DD-87-14, Informs That Time Provided within Which Commission May Act to Review Director'S Decision DD-87-14 Expired.Commission Declined Review.Decision Became Final Agency Action on 870915.Served on 870925

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Informs That Time Provided within Which Commission May Act to Review Director'S Decision DD-87-14 Expired.Commission Declined Review.Decision Became Final Agency Action on 870915.Served on 870925
ML20206C401
Person / Time
Site: Pilgrim
Issue date: 09/24/1987
From: Chilk S
NRC OFFICE OF THE SECRETARY (SECY)
To: Golden W
MASSACHUSETTS, COMMONWEALTH OF
Shared Package
ML20206C347 List:
References
FOIA-88-198 2.206, NUDOCS 8811160262
Download: ML20206C401 (5)


Text

M* '% UNITE D STATES

/p 4 NUCLEAR REGULATORY COMMISSION j wasw Noton. o c. ros55 94g(R

%..... September 24. 1987 gg Op r T,E 08 THE SECRttARY

[kfik The Honorable killiam 8. Golden SERVED SEP 2 51987 Massachusetts State Senate Boston, Massachusetts 02133 l Re: Docket No. 50-293(2.206) ,  ;

Dear Senator Golden:

i This is to inform you that the time provided by NRC regulations within which the Comission may act to review the Director's Decision (DD-87-14) in this docket has expired. The Comission has declined any review. Accordingly, the decision became final agency action on September 15, 1987.

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.edacted a pe r tial partic.pAtatn en.cri u <ron. Gaon t a 10.10 m t'oc nc L.or 9, "E.7 . The ni ci se comme.u d oi th .' c'oci arati c*n of Ur.u z .ie l vont dua t o a t eq.t a t'.; u t t J i n.i v r e d m a n , in Alnrt due t.o a t,tsick oper. ERV. and Ct r.cr a l Emecqc.nc y cme to a LOCA l et Jing to c cre uncovery c.om:-inod with lose f a t. f c t / 0 4u 1,Mi44 a t .

ce f t.r m.n c e t ho licenrett c;os ckly and ccerect ly recognized and classi fied accident ondittens. f'rctoctive .ctien recommendations were conae-vi,tive and time.ly.

taff auqc.cnt at'i on and 4.cility t.ctivation wAh timoly. Sd 'ric al wealnesses aro identified. 7hnse included peccedural p r ob 1 c tr.2 with i ni ti al

,ct i f icati ori raos cago forms; tievocal l's y p osi t i on s i n t h c' ERO d o r.ot b as e.-

tifficient depthi discrcps.ncies between dove Assecument modelst and pec-onacnd and contrel i n the T SC. Overall perfcrmance indictated that the ic0ncet woul d has e per f or.ned in a mar 7er t o protect the health and st4cty cf to pitbli c. in the event of an a:cident.

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pEC 18 '87 13 43 NRC KING OF PRUSSIR P02 -

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TELEPHONE REPORT Datei__Decembst 12.1Ts2 Times stin_e.e.

PSEllitYI P11erim Nucleac_20 wet _Statico nnenet*_.50:233 Brief subjects Pilgrim Restar t Hearing By Full Senate Committee Description of Occurrence A staffer from Senator Kennedy's Boston Office (Kathy Anderson) catted the Region I office at 9893 pm and reported that the Senate LABOR AND HUMAN RESOURCES COMMITTEE will hold a

! hearing on January 7,1988, in the Plymouth, Massachusette area on the publir health imnart nf the ne nnne ait restart nf the Pilgrim station.

Shw Andicated that the 4 issues the committee would be loobing into were:

The progress on improving evacuation plans What is going on at this time with respect to an NRC decision on restart <

. Wnw wtil rKmA's dindinge he addosened {

Why has the NRC not held adjudicatory hearings on the restart as requested

', Their list of proposed attendees was reported to includes

- A panel of local residents A panel of public interest groups i

A panel of representatives from departments of the j Commonwealth of Massachusetts l -

The NRC FEMA l Boston Fdison Company t

I She also indicated the desire to have working level staff '

meetings with NRC during the week after Christmas, in order to prepare for the hearings. She also asked who from the NRC usund be the most prnhable people to partacapate in the h e.t r i n g

! one the working 1kvwl mywting, and where would be a good place i

to hold the working meeting.

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pEC 10 ' O r' 13u43 NkU KINb UF PRUddlA P03 e

She indicated that a time and place for the hearing had not yet been determined, but would be announced at a later date.

9he was r e c en t a c t A,.

snd advased that she should contact the Office of Congresan "vi Affairs to arrange participation of the NRC in this event.

Not'ification received r- L a .. . ;e T. Doorflein ficy Fuhrmeister

a ARNEY FR ANI. o eMiwto% < mt t 4TM o4%?tL(f. M41%4(M(Slfts 1030 Losomos TM Bt is tw%<.

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Aci%c July 1,1986

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Mr. Lando Zech i Chaiman Nuclear Regulatcry Ccanission 1717 H Stree t, N. W.

Washington, MA 20555

Dear Mr. Zech:

I would appreciate it if you would send me detailed infernation regarding your records of radioactive emissions at the Pilgrim Nuclear Power Plant in Plymouth, Massachuse tts.

Please list all radioactive releases that are nomally allowed by your regulations, and also list separately those releases that exceeded the technical specifications fce the plant.

Thank you for your attention to this matter.

BARN E BF/ rvn eo: Representat.tve Edward Markey c  %

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AUG 2 0 986 Docket No. 50-293 Boston Edison Company M/C Nuclear ATTN: Mr. James Lydon Chlef Operating Officer 800 Boylston Street L Boston, Massachusetts 02199  :

Gentlemen:

Subject:

Management Meeting (50-293/86-30) Held on July 30, 1986 This letter transmits a report of the management meeting held in the Region !

