ML20247Q761
| ML20247Q761 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 06/01/1989 |
| From: | Blough A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20247Q704 | List:
|
| References | |
| FOIA-88-284, FOIA-88-285, FOIA-88-286, FOIA-88-287, FOIA-88-519, FOIA-89-A-10, FOIA-89-A-11, FOIA-89-A-12, FOIA-89-A-13, FOIA-89-A-9 NUDOCS 8906070042 | |
| Download: ML20247Q761 (72) | |
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MEMORANDUM FOR: Samuel J. Collins, Deputy Director Division of Reactor Projects FROM: .A. Randy Blough, Chief Reactor Projects Section No. 38
SUBJECT:
PILGRIM INTEGRATED ASSESSMENT INSPECTION (IATI) OPERATING Enclosed is the Operating Plan for the Pilgrim IATI.
A. Ra Blough, Chief Reactor Projects Section No. 3B
Enclosure:
As stated cc w/ enc 1:
Pilgrim Restart Panel Members Pilgrim IATI Team Members 89060g%2OW hREYB9-A'9 info, ' ion in this retor las deleted in a :.n3 ' with th icedam of Information p.t, mmpt;ci, -
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} .. : 8 ENCLOSURE.
Operating Plan for the Pilgrim Integrated Assessment' Team Inspection L
I. Introduction P11 grim 'has been shutdown since April 1986 to resolve long term management and hardware . problems. Region I will perform an Integrated Assessment
.Tearr.-Inspection-(IATI)'at Pilgrim to evaluate the ' effectiveness of licen-see corrective action programs and the readiness of the plant and licensee personnel to resume power operation.
'2. Objective Pilgrim's performance history over the~ 1ast several years has been poor.
When performance improvements were made, they often could not be sus-tained.
technical In April 1986, Pilgrim was_ shutdown due to a series of recurring problems. A Confirmatory Action Letter (CAL 86-10) was -issued requiring resol" tion of the technical problems and approval of the .NRC Region I Regf onal ' Administrator for restart. In August 1986, the CAL was expanded to require the licensee to address other long term management and hardware issues before the NRC would approve plant restart. Additionally,-
the licensee was required to submit
- restart program to the NRC document-ing BECo's- formal assessment of the readiness for restart. including a detailed checklist for assuring that all outstanding items have been
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. satisfactorily resolved and that plant systems have been restored. and are prepared for operation.
During the extended shutdown BECo has initiated numerous management and staffing changes, implemented several complex plant modifications, and made various program improvements. During this period the NRC has per-
. formed numerous inspections to determine the status and adequacy of the improvements. The objective of the IATI is to review the adequacy of any issues not previously inspected or which required followup inspection, determine if improvements made are effective and appear long lasting, and determine if BECo is prepared to support the restart and safe operation of Pilgrim.
- 3. ' Areas To Be Examined 3.1 The IATI will focus on the following areas:
Management Effectiveness / Assurance of Quality Plant Operations Radiological Controls Surveillance Maintenance Security Fire Protection
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3.2 The IATI following inspection:attributes are to be considered and examined in the Development and implementation of management' goals / objectives and how they are understood / implemented at various-levels Of the licensee's organization; Planning / controlling routine activities along with effective program implementation; Level of understanding by workers / supervisors of potential' impact of day-to-day actions on nuclear safety; Attitudes of licensee personnel with respect to nuclear safety; Involvement hy senior management in day-to-day operation of the plant (including visibility of ' senior. site and corporate management);
Ef festiveness of. training, direction, guidance, and supervision by first-line supervisors; Adequacy of staffing in light of planned accomplishments;
. Role of QA/QC in monitoring activities and how their reports are used by plant management; Role of licensee in working with and overseeing contractor personnel; Effectiveness of safety review committees; and Communications / Problem solving process.
3.3 For the Pilgrim IATI, the following generic /long term problem issues will receive special emphasis:
Stability and effectiveness of the management team; Overall material condition (including housekeeping and decon-tamination effort) of the plant; Timeliness and effectiveness of corrective actions (including management attention to ensure resolution and escalation to senior management if necessary);
Interfaces, communication and cooperation among operations, maintenance, and health physics personnel;
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Status of the maintenance backlog (including the fire protection system);
Overtime controls in all functional areas; Validity of licensee interpretations of Technical Specifications and other regulatory bases; Quality of plant procedures and procedure changes generated as a result of modifications; Worker and management support of radiological controls, espe-cially ALARA; Worker perception of the following items:
(i) management policies (ii) management and supervisory involvement and effectiveness (iii) existance of, and reasons for, low productivity Licensee internal tracking systems and validity of closeouts.
3.4 Additional items (by functional area) requiring inspection /verifica-tion identified as a result of the NRC review of the restart plan or the NRC restart checklist are included as Attachment E to this plan.
- 4. Organization and Basic Operation The team will. consist of a. senior manager, inspection team leader, shift ~-
inspectors, and. specialist inspectors (Attachment A). The senior manager will be responsible for all activities of the team.
Reporting to the senior manager will be a team leader. The team leader will be responsible for assessing si,1ft inspector observations, specialist inspector findings, and developing daily inspection assignments. The shift inspectors will cover all three shifts to provide around-the-clock inspection coverage during an early portion (3 to 5 days) of the inspection. The duration of the around-the-clock coverage will be decided by the team leader based on u
ongoing plant activities, findings to date, and efficient use of resources.
The specialist inspectors will provide their own initiative using the attributes noted above and followup on shift inspector observations for which they are assigned by the team leader.
All team members, including the shift inspectors, have a functional area assignment (Attachment B). All inspectors should keep in mind that the functional areas of management effectiveness, training and assurance of quality span all the basic functional areas.
The Pilgrim SRI will assist the team in an advisory role on understanding I the licensee systems and methodologies. All contacts with the press will be referred to the PA0 or the senior manager.
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1 Enclosure 4 I
- 5. Mode of Operations /Information Flow Many of the inspection and monitoring activities during this team inspec-tion will be windows of opportunity (e.g., shift turnovers, any ongoing plant evolutions, ongoing maintenance and surveillance activities, follow-up on any events that occur during the inspection, etc.). For such activ-ities, general inspection planning and guidelines apply. As observations start for to come in and be proce's sed for followup, they become the priority review. Inspectors are expected to focus their activities so as to be able to meet the inspection objectives as discussed above.
guidance is provided in Attachment C. Additional As the inspection is conducted, the inspector should keep in mind and refer to the intent of the programmatic inspection procedures (IP) listed in Attachment C. The inspector will be asked to give a percentage com-pleted for the IP at the conclusion of the inspection that will be for-warded to the SRI. The IP's are only for reference and guidance and it is not intended to go to 100 percent completion for these IP's.
Any safety concerns, apparent or potential violations of regulatory requirements, or items of similar significance will be promptly conveyed to the team leader after the matter hat been identified to the appropriate licensee repr6entative (shift supervisor or other similar or higher level manager).
so as Each team member is expected to work approximately 9-hour days, to provide for appropriate overlap with team personnel on other shifts. Inspection team personnel will meet at 7:30 a.m. daily to discuss observations and expected licensee activities and adjust ongoing planned inspections. It is expected that the inputs of the swing shift inspector will be communicated to the mid-shift inspector and documented in the log.
Team management meetings with selected team members will be conducted at the end of the work day.
- 6. Schedule and Shift Coverage The team will be onsite as necessary, during the week of June 6-10 for badging and inspection preparation. The inspection will begin on June 13 and run through June 24. Team members are expected to be onsite June 27-29 as needed to complete the report documentation.The tentative schedule is presented in Attachment D. The inspection coverage and end date may be adjusted based on experience gained during the course of the inspection. Although the licensee shifts are 0800-1600,1600-2400, and 0000-0800 hours,shif t turnover is typically conducted one-half hour before shift change. Therefore, to provide for review of plant conditions before licensee shift turnover, NRC shifts will be 0700-1630, 1500-0030, and 2300-0830 hours. This provides for a nominal nine-hour work day with a half-hour meal break. Other team members will generally work from 0730-1700 hours to provide for some overlap of each shift and to corres-pond to station staff hours.
Enclosure 5 2
- 7. ' Inspection Documentation Each shift inspector should place their significant observations and activities witnessed in a common- log (bound green book),: which is .to be turned is'to over at the end of each shift to the oncoming shift inspector. It include:
_significant events .that occur during the inspector's shift and important observations thereof; significant information exchanges, including source (person (s));
concerns identified, including bases along with the identification of facts versus perceptions; and routine observations, including activities observed and applicable documents;. e.g.,
, title.
procedure (s) by number, revision, and complete It .is important to note positive, as well as negative, observations. The inspector assigned as lead for a functional area will be responsible to report on that area. Again, positive along with negative observations are needed for proper perspective. The following major report sections /
paragraphs are expected to be a part of the final report:
report(Warren) tive); cover with inspection summary and inspection results (evalua-general overview; (Warren) operations, including event response / assessment; (Wechselberger lead, All) maintenance; (Rebelowski, Lyash) surveillance testing; (Lyash) radiological controls; (Dragoun) fire protection; (We:hselberger) security / safeguards; (Smith) training and qualifications; (Mcdonald) and assurance of quality, including safety review. (Rossbach lead, All)
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Enclosure:
6-l' The specific format and' content will. be s with concurrence by the senior manager. pecified by theeach In general, teamsection leader should include: objectives / acceptance criteria / reference; summary of items reviewed; significant findings
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. conclusion.' ' (positive and negative); .and W.
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ATTACHMENT A ORGANIZATION l . SENIOR l l MANAGER l
' l l l S. Collins l' l l.
I l-I l TE l l TECH -l l LEADER l i ASST- l-1 -
.I I I l R. Blough l . I C. Wa rren ' l-1 l l
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l l l ADMIN ASST l 1 l l M.J. DiDonato'l l l- 1 I
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. l SHIFT INSPECTORS l l SPECIALIST INSPS l 1 l l .
l l L. Rossbach l l T. Dragoun l l J. Wechselberger l l G. Smith l l.D. Ruscitto l l D. Mcdonald l l F. Akstulewicz l l J. Lyash l l l l T. Rebelowski l 1 1 I I I l l'
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!' ATTACHMENT B Pilgrim IATI Roster Senior' Manager: Sam Collins Team Leader: Randy Blough
' Technical Assistant: Clay Warren Administrative Assistant: Mary Jo. DiDonato Shift' Inspectors: Larry Rossbach er Jake Wechselberger Dave Ruscitto-Frank Akstulewicz Specialist Inspectors:
HP: Tom. Dragoun Security: Greg Smith Surveillance / Maintenance: Jeff Lyash Ted Rebelowski Training / Management: Dan Mcdonald Additional Area Assignments:
Fire Protection: Jake Wechselberger QA/QC: Larry Rossbach-Review Committees: Frank Akstulewicz
' Inspection Report Coordinator: T. J. Kim
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. ATTACHMENT C h
INSPECTION GUIDANCE
-Administrative Guidance To Inspection Personnel
- 1. Licensee shifts . are 0800-1600, 1600-2400, and 0000-0800 hours. Shift inspectors will report one hour earlier (i.e. 0700, 1500, and 2300. hours)
.to review plant status and' ongoing ' activities, witness - licensee shif t turnover, and. shift turnover with the offgoing NRC shift inspector.
- 2. The 0800 daily licensee planning and scheduling meeting will be monitored each day by team personnel as directed by the team leader.
- 3. The team leader will receive a daily debriefing at the 0730 team meeting by the 2300-0830 shift inspector, including any carry-over items from the 1500-2430 shif t inspector. In addition, they will interface daily with the 0700-1630 shift inspector during the 0700-1630 time period and receive
.a final debriefing from team members at the close of business.
- 4. Heal breaks may be taken at any time (the one-half hour time allocation will r' equi re bringing food or using the cafeteria / vending machines).
- 5. Outside inquiries and contacts regarding the inspection are to be directed to the team leader.
- 6. Primary licensee contact during the 1500-2430 and 2300-0830 shifts will be the shift supervisor. The day shift inspector (0700-1630) can utilize any appropriate available member of licensee management.
Inspection / Technical Guidance To Inspection Personnel
- 1. Inspectors should maintain all relevant information for significant events, persons interviewed, their title and any important facts or per-ceptions from such interviews, as well as specific activities observed (e.g. applicable procedure number, revision, and complete title).
- 2. Each inspector should pre plan the types of questions to be asked of licensee / contractor personnel to gather information that will allow him to address the inspection objectives and attributes.
Attachment C --Inspection Guidance 2'
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In addition to inspecting ongoing operational, surveillance, maintenance, and other activities-(windows of opportunity), each shift inspector should place special emphasis on maintenance activities with respect to observing pre-job briefing and/or any instructions given to maintenance workers; supervisory ' coverage of maintenance activities;_ experience and training of maintenance workers (that' is, are maintenance tasks within " skills of the craft"); are procedures technically adequate considering experience /
training / knowledge levels; a're procedures adhered to; are . procedures developed for unique evolutions; are procedures properly changed if incor-rect; are systems restored to their correct alignment subsequent to the maintenance activity; and, is the control room aware of the activities and possible effects on plant operation.
