ML20154N393
| ML20154N393 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 05/27/1988 |
| From: | Fairtile M Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20154N398 | List: |
| References | |
| 2.206, NUDOCS 8806020286 | |
| Download: ML20154N393 (3) | |
Text
{{#Wiki_filter:- - _- . _ _ _ _ _ _ _ _ ,e . . 7590-01 UNITED STATES NUCLEAR REGULATORY COMMISSION DOCKET N0. 50-293 BOSTON EDISON COMPANY (PILGRIM NUCLEAR POWER STATION) ISSUANCE OF INTERIM DIRECTOR'S DECISION Notice is hereby given that the Director, Office of Nuclear Reactor Regulation, has issued an interim decision concerning a request filed pursuant to 10 CFR 2.206 by Governor Michael S. Dukakis and Attorney General James M. Shannon on behalf of the Comonwealth of Massachusetts and its citizens (Petitionersi. On October 15, 1987 the Petitioners requested the Director of the Office of Nuclear Reactor Regulation to institute a proceeding to modify, 1 1 suspend, or revoke the operating license held by Boston Edison Company (BECo) for its Pilgrim Nuclear Power Station (Pilgrim). In particular, the Petitioners requested the NRC to (1) modify the Pilgrim license to bar restart of the facility until a plant-specific probabilistic risk assessment (PRA) is perfonned and all indicated safety modifications are implemented; (2) modify the license to extend the current shutdown pending the outcome of a full hearing on the ' significant outstanding safety issues and the development and certification by the Governor of Massachusetts of adeauate emergency plans; and (3) issue an l Order, effective innediately, to modify the Pilgrim license to preclude the licensee from taking steps in its power ascension program until a formal l adjudicatory hearing is held and findings of fact are made concerning safety questions raised. The Director of the Office of Nuclear Reactor Pegulation has determined that the Petitien, with the exception of the management and emergency preparedness issues is denied. The portion of the Petition concerning licensee management and emergency prepareeness will be addressed in a subsequent response. M N
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-2 The reasons for this decision are explained in the "Interim Director's Decision Under 10 CFR 2.206, "00 7 , which is available for public inspection in the Comission's Public Document Room,1717 H Street, N.W.,
Washington, D.C. 20555 and the Local Public Document Room at the Plymouth Public Library, 11 North Street, Plymouth, Massachusetts 02360. A copy of the Decision will be filed with the Secretary for the Com!ssion's review in accordance with 10 CFR 2.206(c). As provided in this ; regulation, the Decision will constitute the final action of the Comission twenty-five days (25) after issuance, unless the Comission, on its own
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motion, institutes review of the Decision within that time period. Dated at Rockville, Maryland, this dav of May 1988. FOR THE NUCLEAR REGULATORY COMMISSION i
. $C %$
Morton B. Fairtils, Acting Director l Project Directorate I-3 Division of Reactor Projects I/II i l l l
_2 l l The reasons for this decision are explained in the "Interim Director's l Decision Under 10 R 2.206, "DD , which is available for public inspection in the Commission's Public Document Room,1717 H Street,'N.W., ' Washington, D.C. and the 1.ocal Public Document Room at the Plymobth Public
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Library,11 North Street, Ply' mouth, Massachusetts 02360. That portion of the N ' j Petition concerning management an'd emergency preparednes_s will be addressed in
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a subsequent response. / A copy of the Decision will be filed with the/7 Secretary for the
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I Commission's review in accordance with 10 CFR 2/206(c). As provided in this '
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regulation, the Decision will constitute the f,inal j action of the Commission twenty-five days (25) after issuance, unle,s's th Commission, on its own motion, institutes review of the Decision /withinthat \ time period. Dated at Rockville, Maryland, this
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day of March 1988. j \
/ FOR THE NUCLEAR REGULATORY COMMISSION l l l' l
N s b Richard H. Wessman, Director Project Directorate I-3 Division of Reactor Projects I/II
*See previous concurrence
- 0FC :PDI-3 * :PDI-3: :DIR/PDI-3 : : : !
.. ___:..__________:_____ .. ___: ...._______:__ .______.:____._______:.____ ____. :__.._______ 1 NAME :MRushbrook :DMcDonald :RWessman :
.___.:.__________:____________:__...___.....g/__g__::.__________.:__...______:___________ . .
DATE :03/09/88 :03/ /88 :03/ /88 // * / t 0FFICIAL RECORD COPY 1
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2 The reasons for this decision are explained in the "Interim Director's-Decision Under 10 CFR 2.206, "DD-88 7 , which is available for public inspection in the Commission's Public Document Room,1717 H Street, N.W., Washington, D.C. and the Local Public Document Room at the Plymouth Public Library,11 North Street, Plymouth, Massachusetts 02360. That portion of the , i Petition concerning management and emergency preparedness will be addressed in j a subsequent response. A copy of the Decision will be filed with the Secretary for the Comission's review in accordance with 10 CFR 2.206(c). As provided in this regulation, the Decision will constitute the final action of the Comission twenty _five days (25) after issuance, unless the Comission, on its own motion, institutes review of the Decision within that time period. Dated at Rockville, Maryland, this y ay of March 1988. FOR THE NUCLEAR REGULATORY COMMISSION r Morton B. F i le, Acting Director Project Directorate I-3 Division of Reactor Projects I/II
*See previous concurrence OFC :PDI-3 * :PDI-3: :DIR/PDI-3 : : : ,
..._ _ : .... O4?_ _ _ : _ _ hyp,,$t : _ _ ggg. :____......__: .......___.:.............___________ , NAME :MR6's b k :DMcDonald :RWessman : : ..___:..... h__:............:._____......:....__...___:.__________:...____.....:.........__ DATE:03/09/8 :@/, /88 :07/ /88 : : : 5]m 0FFICIAL RECORD COPY gg l
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Director's Decision - 10 CFR 2.206 - Attorney General James M. Shannon, Commonwealth of Massachusetts Distribution: DocketFile-50-293w/incomingletteronly(( NRC PDR Local PDR EDO # 003245 ED0 Reading T. Murley/J. Sneizek F. Miraglia AD/ Region I - B. Boger R. Wessman H.-Rushbrook D. Mcdonald E. Trottier D. Mossburg, PMAS (ED0 ! 003245) PD I-3 Reading D. Hagan V. Stello Docketing & Service - 16H-3 (6 w/2 copies.of incoming) J. Lieberman, OGC-ASLAB ASLBP ACRS (10) J. Resner (2) (W-501) cc: Licensee .'w/ incoming petition) Service L'st
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/g* "G W (c, UNITED STATES l E' i NUCLE AR REGULATORY COMMISSION WASHING TON, D. C. 20555
%. ./ August 21, 1987 Dockat No.: 50-293 The Honorable William B. Golden Massachusetts State Senate Boston, Massachusetts 02133
Dear Mr. Golden:
This letter is ir, further response to your Petition of July 15, 1986, requesting that the Nuclear Regulatory Comission (NRC) order the Boston Edison Company to show cause why the Pilgrim Nuclear Power Station should not remain closed or have its operating license suspended by NRC. The basis for this request was (1) numerous deficiencies in licensee management, (2) inadequacy of the existing rad'ological emergency response plan, and (3) inherent deficiencies in the facility's containment structure. As you may recall, you were notified in a letter dated August 12, 1986, that your Petition would be treated as a request of action pursuant to 10 CFR 2.206 of the Comission's regulations. The staff has concluded its evaluation of the information contained in the Petition concerning items (2) and (3) and for the reasons stated in the enclosed "Interim Director's Decision under 10 CFR 2.206," your Petition, with the exception of the management issue, has been denied. That portion of the Petition covering the management issues will be addressed in a subsequent response. A copy of this decision will be filed with the Secretary for the Comission's review in accordance with 10 CFR 2.206(c). As provided in 10 CFR 2.206(c), this decision will become the final action of the Comission in 25 days, unless the Comission determines to review the decision within that time. I have also enclosed a copy of a notice that is being filed with the Office of the Federal Register for publication. Sincerely,
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Thomas E. Murley, Director - Office of Nuclear Reactor Regulation
Enclosures:
- 1. Director's Decision 87-14
- 2. Federal Register Notice cc: See next page E
t t l CC: Mr. K. P. Roberts, Nuclear Operations Boston Edison Company Pilgrim Nuclear Power Station ATTN: Mr. Ralph G. Rird Boston Edison Company Senior Vice President - Nuclear RFD #1, Rocky Hill Road 800 Boylston Street Plymouth, Massachusetts 02360 Boston, Massachusetts 02199 Resident Inspector's Office Mr. Richard N. Swanson, Manager U. S. Nuclear Regulatory Commission Nuclear Engineering Departrent Post Office Box 867 Boston Edison Company Plymouth, Massachusetts 02360 25 Braintree Hill Park Braintree, Massachusetts 02184 Chairman, Board of Selectmen 11 Lincoln Street Ms. Elaine D. Rabinson Plymouth, Massachusetts 02360 Nuclear Information Manager Pilgrim Nuclear Power Station Office of the Commissioner RFD #1, Rocky Hill Road Massachusetts Department of Plynouth, Massachusetts 02360 Environmental Ouality Engineering One Winter Street Ms. J. Rachel Shimshak Boston, Massachusetts 02108 Massachusetts Public Interest Research Group Office of the Attorney General 29 Temple Place 1 Ashburtnn Place Roston, Massachusetts 02111 19th Floor Boston, Massachusetts 02108 Mr. Richard W. Krimm Mr. Robert P. Hallisey, Director Assistant Associate Director Radiation Control Program Office of Natural and Technological Massachusetts Department of Hazards Programs Public Health Federal Emergency Management Agency 150 Tremont Street, 2nd Floor Washington, D.C. 20472 Boston, Massachusetts 0?lli Regional Administrator, Region i U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pennsylvania 19406 Mr. James D. Keyes Regulatory Affairs and Programs Group Leader Boston Edison Company 25 Braintree Hill Park Braintree, Massachusetts 02184
t 4 7590-01 I UNITED STATES NUCLEAR REGULATORY COM'ilSSION BOSTON EDISON COMPANY pfLGRIM NUCLEAR POWER STATION DOCKET NO. 50-293 NOTICE OF ISSUANCE OF INTERIM DIRECTOR'S DECTSTON Notice is hereby given that the Director, Office of Nuclear Reactor Regulation, has issued an interim decisinn concerning a reouest filed pursuant to 10 CFR 2.206 by the Honorable William B. Golden which requested that the Pilgrim Nuclear power Station remain shut down or have its license suspended because of (1) deficiencies in the licensee management, (2) inadequacies in the emergency radiological plan, and (3) inherent deficiencies in the containment structure. The Director of the Office of Nuclear Reactor Regulation has determined that the Petition, with the exception of the license management issue, should be denied. The reasons for this decision are explained in the "interim Director's Decision Under 10 CFR 2.206." DD-87-14, which is available for public inspection in the Commission's Public Document Room,1717 H Street, N.W., Washington, DC and at the Local Public Document Room at the Plymouth Public Library,11 North Street, Plymouth, Massachusetts 02360. That portion of the Petition concerning licensee management will be addressed in a subsequent response. A copy of the Decision will be filed wit.h the Secretary for the Commission's review in accordance with 10 CFR 2.206(c). As provided in this regulation, I the Decision will constitute the final action of the Commission twenty-five gyg-14-6 ' A la %pp.
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(2fi days after issuance, unless the Comission, on its own motion, institutes review of the Decision within that time period. Dated at Bethesda, Maryland, this 21st day of August 1987. FOR THE NUCLEAR REGULATORY C M ISSION Project Directorate ,I-3 Division of Reactor Projects 1/II 4 I i
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i ( ) l 00-87-14 i l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Dr. Thomas E. Murley, Director In the Matter of ) i Docket No. 50-293 BOSTON EDISON COMPANY ) (Pilgrim Nuclear Power Station) ) (10 C.F.R. 62.206) INTERIM DIRECT 0P'S DECISION UNDER 10 C.F.R. 6 2.206 INTRO 0VCTION On July 15, 1986, Massachusetts State Senator William B. Golden and others (Petitioners) filed with the Nuclear Regulatory Commission a Petition requesting thet the Director require Boston Edison Company (BEco, the licensee) to show cause why the Pilgrim Nuclear Power Station should not remain closed or have its operating license suspended by NRC until the licensee demonstrates that the issues raised by the Petitioners have been resolved. The Petitioners also requested that NRC require the licensee to submit a feasibility study related to certain structural modifications and that the NRC schedule a public hearing to address the issues raised by the Petitioners. The Petitioners assert as grounds for their request (1) numerous ; deficiencies in the licensee's management (2) inadeouacies in the existing ! radiological emergency response plan, and (3) inherent deficiencies in the facility's containment structure. The Petitioners assert that "the deficiencies cut a broad swath across the spectrum of safety requirements" and that, in the i aggregate, these deficiencies compromise the reliability of the most important i safety systems in the plant. Further, the Pe'titioners assert that the licensee ! and the NRC have failed to resolve these safety issues, wnm . l
i 1 l l l 1 On August 12, 1986, James M. Taylor, then Of rector of the Office of Inspection and Enforcement, acknowledged receipt of the Petition. He inforrned the Petitioners that the Petition would be treated under 10 CFR 2.206 of the Comission's regulations and that a formal decision would be issued within a reasonat'le time. Notice of receipt of the petition was published in the Federal Reaister (51 FR 29728). On December 19, 1986, Mr. Taylor provided further response to the Petitioners in a letter to Senator Golden. He stated it would be more l meaningful to fomally respond to the Petition after (1) the licensee has had an opportunity to address the issues outlined in the Petition and (2) the NRC has had an cpportunity to review the licensee's actions. He also stated (1) l i l that the Pilgric Station will not be permitted to restart until the NRC detemines that there is reasonable assurance that the public health l and safety will be protected and (2) that the staff will consider the manage-ment, emergency planning, and containment issues raised by the Petition. Dr. Thomas E. Murley, then Regional Administrator of NRC Region I, sent additional letters regarding the Petition to Senator Golden on February 20, and April 1, 1987 The February 20 letter acknowledged that a meeting with the Petitioners had been delayed because the NRC first wanted to have available i i the licensee's report documenting why the licensee believes the Pilgrim Station l can be restarted. The April 1 letter was in response to the Petitioners' letter of February 25, 1987, regarding a meeting between NRC and the Petitioners. Dr. Murley's April 1 letter provided clarification regarding the proposed meeting with Petitioners; it also noted that ' het olant has remained shut down
t f/ ! l and that considerable changes had occurred, and continue to uccur, in the substantivs bress outlined in the Petition. On August 5,1987, Massachusetts Public Interest Research Group (MASSFIRG) submitted "Health Surveillance of the Pilgrim Area" as an addendum to the Petition. This report provides results of the Massachusetts Department of Public Health (MDPH) study to determine whether there is excess risk of certain adverse health outcomes among residents in the comunities surrounding the Pilgrim Station. The data revealed no disturbing trends ir, ebber the patterns of cancer mortality or in the expression of low birthrate and infant mortality, but indicated higher than expected incidence of leukemia. As stated in the M0pH study, radiation monitoring records did not suggest any significant levels of radiation that could have potentially exposed the residents in the communities surrounding the Pilgrim Station. The report was the result of a descriptive, first step epidemiolooitdl study which acknowledged ma.ior gaps in understanding the relationship, if any, between the occurrence of leukemia and the Pilgrim Station. Consequently, no further consideration of this report by the NRC is merited at this time. For the reasons discussed below, Petitioners' request insofar as it relates to the emergency preparedness and containment issues is denied. A final decision with respect to the management issues is deferred, However, to the extent Petitioners are reouesting that Pilgrim remain shut down until the NRC is satisfied that management and emergency preparedness issues are dealt with to the Comission's satisfaction, the Petition is granted. Petitioners also request that "the NRC, prior to making a decision I pursuant to issuing an operating license suspension, schedule a comprehensive public hearing to address the issues raised by the Petitior,ers herein d (Petitionat39). In respo.se to that reouest, the NPC staff has agreed to l l
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T i f. .. n l meet with Senator Golden and other petitioners to discuss the issues raised in the Petition as well as the overall status of NRC regulatory activities at Pilgrim when the licensee has completed those actions necessary for restart of the plant. In addition, the Commission intends to hold a public meeting to be briefed by the Staff on the readiness of Pilgrim to resume operations before allowing restart. The filing of a 2.206 Petition, however, does not require the NRC to hold formal evidentiary hearings with respect to issues raised by the Petition. Illinois v. U.S Nuclear Regulatory Commission, 591 F.2d 12, 14 (7th Cir.1979); Porter County Chapter of the Izaak Walton League of America, Inc. v. Nuclear Regulatory Conmission, 606 F.2d 1363 (D.C. Cir. 1979); Wells Eddleman, et al. v. Nuclear Reoulatory Commission No. 87-1018, slip op, at 5 (4th Cir. August 10,1987); Lorion v. Nuclear Regulatory Commission, 785 F.2d 1038 (D.C. Cir.1986). See also Florida Power & Light Co. v. Lorion, et al. , 740 U.S. 729 (1985). BACKGROUND T5e 'O staff found the overall performance at the Pilgrim Station acceptable during the assessment period covered by the Systematic Assessment
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- 1 of Licensee Performance (SALP No. 85-99). M There was sufficient concern, however, about the facility's performance that Region I conducted a special in-depth Diagnostic Team inspection from February 18 to March 7,1986 (Inspection Report No. 50-293/86-06, issued April 2,1986). The team found that improvements were inhibited by (1) incomplete staffing, particularly operators and key nid-level supervisory personnel; (?) a prevailino (but incorrect) view in the organization that the improvements made to date had corrected the problems; (3) reluctance, on the par'. of the licensee's management, to acknowledge some problems identified by the NRC; and (4) the l
licensee's dependence on third perties to identify problems rather than implementing an effective program for self-identification of weaknesses. Nonetheless, in a letter from Region I to the licensee dated May 23, 1986, the ; Diagnostic Team insoection results confirmed the SALP Board conclusions for SALP No. 85-99. In that letter, Region I rastated its belief that
"... performance in the operation of the facility was found acceptable although some areas were only minimally acceptable."
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'-1/ This Decision refers to two SALPs. The first is identified as SALP No. 85-99 arid relates to the licensee's perfomance during the period October 1, 1984 - October 31, 1985. The report of this SALP was initially issued by Region I on February 18, 1986. It was the subject of further correspondence dated May 23, 1986, between Region I and BECo. The second SALP ts identified as SALP No. 86-99 and relates to the licensee's performance during the period November 1,1985 -
Jansary 31, 1987 The report of this SALP was initially issued April 8, 1987 It was issued as a final report on June 17, 1987
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1 On April 12, 1986, the licensee shut down the Pilgrim Station because of equipment problems and operational difficulties. The NRC Regional Administrator acknowledged this shutdown in Confirmatory Action Letter (CAL) 86-10, which was issued that same date. On July 25, 1986, the licensee stated that the facility would remain shut down for the completion of various modifications and for refueling. In an August 27, 1986, letter to Mr. J. Lydon of BECo, Dr. Murley stated that, although the licensce's actions in response to CAL 86-10 appeared to be thorough, additional issues had been identified that had to be resolved before restart of the facility. These issues included certain technical issues (overdue surveillances, malfunction of recirculation pump motor generator field breakers, seismic qualification of emergency diesel operator differential relays, and completion of Appendix R modifications) and progrannatic matters (the licensee's action plan for improvements, the role of the licensee's safety review connittees, and the readiness of the plant and corprate staffs to support restart). Further, Dr. Murley stated in the same lette", "In light of the number and scope of the outstanding issues, I am not prepared to approve restart of the Pilgrim facility until you provide a written reoort that documents BECo's fmnal assessment of the readiness for restart operation." At this time, the Pilgrim Station remains shut down. The staff i
- i. catly issued SALP Report No. 86-99 (April 8, 1967). Although this report identifies a number of perfonnance problems (as did the previous SALP report), i the staff believes the licensee is beginning 'to effectively deal with these
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problems and is making progress toward improving their performance. For ex-ample, changes have been made to the radiological controls program, decon-tamination is in progress, fire protection modifications are being completed, and various surveillance, maintenance, and modification issues are being resolved. Offsite emergency planning issues have been evaluated by the Federal Emergency Management Agency (FEMA). These are reported in a FEMA report entitled, "Self-Initiated Revievi and Interim Finding for the Pilgrim Nuclear Power Station," dated August 4,1987 The licensee has stated that the facility is not expected to be ready for restart before the end of September 1987 NRC has asked the licensee to submit a readiness assessment report at least 45 days before the planned restart of the plant. On July 30, 1987, the licensee submitted a report entitled "Pilgrim Nuclear Power Station Restart Plan." This Plan describes a portion of the programs, plans and actions i considered necessary by BECo management for safe and reliable restart and operation of Pilgrim. Portions of the Plan will be updated six weeks before BEco's proposed restart and final results will be submitted three weeks before the proposed restart. The Plan is currently under staff review. A specific discussion of each of the three areas addressed in the Petition follows, i l l l l l l
1 i l l l DISCUSSION l l l A. Management The Petitioners allege numerous deficiencies in the MeanMe's management. The Petition essentially states that (1) competent management is critical to t ensure the safe operation of any nuclear power facility; (?) the licensee's management of the Pilgrim Station is deficient; and (3) long-standing management deficiencies at Pilgrim Station have not been corrected. As a basis for their Petitien, the Petitioners have provided an extensive list of management deficiencies that have been docurvnted in NRC inspection and SALP reports. The areas of concern include: plant operations, radiological I controls, onsite energency preparedness, maintenance and modifications, surveillance testing, security and safeguards, refueling and outage manageinent, licensing activities and fire protection. The basic documents relied on by the Petitioners were SALP Report No. 85-99, issued February 18, 1986, and the Special NRC Diagnostic Team Inspection Report issued on April 2,1986. In addition, the Petitioners referred to the 1982 Civil Penalty and Order modifying the Pilgrim license, and to news accounts of statements by Conrnissioner James Asselstine to the effect that Pilgrim is one of the worst run and least safe plants in the nr tion. At the time the Petition was filed, the NRC felt the licensee had not
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successfully dealt with the problems that were identified in (1) the enforce-ment actions taken in 1982, as evidenced by S' ALP No. 85-99, and (2) the 3
. s Diagnostic Team inspection findings. Although the licensee liad instituted programs intended to improve management and had made progress at certain times and in specific areas (such as in engineering and technical support), the letter transmitting SALP No. 85-99 expressed NRC's concern about the licensee's apparent "inability to improve performance, or sustain improved perforwance once achieved." Several management changes have taken place in the licensee's organiza-tion since early 1986. The station manager was replaced on May 1,1986, and was replaced again on February 1,1987 On July 1,1986, the Senior Vice President-Nuclear was transferred. At that time, the Chief Operating Officer assumed the respnnsibilities of the Senior Vice President-Nuclear, which he held until February 20, 1987, when the current Senior Vice President-Nuclear (Ralph G. Bird) assumed the responsibilities of this position. On March 26, 1987, the Chief Operating Officer and the Executive Vice President / Chief Financial Officer announced their intent to retire within the next year. On April 10,1987, the Vice President for Nuclea Operations resigned; his responsibilities are being managed by the Senior Vice President-Nuclear, and a replacement has not been hired at this date. The NRC has monitored management issues at Pilgrim Station since SALP No. 85-99 and the Diagnostic Team inspection. The most recent SALP evaluation, SALP No. 86-99, issued April 8,1987, states: "The lack of a clear
a 1 organizational structure, recurring management changes, and chronic staffing vacancies delayed the establishment of a stable licensee management team at the plant and inhibited progress during the assessment period." Starting with CAL 86-10, issued April 12, 1986, the NRC has taken steps to ensure the Pilgrim Station will not restart until adequate corrective actions have been taken. On July 30, 1986, Dr. Murley, at a meeting with the licensee, infomed the licensee that, even when the technical issues set forth in CAL 86-10 were resolved, he would not approve restart of the plant until the management issues discussed in SALP No. 85-99 also were resolved. In addition, on August 27, 1986, in a letter to the licensee, Dr. Murley stated that rr.. tart of the Pilgrim Station would not be approved until the licensee femally documented and NRC reviewed (1) an assessment of the licensee's readiness for plant restart and (2) a restart program and schedule including well-defined hold-points at discrete milestones. The NRC agrees with the Petitioners that sijnificant management defi-ciencies have existed at Pilgrim Station. The NRC is continuing to observe and evaluate the licensee's performance through ongoing inspections, bimonthly management meetings with the licensee, and the SALP prncess. The NRC will conduct an independent team review of the licensee's actions in response to , the SALP findings and the findings of the Diagnostic Team inspection of February-March 1986. The NRC will evaluate the Pilgrim Restart Plan and other information to detemine whether the issues raised by the Petitioners, including management issues, have been adequa'tely resolved.
1 5 5 l II - Because the Pilgrim Station is currently shut down and will not be ) allowed to restart until authorized to do so by the NRC, there is no additional sefety assurance to be gained by granting Petitioners' request. Thus, the management deficiencies at the Pilgrim Station do not warrant a Show Cause Order for the facility to remain closed or have its operating license suspended. A final Director's Decision regarding management issues cannot be rendered until the management deficiencies have been suitably addressed by the licensea and the staff completes its assessment. This portion of the Petition will therefore be addressed in a subsequent final decision. B. Radiological Emergency Response Plan The Petitioners allege inadequacies in the existing Radiological Emergency Response Plan (RERP) for the Pilgrim Station. The Petitioners essentially state that there are deficiencies in (1) the RERP, (?) the procedures for providing advance infomation to the public, (3) the systems for notification of the public during an accident, (4) the evacuation plans, (5) available medical facilities, (6) the size of the emergency planning zone, and (7) the coordination and prioritization of the RERP. The emergency response plans for Pilgrim Station were submitted in response to the NRC requirements that resulted from the issuance of a revised emergency preparedness rule on August 19, 1980 (45 B 55402). After the
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revised rule was issued, FEMA reviewed the State and local response plans for the Pilgrim site and evaluated the March 3,1982 joint full-participation exercise. On the basis of this review and eva'iuation, FEMA's Region I office issued interim findings in a report entitled, "Joint State and Local Radiological Emergency Response Capabilities for the Pilgrim Power Station, Plymouth, Massachusetts," dated September 29, 1982. In this report, FEMA concluded that the Massachusetts State and local emergency plans and preparedness for coping with the offsite effects of radiological emargencies that may occur at the Pilgrim Station were adequate to protect the public. With regard to the onsite portior, of the March 3,1982 exercise, the NRC detemined that the emergency response actions taken by the licensee were adequate to protect the health and safety of the public. Since that time, the licensee has participated in additional emergency preparedness exercises where onsite and offsite response capabilities were demonstrated and evaluated by the NRC and FEMA. The most recent full-participation exercise was conducted on September 5,1985. A remedial exercise, held on October 29, 1985, demonstrated that four deficiencies identified during the September exercise had been corrected. As a result, FEMA Region I concluded that there was reasonable assurance that appropriate offsite action can be taken in the event of a radiological emergency to adequately protect the public health and safety. The relevant portions of the Petition relating to emergency preparedness were transmitted to the FEMA staff on August 4,1986, and the NRC requested on August 11, 1986, that FEMA raview offsite emergency planning
and preparedness issues raised in the Petition. On December 22, 1986, the Secretary of Public Safety of the Comonwealth of Massachusetts sent FEMA a copy of the Office of Public Safety report entitled, "Report to the Governor on Emergency Preparedness for an Accident at the Pilgrim Nuclear Power Station," dated December 1986. The Secretary of Public Safety also asked FEMA Region I to review a report entitled, "Evaluation of Offsite Emergency Preparedness in the Area Surrounding the Pilgrim Nuclear Power Station," dated January 1987, which was prepared for the licensee by the Impell Corporation. On January 14, 1987 FEMA informed the NRC that the requests for a review of these reports micht delay the completion of the FEMA evaluation of the issues raised in the Petition. In a memorandum to NRC dated March 31, 1987, FEMA stated that it was also conducting a self-initiated review of the overall l state of emergency preparedness at Pilgrim Station. FEMA said that it would ! prepare a consolidated evaluation that would address the Petition issues, the report submitted by the Office of Public Safety, the Impell report, FEMA's self-initiated review, and other relevant available information. FEMA comitted to make the production af their evaluation report a priority task. By memorandum dated April 29, 1987, the NRC provided FEMA with a copy of a report prepared by the Town of Plymouth Nuclear Comittee entitled, "Report to the l Selectmen on the Plymouth Radiological Emergency Response Plan," dated March 1987, and asked FEMA to include this report in the ongoing review. On June 4,1987, BECo prepared reports reoarding Evacuation Time Estimates and Beach Population Sheltering, Mo'bility Impaired, and Special
c i Facilities. One June 12, 1987, BECo prepared a report regarding a Northern Reception Center. NRC forwarded these reports to FEMA on July 1, 1987 On August 6,1987, FEMA forwarded their August report entitled, "Self-Initiated Review and Interim Finding for the Pilgrim Nuclear Power Station, Plymouth, MA," to the NRC. This report included FEMA's iluly 29, 1987, analysis of the issues raised in the subject petition entitled, "Analysis of Emergency Preparedness Issues at Pilgrii Nuclear Power Station Raised in a Petition to the NRC Dated July 15, 1985." In their analysis FEMA individually addressed each of the seven issues in offsite emergency planning raised in the subject Petition and one-by-one found that the information in the Petition did not sustain the Petitioners' contentions when compared to the record at the time the Petition was reviewed. For convenience, FEMA's detailed analysis is provided as Attachment A to this Director's Decision. On the basis that FEMA's analysis of the Petition's specific issues did not sustain the contentions, this portion of Petitioners' request is denied. This denial notwithstanding, the Coninission acknowledges that FEMA agrees with the general thrust of some of the conclusions of the Petition for reasons cited in FEMA's Self-Initiated Review and Interim Finding dated August 4,1987 Based on this latter report, FEMA has concluded that offsite radiological emergency planning and preparedness for Massachusetts are inadequate to protect the public health and safety in the event of an sceident at the Pilgrim Nuclear Power Station. The issues that FEMA identified as a basis for this conclusion were:
- 1. Lack of evacuation plans for public and private schools and daycare centers.
- 2. Lack of a reception center for people evacuating to the north.
- 3. Lack of identifiable public shelters for the beach population.
- 4. Inadequate planning for the evacuation of the special needs population.
- 5. Inadequate planning for the evacuation of the transportation dependent population.
- 6. Overall lack of progress in planning and apparent diminution in energency prepa-edness.
In summary, while this portion of Petitioners' request is denied,sthe emergency planning issues identified by FEMA are a matter of serious concern. The detennination whether to restart the Pilgrim plant will involve, in necessary part, consideration of the resolution of emergency planning issues identified by FEMA. C. Containment Structure The Petitioners allege that there are numerous deficiencies in the General Electric (GE) Corpany Mark I containment structure. The Petitioners assert that the GE Mark I presssure-suppression system employed by the Pilgrim reactor contains inherent design flaws that raise questions about its ability to with-stand accidents. Generally, the concerns relate to (1) design issues raised by Dr. S. H. Hanauer in the early 1970s, (21 the Chernobyl accident, and (3) the capability of the Pilgrim containment to withstand severe accidents. These are addressed below. However, before discussing the adequacy of the Pilgrim con-tainment it would be useful to describe the design philosophy and licensing ; requirements, which are the basis for reactor containments in the United States. l l l l l l
- 1. BACKGROUND Containment structures are an integral part of the US reactor designs in that they form one part of a structured tiered approach to public safety known as defense in depth. Concisely put, defense in depth is the process imple-mented by the AEC (later NRC) to ensure that multiple levels of assurance and safety exist to minimize risk to the public from nuclear plant operation.
A primary level of assurance are those activities to ensure that the plant is designed and constructed to high auality standards. Guidance on plant desion is provided in the Code of Federal Regulations and specified in the General Design Criteria (GOC). Specific infomation is provided in the NRC's Standard Review Plan (SRP) which details acceptable methods for complying with the requirements established in the GOC. Early in the development of commercial nuclear power it was reccgnized that these complex systems could not be expected to be immune from various failures and malfunctions, regardless of the quality of design, construction, and operation. Therefore, a further level of defense was established in that the plants were required to be designed for successfully coping with various equipment failures, transients and postulated accidents. The scenarios for postulated accidents, to which all plants are c:esigned to adequately respond, are known as design basis accidents and are detailed in the NRC's Standard Review Plan, which is used to evaluate the design of each nuclear power plant prior to the granting of a construction permit or operating license. Design basis accidents were chosen to represent a wide spectrum of plant problems, some of which were expected to be experienced in the plant lifetime (such as failure of power systems), as well as events considered to be quite infrequent (such as major ruptures of piping systems).
Details of these design basis accidents are found in Chapter 15 of the NRC Standard Review Plan, which also identifies acceptable plant protection standards for each postulated plant ar.cident. The requiremnts and capabilities of plant safety systems necessary to p event these design basis accidents from leading to unacceptable radiological releases are specifically identified. Guidelines for juoging the acceptability of the analytical results in response to these hypothetical scenarios are specified in NRC regulations. The plant design guidance required as a result of this approach results in the incorporation of multiple and backup safety systems which will protect the reactor during the postulated failures of these various protection devices. Notwithstanding the above, additional margins are required in the plant design to protect the public even in the event of very unlikely accidents. The reactor containment provides an additional level of safety. Design basis accidents for containment reflect a number of arbitrary accident secuences developed from postulated events. For example, the containment structural design is based upon the effe:ts of a concurrent earthquake and a rupture of major reactor coolant system pioing. Concurrently, in order to assess the effectiveness of leaktightness, the safety systems are presumed to not be effective in cooling the reactor core resulting in the release of fission products from the reactor core. Although the design basis accidents discussed above are allowed to result in some failed fuel (less than one percent), they do not result in core damage. For the containment design, some independent failures of the protection systems are assumed to occur simultaneously with the occurrence of the accident they are intended to control. While the purpose of other safety systems is to shut down the reactor fission process and provide
emergency cooling water to the reactor core, the containment has a required function of providing an essentially leaktight barrier to "bottle up" any radioactive material released to the containment through any rupture or break in the reactor coolant system. Given the release of the radioactive material and cooling wter, the containment is required to retain this material and prevent significant releases to the environment. Consequently, the assessment of containment design adequacy assumes the postulated release of fission products to the containment irrespective of the perfonnance of the core cooling safety systems. While design basis accidents are used to detemine the adequacy of plant systems' design and performance, a set of additional assumptions is imposed to further presume that these systems will not work as designed. The containment design basis reflects a contination of parameters incorporating several desion basis accidents for structural considerations coupled with an assumed release ' of radioactive material to containment for assessing leaktightness, 1 In sumary, the original design purpose of the reactor containment was to 1 protect against postulated radioat tive releases from hypothetical reactor i accidents'up to and including major ruptures of reactor coolant piping, where ' l such events resulted in some degree of core damage. These hypothetical events j l postulated a release of fission products from the reactor core to the reactor coolant system and subsequently into the containment through the pipe break. This was considered one of the less likely, but possible accidents and i l provided a straightforward means of providing additional margins for containment design. i j l l l
One must also consider the concept of severe nuclear accidents and how they fit within the framework of protection from design basis accidents. U For the last several years, as part of the NRC's efforts to continually evaluate and increase power plant safety, we have been studying the likelihood and consequences of extremely low probability incidents with attendant higher estimates of core damage and higher radiological releases from the core. This class of accidents is beyond the existing design basis and is known generally as severe accidents. This was first dcne comprehensively by the Reactor Safety Study (WASH 1400), which is known as a probabilistic risk assessrent (PRA1. The type of accidents studied in this evaluation are basically those whera multiple backup safety systems fail, eventually resulting in damage to the nuclear fuel and considerable releases of radioactive material outside of the reactor cooling system. Depending on other failures and containment behavior, significart radiologicel releases into the environment could conceivably occur. Implicit in these scenarios is the development of a better understanding of containment performance and its failure mechanisms. More detailed PRA studies have been conducted since the publication of WASH 1400 to better understand the probability of these unlikely events and also to better predict the magnitude of potential radiological releases into the environment, given a containment failure and attendant consequences. Considerable work has also focused on the behavior of reactor containments fol-lowing a severe accident where molten reactor fuel could potentially melt through the reactor vessel. Results of such studies have generally confirmed
-2/ Severe accidents are defined as those "in which substantial damage is done to the reactor core, whether or not there are serious offsite consequences." This definition is extracted from the "Policy Statement on Severe Reactor Accidents Regarding Future Designs and Existing Plants,"
50 Fed. Rea. 3?138, August 8, 1985.
= __
. b the very low likelihood of such accidents and relatively low risk to the public even if such very low probability accidents were to occur. While not originally designed to protect against some of the severe accidents, reactor containments provide considerable benefit from their ability to reduce radiological releases to the public from such accidents. For example, the t'esults of research work indicate that the actual pressure retaining capability of most containments is well above heir original design pressures. Studies also indicate that the massive containment structures may provide considerable retention of radioactive material even if they were to fail following a core melt event. As discussed in Section C.4, there exists considerable uncertainty regarding a Mark I containment's behavior during a core melt accident. A recent study judged the probability of some form of containment failure, assumino a core melt had occurred, to be between 10 and 90 percent. E Due to the very complex processes involved in a severe reactor accident, exact predictions of accident consequences are difficult. Considerable research isunderway to give us additional information in this area. Results from such studies allow us to focus our attention in areas where improvements can be made to provide increased levels of safety from these very unlikely events. The purpose of these projects is to conduct hypothetical "what if" studies, to understand ways public risk from nuclear operations can be justifiably reduced, i Even though we strive to reduce public risk further, results of our studies indicate that risk from these severe accidents are very low and do not warrant l l E The Reactor Risk Reference Document - Draft (NUREG-1150).
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l
immediate actions. More information on the adequacy of the Pilgrim containment and its adequacy with respect to severe reactor accidents is provided in Section C.4 For background information purposes, a brief description of the Pilgrim Mark I Containment Design is provided in Attachment B. A discussion of the historical problems and the specific three assertions regarding deficiencies in the Mark I design is provided below. Section C.2 will address the Hanauer issues, Section C.3 will address the Chernobyl issues and Section C.4 will provide additional information on the Pilgrim containment's acceptability from a perspective of severe accident risk.
