ML20235A913
| ML20235A913 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 10/07/1988 |
| From: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Zech NRC COMMISSION (OCM) |
| Shared Package | |
| ML20235A915 | List:
|
| References | |
| FOIA-88-285, FOIA-88-286, FOIA-88-287 NUDOCS 8810250001 | |
| Download: ML20235A913 (29) | |
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UNITED STATES T,tyAkrf4 y p, NUCLEAR REGULATORY COMMISSION ,
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%*****# Kout uAllO.EM HEMORANDUM FOR: Chairman Zech sLpg g ,
Commissioner Roberts SA,e n gg,, g " .I l Commissioner Carr Commissioner Rogers X rpA. 6,,f.
(4 rrusM FROM: Victor Stello, Jr. R. Al O Executive Director for Operations p, yg
SUBJECT:
VPDATED STAFF ACTIONS FOR PILGRIM NUCLEAR POWER N ' O WM STATION f, fig T'. A'B'"asKI On September 28, 1988, Boston Edison Company (BEco) requested NRC approval for the restart of the Pilgrim Nuclear Power Station. On October 5, 1988, Dr. Murley g Ih and members of the staff met with 8Eco and representatives -of the Commonwealth of Massachusetts to discuss the readiness of the Pilgrim facility as part of' the staff's preparations for a Comission meeting on Pilgrim on October 14, 1988.
Enclosed is a copy of the staff's briefing viewgraphs for the upcoming '
Commission meeting. Also enclosed is a sumary of the status of offsite energency preparedness at Pilgrim. Copies of the Restart Assessment Report dated September 26, 1988, prepared by the Pilgrim Restart Assessment Panel as l directed by the Region I Administrator, have been provided separately to the Comis sioners. Copies of the BEco viewgraphs for the upcoming Comission meeting have also been provided separately.
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Victor Stello, Jr.
Executive Director for Operations Enclosures As stated i
cc: SECY OGC CONTACT: R. Wessman, NRR X21433 Hienames 19 y l
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COMMISSION MEETING CONSIDERATION OF RESTART OF THE PILGRIM NUCLEAR POWER STATION OCTOBER 14, 1988 9
- - - - - - _ - - - . - _ . ~ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ __
PRESENTATION OUTI.iNE BACKGROUND RESTART CRITERIA STAFF ASSESSMENT ACTIVITIES AND RESULTS EMERGENCY PREPA7EDNESS STATUS POWEP ASCENSION PROGRAM CONCLllSION a
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SHUTDOWN APRIL 12, 19A6
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CONFIRMATORY. ACTION LETTER 86-10 AND SUPPLEMENTS ,;.
TECHNICAL AND MANAGEMENT' ISSUES TECHNICAL AND EQUIPMENT. PROBLEMS MANAGEMENT! CONCERNS SALP FINDINGS OTHER IS$UES-FEMA EMERGENCY PREPAREDNESS FINDINGS SAFETY ENHANCEMENT PROGRAM (SEP) INITIATIVE 2.206 PETITIONS AFf1 PUBLIC PARTICIPATION t
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RESTART CRITERIA STABLE AND EFFECTIVE MANAGEMENT:.AND STAFF AT PILGRIM RESOLUTION OF MAJOR:TECHNICALTISSUES DEMONSTRATED IMPROVEMENTJIN SALP PROBLEM AREAS MAINTENANCE PROGRAM-AND WORK BACKLOG ISSUES ADDRESSED 1
1 NRC SATISFIED THAT CERTAIN EMERGENCY PLAN IMPROVEMENTS l
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ASSESSMENT ACTIVITIES AND RESULTS AUGMENTED INSPECTION AND REVIEW EFFORTS PILGPIM RESTART' ASSESSMENT PANEL AUGMENTED INSPECTION EFFORT THROUGHOUT SHilie0WN PERIOD SALP REPORT,NO.- 50-293/87-99 INTEGRATED ASSESSMENT TEAM INSPECTION (IATI)
MEETINGS-AND PUBLIC/ LOCAL 0FFICIALS INPUT RESULTS RESTART READINESS ASSESSMENT REPORT ACRS RECOMMENDATION 1
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. ASSESSMENTACTIVITIESANDRESULTSiCONT)-
