ML20245C326

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Forwards Draft Response to Util Request for Exercise Exemption.Author Supports Granting of Exemption Re Conduct of Full Participation Exercise in 1987
ML20245C326
Person / Time
Site: Pilgrim
Issue date: 10/26/1987
From: Congel F
Office of Nuclear Reactor Regulation
To: Varga S
Office of Nuclear Reactor Regulation
Shared Package
ML20244D847 List:
References
FOIA-88-198 NUDOCS 8904270115
Download: ML20245C326 (26)


Text

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k #js.n uog 'a UNITED STATES t 8' i NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555

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%, #,e October 26, 1987 Docket No. 50-293 MEMORANDUM FOR: Steven A. Varga, Director i i

Division of Reactor Projects-I/II Office of Nuclear Reactor Regulation ,

FROM: Frank J. Congel, Director Division of Radiation Protection and Emergency Preparedness, NRR

SUBJECT:

PILGRIM EXERCISE EXEMPTION REQUEST Enclosed is a draft response to the Boston Edison request for an exercise exemption for the Pilgrim Nuclear Power Station. Based on the good faith effort of the licensee to comply with the regulations and the extensive ongoing offsite emergency preparedness improvement efforts for Pilgrim, we support the granting of the exercise exemption regarding the conduct of a full participa-tion exercise in 1987.

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w Frank J. Congel, Director Division of Radiation Protection and Emergency Preparedness, NRR

Enclosure:

Pilgrim Exemption CONTACT: Rosemary T. Hogan, NRR 492-4866 8904270115 890419 PDR FOIA -

JOHNSON 88-198 PDR j

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  • Docket No. 50-293 Mr. Ralph G. Bird Senior Vice President-Nuclear Boston Edison Company 800 Boylston Street Boston, Massachusetts 02199

SUBJECT:

ISSUANCE OF EXEMPTION TO 10 CFR PART 50, APPENDIX E,

' SECTION IV.F.3 FOR THE PILGRIM NUCLEAR POWER STATION

Dear Mr. Bird:

The Nuclear Regulatory Consnission has granted the enclosed Exemption regarding the conduct of a full participation emergency preparedness exercise for the Pilgrim Nuclear Power Station in 1987. The Exemption was granted in response to your letter dated September 17, 1987.

We find that granting the Exemption is authorized by law, will not present an undue risk to the public health and safety, is consistent with the common de-fense and security, and meets the special circumstances described in 10 CFR 50.12(a)(2)(v).

The Exemption has been forwarded to the Office of the Federal Register for publication.

Sincerely, Steven A. Varga, Director Division of Reactor Projects-I/II Office of Nuclear Reactor Regulation

Enclosure:

Exemption cc w/ enclosure:

See next page

M a UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

'In the Matter of Boston Edison Company ) Docket No. 50-293 (Pilgrim Nuclear Power Station) )

EXEMPTION I.

Boston Edison Company (the licensee) is the holder of Facility Operating License No. DPR-35 which authorizes operation of Pilgrim Nuclear Power Station (the facility) at steady-state reactor power levels not in excess of M98 megawatts thermal. The license provides, among other things, that it is subject to all rules, regulations and Orders of the Nuclear Regulatory Commission (the Commission or NRC) now or hereafter in effect. The facility consists of a boiling water reactor located at the licensee's site - in Plymouth, Massachusetts.

II.

Section 50.54(q) of 1(; CFR Part 50 requires a licensee authorized to operate a nuclear power reactor to follow and maintain in effect emergency  ;

plans which meet the standards - of 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR Part 50. Section IV.F.3 of Appendix E requires that each licensee at each site shall exercise with offsite authorities such that the State and local government emergency plans for each operating i reactor ' site are exercised biennially with full or partial participation

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?-. 2 by States and local governments, within the plume exposure pathway Emergency Planning Zone (EPZ).

The NRC may grant exemptions from the requirements of the regulations which, pursuant to 10 CFR 50.12(a) are (1) authorized by law, will_ not present-i l

an undue r sk to _ the public health and safety, and are consistent with the y

common de.ense and security, and (2) present special circumsta1ces. Section 50.12(0)(2)(v) of 10 CFR describes the special circumstances in that the exemp-tion would provide only temporary relief from the applicable regulation and the -

licensee has made good faith efforts to comply with the regulation.