- 2. Hanauer Issues The Petitioners have expressed concerns that are based on memoranda written before 1978 by the staff of the Atomic Energy Commission (AEC) and the NPC (which succeeded the AEC in 1975). These concerns relate to the ability of the Mark 1 containment to respond adequately to its original design function l l
(i.e., deal with a large loss of coolant accident). The key document cited is { a memorandum written by Dr. S. H. Hanauer on September 20, 1972. This document raised seven concerns, all of which centered on the viability of the pressure-suppression containment concept. Portions of four of th.ese concerns have been either directly or indirectly quoted in the Petition; they relate to steam-bypass susceptibility, valve reliability, lack of adequate testing, and volume limitations causing overcrowding, i i
When Dr. Hanauer's seven concerns were raised, the staff evaluated each of them to determine whether adequate safety margins were being maintained on existing plants. Subsequently, the NRC staff concluded that Dr. Hanauer's concerns had been properly considered, and documented its findings in NUREG-0474, "A Technical Update on Pressure Suppression Type Containments in Use in U.S. Light Water Reactor Nuclear Power Plants," issued in July 1978. Enclosure A to NUREG-0474 sumarizes NRC staff actions related to each of the seven concerns identified in Dr. Hanauer's memorandum of September 20, 1972. For convenience, a copy of that enclosure is provided as Attachment C to this response. Each statement of concern was followed by a response that reflected the NRC evaluation. In each case, the response showed that the NRC no longer considered the concern an unresolved safety issue, it should be noted that while the concern reflected the views of Dr. Hanauer in September 1972, the NRC response reflected the status of the issue in July 1978 Moreover, by June 1978, Dr. Hanauer had changed his opinion regarding his 1972 concerns, as reflected in a memorandum dated Jure 20, 1978 in which he stated: "Thus while we may yearn for the greater simplicity of ' dry' containments, the problems of both ' dry' and pressure suppression con-tainments are solvable, in my opinion, and the design safe, therefore licensable" (NUREG-0474), i
Our review of the Petition issues that are based on correspondence dated 1978 or earlier indicates that all of these issues have been addressed in NUREG-0474 Although various changes have occurred since then, the fundamental safety conclusions stated in NUREG-0474 are essentially unchanged. The most notable of the changes has been the NRC position related to inerting the con-tainment.Al Since NUREG-0474 was issued, the regulations relating to this issue (10 CFR 50.44, "Standards for Combustible Gas Control Systen in Light Water Cooled Power Reactors") have been revised to require all Mark I and II containments to be inerted. The response to Dr. Hanauer's concern (see Item B of Attachment C to this responsel indicates that nost Mark I containments were already inerted. Pilgrim was inerted at the time NUREG-0474 was published; however, the reason for inerting was restricted to Design Basis Accident (DRA) considerations. With the issuance of the revised 10 CFR 50.44, the Commission required all Mark I and II containments to be inerted to accommodate the de-graded core accident. Therefore, although the revision did not cause any immediate change to the Pilgrim plant operation, the change did alter the basic NRC requirements in this area. A review of this and other changes made since NUREG-0474 was issued indicates that, in no case, have the changes altered the fundamental staff conclusions concerning safety contained in NUREG-0474 The Petition references statements from NUREG-0474 that relate to differences between expected experimental results and actual test results. 4/ An inerted containment is on'e in which oxygen is replaced by enough nitrogen to preclude combustion. T
, .- - - , - , - - , - . _ . . .,- ,,, - - , ~ . - --
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The Petitioners state that surprises repeatedly occurred during the course of the various, then-ongoing, test programs. The statements extracted from NUREG-0474 were made during 1978 when many of these test programs were in their early stages. These test programs were initiated by utilities owning Mark I plants as part of a program in response to NRC lette s that were transmitted in February and April 1975 to all utilities owning BWR facilities with Mark I design containments (including the licensee). The letters requested that the owners quantify the hydrodynamic and safety-relief valve (SRV) discharge loads and assess the effect of these loads on the containment. (These loads had not been considered during the licensing of the individual plants because these loads (including pool swell) were identified in the period 1972 through 1974 as part of the review of the large-scale testing of the Mark III containment system design.) As a result of these letters from the NRC and recognizing that the evaluation effort would be very similar for all Mark I BWR plants, the utilities (including the licensee) formed an ad hoc Mark I Owners Group. The objectives of this Owners Group were to determine the magnitude and significance of these l i dynamic loads as quickly as possible and to identify actions to resolve any 3 1 outstanding safety concerns. A series of generic test programs was created to accomplish these objectives. Since NUREG-0474 was issued in July 1978, the generic test programs ! related to the Mark I containment design and the NRC assessment of the tests have been completed. The staff evaluation of the generic tests programs was reported in NUREG-0661, "Mark 1 Containment Long Tenn Program Safety Evaluation
- 2 Report,"-issued in July 1980. NUREG-0661 describes and presents staff con-clusions regarding the generic techniques for the definition of suppression pool hydrodynamic loads in a Mark I system and the related structural acceptance criteria. As part of the acceptance criteria, the staff required a plant-specific analysis.
The licensee performed a plant-specific analysis on the Pilgrim Station. The licensee submitted the Plant Unioue Analysis Report (PUAR) of the Suppression Chamber - Mark I Containment Long-Tenn Program (TR-5310-1) on October 27, 1982, and the PUAR of the Torus Attacled Piping - Mark I Contain-ment Long Term Program (TR-5310-2) on October 26, 1983. On the basis of this analysis, the licensee proposed design changes to restore the intended safety margins. (The intended margin in this context simply means that the structural margin that was computed without consideration of the hydrodynamic and SRV loads would remain unchanged when the loads are included and the modifications compl eted. ) The staff reviewed these changes and approved them in a Safety Evaluation Report issued January 30, 1985 The modifications have been imple-mented and the licensee has demonstrated that the Pilgrim containment is capable of accocinodating design-basis accidents with adequate margin. The Petition refers to another concern which can be considered as related to Dr. Hanauer's concerns. The concern focused on the safety dis-advantages of pressure-suppression contairments. This issue is related to the possibility of steam bypassing the suppression pool in BWR pressure-suppression containments, and was designated as Generic l's sue 61, "SRV Line Break Inside the Wet Well Airspace of Mark I and 11 Containments." An evaluation of this issue
was recently completed, and the results were presented in NUREG/CR-4594, "Estimated Safety Significance of Generic Issue 61," which was issued in June 1986. On the basis of these results, the staff concluded that no new requirements were justified and, on the basis of an overall risk assessment, no further study of this safety issue was warranted. In summary, the Petitioners have asserted that the pressure-suppression containment design is flawed from the perspective of its original design function and they have questioned the viability of this containment type. We have shown that many of their specific concerns, and in particular those issues raised by Dr. Hanauer, were previously and satisfactorily addressed in NUREG-0474 and in various generic issues programs. For those concerns identi-fied since NUREG-0474 was issued, generic programs were conducted to determine the magnitude of the design loads under investigation and the licensee, based on the program results, implemented design changes at Pilgrim to reestablish acceptable structural design margins. Consequently, these concerns are resolved.
- 3. Chernobyl Accident The Petitioners express concern regarding the threat of a Chernobyl-type event at the Pilgrim Station as part of an overall reference to severe accidentr.
Immediately upon learning of the event at the Chernobyl plant in the ! Soviet Union, the NRC fonned a task force to thoroughly evaluate the accident j i
to learn as much as possible about its causes, cours', and consequences. The results of this effort were published in NUREG-1250, "Recort on the Accident at the Chernoby1 Nuclear Power Station." NUREG-1250 was prepared collaboratively by the NRC, other United States Government agencies, and other groups. l Within the next few weeks, the NRC plants to issue for public connent a ) report entitled, "Implications of the Accident at Chernobyl for Safety Regulation of Commercial Nuclear Power Plants in the United States," NUREG-1251 (August 1987). The facts of the Chernobyl accider.t relied on for this report are drawn from NUREG-1250 and its scurces. NUPEG-1251 presents an assessment of the implications, with respect to a number of U.S. reactor safety regulatory issues. The issues selected for evaluation were those associated with significant factors which led to or exacerbated the consequences of the Chernobyl accident. Issues covered are in the areas of administrative controls and operational practice, design, containment, emergency plannino, and severe accident phenomena. Nothwithstanding important design differences between the Chernobyl reactor and U.S. comercial reactors, the findings from these reports add to our understanding of some of the phenomena that may be involved in a severe nuclear accident and provide some additional insights useful in guiding our severe accident programs. The findings and assessments provide us with conclusions regarding the vulnerability of plants such as Pilgrim to a Chernobyl-type event. l l The Chernobyl accident was initiated by serious operator violations of safety procedures. However, the ensuing reactor damage resulted from basic design features of the RMBK 1000 reactor which are specifically prohibited
in fr., reactors. The RM8K reactor design does not use large steel reactor pressure vessels with water as a moderator, such as are employed in the US designs. Rather, the RMBK utilizes a graphite moderated pressure tube concept. For some conditions or modes of operation this design has an undesirable characteristic known as a positive void coefficient. A positive void coefficient treans that, for reactor incidents where rapid power increases vaporize cooling water in the pressure tubes, a further power increase is incited. This is known as negative control stability, and occurred so quickly at Chernobyl that the operators or safety systems had no opportunity to respond and an explosion resulted. In violation of operating procedures, some safety systems had also been deactivated. The RMBK design also possesses a slow acting safety control rod system, which further contributed to the event. As nuclear power was being developed in the United States, the importance of control stability and specifically negative void and negative power co-efficients were recognized. The nuclear cores of US reactors are specifically designed to prevent the power instability which caused the Chernobyl accident, and also include f ast acting safety control rod systems. Fully complying with these design criteria, Pilgrim responds to an increase in voiding by a power reduction due to the inherent physics of its design. Additionally, it is worth noting that the accident at Chernobyl was exacerbated by the graphite fire which resulted. Since Pilgrim does not utilize graphite in its design, the concerns associated with a graphite fire are not applicable. Also of note is the fact that the reactor at Chernobyl is surrounded b'y a confinemnt structure as opposed i i to a containment, as in Pilgrim. The differences in design relate to the basis ' l
- . s l
l 4 of the pressure retaining capability of the two structures. The Pilgrim reactor containment would be expected to withstand an internal pressure resulting from an energy release many times the energy release that the Chernobyl reactor confinement could (by design and in fact) withstand. As discussed above, the steam explosion in the reactor core, which ruptured the reactor core and surrounding building, was caused by a nuclear physics design vulnerability specifically prevented by the Pilgrim design. Due to that and other factors discussed above, wo find that the contentions of the Petitioners regarding Chernobyl are without merit.
- 4. Cajajlity of the Pilgrim Containment to Withstand Severe Accidents The Petitioners raised concerns regarding the possibility that the Pilgrim containment might fail in the event of a severe accident. The Petitioners assert that there is a tendency to underestimate the probability of various types of accidents; they cite, among other things, the recent accident at Chernobyl (see previous section). The Petitioners also conclude that there is a high probability that Pilgrim's Mark I containment structure will not stand various severe accident scenarios.
As discussed at the initial introduction to this section (C.1), the NRC views probabilistic risk assessment as a structured method for investigating the likelihood and consequences of reactor accidents considered to have a very low frequency of occurrence. The perceived inability of the Pilgrim l l l l l l
; 'o l
i containment to survive a severe acciden't was identified by the Petitioners as a design flaw. The evaluation of severe accident vulnerability involves three distinct evaluations. First, the probability of an accident involving core damage. Second, the likelihood of containment failure and third, an assessment of the radiological consequences and public doses resulting from the accident. All three issues must be considered in making a determination on the magnitude of severe accident risk and what actions should prudently be taken to reduce those risks. The studies which have been conducted emphasize that the results inherently possess large uncertainties. The draft results of NUREG 1150 present the most recent program, whose intent is to accurately reflect the severe accident risk at a number of US nuclear power plants, and also to properly reflect the areas of uncertainty. This study included an evaluation for Peach Bottom, a plant quite similar to Pilgrim in reactor design and containment. The study pre-sented the estimated mean frequency of core damage to be approximately cne chance in 100,000 per year of operation. Another comprehensive risk study conducted for the Limerick plant estimated a mean core damage probability of 1 in 10,000. These results are consistent with NRC's belief that core melt accidents are very unlikely. Draft NUREG 1150 also investigated the probability of early containment failure following a core melt. This study concluded that or ability to accurately predict the response of'a Mark I containment was limited
i o l for situations where it was subjected to the harsh temperature and pressure conditions following a core melt accident. As stated earlier, the report indicated that contaiment failure probability (for these extremely unlikely events) could likely range from 10 to 90 percent. These uncertainties are currently the subject of research efforts to better predict the behavior of containments during severe accidents, so that a more complete risk perspective can be assembled for guiding our regulatory activities. However, it is important that these uncertainties be properly characterized. They are not identified deficiencies in the BWR Fbrk I con-tainments, which have been demonstrated to satisfy their design performance requirerents (see Hanauer issues, Sec. C.2). Rather, these uncertainties are areas which guide our research investigations, whose goals are to provide improved understanding of very unlikely risk situations at nuclear power facilities. Results from these studies (including high containment failure probabilities) also allow us to calculate public risk estimates assuming that one element of the three which go into a risk assessment (containment failure) is less favorable. Even allowing the large uncertainties which result in a high upper value for containment failure, the NUREG 1150 study estimated that the probability of a large reactor accident that results in 1 or more early fatalities ranged ! from 1 in one million to 1 in one billion. Given a severe accident, the prob- l abilities of very high radiation exposure and the distances over which they would occur were also estimated to be reasonably small. The risk levels for Pilgrim would of course depend on its actual core nelt probability, containment
w behavior, the local demography, and could vary somewhat from the results presented in NUREG 1150. The results of this and related studies do, however, suppor+ Sur overall conclusion of low severe accident risk at the Pilgrim utility. One con-tributing factor is the issue mentioned in Secticn C.1, that the massive reactor containment structures may retain considerable radioactive material following a core melt even if its pressure boundary is failed. In this regard, containment failures include cracks or other phenomena that result in loss of pressure integrity that can result in leaks but should not be viewed solely as catastrophic failure of the containment structure. Plateout and deposition of material within containments, even though there may be leakage, also increase the tima available to implement effective evacuation activities. While we believe that severe accident risks are low at operating nuclear 1 plants, our goal is to pursue additional activities to achieve even lower levels of public risk. To assure that our risk conclusions are applicable to all operating units, a number of programs are going forward to assess severe accident likelihood and consequences. The.a programs include plant specific studies to determine any severe accident vulnerabilities, both from the per-spective of accident frequencies and from containment performance following a core melt. Any problems will be dealt with if identified. This program is known as the individual plant examination (IPE) program which is expected to conmence later this year. These and related programs will be conducted to provide further assessments of severe accidents on a plant specific basis, so that appropriately low risk levels can be maintained.
On July 25, 1986, the licensee announced that it is voluntarily considering implementation of certain modifications to enhance the Pilgrim Station containment capabilities. In an April 30, 1987 letter from S. Varga to R. Bird, NRC asked the licensee to provide details of the modifications and procedural changes. We have received the licensee's response dated July 8, 1987 and it is currently under review. The NRC does not view any of these modifications as necessary before the plant restarts. The NRC staff will review these modifications to ensure that they do represent overall safety improvements er.d that they have no overall adverse safety impact on existing systens. The Petitione*s also recuested that the NRC require the licensee to submit a feasibility study on all possible structural modifications before NRC approves specific modification proposals. At the present tine, neither the licensee, nor the staff, nor the Petitioners have identified any structural modifications to the Cilgrir containment that would be warranted by severe accident considerations. Therefore, this reouest for a feasibility study is denied. The Petitioners' assertions with respect to inherent design flaws in the pressure-suppression system utilized at the Pilgrim plant have been addressed above. The licensee has implemented modifications to re-establish Pilgrim's intended containment design margins (see the discussion on the Pilgrim PUAR). Evaluations of the Mark I containment with respect to severe accidents are continuing through (1) the implementation of the Comission Policy Statement 1 on Severe Accidents, (2) the NRC staff and industry dialogue to improve l containment severe accident performance for all BWRs, and (3) the licensee's voluntary initiative.
e 6 As indicated in the discussion on the Mark I cantainment, the Petitoners have not presented sufficient evidence to indicate that the Pilgrim Station should not operate while risk-reduction improvements are being considered. That is, there is not sufficient evidence of either design flaws at Pilgrim or high risk to warrant a Show Cause Order for the plant to remain closed or to suspend the operating license. Therefore, this portion of Petitoners' request is denied,
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~h 'O CONCLUSION The NRC has required, and will continue to require, that the Pilgrim facility remain shut down until the management and emergency preparedness issues are dealt with to the satisfaction of the NRC. For the reasons discussed above, a decision cannot be made at this time regarding the management issues. This portion of the Petition will be addressed in a subsequent response. For the reasons discussed above, the information identified by the Petition does not warrant the initiation of the requested proceedings in regard to the radiological emergency response plan. Based on the FEMA evaluation of the emergency preparedness issues raised by the Petitioners, the ; Petitioners' request for action pursuant to 10 CFR 2.206 on this issue is denied. However, in view of FEMA's interim finding that Massachusetts offsite radiological emergency planning and preparedness are inadequate to protect the public health and safety, the Comission will consider, among other issues, corrective actions regarding emergency planning issues identified by FEMA before pennitting the restart of the Pilgrim Plant. For the reasons discussed above, the infonnation identified by the i Petition does not warrant the initiation of the requested proceedings in regard
.* b to the containment issues. Accordingly, the Petitioners' reouest for action pursuant to 10 CFR 2.205 on this issue is denied. As provided in 10 CFR 4 2.206(c), a copy of this Decision will be filed with the Secretary _ for the Commission's review. FOR THE NUCLEAR REGULATORY COMMISSION r- ,- --- ,- )? . Thores E. Hurley, Directbr' Office of Nuclear Reactor Regulation Attachments: A. FEMA Analysis of Petition's Contentions B. Mark I Conteinment Design C. Summary of Staff Actions Related to Hanauer Issues Dated at Bethesda, Maryland this 21st day of Aug.1987. l
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l I 1 i
ATTACH liENT A g l -
\%s/) O O ANALYSIS OF EMERGENCY PREPAREDNESS ISSUES l
AT PILGRIM NUCLEAR POWER STATION RAISED IN A PETITluN TO THE NRC I UATED JULY 15, 1986 JULY 29,1987 l I FEDERAL EMERGENCY MANAGEMENT AGENCY JOHN W. McCORMACK POST OFFICE AND COURTHOUSE BOSTON, MASSACHUSETTS 02109-4595
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TABLE OF CONTENTS P_Agt 1-3 SECTION 1 - INTRODUCTION.......................... 3-4 SECTION 11 -
SUMMARY
5-49 SECT ION !!! - FEMA AN ALYSIS . . . . . . . . . . . . . . . . . . . . . . . APPENDICES: 1 ANALYSIS REPORT OF EMERGENCY PREPAREDNESS ISSUES AT PILGRIM NUCLEAR POWER STATION RAISED BY THE MASSACHUSETTS PuBLIC INTEREST GROUP (MASSPIRG) FEMA, NOVEMBER 6, 1983 2 ANALYSIS REPORT ON ISSUES RELATED TO THE PILGRIM EVACUATION IIME ESTIMATE FOR PILGRIM NUCLEAR POWER PLYMOUTH, MASSACHUSETTS, FEMA, MAY 1, 1984 STATION 3 MASSACHUSETTS CIVIL DEFENSE AGENCY (MCUA) ANALYSIS TO THE MASSACHUSETTS PuBLIC INTEREST RESEARCH 6ROUP (MASSPIRG) REPORT "BLUEPRINT FOR LHAOS 11', JULY 20, 1983 4 1986 EMERGENCY PUBLIC INFORMATION (EPI) BROCHURE FOR P!LGRIM EPZ 5 BOSTON EDISON'S RESPONSE ON THE PETITION DATED OCTOBER 29, 1986 6 COMMONWEALTH OF MASSACHUSETTS POLICY ON DISTRIBUTION OF POTASSIUM 10DIDE (KI) 7 SEPTEMBER 5, 1986 FEMA LETTER TO COMMONWEALTH OF MASSACHUSETTS REQUESTING ITS VIEWS CONCERNING THE ALLEGATIONS IN 1HE PETITIONJ AND INDICATING , THAT FEMA WAS UNDERTAKING A SELF-INITIATED REVIEW J OF THE ABILITY OF THE STATE TO PROTECT THE PUBLIC IN THE EVENT OF AN ACCIDENT AT PILGRIM l l l j
1 INTK00VLil0N ON JULY ls, 1930, MASSACHUSETTS 3TATi 3ENATOR SOLDEN, 3 TATE 3EPRESENTATIVES HYNES AND -!LDT, THE MASSACHUSETTS t DUBLIC INTEREST nESEARCH 6ROUP (MASSPIRG), THE PLYMOUTH COUNTY NUCLEAP lNFORMATION COMMITTEE, INC. (PCNIC), THE PLYMOUTH ALLIANCE AND ATTORNEYS Jo ANN SHOTWELL AND JAMES SHANNON FILED A PETli!ON WITH THE NUCLEAR REGULATORY COM-MISSION (NRC). IHIS PETITION REQUESTED THAT THE NRC ISSUE AN ORDER TO THE 00STON EDISON COMPANY,
...T3 SHOW CAUSE AS TO WHY THE P!LGR!M I NUC. EAR HowER 3TATION ("U IL3 RIM") SHOULD NOT 4EMAIN CLOSED AND/OR HAVE ITS OPERATING LICENSE SUSPENDED SY THE NRL UNLESS AND UNTIL THAT TIME AT 4HICH THE LICENSEE DEMON-STRATES CONCLUSIVELY TO THE NKC AND THE PUBLIC: (1) THAT ITS MANAGEMENT IS NO LONGER HAMPERED BY THE DEFICIENCIES NOTED BY THE PETITIONER $; (2) THAT THE KAD10 LOGICAL EMER-GENCY KESPONSE PLAN FULLY COMPLIES WITH 10 CFk 550 47 AND 10 LFR 500 57, !$ GivEN HIGH ORGANIZATIONAL PRIORITY AND SUFFICIENT FUNDING BY THE LICENSEE, THE FEDERAL EMERGENCY MANAGE-MENT AGENCY (FtMA), THE MASSACHUSETTS CIVIL UEFENSE AGENCY (MCDA) AND LOCAL GOVERNMENTS; AND (3) THAT THE INHERENT DESIGN FLAWS NOTED BY THE PETITIONERS dHICH RENDER PILGRIM ,
l's CONTAINMENT STRUCTURE EXTREMELY VULNERABLE l I IN MOST ACCIDENT SCENARIOS HAVE BEEN OVERCOME TO THE EXTENT THAT THE PUBLIC HEALTH AND SAFETY dlLL BE ASSURED. ON AUGUST 11, 1986, NRC FORWARDED A COPY OF THE PETITION j TO FEMA FOR INFORMATION AND INITIAL REVIEW. IKEN, ON. f 1 OCTOBER 16, 1986, NRC FORMALLY REQUESTED THAT FEMA EVALUATE f THE OFF-SITE EMERGENCY PLANNING AND PREPAREDNESS ISSUES
' RAISED IN THE PETITION. IHl$ [$ A REPORT OF THAT EVALVA-Tl0N.
1-
a . l l 2- l IHE PETITION IDENTIFIED SEVEN ALLEGED DEFICIENCIES IN EMER-GENCY PLANNING (LISTED AS NUMBERS 14 THROUGH 20 IN THE PETI- ! T10N) AS FOLLOWS: 14 OEFICIENCIES IN THE RADIOLOGICAL EMERGENCY j KESPONSE PLAN (REMP) 15 UEFICIENCIES IN ADVANCE INFORMATION 16 UEFICIENCIES IN NOTIFICATION UURING AN ACCIDENT 17 UEFICIENCIES IN EVACUATION PLANS 18 DEFICIENCIES IN IlEDICAL FACILITIES 19 THE Ef;E RG E NC Y PLANNING ZONE IS TOO SMALL 20 LACK OF COORDINATION AND PRIORITIZATION OF THE KERP UN SEPTEMBER 5, 1986, FEMA SENT A LETTER (SEE APPENDIX 7) TO ROBERT BOULAY, U! RECTOR, MASSACHUSETTS Civ!L DEFENSE AGENCY WITH A COPY TO BOSTON EDISON REQUESTING THE!R VIEWS CONCERNING THE ALLEGATIONS IN THE PETITION AND FURTHER DEVELOPMENT OF PROCEDURES FOR CORRECTING ANY PLAN DEFICIENCIES WHICH MAY EXIST. FLNR ALSO SENT A LETTER TO SENATOR GOLDEN REQUESTING A TRANSCRIPT OR DETAILED NOTES OF A JUNE 18, 1986 MEETING AT THE STATE HOUSE CONCERNING THE EMERGENCY RESPONSE PLANS FOR THE PILGRIM PLUME EXPOSURE EMERGENCY PLANNING 2ONE, I WHICH WOULD HELP US IN OUR REVIEW OF THE PETITION. l IHE 80STON EDISON COMPANY PROVIDED INFORMATION USED IN RE-VIEWING THIS PETITION. BOSTON EDISON'S WRITTEN RESPONSE IS ATTACHED AS APPENDIX 5 THE STATE INDICATED THAT IT HAD NO i
'o I
COMMENTS ON THE PETITION. WE UNDERSTAND THAT NO TRANSCRIPT j WAS MADE OF THE MEETING AT THE $ TATE HOUS.E, AND FEMA nAS, l THEREFORE, RELIED ON ITS OWN NOTES AND RECOLLECTIONS OF THE MEETING. THE ANALYSIS OF THESE ISSUES WAS PREPARED BY FEMA REGION I WITH THE ASSISTANCE OF THE ARGONNE NATIONAL LA B O R A T O R Y , BASED UPON ORAL INPUT FROM NASSACHUSETTS CONCERNING THE CONTENTS OF THE PETITION; PREVIOUS dRITTEN AND ORAL INPUT FROM MASSACHUSETTS CONCERNING THE ISSUES COVERED BY THE PETITION; RESPONSES PREPAR-ED BY fthA TO A PREVIOUS NAbSPlKb PETITION; F'hA t REVIEWS OF THE MASSACHUSETTS RERPJ AND OF EXERCISE REPORTS FOR THE EXERCISE OF THE MAD 10 LOGICAL EMERGENCY RESPONSE PLANS FOR THE PILGRIM NUCLEAR POWER STATION IN 1982, 1983, AND 1985 ON DECEMBER 30, 1986, FEMA WAS PROVIDED A COPY OF A REPORT CONCERNING THE MASSA-CHUSETTS PLANS TO PROTECT THE PUBLIC [N THE PtLGRIM EPZ. THE REPORT WAS PREPARED BY THE SECRETARY OF PuBLIC SAFETY AND ENDOR-SED BY MASSACHUSETTS GOVERNOR DUKAKIS (HEREINAFTER CALLED THE BARRY REPORT). THE BARRY REPORT AND ALL OTHER RELEVANT FACTORS, INCLUDING INPUT FROM PUBLIC MEETINGS IN BOSTON, DUXBURY, AND PLYMOUTH, A MEETING WITH A REPRESENTATIVE OF THE PLYMOUTH COUNTY NUCLEAR INFORMATION COMMITTEE, INC., AS WELL AS ADDITIONAL ANAL-YSIS BY FEMA STAFF AND CONSULTANTS HAS BEEN SEPARATELY ANALYZED AS PART OF THE ATTACHED REVIEW OF THE MASSACHUSETTS RADIOLOGICAL PLANS FOR PILGRIM WHICH FEMA INITIATED PORSUANT TO 44 CFR 350 l l 1 s
.q -
SUMMARY
IHE DETAILED ANALYSIS OF lSSUES RAISED IN THE JULY 13, 1936 DETITION 15 PRESENTED IN SECTION lil. 10ST OF TdE lSSUES l
\
l
, RAISED IN THE 1936 PETITION ARE ESSENTI. ALLY IDENTICAL *O 115UES RAISED IN A PETITION SUBMITTED TO THE NRC IN 1983 3y MASSPIRG, AND 70 ISSUES PREV!0USLY EXAMINED BY NKC AND FEMA.
3ASED ON A PREVIOUS ANALYSIS BY FEMA, THE NKC DENIED THE 1983 MASSPIRG PETITION ON FEBRUARY 27, 1984 FEMA REVIEaED THIS NEW PETITION IN LIGHT OF THE STATd 0F THE RECORD AT THE TIME OF ITS SUBMITTAL AND INFORMATION AVAILABLE TO N d.I A A S OF 'l0VEMBER, 1986 UUR REVl!W WAS LARGELY COMPLETED BY DECEMBER 20, 1936 FEMA DEALT WITH LATER INFORMATION INCLUD-ING FEMA STAFF ANALYSIS OF PUBLIC AND INTERAGENCY MEETINGS, AND THE 3ARRY REPORT, IN ITS SELF-!NITIATED REvlEw. IT SHOULD BE NOTED, M0 WEVER, THAT, WHILE FEMA'S ANALYSIS CJ THE SEVEN AL-LEGED DEFICIENCIES IN OFF-SITE EMERGENCY PLANNING INDICATES THAT THE !NFORMATION IN THE DETITION DID NOT SUSTAIN THE CON-TENTIONS BASED ON THE STATE OF THE RECORD AT THE TIME THE PETITION aAS REvlEWED, FEMA AGREES WITH THE GENERAL THRUST UF SOME OF THE CONCLUSIONS OF THE PETITION FUR THE REASONS CITED IN ITS $ ELF-lNITIATED REVIEW AND INTERIM FINDING DATED JULY 29, 1987 THE FEDERAL [MERGENCY MANAGEMENT AGENCY WILL CONTINUE TO REVIEW AND ANALYZE THE STATUS OF EMERGENCY PLANNING IN THE VICINITY OF ALL NUCLEAR POWER PLANTS, INCLUDING FILGRIM, TO INSURE THAT A CORRECT ANALYSIS O'F OFF-SITE EMERGENCY PLANNING [$ PRESENTED TO THE NUCLEAR REGULATORY COMMISSION. i
5- ((l. ANA LYS I S FEMA HAS ADDRESSED EACH OF THE SEVEN ISSUES IN OFF-SITI EMERGENCY PLANNING RAISED IN THIS PETIT!'ON BELow. 14/ UEFICIENCIES IN THE MAD 10 LOGICAL EMERGENCY RESPONSE PLAN (RERP) PETITIONERS: SERIOUS DEFICIENCIES EXIST IN THE REKP FOR P!LGRIM, WARRANT-ING SUSPENSION OF 00STON ED! SON'S OPER ATING THE LICENSE BY THE COMBINED NRC. THE DEFICIENCIES ARE OUTLINED BELOW. EFFECT OF THESE DEFICIENCIES IS TO ABROGATE THE "REASONABLE ASSURANCE THAT ADEQUATE PROTECTIVE MEASURES CAN AND WILL BE TAKEN IN THE EVENT OF A RADIOLOGICAL EMERGENCY," THE STAND-ARD SET BY 10 LF8 530 47 (A)(1). FEMA: FEMA HAS PROVIDED RESPONSES TO EACH OF THE PETITIONER'S ALLE-GATIONS. THESE RESPONSES ARE GIVEN BELOW. 15/ UEF'.CIENCIES IN ADVANCE INFORMATION A) PETITIONERS: IHE ONLY METHOD BEING USED FOR ADVANCE PUBLIC EDUC '!ON i IN THE PILGRIM EMERGENCY PLANNING LONE (EPl) IS THE DISTRIBU- ! T10N OF PAMPHLETS BY MAIL. A NASSPlKG TELEPHONE SURVEY CON- l DUCTED IN 1983 REVEALED SERIOUS INADEQUAClES IN'THE DISTRIBU-TION, RETENTION, AND UNDERSTANDING OF THE PAMPHLETS BY AREA RESIDENTS. NO IMPROVEMENTS IN THE ADVANCE INFORMATION PROCE-DURES MAVE BEEN CARRIED OUT SINCE 1985 1 FEMA: ; IHIS ISSUE WAS RAISED PREVIOUSLY IN THE PETITION OF THE MASS-ACHUSETTS PUBLIC [NTEREST RESEARCH GROUP FOR EMERGENCY AND , REMEDIAL ACTION FILED BY MASSPlRG wlTH THE NRC ON JULY 20, 1983 NO SUBSTANTIVE NEW ISSUES,ARE RAISED BY THE CURRENT ) PETITION. IN RESPONSE TO THE 1983 PETITION (APPENDIX 1) FEMA STATED:
4 , l 6 IWO PAMPHLETS ENTITLED "EMERGENCY PUBLIC INEoo-MATION" AND "NUCLEAR dNERGY QUESTIONS AND ANSWERS" WERE MAILED TO ALL RESIDENTS lN THE tPL IN dEPTEMBER 1981 AND SEPTEMBER 1982 IN ADDITION, THE PAMPHLETS dERE DISTRIBUTED TO COMMERCIAL ESTABLISHMENTS AND PUBLIC BUILDINGS IN THE EP2, INCLUDING HOTELS. UVER
~
120,000 0F BOTH BROCHURES MAvE BEEN DISTRIBUTED IN AN AREA 0F APPROX!MATELY 55,000 POPULATION AND 20,000 HOUSEHOLDS. POSTERS DEPICTING EMERGENCY INFORMATION HAVE BEEN DISPLAYED IN THE EPZ SINCE OCTOBER 1982 MASSPIRG'S INFORMATION WAS DERIVED FROM A POLL THAT THEY CONDUCTED OF SOME OF THESE RESIDENTS IN THE AREA. WHEN ASKED IF THEY HAVE RECE!VED EPl BROCHURfS, A SUS-STANTIAL 70% RESPONDED THAT THEY DEMEMBERED RECE!VING THEM. MASSP.lR6 ALSO REPORTS THAT 95 0F THOSE POLLED SAID THEY WOULD TUNE TO AN EbS RADIO STATION AS A FIRST REACTION TO HEARING THE S!RENS, AND AN ADDITIONAL 19% WOULD TUNE TO RADIO OR IV, BOTH OF WHICH ARE REASON-ABLE AND APAROPRIATE RESPONSES. 9ASSPlM6 310 NOT ASK WHAT PEOPLE *0ULD 00 UPON SOME REFLECTION AS THE S!RENS CONTINUED TO SOUND. dACH S!REN HAS A PUBLIC ADDRESS CAPABILITY AND CAN BE USED TO BROADCAST SPECIFIC INSTRUCTIONS TO THE PUBLIC, INCLUDING TRANSIENTS, IN AN EMERGENCY AND THIS SHOULD BE CONSIDERED TO BE PART OF THE PUBLIC EDUCATION EFFORT. LOC AL AND STATE PUBLIC SAFETY VEHICLES ALSO ARE EQUlPPED
*lTH PA CAPABILITY. MESSAGES WILL BE BROADCAST OVER THESE PUBLIC ADDRESS SYSTEMS TO TUNE TO THE EBS STATION FOR INFORMAil0N. IHIS SHOULD BE SUFFICIENT TO AfD RESI-DENTS AND TRANSIENTS IN AN EMERGENCY.
PEMA DETERMINED IN 1933 THAT THE PETITION DID NOT INDICATE THAT THE COMMONWEALTH WAS UNADLE TO PROTECT fHE HEALTH AND l SAFETY OF T li PUBLIC. IHE MASSPIRG PETITION WAS DENIED BY I
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I THE NRC IN THE ' INTERIM DIRECTOR'S DECISION UNDER 10 CFR l 2 206", FEBRUARY 27, 1984 HOWEVER, SINCE THAT TIME THE 1 COMMONWEALTH hAS TAKEN ADDITIONAL STEPS TO ENHANCE ITS PUBLIC INFORMATION PR00 RAM. i ACCORDING TO INFORMATION PROVIDED BY MCDA AND THE BUSTON 1 I l
)
7-EDISON COMPANY, THE ANNUAL PUBLIC EDUCATION BROCHURE ENTI-TLED "EMERGENCY PUBLIC INFORMATION: WHAT TO 00 IN CASE OF AN EMERGENCY AT PILGRIM NUCLEAR POWER STATION" (APPENDIX 4) WAS MAILED TO RESIDENTS, HOTELS AND MOTELS, AND PUBLIC BUILD-INGS IN THE PLUME EXPOSURE EMERGENCY PLANNING LONE (hPZ) IN AUGUST 1986 (SEE APPEND!X 3). BROCHURES WERE ALSO MAILED TO RESIDENTS IN 1985 THE 1986 BROCHURE IS IN COMPLIANCE WITH THE GulDANCE PROVIDED IN NUKEG-U654, FEMA-KEP-1, kev 1, "LRITERIA FOR PREPARATION AND LVALUATION OF KAD10 LOGICAL LMERGENCY dESPONSE PLANS AND PREPAREDNESS IN SUPPORT OF: NUCLEAR F0WER PLANTS." lHE CURRENT BRUCHURE CONTAINS THE FOLLOWING INFORMATION: LDUCATIONAL INFORMATION ON RADIATION) DESIGNATION OF RADIO STATIONS FOR EMERGENCY PUBLIC INFORMATION;
- PROTECTIVE MEASURES (1.E., SHELTERING, RESPIRATORY PROTECTION, EVACUATION ROUTES, AND RECEPTION CENTERS);
AND A RETURN POSTCARD AND INSTRUCTIONS FOR PERSONS WITH SPECIAL NEEDS SO THAT ARRANGEMENTS CAN BE MADE TO PROVIDE APPROPRIATE TRANSPORTATION IN THE EVENT OF AN EVACUATION. FEMA SPONSORED A STATISTICALLY VALID SURVEY AFTER THE 3EPTEM-BER 29, 1986 TEST OF THE PILGRIM PUBLIC ALERT AND NOTIFICA-TION SYSTEM. THE SURVEY INDICATED THAT 72 8% OF THE PEOPLE I REMEMBER RECEIVING THE PUBLIC INFORMATION BROCHURE. FEMA, THEREFORE, CONCLUDES THAT THE PETITION DOES NOT PROVIDE INFORMATION WHICH SUSTAINS THE CONTENTIONS.
5 '.
.g.