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], STABLE AND EFFECTIVE MANAGEMENT IS IN PLACE ORGANIZATIONAL STRUCTURE EXPANDED AND STRENGTHENED EXTENSIVE MANAGEMENT' IMPROVEMENTS AND STAFF INCREASES BECo SELF ASSESSMENT-PROGRAM i
2, MAJOR TECHNICAL.lSSUES ARE RESOLVED ORIGINAL TECHNICAL ISSUES THAT LED TO PLANT-SHUTDOWN RESOLVED-1 EXTENSIVE PLANT AND PROCEDURE MODIFICATIONS , 1 SAFETY ENHANCEMENT PROGRAM e
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ASSESSMENT ACTIVITIES.AND RESULTS (CONT)
- 3. IMPROVEMENTS IN SALP PROBLEM AREAS
- PROGRAMMATIC IMPROVEMENTS IN SECURITY, FIRE PROTECTION, SURVEILLANCE AND i
ASSURANCE OF QUALITY RESULTED IN CATGORY 2 PATING (UP FROM CATEGORY 3)
RADIOLOGICAL CONTROLS RATED AS CATEGOPY 3-1MPROVING, WITH FUPTHER IMPROVEMENTS NOTED SUBSEQUENT TO SALP
- 4. MATI:TFNANCE PROGRAM AND WORK BACKLOG IMPROVEMENTS ORGANIZATION AND STAFFING IMPROVEMENTS IMPROVED MAINTENANCE Al!D POST-WORK TEST PROCEDURES ,
4 BACKLOG REDUCED AND PRIOR!TIZATION OF OPEN WORK ACCOMPLISHED 4
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POWER ASCEliSION PROGRAM ]
PROVIDES FOR'DEllBERATE AND CONTROLLED RETURN TO POWER OPERATION )
FIVE HOLD POINTS SPECIFIED AND NRC APPROVAL REQUIRED TO PROCEED BEYOND EACH POINT AUGhENTED INSPECTION COVERAGE WILL BE PROVIDED STAFF WILL FORM CONCLUSION ON EFFECTIVENESS OF PROGRAM AND'BECo CPERATI0ft OF PILGRlh l
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OFFSITE ENERGENCY PREPAREDriESS STATUS SIGNIFICANT PROGRESS MADE TOWARD RESOLVlflG ISSUES IDENTIFIED BY FEMA lh AUGUST 1987
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PROGRESS Ot1 IMPROVING PLANS AND PROCEDURES FOR SCHOOLS, DAYCARE CEilTERS AND SPECI AL NEEDS AllD TRANSPORTATION DEPENDENT POPULAT10f1S IN EPZ TRAlfilNG FOR OFFSITE ENERGENCY RESPONSE PERS0flNEL IS IN PROGRESS LOCAL PLANS, REVISION OF hCDA AREA 11 PLAN AliD REVISION OF COMMONWEALTH'S STATE-WIDE PLAN AliD PROCEDURES ESSENTIALLY COMPLETE IN DRAFT FORN AND REVIEWED BY FEhA fiRC STAFF HAS OBSERVED LlHITED DEh0tiSTRAT10f1S ASSOCI ATED WITH EVACUAT10fi PLANS FOR SCHOOLS AliD DAY CARE CENTERS, TRANSPORTATION DEPENDEfiT AND SPECIAL NEEDS POPULATIONS STAFF ASSESSMENTS OF EP PROGRESS WILL CONTINUE 8
CONCLtlSION I
- - TECHNICAL AND MANAGEMENT ISSUES RESOLVED EMERGENCY PLANNING-IMPROVEMENTS MADE AUGUMENTED INSPECTION OF POWF.R ASCENSION PROGRAM CONTINUE ASSESSMENTS OF-EMERGENCY
- PREPAREDNESS 4
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Pilgrim Offsite Emergency Planning Issues Status A number.of emergency preparedness (EP) issues have been raised since the Pilgrim plant was shutdown in April of 1986. As a result of its self-initiated review (SIR) of the overall state of_ emergency preparedness at Pilgrim, the Federal Emergency Management Agency (FEMA) identified (August '
1987) six areas of major concern in the emergency plans for the Pilgrim ten-mile emergency planning zone (EPZ).*' Although separate from the technical and 1 l management issues which initiated plant shutdown by the licensee and NRC Con-l firmatory Action Letters, the NRC has indicated that the progress towards resolution of these issues will be considered by the agency as a part of a decision on Pilgrim restart. Specifically the six significant emergency pre--
i paredness issues identified by FEMA are summarized below. 3
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i 1. Lack of evacuation plans for public and private schools and ,
day-care centers. l i
- 2. Lack of a reception center for people evacuating to the North.