- 4. Individual inspectors may be requested to prepare other documentation dur-ing the course of . the inspection such as: inputs ' to interim progress report (s); notes for the exit interviews; daily (morning) reports; etc.
- 5. ' Reference Inspection Procedures
'All areas: 71715 - Sustained Control Room and Plant Observations 42700 - Plant Procedures 40700 - On-Site Review Committee 40701 - Off-Site Review Committee 37703 - Tests and Experiments Program 39701 - Records Program 39702 - Document Control Program 40703 - Off-Site Support Staff Plant Operations: 71707 - Operational Safety Verification 71710 - ESF System Walkdown 71711 - Plant Startup from Refueling Outage Maintenance: 62700 - Maintenance Program - Implementation 62702 - Maintenance Program 62704 - Instrument Maintenance-62705 - Electrical Maintenance Surveillance: 38701 - Procurement Control 38702 - Receipt, Storage and Handling of-Equipment Program 56700 - Calibration 61700 - Surveillance Procedures / Records 61725 - Surveillance Testing and Calibration Program 4
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JAttachment C - Inspection Guidance- 3 y
Training: 41400 - Tra'ining -'Non-L'icensed
- 41701 -. Training - Licensed Assurance'of Quality: 35701 ~- QA Program. Annual Review 35750 - QA Program Measuring and Test' Equipment' 36700 - Organization and Administration
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40702 - Audit Program.
40704 Implementation -Audit Program Radiological f Controls: . 83000 - Series Security: ' 81000'- Series-l' i
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ATTACHMENT D' Pilgrim IATI Tentative Schedule I. 6/6 Prep Week Onsite, as needed for individual preps and badging. As_ a minimum, team members should complete badging, arrange and receive a briefing from the resident inspectors, and attend licensee self-assessment presentations.
6/7 a.m.
Licensee presentation on plant and program status, including results of BECo self-assessment and INPO review.
6/7 p.m.
Detailed plant tour in ' three groups (Warren, Lyash and Kim coordinate).
6/7 - 5:00-7:00 p.m.
Tee = meeting at either hotel or site. Additional meetings will be held as needed throughout the inspection.
'II . 6/13-6/24 - Inspection 6/13 - 1:00 p.m.
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Entrance interview onsite.
6/13
' Begin specialist inspection (each inspector is responsible for his per-sonal inspection sequencing and scheduling). Shift inspectors will have assignments of programmatic issues to evaluate when not in shift work.
6/14-15 Continue inspection. .
6/15 - 3:00 p.m.
Begin shift coverage.
l 6/16-17 Continue specialist and shift inspecticn.
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' Attachment D - Tentative Schedule 2 6/18 - 8:00 p.m.
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Decision will be made whether enough has been learned to discontinue shift inspections.
6/19 Sunday Off (Optional).
f a 6/20-22 Continue. specialist inspection and followup of. shift inspector identified issues.
6/23 a.m.
Individuals organize / summarize.
6/23 - 2:00 p.m.
Team Meeting.
6/24 - 8:00 a.m.
Exit Dry Run and Critque.
6/24 - 10:00 a.m.
Wrap-up'- fill holes.
6/24 - 1:00 p.m.
Exit Interview III'. 6/24-29 Complete Individual' Documentation Onsite Each inspector will be required to provide report input, acceptable to the Team Leader, prior to being released. Inspectors may work the weekend to accomplish this or may take as much of 6/27-29 onsite as needed.
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4 ATTACHMENT E Items Requiring Inspection Based on Restart Plan Review and Restart Checklist I. Operations 1.
- 2. Evaluate effectiveness of onsite engineering support group Adequacy of operator training and procedure changes on the RF0 7-modifications (87-22-02, 87-25-01) 3.
- 4. Adequacy of operator refresher training in light of the long shutdown 5.
Performance and attitude of licensed and non licensed operators Adequacy of operating procedures; E0P issues resolved NOTE:
Also refer to NRC restart checklist item numbers 2, 3, 6, 8, 9, 11, 17, 18, 20, 21, 25-28, 31, 33-35, 46, 47, 49, 51, 52, 54-60, 114 and 144.
11.* Radiological Controls
- 1. Adequacy of staffing and personnel qualifications
- 2. Adequacy of corporate assistance / support
- 3. Supervisory span of control and authority
- 4. Initial training and continuing education of HP techs
- 5. Development of HP professional staff 6.
7.
Adequacy of worker HP training (GET, respiratory,etc)
Adequacy of long range and short range ALARA programs B.
Effectiveness of RWP process in control of exposures
- 9. Adequacy in controlling work in progress
- 10. Adequacy of control of locked high rad areas 11.
Quality of count room procedures, equipment, and personnel
- 12. Amount and quality of survey meters 13.
14.
Adequacy of installed monitoring (area, stack, PING)
Status of NUREG 0737 PASS items 15, Are procedures and policies clear and consistent? Are all operations covered by procedure? Adequacy of process for updating / technical improvement of procedures 16.
Adequacy of QA/QC audits of the HP area including schedule, auditor qualifications, effectiveness in upgrading programs, deficiency reporting, followup, and root cause analysis NOTE:
Also refer to NRC restart checklist item numbers 2, 3, 6, 8, 9, 11, 17, 18, 20, 21, 25-28, 31, 33-35, 46, 47, 49, 51, 52, 54-60, 114 and 144.
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l Attachments-ReviewandRestart 2 Checklist III. Maintenance
- 1. Staffing adequacy and personnel qualifications
- 2. Adequacy of post maintenance testing
- 3. Prioritization of maintenance requests-
- 4. Adequacy of planning and scheduling (88-01-02)
- 5. Maintenance backlog status
- 6. Adequacy of procedures and task specific instructions
- 7. Implementation of preventive maintenance program (88-08-01)
- 8. Maintenance program administrative procedures in place and effective (88-07-01,88-07-02)
NOTE:
Also refer to NRC restart checklist item numbers 2, 3, 6, 8, 9, 11, 17, 18, 20, 21, 25-28, 31, 33-35, 46, 47, 49, 51, 52, 54-60, 114 and 144.
IV. Surveillance
- 1. ' Technical adequacy of surveillance procedures including the ECCS logical functional tests and the analog trip system tests
- 2. Effectiveness and adequacy of the surveillance test scheduling program f- 3. Is the surveillance test program controlled by a centralized, tech-nically knowledgeable person or group?
- 4. Is there an ongoing program to review and improve surveillance tests?
NOTE:
Also refer to NRC restart checklist item numbers 2 , 3 , 15 , 8 , 9 ,
11, 17, 18, 20, 21, 25-28, 31, 33-35, 46, 47, 49, 51, 52, 54-60, 114 and 144.
V. Fire Protection
- 1. Have fire protection barriers been identified, controlled, and checked at appropriate frequencies?
- 2. Status of inoperable fire protection equipment? Has reliance on compensatory measures been reduced?
NOTE: ' Also refer to NRC restart checklist item numbers 2, 3, 6, 8, 9, 11, 17, 18, 20, 21, 25-28, 31, 33-35, 46, 47, 49, 51, 52, 54-60, 114 and 144.
VI. Security
- 1. Completeness of security equipment modifications and reducing -
reliance on compensatory measures
- 2. Staffing adequacy and personnel qualifications
Ai achment E - Review and' Restart 3 Checklist
- 3. Maintenance program for security equipment
- 4. Program and procedures'to ensure vital area barrier integrity (85-24-01, 87-30-01, 87-30-02, and 87-50-02)
NOTE:
Also refer to NRC restart checklist item numbers 2, 3, 6,'8, 9, 11, 17,'18, 20, 21, 25-28, 31, 33-35, 46, 47, 49, 51, 52, 54-60, 114 and 144. ,
VII. QA Program
- 1. Adequacy of drawing _ control program (87-45-01)
- 2. Adequacy of QC receipt inspection program (87-45-02) 3.
QC review of surveillance test results (87-36-01)
NOTE: Also refer.to NRC restart checklist'. item numbers 2, 3, 6, 8,_9, 11, 17, 18, 20, 21, 25-28, 31, 33-35, 46, 47, 49, 51,' 52, 54-60, 114 and 144.
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ITEM A. Mark I-Containment A.l. What action is the staff taking regardina reactors with a Mark I-containment?
A.2.!Who constitutes the expert group involved in the development of the
" Review of the Status of the BWR Mark I Melt-Through Issue" report referred to in Inside NRC of 12/7/87?
A 3. What is the implication of the Mark I Containment Evaluation Program for Pilgrim?
A.4. What will NRC require by way of Mark I Containment improvements at Pilgrim before restart?
A.5. What is the status of the Safety Enhancement Proaram?
A.6. What action is the staff taking regarding the Direct Torus Vent?
A.7. What is the status of the staff's review of Pilgrim Emercency Procedures?
B. Eneroency Preparedness B.l. What action is NRC taking in response to the FEMA findings of July 29, 19877 B.2. Why is the Pilgrim restart process continuing with the FEMA-identified deficiencies unresolved?
B.3. What energency preparedness actions will be.necessary by BECo, state and local entities, and FEMA before a restart is authorized?
B.4. Do NRC regulations allow a nuclear plant to operate durino the four months after an NRC finding of inadequate emergency plans?
B.S. Can the NRC allow Pilgrim station to operate without adequate energency plans?
B.6. How will the NRC evaluate the status of the resolution of emergency preparedness issues?
D.7. If the NRC finds that the state of energency preparedness does not provide reasonable assurance that adequate protective neasures can and will be taken in the event of a radiological energency, what action can the NRC take?
B.8. Will we require all of the FEMA and Barry deficiencies to be corrected prior to restart?
B.9. Will we require a satisfactory emergency exercise with a FEMA report )
before restart? 3 r//
B.10. Is an approved offsite emergency preparedness plan required for restart?
B.ll. What would NRC do if the state can't prepare and provide a plan to FEMA?
B.12. Does NRC have emergency preparedness experts with qualifications equivalent to FEMA experts?
B.13. Your testimony refers to "some demonstration of the critical aspects" of the evacuation plans. What do you nean by "some demonstration?"
B.14 What do you mean by " addressed prior to restart" when you refer cto the FEMA identified deficiencies?
B.15. What is the NRC position on the Commonwealth's plan to enlarge the EPZ?
C. Public Health C.l. Sone studies have shown that certain communities surrounding Pilgrim have cancer rates two to three times the average U.S.
rates. Could this be due to Pilgrim?
C.7 Could the above averaoe cancer rates be due to exposure of workers?
C.3. How does Pilgrim rank in terns of exposure to members of the general public' C.4. How does Pilgrim rank in terns of exposure to workers at the facility?
D. Federal and State Roles D.1 What is the statuatory basis for the authority of the NRC and the states in regulating radioactive materials?
D.2. What NRC programs are in place to facilitate interaction betweentheNLCandthestates?
Ta.3 CQvdo e Anw 'tt 4 % 4~%1 h,gR E. Miscellaneous E.1, What specific actions / steps will NRC take prior to authorizing restart?
E.2. Explain why there appears to be continued problems at Pilgrim, as evidenced by the Loss of Offsite Power Event of November 12, 1987.
E.3. What is the criteria for determining that management is effective?
E.4. Why is an adjudicatory hearing inappropriate in this case?
E.5. Would Pilgrim as currently designed, constructed and sited be buildable and operable under today's standards? If not, then why should we let Pilgrim go back on line?
E.6. Discuss the Commission's Safety Goals, referred to in GA0 Report RCED 87-141, issued in August 1987 What are typical "ouidelines" that implement these goals? What is the status of guideline development? How do these guidelines apply to Pilgrim?
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. QUESTION =A.I. What action is the staff-taking regarding reactors'with a Mark I containment?.
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DealingLwith severe reactor accidents at al1 types off nuclear plants . requires afcomprehensive approach which addresses 3 principal elements related to plant-safety: 1) plant operations,'2) severe accident vulnerabilities, and 3) containment performance. Plant operations refers toLthe manner in which a plant is ,
normally operated, including maintenance, surveillance and testing. It encompasses the. level of performance of operators.during routine and emergency-
. situations. Any serious attempt to' improve plant safety should examine this
. facet of a plant for possible improvements. The second element of a severe accident. risk' reduction program should involve a: systematic search for specific' design features which-significantly contribute to the likelihood of a ~
core melt accident. Finally, the assessment of. risk to the public posed by any nuclear plant should include consideration of .the containment performance during severe accidents to determine if plant improvements can be made which-would result in substantial risk reduction. The elements described above serve as a framework for reducing risks at all nuclear plants and are not limited' to treatment of the BWR Mark I type plant.
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, ' QUESTION A.I. -(Continued) 1 i.
Because of concerns over the particular vulnerabilities of Mark I containments
'and in'part due to a belief that reasonable cost effective plant improvements
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have been identified,-the staff has proposed'a program plan with an expedited schedule to resolve the generic issue of Mark I containment performance. This plan and schedule is discussed in SECY-87-297, issued on December 8, 1987.
