l treatment (SBGT) system. In the event of an accident, the SBGT system processes the reactor building atmosphere to remove radioactive iodine and particulate prior to release through the main plant stack. The SBGT system has two filter trains which are cross connected. Boston Edison Engineering personnel identified that if one of the trains is assumed to be ineffective during an accident, the potential exists for a percentage of the reactor building exhaust flow to pass through the inoperable train to the main stack without being processed. This could result in higher radioactive release rates. An inadvertent actuation of the fire deluge system in one of the filter trains is one postulated way tnat a filter train could be rendered ineffective. The acceptability of the system design is under review. Failure to Perform Nitrogen Make-Up Monitorine Required by Technical Specifications An Emergency Notification System call was made on August 15, 1986, when the licensee identified that monitoring of the primary containment inerting system makeup flow rates had not been conducted as required by technical specifications. During operation the primary containment atmosphere is inerted with nitrogen. A system is in place to add nitrogen to the containment as needed. Technical specifications require that the amount of nitrogen added be monitored to provide indication of any large increase in containment leakage. Instrumentation used to
, perform this monitoring had been out of service since January, 1985, and as a.res' ult the technical specification requirements were not met.
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2 Local Leak Rate Testing The local leak rate test program started on April 12, 1986, continues. Tests completed through August 27, 1986 include 96 of approximately 101 type B components with 2 failures. In addition, 124 of approximately 133 type C components have been tested with 15 failures. No failuras were identified during this report period. Unsubstantiated Bomb Threats Received at Pilorim On August 24, and again on August 27, 1986, information from anonymous individuals was received stating that bombs had been planted at Pilgeim station. Appropriate security measures were taken. Searchet revealed no evidence to substantiate the claims. The FBI was notified regarding the events. 4.0 HRC Staff Status durino the period Two NRC Resident Inspectors monitored plant activities between August 14, and August 27, 1986. The resident inspector staff at Pilgrim during the report period consists of the following: Martin McBride, Ph.D. --- Senior Resident Inspector Jeffrey,Lyash --- Resident Inspector k
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7 t l ENCLOSURE PILGRIM STATUS REPORT FOR THE PERIOD SEPTEMBER 25. - OCTOBER 8. 1986 9 1.0 Plant Status - As of 8:00 a.m. on October 8,1986, the reactor was in cold shutdown with reactor coolant temperature at about 100 degrees Fahrenheit. 2.0 Facility Doerations Summary The plant has been shut down for maintenance, and to make program improvements since April 12. 1986. Boston Edison announced on July 25, 1986 that the present outage will continue until early 1987 and will include refueling of the reactor. 3.0 1,tems of Special Interest Annual Emergency preparedness Exercise Schedule Chance the NRC and Boston Edison have agreed to postpone the annual emergency - preparedness exercise from October 23, 1986_to December 10, 1986. The postponement will allow other agencies to participate in the drill. , Main Steam Line Weld Flaw Indications During each reactor refueling outage the licensee is required to perform an extensive inservice inspection (ISI) program. As part of this !$1 pro-gram, nondestructive examinations of numerous reactor coolant system welds
,are conducted. The purpose of these examinations is to identify any early si n of pipe or weld cracking. Indications of flaws in or around the welds are documented and evaluated to determine possible cause and effects.
During this report period the licensee began inspection of welds associated with the reactor main steam lines. Five main steam line flaw indications have been identified and are being evaluated by the licensee. The flaw indications are small enough (one inch or less in length) that they do
- not pose an immediate concern regarding piping integrity. The licensee reported discovery of the indications to the NRC via the Emergency Notifi-cation System (ENS). The inspectors will review the licensee's evaluation of these indications, and~any repairs needed.
Hydraulic Shock Suppressor Damage j v As part of the inservice inspection (ISI) program described above visual 1 examinations of piping system supports are conducted. One type of piping support is a hydraulic shock suppressor. This component allows the pipe to move freely during system expansion and contraction, but will act to suppress any abnormal higher velocity vibrations as might be experienced
'in an earthquake. During examination two damaged supports were identified.
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4 l l 2 , The NRC was notified via ENS on October 3,1986. The licensee is evalu- I ating the damage to determine if it would have affected the ability of the component to function. Ongoine Fire protection System Walkdowns Certain equipment important to safe operation of the plant is protected by fire barriers. These barriers prevent a postulated fire from j spreading to adjacent areas for at least three hours, allowing time to extinguish the fire. The licensee is required to periodically inspect the fire barriers to ensure their integrity. H arv deficiencies are identified the licensee is required to take co.vpem atory measures wnich include establishment of a continuous or hourly Mn watch. A series of : ongoing inspections has identified numerous discrepancies between the fire barriers and the inspection acceptance criteria. The licensee is evaluating these discrepancies to determine if they affect the barriers ability to withstand a fire. Necessary repairs and compensatory fire watches have been initiated. On October 1, 1986 the licensee notified the NRC via the Emergency Notification System that 17 instances in a twenty-four hour period had been identified where hourly fire watches wre not properly documented and probably missed. No fires occurred during the time period, however, missing the required watches is not acceptable. The licensee is taking steps to ensure that similar situations are avoided in the future. The NRC will monitor these actions for effectiveness. 4.0 NRC Staff Status during the Period i Two NRC Resident Inspectors monitored plant activities between September 11, and September 24, 1986. The resident inspector staff at Pilgrim during the report period consists of the following: Martin McBride, Ph.D. --- Senior Resident Inspector Jeffrey Lyash --- Resident Inspector A region based inspector was on-site during the week of Septernber 29 to assist the resident inspectors. Also, two specialists inspectors from Region I were on-site during the week to inspect previously identified NRC items in emergency planning and environmental effluent monitoring. Two NRC region based operator licensing examiners were onsite from October 1 - 3, 1985 to inspect Boston Edison's licensed operator requalification training program.
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l 9 - ENCLOSURE PILGRIM STATUS REPORT FOR THE PERIOD DECEMBER S,. - DECEMBER 17, 1986 l 1.0 plant Status ,, As of 8:00 a.m. on December 17, 1986, the reactor was in cold shutdown with moderator temperature about 75 degrees Fahrenheit. 2.0 Facility Operations Summary The plant has been' shut down for maintenance, and to make program improvements since April 12, 1986. The present outage will continue until April 1987 and will include refueling of the reactor. During this report period upper portions of the primary containment and reactor vessel were disassembled in preparation for removal of fuel. The licensee plans to completely defuel the reactor in late January, transferring all fuel from the reactor vessel to the fuel sto-age pool. This will 5" r, oc 'o rman",e # er'.e r ..' u o in d *1 ations wh.6 are mo-e easily done witnout fuel in the reactor. Reloac of the fuel will begin approximately two months later. 3.0 Items of Special Interest
/~PotentiallyInocerableSnubber On December 4, 1986 a potentially inoperable pipe snubber was identified and reported to the NRC. However, a preliminary licensee evaluation indicates that the snubber is acceptable. A snubber is a device used to support piping configuration during an earthquake, yet allow pipe movement during normal thermal expansion and contraction.
Release of a trundry Truck from the Site without a Radiological Survey On December 6, 1986, a contracter laundry truck left the Pilgrim site without proper radiological clearance. The truck had not entered a contaminated area, however, survey of all vehicles for contamination prior to leaving the site is required by licensee procedures. Its ; release was caused by confusion resulting from efforts to allow prompt access of an ambulance for treatment of a medical emergency. The truck driver was instructed to remain ju!.t outside the gate while the ambulance was admitted. The driver of the truck did not understand the instructions and left Boston Edison property. The truck was later located, surveyed and no radioactive contamination found. In the future, security personnel will accompany vehicles outside exit gates during unusual circumstances, such as this event, to ensure that appropriate instructions are given to the drivers and radiological surveys made. The 1 NRC will continue to closely monitor this area and the effectiveness of these controls. ,-
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B ston. Massachusetts 02199 James M. Lydon c et oce airs othce' October 14, 1986 BEco Ltr. #86-159 Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Docket No. 50-293 License No. DPR-35
Dear Sir:
The attached Licensee Event Report 86-023 "Mtssed.Ftre Watch and Fire Watch Patrols" is f.ereby submitted in accordance with the requirements of 10CFR50.73.
'-' If there are any questions on this subject, please do not hesitate to contact me.
Respectfully subettted, W@ mes M. Lydon BPL/ko
Enclosure:
LER 86-023 cc: Dr. Thomas E. Murley Regional Administrator, Region i U.S. Nuclear Regulatory Commission 631 Park Avenue i King of Prussia, PA 19406 Standard BECo LER Distribution i s _n &hwrc _J:T':1v . ~'~Xk: ^ =:b:L ' =* ?:_ : :: _ * - + 2- ' _. n
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,..c,,u..-...-- ._ n On 9/12/86, with the plant in the cold shutdown condition, a Boston Edison Company (BECo) management review of posted fire ' watches identified that a continuous fire watch had not been posted as ordered on 9/5/86. On 10/1/86, while reviewing the documentation for hourly fire watch patrols, the Fire Protection and Prevention Officer (FPPO) identified 17 discrepancies where hourly patrols were not documented i for periods of one to three hours.
Immediate corrective action for both events was to ensure that the required fire watches were adequately manned and maintained. Subsequently, BECo management has provided increased direct oversight of the contractor fire watches. Fire watch personnel have been formally briefed of the identified problems and have signed documents attesting to their understanding of fire watch requirements. BECo is evaluating the adequacy of the organizational structure, staffing level, and training needs of the Fire Protection and Prevention Program to meet the current and long term goals of the Nuclear Organization. i
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"On November 11, 1986 the fire water supply system was determined to be inoperable due to an inadvertent alignment of the fire pump suction valves to Fire Water Storage Tank "B" which had been drained for maintenance on 11/5/86. The operation of the electric motor driven fire pump (with its suction isolated) resulted in the pump becoming inoperable due to mechanical damage. As immediate corrective action. the diesel driven fire pump and associated water supply were aligned to provide the required fire water supply capability.