III.

By letter dated September 17, 1987, the licensee requested a one-time exemption from the schedular requirements of Section IV.F.3 of Appendix E.

The last biennial emergency preparedness exercise _ was a full participation exercise conducted at the Pfigrim Nuclear Power Station on September 5,1985.

The licensee requests that an exemption be granted to allow the next biennial exercise to be deferred from 1987 to the second quarter of 1988. The schedule for. future biennial exercises will not be affected by this one-time exemption (i.e., the following biennial exercise will be held in 1989).

The licensee states that the Commonwealth of Massachusetts, the local governments within the EPZ and the two emergency reception center communities

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are in the process, with the assistance of the licensee, of implementing numerous improvements in their offsite emergency preparedness programs. These improvements include revision of the emergency plans of the local governments and the Commonwealth, the development of associated procedures, the development and implementation of training programs for officials and emergency personnel, and the upgrading of Emergency Operation Centers. The licensee expects the work'to continue through early 1988. The licensee has informed the NRC that in view of these extensive ongoing efforts, the Commonwealth and the local govern-ments have indicated that they are not able to fully participate in an exercise during calendar year 1987. In addition, the licensee states that the proposed deferral has been discussed with the Commonwealth and local emergency response officials, and all of the parties have indicated that they support the proposal.

l The activities to upgrade offsite emergency planning and preparedness are in response' to a Federal Emergency Management Agency (FEMA) evaluation of the adequacy of offsite preparedness at Pilgrim. On September 5, 1986, FEMA informed the Commonwealth of Massachusetts that it was undertaking a self-initiated review of its September 29, 1982 Interim Finding on offsite i

emergency preparedness for the Pilgrim Nuclear Power Station because of concerns raised during meetings in the spring of 1986 and information received subsequent to those meetings from local officials, the Commonwealth, and other interested parties. Based on a review of the overall state of offsite L

i emergency preparedness for Pilgrim, FEMA concluded, in an Interim Finding )

issued on August 4, 1987, that offsite radiological emergency planning and l

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l preparedness for Massachusetts was inadequate to protect the health and safety l

of the public in the event of an accident at the Pilgrim Nuclear Power Station.

l The August 4,1987 Interim Finding superseded the previous finding of adequacy contained in the Interim Finding of September 29, 1982. l l

FEMA identified six areas of major concern during the course of its review:

- Lack of evacuation plans for public and private schools and daycare centers.

- Lack of a reception center for people evacuating to the north.

- Lack of identifiable public shelters for the beach population.

- Inadequate planning for the evacuation of the special needs population.

- Inadequate planning for the evacuation of the transport dependent population.

- Overall lack of progress in planning and apparent diminution in emergency preparedness.

Boston Edison is assisting the Commonwealth and the local authorities in the improvement of their emergency response programs. These efforts have included an updated evacuation time estimate study and traffic management plan, a study to identify public shelters for protecting the beach population, and the identification of and provision for the special needs and transportation dependent populations within the EPZ. In addition, the licensee is providing professional planners to assist the local governments and the Commonwealth in upgrading their plans and in the development of a new training program for off-site emergency response personnel. Some training has been conducted to date and training will continue after the development of the new training program has been completed.

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I 5-I Onsite emergency preparedness has been evaluated by the NRC during inspec- t tions and exercises including the most recent onsite exercise conducted on l

December 10, 1986. The 1986 exercise included partial participation by the Commonwealth. The inspection report for the 1986 exercise documented that 1

Boston Edison's emergency response actions were adequate to provide protective q measures for the health and safety of the public. The licensee has held quar-terly onsite drills in Ma rch , June and August 1987. The . NRC inspection findings and the licensee'.s training drills provide assurance that the licensee has maintained a satisfactory capability to respond to an emergency at Pilgrim.

In addition, the ifcensee has scheduled its annual onsite exercise for December 9,1987 which will test the current level of onsite emergency pre- I paredness at the Pilgrim station. The licensee states that this exercise will also include limited participation by the Commonwealth.

