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: 23. "Probabilistic Risk Assessment: The Impact of Uncertainties on Radi-ological Emergency Planning and Preparedness Considerations," Union of Concerned Scientists, Washington, D.C., June 28, 1983. | : 23. "Probabilistic Risk Assessment: The Impact of Uncertainties on Radi-ological Emergency Planning and Preparedness Considerations," Union of Concerned Scientists, Washington, D.C., June 28, 1983. | ||
i i | i i | ||
: 24. " Response to GA0 Questions on NRC's Use of PRA," Union of Concerned Sci-entists, Washington, D.C., October 6,1983, attachment to letter dated October 6, 1983, from Steven C. Sholly to John E. Bagnulo (GAO, Washing-ton,D.C.). , | : 24. " Response to GA0 Questions on NRC's Use of PRA," Union of Concerned Sci-entists, Washington, D.C., October 6,1983, attachment to {{letter dated|date=October 6, 1983|text=letter dated October 6, 1983}}, from Steven C. Sholly to John E. Bagnulo (GAO, Washing-ton,D.C.). , | ||
: 25. The Impact of " External Events" on Radiological Emergency Response Plan-ning Considerations, Union of Concerned Scientists, Washington, D.C., De- , | : 25. The Impact of " External Events" on Radiological Emergency Response Plan-ning Considerations, Union of Concerned Scientists, Washington, D.C., De- , | ||
cember 22, 1983, attachment to letter dated December 22, 1983, from ' | cember 22, 1983, attachment to {{letter dated|date=December 22, 1983|text=letter dated December 22, 1983}}, from ' | ||
Steven C. Sholly to NRC Commissioner James K. Asselstine. | Steven C. Sholly to NRC Commissioner James K. Asselstine. | ||
: 26. Sizewell 'B' Public Inquiry, Proof of Evidence on: Safety and Waste Man-agement Implications of the Sizewell PWR, Gordon Thompson, witii supporting evidence by Steven Sholly, on behalf of the Town and Country Planning Association, February 1984, including Annex G, "A review of Probabilistic Risk Analysis and its Application to the Sizewell PWR," | : 26. Sizewell 'B' Public Inquiry, Proof of Evidence on: Safety and Waste Man-agement Implications of the Sizewell PWR, Gordon Thompson, witii supporting evidence by Steven Sholly, on behalf of the Town and Country Planning Association, February 1984, including Annex G, "A review of Probabilistic Risk Analysis and its Application to the Sizewell PWR," | ||
Latest revision as of 11:55, 20 March 2021
| ML20235W450 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 10/15/1987 |
| From: | Dukakis M, Shannon J MASSACHUSETTS, COMMONWEALTH OF |
| To: | NRC COMMISSION (OCM) |
| Shared Package | |
| ML20235W444 | List: |
| References | |
| NUDOCS 8710160236 | |
| Download: ML20235W450 (95) | |
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i j l UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION PETITION OF MICHAEL S. DUKAKIS, GOVERNOR AND JAMES M. SHANNON, ATTORNEY GENERAL FOR THE INSTITUTION OF A PROCEEDING PURSUANT TO 10 C.F.R S2.202 TO MODIFY, SUSPEND, OR REVOKE THE OPERATING LICEtiSE HELD BY THE BOSTON EDISON COMPANY FOR THE PILGRIM NUCLEAR STATION Dated: October 15, 1987 l slao2%BS!R8?!8));a G
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l i e l J UNITED STATES OF-AMERICA BEFORE:THE NUCLEAR REGULATORY COMMISSION PETITION.0F MICHAEL S. DUKAKIS, GOVERNOR-AND JAMES M. SHANNON, ATTORNEY GENERAL.FOR THE INSTITUTION OF A PROCEEDING PURSUANT TO-10>C.F.R.S2.202 TO MODIFY, SUSPEND, OR' REVOKE THE-OPERATING LICENSE-HELD BY ! THE BOSTON EDISON COMPANY FOR THE PILGRIM NUCLEAR STATION i Dated: . October 15, 1987 l-
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TABLE OF CONfENT3 I. INTRODUCTION . . . . . . . . . . . . . . . . . . . . . 1 I II. EVIDENCE OF SERIOUS MANAGERIAL DEFICIENCIES . . . . . 3 A. OVERVIEW . . . . . . . . . . . . . . . . . . . . . 3
- 8. 3ECo'S PAST PERFORMANCE . . . . . . . . . . . . . . 4 BBCo's SALP Evaluations . . . . . . . . . . . . . 5 BECo's Regulatory Violations . . . . . . . . . . . 7-C. RECENT INDICIA OF BECo'S PERFORMANCE LEVEL . . . . 9 i
BeCo's 1987 SALP Report . . . . . . . . . . . . 10 Recent Reports of Violations . . . . . . . . . . 12 III. EVIDENCE THAT INDICATES THAT A PLANT SPECIFIC PRA FOLLONED BY IMPLEMENTATION OF ANY INDICATED SAFEfY MODIFICATIONS SHOULD BE REQUIRED PRIOR TO PILGRIM'S RESTART . . 12 IV. EVIDENCE OF INADEQUATE EMERGENCY PREPAREDNESS .. . 15 V. CONCLUSION . . . . . . . . . .. . . . . . . . . . . . 21 I l i 3 J l l l 3
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UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION !
- PETITION OF MICHAEL S. DUKAKIS,-GOVERNOR AND I JAMES M. SHANNON, ATTORNEY GENERAL-FOR'THE !
INSTITUTION OF A PROCEEDING PURSUANT TO l 10 C.F.R S2.202 TO MODIFY, SUSPEND, OR ) REVOKE THE OPERATING LICENSE HELD BY- { THE BOSTON EDISON COMPANY FOR THE PILGRIM NUCLEAR STATION l I. INTRODUCTION Governor Michael S. Dukakis and Attorney General James M. Shannon, pursuant to 10 C.F.R. S2.206, hereby request that the Director of the Office of Nuclear Reactor Regulation institute a proceeding pursuant to 10 C.F.R.-S2.202 to modify, l t suspend, or revoke the. operating license held by Boston Edison Company ("BECo." or "the Company") for the Pilgrim Nuclear Power Station (" Pilgrim") in Plymouth, Massachusetts. This petition is filed on behalf of the Commonwealth of Massachusetts'and its citizens. The Governor and the Attorney J General base this request on evidence of continuing serious I i managerial deficiencies at the plant, on evidence that a plant specific probabilistic risk assessment ("PRA") as well as the implementation of any safety modifications indicated thereby should be required prior to Pilgrim's restart, and on evidence that the state of emergency preparedness does not provide reasonable assurance that adequate protective measures can and i i b
l i will be taken in the event of a radiological emergency during ) J operations at the Pilgrim plant. The Governor and the Attorney l General submit that this evidence, as cet forth below, demonstrates the necessity of Nuclear Regulatory Commission ("NRC") action pursuant to 10 C.P.R. S2.202. Further, the Governor and the Attorney General believe that the public interest requires that the NRC exercise its ! authority under 10 C.F.R. S2.202(f)1/ so that BECo. is ; I prevented from proceeding any further with the restart of Pilgrim2/ until a formal adjudicatory hearing has been held and findings of fact are made concerning the safety questions l surrounding the continued operation of the Pilgrim plant. In particular, the Governor and the Attorney General request that the NRC issue an order, effective immediately, modifying BECo's operating license to preclude BECo. from taking any steps in I 1/ 10 C.F.R. 2.02(f) provides: When the Executive Director for Operations, i during an emergency as determined by the EDO, or the Director of Nuclear Reactor Regulation, Director of Nuclear Material Safety and Safeguards, Office of Inspections and - Enforcement, as appropriate, finds that the public health, safety, or interest so requires L or that the violation is willful, the order to i show cause may provide, for stated reasons, that l the proposed action be temporarily effective l pending further review. 2/ At each step of BBCo's so-called " power ascension" l program there is an increase in the probability of an l accident at Pilgrim as well as in the potential l
- consequences of such an accident. See Affidavit of l l Steven C. Sholly (attached hereto as Attachment 1). ,
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n I its power ascension program until the hearing is held and the findings are made. II. EVIDENCE OF SERIOUS MANAGERIAL DEFICIENCIES ; Recent events at Pilgrim indicate that BEco.'has not corrected ,the long-standing managerial shortcomings that have plagued the plant. In the areas of security, radiological controls, personnel management, and corporate culture, the management of Pilgrim continues to be seriously flawed. As a result, Pilgrim poses an unreasonable risk to public health and safety. Its continued operation under the present circumstances is inimical co public health and safety. A. OVERVIEW Pilgrim commenced commercial operation in June, 1972, when BECo. received an operating license for the plant. During the intervening fifteen year period of operation by BECo., Pilgrim has had a capacity factor of ,approximately 50 percent,1! which compares quite unfavorably with the average for all New England nuclear plants of approximately 67 percent.A! 3/ The " capacity factor" for a plant is a measure of performance in terms of the power it has actually delivered over a period of time relative to the power it was capable of delivering over that same period of time. It is calculated by dividing the actual number of kilowatt hours produced by the ! plant in the period of measurement by the product of the s plant's rated kilowatt capacity and the number of hours in the period. 4/ Electric Council of New England, New England Nuclear News, TJune, 1987) (Attached hereto as Attachment 2). .
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1 l K l B. BECd's PAST PERFORMANCE 1 The plant has been out of service since April, 1986, when the'NRC, in Confirmatory Action Letter 86-10, ordered a l shutdown after recurring operational problems at the plant.E! Pilgrim has been beset with managerial problems from the l outset. BECo. has consistently received low ratings in the
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NRC's Systematic Assessment of Licensee Performance ("SALP") ] reports. Pilgrim has been identified by the.NRC as one of the worst run and least safe plants in the country !5and BBCo. was ordered to initiate performance / management improvement ) I programs in 1982 and 1984.2/ BEco. has been the subject of a i long line of enforcement actions as a result of regulatory violations. While the NRC's efforts to spur BECo. to a higher t level of performance have, on occasion, met with some initial i success, a review of BEco's performance record, however, shows that all such successes have been short lived. Indeed, BEco, f l 5/ Confirmatory Action Letter 86-10 was clarified and expanded in an subsequent letter, dated August 27, 1987, from the NRC Region 1, Regional Administrator to BECo's_ Chief Operating Officer. (attached hereto as Attachment 3). In this letter, BECo. was informed that: In light of the number and scope of the l outstanding issues, I (the Regional l Administrator) am not prepared to approve ! restart of the Pilgrim facility until you ( (BECo.) provide a written report that documents l BECo's formal assessment of the readiness for restart operation. 6/ Boston Globe, May 28, 1986. 7/ Order Modifying License Effective Immediately, 47 Fed. Reg. 4171 (January 28,.1,987). l I 1 1
-appears to have an organic inability to manage Pilgrim in an
{ effective and safe manner.8/
** BECo's SALP Evaluations **
1 BECo. has consistently received low ratings in SALP reports.S! 8/ Although it is the failings of BEco's management of the Pilgrim plant which are the subject of this petition, it is ! significant that findings have been made in other settings that confirm BEco's managerial deficiencies and indicate that they extend to the other aspects of its business. ,See e.g., Boston Edison Company, Massachusetts Department of Public Utilities Docket No. 87-1A-A (1987) (imprudence in operation of oil fired generating unit). Of particular relevance to the notion that BEco, responds to the identification of deficiencies with i half-hearted (although sometimes quite showy), short-term solutions that treat the symptoms, not the disease, is the series of decisions by the Massachusetts Department of Public Utilities that address BBCo's need to consider and develop new sources of power in the aftermath of the 1981 cancellation of the construction of the Pilgrim II nuclear unit. Boston Edison Company, MDPU 906 (1982) (ordering BEco. to develop a new plan to meet its future power needs); Boston Edison Company, MDPU No. 86-270 (found reason to believe BEco lacked commitment and/or skill to fulfill public service obligation). 1 9/ The SALP process is.the mechanism by which the NRC on a f periodic basis systematically assesses the overall performance of a licensee. For each assessment period (generally 12 to 18 months) a Board of NRC officials evaluates, in accordance with preestablished attributes and rating guidance, the licensee's ' performance for each of the various, preestablished functional . areas and rates the licensee's performance in each area. The ' Board also compares the licensee's performance for the current ! period with that of the previous assessment period and i identifies, for further followup and inspection, any areas where the licensee's corrective action to improve performance 1 has not been fully effective. 1 Arizona Public Service Company, (Palo Verde Nuclear Generating Station, Unit 2), DD-86-8, 24 NRC 151, 156 (1986). i
In 1980, BECo. received ratings indicating'significant weakness in three of the nine functional areas evaluated. The most recent SALP Report, seven years later, indicates that. conditions have not improved but rather have worsened. BECo. received ratings indicating significant weaknesses in five of the twelve functional areas evaluated. It has only once received a SALP Report without a rating indicating a significant weakness. On all other occasions, it has received' reports indicating significant weaknesses in at least two functional areas. (See Appendix I: BECo. SALP History Tabulation) Of particular significance, every time Quality Assurance has been assessed as a separate functional area during a SALP review, BEco. has received the lowest possible rating. These findings are indicative of the ineffectiveness of BBCo's management. They are a measure of its inability and/or its lack of commitment to run the plant in a effective and safe manner. 1 Although BEco. has at one time or another received the lowest possible rating in all but three of the twelve functional areas covered by the NRC's SALP process, these individual poor SALP ratings are not the most troubling aspect i of BBCo's SALP record. Instead, the most troubling and telling
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facet of BECo's SALP record is the Company's distinct inability to maintain any period-to-period performance improvements. BEco. has at one time or another improved its SALP performance l 1 1 1 1 in eight functional areas. However, it has not been able to sustain the increased level of performance in seven of those l eight areas. In all but one instance, BEco's improved performance proved to be short-lived and its performance f subsequently fell back to lower levels. This is not surprising as an ever recurring theme in NRC evaluations of BECo's performance is that NRC oversight and prompting is necessary at every stage of Pilgrim's operation.1E! The increased NRC attention (i.e., oversight and prompting) that a "3" rating calls for has, on occasion, produced better performance by BECo. However, when that level of attention returns to that norm, BECo's performance falls below the norm. BECo's SALP track record.is proof of the proposition that BECo. by itself 1 has not effectively operated Pilgrim and that the short-term solutions it has adopted in response to criticism have invariably permitted the reoccurrence of the original problems.
** BECo's Reaulatory Violations **
BGCo., an enforcement action record that is a mirror of its SALP. Report record. It has had at least one Severity Level III violation during each of the past six years.11/ (See l 10/. E.g., 1987 SALP Review at 8; 1986 SALP Review at 7. ) 11/ As set forth in 10 C.F.R. Part 2, Appendix C; General Statementof Policy and procedure for NRC Enforcement Actions, regulatory violations are categorized into five descending levels of severity. Level III corresponds with " violations ! that are cause for significant concern." l 1 1
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i Appendix II; BECo._ VIOL ATIONS TABULATIONS - SEVERITY LE'JEC'III VIOLATIONS _) In the area of Security and Safeguards, BECo. had a Severity Level III violation in all but one of the years between 1981 and 1986. In 1982, a civil penalty in the amount of $550,000 -- at the time the largest penalty to have ever been assessed by the NRC -- was levied against BECo. for serious plant operations violations and for uubmitting false information to the NRC.1 ! While the number of such Severity Level III violations discovered at Pilgrim has not exceeded two in any single year since 1981, the number of Severity Level IV violations per year has more than doubled in the past few years. DECO's enforcement action record also mirrors its SALP Report record in demonstrating BECo's chronic recidivism. It has been cited five times for Radiological Controls violations involving waste shipment packaging requirements.15! It has been cited five times for Security and safeguards violations involving the control of sensitive material such as keys to vital areas, security plans, and firearms.1SI 12/ U.S. General Accounting Office, Report to the Honorable Alfonse M. D'Amato, U.S. Senate: Nuclear Regulation !?.tforts to Ensure Nuclear Power Plant Safety Can Be Strengthened (GAO-RCED-87-141 August, 1987), pp. 36-37, 13/ See NRC Enforcement Summary Tables taken from various SALP Reports (attached hereto as Attachment 4). 14/ Id. e C. RECENT INDICIA OF BECo'S PERFORMANCE LEVEL , The most recent indicia of the level of BEco's performance
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in managing Pilgrim are consistent with its past performance. They confirm the notion that BECo. appears to be organically incapable of managing a nuclear facility. Notwithstanding the frequent incantation by senior management of a program for Cne 1 4
" pursuit of excellence," the addition of new personnel and the expenditure of large sums of money,1E! the available evidence indicates that BEco. has not changed. Its 1987 SALP Report shows that the Company continues to merit the lowest possible ratings in many functional areas. BECo. continues to be incapable of maintaining performance gains. On the basis of news reports, it appears that BEco's management of the Security and Safeguards function is deteriorating, not improving.
Further, on the basis of statements made by NRC officials at a recent meeting, the NRC has received and is investigating allegations that the company may be compromising safety by , overworking its or its contractors' employees in an effort to return the plant to service soon. This evidence suggests that - BEco's c.laim to be approaching readiness for restart may 15/ E.g., NRC Docket No. 50-293, Official Transcript of NRC Office of Nuclear Reactor Regulation, " Meeting With Boston Edison Re: Pilgrim Status and Activities Leading to Restart s Readiness," pp. 13-14, 18-20 (September 24, 1987) (hereinafter .'
"9/24/87 NRC/BECo. Readiness Meeting"). (Testimony Submitted by Stephen J. Sweeney, President and Chief Executive Officer, l
Bocton Edison Company, to the U.S. House of Representatives, l Subcommittee on Energy Conversation and Power of the Committee l on Energy and Commerce July 16, 1986, pp. 4-5 (attached hereto as " Attachment 5").
be hasty and misleading.15!