The misalignment was due to errors in the fire water piping and instrument diagram (PLID) which in turn created errors in operating procedures and l incorrect labeling of the valves. Long term corrective actions included relabeling the valves and correcting the procedures after a system wide walkdown was cc pleted on 11/13/86. Investigation into the electric driven fire pump failure revealed that the damage had occurred to the pump impeller. .The electric fire pump was repaired and declared operable on 2/4/87. While repairs to the electric fire pump were being performed. a minor repair to a 1/4" seal leakoff gland on the backup diesel driven fire pump was recuired on December 3. 1986. Details of the leakoff gland repair are discussed in the " Text" section of this LER. mes ***- 2 ! O m: _ _ _ - _ M* _LmC' ~ = ':- " = W P ~a - -
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l This Licensee Event Report (LER) i s submitted as a supplement to the original which was submitted on November 25. 1986 and provides additional information with regard to operability of the electric fire pump as requested by the Pilgrim Station Senior Resident Inspector. The special report requirements et the Technical Specifications are also addressed with this LER. Event - On 11/11/86 while attempting to wash the "B" fire water storage tank, (FWST, E.I.I.S. system code KP) which had been drained for maintenance, & loss of fire hose pretsure was experienced after one minute of operation. Although all fire pumps (jockey, electric and diesel) started automatically as required, the suction header pressure dropped to zero indicating that fire suppression water was not aligned to the fire pump suction. The reactor was in cold shutdown at the time of this event. The operation of the electric motor driven fire water pump. (EIIS system component code PFR) with its suction supply isolated, resulted in mechanical damage to the pump rendering it inoperable. The diesel driven fire pump remained operable. Cause On 11/13/86 a fire water supply system walkdown identified that the system piping and instrumentation diagram (P&ID) was incorrect with respect to the routing of piping from the FWST's to the suctions of the electric fire pump and diesel fire pump. This discrepancy led to designating the wrong valve numbers on the isolation sheet for the maintenance request issued to wash the "B" FWST. Also the valve descriptions in the Fire Water Supply System procedure as well as the valve label descriptions in the field corresponded to the incorrect P&ID . Implementation of the system _ isolation as per the maintenance request resulted in the Fire Water Pumps being incorrectly aligned to take suction from the "B" FWST while the sur.tions from the "A" FWST had been isolated. Corrective Actions Taken The following corrective actions have been completed.
- 1. The "A" fire water storage tank was aligned as the source of fire water on 11/11/86.
- 2. All hot work (i.e. welding and grinding) was stopped untti the suppression capability was restored on 11/11/86.
- 3. The diesel fire pump was verified operable in accordance with the PNPS surveillance procedure 8.B.1 on 11/11/86.
- 4. A priority maintenance request was issued for repair of the electrical fire pump on 11/11/86.
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- 5. The valve label descriptions were corrected on 11/14/86.
- 6. The P&ID was corrected on 11/18/86.
- 7. A procedure change to correct the valve descriptions in the Fire Water Supply System procedure was completed on 12/9/86.
- 8. A procedure change to revise the System Lineup File procedure to require independent verification of fire water supply system lineup changes was completed on 11/25/86.
- 9. Conducted a walkdown of the fire water supply system which identified other valve label discrepancies for which corrective actions have been identified.
- 10. Conducted a review of other plant systems with buried piping. Identified discrepancies in the Salt Service Water System prints and the Diesel Fuel Oil System prints were of a minor nature and do not affect system operability. Corrective Actions have been initiated to resolve these discrepancies.
- 11. Eight Fire Water Supply System surveillance procedures have been identified which require revision to incorporate independent verification requirements. This effort is approximately 50% complete at this time.
- 12. Completed repairs to the electric fire pump and successfully performed post work testing on 2/4/87.
On December 1, 1986, a leak was identified on the station diesel driven fire pump (EIIS system component code PFR), at the 1/4 inch seal leakoff line leading to the pump's inboard packing gland. A priority maintenance request was issued to allow immediate repair. Compensatory measures were initiated in i accordance with PNPS procedure 2.4.54 during the period of diesel pump ' administrative inoperability. Repair and post work testing was completed within approximately one hour and the pump was declared operable. On December 3, 1986, a nonconformance report (NCR) was issued when it was determined that the 1/4 inch ferrule installed on the seal leakoff line did not have the required material traceability. Issuance of the NCR rendered the diesel fire pump administratively inoperable in accorcance with the Boston Edison Quality Assurance Manual (BEQAM) section 15.2.3. This endition was not recognized until January 22, 1987, when the Boston Edison Quality Assurance organization issued Deficiency Report No. 1644, identifying the failure to declare the diesel engine driven fire pump inoperable in accordance with the BEQAM. 3 .o.. n..
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,w a. . -- . ,. . e - au ,, .m Although the pump was administratively inoperable from* December 3, 1986 to January 23, 1987, the successful completion of post work testing on December 3, 1986 and subsequent weekly operability surveillance tests provide a high degree of confidence that the diesel fire pump would meet its design function. The administrative oversight which resulted in an outstanding NCR on an operable system will be resolved internally via Quality Assurance Deficiency Report No. 1644.
Safety Consequences The lack of immediately available fire water supply identified on November 11, 1986 rendered.the fire water suppression system incapable of performing its design function. The PNPS Technical Specifications require the plant to be shut down within 24 hours of loss of all fire water suppression capabilities. The Technical Specification limiting condition for operation (LCO) was in effect when this event occurred. j During this event, the city fire cross connect was also available to provide back-up water supply. In this configuration, it has been determined that sufficient water pressure / flow was available to service up to 5 sprinkler heads at the highest elevation where sprinkler systems exist. Generally speaking, these sprinkler systems support the protection of the necessary equipment to maintain cold shutdown. National Fire Protection Association (NFPA) studies indicate that 5 sprinkler heads are capable of addressing about 75% of all probable fires. Furthermore, the station pumper truck was available which, when hooked up, provides sufficient capability to support 10 sprinkler heads. NFPA studies indicate 10 sprinkler heads will provide adequate protection to suppress / extinguish 85% of all fires. The use of this pumper truck would also allow the use of one hose station any where in the plant, including the highest elevation in the plant. Little or no increase in risk to the health and safety of the public resulted from this event based upon: ,
- 1. The existing operating condition of the plant, j
- 2. The immediate corrective actions taken,
- 3. The ability of the installed plant sprinkler system to operate as discussed, '
and .
- 4. ,The uninterrupted availability of fire protection systems / processes.
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Representative Peter Forman, Chairman Special Joint Committee on the l Investigation and Study of the Pilgrim Station Nuclear Generatina Facility at Plymouth State House, Room 40 l Boston, MA- 02133
Dear Representative Forman:
As recuested, the following is an update of the Decartment of Public .
, Health's monitorina activities around nuc1. ear power clants: I A. MONITORING ACTIVITIES The Department of Public Health has been conductina extensive monitoring activities in the vicinity of the Pilarim Nuclear Power Plant in Plymouth, Massachusetts since the 1970s.
Since 1980, we have had at 46 locations thermolumenencent dosime-ters (TLDs) which measure gamma radiation exoosu.re at each site over a three month period. These detection devices are main-tained and/or counted by the Department of Public Health, the Nuclear Regulatory Commission, or the Boston Edison Company. Of these, 24 are Department of Public Health stations, 36 are Nuclear Regulatory stations and 17 are Boston Edison Stations. A number of these are located jointiv. These TLDs are chanced quarterly and information from these detection devices would indicate any increase in gamma radia~ tion exposure above background levels to individuals livine within a five mile area. We are enclosing a map showing the location of the of fsite moni-toring stations (Attachment 1). Members of the Radiation Control Program inspect the Pilorim Nuclear Power Station on Tuesday of every week. Durina the inspections the followine functions are cerformed:
- 1) Weekly change of air particulate filter and monthly chance of the charcoal cartridae in the air filtering system. The results of these are included in the NRC confirmatory program and they provide a cross check on the utility monitorine procram as well as demonstrate our capability to perform sample analvsis pro.cedures.
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- 2) . Weekly interviews:
A) NRC Inspectors We conduct a review of plant operation acainst technical , specifications to determine any persistant problems. We j
< review anv plans developed to correct immediate and long rance operational problems. During these meetings, we discuss new NRC regulations, reports, decisions as thev apolv to Pilgrim Nuclear Power Plant. For example, during shutdowns longer'than 120 consecutive days for any reason, the plant has to finish its fire protection work in addition to any other work being done. This particular corrective action will most erobably extend the time Pilgrim will remain shut down (fire protection work involves re-wiring an entire plant's wirina so that a fire in one area can be switched out of the logic loop).
B) Public Relations Officer We meet with the Public Relations Officer to aive us insicht into current public concerns; for examole, emercency drills, plant shutdowns, imaginary PNPS sefety ratings, restart delays (causes and extent), and clant's contribution to local cancer rate increase. C) Plant Chemistrv Supervisor Here we review documentation of environmental effluent releases. After much research, we determined that the chemistrv department generates and maintains records of all plant releases except those that occur durina transportation of material off-site. The Department presently receives 24 hour notification of shioments through Massachusetts from nuclear power plants. The chemistry department e,rovides us with records of: Gaseous releases Main Stack Reactor buildino main vent We weekiv inspect strip chart recordinos of these two release points. Also, hera we can pick up any anomalous activity. Liquid Releases We pick up monthly release records and compare
' concentrations to check specifications.