Since the last full participation biennial exercise at Pilgrim (in September 1985), the Commonwealth has participated on a limited basis with the licensee in the December 1986 exercise and the quarterly onsite drills in 1987. The March and June 1987 drills also included ifmited participation by several of the towns within the EPZ. The towns within the EPZ have also cooperated in the full scale siren test conducted by FEMA in September 1986.

The Commonwealth has also participated in full participation exercises at the Yankee Nuclear Power Station in June 1986 and is scheduled to participate in a full participation exercise at the Vermont Yankee Nuclear Generating Station during the week of November 29, 1987.

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IV.

The requested exemption is a temporary one and is necessary because ongoing.

emergency preparedness efforts will not be completed before early 1988. The licensee has made a good faith effort to comply with the regulation by assisting f in the ongoing improvements to the Commonwealth and local offsite emergency.

response programs. The extensive efforts required to upgrade the offsite' plans, implement the changes and conduct training preclude the conduct of a meaningful and effective full participation exercise in 1987. This situation constitutes the special circumstances described in 10 CFR 50.12(a)(2)(v). Further, the NRC staff believes that the public health and safety will be better served by the

-conduct of ~a full participation exercise following the completion of efforts to improve the Commonwealth and local government emergency response programs.

The Comission has thus determined that, pursuant to 10 CFR 50.12, the exemption requested by the licensee's letter dated September 17, 1987, as discussed above, is authorized by law, will not present an undue risk to the public health and safety, and is consistent with the common defense and security.

Accordingly, the Commission hereby approves the following exemption:

"The Pilgrim Nuclear Power Station is exempt from the requirements of 10 CFR 50, Appendix E, Section IV.F.3 for the conduct of an offsite full par-ticipation emergency preparedness exercise in calendar year 1987."

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7-Pursuant to 10 CFR 51.32, the Consnission has determined that the granting of this Exemption will have no significant impact on the environment

( FR ). This Exemption is effective upon issuance.

Dated at Bethesda, Maryland this day of October 1987.

FOR THE NUCLEAR REGULATORY COMMISSION Steven A. Varga, Director Division of Reactor Projects - I/II Office of Nuclear Reactor Reactor

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l 3 Pilgrim - Activities Update - 10/28/87 '

l On October 27, 1987 NRC filed a Motion to Dismiss State Senator Golden's Appeal of October 1,1987 (Senator Golden's Appeal requested NRC to suspend Pilgrim's operating license until safety and emergency planning concerns are  !

resolved). The NRC Motion, filed in the U.S. Court of Appeals,1st Circuit, )

is based on grounds that the Court lacks , jurisdiction on the NRC refusal to  !

take enforcement action (i.e. The Director's Decision of August 21, 1987 in l Response to Senator Golden's 2.206 Petition of .luly 15, 1987). 0GC will also file within a few days a Motion to Dismiss the Commonwealth of Massachusetts' Motion for Leave to Intervene in Senator Golden's Appeal.

In response to the Town Selectmen's request, the NRC will attend a public.

meeting in Duxbury, MA on October 29, 1987 to respond to public questions regarding Pilgrim (Staff participants include W. Kane, S. Collins. T. Martin of Region I and B. Boger of NRR). Commonwealth and BECo representatives also plan to participate. Senator Golden, a representative of Congressman Studd's office and other local officials will also participate.

The NRC Restart Panel will meet at the Pilgrim site on October 29, 1987 to I discuss coordination of staff activities regarding Pilgrim. l On October 26, 1987 Boston Edison signed the submittal of Part II of their Restart Plan, including Appendices. Copies are not yet available in Pashington, Staff work and OGC review continues on the BECo request of September 17, 1987 for a one time schedular exemption from the requirement to complete the biennial emergency preparedness exercise by December 31, 1987 Staff work has commenced on the response to the October 15, 1987 10 CFR 2.?06 Petition from the Massachusetts Governor and Attorney General. Petitioners request an order to show cause why the Pilgrim Nuclear Power Plant should nnt remain closed until a full adjudicatory hearing resnives the issues identified in the Petition.

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' NOVEMBER 1987 OVERVIEW REPORT PLANT NAME: PILGRIM PROJECT MANAGER: R. H. UESSMAN l

MONTHLY OPERAT!0NAL OVERVIEW FOR NOVEMBER 1987 The plant continues to be down for an extended outage for refuelino, ru olution of equipment and operational difficulties, management issues and eneroency planning concerns Core reload completed 10/14/87.