- 3. Lack of identifiable shelters for the beach population. !
- 4. Inadequate planning for the evacuction of the special needs population. j7 1
- 5. Inadequate planning for the evacuation of the transportation-dependent population.
S. Overall lack of progress in planning and apparent diminution in emergency preparedness.
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- As ,a result of the specific issues identified in the existing Commonwealth and local offsite emergency plans, FEMA withdrew (8/87) its interim adequacy finding on offsite emergency preparedness for Pilgrim. The adequacy finding en Comon-wealth and local response planning was issued by FEMA in September 1982.
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The staff has been carrying out an ongcing assessment of progress towards resolving these issues. In evaluating the current sutus of emergency plan-ning, the NRC staff has reviewed the revised emergency plans and implementing proc,edures, available to the NRC staff, which have been developed through j cooperative efforts by the utility, and Commonwealth and local governments.
NRC staff efforts have also included discussions with' FEMA Region I staff, Commonwealth emergency planning officials and Boston Edison representatives.
In addition, NRC Region I and Headquarters staff have made several visits to the site area to observe limited demonstrations, esssociated with emergency 1 I
worker training, of evacuation plans for schools and day care centers, the transportation-dependent population and the special-needs population.
1 ll Considerable progress has been made in drafting plans and procedures for the l plume exposure pathway emergency planning zone (EPZ) and reception center I
comunities to correct the FEMA-identified issues (Issues Nos,1, 4 and 5).
l The draft revised plans for all seven of the EPZ (5) and reception center (2) comunities have been submitted by the Commonwealth for informal technical review by FEMA. FEMA and the NRC member of the Regional Assistance Comittee (RAC) have reviewed and connented on the draft plans submitted by the Common-wealth for the EPZ comunities of Plymouth, Kingston, Carver and Duxbury and the reception center comunities of Taunton and Bridgewater. The FEMA coments, as well as additional coments from the Massachusetts Civil Defense Agency (MCDA) have been incorporated into the plans and procedures drafted for these towns as well as the remaining EPZ comunit; of Marshfield. The status of the plans is sunEarizedasfollows:
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'Marshfield - the draf t Plan, Implementing Procedures (IPs) and i Shelter Implementation-Program were ' authorized by the Selectmen j for submittal and have been forwarded to MCDA and transmitted to !
FEMA for review.
- 2. Taunton - the draft Plan and Implementing Procedures were authorized i by the Selectmen for submittal and have been forwarded to MCDA.and a '/9 P
transmitted to FEMA for review. /
- 3. Duxbury - all documents are complete except for two IPs. These'are )
in draf t form and have been sent to the town planning comittee for )
review prior to submission to MCDA.
.4. Plymouth - all documents are complete except for three IPs. These are in draft form and have been sent to the town planning comittee for review prior to submission to MCDA.
- 5. Kingston - all documents are cunplete and were authorized by the ,
Selectmen for submittal and have been forwarded to MCDA. j i
- 6. Carver - all documents are complete and were authorized by the Select- l men for submittal and have been forwarded to MCDA. !
- 7. Bridgewater - the draft Plan and Implementing Procedures were !
authorized by the Selectmen for submittal and have been. forwarded ]
to MCDA.
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The revised plans and procedures include; 1) identification of schools, day- f j
care centers, the special needs population and the transportation-dependent d population; 2) detailed evacuation procedures' for these populations and 3)identificationoftransportationresources.. In support of the revised plans and procedures, BECO has developed an evacuation time estimate (ETE).and traffic management plan update for the 10-mile EPZ which was submitted to FEMA by the Commonwealth in March 1988 for review. The ETE study was further updated and distributed to the local plannehs and MCDA on August 26, 1988. BECO is also developing, for submittal to MCDA, a traffic management plan for certain areas beyond the EPZ.
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In addition to the local plans, the revision of the MCDA Area 11 emergency plan
- and procedures and the revision of the Commonwealth's state-wide plan emergency plan ** and procedures which support local plans are essentially complete. The MCDA Area 11 plan has been transmitted by the Commonwealth to FEMA for informal technical review. The state-wide plan remains to be submitted by the Common-l wealth to FEMA for review.
Thus far the plans submitted by the Commonwealth to FEMA have been submitted for " informal technical review." The Commonwealth while participating in the revised plan development process continues to characterize all of the revised plans as " draft". In correspondence with the Commonwealth dated March 30, 1988 and August 22, 1988,, FOKA has recognized the progress being made in improving energency plans for Pilgrim and has encouraged the development, by the Connon-wealth, of a schedule indicating Commonwealth milestones for completing the overall planning process. The Commonwealth has not yet indicated when revised plans will be formally submitted to FEMA.