Solid Releases See notification of shipment procedure above. w1We :;x_ m -m . = ~ ~ .: ~ ,+
k l l Pace 5 As previously described, a basic environmental monitorine orogram is presently being conducted in the vicinity of the Pilgrim and Rowe nuclear power plants. However, the Department could, with the proper resources, establish a state-of-the-art comprehensive monitoring program in this area. This comprehensive procram would include personnel specifically dedicated to nuclear power plant activities and also include increasina the number of noni-toring stations and changina these on a monthlv rather than a quarterly basis. The procram would also involve the collection and analysis of water and milk samples on a monthly basis instead of quarterly, and food, fish and sediment samples on a quarterly rather than an annual basis. If needed, the filters on the air samplers could be changei on a daily basis. l C. NUCLEAR POWER PLANT REAL TIME MONITORING SYSTEM (TELEMETRY) The Massachusetts Department of Public Health is investicatino the feasibility and usefulness of a real time menitoring system for nuclear power plants which would involve tha transmission of ongoing radiation levels at selected locations within the boun-daries and off-site of nuclear power plants to a State facilitv. This system would allow a State agency to know immediate1v if and when radiation was released into the environment. Presentiv only the State of Illinois has a comprehensive real time telemetry system in place. Most of our information has been received from Illinois and the cost estimates are developed based upon fi4ures obtained from the manufacturer of the equipment used in this system. The program in Illinois involved approximately six years develno-ment time and once in place needs constant attention. Since the state-of-the-art in this area chances rapidly, the ecuipment must be constantly up-dated, modified, or replaced. The Illinois Department of Nuclear Safety's Remote Monitorina System (RMS) incorporates three maior components: cross gamma detectors radially positioned around each nuclear power stations on-line automated, isotopic caseous effluent monitors which sample from major engineering release points; and an on-line reactor carameter data communication link to each facility's on-site computer. In addition, on-line liquid effluent monitors, which will be located at each plant's liquid discharge points, are scheduled'for installation at two sites within the next year. All RMS components are connected through dedicated data com- { munications links to the Illinois Department of Nuclear Safety l Radiological Emercency Assessment Center (REAC) located in springfield, Illinois. At the REAC, technical staff, comprised j of nuclear enaineers, health physicists, and other nuclear safetv l specialists, review the data and nerform analyses of plant con-ditions. This REAC staff is divided into two analytical aroups, one concerned with the status of reactor safety systems and the
,other with environmental assessment.
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Pace 6 An estimate of the cost of a monitorine system similar to.the existing system was obtained from Reuter Stokes in Cleveland, Ohio. The following is an estimate for a basic svstem for a sincie power plant which would allow Massachusetts to add on as
. needed or as new technolocy becomes available:
Breakdown of Costs Remote Sensor $16,000 16x16,000 = $256,000 Computer $100,000 $100,000 (This computer should be able to handle up to 64 remote sensors) ' ~ Spare parts $18,000 , S 18,000 Installation per $12,000 16x12,000 = $192,000 sensor Phone charges $2,000/ 12x2,000 = $ 24,000 month - Personnel $150,000 $150,000 (One of Each - Scientist, Electronic Encineer, Computer Operator, & Clerical) Calibration $400/ 16x400 = S 6,400 unit Maintenance & Repairs $30,000 S 30,000 Total Estimated Cost $776,400 (Per power station oer vear with 16 remote sensors) It should be noted that each power station in this country that emoloys this telemetrv system has had 10-16 remote sensor sta-tions. Outside of the U.S. (e.c., Finland or Korea), an averaca of 10 is common. The State of Illinois estimates that their cost of the telemetrv system averace calls for two million dollars / reactor. This was due to the cost of developing the system, as well as the fact that the entire operating cost of the Radiation Control Program (x-ray inspections, nonionizing, nuclear medicine inspections, etc.) was included in their budoet orocess. The Massachusetts' estimates above are based on a pro-posed procram oniv for monitorine a single nuclear power plant. 9
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Pace 7 D. RELEASES FROM PILGRIM DURING JUNE 1982
- 1. The first event took olace at 3:22 p.m. on June'3, 1982 in which the plant declared an Unusual Event because a tra-versing incere probe (TIP) became dislodced from its track leaving the probe outside of the' reactor vessel in the reac-ter building. This led to a hich level of radiation within the building which could have presented a hazard to workers in the area. The area was cordoned off until the TIP could be reinserted into-the reactor vessel. The NIAT team responded to this Unusual Event which was raised to an Alert level, by activatina the NIAT team at.the Emergency operations Facility. This Alert was terminated at 5:20 p.m.
when the exposed detector was-shielded to prevent exoosure to individuals. There was no release of radioactivity offsite . and the Alert presented no public' health. problem.
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- 2. The second event occurred on June 11, 1982 in which scent resin was detected by the health physics team on rooftops and cavement within the protected area of Pilgrim Nuclear Power Station. This resin was identified as coming from the con-densate demineralized system. Durina resin transfer coera-tions into the condensate demineralized resin escaped throuch an open vent valve. The identification of the resin was observed by a health physics technician while collectina ran-dom supplies on top of the condenser retube.buildina as part ef a ceneral site survev.
An extensive survey was conducted both onsite and offsite. Small quantities of resin were detected on-sections with the protected area to the south and west of the plant. The total amount of resin found outside of the crocess buildinas was less than one cubic foot. Vehicles in the parkina lot, the storm drain outlet to the discharge canal, the shorefront area, main stack area and soil samples collected in selected areas did not show any activity above background. In this situation there was also no telease of radioactivity offsite and no threat to public health and safety. Enclosed are copies of the U.S. Environmental Protection Agency's sampling reports on contamination in air, water and milk throuahout the country for June of 1982. Also attache? are tables from the Nuclear Reculatorv Commission's TLD Direct Radiation Monitoring Network (NUREG 0837, Vol. II, Numbers 2 and 3) for PNPS for the second and third cuarters of calendar year 1982 (Attachment 3). All of the above do i not show any significant increase in radioactivity which could be attributable to a release from the Pilgrim Nuclear Power Plant. In conclusion, the above information does not appear to indicate any releases of radioectivitv above background that could be attributable to the Pilgrim Nuclear Power Plant durino June of 1982. j l . Lmm .wwm-mm . - ~ - --
a 4 Pace 8 We hooe that this has responded to all the cuestions that you raised. If you'have any further questions, please do not hesitate to contact this office. Sincerely, . sg e > M_1_ t Bailus Walker Jr. , Ph.D. , M.P.H. Commissioner i i Attachments (3) , i l l l l 4
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' "" M Offff Office of the Assistant Commissioner Bureau of Environmental Health Services-February 19, 1987 Representative Peter Forman Massachusetts House of Representatives State House, Room 40 Boston, Massachusetts 02133
Dear Representative Forman:
Per your request, enclosed is a description of the rele of the MDPH in Emergency Response at Nuclear Power Plants. If you have any questions, please do not hesitate to contact this office. Sincerely, lbf Gerald S. Parker, P.E. Assistant Commissioner GSP/erp Enclosure (1) i 1 -
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I ATTACHMENT The Role of MDPR In the event of an accident at a nuclear power olant the Decartment of Public Health is notified throuch the appropriate State Police Barracks. Upon receipt of the notification the'princloal represen- i of the Department tative of the Nuclear Incident Advisorv Team (NIAT) of Public Health immediately call.s the control room of the nuclear power plant to ascertain the extent and severity of the accident. I6 the event that the Decartment of Public Health's response is warranted, individuals are sent to the Emeroency Operations Facility (EOF) of the plant, the Emergency Operations Center (EOC) in Framinoham and the appropriate media center. The response of the Decartment of Public Health is desioned to acecmolish the following secuence of events:
- 1) Confirmation that a radiation emergenev does indeed exist.
- 2) Notification to appropriate response individuals and ace!.cies identified in the Comprehensive Emercency Response Plan (CERP) .
- 3) Evaluation of the radiation hazard.
- 4) Comparison of the radiation hazard acainst protective action guides as detailed in the CERP.
- 5) Recommendation of appropriate and timelv protective actions es detailed in the CERP.
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- 6) Performance of radiation surveys to confirm that ambient radiation levels are low enough to permit re-entry of the ceneral public.
l Individuals specifically assigned to the various areas have secerate functions to perform. The individual at the EOF, from the Radiation Centrol Procram (Radiation Control Program Director or his desionee), will represent the Department. The individual's primarv respon-sibility at the EOF will be to assess the effects of the accident and make recommendations of appropriate protective actions to his counter-part at the MCDA Headquarters in Framincham. This initial decision will be based on olant' process parameters and the recommendations of the utility. The individual will be responsible for coordinating field measurements and samole gatherina bv all State and Federal acen-cies. The individual will work in concert with the NIAT coordinators in Framinoham and Boston. There will also be an individual at the MCDA Framinoham EOC. The control of the accident at the State level will be implemented from MCDA Headquarters at Framincham bv the MCDA. All recommendations con-cerning protective actions will come to the Commissioner of Public Health (or his desionee) from the NIAT coordinator at the EOF. The Commissioner for his desionee) will relay the recommended protective actions to the CD Director who will then implement the protective actions. Further responsibilities of the Commissioner of Public
- Health (or his designee) include provision of hospital, medical, and ambulance information. He will be responsible for coordinating State g
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O Pace 3 and Federal acency resources to supplement the environmental moni-toring at the reactor site based on recuests by the NIAT coordinator at the EOF. Oniv the Commissioner of Public Health (NOT his designee) may* authorize the administration of potassium iodide as a thyroid blockinc agent for emergency workers. In the unlikelv event that a DPH individual is not at the EOC, the NIAT coordinator at the EOF can relav the recommended erotective actions to the CD Director. There will also be a Decartment of Public Health person at Boston who will be responsible for coordinating the Department's response with that of Framingham and the utilitv. The person will activate NIAT and New England Radiological Health Compact personnel and provide the Department of Public Health with backup and relief personnel to Framingham and the EOF. There will also be an individual assioned to the joint State / utility media center to answer technical questions concernino the accident as it relates to public health and safety.