B) PETITIONERS: IHE CURRENT (SEPTEMBER 1985) PAMPHLETS CONTAIN NO INFORMA-TION REGARDING PUBLIC TRANSPORTATION FOR PURPOSES OF EVACUA-T!ON, DESPITE THE FACT THAT THE RADIOLOGICAL EMERGENCY 4E-SPONSE PLAN (RERP) FOR THE IOWN OF PLYMOUTH PROVIDES FOR THIRTEEN "STAGING AREAS" WHERE PERSONS WITHOUT TRANSPORT-ATION WILL BE DIRECTED FOR "POSSIBLE" PUBLIC TRANSPORT. FEMA: IHIS ISSUE WAS RAISED PREVIOUSLY IN THE "PETITION OF THE MASS-ACHUSETTS PUBLIC INTEREST MESEARCH GROUP FOR LMERGENCY AND dEMEDIAL ACTION" FILED BY MASSPlH6 WITH THE NRC ON JULY 20, 19b3 NO SUBSTANTIVE NEW ISSUES ARE RAISED IN THE CURRENT PETITION. IHE LOMMONWEALTH STATED IN ITS RESPONSE TO THE 1985 PETITION: (APPENDIX 3) LOCAL ALANS UTILIZE LISTINGS OF POST OFFICES, FIRE HOUSES, SCHOOLS AND OTHER WELL KNOWN, RECOGNIZABLE SITES FOR ' STAGING AAEAS.' ALTHOUGH LOCAL RESIDENTS ARE WELL AWARE OF THESE SITES, WE ARE STUDYING THE USE OF MAPS AND MAY INCLUDE THEM IN FUTURE PUBLICA-T10NS. FEMA STATED IN ITS RESPONSE TO THE 1983 PETITION: (APPENDlX 1) PUBLIC IRANSDORTATION - IHE LACK OF PROVISIONS IN THE PLANS FOR TRANSPORTATION OF THOSE WHO MAY NOT HAVE ACCESS TO CARS WAS PREVIOUSLY NOTED AS A DE- l FlCIENCY AND THE STATE l$ REVIS!NG THE PLANS ACCORD- I INGLY. NO REQUESTS FOR SPECIAL TRANSPORTATION HAVE, I TO DATE, BEEN REGISTERED WITH PLYMOUTH Civil UEFENSE, : ALTHOUGH SUCH INFORMATION HAS BEEN SQLlC!TED. 1 IHE 1986 PUBLIC INFORMATION BROCHURES DIRECT PERSONS IN NEED OF TRANSPORTATION OR OTHER SPECIAL HELP TO RETURN THE POSTCARD FOUND IN THE BROCHURE TO MCUA AREA 11 HEADQUARTERS l OR TO CALL THE!R TOWN HALL OR CIVlt UEFENSE UFFICE AS SOON l l AS POSSIBLE TO ARRANGE FOR ASSISTANCE BEFORE AN EMERGENCY. l
- 0, -
IF PEOPLE NEED ASSISTANCE DURING AN EMERGENCY,
- HEY ARE 70 THE LOCAL 8LANS SPECIFy CALL THE LOCAL Clv!L DEFENSE OFFICE.
THAT CONTRACTOR SCHOOL SUSES MAY BE USED TO MOVE THOSE alT [F NEEDED, ADDITIONAL BUSES PERSONAL MEANS OF TRANSPORTATION. (OR OTHER ME ANS OF MASS TRANSPORT) WILL BE REQUESTED THROUGH HEAD-THE MASSACHUSETTS CIVIL DEFENSE AGENCY (MCDA) AREA II OVARTERS. IME COMMONWEALTH OF ?tASSACHUSETTS HAS (DENTIFIED O IN iTS ATATE LAN A VAST NUMBER OF STATE CONTROLLED RES0URCES AVAILABLE 'N THE EVENT OF AN ACCIDENT AT ? !LGRIM. UREDETERMINED STAGING AREAS FOR BUSES d!LL BE ACTIVATED AT SITES SPECIFIED BY THE DIRECTOR OF Civil DEFENSE (CD) AS THE SITUATION REQUIRES. PLYMOUTH HAS IDENTIFIED 13 STAGING AREAS WHERE THOSE PEOPLE IN NEED OF TRANSPORTATION WOULD GO TO OBTAIN PUBLIC TRANSPORTATION. IF AN EVACUATION WERE ORDERED, PEOPLE *0VLD BE ADVISED TO STAY TUNED TO RADIO AND IHE PLYMOUTH IV FOR INFORMATION REGARDING THE EVACUATION. Civil DEFENSE DIRECTOR IS RESPONSIBLE FOR COORDINATING WITH MC0A AREA II HEADOUARTERS TO ASSURE THAT INFORMATION REGARD- l ING THE ARRANGEMENTS FOR THOSE PEOPLE IN NEED OF TRANSPORTA-TION ARE CONTAINED IN EBS MESSAGES. FEMA, THEREFORE, CONCLUDES THAT THE PETITION DOES NOT PRO-VIDE INFORMATION WHICH SUSTAINS THE CONTENTION. ) i l l l
. e 10 -
C) PETITIONERS: IHE ADVANCE INFORMATION SYSTEM FOR TOURISTSFOR ANDEXAMPLE, OTHER so TRANS!ENTS IS !NADEOUATE OR NONExlSTENT. SIGNS HAVE BEEN POSTED TO PROVIDE APPROPRIATE INFORMAtl0N FOR TRANS!ENTS, A MEASURE SUGGESTED BY. THE f4KL IN lU LPn 9 ART 50, APPENDIX E. IV.0 2 FEMA: IHis ISSUE WAS RAISED PREVIOUSLY IN THE "PETITION OF THE MASSACHUSETTS PuBLIC INTEREST RESEARCH GROUP FOR EMERGENCY AND REMEDIAL ACTION" FILED BY MASSPIRG WITH THE NRC ON July 20, 1983 NO SUBSTANTIVE NEW ISSUES ARE RAISED IN THE CURRENT PETIT!ON. IME LOMMONdEALTH STATED IN ITS RESPONSE TO THE 1983 PETITION: (APPENDlx 3) POSTERS HAVE BEEN DISTRIBUTED, AND ARE AVAILABLE THROUGHOUT THE LPl. lHE LFl PAMPHLETS INCLUDE RE-MOVABLE EMERGENCY PUBLIC INFORMATION STICKERS AND HAVE ALSO BEEN DISTRIBUTED (SEE ENCLOSED). IHE SIREN SYSTEM INSTALLED THROUGHOUT THE EPl IS EQUIPPED WITH PUBLIC ADDRESS CAPABILITY WHICH WOULD BE USED TO PROVIDE TRANS!ENTS dlTH EMERGENCY INFORMATION. LOCAL AND STATE PUBLIC SAFETY VEHICLES ARE ALSO EQUIPPED WITH PA CAPABILITY. FEMA'S RESPONSE TO THE 1983 PETITION (APPENDIX 1) STATED: IWO PAMPHLETS ENTITLED "EMERGENCY PUBLIC INFORMATION" AND "NUCLEAR ENERGY QUEsil0NS AND ANSWERS" WERE MAILED TO ALL RESIDENTS IN THE EPZ IN SEPTEMBER 1981 AND SEP-TEMBER 1982 IN ADDITION, THE PAMPHLETS WERE DISTRIB-UTED TO COMMERCIAL ESTABLISHMENTS AND PUBLIC BUILDINGS IN THE EPZ, INCLUDING HOTELS. OVER 120,000 0F BOTH BROCHURES HAVE BEEN DISTRIBUTED IN AN AREA 0F APPROX-IMATELY 55,000 POPULATION AND 20,000 HouSEHotDS. POSTERS DEPICTING EMERCCNCY INFORMATION HAVE BEEN DIS-PLAYED IN THE EPl SINCE OCTOBER 1982 ACCORDING TO INFORMATION PRESENTED TO FthA BY BOSTON EDISON, s i t
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.' 'e 11 -
WHO D!$ TRIBUTE T,5 BROCHURES FOR T H E :ASSACHUSETTS LIVit UEFENSE AGENCY, EMERGENCY PUBLIC INFORMATION BROCHURES dERE RECENTLY DISTRIBUTED TO HOTELS AND MOTELS, LIBRARIES, AND TOWN OFFICES IN THE AREA, AND PLACARDS WERE POSTED AT VARIOUS LOCATIONS THROUGHOUT THE LPl (SEE LETTER FROM 00STON LDISON, DATED UCTOBER 29, 1980, APPENDIX b). FEMA, THEREFORE, CONCLUDES THAT THE PETITION DOES NOT PROVIDE INFORMATION WHICH SUSTAINS THE CONTENTION. D) PITITIONERS: IHE INADEGUATE ADVANCE INFORMATION SYSTEM VIOLATES 10 CFR 550 47 (B)(7); 10 CFR FART 50, APP 2NDlX E. IV U.2, AND EVALUATION CRITERIA G 1, G 2 AND P. 10 0F NUREG-0654 FEMA: FEMA HAS RESPONDED TO THIS ISSUE IN ITEMS A, B, AND C ABOVE. 10/ UEFICIENCIES IN NOTIFICATION UURING AN MCCIDENT A) PETITIONERS: IME WARNING S!REN SYSTEM AND BACK-UP SYSTEMS ARE INADE-QUATE TO ESSENTIALLY COMPLETE THE INITIAL NOTIFICATION OF THE PUBLIC WITHIN THE PLUME EXPOSURE PATHWAY OF THE EMER-GENCY PLANNING REQUIRED 40NE EY 10 CFR (LPl)59, PART WITHIN APPENDIX FIFTEEN E.,MINUTES, IV. D.3 AS-1R EXAMPLE, THE S!REN SYSTEM HAS BEEN PLAGUED WITH F1 .t ALARMS. RATHER THAN CORRECT THis PROBLEM, THE P{.PvNSE HAS BEEN TO DISCONNECT THE SIREN SYSTEM DURING EltCTRICAL STORMS. t _..___.m__ _ _ _ . _ _ _ _ _ _ . _ _
'e 'e : 12 - FthA: IHIS ISSUE WAS RAISED PREVIOUSLY IN THE "PETITION OF THE MASSACHUSETTS PUBLIC [NTEREST MESEARCH 6ROUP FOR iMERGENCY AND REMEDIAL ACTION" FILED BY MASSPlk6 WITH THE NRC ON JULY 20, 1983 NO NEW SUBSTANTIVE ISSUES ARE RAISED IN THE.- CURRENT PETITION. WHILE THE ALERT AND NOTIFICATION SYSTEM EXPERIENCED FALSE ALARMS FOR SOME TIME AFTER ITS INSTALLATION, BOSTON EDISON EXAMINED THE PROBLEM AND MADE IMPROVEMENTS IN THE SYSTEM. 1 FEMA'S REvlEW OF THE $1REN TEST RESULTS, THE ALERT AND NOTIF-ICAT10N $YSTEM DESIGN AND OPERATIONAL RECORDS PROVIDED BY BOSTON EDISON COMPANY INDICATES THAT THIS PROBLEM DOES NOT NOW EXIST. (ALSO SEE APPEND!x 5, PAGE 8, ET. SEQ.) FthA, THEREFORE, CONCLUDES THAT THE PETITION DOES NOT PROVIDE INFORMATION WHICH SUSTAINS THE CONTENTION. B) PETITIONERS: IHE SIRENS ARE INAUDIBLE OR BARELY AUDIBLE WITHIN LARGE AREAS OF THE EPZ (KEPORT ON THE PILGRIM NUCLEAR POWER STATION SIREN IEST, JUNE 19, 1982, FEMA, JANUARY 1983, P.6). FURTHERMORE, FEDERAL REGULATIONS REQUIRE NOTIFICATION OF "ALL SEGMENTS" 0F THE POPULATION (CRITERIA J.10.C, E.6; 10 CFR PART 50, APPENDIX 6, {V. U.3). FEMA: IHIS ISSUE W AS RAISED PREVIOUSLY IN THE "PETtit0N OF THE MASSACHUSETTS PuBLIC INTEREST KESEARCH GROUP FOR EMERGENCY ) I AND 3EMEDIAL ACTION" FILED BY MASSPlRG WITH THE NRC ON JULY 20, 1983 NO SUBSTANTIVE NEW ISSUES ARE RAISED IN THE CURRENT PETITION. I 1
a . 13 - FEMA STATED IN ITS RESPONSE TO THE 1983 PETITION (APPEND!X 1) ; THAT: MASSPIRG SEEMS TO HAVE MISUNDERSTOOD THE REPORT ON THE "D ILGRIM NUCLEAR POWER STATION SIREN RESPONSE EXERCISE FOR THE PILGRIM NUCLEAR POWER STATION, MARCH 3, 1982." THE FIXED SIREN SYSTEM WAS DESIGNED TO BE USED IN CONJUNCTION WITH OTHER METHODS OF NOTIFICATION SUCH AS MOBILE NOT!FY!NG TEAMS, TONE ALERT RADIOS, AND THE EBS. FEMA IS CURRENTLY DE-VELOFING STANDARDS FOR MEASURING THE EFFECTIVENESS OF FIXED SIRENS. h0 WEVER, THE 1982 51REN TEST DEMONSTRATED AN IMPRESSIVE ABILITY TO NOTIFY THE PUBLIC USING SIRENS ALONE. IN OUR OPINION, THE TEST ALSO DEMONSTRATED A CONTINUING NEED FOR THE OTHER FORMS OF PUBLIC NOTIFICATION THAT ARE PRES-ENTLY [NCLUDED IN THE PLANS. EtMR'S REPORT ON THE PILGRIM NUCLEAR POWER STATION blREN , IEST DID NOT STATE THAT THE SIRENS WERE INAUDIBLE OR BARELY AUDIBLE WITHIN LARGE AREAS OF THE EPl. PAGE 6 0F THE REDORT, dHICH THE THE PETITIONERS REFERENCE, DISCUSSES WHERE FtMA OBSERVERS WERE LOCATED DURING THE TEST. FEMA STATED ELSEWHERE IN THE REPORT THAT WE CHOSE TO LOCATE THE 18 OBSERVERS IN TNOSE FEW AREAS WHERE SIREN OUTPUTS WOULD BE THE WEAKEST. IHEREFORE, dE CONCLUDED THAT THE OBSERVERS' REPORTS SHOULD NOT BE TAKEN AS AN INDICATION OF WIDESPREAD PROBLEMS. IT IS WORTH NOT!NG THAT FEMA SPONSORED A TELEPHONE SURVEY IMMEDIATELY FOLLOWING A SEPTEMBER 29, 198b TEST OF THE PILGRIM ALERT AND NOTIFICATION SYSTEM WHICH INDICATED THAT 88 2% OF THE PEOPLE WERE DIRECTLY ALERTED BY THE SIRENS ON THE DAY OF THE TEST. FbhA, THEREFORE, CONCLUDES THAT THE PETITION DOES NOT PRO-v!DE INFORMATION WHICH SUSTAINS'THE CONTENTION. l
14 - C) PETITIONERS: IHE DEFICIENT SIREN SYSTEM ?ULD FAIL TO WARN THE mEARINT TEST! MOPY AT THE .iE id, 198b HEARING ON TmE [MPA! REC;ERP BEFDRE MASSACHUSETTS LEGISLATORS PROVIDED NO P!LGR!M M EVIDENCE OF THE EXISTENCE OF AN ALTERNATE PLAN FOR NOTIF1-CATION OF THis SEGMENT OF THE POPULATION, A DIRECT V!OLA-T10N UF THIS STATUTORY MANDATE. FEMA: IHIS ISSUE WAS RAISED PREVIOUSLY IN THE "PETITION OF THE MASSACHUSETTS PUBLIC INTEREST GROUP FOR EMERGENCY AND KEME-DIAL ACTION" FILED BY MASSPIRG WITH THE NRC ON JULY 20, 1983 NO SUBSTANT!vE NEW ISSUES WERE RAISED IN THE CURRENT PETITION. IN ITS RESPONSE To THE 1983 MASSPIRG PETITION (APPENDIX 3), THE COMMONWEALTH OF MASSACHUSETTS STATED: MCUA AND BOSTON EDISON HAVE WORKED WITH THE MASSA" CHUSETTS UFFICE FOR THE UEAF (MUU) AND THE UEAF LOM-MUNITY CENTER IN FRAMINGHAM, MA IN ORDER TO ADDRESS THIS PROBLEM. BOSTON LDISON OFFERED TO EOUIP HOUSE-HOLDS OF DEAF PEOPLE LIVING ALONE IN THE EPZ WITH TELE-TYPEWRITER DEv!CES FOR THE!R TELEPHONE. THIS DEvlCE IS WIDELY ACCEPTED AS ADEQUATE COMMUNICATIONS FOR SERVING A DEAF PERSON DURING AN EMERGENCY. NEWS-LETTERS FOR THE DEAF CARRIED NOTIFICATION OF THIS PROGRAM. NO SUCH HOUSEHOLDS HAVE BEEN [DENTIFIED IN THE PILGRIM EP2 FEMA STATED [N ITS NOVEMBER 3, 1983 ANALYSIS OF THE 1983 MASSPIRG PETITION (APPENDIX 1). THE COMMONWEALTH OF MASSACHUSETTS AND BOSTON EDISON HAVE WORKED WITH THE MASSACHUSETTS OFFICE OF THE DEAF, THE COUNCIL OF ELDER AFFAlR$ AND THE DEAF COMMUNITY CENTER IN PRAMINGHAM IN AN ATTEMPT TO IDENTIFY DEAF RESIDENTS WITHIN THE EPl. THEY HAVE ALSO ATTEMPTED TO NOTIFY DEAF PEOPLE WITHIN THE EPZ THROUGH NEWSLETTERS ABOUT EFFORTS TO PROVIDE
15 - DEAF RESIDENTS OF THE EP2 WITH TELETYPEWRITER (ITY) DEVICES. NO SUCH HOUSEHOLDS HAVE BEEN IDENTIFIED BY THESE EFFORTS. THIS MAY BE BE.CAUSE MOST INDIVID-VALS WITH SPECIAL NEEDS L!vE WITH SOMEONE AND CAN RELY ON OTHER MEMBERS OF THE HOUSEHOLD IN TIMES OF EMERGENCY. ALSO, DEAF PEOPLE AND OTHER INDIVIDUALS WITH SPECIAL NEEDS TEND TO CONGREGATE IN URBANIZED AREAS WHERE THEY CAN RECEIVE SERVICES READILY AND THE P!LGRIM hPZ l$ NOT URBANIZED. CONFIDENTIAL LISTS IDENTIFY!NG THE DEAF ARE BELIEVED TO EXIST. IN A MEETING ON AUGUST 19, 1983 WITH MASSPIRG, THE MASSACHUSETTS SECRETARY OF PUBLIC SAFETY AGREED TO 00 RESEARCH ON EXISTING LAWS TO SEE 1F THIS INFORMATION COULD LEGALLY BE MADE AVAIL-ABLE To THE MCUA FOR PLANNING PURPOSES. IHE COMMON-WEALTH AND UTILITY HAVE ASSURED FthR THAT THEY WILL CONTINUE THEIR OUTREACH AND dlLL PROVIDE IlY DEVICES TO ANY PROFOUNDLY DEAF PERSON IN THE LPl WHO REQUESTS NE. IHE EFFORT TO IDENTIFY HEARING IMPA! RED PEOPLE WHO MAY REQUIRE ITY DEVICES CONTINUES THROUGH ANNUAL EMERGENCY PUBLIC INFOR-MATION (EPI) BROCHURES MAILED TO ALL HOMES WITHIN THE 10-MILE EP2 AS NOTED EARLIER, THESE BROCHURES CONTAIN A POSTCARD TO BE USED BY SPECIAL NEEDS INDIVIDUALS APPRISING LOCAL l 0FFICIALS OF THE INDIVIDUAL'S SPECIAL NEED. BOSTON EDISON ! l RECENTLY SENT A LETTER TO THE MASSACHUSETTS COMMISSION FOR l l UEAF AND HARD OF HEARING TO REQUEST THE!R AfD IN IDENTIFYING l l INDIVIDUALS LIVING IN THE PILGRIM EPL, WHO MAY NEED TIY DEVICES (SEE BOSTON LDISON LETTER - APPENDIX b). MCUA AND BOSTON EDISON INFORMED US THAT AS OF OCTOBER 1986, h3 HOUSEHOLDS CONTAINING A DEAF PERSON HAVE BEEN IDENTIFIED.
1 15 - ; EEMA, THEREFORE, CONCLUDES THAT THE PETITION DOES '4 0 T 240-
/lDE INFORMATION wmlCM SUSTAINS THE CONTENTION.
D) ?ETITIONERS: IN TESTIMONY SEFORE MASSACHUSETTS STATE LEGISLATORS ON JUNE 13, 1986, EDWARD A. IHOMAS, O!v!$10N CHIEF, NATURAL
& IECHNOLOGICAL HAZARDS, FEMA, STATED THAT BOSTON EDISON HAD FAILED REPEATEDLY TO DELIVER To rthA NECESSARY TECH-NICAL SPECIFICATIONS ON THE SIREN SYSTEM. MR. THOMAS ADDED THAT THESE DELAYS BY btCO HAVE FORCED REPEATED POSTRONEMENTS OF THE FULL
- SCALE SYSTEM TEST RECUlRED SY EENA.
EENA: i nHILE dOSTON EDISON D!D NOT SUBMIT THE NECESSARY TECHNICAL INFORMATION wHEN SCHEDULED, THE COMMONWEALTH OF MASSACHUSETTS FORWARDED TO FEMA THE "FEMA-43 KEPORT, PuntlC ALERT AND NOT!FICATION 3fSTEM FOR THE PILGRIM NUCLEAR POWER STATION" ON JUNE 20, 1985 ADDITIONAL INFORMATION WAS REQUESTED AND PROVIDED TO FEMA SY BOSTON EDISON ON JUNE 23, 1986 THE ADDITIONAL INFORMATION WAS ANALY!ED AND FOUND TO BE IN SUFFICIENT COMPL l ANCE WITH THE REQUIREMENTS OF FEMA-43 TO ENABLE FEMA TO CONDUCT A TEST OF THE PIL8RlM SIREN SYSTEM ON bEPTEMBER 29, 1986 THIS TEST INDICATED THAT 88 2% OF THE PEOPLE WERE DIRECTLY ALERTED BY THE SIRENS ON THE DAY OF THE TEST. FdMA, THEREFORE, CONCLUDES THAT THE PETITION DOES NOT PROVIDE INFORMATION WHICH SUSTAINS THE CONTENTION. I
17 - 17/ UEFICIENCIES IN EVACUATION PLANS A) OETITIONERS: IME EVACUATION TIME ESTIMATES FOR THE PILGRIM EPl ARE UNREALISTICALLY LOW. IHEY FAIL TO TAKE INTO ACCOUNT THE PROBABILITY OF SOME PANIC, TRAFFIC DISORDER, TRAFFIC OBSTACLES OUTSIDE THE EPZ AND THE FACT THAT THOUSANDS OF PEOPLE OUTSIDE DESIGNATED EVACUATION ZONES WILL ALSO EVACUATE. ACCORDING TO TESTIMONY BEFORE MASSACHUSETTS LEGISLATORS ON JUNE 13, 1986, BY EDWARD A. IHOMAS, DivtSION CHIEF, NATURAL & IECN0 LOGICAL HAZARDS, FLMA, THE "REASONABLE ASSURANCE" ADEQUACY OF THE CURRENT PLAN IS BASED ON THE ASSUMPTION THAT COMMUNITIES OUTSIDE OF THE TEN MILE t?! mAvE DEVELOPED PLANS TO AUGMENT EVACUAT ON AND SHELTERING aHEN ASKED, NR. LU B E R I NG , \ S I C (' UlRECTOR UEPUTY EFFORTS. OF THE *tASSACHbOETTS LIVll UEFENSE mGENCY (MlUA)g STATED THAT aE ~AD NO EVIDENCE THAT SUCH PLANS EXIST. "URTHER-
"0RE, EVACUATION TIME EST! MATES ARE :40T PROVIDED FOR VARIOUS AUVERSE dEATHER SCENARIOS.
FEhn: IME CURRENT EVACUATION TIME ESTIMATES ARE BASED ON A SEPTEM-BER, 19S0, STuDv CONDUCTED BY HMM ASSOCIATES, INC. WHICH WAS UPDATED IN AUGUST, 1961 IHERE dERE ALSO SUPPLEMENTAL STUDIES ADDRES$1NG TRAFFIC CONGESTION PROBLEMS OUTSIDE OF THE EP2 IN THE V!CINITY OF 3UZZARDS 3AY AND THE $AGAMORE 3 RIDGE AND PRO-JECTING THE IMPACT OF FUTURE POPULATION GROWTH. IHESE STUDIES wERE EXTENSIVELY REVIEWED BY THE NRC AND FEMA AS PREVIOUSLv l MENTIONED IN THIS REPORT. dOSTON EDISON MAS RECENTLY CONTRACTED l TO UPDATE THE EVACUATION TIME ESTIMATE FOR THE P!LGRIM NUCLEAR POWER STATION. IHE PETITIONERS RAISE FIVf. SEPARATE ISSUES WITH RESPECT TO EVACUATION WHICH WE HAVE ADDRESSED BELOW: l A) WANIC - PANIC, AS ACCEPTED BY MOST DISASTER RESEARCH l l PROFES$10NALS, WAS DEFINED By ENRICO L. QUARANTELLI TO MEAN "EOPLE RUNN!NG FROM AN ASSUME 0 THREAT OF DANGER, NOT JUST A 1 l
o' 4 18 - MElGHTENED SENSE OF ANXlETY
. PANIC ALSO CONNUTES A SUDDEN OVERWHELMING FEAR THAT PRODUCES MfSTERICAL 3R (RRATIONAL BEHAv!0R THAT 3AN SPREAD QUICKLY THROUGH A GROUP OF 3EOPLE.
AESEARCH BASED ON ACTUAL DISASTERS HAS REVEALdD THAT THE SPECTER OF d!LD OR 1RRAT10NAL FLIGHT IN THE FACE OF GREAT , THREAT OR DANGER IS NOT BORNF OUT IN REALITY. PEOPLE WILL OFTEN STAY IN A THREATENING SITUATION RATHER THAN MOVE OUT l OF IT. RUSSEL 9YNES AND OTHER RESEARC 1 M HAVE COMMENTED THAT THERE IS NO REASON TO EXPECT THAT 'r. OLE dOULD REACT ANY 01: 8ERENTLY BECAUSE 0F A RADIATION fMREAT : ROM AN E"ER- . GENCY AT A NUCLEAR POWER PLANT THAN THEY WOULD TO ANY OTHER , DISASTER. THEY HAvc ALSO EMPHASIZED THAT A KEY TO THE SAN-AGEMENT OF PEOPLE IN DANGER 15 THE ABILITY FOR OFFICIALS TO PROVIDE CLEAR INSTRUCTIONS AND INFORMATION THAT WILL ADDRESS PUBLIC FEARS AND MINIMlZE CURIO $lTY THAT COULD ATTRACT ON-LOOKERS dHO MIGHT INHIBli OR INTERFERE d!TH MEASURES TAXEN TO PROTECT THE PUBLIC IN DANGER. B) TRAFFIC DISORDEQS DISASTER RESEARCH LITERATURE HAS l GENERALLY SHOWN THAT DURING A DISASTER PEOPLE DRIVE SArELY AND DO NOT EXHIBIT ERRATIC DRIVING BEHAVIOR 3,4 IN ADDITION, THE COMMONWEALTH OF MASSACHUSETTS HAS DEMONSTRATED THE ABILITY TO DEAL WITH TRAFFIC DISORDERS IN NUMEROUS EXERCISES AND REAL LIFE SITUATIONS. l
19 - C) TRAFFIC OBSTACLES OUTSIDE THE EPl THIS ISSUE WAS RAISED BY THE NUCLEAR KEGULATORY COMMISSION AND WAS EXTENSIVELY RE-VIEWED BY $thA IN A REPORT DATED NAY 1, 1984 (HPPENDIX 2). IN BRIEF, OUR MAY 1, 1984 REPORT INDICATES THE TWO AREAS WHICH MIGHT PRESENT OBSTRUCTIONS TO EVACUATING TRAFFIC OUTSIDE OF THE EPZ ARE THE ROUTE 128, ROUTE 3 (SOUTH) INTERCHANGE AND THE SAGAMORE BRIDGE ROTARY. FEMA'c ANALYSIS INDICATED THAT THE COMMONWEALTH OF MASSACHUSETTS HAS UTILIZED THE IN-FORMATION DEVELOPED BY BOSTON EDISON AND ISSUES IDENTIFIED BY NRC TO DEVELOP AN ADE00 ATE TRAFF;C MANAGEMENT PLAN. IHIS PLAN IS ENTITLED "MASSACHUSETTS STATE POLICE IROOP U HEAD-QUARTERS, MIDDLEBOROUGH, MASSACHUSETTS, HIGHWAY IRAFFIC l CONTROL.AND PLAN FOR AN EMERG'ENCY LONDITION AT PILGRIM i NPS." IHE PLAN CALLS FOR CONTROL OF TRAFFIC AT THE SAGAMORE
$ RIDGE AND SEVERAL MILES TO THC WEST TO EXPEDITE THE FLOW OF TRAFFIC OUT OF THE EPl. IRAFFIC FROM CAPE COD WOULD BE RE-ROUTED TO THE bCURNE BRIDGE.
IN THE MOST SEVERE CASE MASSACHUSETTS PLANS TO CLOSE ROUTE 3 SOUTH AT ITS INTERSECTION WITH ROUTE 128 IN OTHER CASES THEY WILL CLOSE ROUTE 3 SOUTH AT ROUTE 18 WHICH IS 4 MILES SOUTH OF THE 128/3 INTERCHANGE. l D) SHAD 0w EVACUATION - IHE MAIN EVACUATION ROUTES OUT OF THE i PILGRIM EPZ ARE ROUTE 3 NORTH; ROUTH 3A NORTH; ROUTE 3 SOUTH; ) l ROUTE 3A SOUTH; ROUTE 6/28 WEST,; ROUTE 44 WEST; ROUTE 58 l NORTHJ ROUTE 58 SOUTH; ROUTE 108 WEST AND ROUTE 495 WEST. i l
IHERE ARd ADDITIONAL SECONDARY ROADS OUT OF THE OPl 4HICH WOULD ALSO BE UTILIZED DURING AN E V A C U A'T I O N . IHE STATE POLICE HAVE DEVELOPED A DETAILED TRAFFIC MANAGEMENT PLAN FOR THE PILGRIM EPZ SO AS TO EXPEDITE TRAFFIC MOVEMENT OUT OF THE EPZ IN THE EVENT OF AN ACCIDENT AT THE PILGRIM NUCLEAR POWER STATION. THEY WILL BE ASSISTED BY THE MASSACHUSETTS DEPARTMENT OF PuBLIC WORKS. E) ADVEQSE WEATHEQ
- THE AUGUST 19, 1981 UPDATE OF T'tE PIL-3Riv iVACUATION IlME ESTIMATES PROVIDED AN ESTIMATE FOR AN ADVERSE WEATHER CONDITION WHICH WAS INCLUDED IN THE AREA Il MLUA PLAN. IHE EVACUATION TIME ESTIMATE UPDATE FUR PILGRIM WFiCH IS NOW BEING PERFORMED FOR BOSTON EDISON WILL ADDRESS ADVERSE dEATHER SCENARIOS IN MORE DETAIL.
CONCERNING THE REMARKS ATTRIBUTED TO EDWARD A. IMOMAS, THE THRUST OF }lR . IHOMAS'S COMMENTS WERE THAT: (A) FEMA AND THE COMMONWEALTH OF MASSACHUSETTS SUPPORT THE DEVELOPMENT OF COMPREHENSIVE PLANS TO DEAL WITH A WIDE VARIETY OF EMER-GENCIES; (B) LOCAL GOVERNMENTS.HAVE THE OPTION OF DETER-MINING WHICH PARTICULAR HAZARDS WILL BE SPECIFICALLY IDEN-TIFIED IN THE!R PLANSj (C) AND THAT LOCAL EMERGENCY PLANS CAN BE AND HAVE BEEN USED TO SUCCESSFULLY PROTECT THE PUBLIC FROM HAZARDS NOT SPECIFICALLY RECOGNIZED IN THE EMERGENCY PLANS. MR. IHOMAS POINTED OUT THREE EXAMPLES OF THE USE
-.,-_-s y-- - - -, , . - . - - c. , --
1 , 21 - 0F EMERGENCY DLANS DESIGNED FOR ONE 9AZARD TO PROTECT THE PUBLIC FROM ANOTHER HAZARD: A. $UCCESSFUL USE OF CRISIS RELOCATION PLANS TO MOVE APPROXIMATELY 250,0U0 PEOPLE FROM THE PATH OF HURRICANE FREDERICK IN 1979
- b. buCCESSFUL USE BY STATE AND LOCAL GOVERN-MENTS OF RADIOLOGICAL EMERGENCY RESPONSE PLANS AND EQUIPMENT TO PROTECT THE PUBLIC IN A SECTION OF CONNECTICUT DEVASTATED BY SUDDEN AND CATASTROPHIC FLOODS IN 1982 L. $UCCESSFUL USE OF LOCAL RADIOLOGICAL EMER-GENCY RESPONSE DLANS AND EQU!PMENT TO PROTECT THE PUBLIC FROM A T0XIC RELEASE OF CHEMICALS FROM A CHEMICAL MANUFACTURER LOCATED NEAR THE WATERFORD NUCLEAa POWER PLANT IN LOUI S ! AN A.
IHEREFORE, MR. IHOMAS CONCLUDED, THAT IN CONSIDERING WHETHER OR NOT A LARGER EMERGENCY PLANNING 20NE WAS REQUIRED TO PROTECT THE PUBLIC ON LAPE C0D OR IN OTHER AREAS OUTSIDE THE CURRENT EMERGENCY PLANNING ZONE FOR PILGRIM ESTABLISHED BY THE LOMMONWEALTH OF (1ASSACHUSETTS, THE LEGISLATURE MAY 4 ANT TO CONSIDER FUNDING THE COMPREHENSIVE IMPROVEMENT.0F EMERGENCY PLANS FOR THE AREA TO DEAL WITH ALL HAZARDS IN-CLUDING THOSE OF T0XIC CHEMICAL SPILLS, HURRICANES AND FLOODS WHICH EVERYONE AGREES HAVE A MUCH HIGHER P R O B A B I '. ! T Y OF CCCURRING THAN AN ACCIDENT AT A NUCLEAR POWER PLANT. FEMA, THEREFORE, CONCLUDES THAT THE PETITION DOES NOT PRO-VIDE INFORMATION WHICH SUSTAINS THE CONTENTION.
a . B) PETITIONERS:
"IHERE ARE NO WORKABLE PLANS FOR EVACUATING THE PHYSICALLY DISABLED, NURS!NG HOME RESIDENTS, SCHOOL CHILDREN, HOSPITAL PATIENTS, CAMPERS, INMATES OF CORRECTIONAL FACILITIES, CR PEOPLE WITHOUT AUTOML.!LES. IN LIGHT OF THE DEFICIENCY NOTED IN C. BELOW (LACK OF CONTRACTUAL AGREEMENTS WITH TRANS-PORTATION PROVIDERS), GENERAL STATEMENTS IN THE PLAN TO THE EFFECT THAT THESE GROUPS WILL SOMEHOW BE EVACUATED ARE MEAN-INGLESS AND UNREALISTIC."
FEMA: IHIS ISSUE WAS RAISED PREVIOUSLY IN THE "PETITION OF THE NASSACHUSETTS PUBLIC INTEREST KESEARCH GROUP FOR EMERGENCY AND KEMEDIAL ACTION" FILED BY MASSPIRG WITH THE NRC ON JULY 20, 1983 NO SUBSTANTIVE NEW ISSUES ARE RAISED IN THE CURRENT PETITION. FEMA HAS STATED PREVIOUSLY IN ITS NOVEMBER 3, 1983, ANALY-SIS OF THE MASSPIRG PETITION (SEE APPENDIX 1) THAT THE COMMONWEALTH OF MASSACHUSETTS PLANNING FOR SPECIAL NEEDS POPULATION IS WEAK BUT ACCEPTABLE. MCUA IN ITS RESPONSE TO THE 1983 MASSPIRG PETITION, HAS STATED THAT IN ADDITION j TO LOCAL RESOURCES THE SUBSTANTIAL RESOURCES OF THE LOMMON- i 1 WEALTH WOULD BE BROUGHT TO BEAR SHOULD LOCAL GOVERNMENTS NEED ADDITIONAL ASSISTANCE IN EVACUATING SPECIAL NEEDS POPULATIONS. THE LOCAL PLANS SPECIFY THAT NURS!NG HOME RESIDENTS WILL BE EVACUATED BY PRIVATE AUTO, INSTITUTIONAL VAN, FIRE DEPARTMENT AMBULANCES, AND BUSES, IF NECESSARY. j IHE ONLY HOSPITAL LOCATED WITHIN THE 10-MILE EPl IS THE JORDAN HOSPITAL IN PLYMOUTH. IHE PROTECTION FACTOR AFFORDED BY THE HOSPITAL BUILDINGS' STRUCTURE AND MATERIALS WILL BE SUFFICIENT TO ALLOW SHELTER-!N-PLACE AS THE APPROPRIATE
23 - PROTECTIVE ACTION FOR MANY ACCIDENT SCENARIOS. n0 WEVER,
- ~ NECESSARY, MOST ;F THE :ATIENTS .v0ULD BE EVACUATED EY 2RIVATE AUTOS GF THE STAFF AND PATIENTS OR SY SUSES COOR-DINATED Ef ?LYMOUTH.alvlt UEFENSE STAFF. INTENSIVE CARE AND ORTHOPEDIC PATIENTS'WHO NEED LIFE-SUPPORT SYSTEMS OR SPECIAL CARE IN MOVING WILL BE TRANSPORTED BY AMBULANCES.