The revised plans and procedures for the EPZ and reception center towns are in sufficiently final form that training is being conducted in accordance with a
- The MCDA Area II Plan provides for coordination of response among EPZ and reception center communities, and details how State resources should be requested and provided to support local response.
- The State Radiological Emergency Response Plan details overall coordination of emergency response, the duties of State agencies in support of local response, and the relationships with Federal agencies and adjacent States.
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l training program approved by the Commonwealth. Almost all of the training j modules and lesson plans have been prepared, and training of emergency response personnel by Comenwealth certified instructors is well underway. General over-view training has been conducted for many offsite organizations, and specific training is being conducted including training for transportation providers.
The NRC staff has reviewed the training program including the individual lesson plans and has observed the training of bus and ambulance drivers from companies providing transportation for schools and daycare centers, special-needs popula-tion and transportation-dependent persons. The training includes use of 1
dosimetry and route maps, and travel on the actual routes to be used in an emer-gency. The training program is currently ongoing and most emergency response personnel are expected to be fully trained in their response duties by the end )
of the year.
Regarding Issue No. 2, lack of a reception center for people evacuating to the north, the Commonwealth has tentatively designated a state-run facility in the town of Wellesley as the northern reception center and is currently con-ducting a feasibility study to determine if the facility is suitable for a reception center. This study is expected to be completed in several weeks and, if the results of the study are favorable, the Commonwealth has indicated that it will undertake capital improvements and procedure development. As a related matter, Boston Edison has performed an analysis which concludes that the existing two reception centers (Taunton and Bridgewater), with appropriate renovations and additional equipment, have the capability to support an evacua-tion from the EPZ. The Commonwealth has not yet authorized these improvements and has indicated that it will pursue development of a third reception center.
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Regarding issue No. 3, lack of identifiable shelters for the beach population. l FEMA in a letter to the Commonwealth dated August 22, 1988, reiterated its position, supported by the NRC, that "a range of protective actions" could be 4 satisfied by evacuation alone for the beach population. The FEMA position on i shel'ters for the beach population was developed subsequent to the issuance of FEMA's Pilgrim report in August 1987. Thus the issue of shelters for the beach population has been removed as a concern by FEMA. Prior to this determination, BECO completed a shelter survey and developed a shelter implementation program including shelter identification, letters of agreement and shelter procedures. l BEC0 has indicated that, FEMA's position notwithstanding, it will continue it's shelter program for the beach population.
Issue No. 6, overall lack of progress and support in emergency preparedness, l is being resolved by the progress being made in correcting the other specific FEMA-identified issues including the development of revised State plans. Addi-I tional details on the status of the corrective actions of the six FEKA-iden-tified offsite preparedness issues at Pilgrim are shown in the attached table.
In sumary, the NRC review of the status of emergency preparedness at Pilgrim indicates that while all tasks have not been completed, progress is being made toward resolving the issues identified by FEMA in their August 1987 report. In particular, significant progress has been maae in improving the emergency plans and procedures for schools and day care centers and for the special-needs and transportation-dependent populations in the EPZ. The development of these plans and procedures, in conjunction with the training program directed toward l
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the transportation providers responsible for evacuating school children and the f special needs and. transportation-dependent populations, indicates that the off-site response plans include measures to protect these sensitive groups. The NRC plans to continue to assess the progress made toward fully resolving the FEMd-identifiedissuesinoffsitepreparedness.
Regarding the scheduling of an exercise, Boston Edison was granted an exemption l from conducting a full-participation exercise because ongoing improvement efforts in the offsite response plans were not complete. A full-participation .l l
l emergency preparedness exercise will be required to be conducted, in accordance with the regulations, upon the completion and submittal of the revised plans and ,
1 l procedures by the Commonwealth to FEMA. i l
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I-appreciate the opportunity to be.here-today. I- understand that many of;you l
have concerns about the safe operation at Pilgrim and we want to be responsive q l
to your concerns. We share the same goal of safe operation _of Pilgrim.- '1
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. We in the NRC recognize that times are changing with regard to States'-
interest in nuclear regulation. We want to work with Massachusetts'in a i
cooperative way and to be responsive to Governor'Dukakis' concerns. 1 To begin, I would like to discuss how we got where.we are today with Pilgrim. With the Committee's indulgence, I will go back several years. 1 Starting in 1946, atomic energy was put under civilian control in the Atomic Energy Commission (AEC). In 1954, President Eisenhower; issued his Atoms for Peace program. A large amount of nuclear reactor information was. declassified l
and the Atomic Energy Act was amended to have the Federal government promote commercial nuclear pgwer. The,AEC was then both the promoter and the !