Restart readiness expected early 1987 Monthlv Licensing Action Sumary:

l' TRIPS THIS MONTH 0 TRIPS LAST 12 MONTHS 0 NUMBER OF REPORTABLE EVENTS 0 LICENSING ACTIONS TYPE CATEGORY 1 CATEGORY 2 CATEGORY 3 TOTAL 0 1 0 3 Licensing Actions Opened in 11/87 (Pro.iected Categories) 0 0 4 Licensing Actions Closed in 11/87 0 Licensing Actions in Progress 0 0 0 T (Nov.30 1987)

Licensing Actions Returned (Cat 1) in 11/87 0 For Applications received prior to 9/4/87 Number under review by PM n Number reviewed and completed by PM 0 SIGNIFICANT ISSUES AND EVENTS Significant Activities During November 1987 On November 9, 1987 Ralph Bird (Senior Vice President - Nuclear) issued a stop work order for maintenance and modification activities at Pilgrim. This was in response to his determination that the BEco standards of excellence were not being met by onsite personnel as indicated by several incidents occurring over the previous weekend. These incidents include (1) taped over lock on a high radiation area door on the refueling floor; (2) the removal of ductwork by maintenance personnel that would have led to a breech in a vital area barrier; (3) a small radioactive spill caused, in part, by the installation of a RHR valve (part of Safety Enhancement Program modification to provide cross-connect between RHR and fire water systems) without any packino; and (4) a missed RPS surveillance. None of these incidents appear to have resulted in an actual event with safety consequences nor does there appear to be any direct linkage between the incidents. BEco is evaluating the incidents and is gradually returning craft personnel to work.

Staff work and OGC review is complete on the BEco request of September 17, 1987 for a one time schedular exemption from the requirement to complete the biennial emergency preparedness exercise by December 31, 1987 The exemption should be issued in early December.

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Events At 2:05 a.n. on 11/12/87, Pilgrim experienced a comolete loss of offsite power. At the time of the event, the plant was shutdown, with the reactor refueled and reactor vessel reassembled, and power supplied through the startup transformer. Both Emergency Diesel Generators started automatically i

and picked up the safety related buses. The cause of the loss of offsite pnwer appears to be associated with switchyard icing due to adverse weather l conditions.

Power was not restored until about 11 p.m. Novemt *r 17, 1987. NRC conducted an Augmented inspection Team of the event on Nnve,aber 16-20, 1987, and a report is expected by mid-December. Initial conclusions indicate no ma;for licencee shortcomings or significant generic implications.

Significant Meetings Scheduled Durina December 1987 (NRR, Recion, etc.)

The Pilgrim Restart Assessment Panel will meet at the site on December 8, 1987 to discuss sterf coordination of technical reviews and inspections.

BECo will meet with the staff in Bethesda on December 10, 1987 to discuss their Emergency Operating Procedures upgrade program.

BECo plans to hold a " partial participation" Emergency Planning Exercise on December 9, 1987. Headquarters and Region I will observe.

Items for Mar,acement Attention Pilgrim readiness for restart remains uncertain. The Stop Work Action of November 9 and loss of offsite power event of November 12 have induced delays. Staff estimates RCS hydro will be conducted in mid-December and the ILRT will be conducted after January 1.

On November 16, 1987 Clay Warren assumed responsibility as Senior Resident Inspector. (Jeff 1.ynch and Tae Kim continue as residents).

NRR and BEco met on 11/24/87 to discuss a number of Fire Protection issues.

One area of concern which was ice.itified was the fact that no reviewer resources have been assioned on exemption requests 15, 18 and 22 (TAC No. 65962). All fire protection issues (4 out of 10 Restart TAC Numbers) have been designated as Restart Items because of BECo's performance in this area. NRC will determine whether these specific exemption requests should be considered Restart Items, and if so, will seek the assignment of higher review priority.

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Status of Items Previously Identified for Management Attention G, Requa, Project Engineer fron PDII-I, continues to be inaned on a part-time basis to the Pilgrim Project team to assist with the licensing workload.

Owen Gormley returns to Nuclear Regulatory Research after serving for the month of November to assist on Pilgrim tasks.

