ML20245C339

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Requests Descriptive Matl Re Proposed Organization Changes & Amend Package
ML20245C339
Person / Time
Site: Pilgrim
Issue date: 12/09/1987
From: Wessman R
Office of Nuclear Reactor Regulation
To: Murley T
Office of Nuclear Reactor Regulation
Shared Package
ML20244D847 List:
References
FOIA-88-198 NUDOCS 8904270121
Download: ML20245C339 (16)
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4 December 9,1987

' NOTE TO: Dr. Thomas E. Murley, Director j Office of Nuclear Reactor Regulation 1 FROM: Richard Wessman, Project Manager ,

SUBJECT:

PILGRIM ORGANIZATIONAL CHANGE Pilgrim Technical Specifications allow organizational changes without prior license amendment (See attached page 208, Section 6.2.C).

BEco discussed their proposed organization changes with the Restart Panel l on December 8. The Panel requested they submit descriptive material regardiny '

the change promptly upon implementation to facilitate our review of management issues. I suggested they also submit the necessary amendment package shortly thereafter. (We may wish to withhold approval of the amendment until our assessment is complete).

Original signed by:

Richard H. Wessman, Senior Pro,iect Manager Pro.iect Directorate I-3 Division of Reactor Pro,iects I/II

Enclosure:

As Stated cc: J. Scinto F. Miraglia S. Varga B. Boger B. Clayton DFC :PDI-3  :  :  :  :  :  :

... .. : . . . . 7 ...:............:............:............:............:............:...........

NAME :RWessiian  :  :  :  :  :  :

DATE :1? & /87  :  :  :  :  :  :

OFFICIAL RECORD COPY J 1

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8904270121 890419 PDR FOIA

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,. 16.0 ADMINISTRATIVE CONTROLS 6.1 RESPONS!BILITY ,

The Ndelear Operations Manager shall.be accountable for overall facility operation. In his absence the Nuclear Operations. Manager shall designate in writing the individual to assume th.ls responsibility.

6.2 ORGANIZATION' A. OFFSITE .

The Company organization for station management and technical support shall be as shown on Figure 6.2.1..

B. FACILITY The Facility organization shall, be as shown on Figure 6.2.2 and:

1. Each on duty shift shall be composed of at least the minimum shift crew composition shown in Table 6.2.1. ,
2. When the unit is in an operational mode other than cold shutdown or refueling, a person holding a Senior Reactor Operator License shall be pr6sent in the control room at all times. In addition to this Senior Operator, a; Licensed Operator or Senior Operator shall be present at the con.trols when fuel is in the vessel.

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3. At least two Licensed Operators shall be present in the control s room during reactor startup, scheduled reactor shutdown and during recovery from reactor trips.
4. An individual qualtfled in radiation protection procedures shall ,

be on' site when fuel is in the reactor. -

S. ALL CORE ALTERATIONS performed while fuel is in the reactor

  • l vessel after the initial fuel loading shall be directly

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supervised by either a licensed Senior Reactor Operator or Senior.

l Reactor Operator Limited to Fuel Handling.who has no other concurrent responsibilities during this operation.

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6. A Fire Brigade of 5 members including a Fire Brigade Leader shall I be maintained on site at all times.' This excludes 3 members of f- the minimum shift crew necessary for safe' shutdown and any personnel required for other essential functions during a fire 4 emergency.

C. CHANGES TO THE ORGANIZATION i

, Changes may be m.ade to the organization without prior license amendment provided that the NRC is notified in writing within 30 days and a revision to Section 6.2 is included in a subsequent license amendment request.

Amendment No. 69, 59. 88 208 06 t d.CC ui) .t c th ( d .[l (/- / 0 6'i

PILGRIM - ACTIVITIES UPDATE 12/9/87.

BEco met with the Restart Assessment Panel at the site on December 8, 1987.

Significant items discussed are:

- The latest BEco schedule indicates Pilgrim could be physically ready for restart 1/23/88. This schedule does not consider matters such as NRC restart assessment, emergency preparedness issues, Comission Meeting, etc.