Office, King of Prussia, Pennsylvania on July 30, 1986 to discuss Boston Edison Company (SECo) corrective action and improvement programs, including plant status, SALP issues, Mark I containment enhancements and other issues.

We believe the discussions were frank and constructive.

Thank you for your cooperation.

Sincerely, .

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%B.'Ister, a ry e

)roject nch No. 1 I

Enclosure:

Management Meeting No. 50-293/86-30 ,

cc w/ enc 1:

L. Oxsen, Vice President, Nuclear Operations A. E. Pedersen, Station Manager Paul Levy, Chairman, Department of Public Utilities Edward R. MacCormack, Senior Regulatory Affairs and Program Engineer Chairman, Board of Selectmen Plymouth Civil Defense Director l J. D. Keyes -

The Honorable E. J. Markey r Senator Edward P. Kirby The Honorable Peter V. Forman 4 Sharon Pollard '

Public Docurent Room (PDR)  :

Local Public Document Room (LPOR)

Nuclear Safety Information Center (NSIC) ,

i NRC Resident Inspector i CommonwealthofMassachusetts(2) i t

Boston Edison Company M/C Nuclear 2 l

bec w/ encl: i Region I Docket Room (with concurrences)

Management Assistant, DRMA (w/o encl) j Section Chief, ORP l W. Raymond, SRI, Vermont Yankee  !

T. Shedlosky, SRI, Millstone 1&2 i H. Eichenholz, $RI, Yankee P. Leech. LPM. NRR l

~PA0 (2) SALP Reports Only  :

Robert J. Bores, OR$5  !

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U. S. NUCLEAR REGULATORY COMMISSION ,

REGION I Meeting No. 50-293/86-30 Docket No. 50-293 1

License No. OPR-35 Licensee: Boston Edison Company M/C Nuclear '

' S00 Boylston Street I Boston, Massachusetts r Facility Name: Pilgrim Nuclear Power Statio'n Meeting At: USNRC, Region I, King of Prussia, PA Meeting Conducted: Jul 30 1986 Prepared by:- & d _.esta ' Y MN4 Date

-tvifpBride, Senior Resident Inspector Approved by: -

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Z/Strosnider, Chief,ProjectsSection ')a te l4, DRP

  • i Meeting Summary: A management meeting was held at NRC Region I on July 30, i 1986 to discuss plant status, SALP improvement :;',atus, overtime control, '

startup checklist, Mark I Containment enhancement and other issues. The i meeting lasted about two hours. Members of the news media attended the  !

meeting.

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DETAILS 1.0 Purpose The management conference was held at the request of NRC Region I. The licensee was asked to discuss recent program improvements and other topics of ,

interest at the plant. The licensee announced prior to the meeting, that the current outage would be extended until early 1987, 2.0 Meetina Summary Dr. T. Murley, NRC Region I Administrator, opened the meeting with a brief discussion of recent regulatory actions, including the Augmented Inspec-tion Team, Con'irmatory Action Letter.(CAL) 86-10, and the agreement to seek Region I approval prior to starting the plant. Mr. A. L. 0xsen, Vice .

President of Nuclear Operations, opened Boston Edison's presentation by discussing recent licensee program changes, including a management realign- ,

ment under an Executive Vice President and the decision to enter into re-fueling outage number seven. Mr. Oxsen indicated that Boston Edison will

omplete fire protection modifications required by 10 CFR 50, Appendix R during this outage. Boston Edison also plar.s to work on further improv r ments in management control processes and implement certain Mark I contain-ment enhancements during the outage.
a. Plant Status Current outage work was discussed, including inspections of the resi-dual heat removal (RHR) pump impeller wear rings and ongoing contain-ment leakage testing. No visual indications have been detected in  ;

the wear rings of the two RHR pumps that had been disassembled. The remaining two RHR pumps will be inspected in the near future. The licensee discussed bearing wear that had been detected in one of the pump motors and indicated that the pump impeller wear rings will be tested for hardness and dye perietrant checked. ,

The status of local leak rate testing (LLRT) was reviewed. Problems with the leakage test procedure for the feedwater check valves that l may have contributed to a falsely high as-found leakage rate were discussed. The licensee stated that the LLRT procedure would be modified prior to as-left testing. The licensee's plans for inte- ,

grated Teakage testing were also discussed,

b. SALP Improvement Status Improvements in management programs that relate to SALP-identified ,

weaknesses were discussed, including the work control process at the i.

station, the development of performance indicators, communication of problems within the licensee organization, and staff accountability.

The licensee stated that full-time planners would be assigned to  ;

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3 each management section head, to help track and prioritize section work. Periodic morning meetings between the Plant Manager, QA, and the section heads were also described.

The licensee's preparations for this year's emergency planning exercise were discussed. The licensee indicated that several practice drills were planned.

c. Overtime Control Ouring Startup The projected number of licensed operators available for the plant start up in 1987 were discussed. The licensee Indicated that five shifts will be manned and that an additional senio' licensed operator will be added to each watch. Boston Edison agreed to discuss planned overtime controls during the next plant startup in more detail during the next NRC management meeting,
d. Startup Check List The preparation of a detailed check itst of items that should be com-pleted prior to a plant startup was discussed. The licensee indicated that the startup will last several weeks and will contain hold points at particular power levels. Regional managesant indicated that the checklist and the startup itself will be reviewed in considerable detail and that Regional Administrative approval will be required prior to proceding past certain critical hold points to be identified later. The Regional Administrator indicated that he will not grant approval for a restart until aftar the NRC has reviewed the licensee's startup plan.
e. Herk I Containment Enhancements The licensee discussed possible improvements for the Mark I contain-ment at Pilgrim. The changes will probab?y be made to enhance such

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features as containment oxygen control, containment venting, and con-tainment spray. The need to consider these changes carefully and avoid inadvertently degrading othar aspects of containment was emphasized by regional management. The licensee agreed and indicated that the enhancements would receive a thorough review. The Itcensee also ind,1cated that they would be working closely with Vermont Yankee, another plant that is reviewing the Mark I containment design.