Next Scheduled Refuelino Outage ,

I February 1989 cc: R;-Wessman PDI-3 R/F M. Rushbrook V. Rooney E. Adensam J. Wilson, Research e

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Pilgrim - Activities Update - 11 /04/87 \

In response to the Town Selectmen's request, the NRC attended a public meeting MA on October 29, 1987 to respond to public questions regarding in Duxbury[ Staff participants included S. Collins, R. Bellamy and J. Wiggins of Pilgrim.

Region I and B. Boger of NRR). Connonwealth and BECo representatives, State Senator Golden, Citizen Urging Responsible Energy (CURE), and other local officials also participated. The general tone of the meeting reflected opposition to plant restart until safety and emergency planning issues are resolved.

The NRC Restart Panel met at the Pilgrim site on October 29, 1987 to discuss coordination of staff activities regarding Pilgrim.

The staff has received the BECo Revision to Volume II of the Restart Plan.

Initial staff review is in progress.

Staff work and OGC review continues on the BECo request of September 17, 1987 for a one time schedular exemption from the requirement to complete the ,

biennial emergency preparedness exercise by December 31, 1987  !

Staff work has commenced on the response to the October 15, 1987, 10 CFR 2.206 Petition from the Massachusetts Governor and Attorney General. Petitioners request an order to show cause why the Pilgrim Nuclear Power Plant should not l remain closed until a full adjudicatory hearing resolves the issues identified in the Petition.

NRP issued 3 amendments to t..< ".igrim license during the week ending October 30, 1987 They involved minor technical specification changes for undervoltage relays, HPCI/RCIC operability requirements and reactor pressure transmitter '

surveillance.

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As ."7 Pilgrim - Activities Update - 11/10/87 )

1 On Novamber 9,1987 Ralph Bird (Senior Vice President - Nuclear) issued a stop  !

work order for maintenance and modification activities at Pilgrim. This was

! in response to his determination that the BEco standards of excellence were not >

being net by onsite personnel as indicated by several incidents occurring over f the weekend. These incidents include (1) minor contamination of several individuals during chemical waste pump maintenance; (2) taped o'!er lock on a )

high radiction area door on the refueling floor; (3) the removal of ductwork by maintenance personnel that would have led to a breech in a vital area barrier; (4) a small radioactive spill and personnel contamination caused, in part, by the installation of a RHR valve (part of Safety Enhancement Program modification to provide cross-connect between RHR and fire water systems) without any packing; (5) a missed RPS surveillance; and (6) several other minor area contamination incidents. None of these incidents appear to have resulted in an actual event with safety consequences nor does there appear to be any direct linkage between the incidents. BEco management has sent GE and Bechtel craft personnel home until Thursday. BECo is evaluating the incidents and developing an action plan to deal with these issues. The resident inspectors are 1ollowing the licensee's actions.

On November 5,1987 OGC filed a Motion to Disniss the Connnwealth of Massachusetts as a party to the proceeding between Massachusetts Public Interest Research Group (MASSPIRG), et al and the NRC. This proceeding was instituted October 1, 1987, by State Senator Hilliam Golden's appeal in the U.S. Court of Appeals, 1st Circuit. Golden, MASSPIRG, et al are seeking ,iudicial relief to the Director's Decision of August 21, 1987 regarding Pilgrim management, containment and emergency preparedness issues, and Massachusetts sought admittance before the Court on October ?, 1987.

Staff work and OGC review continues on the BEco request of September 17, 1987 for a one time schedular exemption from the requirement to complete the biennial emergency preparedness exercise by December 31, 1987.

Staff work continues on the response to the October 15, 1987, 10 CFR 2.706 Petition from the Massachusetts Governor and Attorney General. Petitioners request an order to show cause why the Pilgrim Nuclear Power Plant should not remain closed until a full adjudicatory hearing resolves the issues identified in the Petition.