** BEco's 1987 SALP Report **
4 On April 8, 1987, the NRC released a SALP Report for BECo. which was based on the results of various inspections and evaluations conducted at Pilgrim over the period from November 1, 1985 through January 31, 1987. Ratings were given for BECo's performance in twelve functional areas. In keeping with its past record, BECo. received the lowest possible ratings in five of the twelve functional areas.12/ It
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received the highest possible rating in only two functional areas.10! The picture painted in the SALP report is one of a plant with "(p)oor management control," an " obscured ... chain of command and weakened accountability," and "-(s)significant recurring program weakness ... in some functional areas, showing the effect of ... long-term problems."1E! 4 16/ BEco's claim of readiness should be measured against its adoption of 9/24/87 NRC/BECo. Readiness Meeting, p. 43. This tendency to ignore reality in the operation of the plant has been previously found to be undesirable. See Boston Edison Company, MDPU NO. 1009-F (1982) (BECo. denied where evidence established that it had imprudently underestimated the necessary time required to perform outage tasks). ll/ The five areas were: Radiological Controls, Surveillance, Fire Protection, Security and Safeguards, and Assurance of Quality. 18/ The two areas were: Outage Management, Modifications, and Technical Support Activities and Engineering and Corporate Technical Support. 19/ 1987 SALP REPORT at 8. ! Of particular importance to this Petition, were SALP ratings in three areas where BECo. had previously improved its performance. In the functional areas of Surveillance, Fire Protection, and Licensing Activitics, BECo. had in the past improved its ratings between periods -- in fire protection, it had gone from a "3" to a "1" between its third and fourth SALP Reports -- but by the time of the review for the 1987 SALP e Report, its performance had fallen back to earlier levels. With respect to the functional area of Security and Safeguards, the 1987 SALP Report discussed continuing hardware problems, BECo's excessive reliance upon contractors, and management's failure to give this area sufficient attention.SS! The report noted that BECo's corrective actions for deficiencies in this area had not generally been effective and referenced three degradations in vital area barriers that had occurred during the evaluation period.S1! 20/ Id. at 31-34. 21/ The Commission's regulations define a " vital area" as any 3 area which contains: any equipment, system, device, or material, the failure, destruction, or release of which could directly or indirectly endanger the public health and safety by exposure to_ radiation. Equipment or systems which would be required to function to protect public health and safety following such failure, destruction, or release are also considered vital areas. 10 C.F.R. S73.2(h) and (i) (emphasis added). Such areas are to "be located within a protected area such that access to vital equipment requires passage through at l least two physical barriers." 10 C.F.R. , S73.50(b)(1). Access into a protected area is to be controlled through the checking of authorization and identity at entry control points to which barriers surrounding the protected area
" channel persons and material." 10 C.F.R S73.45(b)(1)(i) and 73.50(c).
** Recent Reports of Violations **
On the basis of news reports and statements made by NRC officials at a recent meeting, it appears that BECo. has suffered from at least four significant Security and Safeguards lapses in the past six months: a misplaced gun; a misplaced set of sensitive keys; a " serious degradation in a vital area barrier;" and ineffective identification cards.22/ While all four alleged lapses would be significant, the latter three would be a particularly strong indication of BECo's failure to learn from its past mistakes -- nearly identical lapses have occurred in the past.15! Further, allegations have recently been made which NRC stated at a recent meeting that they are investigating that BBCo. may be compromising worker and/or plant safety by requiring excessive overtime.1S/ III. EVIDENCE THAT INDICATES THAT A PLANT SPECIFIC PRA FOLLOWED BY IMPLEMENTATION OF ANY INDICATED SAFETY MODIFICATIONS SHOULD BE REQUIRED TO PILGRIM'S RESTART. Pilgrim is a GE Mark I design plant. As such, it has a primary containment which, by nearly unanimous agreement, has an extremely high probability of failure in the event of 22/ Boston Globe, September 4, 1987, p. 1; Boston Globe, September 9, 1987, p. 21; . Boston Herald, September 10, 1987,
- p. 24, 23/ See 1985 SALP Report, p. 40; 1983 SALP Report, pp. 41-43; 1982 SALP Report, p. 38 (included in Attachment 3 hereto).
24/ Boston Globe, September 29, 1987, p. 21. 12 -
certain accidents.15! This characteristic is especially critical since Mark I design reactors, such as Pilgrim, do not have the backup of a secondary containment structure which can withstand any significant position pressure. ("PWRs").Sb! In fact, Pilgrim's so-called " containment building" is not really designed to perform a backup function. It has " blow panels" which in some design and most severe accidents would activate and create a ready path for hazardous radioactive materials to escape into the environment.22/ The combination of an
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extremely vulnerable primary containment structure, a secondary containment not designed to provide an effective backup, and - the large population in the immediate vicinity of Pilgrim 1S! compel the Governor and the Attorney General to request that the NRC modify the Pilgrim operating license to bar restart until a plant specific probabilistic risk assessment ("PRA") is performed for Pilgrim and all indicated safety modifications are implemented. Until this occurs, the operation of the plant would pose an unreasonable threat to public health and safety.2}/ 25/ See NUREG-1150, Reactor Risk Reference Document, Draft for Comment, Feb. 1987, at 4-33, 4-39, 26/ Affidavit of Steven C. Sholly (attached hereto as Attachment 1), 27/ Id. 28/ Id. 29/ Id. _- j
The Governor and the Attorney General are aware that the NRC has to date declined to order mitigative modifications for Mark I design plants.10,/ They submit, however, that the evidence presented here -- the combination of extremely k vulnerable containment structures and a large population , surrounding the plant -- precludes application of NUREG-ll50's finding that the probability of a large reactor accident with early fatalities is extremely remote. The NUREG-ll50 findings do not reflect the amalgam of risks posed by Pilgrim. BECo. has proposed a number of modifications as remedial actions for the plant's design deficiencies.31/ These actions do not, however, address the inherent defects of the plant's design in any real way. The Governor and the Attorney General do, however, submit that through its so-called " safety enhancement program," BECo. has put the question of the appropriate modifications to be made to remedy the defects of the Mark I design in issue. 30/ E.g., Boston Edison Company (Pilgrim Nuclear Station), DD-87-14, __ NRC __ (1987) (slip at 31-32). 31/ Letter with enclosures dated July 8, 1987, from Mr. Ralph G. Bird, Senior Vice President-Nuclear, Boston Edison Company, to Mr. Steven A. Varga, Director, Divisior, of Reactor Projects, I/II, Nuclear Regulatory Commission (attached hereto as Attachment 6).
IV. EVIDENCE OF INADEQUATE EMERGENCY PREPAREDNESS i Within the past twelve months, two authoritative assessments have been made of the Pilgrim Radiological Emergency Response Plan and the state of emergency preparedness within the Emergency Planning Zone ("EPZ") for Pilgrim. Both conclude that the plan and the state of preparedness "are not adequate to protect the health and safety of the public in
.the event of an accident at the Pilgrim Nuclear Power Station."15/ Both also concluded that the plan and the state of preparedness have significant deficiencies and suggest potential remedies for those deficiencies that will require a substantial commitment of time, resources and cooperation.31/ BEco. has not quarreled with these conclusions.SE! The Governor and the Attorney General submit that these conclusions compel immediate action by the NRC. The 32/ FEMA, "Self-Initiated Review and Interim Finding for the Pilgrim Nuclear Power Station, Plymouth, MA" (August 4, 1987) '
(hereinafter " FEMA Self-Initiated Review"); Secretary of Public Safety, " Report to the Governor on Emergency Preparedness for an Accident at the Pilgrim Nuclear Power Sthtion" (December 16, l 1986) (hereinafter "Barry Report"). 33/ FEMA Self-Initiated Review at 1-2; Barry Report at 74. l 34/ FEMA Self-Initiated Review, p p ., 12-13, 19, 22, 29-32, 43-44; Barry Report, pp. 47-55, 35/ 9/24/87 HRC/BECo Readiness Meeting", pp. 49-54. 4
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authoritative expert agencies3 1/ agree that there is no t reasonable assurance that the public can or will be protected in the event of an accident at Pilgrim. It is, thus, incumbent - upon the NRC to take action immediately to insure that no steps are taken by BEco. which could increase the likelihood or the consequences of an accident.32/ A. THE PLANNING AND PREPAREDNESS DEFICIENCIES IDENTIFIED BY FEMA AND THE MASSACHUSETTS EXECUTIVE OFFICE OF PUBLIC SAFETY The deficiencies of the Radiological Emergency Response Plans for Pilgrim are manifold. Although the analyses of FEMA and the Massachusetts Executive Office of Public Safety do not reach the same conclusions on all issues, the following areas of substantial deficiency have been identified by both agencies:
- 1. the lack of any articulate 9 evacuation plans for public and private schoc?s as well as day care centers;
- 2. the lack of any articulated eva:uation plans for the special needs populatic1; ,
36/ FEMA is explicitly recognized by the commission as the expert Federal authority on questions of nuclear power plant offsite emergency preparedness (Memorandum of Understanding, 50 Fed. Reg., No. 75, 15,486 (April 18, 1985) and the Commission is expressly required to base its findings on off-site emergency issues on FEMA's conclusions concerning such issues. 10 C.F.R. S50.47(s)(3). The Massachusetts Secretary of Public Safety oversees the Massachusetts Civil Defense Agency and Office of Emergency Planning, which pursuant to M.G.L. c. 147, S1 is responsible for the Commonwealth's emergency activities. 37/ Each step of BECo's power ascension plan corresponds with a substantial increase in the probability of an accident at Pilgrim. Affidavit of Steven C. Sholly (attached hereto as Attachment 1). E-_-_-_-___---__. - - . - -
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- 3. the lack of any articulated evacuation plans for the transport dependent population;
- 4. the lack of identifiable public shelters for the beach population;
- 5. the lack of a reception center, as required in the plan, for people evacuating by the northern route; 6 the lack of real progress in planning and the diminutionintpestateofemergency preparedness.2S These are critical deficiencies. The plans do not even purport to provide any measure of protection for significant numbers of people: pre-school and school age children; those who require special measures to transport; and those without ready access to private transportation. They fail to address the significant beach population in an adequate fashion. They do not incorporate current or reliable evacuation time estimates ("ETEs"). Nor do they incorporate a delineated inventory of identified and identifiable shelters which are accessible to the public. Moreover an integral component of the current plans -- a northern reception center2S!
38/ FEMA Self-Initiative Review, pp. 12-13, 19, 22, 29-32, 43-44; Barry Report, pp. 47-55. 39/ The lack of a reception center for those evacuating to the north is as worrisome as the more general planning failures. The lack of a northern recepcion center indicates that even if evacuation from the EPZ were successful -- a heroic assumption in light of the assorted planning deficiencies -- those who received and followed instructions to evacuate to the nccth would find no facilities available at their designated destination. According to FEMA, approximately 60,000 people would be left without facilities at which to register, be monitored and decontaminated if necessary. FEMA Self-Initiated Review at 19.
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-- is missing altogether. Finally, offsite exercises and drills -- the most effectise means of assuring preparedness --
have not been held in years. B. THE CURRENT STATUS OF PLANNING AND PREPAREDNESS The specific functional deficiencies in the first four areas enumerated above, as well as the functional areas in which work must be done before any determination can be made if adequate plans can be developed, encompass the entire set of tasks required for adequate planning and preparedness:
- 1. Identification / Estimation of populations; 2- Identification / Estimation of resources;
- 3. Develop plans for emergency actions to be taken for each population with potentially available resources;
- 4. Obtain commitments for required resources;
- 5. Provide education /information to public;
- 6. Conduct exercises / drills.
At present, it appears that the school /daycare population has been identified but that the special needs and transport l dependent populations have not.AS/ Preliminary estimates of the resources potentially available to evacuate these i populations have now been obtained, but neither plan l l development not obtaining commitments of resource availability can proceed in the absence of reliable ETEs.A1! 40/ Executive Summary of the Report on Emergency Preparedness For an Accident at Pilgrim Power Station) (October 15, 1987) Thereinafter "Barry Report Update"), p. 2. 41/ Id. at 2.
While BECo. has recently -- August 18, 1987 -- delivered an ETE study to the Commonwealth's public safety officials,S2/ the document is still being reviewed by those officials and i preliminary analysis has uncovered shortcomings that ;ill l l necessitate further work. It is, thus, unlikely that final ETEs will be available within the immediate future for use in developing specific plans.A2! This shortcoming is critical. Id A consequence of the unavailability of reliable ETEs is that emergency planning is effectively on hold. Even when the task of identifying / estimating populations and resources is completed, radiological emergency planning cannot in any real , sense proceed without reliable ETEs and a traffic management , plan. As FEMA and the NRC well recognize, a realistic set of ETEs is an essential element of a workable emergency plan. See Cincinnatti Gas & Electric Company (Wm. H. Zimmer' Nuclear Power Station, Unit No. 1), ALAB-727, 17 NRC 760, 770-71 (1983). With respect to the beach population, preliminary population estimates and sheltering data have been provided to the Commonwealth's public safety officials but, at least in the case of the sheltering sr.rvey, these materials have been found 42/ KLD Associate . Pilgrim Station Evacuation Time Estimates and Traffic Management Plan Update (Final Draft for Review) August 18, 1987. 43/ Barry Report Update, p. 2. N 1 4 s 19 -
to be inadequate for planning purposes.AA! Again, plan development and resource availability commitments, much less public education /information efforts and exercises / drills, cannot proceed usefully without reliable final ETEs and sheltering data.AE! No replacement site for a northern reception center has been foundd5! and no determination has yet been made whether an emergency plan incorporating only two reception centers would provide an adequate assurance of protection.A2! 44/ Barry Report Update, p. 2; Letter with enclosures from Robert J. Boulay, Director, Massachusetts Civil Defense Agency, dated September 18, 1987, to Ralph C. . Bird, Executive Vice l President-Nuclear, Boston Edison Company (attached hereto as Attachment 7) 45/ Barry Report Update, p. 2; see also FEMA Self-Initiated Review at 26-27: Before FEMA and the RAC can make a determination on this (whether protective actions for thebeach population are or readily can be made adequate) it must receive the following information:
- 1) an updated geographical description of the beaches and their capacity; 2) a detailed analysis of the beach population, including the number of permanent and temporary residents and the number of day visitors, together with their geographical dispersion; 3) an updated estin ate of the length of time it would take to evacuate the beach population; and 4) a list of suitable buildings available for sheltering the beach population at each beach, including the capacities of these buildings and their i
distances from the beaches. If these buildings ! are not open to the public, the plans must l clearly state how they will be niade accessible and letters of agreement must be obtained as appropriate. 41/ Id. 41/ 9/24 nac/Beco. Readiness Meeting, p. s2. But see PEMA Self-Initiated Review at 19 (The use of only two reception centers "is not likely to be logistica11y feasible."). Finally, in the abe nee of new plans, public information/ education e_larts and exercises / drills cannot, by definition, occur. There are no plans to inform the public of exercises, much less to exercise. Although the provisions of 10 C.F.R. Part 50, Appendix E, Section IV.F. require that a l l full participation biennial emergency preparedness exercise for l Pilgrim be held this year, the NRC is presently considering a request from BECo. for a one-time exemption from that requirement to allow the exercise to be postponed to the second quarter of 1988.18/ IV. CONCLUSION In light of all of the foregoing deficiencies of the current state of emergency planning and preparedness, as well as the substantial questions raised herein concerning the managerial ability of the licensee, BECo., and the safety of the Pilgrim reactor, the Governor and Attorney General submit that the NRC must take action pursuant to 10 C.F.R. S2.202 to insure that BECo. does not take any action that could increase either the risk or the consequences of an accident at Pilgrim. l Since that Pilgrim is a GE Mark I design reactor, and the EPZ population at this plant is among the highest in the country, it is evident that the deficiencies in emergency planning and preparedness are significant for Pilgrim. These 48/ Letter with enclosures dated September 18, 1987, from Mr. Ralph G. Bird, Senior Vice President-Nuclear, Boston Edison Company, to NRC (attached hereto as Attachment 8). deficiencies are so substantial and their potential ramifications are so significant, that it is impossible to conclude that any interim compensating actions have or can be taken. The NRC's regulations IJave it nc course other than issuing an order modifying BEco's license to extend the current shut down pending the outcome of a full hearing on the significant outstanding safety issue and the development and certification by the Governor of adequate emergency plans.AE/ Respectively submitted, James M. Shannon Attorney General Commonwealth of Massachusetts Michael S. Dukakis Governor Commonwealth of Massachusetts Dated: October 15, 1987 49/ Compare 10 C.F.R. S50.54(s)(2)(ii):
... In determining whether a shutdown or other enforcement action is appropriate, the Commission shall take into account, among other factors, whether the licensee can demonstrate to the Commission'a satisfaction that the deficiencies in the plan are not significant for the plant in question, or that adequate interim compensating actions have been or will be taken promptly, or l that there are other compelling reasons for continued operation.
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6" APPENDIX I: BECo. SALP HISTORY TABULATION Inspec. Plant Radiol. Maint. Surveil. Fire Emergen. Period Oper. Control Prot. Prepared 01/01/80 2 3 2 2 2 2 12/31/80 09/01/80 3 2 3 2 2 1 08/31/81 09/01/81 3 2 2 2 3 1 06/30/82 07/01/82 2 2 2 1 1 1 06/30/83 07/01/83 2 3 1 1 2 3 09/30/84 10/01/84 3 3 2 2 - 3 10/31/85 11/01/85 2 3 2 3 3 2 01/31/87 l Inspec. Secur. Out.Mgt. Licen. Eng/ Corp Train Quality Period Safegde Mod.Act Activ. Tech.Sup Qual.Ef Assuran 01/01/80 2 3 - - - 3 12/31/80 09/01/80 2 2 - - - 3 08/31/81 09/01/81 2 2 2 - - - 06/30/82 07/01/82 2 - 1 - - - 06/30/83 07/01/83 2 1 1 - - - 09/30/84 10/01/84 2 1 1 - - -
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10/31/85 11/01/85 3 1 2 1 2 3 0.1/31/87 .,
APPENDIX II: BECo. VIOLATIONS TABULATIONS SEVERITY LEVEL III VIOLATIONS: 9/1/81-1/31/87 1981 1982 1983 1984 1985 1986 1987 Functional Area Plant Operations 3 1 2 1 Radiological Controls Mainenance Surveillance Fire Protection Emergency' Preparedness 1
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1 Security / Safeguards 1 1 1 Outage Mgt ... Licensing Activities Training ... Eff' ness Assurance of Quality Engineer / Corp. Support BECo. VIOLATIONS BY SEVERITY LEVEL: 9/1/81-1/31/87 Severity Level 81/82 82/83 83/84 84/85 85/87 II 7 1 1 2 1 III 9 9 18 17 21 IV 20 20 6 5 6 V VI 2 3 3 1 3 1 Deviations 40 33 26 27 29 Total Violations l l l
r UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION in the matter of a BOSTON EDISON COMPANY Docket No. 50-293 (Pilgrim Nuclehr Power Station, Unit 1) i AFFIDAVIT OF STEVEN C. SHOLLY Stever, C. Sholly, being on oath, deposes and says as follows:
- 1. !. am an Associate Consultant with MHB Technical Associates,1723 Hamilton Avenue, Suite K, San Jose, California,95125. A statement of my professional qualifications is attached hereto and marked Attachment A. In brief, I have more than six years experience in the review, analysis, interpretation, and application of probabilistic risk assessment to the analysis of safety issues .
related to commercial nuclear power plants, including issues related to radiological emergency planning. I have served as a member of the peer e review group for the NRC publication NUREG-1050 (1984) (Probabilistic Risk Assessment (PRA) Reference Document, September 1984), and have more recently served as a member of the Conta/nment . Performance Deslan Oblective Workshoo, the Panel on ACRS Effectiveness (1985), end the Severe Accident Policv Implementation External Events Workshoo (1987). l have previously testified as an expert witness on probabilistic risk assessment and emergency planning matters in NRC proceedings on the Catawba Units 1 and 2, Indian Point Units 2 and 3, and Shoreham Unit 1 nuclear plants, and also in the Public inquiry regarding the proposed Sizewell-B nuclear plant in the United Kingdom, in addition, I have co-authored two major reviews of source term 1 L_ _ - - - - _ - - - - - - -
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and risk estimate issues published in NRC reports NUREG-0956 and NUREG-1150. I have also performed reviews of various technical aspects of the Shoreharn, Limerick, Indian Point, Sizewell, Zion, Seabrook, Millstone-3, and Oconee-3 probabilistic risk assessments and the Vermont Yankee Containment Safety Study.
- 2. MHB Technical Associates ("MHB") has been requested by the Nuclear Safety Division, Department of the Attorney General, The Commonwealth of Massachusetts, to evaluate the increase in risk resulting from a startup program for return to power from the current refueling and modifications ,
outage for the Pilgrim Nuclear Power Station, Unit 1 (PNPS-1). 1
- 3. In its current configuration (refueled) and considering the duration of the current shutdown, Pilgrim currently poses very little risk to the public health and safety. This is due to the multiplicity of systems theoretically available to inject water into the reactor vessel and due to the low decay heat level present in the fuel. In the event of a core heatup transient with the plant in its current
- configuration, considerable time would elapse between initiation of coolant loss
( and the onset of fuel damage, time during which measures could be taken to initiate coolant makeup and/or other recovery and mitigative actions. Moreover, in theory a longer time period is available within which to implement offsite protective actions due to the slower accident progression time compared with accidents at higher power levels.
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- 4. Boston Edison Company (BECO), the licensee for Pilgrim, currently envisions restart power ascension program with a minimal number of hold points, in ,
brief, BECO proposes to institute holds on restart (pending approval from NRC ) in accord with Confirmatory Action Letter No. 86-10), recovery from reactor mode switch testing prior to conducting a test for shutdown from outside the control room, and prior to movement of the scram set point above 95% power. (Saa, Boston Edison Company, Pilgrim Nuclear Power Station Restart Plan. l pages IV-29 to IV-31.) The details of the power ascension program in Attachment 13 of the Pilgrim Nuclear Power Station Restart Plan have not yet been provided.
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- 5. My current understanding of the BECO power ascension program is that the program would result in a relatively rapid ascension from the current shutdown condition to full-power operation. In so doing, the risk to the public health and l safety posed by operations at the Pilgrim plant will be increased markedly.
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- 6. The Commission has concluded generally that the risks from 5% power operation are negligible. [Spg, for example, SECY-84-155,12 April 1984, and 1 attachments; and letter dated 15 June 1984 from Nunzio J. Palladino to Hon.
Edward J. Markey, and attachments.] The evaluations upon which the Commission has drawn these conclusions, however, were for plants with very little operating history and no spent fuel pool inventory. Clearly, Pilgrim is different in this regard, with a substantial long-half-life fission product inventory present in both the refueled reactor core and the spent fuel pool. Moreover, these evaluations did not consider the unique risks posed by accidents resulting from externally-initiated events (specifically, in this case, seismic , events). In my opinion, the presence of more than 1100 spent fuel assemblies, I prior operation of two-thirds of the core at equivalent full power for most of an operating cycle, and the matter of external events render the circumstances at Pilgrim sufficiently different from those previously evaluated for 5% power operation that the previous evaluations understate, perhaps significantly, the ; risk posed by operation of Pilgrim at 5% of full power. This conclusion is further supported by the likelihood that the primary containment will not be q inerted until operation above 5% power is commenced. In my opinion, virtually any severe accident at 5% power with the containment de-inerted will result in early containment failure (due to hydrogen burn or hydrogen detonation in the primary containment, and/or other causes).
- 7. As power level increases, risk to the public increases. This is due to several factors, including a marked increase in volatile fission product inventory and a marked increase in decay heat level, which results in accident progression times which are much shorter than at low power levels. This reduces the amount of time available for implementation of recovery and/or mitigation ]
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actions and reduces the amount of time available to implement offsite
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protective measures. {
- 8. A full-scope probabilistic risk assessment for the Pilgrim plant has been in progress for several years. It is my understanding that this study is nearly ;
completed. It is my expectation that this study will identify seismic initiating i events as a significant contributor to core melt frequency (i.e., contributing 10% or more to core melt frequency from all causes). This expectation is based on l my familiarity with seismic risk assessments performed on similar designs and performed on other plants in the general region of Pilgrim (e.g., Shoreham, Seabrook Units 1 and 2, Millstone Unit 3, and Limerick Units 1 and 2). Seismically-initiated accident sequences are accompanied by potentially severe impacts 'on offsite emergency response even when there are fully-approved and operational emergency plans. In the case of Pilgrim, the current status of emergency planning is such that there is not adequate assurance that protective actions can and will be taken in the event of an accident. Given the more severe conditions of a seismically-initiated accident scenario, this conclusion is all the more applicable. , l
- 9. A study of risk at 25% power for the Shoreham nuclear plant, which possesses l a nuclear steam supply system which is grossly similar to Pilgrim, indicates that i
the core melt frequency for operations at up to 25% of full power may not differ dramatically from the core melt frequency at full power. The 25% power PRA l estimates a core melt frequency of 2.8 x 10-5 per reactor-year. [Sga, E.T. l I Burns, S. Mays, and T. Mairs, Probabil/stic Risk Assessment of the Shoreham Nuclear Power Station: Initial Power Ooeration Limited to 25% of Full Power. l Delian Corporation, prepared for Long Island Lighting Company, April 1987, ! page 4-12.] The full power PRA analyses for Shoreham estimated a core melt l frequency of about 6.5 x 10-5 per reactor-year. [Sga, Science Applications, ! Inc., Final Reoort: Probabilisticfisk Assessment. Shoreham Nuclec Power Sfat/pa, prepared for Long Island Lighting Company,24 June 1983, page 4; j and V. Joksimovich, et al., Maior Common-Cause initiatina Events Studv: l Shoreham Nuclear Power Station. NUS Corporation, NUS Report No. NUS-4617, prepared for Long Island Ughting Company, February 1985, page 1-8]
l 1 i 1 This represents less than a factor of three difference in the likelihood of a core melt accident at 25% power versus full power. Although this assessment is for Shoreham and not for Pilgrim, it suggests that the likelihood of an accident is not markedly different for 25% power versus 100% power. i
- 10. Further, a limited-scope PRA of Shoreham at 5% power was prepared for LILCO. This study, which did not include external events, concluded that the core melt frequency for 5% power operation was about 4.9 x 10-6 per reactor-year. [ Sag, Delian Corporation and Science Applications, Inc., Proba6///stic R/sk Assessment. Shoreham Nuclear Power Station. Low Power Ooeration Un to 6% of Full Power. prepared for Long Island Lighting Company, draft, May f
1984, page 78.) This indicates that core melt frequency at 5% power is significantly reduced from 25% power or full power, by a factor of roughly 20, but not nearly as significantly reduced as previously predicted by the NRC staff, q which predicted a reduction factor of 1,000 or more.1/ Moreover, the 5% 1 power reduction factor of 20 is an underestimate since the 5% power estimates do not include external events.
- 11. The 5%, 25%, and 100% power PRA studies for Shoreham indicate, in my l
opinion, that the core power level for Pilgrim will have at best a moderate impact on the likelihood of an accident. Considering the uncertainties involved, j the likelihood of an accident may be nearly indistinguishable at the various power levels indicated above. Moreover, the Shoreham results are lower than the core melt frequency estimates for many other plants. A Brookhaven National Laboratory review of the Shoreham PRA for internal events only estimated a core melt frequency of 1 x 10-4 per reactor year. An average value for full-scope PRAs completed to date is of the order of 3 x 10-4 per reactor-year, t 1/ The NRC staff, in SECY-84-156, predicted core melt frequency reduction factors for various classes of BWR accidents ranging from 1,000 to 100,000. [See, SEGY-84-156, Enclosure 1, " Staff Review Process for 5 Percent Power Operation", I page 2.] Thus, in the aggregate, the NRC staff would have expected a core melt "requency reduction of at least 1,000, compared with the Shoreham value of 20. The results for Shoreham indicate a reduction factor approximately 50 times less than the NRC staff expected based on engineering judgment.
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- 12. These results are especially significant for a plant with a containment design j similar to- Pilgrim. Pilgrim employs a steel Mark I pressure suppression containment. Such contairiments have been estimated in a variety of studies
! sponsored by IDCOR, NRC, and utilities to have an early containment failure l probability -- given a severe accident -- in a range from 10-90%. This means ! that there is a significant chance that, given a severe accident, the accident will l be accompanied by a large early release of radioactivity to the environment. L
- 13. The Pilgrim plant, like all Mark I containment design plants, also employs a secondary containment, usually referred to as a reactor building. This I structure is not designed to withstand the high internal pressures which would
[ accompany a severe accident, and is unlikely to survive in a leak-tight condition i folicwing primary containment failure. High pressure in the secondary containment due to a . severe accident would be produced by a combination of blowdown due to primary containment failure, primary containment leakage, f primary containment venting, and burning of combustible gases. Indeed, Mark j i plants are designed with both internal and external " blow-out panels" which are des /gned to relieve pressure. In the case of Pilgrim, there are blow out panels at the refueling deck elevation which relieve pressure directly to the environment. In my opinion, there is little basis for assuming that releases from the primary containment will be significantly mitigated by the presence of the l secondary containment.
- 13. Based on the above considerations, it is my opinion that Pilgrim Unit 1 should not be restarted until the offsite emergency response plans are upgraded and evaluated to adequately protect the public health and safety. Further, it is my recommendation that BECO be required to promptly submit the Pilgrim probabilistic risk assessment study to the NRC for public review and evaluation prior to restart. The review of such a study should indicate whether there l
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- l. l-remain significant operational risks which must be ameliorated in order to provide adequate protection to the public health and safety.
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Steven C. Sholly / Associate Consultant /
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& ACKNOWLEDGMENT No ni vers.e7727?Acrwxrdwwsmeree&cerJrarxxWMsX#MMMAPKr/M7/n88BC.M 39 _ _ On this theLV__ day of __ 19ff_, before me, ro X, ~s y A.We L KLL. , the undersigned Notary Public, personally appeared M. W-_ - - 9.Y7 ' OFFICIAL SEAL t:1 personally known to me Nota Y PV C
- Cd i RNIA # proved to me on the basls of satisfactory evidence SANTA CtARA COUNTY to be the person (s) whose narne(s) _._ _ L.T ___ subscribed to the My comm. expires JUN 24, 1991
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within instrument, and acknowledged that dp executed it. WITNESS my hand and of ficial seal. Solary's Signa ar _-'D - Vde'&#FAW/MiWA<Ae'MP2FFdf2M&2PfM2222VA24WMFM&2M22W28'=XTeWr*27AM7kP/2R2Z*1 NAfloNAL NOTARY ASSOCIATION
- 23012 Ventura Blvd a Po Box 4625 e Woodland HA CA 91365-4625
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L ; PROFESSIONAL QUALIFICATIONS OF STEVEN C. SHOLLY ; STEVEN C..SHOLLY.
.MHB Technical Associates 'j 1723' Hamilton Avenue 1 C
Suite K , li San Jose, Californian-95125 (408)_266-2716 i l EXPERIENCE: September 1985 - PRESENT 1 ' Associate --MHB Technical Associates, San Jose, California
' Associate in energy consulting firm that specializes _in .. technical and economic assessments of energy production facilities, especially nuclear, i for local, state, and federal governments and private organizations. MHB: l 1s extensively involved in regulatory proceedings and the preparation of a studies and reports. Conduct research write 3 reports, participate in !i discovery process in regulatory proceedings,' develop- testimony and other documents for regulatory proceedings, and respond to client -inquiries.
Clients have included: State of California, State of New' York, State of Illinois. February.1981 - September 1985 i Technical-Research Associate and Risk Analyst - Union of Concerned Scien- -{ tists, Washington, D.C. i Research associate and risk analyst for public interest group based in l Cambridge, Massachusetts, that specializes in examining the impact of ad- L vanced technologies on society, principally in the areas of arms control J and energy. Technical work focused on nuclear power plant _ safety, with emphasis on probabilistic risk assessment, radiological emergency 4 s planning and preparedness, and generic safety issues. Conducted l
. research, prepared reports and studies, participated in administrative l proceedings before the U.S. Nuclear Regulatory Commission, developed ;
testimony, anlayzed NRC rule-making proposals and draft reports and i _ prepared comments thereon, and responded to inquiries from sponsors, the j
- general public, and the media. Participated as a member of the Panel on t ACRS Effectiveness (1985), the Panel on Regulatory Uses of Probabilistic !
. Risk Assessment (Peer Review of NUREG-1050; 1984). Invited Observer to '
NRC Peer Review meetings on the source term reassessment (BMI-2104; 1983- ! 1984), and the Independent Advi-sory Comittee on Nuclear Risk for the ; Nuclear Risk Task Force of the National Association of Insurance Commissioners (1984).
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I i January 1980 - January 1981 q Project Director and Research Coordinator - Three Mile Island Public Interest Resource Center, Harrisburg, Pennsylvania Provided administrative direction and coordinated research projects for a public interest group based in Harrisburg, Pennsylvania, centered around issues related to the Three Mile Island Nuclear Power Plant. Prepared , fundraising proposals, tracked progress of U.S. Nuclear Regulatory Com- l mission, U.S. Department of Energy, and General Public Utilities activi- l ties concerning cleanup of Three Mile Island Unit 2 and preparation for l restart of Three Mile Island Unit 1, and monitored developments related !
'to emergency planning, the financial health of General Public Utilities, 1 and NRC rulemaking actions related to Three Mile Island.
July 1978 - January 1980 Chief Biological Process Operator - Wastewater Treatment Plant, Derry Township Municipal Authority, Hershey, Pennsylvania Chief Biological Process Operator at a 2.5 million gallon per day ter-tiary, activated sludge, wastewater treatment plant. Responsible for bi-ological process monitoring and control, including analysis of physical, chemical, and biological test results, procees fluid and mass flow man-l agement, micro-biological analysis of activiated sludge, and maintenance of detailed process logs for input into state and federal reports on treatment process and effluent quality. Received certification from the Commonwealth of Pennsylvania at a wastewater treatment plant operator. Member of Water Pollution Control Association of Pennsylvania, Central Section, 1980. July 1977 - July 1978 Wastewater Treatment Plant Operator - Borough of Lemoyne, Lemoyne, Penn-sylvania Wastewater treatment plant operator at 2.0 million gallon per day sec-ondary, activated sludge, wastewater treatment plant. Performed tasks as assigned by supervisors, including simple physical and chemical tests on wastewater streams, maintenance and operation of plant equipment, and maintenance of the collection system. , September 1976 - June 1977 Science Teacher - West Shore School District, Camp Hill, Pennsylvania Taught Earth and Space Science at ninth grade level. Developed and im-plemented new course materials on plate tectonics, environmental geology, and space science. Served as Assistant Coach of the district gymnastics team. l
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September 1975 - June 1976 n
/ ' Science Teacher - Carlisle Area School District, Carlisle, Pennsylvania Taught Earth and Space Science and Environmental Science at ninth grade level. Developed and implemented new course materials on plate tecton-ics, environmental geology, noise pollution, water pollution, and energy.
Served as Advisor to the Science Projects Club. EDUCATION: B.S., Education, majors in Earth and Space Science and General Science, minor in. Environmental Education, Shippensburg State College, Shippens-burg, Pennsylvania, 1975. Graduate coursework in Land Use Planning, Shippensburg State College, Shippensburg,. Pennsylvania, 1977-1978. PUBLICATIONS:
- 1. " Determining Mercalli Intensities from Newspaper Reports," Journal of Geological _ Education, Vol. 2S, 1977.
- 2. A Critique of: An Independent Assessment of Evacuation Times for Three ;
t Mile Island Nuclear Power Plant. Three Mile Island Public Interest ; Resource Center, Harrisburg, Pennsylvania, January 1981.
- 3. A Brief Review and Critique of the Rockland County Radiological Emergency Preparedness Plan, Union of Concerned Scientists, prepared for Rockland County Emergency Planning Personnel and the Chairman of the County Legis- ;
iature. Washington, D.C., August 17, 1981, l
- 4. The Necessity for a Prompt Public Alerting Capability in the Plume Expo-sure Pathway EPZ at Nuclear Power Plant Sites, Union of Concerned Scien-tists, Critical Mass Energy Project, Nuclear Information and Resource i Service, Environmental Action, and New York Public Interest Research !
Group Washington, D.C., August 27, 1981. * '
- 5. " Union of Concerned Scientists, Inc., Comments on Notice of Proposed Rulemaking, Amendment to 10 CFR 50, Appendix E. Section IV.D.3," Union of Concerned Scientists, Washington, D.C., October 21, 1981. *
- 6. "The Evolution of Emergency Planning Rules," in The Indian Point Book: A Briefing on the Safety Investis ation of the Indian Point NucTiear Power t Plants Anne Witte, editor, Un on of Concerned Scientists (Washington, D.C.) and New York Public Interest Research Group (New York, NY),1982.
- 7. " Union of Concerned Scientists Comments, Proposed Rule,10 CFR Part 50 Emergency Planning and Preparedness: Exercises, Clarification of Regula-tions, 46 F.R. 61134," Union of Concerned Scientists, Washington, D.C.,
January 15, 1982.
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a 's 3 l 8.- Testimony of. Robert D. Pollard and Steven L Sholly . before the Sub- , i i committee on Energy and the Environmen t, Committee in IntkHor and-
. Insular-Affairs,_ U.S. House of Representatives, gilddletod, Pennsylvania, March 29, 1982, available from the Union of ConcerneJ) Scientists.
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- 9. " Union of Concerned Scientists Detailed Comments on Petition for RulewW l ing by Citizen's Task Force, Emergency Planning,10 CFR Parts 50 and '70) }
Docket No. PRM-50-31, 47 F.R. 12639," Union of Concerned Sciertists,' Washington, D.C., May 24, 1982. , [ , s
- 10. Supplements to the Testimony of Ellyn R. Wriss, Esq. , General Chunsel, Union of Concerned Scientists, before the Subcommittee on Energy j
[ Conservation and Power, Committee on Energy and Commerce, U.S. House of 1 Representatives, Union of Concerned Scientists, Washington, D.C., August ' 16, 1982. t c
- 11. Testimony of Steven C. Sholly, Union of Concerned Sch'r.tists, Washington, ',
j- D.C., on' behalf of the New York Publib Interest Redech Group, Inc., be-fore the Special Committee on Nuclem Power Safety it the Assembly of the { State of New York, hearings on Legis12tive Overfight of the hiergency Ra-diologic Preparedness Act, Chapter 708, Laws of 1981, Septeder 2,198,2. , ? ( s , t 12. " Comments on ' Draft Supplement to Fina?" Environmental dabdnt Related ' l to Construction and Operation of C? inch River Bree' der ,Reactd Pldit'," L Docket No. 50-537, Union of Cor,cstrd Scientists, Washington,' D.C., September 13, 1982. * ,
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- 13. " Union of Concerned Scientists Commeud or, ' Report to the County Commis- J sioners', by the Advisory Committee on Radiological Emergency Plan for ,
Columbia County, Pennsylvania," Union of Concerned Scientists, Washirq.- l ton, D.C., September 15, 1982. '% j\
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- 14. " Radiological Emergency Planning for Nuclear Reactor Accidents," pre- i sented to Kernenergie Ontmantsid' Congress, Rotterdam, The 'Nethrlands, l Union of Concerned Scientists, Washington, D.C., October 8,1982. i '
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- 15. " Nuclear Reactor Accident Com equences: Implications for Radiological g l Emergency Planning," presented to the Citizen's Advisory Committee to Rc- l view Rockland County's Own Nuclear Evacuation and Preparedness Plan and h General Disaster Preparedness Plann Union of Concerned Scientists, Wash-ington, D.C. , November 19, 1982.
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- 16. Testimony of Steven C. Sholly before the Subcommittee eni Overstpht and.
Investigations. Committee on Interior and Insular Affeirs, U.S. House of Representatives, Washington, D.C., Union of Concernet Scientists, Decem- 4 ber J3, U 32. >' 1 l i
- 17. Testiwny of Gordon R. Thompson and Steven C. Sho11y do Commission Ques- ,
tion Two, Contentions 2.1(a) and 2.1(d), Union of Concerned Scientu.ts !' and New York Public Interest Research Group, before tne U.S. Nuclear Reg-ulatory Commission Atomic Safety and Licensing Board, in the Matter of Consolidated Edison Company of New York (Indian Point Unit 2) and the Power Authority of the State of %w York (Indian Point Unit 3), Docket Nos. 50-247-SP and 50-286-SP, Des. der 28,1%2.
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- 18. Testimony of Steven C. Sholly on the Consequences of Accidents at Indian Point (Commission Question One and Board Question 1.1, Union of Concerned Scientists and New York Public Interest Research Group, before the U.S.
Nuclear Regulatory Commission Atomic Safety and Licensing Board, in the Matter of Consolidated Edison Company of New York (Indian Point Unit 2) and the Power Authority of the State of New York (Indian Point Unit 3), Docket Nos. 50-247-SP and 50-286-SP, February 7, 1983, as corrected ' February 16, 1983. *
- 19. Testimony of Steven C. Sholly on Commission Question Five, Union of Con-cerned Scientists and New York Public Interest Research Group, before the U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board, in the Matter of Consolidated Edison Company of New York (Indian Point Unit
- 2) and the Power Authority of the State of New York (Indian Point Unit 3), Docket Nos. 50-247-SP and 50-286-SP, March 22, 1983. *
- 20. " Nuclear Reactor Accidents and Accident Consequences: Planning for the Worst," Union of Concerned Scientists, Washington, D.C., presented at Critical Mass '83, March 26, 1983.
- 21. Testimony of Steven C. Sholly on Emergency Planning and Preparedness at Commercial Nuclear Power Plants, Union of Concerned Scientists, Washing-ton, D.C., before the Subconraittee on Nuclear Regulation, Committee on Environment and Public Works, U.S. Senate, April 15, 1983, (with " Union of Concerned Scientists' Response to Questions for the Record from Sena-tor Alan K. Sinipson," Steven C. Sholly and Michael E. Faden).
- 22. "PRA: What Can it Really Tell Us About Public Risk from Nuclear Ac-cidents?," Union of Concerned Scientists, Washington, D,C., presentation to the 14th Annual Meeting, Seacoast Anti-Pollution League, May 4, 1983. l
- 23. "Probabilistic Risk Assessment: The Impact of Uncertainties on Radi-ological Emergency Planning and Preparedness Considerations," Union of Concerned Scientists, Washington, D.C., June 28, 1983.
i i
- 24. " Response to GA0 Questions on NRC's Use of PRA," Union of Concerned Sci-entists, Washington, D.C., October 6,1983, attachment to letter dated October 6, 1983, from Steven C. Sholly to John E. Bagnulo (GAO, Washing-ton,D.C.). ,
- 25. The Impact of " External Events" on Radiological Emergency Response Plan-ning Considerations, Union of Concerned Scientists, Washington, D.C., De- ,
cember 22, 1983, attachment to letter dated December 22, 1983, from ' Steven C. Sholly to NRC Commissioner James K. Asselstine.
- 26. Sizewell 'B' Public Inquiry, Proof of Evidence on: Safety and Waste Man-agement Implications of the Sizewell PWR, Gordon Thompson, witii supporting evidence by Steven Sholly, on behalf of the Town and Country Planning Association, February 1984, including Annex G, "A review of Probabilistic Risk Analysis and its Application to the Sizewell PWR,"
Steven Sholly and Gordon Thompson, (August 11, 1983), and Annex 0,
" Emergency Planning in the UK and the US: A Comparison," Steven Sholly and Gordon Thompson (October 24,1983).
- 27. Testimony of Steven C. Sho11y on Emergency Planning Contention Number Eleven, Union of Concerned Scientists, Washington, D.C., on behalf of the Palmetto Alliance and the Carolina Environmental Study Group, before the U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board, in the Matter of Duke Power Company, et. al. (Catawba Nuclear Station, Units 1 and 2), Docket Nos. 50-413 and 50-414, April 16,1984. *
- 28. " Risk Indicators Relevant to Assessing Nuclear Accident Liability Premi-ums," in Preliminary Report to the Independent Advisory Committee to the ,
NAIC Nuclear Risk Task Force, December 11, 1984, Steven C. Sholly Union of Concerned Scientists, Washington, D.C. { j
- 29. " Union of Concerned Scientists' and Nuclear Information and Resource Ser-vice's Joint Comments on NRC's Proposal to Bar from Licensing Proceedings the Consideration of Earthquake Effects on Emergency Planning," Union of Concerned Scientists and Nuclear Information and Resource Service Wash-ington, D.C., Diane Curran and Ellyn R. Weiss (with input from Steven C. i Sholly), February 28, 1985. *
- 30. " Severe Accident Source Terms: A Presentation to the Commissioners on the Status of a Review of the NRC's Source Term Reassessment Study by the Union of Concerned Scientists," Union of Concerned Scientists, Washing-ton, D.C., April 3, 1985. *
- 31. " Severe Accident Source Terms for Light Water Nuclear Power Plants: A Presentation to the Illinois Department of Nuclear Safety on the Status
{ of a Review of the NRC's Source Term Reassessment Study (STRS) by the Union of Concerned Scientists," Union of Concerned Scientists. Washington, D.C. , May 13, 1985.
- 32. The Source 1erm Debate: A Review of the Current Basis for Predicting Se-vere Accident Source Terms with Special Emphasis on the NRC Source Term Reassessment Program (NUREG-0956), Union of Concerned Scientists, Cam-bridge, Massachusetts, Steven C.~ Sholly and Gordon Thompson, January 1986. i j
- 33. Direct Testimony of Dale G. Bridenbaugh, Gregory C. Minor, Lynn X. Price, and Steven C. Sholly on behalf of State of Connecticut Department of Pub-lic Utility Control, Prosecutorial Division and Division of Consumer l i
Counsel, regarding the prudence of expenditures on Millstone Unit III, ! February 18, 1986,
- 34. Implications of the Chernobyl-4 Accident for Nuclear Emergency Planning for the State of New York, prepared for the State of New York Consumer Protection Board, by MHB Technical Associates, June 1986.
- 35. Review of Vermont Yankee Containment Safety Study and Analysis of Containment Venting Issues for the Vermont Yankee Nuclear Power Plant, prepared for New England Coalition on Nuclear Pollution, Inc., December 16, 1986.
- 36. Affidavit of Steven C. Sholly before the Atomic Safety i and Licensing Board, in the matter of Public Service
]
Company of New Hampshire, et al., regarding Seabrook Station Units 1 and 2 Off-site Emergency Planning Issues, Docket Nos. 50-443-OL & 50-444-OL, January 23, 1987.
- 37. Direct Testimony of Richard B. Hubbard and Steven C.
Sholly on behalf of California Public Utilities Commission, regarding Diablo Canyon Rate Case, PG&E's Failure to Establish Its Committed Design QA Program, , Application Nos. 84-06-014 and 85-08-025, Exhibit No. ' 10,935, March, 1987.
- 38. Testimony of Gregory C. Minor, Steven C. Sholly et.. al.
on behalf of Suffolk County, regarding LILCO's Reception Centers (Planning Basis), before the Atomic Safety and Licensing Board, in the matter of Long Island Lighting ; Company, Shoreham Nuclear Power Station Unit 1, Docket No. 50-322-OL-3, April 13, 1987.
- 39. Rebuttal Testimony of Gregory C. Minor and Stevw C.
Sholly on behalf of Suffolk County regarding LILCO's Reception Centers (Addressing Testimony of Lewis G. Hulman), Docket No. 5 0 - 3 2 '2-O L- 3 , May 27, 1987.
- 40. Review of Selected Aspects of NUREG-ll50, Re ac tor Risk Reference Document," prepared for the Illinois Department of Nuclear Safety by MHB Technical Associates, September 1987.
- Available from the U.S. Nuclear Regulatory Commission, Public Document Room, Lobby, 1717 H Street, N.W.,
Washington, D.C.
lllllNew. England Nuclear News JUNE 1987 (April oata) CONNECTICUT YANKEE On April 16, the plant shutdown because of problems with turbine control valve #4. After chemistry holds and a load runback, the p! ant reached full power (94%) on April 21st. The Institute for Nuclear Power Operations (INPO) will conduct its annual critique of plant operations beginning on June 8th. MAINE YANKEE Maine Yankee shutdown for refueling is proceeding generally according to schedule with \ startup expected in early June. Very small cracks found in the disks of both low pressuro turbine rotors have necessitated the replacement of one and the repair of the other. YANKEE Yankee began its 18th refueling on May 2nd. The last cycle of the plant produced more than 2 million megawatthours over a 17 month period with a capacity factor of 93 percent. PlLGRIM Pilgrim remained off-line during the month. VERMONT YANKEE On April 4, Vermont Yankee came down in power and took the turbine off-line to repair a small steam leak in a main steam drain line. The plant came back on-line the same day and operated at full power for the remainder of the month. MILLSTONE 1 & 2 i Millstone Unit 1 operated routinely for the month of April. A scheduled refueling outage will begin in middune and last for approximately 10 weeks. Millstone Unit 2 operated routine-ly except for a trip on April 16 due to a generator exciter field circuit breaker opening on prwemed MeteNa trmsformer fault indication. Instruments in place to monitor the suspect , bistable. The unit returned to service after a 20 hour outage on April 18. ; MILLSTONE 3 Millstone Unit 3 returned to service after a scheduled outage. After startup on April 11, the unit tripped on the next day while at 10 percent power level due to steam generator I low level when turbine driven feed pump oscillated. Feedwater regulating control valve i failed to open on demand due to a control air leak. The unit returned to service on April 14 after belt.g out for 29 hours. nf ncf **'"" { GCne
lp b.-{ . lv 4 NEW ENGLAND NUCLEAR NEWS. NUCLEAR GENERATION AS A PERCENT OF TOTAL ENERGY REQUIREMENTS . april,1987 i l- CAPACITY FACTORS Net Barrels . Year to' Plant - Kilowatthours Oil Saved Month ' Date Cumulative
% % % a
' Connecticut Yankee 334,216,000 . 554,300 80.0 . ~ 92.0 76.0 Millstone 1 463,479,000 768,600 - 97,7 - 97.0 68.4
- Milletone 2 597,711,000 991,200 94.9 81.1 62.5 Millstone 3 453,732,000 752,500 54.7 68.7 78.9 '!
Vermont Yankee 353,972,000 587,000 95.8 99.1 68.7 Maine Yankee 0- 0- 64.1 ' 68.9 Yankee 97,011,000 160,000 '77.1 88.5 70.9
). . Pilgrim 0- 0- 0- 52.9
*coastdown Weighted Average Capacity Factor 58.6% 71.1 % 67.0 %
l . Total Nuclear Generation 2,300,121,000 Total Energy Requirements 8,184,000,000 ' Nuclear as % of Total 28.1 %
. Total Barrels Oil Saved 3,814,500 TWELVE MONTHS ENDED APRIL 1987:
Nuclear Generat!on: 32,899,000,000 kwhs.
' Nuclear as a Percent of Total Energy Requirements: 32.0 percent Barrels of Oil Saved: 54,227,000 banels t- p 7-nrw_.._ ,1 'i
* . 00 5
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7 - - . - (i,. , . , /hh . . 9 New Mw7 pllLa t 1 England v Nuclear News ; m cHAct r ctrAav OliP7 OF IMd AT'YY GEN ONt ACIG,GRTON FL 30STOL MA 02309 i ELECTRIC COUNCIL OF NEW ENGLAND 54 MIDDLESEX TURNPIKE, BEDFORD, MA 01730 1 1
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# 800 UNITED STATES
- I i
\ ,, NUCLEAR REGULATORY COMMISSION , h-
'{E REGION I 531 PARK AVENUE
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- I niNo oP PRuss:A. PENN5YLVANI A 19404
++..* AUG 2 71986 j Docket No. 50-293 Boston Edison Company M/C Nuclear
-ATTN: Mr. James M. Lydon Chief Operating Of ficer ,. -
i'[ Mf 800 Boylston Street . l Boston, Massachusetts 02199 l Gentlemen: l
Subject:
Confirmatory Action Letter 86-10 l This letter is to provide further guidance on the requirements we expect to be met prior to the. restart of the Pilgrim plant. We acknowledge receipt of Boston Edison Company's (BECO) letter of June 16, 1986, in response to CWrf~irmatory Action l Letter (CAL) 86-10. Your actions with regard to the issues in CAL 86-10 appear to ' be thorough and technically sound. .My staff has a few remaining questions, which have been discussed with your staff and which will be documented in Inspection Report 50-293/86-25. In addition to the specific plant hardware inues involved with CAL 86-10, several other issues have been identified that require resolution prior to restart of the Pilgrim plant. Soecific technical issues of concern include: overdue surveil-lances. malfunction of recirculation motor generator set field breakers, seismic auali ficatien of__ emergency diesel __ qenerator dif ferential relays, and completion of Accendix R modifications. Plene be prepared to discuss these issues at our next manacement meeting at the plant on September 9, 1986. Me would also like to hear at this meeting the scope and status of all vour orocrams related to restart o.f
, .P i l c-i m . These include (a) the results of your six week action plan f,or improve-ments. (b) the _ role of BECO safety review committees, including ths Procram For_
Fxcellence Task Force. in assessing readiness for restart, and (c) the readiness 0f 1 the plant and corporate staff to support plant startup, testing, and operations. In light of the number and scope of the outstanding issues. I am not orecared to approve restart of_ the Pilarim facility until vou orovide a writton rannet that documents BECO's formal assessment of the readiness for restart operation. This assessment should include your detailed check list for assuring that all out-standing items have been satisfactorily resolved and that plant systems have been restored and prepared for operation. A formal restart program and schedule should also be suomittad for MC reviaw and approval. Thh program should include held po,ints ,at, appropriate Atapas .sixh et c-!HM My, - cm.Meuon of mode switch test-ing, and at specific milestones during ascension to full power. Authorization to proceed beyond each hold point will be contingent upon my approval and will be based on my staff's evaluation of the operational performance of the plant-. We will have substantially augmented NRC inspection coverage during this restart
. period.
Please plan to submit your readiness assessment and restart procram and schedule at least forty-five days before your planned startup from the current outaae. My decision on restart will be based in part on our review of these documents. o
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. Your co~ operation is' appreciated, j
Sincerely, Thomas E..Murley i L , Regional Administrator CC f . L. Oxsen, Vice' President, Nuclear Operations A. E. Pedersen, Station Manager .
~'.
Paul' Levy,'Chairmaa,. Department of Public Utilities. Edward R. MacCormack, Senior Regulatory Affairs and Program Engineer a
-Chairman, Board of. Selectmen i
. Plymouth Civil Defense Director
'The Honorable E. J. Markey ;
. J. D. Keyes .
Senator' Edward P. Kirby 3
- The Honorable Peter V. Forman Sharon Pollard Public Document Room (PDR)
Local Public Document Room (LPDR) Nuclear Safety Information Center (NSIC)
. - NRC Resident Inspector .
Commonwealth of Massachusetts (2) t . I l t
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; '! * ' . J '.- UNITED STATES .
- l' J / 1 NUCLEAR REGULATORY COMMISStON i
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REGION I sat ranx 4vewus owo or enussia, emusvi. vama suas [ " APR 0 81987 . Docket No. 50-293
. Boston Edison Company M/C Nuclear
'ATIN: 'Mr. Ralph Bird _ -
Senior Vice President - Nuclear 800 Boylston Street Bosten, Massachusetts 02199 Gentlemen:
Subject:
Systematic Assessment of Licensee Performance ( SALP) Report No. 50-293/86-99 Tc.e Region I SALP Board has reviewed and evaluated the performance of activ-ities at the through JanuaryPilgrim 31, 1987. Nuclear Power Station for the pesriod November 1,1985 The results are presented tre the enclosed report. A r.eeting to acie da' e. The reeting will be held on discuss this assesscent will be scheduled for a mutually accept- 1 or near the sit e so that appropriate se: or corporate managecent anc plant efficials can discuss with us the l strer;ths and weaknesses noted. It is our intent that th is meeting be cc=bined , l with the periodic management meeting to review istprov emen t program status.
. 'ur.ctional He SALP areas. Board identified significant recurring progra m . weaknesses 1r some aere also noted. However, Improvements, such as in the area of e mergency preparedness, the SALP perf Boarc found the rat;e of such change was I
slow during most of the assessment ed. l b'e recognize that the Boston Edison Company (BECo) has meade signifiedqt staff-ing anW nrdnre commitments to improve performance at ! we believe they are beginning to have a positive impact.t. hie As Pilgrim you areSta\ ion and-aware, the' NRC is
- rcblems at looking for progress in correcting the previously~ fdentified lorg tera the. Pilgrim Station prior to plant restart, particularly ir
- h:n
'uretionai areas witn'a Category 3 rating. .
In :*eparation for the SALP meeting, please ce . prepared t;o discuss your evalua-tien of our assessment and the status of your performance improvener.t prcgra .s. Any com'nents_ you may have regarding our report may be dis cussed at the meeting. adcttionally,;,you may provide written corr. rents within 30 days af ter the meet- , i ing. Following our meeting and receipt of your written response, the enclosed report, youNresponse, and a summary of our findings ar.d olanned actions will. ce placco in (the NAC Public Document Room. ; _ _ _ _ _ _ - . _ _ _ - - - - - -" ~
l_
.p 63-TABLE 4 1 l
-ENFORCEMENT
SUMMARY
-(11/01/85 - 01/31/87)' PILGRIM NUCLEAR POWER STATION A. Number and Seve ity Level of Violations Severity Level I O Severity Level II O Severity Level III 1 Severity Level IV 21 , Severity Level V 6 Deviation 1 Tc:a1 29 B. Viciations'Vs, Functional Area Severity Leve * ~ s
~.;r::iona r I,re a s I !! IIT IV V C e'v Tetal
; :1 ant Operatiens ~ - - - -
1 1
- 2. F.cciological Controls ~- -
1 3 - ' - 4 3 maintenance - - - 1 1 l f, 5;rve111ance - - 6 3 - 9
- 5. ~4re Protectic, - - -
5 - 2 6
'( i~.ergency F-e:n-etness -
0 ; 7 5a:; ity Saf eg arcs - - - 1 1 - 2
- 3. Ostageg-Manager.ent and Modification Activities - - -
1 1 2
'9. Licensing Activities - - - - - -
0
~
- 10. ra'.ning anc Qualification
. Effectiveness - - - - - -
O
, 1: '.-at:e c' ~.a'ity - - - 4 - - 4
- E: ot- ; a : ::r:.: a:e
'e: r icai Sa:::-: - - - - - - -
~
T:u i s C ; 1 21 6 1 29
i 64 TABLE 4 (Continued) U C. Summary 2nspect' ion Report- Severity Functional Number Level Area Violation
'E5-22 V Surveillance Instrument channel. tests were not being performed monthly for the reactor building vent and stack waste gas monitors. i E5-22 V Secu ity Failure t o perform a Safeguards proper search of a package brought i nto the protected .
area. Et-01 y
?lant. Dost trip review 86-01 anc C:erations 66-02 la: Ked required recorder .: harts. Inadequate control a com lo; entries on disabled annunciators.
I I
.E6-04. III Radiological A waste s hipment of solid l- Ccetrels metallic oxices on non- ,,
compacted trash lacked requirec strong packaging ans quality control measures. j EE-06 IV Surveillance l' Replaceme nt squib charges were installed in the stanc:y liquid centrol system from a batch tha t had not been testec during a manual initiation c f l
'the Stancby Liquid Centrol i System.
26-10 IV Radiological Radiatice surveys of packageo Controls irradiated reactor compenent:s were not documented on ! approprie.te radiation survey f orms anc' macs. El-10 I\ Assarance of Quality e entrcl reasures we e
". . a t i ty not take- in transferring racicact' ve waste shipments
l 65 TABLE 4 (Continued] I C. Summary Inspection i Report Severity Functional Level Area Violation
' Number IV Assurance of Previously identified 86-14 inadequacies 11nvolvi ng Quality surveillance testing of the ,
high pressure coolant injection syr, tem were not corrected for six months. 56-14 V Surveillance Failure co' properly control measuring and test equip ent. 36 :V Surveillance Battery r: ate: '. cad di scha rge Test proc edure was not updated te eflect syster alteratio*ns arc restorations. 36-25 :V Assurance of Failure a nd Malfunett on Ouali:y Report wa s n:t completed by engine ering personnel after they iden tif *; ed deficient station f ire barriers. 86-25 V Surveillance Surveilla r.ce tests were performed without independent verification of system rescense and system restoration. 56-25 Deviation Fire Drotection Failure to comply with the commitment to cenduct quarterly fire brigade drill: for all fire brigade members. 16-34 IV Security Improper package search and Safeguards inadequate follow up. BE-36 IV Fire Protection Fire brigade members had r.et received the required training. Ei-2i :V Fire 0-:;ection :'re watches f ailed to pe-f:r-the required hourly patrcl of the motor generator set room t_ b6 __ . _ .
66 TABLE 4 (Continued) r C. Summary Inspection Repcrt Severity Functional Area Violation _ Number Level } inadequate fire brigade ch ill. 66-37 IV Fire Protection . Modifications Safety-related modifictti on s 86-37 IV were not performed i r accordan ce with applier. bit design requirements, Fire Protection Adequate procedures and 66-38 IV drawings had not been j established 'for the sttelen fire wat er sustem. 2diological Failure to it;7ement a 56-44 :V radiological control procecure Controls for chec king; vehicles lead ng the site. S7-01 IV Surveillance Failure to adhere tc the procedure gcverning surveilitance testing of the Post Acciden t Sampling System (:3 ASS ) system. Maintenance Lack of procedure guidance on 67-01 IV maintenance of the heat tracing control circuit reisys for the DASS system. IV Fire Prote: tion ' Failure to ta ke required 57-03 action for inoperable fire protection equipment. 87-03 Y IV Radiological Failure to control a master Cent-els key to all iccked high radiation areas. E7-03 IV Assurance of Failure and Malfunct on Osaldty Repe-t not cenpleted afte-a sa f ety-rela .ed bus trar s'e-die not pecur during a surveillance test.
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67 I. j TABLE 4 (Continued) C. Summary Inspection Report Severity Functional Number Level Area Violation 27-04 IV Surveillance A surveillance test on Standby j Gas Treatment Systern failed to i meet the intent of the Tech Spec requirements. 87-04 IV Surveillance Failure to calibrate measuring and test equipment. 87-04 V Modification Perforrning post-modi fication test or, the rwfuel bridge without app eted procedure changes. 67-04 IV Surveillance Master test tr: gram procedures do not adeci stely address survefilar: test at:d pcst i modificatt' test programs. e e J - v' - w -
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? l , g.m.5 , UNITED STATEe [ \j, f 1 p, NUCLF AR REGULATORY COMMI IO!!
- ; 6 A '.i. e. ! REGION : .
$ 94 631 PARK AVENUE j ' * ~ * * - - - -
% '\"' j KING OF PRUSSIA, PENh.SYLVANIA 1940C 3- a a a as RECEIVEL Docket No. 50-293 MAY?O" 1 Boston Edison Company M/C Nuclear ATTN: Mr. William O. Harrington F* P
- O
- Senior Vice President, Nuclear 800 Boylston Street I _._ . . . . . , , . _ , _ , , , ,
g Boston, Massachusetts 02199 y Gentlemen: J
Subject:
Systematic Assessment of Licensee Performance (SALP) Report No. 50-293/85-99 ) j This letter refers to the Systematic Assessment of Licensee Performance (SALP)' of the Pilgrim Nuclear Power Station for the period of October 1, 1984 through ! October 31, 1985, initially forwarded to you by our February 18,'1986 letter (Enclosure 1). This SALP evaluation was discussed with you and your staff at l a meeting held in Plymouth, Massachusetts on March 5,1986 (see Enclosure 2 for i attendees). We have reviewed your March 26, 1986 written comments (Enclosure 3) l and herewith transmit the final report (Enclosure 4). ) I Overall, your performance in the operation of the facility was found acceptable -l x although some areas were only minimally acceptable. I ) As projected in our letter of February 18, 1986, a special in-depth team in-
\
spection was conducted from February 18 to March 7, 1986 (Inspection Report No. 50-293/86-06) to determine the underlying reasons for the poor performance : discussed above. The team found that improvements were inhibited by (1) incom- ! plete staffing, in particular operators and_ key mid-level supervisory personnel, l (2) a prevailing view in the organization that the improvements made to date l have corrected the problems, (3) reluctance, by management, to acknowledge some I problems identified by the NRC, and (4) dependence on third parties to identify J problems rather than implementing an effective program for self-identification of weaknesses. We believe these findings confirmed the SALP Board conclusions. l We acknowledge your discussion of program and staffing improvements in plant operations, radiological controls and emergency preparedness. However, we believe that tbe success of your programs depends upon resolution of the four i principal fagtors inhibiting improvement noted above which, in turn, depends ; heavily on adnagement attitudes and aggressive followup. In this regard we i request that you be prepared to discuss the scope, content and schedule of each improvement program at a management meeting scheduled for 1:00 p.m. on June 12, 1986 at the NRC Region I Office.
T-4-I TABLE 4
-pfJC$MENT
SUMMARY
(10/1/84-10/31/85) PILGRIM NUCLEAR POWER STATION S_everity Levels FUNCTIONAL AREAS I II. III IV V 'DEV Tota 1. :1
\
A. Plant Operations - - - 4 2 - 6~ ! B. Radiological Controls - - 1 1 1 2' 5-i C. Maintenance & Mod'fications - - - 1 1 1
.D. Surveillance - - -
.9 2- 1 12
.E. Emergency Preparedness - - -
2 - - 2 F. Security & Safeguards - - 1 - - - 1 G. Refueling & Outage Management - - - - - - 0 .f c\ . }1 -H. Licensing Activ.ities - - - - - - 0 Te als by Seve-it, Le.e1 0 0 2 .17 5 3 27 i l. i nu i, k _. I
i l T-5-1 1' h . TABLE 5 ENFORCEMENT DATA 3 PILGRIM NUCLEAR POWER STATION { i Insp. .Insp. Severity Functional _No. Date . level Area Violation 84-36 11/1-31/85 IV Plant Failure to conduct an adequate Operations shift turnover for control room ; personnel during refueling ! IV Plant Operitions Failure to continuously monitor 1 source range monitors during ! refueling
- 84-39 11/21- IV 12/31/84 Surveillance Failure to promptly identify conditions adverbe to quality l (i.e. failure to initiate Failure and Malfunction Reports) :
I 84-41 12/10-13/84 IV Emergency Preparedness Failure to diseminate emergency planning information IV Emergen:y Creparterest Failure to update the emergency riar ard pr :edures 84-44 12/15-19/84 III Radiological l Controls Failure to follow radiation work I permit instructions and failure ' to establish a procedure for a remote reading teledosimetry j system 85-01 1/1-31/85 l! V -Plant C$erations Failure to maintain centrol room staf fing at levels required by 10 CFR 50.54 IV Surveillance failure to test the containment cooling subsystem immediately 1 when the low pressure coolant ; injection system war, inoperable 85-03 2/1/85- IV Surveillance Failure to conduct surveillance 3/4/85 i tests for the reactor protection system (six examples) IV Surv eillare;e ) Failure to conduct rod block surveillance tests (five examples) ' gg:.
- n' , _ __
/ I /~ i T-5-2 j j Insp. Severity Functional Insp.
No. .Date Level Area Violation IV Plant Failure to promptly correct con-Operations ditions adverse to quality (i.e. j failure to take timely action l on Quality Assurance surveillance i findings) j or V Surveillance Failure to use the most current revision of e.aseweillance test i procedure 'fr- { V Surveillance Failure to calibrate test equip-ment within the calibrated period 85-06 3/5/85- V Plant Failure to maintain an uncali-4/1/E5 Operations brated local power range monitor in a bypassed state IV Maintenance Failure to conduct a dioctyi phthalate test of HEPA filters ( following maintenance on ths standby gas trestment system S/20-24'85 V Radiological Failure to have the Operations 85-13 Cor.trols Review Committee (ORC) review two radiological procedures and failure to control work in the fuel pool with a maintenance request , Deviation Radiological Failure to conduct an adequate Controls review of systems that could generate an uncontrolled, un-mon (tored radibective effluent release, as recommended in IE Bulletin 80-10 85-17 6/33/85- 3.V Surveillance Failure to conduct a surveillance 7/25/85 surveillance test of the 250 V battery system required by the technical specification and to follow station procedures for additional battery tests IV Radiciogical Failure to specify high radiation l Controls area surveillance frequencies on radiation work permits l w _
T-5-3 l l Insp, I n s p ~. Severity Functionai i No. Date Leve,l_ _, Area Violation Deviation Surveillance- Failure-to conduct inservice I tests as specified in an NRC ! ' submittal 85-20 7/I6/85- IV Surveillance Failure to maintain the trip j 8/19/85 level' setting for.the "B" and "C" sain steamni ke high radi- - ation monitors within technical specification limits 1 85-21 7/16/85- IV Surveillance Failure to maintain se ondary-7/30/85' , containment IV Surveillance Failure to test alternate safety system when an emergency diesel generator was found to be inoperable IV Surveillance Failure to initiate Failure and i Malfunction Reports as required by station procedures j 85-24 8/6-E/65 III security Failure to maintain an adequate vital area barrier 85-26 E/20/EE- IV Plant Failure to properly authorize 9/23/E5 Operations excessive licensed operator overtime as required by station procedures (thirty-five instances) i 8S-27 9/16/85- Deviation. Radiological Failure to install a protective 9/20/E5 Controls conduit j
y. n n' , .
/, ,
UNITED STATES t, NUCLf;AR REGULATORY COMMISSION 'l ':y.
.{
- j. REGION f
' a31 PARK AVENuf
%.? ,o#g KING oF PRUS$1A, PENNSYLVANIA 19408 -
Docket No. 50-293-1?1985- N"r;efp Boston Edison company M/C Nuclear-
' ATTN: Mr. William D.'.Harrington ' f,# -
. Senior Vice President, Nuclear , :n i 800.Boylston Street Boston, Massachusetts' 02199 W. p
. Gentlemen:
Subject:
Systematic Assessment of Licensee Performance (SALP) Report No. 50-?93/ ; 84-34 and Your Reply Letter BEco 85-031 Dated February 12, 1985' ' Thank you for your reply- to SALP Report No. 50-293/84-34. In your letter you pre-sented additional information concerning assessments and requested we recorwider
'some of.the assessments to better account for the assessment period's extraordinary i circumstances (i.e., the sxtended outage for piping replacement).
Based on our discussions with you at the January 23, 1985 management meeting and the information presented in your reply letter, the SALP Board found it appropriate to revise the declining trend of the Category 2 rating for fire protection / house-keeping to a Category 2 rating with a consistent trend. We % 1 this is appropriate -- as we may not have properly accounted for the extended outaQ :,1 our evaluation for trend. However, we continue to feel that the extent of Leslamination that I existed throughout the plant was inconsistent with a Category I rating. The en-closed SALP Report has been supplemented to reflect this change. .The SALP Board also found that.the other ratings should remain unchanged. With regard to the current status of your operations, we acknowledge the improving 1 trend of your performance in the plant operations and maintenance areas and en-courage you.to continue your efforts in these areas. Further, we note the progress {
- being made.in implementing your recently established Radiological Improvement Pro- 3 1
gram and encourage your efforts to decontaminate the plant, to reduce plant radi- 1 ation levels, to enhance oversight of the radiation protection program, and to establish support for the program by plant personnel. Your cooperation with us is appreciated. 1 l (
.j Sincerely, Mt -hb >
Thomas E. Murley i Regional Administrator l l , i
1 1
. '381 TABLE 2 VIOLATION
SUMMARY
(7/1/83 - 9/30/84). PILGRIM NUCLEAR POWER STATION-A. , Number and Severity Level of Violations Severity Level I. O Severity Level II 0
-Severity Level-III 1
-Severity Level IV 18 Severity. Level V 6 Deviation
_1
-Total 26*
.q B. ~ Violations Vs. Functional Area Severity Level Functional Areas I II III IV V OEV s
A. Plant Operations 2 5 B. Radiological Controls
- 1 7 1 1 C. -Maintenance 2
1 D. Surveillance 1 E. - Fire Protection and Housekeeping i F. Emergency Preparedness i G. ' Security and Safeguards 6 H. Refueline and Outage Management I. Licensing Activities I Totals
- 1 18 6 1 !
i
- Totals do not include three apparent violations and one apparent deviation in the area of radiological controls that were identified during inspection 84-25.
NRC enforcement action was under review at the end of the assessment period.
39 C. Summary Inspection.- Inspection Severity-Report No. Functional Date Level Area- Violation l
- 83-19 '8/16-10/3/83 V A i
Failure toLreview-and up-date special orders V A Failure to vent piping from the high point in the core spray system
.83-20 8/8-12/83 IV I B
Failure to follow a Radi- ! ation Work Permit ' 83-21 8/22-24/83 V A Failee to schedule 'exter- ' l nal audits V A Failure to document defi-ciencies in deficiency ] reports 83-23 10/4-11/7/83 IV 'O Failure'to conduct an in- ' service test on a high- i pressure coolant injection ! (HPCI) valve l) IV C Failure to review a proce-dure for procuring safety ' i related items. 83-24 11/8-12/31/83 IV A Failure to record reactor , vessel cool down rate ! 84-03 1/20-27/84 III B Failure to label a container of licensed material, use ' extremity dosimetry, and instruct workers on radi-ation levels 1, 84-04 2/7-3/12/84 IV 3 A Failure'to maintain a pro- ( cedure for the proper ! operation of the contain-ment atmospheric dilution l system 84 2/13-17/84 IV B Failure to follow a radi- I ation work permit j l 1 1 1 ______ -l
40 l Inspection Inspection Severity Report No. Functional Date _ Level Area Violation 84-11 4/23-27/84 IV C Failure to maintain a pro-cedure for controlling welding slag 84-13 4/24-27/84 IV. B Failure to properly review and approve contractor. pro-cedures involving transpor- 1 tation of radioactive materials. IV B Failure to comply with the requirements of a Certifi-cate of Compliance for a transport package V B Failure to properly document a quality assurance program for transport packages ; DEV B Failure to fulfill a trans-portation training commit-ment 84-14 5/9-11/84 IV B Failure to' instruct worke"s on the presence of radio-active materials l IV B Failure to survey radiation hazards ' IV B Failure to implement pro-cedures consistent with 10 CFR 20 84-22 7/16-20/84 IV G Failure to control a security key card IV G Failure to maintain photo ' ID badges IV G Failure to respond to two vital area alarms IV G Failure to maintain one guard radio and one offsite communications net operable
D l '
- ------D L
1 g y 41 s Inspection. Inspection Severity-
- Report No. Functional 1 Date Level- . Area Vio'lation IV . G.
Failure to maintain effee-tive compensatory measures. IV G Failure to maintain effec-tive compensatory measures.
.84-25 8/6-10/84
- B Failure to perform radiation ,
surveys ! B Failure to instruct workers on radiation hazards B Failure to properly approve procedures
' B Failure to implement recom- i mendations in Regulatory Guide 8.8 i 84-26 8/28-10/8/84 V A Failure to properly approve QA program related proce-dures CApparent violations and deviations.
! end of the assessment period. Enforcement action was under review at the 1 5 6 ! J l _______--------2--- - -
~~ . , , . , l UNITED STATES u, p 'o, NUCLEAR REGULATORY COMMISSION
.h54 MEGION i 8 ;p g .-
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Docket No. 50-293 Boston.Edisor Comoany M/C Nuclear q ATIN: .Mr; William. D. Harrington -i RECEIVED Se'nior Vice President, Nuclear j 800 Boylston Street l Boston, Massachusetts 02199 SEI 15 lo" W . D . H .- j Gentlemen:
SUBJECT:
SYSTEMATIC ASSESSMENT 0F LICENSEE PERFORMANCE (SALP) j The NRC Region I SA'LP Board conducted a review on August 25, 1983, and evaluated the performance of activities associated with the Pilgrim Nuclear Power Station. The results of this assessment are documented in the enclosed.SALP Beard Report. ' A' meeting has been scheduled for September 21, 1983, at Braintree, Ma. to ciscuss this assessment. At the meeting, you -should be precared to discuss' our assessment and your ' ' plans to improve performance. Any comments you may have regarding our recort may be discussed at the meeting. Additionally, you may provide written commerts within 20 days af ter the meeting. F0llowing our meeting and receipt of your response, the enclosed report, your response, anc a summary of our findings and planned actions will be placec in g tre NRC Public Document Room. Ycur cooperation is appreciated. Sincerely,
)
i cnard . . arostecki SALP Board Chairman, Director Division of Project and Resident Programs Enciosure: As Statec cc w/ encl: A. V. Morist , Manacer, Nuclear Ooerations Support C. J. Matnis, Station Manager O 4
\
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-- ,,,,--~%_..- J
39 TABLE 4 VIOLATIONS (7/1/82 - 6/30/83) PILGRIM NUCLEAR POWER STATION
.A. Number and Severity Level of Violations Severity Level I O Severity Level II O Severity Level III 1 Severity Level IV 9 Severity Level V 20 Deviations 3 .
Total Violations 30 Total Deviations 3 B. Violations Vs. Functional Area Severity Levels FUNCTIONAL AREAS I II III IV V DEV
- 1. Plant Ooerations 4 8
- 2. Radiological Controls 1 7 1
- 3. Maintenance 1 1
- 4. Surveillance
- 5. Fire Protection / Housekeeping 3 1
- 6. Emergency Preparedness
- 7. Security and Safeouards 1 3 2
.8. Refueling
- 9. Licensing Activities !
1 Totals 0 0 1 9 20 3 Total Violations = 30 Total Deviations = 3
g-
.Y N
40 TABLE 4 (Continued) Summa ry
'Jnspection Inspection :
Require-NoL_ Date Subject __ments Severity A_rla 82-19 June 14 - Blocking open a' fire August 1 'T.S. V 5 door without proper controls Failure to evaluate T.S. V- 5 fire loading prior to moving combustibles-into safety related ares
- Failure to translate 10CFR50 V 1 design bases into App. B drawings Failure to perform -10CFR50.59 V 1 an adequate safety evaluation prior to
) changing a station valve lineup procedure i Failure to maintain T.S. V 5 a fire door position ! l continuously annunciated l Failure to perform Fire D 5 daily checks of non- Protection alarmed fire doors Review j as committed to the l NRC 82-22 August 2 - Failure to make a T.S. IV 1 prompt notification Failure to make a 10CFR50 V 1 ! 50.72 notification l Failure to perform a T.S. IV 2 ! leak rate test required l by the LCO for an l inoperable Vacuum Breaker l Alarm System l 1 l
t .41 k TABLE 4 (Continued)
~ Summary
!nspection Inspection- Require-No. Date .. Subject ments- Severity Area 82-24 Septemoer 7.- Failure to revise- Licensee D 2 October 18 procedures for radio- Response active discharges as to committed to the NRC Violation 81-19-01'
'82-29 October.19' - Improper equipment T.S. V 1 November 15 tagging Failure to properly '
set a main steam safety valve a Failure to properly 10CFR50 IV 1 control distribution App. 8 of the Q-List Failure to use proper Security V 7 methods of access Plan control Failure to prevent Security IV 7 unauthorized entry into Plan vital area or followup on a security deficiency N/A(1)- January 31, Safeguards information 10CFR73.21 III 7 1983 not properly controlled resulting in a loss of copy of the site physical Security Plan 83-03 January 25 Failure to perform T.S. V 2(1)* ,g February 25 chemistry samples Failure to assure that 10CFR50 V 1 training certification App. B forms were completed g prior to watch assignment Failure to properly T.S. V 1(5)* control high pressure gas cylinders
,,. 3
+ q s e p
( ! 4 42 -
\ >
' t .
., ; s TABLE 4(Con $ued) t
.jammary.
t bspection Inspection
- No. Date Sub.iect Require-ments s
( h vd ity Area !.
'l 83-07 March 22-April 18 Failure to imple-ment.a station pro-T.S. [V.6 r
g ; '2(3)" 7 cedure for inspection 'i^ s 3 and cleaning of the w is '; t K SBGT. System inlet- '
'* 1 plenum ,i p ',
83-08 May 9 - Failure to conduct 7;S J V 2/ May 13 an audit of the 'h k ? Radiological Environ- 4 mental Monitoring .i Program report when required ,'
\,
83'09 April 4 - Accepting, in receipt 20CFR50 V 1-May 3 inspection, material . App B h not in conformance / with the P.O. Requirt . ments i *i g , i Failure to maintain 10CFR50 i JV ' 1
)
l the Q-List b App.B - , l l , Failure to upcaie the 10CFR50.71(e) V (2) ~ 1 FSAR 5 Failure to perfprm IEB 79-09 0 3 preventive mainten- Commitment ante as commit <.ed to the NRC 83-10 April 19 - Safeguardsinformation10CFR73.2.'j'1 TV 7 May 23 not properly controlled , Security access' card Secur,ity IV + 7 key not properly icon- Plan' 1- 1 trolled- , g ,-
F UNITED STATES l ,..j# % NUCLEAR REGUL ATORY COMMISSION 3, % f) j j ,I l'
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REGION 1 631 PARK AVENUE p '. > KING OF PRUSSIA. PENNsYl.VANIA 19406 7 q ". v j/ - . ovis a 3 O Docket No. 50-293 Boston Edison Company M/C Nuclear ATTN: Mr. William D. Harrington l Senior Vice President, Nuclear l 8C0 Boylston Street l ' Boston, Massachusetts 02199 Gentlemen:
Subject:
Systematic Assessment of Licensee Performance ($ ALP) i This letter and itsThe enclosures document NRC's assessmen enclosed SALP Report, cated August 12, 1982. i 1, 1981, to June 30, 1982. includes performance assessments for'each of the nine functional areas which These individual assessments were discussed with ye.u and your were evaluated. l staff by Mr. R. W. Starostecki of this office on September 1,1982, at the l Boston Edison Company offices in Braintree, MA. l. Our overall assessment of the performance of NRC licensed activities at the Pilgrim facility is that improvement has occurredThere sincenow theappears organizational to be and personnel changes which took place earlier this year. f g y O satisfactory level of management attention and involvement in p matters. safety. We recognize that efforts are underway to improve the management These changes systems and utilization of resources _at the Pilgrim facility. and plans are documented in the Performance Improvement Plan which wer mitted to the NRC on July 30, 1982. Although several months before some of these improvements will be completed. performance has improved recently, some shortcomings In particular, have been noted and we we believe additiera1
, have included them in this report. attention is warranted on your part We will be increasing ourin the areas of day tions and fire protection / prevention activities.
attention to these treas to ascertain if identified weaknesses are being corrected, I In the meeting of September 1, 1982, the NRC staff benefited from your comments
'concerning the SALP Program and the functional 20, area1982 performance and haveassessments.
included I have also reviewed your letter of SeptemberThe SALP Board also considered responses to your comments in this package. The results of these your concerns and I had the benefit of their input. considerations are presented below. ) l l l l- " ~ ~ --- --
TABLE 5 VIOLATIONS (9/1/81 - 6/30/82) PILGRIM NUCLEAR POWER STATION A. Number and Severity level of Violations _ a. Interim NRC Policy Severity Level (September 1,1981 - March 9,1982) Severity Level I 0 Severity Level II O Severity Level III 6
) Severity Level IV
' 5 h t Severity Level V 17 5everity Level VI 2
, Deviation 1
- b. NRC policy Severity Levels (March 10,1982-June 30,1982*) ,,
swity Level I o 4 Severity Level II o Severity Level III 1 Severity Level Iy Severity Level V 4 Deviation 3 j l Total Violations 38 Total Deviations 2 Functional Area U I Septeeter l e 1981 - March 9, 1982 Severity Levels I II IIT IV V VI DEV .
, 0 0 3 3 5 0 0
- 3. 4 15 4du N 0 0
0 0 1 0 0 1 3 2 0 0 0 1 '
- 5. Fim 0 0 0 1 1 1 0
- 6. Emergene p 0 0 0 0 5 0 0
- 7. Securi 0 0 1 0 0 0
- 8. RefuelinN o 0 0 1 0 0 0 0'
0
- 9. Licensin 0 0 0 Tarals - 0 1 0 0 es 0 0 0 0 0 1 0 0 .. 0 6 5 17 2 1
TABLE 5 (Continued)
- 8. Violations Vs. Functional Area (2) March 10, 1982 - June 30, 1982*
Severity Levels FUNCTIONAL AREAS I II III IV V DEV
- 1. Plant Operations 0 0 0 1 1 1
- 2. Radiological Controls
- 0 0 0 1 0 0
- 3. Maintenance 0 0 0 1 0 0
- 4. Surveillance 0 0 0 0 2 0
- 5. Fire Protection
- 0 0 0 0 0 0 1
- 6. Emergency Preparedness 0 0 0 0 0 0
- 7. Security & Safeguards 0 0 1 0 0 0
~~
- 8. "Refue1in'a ~ 0 0 0 1 0 0
- 9. Licensing Activities 0 0 0 1 0 0 Totals 0 0 1 4 3 1 Total Violations = 38 Total Deviations = 2
- Does not include the following reports, not yet issued:
82 Resident Inspector 82 Special Health Physics i 36
- m. -
\i l
l TABLE 5 (Continued)_ C. Summary Inspaction Inspection Subject Reo. Sev. Area No. Date 81-18 June 15 - Failure to have an operable 10 CFR III 1 (9)* Sept. 30 combustible gas control system 50.44 (multiple examples of design errors, procedural and drawing errors,)and reviews inadequate safety 81-18 June 15 - Failure to infom the NRC of T.S. III 1 (9)* Sept. 30 the erroneous statement that an installed system met the require-l ments of 10 CFR 50.44 - Material False Statement 81 -19 August 18 - Failure to follow station pro- T.S. Y 1 Sept. 30 cedure 81-19 August 18 - Failure to perform a safety 10 CFR IV 1 Sept. 30 evaluation prior to disabling 50.59 protection for an RHR pump 81-21 August 31 - Failure to post a high radia- T.S. IV 2 Oct. 2 tion area 81-21 August 31 - Failure to adhere to radiation T.S. V 2 Oct. 2 protection procedures for I radiation work pemits. 81-21 August 31 - Failure to post copies of NOV's 10 CFR V 2 Oct. 2 involving radiation protection 19 81-22 Sept. 16 - RCIC containment isolation valves T.S. III 1 Sept.17 were left open when their control instrumentation was inoperable 81-24 Dec 1. 1981- Operation at drywell temperatures 10 CFR IV 1 Jan. 18. 1982 above FSAR description without 50.59 adequate safety evaluations 81-24 o*C 1.1981- Failure to adequately prepare and T.S. Y 1(4)
- an. 18. 1982 implement procedures for coping with high drywell temperatures d
37
o o ,. s i i C. TABLE 5 (Continued) Sunmary , i
' Inspection.
No. Inspection Data Subject 81-24. Rec. Dec. 1, 1981- Sev. Area Jan. 18, 1982 Failu n to promptly evaluate and _ 1 10 CFR V ' correct conditions adverse to quality 50 App 8 1 81-24 Dec. 1, 1981-Jan. 18, 1982 Security perly access card keys not pro-controlled Security III 7 81-24 Dec. 1, 1981- Plan Jan. 18, 1982 Combustibles were not removed from area near hot work T.S. V 5 81-24 Dec. 1, 1981-Jan. 18, 1982 Improper equipment tagging' T.S. V t- 81-25 1(3)' Oct. 15 - Oct. 18, 1981 Failure to have all ORC members present at a pre-refueling meeting . T.S. V 8 k 81-26 July 20, 1981~ Transported radioactive materials with liquid in drums 10 CFR III 2 81-35 30.41 Nov. 1 - Nov. 30 Control / Storage of combustible gas cylinders was not in accord- T.S. V 5 81-35 ance with station' procedures Nov. 1 - ' Nov. 30 Failure to establish and imple- i ment procedures for t T.S. V E of combustible scrap,he control i 81-35 waste, debris Nov. 1 - ; Nov. 30 Failure to establish and imple-ment procedures for the control T.S.. V 5 \ 81-35 of combustible oil i Nov. 1 - Nov. 30 Control of foreign material during repairs to MSIV's was not T.S. V 3 in accordance with procedure s 81-36 ! Nov. 30, 1981-Dec. 4, 1981 ! A master not surveillance schedule was established T.S. VI 4 81-36 Nov. 30, 1981-Dec. 4, 1981 T.S. Amendments were not properly entered into controlled volumes T S. VI 9(1)h l w=_.1 . = --.- . - . _ . . - - _ -__- ^
l-TABLE 5 (Continued) C. Sumary , 2 I Inspection Inspection No. Date Subject Rec. Sev. Area l 81-36 Nov. 30, 1981- Program and procedures were not 10 CFR V 3 (5)
- Dec. 4, 1981 established for housekeeping and 50 App B system cleaning that meet the QAM standards stated in the' QA Manual 82-01 Jan. 18, 1982- Workers were not properly in- 10 CFR V 2 Feb. 28, 1982 structed of the storage and 19.12 transfer of radioactive resins 82-01 Jan.18,1982- Procedures were not adequately T.S. V 5 Feb. 28, 1987 established and implemented to provide required numbers of SCBA units for fighting fires 82-02 Jan. 1 - Uncalibrated brush recorders 10 CFR V 4 g Jan. 15, 1982 were used during RPS surveillance 50 App 8 82-02 Jan. 1 - Maintenance activities were per- T.S. IV 3 Jan. 15, 1982 fonxd without using approved pMeedures 82-02 Jan. 1 - Instrumentation was not calibrated T.S. Y 4 Jan. 15, 1982 at frequency specified in station procedures 82-02 Jan. 1 - Improper control of access to Security III 7 Jan. 15, 1982 Vital Areas Plan 82-04 Jan. 25 - Failure to implement procedures T.S. Y 4(1)*
Jan. 29, 1982 for LLRT and drawing change revisions 82-04 Jan. 25 - Drawings and procedures did not 10 CFR IV ' 1 Jan. 29, 1982 identify the as-built condition 50 App B of valves in piping syst es 82-05 Feb.1 - Untimely corrective action to 10 CFR V 1 Feb. 5, 1982 internal QA Audit Deficiency 50 App B Reports 82-06 Feb. 10 - Training and requal. program for Comittment DEY 2 i Feb. 12. 1982 personnel who operate and process IEB 79-19 radioactive waste not implemented as comitted 39 __h - - . _ _ _ . _
~
prf,
*f.{
e l ,..- I TABLE 5 (Continued) C. Sunnary Inspection Inspection No. Date Subject Rec. Sev. Area N/A Feb. 12, 1982 Prompt Notification System 10 CFR 6 (sirens)notinstalledby 50.54 III I February 1,1982 82-10 March 1 - April 4,1982 Performed maintenance'on valve with T.S. V 1 (3)* red tag attached 82-10 Merch 1 - ! Plant shielding study mod.' April 4, 1982 (trucklockdoorpanel)not NUREG 0737 DEY 6 completed as stated in respor.sc to NRR E2-11 Feb. 25 - An unauthorized adjustment was IV Feb. 28, 1982 made to a leaking flange during 10 CFR 50 App J 4
)
the conduct of the FCIUti - 82-12 April 5 - May 9, 1982 Failure to follow actions re- T.S.- IV 1 l quired by T.S. with inoperable ! reactor vess(1 water level instrwrantation 82-13 Aprii 12 - Inadequate design control, for 10 CFR IV S (5)
- l April 16, 1982 interfaces and verification 50 App 8
.82-16 May 10 -
June 13, 1982 Failure to lock or control access T.S. IV 2 to a high radiation area (stuck TIP ' drive) , 1 1 l l 1 l
'( )* secondary arta involved 1 g
1 4 40 ' _-- i
.m- v: . I i
i I Testimony Submitted by 4 Stepnen J. Sweeney - President and Chief Executive Officer Boston Edison Company to the U.S. House of Representatives , Subcommittee on Energy Conservation and Power ;. of the Committee on Energy and Commerce July 16, 1986
\
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y , N e , J; - J3 o f lNTR00VCTION' i t $- g Boston _ Edison Company appreciates the opportunity to address a m ._ ,{ [ number of-issues involving the Pilgrim Nuclear Power Station which are of
' concern to this committee, the Nuclear Regulatory Commission and to.me-i personally. At~ the outset let,.me stress that most of the issues raised:by-
' the NRC in various reports and by this committee were of concern to me more .
~
'than a year ago and that corrective actions were underway as early as September 1985. :As discussed'in the following pages, those actions are
- meeting with success.
.In today's environment, public concern about nuclear power is .
~ heightened substantially. Public confidence in the technology and'the institutions involved with it is at a ' low point. .
Boston Edison Company has a great deal'of work to do in this
' environment to gain public confidence in our ability to manage and run -
, P_llgrim. Station. I personally will >not be satisfied until we have achieved i a level of public and regulatory confidence that allows Pilgrirn Station to place among the best. We have made an internal commitment to measure ourselves against the best, which is a significant change in how we are J 7 approaching our current problems. 1 As will be evident in reviewing our testimony, we were historically plagued by not looking outside to measure our success and to undertake the I intensive self-criticism necessary to assess performance honestly and objectively. That has changed. He are moving in a.new direction, one based on rising standards of excellence which are set, not by regulation, but by i the' performance of those plants judged to be among the best. l
L p - H q It-.should be noted that-the concerns.we are addressing today are different from.those.for which we were fined in 1982. The issues then were safety-relatedland failure to comply with regulations. Today, the issues
'are not 'directly' related either to .co:npliance or: to safety. They instead E
. involve a rising, standard of performance going far beyond mer6 compliance
.with rules to a much; broader dimension in the regulatory process. That'new dimension is.one that. dictates. comparisons and success is measured by' relative performance, We endorse,it, j Before discussing our current activities, let me' offer perspectives on three time' frames.
a- .. { The first time frame is 1972 to'1979 and Three Mile Island. Our
. major.nianagement shortcoming then was the failure to recognize fully that the operational and managerial demands placed on a nuclear power plant are very different from:those of a conventional. fossil-fired power plant.
Boston Edison structured its nuclear organization as'part of a traditional operating arm. While many members of the Pilgrim Station organization :
, recognized the differences in the technologies, they had limited success in
. arguing for the resources necessary to meet a set of standards that already I were rising fairly rapidly. This was also a period of poor quality feel
.hich resulted in significant internal radiological problems that affected the' plant for years.
Then came Three Mile Island. From March 1979 until early 1962 the
'same structure, under one vice president, attempted to deal with the Dost-TMI demands on operations and engineering, while at the same time pursuing a construction permit for a second unit at Pilgrim Station. The staff increased dramatically to 200, 300 and then 400 people. It was an unreasonable workload for the structure and we paid a costly penalty for not
'ecognizing it -- $550,000 in early 1982.
~:
From 1982 until mid-1985, we operated with a'new and improved management structure that. recognized the unique nature of nuclear power _ plants _and the demands _of.the post-THI period. We committed.the financial and human resources necessary to upgrade equipment and hardware and to install various improvement programs to meet NRC concerns. More than
$300 million went into hardware improvements, the staff grew from 400 to ?
nearly 600 people and the organization was restructured under a senior vice president and two vice. presidents. We achieved a_significant measure of I Esuccess for which we.were recognized by the NRC and in the plant's
= outs.tanding operating performance in both 1983 and 1985.
But in managing.the equipment improvements and the new management. systems and programs we put in place, we didn't-focus enough on what was j going on outside the company in the industry and within the NRC. What we didn't see because we were so internally focused was the fact that the industry itself and the NRC were looking under, behind and around all of the ; hardware and management programs reaching for excellence. In our case, not seeing that put us in a defensive posture. We weren't identifying weaknesses that were inhibiting continued improvement L l ourselves. We weren't being self-critical, others had to tell us what was wrong. We weren't holding managers accountable enough for the end result of an action or inaction. We weren' t working well enough together. Those problems were very real, very serious and of great concern to me and to the Board of Directors.. I became particularly concerned about management performance, not management systems and programs, but the results of those systems and programs as measured by effectiveness. In mid-1985, I N -
, . - a 1
asked the Vice President of Nuclear Operations to investigate my concerns,
'(
)
which he shared, and issue a report. As he progressed through the study, he { { l i 1
and other managers began identifying needs. In September 1985, we increased the operator staff by a third. In December, we reorganized. plant management E to' improve reporting relationships and build in greater accountability, In February 1986, the NRC issued their report. They said the same thing: We had attitude problems that were seriously interfering with our ability to get the results we should be seeing given our financial and human resource commitments. By March, we had taken a number of other actions, all of which.are detailed (n 'the following pages. He began eliminating those old attitudes tha't were not serving us well and began to inject the nuclear organization with the skills and perspectives necessary to achieve a measure of j performance which would place us among the best. In the same time frame we made further human resource commitments. We increased our emergency planning complement five-fold, we increased the number of radiological technicians 35 percent and we implemented an apprentice program for the long-term development of skilled personnel. The shutdown on April 12 gave us an opportunity to accelerate that change. A different approach to problem solving was taken. It stressed a more deliberative and integrated . effort.at identifying root causes and taking corrective action. In early May, a new plant manager and a new J operations section head were brought on board, nearly rounding out a new 16 1 I member plant management team. Of the 16, 11 were new in their positions in . the past 8. months and 5 were new to the company. He h...e new perspectives. We have people with strong nuclear navy backgrounds, people with NRC inspection experience and people who grew up professionally not in conventional fossil-fired power plants, but in nuclear plants.
1
. l L
On May 27, having accepted that management is just as important as equipment, we took the unprecedented stao of giving the new plant manager and his new team additional time, while the unit was shut down, to become familiar with the issues, to accelerate the development of new programs and, most importantly, to infuse the organization with attitudes and behaHor that will make those programs work. These are attitudes that demand self-criticism, demand accountability, demand teamwork and demand results which go far beyond mere compliance witn a set of rules, regulations and technical specifications. Excellence is our goal. But excellence is, after all, an attitude which accepts nothing less. Achieving excellence will not be easy, we know that. We know our problems. We have made the human resource and financial commitment to solve them. We know what has to be done and we are doing it. As a result, I am confident we will, in time, demonstrate to you, to the Nuclear Regulatory Commission and the public that we have responded effectively to the concerns which are shared by all of us. As a final point, I know that an important question on the minds of many people is "why should Boston Edison be believed today given the problems over the years at Pilgrim Station?" I hope I already answered that question in part. It is perhaps the most difficult question and can or ly be answered fully by performance over time. But in closing I would underscore two major differences today from the past. The first is our forceful acceptance of the need for us to measure our performance against an ever increasing set of standards set by those plants ju4ed by industry and the NRC to be among the best. l l
.j g.[, -.6- -
1 J The'second is the fact that we have adopted.the basic principles 4. and' criteria.for good management that are applied to'..the nuclear navy. They
. are the'same' principles and criteria that are in: evidence at all.of the top rated plants.
1
.This'Is a demanding. industry with a vital' role in..the social.and {
economic' health of'the country. It. operates in a demanding regulatory- ! climate as evidenced by this hearing today.
~
For us as a company with a' - i i
- single unit to succeed in this environment means.that.we must impose'on' ourselves the highest standards of performance found in the industry. We-
. are doing just'that.
The balance of this filed testimony is arranged in the order of the six sections on which you requested information in your letter of July 2, 1986. We..have repeated your request at the beginning of each section. l i I l
I BOSTDN EDISCW
,i7: .* + ;" :e
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- r :- a was .: :a ,
palph G. Bird
- e-r, :e mes :e July 8, 1987
..: er BECo Ltr . 87--111 Mr. Steven A. Varga Director Olvision of Reactor orojects, I/II )
Unitea 5tates Nuclear Regulatory Commission Wasningtcn, O. C. 20555 License DPR-35 Docket 50-E93 INFORMATION REGARDING PIIGRIM STATION SAFETY ENHANCEMENT PROGRAM i
Reference:
NRC Letter, Drocosed Enhancement to the Mark I Containment - l Pilgrim Station, dated April 30, 1987 l
Dear Mr. Varga:
As agreed during July 1, 1987 discussions between Frank Miraglia, USNRC. i and Jonn Fulton..Soston Ecison Company (BECo), w are submitting th15 resconse to your letter to BECo catec Acril 30, 1987. Enclosed for your information is a detailed tescriotion of tne Safety Enhancement Drogram (SEP) hardware changes that BECo has voluntarily elected to implement for Pilgrim Nuclear .; Power Station (PNPS). The description of procecural changes and personnel training will be furnishec under secarate cover. A current implementation schedule for the SEP modifications will also be furnished separately. A ; condition is that the modifications scheduled during the current outage do not l recuire orier governmental accroval. $hould this concition not be met for any of tnese voluntary modifications, with the result tnat the current implementation s:nedule must De extenced, tnen SECo will be unable to ; implement the affected modifications curing tne current outage. ] Additional documentat i on will be availaole f r review by the NRC Staff at SECo's Braintre* offices or the PNPS site. Cognizant BECo personnel wili te available at tnose locations for discussion with tne Staff. Current evaluations of tne cerefit from the SEP modifications are based primarily ucon extensive, altnougn still preliminary, analyses and qualitat've engineering jaagments. Final quantitative analysis must, in accordance l with the statea long term goal of the SEP, await final identification of modifications anc cmoletion of the Indivicual Plant Evaluation (IPE). BECo understands tnat the NRC intends to issue later this year a generic letter recutring all plants to perform an IPE as part of the
l W- 3:e,99 .arja -:- Ju l .e 3. '"37 C 0SJre of the C;mmiti!:n : Seve#9 Accite" 20'/3:atinent. When 09u: j requirement 15 i35ued. 5E": ex:ects :c ::moie:e : e 'PE ano :reme::y make :ne resgits availaole in AC::r ance with :n6 revien Or0 cess pres:r10ed oy ne generi letter. Please feel free 0 contact me Or 2:. var: Howard, Of my staff at (617) 349-3900 'f jcu 9 ave any Oue'It'OnS 00r i'1i19 ~"9 Ta*0er a:0'e!Ied in :ni!
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R. u, d otr Enclosures cc: Nuclear Regulatory Commission Document Control Desk Washington, D. C. 20555 l Nuclear Regulatory Coctnission ;
- Region I i l 631 Park Avenue I King of Prussia, PA 19406 )
Senior NRC Resident Inspector Pilgrim Nuclear Pcwer Statien Mr. R. H. Wessman, Project Manager Division of Reactor Projects, I/II Of fice of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission j 7920 No #c1k Avenue 1 i Betnesda, MD 20814
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$d$rs/cm ufYanacAiae//> C2/C8 (1917) 7:7 7775 EXECUTIVE
SUMMARY
OF THE PROGRESS REPORT ON EMERGENCY PREPAREDNESS FOR AN ACCIDENT AT PILGRIM NUCLEAR POWER STATION I.. EXECUTIVE
SUMMARY
On' December 16, 1986, I transmitted to the Governor r comprehensive report-on safety at Pilgrim Nuclear Power Station. This is a progress report about the activities by state and local government, the Boston Edison Company, the U.S. Nuclear Regulatory Commission and the Federal Emergency Management Agency since that time to address the concerns we found. In April of 1986, operation of Pilgrim Station was halted because of several. mechanical problems. The U.S. Nuclear Regulatory Commission has ordered that the Boston Edison Company keep the plant shut until a variety of corrections.regarding the rmnagement and operation of Pilgrim Station have been made. As of this date, Pilgrim remains closed., although Boston Edison has asked the NRC for permission to restart the facility. In my December, 1986 report, I concluded that Radiological Emergency Response Plans for the Pilgrim facility were not adequate.to protect the public health and safety. I further identified serious problems regarding the management of the power plant End the engineering safety of the reactor. In my view, these three issues -- emergency planning, plant management, and reactor safety -- were so serious and the weaknesses and deficiencies so severe that I recommended that the plant should not be allowed to restart unless and until these concerns had been satisfactorily addressed. There has been a considerable amount of activity at all levels to address these concerns since my report was issued. In some cases substantial progress has been made. In particular, the Massachusetts Civil Defense Agency and Office of Emergency Preparedness has devoted all available staff and rescerces to the effort of developing the best possible emergency response plans.
MCDA/OEP has instituted a planning process at the state and. local level and revisions are well under way. In addition, a new system has been installed for off-site notification in the event of an accident at Pilgrim Station. We now have the advantage of a new Nuclear Safety Emergency Preparedness Program and a professional staff which for the first time is dedicated to off-site emergency preparedness and planning. This new program and staff are the result of the Governor's initiative in the Fiscal Year 1988 budget. I The Governor has requested additio,nal funds for the new program as a supplementary appropriation for the current fiscal year. Nonetheless, I continue to make the finding that adequate plans for response to an accident at Pilgrim Station do not exist, and I reaffirm my earlier position that the Pilgrim facility should not be allowed to restart until such plans have been fully developed and have been demonstrated to be workable and effective through a graded exercise of all plans and facilities. This finding is based on the fact that in every critical area in which I found a deficiency to exist in my December, 1986 report substantial work remains to be done before a determination of adequacy can be made. For example, analysis of a new Evacuation Time Estimate and Traffic Management Study by state and local authorities is still underway. The ETE is one of the most critical pieces of information in the entire process and the foundation of effective emergency planning. Our preliminary review of the ETE suggests that more resources are required to successfully implement the traffic management plan. The shelter survey which was prepared by Boston Edison has been returned to the company for further study because is was found to be woefully inadequate. Plans and implementing procedures for special needs populations remain incomplete, and it may be necessary to undertake an additional survey of people who would need assistance in emergency response or to do further statistical analysis of this matter. The development of implementing procedures and the identification of resources to care for school age populations also requires additional work. In regard to the adequacy of reception centers, the question of need for a facility to serve people in the northern portion of the EPZ remains open. We cannot make decisions on the need for or identification of a third reception center until Boston Edison has provided us with an analysis of the adequacy of the existing two reception facilities.
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E i With regard to plant management, we have seen numerous changes in Boston Edison's personnel and notable The most organization
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changeforis management of Pilgrim Station. Bird as Senior Vice the appointment of Mr. Ralph G. Nuclear, who directly reports to the company's
' President, Yet despite these changes, I cannot chief executive say at this For officer.the timeexample, management that we are concerned problems have been fully about recent resolved. !
incidents including violation'of NRC regulations in the area of plant-security, and allegations of excessive overtime worked:by utility employees. We are also concerned by Boston Edison's action to refuel Pilgrim Station without having ; responded to my objections and the objections of several state legislators. The Systematic Assessment of Licensee Performance (SALP) perfomed by the NRC is the most comprehensive studyThe andlast report on nuclear management at Pilgrim Station. i SALP report was issued on April 8, 1987 and it showed since deterioration in several aspects of nuclear managementUntil a similarly the last managementreport.under the new organization has been conducted our management and the above concerns resolved, I cannot say that concerns have been addressed. l With regard to reactor safety issues, we have carefully (SEP). l t reviewed Boston Edison's " Safety Enhancement Program" The SEP has been undertaken since the issuance of a " Draft Generic Letter" from Mr. Robert Bernero of the NRC concerning containment structures such as the Pilgrim i safety'at containment. Mark IWe have two major concerns in the area of reactor safety. j First, despite the fact that the NRC letter was prompted by a finding failurethat there was during a highsevere certain probability accident of Mark I scenarios, containment the NRC has yet to adopt an official position regarding safety enhancement. Moreover, according to NRC Region I Administrator William Russell, with whom my staff and other state officials met at NRC's regional offices in King of Prussia, Pennsylvania on October 8, 1987, enhancement of the Mark I containment at Pilgrim is not an issue that the NRC believes must be finally resolved before restart. to Our second concern is the uncertainty that continues exist about at least oneNo feature of the Boston Edison SEP, concensus has been reached on the direct torus vent. whether installation of the torus vent creates unreviewed
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e., safety issues or if the torus vent is authorized, how it will be used in the event of a severe nuclear accident. . The findings of my December, 1986 report have been strengthened by two other analyses of safety at Pilgrim Station. The Specia? Joint Legislative Commission to Study Pilgrim Station has issued its report which further In studies addition, and documents many of the same safety concerns. the Federal Emergency Management Agency has issued a Self-Initiated Review of plans for response to an accident at Pilgrim Station. Based on several of the issues raised in my report FEMA has changed its interim finding and now agrees that the off-site plans for an accident at Pilgrim are not adequate. FEMA has transmitted their new finding to the Nuclear Regulatory Commission. However, the 11RC has yet to indicate l i Whether or not development of adequate off-site plans will be a condition to the restart of Pilgrim. We are not satisfied with the view recently expressed by the NRC Region I staff that emergency planning problems must be " addressed" before
. restart. Such problems must be satisfactorily resolved before restart. Off-site response plans are just as important as nuclear management and reactor safety in protecting the public from an accidental release of radiation.
Therefore, for these reasons -- the absence of adequate emergency response plans, lack of demonstrable assurance that management problems have been solved, and uncertainty about the safety of the Mark I containment structure -- I continue to find that Boston Edison has not met the heavy burden of showing readiness to restart the Pilgrim Nuclear Power Plant. I also continue to believe that it remains to be seen if adequate emergency response plans can be developed and if all other saf ety issues can be resolved to our satisf action. Finally, I recommend that in light of the number of outstanding issues and their complexity, and Boston Edison's evident determination to press ahead with the effort to restart, that there should be a full scale public hearing by of the NRC before any decision is made regarding the restart Pilgrim Station. i October 14, 1987 CHARLES V. BARRY SECRETARY OF PUBLIC SAFETY I t 1051J. l
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h , THE COMMONWEALTH OF MASSACHUSETTS EXECUTIVE DEPARTMENT - C civil DEFENSE AGENCY ANb OFFICE OF EMEROENCY PREPAREDNESS b
,. 400 WORCESTER ROAO * ,,,, P.O. BOX 1496 TR ).; , FRAMINGHAM, MASS. 0t?O14317 ' MICHAEL S. DUKAKis ROBERT J. BOULAY
_.-CoVERNOR DIRECTOR ic-M t September 18, 1987 Mr. Ralph Bird
~ Senior Vice Pre.sident
- Boston Edison Company 800 Boylston Street Boston, Massachusetts i
Dear Mr. Bird:
My staff has reviewed the August, 1987 " Study to Identify Potential Shelters in EPZ Coastal Region of the Pilorim Nuclear Power Station," which was prepared for you by Stone and Webster. We find that.this study is deficient in several' respects and that additional work is required to provide.Information to local officials which is sufficient to support develonnent of-implementable shelter utilization plans. I have attached a 1 copy of a memorandum prepared by my staff which detaffs our : specific concerns regarding this study. If you have any questions or. observations regarding our evaluation, please contact Buzz Hausner of my staff. Thank you for your cooperation in this matter. 1 Sin - N tobegrt o - ulay A j Director ' Q cc: Assistant Secretary, Peter W. Agens, Jr. Deputy Director, John L. Lovering i Mr. Buzz Hausner 1
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' , ~ 'THE COMMONWEALTH OF MASSACHUSETTS A@#t 6#
EXECUtlVE DEPAR7 MENT N.h
. CWIL DEFENSE AGENCY AND OFFICE OF EMER0tNCY PREPAREDNESS 400 WORCESf(R ROAD */
I l P.O Box 1496 h % f rRAMINGHAM, MASS. 01101M17 g hAEL S. oVKAKis HoDERT J. BoULAY ! OOVEPINOg DintCTOR t *
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i L TO: . DIRECTOR BOULAY
,FROM: BU7 USNER .
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IN RE: SHELTER SURVEY OF PILGRIM EPZ PREPARED BY BOSTON EDISON COMPANY
.DATE: SEPTEMBER 11, 1987 -
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We have made a preliminary review o'f the shelter survey of the Pilgrim EPZ which was nrepared by the Boston Edison Company and its consultants. While this document compiles some very useful data, we feel that more work must be done to estimate the effectiveness of shelter as a protective action. Our principal concern is that we must be able to put data in the hands of local officials.which are sufficient for the development of shelter utilization plans for all areas of all five communities within the Pilgrim EPZ. With this in mind, we have the following comments. The survey only covers an area approximately one mile wide along the coast. The shelter capabilities of the entire EPZ must be surveyed and reported.
- The survey does not separate out those structures which could "most reasonably" be used as shelters from those '
where shelter is less appropriate. For instance it would help to have a separate list of public buildkngs and facilities for each town, including an estimation of the sctual useable shelter space and protectJve factors for shelter under government authority. Many of the shelt'ers listed, such as jewelry stores and pharmacies are, clearly not suitable for public shelter. In a severe emergency, every available resource will of course be put to use. However, to develop an implementable shelter utilization plan, local officials must be able to match estimated needs with the most appropriate resources available. t
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-: Regard [ng prot'ection. of the beach population, the
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',"_ survey;1dentifies shelters within.a mile of the coast
,1butfdoes "not : indicate the distances that beach goers
'W' p' , twould haVe'to travel.to find shelter. .In' addition, the !
"~ -survey'must demonstrate that adequate proximate shelter
' isTavailableifor the total population at the individual beaches.!
For' instance, Duxbury beach is about seven miles long and.the survey should indicate the distance peonle at
'Saquish Head are required to travel to reach adequate
' shelter. Further, an implementable shelter' utilization .
plan must demonstrate that the nearest shelter would
>0 not be full to capacity before the people at the most remote' points.of the' beaches arrived.
The survey must' identify adequate shelter which is handicapped accessible. The survey does not distinguish between available space ' and usable space. For instance, residents of Plymouth , have indicated to us that some basements listed in the I survey are no more than crawl spaces. Crawl spaces cannot.be considered for public shelter. Further,' in most buildings, a good deal of floor area will be occupied by machinery, counters, office furniture, et
. cetera. The survey must identify accurately the actual useable shelter space available in each structure.
Stone and Webster uses a FEMA nuclear attack value of ten square feet per person to estimate the potential population which can be sheltered. Local ~ Civil Defense .
^ Officials may wish to allocate more space -- uo to twenty square feet per person -- in their utilization plans. The value used in the survey overestimates the potential capacity of various buildings. We doubt.that 17,000 people can be sheltered at Duxbury High School, or that 89,700 can be sheltered at the 5 Cordage Park Buildings.
The survey must demonstrate that public shelters are free from asbestos and other environmental hazards. 1
'The' report' estimates residential " sheltering {
capability" in individual communities as between 53% f and 81%. These figures indicate that a significant number of residents do not have adequate domestic shelter and emphasize the need for a full study of public shelter capacities throughout the entire EPZ. l
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4 m . Further, even if it:can be established that the vast t , majority of' residences offer adeouate shelter,. local-officials must be prepared to offer public shelter of a known. protective capability to residents who demand 3 i assistance.. , This' report makes no definitive statement of what i
' constitutes adequate shelter't'o protect people from the j effects of a radioloolcal release ~from Pilorim Station. This 1s necessary to determine what I facilities are most appropriate.ror a 1 peal. shelter I e
utilization plan and to determine the public shelter j
., needs of each community. j In summ.ary, we w'ould say that this survey isla useful'beginning-
- but that much more work is required before we can assess our. !
ability to develop implementable shelter utilization plans
; consistent with the public safety concerns in Secretary Barry's report to the Governor.
cc: Assistant Secretary Peter W. Agnes,.Jr. -
' Deputy Director' John L. Lovering i
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Q. yes e eosamscw Executive offices 800 Boylston street - Boston, Massachusetts 02199 Ralph G Bird September 17,1987
- senior Vice President ", Nuclear BECo Ltr. #87 146 I
U.S.-Nuclear Regulatory Commission Document Control Desk Hashington,.D.C. 20555 Docket 50-293 License No. DPR-35 i
Subject:
Boston Edison. Company Request for Exemption from 10 CFR Part 50, Appendix E, Section IV.F.
Dear Sir:
In.accordance with 10 CFR'section 50.12(a), Boston Edison Company requests
-that the Nuclear Regulatory Commission (NRC) grant a one-time exemption from the requirements of 10 CFR Part 50, Appendix E, Section IV.F., that would
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authorize the next biennial full participation emergency preparedness exercise for the Pilgrim Nuclear Power Station (Pilgrim) to be conducted in the second . The schedule for future biennial exercises will not be ! p Lquarter of 1988.affected by this one-time exemption, but rather will continue to pro such exercises will be conducted every second year (LA, the following biennial exercise will be held in 1989). The proposed deferral of the full participation exercise has been discussed with the Commonwealth of Massachusetts (Commonwealth) and loc response officials. proposal. The request will not affect the onsite exercise at Pilgrim planned for December 9, 1987. l'
' The requested exemption is necessary because the
- (EPZ) and the two emergency reception center communities are at present engaged in implementing numerous improvements in their offsite These emergency preparedness programs, with the assistance of Boston Edison.
' improvements include revision of the emergency plans of the local governme revision of the Massachusetts Civil Defense Agency (MCDA) Area II plan as wel as the Commonwealth's state-wide plan, the development of revised related procedures, the development and implementation of training programs for officials and emergency personnel, and the upgrading of Eme Centers (EOC's).
'to accomplish these improvements, and the work is expected to continue thro the remainder of the year and early 1988.
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U.S. Nuclear Regulatory Commission Page 2 , s In view of these extensive ongoing efforts, the Commonwealth and the local governments have indicated that they are not able to participate in an exercise during calendar year 1987. Moreover, it is apparent that under these circumstances, conduct of the full participation exercise will be much more effective after the ongoing improvements have been implemented. In granting ! one-time exemptions authorizing deferral of exercises for licensed plants in the past, the NRC has recognized that the most effective and beneficial exercises are those which include the full-scale participation of State and local governments and that it is appropriate to defer an exercise until program revisions or facility improvements have been completed. Since the last full participation biennial exercise at Pilgrim, Boston Edison has. held an onsite exercise at Pilgrim in December 1986; has held quarterly onsite drills in March, June and August of 1987; and has scheduled its annual onsite exercise for December 9,1987 (in which the Commonwealth will exercise various offsite objectives as described in BECo Ltr. #87 -147
" Scheduling of Pilgrim Onsite Exercise"). The previous exercise and drills have included limited participation by the Commonwealth, and the Harch and June 1987 drills included limited participation by several of the towns. The towns within the EPZ have also cooperated in the full scale siren test reviewed by FEMA, which was conducted on September 29, 1986. In addition to its activities involving Pilgrim, the Commonwealth has also participated in full participation exercises at the Yankee Nuclear Power Station in June 1986 and is scheduled to participate in a full participation exercise at the Vermont Yankee Nuclear Generating Station during the week of November 29, 1987. ,
j This request meets a number of the special circumstances listed in Section 50.12(a)(2) . t First, granting the request will provide only temporary relief from the applicchle regulation and the licensee has made good faith efforts to comply with the regulation. Over the past year, Boston Edison has assisted Commonwealth and local authorities in a variety of ways to accomplish as many i improvements as possible in their offsite emergency response programs. For example, Boston Edison has developed substantive information for the . enhancement of those programs. The major products of this effort include the l
" Pilgrim Station Evacuation Time Estimates and Traffic Management Plan Update" l (August 18, 1987) prepared by KLD Associates, Inc. and "A Study to Identify l Potential Shelters in the EPZ Coastline Region of Pilgrim Nuclear Power Station" (August 1987) prepared by Stone & Webster Engineering Corporation, as well as information generated in surveys to identify the special needs and transportation dependent populations within the EPZ.
In addition, Boston Edison is providing assistance to the local governments in their offsite emergmcy program enhancement efforts in accordance with the Massachusetts Civil Defense Act of 1950 (Chapter 639, Section 15, Acts of 1950 as amended). This assistance includes the provision of two professional planners to work under the direction of the officials of each town within the EPZ in upgrading its plan, procedures and training; one
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'U.:S. Nuclear Regulatory Commission Page;3
, professional planner to assist each reception center community; and four professional planners working under the direction of MCDA in the upgrading sof the MCDA Area II and Commonwealth program. In the first half. of 1987, Boston Edison provided introductory emergency training to about 350 personnel within
,the five towns in.the EPZ and enhanced introductory training modules are
. currently being prepared for review by the MCDA prior to further l
' implementation. The planners prov*ded by Boston Edison have also begun to prepare task-based modules for. training of specific categories of emergency -
personnel and will b9 available to participate in the training programs. In I
- l. addition,' Boston Edison'is_ executing agreements with each of the five towns within the EPZ, as well as the two reception center communities, for assistance in the renovatior, of their E0C's. Moreover, four of the five EPZ l , towns and both reception center communities, to date, have accepted BECo's l ' offer of-funding support for full-time civil defense staff positions.
Second, literal compliance with the regulation would not serve its l underlying purpose and would result in undue hardship to Commonwealth and i local emergency response agencies by requiring an exercise of portions of the ; offsite emergency plans that are in the process of significant revision and ; improvement. This would necessarily involve disruption of the ongoing process of implementing these changes, and consequently, the imposition of additional
- costs and delay in accomplishing the planned improvements. The NRC's emergency exercise requirements. clearly were not intended to disrupt the orderly implementation of improvements in such manner.
Finally, because granting the request will allow work to proceed without ; disruption, it will result in a net benefit to the public health and safety.
.The NRC has acknowledged that flexibility is appropriate in applying emergency planning. requirements. This flexible approach is especially appropriate in ,
this case, where granting the request will facilitate more prompt and i effective implementation of improvements. For all these reasons. Boston Edison asks that NRC grant the requested enemption. In accordance with 10 CFR 6170.12(c), a fee of one hundred and fifty dollars ($150.00) will be electronically mailed to your offices. If you should require any additional information in connection with this request, please contact either myself or Mr. Ron Varley of my staff (telephone: 617 - 424-3832). [
, Ralph . Bird RAL/d1w l J
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Office of Nuclear Reactor Regulation ; j
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The Phillips Building . h/ Hashington, D.C. 20555 y
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Mr. R.H. Hessman, Project Manager s Division of Reactor Projects - I/II ' Office of Nuclear Reactor Regulation ' U.S. Nuclear Regulatory Commission .^ 7920 Norfolk Avenue Bethesda, MD 20814 Mr. Richard Krimm, Assistant Associate Director , FEMA 500 C Street - Federal Plaza ' Washington, D.C. 20472 { Hr. Edward Thomas / FEMA - Region 1 g J. H. McCormack Post Office and Court House 3 i Boston, MA 02109 ,c g. Mr. Peter Agnes, Jr. f)y') /-
' e Commonwealth of MA i Assistant Secretary of Public Safety 1 Ashburton Place - Room 2133 '
Boston, MA 02108 / U. S. Nuclear Regulatory Commission s
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Region 1 - 631 Park Avenue
' King of Prussia, PA 19406 .-
Senior NRC Resident Inspector . Pilgrim Nuclear Power Station Rocky Hill Road Plymouth, MA 02360 Henry Vickers, Regional Director ' FEMA - Region 1 ' J.H. McCormack Post Office and Court House Boston, MA 02109 6 ) a3
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