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Docket No. 50-309 RfGULATORY PERFORPfANCE N!KTORY . 5 . A tabulation of significant af festones anh enforcement actions as of June 19, 1986
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June 1972 Issued operating license. December 1973 shutdown order issued to inspect for and re-pair fuel channel box damage. . December 1974 - Fuel fa.ilute:,.tly.dfjd.ing and pellet-clad interaction vanures resulted in Mgh gaseous activity. Operation with the fuel cladding perforations resulted in high dose
- rates in locations requiring access for operation and maintenance. During 1975. 76 and 77, power was limited betwen 60-805 to maintain offgas " activity within regulatory requirements. The last of the defectiv'e fuel bundles was replaced during the 1977 refueling outage.
May 1975 A civil penalty ($12,000) was assessed for I violations concerning Inservice Inspection !
- activities identified during an inspection n- - conducted December 1974 - February 1975.
July 1976 Management meeting to discuss concems . I related to the management and implacentation of the Health Physics Program. I October 1976 Management meeting to discuss concerns related te management and teplementation of I the Health Physics Program. November 1977 Management meeting to review licensee efforts l to strengthen Radiation Protection Program. ) l March 1978 A civil penalty ($16.000) was assess 4d'for ) violations identified in inspection report j
. 50-293/77-31. The violations were: over-exposure of one individual; failure to in -
struct personnel in acconfance with to CFA . 19; failure to perform required air sagling; and failure to follow procedures. l' September 1978 hanagement meeting to discuss concerns on
- 'recent inspection findings (all areas).
5eptemler 1979 - Management' meeting to discuss violat, ion of _," . ._ primary containment integr.ity. _ , October~ 1979
-- - A c'ivil penalty (35.000) was assessed (oV a _
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- violation identified in inspection ~ report ---
~ -- '50-293/79-15 iny'olving a fatIvce to-follow .
- . the. Security Plan. -.
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February 1980 A civil penalty ($5.000) was assessed for shipping radioactive materials with external
. radiation levels in excess of regulatory limits. 1 March 1981(SALP) Mana nt setting to discuss theuresultut.f _ .
l the P for the period January 1,1980 to December 31, 1980. - April 1981 A civil penalty ($13.000) was assessed for events surrounding suvemnt ur Irtsdieted fuel without secondary containment as identified in inspection rep'o rt s ". 50-293/80-09. - July 1981 A management setting was held in July 1981 to i discuss concerns for TMI Action plan Items
. -- involving post accident sampling procedures and equipment and an Issuediate Action Letter was issued regarding implementation of these l
. -- items. Meeting was prompted by a June 1981 l radiation protection inspection (50-293/81-14) found the licensee failed to conform with NRC criteria in connection with 4 of the 5 NUREG-0578 Category A items inspected.
June - September 1981 Inspections 50-293/81-18 and 81-22 identified six problems; inoperable combustible gas contr91 system; failure to perform an adequate 50.59 review; failure to provide { appropriate procedures and drawings; failure ' j to make a report required by Technical i Specifications; failure to provide ac" cur, ate ! information to kRC; and failute to satisf -
- an Limiting Cend! tion for Operation (LCO)y ]
regarding pr'4 mary contairunent isolation valves. These inspections were subsequently - the subject of enforcement actions taken in 1 January 1982.
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A Performance Appraisal Inspection (50-293/ _ _ :- _ 81_-20) found 5 of 8 areas examined below l
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, . . assu'rance audits; maintenance .
- quality'ive correct action systeess licensed and non-
~ . _. . _- " licensed training; and pr5curement. Plant u-
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. operations and design changes and modifRa-tions were found to be average; however.'
_ .: __ ~ __ ____ P- _ significant uitiknesses were- identified in -
- both areas.
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October 1981 Enforcement ccnference to discuss management . controls of safety related activities in- l cluding the violations identified during i inspections 50-293/81-18 and 81-22. the Perfonnance Appraisal Inspection 'results, and an interim SALP revies (period Saptember 1.1980 - August 31,1981). January 1982 Civil penalty ($550,000) assessed for failure to comply with requirements of 10 CFR 50.44; submittal of false information to NRC and subsequent delay of notification to XRC of known inaccurate inforation; and., failure to comply with LCO for RCIC ' containment isolation valvet, (PIP) Order sodifying Ifeense required licensee to submit a comprehensive plan of action that would yield an independent appraisal of sita e and corporate management, reconnendations for improvements in management contm1s and oversight, and a review of previous com-pliance with NRC requirements. Management meeting to discuss implementing requirements of the NOV/ proposed civil penalty and order redifying license regarding the independer.1 appraisal of Boston Edison Company (BEco) management practices. January 1982 Inspection report 50-292/81-26 identified a severity level III violation for transporta-tion of radioactive materials with lisW in the containers. This violation was based on
. an inspection in August 1981 by the State of South Carolina which resulted in issuance of a civil penalty ($1.000). ,
March 1962 Boston Edison Company (BEco) submitted the Perfernance Improvement Program (P!P)
. . . required by the January 1982 Order.
NRC Management meetings to review-status of the Perforr.aace Improvement Program were
~ - . held approximately every six weeks until ..
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4 June 1982 A special inspection (50-293/82-20) condseted of licensee actions after radioactive spent resu was found on roof tops and pavement within the protected area. No violations identified. Confirmatory Action Letter fssued concerning actions to be taken
.reparcing the spent resin.
July 1982 ~ Enfere.ement Conference to discuss exceeding
. an LCO associated with the Reactor Protection System water level instrumentation. -
.m August 1982 Enforcement Conference to discuss exceeRing an LCO associated with the Vacuum Breaker Alarm System.
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. Septancer 1982' (SALP) Management meeting to discuss the results of the.5 ALP for the period September 1,1981 to V '. .
June 30, 1982.
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August 1983 A shutdown order was issued requiring the licensee to shutdown in December 1983 and inspect tne recirculation system piping for Intergranular Stress Corrosion Cracking. It required them to remain in cold shutdown until Luthorized to restart by the Director of NRR. The licensee replaced the recirculation system piping and was authorized to restart in Decer6er 1964. Septerher 1983 ($ ALP) Management meeting to discuss the results of the SALP for the period July 1,1982 to June 30, 1983. **
. November 1983 Managementmeetingtodiscushrefueling/ pipe replacement preparations.
January 1984 Confirmatory Action Letter issued regarding licensee actions relative to health physics
- - practices following the discovery of small.
highly radioactive sources in the control r rod drive repair room.
-- Febtvary 1984 -
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- confererice trolled handling of small, regardin{y high
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. 5 April 1984 A civil penalty ($40,000) was assessed for groblems in connection with the uncontrolled
- handling of small, highly radioactive sources in the control rod drive. repair room between January 14 and 18, 1984. The violation involved identified problems with the labeling of containers,-::.M.Tof' -
extremity dosimetry and the adequacy of . 1 instmetions given to individuals working in the repefr room. , Septes6er 1984 Management meeting to discuss a second .
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instance of the uncontrolled pmsenc.e.ef small, highly r.adioactive sources in' the control rod drive repair room. October 1984 Enforcement conference on the unplanned ex-tractity exposure (within regulatory limits)
- connected with the small, highly radioactive
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i sources in the control rod drive repair - room. (Follow-up to September 1984 i
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management meeting on same subject)
...k-Confirmatory Action Letter issued in .
- ennection with recurring radiation '
protection program weaknesses. The letter
- outlined licensee plans for evaluating and correcting these weaknesses.
November 1984 An order modifying the license was issued in connection with recurring weaknesses in the radiation protection program. The order re. quired the licensee to complete an -- independent contractor assessment of the radiological controls program and to submit
- to MRC review and approval a Radiological Improvement Plan (RIP) for upgrading the radiological controls program. Followup .
inspections conducted in May, August. and November 1985 and April 1986. D . A Severity Level 111 violation (no civil i penalty).was. issued for failure to perfom
- - .. radiation surveys; failure to instruct
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- workers in.accordance with 10 CFR 19; and .
_ failure to properly implement a procedure in -
' - connection with the unplanp.ed exposure noted .
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January 1985 (SALP) Management meeting to discuss the results of
, the SALP for the period July 1,1983 to September 30, 1984 Enforcement conference to discuss ~en ' ~ ~ --"" ~ ~
unplanned occupational radiation exposure within regulatory limits associated with- --- sludge-lancing operations on a waste tank as identified in inspection 50-293/84-44. August 1985 Enforcement conference to discuss licensee's action on abnormal surveillance test results and a degraded vital area barrier. , , , October 1985 A civil penalty'($50,000) was assessed for the degradation of a vital area barrier. November 1985 A safety system functional team inspection (50-293/85-30) was conducted by the Office of Inspection and Enforcement to assess the operational readiness and function of selected safety systees. The inspection identified that the Itcensee had not effectively mitigated a water hanner problem associated with the HPCI turbine exhaust
. line which had been occurring since the beginning of plant operation. Weaknesses were also identified with the licensee's design change process; control of plant instrumentation; handling of vendor informa-tion; program for approving and validating emergency operating. procedures; capability to conduct a plant shutdown from outside the control room; and maintenance progras for notar operated valves. .