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RESTART STATUS 11/13/87 LICENSEE RESTART ACTION ASSESSMENT COMMISSION RESTART PLANT SHUTDOWN PLAN REPORT ' BRIEFING DECISION Pilgrim 0A/12/86 10/26/87C 01/29/88E 02/12/88E 02/26/88E COMMENTS: RCS HYDRO IS EXPECTED IN LATE NOVEMBER AND ILRT IS EXPECTED IN EARLY DECEMBER. BECO IS STILL FORECASTING COMPLETION OF MOST OUTAGE ACTIVITIES BY DECEMBER. LOSS OF 0FFSITE POWER EVENT (11/12/87) AND STOP WORK ACTION (11/09/87) MAY DELAY COMPLETION OF ONSITE ACTIVITIES.

1NITIAL REVIEW OF BECO RESTART PLAN IS IN PROGRESS AND IS EXPECTED TO TAKE UNTIL MID-DECEMBER. INTEGRATED TEAM ASSESSMENT OF UTILITY READINESS IS PLANNED FOR EARLY JANUARY 1988.

RESOLUTION OF 0FFSITE EMERGENCY PREPAREDNESS ISSUES EXPECTED TO BE A MAJOR ISSUE. COMPLETION OF IMPROVED LOCAL PLANS IS NOT EXPECTED BEFORE 12/31/87. SUBMITTAL DATE OF COMMONWEALTH EMERGENCY PREPAREDNESS PLANS TO FEMA IS UNKNOWN. BECO HAS RE00ESTED AN EXEMPTION FROM THE BIENNIAL EP EXERCISE (REOUIRED BY 17/31/A7) UNTIL EARLY 1988. ,

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Pilgrim 0/ 11r/97 At 2:10 a.m. on 11/12/87, Pilgrim experienced a complete loss of offsite power. At the tine of the event, the plant was . shut down, with the reactor refueled and reactor vessel reassembled, and power supplied through the startup transformer. Both Energency Diesel Generators started automatically and picked up the safety related buses. The cause of the loss of offsite power appeared to be associated with switchyard icing due to an ongoing snow storm. Shutdown cooling was restored in approximately twenty minutes; however, it is not needed due to extremely low decay heat loads.

Reactor coolant temperature dropped from 183*F to 90'F during the event. All safety systens appea*"ed to have functioned as designed following the loss of power. The Commonwealth of Massachusetts Civil Defense agency was notified by NRC:RI at 5:25 a.m. The resident inspector responded to the site and Region I partially manned the Incident Response. Center at 4:40 a.m.

At 11:48 a.m., operations personnel shut down the 'B' Emergency Diesel Generator due to a problem with the 'C' phase current transformer. This resulted in loss of the only operable air compressor and another shutdown cooling isolation.

However, reactor coolant temperature remained stable due to the extremely low decay heat loads. By 3:00 p.m. weather conditions had improved and portions of the switchyard ring header had been re-energized from both incoming offsite power lines. At around 11:15 p.m. 11/1?/87, offsite power wss re-established to vital and non-vital buses via back-feeding through the main and auxiliary transformers. As of 7:00 a.m. 11/13/87, the A Emergency Diesel Generator (EDG) was still running supplying power to its associated vital bus and the B EDG was being prepared for testing. Thus far, the licensee has identified no equipment damage associated with the loss of power. The loss of power on 11/12/87 is still believed to have been associated with icing in the switchyard, however some anomalies associated with offsite power supply have been noted and may be associated with motion of ice laden lines in the wind.

A temporary air cormressor has been noved onsite and is available to tie into the plant air system to provide a backup to the installed essential and nonessential plant systems as required.

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. l In response to the Loss of Offsite Power event on November 12, 1987, the NRC has dispatched an Augmented Inspection Team to Pilgrim Station to commence an inspection on November 15, 1987. The Conrnonwealth of Massachusetts has been informed. The inspection will focus on the sequence of events and the

licensee's response. Further, the Team will assess if a vulnerability exists

! in the Pilgrim Station design for loss of offsite power events. The team is expected to be onsite November 15-20, 1987. The team will also meet at Region I during the week of November 22-27. The full time participation of the NP.R PM in these two weeks of activit.y will delay other ongoing actions such as the NRR Response to the Mass. 2.206 Petition ard essential licensing actions.

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Pilgrim y[2.5/fg3 The Augmented Inspection Team is meeting this week at Region I to develop its report on its investigation of the recent loss of offsite power event. The Project Manager is continuing his -full time participation in this activity.

NRR and BEco met on 11/24/87 to disc:iss a num',er of Fire Protection issues.