K regulator of nuclear energy.
In 1975, the regulatory and promotional responsibilities for commerical i
4' nuclear power were separated. The Nuclear Regulatory Commission (NRC) was established with the sole job of regulating public health.and safety and !
material safeguards. The NRC carried over most of the safety regulations from AEC, but our meetings and deliberations are now much more open to the public.
Nevertheless, we were probably slower than we should have been in developing closer ties with the States.
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Against this backdrop, Boston Edison ordered the Pilgrim plant in the late ,
1 1960's. They received a construction permit in August 1968 and an operating license in September 1972. If one looks back, we can :see that the seeds j of many of their current problems were sown in those very early days. The design, construction and operation of Pilgrim was treated much like any other .
l fossil-fired plant in the Boston Edison system. So one saw a nuclear plant being operated in a fossil plant environment. One can contrast that situation with the Yankee plant, where the plant was operated within a nuclear ethic l l from the very beginning. The demands, the training, and the attitudes are 1
much dif ferent for operating a nuclear plant than for a fossil plant.
At Pilgrim there were fuel failures in the 1970's and the plant systems became l l
radioactive. This legacy contributes to some of their problems today. In l l
1980 and 1981, there were management problems at Pilgrim that led to a $550,000 e
fine. BECo responded positively by creating a separate nuclear organization with a Senior Vice President in charge. During 1980 to 1984, we started to see improvements:
they invested millions of dollars in plant hardware they increased spare parts inventory j they began to clean-up the plant they replaced some piping that had become cracked i
During this time, the NRC was issuing a flurry of new requirements as a result t
of the TMI accident. Thus, we saw a paradox. While there were visible signs of improvement, the workload was growing too fast, and the management systems at Pilgrim were being overloaded.
That brings us to 1986. Early that year, we issued a Systematic Assessment j of Licensee Performance (SALP) review covering a 12 month period from October 1984 to October 1985. That report brought into focus for the first l
c time a number of problem areas: !
1 a shortage of licensed operators causing excessive operating over-time a large maintenance backlog with a number of management vacancies in the maintenance area l l
an inef fective radiological protection program l
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an ineffective emergency preparedness program 1 l
l insufficient oversight by Boston Edison supervisors of work in i I
progress !
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poor procedural adherence and administrative practices I 1
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failure of managers and supervisors to ensure proper planning and scheduling of required tests and maintenance These problems were compounded by a lack of critical self-assessment on the part of Boston Edison and a tendency toward superficial corrective action.
I I talked with the senior management of BEco in January 1986 and forcefully told them of NRC's concerns. In February 1986, I sent in a special team of inspectors for a few weeks of round-the-clock inspection coverage in order to obtain a more complete understanding of the underlying reasons for the poor performance. This team confirmed the SALP conclusions. In April 1986, a series of plant hardware problems caused the plant to shut down. At that time, I issued a Confirmatory Action Letter keeping the plant shut down and I sent in another NRC inspection team. Later in the summer of 1986, I revised and extended the Confirmatory Action Letter to assure that BECo would keep Pilgrim shut down until those management deficiencies identified in the SALP and the diagnostic team inspection were resolved. BEco agreed. The plant has since remained shut down for refueling and modifications. They subsequently decided to make additional safety improvements to the plant, including their Mark I containment structure. In this safety initiative, they are leading the rest of the industry and are going beyond NRC suggestions for improvement.
Finally, I will get to direct answers to your questions.
- 1. The adequacy of BEC0's actions? I believe they are clearly on the right track. We see signs of improvement at the plant. There is a
new Senior Vice President in charge of.the nuclear program who.has extensive experience in the nuclear Navy. A recent emergency preparedness exercise showed better planning and senior management involvement in that program.
However, out in the plant the workers are still struggling to get-their arms around the problems. The management team ,has.not yet jelled. There is still a large work activity backlog'and still a shortage of reactor operators. In addition, the security, fire I
l protection and radiological protection programs'are not as effective _
as they need to be. The organization has to overcome the legacy of years of fossil plant type of operation that mere words at the' top cannot change.
