ML20205A206

Responds to to President Reagan Re NRC Insp Performance & Emergency Planning Criteria.Recent SALP Rept Best Info Source Re Util Performance.Performance Improvements & Corrections Final Goal

ML20205A206
Person / Time
Site:	Pilgrim
Issue date:	08/05/1986
From:	Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Ott M AFFILIATION NOT ASSIGNED
Shared Package
ML20205A210	List: ML20205A206 ML20205A232
References
NUDOCS 8608110322
Download: ML20205A206 (12)

Text

,

, SG-M3 AUG 5 1986 Ms. Mary C. Ott 196 Chestnut Street Post Office Box 1424 Duxbury, Massachusetts 02331

Dear Ms. Ott,

Your letter to President Reagan, received by the White House on July 8, 1986, expressing your concerns about the Pilgrim Nuclear Power Station in Plymouth, Massachusetts has been referred to me. Similarly, your letter to the Chairman of the NRC was also received by us and it addresses the same issues. As Administrator of the NRC Region I Office, I am very familiar with issues at Pilgrim and have therefore been asked to respond to your concerns.

In your letter you mentioned several issues regarding Pilgrim and you ques-tioned the performance of the NRC. Before discussing the specific issues you raised, I would like to comment briefly on NRC's activities with regard to Pilgrim. First, I want to emphasize that the NRC does have serious concerns regarding problems at Pilgrim. The best single source of information about our assessment of Pilgrim is our most recent Systematic Assessment of Licensee Performance (SALP) report (copy attached). I believe that if you review the report you will find that we have performed a critical and objective evaluation of Boston Edison's performance. The SALP is based on an extensive inspection effort by NRC. Because of historical problems at Pilgrim our inspection effort there has been approximately 50% greater than at other similar facilities. I believe this effort has successfully resulted in our identifying problems in plant programs and management before they result in conditions that would threaten the health and safety of the public.

Identifying problems is, of course, only the first steps in assuring safe plant operation. Corrections and improvements in performance are the final goal.

These corrections and improvements must be made by the utility. However, it is the NRC's responsibility to ensure that problems are corrected. In the case of Pilgrim this is being accomplished through continuation of an aggressive in-spection program, increased involvement of senior NRC officials, and frequent meetings with senior BECo management. In addition, Boston Edison Company has been required since April 12, 1986 to obtain my approval prior to restarting the Pilgrim plant. This hold on operation was originally established in re-sponse to specific, recurring technical problems; however, I will not authorize restart until I am confident that plant restart and operation can be conducted in a safe manner and that significant program and management improvements have been made and are continuing. Also, I have informed BECo that in addition to needing my approval to restart the plant, certain hold points will be establish-ed beyond which restart of the plant cannot proceed without my approval. Boston Edison Company recently announced that the Pilgrim plant will remain shutdown into next year in order to implement safety related plant modifications. I believe this is a positive step that will not only result in hardware improve-ments but will also allow BECo to focus on correcting existing problems. During this period the NRC will continue to closely monitor BECo's progress in re-solving these problems and we will continue to keep the public informed of our observations.

OtFICIAL RECORD COPY 318STROSNIDER7/31/86 - 0001.0.0 86081103E2 860tMS DR A".,i>CK 05000, 3 g

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Ms. Mary C. Ott 2 With regard to the specific issues you discussed in your letter, we are aware of these issues and, in fact, many of them were identified by the NRC. Speci-fically, the NRC SALP report (enclosed) discusses the clogging of the standby liquid control system injection line with debris, problems with the Pilgrim emergency plan, and problems in the fire protection system. With regard to the standby liquid control system, it is possible that the debris got into the system as a result of " horse play" although it has not been proven. But, re-gardless of how the debris got into the system this is an unacceptable situa-tion. NRC has told BEco that management attention must be devoted to ensuring that this type of event does not recur and we are closely monitoring BECo activities in this area. Incidentally, the debris was discovered through a required surveillance test and the plant was shutdown in January 1985 (not April 1986) to remove the debris.

With regard to the Pilgrim emergency plan, the NRC has identified several areas requiring improvement, as noted in the enclosed report. In your letter you indicated that the emergency planning booklets are " fraught with misinformation".

Feedback in this area from individuals like yourself is very important and I would greatly appreciate your providing me with the specifics of the misinfor-mation you have identified, so my staff can followup on your concerns.

It is true that some automatic fire protection systems at Pilgrim have been inoperable for extended periods of time. This resulted in the need for compen-satory measures such as posted fire watches. Although this is acceptable by Federal Regulations, it is preferable to have the automatic fire protection systems operable. Since the issuance of the enclosed SALP report, BECo has restored many of the automatic fire protection systems to operable status and the number of compensatory fire watches at the plant has been reduced by ap-proximately 70%. Also, you appear to have some incorrect information in that the NRC has not issued 250 violations in this area. I believe the number 250 refers to the backlog of maintenance requests related to fire protection (see enclosed SALP). This backlog is the reason that many of the systems have been inoperable and fire watches required.