IHROUGH RESPONSE CARDS INCLUDED WITH THE ANNUAL iPI BRO-CHURES DISTRIBUTED TO ALL HOUSEHOLDS wlTHIN THE 19 MILE LE2, DHYSICALLY DISABLED INDIVIDUALS ARE SElNG IDENTIFIED 10 MAT i:EC: AL RANSPORTATION NEEDS CAN EE : DENT!FIED !N ADVANCE. AS MENTIONED ABOVE IN RESPONSE TO ISSUE 15(B), THE LOCAL DLANS SPECIFY THAT CONTRACTOR SCHOOL BUSES MAY BE USED To MOVE THOSE WITHOUT PERSONAL MEANS OF TRANSPORTATION. TviE PLAN PROVIDES THAT, IF THERE IS TIME, SCHOOL CHILDREN WILL SE RETURNED HOME TO EVACUATE dlTH THElR FAMILIES, UNLESS A DECISION lS MADE AT THE OTATE OR LOCAL .EVEL, TO EVACUATE IN BUSES-dVACUATION PLANS FOR INMATES AT CORRECTIONAL FACILITIES ARE DETAILED IN LOCAL PLANS. IHERE ARE ONLY THREE SUCH FACIL-ITIES ALL LOCATED WITHIN THE IOWN OF PLYMOUTH. IHESE l ARE THE PLYMOUTH COUNTY HOUSE OF CORRECTION (1984 EST. PEAK USE 255 INMATES), THE IOWN OF PLYMOUTH JAll (1984 EST. PEAK USE - 22 INMATES), AND THE MASSACHUSETTS COR-RECTIONAL INSTITUTION (1984 EST. PEAK USE - bS INMATES). I
.36),
ACCORDING TO THE IOWN CF ?LYMOUTH ntnP DATED .' AY EACH FACILITY HAS ESTABLISHED PROCEDURES FOR SHELTERING OR EVACUATION OF INMATES AND STAFF. RECEPTION FOR INMATES, IN THE EVENT OF AN EVACUATION, WILL BE PROVIDED BY THE MASSACHUSETTS CORRECTIONAL [NSTITUTION IN BRIDGEWATER. IRANSPORT WILL BE VIA BUSES AND VANS PRO-VIDED 3Y EACH INSTITUTION, dlTH ADDITIONAL BACK-UP AVAIL-ABLE : ROM THE MATIONAL 3UARD. A COMPARISON OF THE ANTICIPATED TRANSPORTATION REQUIREMENTS THAT a0ULD BE NECESSARY TO EVACUATE THE TRANSIT DEPENDENT POPULATION (INCLUDING MOBILITY IMPAIRED INDIVIDUALS, NURSING HOME RESIDENTS, HOSPITAL PATIENTS, SCHOOL CHILDREN AND INMATES AT CORRECTIONAL FACILITIES) WITH THE TRANSPORTATION RESOURCES ARTICULATED BY THE COMMONWEALTH OF NASSACHUSETTS, (ESPECIALLY, THE VAST $ TATE CONTROLLED RESOURCE OF MBIA BUSES) DOES NOT SUPPORT THE PETIT 10N'S ALLEGATIONS THAT THE AREA 11 MCDA AND AND STATE RESOURCES ARE '1NADEOUATE TO HANDLE AN EVACUATION. FEMA, THEREFORE, CONCLUDES THAT THE PETITION DOES NOT PROVIDE INFORMATION SUFFICIENT TO SUSTA!N ITS CONTENTION. ON THE OTHER HAND, FEMA, IN ITS SELF-INITIATED REVIEW HAS ANALYZED INFORMATION OF ITS OWN THAT SPEAKS TO THE ISSUES RAISED.
25 - . C 1) PETITIONERS: IESTIMONY BY FEMA AND MCDA 0FFICIALS AT THE JUNE 18, 1986 HEARING ON THE PILGRIM KERP INDICATED THAT THERE ARE NO CONTRACTUAL AGREEMENTS WITH BUS COMPANIES OR BUS DRIVERS, AMBULANCE COMPANIES, OR ANY OTHER TRANSPORTATION PROVIDERS FOR THOUSANDS OF PEOPLE WHO CANNOT DRIVE OR MAY NOT HAVE AN AUTOMOBILE. FEMA: IHIS ISSUE WAS RAISED PREVIOUSLY IN THE "PETITION OF THE MASSACHUSETTS P U B '. ! C INTEREST RESEARCH GROUP FOR LMERGENCY AND KEMEDIAL ACTION" FILED BY MASSPiKG w!TH THE NRC ON JULY 20, 1963 NO SUBSTANTIVE NEW ISSUES ARE RAISED IN THE CURRENT PETITION. AT THE PRESENT TIME THERE ARE NO WRITTEN AGREEMENTS WITH PRIVATE BUS COMPAN!ES ALTHOUGH THE STATE HAS BEEN CONSIDER-INC THE NEED FOR THESE AGREEMENTS SINCE JULY 1983, (SEE MCDA RESPONSES TO MASSPIRG PETITION, PAGE 9, APPENDIX lll). AS STATED IN FEMA'S RESPONSE TO THE 1983 MASSPIRG PETITION (APPENDlX 1), ARRANGEMENTS HAVE BEEN MADE WITH THE MASSA-CHUSETTS 3AY IRANSPORTATION AUTHORITY (MBTA), A STATE AGENCY THAT, IN AN EMERGENCY, MAY BE DIRECTED BY THE 60VERNOR TO RESPOND. ACCORDING TO THE COMMONWEALTH OF 1 MASSACHUSETTS, AN INVENTORY OF PUBLIC TRANSPORTATION RESOURCES IS AVAILABLE ON COMPUTER AND THESE RESOURCES SHOULD BE SUFFICIENT TO PROVIDE TRANSPORTATION TO THOSE WHO NEED IT. [111, SELF-lNITIA.TED REVIEW AND INTERIM i flNDING FOR UPDATED INFORMATION). l
C.2) PETITIONERS:
~
NO DRIVERS HAVE BEEN TRAINED IN THEIR SUPPOSED ROLE IN EVACUATION PLANS. IN FACT, NO DRIVERS HAVE BEEN INFORMED THAT THEY HAVE A ROLE IN EVACUATION PLANS. FEMA: AN EMERGENCY WORKER IS AN INDIVIDUAL WHO HAS AN ESSENTIAL MIS-SiON WITHIN THE PLUME LXPOSURE LPl TO PROTECT THE HEALTH AND SAFETY OF THE PUBLIC WHO COULD BE EXPOSED TO 10N! ZING RADIATION FROM THE PLUME OR ITS DEPOSITION. THE EMERGENCY WORKER MUST BE TRAINED IN THE BAS!C CHARACTERISTICS OF [0N! ZING RADIATION AND ITS HEALTH EFFECTS. IN THIS CONTEXT, BUS DRIVERS AND OTHER DERSONNEL WHO WILL drive EVACUATION VEHICLES MAY BE EMERGENCY w0RKERS AND AS SUCH SHOULD BE TRAINED IN THEIR ROLE DURING AN EMERGENCY. [111, FEMA-REP-2 (REV. 1) "6UIDANCE ON OFF-SITE EMERGENCY RADIATION SYSTEMS", PHASE 1 - AIRBORNE KELEASE, DECEMBE'R 1985, P. 5-1, AND NUREG-U6S4, FEMA REP-1, REv.-1, 11 U. 1,2, 4 AND 5.] IHE MASSACHUSETTS PLANS FOR DEALING WITH AN ACCIDENT AT PILGRIM INDICATE THAT THE PRIMARY MEANS OF EVACUATION FOR THE LPl WILL BE PRIVATE AUTOMOBILES. (1LE, 112., IOWN OF PLYMOUTH RADIO-LOGICAL EMERGENCY RESPONSE PLAN, P.7 ET SEQ.l. FOR POPULATIONS WHO DID NOT HAVE ACCESS TO PRIVATE AUTOMOBILES, THE PLANS CON-TEMPLATE THE USE OF BUSES OR AMBULANCES. [F EXTRA BUSES ARE NEEDED FF,0M OUTSIDE THE EPZ, THE TOWNS WOULD CONTACT THE STATE AREA 11 CIVIL DEFENSE HEADQUARTERS WHICH WOULD THEN COORDINATE THE PROVISION OF SUCH RESOURCES FROM THE VAST RESOURCES AVAILABLE To THE COMMONWEALTH Oc MASSACHU5ETTS ESPECIALLY INCLUDING THE MBIA (ID. AT PP. 24-33).
27 - FEMA HAS NO INDICATION THAT APPROPRIATE TRAINING (E.G., IN NOTIFICATION, RAD 10' LOGICAL EXPOSURE CONTROL, AND RADIOLOGICAL ACCIDENTS) HAS BEEN PROVIDED. IHE IOWN OF PLYMOUTH l!Vil UEFENSE U! RECTOR INDICATED AT THE FEMA SPONSORED PUBLIC MEET-ING ON THE PLANS ON JUNE 3, 1982, THAT A TRAINING PROGRAM FOR BUS DRIVERS WAS BEING DEVELOPED FOR DEPLOYMENT IN THE FALL OF 1982 (1LE, TRANSCRIPT OF A PUBLIC MEETING AN THE STATE KAD10 LOGICAL EMERGENCY KESPONSE PLAN, P. 37). HOWEVER, dE UNDERSTAND THAT SUCH TRAINING DID NOT TAKE PLACE, AND IN ANY CASE, TRAINING FOR BUS DRIVERS IN RADIOLOGICAL EXPOSURE CONTROL HAS NOT EVER BEEN PROVIDED TO BUS DRIVERS. LACK OF TRAINING FOR DRIVERS OF EVACUATION VEHICLES OR ANY OTHER EMERGENCY WORKER IS A PROBLEM AND IS NOT IN ACCORDANCE WITH FEDERAL GUIDANCE. IHE COMMONWEALTH OF MASSACHUSETTS PLANS FOR EVACUATING THE PILGRIM EPZ CONTEMPLATE THAT THOSE BUS DRIV;RS FROM OUTSIDE THE LPZ WILL MAKE ONLY ONE RUN INTO THE LPZ, PICK UP PASSENGERS AT A OESIGNATED SITE, AND IMMEDI-ATELY LEAVE. IN ADDITION, BASED ON OUR OBSERVATIONS OF THE MASSACHUSETTS EXERCISES OF THE PILGRIM PLANS, WE UNDERSTAND THAT THE STATE WILL CAREFULLY CONSIDER THE DOSE CONSEQUENCES TO THE DRIVER AND HIS PASSENGERS, AND THE OPTIMUM TIME FOR THE EVACUATION TRIP SELECTED. (1E1, hASSACHUSETTS KAD10 LOG-l CAL EMERGENCY RESPONSE PLAN SSP.A.3, P.B.1, AND P.B.31 IHE STATE HAS INFORMED US THAT IN THE EVENT THAT A DRIVER
1 o' 'e l l 28 - 0F AN EVACUATION VEHICLE WAS LIKELY TO'BE EXPOSED TO A LARGER DOSE OF RADIATION THAN THE GENERAL PUBLIC, THE STATE DECISION-MAKERS COULD USE AS EVACUATION DRIVERS A SUBSTANTIAL POOL OF STATE POLICE AND CIVIL DEFENSE WORKERS WHO HAVE BEEN APPROPRIATELY TRAINED IN RADIOLOGICAL EMERGENCY RESPONSE. IHIS TYPE OF PRIMARILY AA dQC RESPONSE IS NOT DESIRABLE HOWEVER, AND THE COMMONWEALTH SHOULD IMPROVE ITS PLANS IN THIS AREA. IO ASSIST STATE AND LOCAL GOVERNMENTS IN IMPROVING THEIR PLANNING IN THE AREA 0F BUS TRANSPORTATION, PARTICULARLY FOR SCHOOL CHILDREN, FEMA HAS DEVELOPED GUIDANCE MEMORANDUM EV-2, "PROTECTIVE ACTIONS FOR SCHOOL CHILDREN". IHIS DOCUMENT WILL ASSIST THE COMMON-WEALTH IN REFINING PLANS FOR BUS TRANSPORTATION, AND DRIVER TRAINING. FEMA WILL INSIST THAT IMPROVED PLANS AND TRAINING RELATED TO BUS DRIVERS BE DEVELOPED PRIOR TO, AND TESTED DURING, THE NEXT EXERCISE OF THE PILGRIM RADIOLOGICAL EMERGENCY MESPONSE PLANS. IN THE MEANTIME, FEMA BELIEVES THAT THE USE OF TRAINED STATE POLICE AND civil DEFENSE WORKERS AS BUS DRIVERS IS AN ADEQUATE COMPENSATORY MEASURE, AND THEREFORE, THE 1 PETITION DOES NOT PROVIDE INFORMATION WHICH SUSTAINS THE l CONTENTION. l l
29 - C.)) PETITIONERS: FURTHERMORE, THE PROPOSED ROUTE OF SUC.H EVACUATION (KOUTE 3 NORTH AND MOUTE 44 WEST) ARE COMPLETELY INADEQUATE TO EFFEC-T!VELY HANDLE THE ANTICIPATED VOLUME OF TRAFFIC. IHIS IS PARTICULARLY TRUE DURING THE SUMMER MONTHS DUE TO THE HEAVY VOLUME OF TJURISTS HEADING TO AND FROM CAPE COD. FEMA: FEMA THOROUGHLY ANALYZED THIS ISSUE IN 1984 AT THE REQUEST OF THE NRC, (SEE APPENDIX 2). WHILE ROUTES 3 AND 44 ARE T H E .'i A J O R ROUTES LEADING OUT OF THE EPZ, THERE ARE MANY OTHER ROADS *HICH CAN BE USED TO LEAVE THE AREA. ALL RCUTES LEADING INTO THE kPl WILL BE CLOSED TO INCOMING TRAFFIC, ACCORDING TO THE "STATE PO'. ! C E HIGHWAY IRAFFIC LONTROL. AND NOTIFICATION PLAN FOR AN EMERGENCY AT PILGRIM l NPS." IHE EVACUATION TIME ESTlMATE FOR THE PILGRIM LPl 'H AS BEEN EXTENSIVELY REVIEWED BY EbMA AND THE NRC AND FOUND TO BE ADEQUATE. POSSIBLE BOTTLE NECKS HAVE BEEN IDENTIFIED AND TRAFFIC MANAGEMENT PLANS HAVE BEEN DEVELOPED TO ALLOW EVAC- l UATION TO PROCEED AS RAPIDLY AS POSSIBLE. BOSTON EDISON HAS RECENTLY CONTRACTED TO UPDATE THE EVACUA-TION IIME ESTIMATE AND TRAFFIC MANAGEMENT PLAN FOR THE , PILGRIM EPZ. (SEE APPENDIX 5, PAGES 11-12). 1 l FEMA, THEREFORE, CONCLUDES THAT THE ISSUES RAISED IN SECTION 17 0F THE PETITION DO NOT PROVIDE INFORMATION SUFFICIENT TO SUSTAIN ITS CONTENTION. UN THE OTHER HAND, FEMA, IN ITS
'. '. l l l l 30 - l l i i SELF-INITIATED REVIEd HAS ANALYZED INFORMATION THAT SPEAKS TO THE ISSUES RAISED IN 17.C.1 AND 17.C.2 i 18/ ALLEGED UEFICIENCIES IN MEDICAL FACILITIES 1 A) PETITION: VARIOUS NRC AND FEMA REGULATIONS REQUIRE THAT ARRANGEMENTS BE MADE FOR MEDICAL SERVICES FOR CONTAMINATED INJURED INDI-VIDUALS (10 CFK $50 47 (B)(12); 10 CFR PART 50, APPENDIX L. ll.h AND IV. E.7; EVALUATION CRITERIA L 1 AND L 3). THE PLAN MAKES INADEQUATE PROVISION FOR TREATMENT OF VICTIMS OF RADIO-ACTIVE CONTAMINATION. A naSSPik6 1983 STUDY OF THE TWO HOSPITALS LISTED IN THE PLAN IN EFFECT REVEALED THEY HAVE A TOTAL CAPACITY TO TREAT ONLY EIGHT OR N!NE VICTIMS OF RADIO-ACTIVE CONTAMINATION. UNE OF THESE (JORDAN HOSPITAL, PLYMOUTH) IS WITHIN FOUR MILES OF THE PLANT, SO !T MAY NEED TO BE EVACUATED. IHE OTHER (MORTON HOSPITAL, IAUNTON) IN 1985 HAD NO STAFF TRAINED FOR RADIOLOGICAL ACCIDENTS. NO DATA SUGGESTS THE SITUATION HAS MATERIALLY IMPROVED SINCE 1983 FEMA: IHIS IS$ge WAS RAISED PREVIOUSLY IN THE "PETITION OF THE MASS-ACHUSETTS FJBLIC INTEREST RESEARCH GROUP FOR EMERGENCY AND KE-MEDIAL ACTlLN" FILED BY MASSPIRG WITH THE NRC ON JULY 20, 1983 NO SUBSTANTIVE rt E N ISSUES ARE RAISED IN THE CURRENT PETITION. [N ITS RESPONSE TO THE PETITION THE COMMONWEALTH OF MASSACHU-SETTS STATED (APPENDIX 3, JULY 20, 1983): UNDER NO CIRCUMSTANCES WOULD WE EXPECT LARGE NUMBERS OF CONTAMINATED INDIVIDUALS. THE NRC THROUGH NUREG-0396 MADE IT CLEAR THAT MEDICAL REQUIREMENTS RESULTING FROM POWER PLANT ACCIDENTS NEED INVOLVE ONLY LIMITED FACILITIES FOR TREATMENT OF EXPOSED OR CONTAMINATED INDIVIDUALS. NONETHELESS, ALL ACCREDITED MASSACHUSETTS HOSPITALS MUST MAINTAIN A CAPABILITY TO TREAT EXPOSED OR CONTAMINATED INDIVl* DUALS. l
l I EEMA PREVIOUSLY STATED (APPENDIX 1, NOVEMBER 3, 1983): IKIS CONCERN HAS BEEN ADDRESSED IN ACCORDANCE WITH NRC'S REQUIREMENTS AS FOLLOWS:
- 1) NUREG-0396 MAKES IT CLEAR THAT MEDICAL REQUIREMENTS RESULTING FROM POWER PLANT ACCIDENTS NEED. INVOLVE ONLY <
LIMITED FACILITIES FOR TREATMENT OF EXPOSED OR CONTAM- ' INATED INDIVIDUALS. IHIS POSITION IS IN ACCORD WITH THE NRC COMMISSIONER'S MEMORANDUM AND ORDER OF APRIL 4, i 1983 (17 NRC 528 (1983), C L1-83-10) WHICH STATES: NO ADDITIONAL MEDICAL FACILITIES OR CAPABILITIES HOWEVER, ARE REQUIRED FOR THE GENERAL PUBLIC. FACILITIES WITH WHICH PRIOR ARRANGEMENTS ARE MADE AND THOSE LOCAL OR REGIONAL FACILITIES WHICH HAVE THE CAPABILITY TO TREAT CONTAMINATED INJURED INDIVI-DUALS SHOULD BE IDENTIFIED....kMERGENCY PLANS SHOULD, HOWEVER, IDENTIFY THOSE LOCAL OR REGIONAL MEDICAL FACILITIES WHICH HAVE THE CAPABILITIES TO PROVIDE APPROPRIATE MEDICAL TREATMENT FOR RADIATION EXPOSURE. NO CONTRACTUAL AGREEMENTS ARE NECESSARY AND NO ADDI-TIONAL HOSPITALS OR OTHER FACILITIES NEED BE CON-STRUCTED.
- 2) WE NOTE THAT ALC ACCREDITED MASSACHUSETTS HOSPITALS ARE REQUIRED BY THE COMMONWEALTH TO MAINTAIN A CAPABILITY TO TREAT EXPOSED OR CONTAMINATED INDIVIDUALS AND EMER-GENCY PERSONNEL ARE ADVISED IN THE HANDLING OF RADI-ATION VICTIMS. IN ADDITION, AS REQUIRED BY NRC REGULA-T10NS, THE UTILITY HAS MADE ARRANGEMENTS WITH JORDAN HOSPITAL IN PLYMOUTH TO PROVIDE ACUTE TREATMENT FOR EXPOSED OR CONTAMINATED PERSONNEL. IHIS ABILITY WAS REVIEWED BY THE MAY 1982 EXERCISE OF THE EMERGENCY PLAN AND FOUND ACCEPTABLE.
IHESE ARRANGEMENTS ARE DOCUMENTED ON PAGE 133 AND ANNEX A 0F THE EMERGENCY PLAN FOR THE PILGRIM NUCLEAR POWER STATION. BOSTON EDISON STATED THAT ADDITIONAL HOSPITALS HAVE BEEN , 1 IDENTIFIED AND ARRANGEMENTS HAVE BEEN MADE WITH THEM CON-1 CERNING TREATMENT OF CONTAMINATED INDIVIDUALS OR RADIATION i VICTIMS. (APPENDIX 5, PAGE 15). l l l l l i
32 - ADDITIONAL RESOURCES ARE AVAILABLE IN OTHER AREAS AND THROUGH THE FEDERAL kAD10 LOGICAL EMERGENCY XESPONSE PLAN. EEMA, THEREFORE, CONCLUDES THAT THE PETITION DOES NOT 390-VIDE INFORMATION WHICH SUSTAINS THE CONTENTION. B) PETITIONERS: IHE PLAN FAILS TO PROVIDE FOR THE DISTRIBUTION OF RADIO-PROTECTIVE DRUGS FOR THE PREVENTION OF THYR 0!D TUMORS TO THE GENERAL PUBLIC OR TO PERSONS IN INSTITUTIONS WHO MAY NOT BE EVACUATED. THE NRC AND FthA RECOMMEND DISTRIBUTION OF SUCH DRUGS AT LEAST TO SUCH INSTITUT10NALIZED PERSONS (hVALUATION CRITERIA, J.10.E. AND J 10.F.J). FEMA: IHIS IS SIMILAR TO AN ISSUE THAT WAS RAISED PREVIOUSLY IN THE "PETITION OF THE MASSACHUSETTS PUBLIC INTEREST RESEARCH 6ROUP FOR EMERGENCY AND REMEDIAL ACTION" FILED BY MASSPIRG wlTH THE NRC ON JULY 20, 1983 HOWEVER THE PETITIONER IN THIS CASE MAKES THE ADDITIONAL POINT THAT THERE ARE NO SPECIFIC PROVISIONS IN THE MASSACHUSETTS RADIOLOGICAL EMERGENCY PLANS FOR PROVIDING RADIO PROTECTIVE DRUGS TO INSTITUT!0NALIZED PERSONS AS IS REQUIRED BY FEDERAL GUIDANCE. IN ITS RESPONSE TO THE 1983 NASSPIRG PETITION, THE COMMONWEALTH OF MASSACHUSETTS STATED (APPENDIX 3): THE MASSACHUSETTS DEPARTMENT OF PUBLIC HEALTH (MDPH) HAS ADVISED THAT DISTRIBUTION OF POTASSIUM IODIDE IN MASSACHUSETTS WILL BE LIMITED TO EMERG-ENCY WORKERS DURING THE INITIAL PHASE OF AN EMERG-ENCY. IHE MDPH POLICY IS BASED UPON THE DRUG S POTENTIAL ADVERSE SIDE EFFECTS !F DISTRIBUTED TO THE GENERAL POPULATION INDISCRIMINATELY. 1 FEMA STATED IN ITS RESPONSE TG THE 1983 MASSPi1G PETITION (APPENDlX 1):
33 - IHE COMMONWEALTH OF MASSACHUStTTS HAS CAREFULLY REVIEdED THIS ISSUE AND FORMULATED A POLICY FOR THE DISTRIBUTION OF POTASSIUM IODIDE WHICH IS THAT IT WILL ONLY BE GIVEN TO EMERGENCY WORKERS UNDER EX-TRAORDINARY CIRCUMSTANCES. [F THERE WERE A POS-SIBILITY OF RADICACTIVE 10 DINES BEING RELEASED, THE COMMONWEALTH WOULD EVACUATE THE AREA OR SHELTER THE POPULATION RATHER THAN HAVE THEM TAKE RADIO-PROTECT!vE DRUGS. IHIS POLICY IS BASED UPON THE COMMONWEALTH'S PERCEPTION OF THE DRUG'S POTENTIAL ADVERSE SIDE EFFECTS IF DISTRIBUTED TO THE GENERAL POPULATION, AND IS CONSISTENT WITH CURRENT FEDERAL POLICY. (SEE APPENDIX b) IHE COMMONWEALTH'S PLAN FOR THE DISTRIBUTION OF POTASSIUM IODINE TO INSTITUT10NALIZED PEOPLE IS WEAK. IHE bTATE UIR-ECTOR OF THE UEPARTMENT OF PuBLIC HEALTH, HADIATION LONTROL UNIT HAS TOLD US THAT THE LURRENT hASSACHUSETTS POLICY 15 THAT THE COMMISSIONER OF PUBLIC HEALTH WOULD ANALYZE THE SITUATION AT THE TIME OF THE ACCIDENT TO DETERMINE IF THE ADMINISTRATION OF Kl TO INSTITUT10NALIZED PEOPLE IS WARRANTED. BECAUSE OF THE COMPARATIVELY FEW INSTITUTIONS IN THE P!LGRIM PLUME EXPOSURE EMERGENCY PLANNING ZONE THE DISTRIBUTION OF Kl TO THE INSTITUTIONS COULD BE ACCOMPLISHED ON AN AD HOC BASIS USING EXISTING STOCKS MAINTAINED BY NUCLEAR UTILITIES. IHE COMMONWEALTH'S PLAN WOULD BE ENHANCED IF THE POLICY FOR THE ADMINISTRATION OF Kl TO INSTITUT10NALIZED PEOPLE WERE CLEARLY STATED; AND IF PROCEDURES FOR THE DISTRIBUTION OF Kl TO THE INSTITUTIONS WERE MORE FULLY DEVELOPED. l FEMA, THEREFORE, CONCLUDES THAT WHILE THE PETITION POINTS OUT A WEAKNESS IN THE MASSACHUSETTS PLANS, IT DOES NOT PROVIDE INFORMATION WHICH SUSTAINS THE CONTENTION. 1
34 - 10/ IHE EMERGENCY ULANNING 20NE IS IOO SMALL A) PETITIONERS: IHE ENVIRONMENTAL PROTECTION AGENCY (EPA) RECOMMENDS PRO-TECTIVE MEASURES BY THE PUBLIC WHEN RADIATION EXPOSURE IS LIKELY TO EXCEED THE EPA'S "PROTECTIVE ACTION GUIDE" 0F ONE REM (MANUAL OF PROTECTIVE ACTION 6UIDE AND PROTEC-TIVE ACTIONS FOR UUCLEAR ACCIDENTS, EPA-520/1-75-001, EPA, 1975). FEMA: IHE COMMONWEALTH OF MASSACHUSETTS KAD10 LOGICAL EMERGENCY XESPONSE PLAN IS CONSISTENT alTH FEDERAL PROTECTIVE ACTION 3UIDELINES. B) PETITIONERS: NRC REGULATIONS REQUIRE THE EXACT SIZE AND CONFIGURATION OF EACH EPl TO BE "DETERMINED IN RELATION TO LOCAL RESPONSE NEEDS AND CAPABILITIES AS THEY ARE AFFECTED BY SUCH COND!- T10NS AS DEMOGRAPHY, TOPOGRAPHY, LAND CHARACTERISTICS, ACCESS ROUTES, AND JURISDICTIONAL BOUNDARIES." GENERALLY, THE NRC PROVIDES, THE PLUME EXPOSURE EPZ SHOULD BE ABOUT TEN MILES IN RADluS (10 CFR PART 50 47 (C)(2)). BOSTON EDISON COMPANY HAS ADMITTED THAT THE ONLY FACTOR USED TO CREATE THE PILGRIM EPZ WAS JURISDICTIONAL BOUNDARIES (RESPONSE OF BOSTON EDISON COMPANY TO COMMONWEALTH OF MASSACHUSETTS' FIRST SET OF INTER-ROGATORIES ON EMERGENCY PLANNING, JULY 20, 1931, P. 21). FEMA: IHE REGIONAL ASSISTANCE COMMITTEE, WHICH IS CHAIRED BY FEMA, REVIEWED THE PROPOSED PILGRIM NUCLEAR POWER STATION PLUME EXPOSURE EMERGENCr PLANNING ZONE AND FOUND IT TO BE ADEQUATE IN SIZE AND THAT IT ADEQUATELY ADDRESSED THE DEMOGRAPHIC, TOPOGRAPHIC AND LAND USE CHARACTERISTICS, ACCESS ROUTES, AND JURISDICTIONAL BOUNDARIES.. I l l l 1
l l 35 - IHE COMMONWEALTH OF MASSACHUSETTS INDICATED AT THE PLYMOUTH PUBLIC MEET!NG (JUNE $O, 198b) IT WILL REVIEW THE SIZE OF THE PILGRIM PLUME EXPOSURE EMERGENCY PLANNING /0NE AS PART OF AN ONGOING EFFORT TO IMPROVE EMERGENCY PLANS AND PREPARED-NESS AROUND NUCLEAR POWER PLANTS. FEMA CONCLUDES THAT THE PETITION CONTAINS NO EVIDENCE TO SUGGEST THAT THE SIZE OF THE PLUME EXPOSURE EMERGENCY PLAN-NING 20NE FOR THE PILGRIM NUCLEAR POWER STATION IS TOO SMALL. C) PETITIONERS: CAPE COD BEGINS JUST ELEVEN MILES FROM PILGRIM AND IS CONNECTED TO THE MAINLAND BY ONLY TWO BRIDGES. lHERE IS NO EMERGENCY PLANNING FOR CAPE COD, NOR PUBLIC EDUCATION OF PROTECTIVE MEASURES, NOR WARNING SIRENS. HOWEVER, THERE ARE PLANS TO CLOSE THE CAPE COD BRIDGES TO PREVENT ITS EVAC-UATION, SO AS TO GIVE PREFERENCE TO EVACUEES WITHIN THE PLANT'S lO-MILE RADIUS. IHIS IS TOTALLY UNACCEPTABLE TO THE PEOPLE ON THE LAPE, WHO WOULD BE IN THE PATH OF A RADIOLOGICAL PLUME IF THE WIND WERE BLOWING TOWARD THE CAPE. EVEN IF THEY WERE ALLOWED TO EVACUATE THE CAPE OVER THE CONNECTING BRIDGES, THEY WOULD BE DOING SO IN THE DIRECTION OF THE PLANT AND THE SOURCE OF THE RADIATION. IHE ISSUE OF EVACUATING CAPE COD IS EXTREMELY IMPORTANT IN THE LIGHT OF THE CHERNOBYL ACCIDENT, SINCE THERE THE RADIOACTIVE PLUME EXTENDED MUCH FURTHER THAN lO-MILES. FEMA: IHIS ISSUE WAS RAISED PREVIOUSLY IN THE "PETITION OF THE MASSACHUSETTS PUBLIC INTEREST RESEARCH GROUP FOR EMERGENCY AND REMEDIAL ACTION" FILED BY MASSPIRG WITH THE NRC ON l JULY 20, 1983 NO SUBSTANTIVE NEW ISSUES ARE RAISED IN THE CURRENT PETITION. i FEMA STATED IN ITS RESPONSE TO iHE 1983 PETITION (APPENDIX 1): 1 i _ _ - - . ~ - - -
'e l l
l 36 - i I IHE CONCLUS!0N IN THE MAbbFlkb PETITION THAT THE
$1ZE OF THE iMERGENCY DLANNING LONE SHOULD BE IN-CREASED TO INCLUDE LAPE LOD AND OTHER AREAS IS BASED UPON A REPORT DREPARED FOR THE MASSACHUSETTS ATTORNEY 6ENERAL'S OFFICE. IMIS REPORT WAS PREPARED BY hHb IECHNICAL ASSOCIATES AND IS ENTITLED "REVIEW OF CAL-CULATION OF KEACTOR ACCIDENT CONSEQUENCES (CRAL 2)
RESULTS AND L10u!D PATHW AYS, (NUREG-1596) STUDY:
"I PLICATIONS M FOR EMERGENCY PLANNING IN THE VICINITY OF THE PILGRIM NUCLEAR POWER STATION."
IHE REPORT CONCLUDES "... PROTECTIVE ACTION GUIDELINE DOSES MAY BE EXCEEDED IF THE CURRENT EMERGENCY PLANNING ZONES ARE USED." IO THE EXTENT THAT THIS STATEMENT INDICATES.A NEED TO INCREASE THE SIZE OF THE APPROXIMATELY lO-MILE RADIUS PLUME EXPOSURE PATHWAY ZONE AT PILGRIM, SUCH A CONCLUSION IS NOT GENERALLY ACCEPTED BY THE SCIENTIFIC COMMUNITY AT THIS TIME. IHE SIZE AND CONFIGURATION OF THE EMERGENCY PLAN-NING 40NE FOR PILGRIM !S BASED UPON NUKtG-Obb4 CRITERIA AND APPROVED BY THE KEGIONAL ASSISTANCE LOMMITTEE (KAC). IHE SIZE OF THE LPl TO BE USED FOR RADIOLOGICAL EMERGENCY RESPONSE WAS DETERMINED BY A JOINT NKC/LPA IASK FORCE STUDY. lHE CONCLU-SIONS REACHED BY THE TASK FORCE ARE DOCUMENTED IN NUKtG-0396, LPA 320/1-78-016 BOTH NUKtb-Ubb4 AND NUREG-0396 RECOGNIZE THAT PAGS MIGHT BE EXCEEDED BEYOND THE TEN MILE PLUME EXPOSURE LPl IN THE EVENT OF THE WORST POSSIBLE ACCIDENT AND METEOROLOGICAL CONDITIONS. HOWEVER, A IEN N!LE PLUME EXPOSURE tPl WAS STILL CHOSEN AS A PLANNING BASIS IN NUREG-0654 BECAUSE: A. CROJECTED DOSES FROM THE TRADITIONAL DESIGN BASIS ACCIDENTS WOULD NOT EXCEED PAG LEVELS OUTSIDE THE ZONEJ B. PROJECTED DOSES FROM MOST CORE MELT SEQUENCES WOULD NOT EXCEED PAG LEVELS OUTSIDE THE ZONE; C. FOR THE WORST CORE MELT SEQUENCES, IMMEDIATE LIFE THREATENING DOSES WOULD GENERALLY NOT 1 OCCUR QUTSIDE THE ZONE; D. DETAILED PLANNING WITHIN 10 MILES WOULD PROVIDE A SUBSTANTIAL BASE FOR. EXPANSION OF RESPONSE , EFFORTS IN THE EVENT THAT THIS PROVED NECESSARY. l l l l l
.' 'o 37 - IHE 'lRC MAS BEEN,1NVEST!3ATING ACCIDENT SOURCE TERMS, DROBABILITIES AND CONSEQUENCES OF NUCLEAR REACTOR AC-OIDENTS :0R SEVERAL YEARS. IHE RESULT OF THESE STUDIES, WHEN COMPLETE, ARE EXPECTED TO BE USED IN REVISING NUKtG 0654 IHE REVISION OF NUKE 6-Ub$4 MAY INCLUDE RECONSID-ERATION OF THE SIZE OF THE tMERGENCY PLANNING LONE.
. CAPE COD IS BEYOND THE 10 MILE LPZ AND DOES NOT NEED SPECIFIC RADIOLOGICAL EMERGENCY PLANS. HOWEVER, AS NOTED EARLIER IN THIS EE5PONSE, THE COMMONWEALTH HAS INDICATED TO FEMA THAT IT WILL REVIEW THE SIZE OF THE PILGRIM PLUME EXPOSURE EMER-3ENCY ULANNING ZONE AS PART OF AN ON-GOING EFFORT TO IMPROVE EMERGENCY OLAN3 AND PREPAREDNESS AROUND NUCLEAR POWER PLANTS.