- BEco discussed organizational and personnel changes they expect to implement in the coming few weeks. - A new organization chart is not available; however the realignment will increase the line functinns reporting)directly to the Senior (unfilled will be replaced VP Station by.the Nuclear,Director the VP for (toOperations be filled by new hire, Ken Highfill) and the station organization is realioned.

Several of the new senior management positions remained unfilled and' many of the senior managers are new to BECo within the past year.

- Offsite Emergency Preparedness efforts with state and local entities continue and should be largely complete by January 31, 1988. BEco did not indicate when Stato plans would be submitted for FEMA review.

The Restart Panel met at the site December 8. The Regional Administrator attended this meeting and discussions between the Panel and BEco (see above).

.Significant items discussed were:

- Diagnostic Inspection is expected for February 1988.

- Arrangements are in progress for local public meetings to receive public coments on the BEco Restart Plan. The first of these meetings i is expected in January. i The RCS hydro is in progress and should be completed by December 11. BEco expects to complete the ILRT by December 20.

Operator License Exams are being held at the site the week of December 7. 6 R0 and 2 SRO candidates are involved. If all candidates are successful, the Pilgrim active complement of licensed watchstanders will be about 20 R0s and 17 SR0s. (The next class of 10 R0 and 6 SRO candidates will start in early ,

1988, and be examined in early 1989).

On December 9,1987 BECo held a " partial participation" Emergency Preparedness Exercise. Headquarters and Region I personnel observed licensee activities.

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s. ACTION ASSESSMENT COMMISSION RESTART PLANT SHUT 00WN PLAN REPORT BRIEFING DECISION

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e. o .Jor/ i at7 COMMENTS: RCS HYDRO E EL CTID !." EfRLY DECEMBE AND ILRT IS EXPECTED IN LATE DECEMBER. BECO ISs8MEE FORECASTING C PLETION OF MOST OUTAGE ACTIVITIES B %C "%". Oi, 10S7, LOSS OF Off SITE POWER EVENT (11/12/87) AND STOP l b, ,, y y ORK ACTION (11/09/87 MRV DELA VCOMPLETION OF ONSITE ACTIVITIES. h 1e m
  • f INITIAL REVIEW 0F BECO ART PLAN IS IN PROGRESS AND IS EXPECTED

,- TO TAKE UNTIL MID-966 EMBER. INTEGRATED TEAM ASSESSMENT OF UTILITY  !

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READINESS IS PLANNED FOR EARLi ,Yihnn.

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/ LUTION OF 0FFSITE EMERGENCY PREPAREDNESS ISSUES EXPECTED TO BE A ,

UE. COMPLETION OF IMPROVED LOCAL PLANS IS NOT EXPECTED

- { gh jgg MAJO BEFORE 12/21/0P. SUBMITTAL DATE OF COMMONWEALTH EMERGENCY PREPAREDNESS PLANS TO FEMA IS UNKNOWN. BECOIWhtEQUESTEDAN EXEMPTION FROM THE BIENNIAL EP EXERCISE (REQUIRED BY 12/31/87) UNMt-CEL'l U2. e4 SL)[ p H4 cae f w hu.A cr. i4/ 7 THE AIT HAS COMPLETED THE ONSITE REVIEW OF THE LOSS OF 0FFSITE POWER EVENT AND THE REPORT IS IN PREPARATION. Vo yr I.M  !

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RESTART STATUS 12/14/87 LICENSEE RESTART ACTION ASSESSMENT COMMISSION RESTART PLANT SHUTDOWN PLAN REPORT BRIEFING _ DECISION PILGRIM 04/12/86 10/26/87C 02/29/88E* 03/ll/88E* 03/25/88E* l C0ffiENTS: RCS HYDRO WAS COMPLETED DECEMBER 10, 1987 AND ILRT IS EXPECTED IN LATE DECEMBER. BECO IS FORECASTING COMPLETION OF MOST OUTAGE ACTIVITIES BY JANUARY 23, 1988. LOSS OF 0FFSITE POWER EVENT (11/12/87) AND STOP WORK ACTION (11/09/87) DELAYED COMPLETION OF ONSITE ACTIVITIES. CRITICAL PATH AREAS INCLUDE FIRE PROTECTION AND SAFETY ENHANCEMENT PROGRAM MODIFICATIONS.