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f. Other Topics i Other discussion topics included maintenance planning, the maintenance backlog, once per cycle surveillance test scheduling, outage activi-ties, and security program problems.

The Itcensee indicated that efforts were underway to reduce the main-tenance backlog and implement a maintenance planning group. The li- l consee does not expect the planning group to be fully developed until  ;

the end of the current outage (although planning procedures should be  :

in place by this fall). The licensee stated that the number of out- l

  • standing maintenance requests has been decreasing, although the t number increased during the recent Boston Edison strike. The licensee i indicated that the number of open maintenance requests by itself was r I

not a good indicator of the plant physical condition. On another main-tenance item, the licensee indicated that the deficiency stickers for  ;

the control rod position indication system in the control room could i f

not be cleared without extensive under vessel work. The status of these repairs was questioned during a recent visit to the site ey an l NRC commissic Jr. l The licensee briefly discussed some of the recent surveillance test j scheduling problens, and iadicated that the testing frequency for ,

once-per-cycle tests would be clarified with NRR. The NRC regional I staff discussed tne importance of carefully reviewing the surveil-  !

lance frequency for each type of once-per-cycle test and noted that l certain safety-related electrical equipment, required to be cali- (

brated once-per-cycle, had recently been found out of calibration.  ;

Security staffing problems and the amount of inoperable security equipment (requiring compensatory measures) was discush Boston [

i Edison indicated that staffing levels for the contractor security  !

force would be increased and overtime closely monitored by Boston Edison management in the future. Boston Edison agreed to furnish i i

the Pilgrim Senior Resident Inspector with the expected completion >

date for engineering evaluations of the scope of security equipment improvements. Subsequently, 'he licensee indicated that the evalua- [

tions would be completed by August 18, 1944. l r

Boston Edison stated that a major decontamination effort would be made in the plant during the current refueling outage. The licensee expects to decontaminate areas with Safety-rehated equipment in the 3 j

reactor building quadrant rooms so siat these areas can be toured without protective clothing.

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5 3.0 Concluding Statements At the end of the meeting, Dr. Murley requested that Boston Edison be prepared to discuss the following issues during the next management meeting:

I -- Overtime control during the plant startup

-- The expected scope of startup testing

-- Containment leakage test results and fixes Mark I containment enhancements i

-- Updated outage schedule Dr. Murley also indicated that the NRC will need to review Boston Edison's i start up plans and hold points. .

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ATTACHMENT TO MEETING rep 0RT 50-293/86-30 MEETING ATTENDEES Boston Edison Company (BEco) i J. Lydon Chief Operating Officer E. Howard Vice President - Engineering & QA A. 0xsen Vice President - Nuclear Operations A. Pedersen Plant Manager i K. Roberts Ofrector of Outage Management t R. Swanson Nuclear Engineering Man'ager  ;

5. Hudson Operations Section Head  !

C. Gustin Manager, Public Information , [

t U. S. Nuclear Regulatory Commission  ;

T. Murie. Regional Administrator  :

R. Starostecki Director, Divisica of Reactor Projects

5. Eeneter Director, Divisicn of Reactor Safety  :

H. Kiste- Chief, Reactor Projects Branch #1 L L. Bettenhau en Chief, Operations Branch J. Dure Chief, Engineering Branch J. Strosnider Chief, Reactor Projects Section 18 M. Shanbaky Chief, Facilities Radiation Protection Section i M. McBride Senior Resident Inspector, Pilgrim G. Nejfelt Resident Inspector. Hatch t G. Smith Safeguards Specialist P. Leech Project Manager, NRR j i

Press J. Gehorgan Associated Press [

J. Impemba Boston Herald  :

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' f NUCLEAR REGULATORY COMMIS$lON s neoloN o eat Pant Av849e EHe0 0F PauS5tA. PEN 48VLVANIA toees e...*

APR 01 tM7 .

The Honorable William B. Golden Massachusetts State Senate -

Boston, Massachusetts 02133

Dear Mr. Golden:

This letter is in reply to your letter dated February 25, 1947, regarding our proposed Station. meeting to discuss t sluts relating to the Pilgrim ksclear Power

! recognize that considerable time has passed since you filed your Petttton on July 15, 1986, which requested that the Boston Edisc,n Company (SEco) be ordered to show cause why Pilgrim should not remain closed cr have its operating license suspended until SEco demonstrates that the issues raised by you have been resolved. While ! appreciate your concerns on this matter, I want to make it clear that this deity does not mean the NRC has prejudged your Petition or denied its contentions. Rather, the delay has resulted from the NRC staff's recognition that the plant has remained in a shutdown cendition since Apet),

1946, and, during this period, considerable changes have occurred and continue so occur in the substantive areas outilned in your Petition. As was indicate'd in Mr. James Taylor's letter to you, dated December 19, 1984, the NRC will formally respond to the issues raised in the Petition. Further, NRC wit) not agree to the restart of the plant until the issues which developed during its prolonged shutdown have been addressed to the satisfaction of the NRC.

In response tion to the specific questfons in your letter, the following clarifica-is provided.

First, our proposed meeting is not intended to substitute for the completion of agency action on your Petitlen. The purpose cf the meeting is to discuss NRC's actions regarding the P11orte plant, and answer que,stions you have, as we con-ttnue to evaluate the ' iconsee's program to correct prevlevsly identified problems. Several senter members of the Region I staff will attend the meet-ing,meeting.

the and they will be able to address the techatcal issues which arise during Second, we are willing to have the meeting open to all the co petitleners as well as any other interested party, including the Itcensee. However, for the sake of efficientf, we request that each group be represented by one er two preselected spokesperseas and that time 1tatts be pre-established for each group and/or topic. We have no objection to a transcript of the meeting, but we can discuss this matter further. .