F There are.a number of potentially important challenges to a Mark I
- i. containment which may arise during the course of a severe accident. These L
failure mechanisms include: .1) early overpressure or overtemperature failures (due to molten fuel quenching in-vessel, direct containment heating, and combustible gas generation and ignition), 2) core debris attack on the steel containment liner'resulting in liner melt through, 3) later overtemperature or overpressure failure, of the containment, 4) containment bypass (due to failure to isolate containment; suppression pool bypass and interfacing systems LOCA's),
and 5) basement penetration.
To reduce the threat posed by these challenges a number of potentially cost effective improvements have been suggested and preliminarily assessed by the staff, its contractors, two utilities (Vermont Yankee and Boston Edison) and an industry group (IDCOR). These improvements are related to the following containment performance issues:
- 1) Hydrogen control -Reduction of allowable time during which operation is permitted and improved long-term inerting capability.
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QUESTION A.I. (Continued) -
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J characterization, parametric' studies, experiment assessments and a critical-
+ ' focus on each of the relevant technical issues. The second stage will involve the determination as to whether'an issue is.either 1) resolved or unimportant,
- 2) amenable to resolution by additional testing / analyses, or 3) a candidate for additional' regulatory requirements. The current' schedule calls for staff
-conclusions and recommendations to be provided to the Commission by August, 1988. The staff believes that this program involving representatives from National Labs, industry, other experts and interested members of the public is-essential to the process of resolving safety issues related to Mark I containment' performance and thereby improving plant safety.
The probability of a severe accident that could challenge the Mark I containment is to considered to be extremely low. Consequently, the staff has
~
~ concluded that the potential risk to the public is acceptably low enough for reactors with Mark I containments to continue operating while evaluations are being conducted.
_ _ _ . _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ __m. _ _ . . _ _ _ . _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . . _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
QUESTION A.I. (Continued) i
' 2) Containment spray
-Improvements to cor,tainment spray capability during accidents in which all AC electric power is lost
- 3) Containment venting
-Improvements to containment venting capability.
- 4) Core debris control
-Provision for core debris control on the drywell floor and in the torus room under the suppression pool.
- 5) Reactor Building
-Provision for reduction of fission products Fission Product outside containment by additional or modified Attenuation reactor building sprays.
- 6) Basemat isolation -Provide means for isolating core debris for accidents involving basemat melt-through.
- 7) Procedures and
-Improvements in existing emergency procedures training and operator training.
The expedited program plan for resolution of Mark I containment issues calls L
for a two stage process.
The first stage will consist of issue 1
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f1 t, '00EST10N'A.?: What is.the implication'of the Mark I Containment Performance
- g. .,
Proaram for' Pilgrim? ,
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ANSWER:
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'At the completion of.the Mark I Containment. Performance Program, currently l scheduled:for' August 198R,.the staff will have identified appropriate containment improvements which will' extend the capability of Park-I plants to cope with core nelt accidents. Upon Commission approval of the staff .
proposals. implementation of any: additional requirements at Pilgrim,'as well as.
at. Mark I plants, will proceed consistent with the plants operating schedule. ,
1 Furthermore, utility and NRC activities related to the Mark I Containment l Performance Program will be coordinated with activities associated with the Individual Plant Examination (IPE) Program.
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ls QUESTION A.3: Who constitutes the expert group involved in the development _of the " Review of the Status of the BWR Mark I Melt-Through Issue" reportreferredtoinInsideNRCofDecember7,198k?
ANSWER:
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The expert group referred in the Inside NRC article is comprised of five individuals from National Laboratories involved in severe accident research, )
G. A. Green (Brookhaven National Laboratory), S. A. Hodge (Dak Ridge National Laboratory), K. D. Bergeron (Sandia National Laboratory), D. A. Powers (Sandia j National Laboratory), and J. Dallman (Idaho National Engineering Laboratory). i I
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'h . QUESTION A.A. What'will the NRC require by_ way of Mark I. Containment improve-ments at Pilgrim prior to' restart? ,
ANSWER:
The NRC. clarified its position and approach to ' resolution of severe accident
. issues for all nuclear reactors, including those with a Mark I containment,- by.
the " Policy Statement on Severe Reactor Accidents Regarding Future Designs and Existing Plants." .This policy statement issued on August 8,1985. reaffirmed -
the Commission's position that existing plants pose no undue risk to public health and safety. To verify the conclusion of acceptable risk on a plant specific basis, the Commission indicated in the policy statement its intent to require that individual licensees perform safety analysis of severe accidents to identify plant specific vulnerabilities. These studies will be conducted as part'of the Individual Plant Examination (IPE) Program, which will assess
- accident likelihood and containment performance. Pilgrim will participate in this program, which is expected to get underway early 1988.
' Boston Edison has voluntarily taken the initiative at Pilgrim to improve containment performance. This program is called the Safety Enhancement Program. The staff will review-the plant modifications to ensure they have no overall adverse safety impact on existing systems. However, the licensee's i
initiative to improve plant safety beyond the point of complying with existing NRC regulations is not a precondition for restart or a basis for modifying the license to operate the Pilgrim facility.
l
y' OllESTION A.S.7 What'is the status of-the Pilorim Safety Enhancement Program? '
$ f ANSWER:-
The Boston Edison Cc.., by letter dated iluly 8, 1987, provided the staff with a description of.the Safety Enhancement Procram (SEP) design chances that Boston Edison elected to implement at the Pilgrim plant. The coals of the SEP are:
- 1) to identify and implement plant improvements-responsive to previous NRR draft BWR containment policy, 2) revise emeroency procedures in accordance with Revision 4'of the BWR EPG's and 3) perform a comprehensive safety ,
assessment of-severe accidents. The licensee identified 12 plant changes to
-improve safety.; Since the licensee's program is not solely limited to containment issues, a number.of the proposed plant improvements are intended to. address other. areas of plant safety. Furthermore, a number of items would
. serve two functions, i.e., to enhance containment performance and to reduce the likelihood of core melt accidents.
The Pilgrim SEP identified the following improvements related to containment performance: 1) direct torus vent system, 2) drywell spray nozzle optimization, 3) fire water intertie to the residual heat removal system, 4)
, additional diesel pump capability, and 5) long tern nitrogen supply capability. A brief comparison of the Boston Edison proposed plant improvements with those identified earlier by the staff as possible candidates reveals that the Pilgrim SEP has addressed many of the relevant issyes.
(The Licensee has not found that measures for core debris control on the containment floor are needed).
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QUESTI0flA.S. (Continued) !
! {
The staff has performed an initial assessment of the proposed Pilgrim plant -
modi'ications'and reported that evaluation in a letter to Boston Edison dated l-L August 21, 1987. The minimum objective of the staff review is to ensure that q
the plant modifications associated with the Safety Enhancement ' Program have no.
- overall adverse safety impact on existina systems. In that regard the staff l requested additional infonnation prior to implementation of several items.
Staff found a number of the SEP modifications acceptable under provisions of 10 CFR 50.59 or approved related Technical Specification' changes. These include:
Containment Spray Nozzle Modification Diesel Fire Pump Diesel Fire Pump Fuel Oil Transfer System Blackout Diesel Generator ATWS Feedwater Pump Trip
ADS Logic Modification (Tech. Spec.)
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' QUESTION A.S. (Continued) i.
Staff has additional concerns with Direct Torus Vent System (DTVS) and questions regarding:
~RCIC Modification Backup Nitroger Supply Modification to RHR System One of the; proposed improvements ' Direct Torus Vent) was not endorsed by the staff for implementation at this time, pending resolution of a number of questions regarding its use.
Ouestions to BEco (sent on August ?l,1987) regarding DTVS include: ,
1 -Analysis of accident sequences
-Analysis of vent failure
-Estimates of releases for various sequences
-Maintenance or surveillance errors Boston Edison has not yet responded to the staff's letter of August 21, 1987.
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e 00EST10N A.6. What action is the staff taking regarding the Direct Torus. Vent?
I ANSWED:
As part. cf their Safety Enhancement Program (SEP), Boston Edison Company (BEco), the Pilgrim licensee, proposed the jnsta11ation of a Direct Torus Vent System (DTVS) as one of several SEP measures to improve containment '
performance'at-Pilgrim. The Direct Torus Vent provides a path from the torus
-to the plant stack and would be used to relieve containment pressure in certain severe accident situations.
The staff's initial- safety' assessment (issued August 21,1987) of the SEP modifications did not endorse the use of the DTVS at this time. The staff has asked Boston Edison a number of questions regarding the use of the DTVS. PEco will not be allowed to place the DTVS system into service until it is thoroughly evaluated and approved by the staff.
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QtlESTION A.7. What is the. status -of the staff's review of Pilgrim Emergency
. Procedures?-
l JANSWER g
Boston Fdison has prepared Emergency Operating Procedures that are written to Revision 4 of the Emergency Procecure Guidelines (EPGS). (Althoughthe. staff
'has not yet approved Revision 4 to the EPGs, they represent an improvement over previous EPGs.and are endorsed for use by the industry.wbile the staff review proceeds).
The Pilgrim E0Ps and associated procedures generation package (plant-specific
. technical guidelines, verification procedures and training programt were submitted for staff review in November 1987. Staff review will take a couple months and will include a site visit to observe simulator usage of the E0Ps. 4 Concerning revision 4 of the BWROG EFGs, the staff is not expected to complete its review o' that revision until ectly 1988. Althcugh the staff has previously approved a strategy for containment venting for Pilgrim and other boiling water reactors in conjunction with their review of current BWROG EPGs, the proposed revision 4 guidelines recommend a new approach, with containment
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Ol!ESTION A.7. (Continued) -?-
venting used as an anticipatory response to elevated containment pressure.
This new approach must be thoroughly evaluated and approved by the staff before specific containment venting modifications inay be found acceptabic et Pilgrim.
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- :0VESTION B.1.: What action..is:NRC taking in response to the FEi1A findinos of
- 1uly 29, 1987?
4,;
ANSWER:.
5 1 L If On August 18, 1987, the NRC requested an action plan and schedule for correction from Boston Edison Company addressing the FEMA-identified deficiencies. Boston.
Edison submitted their: action plan on September 17. -1987. Headquarters 'and-regional NRC staff have closely monitored the progress of the utility's efforts.-
regarding the resolution of..offsite emergency preparedness issues. On various-occasions,"NRC staff members have discussed the status of emergency preparedness-with the utility as well.as the Commonwealth and local officials. Information.
- from.these' parties. indicates that significant progress has_been made towa'rd. .
. resolving the FEMA-identified issues. The NRC will. continue to monitor the progress of the utility, Corrnonwealth, and 1cca1' officials in correctino the '
emergency preparedness deficiencies. The determination whether to restart the Pilgrim plant will involve consideration of the correctiva actions taken to address each of the emergency planning issues identified by FEMA. The NRC will coordinate review efferts with Boston Edison, FEMA, State, and local officials to identify the most important aspects of these deficiencies and the actions necessary to demonstrate adequate preparedness.
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MUESTION B.2: Wh;y is the. Pilgrim restart process continuino with the FEMA-
- ..c identified deficiencies unresolved?
-ANSWER:
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The restart process principally involves BEco's correction -of; identified
. deficiencies'to the NRC's satisfaction. Pilgrim'is. presently shutdown with:
plant activities being conducted in accordance with the conditions of their
~ license as modified by our' Confirmatory Action Letter. While the NRC agrees ,
- that eneroencyfplanning deficiencies do exist at Pilgrim and further agrees that corrective' actions should be taken, we have not agreed that such concerns present an:"iminent- danger" to the 'p'uhlic that would warrant an enforcement -
action affectino the Pilgrim license. Consequently, any actions that may be taken with regard to' emergency planning concerns at Pilgrim do not preclude the NRC.-frcm authorizing Boston Edison to resume operation of the facility pending final resolution of all emergency preparedness deficiencies. None of?
the FEMA-identified deficiencies-appears to be of such compicxity that it can--
- not be' corrected. FEMA has outlined in their report what would be necessary
- for each item to be corrected. Therefore, it is reasonable to assume that-the deficiencies will be satisfactorily resolved.
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00ESTION B.3.: What- emergency preparedness -action will be necessary by BECo, State and. local. entities, and FEMA before a restart is authorized? I
' ANSWER:
Any actions'that may be taken with reoard to emergency plan _ning concerns at Pilgrin do not preclude the NRC from authorizing Boston Edison to resume o peration of the facility pending final resolution of all emergency prepared-ness deficiencies. Notwithstanding the fact that NRC has taken no enforcement action affecting the Pilgrim license, NRC will.not permit the facility to resume operation until corrective actions. satisfactory to NRC have been taken.
to address the emergency planning deficiencies identified by FEMA. We will give special' attention to i!he improved evacuation plans for schools and day care centers as well as the improved evacuation plans for special-needs and l transportation-dependent populations in the ten-mile emergency planning. zone.