BECO PLANS SEVERAL ORGANIZATIONAL AND PERSONNEL CHANGES IN THE NEXT FEW WEEKS. REALIGNMENT IS EXPECTED TO INCREASE LINE FUNCTIONS REPORTING TO SENIOR VP NUCLEAR AND REALIGN STATION ORGANIZATION.

INITIAL REVIEW OF BECO RESTART PLAN IS IN PROGRESS AND IS EXPECTED TO TAKE UNTIL MID-JANUARY. LOCAL MEETINGS TO RECEIVE PUBLIC COMMENTS l ON RESTART PLAN ARE PLANNED FOR MID-JANUARY. INTEGRATED TEAM ASSESS-MENT OF UTILITY READINESS IS PLANNED FOR EARLY FEBRUARY 1988.

RESOLUTION OF 0FFSITE EMERGENCY PREPAREDNESS ISSUES EXPECTED TO BE A MAJOR ISSUE. COMPLETION OF IMPROVED LOCAL PLANS IS NOT EXPECTED BEFORE.1/31/88. SUBMITTAL DATE OF COMMONWEALTH EMERGENCY PREPARED-NESS PLANS TO FEMA IS UNKNOWN. BECO REQUESTED AN EXEMPTION FROM THE BIENNIAL EP EXERCISE (REQUIRED BY 12/31/87) AND STAFF GRANTED EXEMPTION DECEMBER 9, 1987.

THE AIT HAS COMPLETED THE ONSITE REVIEW 0F THE LOSS OF 0FFSITE POWER EVENT AND THE REPORTHS IK RE&EARAMM. NO MAJOR LICENSEE SHORT- -

COMINGS OR SIGNIFICANT GENERIC ISSUES WERE IDENTIFIED.

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PILGRIM - ACTIVITIES UPDATE 12/16/87 The RCS hydro was successfully completed December 10, 1987 BECo plans to J conduct the ILRT prior to Christmas, and still expects to complete plant I outage activities by the end of January.

BECo ennducted a " partial participation" Emeraency Preparedness Exercise on December 9, 1987 Although NRC observers noted some minor weaknesses, overall performance indicated that the licensee would have performed in a manner to 1 protect the health and safety of the public, in the event of an actual .

accident. There was no local participation in the exercise and only limited i Commonwealth participation (telephone checks). IEMA did not observe the {

exercise. l l

On December 10, BECo met with the staff to discuss their Emeraency Operating '

Procedures (EOP1 program. BECo has provided the staff with their current Procedures Generation Program (PGP) which is written to revision 4 of the (industry-proposed) Emergency Procedures Guidelines (EPGs). (Staff review of these EPGs is not expected to be complete until Spring 1988; however the staff endorses utility use of the unapprove EPGs in their current form).

Flow-chart oriented E0Ps were placed in the Control Room in November and l operator training is being conducted. The staff plans to review the Pilgrim PGP, assess the E0Ps, conduct a site visit, and prepare a SER prior to a restart  !

decision. Headquarters, Region I, and contractor personnel will conduct the review. { -

01 investigators have been at the Pilgrim site during the first two weeks of December. Their investigation is related to allegations involving the physical security program. The licensee has suspended three members of the i ouard force for possible procedural violations.