February 1986 Inspection report 50-293/86-04 identified a severity level !!! victation for failure to , meet packaging requirements for low specific activity radioactive materials. This viola-
. . tion was based on an inspection in January 1986 by the State of South Carolina which resulted in issuance of a civil penalty
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March 1986(SALP) Management meeting to discuss the results of the $ ALP for the period October 1,1964 -
. October 31. 1985. ;
February-March 1986 A special diagnostic team inspect"fon 50-29 4 ri N 1 MAf g,[gfQ3 dl5KE51M5 WHeilEKM MM'/ lying reasons for the licensee's poor performance described in the most recent 5 ALP and to escartain whether they could
- have an adverse impact on the safety of plant operations.
April 1986 An Augmented Inspection Team (AIT) conducted an inspection of recent operational e~ vents which included 1) the spurious group one primary containment isolations (and associated reactor scrams) that occurred on April 4 and 32, 1986. 2) the failure of the main steam isolation valves to promptly
~ reopen after the containment isolations, and jf ,,, ~ 3) the recurring pressurization of the - #]'W- residual heat maoval system. The AI) found .
the licensee's evaluations following the ! second event to be carefully structured and thorough. A Confirmatory Action Letter concerning the events was issued which required the licensee to provide a written report prior to restart containing the
. bk . shi.Ih Y Administrator authorization for restart.
q Mkb! Inspection (50 2g3/86-10) reviewed . implementation of the RIP. The inspection found the if censee adequately addressed 13
- of the 34 items reviewed.
May 1986 Management meeting to discuss evaluations and corrective actions concerising the operational
- events of April 4 and 12,1986.
June 1986 . . The first in a planned series of management
! . meetings scheduled to review BEco management oversight of the implementation of the licensee improvement programs in vmgress. ,
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I EMERGENCY ACTION PLANS 1981 - Present l i June 3, 1982: Alert declared A Traversing In-Core Probe (TIP #2) was withdrawn out of its shield int'o the TIP machine. Increased radiation levels were limited to a minimal area within the TIP room. There were no increased radiation levels elsewhere in the building or on-site. The alert status was terminated in about two hours. , August 18, 1982: Unusual event declared A fire was reported in a mask fit machine. The fire was in a mask fit booth in the retube building outside the reactor building. April 16, 1984: Unusual event declared A person injured in the drywell required immediate medical attention and was sent to the hospital. Because there was no time to deter'nine if contamination was present, plant personnel took the conservative route and declared an unusual event in case he was contaminated. It was later shown the person was not contaminated and the declaration of the unusual event would have been unnecessary. May 16,1985: Unusual event declared The 'B' diesel generator was declared inoperable when a pre-lube pump tripped. About the same time, plant personnel noticed potentially degraded pipe hangers in some other safety systems. Being unsure if the pipe hangers could render those systems inoperable, plant personnel acted conservatively and declared an unusual event and began plant shutdown procedures. The pump was repaired in about two hours and the unusual event was terminated. May 23, 1985: Unusual event declared Wt le the high pressure coolant injection system was inoperable due to maintenance, the 'B' diesel generator pre-lube pump tripped again. Plant
. operating r;rocedures mandate that if two ufety systems are inoperable st the same time, an unusual event must be declared. The pre-lube pump motor was replaced the same day and the unusual event was terminated.
Sectember 20, 1985: Unusual event declared The low pressure coolant injection system and the 'A' diesel generator were both declared inoperable due to maintenance. October 15, 1985: Unusual event declared While the 'B' containment cooling system was inoperable due to surveillance testing, the 'A' diesel generator failed to lock onto the bus properly but did not affect the operation of any safety systems. , i
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l l November 4. 1985: Unusual event declared While an RHR pump was out of service for modifications, a valve failed in the suppression chamber cooling system. January 9, 1986: Unusual event declared 4 , A fire was reported in a hydrogen tank storage area which 15 in a
- l. remote location away from the reactor building. The fire was extinguished in 30 minutes with no damage, no injury and no loss of generation. Flant operating procedures mandate that, if a fire on site cannot be contained in 20 minutes, an unusual event must be declared.
February 14. 1986: Unusual event declared While a valve in the low pressure coolant injection system was out of service, it was determined that the oil in the 'A' diesel generator was out of specification for viscosity and declared inoperable. April 11. 1986: Unusual event declared Two primary containment isolation valves in series indicated leakage and were declared inoperable. Plant operating proce'dures and technical specifications require that if two valves in series indicate 4 leakage and cannot be repaired within 24 hours, an unusual event must be ! declared and the plant must be taken off-line. 1 i
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i e l l f l 1 l 1 D l APPENDIX 9 I q
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APPENDIX 9 1 l i THE COMMITTEE ON NUCLEAR MATTERS MEMBERS: Grace M. Healy, Chair Charles W. Adey Ann Waitkus Arnold Theodore L. Bosen Marie P. Tahlow . Kenneth T. Holmes Kathleen M. Leslie Anthony V. Ionardo John P. Rooney James W. Ryan Howard E. Shetterly SUBCOMMITTEE MEMBERS: Ann Waitkus Arnold Kenneth T. Holmes I
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'a TOWN OF PLYMOUTH THE RADIOLOGICAL EMERGENCY RESPONSE PLAN _
1 INTRODUCTION As one of its tasks, the Committee on Nuclear Matters assumed respon-sibility for a re riev of the Plymouth Radiological Emergency Response Plan (RIRP). The following is the result of research undertaken by subcommittee members Ann Waitkus-Arnold and Kenneth Rolmes, and of the deliberations of the entire committee. In order to determine Plan adequacy and feasibility, information was sought from many sources. Subcommittee members reviewed written materials: other Emergency Response Plans (ERP); Federal Emergency Management Agency (FEMA) Regulations; reports on the adequacy of various RERP's; testimony of public interest groups, and one available section of Secretary Barry's report. Subcommittee members also contacted, in person and by telephone, representatives from (1) Local, Regional and State Civil Defense Offices, (2) FEMA, (3) various Town Offices; (4) State Office of Handicapped Affairs; and (5) Boston Edison.
SUMMARY
CONCLUSIONS AND RECOMMENDATIONS Moreover, these There are deficiencies in the Plymouth RERP. deficiencies are serious enough, in the Committee's judgment, to preclude
"... reasonable assurance that adequate protective measures can and will be ,
taken (by the Town and State) in the event of a Radiological Emergency." There is reason to believe that as things stand now, the Selectmen cannot fulfill their legal responsibility, particularly during a Radiological Emergency, ".... to provide for the health and safety of persons and their property ...." j The Plymouth RERP is a " paper" plan, essentially untested relative to mobilization of some of the essential personnel. As long as it remains such, difficult questions and their related decisions can be avoided. This is a situation unacceptable to the members of the committee. Thus, we respect- j fully urge Selectmen to assign tasks and timelines to appropriate personnel i and/or offices to ensure accomplishment of the following: ] A. Comprehensive revision of the Plymouth RERP.
- 1. Correction of outdated information.
- 2. Elimination of specific deficiencies noted below.
- 3. Complete specification of implementation procedures.
- 4. Specification of procedures for ongoing updating and coordination with local, area, and state plans.
- 3. Appointment of a. full-time Civil Def ense Director, with staff as needed, with adequate interim headquarters, and with long-term plans for location in one of the new Town buildings.
C. Development.of funds for emergency preparedness from federal, state l I and utility sources. (Appointment of liaison for same.) O 9 4 e
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I I i Full Town participation in a comprehensive drill prior to Pilgrim's
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coming back on-line. (While actual citizen evacuation may not be feasible, full participation must at least include A1.1. Coordination responsible personnel being in-of agencies , their place. and carrying out assigned tasks.) services and lines of responsibility - local, state, federal levels must be tested.
' These recommendations, together with those which follow, in the unanimous opinion of the Committee, do merit immediate attention. There the is, opinion within the committee relative to however, dissenting recommendation that all deficiencies must be remedied and all recommendations implemented prior to reactor start-up. The dissenting opinion Rence,isthe based upon objection feasibility of timelines for task accomplishment.
relates to making total task accomplishment a condition for reactor start-up when longer time may be required for some tasks. The dissenting opinion does on time-not represent disagreement on deficiencies or recommendations, but lines . In all cases there is agreement on need and urgency for action. SPECIFIC DEFICIENCIES AND RECOMMENDATIONS Following are specific deficiencies 19,331 by the Committee on Nuclear Matters and some recommended corrective measures;' they have been grouped in eight categories: (A) Advance Information, (B) Notification and Communication Systems, (C) EvacuatiJa Routes, (D) Evacuation Time Esginates, (E) Transport of Dependent' Populations. (F) Reception Centers and Public Shelters. (G) Medical Facilities, and (R) Radioprotective Drugs. A. ADVANCE INFORMATION DEFICIENCIES:
- 1. Inadequate public information in Emergency Preparedness Zone (EPZ).
Lack of multi-lingual information (Italian, Portuguese, Spanish, 2. Japanese).
- 3. Inadequate distribution of Energency Preparedness Information (EPI) brochures.
- 4. No information for people without access to transportation.
- 5. No information about staging areas (pick-up points).
- 6. Tourist and transient information inadequate or non-existent.