SPECIFIC, DETAILED PLANS DEVELOPED FOR THE EPZ DO NOT PRECLUDE TAKING APPROPRIATE PROTECTIVE ACTIONS BEYOND THE 10-MILE AREA. IN FACT, THE DETAILED EPZ PLANS BECOME THE BASIS FOR ANY ACTIONS REQUIRED AT GREATER DISTANCES. ACCORDING TO THE MASSACHUSETTS civil UEFENSE AGENCY COMPRE-HENSIVE EMERGENCY MANAGEMENT PLANS WHICH ADDRESS THE USE OF SHELTER AND EVACUATION AS POSSIBLE PROTECTIVE RESPONSE TO EMERGENCIES CURRENTLY EXIST IN MOST COMMUNITIES OUTSIDE OF THE PLUME EXPOSURE EMERGENCY PLANNING ZONE. FEMA HAS JOINED NRC AND THE UEPARTMENT OF bHERGY, LPA AND THE NUCLEAR INDUSTRY IN THE PREPARATION OF A REPORT ON THE CHERNOBYL ACCIDENT. FEMA ACCEPTED THE RESPONSIBILITY FOR THE CHAPTER ON EMERGENCY RESPONSE AND PREPAREDNESS. WE VIEW THIS REPORT AS A NECESSAR PREREQUISITE FOR ANY REvlEW
38 - 0F THE U.b. AAD10 LOGICAL EMERGENCY PREPAREDNESS PROGRAM. IT SHOULD IDENTIFY LESSONS FROM THE CHERNOBYL EXPERIENCE THAT CAN BE USED IN REVIEWING THE V.S. PROGRAM. AT THIS TIME, HOWEVER, WE ARE NOT YET IN A POSITION TO DETERMINE IF THE LESSONS LEARNED AT CHERNOBYL WILL REQUIRE CHANGES IN THE RADIOLOGICAL EMERGENCY PLANNING. FEMA, THEREFORE, CONCLUDES THAT THE PETITION DOES NOT PROVIDE INFORMATION WHICH SUSTAINS THE CONTENTION. D) PETITIONERS: CASING MIS CONCLUSION UPON NKC DATA, THE ATTORNEY bENERAL OF NASSACHUSETTS HAS CONCLUDED THAT THE SIZE OF THE PILGRIM LPl IS INADEGUATE (COMMENTS OF ATTORNEY GENERAL FRANCIS X. DELLOTTI KELAT!vE TO UFF-SITE LMERGENCY PLANNING FOR THE PILGRIM NUCLEAR POWER $TATION, SUBMITTED TO FEMA, AUGUST 1982). FtNA: {N RESPONSE TO A JUNE 3, 1982, PuBLIC MEETING ON THE STATE AND LOCAL UFF-SITE RADIOLOGICAL EMERGENCY PLAN, ASSISTANT j ATTORNEY GENERAL JOANN $HOTWELL OF THE ENv!RONMENTAL PRO-TECTION O! VISION OF THE MASSACHUSETTS ATTORNEY 6ENERAL'S OFFICE REQUESTED BY A LETTER OF JUNE 16, 1982, THAT THE MEETING RECORD BE LEFT OPEN UNTIL THE END OF JULY SO THAT HER OFFICE COULD SUBMIT FURTHER COMMENTS. IHE ATTORNEY GENERAL'S OFFICE RETAINED MHB IECHNICAL ASSOCIATES OF SAN JOSE, CALIFORNIA, TO REVIEW FOR THEM CERTAIN DOCUMENTS RE-LATED TO OFF-SITE PLANNING AROLND THE PILGRIM NPS. IHE MHB REPORT WAS TITLED "MEviEW OF CALCULATION OF REACTOR CON-
'. . i i 39 - SECUENCES (CHAC 2) KESULTS AND LICUID PATHWAYS (NUMEb-1$96) 3TUDY: ! M P L .f ; A T I O N S FOR iMERGENCY E' ANN I NG !N THE '/ICINITY OF THE flLGRIM kUCLEAR POWER STATION". IN A LETTER DATED AUGUST 2b, 1982, FRANCIS X. DELLOTTI, THE .1ASSACHUSETTS ATTORNEY GENERAL (AG) SENT TO FEMA REGION 1, FIFTEEN PAGES OF COMMENTS ADDRESSING FOUR GENERAL ISSUES. UNE OF THESE ISSUES DEALT WITH THE SIZE OF THE 10 MILE PLUME EXPOSURE d?2 SASED ON MHb's TECHNICAL REVIEW OF THE REFERENCED NRC U0CUMENTS, IKE MASSACHUSETTS AG INDICATED THAT 20 TEN-T!AL DOSES TO THE DOPULATION WOULD EXCEED THE .EVELS AT dHICH THE E?A PROTECTIVE ACTION GUIDES RECOMMEND EVACUATION, EVEN AT DISTANCES OF 50 MILES DOWNWIND ~ ROM THE PLANT. THIS SITUATION, THE AG BELIEVES, WOULD OCCUR DURING AN $$I-l w0RSE CASE AC ! DENT UNDER CERTAIN WEATHER CONDITIONS THAT RESULT IN MAXIMUM DOSE. IHUS, THE AG BELIEVES THAT THE CURRENT USE OF THE 10-MILE LPl FOR PILGRIM IS NOT APPRO-PRIATE, AND THAT THE EP2 SHOULD, THEREFORE, BE EXTENDED FURTHER TO INCLUDE ALL OF LAPE LOD. IHIS SAME CONCERN WAS RAISED BY MASSPlHG AND WAS REFERRED TO THE NRC FOR THEIR RESPONSE AS IT WAS IN DIRECT CONFL!CT WITH NRC'S REGULATION 10 CFR 50 7 (C) (2). NRC'S RESPONSE TO MASSPIRG IS DISCUSSED ON PAGES 10-14 0F NRC'S "lNTERIM DIRECTOR'S DECISION UNDER 10 CFR 2 206 (DOCKET NO. 50-293)," (FEBRUARY 27, 1984). I
' l l
40 - THE RESPONSE STATES THAT IHE PLUME EPZ FOR THE PIL3 RIM FACILITY 15 BASED UPON NUREG-0654 GUIDANCE CRITERIA. IHE JOINT NRC/ EPA IASK FORCE THAT DEVELOPED NUKEG-0396 CONSIDERED SEVERAL POSSIBLE RATIONALES FOR ESTABLISHING THE SIZE OF THE EPZS. THESE INCLUDED RISK, PROBABILITY, COST IHE EFFECTIVENESS AND AN ACCIDENT CONSEQUENCE SPECTRUM. IASK FORCE CHOSE TO BASE LPl $1ZE ON A FULL SPECTRUM OF ACCIDENTS AND CORRESPONDING CONSEQUENCES TEMPERED BY PROB-ABILITY CONSIDERATIONS. IT WAS THE CONSENSUS OF THE IASK EORCE THAT A PLUME t?l 0F ABOUT TEN MILES WOULD PROVIDE AN ADEQUATE PLANNING BASE BEYOND WHICH ACTIONS COULD BE TAKEN-ON AN 12 Ngi BASIS USING THE SAME CONSIDERATIONS THAT WENT INTO THE INITIAL ACTION DETERMINATIONS. IN ITS STATEMENT ON "PLANNING 3 ASIS FOR EMERGENCY RESPONSE TO NUCLEAR POWER ACCIDENTS," 44 FED. REG. 61123 (UCT. 23, 1979), THE COMMIS-S!ON NOTED THAT AN EPZ OF ABOUT 10 MILES IS CONSIDERED l LARGE ENOUGH TO PROVIDE A RESPONSE BASE WHICH WOULD SUPPORT ACTIVITY OUTSIDE THE PLANNING ZONE SHOULD THIS EVER BE NEEDED. l THE PETITIONER CONTENDS THAT, BASED UPON THE REFERENCED CRAC 2 RESULTS, AN ENLARGEMENT OF THE CURRENT PILGRIM PLUME l EPl IS WARRANTED BECAUSE THE PROJECTED DOSES EXCEED THE EPA PROTECTIVE ACTION bU! DES (PA6S) OUTSIDE THE 10-MILE EPl. BOTH NUREG-Ub54 AND NUREG-0396 RECOGNIZE, BASED UPON CRAC 2 RESULTS, THAT THE PAUS MIGHT B,E EXCEEDED BEYOND THE TEN MILE i
.' b 41 - PLUME EXPOSURE iPl IN THE EVENT OF THE WORST POSSIBLE ACCIDENT AND *ETEOROLOGICAL CONDITIONS. 10 WEVER, A TEN MILE PLUME EXPOSURE ;Fl dAS STILL CHOSEN AS A PLANNING BASIS IN NUKtb-VbD4 BECAUSE: A. DROJECTED DOSES FROM THE TRADITIONAL DESIGN BASIS ACCIDENTS WOULD NOT EXCEED PAb LEVELS OUTSIDE THE ZONE; 3 PROJECTED DOSES FROM MOST SEVERE FUEL DEGRADATION SEQUENCES w0VLD NOT EXCEED PA6 LEVELS OUTSIDE THE ZONE; C. COR THE WORSE FUEL DEGRADATION SEQUENCES, IMMEDIATE Ll E THREATENING DOSES WOULD GENERALLY NOT OCCUR 00T-SIDE THE ZONE; AND D. DETAILED PLANNING dlTHIN 10 MILES WOULD PROVIDE A SUB-STANTIAL BASE FOR EXPANSION OF RESPONSE EFFORTS IN THE EVENT THAT THIS PROVED NECESSARY. HENCE, AT THE PRESENT TIME, NRC HAS INDICATED TO FEMA THAT THERE IS NO BASIS FOR REQUIRING THAT A PLUME EXPOSURE PATH-WAY 'PI SHOULD BE GREATER THAN APPROXIMATELY A lu M'.LE RADIUS t FROM THE PLANT. NihA, THEREFORE, CONCLUDES THAT THE PETITION DOES NOT DR0 VIDE l INFORMATION nHICH SUSTAINS THE CONTENTION. j 1 20/ LACK OF COORDINATION AND PRIORITIZATION e i A) PETITIONERS: IHE NRC SHOULD SUSPEND THE OPERATING LICENSE OF THE PILGRIM l POWER PLANT UNTil A REALISTIC, DETAILED RERP IS DEVELOPED, I SHOWING AN ACTUAL CAPABILITY TO EDUCATE, A L E R.T , TREAT AND EFFICIENTLY EVACUATE ALL PEOPLE WHO MAY BE AT RISK FROM A CATASTROPHIC ACCIDENT AT THE PLANT. FEDERAL, STATE AND LOCAL GOVERNMENT AGENCIES, AS WELL AS HAVE BOSTON EDISON,INSTEAD ALL ACCORDED A LOW PRIORITY TO EMERGENCY PLANNING. OF TRYING SER10VSLY TO DEVISE A PLAN THAT WILL PROTECT ALL
C 's 0F THE PUBLIC, PLANNERS HAVE SOUGHT TO ACHIEVE ONLY MINIMUM COMPL!ANCE #1TH NRC REGULATIONS; AS SECTIONS 13 THAOUGH 13 0F THIS_ PETITION DEMONSTRATE, THEY HAVE FAILED TO DO EVEN THAT. lHIS INSUFFICIENT COMMITMENT TO PUBLIC PROTECT 10N IS EVIDENT IN MISSED DEADLINES, SLOW PROCESSING OF PAPER-WORK, LACK OF ATTENTION TO DETAll AND INADEQUATE BUDGETS AND STAFFING. , IO DATE, FEMA HAS LARGELY ACQUIESCED IN PLANS THAT FAIL TO DEMONSTRATE A CAPABILITY TO ADEQUATELY RESPOND TO AN ACTUAL EMERGENCY, AND FEMA'S ACQUIESCENCE HAS BEEN EMULATED BY THE NHL. WHERE FENA HAS CRITIC! ZED PARTS OF THE PLAN, THE MASSACHUSETTS CIVIL DEFENSE AGENCY (MCUA) HASFORNOT RESPONDED EXAMPLE, AC-IN A TIMELY FASHION TO FEl'lA'S CONCERNS. CORDING TO TESTIMONY BEFORE MASSACHUSETTS STATE LEGISLATORS ON JUNE 18, 198b, BY EDWARD A. IHOMAS OF ~FthA, THE AGENCY ! SENT LETTERS OUTLINING PERSISTENT FEMA CONCERNS TO MCUA IN UCTOBER, 1985 AND JANUARY, 1986 FEMA RECEIVED NO RESPONSE TO THE JCTOBER LETTER UNTIL JUNE 0, 198b AND FEMA MAD NOT YET RECElvED A RESPONSE TO THE JANUARY LETTER BY THE TIME , I OF THE HEARING. FEMA: , ON JUNE 15, 1981, THE DIRECTOR OF THE MASSACHUSETTS CIVIL DEFENSE AGENCY (MCUA) ON BEHALF OF THE GOVERNOR OF THE COMMONWEALTH OF MASSACHUSETTS SUBMITTED THE RADIOLOGICAL EMERGENCY RESPONSE PLANS FOR REVIEW PURSUANT TO 44 CFR 350, AND STATED THAT IN THE OPINION OF MCDA THE PLAN WAS ADEQUATE l TO PROTECT THE PUBLIC HEALTH AND SAFETY. UN SEPTEMBER 29, 1982, FEMA ISSUED AN INTERIM FINDING THAT ALTHOUGH THE PLANS WERE NOT PERFECT, "THE INTERIM FINDING OF FEMA 15 THAT THE I STATE PLAN AND LOCAL PLANS TOGETHER ARE ADEQUATE TO PRO-TECT THE HEALTH AND SAFETY OF THE PUBLIC."D UN MARCH 6, 1985 AND OCTOBER 30, 1985 FEMA INFORMED THE MASSACHUSETTS LIVIL 4 DEFENSE AGENCY BY LETTER THAT BECAUSE OF UNRESOLVED EMERGENCY PLANNING ISSUES RAISED DURING THE RAC REVIEWS OF UCTOBER 1981
- 'a 43 -
AND SEPTEMBER 1982, AND DURING THE ihb2 AND 1363 EXERCISES dE HAD SUSPENDED PROCESSING THE!R REQUEST.FOR A FORMAL APPROVAL PURSUANT TO 44 CFR 350 FthA HAS NOT RESUMED ITS PROCESSING OF THE 350 APPROVAL RE0 VEST BECAUSE MCDA HAS NOT ADE00ATELY ADDRESSED THE ISSUES RAISED IN THE LETTERS. IT SHOULD BE UNDERSTOOD THAT WHILE THE RESOLUTION OF THESE ISSUES WOULD ENHANCE THE MASSACHUSETTS PILGRIM KERP, NEVERTHELESS T 6' PLANS HAVE BEEN FOUND TO BE ADEOUATE IN THAT THEY MEET THE MINIMUM STANDARD OF PROVIDING A REASONABLE ASSURANCE THAT THE STATE AND ' 0C AL DLANS ARE ADEQUATE TO PROTECT THE HEALTH AND SAFETY OF THE PUBLIC IN THE PILGRIM LPl. ih11, SELF-INITIATED dEVIEW AND INTERIM FINDING FOR UPDATED INFORMATION.l bxERCISES OF THE PLANS AND PREPAREDNESS OF STATE AND LOCAL GOVERNMENTS WITHIN THE PLUME LXPOSURE LMERGENCY PLANNING 2ONE FOR THE PILGRIM NUCLEAR POWER STATION WERE OBSERVED BY FbhA ON MARCH 3, 1982; JUNE 29, 1983, AND SEPTEMBER 5, 1985 A REVIEW 0F THE EXERCISES INDICATES THAT THE LOMMONWEALTH OF MASSACHUSETTS HAS MOVED PROMPTLY TO CORRECT PLAN OR PERFORM-ANCE PROBLEMS WHICH WOULD INTERFERE WITH ITS ABILITY TO PROTECT THE PUBLIC IN THE EVENT OF AN ACCIDENT AT PILGRIM. THE 1982 AND 1983 EXERCISES DEMONSTRATED THAT A CAPABILITY EXISTED FOR STATE AND LOCAL GOVERNMENTS TO PROTECT THE HEALTH AND SAFETY OF THE PUBLIC IN THE EVENT OF AN ACCIDENT AT THE PILGRIM NUCLEAR POWER STATION.
. '4 44 - liOW EV E R , EthA'S OBSERVATION UF THE EXERCISE CONDUCTED ON OEPTEMBER 3, 1985, IDENTIFIED FOUR DEFICIENCIES IN THE dXER-CISE. FEMA NOW USES THE WORD "DEFICIENCIES" TO MEAN DEMONSTRATED AND OBSERVED INADEQUACIES THAT WOULD CAUSE A FINDING THAT OFF-SITE EMERGENCY PREPAREDNESS WAS NOT ADEQUATE TO PROVIDE REASONABLE ASSURANCE THAT APPROPRIATE PROTECTIVE MEASURES CAN BE TAKEN TO PROTECT THE HEALTH AND SAFETY OF THE PUBLIC LIVING IN THE V!CINITY OF A NUCLEAR POWER FACILITY IN THE EVENT OF A RADIOLOGICAL EMERGENCY. UN SEPTEMBER 20, 1985, FEMA SENT A LETTER TO MCDA INFORM;NG THEM OF THE EXISTENCE OF THE FOUR DEFICIENCIES IDENT!FIED FOR i THE CARVER EOC AND THE IAUNTON RECEPTION CENTER. UN UCTOBER 29, 1985, A KEMEDIAL LXERCISE WAS HELD TO DEMONSTRATE CORREC- l T10N CC THESE DEFICIENCIES. IHE FOUR DEFICIENCIES wire CORRECTED. (SEE FthA l DOCUMENT, "REPORT ON THE KEMEDIAL l LXERCISE FOR THE PILGRIM NUCLEAR POWER STATION", UCTOBER 29, 1985). ; l IHE COMMONWEALTH OF MASSACHUSETTS RESPONDED PROMPTLY TO THE DEFICIENCIES IDENTIFIED DURING THE 1985 EXERCISE. AS INDI-l CATED ABOVE BOTH BY FEMA AND THE PETITIONERS, THE RESPONSE I TO ISSUES WHICH WERE NOT CATEGORIZED AS DEFICIENCIES HAS NOT BEEN TIMELY. FOLLOWING THE JUNE 29, 1983 EXERCISE NO DEFI-CIENCIES WERE IDENTIFIED AND THE COMMONWEALTH PROVIDED A
. b 45 - COMMUNITY LEVEL. IHE 5 TATE TH'EN PROVIDED A SCHEDULE OF CORRECTIVE ACTIONS IN A LETTER TO FEMA DATED JUNE 20, :985, FOR ALL $ TATE AND LOCAL COMMUNITY INADEQUACIES NOTED AT THE 1983 EXERCISE. FEMA oBEERVED, DURING THE 1985 EXERCISE, THAT MANY OF THE DROBLEMS IDENTIFIED IN THE 1982 AND 1983 EXERCISES HAD BEEN CORRECTED BUT MANY NEW "AREAS REQUIRING CORRECT!vE ACTION" (ARCA) AND FOUR DEFICIENCIES WERE IDENTIFIED. IHE COMMONWEALTH HAD CORRECTED THE DEFICIENCIES BY OCTOBER 29, .985 AND ON UCTOBER 50, 1985 PROVIDED FEMA WITH A PLAN OF ACTION *HICM, IT FELT, IF IMPLEMENTED WOULD RESOLYE THE UN . LARCH 5, .360 N C,h A "AREAS RE2VIRING CORRECTl/E ACTION". SENT THE LOMMONWEALTH THE REPORT ON THE SEPTEMBER ), 1985 EXERCISE. IHE LOMMONWEALTH, AS PROVIDED IN FEMA GUIDANCE, WAS TO PROVIDE FEMA WITH A SCHEDULE OF CORRLCTlvE ACTIONS FOR THE "AREAS REQUIRING CORRECTIVE ACTION" WITHIN $U DAYS OF THE REPORT'S RECEIPT. ALTHOUGH FEMA HAD NOT RECEIVED A SCHEDULE BY THE TIME THE PETITION WAS FILED, IT DID NOT FEEL THE SCHEDULE WAS OVERLY LATE. IHE COMMONWEALTH HAS NOT YET, HOWEVER, SUBMITTED ITS SCHEDULE OF CORRECTIVE ACTIONS. IHIS SUBJECT IS DEALT WITH IN FEMA'S SELF-INITIATED REVIEW AT PP 37-44 B) PETITIONERS: ANOTHER EXAMPLE OF THE SERIOUS LACK OF COORDINATION WAS THE FAILURE OF MCUA TO DELIVER TO FthA AN UP-TO-DATE VERS!ON OF THE STATE EMERGENCY PLAN. ACCORDING TO STATEMENTS BY FEhA AND MCDA 0FFICIALS IN THE JUNE 20, 198b EDITION OF THE PATRIOT LEDGER OF QUINCY, MA, THE PLAN WAS NOT DELIVERED UNTIL 10 MONTHS AFTER IT WAS PREPARED. MCUA COMPLETED THE
.- 5 UPDATED PLAN IN AUGUST; 1985 BUT DIO NOT DELIVER A COPY OF li UNTIL JUNE 25, 1986 FENA MAD FORMALLY REQUESTED'A COPY OF THE PLAN IN OCTOBER, 1985, BUT DID NOT FOLLOW UP ON THAT REQUEST. *iC D A ' S FAILURE TO RESPOND TO PtMA'S REQUEST AND EMA'S Ev! DENT LACK OF CONCSRN AND UNWILLINGNESS TO DEMAND MORE RESPONSIVE ACTION ARE SYMPTOMATIC OF AN EMERGENCY RESPONSE REGIME THAT [5 UNCOORDINATED AND GIVEN LOW PRIORITY BY ITS ATTENDANT PUBLIC AGENCIES. FEMA: IHE BULK OF THE MASSACHUSETTS RERPS FOR THE P!LGRIM EPl WHICH FEMA HAS ON F[LE ARE CURRENT. IHE LAST MAJOR R /ISION TO THE STATE PLAN WAS IN 1982 AND FEMA HAS THOSE CHANGES. MINOR CHANGES TO LOCAL DLANS WERE MADE IN 1985 FEMA REQUESTED COPIES OF THE PLANS ON OCTOBER 30, 1985, AND FE?lA RECE!VED COPIES OF THEM FROM HMM ASSOCIATES IN A LETTER DATED JUNE 22, 1986 IHE COMMONWEALTH SUBSEQUENTLY INFORMED FEMA THAT THE 1985 VERS'!ON OF THE LOCAL PLANS WERE CURRENT. FEMA WOutD ENCOUPAGE ATTEMPTS BY THE COMMONWEALTH OF MASSACHUSETTS TO GIVE KADl0 LOGICAL EMERGENCY PREPAREDNESS PLANNING A HIGHER PRIORITY. C) P; TIT 10NERS: FURTHER EVIDENCE OF THIS LACK OF C00RDINATIDN AND PRIORITI-ZATION WAS REVEALED IN MR. IHOMAS' JUNE 18, 1986 TESTIMONY. MR. IHOMAS STATED THAT BOSTON EDISON HAD FAILED REPEATEDLY TO DELIVER TO FEMA NECESSARY TECHNICAL SPECIFICATIONS ON THE SIRENS THAT WOULD NOTIFY THE PUBLIC OF A RADIOLOGICAL EMERGENCY AT THE PILGRIM PLANT. MR. IHOMAS STATED THAT THESE DELAYS BY 80STON EDISON HAVE FORCED REPEATED POSTPON-MENTS OF SYSTEM TESTING. IHUS, THE SYSTEM HAS NEVER BEEN GIVEN THE FULL-SCALE TEST REQUIRED BY FEMA. FEMA: AS NOTED IN THE RESPONSE TO ITES 16 ABOVE, FEMA RECE!VED THE
. Io 47 - , SIREN SYSTEM TECHNICAL SPECIFICATIONS ON JUNE &D, 1985, AND PERFORMED A DETAILED REVIEd OF THE STATE AND LOCAL :ULL-SCALE S!REN TEST ON 3EPTEMBER 23, .986.~ SESULTG OF THE SIREN TEST INDICATED THAT 38 2% OF THE PEOPLE dERE DIRECTLY ALERTED BY THE SIRENS ON THE DAY 0F THE TEST. HOWEVER THE PETITION DOES NOT DEMONSTRATE THAT THESE DELAYS INTERFERED WITH THE COMMONWEALTF'S ABILITY TO PROTECT THE PUBLIC. L) PETITIONERS: ME EMERGENC) RESPONSE SYSTEM's<2ACK OF PRIORIT!ZATION !$ FURTHER DEMONSTRATED BY THE FACT THAL LOCAL CIVIL DEFENSE AGENCIES IN THE COMMUNITIES WITHIN TH'E EMERGENCY DLANNING ONE MAVE SERIOUS STAFFING AND BUDGETARY PROBLEMS. 4'10 S T LOCAL Civil DEFENSE DIRECTORS WITHIN THE EPl ARE UNPAID OR RECE!VE ONLY $ MALL ST! PENDS. MOST HAVE LITTLE OR NO PAID STAFF. THE RELIANCE ON VOLUNTEERS, WHO OFTEN HAVE MINIMAL PROFESSIONAL ITPERIENCE OR TRAINING, REFLECTS THE UNWILLING-NESS OF STATE AND LOCAL GOVERNMENT TO MAKE A GENUINE COMMIT-MENT TO EMEOCENCY RESPONSE FLANNING- MAJOR IMPROVEMENTS IN STAFFING AND BUDGETS OF STATE AND LOCAL civil DEFENSE BODIES MUST BE IMPLEMENTED BEFORE PUBLIC SAFETY CAN BE ENSURED. MORE0VER, LE0i THE NECESSARY MEASUyES TAKEN CONSTITUTE PUBLIC SUBSlDIZATION OF THE FINANCIAL REQ 91REMENTS OF A SAFE NUCLEAR POWER SYSTEM, BOSTON EDISON LHOULD BE REQUIRED TO PROV;DE THE FINANCIAL MEANS FOR THEM. EEMA: FEMA FEELS THAT THIS ALLEGATION IS TOTALLY WITHOUT MERIT BASED UPON PAST HISTORY WITH YOLUNTEER GOVERNMENT IN THE U.S. EACH DAY THOUSANDS OF VOLUNTEEC1 IN LOCAL GOVERNMENTS PERFORM ADMIRABLY, 0: TEN WITH GREAT RISK TO THE!R PERSONAL SAFETY AHD WELL-BEING. UNE EXCELLENT EXAMPLE OF THIS IS THE DEDICATION AND C OMM I Th' INT DISPLAYED BY VOLUNTEERS WHO PARTIC-IPATE IN RAL:50 LOGICAL EMERGENCY RE3PONSE EXERCISES AND RES-l i a
.' )
48 - POND TO EMERGENCIES IN THE!R COMMUNITIES ON A DAILY BASIS. HS NOTED SY PEDERAL EVALUATORS' COMMENTS IN EXERCISE REPORTS FOR THE EXERCISES OF THE KAD10 LOGICAL
- EMERGENCY KESPONSE-PLANS FOR THE PIL3 RIM NUCLEAR POWER STATION IN 1982, 1983, AND 1985, THE DEDICATION AND COMMITMENT OF THE VOLUNTEERS HAS BEEN CONSISTENTLY DISPLAYED. IHE VOLUNTEERS HAVE IN-CLUDED LOCAL CIVIL DEFENSE DIRECTORS t.ND STAFF, SELECTMEN,
?!RE DERSONNEL, PARA-MEDICS, KED CROSS VOLUNTEERS, MACES AMATEUR RADIO OPERATORS, THE CIVIL A!R PATROL AND OTHERS.
IHE .OLUNTEERS ARE KNOWLEDGEABLE OF THE!R DUTIES AND CON-SCIENT10US IN THE PERFORMANCE OF THESE DUTIES. ALTHOUGH VOLUNTEERS RECEIVE LITTLE OR NO STIPENDS FOR THE!R SER-VICES, THEY ARE WORKING TO MAKE THEIR COMMUNITIES A SAFER AND BETTER PLACE FOR THEIR FAMILY AND FRIENDS TO LIVE. MANY VOLUNTEERS HAVE INDICATED TO QUR STAFF THAT THE SAT-ISFACTION OF HELP!NG PROTECT THEIR COMMUNITY AFFORDS THEM FAR GREATER REWARDS AND INCENTIVE THAN ANY MONETARY COMPEN-SATION COULD PROVIDE. 4 FEMA, THEREFORE, CONCLUDES THAT THE ISSUES RAISED IN SEC-TION 20 0F THE PETITION DO NOT PROVIDE INFORMATION WHICH SUSTAINS THE CONTENTION. 9 t I i
t' 4 49 - FOOTNui_ts h 1 HANS, JOSEPH M., JR.; SELL, IHOMAS L., EVACUATION RISKS - AN LVALUATION, kNVIRONMENTAL PROTECTION AGENCY, LFA-32U/b-74-UU2, JUNE, 1974 2 IBID; PG 43 3 IBlD; PG 13 4 IREADWELL, MATTIE E., HURRICANE {ARLA - SERTEMBED l-13, 1011; UEPARTMENT OF UEFENSE - UFFICE OF LIVIL DEFENSE, nEG10N V, DENTON, IEXAS, PG 16 5 FEMA REGION I INTERIM FINDINGS "JOINT ST ATE AND LOC AL EMERGENCY RESPONSE CAPABILITIES FOR THE P!LGRIM NUCLEAR POWER STATION, PLYMOUTH, MASSACHUSETTS, SEPTEMBER 1982" i J l
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- B.1 Attachment B Mark I Containment Design As discussed in Section C.1 of the Petition, the original design basis of the reactor containment was to provide protection against loss of coolant accidents (LOCAs). This discussion will describe how it fulfills its function of protecting against these design basis events.
The design of the Pilgrim containment is referred to as the "fiark I" design, which features a "pressure-suppression" containment (see Figure 1). A pressure-suppression containment uses a large pool of water to reduce the buildup of steam pressure inside the containment following a LOCA. The steam is condensed by passing it through the pool of water. The concept of pressure suppression with water was developed by GE for the Humboldt Bay Nuclear Plant during the time period from 1958 to 1962. Since that tine, GE has designed many boiling water reactor (FWR) plants and has developed three distinctively different pressure-suppression containment designs, identified as the Mark I, II, and III designs. The Mark I containment system consists of (1) a drywell that encloses the reactor vessel, the reactor coolant system, and other branch connections of the reactor coolant system; (2) a donut-shaped pressure-suppression chamber (torus) containing a large volume of water; (3) a vent system connecting the drywell to the water space of the torus; (4) containment isolation valves; (5) containment cooling systems; and (6) other service equipment. The drywell is a steel pressure vessel supported in concrete with a spherical lower section and a cylindrical upper portion. The pressure suppression chamber is a steel pressure vessel in the shape of a torus, and is
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- B located below and encircling the drywell. The suppression chamber is held in place by supports that transmit operational, accident, and seismic loads to the reinforced concrete foundation slab of the reactor building. The drywell-to-torus vents are connected to a vent header that is located in the airspace of the pressure-suppression chamber. Projecting downward from the vent header are the downcomer pipes, which are nominally 24 inches in diameter and end approximately 3 feet below the water surface of the pool.
In the event of a LOCA, reactor water and steam would be suddenly released into the drywell atmosphere. This is referred to as a blowdown. As a result of increasing drywell pressure, a mixture of drywell atmosphere, steam, and water would be forced through the vent system into the pool of water that is stored in the suppression chamber. The steam vapor would condense in the suppression pool, thereby reducing the drywell pressure. Noncondensible gases and fission products would be collected and contained in the air space of the torus. The drywell atmosphere would initially be transferred to the suppression chamber and would pressurize the chamber. At the end of the blowdown, water supplied by emergency core cooling systems (ECCS) would spill out of the break and rapidly reduce the drywell nressure. The suppression chamber would vent to the drywell through installed vacuum breakers to equalize the pressures between the drywell and suppression chamber. The ECCS would cool the reactor core and transport the heat to the water in the suppression chamber. Cooling systems are available to remove heat from the water in the suppression chamber, thus allowing for the continuous removal of decay heat from the primary containment under accident conditions following the initial deposition of energy to the suppression chamber from the blowdown.
- 'o ATTACH!OT C TO RESPONSE TO DETITIONERS C-1 ENCLOSURE A to liUREG-0474 Sumary of NRC Staff Actions Related To The Technical Issues Identified In Dr. Hanauer's Memorandum of September 20. 1972 A. Concern:
"Like all containments the pressure suppression designs are required to include margins in capability. Experiments have been conducted by
, GE and Westinghouse to establish the rate of steam generation that can be accomodated. The pressure-suppression pools, ice condenser, etc.,
are then sized for the ocuble-ended break steam flow, with margins for unequal distribution of steam to the many modular units of which the condenser is composed. The rate and distribution margins are probibly adequate. More difficult to assess is the margin needed when applying the exper. 1 mental data to the reactor design. Recently, we have reevaluated the 10-year old GE test results, and oecided on a more conservative interpretation than'has been used all these years by GE (and accepted by us). We now believe that the fonner interpretation was incorrect, using data from tests not applicable to accident conditions. We are requiring an independent evaluation of the ice condenser design and its bases to make less probable any comparable misinterpretation of this design." Responses: Since this concern was expressed, additional tests, both domestic and foreign, of Bq pressure systems have been conducted, e.g., 4-T, PSTF, and Marviken. Computer codes which have been and are being used to predict the containment pressure and temperature response of the BWR pressure suppression containment systems have been used to calculate the pressure response for these test facilities. The calculated values when compared to the test results have confimed the adequacy of the computer model s. ThesecomparisoAshavebeenmadebyboththevendorandtheNRCM Consequently, the viability of the pressure suppression concept which was originally demonstrated by testing perfonned in 1958 through 1962 has been confinned. , With respect to ice condenser containments, the NRC has developed com-puter codes whit.h are used to predict the containment's pressure response f e-
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, L 1 l l l C -2 l during postulated LOCAs. These codes are now being compared to test data and the preliminary results of such comparisons are that the adequacy of the current models has been confimed. Vendor's codes (Wes})nghouse)havebeencomparedtotestsandhavebeen conf i med.- The margins applied for pressure suppression containment design have also been confimed by the additional test data that has become avail- l able since 1972. These margins exist both in the basic design of the ; l containment structure and in the analytical models used to predict the containment response. The exterimental data are no longer applied directly to detemine the containment design requirements. B. Concern:
"Since the pressure-suppression containments are smaller than conven-tional ' dry" containments, the same amount of hydrogen, fomed in a postulated accident, would constitute a higher volume or weight percent-age of the containment atmosphere. Therefore, such hydrogen genera-tion tends to be a more serious problem in pressure-suppression contain-ments. The small GE designs (both the light-bulb-and-doughnut and the over-under configurations) have to be inerted because the hydrogen assumed (per Safety Guide 7) would immediately fom an explosive mix-ture. The GE Mod 3 and the Westinghouse ice condenser design: (they have equal volumes) require high-flow circulation and mixing systems to ensure even dilution of the hydrogen to avoid flamable mixtures in one or more compartments (see following for an additional serious dis-advantage of this needed recirculation and its valves). By contrast,-
the dry containments only require recombination or purging starting weeks af ter the accident." Reseense , Most Mark I BWR pressure suppression l containments are currently required to be inerted as part of the I measures for combustible gas (i.e., hydrogen) control following a postulated loss-of-coolant accident. This requirement resulted from the staff's assumptions regarding the amount of hydrogen generated and the magnitude of the lower limit of hydrogen flamability. However, in ; 1974 the Comission ruled that the technical issues related to inerting ! requirements should be resolved by way of rulemaking. Subsequently, a rulemaking proceeding was initiated which led to the development of I a proposed change to the regulations, i.e.,10 CFR 50.44, "Standards The re*;1 sed assumptions in this proposed ' in ce Branch Technical Position, CSB 6-2,_}e and plants would pemit those to specified de-inert where it can be demonstrated that the hydrogen concentration i
; s C-3 can be maintained below a combustible mixture. The analyses for Vermont Yankee indicate that most, if not all, plang could de-inert using the assimptions in the proposed 10 CFR 50.44-Those facilities with the Mark 11 pressure-suppression containment system deJign have not yet been licensed for operation. However. in light of the staff requirements specified in Branch Technical Position.
CSB 6.2, we do not expect that inerting will be required for these facilities. The Mark III BWR containment system and the PWR ice condenser contain-ment system htye relatively larger volumes and do not require inerting for combustible gas control. However, mixing systems are provided to take advantage of the total contaiment volume for dilution of hydro-gen. Ir. the ice condenser containment design, the primary function of the mixing system is to assure long-tem condensation within the ice bed. Staff positions were developed during the course of the review of the first Mark III plant application (i.e., Grand Gulf the minimum design requirements for the p'ing the potential for excessive steam bypass-systems.j/which set fo and to preclude Although the time frame within which combustible gas control must be initiated is much shorter for a pressure suppression contaiment than for dry contaiments, it is still long enough to pemit manual oper-ation and it occurs well after the initial blowdown transient. C. Concern:
"All pressure-suppression containtnts are divided into two.(or more) major volumes, the steam flowing from one to the other through the con-densing water or ice. Any steam that flows from one of these volumes to the other lithout being condensed is a potential source of unsuppres-sed pressure. Weither the strength nor the leakage rate of the divider (between the volumes) is tested in the currently approved programs for initial or periodic inservice testing. Some effort is now underway to devise a leakage test, but none has so far been accomplished."
Response
With respect to the BWR pressure suppression containment systems, the leakage of steam from the drywell directly to the suppression chamber airspace bypasses the suppression pool and could potentially result in an overpressurization of the containment. The maximum allowable by- s pass leakage rate is a function of the si:e of the p ;tulated loss-of- I coolant accident. Facility Technical Specifications ' include periodic l l l 8**
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, 4 s C -4 (approximately every eighteen months) testing requirements to monitor the bypass leakage rata. The tests are performed by pressurizing the drywell to one to two pounds per square inch greater than the suppres-sion chamber and monitoring the rate of pressure decay. The pressure decay rate is then correlatable to an equivalent bypass leakage t.rea.
Tht: test is conservative since all drywell leakage paths are l inherently included in the test results while only a small per- i tien of these paths centribute to bypass leakage. In addition, most BWR operating plants with pressure suppression containments have been operating with a positive pressure differen-tial 1976 p/ tween the drywellthis Maintaining andpressure suppression chamber differential since February provides a continuous monitor of bypass leakage and a verification of the status of the drywell to suppression chamber vacuum breakers. With rtspect to the ice condenser containment design, a substantive amount of bypassing can be tolerated without exceeding design condi-tions. Analysis indica feet can be tolerated.*_g that bypass This areas is a large of about area 35 to 50 square when compared to the bypass area which can be tolerated for water pressure-suppression systems (which varies between about .02 and I square feet) and, there-fore, less testing has been required. However, we do require both pre-and post-operationalgsting to confirm the bypass capability of each 1 ice condenser plant - The strength capacity of the ' divider" in the Mark I design is demon-strated by structural analysis of the vent system. The strength capacity of the "divider" floor in the Mark II design will be con-firmed by preoperational testing. D. Concern:
"Bectuse of limited strength against collapse, the "receiving" volume has to be provided with vacuum relief. In all designs except GE Mod lil, this function is performed by a group of valves. Such a valve stuck open is a large bypass of the condensation scheme; the amount of steam that thus escapes condensation can overpressurize the containment.
Yalves do not have a very good reliability record. Recently, five of l the vacuum relief val ~ves for the pressure-suppression containment of Quad Cities 2 were found stuck partly open. Moreover, these valves had been modified to include redundant "valve-closed" position indicators and testing devices, because of recent Reg concerns. The redundant . position indicators were found not to indicats correctly the particular partly open situation that obtained on the five failed valves. We have only recently begun to pay serious attention to these valves, so pre-t i
e % C-5 vious surveillance programs have not generally ~1ncluded them. The GE Mod 111 design has an elegant water-leg seal that obviates the need for vacuum relief valves."
Response
Yacuum breakers are provided between the drywell and the suppression chamber to allow reverse flow back to the drywell following the ini-tial blowdown transient. These valves are normally closed; however should any of these valves be open at the time of the accident, steam bypass could potentially result in an overpressurization of the con-tainment. Since 1972, staff positions were developed which required periodic testing and redundant position indication to assure that excessive bypass leakage through the vacuum breakers would not occur.1$f Continuous monitoring of these valves is provided by the positive pressure differential between the drywell and suppression chamber. Additional testing requirements also exist to demonstrate the capabilityg/ functions 1 f these valves to perform their vacuum-relief All of these testing requirements are included in the surveillance requirements contained in the Technical Specifications for each plant. These testing requirements have also served at a basis for the develop-ment of maintenance programs to correct deficiencies in the valve ' position indicators. As a result of these independent maintenance programs, failures of the position indicators have been very infre-quent over the past several years. { E. Concern:
"The high capacity atmosphere recirculation systems provided for hydrogen mixing involve additional valves which, if open at the wrong time, would constitute a serious steam bypass and thus a potential source of containment overpressurization. These valves are large, and must open quickly and reliably when recirculation is needed.
In other engineered safety features, no single valve is relied on for such service, yet redundancy has not been provided even for single failures, open and closed, of these valves. This is a serious mission, since opening at the wrong time leads to overpressurization, while f ailure to open when needed inhibits recirculation." l _ , . . . _ _ . . _ . _ . - - . _ _ _ - . . - . . _ - _ _ , . .._.___.__,-._-__.-...,_.m._m,,, ,y- re-e .,_m~
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Response
This issue relates to the BWR Mark III contaiment system design. In 1974, the AEC developed a position in conjunction with the review of the first Mark III BWR (i.e., Grand Gulf) which addresse th concern of large mixing system penetrations in the drywell y/This e position included the following features:
- 1. Alternate mixing system designs were to be developed to limit the potential for bypass through large drywell penetrations.
- 2. Containment bypass capability was to be increased to accoanodate single f ailures of the valves in the lines.
As a result of this position each Mark 111 applicant provided a mixing system design consistent with our position. The designs included the following features: small drywell penetrations; re-dundant inlet and exhaust penetrations to assure a recirculation path; the use of two valves in series on each line to assure isola-tion capability; and an evaluation of the contaiment capability
- ac odate bypass through an inadvertantly open recircul:, tion F. Concern:
"The smaller size of the pressure-suppression contaiment, plus the t equirement for the primary system to be contained in or.e of the two volumes, has led to overcrowding and limitation of access to reactor and primary system components for surveillance and in-service testing."
Responsel Although pressure-suppression contaiment system designs are generally more crowded and less accessible than dry containment system designs, based upon the experience gained through our reviews of the Inservice Inspection and Inservice Testing (ISI/IST) programs which have been submitted by licensees in accordance with the requirements of 10 CFR 50.55.a. only one significant BWR inspection-related accessibility problee has been identified, i.e., the beltline region of the reactor pressure vessel. This inaccessibility is a result of the vessel design, not the contaiment design. The beltline region of PWR vessels can be inspected from the inside of the vessel because the core internals can be removed whereas this is not possible for BWRs. Augmented inspe tion of accessible
o, ,o C -7 areas cf BWR reactor pressure vessels and operating limits on reactor pressure and temperature compensate for this inability to perform ISI. With the exception of the above-mentioned area, no other significant inspection-related accessibility differences between PWR and BWR con-taiments have been identified. G. Concarn:
"Separate shielding of corponents has tended to subdivide into compart-
' ments the volume occupied by the primary system. (Some compartmenta-tion of dry containment also occurs.) A pipe break in one of these compartments creates a pressure differential; each compartment must be designed to withstand this pressure. A method of testing such designs has not been developed."
Resconse: The arrangement of structures internal to the containment differ between the Mark 1/11 containment system design and the Mark III containment design. The Mark 1/Ils have fewer compartments than PWR dry containments because there is less need for radiation shielding. The Mark 1/Ils are essentially inaccessible during normal plant operations, thereby requiring fewer structures for shielding. The Mark 111 design for internal structures is generally comparable to the PWR dry contaiment design. For all designs, both dry and pressure suppression containments, we analyze pipe the pressure breaks to en r response within compartments for postulated for compartments g/e >_s g'g adequacy There areofnthe design pressure differential ducted to verify analytical methods.Ip/ going foreign tests being con-of this program. NRC and vendor codes are part
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y b THE COMMONWEALTH OF MASSACHUSETTS i DEPARTMENT OF THE ATTORNEY GENERAL [ _h JOHN W. McCoRMACK STATE OFFICE BUILDING
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ONE A3HOURToN PLACE, BOSTON 021o81698 JAMES M. SHANNON ATTORhtV Ctht RAL
, October 15, 1987 l FEDERAL EXPRESS Director of the Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC. 20555 RE: Enclosed 10 C.F.R. S 2.206 Petition concerning the Pilgrim Nuclear Power Station
Dear Sir:
Enclosed is the Petition of Michael S. Dukakis, Governor and James M. Shannon, Attorney General for the Institution of a Proceeding Pursuant to 10 C.F.R. S 2.202 to Modify, Suspend, or Revoke the operating License Held by the Boston Edison Company For The Pilgrim Nuclear Station, which I am filing on behalf of myself and Governor Michael S. Dukakis. Very .uly your , e v
, Jame/ M. Shannon i Attc :ney General i
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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 LICENSE HELD BY THE BOSTON EDISON COMPANY FOR THE j PILGRIM NUCLEAR STATION t <
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- i. i j Dated: October 15, 1987 i
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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 LICENSE HELD BY i THE BOSTON EDISON COMPANY FOR THE I PILGRIM NUCLEAR STATION 1
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1 l 1 i i i Dated: October 15, 1987 i i i l l 1 l 1 1
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{} TABLE OF CONTENTS
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L I. INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . 1 II. EVIDENCE OF SERIOUS MANAGERIAL DEFICIENCIES . . . . . 3 j A. OVERVIEW . . . . . . . . . . . . . . . . . . . . . 3 3 B. 3ECo'S PAST PERFORMANCE . . . . .. . . . . . . . 4 l 3ECo's SALP Evaluations . . . . . . . . . . . . . S
. ,j ..
SECo's Regulatory Violations . . . . . . . . . . . 7 J! C. RECENT INDICIA OF BECo'S. PERFORMANCE LEVEL , . . . 9 i
'l BEco's 1987 SALP Report . . . . . . . . . . . . 10 .
Recent Reports of Violations . . . . . . . . . . 12 III. EVIDENCE THAr INDICATES THAT A PLANT SPECIFIC i PRA FOLLONED 3Y IMPLEMENTATION OF ANY INDICATED SAFEIY MODIFICATIONS SHOULD BE REQUIRED PRIOR r0 PILGRIM'S RESTART . . 12
. IV. EVIDENCE OF INADEQUATE E'4ERGENCY PREPAREDNESS . . . 15 l
,i V. CONCLUSION . . . . . . . . . . . . . . . . . . . . . 21
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UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION PETITION OF MICHAEL S. DUKAKIS, GOVERNOR AND
- JAMES M. SHANNON, ATTORNEY GENERAL FOR THE j
INSTITUTION OF A PROCEEDING PURSUANT TO 10 C.F.R S2.202 TO MODIFY, SUSPEND, OR d REVOKE THE OPERATING LICENSE HELD BY fj THE BOSTON EDISON COMPANY FOR THE l I PILGRIM NUCLEAR STATION a
) I. INTRODUCTION i 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
- 1 institute a proceeding pursuant to 10 C.F.R. S2.202 to modify, l suspe'ed, or revoke the operating license held by Boston Edison I
; company ("BECo." or "the company") for the Pilgrim Nuclear
-l This Power Station ("Pilgrim") in Plymouth, Massachusetts.
petition is filed on behalf of the Commonwealth of 1
' i
.! Massachusetts and its citizens. The Governor and the Attorney t i
General base this request on evider.ce of continuing serious f j managerial deficiencies at the plant, on evidence that a plant specific probabilistic risk assessment ("PRA") as well as the
; implementation of any safety nodifications indicated thereby l 1
should be required prior to Pilgrim's restart, and on evidence ; that the state of emergency preparedness does not provide j reasonable assurance that adequate protective measures can and r
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a: will be taken in the event of a radiological emergency during
.j operatiens at the Pilgrim plant. The Governor and the Attorney i
' General submit that this evidence, as set forth below, i
.I demonstrates the necessity of Nuclear Regulatory Commission
.i j
5: ("NRC") action pursuant to 10 C.F.R. S2.202. > 1 Further, the Governor and the Attorney General believe that Nj if the public interest requires that the NRC exercise its
- authority under 10 C.F.R. S2.202(f)1/ so that BEco. is ,
]
prevented from proceeding any further with the restart of Pilgrim 1/ until a formal adjudicatory hearing has been held and findings of fact are made concerning the safety questions surrounding the continued operation of the Pilgrim plant. In I particular, the Governor and the Attorney General request that the NRC issue an order, effective immediately, modifying BECo's j operating license to preclude BECo. from taking any steps in
?
l 1 1/ 10 C.F.R. 2.02(f) provides:
.. When the Executive Director for Operations, j
, during an emergency as determined by the EDO, or <
;;, the Director of Nuclear Reactor Regulation, 4
.i Director of Nuclear Material Safety and )
ij Safeguards, Office of Inspections and l
; Enforcement, as appropriate, finds that the
;) public health, safety, or interest so requires
-i or that the violation is willful, the order to i show cause may provide, for stated reasons, that
, the proposed action be temporarily effect*ie
; pending further review.
2/ At each step of BEco's so-called "power ascension" program there is an increase in the probability of an
- accident at Pilgrim as well ns in the potential consequences of such an accident. See Affidavit of Steven C. Sholly (attached hereto as Attachment 1). l
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1 4 2 its power ascension program until the hearing is held and the , t findings are made. R
! II. EVIDENCE OF 1ERIOUS MANAGERIAT. DEFICIENCIES 4
d Recent events at Pilgrim indicate that BECo. has not
, :1
-1 lj corrected the long-standing managerial shortcomings that have
.U} plagued the plant. In the areas of security, radiological controls, personnel management, and corporate culture, the
- ]g 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
\
i circumstances is inimical to public health and safety. l ( , A. OVERVIEW Pilgrim commenced commercial operation in June, 1972, when BECo. received an operating license for the plant. During the
; j intervening fifteen year period of operation by BECo., Pilgrim
-i j has had a capacity factor of approximately 50 percent,1/
1 I h which compares quite unfavorably with the average for all New 4
~
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 ' plant's rated kilowatt capacity and the number of hours in the f period. . 4/ Electric Council of New England, New Enoland Nuclear News, I
' TJune, 1987) (Attached hereto as Attachmeni 1).
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's B. BECo's PAST PERFORMANCE 1,
j The plant has been out of service since April, 1986, when I the NRC, in Confirmatory Action Letter 86-10, ordered a shutdown after recurring operational problems at the plant.E/ I Pilgrim has been beset with managerial problems from the _,
'I j outset. BEco. has consistently received low ratings in the 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 /6and BECo.
was ordered to initiate performance / management improvement programs in 1982 and 1984.2/ BECo. has been the subject of a [ long line of enforcement actions as a result of regulatory
; violations. While,the NRC's efforts to spur BECo. to a higher I level of performance have, on occasion, met with some initial success, a review of BECo's performance record, however, shows 5 that all such successes have been short lived. Indeed, BEco.
'i J
4 5/ Confirmatory Action Letter 86-10 was clarified and expanded I in an subsequent letter, dated August 27, 1987, from the NRC ll 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 j outstanding issues, I (the Regional 3 j Administrator) am not prepared to approve restart of the Pilgrim facility until you j (BECo.) provide a written report that documents 3Eco's formal assessment of the readiness for ' restart operation. 6/ Boston Globe, May 28, 1986. , i 7/ Order Modifying License Effective Immediately, 47 Fed. Reg. 4171 (January 28, 1987). l l i 3
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1 t I I appears to have an organic inability to manage Pilgrim in an effective and safe manner.S!
** BECo's SALP Evaluations **
j BECo. has consistently received low ratings in SALP l reports.E/ s
)
'l 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 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 BEco's need to consider and develop new i
sources of power in the aftermath of the 1981 cancellation of
} the construction of the Pilgrim II nuclear unit. Boston Edison i 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 t and/or skill to fulfill public service obligation).
- 9/ The SALP process is the mechanism by which the NRC on a l periodic basis systematically assesses the overall performance j of a licensee. For each assessment period (generally 12 to 18 I months) a Board of NRC officials evaluates, in accordance with
; preestablished attributes and rating guidance, the licensee's l performance for each of the various, preestablished functional
.i 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 identifies, for further followup and inspection, any areas where the licensee's corrective action to improve performance has not been fully effective.
Arizona Public Service Company, (Palo Verde Nuclear Generating Station, Unit 2), DD-86-8, 24 NRC 151, 156 (1986).
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In 1980, BECo. received ratings indicating significant weakness
-l in three of the nine functional areas evaluated. The most
'I recent SALP Report, seven years later, indicates that 1
! conditions have not improved but rather have worsened. BECo.
1
] received ratings indicating significant weaknesses in five of j
- J the twelve functional areas evaluated. It has only once
- received a SALP Report without a rating indicating a J significant weakness. On all other occasions,.it has received y
; 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
{ i
) review, BEco. has received the lowest possible rating. These 1
j findings are indicative of the ineffectiveness of BEco's management. They are a measure of its inability and/or its I lack of commitment to run the plant in a effective and safe
~!
l manner. i j Although BECo. has at one time or another received the i lowest possible rating in all but three of the twelve
] functional areas covered by the NRC's SALP process, these ;
l individual poor SALP ratings are not the most troubling aspect !
.; < l of BECo's SALP record. Instead, the most troubling and telling I facet of BECo's SALP record is the Company's distinct inability l i
to maintain any period-to-period performance improvements. BECo. has at one time or another improved its SALP performance 4
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M '* i f u1 l in eight functional areas. However, it has not been able to i q sustain the increased level of performance in seven of those i
'j eight areas. In all but one instance, BEco's improved i
j performance proved to be short-lived and its performance subsequently fell back to lower levels. This is not surcrising as an ever recurring theme in NRC evaluations of BECo's
- d performance is that NRC oversight and prompting is necessary at
; every stage of Pilgrim's operation.1S/ The increased NRC
'. attention (i.e., oversight and prompting) that a "3" rating
}
calls for has, on occasion, produced better performance by 1 BECo. However, when that level of attention re. urns to that ! i j norm, BEco's performance falls below the norm. BECo's SALP t l track record is proof of the proposition that BEco. by itself , has not effectively operated Pilgrim and that the short-term 1 solutions it has adopted in response to criticism have i j invariably permitted the reoccurrence of the original problems. I
'i J ** BEco's Regulatory Violations **
I i i BECo., an enforcement action record that is a mirror of its l SALP Report record. It has had at least one Severity Level III violation during each of the past six years.11/ (See I i l 10/ E.g., 1987 SALP Review at 8; 1986 SALP Review at 7. i 11/ As set forth in 10 C.F.R. Part 2, Appendix C; General i Statementof Policy and Procedure for NRC Enforcement Actions, j regulatory violations are categorized into five descending levels of severity. Level III corresponds with "violations j that are cause for significant concern." , i
! I l
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)
VIOLATIONS) In the area of Security and Safeguards, BEco. had a Severity Level III violation in all but one of the years
'i
} between 1981 and 1986. In 1982, a civil penalty in the amount of $550,000 -- at the time the largest penalty to have ever been assessed by the NRC -- was levied against BECo. for
- s. serious plant operations violations and for submitting false information to the NRC.$ !
While the number of such Severity Level III violations discovered at Pilgrim has not exceeded two i in any single year since 1981, the number of Severity Level IV 1 violations per year has more than doubled in the past few years.
'-).l
} BECo's enforcement action record also mirrors its SALP i
! Report record in demonstrating BEco's chronic recidivism. It Is 1 has been cited five times for Radiological Controls violations involving waste shipment packaging requirements.11/
It has been cited five times for Security and Safeguards
; violations involving the control of sensjtive material such as keys to vital areas, security plans, and firearms.1d/
l 1,2/ U.S. General Accounting Office, Reoort to the Honorable Alfonse M. D'Amato, U.S. Senate: Nuclear Regulation Efforts to Ensure Nuclear Fower Plant Safety can Be Strengthened (GAO-RCED-87-141 August, 1997), pp. 36-37. 13/ See NRC Enforcement Summary Tables taken from various SALP
, Reports (attached hereto as Attachment 4).
14/ Id. ! l i j 1 1
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=1 C. RECENT INDICIA OF BECo'S PERFORMANCE LEVEL 1
i The most recent indicia of the level of BEco's performance in managing Pilgrim are consistent with its past performance, j They confirm the notion that BECo. appears to be organically i 4 incapable of managing a nuclear facility. Notvithstanding the i M frequent incantation by senior management of a program for the
^
- "pursuit of excellence," the addition of new personnel and the expenditure of large sums of money,1E/ the available evidence
\l
! 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 t
i 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.
-i Further, on the basis of statements made by NRC officials at a j
~i recent meeting, the NRC has received and is investigating 1
-l allegations that the company may be compromising safety by l
j overworking its or its contractors' employees in an effort to i return the plant to service soon. This evidence suggests that
, J ,
l BECo's claim to be approaching readiness for restart may g
.; I l
15/ E.g., NRC Docket No. 50-293, Of ficial Transcript of NRC Office of Nuclear Reactor Regulation, "Meeting Nith Boston Edison Re: Pilgrim Status and Activities Leading to Restart Readiness," pp. 13-14, 18-20 (September 24, 1987) (hereinafter "9,24/87 NRC/BECo Readiness Meeting"). (Testimony Submitted by l Stephen J. Sweeney, President and Chief Executive Officer, i Boston Edison Company, to the U.S. House of Representatives, l
. Subcommittee on Energy Conversation and Power of the committee on Energy and Commerce July 16, 1986, pp. 4-5 (attached hereto i as "Attachment 5").
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be hasty and misleading.15/
'1
** BEco's 1987 SALP Report **
I On April 8, 1987, the NRC released a SALP Report for BEco. i 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
}j with its past record, BEco. received the lowest possible 1l
- ratings in five of the twelve functional areas.11/ It
. t I received the highest possible rating in only two functional ,
I ) areas.1SI The picture painted in the SALP report is one of a ! j plant with "(p)oor management control," an "obscured ... chain of command and weakened accountability," and "(s)significant
~
i 1 1 recurring program weakness ... in some functional areas, I showing the effect of ... long-term problems."1E! j! 1 ! i i l 16/ BEco's claim of readiness should be measured against its
- ~! adoption of 9/24/87 NRC/BECo. Readiness Meeting, p. 43. This ;
i 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 1'
;j necessary time required to perform outage tasks),
t
.{ ll/ The five areas were: Radiological Controls, Surveillance, 4
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. 1 ; 1 i } i l 10 - __ .u-
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I of particular importance to this Petition, were SALP i ratings in three areas where BEco. ::ad previously improved its performance. In the functional areas of Surveillance, Fire i
; Protection, and Licensing Activities, 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 q
Reports -- but by the time of the review for the 1987 SALP Report, its performance had fallen back to earlier levels, a With respect to the functional area of Security and i Safeguards, the 1987 SALP Report discussed continuing hardware problems, BECo's excessive reliance upon contractors, and management's failure to give this area sufficient i attention.20/ The report noted that BEco's corrective actions for deficiencies in this area had not generally been i j effective and referenced three degradations in vital area l barriers that had occurred during the evaluation period.21/ e 2_0/ Id. at 31-34. 21/ The Commission's regulations define a "vital area" as any area which contains: l
- any equipment, system, device, or material, the j failure, destruction, or release of which could l 4
directly or indirectly endanger the oublic health l 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 least two physical barriers." 10 C.F.R. 573.50(b)(1). Access into a protected area is to be controlled through ti.e checking of authorization and identity at entry control points to which barriers surrounding the protected area "channel persons and material." 10 C.F.R 573.45(b)(1)(1) and 73.50(c).
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Recent Reports o,2 V'olations **
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On the basis of news geports,ank statements made by NRC n f officials at a recenc'heet.in], it appears that BECo. has
,a ,4 suffered from at 1,:rast four significhne Security and Safeguards lapses in the past six months: a misplaced gun; a misplaced l
,[ set of sensitive keysi,a "sericus degradation in a vital area
, [js barrier;" and ineffective identification cards.M/ While all j four alleged lapses would be sidnificant, ' the latter three 3
. .; would be a particularly strong indication of BEco's failure to
; t j learn from its past mistakes'-j nearly identical 1.apue.s have i occurred in the past. E '
/ i i t /
~l Further, allegations ha.ve recently been"made which NRC 1
! stated at a recent meeting that they are investigating that i>
BECo. may be compromisibg. worker and/or plant safety by requiring excessive overtime. b III. EVIDENCE THAT INDICATES THAT 'A PLANT SPECIFIC PRA FOLLOWED BY IMPLEMENTATIJN OF ANY INDICATED SAFETY MOTI.7ICATIONS SHOULD BE REQUIRED TO PILGR!M'S RESTART, t Pilgrim is a 35 Mark I design plant. As such, it has a , c < primary containment whick, by>nearly unanimous agreement, has an extremely high probab1?ity of failure in the event of l ,, f
- 22/ Boston Globe, September 4,,19i37, p. 1; Boston Globe, '
, September 9, 1937,'p. 21; Boston' Herald, September 10, 1987,
) p. 24. /'
?
I 23/ See ,1.985 SALP Reoort, p. 40; 1983 SALP Reoort, pp. 41-43; l 1982 SALP Rer, ort, p. 38 (included yn Attachment 3 hereto).
'l i 24./ Boston Globe,iSeptember 29, 1987; p. 21.
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j certain accidents.21/ This characteristic is especially j critical since Mark I design reactors, such as Pilgrim, do not ll have the backup of a secondary containment structure which can
.]
l withstand any significant position pressure. ("PNRs"). 5! In
..i l fact, Pilgrim's so-called "containment building" is not really
.-- ]
designed to perform a backup function. It has "blow panels" ,d. 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
! extremely vulnerable primary containment structure, a secondary , .(
containment not designed to provide an effective backup, and the large population in the immediate vicinity of Pilgrim2 1/ 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 i
d would pose an unreasonable threat to publis health and safety.22/
-s 25/ See NUREG-1150, Reactor Risk Reference Document, Draft for Comment, Feb. 1987, at 4-33, 4-39.
, 21/ Affidavit of Steven C. Sholly (attached hereto as
.! Attachment 1).
i 22/ Id. SS/ ld' j _2_9/ _I_d. f i i j -- . . - - . . . . . . . -. -
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a.a.u w -J. 2. L.. . :.. .u . . . a .L :.e .;. ~. : . .a .. . . . :.u .....e. ..c. u. - t,- The Governor and the Attorney General are aware that the i f 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 ( , vulnerable containment structures and a large population 3 surrounding the plant -- precludes application of NUREG-1150's finding that the probability of a large reactor accident with early fatalities is extremely remote. The NUREG-ll50 findings L. , .; f do not reflect the amalgam of risks posed by Pilgrim. I J (~ j BEco. has proposed a number of modifications as remedial
; actions for the plant's design deficiencies.21/ These
; actions do not, however, address the inherent defects of the l 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 1 appropriate modifications to be made to remedy the defects of 1 the Mark I design in issue.
)
-1 l 20/ E.g., Boston Edison Comoany (Pilgrim Nuclear Station), l DD-87-14, __ NRC __ (1987) (slip at 31-32). !
. a -
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, Division of Reactor Projects, I/II, Nuclear Regulatory Commission (attached hereto as Attachment 6). i t i I e
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- d IV. EVIDENCE OF INADEQUATE EMERGENCY PREPAREDNESS
! Within the past twelve months, two authoritative
-I
; 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.1 !
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."1S! Both also concluded that the plan and the state
'N ; of preparedness have significant deficiencies and suggest a potential remedies for those deficiencies that will require a substantial commitment of time, resources and I cooperation.21! BEco.'has not quarreled with these conclusions.SS! 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 Station" (December 16,
. 1986) (hereinafter "Barry Report").
33/ FEMA Self-Initiated Review at 1-2; Barry Report at 74. 34/ FEMA Self-Initiated Review, pp. 12-13, 19, 22, 29-32, 43-44; Barry Report, pp. 47-55. 35/ 9/24/87 NRC/BECo Ptauiness Meeting", pp. 49-54. I I i l t i
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s I authoritative expert agenciesl6/ agree that there is no reasonable assurance that the public can or will be protected j in the event of an accident at Pilgrim. It is, thus, incumbent i i 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.21/ b& A. THE PLANNING AND PREPAREDNESS DEFICIENCIES IDENTIFIED
.. BY FEMA AND THE MASSACHUSETTS EXECUTIVE OFFICE i OF PUBLIC SAFETY
.1 0
a The deficiencies of the Radiological Emergency Response d j Plans for Pilgrim are manifold. Although the analyses of FEMA and the Massachusetts Executive Office of Public Safety do not J} reach the same conclusions on all issues, the following areas I of substantial deficiency have been identified by both agencies:
.]
I 1. the lack of any articulated evacuation plans
'! for public and private schools as well as day j care centers;
- 2. the lack of any articulated evacuation plans for the special needs population; l
36/ FEMA is explicitly recognized by the commission as the expert Federal authority on questions of nuclear power plant of fsite emergency preparedness (Memorandum of Unde: standing, 50 j Fed. Reg., No. 75, 15,486 (April 18, 1985) and the Commission is expressly required to base its findings on off-site
)
l emergency issues on FEMA's conclusions concerning such issues. l 10 C.F.R. S50.47(s)(3). The Massachusetts Secretary of Public I 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, j 37/ Each step of BECo's power ascension plan corresponds with i j a substantial increase in the probability of an accident at Pilgrim. Affidavit of Steven C. Sholly (attached hereto as Attachment 1). l t
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,a f 3. the lack of any articulated evacuation plans j for the transport dependent population; a
1 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; l
- 6. the lack of real progress in planning and the
;j .
diminutioningpestateofemergency preparedness._
, These are critical deficiencies. The plans do not even
.c b
c-a purport to provide any measure of protection for significant q numbers of people: pre-school and school age children; those
; who require special measures to transport; and those without-i ready access to private transportation. They fail to address
{ the significant beach population in an adequate fashion. They
.I do not incorporate current or reliable evacuation time J'*
.] 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 center3 1/
+
q i 1 38/ FEMA Self-Initiative Review, pp. 12-13, 19, 22, 29-32, ! 43-44; Barry Report, pp. 47-55. i 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 reception center indicates that even if d evacuation from the EPZ were successful -- a heroic assumption l in light of the assorted planning deficiencies -- those who
; received and followed instructions to evacuate to the north 1 i would find no facilities available at their designated I destination. According to FEMA, approximately 60,000 people l would be left without facilities at which to register, be i monitored and decontaminated if necessary. FEMA Self-Initiated {
} Review at 19. I i
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. I j -- is missing altogether. Finally, offsite exercises and i
drills -- the most effective means of assuring preparedness -- have not been held in years, i j B. THE CURRENT STATUS OF PLANNING AND PREPAREDNESS y The specific functional deficiencies in the firct four SA areas enumerated above, as well as the functional areas in ce which work must be done before any determination can be made if.
- s y adequate plans can be developed, encompass the entire set of
-} tasks required for adequate planning and preparedness:
i i 1. Identification / Estimation of populations; i
- 2. Identification / Estimation of resources; i
} 3. Develop plans for emergency actions to be
]
taken for each population with potentially j available resources; 1 I
- 4. Obtain commitments for required resources;
- 5. Provide education /information to public;
.1 '
- 6. Conduct exercises / drills.
At present, it appears that the school /daycare population has been identified but that the specia.'. needs and transport dependent populations have not.SS/ Preliminary estimates of I 4j the resources potentially available to evacuate these populations have now been obtained, but neither plan development nor obtaining commitments of resource availability I can proceed in the absence of reliable ETEs.$1! l 1 i 40/ Executive Summary of the Reoort on Emergency Preoaredness i f For an Accident at Pilgrim Power Station) (October 15, 1987)
-{ Thereinafter "Barry Report Update"), p. 2.
i
, 41/ Id. at 2.
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R$ 2; While BECo. has recently -- August 18, 1987 -- delivered an ETE study to the Commonwealth's public safety officials,d2/ 1 the document is still being reviewed by those officials and
]
l preliminary analysis has uncovered shortcomings that will i
$ necessitate further work. It is, thus, unlikely that final
-l J ETEs will be available within the immediate future for use in developing specific plans.SS/ This shortcoming is critical.
1 A consequence of the unavailability of reliable ETEs is that emergency planning is effectively on hold. Even when the task
.]
l of identifying / estimating populations and resources is
- completed, radiological emergency planning cannot in any real j sense proceed without reliable ETEs and a traffic management
.f plan. As PEMA 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 4 the Commonwealth's public safety officials but, at least in the m case of the sheltering survey, these materials have been found 12/ KLD Associates, Pilgrim Station Evacuation Time Estimates and Traffic Management Plan Update (Final Draft for Review) August 18, 1987.
~i 43/ Barry Report Update, p. 2.
i i
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19 - i
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' n1 1 , db l to be inadequate for planning purposes.AA/ I I
Again, plan development and resource availability commitments, d _j much less public education /information efforts and i
,j exercises / drills, cannot proceed usefully without reliable final ETEs and sheltering data. b 1
' j:f No replacement site for a northern reception center has been foundA5/ and no determination has yet been made whether l J,
,j an emergency plan incorporating only two reception centers i would provide an adequate assurance of protection.47/
, J
, ; ,J 3
a j 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
.i President-Nuclear, Boston Edison Company (attached hereto as 1 Attachment 7) l 4',/ 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) l i it must receive the following information:
; 1) an updated geographical description of the
, beaches and their capacity; 2) a detailed l 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 estimate of the length of time it would take to evacuate the beach population; and 4) a list of suitable i buildings available for sheltering the beach
, q population at each beach, including the capacities of these buildings and their distances from the beaches. If these buildings are not open to the public, the plans must j clearly state how they will be made accessible i and letters of agreement must be obtained as j appropriate.
46/ Id. 47/ 9/24 NRC/BECo. Readiness Meeting, p. 52. But see FEMA Self-Initiated Review at 19 (The use of only two reception centers "is not likely to be logistically l feasible.").
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Finally, in the absence of new plans, public information/ education efforts and exercises / drills cannot, by 4
-] definition, occur. There are no plans to inform the public of
. exercises, much less to exercise. Although the provisions of u
-l 10 C.F.R. Part 50, Appendix E, Section IV.F. require that a
.A
'T full participation biennial emergency preparedness exercise for
.L "j 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 1988.38,/
- i
,] IV. CONCLUSION 1
! In light of all of the foregoing deficiencies of the i
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 r the Pilgrim reactor, the Governor and Attorney General submit that the NRC must take action pursuant to 10 C.F.R. 52.202 to
, insure that BECo. does not take any action that could increase either the risk or the consequences of an accident at Pilgrim.
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 fuc Pilgrim. These 48/ Letter with enclosures dated September 18, 1987, from Mr. Ralph G. Bird, Senior Vice President-Nuclear, Boston Edison Comaany, to NRC (attached hereto as Attachment 8). 1 l. 1
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'4 I deficiencies are so substantial and their potential
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'l ramifications are so significant, that it is impossible to ll i conclude that any interim compensating actions have or can be a
j taken. The NRC's regulations leave it no course other than i
.' ] .I issuing an order modifying BEco's license to extend the current fl shut down pending the outcome of a full hearing on the
-d -
significant outstanding safety issue and the development and certification by the Governor of adequate emergency plans.SE/
-l j Respectively submitted, 4*
James M. Shannon Attorney General j Commonwealth of Massachusetts j
'! Michael S. Dukakis Governor Commonwealth of Massachusetts s
Dated: October 15, 1987 q 49/ Compare 10 C.P.R. S50.54(s)(2)(ii):
... In determining whether a shutdown or other I enforcement action is appropriate, the Commission shall take into account, among other factors, whether the licensee can demonstrate to the s Commission's 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 that there are other compelling reasons for continued operation.
-I i
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t ' 1 4 APPENDIX I: BECo. SALP HISTORY TABULATION
~[I Inspec. Plant Radiol. Maint. Surveil. Fire Emergen, i '; Period Oper. Control Prot. Prepared
i)] 2 2 q 01/01/80 2 3 2 2
'{ 12/31/80
- :1 2 1
- j 09/01/80 3 2 3 2
'- -j 08/31/81 2
1
- ; l} 09/01/81 3 2 2 2 3
-! 06/30/82 i
I 07/01/82 2 2 2 1 1 1
- 06/30/83 07/01/83 2 3 1 1 2 3 l 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
$ Inspec. Secur. Out.Mgt. Licen. Eng/ Corp Train Quality 2
1 Period Safegds Mod.Act Activ. Tech.Sup Qual.Ef Assuran
'i 01/01/80 2 3 - - -
3 12/31/80
; 09/01/80 2 2 - - -
3 3- 08/31/81 m, .) ,09/01/81 2 2 2 - - -
't 06/30/82 07/01/82 2 -
1 - - -
! 06/30/83 j 07/01/83 2 1 1 - - -
1 09/30/84
.! 10/01/84 2 1 1 - - -
l 10/31/85 l
; 11/01/85 3 1 2 1 2 3
{ C1/31/87 i i I
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-i APPENDIX II: BECo. VIOLATIONS TABULATIONS
'j
.t 's t 3 SEVERITY LEVEL III VIOLATIONS: 9/1/81-1/31/87
. -1 1981 1982 1983' 1984 1985 1986 1987
.1 Functional Area
, 5f Plant Operations 3
, '1 1 2 1 Radiological Controls
, .- Mainenance Surveillance Fire Protection Emergency Preparedness 1 1 ?
.1j Security / Safeguards 1 1 1
' Outage Mgt ...
]j Licensing Activities Training ... Eff' ness Assurance of Quality i 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 I
II 7 1 1 2 1 III
, IV 9 9 18 17 21 20 20 6 5 6 1 V
. VI 2 2 3 1 3 1 Deviations 3
26 27 29
' ^ ;l' . Total Violations 40 33
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.! UNITED STATES OF AMERICA i NUCLEAR REGULATORY COMMISSION Ji BEFORE THE COMMISSION q in the matter of BOSTON EDISON COMPANY Docket No. 50 293 (Pilgrim Nuclear Power Station, Unit 1)
AFFIDAVIT OF STEVEN C. SHOLLY l
. 1 Steven C. Sholly, being on oath, deposes and says as follows: l
] 1. I 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 I more than six years experience in the review, analysis, interpretation, and l l
application of probabilistic risk assessment to the analysis of safety issues q related to commercial nuclear power plants, including issues related to ; radiological emergency planning. I have served as a member of the peer 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 Containment Performance Deslan Obiective Workshoo. the Panel on ACRS Effectiveness (1985), and the Severe
~
'1
-1 Accident Policv imolementation External Events Workshoo (1987). I have
! previously testified as an expert witness on probabilistic risk assessment and j emergency planning matters in NRC proceedings on the Catawba Units 1 and i
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 l Kingdom. In addition, I have co authored two major reviews of source term l
}
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- ,1 and risk estimate issues published in NRC reports NUREG-0956 and NUREG-1150. I have also performed reviews of various technical aspects of the i Shoreham, Umerick, Indian Point, Sizewell, Zion, Seabrook, Millstone-3, and
- Oconee-3 probabilistic risk assessments and the Vermont Yankee Containment Safety Study.
~1 1 2. MHB Technical Associates ('MHB') has been requested by the Nuclear Safety j Division, Department of the Attorney General, The Commonwealth of
'j Massachusetts, to evaluate the increase in risk resulting from a startup 4 program for return to power from the current refueling and modifications I outage for the Pilgrim Nuclear Power Station, Unit 1 (PNPS-1).
d l
- 3. In its current configuration (refueled) and considering the duration of the ;
i 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 l
} and the onset of fuel damage, time during which measures could be taken to j initiate coolant makeup and/or other recovery and mitigative actions, j 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.
- 4. Boston Edison Company (BECO), the licensee for Filgrim, currently envisions
, '(" restart power ascension program with a minimal number of hold points in
- f. brief, BECO proposes to institute holds on restart (pendirig approval from NRC in accord with Confirmatory Action Letter No. 86-10), recovery from reactor 3
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.
(Seg, Boston Edison Company, Pilarlm Nuclear Power Station Restart Plan.
; pages IV 29 to IV-31.] The details of the power ascension program in Attachment 13 of the Pilarlm Nuclear Power Station Restart Plan have not yet been provided.
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j 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
; safety posed by operations at the Pilgrim plant will be increased markedly.
i 1, 6. The Commission has concluded generally that the risks from 5% power
! operation are negligible. (Sg.e, for example, SECY-84-155,12 April 1984, and 1
attachments; and letter dated 15 June 1984 from Nunzio J. Palladino to Hon. 4 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 l present in both the refueled reactor core and the spent fuel pool. Moreover, l these evaluations did not consider the unique risks posed by accidents l resulting from extemally initiated events (specifically, in this case, seismic
- events). In my opinion, the presence of more than 1100 spent fuel assemblies, l 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 i i Pilgrim sufficiently different from those previously evaluated for 5% power l 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
] inerted until operation above 5% power is commenced. In my opinion, virtually i any severe accident at 5% power with the containment de-inerted will result in j
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 i
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q actions and reduces the amount of time available to implement offsite 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 J events as a significant contributor to core melt frequency (i.e., contributing 10%
~d or more to core melt frequency from all causes). This expectation is based on j my familiarity with seismic risk assessments performed on similar designs and 1 performed on other plants in the general region of Pilgrim (e.g., Shoreham, 1
Seabrook Units 1 and 2, Millstone Unit 3, and Umerick 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 l
! conclusion is all the more applicable.
}.
} 9. A study of risk at 25% power for the Shoreham nuclear plant, which possesses 1 a nuclear steam supply system which is grossly similar to Pilgrim, indicates that the core melt frequency for operations at up to 25% of full power may not differ j dramatically from the core melt frequency at full power. The 25% power PRA j estimates a core melt frequency of 2.8 x 10-5 per reactor-year. [ Sag,E.T. I Burns, S. Mays, and T. Mairs, Brobabl/Istio Risk Assessmcat of the Shoreham
^
Nuclear Poster Station: Initial Power Ooeration Lim!:ed to 25% of Full power. Delian Corporation, prepared for Long Island Ughting Company, April 1987, [ page 4-12.) The full power PRA analyses for Shoreham estimated a core melt frequency of about 6.5 x 10-5 per reactor year. (Ste, Science Applications, Inc., Final Reoort: Probabilistic Risk Assessment. Shoreham Nuclear Power Stat /on. prepared for Long Island Ughting Company,24 June 1983, page 4; and V. Joksimovich, et al., Maior Common-Cause Initiatina Events Studv:
! Shoreham Nuclear Power Station. NUS Corporation, NUS Report No. NUS-4617, prepared for Long Island Ughting Company, February 1985, page 1-9]
i I
wl;: 'O m u.di.2is1 1 2.:a.a._u M 1 w u.2 .u m ..L.. _ ..n m. w . 5-j This represents less than a factor of three difference in the likelihood of a core i melt accident at 25% power versus full power. Although this assessment is for U Shoreham and not for Pilgrim, it suggests that the likelihood of an accident is not markedly different for 25% power versus 100% power.
- 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
.Q core melt frequency for 5% power operation was about 4.9 x 104 per reactor-year. [Seg, Delian Corporation and Science Applications, Inc.,'Probabl/Ist/c
; Risk Assessment. Shoreham Nuclear Power Station. Low Power Ooeration Uo
! to 5% of Full Power. prepared for Long Island Lighting Company, draft, May i 1984, page 78.] This indicates that core melt frequency at 5% power is j significantly reduced from 25% power or full power, by a factor of roughly 20, I but not nearly as significantly reduced as previously predicted by the NRC staff, j which predicted a reduction factor of 1,000 or more.1/ Moreover, the 5%
power reduction factor of 20 is an underestimate since the 5% power estimates j do not include external events.
- 11. The 5%, 25%, and 100% power PRA studies for Shoreham Indicate, in my opinion, that the core power level for Pilgrim will have at best a moderate l impact on the likelihood of an accident. Considering the uncertainties involved, 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 104 per reactor-
,< year.
1/ The NRC staff, in SECY-84-156, predicted core me't frequency reduction factors 4 for various classes of BWR accidents ranging from 1,000 to 100,000. (SSR, i SECY-84-156, Enclosure 1, ' Staff Review Procoss for 5 Percent Power Operation *, page 2.] Thus, in the aggregate, the NRC staff would have expected a core melt frequency reduction of at least 1,000, compared with the Shoreham value of 20. i The results for Shoreham indicate a reduction factor approximately 50 times less than the NRC staff expected based on engineering judgment. i l I i
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- 12. These results are especially significant for a plant with a containment design
;jl similar to Pilgrim. Pilgrim employs a steel Mark I pressure suppression
] containment. Such containments have been estimated in a variety of studies ;
} sponsored by IDCOR, NRC, and utilities to have an early containment failure I 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 _.3u) be accompanied by a large early release of radioactivity to the environment. l 1 j 13. The Pilgrim plant, like all Mark I containment design plants, also employs a 1 secondary containment, usually referred to as a reactor building. This I I structure is not designed to withstand the high internal pressures which would l accompany a severe accident, and is unlikely to survive in a leak-tight condition following primary containment failure. High pressure in the secondary l containment due to a severe accident would be produced by a combination of
; blowdown due to primary containment failure, primary containment leakage, d primary containment venting, and burning of combustible gases, indeed, Mac j
! I plants are designed with both internal and external "blow-out panels" which l l <l are des /gned to relieve pressure, in the case of Pilgrim, there are blow-out 1 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 l j the primary containment will be significantly mitigated by the presence of the I 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 c( recommendation that BECO be required to promptly submit the Pilgrim probabilistic risk assessmer't study to the NRC for public review and evaluation prior to restart. The review of such a study should indicate whether there i
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A 0.Steven C. Sholly / 1 Associate Consultant /
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*)$GENERAL ACKNOWLEDGMENT No. ol
_-_ ,g ,; State of on this the/ 9 day of - 1922 before me, County o ,
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p.. '. . , s. PROFESSIONAL QUALIFICATIONS OF STEVEN C. SHOLLY
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i STEVEN C. SHOLLY
! MHB Technical Associates L 1723 Hamilton Avenue Suite X San Jose, California 95125 (408)266-2716
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,g EXPERIENCE:
September 1985 - PRESENT Associate - MHB Technical Associates, San Jose, California
$ Associate in energy consulting firm that specializes in technical and s economic assessments of energy production facilities, especially nuclear,
, for local, state, and federal governments and private organizations. MHB
; is extensively involved in regulatory proceedings and the preparation of studies and reports. Conduct research, write reports participate in
; 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. l February 1981 - September 1985 3 Technical Research Associate and Risk Analyst - Union of Concerned Scien- ! I tists, Washington, D.C. Research associate and risk analyst for public interest group based in Cambridge, Massachusetts, that specializes in examining the impact of ad-vanced technologies on society, principally in the areas of arms control and energy. Technical work focused on nuclear power plant safety, with
~
emphasis on probabilistic risk assessment, radiological emergency planning and preparedness, and generic safety issues. Conducted research, prepared reports and studies, participated in administrative
-. proceedings before the U.S. Nuclear Regulatory Commission, developed
; testimony, anlayzed NRC rule-making proposals and draft reports and prepared comments thereon, and responded to inquiries from sponsors, the general public, and the media. Participated as a member of the Panel on 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-l 1984), and the Independent Advi-sory Comittee on Nuclear Risk for the
' Nuclear Risk Task Force of the National Association of Insurance Comissioners (1984).
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me 2e.u_.nunidasz.u mi_.i...u,witra._whidOG2Rl2KW F, jj ',, ! l January 1980 - January 1981
'I 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
-i fundraising proposals, tracked progress of U.S. Nuclear Regulatory Com-i mission, U.S. Department of Energy, and General Public Utilities activi-i ties concerning cleanup of Three Mile Island Unit 2 'and preparation for
,1 restart of Three Mile Island Unit 1, and monitored developments related to emergency planning, the financial health of General Public Utilities, and NRC rulemaking actions related to Three Mile Island. .
l July 1978 - January 1980
} l 1
l Chief Biological Process Operator - Wastewater Treatment Plant, Derry l
, Township Municipal Authority, Hershey, Pennsylvania l l
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, I chemical, and biological test results, procees fluid and mass flow man-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 Comonwealth of Pennsylvania as a wastewater treatment plant operator. l Member of Water Pollution Control Association of Pennsylvania, Central
.l 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.
'.. l September 1976 - June 1977 Science Teacher - West Shore School District, Camp Hill, Pennsylvania J
Taught Earth and Space Science at ninth grade level. Developed and im-i plemented new course materials on plate tectonics, environmental geology, j and space science. Served as Assistant Coach of the district gymnastics j team. - 4
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a ::.um.:.;a uwa.w.s:w - cua.xv L.u.a s wa . >.w=:~ u. . e x : .a t September 1975 - June 1976
! Science Teacher - Carlisle Area School District, Carlisle, Pennsylvania I i
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: 1
.l B.S., Education, majors in Earth and Space Science and General Science, j minor in Environmental Education, Shippensburg State College, Shippens-burg, Pennsylvania, 1975. ; Graduate coursework in Land Use Planning, Shippensburg State College, i Shippensburg, Pennsylvania, 1977-1978.
PUBLICATIONS: I
- 1. "Determining Mercalli Intensities from Newspaper Reports," Journal of
'. Geological Education, Vol. 25, 1977.
- 2. A Critique of: An Independent Assessment of Evacuation Times for Three 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 l Preparedness Plan, Union of Concerned Scientists, prepared for Rockland 1
County Emergency Planning Personnel and the Chairman of the County Legis-lature Washington, D.C., August 17, 1981.
- 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 Service, Environmental Action, and New York Public Interest Research Group. Washington, D.C., August 27, 1981. *
- 5. "Union of Concerned Scientists. Inc., Coments on Notice of Proposed i
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 Investication of the Indian Point Nuclear Power 3
Plants. Anne Witte, editor, Un< on of Concerned Scientists (Washington.
- D.C.) and New York Public Interest Research Group (New York, NY),1982.
1
', 7. "Union of Concerned Scientists Coments, 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.,
l January 15, 1982. *
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- 8. Testimony of Robert D. Pollard and Steven C. Sholly before the Sub-comittee on Energy and the Environment, Committee on Interior and Insular Affairs, U.S. House of Representatives, Middletown, Pennsylvania, j March 29, 1982, available from the Union of Concerned Scientists.
- 9. "Union of Concerned Scientists Detailed Comments on Petition for Ru1W.-
, ing by Citizen's Task Force, Emergency Planning,10 CFR Parts 50 and 10, Docket No. . PRM-50-31, 47 F.R. 12639," Union of Concerned Scientists, q Washington, D.C., May 24, 1982.
j- 10. Supplements to the Testimony of Ellyn R. Weiss, Esq., General Counsel, Union of Concerned Scientists, before the Subcommittee -on Energy 4 Conservation and Power, Comittee on Energy and Commerce, U.S. House of 1 Representatives, Union of Concerned Scientists, Washington, D.C., August j 16, 1982. a i 11. Testimony of Steven C. Sholly, Union of Concerned Scientists, Washington, D.C., on behalf of the New York Public Interest Research Group, Inc., be-
. fore the Special Comittee on Nuclear Power Safety of the Assembly of the State of New York, hearings on Legislative Oversight of the Emergency Ra- ,
diologic Preparedness Act, Chapter 708, Laws of 1981. September 2,1982. !
- 12. "Coments on ' Draft Supplement to Final Environmental Statement Related i to Construction and Operation of Clinch River Breeder Reactor Plant',"
! Docket No. 50-537, Union of Concerned Scientists, Washington, D.C.,
September 13, 1982. * - ~! 13. "Union of Concerned Scientists Coments on ' Report to the County Comis-i sioners', by the Advisory Comittee on Radiological Emergency Plan for Columbia County, Pennsylvania," Union of Concerned Scientists. Washing-ton, D.C., September 15, 1982.
- 14. "Radiological Emergency Planning for Nuclear Reactor Accidents," pre-sented to Xernenergie Ontmanteld Congress, Rotterdam, The Netherlands.
-{ Union of Concerned Scientists, Washington, D.C., October 8,1982. ,
1
- 15. "Nuclear Reactor Accident Consequences: Implications for Radiological Emergency Planning," presented to the Citizen's Advisory Comittee to Re-view Rockland County's Own Nuclear Evacuation and Preparedness Plan and General Disaster Preparedness Plan, Union of Concerned Scientists, Wash-ington, D.C., November 19, 1982.
, 16. Testimony of Steven C. Sholly before the Subcomittee on Oversight and Investigations, Comittee on Interior and Insular Affairs, U.S. House of Representatives Washington, D.C., Union of Concerned Scientists. Decem-ber 13, 1982.
i 17. l Testimony of Gordon 2.1(a tion Two Contentions R. Thomp) son andUnion and 2.1(d) Steven C. Sholly on of Concerned Comission Ques-Scientists and New York Public Interest Research Group, before the U.S. Nuclear Reg-
! ulatory Comission Atomic Safety and Licensing Board, in the Matter of
! Consolidated Edison Company of New York (Indian Point Unit 2) and the l Power Authority of the State of New 'lork (Indian Point Unit 3), Docket j Nos. 50-247-SP and 50-286-SP, December 28, 1982.
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j 18. Testimony of Steven C. Sholly on the Consequences of Accidents at Indian Point (Comission Question One and Board Question 1.1, Union of Concerned
] Scientists and New York Public Interest Research Group, before the U.S. ! Nuclear Regulatory Comission 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),
2 Docket Nos. 50-247-SP and 50-286-SP, February 7, 1983, as corrected February 16, 1983. *
- 19. Testimony of Steven C. Sholly on Comission Question Five Union of Con-
, cerned Scientists and New York Public Interest Research Group, before the H U.S. Nuclear Regulatory Comission Atomic' Safety and Licensing Board, in i the Matter of Consolidated Edison Company of New York (Indian Point Unit 1 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.
- j 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 Subcomittee on Nuclear Regulation, Comittee 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. Simpson," Steven C. Sholly and Michael E. Faden).
l 22. "PRA: What Can it Really Tell Us About Public Risk from Nuclear Ac-
! cidents?," Union of Concerned Scientists Washington, D.C., presentation f to the 14th Annual Meeting, Seacoast Anti-Pollution League, May 4,1983.
- 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.
! 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 1 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 Comissioner James X. Asselstine.
- 26. Sizewell 'B' Public Inquiry, Proof of Evidence on: Safety and Waste Man-agement Imolications of the Sizewell PWR, Gordon Thompson, with supporting evidence by Steven Sholly, on behalf of the Town and Country j Planning Association, February 1984, including Annex G, "A review of f Probabilistic Risk Analysis and its Application to the Sizewell PWR."
i 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).
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- 27. Testimony of Steven C. Sholly on Emergency Planning Contention Number Eleven, lirion of Concerned Scientists, Washington, D.C., on behalf of the 4 Palmetto Alliance and the Carolina Environmental $tudy Group, before the l 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.
- l 28. "Risk Indicators Relevant to Assessing Nuclear Accident Liability Premi-i ums," in Preliminary Report to the Independent Advisory Committee to the
;j NAIC Nuclear Risk Task Force, December 11, 1984, Steven C. Sholly. Union 11 of Concerned Scientists, Washington, D.C.
a
- 29. "Union of Concerned Scientists' and Nuclear Information and Resource Ser-
'O vice's iloint Comments on NRC's Proposal to Bar from Licensing Proceedings 1 the Consideration of Earthquake Effects on Emergency Planning," Union of
.! Concerned Scientists and Nuclear Information and Resource Service, Wash-
.i ington, D.C., Diane Curran and Ellyn R. Weiss (with input from Steven C.
! Sholly), February 28, 1985 *
- 30. "Severe Accident Source 1erms: A Presentation to the Commissioners on the Status of a Review of the NRC's Source Term Reassessment Study by the l Union of Concerned Scientists," Union of Concerned Scientists, Washing-l 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.
~l 32. The Source Term Debate: A Review of the Current Basis for Predicting Se-i i vere Accident Source Terms with Special Emphasis on the NRC Source Term Reassessment Program (NUREG-0956), Union of Concerned Scientists, Cam-j bridge, Massachusetts, Steven C. Sholly and Gordon Thompson, January 1986.
lt
- 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 Counsel, regarding the prudence of expenditures on Millstone Unit III, February 18, 1986, t
- 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.
] I
- 35. Review of Vermont Yankee Containment Safety Study and Analysis of
! Containment Venting Issues for the Vermont Yankee Nuclear Power Plant, I
prepared for New E.991and Coalition on Nuclear Pollution, Inc., December { 16, 1986. i i
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; 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 i Failure to Establish Its Committed Design QA Program, ,fj Application Nos. 84-06-014 and 85-08-025, Exhibit No.
j 10,935, March, 1987.
- 38. Testimony of Gregory C. Minor, Steven C. Sholly et. al.
j 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 Steven C.
i Sholly on behalf of Suffolk County regarding LILCO's Reception Centers (Addressing Testimony of Lewis G. Hulman), Docket No. 50-322-OL-3, May 27, 1987.
- 40. Review of Selected Aspects of NUREG-ll50, "Reactor Risk Reference Document," prepared for the Illinois
- Department of Nuclear Safety by MHB Technical Associates, September 1987.
i t l l Available from the U.S. Nuclear Regulatory Commission, i I Public Document Room, Lobby, 1717 H Street, N.W., Washington, D.C. l 1 ;
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i 0lllllNew 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 plant reached full power (94%) on April 21st. ! The Institute for Nuclear Pqwer Operations (INPO) will conduct its annual critique of plant ] operations beginning o'f June 8th. MAINE YANKEE Maine Yankee shutdofm f,or refueling is proceeding generally according to schedule with startup expected in eady June. Very small cracks found in the disks of both low pressure , 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 cyc'e of the plant produced more than 2 million megawatthours over a 17 month period with a capacity factor of 93 percent. PILGRIM i Pilgrim remained off line during the month. l l 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 'ine the same day and operated at full power for the remainder of the month. j i MILLSTONE 1 & 2 i Millstone Unit 1 operated routineiy for the, month of April. A scheduled refueling outage j will begin in mid-Jur's 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 ' presumed bistable transformer 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 he next day while at 10 percent power level due to steam generator low level when tu:bine driven feed pump oscillated. Feedwater regulating control valve failed to open on demand due to a control air leak. The unit returned to service on April 14 after being out for 29 hours.
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' ***** AUG 2 71986 Docket No. 50-293 Boston Edison Company M/C Nuclear
, ATTN: Mr. James M. Lydon f 1. M Chief Operating Of ficer ,. . ;
800 Boylston Street . 1 Boston, Massachusetts 02199 j Gentlemen:
Subject:
Confirmatory Action Letter 86-10
; This letter is to provide further guidance on the requirements we expect to be met
-i 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 C1Nffirmatory Action 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 issues involved with CAL 86-10, several other issues have been identified that require resolution prior to restart of the Pilgrim plant. Seecific technical issues of concern include overdue surveil-lances , mal fur.ction of recirculation motor aenerator set field breakers, seismic oualification of emeroency diesel generator differential relays, and completion of Accendix R modifications. please be prepared to discuss these issues at our next manacement meeting at the plarit on September 9, 1986. we would also Ige,to hear at this meeting the scope and status of all vour orocrams related to restart of
,.Pilorim. These include (a) the results of your six week action plan for improve-
; ments. (b) the role of BEC0_ safety review committees. including the Procram For i Frepilence Tgsk Force, in assessino readinets for restart, and (c) the readiness qf the plant and corporate staff to support plant startup, testing, and operations.
In light of the number and scope of the outstandina issues. I am not orecared to approve restart of the Pilorim facility until vou nrovide a written rennet that documents BEC0'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 t.lso be submitted for NRC review and approval. This program should include hold
.f points at appropriatt stages such as criticality, completion of mode switch test-1 ing, and at specific milestones during ascension to full power. Authorization to l proceed beyond each hold point will be contingent upon my approval and will be I 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 program and schedule j at least forty-five days before your olanned startuo from the current outaae. My ' decision on restart will be based in part on our review of these documents. f i I
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i . Your cooperation is appreciated. Sincerely, E a l -; Thomas E. Mutley
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Regional Administrator I CC: L. Oxsen, Vice President, Nuclear Operations
. A. E. Pedersen, Station Manager
- Paul Levy, Chairman, Department of Public Utilities Edward R. MacCormack, Senior Regulatory Affairs and Program Engineer Chairman, Board of Selectmen Plymouth Civil Cefense Director The Honorable E. J. Markey J. O. Keyes ..
Senator Edward P. Kirby The Honorable Peter V. Forman Sharon Pollard Public Document Room (POR) Local Public Document Room (LPOR) Nuclear Safety Information Center (NSIC) NRC Resident Inspector . Commonwealth of Massachusetts (2) 4 i i
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APR 0 81997 . Occket No. 50-293
.; Boston Edison Company M/C Nuclear 1
ATIN: Mr. Ralph Bird - i l Senior Vice President - Nuclear 800 Boylston Street i Soston, Massachusetts 02199 m 1 Gentlemen: !
Subject:
Systematic Assessment of Licensee Performance ( SALP) Report 1 No. 50-293/86-99
- ' ine Ree, ion ! SALP Board has reviewed and evaluated the performance of activ-ities at January threugh the Pilgrim Nuclear Power Station for the period November 1,1985 31, 1987. The results are presented ir' A reeting to discsss this assessment will be scheduled -forthe enclosedaccept-a mutually report.
. acie ca ,e.
The reeting will be held on or near the sit e so that apprcprine se or corporate managecent anc olant efficials ccn di sc'as s with us the st er.gths and aeak. esses noted. It is our intent that th is meeting be ce=bined with the periodic management meeting to review imorov tment program status.
'e SALP Board icentified significant recurring progra m weaknesses ir so e f ur.:tional area s.
, ere also notec. However, Improvements, such as in the area of e mergency preparedness, j slow during most of the assessment the SALP Boarc found the rar.e of such change was perted.
j
; Ve recognize that the Boston Edison Company (BECo) has ciade significant staff-ing anB hardere comnitments to improve performance at the Pilgrim Statier, and-we believe they are beginning to have a positive impact. As you are aware, the
cNRC etle is.slooking for progress in correcting the previously identified lorg te~ " at the. Pilgrim Station prior to plant restart, carticularly te tr:t: ure-icnai a eas witn a Category 3 rating. ;
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~i In : reparation for the SALP meeting, please ce . prepared to discuss your evalua-tien of our assessment and the status of your performancer improvener.t pregra?.s.
Any com.ents you may have regarding our report may be dis cussed at the meetirg, Ac:itionally,.you may provide written coa ents within 30 days af ter the meet- ) ing. Following'our meeting and receipt of your written response, the snelosed report, your response, at.d a summary of our findings an-d planned acticat wilt ce visceo in the NRC Public "ocument Room. I 1 l l
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J , i TABLE 4 l 1 1 . l ) ENFORCEMENT
SUMMARY
(11/01/85 - 01/31/87) t { P!LGRIM NUCLEAR POWER STATION l' ! 1 (
. '; A. Number and Seve-ity level of Violations i ~I Severity Level ! 0 i
( l Severity Level II O l Severity Level !!! I Severity Level IV 21 Severity Level V 6 Ceviation 1 1 1 Tesal 29 l S. 'viciations Vs "unctional Area l Severity Leve * $
.r::1ena'. Area I !! !!! I v' V :!Iv Tetal
- ant Operati:ns - - -
1 1
. O. Eaciological Centrels - -
1 3
- - 4
! 3 va'ntenance - - -
1 1 i 5;rveillance - - - 6 3 - 9 1 i
- 5. :fre Drotectics - - -
5 - 2 5 l E E ergency P e:a-ecness - - - - - - O i=:. 1:y Safeg. ares 7 - - - 1 1 - 2 l 4 3 Catage Manager.ent and l Mcdifi. cation Activities - - - 1 1 2 l
- 9. Licensing Activities - - - - - -
O j
;0. Tra: ring anc Cualification Effectiveness - - - - - -
O l
. 1::.--ar.:e c' .a t i: - - - 4 - - c '
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q 'e: r teai S.:::-
- als C , 1 21 6 1 29
w , ; .. . . a x . .. :- . . 2 : . e"O" :-"-'~'"~^'" "'~ ~~ '
~ ~
l . . I ~! l 64 i l IABLE 4 (Continued) C. Summary Inspection
- Report Severity Functional *
. Number Level Area I Violation
~i 85-32 V Surveillance
' Instrument channel tests were not being performed monthly for the reactor i
building vent and stack waste gas sonit. ors. ! 1 55-32 V Secu ity Failure t o perform a i SafegLards proper se arch of a package brought i nto the protected area. Ei-C. V ' ant Dost trio review 86-01 anc C:a-ations 86-02 lac (ed required recorder .:ha-ts . Inadequa t e control com icg entries or. disabled annunc'.ators.
; E6-04 1 ;aciological A waste s hiprea.t of solid j Cc-trols metallic oxices on non-g,.
compactec trash lacked i requireo . strong packsging an: quality control measures. 56-06 IV Surveillance Replaceme nt squib charges were inst.alled in the stan:::y liquid ccutrol syste.- fece a 1 batch tha t had not been testec during a manual initiation c f ' i the Stancby Liquid Centrol
-i 1
System. 56-10 IV Radiological Radiattor surveys of pack.ageo Controls irradiated reactor compenents were not cocumented on appropriate radiation survey { f o rms anc' ma c s . I El-I; I '. Ass.rance of Quality contrcl reasures we e 0 tty not takt- 'n transfe-ring racicact' ve wa ste shi;ments
<~
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-i 65 l
TABLE 4 (Continued) C. Summary i Inspection Report Severity Functional lyr.b e r Level Area Violation IV Assurance of Previous 3y identified I 95-14 inadequacies involving Quality
., surveillance testing of the high pressure coolant
' injection system were not
' corrected for six months.
36-14 V Surveillance Failure to' properly control r.easuring and test equipment. 35-2: :V Su-veillance Battery r ate::
- cac discharge Test proc edure was not updated ::c eflect syster
' alterations anc restorations.
I f li-25 :V Assuran e of Ouality Failure a nc f'alfunet on Report wa s not completed by engine ering personnel af ter
' they iden tified deficient station f tre barriers, t
36-25 V Surveillance Surveillar.ce tests were
' performec without incependent verification of systen restense
- and systen restoration.
J j 56-25 Deviation Fire Drotecti:n Fatture to comply with the
' coxatitment to ccnduct quarterly fire brigade dei 11:
for all fire brigade metters. 15-54 IV Security Improper package sear-ch anc Safeguards inadequate fo11ew up. 56 ~6
; IV Fire protection Fire brigade members had not received the required training.
l Ei-2i V Fire : :tectiem :' re watc hes f ailed .:a pe-f:r-the required hourly patrci of the motor generator set room 1
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- l
- 1
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TABLE 4 (Continued) : i C. Summary i
! Inspection Functional j Report Severity Level Area Violation Humber
.l inadequate fire brigade drili.
i Fire Protection j 86-37 IV 1 Modifications Safety-related modifications 86-37 IV were not performed i n
];. accordance with applicable i
design requirements. Fire Prctection Adequate procedures and 55-35 IV drawings had not been established "or the station fire wat er sustem.
- adiological Failure to ir;?ement a V
16-ca radiolog ical cortrol procecure Controls j for chec king. vea.icles leaving the site. IV Survetilance Failure to adhere te the 1 37-01 procacure gcverning
;j surveilliance testing of t9e j Post Ace'iden , Sampli ng "l Syster (: PASS ) system.
! IV Waintenance t.ack of procedure guidance or, 67-01 maintenance of the heat I
tracing centr ol cf reuit relay s I for the DASS system.
; ('
IV Fire Prote: tion Failure to ta ke required 57-03 action for inoperable fire protection ecuipment.
. O.* .
4.L Radiological Failure to control a master 87-03 b IV key to all locked nigh
'o Centrols radiatt ' areas.
IV Assurance of Failure and M.alfunction 57-03 Repc-t n ot cc9oitted af te-Osaty a saf ety-related bus trar s'e-die not occur during a surveillance test. L - w,. . , m - - - e . --"
. -. _,, . . . .......: ... . .u. .w ~ .._.. . , . . . . . ... ,< , , * -. p.i 1
67 1 TABLE 4 (Continued) C. Sum: nary l Inspection . 1 Report Severity Functional Number Level Area Violation i l 27-04 IV Surveillance A surveillance test on Standby : Gas Treatment System failed to meet the intent of the Tech Soec requirements. 87-04 IV Surve ' lance Failure to calibrate measuring i and test equf ocent. 57-04 V Modification Perforrning pc'st-modt fication test or, the rtfuel bridge withou ap;*0Ved procedure changes. 57-04 IV Surveillance Master test ra:; ram procedures co not ace:. uely acdress surve t "lar : test at:d pcs: 9 modi ficat: - test progra:.: . t
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'\ KING OF PRUS$lA, PENNSYLVANIA 194;C U #e m a a ms RECEIVEL Oceket No. 50-293 g O ~ 1 Boston Edison Company M/C Nuclear ATTN: Mr. William O. Harrington Senior Vice President, Nuclear Q, P, Q, 800 BoyIston Street I , ......._,.,_,,,, d Boston, Massachusetts 02199 la Gentlemen:
Subject:
Systematic Assessment of Licensee Performance (SALP) Report No. 50-293/85-99 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 a meeting held in Plymouth, Massachusetts on March 5,1986 (see Enclosure 2 for attendees). We have reviewed your March 26, 1986 written comments (Enclosure 3) and herewith transmit the final report (Enclosure 4). Overall, your performance in the operation of the facility was found acceptable although some areas were only minimally acceptable. 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, (2) a prevailing view in the organization that the improvements made to date have corrected the problems, (3) reluctance, by management, to acknowledge some problems identified by the NRC, and (4) dependence on third parties to identify problems rather than implementing an effective program for self-identification of weaknesses. We believe these findings confirmed the SALP Board conclusions. j We acknowledge your discussion of program and staffing improvements in plant I
! operations, radiological controls and emergency preparedness. However, we l believe that .the success of your programs depends upon resolution of the four principal faqtors inhibiting improvement noted above which, in turn, depends i heavily on asnagement attitudes and aggressive followup. In this regard we 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.
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T-4-1 TABLE 4 ENFORCEMENT
SUMMARY
(10/1/84 - 10/31/85) PILGRIM NUCLEAR POWER STATION i i Severity Levels 3 FUNCTIONAL AREAS I II III IV V DEV Total i A. Plant Operations - - - 4 2 - 6 B. Radiological Controls - - 1 1 1 2 5 C. Maintenance & Mettfications - - - 1 1
- 0. Surveillance - - -
9 2 1 12 E. Emergency Preparedness - - - 2 - - 2 F. Security & Safeguarcs - - 1 - - - 1 G. Refueling & Outage Management - - - - - - 0 H. Licensing Activities - - - - - - 0 i Tetals by Seve it., Le.ei 0 0 2 17 5 3 27 i f C 1 I
'. h 1
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_ ..,: ). + x ' ~ ' ' - " ' ' * * ' " ~ ^ m... l l l T-5-1 l h . TABLE 5 ENFORCEMENT DATA PILGRIM NUCLEAR POWER STATION 4 Insp. Insp. ( _ No. Severity Functional Date level Area Violation 84-36 11/1-11/85 IV Plant Failure to conduct an adequate Operations shift turnover for control room personnel during refueling IV Plant Operations Failure to continuously monitor source range monitors during refueling 84-39 11/21- IV 12/31/84 Surveillance Failure to promptly identify conditions adverse to quality (i.e. failure to initiate Failure and Malfunction Reports) 84-41 12/10-13/84 IV Emergency l Preparedness Failure to diseminate emergency planning information IV Eee* gen:y
- re; a rt:r.a s s Failure to update the emergency plar and pr::ecures i 84-44 12/15-19/84 III Radiological Controis Failure to follow radiation work permit instructions and failure to establish a procedure for a remote reading teledesimetry system 85-01 1/1-31/85
' V Plant C;erations Failure to maintain control room staffing at levels required by 4 10 CFR 50.54 I
IV Surveillance
' Failure to test the containment cooling subsystem immediately when the low pressure coolant injection system was inoperable 85-03 2/1/85- IV Surveillance 3/4/85 Failure to conduct surveillance tests for the reactor protection system (six examples)
IV Surveillance g Failure to conduct rod block surveillance tests (five examples) l l
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T-5-2
> Insp. Severity Functional l Insp. Violation l No. Date Level A*ea l I
IV Plant Failure to promptly correct con-Operations ditions adverse to quality (i.e. failure to take timely action i on Quality Assurance surveillance j findings) o-Failure to use the most current surveillance V i revision of s epwe111ance test procedure ;fe-l V Surveillance Failure to calibrate test equip-ment within the calibrated period 85-06 3/5/E5- V Plant Failure to maintain an uncali-Operations brated local power range monitor 4/1/85 in a bypassed state IV Maintenance Failure to conduct a dioctyl phthalate test of HEPA filters following maintenance on the standby gas treatment system Radiological Failure to have the Operations 85-13 5/20-24'85 V i C or.t rol s Review Comittee (ORO) review twc radiclogical procedures and 4 failure to control work in the fuel pool with a maintenance request , 4 Deviation Radiological Failure to conduct an adequate Controls review of systems that could generate an uncontrolled, un-monitored radioactive effluent ! release, as recommended in IE l Bulletin 80-10 85-17 6/13/85- IV Surveillance Failure to conduct a surveillance 7/15/85 surveillance test of the 250 V battery system required by the technical specification and to follow station procedures for additional battery tests IV Radiological Failure to specify high radiation Controls area surveillance frequencies on radiation work permits
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t T-5-3 Insp. Insp. Severity Functionai No. Date Level Area Violation Deviation Surveillance Failure to conduct inservice tests as specified in an NRC submittal 85-20 7/16/85- IV Surveillance Failure to maintain the trip i 8/19/85 level setting for the "B" and "C" sain steaseltee high radt-ation monitors within technical l specification limits 85-21 7/16/85- IV Surveillance Failure to maintain secondary 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 Malfunction Reports as required by station procedures
)
] 85-24 8/6-E/55 III Security Failure to maintain an adequate j vital area barrier 85-26 E 20/EE- IV plant Failure to properly authori7.e 9/23/E5 Operations excessive licensed operator
- overtime as requireo by ttation procedures (thirty-five instances) 85-27 9/16/85- Deviation Radiological Failure to install a protective 9/20/E5 Controls conduit t
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/ o, UNITED STATES j J' ;
1 i , ,. , 1 NUCLEAR REGULATORY COMMISSION MEGION 1 o utPAnx4vtNue
,/ xmo or PaussiA. PaNNSYLVANIA 19406 Docket No. 50-293 JUN 191985 "C *I p; 3 Boston Edison company M/C Nuclear ATTN: Mr. William O. Harrington 'i, Senior Vice President, Nuclear ::.
} 800 Boylston Street W. g n
-j Boston, Massachusetts 02199 -
l Gentlemen:
$- )
Subject:
Systematic Assessment of Licensee Performance (SALP) Report No. 50-293/
,1 84-34 and Your Reply Letter BEco 85-031 Dated February 12, 1985 m 1
- 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 reconsider some of the assessments to better account for the assessment period's extraordinary circumstances (i.e., the extended 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 feel this is appropriate
' as for we may not have properly accounted for the extended outage in our evaluation trend.
I However, we continue to feel that the extent of contamination that j existed throughout the plant was inconsistent with a Category 1 rating. The en-closed SALP Report has been supplemented to reflect this change.
! The SALP Board a also found that the other ratings should remain unchanged.
} With regard to the current status of your operations, we acknowledge the improving 3
; trend of your performance in the plant operations and maintenance arets and en-courage you to continue your efforts in these areas. Further, we note the progress j
; being made in implementing your recently established Radiological Improvement Pro-gram and encourage your efforts to decontaminate the plant, to reduce plant radi-ation levels, to enhance oversight of the radiation protection program, and to establish support for the program by plant personnel.
4 _j , Your cooperation with us is appreciated. j Sincerely, A' Thomas E. Murley Regional Administrator t _ _ _ -- ~
;3 . . . - . .
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38 TABLE 2 VIOLATION SUWARY (7/1/83 - 9/30/84) t
, PILGRIM NUCLEAR POWER STATION 9 A. Number and Severity level of Violations
.)
.1).lj Severity Level I O
,- Severity Level II' 0
- 0. ., Severity Level III 1 1 Severity Level IV 18
~i -
Severity Level V 6 Deviation 1 Total 26*
~] : B. ' Violations Vs. Functional Area
-4 i
Sevirity Level Functional Areas I II J,'I IV V OEV
-3l , A. Plant Operations '
.; 2 5
_ 'j B. Radiolecical Controls" 1 7 1 1 i
- ]
-] C. Maintenance i s
2
> - -. O. Surveillance 1 :
; E. Fire Protection and Housekeepinc 1 a _
l j F. Emercency Preparedness aA fi G. Security and Safeguards 6 j ! H. Refueline and Outace Manacement
)
I. i Licensing Activities
-1 t
t Totals
- 1 18 6 1 f
- 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 enforcemert action was under review at the end of the assessment period. ' l l l \ . _ _ .
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39 i 1 C. Summary Inspection Inspection Severity Report No. Functional s Date _ Level Area Violatien 4 83-19 8/16-10/3/83 V
.'j A Failure to review and up-date special orders V
>K A Failure to vant piping from the high point in the core x::
spray system
.; 83-20 8/8-12/83 IV j
B Failure to follow a Radi-ation Work Permit 83-21 8/22-24/83 V A Failure to schedule 'exter-nal audits
. V A Failure to document defi-ciencies in deficiency i
reports 83-23 10/4-11/7/83 IV 3 D Failure to conduct an in-y service test on a high Kj pressure coolant injection 1 (HPCI) valve v: 1 IV i q C Failure to review a proce-3 dure for procuring safety-i related items. j 83-24 11/8-12/31/83 IV A
.j Failure to record reactor
. vessel cool down rate
! 84-03 1/20-27/84 III l
B Failure to label a container i of licensed material, use
')7 extremity dosimetry, and l
l instruct workers on radi-ation levels
'! 84-04 2/7-3/12/84 IV A Failure'to maintain a pro-cedure for the proper operation of the contain-ment atmospheric dilution system 84-06 2/13-17/84 IV B Failure to follow a radi-ation work permit e _, - - . _ - - - _ . . - , _ -,% --
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40 1 5 Inspection Inspection Severity Report No. Functional Oate level Area Violation 84-11 4/23-27/84 IV i C Failure to maintain a pro- .
! cedure for controlling '
welding slag 84-13 4/24-27/84 IV
- B Failure to properly review cg' and approve contractor pro-H cedures involving transpor-J, 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-1 ment 84-14 5/9-11/84 IV B
, Failure to instruct workers on the presence of radio-
"t active materials
.! IV B Failure to survey radiation hazards ;
I y
, 3 IV B Failure to implement pro-cedures consistent with 10 CFR 20 i
.) 84-22 7/16-20/84 IV i
j G Failure to control a security key card j a a IV G Failure to maintain photo 10 badges Il G Failure to respond to two vital area alarms i IV G Failure to maintain one guard radio and one offsite l i communications net operable ; i 1 1
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.; 41
- $i i
Inspection Inspection Severity tj Report No. Functional Date __ Level Area Violation 1
,1 IV G Failure to maintain effae-
.A tive compensatory measures.
4 IV d G Failure to maintain effec-3 tive compensatory measures.
#L:j 84-25 8/6-10/84 *
,- y; B Failure to perform radiation
; surveys
- J a)
- 8
)
"i Failure to instruct workers ,
d on radiation hazards '
, I
- 8 Failure to properly approve procedures
- B Failure to implement recem- 1
. mendations in Regulatory !
Guide 8.8 ' t 84 26 8/28-10/8/84 V
- A Failure to properly approve
.j QA program related proce- i dures !
.I 1
.2
.3 ' Apparent violations and deviations. 1 i and of the assessment period. Enforcement action was under review at the I l
; i I
i
-1 1
h l 4 .
?
i
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an VNITeD STATll "I '
;#* # NUCLEAR REGULATORY COMMISSION
' ]. g msg 40N I y ,, e 2 I sai pann avsNys f
nine op paussia, psNwsvLv ANi A is4ee h ce: , No. 50-293 g 4 g: sten 5:isca Company M/C Nuclear AiiN: M*. '.'illiam D. Harrington Senior V1:e President. Nu: lear RECEIVED
^
-;l-j 500 5:ylster Street
.' ~, Best.w Massa:nusetts 02199 S E i 1. 5 F.C.'.
... W, o, H, Gea.lemen:
L'l
" v : ..
S',E,' E0T : SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP) 4 ~' , .l'j! 3 ine NR0 Region I SALP Boarc condu:ted a review on August 25, 1963, and evaluated "j a
- ne :eaferman:e of activities associatec witn the Pilgrim Nuclear Power Station.
I ine results of this assessment are cc umentec in the enclosec SALP B:ard Report.
- i a meeting has teen seneculec for Septem er 21, 1953, at Braintree, Ma. to cis:uss this assessment.
At ne meeting, you should be creoared to dis:uss our assessment and your Olans : im: rove ceaformance. Any :omments you may have regarding our re: ort may :e cis:ussed at tne meeting. Additionally, you may provice written c mmeats within 2D cays af ter the meeting.
' E0licwing our meeting arid receiet of your response, the en:losed recort, your res:ense, an: a summary of our findings and planned actions will te placec in d' t*e NRO Pu li Oc:vment R00m.
. . <?,
O'hi YCur Oc;:eration is appreciated.
-i Sincerely,
_ .._ . ~ j,
-d
,d
-<}n n icha C . arostecki SALP B0erc Chairman, Dire: tor
'$ ' I
" Division of Project and
' Resident Programs
- Iosure: As Statec
- w! e a.:1 :
A V M risi, Maa.ager, Nu: lear Ocerations Supeort C J Mainis, Station Manager 1 1 i
\
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39 i 1 4
; TABLE 4 VIOLATIONS (7/1/82 - 6/30/83)
PILGRIM NUCLEAR POWER STATION J
,A. Number and Severity Level of Violations
. ,-)
. ., t ! Severity Level I O Severity Level II O
^b Severity Level III 1 ci Severity Level IV 9 Severity Level V 20 Deviations 3 ,
Total Violations 30 Total Deviations 3 B. Violations Vs. Functional Area Severity levels FUNCTICNAL AREAS I II III IV V DEV I 4 8
. 1. Plant Oeerations
- h 7 Radiolecical Controls
~
1 1
;l 2.
,. ;] 1
.lj 3. Maintenance 1
. -) l
! 4 Surveillance
- 5. Fire Protection /Housekeecine 3 1 q
' -i Emereeney Precaredness
.] 6.
- 7. Security and Safecuards 1 3 2
- 8. Refueline
- 9. Licensine Activities i
Totals 0 0 1 9 20 3 l i { Total Violations = 30 Total Deviations = 3 0
- ._m... * *_ -
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, 40 j
TABLE A (Continued) i Seea ry Inspection Inspection Require-Nel Date Subject __ments Severity Area 82-19 June 14 - Blocking open a fire T.S. V 5 August I door without proper controls v., g Failure to evaluate T.S. V 5 fire loading prior ' to moving combustibles
; into safety related '
area
- l Failure to translate 10CFR50 V 1 design bases into App. B drawings j
Failure to perform 10CFR50.59 V 1 l
- an adequate safety evaluation prior to l
-) changing a station l
._; valve lineup procedure
.'I Failure to maintain T.S. V 5 1
a fire door position
,l continuously annunciated J
Failure to perform Fire D 5
! daily checks of non- Protection alarmed fire coors Review as committed to the NRC 82-22 August 2 -
Failure to make a T.S. IV 1 prompt notification Failure to make a IOCFR50 V 1 50.72 notification , Failure to perform a T.S. IV 1 i leak rate test required by the LCO for an inoperable Vacuum Breaker
,' Alarm System I
I 1
.a n- -
.m
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.7.
, 41 TABLE 4 (Continued)
Summary Inspection Inseection Require-No. Date Subject ments Severity Area
, 82-24 Septemoer 7 - Failure to revise Licensee D 2 October 18 procedures for radio- Response j active discharges as to
, ;l committed to the NRC Violation 81-19-01
}
l 82-29 Octobe Improper equipment T.S. V 1 November 15 tagging Failure to properly ' set a main steam safety valve Failure to properly 10CFR50 IV 1 control distribution App. B of the Q-List
, Failure to use proper Security V 7 methods of access Plan
] 1 control i Failure to prevent Security IV 7 unauthori:ed entry into Plan vital area or followup j en a security deficiency
~l N/A(1) January 31, Safeguards information 10CFR73.21 III 7
; 1983 not properly controlled 7(
resulting in a loss of
copy of the site physical Security Plan 1 l ,$3-03 January 25 Failure to perform T.S. V 2(1)"
j Feerwary 28 chemistry samples i Failure to assure that 10CFR50 V 1 1 training certification App. B forms were completed prior to watch assignment , l Failure to properly T.S. V 1(5)* { i control hign pressure gas cylincers l l i m-. ;
~ :l
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...f 1
i l 42 TABLE 4 (Continued) l Suma ry j Insoection Inspection Require-
; No. Date Subject ments Severity Area
'j March 22- T.S.
; 83-07 Failure to imple- V 2(3)*
i April 18 ment a station pro-j cedure for inspection i and cleaning of the SEGT System inlet i plenum 83-08 May 9 - Failure to conduct T.S. V 2 .' May 13 an audit of the Radiological Enviroa-mental Monitoring Program report when required S3-09 April 4 - Accepting, in receipt 10CFR50 V 1
! May 3 inspection, material App. B g not in conformance with the P.O. Require-j ments i
! Failure to maintain 10CFR50 IV 1 j the 0-List App.B (2) Failure to upcate the 10CFR50.71(e) V 1 FSAR
] Failure to perform preventive mainten-IES 79-09 Commitment 0 3 ance as committed to the NRC
.; S3-10 April 19 - Safeguards information 10CFR73.21 IV 7 May 23 not properly contro11ec Security access card Security IV 7 key not croperly con- Plan trolled D
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#* "'%,,v* NUCLEAR REGULATORY COMMISSION REGION I I !* .( "' !l sai Panx AvcNur niNo oF Pmussi A. PENNsV LV ANI A 19404
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' Occket No. 50-293 i
i Boston Edison Company M/C Nuclear ATTN: Mr. William D. Harrington i Senior Vice President, Nuclear 800 Boylston Street Boston, Massachusetts 02199
' d,1 Gentlemen:
Subject:
Systematic Assessment of Licensee Performance (SALP) This letter and its enclosures document NRC's asse The enclosed SALP Report, dated August 12, 1952, 1,1981, to June 30, 1982. i includes performance assessments for each of the nine functional areas which These individual assessments were discussed with you and your were evaluated. staff by Mr. R. W. Starostecki of this of fice on September 1,1982, at the Boston Edison Company offices in Braintroe, MA. Our overall assessment of the performance There now appears of to beNRC l personnel changes which took place earlier this year. l a satisfactory level of management attention and involvemi ll i j matters. safety. We recognize that ef forts are underway to improve the manageent These changes j systems and utilization of resources at the Pilgrim facility. and plans are documented in the Performance Improvement Plan which mitted to the NRC on July 30, 1982. Although i several months before some of these improvements will be comoleted. j i performance has improved recently, some shortcomings In particular, we believehave been noted and we additional have included them in this report,
, attention is warranted on your part in the areas ofWe day-to-day plant opera-will be increasing our
.; tions and fire protection / prevention activities.
attention to these areas to ascertain if identified weaknesses are being j corrected.
'i in the meeting of September 1, 1982, the NRC staff benefited from your comments t concerning the SALP Program and the functional 20,area 1982performance assessments.
and have included j 1 have also reviewed your letter of SeptemberThe SALP Board also considered responses to your comments in this package. The results of these l-your concerns and I had the benefit of their input. ; i considerations are presented below. l 1 l 4 i l J l -w--~~ N@M
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I _ TABLE 5 VIOLATIONS (9/1/81 - 6/30/82) PILGRIM NUCLEAR POWER STATION .- A. macer and Severity Level of Violations
- a. IntaHe NRC Policy Severity Level (September 1,1981 - March 5,1982) l SeveHty Level I O 1
leveHty Level II O ' 5everity Level III 6
!averity Level IV 5 SeveHty Level V 17 SeveHty Level VI 2 biation 1
- b. Mc policy Severity levels (March 10, 1982 - June 30, 1982*)
SenHty Level I o 4 SenHty Level II O SenHty Level III j leveHty Level ty 4 SeveHty Level V biation 3
)
l I'tilViolations 38 Total Deviations 2 Functional Area I. P l 1981 - March 9.1982 4 gg Severity levels 1 1 p3 I II III IV V VI DEV 2 ta 0 0 3 3 5 0 0 8
- 3. Ma 0 0 1 1 3 0 1 4 Surve 0 0 0 0 2 0 0
- 5. Fire % p 0 0 0 1 1 1 0
- 6. EDemne p 0 0 0 0 5 0 0
- 7. Securi m 0 0 1 0 0 0 0
- 8. Re fuelt 0 0 1 0 0 0 0
- 9. Licensin 0 0 0 0 1 0 0 0 0 o o o 1 LLL __
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- 5. Violations Vs. Functional Area
{ (2) March 10,1982 - June 30,1982* j Severity Levels i v ' d FUNCTIONAL AREAS I II III IV V OEV
. 1. Plant Operations 0 0 0 1 1 1
- 2. Radiolecical Centrols* O O O 1 0 0 l
- 3. Maintenance 0 0 0 1 0 0 l
l
- 4. Surveillance 0 0 0 0 2 0 ;
- 5. Fire Protection
- 0 0 0 0 0 0
- 6. Emer;ency Preparedness 0 0 0 0 0 0 i S
- 7. Security & Safeguards 0 0 1 0 0 0 I
; ~
0 0 0 1 0 0
.' L_7Refuenn'a -
- 9. Licensine Activities 0 0 0 1 0 0 i.
Totals 0 0 1 4 3 1 Total Violations = 38 Total Deviations = 2
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- Does not include the following reports, not yet issued: ;
l l 82 Resident Inspector l i j 82 Special Health Physics l-i ) 36
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l, . ) ' .' . 1 q l ), i TABLE 5 (Continued)_ [ C. Sumary Inspection Inspection Sev. Area Subject Reo. i No. Octe d 1 (9)* 81-18 June 15 - Faili!ra to have an operable 10 CFR III Sept. 30 cos ,...ible gas control system 50.44 (multip'e exangles of design errors, procedural and drawing i errors,)and reviews inadequate safety 81-18 June 15 - Failure to infonn the NRC of T.S. III I (9). Sept. 30 the erroneous statement that an installed system met the require-ments of 10 CFR 50.44 - Material False Statement 81-19 August 18 - Failure to follow station pro- T.S. Y l Sept. 30 cedure t
,' 81-19 August 18 - Failure to perfonn 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
- radiation work permits, j 81-21 August 31 - Failure to post copies of NOV's 10 CFR V 2 j
Oct. 2 involving radiation protection 19 j 81-22 Sept. 16 - RCIC containment isolation valves T.S. III 1 i Sept.17 were left open when their control instrunentation 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 Failure to adequately prepare and T.S. 1(4)
- gec 1.1981- V an. 18. 1982 implement procedures for coping with high drpell terceratures
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'1 TABLE 5 (Continued)
C. Sunna. j Inspection 9 b' in [ No. . F Subject Th 81-24 , , , . Rec. Sev. Area 11 1981-j de . i6, 1982 Failure to promptly evr,1uate and 10 CFR V correct conditions adverse to quality 50 App 8 1 5 81-24
/ 1 Dec. 1, 1981-1 Jan. 18, 1982 1 Security access card keys not pro-parly controlled Security III 7 81-24 Plan Dec is 1981-Jan. 1:9,1982 Cembustibles were not; removed from area near hot work T.S. V 5 81-24 Dec. 1, 1981- '
Jan. 18, 1982 Improper equipment tagging T.I. V 1(3) 81-25 Oct. 15 - i Oct. 18, 1961 Failure to have all ORC membersT.S. 4 present at a pre-refueling meeting V 8 k
'! 81-26 1 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'combu'st'ble s 3 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
, cent procedures for t T.S. V S t
oE combustible scrap,he control ! i 81-35 waste, debets i j Nov. 1 - Nov. 30 Failure to establish and imple. j ment procedures for the control T.S. Y 5
,of combustible oil $
! 81-35
! Nov. 1 -
Nov. 30 Control of foreign material during repairs to MSIV's was not T.S. V 3 in accordance with procedure 81-36 Nov. 30, 1981-Dec. 4, 1981 A master surveillance schedule T.S. was not, established VI 4 81-M Nov. 30, 1981-Dec. 4, 1981 T.S. Amendments were not properly entered into controlled volumes T.S. VI 9 (1) h 38 i
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1 - l TABLE 5 (Continued) C. Sumary l Inspection No. Inspection Date Subject Rec. Sev. Area 81-36 Nov. 30, 1981- Program and procedures were not 10 CFR V 3 (5)
- N Dec. 4, 1981 established for housekeeping and 50 App B
'I system cleaning that meet the QAM
] .
standards stated in the'QA Manual 82-01 Jan. 18, 1982- Workers we e not properly in- 10 CFR V 2 Feb. 28, 1982 structed of the storage and 19.12 : transfer of radioactive resins 1 82-01 Jan. 18, 1982- Procedures were not adequately T.S. Y 5 Feb. 28, 1982 established and implemented to i provide required numbers of SC8A units for fighting fires 82-02 Jan. 1 -
)
i 82-02 Jan. 15, 1982 Jan. 1 - Uncalibrated brush recorders were used during RPS surveillance Maintenance activities were per-10 CFR 50 App B T.S. V IV 4 3
! Jan. 15, 1982 fonned without using approved j procedures i 82-02 Jan. 1 - Instrumentation was not calibrated T.S. V 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 i
82-04 Jan. 25 - Failure to implement procedures T.S. V 4(1)* Jan. 29, 1982 for LLRT and drawing change j t 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 systems
, 82-05 Feb. 1 - Untimely corrective action to 10 CFR V 1 Feb. 5, 1982 intamai QA Audit Deficiency 50 App B Reports 82-06 Feb. 10 - Training and requal. program for Comittnent DEV 2 i Feb. 12, 1982 personnel who operate and process IES 79-19
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radioactive wasta not implemented as comitted
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t TABLE 5 (Continued)
~i C. Sumary ~j Inspection No.
Inspection Date Subject Rec. Sev. Area N/A Feb. 12, 1982 Prompt Notification System ~ ~ '.;r 10 CFR III 6 (sirens) not installed by 50.54 q February 1,1982
-}' 82-10 March 1 -
April 4,1982 Perfomed maintenance on valve with T.S. V 1 (3)
- red tag attached 82-10 March 1 - Plant shielding study med.-
April 4, 1982 (truck lock door panel) not NUREG 0737 DEY 6 completed as stated in response to NRR 82-11 Feb. 25 - An unauthorized adjustment was 10 CFR IV 4 Feb. 28, 1982 made to a leaking flange during { 50 App J the conduct of the PCILRi i 82-12 April 5 - l: May 9, 1982 Failure to follow actions re- T.S. IV 1 quired by T.S. with inoperable I reactor vessel water level instnanentation
-)
- ) 82-13 April 12 -
Inadequate design control, for 10 CFR IV i April 16, 1932 interfaces and verification 50 App 8 9 (5) * { 82-16 May 10 - 1 June 13, 1982 Failure to lock or control access T.S. IV 2 to a high radiation area (stuck TIP drive) i i i, i ( )* secondary area involved g t 40
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.t "I Testimony Submitted by l- Stephen J. Sweeney l
President and Chief Executive Officer Boston Edison Ccmpany to the U.S. House of Repr9sentatives Subcommittee on Energy Conservt.tlon and Power of the Committee on Energy and Commerce July 16, 1986 1
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'q,. { P .- INTRODUCTION j Boston Edison Company appreciates the opportunity to address a number of issues involving the Pilgrim Nuclear Power Station which are of a j concern to this committee, the Nuclear Regulatory Commission and to me
, yi
.., 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 ;arly as September 1985. ' As discussed in the following pages, those actions are
. i. l ; meeting with success.
In today's environment, public concern about nuchar 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
-i j environment to gain public conficence in our ability to manage and run
't
! Pilgrim Station. I personally will not be satisfied until we have achieved
. a level of public and regulatory confidence that allows Pilgrim Station to l 1 i place among the best. He have made an internal commitment to measure ourselves against the best, which is a significant change in how we are
-/ approaching our current problems.
As will be evident in reviewing our testimony, we were historically plagued by not looking outside to measure our success and to undertake the intensive self-criticism necessary to assess performance honestly and objectively. That has changed. He are moving in a new direction, one t,ased on rising standards of excellence which are set, not by regulation, but by
, the performance of those plants judged to be among the best.
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It should be noted that the concerns we are addressing today are i different from those for which we were fined in 1982. The issues then were
. safety-related and failure to comply with regulations. Today, the issues are not directly related either to compliance or to safety. They instead i s
- .y 4~ :1 involve a rising standard of performance going far beyond mere compliance
':; )
I 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.
4
; 8efore discussing our current activities, let me offer perspectives
- en three time frames.
~ .,
The first time frame is 1972 to 1979 and Three Mile Island. Our major management 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. Sosten Edison structured its nuclear organization as part of a traditional coerating arm. While many members of the Pilgrim Station organization reccgnized the differences in the technologies, they had linalted success in arguing for the resources necessary to meet a set of standards that already were rising fairly rapidly. This was also a period of poor quality fuel
! ehich resulted in significant internal radiological problems that affected i'
i the plant for years, i Then came Three Mlle Island. From March 1979 until early 1982 the same structure, under one vice president, attempted to deal with the cost-THI demands on operations and engineering, while at the same time Oursuing a construction permit for a second unit at Pilgrim Station. The staff increased dramatically to 200, 300 and then 400 people. It was an j unreasonable workload for the structure and we paid a costly penalty for not rec 0gnizing i t -- 5550,000 in early 1982. y . .
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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
.,.1 and human resources necessary to upgrade equipment and hardware and to
..J
'T install various improvement programs to meet NRC concerns. More than
$300 million went into hardware improvements, the staff grew from 400 to w nearly 600 people and the organization was restructured under a senior vice
~;
_P '_ fj president and two vice presidents. We achieved a significant measure of
. .)
f; success for which we were recognized by the NRC and in the plant's i 1 outstanding operating performance in both 1983 and 1985. i But in managing the equipment improvements and the new management 4 I systems and programs we put in place, we didn't focus enough on what was going on outside the company in the industry and wlthin the NRC. What we j . 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, my In our case, not seeing that put us in a defensive posture. He weren't identifying weaknesses that were inhibiting continued improvement ourselves. We weren't being self-critical, others had to tell us what was
'j wrong. We weren't holding managers accountable enough for the end result of
<1 an action or inaction. He weren't working well enough together.
Those problems were very real, very serious and of great concern to l
. 1 l me and to the Board of Directors. I became particularly concerned about
- 1 management performance, not management systems and programs, but the results
, of those systems and programs as measured by effectiveness. In mid-1985, I i -
asked the Vice President of Nuclear Operations to investigate my concerns. I which he shared, and issue a report. As he progressed through the study. he i i l 2
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and other managers began identifyin3 needs. In September 1985, we increased 1
; the operator staff by a third. In December, we reorganized plant management 1
-d 1 to improve reporting relationships and build in greater accountability.
- j In February 1986, the NRC issued their report. They said the same sq
> b thing: We had attitude problems that were seriously interfering with our l
'^
aallity to get the results we should be seeing given our financial and human
- resource commitments.
3 By March, we had taken a number of other actions, all of which are j detailed in the following pages. He began eliminating those old attitudes i that were not serving us well and began to inject the nuclear organization v
. with the skills and perspectives necessary to achieve a measure of cerformance which would place us among the best. In the same time frame we made further human resource commitments. We increased our emergency
- d
.] '
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, l l 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 l q :cerations section head were brought on board, nearly rounding out a new 16 ' l 3 member plant management team. Of the 16, 11 were new in their positions in , l the past 8 months and 5 were new to the company. He have new perspectives, i We have people with strong nuclear navy backgrounds, people with NRC 1
- Inspection experience and people who grew up professionally not in i I
- conventional fossil-fired power plants, but in nuclear plants. I l
4 i
o - _ J' u x __ _ ?j I l l 4 On May 27, having accepted th'.t management is just as important as I eculpment, we took the unprecedented step of giving the new plant manager i and his new team additional time, whi'e the unit was shut down, to become familiar with the issues, to accelerate the development of new programs and, most importar.tly, to infuse the organization with attitudes and behavior that will make those programs work. These are attitudes that demand self-criticism, demand accountability, demand teamwork and demand results j which go far beyond mere compliance with a set of rules, regulations and 1 technical specifications. Excellence is our goal. But excellence is, after all, an attitude 1 which accepts nothing less. Achieving excellence will not be easy; we know that. We know our problems. He have made the human resource and financial commitment to solve them. He know what has to be done and we are doing it, t
; 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 .l ~
effectively to the concerns which are shared by all of us. l
.1 As a final point, I know that an important question on the minds of
.I
] 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 only 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 judged by industry and the NRC to be among the best. J
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'i The second is the fact that we have adopted the basic principles and criteria for good management that are applied to the nuclear navy. They
- i l are the same principles and criteria that are in evidence at all of the top
,1
. :, rated plants.
b :c, This is a demanding industry with a vital role in the social and
?-
economic health of the country. It operates in a demanding regulatory Y climate as evidenced by this hearing today. For us as a company with a
, [ single unit to succeed in this environment means that we must impose on 2
ij ourselves the highest standards of performance found in the industry. We
;l
,j are doing just that.
1 i The balance of this filed testimony is arranged in the order of the
'I 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. O
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-, Ralph G. Bird jy;y 3, 19g7
, w cr , :e 7 u :e '..: ear i SECo I.tr. 87-111 i
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- Mr. Steven A. Varga, Olrector !
lj Olvisten of Reactor o rojects, I/II , k'; Unitec States Nuclear Regula:ory Commission l Wasning::n, O. C. 20555 l s l License OPR-35 ll' Occket 50-293 l 1
'i
.1 INFORMATION REGARDING PIIGRIM STATION f SAFETY ENHANCEMENT PRCGRAM a
Reference:
NRC Letter, 8recosed Enhancement to the Mark I Containment - j Pilgrim Sta:icn, dated April 30, 1987
.j Dea- Mr. Varga:
3
.! As agreed dur!ng July 1, 1987 discussions between Frank Hiraglia, USNRC, j
': ' ];{ and Jenn Fulten, Botten Ect son Company (SECo), ae are submitting this rescense to your letter to SECo ca:ec Acril 30, 1987. Inclosed for your information is 1
a cetailec :escription of tne Safety Ennancement arcgram (SEP) hardware j{ changes tnat BEcc has voluntarily elected to imolement for Pilgrim Nuclear
, Power Station (PNPS). The description of procecural changes and personnel training will be furnishec uncer sacarate cover. A current imclementatien schecule for the SEP mcdif!ca:icns will also be furnished separately. A conditien is tnat the modtfications scheduled during the current cutage do not require errer governmental accroval. Should this c0ncitten not te me: for any of these voluntary eccifications, with the result tnat the current
~:j imolementation $:nedule must te extenced, tnen 3ECo will be unable to imclemen: the affected eccifications curing tne current cutage.
Additional documentation will be availaole for review cy the NRC Staff at [
. SECo's Braintret offices er tne PNPS site. C0gni: ant SEco persennel wil! te availacle at enose locati:ns for discussien with tne Staff.
11 Current evaluattens of :ne tenefit frem the SE? modifica:icns are cased
#j primarily ucon ex:ensive, altn0 ugh s:111 preliminary, analyses and cualita:ive engineering jacgments. Final quantitative analysis must, in accordance i witn the statec long *erm 9011 of tne SE?, await final 'dentification of l modifications anc :cmoleOcn of the Indivicual Plant Evaluation (IPE).
' SECo understancs :na: the NRC intends to issue later this year a generic letter re:uiring all plants to perform an IPE as part Of the i
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- cture of tne C:mmirs':n i 5 eve e Ac:!:ea: c:':/ 5:atenen:. When :94:
recutremen: !s isiue:. 5E00 et:ects :c :cmcii:e :Pe !?! ano Orome;;y make :na 1 resui:s avaliaole in ac: r:an:e 41:n :ne revie. :r: cess pres:rt:ed oy One DI generic letter. 9 Please feel free :c contact te cc i:4ar: Howard. cf my s:aff at (617) ii 34;-3900 !? ;,cu 9 ave any :ues:!:ns ::n:e it 9; :9e matter 1::'essed in :nts 6l res0Cnse.
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. .I 19 closures j cc: Nuclear Regulatory Ccmmission 3 Cocument Control Oesk
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Washingt:n, D. C. 20555 L l J} Nuclear Regulatory Ccmmission i Degion I ( 631 Park Avenue
' .j 1 King of Prussia, PA 19406 VI Senior NRC Resident Inscector
/i Pilgrim Nuclear Pcwer Station
'd Mr. R. H. Wessman, Project Manager Division of Reactor Projects, I/II
,7 ii Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Ccmmission
- - 7920 Nondol'< Avenue i Bethesda, MD 20814 1
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.-f Ni EXECUTIVE
SUMMARY
OF THE PROGRESS REPORT ON EMERGENCY PREPAREDNESS FOR AN lc)
-1 ACCIDENT AT PILGRIM NUCLEAR POWER STATION s
d I. EXECUTIVE
SUMMARY
e On December 16, 1986, I transmitted to the Governor a 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.
j Nuclear Regulatory Commission has ordered that the Boston
-i Edison Company keep the plant shut until a variety of corrections regarding the management and operation of Pilgrim Station have been made. As of this date, Pilgrim remains
'j closed, although Boston Edison has asked the NRC for
.. permission to restart the facility.
1 In my December, 1986 report, I concluded that
'I Radiological Emergency Response Plans for the Pilgrim j facility were not adequate to protect the public health and safety. I further identified serious problems regarding the a
jj management of the power plant and the engineering safety of
- the reactor. In my view, these three issues -- emergency j planning, plant management, and reactor safety -- were so serious and the weaknesses and deficiencies so severe that I
.i d recommended that the plant should not be allowed to restart 1
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 resources to the effort of developing the best possible emergency response plans. i I
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i MCDA/OEP has instituted a planning process at the state j and local level and revisions are well under way. In 1 addition, a new system has been installed for off-site
' j notification in the event of an accident at Pilgrim Station. .. 'q /
We now have the advantage of a new Nuclear Safety Emergency
' ,' ;] Preparedness Program and a professional staff which for the s
J sf; first time is dedicated to off-site emergency preparedness
' ,i 'q and planning. This new program and staff are the result of
."i the Governor's initiative in the Fiscal Year 1988 budget.
,M The Governor has requested additional funds for the new program as a supplementary appropriation for the current
,. ;];, ,
fiscal year. h 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 24 plans have been fully developed and have been demonstrated to
; be workable and effective through a graded exercise of all
.: plans and facilities.
1 This finding is based on the fact that in every critical area in which I found a deficiency to exist in my December, s', 1986 report substantial work remains to be done before a
- sj determination of adequacy can be made. For example, analysis of a new Evacuation Time Estimate and Traffic Management q The i Study by state and local authorities is still underway.
; ETE is one of the most critical pieces of information in the c]i entire process and the foundation of effective emergency Our preliminary review of the ETE suggests that J planning.
,~I 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
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- inadequate.
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' " Mi I populations remain incomplete, and it may be necessary to undertake an additional survey of people who would need
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,1 9 With regard to plant management, we have seen numerous
'l changes in Boston Edison's personnel and organization.forThe most notab management of Pilgrim Station. Bird as Senior Vice Ja' M the appointment of Mr. Ralph og G~. President, Nuclear, who directly reports to the company's i88'3 Yet despite these changes, I. cannot
# FU chief executive officer.the management problems-have been fully 5' ~EW say at this time thatFor example, we are concerned about.recent.
c t/G resolved. incidents including violation of NRC regulations in the area
'l9A of-plant security, and allegations We 1of are excessive overtime also concerned by Boston
/7 II worked by utility employees.
"L?d Edison's action to refuel Pilgrim Station without having n
"]j responded to my objections and the objections of several
'- state legislators.
- v] ,
The Systematic Assessment of Licensee Performance (SALP) 1 perfomed by the NRC is the most comprehensive studyThe andlast
. 'y -j report on nuclear management at Pilgrim Station.
SALP report was issued on April 8, 1987 and it showed j)
' deterioration in several aspects of nuclear management since the last report. Until a similarly comprehensive analysis of management under the new organization has been conducted and the above concerns resolved, I cannot say that our management
,yrf, concerns have been addressed.
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' With regard to reactor safety issues, we have carefully
, s reviewed Boston Edison's "Safety Enhancement Program" (SEP).
Ju
' t) The SEP has been undertaken since the issuance of a "Draft Generic Letter" from Mr. Robert Bernero of the NRC concerning l' safety at Mark I containment structures such as the Pilgrim containment. We have two major concerns in the area of
.,j reactor safety. .
'Q->
A &, i'W4; First, despite the fact that the NRC letter was prompted
% by a finding that there was a high probability of Mark I #9@
1 containment failure during certain severe accident scenarios,
- ff ;Q the NRC has yet to adopt an official position regarding J$ffl- safety enhancement. Moreover, according to NRC Region I
<4 M
"# 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.
L Our second concern is the uncertainty that continues to exist about at least one No feature of the Boston Edison SEP, i the direct torus vent. concensus has been reached on whether installation of the torus vent creates unreviewed 1 1
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eq N is authorized, how it will d safety issues or if the torus vent _ 3 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 l Station. The Special Joint Legislative Commission to Study l
,4fi Pilgrim Station has issued its report which further In studies addition,
. ..:i ;
and documents many of the same safety concerns. l t; the Federal Emergency Management Agency has issued a i s Self-Initiated Review of plans for response to an accident at !
-'i
Pilgrim Station. Based on several of the issues raised in my report FEMA has changed its interim finding and now agrees l that the off-site plans for an accident at Pilgrim are not j ft adequate, FEMA has transmir.ted their new finding to the Nuclear 9 Regulatory Commission. However, the NRC has yet to indicate , I d whether or not development of adequate off-site plans will be a condition to the restart of Pilgrim. We are not satisfied 1 i 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 s m, 4 important as nuclear management and reactor safety in
~ ,' protecting the public f rom an accidental release of radiation.
Therefore, for these reasons -- the absence of adequate l l 7 . emergency response plans, lack of demonstrable assurance that l management problems have been solved, and uncertainty about containment structure -- I continue
- the safety of the Mark I l to find that Boston Edison has not met the heavy burden of showing readiness to restart the Pilgrim Nuclear Power H Plant. I also continue to believe that it remains to be seen vf , if adequate emergency response plans can be developed and if
~
all other safety issues can be resolved to our satisfaction.
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- 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 j
the NRC before any decision is made regarding the restart f Pilgrim Station. i, 1 i October 14, 1987 CHARLES V. BARRY SECRETARY OF PUBLIC SAFETY l 7 l 4
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.' - '*: 6 THE COMMONWEALTH OF MASSACHUSETTS
{s EXECUTIVE DEPARTMENT ,h q CIY11. DEFENSE AGENCY AND OFFICE OF EMEROENCY PREPAREONE53 400 WORCESTER ROAD -
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, FRAMLNG HAM, MASS. 017014317
#, MICHAEL S. DUKAKis ROBERT J. BoULAY
.j 00VERWO9 .
DIRECTOR l
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September 18, 1987
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s 'd Mr. Ralph Bird
d ' Senior Vice President d Boston Edison Company 9 800 Boylston Street
, y Boston, Massachusetts
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 resoects and I
that additional work is required to provide information to local officials which is sufficient to support development of implementable shelter utilization plans. I have attached a copy of a memorandum prepared by my staff which details our l specific concerns regarding this study. If you have any questions or observations regarding our j evaluation, please contact Buzz Hausner of y e staff. Thank you for your cooperation in this matter. -
] ,
Sinc 2, -
- obert ulay Q
q Director i 4 cc: Assistant Secretary, Peter W. Agens, Jr. Deputy Director, John L. Lovering
~i Mr. Buzz Hausner a
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, THE COMMONWEALTH OF MASSACHUSETTS EXECUTIVE DEPARTMENT AtM844
.h k CfY1L DEFINst A0tNCY AND OFFICE OF tWEROLHCY PREPAREONES$ l l f ,,Q,)
3, an wometsrtR RoAo / i P.O Box 1806 % F RAutNoHA W. W ASS. 01 F010317 c.;HAEL s. oVKAKis ROBERT J. BOULAY OOVERNOM OtRfCTOR
. TO: DIRECTOR BOULAY ;
,FROM: BUZ USNER
. $) 'IN RE: SHELTER SURVEY OF PILGRIM EPZ PREPARED BY BOSTON EDISON _ -i COMPANY DATE: SEPTEMBER 11, 1987 e
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, _L_______________,________________________________________________
We have made a preliminary review of the shelter survey of the Pilgrim EPZ which was prepared by the Boston Edison Company and its consultants. While this document compiles some very useful data, we feel that n)re 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 i hands of local officials.which are sufficient for the development j of shelter uti'lization plans for all areas of all five M communities within the Pilgrim EPZ. With this in mind, we have l tha following comments. ,
- t The survey only covers an area approximately one mile 1 wide along the coast. The shelter capabilities of the 1
entire EPZ must be surveyed and reported. I _ The survey does not separate out those structures which could "most reasonably" be used as shelters from those
, where shelter is less appropriate.
4
.0 For instance it would help to have a separate list or public buildings and facilities for each town,
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, including an estimation of the actual useable shelter i space and protective factors for shelter under j government authority. {
1 Many of the shelters listed, such as jewelry stores and l pharmacies are. clearly not suitable for public i 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.
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Regarding protection of the beach oooulation, the survey identifies shelters within.a mile of the coast but does not indicate the distances thet beach goers would have to travel.to find shelter. In addition, the survey must demonstrate that adequate proximate shelter y is available for the total population at~ the individual
-.i !
beaches. -
.t 7i For instance, Duxbury beach is about seven miles long
.- 1 and the survey should indicate the distance peonle at 4
. 4 Saquish Head are required to travel to reach adequate 4 shelter. Further, an implementable shelter utilization i plan must demonstrate that the nearest shelter would i ' '
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
., survey are no more than crawl spaces 4 Crawl spaces
!! cannot be considered for public shelter. Further, in j , most buildings, a good deal of floor area will be
't occupied by machinery, counters, office furniture, et 1 cetera. .The survey must identify accurately the actual j useable shelter space available in each structure.
) -
Stone and Webster uses'a FEMA nuclear attack value of I q ten square feet per person to estimate the potential
; population.which can be sheltered. Local' Civil Defense e
, Officials may wish to allocate more space -- uo to
] twenty square feet per person -- in their utilization i plans. The value used in the survey overestimates the Q potential capacity of various buildings. We doubt.that 1~ 17,000 people can be sheltered at Duxbury High School, or that 89,700 can be sheltered at the 5 Cordage Park
, Buildings.
9 The survey must demonstrate that public shelters are { free from asbestos and other environmental hazards. The report estimates residential "sheltering capability" in individual communities as between 53% and 81%. These figures indicate that a significant l 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.
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]; Further, even if it can be established that the vast majority of residences offer adeouate shelter, local
.i officials must be prepared to offer public shelter of a
- 7 known protective capability to residents who demand i assistance. .
, 1
'-3 - This report makes no definitive statement of what
' , ,j - constitutes adequate shelter to protect people from the 3 effects of a radioloolcal release from Pilorim
~ A -j Station. This is necessary to determine what d facilities are most appropriate for a 1 peal shelter
'1 utilization plan and to determine the public shelter fj , needs of each communitiy.
In summary, we wTuld say that this survey is a useful beginning I but that much more work is required before we can assess our I ability to develop implementable shelter utilization plans consistent with the public safety concerns in Secretary Barry's q report to the Governor. ! 1 l t 1 I
. -d cc: Assistant Secretary Peter W. Agnes, Jr. -
{, Deputy Director John L. Lovering .
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.' 800 Boylston street Boston, Massachusetts 02199 Ralph G. Bird September 17BECo 146 Ltr. #8i 1987 d, senior Vice President - Nuclear d -p
- i. ,
U.S. Nuclear Regulatory Commission
.] Document Control Desk Hashington, D.C. 20555
, .j Docket 50-293 License No. OPR-35
Subject:
Boston Edison Company Request for Exemption from 10 CFR Part 50, J Appendix E, Section IV.F. r
Dear Sir:
J In accordance with 10 CFR section 50.12(a), Boston Edis the requirements of 10 CFR Part 50, Appendix E, Section IV.F., that would 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 quarter of 1988.affected by this one-time exemption, but rather will continue to provi such exercises will be conducted every second year (LL., the following biennial exercise will be held in 1989).
-i The proposed deferral of the full participation exercise has been discussed d '
with the Commonwealth of Massachusetts (Commonwealth) and 1. c
'd response officials.
N;1 proposal. J: .. . C; The request will not affect the onsite exercise at Pilgrim planned for
, ,; j December 9, 1987.
' The requested exemption is necessary because the Commonwealth, the local governments within the ten-mile plume exposure pathway emergency plannin (EPZ) and the two emergency reception center communities are at present y
engaged in implementing numerous improvements in their offsite These emergency j preparedness programs, with the assistance of Boston Edison. improvements include revision of the emergency plans of the local governmen revision of the Hassachusetts Civil Defense Agency (HCDA) Area II plan as well f as the Commonwealth's state-wide plan, the development of revised related l' 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 throug the remainder of the year and early 1988. 1 L- _ ._ __ - ~ - - - ~ _ _ _ _ , . _ ,
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m.uwx.-.m ~ - a. n w.- . , . .- .u .x - a. w u. - ~ . . l N U.S. Nuclear Regulatory Commission l 1 Page 2 1 3 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 i circumstances, conduct of the full participation exercise will be much more effective after the ongoing improvements have been implemented. In granting 1 one-time exemptions autnorizing deferral of exercises for 1.icensed 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 U local governments and that it is appropriate to defer an exercise until program revisions or facility improvements have been completed.
a 1 Since the last full participation biennial exercise at Pilgrim, Boston Edison d has held an onsite exercise at Pilgrim in December 1986; has held ' l
- quarterly onsite drills in March, June and August of 1987; and has scheduled 1 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 March and i June 1987 drills included limited participation by several of the towns. The towns within the EPZ have also cooperated in the full scale stren test reviewed by FEMA, which was conducted on September 29, 1986. In addition to its activities involving Pilgrim, the Commonwealth has also participated in i
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. i This request meets a number of the special circumstances listed in Section 1 50.12(a)(2) . I l First, granting the request will provide only temporary relief from the l applicable regulation and the licensee has made good faith efforts to comply 4 with the regulation. Over the past year, Boston Edison has assisted
.i Commonwealth and local authorities in a variety of ways to accomplish as many improvements as possible in their offsite emergency response programs. For I example, Boston Edison has developed substantive information for the i enhancement of those programs. The major products of this effort include the "Pilgrim Station Evacuation Time Estimates and Traffic Management Plan Update" (August 18, 1987) prepared by KLD Associates, Inc. and "A Study to Idantify 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 emergency program enhancement efforts in accordance with the 3
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 l l
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professional planner to assist each reception center community; and four i professional planners working under the direction of MCDA in the upgrading of the MCOA Area II and Commonwealth program. In the first half of 1987, Boston
'i Edison provided introductory emergency training to about 350 personnel within the five towns in the EPZ and enhanced introductory training modules are
.l currently being prepared for review by the HCDA prior to further implementation. The planners provided by Boston Edison have also begun to
?j prepare task-based modules for training of specific categories of emergency 1 personnel and will be available to participate in the training programs. In
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'i addition, Boston Edison is executing agreements with each of the five towns I within the EPZ, as well as the two reception center communities, for
'I assistance in the renovation of their EOC's. Moreover, four of the five EPZ a towns and both reception center communities, to date, have accepted BECo's offer of funding support for full-time civil defense staff positions.
]
Second, literal compliance with the regulation would not serve its 2 underlying purpose and would result in undue hardship to Commonwealth and 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 1 orderly implementation of improvements in such manner. 2 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. J. The NRC has acknowledged that flexibility is appropriate in applying emergency i planning requirements. This flexible approach is especially appropriate in 7 this case, where granting the request will facilitate more prompt and l ef fective implementation of improvements. l for all these reasons, Boston Edison asks that NRC grant the requested
.) exemption. In accordance with 10 CFR {170.12(c), a fee of one hundred and d fifty dollars ($150.00) will be electronically mailed to your offices. If you l should require any additional information in connection with this request, please contact either myself or Mr. Ron Varley of my staff (telephone: 617 -
,9 424-3832).
<J-j -
RAL/dlw Ralph G. Bird 4 9 e
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6
q lg . . l l U. S. Nuclear Regulatory Commission ! Page 4 cc: Dr. Thomas E. Hurley, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission The Phillips Building . Hashington, D.C. 20555 l Mr. R.H. Hessman, Project Manager Division of Reactor Projects - I/II l Office of Nuclear Reactor Regulation l U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, MD 20814 Mr. Richard Krimm, Assistant Associate Director FEHA 500 C Street - Federal Plaza Hashington, D.C. 20472 Hr. Edward Thomas ' FEMA - Region 1 J. H. McCormack Post Office and Court House Boston, MA 02109 Hr. Peter Agnes, Jr. Commonwealth of MA Assistant Secretary of Public Safety 1 Ashburton Place - Room 2133 Boston, MA 02108 U. S. Nuclear Regulatory Commission 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
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