We will require some demonstration of the critical aspects of these evacuation plans before we can decide that Pilgrim is ready to resume operation. The NRC will coordinate review efforts with 8Eco, FEMA State and local officials to l' identify the most important aspects of the identified deficiencies and the actions necessary to demonstrate adequate preparedness.
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g y y OUESTIONlL4.: Do NRC regulations allow a nuclear plant to operate during the
[i four' months'after an NRC' finding of_inadeouate. emergency t*
preparedness?
- E ANSWER:
The Commission recognizes that there can be deficiencies in the emergency planning and preparedness associated with a nuclear facility. However, there must be substantial compliance with the regulations, i.e., compliance sufficiert to find that there is reasonable assurance that adequate protective.nessures can and will be-taken in a radiological energency. Indee',
d even in those instances-where the Commission can no longer make its reasonable assurance finding, emer-gency preparedness deficiencies may not require facility shutdown. See 10 CFR 450.54fs)(2)(ii). In practice, radiological emergency response plans are rarely if ever perfect and complete. This is the reason for the continuing FEMA and NRC oversight of this area. Deficiencies will be found and assessed for signif-
'icence. While all deficiE9cies are expected to b6 Corrected, rot all W ll #
change a finding of reasorable assurance by the NRC.
For an operating plant, such as Pilgrim, the regulations provide considerable enforcement-flexibility to the NRC. Whereas significant deficiencies in a safety system at an operating reactor could cause it to be shut down at once, the identification of significant deficiencies in energency planning results e
'OVESTION B.4.: (Continued) i.
in the initiation of a four-nonth period within which the; deficiencies are addressed, not in an automatic shutdown of the facility. Even after this-
"120-day clock" has run, the regulations provide that,the NRC has the enforce -
ment discretion to allow the' plant to continue operation even in the face of such a deficiency. In determining whether a shutdown or other action is appropriate, the Commission will take into account such factors as whether the licensee can demonstrate that the deficiencies in the plan are not significant, or that adequate interim compensating actions have been or will be taken promptly, or.that there are other compelling reasons for continued operation.
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'00ESTION B.5.: Can the NPC allow the P11 grin station' to operate without adequate emergency plans?- ,
i ANSWER:
While the NRC acrees that emergency planning' deficiencies do exist.at Pilgrim and further agrees that corrective actions should be taken, we have not agreed that such concerns present an " imminent danger" to the public that would warrant an enforcement action affecting the Pilgrin license. Consequently, any actions.
that may be taken with regard to emergency. planning concerns at Pilgrim do not preclude the NRC from authorizing Boston Edison to resume operation of the facility pending final resolution of all emergency preparedness deficiencies.
For an operating plant, such as Pilgrin, the regulations provide considerable enforcement f1e'xibility to the NRC. Whereas significant deficiencies'in a ,
. safety system at an operating reactor could cause it to be shut"down at once,
'the~ identification of significant deficienc!es in emergency planning results ia the' initiation of a fou -nonth period within which the deficiencies are addressed, not in an automatic shutdown of the facility Even after this "120-day clock" has run, the regulations provide that the NRC has the enforce-sent discretion to allow the plant to continue operation even in the face of !
such a deficiency.
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OVESTION B.6.: How will the NRC evaluate the status of the resolution of emergency preparedness issues?
ANSWER:
The determination whether-to restart the Pilarim plant will involve consid-eration of the corrective actions taken to address each of the emergency planning issues identified by FEMA. Based on information obtained from the licensee, FEMA and State and local officials, the NRC will review the energency planning issues,to deternine which are of highest priority and what actions are necessary to' demonstrate that reasonable'preparedisess exists prior to restart.
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00ESTION B.7: If the NRC finds that the state of.eneroency preparedness does
- not provide reasonable assurance that' adequate prot etive measures can'and will be taken in the event"of a radiological emergency, what action can the NRC take?
ANSWER:
If the deficiencies in emergency preparedness are not corrected within four months of the NRC finding, the Commission will determine whether the reactor shall be shut down until such deficiencies are remedied or whether other enforcement action is appropriate. The Commission will take into account such factors as whether the licensee can demonstrate to the Connission's satisfac-tion that the' deficiencies in the plan are not significant for the plant in questiot. or that adequate interim compensatory actions-will be'taken promptly, or that there are other compelling reasons for continued operation.
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00ESTION B.8: Will we require all of the FEMA.and Barry deficiencies to be corrected prior lto restart?- ..
ANSWER:
It is the NRC's position that.all'of the deficiencies identified by FEMA will-be. addressed prior to restart. Deficiencies concerning the evacuation of schools and daycare centers as well as the evacuation of special needs and transporta-
. tion dependent populations will be given special attention. We will require -
some demonstration of the critical aspects of these evacuation plans before a decision is nade that Pilgrim is ready to resume operation. Vith respect to the
' deficiencies identified by Secretary Barry, FEMA has indicated that these have been included in the FEMA self-initiated review..
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.Ol!ESTION R.9:' Will we-: require a satisfactory emergency exercise' wjth' a FEMA i -- 1 report before restart?
- L-ANSWER:
f-Adequate. emergency preparedness can be demonstrated in a number of ways, includ-ing evaluation of plans.and' procedure, verification of trainina.in specific
-areas, drills, table top exercises, and full or partial participation exercises -
-The.1987.fu11 participation exercise:for Pilgrim has been deferred as requested by the licensee to-the first half of 1988. . The c'orrection of. some of the. issues-in,the' emergency preparedness. program for. Pilgrim may be~ demonstrated in'a drill:
or exercise-of the plan changes, however, we see no need to' recuire a full-par--
ticipation exercise. prior to restart. The NRC will, nonetheless.-verify that
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the overall state of energency preparedness is adeq'uate to protect the. public -
health and safety rp' k- to restart.
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L OUEST10N B.10:LIs an ap~ proved'offsite emeraency preparedness = plan equired-for restart?
- ANSWER:
An approved.offsite' emergency plan is not required for restart. The restart' process principa11y' involves'BEco's correction of identified hardware and management deficiencies to the NRC's satisfaction. ' Pilgrim is presently shut ,
down.in accordance with the conditions of their license as modified b.v our -
confirmatory Action Letter. While the NRC agrees that emergency planning
' deficiencies do exist at Pilgrim and further acrees that corrective actions:
should be taken, we'have not agreed wthat such concerns would warrant an enforcement action affecting the Pilgrim license. Consequently,-any actions that may be taken with regard to energency planning concerns at Pilarim do not
- preclude the NRC from authorizing Boston Edison to resume operation of the facility pend;ng. final approval of an offsite emeigency plan.
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-OUESTION B.11: What would/the NRC do if Massachusetts.cannot prepare and-provide an offsite emergency plan to FEMA' '
L ANSWER:
The NRC requires the development of offsite emergency _ plans.that are adequate and_can b'e-implemented. If Massachusetts cannot prepare an offsite eneroency plan, Boston Edison would have to prepare a compensating offsite plan.and Atp7f sumit it for FEMA and NRC review. FEMA has determined in.its Apr&F 1987 interim finding, that the deficiencies in offsite plans identified in that findino are-correctable. The resolution of the deficiencies would be based on a review'of the offsite plans and consideration of any other information available to FEMA.
Over the past several months, Boston Edison, the Commonwealth and.the local governments in the Pilorim area have committed considerable re-sources and .,
effort-toward improving o?fsite emergency respense prograns. The status of these activities would be considered in the determination of a finding of adequacy. The NRC would conrider the overall status of offsite emeroency preparedness, including FEMA's evaluation, whet; determining whether a reasonable assurance finding can be made.
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I QUESTION P.12: Does the NRC have emergency preparedness experts with qualifications equivalent to the FEMA' experts?
I.
I ANSWER:
Yes. 'The'NRC recognizes the expertise of FEMA in evaluating offsite emergency preparedness and'in interfacing with State and local governments for inter-pretation of emergency planning criteria; however, many NRC staff members have extensive equivalent expertirn. NRC regional emergency preparedness specialist.s-are members of the FEMA Radiological Assistance Committees that review all off-site emergency plans. .These NRC personnel have equivalent qualifications and-experience in offsite emergency preparedness. The development of NUREG-0654/-
FEMA-REP-1, the. guidance criteria that is used to evaluate all emeraency plans, was a ,ioint NRC-FEMA effort. NRC personnel routinely review FEMA offsite
' findings in order to make an overall finding of adecuacy of emergency pre-paredness. In addition, NRC staff in the Office of Governmental aad Public Affairs regularly coordinate activities with State and local officials. The responsibilities and experience of this NRC office include administration, of State Agreements programs and training of State and loca? government personnel in radiation control programs.
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OUESTION-B.'13:.In.your testimony.you refer to some demonstration of the critical .
aspects of the offsite emergency plans- before a decjsion that Pilorim is ready to resume operation. .k! hat do you dean'by some.
demonstration?
ANSI 4ER:
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Adequate emergency preparedness ~can be demonstrated in a number of ways,'includ-ing evaluation o'f plans and procedures, verification of training in trecific areas, drills, table top. exercises, and full or partial participation exercises.
The correction of some of the issues in the emergency preparedness program for Pilgrim will. require demonstration in a drill'or exercise of the plan changes.
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!OUESTION B.14:-What do you mean by " addressed prior to restart" when you. refer-to'the FEMA identified deficiencies?
i-ANSWER:
NRC will not permit the facility to assume operation until corrective actions satisfactory.to NRC have'been taken to address the emergency planning
- deficiencies identified by FEMA. We will aive special attention to the improved _
evacuation plans for' schools and day care centers as will as the improved evacuation plans for special-needs and transportation-dependent populations in the~ ten-mile emergency planning zone. Ve will require some demonstration of the critical aspects of these evacuation plans before we can decide.that Pilgrim is ready to resume operation.
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00EST10N B.15: What is-the NRC position on the Commonwealth's plan to enlaroe
-the EPZ?- ,.
ANSWER:
The present EPZ has been-reviewed by FEMA and the NRC and found to be acceptable.
We are not aware of the details of a proposed enlargement; however, we under -
stand that the reconfiguration of the EPZ has been deferred by the Commonwealth to~ enable pri.ority attention to' be given to improve emergency preparedness with-in the current EPZ. In general, we have no ob.iection to providing more detailed planning for. the areas outside.the existing EPZ, but due to the greatly reduced ~
risk, see no.need for the same level of planning as required for~the population within the current EPZ..
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- -l L. OUESTION C.1. Some studies-have shown that certain communities surrounding -
S Pilgrim have: cancer rates two to three~ times the ave, rage U.S. I rates. Could this be due to Pilgrim?
ANSWER.
It is very unlikely~ that such an' increase in cancer rates could be due to Pilgrim for several reasons. First, the radioactive materials released from Pilgrim result -in exposures to humans similar to that from nature. t.ow levels of natural radiation are all'around us. Natural radiation (measured in millirems per year and. abbreviated as mrems/yr) is typically about 100 mrems/yr in the U.S., although it varies from about 70 to about 300 mrems/yr deper. ding on the location in it'e U.S. It is important to note that, when expo'sure to radiation is quantified in units of millirems (or rems), there are no differences in the health risks associated with a given amount of radiation, be.it natural or man-made. N6tural radioactivity is in the air we breathe and the food we eat and drink,, For example, the amount of radiation received by humans from potassium-40, a natural radioactive material in the body, is about 20 mrems/yr. Eve 1 though human beings have always been exposed to natural radiation, there is no evidence ttiat such exposure has a
significantly affected human health. The dose to a maximally exoosed member of the public near Pilgrim is estimated to be less than 10 millirems per year. This exposure is a small frEction of exposure to natural background radiation. '
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.g QUESTION C.1. .IContinued) -P-I. '
2
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-Second; even assuming:that there is some increased risk due to exposure to low levels of radiation any: increase in cancer rates would be so sr.all so as to '
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j- be undetectable. . This conclusion is' based on widely accepted scientific reports; such as those compiled by_ the National Academy of Science's Advisory Committee lon the Biological. Effects of Ioniz'ing Radiation. This conclusion is consistent with'the reconsnendations of recognized radiation-protection organizations, such as the National Council on Radiation Protection and Measurement (NCRP), and the International ~ Corsnission of Radiological Protection (ICRP).
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,.# 'lI 7Z OVEST10N'C.P.- Could the'above average cancer rates be due to exposure of-workers? .,
Exposure of workers must.be kept within the limits of'NRC regulations. While-worker. exposure'.at Pilgrim has been high compared with other plants in-the.
U.S., it is still unlikely that this would result in a detectable' increase in cancer rates. This conclusion is based on widely accepted scientific reports, such'as those compiled by the National Academy of Science's Advisory Conmittee on the Bioloaicel Effects of Ionizino Radiation. This conclusion is consistent with the recommendations of recognized radiation-protection
- organizations, such as the National Council of' Radiation Protection and Measurement (NCRP),'and the International Corrnission of Radiological Protection (ICRP)..
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I How does Pilgrim rank in; terns of exposure to members of the QUESTINi C.3.
- gen'eral public? .