- 7. No educations 1 effort outside the Town of Plymouth, s
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ADVANCE INFORMATION (Continued) RECOMMENDATIONS:
- 1. Implement a comprehensive, ongoing public educational program through news ads, cable TV programs, radio public service announcements, and infor1 national packets included in utility bills. Include an outreach program for non-English speaking people in these activities.
- 2. Develop emergency information posters (multi-lingual), with maps explaining:
- Protective Actions - 1,ocation of Public Transportation
- Evacuation Routes - Local Radio Station of EBS
- Location of Public Shelters - Etaging Area locations
- 3. Post Emergency Information Posters in public locations:
Hotels, motels, restaurants, gas stations, phone booths, recreation facilities, tourist sites, informational centers, theaters, airports , bus stations, trolley cars, and all public' buildings. 4 Develop survey to identify special populations:
- a. Non-English speaking people.
- b. Transport dependant groups:
- 15: of Plymouth households have no car;
- 50% of households have one car, but one half of workers have jobs outside of Plymouth.
- c. Special needs' people:
- Federal regulations require notification of "all segments of society."
- Deaf and hard-of-hearing people must be identified beforehand so they can 'oe alerted by appropriate means.
- 5. Distribute updated pamphlets semi-annually to:
- General public and all recommended locations in f3 above.
. Multi-lingual pamphlets should be available in the same places.
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- 3. NOTIFICATION AND COMMUNICATION STSTEMS DETICIINCIES:
Siren System )
- 1. l
- a. The siren system is not equipped to confirm that ALL sirens have been sounded during an exercise. There are no provisions for determining which sirens are not working.
- b. Present siren system does not warn hearing-impaired persons. No alternate plan exists to notify this segment of the population.
- 2. Radio Communications
- a. Department of Public Works radio equipment used for Civil Defense is unreliable and inadequate.
- b. Present system for notifying local officials is unreliable.
- c. Plymouth County radio network (Sheriff's) is inadequate /
inef ficient . RECOMMENDATIONS: ALL PROCEDURES FOR NOTIFICATION OF AN ACCIDENT AT PILGRIM I SHOULD BE REVIEVED.
- 1. Investigate the "hard-wire" system or other alternatives that confirm siren activation. Alert officials vbo will dispatch personnel to areas with defective sirens to activate sirens manually and to warn public from vehicles and loudspeakers.
Develop procedures to confirm activation of every siren. Specify 2. numbers of vehicles and personnel required for #1 above.
- 3. Test sirens weekly on the same day and at the same time.
- 4. Identify hearing impaired people and install telecommunication devices.
- 5. Provide closed captioning for the Emergency Broadcasting System,
- 6. Install tone alert radios in every schoo'1 bus, transport vehicle, and other vehicle specially licensed to transpo.rt children, the elderly, and handicapped persons in the Emergency Preparedness Zone.
- 7. Upgrade Plymouth County Radio network hardware. Test the hardware on a regular basis.
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l C. EVACUATION ROUTES - LIMITED A'CCESS AND EGRESS-DEFICIENCIES: l
- 1. Proposed. routes (Routes 3 and 44) are completely inadequate for effective handling of anticipated volume of traffic. Traffic is already Janused due to the' heavy volume of tourists in the summer months, and I
' during heavy winter storms, or when roads are under construction or repair.
l
- 2. Voluntary evacuation (Evacuation Shadow Phenomenon) is not taken - into account.
RECOMMENDATIONS: The following are not remedial; they simply address worsening of the . problem.
- 1. New development along evacuation routes should require an impact study by developers with specifications set by appropriate Town Offices. The study should be reviewed by the Planning Committee.
- 2. Prior to approval of road construction / repair (along evacuation routes)'
the appropriate Town Office must make an impact assessment and develop alternative routes. D. EVACUATION TIME ESTIMATES DEFICIENCIES:
- 1. Present time estimates are based on outdated information and have major fisws.
- 2. Evacuation Time Estimates (ETE) is based on several questionable assumptions:
- a. It assumes there will be no mass voluntary evacuation not in planned boundaries (shadow-phenomenon) as occurred at Three Mile Island, which could cause major route blockage and back-ups.
b .' It assumes that emergency personnel vill remain in place and not
' evacuate with their families.
- c. It assumes that communities outside the Ten Mile EPZ have developed adequate plans to augment evacuation and sheltering efforts, although Massachusetts Civil Defense Agency (HCDA) states no such
' plan exists.
,d. It assumes the timely presence of State Police and National Cused.
- 3. '.Large discrepancies exist between Boston Edison and the Nuclear Regulatory Consnission (NRC) ETE's. .
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I I t EVACUATION TIME ESTIMATES (Continued)
- 4. Panic and traffic disorder have not been adequately considered:
1
- s. Blocking of cross streets
- b. Disregard of traffic signals
- c. Driving in left hand lane i
- d. Abandoned vehicles i
- e. Driver confusion
- f. Failure of traffic control !
- g. Accidents These considerations plus ineffective traffic control could result !
in more than a. 50% reduction in traffic flow, which would mean the evacuation time could be more than doubled.
- 5. No adequate estimates for time required to evacuate non-car-owning people dependent on public transport.
- 6. Estimates of .the number of vehicles at public beaches is inadequate.
- 7. Estimates required by federal regulations are lacking.
- a. Separate times for adverse weather - fog, rain, flooding , snow, i storms.
- b. Day versus night, workday versus, weekend, peak transient versus' non-p2ak transient, and evacuation versus non-evacuation in adj:. cent sectors.
- c. Separate estimates for "special population groups" on an
" institution by institution" basis (e.g., schools, hospitals, nursing homes, correctional facilities).
RECOMMENDATIONS:
- 1. The new Boston Edison Company (BEco) ETE's must:
- a. be based on realistic assumptions,
- b. include all specific time estimates required by TEMA,
- c. take into account mass voluntary evacuation consequences,
- d. address previously stated shortcomings. .
- 2. The new ETE must be completed prior to plant operation.
- 3. Documentation should be provided by BECo to assure the ETE's provide a workable means to evacuate all, residents of the EPZ based on a vide range of accident scenarios.
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\ l E. [PLANSTOTRANSPORTDEPENDENTPOPULATION l (People without access to cars, school children and children in day l care, hospital and nursing home residents, handicapped persons, campers, persons in correctional institutions.) DEFICIENCIES:
- 1. Numbers of vehicles needed and sources for them have not been analyzed.
- 2. No contracts or letters of agreement have been signed with MBTA, bus companies, drivers, ambulance companies, and other natities providing public transportation and personnel support for the plan.
- 3. There are no 'particular plans for evacuating handicapped people. This segment of the population has not even been identified.
4 Plans call for individuals to make arrangements with local CD for transportation. 14 cal CD vill then contact MCDA Area 11 for assistance; however, the Area II plan does not contain information on how to procure additional transportation.
- 5. Schools - There are no separate plans or procedures for each school and day care center. Bus companies and drivers have not signed agreements to perform during an evacuation. The school plan lacks detailed pro-cedures. Estimated time to mobilize National Guard for schools is three hours, and Guardsmen may not be familiar with road network.
RECOMMENDATIONS:
- 1. Conduct a survey to determine transportation needs of all people dependent on public transportation in all sectors of EPZ. Provide specific and separate information for summer /non-summer, weekday / weekend populations.
- 2. Document available resources and resource needs, such as transportation contractors, trained personnel, drivers trained in emergency response procedures, special care personnel and equipment for disabled persons.
- 3. Obtain written agreements with transportation contractors and drivers.
4 Devalop specific, adequate plans to evacuate each dependent group, such as the population in nursing homes, hospitals, schools, camps, residential homes, correctional institutions, day care centers.
- 5. Provide for special needs population - physically and mentally handicapped people:
- a. Provide notification in advance of special evacuation procedures
' for disabled people;
- b. Plan for delivery of necessary services during an. emergency with trained assistan.ce ,for each handicapped person designated beforehand;
- c. Provide beepers, backup personnel for vacation time s , special equipment and. medications.
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T. RECEPTION CENTERS AND SHELTERS Bridgewater State College and Taunton State Hospital DEFICIENCIES: 1 I
- 1. There are no clearly defined fractions for the reception centers and s,helt ers .
- 2. There are no letters of agreement, or contracts with reception centers.
(Who provides what and who pays?)
- 3. There are no adequate plans, equipment, supplies or personnel to implement purposes for reception centers. (Such as contamination monitoring, decontamination, congregate care, ...)
- 4. Public shelter locations are not identified.
- 5. Adequate plans for public shelters are non-existent (personnel, supplies, etc.)
- 6. Resettlement and/or reentry plans have not been formulated. ,
- 7. The option of shelt ering in private homes versus evacuation is not ,'
addressed. RECOMMENDATIONS:
- 1. Define specific sod separate functions for public shelters and reception f centers. {
- 2. Specify conditions for which sheltering in private homes might be preferable to evacuation.
- 3. Conduct survey of potential shelters adequate to accommodate peak summer populations.
4 Identify and contract for an adequate number of reception centers and public shelters to accommodate EFI population. 5.. Provide adequate plans for equipment, supplies and personnel for centers and shelters. s
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1 Pilgrim-Activities Update-8/12/87 On August 5,1987 FEMA provided a report on offsite emergency planning for the Pilgrim Nuclear Power Station. Because of concerns brought to its attention, FEMA initiated a review of its earlier (September 1982) finding that emergency preparedness for Pilgrim was adequate. Based on this self-initiated review, FEMA identified six issues regarding offsite emergency planning and has con-cluded that Massachusetts offsite emergency planning and preparedness are in- i adequate to protect the public health and safety in the event of an accident l at Pilgrim. The six issues identified by FEMA involve the evacuation of schools, 1 a reception center for evacuees, the beach, special needs and transportation ! dependent populations, and the overall lack of general progress in emergency planning. In its report, FEMA presents an evaluation of each of the issues , including the necessary actions required to correct the identified issues. l NRR is requesting BECO provide their plans and schedule for working with state and local organizations to resolve these issues. The proposed 10 CFR 2.206 response to Senator Golden's Petition of July 15, 1986 is being revised to reflect FEMA findings and to address technical aspects
- of contentions regarding the Mark I containment.