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In the past, we in the NRC mistook good. intentions.in management
, assurances for real, fundamental changes in performance. We will not fall into that trap again. NRC has been giving enhanced inspection coverage and oversight at the' plant and will continue to do so for the foreseeable future. We are having bi-monthly . senior management meetings to assess their progress. There are now three NRC Resident Inspectors assigned to the site.
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- 2. Will the plant be ready to return to full power operation safely?-
The plant. remains shut down. NRC will not permit its. restart until-we make a finding that it can be operated safely. -We.will require
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a comprehensive report from Boston Edison that describe' th -
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improvements that have been made in the plant /)and iepre^-^tts in ]
/ 9 their management systems. This report will be=made public. In {
l addition, NRC will conduct a readiness team inspection and will .
also make public the team's inspection report. This inspection will be similar to the special diagnostic assessment team-inspection 1
which was conducted in FebSarp 1986 and will focus on the general + I I
readiness of the plant with specific emphasis on those problem areas which have been identified at Pilgrim. Finally, there will be. !
a public meeting'with the NRC Commissioners before NRC makes a lj i
decision to allow restart of the reactor. f 1
4m. l If a restart is authorized, NRC Region I would augment its inspection coverage for the startup program. This coverage will be like that which we applied during the Three Mile Island Unit 1 startup and will provide around-the-clock coverage of startup and site activities. I There will be a number of " hold points" beyond which BEco would not be permitted to proceed without my authorization. These decisions 1 l
would be based upon the evaluation of the plant's operation by the on-site inspection team.
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What will we look for to see that the situation has improved at Pilgrim in f preparation for restart? f l
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- 1. A stable and effective management team at the plant. i l
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- 2. Management vacancies are filled and licensed R0 and SR0 positions are filled. l 1
- 3. The work backlog is under control and a system is in place to track i l
the backlog.
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- 4. Solid improvements have been made in long-standing problem areas such as radiation protection, fire protection and plant security.
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- 5. Solid improvements have been made in the offsite emergency planning weaknesses.
Finally, we will expect to see signs that BECo is developing its own internal high standards of performance and is developing the means for self-analysis relative to those standards.
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TESTIMONY BEFORE THE SENATE LABOR AND HUMAN RESOURCES COMMITTEE A REGARDING THE PILGRIM NUCLEAR POWER STATION
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d 67 DR. THOMAS MURLEY, DIRECTOR OFFICE OF NUCLEAR REACTOR REGULATION U. S. NUCLEAR REGULATORY COMMISSION l
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PLYMOUTH, MASSACHUSETTS JANUARY 7, 1988
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Thank you, Mr. Chairman. In response to the request of the.Comittee, I am here to discuss the status of the issues concerning the restart of the Pilgrim Nuclear Power Station. With me today is Mr. William Russell, who is the Regional !
. Administrator of NRC's Region I office.
As part of its regulatory process, the NRC performs a Systematic Assessment of 1
Licensee Performance (SALP). In early 1986 the NRC staff issued a SALP report I on Pilgrim covering a 12-month period from October 1984 to October 1985.
That report brought into focus a number of problem areas at Pilgrim such as a shortage of licensed operators; a large maintenance bqklog with a number of l management vacancies in the maintenance area; radiological protection program weaknesses; emergency preparedness program weaknesses; and instances of poor l proced iral adherence and administrative practices at the plant. These problems
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i were compounded by a lack of critical self-assessment on the part of Boston Edison and a tendency toward superficial corrective actions. We met with the senior management of Boston Edison in January 1986 and forcefully told them of our concerns. In February 1986, a special team of inspectors was sent to the plant for several weeks of around-the-clock inspection. We did this to obtain a more complete understanding of the underlying reasons for the poor performance. This team confirmed the SALP conclusions.
On April 12, 1986, a series of plant hardware problems caused the plant to shut down. At that time, I issued a Confirmatory Action Letter documenting Boston Edison's intent to keep the plant shut down. Later in the sumer of 1986, I revised and extended the Confirmatory Action Letter to confirm that Boston Edison i
would keep Pilgrim shut down until resolution of those management deficiencies identified in the SALP report and by the special team inspections.