In terns of exposure'of members of the general public, Pilgrim ranks.10th' I highest among U.S.: plants. This is based on a population dose of 94 person-rem accumulated over the years 1975 through 19R3 (the latest year.for-
-'which this information is available).. Exposure of. individual members of the public has'been within.the dose design ob.fectives of 10 CFR 50 Appendix I, which are 100 times less than the public health and safety limits of 10 CFR 20.
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- , QUESTION'CM) How does Pilgrim rank. in tems of exposure to workers et the-.
facility?. ,
5 In- terms of exposure of workers, pilgrim has the highest cumulative- average o
exposure" of any plant in .the U.S.' Occupational exposure at Pilgrim has averaged over the years 1973 through 1986 about 1670 person-rems /yr, compared .
with the PWR industry average of about 830 person-rems /yr. (The PWR industry average.is about.500 persen-rems /yr.)
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.00ESTION D'1.. . What'is the statutory basis for the authority of the NRC and the -
states in regulating radioactive materials? ,
,, r ANSWER y
' Energy Act of 1946, Congress has since enacted other statutes effectively
' dividing up the government's authority not only among many egencies but also between the federal and state governments. This has led at times to problems o' fragmentation, unclear lines of responsibility, and overlapping jurisdictions.
'The Atomic Energy Act of 1954 superseded the earlier act and centralized control over all aspects of the fuel cycle in the federal government, giving the Atonic Energy Commission an administrative monopoly of the industry. The Atomic Energy Act of 1954 established the regulation and licensing procedures for nuclear power olants.
Prior to 1959 the states had no role in nuclear policy. In 1959, Congress added an important amendment to the Atomic Energy Act of 1954, !?74, which delegated authority to the states over limited areas of nuclear policy. Although
%274 does not contemplate dual or concurrent regulation, it includes provisions,
, among others, for the Commission to (1) relinquish and states to assume regulatory jurisdiction over defined areas of source, by-product and special nuclear ma terials; (2) enter into agreement with states to perform inspections or other I
o . - _ _ _ _ - _ - - . - - ____
QUESTION D.1. (Continued) i i
functions; end (3) notify states of license applications ard afford opportunity to advise'the Commission. The ambiguity of this.amentrent has formed the basis of subsequent con-stitutional challences on the issue of federal preemption.
Under the Supremacy Clause of the Constitution,- Article. VI, Clause ?, federal law has supremacy. over state law when the two conflict.
r The 1974 Energy Reorganization Act abolished the Atomic Energy Conmission, -
but retained'+be Atomic Energy Act of 1954 and divided the promotion and regulatory functions between two federal agencies, the Energy Research and Development Adm'nistration (FRDA) and the Nuclear Regulatory Commission (NRC).
In response to public demands for protection of the environment, Congress has e enacted several statutes which affect the nuclear power industry directly and indirectly (i.e., National Environmental Policy Act of 1969 (NEPA), Federal Water Pollution Control Act of 1972, 1977 Cleen Air Act amendment, Safe Drinking Water Act of 1974, Resource Conservation and Recovery Act of 1976, and the Hazardous Materials Transportation Act of 1975). ;
[ State activities parallel those of the federal povernment in many respects.
Most states have authority under specific radiation control laws or'under
H l OlIFST10N 'D.1. (Continuedi i a t I
general public health laws to' regulate activities using radiation.- Since the.
federal .goverrnnt is so extensively irvolved-in this area, states operate within the federal legislative framework and are occasionally pre-empted by
. federal activities.
l In recent years, states have taken an' activist stance on nuclear policy by passing moratorium legislation. Such' legislation has raised questions concerning interstate commerce and ~ federal preemption in the courts. Even for )
those~ materiels and facilities which under-the Atomic Energy Act of 1954, as ;
i amended, as interpreted by the courts, must be ifcensed and regulated exclusively '
by the NRC to protect against~ radiological health and safety hazards and for national security interests, the states have a role. This matter is the issue )
dealt with in Pacific Gas and Electric Company vs. State Energy Resources Conservation and Development Comission. Justice White had this to say; among l others, 1
I
". . . as we view the issue Congress, in passing the 1954 Act and in subsequently amending it, intended that the )
1 federal government shoulet regulate the radiological safety J aspects involved in the construction and operation of a nuclear plant, but that the states retain their traditional l responsibility in the field of regulating electrical utili-ties for detennining questions of need, reliability, cost and other related state concerns."
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l' y:
i)
QUEST 10fl D.2. What NRC programs are in effect to facilitate interaction between the'NPC and the states?
I.
ANSWER-1 u
The Commission has had extensive interaction with the states, both formal and informal,: throughout its history. With the reorganization of the NPC in April 1987, State, local and Indian Tribe Programs was created lto achieve a more proactive relationship with state and local governments and'with Irdian Tribes.
The NRC Agreement State Program has often been cited as an outstanding example of Federal-State partnership in dealing with muteal interests. At present there are 29 Agreement States administering a total of approximately 15,000 licensees.
The State liaison Officers' Program provides for interaction between the NRC and Governor-appointed state officials, whose role is to provide a communication channel between the state and the NRC.
The Conference of Radiation Control Program Directors promotes all aspects of radiological health and encourages cooperative enforcement programs with
l p
OUEST10fl 0.2. - (Continuedi -?-
o i federal agencies'and between related enforcement. agencies within each state.
The NRC is an sctive participant in the Conference.and along with other federal.
, agencies provides financial and technical support to the Conference.
The NRC actively ' interacts with the National Governors Association, the National Conference of' State Legislatures, other national associations of states, and regional organizations such as the Southern States Energy Board.
The NRC and several states have signed letters of agreement'and Memoranda of Understanding on reactor and waste issues, entailing among others, information sharing and state inspection activities.
Other NRC activities with the states include:
providing training for state personnel reviewing state legislation and regulations providing information on high level and low level waste technologies and on transportation ~ issues providing infonnation on NRC licensee activities hosting national and regional workshups on nuclear issues. '
L _ _ . _ . _ _ _ _ _ _ _ _ __ - - _ _ - - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
l What are the specific cooperative interactions between the NRC QUESTION D.3 and the Commonwealth of Massachusetts.
ANSWER The NRC and the Commonwealth of Massachusetts have had extensive cooperation in areas of mutual interests. These activities include the following:
Formal Ongoing Activitics State Request to Become an NRC Agreement State NRC worked with MA Special Legislative Committee on low Level Waste to develop legislation that would permit NRC to delegate to Massachusetts the authority to regulate all aspects of LLW Management. The NRC will be reviewing the Commonwealth's draft regulations and program to become a full Agreement State, which will give the authority for MA to regualte byproduct radioactive material and source material.
. State Environmental Contract with NRC Commonwealth collects and analyzes environmental samples and participates in NRC TLD program for Yankee Rowe and Pilgrim under contract to NRC.
State and NRC share data and both issue annual reports.
. Verification of Licensees 10 CFR 50.72 18, reportsbetween 1987 W.Kane and R.Boulay, Letter agreement was signed on June Director, Massachusetts Civil Defense Agency regarding verification of licensees 10 CFR 50.72 reports. This agreement was requested by R. Boulay in response to an oral Executive Order from Governor Dukakis.
State Request to Observe NRC Inspections at Pilgrim in response to a State request to attend the exit meeting of the AIT Inspection conducted because of the Pilgrim Loss of Offsite Power (11/87)
On case by case basis, a State NRC Region I permitted State attendence.
observer will be permitted to attend other NRC inspections, including the Pilgrim Restart Readiness Inspection. NRC also discussed with the State the fonnal agreements that are in effect with some States whereby a State technical representative would be permitted to attend NRC inspections, enforcement conferences and technical meetings.
Interface with Dept. of Public Health State Inspectors NRC notifies State of planned material inspections and permits State to observe NRC Inspections. The State also notifies the NRC Resident Inspector that they are ensite to perform State required inspections and Recently, Civil Defense personnel have discuss issues of mutual interest.
made announced visits to the NRC Residents Office to discuss plant events.
Exchange of Information through SLO Program Sig'nificant information, e.g., safety issues, emergency conditions, issues that may receive press attention, and enforcement actions, is For exchanged example, between the Governor's SLO and the RSLO in a timely manner.
technical briefings were arranged between the State and NRC throughout the Pilgrim toss of Offsite Power. Event.
d' . e.dhiui;w
. -% 4 ,4gbyggg
~
1 I
Part u 1patiott 1r State Requested Meetings and Hearings Joint Legislative Energy Comittee on the Status of Activitics at Pilgrim 12/17/86 Tom Murley pledged.NRC willingness to work with the Governor and State officials in a cooperative manner. Gov. Dukakis released the Barry Report that recommended a greater role for the State in oversight over-Pilgrim, and identified a number of deficiencies in emergency planning at Pilgrim.
State Cabinet Level Meeting to Dicuss Pilgrim and EP issues 2/2/87 W. Kane and T. Martin dicuss with Sharon Pollard and Peter Agnes
-the concerns of the State.
5/21/87 Commissioner Carr meets with MA officials prior to touring Pilgrim.
Commonwealth officials (Shannon Pollard, Anges, Parker. Hubbard, Judge) request Comission to conduct public meetings prior to Pilgrim Restart.
10/8/87 W. Russell, NRC Region I staff and NRR staff meet with Consnon-wealth officials (Agnes, Judge, Dean, Boulay and Alexander) to discuss the NRC staff position on emergency planning, plant safety enhancements, and management deficiencies with regard to Pilgrim.
Special Joint Comittee to, investigate Pilgrim 2/3/87 NRC provided testimony per the State request on Federal / State jurisdiction and NRC/ State interface regarding Pilgrim and other nuclear plants. Comittee established to investigate the effect on public safety of operation of the plant, the response of BECO to NRC findings, Emergency Planning, Commonwealth financing and implementation of emergency pitns.
4/27/87 NRC provided testimony per the State request on the BECo problems in plant management and occupational radiation exposures.
Meetings with Civil Defense Agency and NRC 5/5/87 R. Bellamy attends meeting with MA COA and FEMA where the status of Pilgrim Offsite EP deficiencies and expansion of the EPZ are discussed 7/14/87 W. Lazarus participates in meeting with MA CDA regarding the '
expansion of the EPZ beyond 10 miles.
Other NRC/ State Meetings MA State Liaison Officer has routinely attended NRC sponsored National SLO i and the annual All Agreement State meetings.
The NRC supports the New England Radiation Control Program Directors annual meeting by presenting a status of NRC activities.
The NRC supports the FEMA Regional Assistance Comittee which reviews MA and local emergency plans and procedures.
s .
.t b-
- dllESTION E.1: What specific -actions / steps will NRC take prior'to authorizing
~
restart?
I b
Q
-ANSWER:
- 1. Conduct public.meetinos in the Plynouth. area to solicit commentsiand concerns on the Restart Plan from the general-public, and present the resolution of those commnents and concerns.
2.- Complete review of the BEco Restart Plan, including resolution of ,
comments and concerns expected to be received from the Commonwealth, Lthe public, and Boards of Selectmen within the EPZ.
i.
- 3. Conduct a Restart Readiness Assessment, to include an Integrated Team Inspection of the facility readiness. In general terms, we will be looking for:
a) A stable and effective management team at the plant.
b) Maragement, licensed Senior Reactor Operator, and licensed Reactor' Operator positions at the plant are filled with oualified individuals.
c) The wtrk backlog is under control, and a system is'in place to track the backlog.
d) Solid and continuing improvements have been made in long-standino problem areas such as radiation protection, fire protection, and security.
.__. _ . _ _ _ _ _ _ _. ._.m _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ . _ _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ ___._._________________ _ ____ _ _ _ ___ _.__.__ _ m .
p l
OUESTION E.1: (Continued) l
}
e) Boston Edison to be developing its own internal high standards of performance, and the means for critical self-analysis rela-tive to those standards.
4 Complete those reviews necessary to assure that solid improvements have been made in the offsite emergency planning weaknesses.
- 5. Conduct a public meeting with State Senator Willian Golden and other petitioners, (if they desire such a meeting) to address their Concerns.. *
- 6. Conduct a full Commission meeting at which restart authorization would be considered.
NRC will, of course, continue its detailed inspections of many specific issues within these general areas.
4 00ESTIOf: E.2: How'does the Loss of Offsite Power Event reflect past management-
, concerns? ,
The management response to the November 12, 1987 Loss of Offsite Power event was evaluated by an Augmented Inspection Team. Their report was issued on December 14,1987. It states, in part, The recovery efforts were well planned and reasonably well implemented once the conditions were properly assessed by station management." The concensus of the AIT nembers was that the response to the loss of power was appropriate and well organized, and that reactor plant safety was'never in question.
The plant Management mount 1d an organized recovery effort employing multiple approaches, including. attempts to restore the startup transformer, provide power through the auxiliary transformer, and assessing the reenergization of the 23Xv shutdown transformer. The Nuclear Operations Department Manager administrative 1y staffed the Technical Support Center about midday, allowing the operating shift to focus on plant conditions. In addition, a recovery team was forned under the direction of the Outage Manager, consisting of personnel from outage management, station management, corporate oversight, nuclear engineering department, administration, technical, and maintenance.