Staff review of Safety Enhancement Program (SEP) is essentially complete and response to the utility should be issued within one week. The staff is not prepared to endorse installation of the Direct Torus Vent modification at this time. The licensee plans to commence core reload by the last week in Aucust, - b NRR issued two ame dment on August 5,1987. One concerned use of enriched , boron in the Stan y liquid Control System to meet ATWS rule (10 CFR 50.6?), and the other concerned a minor administrative change. The Restart Assessment Panel will meet August 18, 1987 at Pilgrim to review the I schedule and plans for staff reviews. Initial staff response to the BECo Restart Plan (received 7/30/87) will be discussed with BECo. I BECo is considering a status and issues briefing to Headquarters Management and Commission TA's on September 15, 1987 1
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Pilgrim-Activities Update - 8/19/87 The Restart Panel met with BEco at the Pilgrim site on August 18, 1987 Boston Edison provided the latest restart schedule, showing core reload commencino on August 30 and restart readiness on October 15. BECo expressed their desire for management and Comission meetings as follows: 9/15/87 - Status Brief for Senior HD Management Week of 09/21 - Comission Status Brief by BEco Week of 10/19 - Comission Restart Brief ; The Restart Panel believes there targets are optimistic and that BEco has not considered the impact of eme.rgency preparedness issues on restart and the time required for NRC reviews. r/77
1
.- pilarim cont'd 1 On August 18, 1987, NRR' issued a letter to BEco transmitting the FEMA report on offsite emergency planning. The staff expressed the need to consider the FEMA findin9s as part of the restart decision and requested BECo provide their program for working with the State of Massachusetts and local governments to resolve the FEMA findings.
The proposed 10CFR2.206 response to Senator Golden's Petition of July 15, 1986 has been revised and is in concurrence. The staff 6: view of the Safety Enhancement Program (SEP) is complete and the i NRR letter to BFCo is in concurrence. It is expected to be issued by August 21,. 1987. On August 14, 1987, five Regional inspectors completed a 2-week inspection of BECo modifications activity. A significant issue has been identified regarding qualification of equipment for selected accident scenarios that yield higher containment temperatures than the a large break LOCA. BECo is meeting with Region I on August 20 on this issue.
Pilorim-Activities Update-8/26/87 On August 21, 1987, Dr. Murley signed an inte im Director's Decision in responsa to the July 15, 1986 Petition regar;ing Pilgrim filed by Massachusetts State Senator William B. Golden and others. The Petitioners requested a show cause Order /for Pilgrim shutdown due to: (1) numerous i deficiencies in the licensee's management, (2) inadequacies in the existing f radiological emergency response plan, and (3) inherent deficiencies in the 1 facility's containment structure. The Director's Decision provided the I following conclusions:
- 1. The NRC has required, and will continue to require, that the Pilgrim facility remain shut down until the management and emergency preparedness issues are dealt with to the satisfaction of the NRC.
- 2. A decision cannot be made at this time regarding the management issues.
(This portion of the Petition will be addressed in a subsequent response.)
- 3. Based on the FEMA evaluation of the emergency preparedness issues raised by the Petitioners, the Petitioners' request for action on this issue is denied. However, in view of FEMA's interim finding that Massachusetts offsite radiological emerger.cy planning and preparedness are inadequate to protect the public health and safety, the Costnission will consider, among other issues, corrective actions regarding emergency planning issues identified by FEMA before permitting the restart of the Pilgrim Plant.
4 The infonnation identified by the Petition does not warrant the initiation of the requested proceedings in regard to the containment issues, and the Petitioners' request is denied. On August 21, 1987 the staff issued the initial assessment of the Pilgrim Safety Enhancement Program. 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 infonnation July 8,1987 In its response, the staff has informed BECo that we are not prepared to endorse the use of the Direct Torus Vent System (DTVS) at this time. Additionally, the staff stated that installation of the OTVS cannot be made under the provisions of 10 CFR 50.59 and requested BECo provide answers to a number of questions regarding this system. Most of the other proposed modifications were found acceptable by the staff and can be implemented under the provisions of 10 CFR 50.59. On August 20, 1987 BECo met with Region I (and NRR, by telephone) regarding equipment qualification concerns identified during a recent inspection. It had initially appeared that certain equipment in the drywell had not been qualified for the temperature that could be encountered during a small break LOCA; however it currently appears that the equipment is appropriately qualified and that documentation concerns should be resolved. On August 20, 1987 the licensee reported that a portion of RHR piping on the inlet side of the RHR heat exchanger had failed visual inspections due to heavily pitted conditions on the external surface of the pipe. This is in a heavily contaminated area where there has been valve packing leaks in the past. It is believed that, due to poor housekeeping / maintenance practices, leakage has resulted in the presence of moisture between the RHR pipe insulation and the pipe itself. The utility is evaluating the significance of the pitting and the corrective action to be taken. NRR issued a Technical Specifications amendment on August 25, 1987 It involved administrative changes to the offsite review committee. [
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N. t 3 SEPTEMBER 1987 OVERVIEW REPORT PLANT NAME: PILGRIM PROJECT MANAGER: R. H. Wessman MONTHLY OPERATIONAL OVERVIEW FOR SEPTEMBER 1987 The plant continues to be down for an extended outage for refur li ig, resolution of equipment and operational difficulties, management ssues and emergency planning concerns. Core reload commenced 09/29/87. Restart readiness expected by late November. Monthly Licensing Action Summary: l TRIPS THIS MONTH 0 . TRIPS LAST 12 MONTHS 0 . NUMBER OF REPORTABLE EVENTS 0 . LICENSING ACTIONS Opened in September 1987 - 3 Closed in September 1987 - 1 1 Outstanding 09/30/87 - 46 SIGNIFICANT ISSUES AND EVENTS Significant Activities During September 1987 BECo met with HQ management and the Region I Regional Administrator on September 24, 1987 to discuss facility ,tatus, emergency preparedness, niajor plant modifications, and their restart plan. (On the morning of September 24, BECo rret with FEMA (R. Krimm) to discuss offsite emergency planning activities. NRC representatives attended as observers.) Significant matters discussed between NRC and BECo were:
-The BECo schedule is not firm but the utility expects the facility to be ready for restart in about two months.
-BEco has aggressively worked with State and local governments to develop off-site plans that are responsive to FEMA concerns. State-approved plans are not expected to be available for FEMA review until 12/31/87.
BECo has requested an exemption from the required biennial exercise (due by 12/31/87) until Spring 1988. l'
-The staff is requesting BECo submit recent revisions to their emergency procedures and procedures generation program (PGP) which are written to Revision 4 of the Emergency Procedure Guidelines (EPGs). (Revision 4 of the EPGs is not yet approved by the staff.) Staff review of the '
licensee's submittal may take about 2 months and needs to be completed prior to restart.
J un
. -Appendices to the BECo-Restart Plan have not yet been provided, but are q expected by mid-October.
On September 17, 1987, Boston Edison issued 3 letters dealing with emergency preparedness issues. These letters concerned:
-Exemption From Required Biennial Exercise (until Spring 1988)
-Pilgrim Onsite Exercise - December 9, 1987
-Action Plan and Schedule for Dealing with FEMA Findings (FEMA Report of 8/4/87)
NRC will have lead responsibility for assessing the BEco exemption request; Region I will have lead responsibility (with NRR assistance) for the onsite exercise review and following BECo actions to deal with FEMA findings. Events On the evening of September 5,1987, four individuals from Duxbury were found trespassing on BECo site property (outside protected area). No damage to licensee facilities was identified. Significant Meetings Scheduled During September 1987 (NRR, Region, etc.)
- 10/8/87 - Region I is planning an October 8, 1987 meeting with representatives of the State of Massachusetts. Tentative items for discussion include State participation in certain aspects of NRC inspections, status of several NRC technical reviews, and State actions regarding off-site emergency preparedness issues.
- 10/8/87 - Meeting of Restart Panel, in Region I, to discuss coordination and scheduling of staff actions.
Items for Management Attention Completion of several licensing actions is being impeded by difficulties in achieving quality SEPs. Three actions are currently being revised to satisfy OGC. A fourth action is being returned to Region I for improvements because it probably would not be accepted by OGC. (None of these actions involve restart items). Status of Items Previously Identified for Management Attention G. Requa, Project Engineer from PDII-I, has been loaned to the Pilgrim Project team for 6-8 weeks to assist with the licensing workload. Loss of Project Engineer (currently assigned full time to Pilgrim) on September 30, 1987 leaver PDI-3 over-extended on Pilgrim Tasks. Next Scheduled Refueling Outage February 1989 cc: V. Nerses R. Wessman PDI-3 R/F S. Rushbrook s'. Rooney E. Adensam j l _ - - - - - _ - - _ - . - - . - - - )
)
4 ! (MONTH YEAR) OVERVIEW REPORT 4 PLANT NAME: , PROJECT MANAGER: ', i MONTHLY OPERATIONAL OVERVIEW FOR (MONTH YEAR) I j Monthly Licensing Action Summary: 7, g \
,, e TRIPS THIS MONTH .
'T 4 L e u vk i .. .. .
