ML20245B534
| ML20245B534 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Pilgrim |
| Issue date: | 06/19/1987 |
| From: | Roberts T NRC COMMISSION (OCM) |
| To: | Studds G HOUSE OF REP. |
| Shared Package | |
| ML20235N633 | List: |
| References | |
| FOIA-87-372 NUDOCS 8706250529 | |
| Download: ML20245B534 (8) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION
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WASHINGTON, D. C. 20555
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June 19, 1987 CHAMMAN The Honorable Gerry E. Studds United States House of Representatives Washington, DC 20515
Dear Congressman Studds:
I am responding to your March 6, 1987 letter requesting that the Nuclear Regulatory Commission (NRC) address a number of issues regarding the Pilgrim Nuclear Power Station as raised by the Citizens Urging Responsible Energy (CURE), in their letter to you of February 6, 1987.
Responses to these issues were prepared by i
the NRC staff and are enclosed.
The CURE letter of February 6, 1987, which was attached to your letter, had not previously been received by NRC.
The Commission will hold a public meeting to be briefed by staff on the readiness of Pilgrim to resume operations before allowing restart of the plant.
As a prerequisite to restart, the licensee, Boston Edison Company, must satisfy itself and the NRC that the facility and its operating staff and managers are ready to resume operation.
Boston Edison has not yet made such a determination.
Consequently, we do not believe it is appropriate at this time to speculate on the extent and nature of further changes needed.
However, we do agree with CURE that a number of issues have been identified which must be addressed before restart.
In the interim, NRC is reviewing the remedial measures being instituted by the licensee.
Commissioner Asselstine disapproved this response.
Sincerely, Thomas M. Roberts Acting Chairman
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Enclosure:
Response to Issues 4
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ENCLOSURE I.
Proposed Rule Related to Emergency Planning The Comission, after holding a public meeting, voted to publish in the Federal Register (Vol. 52, No. 44 dated March 6,1987) a notice of a proposed rule re-garding the situation where there is a lack of cooperalf on by state and/or local governments in emergency planning.
The amendment under consideration l
l would by no means exclude state and local participation in emergency planning.
l The proposed rule would be directed only at those cases where state and/or local governments refuse to participate in such planning.
Utility licensees would be granted no additional power or authority.
The proposed rule, which applies only to those nuclear power plants for which no full power license has been granted, would not guarantee an operating license to any particular plant or plants.
The Comission can grant en operating licer.se only if it finds reasonable assurance that' the public health and safety will be adequately pro-tected.
II. Proposed Rule Related to Radioactive Emissions We assume that the reference to the proposed rule change to raise the tolerable levels of radioactive emissions from nuclear power plants is directed to the proposed revision to the Comission's regulations 10 CFR Part 20 as published in the Federal Register on January 9,1986 (Vol. 51, No. 6, page 1092).
The notice in the Federal Register provided interested members of the public the g
opportunity to coment on the proposed rule.
Your coments and those relating
s 2-to the rule discussed in the preceding paragraph have been forwarded to the Office of the Secretary for consideration by the Comission staff during its review of public coments on these two rulemaking proceedings.
III. Size of the Emergency Planning Zone (EPZ)
A concern was raised about reduction of the current plume exposure emergency planning zone (EPZ) radius of 10 miles for nuclear power plants.
The NRC is reassessing emergency planning in light of new insights arising from the extensive research on severe accident releases or " source terms." However, the NRC staff review has not progressed to a point where it could recomend any generic changes in the requirements pertaining to the size of the plume exposure EPZ.
There are no current plans to reduce the size of the Pilgrim EPZ.
There is a request pending in an individual licensing proceeding involving the Seabrook nuclear power plant to reduce the size of the 10-mile emergency plan-ning zone to approximately 1 mile.
The applicant based its request, in part, on its claim that due to unique features of its plant, a one mile EPZ provides a sufficient level of protection.
No decision has been reached by the Comission regarding this request.
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.v IV. Pilgrim Emergency Plans CURE states that the Pilgrim plant has operated for 14 years without a fully approved evacuation plan. This is misleading because, prior to 1980, there were no detailed evacuation planning requirements included in the NRC's emergency planning regulations.
Pilgrim did comply with NRC emergency l
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planning requirements from 1972, when the plant was licensed, until 1980, when new requirements were imposed. Also, as explained below, emergency planning for Pilgrim has been adequate since 1980.
For each nuclear power plant which held a license to operate at the time the NRC final rule on emergency planning became effective (November 3,1980), as was the case with Pilgrim, the NRC based its post-1980 reasonable assurance s
findings for each operating reactor on consideration of:
(1) upgraded licensee, State and local government emergency plans that substantially met the requirements of the final rule; (2) a review of the onsite plans by the NRC; (3) a comprehensive appraisal conducted by the NRC at the operating reactor site to verify the implementation of the licensee's plan; and (4) the evaluation of a joint exercise involving the licensee, state and local governmental organizations. These reviews and appraisals were conducted between 1980 and 1982. The onsite portions of such exercises were observed by the NRC while the offsite portions were observed by the Federal Emergency l
ManagementAgency(FEMA).
FEMA provided the NRC with its assessment of the exercises. Consideration of the emergency plans, this series of evaluations, and associated corrective actions resulting from the evaluations, constituted the means by which the NRC determined there was an adequate level of emergency preparedness at this and other nuclear power plants with operating licenses.