Overall management of the recovery effort appears to have been somewhat fragmented.
The AIT experienced difficulty in determining who had overall responsibility L
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1, . i OllESTION E.?: (Continued ) -?-
i for managing the recovery. In general, the Nuclear Operations Manacer remained
.in the Control Room, except when attendina meetings in the Maintenance Section Manager's office. 'His operational management involvement was clear, however, his overall direction of station activities seemed less clear.
The overall recovery appears somewhat lengthy. This may be attributed, in part, however, to the weather, the cold shutdown condition of the plant (which ,
did not mandate speedy action), and BECO manacement's stated directive to proceed slowly and deliberately durina the recovery. Initially, power restoration was precluded by the severe weather and lack of clear knowledge of conditions in the switchyard. 1.ater, power restoration by means of the Startup Transformer was precluded by the need to properly test and check out the transformer._ Power restoration via 'backscuttle' (backfeeding through the main and auxiliary transformers) was not immediately possible due to the need to clear tags, open the main generator disconnect links, and and complete insulator washdown.
BEco management acted effectively and responsibly in administrative 1y staffing the TSC. This contributed to effective management of the recovery. Interviews by the AIT indicate that BECO personnel believe the TSC could have been of even areater value had it been staffed sooner. One noteworthy aspect is,that the
___- - _ ___ _- _ - a
OUESTION E.2: (Continued) !
Nuclear Operations Department Manager, who would normally be stationed in the.
TSC when activated pursuant to the Emergency Plan, remained in the Control Room. Had he been in the TSC, he may have been able to more effectively direct the overall recovery effort.
BECo is reviewing several procedures for adequacy based on experience gained during the November 12, 1987. event. Those include: ,
2.4.16 Distribution Alignment Electrical System Malfunctions l 2.4.144- Dearaded Grid Voltage l
1 2.2.36 Instrument Air System 2.2.37 Service Air System 2.2.46 Control Room / Cable Spreading & Computer Room Heating, Ventilation, and Air Conditioning System 5.3.8 Loss of Instrument Air 5.2.2 high W2nds (Hurricane)
This review for adequacy indicates a long-awaited change in the management i
___._-___--.-__.-----_-__.---_A
f ,
OUEST10f1 E.2: (Continued) i.
outlook of BECo in that it indicates a proactive stance. It shows that current' BECo management is trying to prepare for possible events, and be ready. for thair occurrence,~rather than merely responding to events as in the past. This.
..is.not' meant to imply that all the managenent problems are resolved, but rather-thet-there is clear evidence of. improvement.being made. The NRC has made several recommendations to BEco as a result of this event. , They are documented on pages-59 and 60 of the AIT report (attached). These actions,-if properly implemented, could result in improved personnel performance, and increased .
operational flexibility during shutdown periods.
g OUESTION E.3: What are the criteria' for determining that manaaerent 'is 8
effective?- -
j l
-Management effectiveness-is a concept that does not easily lend itself to
. straight-forward definition. However, there are certain' traits that'are typically evident in effective manaaement organizations. Sone of these traits-are:
- 1. Structurally, the organization is established to' bring to bear appro-priate management attention and focus on the various mission areas of the organization. For a nuclear power plant, these areas include Operations, Maintenance, Surveillance, Engineering, Radiological Controls, Security, Emergency Planning, and Licensing.
- 2. Manaoenent positions are filled with qualified persennel. Turnover-
.in these positions is controlled such that' management development and succession plans can be implemented without resulting in significant degradation in performance.
.3. Management policies are clearly stated and widely understood within the organization. Policies and procedures are satisfactorily imple-mented and rarely violated.
I 4 Managenent information systems exist that can provide adequate records and trends of organizational performance, and can serve as a credible basis for management decisions.
= _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ . . i
g-. .
o b I 00ESTION E.3.: (Continued)' !
p 5. Decisionmaking is at the level in the organization that ensures an-adequate manaoenent review.
6 '. Prior planning and appropriate assignnent of priorities are. evident within the organization.-
- 7. Corporate and site management involvement in site activities are' evident. Management reviews are timely, thorough, and technically sound.
- 8. Corrective actions to identified problems are timely and typically l targeted toward the root causes of those problems.
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J
,q i
' QUESTION E.5. Would Pilgrim as currently designed, constructed and sited be buildable and operable under today's standards? If.no, then why should we let Pilprim go back on line?
I ANSWER r
i Part 50 of Title 10 of- the Code of Federal Regulations provides the i regulations regarding licensing of nuclear power plants such as Pilgrim. The Pilgrim facility, was licensed in 1972, subsequent to an NFC review and -
approval process that dated back to the mid-1960's. This review and approval process assured that the facility was designed and constructed in accordance with the Conmission's regulations and applicable codes and standards in effect at that time. The utility's Final Safety Analysis Report (FSAR) and the l staff's evaluation contained in a Safety Evaluation Report (SEP) constitute what is called the " licensing basis" for the plant.
Each license for operation of a nuclear power plant contains technical j specifications which set forth the safety and environmental protection measures to be imposed on the facility and the conditions that must be met for q
the facility to operate. Once licensed, a nuclear facility remains under NRC ;
i surveillance and undergoes periodic inspections throughout its operating j li fe.
l j
(. ..
s g -00ESTION E.5. (Continued) I Because (f.S. nuclear facilities have been built and licensed at different'
. tines they are coverned by different codes, criteria ard regulations. Newer plants.throughout the U.S. are governed by more recent, and in some cases more stringent, requirements. In cases' where the NRC finds that substantial,.
additional protection is necessary for the public health and safety or.the common defense and security, the NRC may require "backfitting" of a licensed plant, i.e., the addition, elimination or modification of structures, systems.
or components of the facility. Some examples of this "backfitting" are the. -
imposition of changes required after the Three Mile Island accident and certain fire protection requirements. Many of the fire protection improvements are currently being implemented at Pilgrim.
t As part of the onooing inspection process and as part of specific licensing reviews in support of changes to the operating license or in support of
~ Commission required generic actions, the ttaff assures that the Pilgrim facility meets it orioinal licensino basis and those subsequent regulations necessary for the public health and safety.
Ll b OUESTION'E.6.: In response-to the'GAO. report received in Auoust, 1987, (87-141)'
what are the NRC's safety coals,. status of quideline ' '
preparation, and how will these guidelines apply to' Pilgrim?
L l
ANSHER:
=The GA0 report referred,to above discussed the lack of quidelines for determining-when a plant should be shut down for safety reasons. The NRC response stated that the operating license includes conditions and technical q specifications which identify operatino conditions that require'the plant to be shutdown and' time limits for achieving shutdown conditions. If violations I of Technical Specifications are of sufficient meanitude, an NRC enforcement' l l
option-is to Order imediate shut down. :
l l
When evaluating overall performance the NRC considers several areas of. '
activity to determine if plant operations are acceptable. This is part of the !<
. Systematic Assessment of Licensee Performance (SALP). The SALP. reviews, j i
plant performance indicators, and the semiannual senior manacement meetings on l plant performance are adequate neans of determining when license performance has deteriorated to an unacceptable safety level. Appropriate action will i
then be taken. No additional guidelines for determining " safe" operations are j i
beino prepared. j i
, OUESTION E.6.: (Continued) i NRC actions at Pilgrim have been consistent with our. response to the GAO
' report. Pilgrim shut down on April 17,.1986 due to equipment problems. This shut down was confirmed by a Confirmatory Action Letter (CAL). Deteriorating
' management controls were idantified by NRC and considered as part of the SALP
' process.- NRC' management met frequently with Boston Edison manecement and, in August 1986, the April CAL was supplemented to. include our management concerns. Boston Edison has kept the Pilgrim facility shutdown while addressina management, emergency preparedness and technical issues. NRC enforcement action, such as shutdown Order, has not been required.
I
A THE COMMONWEALTH OF MASSA'CHUSETTS r i DEPARTMENT OF VME A7TORNEV GENERAL k
LWi JOHN W McCCmVACE 5*4 *E Car CE SutOiNG
[ ONE A$es>.,mf oN DLACE BCSON 02'08 '696 JAMES M $wANNoN
. r oa a v u =< "'
May 23. 1988-Donnie H. Grimsley ERLEDOM OF INF0m
?: t yt. t . r , Divislun of Rules are) Re'ords ACT REQUEST
'.'f i ce e f Mmini st r n ir.n ud Reso sen Mr.3gement ~
nited States Nuclear Regulatory Commission 7735 Old Georgetown Road pg,g g Bethesda, MD - 20814
Dear Mr. Grimsley:
This is a request under the Freedom of Information Act (FOIA), as amended 5 U.S.C. 552.
I hereby request all records concerning commitments, modi f ic a t ions , and/or. exemptions at the Pilgrim Nuclear Power Station related to the fire protection requirements of 10 CFR 50, Appendix R. This request is intended to supplement FOIA request 87-649, f or which a final response was provided by the
. NRC on December 31, 1987.
Accordingly, it includes documents which have become available since that date.
I reserve the Attorney General's right to appeal the withholding or deletion of any material .
As authorized in the Nuclear Regulatory Commission's regulations at 10. C.F.R. $ 9.41, we believe that furnishing these documents without charge to the Massachusetts Department of the Attorney General would be a governmental courtesy appropriate to this request, particularly given the importance of-the documents sought and our limited budget.
As you know, the FOIA also authorizes you to reduce or waive fees when release of requested information would benefit the public interest. As Attorney General for the Commonwealth, we believe the information requested would clearly be in the public interest, and therefore the fees for searching and reproduction should be waived. The documents requested are for the Attorney General *.s review of the conduct of the Boston Edison Company during the outage of the Pilgrim Nuclear Power Plant. The Attorney General conducts such a review regarding n f. _ i e n 9e 1 b 5lu i .D V # 1 Q}
m a.
the'.~ reasonablenessof the Company's action: as part of.his-representation of Massachusetts consumets-Lefote the Massachusetts Department of Public Utilities. Provision of-the requested documents with waiver of fee will both' facilitate'-
this review-process and reduce the cost of providing this
. governmental service for Massachusetts citizens.
request Based on the above and on our limited budget, I therefore-9.41, I that you waive any fees. .As provided in 10.C.F.R. j reserve the Attorney General'a right to appeal any denial of. fee waiver or reduction.
If you have any questions, please call me at 617-727-2265. Pursuant to the FOIA, I will expect a reply within 10 working days.
Sincerely,
', @ # WW ~ k Douglas G. Carrey-Beaver Assistant Attorney General Utilities Division Public Protection Bureau (617) 727-2265 DC-B/cb 4
_______m___- - - - - - - - - - - - -
b L
~
a THE COMMONWEALTH OF MASSACHUSETTS
- k" '
I CEPAATMENT OF THE ATTCANEY GENERAL 8 so-N N ucCCAVACE Sta7E C't CE ButDiNo CNEAsMBLATCN A ACE Bo5'ON 206 4.98 JAMES u SHANNCN a '*ca g, cg gan May 23, 1988 ponnie H. Grimsley I.REEDOM 0F INf0RWT10N Director, Division of Rules and Records I".% QUEST Offace of Administration and Resources Management United States Nuclear Regulatory Commission 7735 Old Georgetown Road
-p c)/f Bethesda, MD 20814 #d[-26 -[
Dear Mr. Grimsley:
This is a request (FOIA), as amended 5 U.S.C. under the Freedom of Information Act 552.
I hereby request all records concerning the NRC's review of Boston Edison Company's proposed Safety Enhancement Program for the July Bird's Pilgrim 8, Nuclear 1987 Power Station as described in Mr. R. G.
request includes, but letter to Mr. Steven A. Varga. This is not limited to, all documents exchanged between the NRC and Boston Edison Company on this subject, meeting memoranda, transcripts, and/or presentation materials, and Bostonand records Edison of telephone conversations between NRC Company.
I withholding or deletion of any material. reserve the Attorney General's ri As authorized regulations in the Nuclear Regulatory Commission's at 10. C.F.R.
$ 9.41, we believe that furnishing these documents without charge to the Massachusetts Department of the Attorney General would be a governmental courtesy appropriate of the documents to this request, particularly given the importance sought and our limited budget.
As you know, the FOIA also authorises you to reduce or waive fees when the public interest. release of requested information would benefit we believe the information requested would clearly be in theAs public interest, reproduction should andbetherefore waived. the fees for searching and The documents requested are for the Attorney General's review of the conduct of the Boston Edison Company during the outage of the Pilgrim Nuclear Power t
- .- plant.
The. Attorney General conducts such a
.the reasonableness of the Company's actions asreview part'nfregarding representation of MassachusettsLconsumers before'the his Massachusetts Department of Public Utilities.