TRIPS LAST 12 MONTHS . NUMBER OF REPORTABLE EVENTS . LICENSING ACTIONS p TYPE CATEGORY 1 CATEGORY 2 CATEGORY 3 ,TOIAf - 9k7 i Licensing Actions Opened in (Me h ) O O b 3 (ProjectedCategories) Licensing Actions Closed in ( ) 0 0 O l Licensing Actions in Progress U C L3 O (1.....fo...........) sep , Get 9& Licensing Actions Returned (Cat 1) in ( ) O For Applications received prior to 9/4/87 l Number under review by PM i , Number reviewed and completed by PM O l l: SIGNIFICANT ISSUES AND EVENTS i Significant Activities During (Month Year) 1: Significant Meetings Scheduled During (Month Year) (NRR, Region, etc.) l Items for Management Attention Status of Items Previously Identified for Management Attention Next Scheduled Refueling Outage O
r i g )
- s s
Pilgrim- Activities lipdate-09/02/87 The Restart Assessment Panel is meeting at the site 0o/03/87 to discuss f coordination and scheduling of staff actions. l BECo has scheduled a meeting with Headquarters Management on 09/24/87 at 1:00 P.M. to discuss facility status, emergency preparedness, ma,ior plant modifications, and restart plans. NRR is preparing a response to the Charles Berry, Massachusetts Secretary of Public Safety,. letter of August 18, 1987. Barry urges the Comission not to allow " refuel or restart of unless and until all previously identified management, reactor safety and emergency planning concerns have been addressed". Barry also urges Comission acknowledgement of FEMA findings and findings of his report (dated 12/16/87) and that a public hearing on Pilgrim issues be scheduled. NRP issued Tech. Spec. Amendment No. 105 on August 31, 1987 It concerned the Core Reload No. 7 A Region I Specialist is inspecting Fire Protection modifications the week of August 31 - September 4, 1987. I
/
J PA j
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', g Pilgrim - Activities Update-9/9/87 The Restart Panel met at the site on 9/3/87 to discuss coordination and scheduling of staff actions. Subsequently, the Panel met with BECo.
Significant items are:
- BEco could ready to reload the core as early as 9/14; however they will defer reload (probably a few weeks) to further complete system testing, modifications to HFA relays and fire protection modifications that can be more easily accomplished before core reload. i
- Pilgrim is expected to be ready for restart about 6-8 weeks after core reload.
- BECo presented a draft of the Pilgrim Power Ascension Test Program.
Initial reaction indicated that the draft was incomplete. Shortcomings include insufficient criteria for assessment / acceptance of satisfactory performance, insufficient consideration of non-licensed personnel activi-ties and lack of clarity regarding organizational interfaces. A formal submittal is expected in about one week.
- BEco expects to provide supplemental information (mostly Volume 2) on their Restart Plan by September 10.
BECo plans to provide an interim response to the staff regarding their actions in the emergency preparedness area. This response, expected by 9/18/87, is to include an exemption request regarding restart prior to the conduct of a full-scale emergency preparedness exercise (required by the end of 1987). BECo continues to plan for a H0 management briefing on 9/24/87 at 1:00 PM in P-118. This briefing will discuss facility status, emergency prepared-ness, major plant modifications and restart plans. NRR issued Tech. Spec. Amendment No. 106 on September 4, 1987. It con-cerned changes to the Automatic Depressurization System. BECo has named Bernard Reznicek as their new president. Reznicek, currently the head of Omaha Public Powe r District, will assume his responsibilities October 1, 1987. He replaces . lames M. Lydon) who is retiring. Ralph Bird (Sr. VP Nuclear) will continue to report to Steve Sweeney (Chairman and Chief Executive Officer). BECo announced that their nuclear training programs are now fully accredited by INP0. BEco further stated they are 16th of 55 nuclear utilities to have full accreditation.
Y . i
.\ .
Pilgrim - Activities Update 9/9/87 (continued) Roger Silva has resigned as emergency preparedness coordinator at BECo, j effective August 28, 1987 He is replaced by Rnn Varley, previously l associated with Davis-Besse. On the evening of September 5,1987, four individuals from Duxbury were j found trespassing on BEco site property (outside protected area). No l damage to licensee facilities was identified. J Pegion I inspection specialists were on site the week of August 31 to follow-up on open itens. Initial indications are that BEco efforts to close some open items have not yielded high avality records packages. E.- .____-__.m____ _ _ _ _ . _ _ _ _ _ _ _
r o o h
"r" f Y]W Pilgrim Activities Update - 9/16/87 BECo plans to commence core reload the week of 9/21/87. The exact reload date is dependent on completion of plant modifications and system testing. The resident inspectors will tollow licensee preparations and monitor for adherence to regulatory requirements.
Delivery of supplemental information on Restart Plan (scheduled for September 10) . has been delayed for several weeks by BECo. This is key material necessary ! for the staff to assess licensee progress and readiness. BEco continues to plan for a H0 management briefing on 9/24/87 at 1:00 PM in P-118. This briefing will discuss facility status, emergency preparedness, major plant modifications and restart plans. In addition to routine resident coverage, regional inspection activity at Pilgrim the week of 9/14/87 includes the following activities:
-Surveillance Programs - 3 inspectors
-Radiological Controls - 2 inspectors
-Physical Security - 1 inspector
-Preoperational Testing - 1 inspector Th
l'
, 9/16/87 g
i 1 i FEMA SELF-INITIATED REVIEW l FEMA FOUND THAT THE 2.206 PETITION PLAN WEAKNESSES WERE NOT j SUFFICIENT TO SUSTAIN CONTENTIONS (BUT RESOLUTION WOULD ENHANCE STATE'S ABILITY TO PROTECT THE PUBLIC) FEMA IDENTIFIED 6 ISSUES l
- LACK OF EVACUATION PLANS FOR PUBLIC AND PRIVATE SCHOOLS AND DAYCARE CENTERS
- LACK OF RECEPTION CENTER FOR PEOPLE EVACUATING TO THE NORTH
- LACK OF IDENTIFI ABLE PUBLIC SHELTERS FOR THE DEACH POPULATION INADEQUATE PLANNING FOR THE EVACUATION OF SPECIAL NEEDS POPULATION INADEQUATE PLANNING FOR EVACUATION OF THE TRANSPORTATION DEPENDENT POPULATION
- OVERALL LACK OF PROGRESS IN PLANNING AND APPARENT DIMINUTION IN EMERGENCY PREPAREDNESS 1
e l PATH _TO RESOLUTION LICENSEE PROVIDE PLAN / SCHEDULE FOR SUPPORT AND ASSISTANCE TO STATE AND LOCAL GOVERNMENTS TO RESOLYE OUTSTANDING JSSUES STATE AND LOCAL GOVERNMENTS PROVIDE FEMA WITH IDENTIFIED PLANNING INFORMATION INCLUDING LETTERS OF AGREEMENT, PROCEDURES, TRAINING. TRANSPORTATION RESOURCES, UPDATED EVACUATION TIME ESTIMATES (BEACH) FEMA PROVIDE NRC WITH FINDING THAT THE 6 ISSUES ARE RESOLYED OR ARE SUBSTANTIALLY RESOLVED EXERCISE -- NONCOMPLIANCE WITH REGULATIONS AFTER 12/87 TIME ESTIMATES: 3-6 MONTHS i l l
b.
-l l
CRITICAL PATH ITEMS CONDUCT OF A FULL-PARTICIPATION EXERCISE FOR CY 1987 (STATE AWAITING PLAN REVISIONS BEFORE SCHEDULING EXERCISE) FEMA EVALUATION OF INDIVIDUAL. ISSUES AS INFORMATION IS PROVIDED BY STATE l
l is l3 l' EXERCISE _ EXEMPTION CONSIDERATIONS NO PREVIOUS EXEMPTIONS TO 2 YEAR EXERCISE REQUIREMENTS S0.12 CRITERIA MUST BE MET
- NO UNDUE RISK TO PH&S
- SPECIAL CIRCUMSTANCES EXIST PRIOR EXEMPTIONS TO I YEAR REQUIREMENTS RELIED ON EXISTENCE OF FAVORABLE NRC (ONSITE) AND FEMA (OFFSITE) FINDINGS THAT ADEQUATE EMERGENCY RESPONSE CAPABILITY
- HAS BEEN DEMONSTRATED, AND
- IS BEING MAINTAINED 1
0
m 9 EDO HIGHLIGHTS PILGRIM ACTIVITIES UPDATE - 9/23/87 On September 17, 1987, Boston Edison issued 3 letters dealing with emergency preparedness issues. These letters concerned:
-Exemption From Required Biennial Exercise (until Spring 1988) 1
-Pilgrim Onsite Exercise - December 9, 1987 J
-Action Plan and Schedule for Dealing with FEMA Findings (FEMA Report of 8/4/87)
NRC will have lead responsibility for assessing the BECo exemption request; ; Region I will have lead responsibility (with NRR assistance 1 for the onsite ] exercise review and following BECo actions to deal with FEMA findings. j BEco continues to prepare for reload of the reactor core, currently expected to comence on or about September 25, 1987. Region I continues to inspect BECo actions and will provide extended coverage of the reload. BECo will meet with HQ management and the Region I Regional Administrator on September 24, 1987 (1 P.M. in P-118) to discuss facility status, emergency preparedness, major plant modifications, and their restart plan. On the morning of September 24, BECo will meet with FEMA (R. Krimi to discuss offsite emergency planning activities. NRC representatives will attend as observers. Last week, inspections were conducted in the areas of surveillance programs, i radiological controls, and closure of open items. No significant deficiencies were identified. I/M}}