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Our most recent SALP review covered the period from November 1985 to January 1987, and was issued April 8, 1987. This report identified five areas that exhibited recurring program weaknesses. These are:
radiological controls surveillance of safety related equipment fire protection physical security and safeguards assurance of quality Over the past few years the NRC has devoted considerable resources to monitor the Boston Edison efforts to address these weaknesses. For example, the NRC has three full-time resident inspectors at Pilgrim, whereas most single-unit facilities have two residents. Furthermore, we have supplemented these resident inspectors with an extensive region-based inspection effort and have comitted additional headquarters resources to review and evaluate Pilgrim issues. This includes a dedicated assessment panel composed of NRC managers to overview and consolidate the NRC approach to Pilgrim activities.
Let me summarize the current status of major Boston Edison and NRC activities regarding the Pilgrim facility. The facility remains shut down. The NRC has met frequently with Boston Edison, members of the public, and with the Commonwealth of Massachusetts, as well as with local officials to discuss issues regarding Pilgrim. Boston Edison has developed a restart plan that describes the programs, plans, and actions considered necessary by the company to restart and safely operate Pilgrim. Although Boston Edison has not reached a position where it would request that NRC consider a restart decision, the utility has completed a number of plant improvements. The reactor was refueled in October and several major systems tests on the reactor coolant system and containment structure have been completed.
3 As part of its Safety Enhancement Program (SEP), Boston Edison has proposed a number of modifications intended to improve plant performance in the event of an accident et Pilgrim. The NRC staff reviewed these modifications in August 1987 and concluded that eight of the modifications were appropriate for implementation.
These include containment spray nozzle modifications, the installation of a third 5 emergency diesel generator, modificaticas to fire protection systems, and features to respond to an anticipated transient without scram. The SEP modifications are designed to mitigate the effects of abnormal conditions that could develop in containment in the event of an unlikely accident. These modifications are in consonance with NRC goals to enhance containment performance under severe accident conditions. We have not made them formal requirements for restart of Pilgrim. We are, howevar, ensuring that these modifications do not result in lessened safety for the plant.
Questions have been raised regarding the Mark I containment at Pilgrim and the Direct Torus Vent modification being considered by Boston Edison. The Direct Torus Vent would provide a hardened path from the containment torus structure to the plant stack and would be used to relieve containment pressure in certain severe accident situations. During staff revie.< of this proposed modification a number of questions were asked of Boston Edison regarding the use of the Direct Torus Vent. These questions must be resolved before this system is placed into service.
Regarding the management area, Boston Edison b., made a number of changes that we believe are improvements. In early 1987 Mr. Ralph Bird was hired as the
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. N 4 I Senior Vice President - Nuclear. He has extensive nuclear navy and management experience. Changes have been made in the onsite organization, additional personnel have'been hired and programs forl improvement are being implemented.
The NRC staff will assess the effectiveness of these programs and management changes in the coming months.
The NRC has a special progransnatic approach for assessing the Boston Edison progress at Pilgrim. Our activities are being coordinated by an Assessment Panel that is chaired by a senior staff member from Region I and includes representatives from the region and headquarters. Once the Pilgrim restart plan has been reviewed by NRC and after Boston Edison has stated it is ready to restart Pilgrim, this Panel will assess restart readiness. This assessment will be a comprehensive evaluation that considers the general readiness of the plant and personnel to resume safe operation and will include a comprehensive 1
onsite team inspection.
In addition, as we indicated to Senator Kennedy and Congressman S.t'udds.in-Chairman Zech's letters of November 20, 1987, we will conduct several public meetings to ensure opportunity for public participation and input to the Assessment Panel regarding the Boston Edison restart plan. These meetings will be formal, transcribed sessions at which the public's testimony will be heara oy NRC senior staff. After the NRC staff has completed the restart readiness assessment, there will be a public meeting at NRC headquarters at which the staff will brief the NRC Commissioners on our findings and recommendations so that the Comission itself can make the ultimate restart decision.
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?~f If restart is authorized, NRC would increase its inspection coverage for the startup program to provide around-the-clock coverage'of startup and site activities. A number of " hold-points" will'be instituted and Boston Edison would not be permitted to proceed without'HRC authorization. These decisions would be based on the on-site inspection team's evaluation of Pilgrim operation.
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In addition to the areas previously discussed, a number of emergency preparedness concerns have been raised at Pilgrim since the Confirmatory Action Letter was issued in April 1986. On July 15, 1986, State Senator William B. Golden and others filed a Petition with the NRC, requesting that NRC order Boston Edison .
to show cause why Pilgrim should not remain closed or have its operating license suspended. That request was based, in part, on emergency preparedness concerns.
On December 22, 1986, the Secretary of Public Safety of the Commonwealth of Massachusetts sent FEMA a copy of an Office of Public Safety report entitled,
" Report to the Governor on Emergency Preparedness for an Accident at the Pilgrim Nuclear Power Station," dated December 1986. In a memorandum to NRC dated March 31, 1987, FEMA stated that it was also conducting a self-initiated review of the l
overall state of emergency preparedness at Pilgrim Station. FE!% subsequently comitted to prepare, on a priority basis, a consolidated evaluation that would address the Petition issues, the report submitted by the Office of Public Safety, its self-initiated review, and other relevant available information.
On August 6, 1987, FEMA sent its report to NRC. It is entitled, "Self-Initiated
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Review and Interim Finding for the Pilgrim Nuclear Power Station, Plymouth, I
' Massachusetts." In-this report, FEMA listed the following six areas of concern j 1
in the Commonwealth of Massachusetts emergency plans for the ten-mile emergency ]
planning zone surrounding Pilgrim:
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- 1. Lack of evacuation plans for public and private schools and day care ]
centers.
- 2. Lack of a: reception center for people evacuating to the north.
- 3. Lack of identifiable public shelters'for the beach population.
- 4. Inadequate planning for the evacuation of the special needs population.
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- 5. Inadequate planning for the evacuation of the transportation-dependent population.
- 6. Overall lack of progress in planning and apparent diminution in emergency preparedness.
On August 18, 1987, the NRC transmitted the FEMA report to Boston Edison and l requested that the utility provide an action plan and schedule for assisting the Commonwealth of Massachusetts and local governments in addressing the FEMA identified emergency planning issues. Boston Edison submitted its Action Plan on September 17, 1987. This action plan details Boston Edison's plans to assist the Connonwealth of Massachusetts and local governments, as well as describing resources and a schedule for completion. '
Over the past few months, Boston Edison, the Commonwealth. and the local
governments in the Pilgrim area have committed considerable resources and effort toward resolving these concerns. Current status is as follows:
- Drafts of local plans were complete November 1, 1987. These currently are in review in the respective towns.
- Drafts of local procedures are in preparation. These address issues such as buses and sheltering.
- The Draft Massachusetts Civil Defense Authority Area II Plan is complete and under review by the Commonwealth.
- The draft of the Commonwealth Plan for Pilgrim is nearing completion.
- A training program has been developed by Boston Edison and provided to the Massachusetts Civil Defense Authority.
- On December 17, 1987 the NRC received the " Report on Emergency Preparedness for an Accident at Pilgrim Nuclear Power Station," from the Commonwealth of Massachusetts. NRC and FEMA will consider this report in their ongoing reviews.
m Additionally, Boston Edisoii submitted an exemption request to NRC on the t requirements for conducting its Biennial Full Participation Exercise. The request was based on the need to make improvements in emergency plans. NRC approved that exemption request, stipulating that the exercise be conducted no later than June 30, 1988.
l The NRC agrees that emergency planning deficiencies do exist at Pilgrim and further agrees that corrective actions are needed. However, considering the shutdown status of the plant and the progress that is being made to address emergency planning issues, we have not taken enforcement action regarding emergency planning.
The NRC will not permit the facility to resume operation until corrective actions satisfactory to NRC have been taken to address the emergency planning deficiencies identified by FEMA. We will give special attention to the mproved evacuation plans for schools and day care centers as well as the improved evacuation plans for special-needs and transportation-dependent populations in the ten-mile emergency planning zone. We will require some demonstration of the critical aspects of these evacuation plans before we can decide that Pilgrim is ready to resume operation.
However, it may be that restart can be authorized with some emergency planning issues not fully resolved. Under the NRC's regulatory framework, whether an outstanding emergency planning deficiency must delay restart will depend upon considerations of the gravity of the deficiency, the nature of-any compensatory actions, and progress toward correction of the deficiency.
For Pilgrim this decision will be made ultimately by the Connission itself.
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In conclusion, there has been and will continue to be a high level of NRC .
management attention to Pilgrim. The NRC staff has adopted a unique approach for monitoring the performance of the utility as it implements needed
! improvements. This approach includes opportunities for public input to the process. I want to assure the Conynittee that Pilgrim will not be permitted to 3 i
restart until the NRC staff has reviewed carefully the plant improvements,.the !
management improvements, and the offsite emergency preparedness improvements and has concluded that the plant will be operated safely.
This concludes my testimony. Mr. Russell and I would be glad to answer l
. questions. .
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