-requested documents with waiver of fee will both Provistoa of the.
facilitate this review process and reduce the cost of providing this governmental service.for Massachusetts citizens.
requestBased on the that you above waive anyand on fees. our' limited budget, I therefore 9.41, I reserve the Attorney General *a.rightAs provided in 10 C.F.R.
denial of fesai.er or reduction. to appeal'agy If you have any questions, please call me at 617-727-2265. Pursuant to the FOIA, within 10 working days. I will expect a' reply Sincerely, 1
y ys., 9 oy09 Douglas G. Carrey-Beaver Assistant Attorney General Utilities' Division Public. Protection Bureau (617) 727-2265 DC-B/cb
'b
.THE COMMONWEALTH OF MASSACHUSETTS 5 h '
DEPAATMENT OF THE ATTCANEY GENERAL
~
JesN w McCoAM ACK STATE ort CE BuhDiNG ONE ASMBUATCrd PL ACE BoS*0N OP061696 sAMES M SHANNoN
.r :a=a, ca saa.
May 23. 1988 Donnie H. Grimsley Director, Division of Rules and Records
. Office of Admin 2stration and awsources Managementggy , , . . .
United States Nuclear Regulatory Commission ACT REQUEST 7735 Old Georgetown Road Bethesda, MD 20814 hM M[*d f
Dear Mr. Grimsley:
This is a request under the Freedom of Information Act (FOIA), as amended 5 U.S.C. 552.
I hereby request all records concerning the Restart Plan (including all referenced appendices) submitted on July 30, 1987 by Boston Edison Company to the NRC for the restart of'the Pilgrim Nuclear Power Station.
This request includes, but is not limited to, all documents concerning the NRC's review of the July 30, 1987 Restart Plan and all of its subsequent revisions. Also included are all records exchanged between Region I and NRC headquarters personnel concerning the Restart Plan, records of telephone conversations between NRC and Boston Edison Company personnel concerning the matters addressed by the Restart Plan, and all records related to review teams assigned to review the Restart Plan and the physical plant (such as the Pilgrim Restart Panel and the Integreated Assessment Team).
I reserve the Attorney General's right to appeal the withholding or deletion of any material. f
{
As authorized in the Nuclear Regulatory Comission's tegtt+rt-iony WilF.
C'. P. RT t' M 41", we' be'lieve" tttat ftrrrei sirty these documents without charge to the Massachusetts Department f of the Attorney General would be a governmental courtesy j appropriate to this request, particularly given the importance of the documents sought and our limited budget.
As you know, the FOIA also authorizes you to reduce or waive fees when release of requested information would benefit the public interest.
As Attorney General for the Commonwealth, b
g igy3 W umy l
n j) , ' '_ q -
we believe public-interest.
reproduction shouldand'therefore be waiv'ed. the fees for. searching'andt The documents requested are for the Attorney General's review of the conduct of the Boston
' Edison Plant'. Company during-the outage of the Pilgrim Nuclear. Power
. :The, Attorney General conducts such a review regarding the reasonableness of the Company's. actions as part oflhis representation of Massachusetts consumers before the Massachusetts Department of Public Utilities.
requested documents with waiver of fee will both Provision of'the facilitate
-this review process and reduce the. cost.of providing ths,s.
' governmental-resvrew-for Masstenbsetts citizens. s request Based.on that you the waive above any and fees.on our limited bud'get, I therefore 9.41,<I As provided in 10 C.F.R.
reserve the' Attorney-General'a right to appeal any $
denial'offfee waiver or reduction.
If you have.any' questions, please call me at 617-727-2265. Pursuant to the FOIA, within 10 working days. I will~ expect a reply i
Sincerely,
'). & P %?%
Douglas G. Carrey-Beaver Assistant Attorney General Utilities Division Public Protection Bureau (617) 727-2265 DC-B/cb
,,. is OEPARTMENT OF THE ATTOANEY GENERAL N somn W McCoAVACE ST ATE OFF CE ButtoiNG m oNE ASNBURioN PL ACE BC$ ton 02106 1696 JAMES M SHANNCN ance=p ct=cea6 May 23, 1988 Donnie H. Grimsley EREEDOM Of INFORM;Tl0g Director, Division of Rules and Records ACT REQUEST Of MceStates United of Administrar to i dod' Resources Nuclear Regulatory CommissionManagement hM-N 6 y 7735 Old Georgetown Road Bethesda, MD 20814 b#d[~ 2 de '
Dear Mr. Grimsley:
(FOIA),This is a request as. amended under the Freedom of Information Act 5 U.S.C. 552.
I hereby request Confirmatory 27, 1986. Action Letter 86-10 issued by the NRC on Aug This request includes, but is not limited to, all documents August which 27,1986 served as input to the final version of the letter, all records exchanged between Region I and NRC headquarters personnel the August 27, 1986 letter, records concerning the matters raised in of telephone conversations ;
between raised matters NRC and in Boston Edison the August Company personnel concerning the 27, the August 27, 1986 letter. 1986 letter and all drafts of I
reserve the Attorney General's right to appeal the withholding or deletion of any material.
As authorized in the Nuclear Regulatory Commission's regulations at 10. C.F.R.
$ 9.41, we believe that furnishing these documents without charge to the Massachusetts Department of the Attorney General would be a governmental courtesy appropriate to this request, particularly given the importance of the der nmanta- sought, and.our.1.i.nted.budgeb .
As you know, the FOIA also authorizes you to reduce or waive the publicfeesintere'st.
when release of requested inforraation would benefit As attorney General for the Corrrnonwealth, we believe the information requested would clearly be in the public interest, reproduction andbe should therefore waived. the fees for searching and The documents requested are for the Attorney General's review of the conduct of the Boston 944Mrift+ )
1
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Edison Plant.
Company during tha outage of the Pilgrim Nuclear Power' The Attorney General conducts such a review regarding the. reasonableness of the Company's actions as part.of his representation of Massachusetts consumers before the Massachusetts Department of Public Utilities.- Provision of the requested documents with waiver of fee will-both facilitate this review Process and reduce the cost of providing this governmental service for Massachusetts citizens.
Based on the above and on our limited budget, I therefore request that you waive any fees. As provided in 10 C.F.R. 5
- 9. 41,- 1 rese rve the A tin gney., cenars1's right tc appeal any denial of fee waiver or reduction.
If you ha;e any questions, please call me at 617-727-2265. Pursuant to the FOIA, I will expect a reply within 10 working days.
Sincerely,
&D % ~0%
Douglas G. Carrey-Beaver Assistant Attorney General Utilities Division Public Protection Bureau (617) 727-2265 DC-B/cb
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/ PART l.- AGENCY RECORDS RE/ASED OR NOT LOCATED/See checaea come No agency recores swerect to t*e reawest have toen located No ace,tioast egency eecords s.biect to the reawest have been located peowesteo recoros are ava.tanse through anoteer pwei.c distnbuten progeam See Comments Sect on
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. m us - >.= a e are already availaces for owDhc espection and coeveg Agency records subsect to the reavest teas are .dentified on Appena,aiest -. O Nmc Pubhc Doc 6anent Room. 2120 L 5treet. N W . Washengton. OC. e a foeder are being made availacio for owDhc espect.on and cco,eg a
under th.s FolA number and reawester name The nonpropnetary vers on of the propossusi that you agreed to accept m a telephone conversaten worn a member . r of especten and copyng et the NRC PutW c Docuenent Room 2120 L Street. N W Washegton. OC. e a fosoor undee th,s F0tA numb Agency records subsect to the reawest that are identif*dca Aopendin$ev e the Comments Section. _ may be espected and copiec at the NRC Local Pubsec Document Room cea U
Enclosed is Weehenston. DC.eformation on how you mov obtem eccess to and the charges tot copymg +ecores placed in the NRC Pubhc %* Docum Av ;v records swbrect to the roovest are enclosed. F Recor3a sub,est to the regwest have been referred to another Federal agencyt.est for rev.ew and direct response to you You will be tulled by the NRC for fees totalm0 8 in v.sw of NRC's response to th.e reawest. no further acten .s temg taken on appees tener caree cs No.
PART 5. A-INFORMATION WITHHELD FROM PUBLic DtSCLOSURE Cortee eformaaon en the reovested recores .: t**g *ithn*4 ' rom puoi.c o sciosure pu svant to the ese-:
e sections 8. C. and D An Lons describec n and for tne easons stated a Pa - si copyng m the NAC Putw c Document Room. 2120 L Street. N W . Washegton. OC. u e a 'oscoev re easeo portions of the uncer th.s 5>A n meer and reawester name COMMENTS )("
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_ 'F.P - J f1, f f M sy 4 R cords subsect to ths recusst that are discribed on the snclosto Appendissest _ N are t.eing ethheld en ther entirety or .rt part unce.' -
Ea:mptions and for the 'essons set forth below oursvent to S U S C. 552rbi and to CFR 917(at of NAC Regulations a
1 The .,thhed eformat.oa 's proper', etassified pursuant to Isecutive Crcer ;(x(MPTION 11 i 2. The ..thhoc information e atos soiehr to the eternal personeel ruses and procedures of NRC. rf *EMPfiON 26 l
l 3 The witnn e.c eformation s spec'ocaily enemotea from pubi.c discloswee by statwee .ndicated iEX(MPTION 31 Sect oas 1a t 145 o' *e Atorme Energ, Act n.c n es,on.b.ts ime a scioswre of Re si,,ctea ce,, o, ro,me,,, Rest,.ci,o o,,, ,42 U $ C 21612165#
5ection 147 of the Atomic f reegv Act am ch prom. bits the d sciosur e of Unciass.fied Sa'egwarce leformat+on 142 U 5 C 2167) 4 The ..tmeca ##ormat.on s a trace secret or commerosi or financisa etormat.cc that s bemg withnew 'or the reason.sl edicated ' EXEMPTION 4 The eformation . coes. cered to be coni dent 1ai bwseess foroor4etarvi information t l Th* 'nfo' mat,on s considered ic De proprietary information purswant to 10 CFR 2 790fdstil i
The eformat.on was swbmitted and received en corif.dence purs ant to 10 CFR 2 790adH2s "f 5 The ithheio eformation coes.sts of eteragency or etrassency recores test a o not evaaeoie throwgm ciscover, ow
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rag litegsten IEA(MPTION Si Apos.caose *n voege the open and frans escha^ge of dess essent.or to the cohberative process b where records are withhee e their entirety. the f acts a o enestr.cabiv erect *ined ..th the precocis.onai .nformation Ther I portions because the eiease of vne f acts wowid permet an indirect nowerv eto the precoc s.onal process of te
e agenCv Attorney work prodwC1 pr'vdege ' doc wments Dreca'ec by an attornev .n conte =olaf.on of let gation s Attorney -chent pr....ege Conoceat.a8 commu n cat.ons tetaeea en attornev and Ns her cheet 6 6
The *>thheid information >s esempeed from pubi.c rd.sciosu e because its erselosure wove rescit e a cisariv r a"eted eves.on of corsonal anvecy ifXEMPTION 61
- 7. The wohheid information consists of records comp.ied for 'aw enfoecoment purocssa and 's being w.thhee for the reasonts) ed>cated IEX(MPTION 1 e e Disclosw forcement e ofcow forts dano reasonabiv im us cow dbe e
espected possibiv totaeteriere ..to an ento,coment proceeceg because o cove evesi the scope oirection and focus of en.
sinoa E x[MPTION 7 i An em to tan e act.on to sm.e.d potent;as arongdomg or a v.o.af.on of NRC rooverereents from invest.gators D.soesure *ow6d const'tute an unwar anted evas.on of personal onweev #EX(MPTION 7tCit The information Coes.sts of names of indsvedwais and other it forrPat.On the disciCsw e of *Nch cov6f 'essc,mabt, be esoected to revese acentit.ej of e
conf. dent.ai sour ces E mf MPTiON 7 'Do OTHER PART E. C-DENYING OFHCIALS Puesvant to 10 CFR 9 25tbi ano or 9 25 ict of the U $ Nuclear Regwistorv Comm ss.on regwistions it has been cetermeec that the miorestion *.thhee is esemp e
from production v or d,sciosw e and that its prod.,ction or o.sclosure .: contrarv to the pubs.c mterest The persoes resoons b+e for the cenisi are tacse otoc,a's icent f.ed below cenia'sas thatdenmayegbe otoc'ais acc.ea,edandtothe theDeector 0+s.on f seestave of Freedom D rector of Informat.on for Operations iEDon and8#weaicat oes Serv.cos OH.ce of Aomm suation and Resources Meagement for any DENYING OFFICIAL TITLE /OmCE RECORDS DENIED APPfLLATE OFFICIAL SECRETARY
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PAAT E. D- APPEAL R>GHTS The denic ev each 6anyme official contAed e Part n C may be appeseed to the Appeitate O*f. ciel .dentif.ed m that section Any such appes must be m watmg end m be made withm 30 deve of receipt of thes respoese Appeals must be addressed as appropriate to the Exeeverve Director for Operations or to the Secretary of the Comemssen, i U S. Nucieai Regwietory Commes.on. Washmgton. DC 20555. and should clearty state on the enve+ ope and in the netter that et is an "Appes troen aninen* FOfA Doc sen/ I unC fores esa Part 2)
'"**' U.S. NUCLEAA MOULATORY COMMissaces FOtA RESPONSE CONTINUATION
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ATTACHMENT C
.k THE COMMONWEALTH OF MASSACHUSETTS q g DEPARTMENT OF THE ATTORNEY GENERAL
, JOHN W. McCoRMACK STATE OFFICE SUILotNG
[ oNE ash 8URToN PLACE. DosToN 021o81698 JAMES M. 5HANNON ATTCANET CENERAL October 11, 1988
[REEDOM 0F INFMT ACT REQUEST Donnie H. Grimsley [C M -)faf/
Director, Division of Rules and Records Office of Administration and Resources Management gggg United States Nuclear Regulatory Commission 7735 Old Georgetown Road Bethesda, MD 20814
Dear Mr. Grimsley:
This is a request under the Freedom of Information Act (FOIA), as amended 5 U.S.C. 552.