Thus, both the NRC and FEMA found that emergency planning at Pilgrim was adequate. The " interim approval" status mentioned in CURE's letter likely refers to FEMA's " interim findings" provided in instances where FEMA had-not completed its formal administrative review of offsite plans and preparedness under FEMA's regulation 44 CFR 350.
Since 1982, the Pilgrim plant has participated in emergency preparedness exercises where onsite and offsite response capabilities were demonstrated and evaluated by the NRC and FEMA. On four separate occasions, FEMA has reported to the NRC the adequacy of offsite response capabilities.
The NRC has requested that FEMA evaluate the offsite emergency planning and preparedness issues raised in the July 15, 1986 petition filed by Senator Golden, et al. (see below).
FEMA has reported that on December 22, 1986, the Commonwealth of Massachusetts' Secretary of Public Safety sent FEMA a ccpy of the Office of Public Safety report entitled, " Report to the Governor on Emer-gency Preparedness for an Accident at the Pilgrim Nuclear Power Station."
In addition, the Office of Public Safety recently requested FEMA, Region I, to
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l review a report entitled, " Evaluation of Offsite Emergency Preparedness in the I
Area Surrounding the Pilgrim Nuclear Power Station," prepared by the Impe11 Corporation for Boston Edison Company.
FEMA is also conducting a self-initiated review of the overall state of emergency preparedness. The results of these evaluations by FEMA will be provided to the NRC and will be reviewed by the staff.
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V.
Petition for Show Cause j
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1 On July 15, 1986, Massachusetts State Senator William B. Golden, et al., filed a petition requesting that the NRC order the Boston Edison Company to show cause why the Pilgrim plant should not remain closed or have its operating l
license suspended by NRC until the licensee demonstrates that the issues raised l
l in the petition have been resolved. The relief sought by the Petitioners was based on allegations of the following:
(1) numerous deficiencies in licensee management, (2) inadequacy of the existing radiological emergency response plan, and (3) inherent deficiencies in the plant's containment structure. The petition was acknowledged by a letter of August 12, 1986.
It is being treated under 10 CFR 2.206 of the Commission's regulations and is currently under re-l view. The NRC staff has forwarded the Petitioner's emergency response concerns 1
to FEMA for their review and evaluation.
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It is the NRC's practice to respond to petitions filed pursuant to 10 CFR 2.206 1
within a reasonable time. The time needed to adequately respond to a particular petition depends on a number of factors including the complexity of i
,. o the issues raised, the specificity of the information provided, w!,ecner addi-tional information is needed or analysis required, and whether responses to the i
petition from the licensee or others are appropriate.
In this case, the Staff decided that it would be more meaningful to formally respond to the petition I
after the licensee had an opportunity to address the issues raised by the petition and the NRC had an opportunity to review the licensee's actions and i
other necessary information. While the NRC continues to evaluate the I
licensee's program to correct previously identified problems, the NRC has proposed a meeting with Senator Golden in order to discuss the NRC's actions and to answer any questions the Petitioners may have. We expect such a meeting will be held in the near future.
CURE requests the NRC to force Boston Edison to undergo the scrutiny of a "public investigation." Although it is not entirely clear what is meant by a public investigation, we have stated how we intend to address the issues in j
this case. As stated in the attached April 1,1987 letter to Senator Golden, (1) the NRC will formally respond to the issues raised in the Senator's Peti-tion, and (2) the NRC will not agree to the restart of the plant until all of the identified problems have been addressed to the satisfaction of the NRC.
VI. Operating Problems at Nuclear Power Plants The NRC has ongoing programs to monitor the performance of nuclear power plants and to detect deteriorating performance such that timely corrective actions can be initiated.
For example, the NRC's Systematic Assessment of Licensee's l
Performance (SALP) program has successfully identified areas where licensees' l
activities needed improving and where additional regulatory oversight by the 1
1 NRC was warranted.
In the specific case of Pilgrim, it was the NRC',s SALP report which documented the staff's concerns with operations at the plant and diagnosed the problem relating to management involvement and oversight. Within a few months after this critical review, Boston Edison Company identified some problems that further supported the SALP findings; subsequently the licensee agreed to delay restart in order to institute more effective corrective measures and to allow the newly assigned managers time to address the issues in a deliberate manner.
l The Report to Congress on Abnormal Occurrences, NUREG-0090, is another ongoing.
program by which the NRC identifies significant events to Congress and the public. The requirement for abnormal occurrence reporting was established to especially highlight significant events from the standpoint of public health and safety. When an event is determined to meet the reporting criteria, addi-tional NRC resources and public attention are focused on the licensee's activi-I ties to ensure that corrective actions are completed in a timely manner to i
reduce the likelihood of a similar event. The number of abnormal occurrences for operating plants having Mark I containments does not appear to be signifi-cantly higher than that of other plants having different containment designs.
However, this does not minimize the importance that the NRC places on plants having this containment design. Recently, the NRC initiated the Performance i
Indicator Program which will contribute to the early detection'of declining performance of plant operations. The goal of all of these programs is to moni-tor licensees' performance in a proactive manner to enable timely corrective actions to prevent accidents and protect public health and safety.
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