Other issues you raised in your letter are the accident at Chernobyl and its implications with regard to the size of the emergency planning zone, purported abnormally high incidents of cancer in the area near Pilgrim, and the adequacy of the security force during a recent guard strike at the plant. With regara to these issues, the NRC is currently evaluating the Chernobyl accident and the differences in design between Chernobyl and commercial nuclear power plants in the United States. Based on this type of evaluation, changes in emergency plan-ning criteria will be recommended, if appropriate. Regarding the various reports of high cancer rates to which you referred, no scientific evidence has been presented that demonstrates a correlation with operation of the Pilgrim plant.

Furthermore, independent NRC radiation monitoring in the area surrounding the plant has not indicated any significant radiation releases. I understand that 0FFICIAL RECORD COPY 3185TROSNIDER7/31/86 - 0003.0.0 08/01/86

e- ,

Ms. Mary C. Ott 3 the State of Massachusetts public health officials are pursuing a more in-depth analysis of the situation. If you chose you may call Dr. Bailus Walker Jr.,

Commissioner of Public Health, for more information.

Your concern about the security guard force appears to be unfounded in that the advertisement you saw was for new recruits to be put into the security guard training program. Security coverage during strike situations is provided by security supervisors and qualified nuclear guards often from other security contractor facilities.

Finally, I would like to provide you with some data on the frequency of unusual event declaration which you discussed in the article you wrote to the Duxbury Clipper newspaper. During the two year period 1984 through 1985 the national average for unusual events declared was approximately two per plant. It is important to note that some plants have slightly different thresholds for de-claring unusual events than others. Although Pilgrim exceeds the average slightly, this really isn't significant, particularly when review of the speci-fic events involved confirms that none of them posed a threat to the health and safety of the public.

In regard to the claims in your article that Mr. Starostecki was not properly prepared or sufficiently informative, I understand tnat forums such as the public meetings held in Plymouth and Duxbury cannot provide sufficient time or information to completely address each question that may arise. We have attended meetings with over 1,000 people from the vicinity of the Pilgrim Station and we are aware and cognizant of your apprehension and fear of the situation. If you could, please send us a copy of your tapes of the meeting in question and identify your specific areas of concern. We will try, to the best of our ability, to address your concerns. For example, it is difficult in a very short answer to explain the differences among the four emergency classifications for events. It appears that you may not have understood the examples cited by Mr. Starostecki at the Duxbury meeting. Consequently, to help you in this regard we are also forwarding a copy of NUREG-0654 FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants. This document includes a description of the various action levels in Appendix 1 beginning on Page 1-3.

In conclusion, some of the concerns raised in your letter are valid issues ebeut which NRC and others are aware and are taking action. On July 16, 1986 Congressman Markey of Massachusetts held a congressional hearing that focused primarily on Pilgrim. At the hearing Representative Markey said that "the NRC has successfully focused the attention of its staff, Boston Edison management 0FFICIAL RECORD COPY 318STROSNIDER7/31/86 - 0004.1.0 07/31/86 l

l

Ms. Mary C. Ott 4 and the general public on serious management problems at Pfigrim". I believe that our efforts to date have resulted in identifying and getting ahead of pro-blems at Pilgrim and I assure you that the NRC will continue to aggressively pursue its responsibilities concerning the Pilgrim plant and will not hesitate to take those actions required to ensure the public health and safety.

Sincerely, OPiEYnal Egge(tiy ThoraS E. Murley Thomas E. Murley Regional Administrator Attachments: As Stated 0FFICIAL RECORD COPY 3185TROSNIDER7/31/86 - 0005.0.0 07/31/86

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' Ms. Mary C. Ott 5 Distribution:

H. Denton J. Taylor G. Cunningham T. Murley J. Allan R. Starostecki W. Kane H. Kister J. Strosnider M. McBride EDO Control No. 001959 SECY No.86-726 Dock'et No. 50-293 Public Document Room (PDR)

Local Public Document Room (LPDR)

Editor, Duxbury Clipper P. Leech, NRR K; Abraham, PA0

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% ,o'g KING OF PRUSSIA. PENNSYLVANIA 19406 AUG 5 1986 Ms. Mary C. Ott 196 Chestnut Street Post Office Box 1424 Duxbury, Massachusetts 02331

Dear Ms. Ott,

Your letter to President Reagan, received by the White House on July 8, 1986, expressing your concerns about the Pilgrim Nuclear Power Station in Plymouth, Massachusetts has been referred to me.- 1 milarly, your letter to the Chairman of the NRC was also received by us and it addresses the same issues. As Administrator of the NRC Region I Office, I am very familiar with issues at Pilgrim and have therefore been asked to respond to your concerns.

In your letter you mentioned several issues regarding Pilgrim and you ques-tioned the performance of the NRC. Before discussing the specific issues you raised, I would like to comment briefly on NRC's activities with regard to Pilgrim. First, I want to emphasize that the NRC does have serious concerns regarding problems at Pilgrim. The best single source of information about our assessment of Pilgrim is our most recent Systematic Assessment of Licensee Performance (SALP) report (copy attached). I believe that if you review the report you will find that we have performed a critical and objective evaluation of Boston Edison's performance. The SALP is based on an extensive inspection effort by NRC. Because of historical problems at Pilgrim our inspection effort there has been approximately 50% greater than at other similar facilities. I believe this effort has successfully resulted in our identifying problems in plant programs and management before they result in conditions that would threaten the health and safety of the public.

Identifying problems is, of course, only the first steps in assuring safe plant operation. Corrections and improvements in performance are the final goal.

These corrections and improvements must be made by the utility. However, it is the NRC's responsibility to ensure that problems are corrected. In the case of Pilgrim this is being accomplished through continuation of an aggressive in-spection program, increased involvement of senior NRC officials, and frequent meetings with senior BECo management. In addition, Boston Edison Company has been required since April 12, 1986 to obtain my approval prior to restarting the Pilgrim plant. This hold on operation was originally established in re-sponse to specific, recurring technical problems; however, I will not authorize restart until I am confident that plant restart and operation can be conducted in a safe manner and that significant program and management improvements have been made and are continuing. Also, I have informed BECo that in addition to needing my approval to restart the plant, certain hold points will be establish-

, ed beyond which restart of the plant cannot proceed without my approval. Boston Edison Company recently announced that the Pilgrim plant will remain shutdown into next year in order to implement safety related plant modifications. I believe this is a positive step that will not only result in hardware improve-ments but will also allow BEco to focus on correcting existing problems. During this period the NRC will continue to closely monitor BECo's progress in re-solving these problems and we will continue to keep the public informed of our l observations.

0 . .

Ms. Mary C. Ott 2 With regard to the specific issues you discussed in your letter, we are aware of these issues and, in fact, many of them were identified by the NRC. Speci-fically, the NRC SALP report (enclosed) discusses the clogging of the standby liquid control system injection line with debris, problems with the Pilgrim emergency plan, and problems in the fire protection system. With' regard to the standby liquid control system, it is possible that the debris got into the system as a result of " horse play" although it has not been proven. But, re-gardless of how the debris got into the system this is an unacceptable situa-tion. NRC has told BECo that management attention must be devoted to ensuring that this type of event does not recur and we are closely monitoring BECo activities in this area. Incidentally, the debris was discovered through a required surveillance test and the plant was shutdown in January 1985 (not April 1986) to remove the debris.

With regard to the Pilgrim emergency plan, the NRC has identified several areas requiring improvement, as noted in the enclosed report. In your letter you indicated that the emergency planning booklets are " fraught with misinformation".

Feedback in this area from individuals like yourself is very important and I would greatly appreciate your providing me with the specifics of the misinfor-mation you have identified, so my staff can followup on your concerns.

It is true that some automatic fire protection systems at Pilgrim have been inoperable for extended periods of time. This resulted in the need for compen-satory measures such as posted fire watches. Although this is acceptable by Federal Regulations, it is preferable to have the automatic fire protection systems operable. Since the issuance of the enclosed SALP report, BECo has restored many of the automatic fire protection systems to operable status and the number of compensatory fire watches at the plant has been reduced by ap-proximately 70%. Also, you appear to have some incorrect information in that the NRC has not issued 250 violations in this area. I believe the number 250 refers to the backlog of maintenance requests related to fire protection (see enclosed SALP). This backlog is the reason that many of the systems have been inoperable and fire watches required.

Other issues you raised in your letter are the accident at Chernobyl and its implications with regard to the size of the emergency planning zone, purported abnormally high incidents of cancer in the area near Pilgrim, and the adequacy of the security force during a recent guard strike at the plant. With regard to these issues, the NRC is currently evaluating the Chernobyl accident and the differences in design between Chernobyl and commercial nuclear power plants in the United States. Based on this type of evaluaticn, changes in energen:y plan-ning criteria will be recommended, if appropriate. Regarding the various reports of high cancer rates to which you referred, no scientific evidence has been presented that demonstrates a correlation with operation of the Pilgrim plant.

Furthermore, independent ilRC radiation monitoring in the area surrounding the plant has not indicated any significant radiation releases. I understand that

Ms. Mary C. Ott 3 the State of Massachusetts public health officials are pursuing a more in-depth analysis of the situation. If you chose you may call Dr. Bailus Walker Jr.,

Commissioner of Public Health, for more information.

Your concern about the security guard force appears to be unfounded in that the advertisement you saw was for new recruits to be put into the security guard training program. Security coverage during strike situations is provided by security supervisors and qualified nuclear guards often from other security contractor facilities.

Finally, I would like to provide you with some data on the frequency of unusual event declaration which you discussed in the article you wrote to the Duxbury Clipper newspaper. During the two year period 1984 through 1985 the national average for unusual events declared was approximately two per plant. It is important to note that some plants have slightly different thresholds for de-clarine unusual events than others. Although Pilgrim exceeds the average slightly, this really isn't significant, particularly when review of the speci-fic events involved confirms that none of them posed a threat to the health and safety of the public.

In regard to the vlaims in your article that Mr. Starostecki was not properly-prepared or sufficiently informative, I understand that forums such as the public meetings held in Plymouth and Duxbury cannot provide sufficient time or information to completely address each question that may arise. We have attended meetings witn over 1,000 people from the vicinity of the Pilgrim Station and we are aware and cognizant of your apprehension and fear of the situation. If you could, please send us a copy of your tapes of the meeting in question and identify your specific areas of concern. We will try, to the best of our ability, to address your concerns. For example, it is difficult in a very short answer to explain the differences among the four emergency classifications for events. It appears that you may not have understood the examples cited by Mr. Starostecki at the Duxbury meeting. Consequently, to help you in this regard we are also forwarding a copy of NUREG-0654 FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants. This document includes a description of the various action levels in Appendix 1 beginning on Page 1-3.

In cor,clusion, some of the concerns raised in your letter are valid issues about which NRC and others are aware and are taking action. On July 16, 1986 tongressman Ma Fey of Massachusetts held a congressional hearing that focused primarily on Pilgrim. At the hearing Representative Markey said that "the NRC has successfully focused the attention of its staff, Boston Edison management

r. 6 . .

Ms. Mary C. Ott 4 and the general public on serious management problems at Pilgrim". I believe that our efforts to date have resulted in identifying and getting ahead of pro-blems'at Pilgrim and I assure you that the NRC will continue to aggressively pursue its responsibilities concerning the Pilgrim plant and will not hesitate to take those actions required to ensure the public health and safety.

Sincerely, v ,:,. ^^-

Thomas E. Murley Regional Administrator Attachments: As Stated bcc: The White House

Ms. Mary C. Ott 5 Distribution:

H. Denton J. Taylor G. Cunningham T. Murley J. Allan R. Starostecki W. Kane H. Kister J. Strosnider M. McBride EDO Control No. 001959 SECY No.86-726 Docket No. 50-293 Public Document Room (PDR)

Local Public Document Room (LPDR)

Editor Duxbury Clipper P. Leech, NRR K. Abrahr.m, PA0 l

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%*****# g F1 g jai EDO PRINCIPAL CORRESPONDENCE CONTROL FROM: DUE: 08/01/86 EDO CONTROL: 001959 DOC DT: UNDATED MARY C. OTT FINAL REPLY:

(WHITE HOUSE REFERRAL)

TO:

PRESIDENT REAGAN FOR SIGNATURE OF: ** GREEN ** SECY NO: 86-726 MURLEY DESC: ROUTING:

CONCERNS RE PILGRIM PLANT DENTON TAYLOR DATE: 07/17/06 GCUNNINGHAM ASSIGNED TO: RI CONTACT: MURLEY

, - - ~ ~ _ _ _ _

SPECIAL INSTRUCTIGNS OR REMARKS:

RETURN CORRESPONDENCE & WORKSHEET W/ COPY OF REPLY TO:

AGENCY LIAISON ROOM 91 THE WHITE HOUSE WASHINGTON, DC 20500 l

1..

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i- .

OFFICE OF THE SECRETARY CORRESPONDENCE CONTROL TICKET PAPER NUMBER: CRC-86-0726 LOGGING DATE: Jul 16 86 ACTION OFFICE: EDO AUTHOR: M.C. Ott AFFILIATION:

LETTER DATE: Jul 16 86 FILE CODE: ID&R-5 Pilgrim

SUBJECT:

Concerned about the Pilgrim I plant ACTION: Direct Reply DISTRIBUTION:

SPECIAL HANDLING: None NOTES:

DATE DUE: Jul 31 86 SIGNATURE: . DATE SIGNED:

AFFILIATION:

Rec'd Oif. EDO

, Date P I '7 -8 to Time - M D~38 V

P 1:DO ---

001959 I

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