On December 9,1987 NRR granted an exemption to the biennial emergency preparedness exercise, required to be conducted by 19/31/87. Exemption is granted until June 30, 1988, and is based on the need to complete development of inproved Commonwealth and local plans prior to conductina a meaningful exercise. I i

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.. _ _._. n s ssNATom r.zHhEDY TO MOLD HEAR!WG ON PUBLIO HEALTN !McACT8 AtpsW A Arsu W 4TH PA0f os15, RESTART OP pit.cu1M 2 WUct.taa stores 9thNT FOR IMMEDIATs asLEA88 Deessaber 11, 1987 CONTACT Paul DeneTan Robin Seekley 802/334-4781 l 8enator Edward M. Kennedy announced today that he will hold j a hearing of the Senate Labor and Human Re40ggtes Cossittee to

, investigate the public health impacts associsited with the propose 6 restart of the Pilgrim I nuclear powr plant in Plymouth, Massachusetts.

The senate Labor and Human Resources casusittee has oversloht sosponsibility for public health iveues. Senater Kennedy 14 Chairman of the Courtittee.

Th's hearing, which will be open to the public, will be held on Januery 7 in the Plymiouth A n'64. (Time and least100 to be announces.) senator Kennedy has invited local e%%isens, state and local officials, fadaval agencies, and representatives of public interest groups to testify.

i "riany local residents and state of ficials have expressed to i me their deep conosso about the possible restarting of the Pilgrip l plant," said F.ennedy. "I share their concerns and I as holding this henming t.o ensure that those concerns are, full lf heard. When the Wac makes its final decision about this plant, .t must de so ba' sed on a full public record and af ter a full public airing cf all potential ef fucts of the oscioton on the health and safety of the people of Moseschusetts.'

l Xennedy and other members of the Massachypotts Congressionei i delegation had asked the Nuclear Regulatory Consisaien (NBC) to I

hold auch a hearing, but the WRC refused. At th8t point, Kennedy took steps to hold a hearing of the Labor and naan Resources Commi t te e .

In the past, the Conunittee has held hearinge (investigating the public health 1:apacts of the Three Nile Island and Chernobyl, uclear accicente.

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- LICENSEE RESTART ASSESSMENT COMMISSION RESTART ACTION

-REPORT BRIEFING DECISION SHUTDOWN PLAN PLANT _

10/26/87C 02/29/88E 03/11/88E- 03/25/88E PILGRIM 04/12/86 p- t- y~ y o s .

COMMENTS: RCS HYDRO WAS COMPLETED DECEMBER 10, 1987 AND ILRT IS TXPECTED-IN -

EE-ICC%n. BECO IS FORECASTING COMPLETION OF MOST GUTAGE ACTIVITIES BY JANUARY 23, 1988. LOSS OF 0FFSITE POWER EVENT j (11/12/87) AND STOP WORK ACTION (11/09/87) DELAYED COMPLETION OF i ONSITE ACTIVITIES. CRITICAL PATH AREAS INCLUDE FIRE PROTECTION AND SAFETY ENHANCEMENT PROGRAM MODIFICATIONS.

BECO PLANS SEVERAL ORGANIZATIONAL AND PERSONNEL CHANGES IN THE NEXT FEW WEEKS. REALIGNMENT IS EXPECTED TO INCREASE LINE FUNCTIO REPORTING TO SENIOR VP NUCLEAR AND REALIGN STATION ORGANIZATION. ,

INITIAL REVIEW OF BECO RESTART PLAN IS IN PROGRESS AND IS EXPECTED TO'TAKE UNTIL MID-JANUARY. LOCAL MEETINGS TO RECEIVE PUBLIC COP INTEGRATED TEAM ASSESS-ON RESTART PLAN ARE PLANNED FOR MID-JANUARY.

MENT OF UTILITY READINESS IS PLANNED FOR EARLY FEBRUARY 1988.

- RESOLUTION OF 0FFSITE EMERGENCY PREPAREDNESS ISSUES EXPECTED MAJOR ISSUE. COMPLETION OF IMPROVED LOCAL PLANS IS NOT EXPECTED BEFORE 1/31/88. SUBMITTAL DATE OF COMMONWEALTH EMERGENCY PREPA NESS PLANS TO FEMA IS UNKNOWN. BEC0 REQUESTED AN EXEMPTION FROM THE BIENNIAL EP EXERCISE (REQUIRED BY 12/31/87) AND STAFF GRANTED EXEMPTION DECEMBER 9, 1987.

AIT LEIED THE ONSITE REVIEW.0_F THE OSS OF-SITEPOWER JOR VEN A R WAS~TS$UEAON DECE3ERQ4 1997A NO IED.

,(QCE(NSE (RR0191 'R'SIGNIFICAkB4ENERIC I SUES WERE' D In a letter dated December 18, 1987, Senator Kennedy requested NRC to participate in a Senate Labor and Human Resources Comittee hea on the evening of January 7,1988, concerning the proposed restart of Pilgrim. An NRC staff meeting with Kennedy staffers is expected on December 30, 1987.

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.. Print Revised 1?/29/87 KENNEDY HEARING 1/7/88

-0UTLINE-PREPARED TESTIMONY I. Historical _ Perspective on Pilgrim-Shutdown of 4/12/86 SALP deficiencies Summary of Local meetinos and public participation II. Major Areas Requiring attention SALP and Technical Issues Management Issues Safety Enhancement Program (SEP)

III. Sumary of Major Activities Major Facility modifications and improvements Restart Panel Actions Inspection activity Restart Plan review Safety Enhancement Program Management changes being made Local meetings (in Plymouth and with Senator Golden)

Commission Meeting Planned  ;

IV. Emergency Planning Issues l

Historical Perspective l

FEMA findinos Current status V. Rules and Regulations applicable to Restart Decision l

i Legal framework Relationship to CAL of 4/12/86 ff' i

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VI. Criteria for Restart Resolution of major technical issues to staff's satisfaction Clear evidence of improvements in SALP deficiencies Clear evidence of management improvements Favorable evaluation by Restart Assessment Panel Solid improvements by made in the offsite emergency preparedness weaknesses VII. Conclusion NRC will continue aggressive review Restart Panel will coordinate Staff actions BEco must demonstrate improvements Will consider restart when issues deelt with to our satisfaction i

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. Expected Ouestions I. Questions Based on OCA conversation with Kennedy staff 1._ What is the NRC view regarding ad,iudicatory hearings on Pilgrim?

2. What is the effect of _ emissions from the Pilarim facility?
3. What is being done reoarding local public health concerns?
4. What action is NRC taking in response to the FEMA findings of
July 29, 19877
5. Why is the Pilgrim restart process continuing with the FEMA-identified deficiencies unresolved?
6. What actions is the staff taking regarding the Mark I containment at Pilgrim?
7. What action is the staff taking regarding the Direct Torus Vent?
8. LIhat specific actions / steps will NRC take prior to authorizing restart?
9. Explain why there appears to be continued problems at Pilgrim, as evidenced by the loss of Offsite Power Event of November 12, 1987.
10. Describe the difference between state and NRC roles regarding protection of public health. Indicate if you feel there is a need for more Federal legislation in this area.

II. Other Questiont

1. What emergency preparedness actions will be necessary by BECo, state and local entities, and FEMA before a restart is authorized?-
2. What is the status of the Safety Enhancement Program?
3. What is the criteria for determining that nanagement is effective?

l 4. Some studies have shown that certain communities surrounding Pilgrim l have cancer rates two to three times the average U.S. rates. Could l this be due to Pilgrim?

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5. Could the above average cancer rates be due to exposure of workers?
6. How does Pilgrim rank in terms of exposure to members of the general public?

7 How does Pilgrim rank in terms of exposure to workers at the facility?

8. Do NRC regulations allow a nuclear plant to operate durino the four months after an NRC finding of inadequate emergency plans?

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9. Can the NRC allow Pilgrim station to operate without adequate emergency plans?

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. 10. How will the NRC evaluate the status of the resolution of emergency preparedness issues?

11. If the NRC finds that the state of emergency preparedness does not rovide reasonable assurance that ~ adeouate protective ineasures can and will be taken in the event of a radiological emergency, what action can the NRC take?

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