Third, we do not intend to substitute SECo's Restart Readiness Report for an NRC response to the issues raised in your petitlen.

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2 APR 01 1967 Honorable William 6. Golden My staf f will be in touch with your office to arrange a meeting in the near future.

Sincerely.

' jf Thomas E. Murle, Regional Administrator cc: -

The Honorable Barbara A. Hildt '

The Honorable Frank M. Hynes Rachel Shimshak, Massachusetts Public Interest Research Group W1111am Abbott. Plymouth County Nuclear Information Committee Gati Reed, Fligrim Alliance bec: '

B. Ktrt P. Polk J. Wiggins p.McBride W. Klingler. IE J. Partlow. IE T. Martin O

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biph G. Sird y 15, 1987  :

sen.o, v.ce Mrsedent - Nvckar SEco 87- 078  ;

Mr. William T. Russell ,

Regional Administrator  :

Office of Inspection and Enforcement '

U. S. Nuclear Regulatory Coenission -

Region 1 631 Park Avenue King of Prussia License DPR-35 Docket 50-293 i

Dear Str:

In response to your Aprl) 7,1987 staff letter Boston Edison reviewed the current overall work plans for emergency prepar,edness. Based on that review, we request that you remove the date of August 12, 1987 for an Exercise at the Migria Nuclear Power Station from the tentative schedule.

In addition, the Massachusetts Civil Defense 01 rector, R. Boulay, has informed Mr. E. Thomas, Chief of Natural and Technological Hazards Division Region 1, i Federal Emergency Management Agcncy, that he is not certain that his organization can support an exercise on August 12, 1987. (see enclosure) i I will contact you with preferred Exercise dates in the near future. l i

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R. G. Bird -

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i U.S. Nuclear Regulatory Commission '

l Region !

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King of Prussia, PA 19406  :

i l Peter M. Agnes. Jr. l

! Assistant Secretary of Public Safety  :

Commonwealth of Massachusetts  !

l Executive Office of Public Safety l

One Ashburton Place
Roca 2133 L Doston, Massachusetts 02108 l

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l DOSTON EDISON COMPANY i

Page Two 1

cc: Robert Boulay, Director  !

Massachusetts Civil Defense Agency and Office . -

of toergency Preparedness 400 Morcester Road l P.O. Sox 1496 '

Fraatngham, Massachusetts 01701-0317 i Thomas P. Rodger, 01 rector  ;

Area Two Massachusetts Civil Defense Agency P. O. Box 54 .

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Bridgewater, Massachusetts 02324-0054 9

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1 hope that this letter clariftes the poettion of this egency regarding its participetten in e graded esereien for Pilgrim Station. Please do not hesitate to contact se if you have any questione regarding this setter.

Since

,t eier ( Voie Director cet Assistent Seeretary Peter W. Agnes, Jr.

Deputy Director John L. Levering, NCDA/0RP Mr. Cert Odetin, loaten Edtaun Company Mr. Rcger Silva, testen Edison Company Chief Executives of P11gris EP2 and Meet Cossunities Ares !! Director Thomse P. Rodger, MCDA/ORP i

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.omwso ou E ne<wtne Of f<es 800 Boyiston Street Boston, Mast 4<husetts 02199 Ralph G. Sird Sen.or v<e Presdent - Nuc'est BECo 87-090 May 30, 1987 Millias T. Russell Regional Administrator U. S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia. Pennsylvanta 19406 License DPR-35 Docket 50-293 Report of Defect or Noncompliance As Required By 10CFR Part 21. Loose and/or Missing Bolts ofLHydraulle Control Unit (HQJ) Structural Framti

Dear Sir:

Pursuant to the requirements of 10CFR 21.21(b)(2), this letter provides 1

written nottf tcation of a condition at Pilgrim Station that could constitute "A Substantial Safety Hazard" within the context of 10CFR 21.3 (Definitions).

Mr. L. Dorflein of the NRC Region I was notified by telephone on 5/29/87 following completion of our evaluation on 5/27/47.

The attachment describes the reportable condition of loose and/or missing bolts on Hydraulic Control Unit Structural Frames.

Attachment cc: See next page C h ,(

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r Attach eat He have recently identified deficiencies involving loose and/or tissing bolts in the Hydraulle Control Unit (HCU) support frames of the Control Rod Drive (CRD) Gystem at the Pilgrim Nuclear Power Station. The deficiencies could impair the ability of the support frames to withstand a Safe Shutdown Earthquake (SSE). 31 of 145 Mydraulic Control Units were affected. The Hydraulic Control Units were installed by Reactor Controls Inc, under contract to Bechtel Power Corp. to a specification written by the Gen,ral Electric Company.

Whether these deficiencies occurred during initial installation, during maintenance and overhaul, or during operation (i.e. vibration) could not be conclusively established. He have been informed that similar deficiencies were found at the Perry Plant and were attributed to original installation.

Accordingly, for the purposes of Part 21 reportability, we are conservatively assuming the deficiencies occurred during initial installation and are filing this report.

He began our investigation into the HCU support frame problem following receipt of a General Electric Company letter, G-HK-6-326. The letter informed Boiling Hater Reactor (BHR) Owners that missing or loose hold down bolts on the HCU support frames had been identified at a BHR/6. He completed our investigation May 27, 1987 and concluded that a Part 21 rotification would be prudent.

The HCU support frame design at Pilgrim Station .s similar to that found at other BHR's. BECo investigations determined that the HCU frame configuration at PNPS is not laterally supported near the location assumed in G.E.'s generic test configuration. The G.E. test configuration did not therefore envelope the Pilgrim site specific configuration and the safety assessment supported by the G.E. test did not apply. General Electric's letter notifying the BHR owners of the existence of this problem states:

"Neither the missing or loose hold down bolts or the erroneous BJM attachment observed at the BHR/6 constituted a safety problem during a faulted event nor would they at any BHR."

This statement could potentially mislead utilities into not recognizing the potential impact of this concetn on their facilities or influence the sense of utgency with which utilities check for the existence of this problem at their facility.

The deficiencies found at Pilgrim Station have been documented in a Failure and Halfunction Report. A prompt 10CFR50.72 notification has been made and a 10CFR50.73 sritten sebmittal is being issued under separate cover. Because the specific root cause could not be established, corrective actions are being implemented to address various potential root causes.

For the purpose of this report, assuming the cause of the loose and/or missing fasteners was initial installation, our corrective action includes restoring the HCU's to original design prior to declaring the system operable.

Additional corrective action to inspect the bolts under a preventive maintenance program is being taken to address the other potential causes.

9 80STON EDISON COMPANY .

Mr. William T. Russell  !

Regional Administrator

}

Page Two ,

cc: Director (3 copies)

Nuclear Reactor Regulation U. S. Nuclear Regulatory Cosmission ,.

Nashington, D. C. 20555 1 Mr. R. H. Nessman, Project Manager 01 vision of Reactor Projects '

Office of Nuclear Reactor Regula^1ons '

U. S. Nuclear Regulatory Commission I 7920 Norfolk Avenue  !

Bethesda, MD 20184 Senior NRC Resident Inspector I Pilgrim Nuclear Power Station

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OGC CA CRVan Niel RWStarostecki The Honorable Gerry E. Studds EPB r/f United States House of Representatives RBellamy, RI Washington, DC 20515 JWiggins, RI CDeliso NRR

Dear Congressman Studds:

0Matthews, NRR I am responding to your March 6, 1987 letter requesting that the Nucler.r 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 The CURE letter of February 6, the NRC staff and are enclosed.

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 de not believe f* 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 l by the licensee.

Commissioner Asselstine disapproved this response.

Sincerely.

dd:

Thomas M. Roberts Acting Chairman

Enclosure:

Response to Issues Originated: NRR: Van Niel

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ENCLOSURE I. Proposed Rule Related to Energency Planning The Comission, after holding a public meeting, voted to pubitsh 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 cooperation by state and/or local governments in emergency planning. The amendment under consideration would by no means exclude state and local participation in emergency planning.

The proposed rule would be directed only at those cases where state and/or local governments refuse to participate in such planning. Utility Itcensees 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 be;n granted, would not guarantee an operating Itcense to any particular plant or plants. The Comission can grant an operating Itcense only if it finds

reasonable assurance that'the public health and safety will be adequately pro-tected, a

!!. Proposed Rule Related to Radioactive Emissions

]

We assume that the reference to the proposed rule change to raise the tolerable I levels of radioactlye eelssions, from nuclear power plants is directed to the proposed revision to the Comission's regulations 10 CFR Part 20 as published in the Federal Reelster on January 9,1986 (Vol. 51, No. 6, page 1092). The i

notice in the Federal Registe* provided interested members of the public the

, opportunity to coment on the proposed rule. Your coments and those relating I

)

3 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 j were no detailed evacuation planning requirements included in the NRC's emergency planning regulations. Pilgrim did comply with NRC emergency planning requirements from 1972, when the plant was Itcensed, until 1980, when l new requirements were imposed. Also, as explained below, emergency planning  ;

for Pfigrim 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 tes: with Pilgrim, the NRC based its post-1980 reasonable assurance i findings for each operating reactor on consideration oft (1) upgraded ;

Itcensee, State and local government emergency plans that substantially met the j requirements of the final rulet (2) a review of the onsite plans by the NRC; l (3) a comprehensive appraisal conducted by the NRC at the operating reactor I

j sitetoverifytheimplementationo'thelicensee'splan;and(4)the

! evaluation of a joint esercise involving the Itcensee, state and local 4

governmental organizations. These reviews and appraisals were conducted (

between 1980 and 19M. The onsite portions of such exercises were observed by the NRC while the offsite portions were observed by the Federal Emergency i

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I Management Agency (FEM). FEM 4 pg ..**d the NRC with its assessment of the i exercises. Consideration of N emergency plan:, this series of evaluations, f and associated corrective actions resulting from the ovaluations constituted I i

the means by which the NRC determined there was an adequate level of emergency L "r  :

preparedness at this and other nuclear power plants with operating Itcenses.

l Thus, both the NRC and FEM found that emergency planning at Pilgrim was i

adequate. The "interim approval" status mentioned in CURE's letter likely i refers to FEM's ' interim findings

  • provided in instances where FEM had not j completed its formal administrative review of offsite plans and preparedness 1

j under FEM's regulation 44 CFR 350. $1nce 1982, the Pilgrim plant has t j participated in emergency preparedness exercises where onsite and offsite l

] response capabilities were demonstrated and evaluated by the NRC and FEM. On l

four separate occasions. FEM has reported to the NRC the adequacy of (

! offsite response capabilities.  !

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l The NRC has requested that TEM evaluate the offsite emergency planning and I i preparedness issues raised in the July 15, 1986 petition filed by senator

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Golden, et al. (see below). FEM has reported that on December 22, 1986, the l l

Comonwealth of Massachusetts' Secretary of Public Safety sent FEM a copy of i c

the Office of Pubite Safety report entitled, "Report to the Governor on Emer-f gency Preparedness for an Accident at the Pilgrim Nuclear Power Station." In  !

! e addition, the Office of Public Safety recently requested FFM, Region I, to I

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6 the issues raised, the specificity of the information provided, whether addf-tional infomation is meded or aftalysis required, and whether responses to the petition from t. 'd . or others are appropriate. In this case, the Staff decided that 11 -

core meaningful to fonnally respond to tne petition after the lico un opportunity to address the issues raised by the petition and the NRC had an opportunity to review the licensee's actions and other necessary information. While the NRC continues to evaluate the licensee's program to correct previously identified problems, the NRC has pro,.csed a meeting with Senater Golden in order to discuss the NRC's actions an3 to answur any questions the Petitioners may have. We expect such a meeting will be held in the near future.

CUP.E 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 this case. As stated in the attached April 1, 1987 letter to Senator Golden, (1) the NRC will formally respond to the ismes raised in the Ser.ator's Peti-tion, and (?) the NRC will not agrey to the restart of the plant until all of the identifies.1 probleras have been addressed to the satisfaction of the NRC.

VI. Operating Probleans at Huclear 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 Atsessment of 1.icensee's l Perfonnance (sal.P) program has successfully identified areas where licensees'

7-4 activities needed improving and where additional regulatory oversight by the 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 tri a deliberate manner.

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 reparting was established to especially highlight significant events from the str.ndpoint of public health and safety. When an event is determined to meet the reporting critena, addi-tional NRC resources and public attention are focused on the licensee's activi-ties to ensure that ccrrective actions are completed in a tinely manner to reduce the likelihood of a similar event. The number of abnonnal accurrences 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 i

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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Comonwealth of Massachusetts i .

Civil De'ense Agency and Office ~

of Emergency Preparedness ATTN: Mr. Robert J. Boulay Directer P.O. Box 1496 400 Worcester Road Framinghw, Massachusetts 01701-0317

Dear Mr. Boulay:

In ;four letter of July 24, 1987, you requested we acknowledge that you have determined the plume exposure emergency planning zone (EPZ) should be reconfigured for the Pilgrim Nuclear Power Station to include the towns of Carver and Marshfield in their entirety. We subsequently understand that this reconfiguration has now been deferred to enable priority attention be given to your ongoing efforts with the current EPZ connunities, the Boston Edison Company and FEMA in improving emergency planning and preparedness within the current EPZ. We enceurage these efforts to improve errergency preparedness.

Sincerely.

OY William T. Russell Regional Administrator CC:

E. Thorr.as FEMA I R. Bird, BeCo bec:

T. Murley, NRR -

R. Starostecki, NRR .

F. Miraglia RR

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Enftch 6tatsg Senate L Wa4WINGTON. 6C te610 l) l' December 18, 1987 t' hr. Lando W. Zech, Jr. j Chairman i>

United States Nuclear Rngulatory Comission i 1717 W 8treet, N.W.

Washington, D.C. 20865

Dear Mr. Zech:

I As Chairman o.f the Sanutw Labor and Human Resources Cormnittee,

  • I will be holding a hearing in Plymouth, Massachusettu ou the evening of  !

January 7, 1988 ennenrntnt the proposed restart of the Pilgrim Nuclear power station and its potential impact on the puolic nealth. 81 .'

1 The Committee on Labor and Muman Resources has oversight r=6ponsih111ty for publig health issues. I believe the upcoming decision on the Pilgrim restart could possibly nave oramatic l imp 1.ications soncerning the health of my constituente in Massachusetts.  :

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As Chairman of the Nuclear Regulatory Comission, you are t uniquely qualified to speak for the Commission concerning the , ,

docioion-making process on the restart question. Therefore, your '

tvetimony will be an euwwntial component of the hearing. .

In the event you are unable to participate on January 7th, I please designate the appropriate NRC reprenantative(s) for an appearance Before the Cor:ur.iLL=e that Avoning. Specif$cally, the Committee is interested in hearing testimony from the NRC with regard to the rules, regulations, standards and criteria  ;

it would apply during consideration of a Pilgrim restart request,  ;

Wemhers of my staff will be available to meet with NRC officialw prior to the hearing to provian the Commivulun with

.utditional deta* 1n. Since tne nearing 1. woheduled for early '

January, I would apprwciate your timely veeponse tc this rottunut.

Thank you for your assistance, and I look forward to seeing you in plymouth.

Edward W. Kennedy

! c t e on L bo and Human Resources

_ _ ,, .,,. , . _ . . . . . ..._ ....s h s

October 20, 1987 NOTE TO: Dick Wessman, NRR Bill Paton, OGC FROM: Mike Blume, OGC SUBilECT: MASSPIRG v. NRC (PILGRIM 1ST CIRCUIT CASE)

Enclosed is a first cut of what is known as a "Certified Index of the Record," to be submitted to the Court of Appeals on November 10, 1987. The "Record" in this case is what was placed before the Agency by the petitione s, and whatever else the Agency relied upon. The attached list

-- the "Certified Index" -- is a complete listing of all documents enclosed with or cited by the Petition and the Director's Decision. The advantage of the certified index is that we don't have to burden the Court with unnecessary documents. Unfortunately, though, the Comission Secretary, who will certify to the Court that the index represents the record, must have all of the documents that are listed. Accordingly, I'm requestir.g that you go over the list, and provide to me ASAP, copies of all of the listed documents that we have. Please note for me which ones we do not have. To the extent we don't have them, it's probably safe to assume that we didn't consider them or rely upon them, and thus they'll be deleted from the list. Also, please add to the list (and provide to me) any documents that we considered or relied upon, but which were not cited.

Many thanks for your continuing assistancel

Enclosure:

As stated l

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D cument Name:

CERT. RECORD Requestor's 10:

WOHL Author's Name:

Lessler Document Coninents:

Pilgrim Nuclear Station - Certified Index Destination Name:

WOHL Distribution Name:

NRCOCA LESSLER 0032 Addressee:

Marilyn Wohl, POI-3, Rm 116, x27831 ate Seriti 10/20/87 me Sent: '

13:57 .

Message:

Please deliver to Dick Wessman from Mike Blume, OGC (x41493).

Thanks, Linda Lessler l

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F UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BOSTON ELECTRIC COMPANY (Pilgrim i Nuclear Power Station)

Docket No. 50-?93 (2.?O6 Request)

CERTIFIED INDEX Date Docketed Office of the Date of Title or Description Secretary Document of Document 11/9/71 Task Force Review, Bypass Effects in GE Pressure Suppression Containment ,

12/1/71 Task Force Review, Bypass Effects in GE Pressure Suppression Containment 9/20/72 AEC internal report by Stephen H.

Hanauer, raising seven concerns centering on the viability of the pressure-suppression containment concept 9/25/72 Memo from Joseph M. Hendrie to John F.

O' Leary, Re: acceptance of pressure-suppression containment concept l

1/15/73 Memo from S. H. Hanauer to E. J. Bloch, i

Re: Bypass Paths on BWR Pressure Suppression Containment t l

l 1975 Manual of Protective Action Guides and l

Protective Actions for Nuclear ,

Accidents, EPA-520/1-75-001, EPA l

2/75 Letter from NRC to all utilities owning RWR facilities with Mark I design containments 4/75 Letter from NRC to all utilities owning BWR facilities with Mark I design containments

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, Docket No. 50-293 (2.206) .

Date Docketed Office of the Date of Title Secretary Occument of Document 1976 ANSI Standard 18 7-1976, Section 5.2.6, Equipreent Control 1977 Study published by Massachusetts Public Interest Research Group entitled "Nuclear 'b ?cuation Planning:

Blueprir.'l 'or Chaos" 6/20/78 Memo from Dr. Hanauer to Dr. Hendrie, ouoting from NUREG-0474 7/78 NUREG-0474, "A Technica". Update on Pressure Suppression Type Containments in Use in U.S. Light Water Reactor Nuclear Power Plants" I?/78 Union of Concerned Scientists "An Analysis of Chairman Hendrie's Response to Senator Hart's Letter of ilune 15, 1978" 1980 IE Bulletin 80-10. "Contamination of Nonradioactive System and Resulting Potential for Unmonitored/ Uncontrolled Release to the Environment" 7/80 NUREG-0661, "Mark I Containtnent long Term Program Safety Evaluation Report" 8/19/80 45 Fed. Reg 55402 11/80 NUREG-0654/ FEMA-REP-1, Rev.1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants" 1981 SALP Report 7/20/81 Response of Roston Edison Co. to Corrrnonwealth of Massachusetts' First Set of Interrogatories on Emergency Planning 19P2 Cover letter from Richard C. Young.

Director, Office of Inspection and Enforcement, NRC to BEco, with NRC 50-293/EA 81-63, Order Modifying License Effective imediately

Docket No. 50-293 (2.206) .

Date Docketed l Office of the Date of Title  !

Secretary Document of Document 1982 SALP Report 1982 Civil Penalty and Order re: Modifying the Pilgrim License 8/82 Coments of Attorney General Francis X, Bellotti Relative to Off-Site Emergency Planning for the Pilgrim Nuclear Power Station, submitted to FEMA 9/20/82 Report issued by Federal Emergency Management Agency, Region I entitled:

"Joint State and Local Radiological Emergency Response Capabilities for the Pilgrim Power Station, Plymouth, Massachusetts" 10/27/82 Plant Unique Analysis Report (PUAR) of the Suppression Chamber - Mark i Containment Long Term (TR-5310-1) 1963 Updated study published by Massachusetts Public interest Research Group entitled "Blueprint for Chaos II: Pilgrim Disaster Plans Still a Disaster" 1/83 Report on the Pilgrim Nuclear Power Station Siren Test, FEMA 1983 MASSPIRG study of two hospital (Jordan Hospital, Plymouth, and Morton Hospital, Taunton) 10/26/83 Plant Unique Analysis Report (PUAR) of I the Torus Attached Piping - Mark i Containment Long Tenn Program (TR-5310-2) 1984 SALP Report 50-293/84-34 1985 SALP Report 1985 NRC inspection Report 50-293/85-13 1985 NRC Inspection Report 50-293/85-22

t Docket No. 50-293 (2.206) 4-Date Docketed Office of the Date of Title Secretary Document of Document 1985 Notice of Violation (Inspection Report 50-293/85-32, cover letter fraa Thomas Martin, Director, Divit, ion of Radiation Safety and Safeauards, and Appendix A, Notice of Violation) 1985 LER No. 85-26 1985 Inspection number 85-24 (revealed security level III violation) 1/25/85 Quality Assurance Surveillance, 85-1.2-1 1/30/85 NRC staff issued Safety Evaluation Report 4/85 Report by Stone & Webster (predicted Pilgrim facility's waste would contain about 1024 curies that year) 7/85 NUREG-0956, "Reassessment of the Technical Bases for Estimating Source Tenns" 7/12/85 Nuclear Operations Manager (NOM)

Memorandum, M85-137, Control and Verification of Operating Actions 8/8/85 50 Fed. Reg. 32138, "Policy Statement on Severe Reactor Accidents Regarding Future Designs and Existing Plants" 10/85 Letter from FEMA to MCOA, outlining FEMA concerns 1/86 Letter from FEMA to MCOA, outlining FEMA concerns 1/86 Steven Sholly and Dr. Gordon Thompson, "The Source Term Debate," Union of Concerned Scientists 2/18/86 SALP Report No. 50-293/85-99 2/21/86 IE Information Notice No. 86-13

4/2/86 Special NRC Inspection Report l 50-293/86-06 i

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Docket No. 50-293 (2.206)

  • Date Docketed Office of the Date of Title g Secreta ry Document of Document 4/12/86 Confinnatory Action Letter (CAL) 86-10, issued by Region I Administrator 5/21/86 Article, Boston Globe, re: NRC Comnissioners ordering the Pilgrim facility to remain shut down temporarily because of safety problems 5/22/86 Statement of James Asselstine before the Subconittee on Enem Conservation and PWer

$/23/85 Statement of NRC Comissioners :t

i. caring before U.S. House Subcomittee on Energy Conservation and Power, Boston Globe 5/28/86 Telephone Interview with James Asselstine, Boston Globe 6/86 NUREG/CR-4594, "Estimated Safety Significance of Generic Issue 6i" 6/6/86 MCDA response to FEMA's October,1985 letter 6/9/86 Statement of Harold Denton, Director, Nuclear Reactor Regulation, quoted in inside NRC, Vol. 8, No. 12 6/18/86 Article, Boston Globe, (example of BEco's failure to insure proper surveillance) 6/18/86 Testimony of Edward A. Thomas Division l Chief, Natural and Technological Hazards FEMA, before Massachusetts l State legislators l 6/18/86 Statement of Mr. Lubering, Deputy Director of the Massachusetts Civil l Defense Agency, before Massachusetts i legislators

, 6/21/86 Joseph M. Hendrie. Letter to the i editor, New York Times, concerning review issues in the GE containments l

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Docket No. 50-293 (2.206) -

L Date Docketed Office of the Date of Title Secreta ry Document of Document 6/24/86 Article, Bee. ton Globe 6/26/86 Hassachusetts Department of Public Utilities report 6/27/86 Excerpts of Massachusetts Department of Public Utilities Report, Bosten Globe 6/28/86 Statements by FEMA and MCDA officials, Patriot Ledoer 7/9/86 Statement of James Asselstine, Patriot

__ Ledger 7/15/86 Petition for Show Cause Concerning Pilgrim I Nuclear Power Station 8/27/86 Letter from Murley, Region I, NRC to

.1 Lydon, BEco re: CAL 86-10 12/86 Report issued by the Office of Public Safety of the Commonwealth of Massachusetts entitled "Report to the Governor on Emergency Preparedness for an Accident at the Pilgrim Nuclear Power Station" 12/19/86 Letter f rom James M. Taylor Director, Office of Inspection and Enforcement to Senator Golden 1/87 Report prepared by Impell Corporation for BECo entitled "Evaluation of Offsite Emargency Preparedness in Area Surrounding the Pilgrim Nuclear Power Station" 2/20/87 Letter from Thomas Murley, Regional Administrator, NRC Region I to Senator Golden re: Delay of Meeting with Petitioners 3/31/87 Memorandum from FEMA to NRC re: FEMA's conduct of a self-initiated review of the overall state of emergency preparedness at Pilgrim Station

, Docket No. 50-293 (2.206) -

Date Docketed Office of the Date of Title Secretary Occument of Document 4/1/87 Letter fmm Thomas E. Murley, Regional Administrator, NRC Region I to Senator Golden re: Meeting between NRC and Petitioners 4/29/87 Memorandum from the NRC to FEMA, with attached copy of March 1987 report by the Town of Plymouth Nuclear Committee entitled "Report to the Selectmen on the Plymouth Radiological Emergency Response Plan" 4/30/87 Letter from S. Varga NRC to R. Bird, 8Eco re: Request that licensee provide details of modifications and procedural changes S/?6/87 Article, Boston Globe, re: pressure suppression systems at Chernobyl and Pilgrim 6/4/87 Reports prepared by BEco re: Evacuation Time Estimates and Reach Population Sheltering, Mobility Impaired, and Special Facilities 6/12/87 Report by BEco re: A Northern Reception Center 6/17/87 Final SALP Report No. 86-94 (initially issued 4/8/87) 7/29/87 FEMA Analysis of the issues raised in the subject petition entitled "Analysis of Emergency Preparedness issues at Pilgrim Nuclear Power Station Raised in a Petition to the NRC Dated July 15,1986" (Attachment A to Director's Decision) 7/30/87 Report submitted by BEco entitled "Pilgrim Nuclear Power Station Restart Plan" 8/87 NUREG-1251, "Inclications of the Accident at Chernobyl for Safety Regulation of Comercial Nuclear Power Plants in the United States"

, Docket No. 50-293 (2.206) Date Docketed-g Office of the Date of Title Secreta ry Document of Document 8/4/87 Report from FEMA entitled "Self-Initiated Review and Interim Finding for the Pilgrim Nuclear Power Station" 8/5/87 Report submitted by MASSPIRG entitled "Health Surveillance of the Pilgrim Area" as addendum to the Petition 8/6/87 Letter from FEMA to the NRC forwarding 8/4/87 FEMA report entitled "Self-Initiated Review and Interim Finding for the Pilgrim Nuclear Power Station, Plymouth, MA" 8/21/87 Interim Director's Decision 87-14 i Undated Rrief description of the Pilgrim Mark I Containment Design Undated Enclosure A to NUREG-0474, "Sunnary of NRC Staff Actions Related to the Technical Issues identified in Or, Hanauer's Memorandum of September 20, 1972 Unda ted Pilgrim Station Reoulatory Perfonnance History Undated NUREG-0713 and 0714 "Occupational Radiation Exposure at Connercial Nuclear Power Reactors" Unda ted Updated survey by the Special Legislative Comission on Low Level Radioactive Waste Undated Deficiency Report (OR) No. 1384 i Undated St Fed Reg. 29728 Undated NRC's Standard Review Plan Urida ted WASH 1400 (Reactor Safety Study)

Undated The Reactor Risk Reference Document -

Oraft (NUREG-1150)

Undated NUREG-1250, "Report on the Accident at the Chernobyl Nuclear Power Station" l

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