One area of concern which was identified was the fact that no reviewer resources have been assigned on exemption requests 15, 18 and 22 (TAC 'No. 65962).

All fire protection issues have been designated as Restart Items because of BEco's performance in this area. NRC will determine whether these specific exemption requests should be considered Restart Items, and if so, will seek the assignment of higher review priority.

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RESTART STATUS 1, . - o/g/g7 1

LICENSEE RESTART l '

ACTION ASSESS.J.NT _ COMMISSION RESTART PLANT SHUTDOWN PLAN REPORT BRIEFING DECISION PILGRIM 04/12/86)I;'191 10/26/87C 01/29/88E 02/12/88E 02/26/88E XPECTEDpIN.. un,sjyki.LM49 lCl::":". AND ILRT IS EXPECTEDIJ& IN N COMMENTS: RCS HYDRO IS DECEMBER. O IS STILL FORECASTING COMPLETION OF MOST OUTAGE ACTIVITIES  !

BY DECEMBE LOSS OF 0FFSITE POWER EVENT (11/12/87) AND STOP WORK ACTION (11/09/87) Y DELAY COMPLETION OF ONSITE ACTIVITIES.

INITIAL REVIEW 0F BECO RESTART PLAN IS IN PROGRESS AND IS EXPECTED TO TAKE UNTIL MID-DECEMBER. INTEGRATED TEAM ASSESSMENT OF UTILITY READINESS IS PLANNED FOR EARLY JANUARY 1988.

RESOLUTION OF OFFSITE EMERGENCY PREPAREDNESS ISSUES EXPECTED TO BE A MAJOR ISSUE. COMPLETION OF IMPROVED LOCAL PLANS IS NOT EXPECTED BEFORE 12/31/87. SUBMITTAL DATE OF COMMONWEALTH EMERGENCY PREPAREDNESS PLANS TO FEMA IS UNKNOWN. BEC0 HAS REQUESTED AN EXEMPTION FROM THE BIENNIAL EP EXERCISE (REQUIRED BY 12/31/87) UNTIL EARLY 1988.

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.- DECEMBER 1987 OVERVIEW REPORT PLANT NAME: PILGRIM PROJECT MANAGER: R. H. WESSMAN MONTHLY OPERATIONAL OVERVIEW FOR DECEMBER 1987 The plant continues to be down for an extended outage for refueling, resolution of eouipment and operational difficulties, management issues and emeroency planning concerns RCS Hydro Completed 12/10/87 ILTR Completed 1P/24/87 P.estart readiness expected early 1988.

Monthlv Licensing Action Summary:

TRIPS THIS MONTH 0 TRIPS LAST 17 MONTHS 0 NitMBER OF REPORTABLE EVENTS 0 LICENSING ACTIONS TYPE CATEGORY 1 CATEGORY 2 CATEGORY 3 TOTAL Licensing Actions Opened in 12/87 0 0 0 0 (Pro.iected Categories)

Licensing Actions Closed in 1?/87 0 0 0 2 Licensing Actions in Prooress 0 0 0 T (Dec.31 1987)

Licensing Actions Returned (Cat 1) in 1?/87 0 For Applications received prior to 9/4/87 Number under review by PM 0 Number reviewed and completed by PM 1 SIGNIFICANT ISSUES AND EVENTS Significant Activities During December 1987 In a letter dated December 18, 1987, Senator Kennedy requested NRC to participate in a Senate Labor and Human Resources Committee hearing in Plymouth on the evening of January 7, 1988, concerning the proposed restart of Pilgrim. Dr.

Murley and W. Russell will testify for NRC. An NRC staff meeting with Xennedy staffers was held on December 30, 1987.

On December 9, 1987 NRR granted an exemption to the biennial emergency preparedness exercise, required to be conducted by 12/31/87. Exemption is granted until June 30, 1988, and is based on the need to complete development of improved Commonwealth and local plans prior to conducting a meaningful exercise.

BECo conducted a " partial participation" Emergency Preparedness Exercise on December 9, 1987. Although NRC observers noted some minor weaknesses, overall performance indicated that the licensee would have performed in a manner to protect the health and safety of the public, in the event of an actual accident. There was no local participation in the exercise and only limited Commonwealth participation (telephone checks). FEMA did not observe the exercise.