I hereby request every document received by or generated by the Pilgrim Restart Assessment Panel insofar as those documents were related to Panel activities.
I reserve the Attorney General's right to appeal the withholding or deletion of any material.
As authorized in the Nuclear Regulatory Commission's regulations at 10. C.F.R. Section 9. 41 (c) , we believe that furnishing these documents without charge to the Massachusetts Department of the Attorney General would be a governmental courtesy appropriate to this request, particularly given the importance of the documents sought and our limited budget.
As you know, the FOIA also authorizes you to reduce or waive fees when release of requested information would benefit the public interest. As Attorney General for the Commonwealth, we believe that information requested would clearly be in the public interest, and therefore the fees for searching and reproduction should be waived. The documents requested are for the Attorney General's review of the conduct of the Boston Edison Company during the outage of the Pilgrim Nuclear Power Plant. The Attorney General conducts such a e r
l[
review regarding the . reasonableness of the Company's actions as part of.his representation of Massachusetts consumers-before the Massachusetts Department of ~ Public Utilities.
-Provision of the requested documents with. waiver of fee will both f acilitate- this review process and reduce the ,
I cost of providing this governmental service- for Massachusetts
. citizens.
Based on'the above and on our limited budget, I therefore request.that you waive any fees. .As provided in'10 C.F.R.-
Section 9.41, I reserve the Attorney General's right to appeal any denial of fee waiver or reduction.
If you have any questions, please call me at (617) 727-220o. Pursuant to the FOIA, I will expect a reply within 10 working days.
Sincerel' y, NQ U (wwy &
Douglas G. Carrey-Beaver-Assistant Attorney General Utilities Division Public Protection Bureau (617) 727-2200 ext.'2573 DC-B/md
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Agene v .eco..: ..D,ec t to tee .co e st ta a, ..e ..ent+e. on Accen. s 'e s e -
[ NRC Pubhc Doewment Room. 2'20 L St.eet N * . W.sh.ngton, DC. en na fol.e. w ...h ..e tems .r . ..anae.e to. puoi.c mopect on an. :oov es r th.s FOtA numbe. .n. .gow.ste. na.no The nonp op.i.ta.y . ors on of t*.e p.coesa.tsiete t vow .g.e.. to acc ept en . te ephone con.e..ation ..th a eemb.. of my st.ft is now b.mg m... av.aae e so. :.:
inspect.on .n. copymg .t th. NAC Pt,boe Docu.aent Aoom 2120 L St.eet. N W . W.shmston DC. .n a tos... un.e. this FDIA numee an. eo e.te. aam.
Agency .co .s subsect to the .eo.est te.t are ent,f.e.on Appee..s es. me, ce m.pect.. .n. c op.e. .: the NRC Local Putv.c Document Acom ,.e.<
m th. Comments Secten Enciosed .s efo.meten on how .ow mar oct.* act.ss to an. th. charg.s fo. copreg esco..: place. m the NAC Pwbhc Docw.nent Room. 2120 L S..eet W.shangton. DC NA y . g.~. ..c o... ._ t t. th. ..o . s , .. . ._ s.. ,
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l: PART N 0- APPUCASLE EMMPTIONS f't corgg subi Ct 10 the reQutst that are descrebed on the enclos:4 AppindiaWst hko.e b3,ng ,,thhtid in thSir entir$f y Essmotions and for th2 'essons $11 forth Deion pursuant to 5 U S C 5521bl and 10 CFM 9 t 7'48 of WC Regulations 1 The e thheid *formaten s properiv ciassified pursuant to Esecut.ve Onder ' EXEMPTION tt 2 The withbeed *eformatee *e'ates soseiv to the seternal personnel rWes and procedures of NRC ' EXEMPTION 21 3 The methrsid 'eformatice $ scocihcally esempted from pubhc d'sclosure D, statute endicated EREMPfiON 3 1
- j Sect oes tai tal o' e Atoraic Eaergy Act wh.ch pron.Dets the d'scioss e of Reser.cted Date o, so ,.e...
e Aestacted Data sa2 V 5 C 2t612165.
Section ta? of the Atomic Eaergy Act an.ch proh.b ts the decloswre of Unciassited Safeguards information .a2 V $ C 21671 a The
.threed #tormaten .s e trade secret or comtnercial or heancial eformation that <s being withhe*C 'or the reasonesi ed.cated ' EXEMPTION ai The cio*maten is cons 4ered to be conhdential bwsmess fotoprestarvi information The mformation 4 cons 4ered to be proprestery eformat on purswent to 10 CFR 2 790idit11
'I the information was submitted and received an conhdence pur swant to 10 CFR 2 790idH2) 4.
A 5 The *'thheid an'ormaten coes.sts of imoragency or er'traagency <ecoros tmot are not aweosese through r d4scovers IExEMPTiON d.e +g ht gat.on Si apohcabe Pa vrege
'Denberstmo Where records are Proceso withheld a0.scioswee of facts the*r enterety. the predecisenal p<e mostricabs eformation would tend to inhibit the open and frans eac*ange of +deas essen ltrortions becswse the reiasse of the facts nowad permit en .no. rect now.tv ero the predec Attornev nors prodwet priwaege iDocuments preca'ed by an attorney in contemplation of 4t+ gat.on
- Attoteev - chent privoege 'Conhdent 4. Commw e cations oetween en attornev and n1 her cuent 8 8 e The wetehead informaten is enempted frorn pubhc C+sc60sw e because its discionwes e nowideresw t in a cisar% w ar ested invas.on of persoriai priwe
.ExtMPTsON 6s 7
The withbeid eformation coesists of socords compiled for law enforcement purposes and s beeg **thhed for the reasontsiindicated IEXEMPTION I 0 sceosw e cowe d reasomapiv de espected to enterieM e
e sith an enlo'coment croceee - becs se it cowid +evesi two scope daect.on and focus of on-
'- forcement (R(MPTION 7of3AH forts and thws Cower ess@ty adow them to tame act on to Sh'eid DOtentier *'ongdoing or 4 ve.aten of NRC requireme D.sclosste *owd e coratitute se unwarranted evasion of personal praecy iExtMPTION 71Cil The enformat conteent.a on coes:sts sources of names EnEMPtiON 7 'DHof moev4wais and other information the d>sciosure of aniCh cow @ easoeable De espected to reveal .centities of OTMER PART N. C-DENYtNG OFF6CIALS a
r
- w swsnt to 10 CFR 9 254pi r and or 9 25 scs of the U $ Nwcmar Reguistory Comra.ssen regu ations it %s beee me mmed tui the informat.on *ithhee e
8,om prod.rCtson v or disclosu e and that its prodi.ect:0% or disciosw e 4 contrary to tFe public .nterest The persoes eswoesitwo for the densai are these e othc below as den.s's 1%st Cen mayingbeoffit.ais STrepiedandtothe theDoactor EneCwt've Dives on of Outefor forFreedom Operatioes of ifleDO forreation and Pwbhcat oas Services Office et a4 ministrationr and Resou ces Managereent iorany DENYING OFFtCIAL TITLE / OFFICE RECORDS DENIED APPELL. ATE OFFICIAL
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, . /A b PART I. D- APPEAL RIGHTS The deniet by each denveg otheist dentified e Part N C may t>e appealed to the Appenste Officielidentifed in tnt sect.on Any such appent must be m writing and mus be made within 30 days of receet of this respones. Appesas must be eddiessed as approonste to the taecutive Director for Operatens or to the Secretary of the Com u s. Nuclear Regulatory Commesen. Washegton DC 205tl. and shound charfy state on tN envokee end m the wetw that it e an " Appeal from en inet.ai FOIA Oeces.on -
esRC FORaf 46a (Port 2
'"**' U S. NUCLEAR REOULATORY COMMIS$aOF FOIA RESPONSE CONTINUATION
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- accordance vmh tr: i cynm of Informatiott r.i Ote st:ons . I rs, A. F fr *.s"/ 9 DO NOT use tNs form es a RECORD of approvers, concurrences, d spesa's.
clearances, and semitar actions FROM: (Name, Org. symMI, Agency t PCst) ; f%c,m tio,~ ting.
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Re: F0! A- 38-519 '-
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.0 APPENDIX 1 _ :C-RECORDS PARTIALLY WITHHELD
' NUMBER LAE' D ' ORIGINATOR; RECIPIENT DESCRIPTION'
~1; Undated Routing slip with Pil Route Slipli page) grim Restart-Issues attached- :
Withhold - Exemption.5 Release;PilgrimRestartissues(1.1
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~ RECORDS' TOTALLY WITHHELD
. NUMBER DATE ORIGINATOR RECIPIENT.
DESCRIPTION u
- 1. Undated: Pilgrim Update - Miscellaneous-Items - Handwritt'en Notes,
.(2!pages) - Withhold:- Exemption 5
p ATTACHMENT E
6 UNITED STATES '
l's NUCLE AR REGULATORY COMMISSION
.[' '! jr REGION I ~
476 ALLENDALE ROAD KING OF PRUS&tA, PENNSYLVANIA A 16408 i
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JUN 291988 Docket No. 50-293 Boston Edison Company ATTN: Mr. Ralph G. Bird Senior Vice President - Nuclear 800 Boylston Street Boston, Massachusetts 02199 Gentlemen:
50-293/88-19
Subject:
NRC Region I Inspection Report No.
Thi s refers to the routine safety inspection (50-293/88-19) conducted 968 Messrs. C. Warren, J. Lyash, T. Kim and others of this of fice on Ap h Massachusetts.
to May 31, 1988, at the Pilgrim Nuclear Power Station, Plymout ,
Areas examined during this inspection are described in the NRC Reg
! tion Report which is enclosed with this letter.
,_ i d to address outstanc'ing
/sctions taken near the close of this inspection per A ocontinued high level of maintenance program concerns appeared strong. implementat-management involvementactions is warranted to assure the development andR in this area.
ion of effective: correctivetenance program weaknesses will be revi Your cooperation with us in this matter is appreciated.
Sincerely, f'
i nuel J. C6 eputy Director Division of Reactor Projects
Enclosure:
50-293/88-19 NRC Region I Inspection Report No.
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(Update) Unresolved Item (86 .36-02), Fire Barrier Operability Evaluations to be performed by the Licensee. In inspection report 50-293/86-36, the inspector concluded that seven recent Licensee Event Reports (LER) regard-ing f. ire protection.were related to fire barriers being declared inoper-able. The primary reasons for the barriers being declared inoperable were the following:
- a. Penetration seal documentation either does not exist or is unclear,
- b. Barrier components appear degrade'd, or
- c. Uncertainty exists as to whether the degraded fire barrier is required.
In order to resolve this problem, .the licensee established a program to evaluate the' barriers and restore degraded barriers to operable status.
This program consisted of surveying the penetrations in all of the plant barriers (approximately 300). Sketches were made . showing the location of all penetrations (about 5200).. During the survey it was Thesedetermined that seals have about 3900 seals did not meet the acceptance criteria.
either been repaired, replaced, or reevaluated as to acceptability.
The inspector reviewed the licensee's procedures for inspection and con-The licensee also demonstrated the -capab41-trol of fire barrier seals.
ities of a computerized penetration seal tracking program called PENTRAC.
PENTRAC enables the licensee to rapidly . determine the identities, types and locations of all seals on a specified wall. By determining the seal type, the seal can also be linked to specific qualification tests verify-ing its fire resistance rating.
Based on a sampling review the inspector concluded that the licensee's procedures are adequate to document the acceptability of all existing fire barrier penetration seals in regard to Appendix A of Branch Technical Position 9.5-1 and Section III(M) of Appendix R to 10 CFR 50.
In addition, the inspectors also audited evaluations It was the performed inspectors'for minor conclus-penetrations in the rated fire barriers.
ion that these analysis were performed under the supervision of qualified fire protection engineers and were technically adequate.
technical standpoint, this item is resolved. However, it will From a is remain open pending further NRC review to determine if any enforcement appropriate in light of the previous fire barrier deficiencies.
(Update) Unresolved Item (87-22-01), Licensee to Clarify the 10 CFR 50 Appendix R Analysis. The licensee committed to develop a document that clearly describes the detailed basis for Appendix R compliance, so that continued compliance will be assured. The licensee has begun this development process. The inspectors reviewed several of the separate items that will comprise the documentation and concluded that the licensee is proceeding in a proper manner. Among the items reviewed were: