ML20207B598

Petition to Show Cause Why Facility Should Not Remain Closed,Due to Problems W/Mgt of Plant Operations, Radiological Emergency Response Plan & Physical Structure of Facility

ML20207B598
Person / Time
Site:	Pilgrim
Issue date:	07/15/1986
From:	Golden W, Hildt B, Hynes F MASSACHUSETTS, COMMONWEALTH OF
To:	NRC COMMISSION (OCM)
References
CON-#386-989 2.206, NUDOCS 8607180125
Download: ML20207B598 (82)

Text

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r-TABLE OF CONTENTS JURISDICTION AND-INTRODUCTION Jurisdiction 1 Description of the Petititioners 2 Intrduction 3 STATEMENT OF THE FACTS I. MANAGEMENT

1. Licensee's Management of Pilgrim is Deficient 5

2. Licensee has Failed to Correct Management Deficiencies 7

3. Deficiencies in the Area of Plant Operations 8

4. Deficiencies in the Area of Radiological Controls 9

5. Deficiencies in the Area of on-site Preparedness 14

6. Deficiencies in the Area of Maintenance and Modifications 15

7. Deficiencies in the Area of Surveillance 16

8. Deficiencies in the Area of Security and Safeguards 19

9. Deficiencies in the Area of Refueling and Outage Management 20

10. Deficien:les in the Area of Liciensing Activities 21

11. Deficiencies in the Area of Fire Protection 21

12. Deficiencies in Licensee Management Manifest in All its Endeavors 23

13. Statement of Law as it Applies to Standards of Management 23 II. EMERGENCY RESPONSE PLAN

14. Deficiencies in the Radiological Emergency Response Plan 25

15. Deficiencies in Advance Information 26

16. Deficiencies in Notification During an Accident 27

17. Deficiencies in Evacuation Plans 27

18. Deficiencies in Medical Facilities 28

19. The Emergency Planning Zone is Too Small 29

20. Lack of Coordination and Prioritization of the RERP 30 III. CONTAINMENT STRUCTURE

21. Inherent Design Flavs of Pilgrim's Containment Structure 32 APPENDIXES Appendix A: Table 5, Enforcement Data (SALP report 850-293/85-99) A-1 Appendix B: Table 7, Plant Shutdowns (SALP report 550-293/85-99) B-1 Appendix C: Pilgrim Station Regulatory Performance History C-1

r UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION PETITION FOR SHOW CAUSE CONCERNING PILGRIM I NUCLEAR POWER STATION JURISDICTION AND INTRODUCTION Jurisdiction This petition is filed pursuant to 10 CFR F2.206 and 10 CFR F2.202. The action requested is that an order be issued to the Boston Edison Company to show cause as to _

why the Pilgrim I Nuclear Power Station Station (" Pilgrim") should not remain closed and or have its operating license suspended by NRC unless and until that time at which thelicenseedemonstratesconclusivelytotheNR5andthepublic: (1) that its management is no longer hampered by the deficiencies noted by the petitioners herein; (2) that the Radiological Emergency Response Plan fully complies with 10 CFR 750.47 and 10 CFR 750.57, is given high organi ational priority and sufficient funding by the licensee, the Federal Emergency Management Agency (FEMA), the Massachusetts civil Defense Agency (MCDA) and local gover.nments; and (3) that the inherent design flaws noted by petitioners herein which render Pilgrim I's containment structure extremely l

vulnerable in most accident scenarios have been overcome to the extent that the public health and safety will be assured.

Ths material which follows demonstrates that there is not reasonable assurance that Pilgrim I can be safely operated due to numerous deficiencies in licen;ee management, the inadequacy of the existing Radiological Emergency Response Plan (RERP),

and inherent deficiencies in the Facility's containment structure. Tha deficiencies discussed in detail below cut a broad swath across the spectrum of safety requirements . It might be argued that one or more of the deficiencies taken individually does not pose an intolerable risk. In the aggregate, however, they l

thoroughly comptorise the reliability of the most important safety systems in the plant and destroy the fundamental principle of defense-in-depth espoused by the NRC.

Both the PilgElm I licensee, Boston Edison company, and the NRC staff have failed to resolve these safety issues which have arisen repeatedly throughout the plant's history.

This petition is filed with the Director of Nuclear Reactor Regulation as the licensee is currently shut down. Therefore, it is vital that the Director address and resolve these safety issues before the licensee is granted a firm date for resumption of operations.

In the face of the information presented herein, failure to institute proceedings pursuant to 10 CFR F2.202 by the Director would violate its statutory mandate to ensure the public health and safety.

Descriotion of the Petitioners William B. Golden is a Massachusetts State Senator repr,esenting Cohasset, Weymouth, Duxbury, Hingham, Hull, Marshfield, and Scituate. Frank M. Hynes is a MassachusettsSt4tef(efvoenhT0cepresentingScituateandMarshfield. Barbara A. Hildt is a Massachusetts StateQi p %:MW representing Amesbury, Newburyport and Salisbury. These legislators have expressed their concern for their constituents within and around the Plymouth Emergency Planning Zone by involving themselves in the issues surrounding nuclear power in the Commonwealth and particularly in their assistance in producinng this petition.

The Massachusetts Public Interest Research Group (MASSPIRG) is a non-profit i

., citizens group concerned with safe energy, environmental issues and consumer protection. MASSPIRG has over 96,000 citizen members and over 75,000 student members throughout Massachusetts. Approximately 2,000' citizen members live in the plume i

exposure Emergency Planning Zone for Pilgrim and approximately 7,000 live on Cape Cod for at least part of the year. Because of its concern for the safety and health of the public and the environment, MASSPIRG has long been involved in the issues of nuclear power, especially with regards to the Plymouth nuclear facility. In 1977, MASSPIRG

published a ctudy of emarstney escponsa plans in Masacchu Itts cntitled 5 Nuclear Evacuation Planning: Blueprint for Chaos" and in 1983 followed it with an updated study

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entitled " Blueprint for Chaos II: Pilgrim Disaster Plans Still a Disaster." Since then, MASSPIRG has represented the public interest in public hearings and debates on the issues of nuclear power.

The Plymouth County Nuclear Information Committee, Inc. (PCNIC) is a non-profit Massachusetts corporation with a principle place of business at 50 Congress St, Boston, MA 02109, care of William S. Abbott, Esq. PCNIC is composed of approximately 300 members who reside in and around Plymouth County. PCNIC was incorporated in 1974 for the purpose of educating the public with regards to the hazards, risks and operating characteristics of various applications of nuclear energy, to participate in licensing hearinEs and other administrative and legal proceedings involving the use of nuclear energy, and to encourage parties licensed by the Nuclear Regulatory Commission to fulfill their obligations to the public. From 1974 to the present, PCNIC has participated in nu=erous regulatory and licensing pecceedings regarding the Pilgrim I station, and the Pilgrim II station (subsequently cancelled by Boston Edison).

The Plymouth Alliance is a citizens' organization based in Plycouth, Massachusetts. Motivated 'by a concern for the health and welf are of tha community, its goal is the establishment of safe energy alternatives. In order to achieve this, the Alliance strives to promote public awareness throuEh education and democratic action.

Jo Ann Shotwell and James M. Shannon are both candidates for Massachusetts State Attorney General.

The remaining signatories of this petition are public efficials, organizations and citizens of the Commonwealth who are concerned with the issue of continuing operation p

of the Pilgrim nuclear facility by the licensee and who endorse the relief requested by the retitioners herein.

Intrcduction The three main issues raised herein have to do with Boston Ediscn's management of l

plant operations, the Radiological Ecergency Response Plan (RERP), and the Pilgrim facility's physical structure.

f Part I (sections 1 through 13) of the statement of the Facts refers to manifsstations of tha licensen's deficient plant manrgsment. Tha manrgtment-relatsd technical and organizational problems listed therein by plant functional area are already known to the NRC, since they are largely culled from NRC inspection reports.

As such, they are not presented as specific violations whose past or ongoing presence at Pilgrim in themselves should warrant a plant shutdown; indeed, some are being dealt with by the licensee under close NRC scrutiny. Rather, they are symptomatic of the long history of Boston Edison's incompetence as the manager of a nuclear facility. The most recent SALP report and the April 2, 1986 special inspection report demonstrate NRC's grave concern with the overall quality of Boston Edison's management. As the reports indicate, every year's round of NRC inspections, each of which covers only a fraction of the facility's mechanical and organizational functions, uncover a plethora of new management-related problems. The reports note that many of the specific problems are not resolved by the licensee in a timely fashion or, in some cases, not at all. Recurring problems in such areas as staffing, self-identification of problems, management oversight of operations and attitudes toward problems, equipment maintenance, radiological controls, and surveillance testing, despite repeated promises by the licensee to resolve them, indicate a history of mismanagement and an

, incapability by Boston Edison to maintain the standards of safety that are required of a nuclear operator. Thus, its continuing operation of the Pilgrim plant poses an

extremely serious and unacceptable health and safety threat to the citizens of the Commonwealth.

Part II (sections 14 through 20) detail the failure of FEMA, MCDA and Boston Edison, to develop a Radiological Emergency Response Plan (RERP) that can be given ,

final approval by the NRC. By law, this in itself should be enough to warrant the suspension of a nuclear facility's operating license. However, given Pilgrim's management deficiencies and their threat to safe plant operations, this lack of an acceptable emergency plan should be of even greater concern to the region's public officials and citizenry. The fact that the NRC has granted interim approval of

.1,lgr10's RERP do3s not provide any reassurance to the public's safety and health.

Rather, the failure of the RERP to gain finni approval by the NRC after many years of plant operation only underscores its unacceptability.

Part III (section 21) deals with the basic deficiencies of the Pilgrim facility's GE Mark I containment structure, which has a very high probability of failure early in the course of severe accident scenarios. This probability of failure is highly significant in light of the facility's managerial problems and the inadequacy of the RERP.

STATEMENT OF THE FACTS I. MANAGEMENT 1). Licensee's Manacement of P11crim is Deficient.

NRC contends that competent management is critical to ensure the safe operation of any nuclear power facility:

No level of technical safeguards can make a nuclear facility safe unless it has good management (statement of NRC Commissioners at hearing before U.S. House Subcommittee or Snergy Conservation and Power, Boston Globe, May 23, 1986)....

The common denominator at inferior plants is poor management (ibid.)....

Management is the single most important factor in assuring safe plant operations.... There seems to be a history and pattern of poor management and leadership at this site (James Asselstine, telephone interview with the Boston Globe, ibid.).

Management has been weak at the plant for some time and this has had a negative influence on safety (James Asselstine, interview, Boston Globe, May 28, 1986).

The NRC commissioners, who had just ordered the Pilgrim facility to remain shut down temporarily because of safety problems (Boston Globe, May 21, 1986), characterized it as one of the worst run and least safe plants in the nation at the above Subcommittee hearing (Eoston Globe, May 28, 1936).

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r Boston Edison (BECo) has failed to correct managerial deficiencies found as fa'r back as 1982, despite NRC's crder to do so through a corprehansive mantgIment improvement program. In that year NRC fined Bsco a record $550,000 for two safety violations and a material false statement made by management about allegedly resolving one of the violations. NRC concluded that " insufficient review is being given by BECo management to the operation of the Pilgrim facility (NRC 50-293/ EA 81-63, cover letter from Richard C. DeYoung, Director, Office of Inspection and Enforcement). The 1982 events, as described by Mr. DeYoung, reveal substantial serious breakdowns in Boston Edison Company's management controls related to the Pilgrim facility. Continued operation of the Pilgrim facility requires significant changes in Boston Edison Company's control of licensed activities. Accordingly, I have determined that the actions set forth below are required by the public health, safety, and interest, and therefore, should be imposed by an immediately effective order (NRC 50-293/EA 81-63, Order Modifying License Ef fective Immediately,Section IV, p. 6) .

The Order Modifying License Effective Immediately specifically demanded:

-a full evaluation by an independent organization of BEco's .

organizational responsibilities, management controls, staffing levels and competence, training and retraining programs, communications, and operating practices, with recommendations for improvement;

-a program for assuring that information supplied by BECo to NRC on items "important to safety" is " complete and accurate."

-an evaluation'and improvement of the program for plant modifications and design changes to ensure " compliance with the provisions of 10 CFR

1. 50.59;"

-an evaluation and modification of " safety-related procedures and the method used in the development and approval of these procedures" and assurance that plant modifications will be included in written procedures and drawings;

-an evaluation and modification of the program for training and retraining personnel involved in safety-related activities;

-an evaluation and modification of the program for assuring " responsible corporate management oversight" of safety-related activities;

-development of a system of audits by management representatives to assure conformance to procedures and continued adherence to changes dictated by any of the reviews listed above (ibid.,Section V, pp. 7-9).

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2), ticensee han Failed to correct Manaaement Deficiencien The recent, ongoing history of managerial deficiencies at the Pilgrim plant clearly demonstrates that the management improvement measures demanded by the order described in section (2) of this petition were never effectively implemented. Special inspection report 50-293/86-06, released April 2, 1986, echoes a theme of managerial weaknesses recurrent since 1982. In this report, NRC found four principle factors that are inhibiting progress in these programs and in identifying and correcting other weaknesses. These are (1) incomplete 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 (Inspection Report 50-293/86-06, cover letter from Richard Starostecki, Director, Division of Reactor Projects).

The conclusions highlighted in the most recent SALP report (report no. 50-293/85-99), issued February 18, 1986, similarly refer to the same general managerial problems that NRC identified and demanded that Boston Edison resolve in 1982. They also

stressed the safety implications of those problems

l One of the significant outcomes noted during the SALP Board deliberations was the recurrent issue of staffing. In the areas of operations, security, maintenance and radiological controls, the adequacy of staffing supervisory, professional and crafts positions was noted to be weak. In a similar vein, the oversight of BECo supervisors i of work in progress by either BECo staff or supervisors was noted to be insuffleient. Whether this is due to a lack of supervisors or a lack of policy to foster such work by supervisors is not clear. However, review of the enforceme..t history (Table 5) clearly highlights a number of recurring problems attributable to either poor procedural adherence,

poor administrative practices or failure on the part of managers and supervisors to ensure proper planning, scheduling and performance of i required tests or maintvance. Similarly, a review of plant shutdowns (Table 7) shows that some of the four automatic scrams and five plant shutdowns can be attributed to similar causes.

Another observation relates to the lack of critical self-

! assessment. During the assessment period, significant NRC interaction was required to identify problems and subsequently to get appropriate ccrrective action. In some cases, corrective actions tended to be

superficial in that they addressed only the symptoms but not the underlying reason for the problea. A coIplicating factor in this regard is the manrg; ment attitude tcward perceivad werknis202; a daf:nsiva posture is frequently taken with respect to NRC as well as licensee self-identified weaknesses. This defensive posture inhibits a thorough and critical evaluation with subsequent delays in resolving the problem (s).

Consequently, problems tend to linger for long periods until drastic measures are taken.... Another lingering problem is the adequacy of licensed operator staffing (SALP Report 50-293/85-99, pp. 6-7).

3.) Deficiencies in the Area of Plant Onerations The SALP reports covering 1981, 1982 and 1985 give Boston Edison the lowest possible rating in the area of plant operations. In 1985, despite four years of NRC concerns, SALP Report 50-293/85-99 concludes that Pilgrim continues to have serious problems in plant operations, specifically with regards to staffing, operator performance, and response to quality assurance (QA) findings:

A chronic shortage of licensed reactor operators grew worse during the -

assessment period due to promotions, job transfers, and the death cf one individual. At the end of the assessment period, only nine reactor operators and one senior operator (functioning as a reactor operator) were staffing five operating shifts. To compensate for the shortage, operators routinely exceeded the overtime guidelines in Generic Letter 82-12. Senior licensee management did not become aware of the full extent of operator overtime until after one individual's time card indicated that he worked 97 hours0.00112 days <br />0.0269 hours <br />1.603836e-4 weeks <br />3.69085e-5 months <br /> in a seven day period. A continuing weakness in the overtime approval process caused operators to repeatedly (thirty-five instances) exceed overtime guidelines without station management's prior knowledge or approval.... NRC action in this area demonstrates inadequate long range planning and staffing, weaknesses in policy implemeritation, and lack of ef fective corrective action for a recurring problem.

The lack of a sufficient number of licensed operators has been a j repeated NRC concern over the past four years.... Despite these concerns, senior licensee management did not act to ensure that an adequate number of individuals with appropriate backgrounds / capabilities entered the reactor operator training program pipeline.... Licensee management actions on personnel related issues as well as the failure to anticipate the shortage in licensed reactor operators indicates inadequate management sensitivity to the effect of personnel decisions on plant operations (SALP Report 50-293/85-99, pp. 9-10).

According to the same SALP report, this long-term operator staffing problem has i

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=b led to serious ltpses in operator performance and attention in instInces which involv:d the use of nuclear instrumentation during refueling operations (bypassing one SRM and not continuously monitoring another SRM), the j assessqqnt of drifting reactor protection system instrumentation (main t

steam line radiation monitors), and an inadvertent reactor scram from i l low power due to inadequate reactor water level control. Additional  !

operator attention could have prevented the loss of secondary i containment integrity while the plant was at power. Circumstantial I evidence indicates that increased operator attention might have prevented refueling equipment from being damaged during fuel movement at the end of the assessment period (ibid., p. 11).

Another aspect of the plant operations area which was of particular concern to NRC was licensee response to QA findings. The SALP report determined that i licensee management was sometimes slow in responding to QA surveillance and audit findings. This lack of responsiveness indicates that management is not taking full advantage of the quality assurance J program. Senior licensee management has not ensured that management support for the QA process is evident and that plant personnel have the appropriate attitudes and resources to effectively respond to QA findings (ibid., p. 11).

The NRC concluded that safety would be eroded without significant attention to the managerial problems in the area of plant operations: l i the board believes that these problems are significant and that future plant performance and safety may be degraded without senior management action to strengthen this functional area (id.).

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4). Deficiencie? In the Aiea of Radioloalcal controls 4 In the area of radiological controls, BEco has had a history of extremely poor management performance and high worker exposure levels since the early 1980's. The company has proven itself unable to address these problems without constant NRC identification, oversight and direction. Despite demands for a specific improvement program, NRC is still finding fundamental weaknesses in management oversight in its implementation. The latest SALP report still assigns the lowest possible rating to this functional area.

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operations et the Pilgrio facility have been characterited by unplanned radiation ralensis End occupational exposures that tra tmong tha highest in tha naticn. SALP report 50-293/85-99 places those levels at 4,082 person-rems in 1984. NRC reports, occupational Radiation Exposure at Commercial Nuclear Power Reactors, NUREG-0713 and NUREG-0714, list the Pilgrim plant among all commercial plants nationwide as having the highest number of man-rems per reactor in the period 1975-197.9 and the highest collective dose per reactor in the period 1980-1984. Although the licensee has made efforts to clean up contaminated areas, " recontamination of the clean areas is an ongoing problem" (SALP report 50-293/85-99 p.16).

In reference to ongoing problems with unplanned radiological releases, the SALP report concludes that The licensee continued to experience problems in the area of self identification of problems and initiation of prompt, comprehensive corrective actions to resolve identified probleum and prevent recurrence.... Examples are:

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-In December 1984, a contractor employee made an unauthorized entry to a tank to perform sludge lancing.

The licensee's oversight of this high radiation area work was less than adequate in that: established high radiation area controls were not implemented, appropriate additional procedures were not established, nor was supervisory oversight of this activity effective....

-A second ' example involved the licensee's oversight of spent fuel pool work. NRC review...found that:

unapproved contractor procedures were being used for the activity; discrepancies existed between unapproved contractor and licensee approved procedures for the work; and personnel were not trained or qualified in all appropriate procedures. Similar problems were identified during licensee and NRC review of two unplanned personnel exposures sustained by contractors during control rod drive work last assessment period. The licensee's corrective actions for fuel pool work were " job specific" and not comprehensive. As a result, additional NRC effort was needed to obtain an acceptable resolution of problems associated with this work. i

-A third example involved failure to correct high radiation area surveillance deficiencies. The problem involved failure to clearly specify the Technical Specification required high radiation area surveillance l

frequincy on ridiction work peraits. This probles was brought to the licensee's ettention on a number of CCCIslons....

Due to the number and nature of problems identified in the radiological control's' area last assessment period (twelve violations and two deviations in radiation protection, three violations in radioactive waste transportation, SEP report 50-293/84-34) an Order Modifying License was issued. This Order required that a comprehensive review of the radiological controls program be perforded by the licensee and that the findings of this review be addressed by a Radiological Improvement Program (RIP) (ibid., pp.14-15) .

Despite the implementation of the RIP, NRC has found that implementation and effectiveness are not closely monitored.... Problems were noted with the RIP failure to address high radiation area access key controls and some failures to generate acceptable procedures to meet RIP commitments....The licensee has considerable work yet to do in the ,

area of EARA Program establishment; procedures; management oversight; I and corrective action system (ibid., p. 15).

Findings of radiological occurrence reports (ROR) were not always _

handled in a timely, comprehensive manner. Corrective actions for ROR findings were sometimes late and superficial. These problems were l apparent in the areas of radiation protection procedure adherence and high radiation area key control....The lack of timely corrective action indicates that mid-level management is either not prioritizing work effectively or does not have sufficient resources to respond to problems (ibid., p.16).

Other NRC inspection reports list problems during the RIP implementation. One example is a routine radiological safety inspection carried out during the SEP evaluation period (from May 20 to May 24, 1985) which uncovered a violation of procedures for fuel pool work:

We are concerned about the violation because it is similar to violations previously identified; and because it had existed for an extended period of time (about a month) prior to being identified by the NRC (Inspection Report 50-293/ES-13, cover letter from Thomas Martin, Director, Division of Radiation Safety and Safeguards).

In sunnarizing the information in the Radiological Control functional area, the l SEP report covering this period states that the licensee continues to experience problems in the area of oversight of radiological work and self identification and resolution of problems to prevent their recurrence....These problems indicate that weaknesses l l

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were still present in the radiation protection progran. Wenknesses in the identifiestion and correction of problems indic:tes that upper manag; ment initictivts in this cras are not fully undarcteod by cid-level managers or that human resources may not be sufficient (SALP ,

report 50-293/85-99, p. 18).

Beside noting that staffing problems still persisted in this functional area, the April 2, 1986 Special Inspection report identifies additional organizational deficiencies:

some problems continue to exist between certain Watch Engineers and radiological controls technicians. The communications problems have

resulted in some violation of radiological controls procedures, friction between the groups (e.g., maintenance, operations, and instrumentation and controls), and morale problems. Recent examples include poor communications during a recent Gai-Tronics problem, and poor 4

communication during an entry into the A0G building to drain filters.

These problems appear to continue in part due to the failure to bring identified deficiencies in this area to the attention of appropriate management for resolution (Inspection Report No. 50-293/80-06, p. 21).

The licensee has not established and implemented an effective

, radiological controls technician retraining program. This is indicative 2

of inadequate planning considering the number of new procedures which are being established and implemented to meet Radiological Improvement -

Program (RIP) commitments. Also, the program does not ensure appropriate retraining of personnel being rotated through various jobs (id.).

i ALARA group personnel do not receive outage planning schedules, are unaware of the work planning process, and in most instances are unaware of work to be performed more than a day in advance of the work.

The lack of adequate review time could compromise the adequacy and effectiveness of ALARA controls.....

Regarding in-field ALARA controls, observations of radiation protection

, technicians covering jobs found non-uniform implementation of ALARA I

controls during work. This is of concern because in some cases, the I technicians provide the only ALARA oversight for the job ( e.g. "A" priority RWPs ) . . . .

An example of poor ALARA planning was the repeated repairs to the clean radwaste pump (Section 5.7) . Here, unnecessary repeated repairs were made in areas with radiation levels of 140 mr/hr (ibid., p. 22).

In discussing radiological occurrence reports (ROR), the April 2, 1986 report

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the progran was found to be less than adequate in that specific problems tssociated with rtdiological incidents were not clearly stated and identified problems were not brought to the attention of tha appropriate level of station management for their review and resolution (e.g.

January 1986 contaminated Watch Engineer ROR) (ibid., p. 22).

The licensee has identified significant problene in the area of use of

. HP personnel resources to support RWPs which are not used.... The licensee has not clearly identified the cause of this problem and initiated timely, lasting corrective action to address it. At one point up to 75% of daily RUPs were not being used. On a yearly basis, the licensee estlaated that unused RWPs could cause up to 26 person-ress of needless radiation exposure to personnel performing radiation surveys (ibid., p. 23).

In the area of Chemistry / Radiochemistry and Effluent Monitoring and Controls, radiological safety inspections have uncovered a number of problems during the RIP I

implementation period. The May, 1985 routine radiological safety inspection reported one deviation:

This deviation involved failure to evaluate certain nonradioactive systems and establish appropriate sampling and analysis programs for these systems in order to identify radioactive contamination in a timely manner to preclude any unmonitored, undetected radioactive effluent i

releases (ibid.).

Another radiological safety inspection conducted August 19-23, 1985 uncovered three unplanned releases. The first involved an " apparent unmonitored release path from the ' Hot' Machine Shop" that "may have existed for some period of time" (Inspection report 50-293/85-22, p.7). The second involved a backed-up drain in the j " Hot" Machine Shop:

j The licensee's investigation indicated that liquid in the drain may be directed to the Main Sewage Pumping Station. Since the effluent from

, this pumping station is directed to an onsite leaching field and the pumping station effluent is periodically pumped out and sent to the Plymouth Sewage Disposal facility, the Main Pumping Station potentially represented an unmonitored effluent release path.... It was determined that the licensee had failed to implement a noncontaminated system

, sampling program consistent with the requirements of IE Bulletin 80-10, '

" Contamination of Nonradioactive System and Resulting Potential for  !

Unmonitored/ Uncontrolled Release to the Environment (ibid., p.10). I The third instance was described as follows:

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On July 30, 1965, the licensee's sanitary sewage systen malfunctioned causing an estimated 100 gallons of untreated sewage to flow into storn drains. Th2 drains disch2rga to Cap 3 Cod Bay vic th2 discharge c2nal.

The licensee investigated the cause and determined it to be inoperable level . instrumentation on the sewage tank at the main sewage pumping station (ibid., pp. 12-13).

Another routine radiological safety inspection conducted November 17-22, 1985 uncovered a violation involving " failure to perform monthly tests on waste gas monitors" for the Reactor Building Vent and the Stack Waste Gas Monitors, as required by Technical Specification 4.8 c.10. This resulted in issuance of a Notice of Violation (Inspection Report 50-293/85-32, cover letter from Thomas Martin, Director, Division of Radiation Safety and Safeguards, and Appendix A, Notice of Violation).

The problems that Pilgrim's management has had with monitoring and controlling radiological exposures, effluents and wastes is further demonstrated by its inability or lack of desire to make accurate low level radioactive waste projections. An April, 1985 report by Stone & Webster predicted that the Pilgrim facility's waste would contain about 1024 curies in that year; an updated survey by the Special Legislative Commission on Low Level Radioactive Waste on the waste produced determined that the

actual level was 1540 curies, or more than 50% greater than predicted.

1 5). Deficiencies in the Area of On-Site Precaredness The deteriorating ratings in the area of Emergency Preparedness over the last two l SALP evaluation periods are particularly critical to plant safety and could lead to potentially catastrophic consequences for the region's citizenry. The 1986 SALP report concluded that performance was only minimally acceptable in this functional area for the second year in a row. Portions of the annual exercise were unsatisfactory and had to be demonstrated in a supplementary drill. The lack of thorough exercise critique was e recurring problem. . Personnel errors were evident during the exercise and may reflect weaknesses in program staffing and training (ibid., p. 27).

During the December routine inspection, two problems were~ identified concerning implementation of provisions of the Emergency Plan. (Failure to mail information brcchures to tha gen 2ral public and failure to perform an annual update to the Emergency Plan and procedures). During the review of the scenario package submitted for the 1985 exercise, it became" apparent that the scenario package did not contain sufficient detail. It was recommended that the exercise be postponed in order to take time to clarify and complete the exercise scenario....

During the exercise, two significant areas of concern were identified by the NRC. The first involved a lack of evaluation or control of radiation exposure for re-entry teams sent into the plant for various tasks. Serious overexposures would very likely have resulted from the actions taken if this had been an actual situation. The second concern involved the fact that there were no procedures in effect for relocation of the EOF to the alternate location, in spite of the fact that the trailers which presently function as the EOF are positioned near the

• stack with no shielding or ventilation filtering. (ibid., p. 26).

6), neficiancies in the Area of Maintenance and Modifications Significant deterioration in performance from the previous SALP evaluation period (07/01/83-09/30/84) to the period evaluated by SALP report 50-293/85-99 was noted in the functional area of Maintenance and Modifications. Over tir , this lack of diligence in management oversight can lead to serious safety-related equipment deficiencies. The current SALP report cites the following problems:

A review of the licensee vendor interface program identified several weaknesses. The licensee program did not systematically address correspondence'from vendors other than General Electric. Additional problems involving the scope of reviews of vendor information, the timeliness of the reviews, and the documentation of the reviews were identified (ibid., p. 20).

Two isolated instances of untimely corrective action (for maintenance findings) were identified during this period. In one case, the licensee did not plan to complete corrective action to prevent the defeat of safety systems during component isolations until 1995. Additional NRC effort was required to obtain timely action in this case. The licensee ,

has also been slow to repair the backup 125V and 250V station battery- j chargers. These chargers have been out of service since the 1984 outage. This could be a problem if battery charger reliability degrades.... The licensee occasionally has been slow to repair equipment that was not required to be operable by the technical specifications, e.g., post accident monitoring equipment. The lack of timely response to out of service safety equipment (not covered by technical specifications) may indicate a weakness in scheduling second and third priority maintenance (ibid., pp. 20-21).

I I

Another problea found in this functional area that is indicative of weak management was an interlace problem between the corporate staff and the site....

Contractors reporting to offsite licensee engineers improperly installed

, a test instrument on the high pressure coolant injection (HPCI) system, i t which made the system inoperable (ibid., p. 21). ,

1 J Also, NRC found that this functional area suffered from a problem typical throughout the facility, that of " staffing weakness" (id.).

7). Deficiencies in the Area of Surveillance

]

As in the area of Maintenance and Modifications, BECo's performance rating in the area of surveillance has experienced significant slippage since the previous evaluation f period. In this area NRC found:

weaknesses in the areas of startup test scheduling, test adequacy, compliance with procedural requirements, and response to abnormal test  ;

results.... (ibid., p. 23).

During a slow startup from a 1984 outage, I

eight surveillance tests required by the technical specifications were not conducted in a timely manner. The tetts were missed due to scheduling omissions and procedural deficiencies. The scheduling omissions indicate a weakness in the licensee's computer scheduling system, the Master Surveillance Tracking Program (MSTP)....

! Another problem with the startup tests involved the timeliness of l followup to quality assurance (QA) audit findings. A QA finding j identified two surveillance tests that did not meet technical

! specification requirements two months prior to the startup from the 1984 j outage. The licensee did not resolve the finding until after the startup, which... demonstrated a lack of sensitivity to the finding.

i Subsequent NRC action could have been avoided if the finding was resolved prior to the startup (ibid., p. 24).

The startup period was marted by additional procedural deficiencies which involved the failure to completely test some safety system components.

I Deficiencies were identified in testing neutron instrumentation and

, certain other reactor protection system instrumentation. An additional example of an incomplete surveillance test procedure was reported in LER No. 85-26. The licensee's staff had difficulty in some cases i

i I

I

deternining which one of.several overlapping test procedures fulfilled regulatory requirements (ibid., pp. 23-24).

The SALP report also described problems in carrying out surveillance tests:

Deficlincies were identified during the assessment period which involved a lack of attention to detail. In one case, operators failed to correct known deficiencies in a station battery surveillance test procedure, j which subsequently caused a technical specification surveillance test to be missed. Lack of attention to detail was also evident in the inadvertent return to service of an uncalibrated local power range neutron monitor during surveillance tests. Arithmetic errors were noted in several salt service water system surveillance tests and a computer program error was identified which falsely lowered vacuum breaker leak *

rates by a factor of sixty....

The licensee did not always react promptly to abnormal surveillance test findings. The lack of action was usually related to delays in reporting abnormal results to the control room via the licensee's Failure and Halfunction Reporting System (F&MR). Delays in submitting P&MR's to the control toon caused secondary containment integrity to be lost for a day while the reactor was at power and caused a delay in conducting compensatory surveillance tests for an inoperable emergency diesel generator. A delay in submitting an F4MR on abnormal inservice inspection results for safety system pipe hangers delayed the licensee's response to those test results.... In one case, considerable NRC effort was needed to resolve abnormal surveillance test results. In this case, the safety implications of drif ting main steam line radiation monitors were not recognized by the licensee. In addition, the licensee was slow to correct a potential weakness in the surveillance test program involving the uncontrolled removal of safety related instruments from service for calibration and testing....

!l A new halon fire suppression system.for the cable spreading room had not been declared operational at the end of the assessment period because of j the lack of a surveillance test for several months (ibid., pp. 24-25).

t In summarizing its evaluation of the Surveillance functional area, the SALP report clearly indicates that weak management oversight has led to lax performance:

I Weaknesses were noted in the response to abnormal surveillance test results, in surveillance test procedural adequacy, and in startup test i scheduling. personnel performance errors contributed to most of these weaknesses. Additional emphasis on attention to detail would improve test timeliness and help minimize problems in this functional area (ibid., p. 25).

j Since the 1986 SALP report was issued, many new revelations of surveillance

testing deficiencies have been uncovered. The April 2, 1986 Special Inspection Report notes the following problems

i 17-4 e ,- , ~ - - .- , .- ,--,.ym,--y-- ,- --,, y.,---,- - . -. .., , _.,,.,_ - _ , . --. -e -. _ , - - - - ----------ww-,------,_--.----~.--., mien

.e--m.--e.m-.r

One particular observation thtt reflected both poor prior planning and control involved recently instituted Inservice Testing (IST) of the HPCI i system in procedure 8.5.4.1, HPCI Pump Opertbility and Flow Rste at 1000....

The test procedure was not promptly changed after the February 21 test.

Therefore, the NPCI test could not be performed as required by procedure on March 1, 1986. A new test sequence will be developed to allow proper i

verification of the minimum flow valve while operating the system.

The deficient procedure in question was reviewed and approved by the ORC without their recognition that 1) the success of the minimum flow check l valve test depended on the presence of the auto-initiation signal, and

2) that the 5 second timing valve was incompatible with system design I. and safety analysis assumptions (Inspection Report, 50-293/86-06).

l During the reviews of IaC surveillance procedures, it was noted that the licensee did not fully provide for independent verification requirements

for lifted leads or installed jumpers. ANSI Standard 18 7-1976, Section '

j 5.2.6, Equipment Control, specifies that temporary modifications, such t as electrical jumpers and lifted electrical leads require independent verification. The ANSI Standard also requires that independent 1 verification of tagging of equipment be performed. During the return to -

service of the HPCI system on March 1,1986, it was observed by an inspector that there were tags removed from the system, with valves realigned, without a double verification of the position of the valves l 4

(ibid., p. 15).

A Quality Assurance Surveillance, 85-1.2-1, dated January 25, 1985, 1

resulted in issuance of Deficiency Report (DR) No.1384. This DR was j issued to resolve questions about independent verification practices i

used by I&C personnel during surveillance testing. The Nuclear Operations Manager (NOM) subsequently issued a July 12, 1985 memorandum M85-137, Control and Verification of Operating Actions, which discussed the method to be used to perform the verifications. The inspector determined that the management objectives of this document were not l translated into the maintenance request and tagging procedure (ibid., p.

j 16).

i

! The inspector expressed concern over an intermittent condition that )

leaves a residual flow indication of approximately 50 GPM following the reactor core isolation cooling (RCIC) pump operability test, precedure i 8.5.5.1. During this test on February 28 and March 1, 1966, the anomalous condition was observed by the inspectors. It was not observed i during the test performed on March 2, 1986. Based upon discussion with 4 . licensee personnel, it appears that this has been a long standing condition.... However, on March 1,1986, it was noted that procedure 3.M.3.8 was neither implemented as required by station policy, nor was a second verification of the valving actions performed when returning the t transmitter to service (ibid., p. 16).

l l However, acceptance of a residual flow indication on the RCIC system i following a surveillance test was an example of a poor attitude (ibid.,

l p. 20).  !

18-

{

_ _ - - . . , , - . . , - - . - , , . , . , , - - . , - - - - - . . , _ , . . . . . . - ..y_, , _,____..,._,,_.m. _ , _ r ,,. . - .m. .m_, ,. c,__-.,....-,. ,r , --%m.-.,.

Tha NRC reviewed the licensea's evaluation of a potentially g2neric probles (subsequently datailed in IE infctmation Notice N. 86-13 dated February 21, 1986) involving explosive squib valves used in the Standby Liquid _ Control System (SLCS).... Bench test firing of a squib valve's explosive charge is and unacceptable test. However, the licensee determined that the squib charges were fired using a bench test, rather than the SLCS firing circuit in 1984. The licensee's failure to perform an in-circuit firing of an explosive charge that came from the same manufactured batch as those installed on April 10, 1984 is contrary to the requirement specified in Technical Specification 4.4.A.2.c and is considered a violation (86-06-07) (ibid., pp. 17-18).

This last instance led to events in which the licensee declared both systems of the SCLS inoperable on February 20, 1986 and initiated a plant shut down. A Notice of Violation was issued with the April 2 Special Inspection Report.

A more recent example of BEco's failure to insure proper surveillance was reported in the June 18, 1986 edition of the Boston Globe. In that instance, Edison failed to perform 90% of the required tests on valves designed to contain the spread of a radioactive leak in case of an accident and 36% of the required tests on leak-detection devices.

Another recent example was reported in the June 24, 1986, edition of the Boston Globe:

An alarm that warns operators when voltage levels are too low to run emergency systems was due to be tested in January or February, but plant operators forgot, according to a report filed with the NRC on Saturday.

8). Deficiencies in the Area of Security and Safecuards In the area of Security and Safeguards, as in other functional areas, staf fing deficiencies and weak corrective actions were noted. These criticisms further reflect on the inadequate nature of BECc's management.

Licensee corrective actions for reportable events were sometimes weak.

For example, six events were reported this year which involved the failure to promptly compensate for security equipment failures. The recurring problem demonstrates both a staffing deficiency and a lack of effective corrective action. Additional security program weaknesses were apparent during a review of openings in a security vital area 1

l

barrier. These weaknesses included inadequate control over contractor ccnstruction activities tdjIcent to the barrier and inc:aplete licensee evalu-tien of tha barrier, cnd tha usa of material to repalr a barrict 1 opening that did not meet requirements. Previous licensee evaluations

of bargjer integrity were conducted in 1982 and were inadequate.

l Considerable NRC attention, including escalated enforcement action, was required to obtain comprehensive corrective action. In both instances, the licensee failed to establish guidelines to implement security objectives. In the first case, the licensee did not establish criteria for timeliness of compensatory actions. In the second case, no i guidelines were established for judging acceptable site openings in l security barrier. Licensee management should be more aggressive in establishing guidelines and clarifying security program objectives (ibid., p. 28).

In addition to these complaints, inspection number 85-24 revealed a security level III violation for " failure to maintain an adequate vital area barrier" (ibid., Table l 5).

9). Deficiencies in the Area of Refuelina and Outaae Manaaement 4

The fact that NRC assigned the highest possible rating to the area of Refueling

+

l and Outage Management, despite finding obvious and continuing examples cf sloppiness J

and weak managerial oversight, raises questions bout NRC's ability to critically access BECo's performance. The recent SALP report admits that:

A significant lack of housekeeping control was indicated by the presence j

of articles of protective clothing and masking tape in the main and test tanks of the stiandby liquid control system (SLCS) early in the

. assessment period. The debris likely fell into the tanks during the j 1984 outage. A reactor shutdown in January 1985 was required while the 4 SLCS system was flushed and the debris removed. The presence of loose i items on the floor of the reactor building (protective clothing, trash, 1 and loose tools) is a continuing intermittent problem at the station.

l Management should increase the emphasis on housekeeping to hsip prevent 2

SLCS type problems from recurring (ibid., pp. 30-31).

j Furthermore, Weaknesses in the turnover of modification from the construction to the

preoperational test groups, verification of system configuration a following preoperational testing, control over nonconforming material, and the lack of a station drawiny for the air start system on the ,

emergency diesel generators were noted (ibid., p. 31).

i 1

- . - , - - - . . . - . - . - - . , _ . . - - , - - . - - . . . - , - ...--n - - ..-. ,--, - ,.. ,--. - . ,---..-.-..,,,.-..,,._n.-

10). Deficiencies in the Area of Licensina Activities The recent SALP report highlights cn:th2r example of man gement deficiencies in the area of Licensing Activities. Responses to concerns about technical specifications have been too slow:

Currently, even minor changes in technical specification wording require several months to prepare and submit to NRR. Current technical specification problems include vaguely worded action statements and incomplete definitions. In some cases, the licensee uses standard technical specification requirements to interpret vaguely worded station specifications . Also, the licensee could have shown more initiative in requesting changes regarding surveillance technical specifications that require additional testing (as compared to Standard Technical Specifications) when components are made inoperable. This change could have resulted in less equipment testing and wear when components were made inoperable during on-line EQ modification work (ibid., p. 33).

11). Deficiencies in the Area of Fire Protection The April 2, 1986 special inspection report found BEco's performance and management in the area of fire protection to be " weak". The summary states: "A lack of management initiative to reduce the number of station fire watches was evident. Fire watch personnel had minimal training. Several examples of degraded fire protection equipment were observed" (April 2, 1986 Inspection report No. 50-293/86-06, p. 30).

The excessive number of Maintenance Requests (MRs) and the presence of numerous fire watches underscores the inability of Edison's management to address deficiencies in a timely manner.

As of February 14, 1986, there were 72 plant locations requiring fire watches (either continuous or hourly) resulting from 90 separate reasons. The reasons for these watches vary from inoperable fire protection suppression equipment and unsealed penetrations between fire area boundaries to one missing screw on a fire door.

There is a significant backlog of fire protection MRs (over 250) which were open from 1984 to the present. This backlog has contributed to the number of fire watches needed. The FPE indicated that Bechtel was recently tasked to reduce this backlog (ibid., p. 28). l

A total of five plant areas have five suppression systen deficiencies.

i These arerspump ricirculctica are the cableg:nnrster motor sprerding satro:0, ro:0,emergency tha H2 seni diesel q;narctors,d oil system En I the standby gas treatment system.

~

The halon system for the cable spreading room has not been weight tested as required by Technical Specifications. The halon system is connected and considered functional. It is difficult to weight test because of the large size of the halon bottles, lack of suf ficient clearance beneath cable trays, and fact that they are restrained by racks for seismic purposes. This condition has existed for about two years without correction. Engineering b7: been involved with attempting to determine halon quantity in place by a level detection system. An unofficial level was obtained which indicated that there had been no change in quantity in the bottles. It is not clear why this system was not taken out of service temporarily, disassembled, and tested. There appears to have been a lack of management attention to fix this problem and eliminate fire watch in this area.

Preaction sprinkler system for the emergency diesel generators (EDG) is inoperable due to a design problem (ibid., p. 28).

The deluge system for both trains of the standby gas treatment system is inoperable due to the manual block valves being taggad shut. This condition stems from an incident in 1983 in which a leaking valve caused wetting of a charcoal filter bed, and the system has been inoperable since that time. This appears to be another case where a fire watch has been used in lieu of achieving problem resolution.

The inspectors were also concerned with the level of training provided to the contractor fire watches, several fire watches were interviewed

to determine their responsibilities and level of training. With the exception of fire watches for hot work, most of the contractor fire watches have little training in fire fighting including use of fire extinguishers. Licensees procedure for fire watches specifies that the fire watches primary duties are to inform the control room in the event of a fire.... In addition, the fire door connecting the 'A' and 'B' EDG rooms is blocked open to allow one fire watch instead of two. However, two individuals who manned this position stated that they had received no instruction to shut this door to prevent fire spread. This is another example of lack of management initiative to correct a long

, standing problem (ibid., p. 29).

An example of particularly sloppy performance and oversight was the following:

On February 28, the inspector again examined the D/G fire pump conditions. A portable electric heater using an ungrounded plug was directed at the battery in an attempt to keep battery cell temperatures within normal range. The heater was connected to an extension cord and the connection was laying on the room floor. If the D/G fire pump had l . started, this area was likely to get very wet from the leaking relief valve. The inspector considered this to be a safety hazard, and brought it to the attention of the NWF (ibid., p. 30).

The roca h2 sting systen for the diesel gineratcr (D/G) fire pump was fcund to be cut of servica due to a frozen motcr. As c censIquinca, tha call tisperaturss for tha fire pump battery were belov v_cificttion.

This condition had existed since December 1985 d.'

12). Deficiencies in Licensee Manaaement Manifest in All its Endeavors Boston Edison's Company's deficient management was the subject of an extremely critical report issued by the Massachusetts Department of Public Utilities on June 26, 1986. This report indicates that these inanagement problems are not restricted to the operation of the Pilgrim facility but rather were manifested in all of the company's endeavors. It announced the refusal of a BEco request for $35 million rate increase and lowered the licensee's allowable rate of return on common stock from 15.25% to 12%,

stating:

We have grave concerns about the ability and desire of Boston Edison's management to carry out its pubile service obligation. Based on the evidence in the record of this case and other recent cases involving the company, we conclude that there is a pervasive att.tude within the company's top management, that unless ratepayers underwrite the business risks associated with the company's operations, it is not required to act in a manner consistent with its public service obligation....If the company continues to combine an abdication of its responsibility for capacity expansion planning with an approach that undervalues the potential for C&LM programs, it will jeopardize the health and safety of its customers and the economy of the region. The company's apparently cavalier attitude toward these impending consequences is a development which we regard with extreme alarm (DPU Report, from excerpts printed in the Boston Globe. June 27, 1986).

Although the problems outlined in the report are not directly related to operations at the Pilgrim facility, Paul F. Levy, DPU chairman, "said that in terms of management alone, the Pilgrim problems 'may be symptomatic' of Boston Edison's entire operation" (ibid.). Boston Edison's lack of social responsibility manifests itself at the Pilgrim facility in the kinds of managerial and organizational deficien,cies that have been described herein to have been of great concern to the NRC for a number of years.

13). Statement of Law as it Acolles to Standards of Manacement

The Ato ic Energy Act, 42 USC F2236(c), provides for the revac2 tion, suspension or modificition of a license if any information is disclosed fro 2 " report, record, inspection or other-means which would warrant the Commission to refuse to grant a license on an original application." Furthermore, the Commission has held that "public safety is the first, last and a permanent consideration in any decision on the issuance of a construction permit or a license to operate a nuclear facility." Power Reactor Develonnent Coro. v. International Union of Electrical Radio and Machine Workers, 367 U.S. 396, 402, 81 S.Ct. 1529 (1961). The Supreme Court, in that case, emphasized that even after a reactor is licensed for operation, the Commission will retain jurisdiction "to ensure that the highest safety standards are maintained." Power Reactor, supra, 367 U.S. at 402, 81 S.Ct. at 1532.

However, since the NRC is able to oversee or inspect only a fraction of the organizational and technical functions of a nuclear facility, it must rely on the management of the utility to honestly, accurately and timely identify safety problems, to perform objective analyses, to propose solutions and to provide a great deal of data necessary for NRC to perform its duties. Petition for Emercency and Remedial Action, CLI-78-6, 7 NRC 400, 418-419 (1978). Unless the licensee demonstrates a full commitment to safety, "it is beyond the power of regulators to put an appropriate program in place." Metronolitan Edison Company (Three Mile Island Nuclear Station, Unit No. 1), LEP-82-56, 16 NRC 281, 358 (1982). Thus, the NRC must rely heavily upon the licensee's competence to manage the facility's operations so as to ensure that the public safety standards are maintained. In the case of the Pilgrim nuclear , facility, the foregoing sections of this petition describe how the NRC tried in 1982 to get Boston Edison to "put an appropriate program in place," to improve management so ps to ensure safe plant operation and how, in numerous reports and public statements issued within the last year, both the NRC and the Massachusetts Department of Public Utilities have expressed their determination that a high degree of management incompetence still remains, despite those efforts by the NRC in 1982. The NRC itself has stated that it

indeed cannot rely up:n the licensee to honestly, accurately and timely identify safety problems at tha Pilgrim facility. In frct, it rep::rts thnt licensso mantgtment suf fers from a defensive attitude toward perceived weaknesses that " inhibits a thorough and critical evaluation with subsequent delays in resolving the problem (s)" (Section 2 herein). Because of annagement's inability or lack of commitment to prevent, identify and resolve organizational and operational problems, NRC itself has recogniz'!d that safety standards are not being adequately maintained as required for the retention of l an operating license. Although through its inspection reports and regulatory oversight the NRC " encourages excellence in operations," Commissioner Asselstine admits, "however, the commission too often accepts far less" (James Asselstine, The Patriot 1

Ledoer. July 9, 1986).

II. EMERGENCY RESPONSE PLAN i

14). Deficiencies in the Radioloalcal Emeroency Resconse' Plan (RERP)

Nuclear Regulatory Commission (NRC) regulations provide that no full power operating license shall be issued by the NRC unless the NRC Einds "that there is reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency" (10 CFR V50.47 (a)(1)). The NRC lists sixteen

particular standards which must be met by the emergency response plans (10 CFR 250.4 (b)). More detailed specifics for RERP's are set out in " Emergency Planning and Preparedness For Production and Utilization Facilities" found at 10 CFR Part 50, Appendix E. The NRC generally bases its finding of adequacy of RERP's upon a review by the Federal Emergency Management Agency (FEMA) of state and local emergency plans (10 CFR V50.47 (a)(2)). The NRC and FEMA have issued " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness In Support of Nuclear Power Plants," NUREG-0654/ FEMA-REP-1, Rev. 1, November, 1980 (hereinafter 1

l

I auvaluation Criterina ). The evaluation criteric are relied upon by state and federal  !

I agencies to set up and evaluate RERPs. l Both the NRC (10 CFR iS0.100, #50.54 (e)) and FEMA (44 CFR F350.13) are empowered j to withdraw their approval of plans that do not adequately protect the public. The NRC can revoke, suspend or modify a license to operate a nuclear power plant (10 CFR 1

1. 50.100).

Serious deficiencies exist in the RERP for Pilgrim, warranting suspension of Boston Edison's operating license by the NRC. The deficiencies are outlined below.

The combined 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 standard set by 10 CFR #50.47 (a) (1).

15). Deficiencies in Advance Information a). The only method being used for advance public education in the Pilgrim Emergency Planning Zone (EPZ) is the distribution of pamphlets by mail. A MASSPIRG telephone survey conducted in 1983 revealed serious inadequacies in the distribution, retention and understanding of the pamphlets by area residents. No improvements in the advance information procedures have been carried out since 1983.

b). The current (September,1985) pamphlets contain no information regarding public transportation for purposes of evacuation, despite the fact that the Radiological Emergency Response Plan (RERP) for the Town of Plymouth provides for thirteen " staging areas" where persons without transportation will be directed for "possible" public transport.

c). The advance information system for tourists and other transients is inadequate or nonexistent. For example, no signs have been posted to provide appropriate information for transients, a measure suggested by the NRC in 10 CFR Part 50, Appendix E. IV. D. 2.

l

l d). Tha inIdequate advrnce information systen violates 10 CPR #50.47 (b) (7); 10 4

CFR Pa'rt 50, Appendix E. IV. D.2, and Evaluation Criteria G.1, G.2 cnd P.10 of NUREG-

, 0654.

16). Deficiencies in Notification Durina An Accident The warning siren system and back-up systems are inadequate to essentially complete the initial notification of the public within the plume exposure pathway of the Emergency Planning Zone (EPZ) within fifteen minutes, as required by 10 CFR Part 50, Appendix E., IV. D.3. For example, the siren system has been plagued with false i

alarms. Rather than correct this problem, the response has been to disconnect the siren system during electrical storms. The sirens are inaudible or barely audible l

within large areas of the EPZ (Report on the Pilgrim Nuclear Power Station Siren Test, June 19, 1982, FEMA, January, 1983, p. 6). Furthermore, federal regulations require

notification of "all segments" of the population (Criteria J.10. c, E.6; 10 CFR Part 50, Appendix E, IV. D. 3). Clearly, the deficient siren system would fail to warn the hearing impaired; testimony at the June 18, 1986 hearing on the Pilgrim RERP before Massachusetts legislators provided no evidence of the existence of an alternate plan for notification of this segment of the population, a direct violation of this statutory mandate, i'

Further, in testimony before Massachusetts State legislators on June 18, 1986, Edward A. Thomas, Division Chief, Natural and Technological Hazards, FEMA, stated that Boston Edison had failed repeatedly to deliver to FEMA necessary technical specifications on the siren system. Mr. Thomas added that these delays by BECo have forced repeated postponements of the full-scale system test required by FEMA.

17.) Deficiencies in Evacuation Plans ,

a). The evacuation time estimates for the Pilgrim EPZ are unrealistically low.

They fail to take into account the probability of some panic, traf fic disorder, traffic obstacles outside the EPZ and the fact that thousands of people outside designated

- - . . _ - - , - - , - ._ =,,_. - . , _ , , _ - ,

ovacuation zones will also evicuate. According to testimony before Massachusetts ,

legis10 tors on Juna 18, 1986, by Edward A. Th: man, Divisicn ChiGf, Natural and Technological Hazqds, FEMA, the " reasonable assurance" adequacy of the current plan is based on the assumption that communities outside of the ten mile EPZ have developed plans to augment evacuation and sheltering efforts. When asked, Mr. Lubering, Deputy Director of the Massachusetts Civil Defense Agency (MCDA), stated that he had no ,

evidence that such plans exist. Furthermore, evacuation time estimates are not provided for various adverse weather scenarios.

b). There are no workable plans for evacuating the physically disabled, nursing home residents, school children, hospital patients, campers, inmates of correctional .

l facilities, or people without automobiles. In light of the deficiency noted in c.)

below (lack of contractual agreements with transportation providers), general statements in the plan to the effect that these groups will somehow be evacuated are meaningless and unrealistic. l c). Testimony by FEMA and MCDA officials at the June 18, 1986 hearing on the Pilgrim RERP 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. 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. Furthermore, the proposed route of such evacuation (Routes 3 North and 44 West) are completely inadequate to effectively handle l

the anticipated volume of traffic. This is particularly true during the summer months )

due to the heavy volume of tourists heading to and from Cape Cod.

l 18). Deficiencies in Medical Facilities al. Various NRC and FEMA regulations require that arrangements be made for medical services for contaminated injured individuals (10 CFR 950 47 (b) (12); 10 CFR Part 50, Appendix E. II. E. and IV. E. 7; Evaluation Criteria I. 1 and L.3). The plan makes inadequate provision for treatment of victims of radioactive contamination. A MASSPIRG 1983 study of the two hospitals listed in the plan then in effect revealed '

l

they hava a totc1 c pacity to trett only eight or nina victir.o of radioactiva conta:1 nation. One of these (Jordan Hospital, Plymouth) is within four tiles of the plant, so it may Oted to be evacuated. The other (Norton Hospital, Taunton) in 1983 had no staff trained for radiological accidents. No data suggests the situation has materially improved since 1983.

b). The plan falls to provide for the distribution of radioprotective drugs for the prevention of thyroid tumors to the general public or to persons in institutions who may not be evacuated. The NRC and FEMA recommend distribution of such drugs at least to such institutionalized persons (Evaluation Criteria, J. 10. e. and J. 10. f.

19). The Rmercency Plannina Zone Is Too Small a). The Environmental Protection Agency recommends protective measures by the public when radiation exposure is likely to exceed the EPA " protective action guide" of one tem (Manual of Protective Action Guide and Protective Actions for Nuclear Accidents, EPA-520/1-75-001, EPA, 1975.

b). NRC regulations require the exact size and configuration of each EPZ to be

" determined in relation to local emergency response needs and capabilities as they are affected by such conditions as demography, topography, land characteristics, access routes, and jurisdictional boundaries." Generally, the NRC provides, the plume l

exposure EPZ should be about ten miles in radius (10 CFR Part 50.47 (c) (2)). Boston Edison Company has admitted that the only factor used to create the Pilgrim EPZ was l jurisdictional boundaries (response of Boston Edison Company to Commonwealth of Massachusetts' First Set of Interrogatories on Emergency Planning, July 20, 1981, p.2).

c). Cape Cod begins just eleven miles from Pilgrim and is connected to the niinland by only two bridges. There 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 evacuation, so as to give preference to evacuatees within the plant's 10-mile radius. This is totally unacceptable to the people on the Cape, who would be in the path of a radioactive plume if the the wind

were blowing toward the Cape. Even if they were allowed to evacuate th3 Cape over the crnnecting bridgrs, thay would ba doing so in the direction of tha plcnt cnd tha source of the radiation._The issue of evacuating Cape Cod is extremely important in the light j of the Chernobyl accident, since there the radioactive plume extended much further than

! 10 alles. ,

d). Basing his conclusion upon NRC data, the Attorney General of Massachusetts has concluded that the size of the Pilgrim EPZ is inadequate (comments of Attorney General Francis X. Bellotti Relative to Off-Site Emergency Planning for the Pilgrim Nuclear Power Station, submitted to FEMA, August 1982).

20). Lack of Coordination and Prioritization of the RERP The NRC should suspend the operating license of the Pilgrim power plant until a ,,

realistic, detailed RERP is developed, showing an actual capability to educate, alert, treat and efficiently evacuate all people who may be at risk from a catastrophic I ~

l accident at the plant. Federal, state and local government agencies, as well as Boston 1

! Edison, have all accorded a low priority to emergency planning. Instead of trying seriously to devise a plan that will protect all of the public, planners have sought to achieve only minimum compliance with NRC regulations; as sections 13 through 18 of this petition demonstrate, they have failed to do even that. This insufficient commitment to public protection is evident in missed deadlines, slow processing of paperwork, lack

) of attention to detail and inadequate budgets and staffing.

To date, FEMA has largely acquiesced in plans that fall to demonstrate a i

j capability to adequately respond to an actual emergency, and FEMA's acquiescence has been emulated by the NRC. Where FEMA has criticized parts of the plan, the Massachusetts Civil Defense Agency (MCDA) has not responded in a timely fashion to FEMA's concerns. For example, according to testimony before Massachusetts state legislators on June 18, 1986, by Edward A. Thomas of FEMA, the agency sent letters outlining persistent FEMA concerns to MCDA in October, 1985 and January, 1986. FEMA l

received no responsa to tha October letter until June 6, 1986, and FEMA htd not yet received a response to the Janu;ry letter by the time of the hearing. Another example of the serious lack of coordination was the failure of MCDA to deliver to FEMA an up-to-date version of the state emergency plan. According to statements by FEMA and MCDA officials in the June 28, 1986 edition of the Patriot Ledger of Quincy, MA, the plan was not delivered until 10 months after it was prepared. MCDA completed the updated plan in August,1985 but did not deliver a copy of it until June 25, '.986. FEMA had formally requested a copy of the plan in October, 1985, but did not follow up on that request. MCDA's failure to respond to FEMA's request and FEMA's evident lack of concern and unwillingness to demand more responsive action are symptomatic of an emergency response regime that is uncoordinated and given low priority by its attendant public agencies.

Further evidence of this lack of coordination and prioritization was revealed in

Mr. Thomas' June 18, 1986 testimony. Mr. Thomas 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. Thomas stated that these delays by Boston Edison have forced repeated postponements of system testing. Thus, the system has never been given the full-scale test required by FEMA.

The emergency response system's lack cf prioritization is further demonstrated by the fact that local civil defense agencies in the communities within the Emergency l

Planning Zone have serious staffing and budgetary problems. Most local civil defense <

directors within the Ep2 are unpaid or receive only small stipends. Most have little or no paid staff. The reliance on volunteers, who often have minimal professional experience or training, reflects the unwillingness of state and local government to make a genuine commitment to emergency response planning. Major improvements in staf fing and budgets of state and local civil defense bodies must be implemer.ced before public safety can be ensured. Moreover, lest the necessary measures taken constitute l

1 l

public subsidization of the fintncial requirements of a safe nuclear power systen, B: sten Edisrn shsuld be required to provida tha financici merns fer thea.

III. CONTAINNENT STRUCTURE 21.) Inherent Desian Flaws of Pilaria's Containment Structure The General Electric Mark I pressure-suppression system employed by the pilgrim reactor contains inherent design flaws which raise serious questions about its ability to withstand a severe accident:

A pressure-suppression containment system has some means of absorbing the heat of the steam in the fluid released to the containment volume.

In all three GE models, the steam is forced to bubble through a pool of water and is condensed....If some unexpected event should result in steam generation or flow greater than the suppression capability, then the steam that is not condensed would add an increment of containment pressure. Since the objective of pressure-suppression is to permit use of smaller containment, rated at lower pressure than would be required without suppression, the incomplete suppression would lead to overptessurizing a pressure-suppression containment so designed ( AEC internal report by Dr. Stephen Hanauer, September 20, 1972).

The containment structure employed at the Pilgrim reactor is rated to withstand 62 pounds per square inch of pressure from steam and other gases. In comparison, the containment structure employed at the Chernobyl reactor (also a pressure-suppression system) was rated to withstand 57 pounds per square inch of pressure (Boston Globe, May 26, 1986).

The AEC internal report by Dr. Hanauer goes on to state:

All pressure-suppression containments are divided into two (or more) major volumes, the steam flowing from one to the other through the condensing water.... Any steam that flows from one of these volumes to i the othar without being condensed is a potential source of unsuppressed l pressure. Neither the strength nor the leakage rate of the divider 1

(between the volumes) is tested in the currently approved programs for -

Initial or periodic inservice testing.... Because of the limited strength against collapse, the " receiving" volume has to be provided with vacuum relief. In all designs... 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. Valves do not have a very good reliability record (AEC internal report by Dr. Hanauer, supra.).

As to the probability of such overpressurization, the Asc has stated i

GE claims two passive failures are required for trouble, but any malfunction of 12 vacuum relief valves, not easily inspected in the torus,*Byer 40 years will set up half the accident, ready for trouble if a steam leak occurs. The GE position that this is too improbable to worry about is rejected (Task Force Review, Bypass Effects in GE Pressure Suppression Containments, November 9,1971 and December 1, 1971).

This situation is exacerbated by the inability to carry out proper tests of the pressure-suppression system:

The smaller size of the pressure-suppression containment, plus the requirement for the primary system to be contained in one of the two volumes, has led to overcrowding and limitation of access to reactor and j primary system components for surveillance and in-service testing.... 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 (AEC internal report by Dr. Hanauer, Supra.).

The implications of the problem with the pressure-suppression containment in the GE reactors was not lost to the AEC:

The problem is germane to all past and present GE pressure-suppression containments. About 40 such are already approved.... GE wants us and ACRS not to mention the problem publicly. They are afraid of delaying

hearings in progress.... In any event, this is potential trouble for the j Vermont Yankee and Pilgrim hearings; it will have to be faced and a real solution found (Task Force Review, Supra.).

i i Given his concerns about the problem, Dr. Hanauer formulated his own solution, I concluding his study by recommending the following:

Recent events have highlighted the safety disadvantages of pressure-i suppression containments. While they also have some safety advantages, i on balance I believe the disadvantages are preponderant. I recommend

] that the AEC adopt a policy of discouraging further use of pressure-

! suppression containments, and that such designs not be accepted for l construction permits filed after a date to be decided (say two years after the policy is adopted) (ibid.).

AEC official Joseph M. Hendrie found Dr. Manauer's recommendation to ban pressure-i suppression containments an " attractive one in some ways," but ultimately rejected it,

)

i i

4 i

_ _ - _ _ _ . _ , - . _ . - . _ , - - , - . - - _ , . ~ . _ _ . . , . _ , _ . , . - - . . _ . _ _ _ _ . . _ . ._-____-_,__

stating: .

Howev;r, the ccceptrnce cf pressura-suppression containment conc pts by all elements of the nuclear field, including Regulatory and the ACRS, is firmlyj mbedded in the conventional wisdom. Reversal of this hallowed

policy, particularly at this time, could well be the end of nuclear power. It would throw into question the continued operation of licensed plants, would make unlicensable the GE and Westinghouse ice condenser plants now in review, and would generally create more turmoil than I can stand thinking about (memo from Joseph M. Hendrie to John F. O' Leary, September 25, 1972).

Clearly, this decision to disregard Dr. Hanauer's recommendation demonstrates that the AEC was much more interested in preserving the interests of the nuclear power industry than in assuring public health and safety. In fact, Dr. Hendrie's response was embarrassing enough to the AEC that it was withheld from the FOIA both prior to an after Dr. Hendrie's confirmation as Chairman of the NRC, despite FOIA's specific request for gli responses to Dr. Hanauer's recommendation (Union of Concerned Scientists, "An Analysis of Chairman Hendrie's Response to Senator Hart's Letter of June 15, 1978," December, 1978, pp. 1-2).

Dr. Hendrie has defended his September 25, 1972 reply to Dr. Hanauer's recommendation by stating that Dr. Hanauer offered his september 20, 1772 memo simply as "an idea to kick around" and that its main conclusion was that it was more trouble than it was worth to work out the review issues in the GE containments, and the concept ought to be discouraged. I thought we should not reject a containment system just because it was harder to review and required more staff effort (Joseph M. Hendrie, letter to the 4

editor, New York Times. June 21, 1386).

This representation of Dr. Hanauer's memo by Dr. Hendrie is is highly misleading.

Although Dr. Hanauer did complain about the inadequacy of testing components of the pressure-suppression system, his conclusion, as quoted in full above, reads very clearly- he felt that the safety disadvantages of the GE pressure-suppression '

containments warranted the end of their use in the industry.

34-I

- .- _-%. .4 .__. , ,., , _,_._,_,p _., , _ _ , _ . - _ . _ _ _ _ _ , , - _

Dr. Han;uer did' assert in a June 20, 1978 memo to Dr. Hendrie th;t his current opinion was th:;t there was (dequ;te assurance of safety in the GE pressure-suppression containments, and,that that had been his opinion in 1972 as well. However, a meno that he wrote in early 1973 lists, among other problems:

Bypass Paths on BWR Pressure Suppression Containments. I think this is a real problem. Please note my memorandum of September 20, 1972, copy enclosed (S. H. Hanauer, meno to E. J. Bloch, January 15, 1973).

It seems obvious that Dr. Hanauer believed on January 15, 1973 that his September 20, 1972 conclusion on the lack of safety in GE pressure-suppression containments was accurate. The very different tone of his 1978 memo " leaves the public to decide whether his 1978 memo which was prepared for public consumption or his 1972 meno which the NRC tried to withhold from the public represents the truth" (Union of concerned Scientists, "An Analysis of Chairman Hendrie's Response to Senator Hart's Letter of June 15, 1978," pp. 11-12).

The reason for the difficult posit!on that Dr. Hendrie found himself in when responding to Dr. Hanauer's memo in 1972 is attributable to the fact that GE plants were being licensed and built before safety problems were solved. In order to justify licensing, the NRC " staff makes 'judgements' in the absence of the proof of safety" and subsequent attempts to "tolve the safety problems are portrayed to the public as

' confirmatory in nature'" (ibid., p.12). As the Union of Concerned Scientists analyses indicate, NRC's confirmatory tests, such as these presented in NUREG-0474, often fail to produce expected results. The December, 1978 analysis summarizes three such cases in NUREG-0474: pool swell hydrodynamics were larger than expected; flow rates into the wet well were not well simulated; and " tests of the ' magnitude and character of hydrodynamics LOCA related air clearing loads on the Mark I containment system... have revealed that the anticipated load reduction due to three dimensional effects may not be realized'" (NUREG-0474, from UCS, supra, p. 13). t.

As the 1978 UCS analysis concludes, the practice of licensing plants before testing is completed and safety cssur:d is that it is impossible Ecr tha NRC t3 enfccc]

its own regulationb "Once plants are in operation, the pressures are enormous to allow them to dontinue in. operation" (ibid., p. 15). Thus, plants with GE pressure-suppression designs, such as the GE Mark I containment structure at the Pilgrim plant, have been allowed to operate despite safety design flaws that have been known to the AEC/NRC for a decade and a half.

A substantial part of the problem in using "judgements" in licensing plants with design flaws like Pilgrim's Mark I containment has had to do with the probability risk assessments (PRAs) that the NRC has typically performed and the perception of risk that they entall. According to a study released by the Union of Concerned Scientists earlier this year, pRAs do not take into account some very important fact.rs, such as the aging of structures; technical specification violations and temporary exemptions

! A 4

from specifications; construction defects and weaknesses; partial system failure l sequences; and external factors such as earthquakes, fires, or sabotage (Steven Sholly j and Dr. Gordon Thompson, "The Source Term Debate," Union of Concerned Scientists, January, 1986).

The Sholly and Thompson depict various accident scenarios and containment failure modes which are not taken into account in pRAs. Some of these entall a situations in which the concerns raised in Dr. Hanauer's 1972 memo may be realized. For instance, the safety / relief valves (SRVs) to limit reactor pressure by discharging to the suppression pool are located on the main steam lines inside the drywell. If a discharge line passlug thrcugh the air space above th suppression pool were to break in the wet well space following a stuck-open SRV in that line, " steam would bypass the suppression pool and rapidly pressurize the containment" (Sholly and Thompson, supra,

p. 4-17). Another type of scenario involves the failure of the residual heat removal system and subsequent lnability to circulate suppression pool water, which could lead

to containment failure. A third type of scenario mentioned in the study involves

station blackout sequences (shelly and Thompson, supra, Chapter 4).

j Other scenarios not accounted for in PRAs include interfacing loss of coolant l cccident (LOCA) sequences, Mark I/II sequences with exploding hydrogen in de-inerted I containment, reactor vessel rupture, main steam isolation valve (MSIV) leakage, and steam explosions (ibid., pp. 4-18 to 4-22). As the study asserts, "the failure to include important sequences such as these means that the estimated nuclear risks will net.essarily be underestimated" (ibid., p. 4-1).

l The tendency to underestimate the probability of various types of accidents, i

especially very serious ones, has had serious implications for nuclear facility i

l construction. Nuclear manufacturers tended toward the lighter GE Mark designs because i

their lower pressure containment requirements and lighter designs were attractive economically. However, as stated recently by Commissioner Asselstine, l as is apparently the case with the Soviet reactors, our reactors were not designed for large-scale core meltdown accidents. Because such i

{ accidents were assumed to be so unlikely as to be incredible, they were

judged to be outside of the design basis for the plants. One ,

< consequence of this assumption is that U.S. reactor containments were designed to withstand the rupture of a large steam pipe but were not

, designed to withstand large-scale core meltdowns....There are accident sequences for U.S. plants that can lead to rupture or bypassing of the

! containment in U.S. reactors which would result in the off-site release

of fission products comparable to or worse than the releases estimated k

by the NRC staff to have taken place during the Chernobyl accident i (James Asselstine, statement before the Subcommittee on Energy ,

1 Conservation and Power, May 22, 1986).

Similarly, in NUREG-0956, Reassessment of the Technical amnes for Estimatina source i IRIma., the Containment Loads Working Group obtained study results that " lead on to conclude that Mark I failure within the first few hours following core melt would 1

appears'rather likely" (NUREG-0956, July, 1985).

1

l. In the sobering light of the Chernobyl disaster, the issue of the inadequacy of the GE pressure-suppression containment has been raised again. The fact that the same J

problems still remain was underscored recently by the NRC's top safety of ficial, Harold

! j

Denton, Director of NRC's Office of Nuclear Reactor Regulation, who urged the nuclear industry to giva top priority to resolving tho containment structure prcbic I don't have the same warm feeling about os containment that I do about the larger dry containments. Thera has been a lot of work done on those containments, but Mark I containments, especially being smaller with lower design pressure- and in spite of the suppression pool- if you look (at the) WASH 1400 reg safety study, you'll find something like a 90%

probability of that containment failing (Harold Denton, quoted in Inside tiRC., Vol. 8, No. 12, June 9, 1986).

The lesson of Chernobyl was not lost on Mr. Denton, who went on to say to industry leaders, We can argue about the probability of severe core damage for a long time. I think the political climate is such that people are willing to concede that maybe they (severe accidents) will happen now and then at U.S. plants, despite the best efforts of everyone (ibid.).

l Taken by itself, the high probability that pilgrim's GE Mark I containment structure will not withstand various severe accident scenarios is a very serious factor threatening public health and rafety within the region. However, the additional factors of deficient plant management, which greatly increases the probability of a severe accident taking place, and an inadequate Radiological Emergency Response Plan, which will fall to protect the public in case of a serious mishap, add up to an intolerable potential for disaster.

CONCI USION The petitioners have demonstrated herein that the managerial and structural problems of the pilgrim nuclear facility, as well as the inadequacy of its Radiological Emergency Response plan, combine to prevent any reasonable assurance whatsoever that "the highest safety standards are maintained," as is deemed necessary by the NRC in the case of facilities with existing operating licenses. (Power Reactor gun, 367 U.S. at 402, 81 S.Ct. at 1532). Since in fact the health and safety of the region's inhabitants are gravely threatened by each of the above factors working both

' independently and in conjuncticn with ecch cther, the petiticn:rs requ:st that the NRC issue cn order to the B:ston Edison company to sh:w c use as to why the Pilgric I j facility should not remain closed,and initiate proceedings to suspend Boston Edison's operating license (BDPR-35),unless and until that time at which the licensee demonstrates conclusively to the NRC and the public: (1) that its management is no longer hampered by the deficiencies noted by the petitioners herein, which have brought the licensee under the criticism of the Massachusetts Department of Public Ut111tles cnd have resulted in the NRC commissioners identifying the Pilgrim plant as one of the worst run in the nation; (2) that the Radiological Emergency Response Plan is in full compliance with the provisions of 10 CFR #50.47 and 10 CFR #50.57, is given high organizational priority and sufficient funding by the licensee, FEMA, MCDA, and local governments, and has practical application over a wide range of serious accident scenarios; and (3) that the deficiencies that render the facility's structure extremely vulnerable in most accident scenarios have been overcome to the extent that public health and safety will be assured even under severe accident scenarios. In the latter case, the petitioners request that the NRC require Boston Edison to submit a feasibility study on all possible structural modifications prior to NRC approval of specific modification proposals. The petitioners also request that, subsequent to the

operating license suspension, the NRC provide to the public full documentation of the factual basis for any determination it makes pursuant to the lifting or revision of the operating license suspension.

Furthermore, the petitioners request that the NRC, prior to making a decision pursuant to issuing an operating license suspension, schedule a comprehensive public hearing to address the issues raised by the petitioners herein. Such a hearing should address other related issues, including but not limited to Pilgrim's relationship to present and future regional energy needs.

l iPPENDIX A*

TABLE 5

_ ENFORCEMENT CATA PLGRIM NUCLEAR PCWED STAT *CN Inso. Inso. Severit y Functional No. Cate Level Area Violation 3;-35 11/1-11/85 IV Plant- Failure to concuct an adacuate Operations shif t turnover for control room i personnel during refueling IV Plant Failure to continuously monitor Operations source range monitors during refueling St-33 11/21- IV ~ Surveillance Failure to promptly identify 12/31/84 concitions adverse to cuality (i.e. failure to initiate Failure and Malfunction Reports) i .

5'-11 12/10-13/34 IV Emergency Failure to diseminate e ergency Precareeness planning informaticn IV Emergency Failure to update the emergency Preparecness plan and procecures 5t-24 12/13-19/34 III Radiological Failure to follow raciation work Controls permit instructions and failure

, to establisn a procedure for a retote reacing telecostmetry -

system ,7 55-01 1/1-31/55 V Plant Failure to maintain control reom , (,s Caerations staffing at levels required by '

10 CFR 50.54 IV Surveillance Failure to tes tne enntainment cooling subsystem immectately when the Icw pressure c ciant injection system was ine:erable 35-03 2/1/35- IV Suneillance Failure to cencuct surveillance 3/t/85 tests for the reactea protec: ton system (six examples) lV 5; vet 11ance Failure to cencuct red block surveillance tes:s (five ena. roles)

A-1

• Reprirted from SALP report 50-293/85-99

Insp. Inso. 3everity Functional No. Cate Level Area Violation IV 91 a. Failure to promotly correct con-Operatiens citions acverse to quality (i.e.

failure to take timely action on Quality Assurance surveillance findings) -

V Surveillance Failure to use the most cu-rent revision of a surveillance test procedure V Surveillance Failure to calibrate test equip-ment within tne calibratec perioc 3/5/S5-85-05 V Plant Failure to maintain an uncali-

• /1/55 Oserations brated local power range monitor in a bypassed state IV Maintenance Failure to conduct a dioctyl phthalate test of HEFA filters following maintenance on the standby gas treatment system 85-13 5/20-24,'55 V Radiological Failure to have the Operations Controls Review Committee (CRC) review two radiological procedures and failure to control work in the fuel ocol with a maintenance request Ceviation Radiolcgical Fatture to~ conduct an adequate -

Controls review of systens that could generate an uncontrolled, un-monitored radioactive effluent release, as recommended in IE

. Bulletin 80-10 85-17 6/13/35- IV Sveveillance Failure to conduct a surveillance 7/15/55 surveillance test of tne 250 V battery system recuired :y the {

technical specification anc to folicw station procedures for acditional battery test IV Radiological Failure to soecify ndgn radiatten Controls area surveillance frequencies on ractation worn permits A-2 j ..

i

Insa. s;. *

,4 veri.y Functional *

.W . 'aie Level A ea Violation Cevia:fon Surveillance Failure to c:nduct inservice tests as specified in an NRC submittal 85-20 7/:6/55- IV Surveillance Failure to mainta'n the trip 3/19/35 level setting for the "B" and "C" main steam line high raci-ation monitors within technical specification limits i

85-21 7/16/35- IV Surveillance Failure to maintain secondary.

7/30/35 containment IV Surveillance Failure to test alternate safety system wnen an emergency diesel generator was found to be inoperable IV Surveillance Failure to initiate Failure ard Malfunc ten Reports as required by station procecures 35-2: 3/5-3/35 III Security failure te maintain an adeasate vital area barrier 85-26 3/20/85- , IV Plant Failure to cecoerly authori:e C 9/23/35 Operations excessive Itcensec coerator N, overtime as recuired by station procedures (thirty-five instances) 85-27 9/16/85- Deviation Radic1cgical Failure to install a protec:tve 9/20/35 Controls concuit 5

e 9

A-3 O

~ - .

APPENDIX B*

i TABLE 7 plint SHUTOCWNS .

Descriotion Cause Snatcown De ioc Cec. 11. 1933 :: Refueling anc recirculation pipe ---

Dec. 24, 195? replacement outage.

i Dec. 24, !?s: Startup from the outage. ---

Dec. 25, 1934 Shutdown from low pewer due to Cesign (trapped air passible J erratic incication of reactor in instrument lines) or water level instruments during the pr:cedure weakness (venting startup. Traccea air in instru- an instrument lines following

ment reference legs is a long extended outage not ace-stancing proclem.

quate).

"(f' Shutc0wn due to the presence of Peor housekeeping (SLCS)

Jan. 1, 1935 t: I-Jan. 7, 1935 cebris in SLCS and for maintenance and c:moonent malfunction

' on torus to crywell vacuum (vacuum breakers). l breakers.

Feb. 9-15, 1935 Shutdown to re: lace failed recir- 0:m:enent malfunction are culation cumo tearings. The bear- procacure weakness (res; nse ing failure was causec by a loss to a nt/lo cil level alarm of pumo lubricating oil inventory, not adequate).

Tne oil loss was caused by a leak in an oil packing glanc that sur-rounds a c: cling water line, i

Fe:. 15-13, 1935 Shutdown to repair a leaking weld Component malfunction, l in the reactor vessel drain line.

March 15-20, 1935 Scram from 1000 a wer on a f alse Cesign weakness (instrumert high reactor pres +vre signal valves orcne to stick) or caused by a sticking instrument personnel error (valve valve. The shutdewn was centinuec evertfghtene ).

to c:mplete maintenance on the reactor water sa ale system and secondary c:ntatement ca pers.

l l June 14, 1935 Scram from less than 1C% power due Persernel error.

to a nign reacter water level l

isolation curing lo power maneuvers.

A April c-5. 1955 Scram from 35% po er cue to a Cesign wea(ness (tur:tre false turoine hign vibration trio Icgic is one out of j n),

signal, i -

L-!

i *Poprinted from SALP report 50-293/85-99

i,nute:wn :*-ta. ..

-escrietten Cause Se:t. 1-5, .*955 Scram from 32% power due to high Design weakness (portions reactor pressure following a generator load rejection. The of switchyard must be washed load rejection was caused when a live).

ground fault occurred in the sta- i tion switchyard during. washing ac-tivities. The fault was caused by a buildup.of ocean salt on switchyard insulators. A leakin g recirculation pump seal was re ,

placed while the reactor was shut C0wn.

Sept. 5-7, 1955 i Shutdown to replace an additional Cesign or maintenance leaking recireslation pump seal, weakness.

e e

B-2

Appendix C ,

l PILGRIM STATION l

l Docket No. 50-309 1

REGULATORY PERFCRMANCE HISTORY A tabulation of significant milestones and enforceme-t actions 4

49 O

O e

p 9

e l

l i

l l

c-1 l

j aune 17" ..- Issued operating license. .

Jecemcer 1973 Shutdown Order issued to inspect for and re-pair fuel channel box damage.

December 1974 Fuel failure: Hydriding and pellet-clad interaction failures resulted in high gaseous activity. Operation with the fuel cladding perforations reJulted in high dose rates in locations requiring access for I operation and mairtenance. Curing 1975, 76 and 77, power was imited between 60-80% to maintain offgas a .ivity within regulatory requirements. Tha last of the defective fuel bundles was replaced during the 1977 refueling outage.

May 1975 A civil penalty ($12,000) was assessed for violations concerning Inservice Inspection activities identified during an inspecti6n , ~ '

conducted December 1974 - February 1975.

r July 1976 Management meeting to discuss concerns related to the management and implementation of the Fealth Physics Program.

4 October 1976 Management neeting to discuss concerns related to management and implementation of-the Health Physics Program.

November 1977 Management meeting to review licensee efforts to strengthen Radiation Protection Program.

March 1978 A civil penalty (516,C00) was assessed for violations identified in inscection report 50-293/77-31. The violations were: over-exposure of cne individual; failure to in-struct personnel in accordance witn 10 CFR 19; failure to perforn required air sampling; and failure to follow procedures.

September 1978 Management meeting to discuss cencerns on recent inspecticn findings (all areas).

September 1979 , Management meeting to discuss violation of primary containment integrity.

' October 1979 A civil penalty (55,000) was assessed for a violation identified in inspection recort 50-293/79-15 involving a failure to follow the Security Plan.

C-2  !

. s

Meary Lid 0 ~~

A civil penalty (55,000) was assesseo for shippirig radioactive materials with external radiation levels in excess of regulatory l imi ts .-

March 1981 (SALP) Management meeting to discuss the results of the SALP for the period January 1,1980 to December 31, 1980.

April 1981 A civil penalty ($13,000) was assessed for events surrounding movement of irradiated l fuel without secondary containment as identified in inspection report 50-293/80-09, i ! July 1981 A management meeting was held in July 1981 .to discuss concerns for TMI Action Plan Items involving post accident sampling procedures and equipment and an Immediate Action Letter was issued regarding implementation of these items. Meeting was prcmpted by a' June 1981 -

radiation protection inspection ,

(50-293/81-14) found the licensee failed to

, conform with NRC criteria in connection with 4 of the 5 NUREG-0578 Category A items inspected.

Jure - September 1981 Inspections 50-293/81-18 and 81-22 identified six problems; inoperable combustible gas control system; failure to perform an adequate 50.59 review; failure to provide

, appropriate procedures and drawings; failure to make a report required by Technical Specifications; failure to provide accurate information to NRC; and failure to satisfy an Limiting Condition for Operation (LCO) regarding primary containment isolation valves. Trese inspections were subsequently the subject of enfcccement actions taken in January 1982.

July - August 1981 A Performance Appraisal Inspection (50-293/

81-20) found 6 of 8 areas examined below average. These were: committee activities; quality assurance audits; maintenance; corrective action systems; licensed and non-licensed training; and procurement. Plant operaticns and de-'gn changes and modifica-tions were found to be average; hcwever, significant weaknesses were identified in botn areas.

C-3

1 l

. :: cur E -

Enforcement conference to discuss man'agement controts of safety related activities in-cluding the violations identified during inspections 50-293/81-18 and 81-22, the Performance Appraisal Inspection results, and an interim SALP review (period

. September 1, 1980 - August 31,1981).

January 1982 Civil penalty (5550,000) assessed for..

failure to comply with requirements of 10 CFR 50.44; submittal of. false informa;f on to NRC and subsequent delay of notification to NRC of known inaccurate information; and failure to ccmply with LCO for RCIC containment isolation valves.

(PIP) s Order modifying ifcense required ifcensee to submit a comprehensive plan of action that would yield an independent appraisal.of. site '

and corporate management, reccmmendations-for improvements in management controls and oversight, and a review of previous com- ,

pliance with NRC requirements. -

Management meeting to discuss implement i ng requi: ements of the NOV/ proposed civil penalty and order modifying license regarding the independent appraisal of .

Easton Edison Cemcany (SECo) management practices.

' January 1982 Inspection report 50-293/81-25 identified a severity level III violation for transporta-tion of radioactive materials with liquid in l

the containers. This violation was based on i

an inspec ticn in August 1981 by the State of South Carolina which resulted in issua.7ce of a civil penalty (11,C00).

March 1932 Easton Edison Ccreany (SEco) submitted the Derformance Improvement Program (PIP) required by the January 1982 Order.

NRC Management meetings to review status or the Performance Improvement Program were held approximate.ly every six weeks until September 1984 l .

l i

C 'e e

.Sne 1982 A special inspection (50-293/82 'c0) conducted

~-

of licensee actions after radioactive spent resin was found on roof tops and pavement within the protected area. No violations identified. Confirmatory Action Letter issued concerning actions to be taken regarding the spent resin.

July 1982 Enforcement Conference to discuss exceeding an LCO associated with the Reactor Protection System water level instrumentation.

August 1982 Enforcement Conference to discuss exceeding an LCO associated with the Vacuum Breaker Alarm System. .

September 1982 (SALP) Management meeting to discuss the results of the SALP for the period September 1,s198L to -

June 30, 1982. ,

August 1983 A shutdown order was issued requiring the ,

licensee to shutdcwn in December 1983 and

. , inspect the recirculation' system piping for Intergranular Stress Corrosion Cracking. Ic required then to remain in cold shutdown until authorized to restart by the Director of NRR. The licensee replaced the ,

recirculation system piping and was authorized to restart in December 1984 September 1983(SALP) Management meeting to discuss the results'of the SALP for the period July 1,1982 to June 30, 1983.

. November 1983 Management meeting to discuss refueling / pipe i replacement preparations.

January 1984 Ccnfirmatory Action Letter issuec regarding licensee acticns relative to health pnysics practices following the discovery of small, highly radioactive sources in the centrol rod drive repair room.

February 1984 Enforcement conference regarding the uncen-trolled handling of small, hignly radioactive sources in the control rod drive repair rocm.

C-5 e

Apr4, 198a A ;ivil penalty (S40,000) wa5 assessed for

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problems in connection with the uncontrolled handling of small, highly radioactive sources in the control rod drive repair room between January 14 and 18, 1984. The violation involved identified problems with the labeling of containers, the use of extremity dosimetry, and the adequacy of 1 instructions given to individuals working in the repair room.

September 1984 Management meeting to discuss a second instance of the uncontrolled presence af small, highly radioactive sources in the control rod drive repair room.

October 1984 Enforcement conference on the unplanned ex-tremity exposure (within regulatory limits) connected with the small, highly r'adioactive sources in the control rod drive repair -

room. (Follow-up to September 1984 -

management meeting on same subject) .

Confirmatory Action Letter issued in connection with recurring radiation -

protection program weaknesses. The letter cutlined licensee plans for evaluating and correcting these weaknesses. ..

November 1984 An order modifying the license was issued in connection with recurring weaknesses in the radiation protection program. The order re-ouired the licensee to complete an independent contractor assessment of the radiological controls program and to submit to NRC review and approval a Radiological Improvement Plan (RIP) for upgrading the radiological controls program. Followup inspections ccnducted in May, August, and November 1985 and April 1986.

A Severity Level III violation (no civil penalty) was issued for failure to perform radiation surveys; failure to instruct  !

workers in acccedance with 10 CFR 19; and l failure to properly impleren: a procedure in connection with the unplanned exposure noted above.

Enforcement conference to discuss weaknesses ,

in the control and monitoring of neutron in-  !

strumentazion during refueling operations. l C-6 O

Jan arv .?55 .; 3A _J)

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Management meeting to discuss the results' of the SALP for the period July 1,1983 to September 30, 1984 Enforcement conference to discuss an unplanned occupational radiation exposure within regulatory limits associated with sludge-lancing operations on a waste tank as identified in inspection 50-293/84-44 August 1985 Enforcement conference to discuss licensee's action on abnormal surveillance test results and a degraded vital area barrier.

October 1985 A civil penalty (550,000) was assessed for the degradation of a vital area barrier.

November 1985 A safety system functional team inspection (50-293/85-30) was conducted by the Office of Inspection and Enforcement to assess' the operational readiness and function of 1

selected safety systems. The inspecticn .

identified that the licensee had not effectively mitigated a water hammer problem associated with the HPCI turbine exhaust line which had been occurring since the

. beginrting_o f_plartt_oge ra tion. Weaknesses were also identified with tha licensee's -

design cha~nge process; control of plant instrumentation; handling of vendor informa-tion; program for approving and validating emergency operating procedures; capability to conduct a plant shutdown from outside the cartrol rocm; snd maintenance program for motor operated valves.

February 1986 Inspection report 50-293/86-02 identified a severity level III violation for failure to meet packaging recuirements for low specific activity radioactive materials. This vioia-tion was based on an inspection in January

, 1986 by the State of South Carolina which resulted in issuance of a civil penalty (51,000).

f C-7 6

a r t., 955 (SALP). Management meeting to discuss the resbits of she SAtP for the period October 1,1984 -

October 31, 1985.

February - March 1986 A special diagnostic team inspection (50-293/

86-06) was conducted to determine the under-lying reasons for the licensee's poor performance described in the most recent SALP and to ascertain whether they could have an adverse impact on the safety of plant operations.

April 1986 An Augmented Inspection Team (AIT) conducted an inspection of recent cperational events which included 1) the spurious group one primary containment isolations (and associated reactor scrams) that occurred on April 4 and 12,1986, 2) the failure of the main steam isolation valves to promptly. '

reopen after the containment isolations, .and

3) the recurring pressurizations' of the -

residual heat removal system. The AIT found the licensee's evaluations following the

, , second event to be carefully structured and thorough. A Confirmatory Action Letter concerning the events was issued which required the licensee to provide a written report prior to restert containing the .

results of the evaluation and corrective actions. The CAL also required Regional

. Administrator authorization for restart.

Inspection (50-293/86-10) reviewed implementation of the RIP. The inspection found the licensee adequately addressed 13 of the 34 items reviewed.

May 1986 Management meeting to discuss evaluations and corrective actions concerning the operational events of April 4 and 12,1986.

June'1986 The first in a planned series of management meetings scheduled to review SECo management oversight of the implementation of the licensee improvement programs in progress.

C-8 e * -

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Descriotion of Imorovement Program I. Performance Improvement Program (PIP) a) Required by Order in January 1982 l

b) Areas for Improvement

1) Independent Review and Evaluation (MAC) 1

2) Organization Review / Revision

3) Management Control System Review / Revision

4) Training on Changes c) 125 milestones established

- examples - Procedure Update Program I (660 procedures)

- Update Design Documents Program -

(450 drawings) ,

d) Status - Complete .

Licensee- QA verification of final commitment performe'd October 1985.

II. Radiological Imorovement Prcoram a) Required by Order in November 1984 -

b) Areas for Improvement

1) Independent Assessment of Program

2) Radiological Organization Review / Revision

3) Radiological Controls Review / Revision

4) Management Oversig.'it and Corrective Actions

5) Training on Changes c) 209 Milestones Established As of December 1985 ene item remains open (reconfigure access control)

III. Continuous Improvement Program a) Initiated by BECo in June 1985 b) Actions

1) Visited plants with good SALP evaluations

2) Conducted internal survey to identify problems /cause

3) Issued report of findings in December 1985 C-9

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, 'reble m 4-eas Identified

1) Attitude

2) Accountability

3) Weak Root Cause Analysis

4) Communication .

5) Effectiveness Assessment d) Status Implementation of sixteen of eighteen recommendations in pregress k

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PETITIQi FOR SHOT CAUSE CQlCERNING PILGRIM-I NUCLEAR PGJER STATIOi k '

SUBMITTED JULY 15, 1986 SIGNATCRIES Signed:

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-d Name: William B. Golden Affiliation: Massachusetts State Senator Address: State House, Boston, .% 02133 Signed: //3**/< O A- - At.e v

~ ..U Name: yg AA*/C j% /-/ 7dej Affiliation: f77/74- eJde 0 Address: State House, Boston, MA 02133 Signed: . /

Name: Barbara A. Hildt Affiliation: Massachusetts State Representative Address: State House, Boston, MA 02133 1

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l Signed:

Name: J. Rachel Shimshak Affiliation: Massachusetts Public Interest Research Group (MASSPIRG)

Address: 29 Temple Pla::e, Boston, MA 02111

PETITIm FCR SHCW CAUSE CWCERNING

--- PILGPIM-I NUCLEAR PGiER STATICH SUBMITTED JULY 15, 1986

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SIGNATCRIES 3 .

Signed: 84G '

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Name: Joaty . Barry, Co-chairperson Affiliation: Pilgrim Alliance Address: 20 Alden St, Plymouth, MA 02360 Signed:

i Name: Gail H. Reed Affiliation: Co-chairperson, Pilgrim Alliance Address: Pilgrim Alliance, 93 Ellisville Rd, Plymouth, MA 02360

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' -IA Name: Mindy S. Lubber, Esquire Affiliation: ssachusetts Public Interest Research Group (MASSPIRG)

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Address: 29 Temple Place, Boston, MA 02111 Signed:

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PETITION FOR SHOW CAUSE CONCERNING

... PILGRIM I NUCLEAR POWER STATION SUEMITTED JULY 15, 1986 SIGNATORIES

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Signed: LL U.-w h 7 E/

William S. Abbott, President Plymouth County Nuclear Information Committee, Inc.

50 Congress Street Boston, Massachusetts 02109

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James M. Shannon Affiliation: Massachusetts Citizen and Candidate for Attorney General Address: 462 Boylston Street Boston, Massachusetts 02116 Signed:

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PETITION FOR SHOV CAUSE CONCERNING PILGRIM-I NUCLEAR POWER STATION SUBMITTED JULY 15. 1986 SIGNATORIES Signed: Michael Mariotte -

Name: Michael Mariotte, Editor Affiliation: Nuclear Information and Resource Service Address: 1616 P St NW, Suite 160, Washington, DC 20036 Signed: Richard Parrish Name: Richard Parrish, Staff Attorney Affiliation: Environmental Task Force Address: 1012 14th St NW, Washington, DC 20005 Signed: Jane Parker Name: Jane Parker Affiliation: Lower Cape Citizens for Peaceful Alternatives Address: PO Box 573, Touro, MA 02666 Signed: Steohen cook Name: Stephen Cook, Spokesperson Affiliation: Mass. Safe Energy Alliance, Greater New Bedford Office Address: 106 Jenny Lind St, New Bedford, MA 02740

PETITION FOR SHOW CAtJRE CONCERNING ,

PfLGRTM-f NUELEAR POWER STATION

... SUBMITTED JULY 15. 1986 SIGNATORIES Signed: Bob French '

Name: Bob French, Spokesperson Affiliation: Greater New Bedford Jobs for Peace Address: 83 Durfee St, New Bedford, MA 02740 t

Signed: Anna Gracia Name: Anna Gracia, Publicity Chairperson Affiliation: Greater New Bedford Area Nuclear Weapons Freeze Group Address: Friends Meeting House, 83 Spring St, New Bedford, MA 02740 Signed: Geraldine Gamburd i

Name: Geraldine Gamburd, Coordinator l l

Affiliation: Human Ecology Center of South Eastern Massachusetts University Address: Old Westport Rd, North Dartmouth, MA J02747 4

Signed: Pat Granahan ~

Name: Pat Granahan, Chairperson Affiliation: Responsible Energy Alternative Coalition of Hingham Address: 36 Croyden Rd, Hingham, MA 02043

PETITI G FOR SH W CAUSE CCriCERNING

._ PILCRIld-I NUCLEAR PGiER STATION SUBMITTED JULY 15. 1986 SIGNATCRIES Signed: fearv Louie  !

., Name: Mary Louie, Chairperson Rffiliation: Boston Rainbow Coaliticn Address: 431 Cc. lumbus, 3oston, MA 02116 Signed: Susan Fernandez Viame: Susan Fernandez, Spokesperson Affiliation: Keep Freetown Hazard Free Address: 35 County Rd, East. Freetown, MA 02717 4

l Signed: Jack Oliver

. Name: Jack Cliver, President Affiliation: Coalition of Vietnam Veterans Address: 181 Hillcian St, New Bedford, MA 02740

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SHOW CAUSE petition with the Nuclear Regulatory Commission concerning the pilgrim nuclear plant in plymouth, MA The Show Cause petition will ask that the NRC suspend Pilgrim's license until Edison and the NRC can demonstrate that the follcwing issuas have been resolved. The areas are

a. Mismanagement D. Structural problems wit:' containment

c. Radiological controls

d. Evacuation plans i

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PETITIQi FOR SHGI CAUSE CONCERNING PILGRI!!-I NUCLEAR PGER STATIGl SUBMITTED JULY 15, 1986 SIGNATCRTES Signed: d[ I RMb Name: $2 RTCR dACK N.bECZ.M.*N Affiliation: M W. 6TST$ $ WSID Address: R C O M 2. 1 3 8 5 TATS Hco.::s Ses rc 9., M A. 02:33 ll /' ] , y  :'

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... PILGRIM-I NUCLEAR PGlER STATICtl SUBMITTED JULY 15, 1986 SIGNATCRTES Signed: , .

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PILGRIM-I NUCLEAR PGlER STATIOl SUBMITTED JULY 15, 1986 SIGNATORTES r

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PILGRIM-I NUCLEAR PGER STATICH SUBMITTED JULY 15, 1986 SIGNATCRIES Signed. kUl $AA t .. O Name: frcmces f {exanclet'

!   Affiliation: Mo S S. Sto fd NP-l                                                                                                                                                       '

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PILGRIM-I NUCLEAR POJER STATIQi SUBMITTED JULY 15, 1986 SIGNATORIES Signed: &M - MM " 3 Name: Scoert f Iahab@'C2 Affiliaticn: frb55 8/(d6 3FP Address: Sfo /< Hcuse' Rm. Ibb ksrto,MA. OQI33 Signed ( kgf[ bl , tb [#M Na:e: S u m (a (' g m Affiliation: Mc,55 STG f C IW P-Address: $ mfg HCU5d Ber7 IJ7

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PETITIOi FOR SHGi CAUSE CCNCERNING

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PII. GRIM-I NUCLEAR PGlER STATIQi SUBMITTED JULY 15, 1986 SIGNATORIES h\ Signed: I - v - Na::1e : h wscl 3 Coht'n Affiliation: ,Q,ss. $7616 EcP-Address: S hia Hcuse

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Nane: fiorg Jeane#e Murruy Affiliation: g gs g ufe g p. Address: St ie Neuse kn. I 5i) kkn, MA. 03 \ 33 Signed: b . Na=e: Thenns f, &cwnell Affiliation: moss Sufc Lp, Address: Star 6 5e

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Name: 'Denos Lc.crence Affiliation: Acn Srcife Rep. Address: Sjn.fe ltese Rm. )@

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PETITIQI FOR SHC4 CAUSE CCNCERNING

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PILGRIM-I NUCLEAR PC4ER STATIQ1 SUBMITTED JULY 15, 1986 l i l SIGNATCRIES Signed: ( ' 0 f l Name: p),gnce; y, .Ggeynn l Affiliation: (Ybss Tnfe Rep Address: Sfore ga3e Rm. 2b Be<,fon, /n9. ca 3 3 l Signed M. C-[ /d +

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Name: 7Icfn C. Brodford Affiliation: /Yb55. Srste Bep. Address: 3 jg gg "Arn. 64 c' 3 c S /v o ,.'6 9 . C Q # 3 3 1 M. Signed: .

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y Name: Ifan (7)c' ac)b , Affiliation: mass 51o te Rep. Address: 3.g 9 ga,y Rm. I30 3cs ton , 'YM. CdI33

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Name: (nnStc pne t~ 3. Hctl 9lbn5 Affiliation: (%5. Stoft Bep. Address: $.fp.fe l-guyf

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PETITICN FOR SHGi CAUSE CCNCERNING ,

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PILGRIM-I NUCLEAR PGiER STATIQI SUBMITTED JULY 15, 1986 SIGNATORIES Signed: A_ --- - C

             /                                                   l Name:     Su za nne. M. Bump Affiliation: p kg). S g fe & p Address:         33 fe gg,.;c Pm. 40
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Signed: W Na:e: Q1(thfa $ Ggc a Affiliation: Mciss Srafe Ap. Address: 397, we

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Signed: 9 ' 7 e -

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Name: Gemen b Evell Affiliation: F%ss. 5 fate, &p. Address: 57afe ricv2e Rm. 22

            &$mn, N19. Cdi 3 3 f ..,l                ,

Signed: /'# M / i ha

                                              /

Name: -- Met h,rtg Affiliation: -- -

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PETITIQi FOR SHOi CAUSE CONCERNING

                      -._        PILGRIM-I NUCLEAR PGIER STATIOT SUBMITTED JULY 15, 1986 SIGNATCRTES
                                                                     ~                  l Signed:       NhD                kk7[4/\

g s Na:::e: [ ld4MCf M i.j C +~5C O Affiliation: Stafc Rep Address: $/afe, Hccid ~ 3m 90

              ~6es'      . M4. 04833 Signed:_      ,    ,

Na=e: Stepnen h) Doran Affiliation: M4SS Sta-fd 'EdP Address: $10fc McvSC - Brn. 47Q 3., Sten, MA. 00133 Signed: - 2 Na:e: Dr~. MIbarn CaldICCTY _ Affiliation: Address: 46 jsonard $l."

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o @ 30 Signed: . 4M . . , Name: 1)r Helen ColcIIcott . a Affiliation: Address: 45 ucmy 57, ' Cices ter, m'4 ., x .cM3D ..,

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