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2 On December 14, 1987, BECo announced several kqv managsment changes at Pilgrim. The Security Section Manager and the Operations Section Manacer are

.- replaced, a Deputy Plant Manager has been hired (R. J. Barrett, from Oyster Creek), and the position of Station Director has been created (filled by new-hire K. L. Highfill, with consulting, San Diego Gas & Electric and nuclear navy experience).

Events None Significant Meetinas Scheduled During December 1987 (NRR, Reaion, etc.)

The Pilgrim Restart Assessment Panlel will meet at the site on .lanuary 8,-1988 to discuss staff coordination of technical reviews and inspections.

NRR Staff will meet with BEco on January 14, 1988 to discuss the pump and valve inservice testing program.

Items for Manacement Attention Unanticipated demands on Pro.iects staff (loss-of-offsite power event, Kennedy hearinas) coupled with loss of 0. Gormley as Pro,1ect Engineer have impacted completion of Pilgrim licensing actions. 11 TACs require completion prior to Restart.

On December 10, BECo met with the staff to discuss their Emergency Operating Procedures (EOP) program. RECo has provided the staff with their current Procedures Generation Program (PGP) which is written to revision 4 of the (industry-proposed) Emergency Procedures Guidelines (EPGs). (Staff review of ,

these EPGs is not expected to be complete until Sprino 1988; however the staff endorses utility use of the unapproved EPGs in their current form).

Flow-chart oriented E0Ps were placed in the Control Room in November and operator training is being conducted. The staff plans to review the Pilgrim PGP, assess the E0Ps, conduct a site visit, and prepare a SER prinr to a restart decision. Headquarters, Region I, and contractor personnel will conduct the review.

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3 Status of Items Previously Identified for fianaoement Attention G. Requa, Project Engineer from PDII-I, continues to be loaned on a part-time basis to the Pilgrim Project team to assist with the licensing workload.

l Dan MacDonald is designated as the new Pilgrim PM. He will assume responsibilities for Pilgrim on ilanuary 18, 1988 Next Scheduled Refuelino Outage February 1989 cc: R. Wessman PDI-3 R/F M. Rushbrook V. Rooney E. Adensam D. MacDonald H. Berkow l

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Pilgrim - Activities Update - 12/2/87 Pilgrim readiness for restart remains uncertain. The Stop Work Action of November 9 and loss of offsite power event of November 12 have induced delays. Staff estimates RCS hydro will be conducted in mid-December and the ILRT will be conducted after January 1.

The Augmented Inspection Team repcrt of the November 12, 1987 loss of offsite power event is essentially complete and should be issued next week. Initial conclusions indicate no inajor licensee shortcomings or significant generic implications.  !

As part of their efforts to resolve offsite emergency preparedness issues, BECo has been offering funding and personnel to local communities. Voters in a Duxbury Special Town tieetina on November 24, '987, have rejected the BECo offer. Besed on local press reports, this action casts doubt on how emercency l preparedness improvements in this locality will be addressed and indicates a

! general sentiment opposing Pilgrim restart. Other local communities have l accepted the BECo funding and assistance.

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e' a BECo plans to hold a " partial participation" Emeroency Planning Exercise on December 9, 1987.

On November 30, 1987 BECo announced that they were reducing contractor work force by about 50%, to about 900 personnel. This is a move to reduce costs and an indication that outage activities are nearing completion.

About 60% of the site work that was interrupted under a Stop Work Order Novenber 9, 1987 has been resumed. Work resumed includes fire protection modifications, physical security enhancements, the third diesel generator and decontamination activities. BEco is still evaluating the causes for the various poor practices and events leading to the Stop Work Order.

Staff work and OGC review is complete on the BECo request of September 17, 1987 for a one time schedular exemption from the requirement to complete the biennial emergency preparedness exercise by December 31, 1987. The exemption should be issued in about 1 week.

The Pilgrim Restart Panel will meet at the site on December 8, 1987. The Regional Administrator plans to attend.

NRR issued two Technical Specification amendments on November 30, 1987. One involved a change to a LPCI surveillance specification and the other involved a clarification to Control Rod Block and APRM instrumentation requirements.

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